Can the CRA Still Audit You After a Voluntary Disclosure in Canada?

You have found a mistake in your past tax filings and you are thinking about coming forward through the Voluntary Disclosures Program (VDP). A natural worry is whether telling the CRA invites an audit of everything else.

This article explains what an accepted application protects you from, what it does not, and what to keep in mind afterward. It covers federal rules only and applies to applications received on or after October 1, 2025, under the CRA circular IC00-1R7.

This article covers Canadian federal tax law, which applies in every province.

What the VDP does and does not give you

If the CRA accepts your application, it may give you penalty and interest relief, and it will not refer the disclosed matter for criminal prosecution. That is real protection, but it is narrower than many people assume.

The relief is on penalties and interest only. The CRA says the VDP provides relief on penalties and interest, not on the tax itself, so the tax owing must be paid.

• Unprompted applications normally get 100% relief of applicable penalties and 75% relief of applicable interest.
• Prompted applications normally get 25% relief of applicable interest and up to 100% relief of applicable penalties.

The CRA can still audit what you disclosed

The CRA reserves the right to audit any information in a VDP application, whether or not relief is granted. Being accepted does not close the file to review.

If the CRA finds fraud or misrepresentation, an assessment may cover any year. That is why accuracy matters as much as coming forward. An incomplete or careless disclosure can leave you worse off than you expected.

The CRA may also deny an application as incomplete if requested information or documents are not provided within a reasonable timeframe, or for insufficient information or other non-compliance.

Protection covers only the information disclosed

Eligible applicants are protected from prosecution for the disclosed information, and gross negligence penalties do not apply to that information. The key words are eligible and disclosed.

The protection applies only to a valid, eligible application and only to what you actually disclosed. Anything you left out is not covered. A disclosure is also not voluntary if an audit or investigation has already started against you or a related taxpayer for the same information, including investigations by law enforcement, securities commissions or other regulators.

Relief dates, decision letters and staying compliant

After receiving your application, the CRA sends an acknowledgement letter with the effective date of disclosure (EDD). Relief runs up to the EDD if you qualify. Anything that happens after that date is outside the relief.

The decision letter states whether your application is unprompted or prompted, the relief level and the eligible tax years. If relief is denied, it gives the reason.

You are expected to stay compliant afterward. If you later want to apply again, the CRA may consider it if the circumstances were beyond your control or if it concerns a different matter.

What to do next

Treat the application as something that may be checked line by line. A few habits help.

• Make the disclosure complete and accurate, with all supporting documents, because the VDP considers fully completed applications only.
• Keep your records. Supporting documents generally cover the most recent six years, or ten years for assets or income located outside Canada.
• Include payment of the estimated tax owing or a request for a payment arrangement, noting approval of an arrangement is not guaranteed.
• Keep filing and paying on time after you apply.
• If the CRA contacts you about an audit later, respond on time, keep copies of everything and consider getting advice from a lawyer or accountant.

If you disagree with a VDP decision, you can ask in writing for a second administrative review, and the CRA asks you to do this before applying for judicial review. There is no right of objection to a VDP decision. Because the right approach depends on your facts, a lawyer or accountant can help you confirm your position before you file.

Frequently asked questions