How Many Years Back Does a CRA Voluntary Disclosure Go in Canada?

If you have missed filing or reporting for many years, you may wonder how far back you have to go to fix things. Going back to the beginning can feel overwhelming, and it is natural to ask whether the CRA expects every year.

The answer involves two different ideas: how many years of records the application must include, and how many years the CRA can give relief for. They are not the same number, so it helps to keep them apart.

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

Two different look-back ideas

The first is the document period: the years you must support with returns, forms and records in your application. The second is the relief window: how far back the CRA can cancel penalties and interest. A long history of non-compliance can touch both.

Whichever years apply, the VDP covers penalties and interest only. The tax itself must still be paid.

Income tax: six years, or ten for foreign assets

Income tax applications must include supporting documents for the affected years. Records generally cover the most recent six years, or ten years for assets or income located outside Canada. Years with no errors or omissions need not be included.

The application must also involve information at least one year past the filing due date. The application package is the signed Form RC199, all returns, forms and schedules needed to correct the non-compliance, and payment or a payment arrangement request.

Where books and records do not exist, the applicant should make reasonable estimates. The CRA may request additional records, and years beyond the required periods are at the CRA's discretion.

GST/HST: the most recent four years

GST/HST Memorandum 16-5-1 applies to applications received on or after October 1, 2025, and its scope includes GST/HST, excise and several other taxes. Earlier applications fall under Memorandum 16-5.

For these taxes, supporting documents are required for the most recent four years. Clean periods in that window need not be included, and the CRA may ask for older periods at its discretion.

The ten-year limit on relief

The CRA's legal basis for cancelling penalties and interest is subsection 220(3.1) of the Income Tax Act. It lets the Minister waive or cancel all or part of any penalty or interest, and the request must be made on or before the day ten calendar years after the end of the taxation year.

Relief follows that limitation period, so older years may get reduced or no relief. The CRA's current VDP guidance also says relief covers information going back up to ten years from the disclosure date, and older information may get reduced relief.

In practice, a very old year may still need to be corrected and the tax paid, even if penalty and interest relief for that year is reduced or unavailable. Because the document period and the relief window are different measures, confirm the current figures before you file.

Once the CRA acknowledges your application, it sends a letter with the effective date of disclosure. Relief runs up to that date if you qualify.

What to do next

Make a year-by-year list of what was missed, so you can see which years are clean, which are wrong, and which fall outside the usual windows. A lawyer or accountant can help decide how far back to go for your situation.

• List each tax and year with an error, omission or unfiled return.
• Mark any years that involve assets or income outside Canada.
• Separate income tax years from GST/HST periods.
• Note any year older than ten calendar years.
• Check that no audit or investigation has started on the same information.
• Get advice before filing, because only fully completed applications are considered.

Frequently asked questions