How does voluntary disclosure work for missed HST returns?

CRA’s Voluntary Disclosures Program (Information Circular IC00-1R7, in effect since October 1, 2025) lets you file overdue HST returns and pay the tax to obtain penalty relief and partial interest relief, provided your application is voluntary, complete, includes at least one filing more than one year overdue, involves a penalty, and includes payment of the estimated tax with the application.

Two application types since October 1, 2025. An unprompted application — filed before CRA contacts you about the matter — normally receives general relief: 100% relief of the applicable penalties and 75% relief of the applicable interest. A prompted application — filed after CRA has contacted you — normally receives partial relief: up to 100% relief of the applicable penalties and 25% relief of the applicable interest. Application is Form RC199 plus a package of amended or original returns.

Example: an Ontario contractor stopped filing HST after their bookkeeper left in 2022. Three years of missing GST34s. They come forward on their own before any CRA contact, submit RC199 with all twelve missed quarters (Q1 2023 through Q4 2025), a spreadsheet reconstructing net tax owing of $78,000, and a payment for that amount. Because they came forward before any CRA contact, this is an unprompted application: s. 280.1 late-filing penalties (potentially over $10,000) are waived and s. 280 interest is reduced by 75%. Files are otherwise treated as filed on time.

Do not file if CRA has already contacted you about the matter. Once CRA opens an audit or enforcement action on the specific period, the disclosure is no longer voluntary.

Note: A named-party disclosure identifies you at intake. A no-name disclosure (used to test eligibility) is no longer available after the March 1, 2018 program overhaul. Get the application right the first time.

Source: canada.ca — Voluntary Disclosures Program

— Bader A. Chowdry, CPA, CA, LPA — Insight Accounting CPA

Disclaimer: Bader A. Chowdry, CPA, CA, LPA is a Licensed Public Accountant regulated by CPA Ontario. Insight Accounting CPA Professional Corporation is a Chartered Professional Accountant firm. This content is general information only and does not constitute professional advice for your specific facts. Confirm current rules and figures with your own advisor before acting.

Source: CRA, Voluntary Disclosures Program — relief levels and limits (IC00-1R7, applications received on or after October 1, 2025).