What is the CRA Voluntary Disclosures Program?

A program that lets taxpayers and GST/HST registrants correct mistakes and missed filings in exchange for relief from penalties and part of the interest. You apply on Form RC199. You still pay all the tax. Since 1 October 2025, unprompted applications get 100% penalty relief and 75% interest relief, and prompted applications get up to 100% penalty relief and 25% interest relief.

Can I use the Voluntary Disclosures Program if I never registered for GST/HST?

Yes, if you meet the conditions. The CRA's GST/HST memorandum says any person can apply to disclose errors or omissions, and the program covers situations where GST/HST was not charged, collected or reported. The application must be voluntary, be at least one reporting period past the filing due date, involve penalties or interest, be complete, and come with payment or a payment arrangement request.

What is the difference between an unprompted and a prompted application?

Unprompted means the CRA hasn't contacted you about the issue, other than a general education letter. It earns general relief: 100% of penalties and 75% of interest. Prompted means you apply after the CRA has contacted you about a specific issue, or already holds third-party information about it. It earns partial relief: up to 100% of penalties and 25% of interest. Since October 2025 prompted applications are accepted, as long as no audit or investigation has begun.

Do I have to pay the tax when I apply to the Voluntary Disclosures Program?

You have to include a payment of the estimated tax owing with your application, or ask for a payment arrangement. The CRA's collections officials review arrangement requests and approval is not guaranteed. Relief only covers penalties and part of the interest, never the tax itself.

Can I get the GST/HST back from customers I never charged?

Generally not in practice. You are liable for tax you should have charged even if you never collected it, and for most online sellers it comes out of the seller's margin. Do not send customers a bill for past sales without advice from an accountant. Start charging correctly from the date you register.

Can I claim input tax credits for the period I should have been registered?

Generally yes, for GST/HST on business costs during the periods you are treated as registered, if you have proper invoices and claim within the time limit. This offsets the tax you owe on past sales, which is why the net amount is usually smaller than the gross. New registrants can also claim on inventory and capital property on hand on the effective date.

Should I apply to the Voluntary Disclosures Program or just register and file?

If you owe tax and are more than a reporting period behind, the program usually costs less, because it cancels all penalties and most of the interest on an unprompted application. Registering and filing yourself is the right move when you are not yet a full period late, when you would owe nothing, or when the program is not available. Apply before the CRA contacts you.

CRA Voluntary Disclosure for Missed GST/HST Registration

Short answer: if you should have registered for GST/HST (or charged it, or filed your returns) and didn’t, you can apply to the CRA’s Voluntary Disclosures Program (VDP) on Form RC199 before the CRA contacts you. You pay all the tax, but the CRA cancels 100% of the penalties and 75% of the interest. The program was overhauled on 1 October 2025, and you can now also apply after the CRA has written to you about the issue, for smaller relief. The alternative is to register, backdate your effective date and file the missed returns, and then pay the penalties and interest in full.

This guide is for Canadian online sellers on Shopify, WooCommerce, BigCommerce, Etsy and Amazon who passed $30,000 of sales without registering, or registered and never filed. It isn’t tax advice for your case. For anything involving tax you collected and kept, or an amount that looks large, talk to an accountant first.

Which route should I take? Find your situation

Your situation	Best route
You passed $30,000, never registered, and owe tax for periods that are at least one reporting period past due (a year, for an annual filer)	Voluntary disclosure, or register and file on your own
You passed $30,000, never registered, and your first return is past due by less than one reporting period	Register and file now. The VDP won’t take it yet
You’re registered but never filed returns with tax owing	Voluntary disclosure
You passed $30,000 recently and the first return isn’t due yet	Just register now and charge tax from your effective date. It’s not a VDP case yet
After your input tax credits (ITCs) you’d owe nothing, or the CRA would owe you	Register and file. No penalty applies, and the VDP doesn’t take refund or nil-balance returns
The CRA has sent you a letter about this issue	VDP with partial relief (prompted application)
The CRA has started an audit or investigation	Not available. Register and file, then ask for taxpayer relief
You charged customers GST/HST and didn’t remit it	Get advice from an accountant before you do anything else

What the Voluntary Disclosures Program is

The VDP is a CRA program that gives relief from penalties and part of the interest to people who come forward on their own to fix a tax mistake or omission. It covers GST/HST along with income tax and other taxes. For GST/HST the rules are in the CRA’s Memorandum 16-5-1, and the general rules are in Information Circular IC00-1R7.

It is not a tax amnesty. The CRA’s own guidance says taxes owing still have to be paid in full. What you get is:

relief from the penalties that would otherwise apply, such as the late filing penalty
relief from part of the interest
no referral for criminal prosecution for the information you disclose, and no gross negligence penalties on it

What changed on 1 October 2025

For applications the CRA received on or after 1 October 2025:

Two tiers of relief replaced the older General and Limited programs: general relief for unprompted applications and partial relief for prompted ones. See relief levels.
You can now apply after the CRA has contacted you about a possible problem, such as an education letter. Before, that usually ruled you out. People under audit or investigation, and those who were egregiously non-compliant, are still restricted.
Form RC199 was simplified.
GST/HST applications cover the most recent four years of returns. Years or reporting periods in that window with no errors can be left out, though the CRA can ask for older periods.

Applications received before that date are handled under the older rules (IC00-1R6 and Memorandum 16-5).

Who can apply, and the five conditions

The CRA’s GST/HST memorandum says any person can apply. You must meet all five of these:

#	Condition	What it means for a seller
1	Voluntary	You apply before an audit or investigation has begun against you or a related person, on the information you’re disclosing. That includes investigations by other bodies like police or securities regulators
2	Complete	You include all relevant information and documents for the periods involved, and answer CRA questions promptly
3	Penalties or interest	There’s an error or omission that carries penalties, interest, or both
4	Past due	The information is for a period at least one reporting period past its filing due date: a year for an annual filer, a quarter for a quarterly filer
5	Payment	You include payment of the estimated tax owing, or ask for a payment arrangement

What doesn’t qualify

The CRA says it typically won’t grant relief for:

returns that would produce a refund or no tax owing
applications that only claim more ITCs or rebates without any matching rise in tax you owe
relief on penalties or interest that have already been assessed
making or changing an election
an insolvency event in the years involved

Relief levels: unprompted and prompted

	General relief (unprompted)	Partial relief (prompted)
When	No CRA contact about the issue. A general education letter or notice that only gives guidance doesn’t count as contact	You apply after the CRA contacted you about a specific issue, or after it already holds third-party information about you
Penalties	100% cancelled	Up to 100% cancelled
Interest	75% cancelled	25% cancelled
Prosecution referral	No	No
Gross negligence penalties	Don’t apply	Don’t apply

Interest relief covers interest that accrued in the 10 calendar years before the year you ask. For GST/HST, the CRA also has a separate wash transaction treatment: where you should have charged GST/HST to a registered business that would have claimed it all back as an ITC, eligible wash transactions get 100% relief from penalties and interest. Ask your accountant whether your wholesale sales qualify.

The practical point: you want to be on the unprompted side. Once the CRA sends a letter about the problem, you move to the 25% interest tier.

How to apply

Get your numbers. Work out which periods you missed, your taxable sales in each, the GST/HST or HST rate for where each order was delivered, and the GST/HST you paid on business costs. Estimates are acceptable where the records don’t exist, but be honest about which are estimates.
Prepare the missed returns. The CRA wants “all necessary returns, forms and schedules needed to correct the non-compliance”, for the most recent four years of GST/HST.
Complete and sign Form RC199, Voluntary Disclosures Program (VDP) Application. Name any adviser who helped create the problem. An accountant can apply for you, but both of you sign.
Include payment, or a request for a payment arrangement, for the estimated tax.
Submit once, one way. Online is the fastest: My Business Account, Represent a Client for an accountant, or My Account for individuals. You can also fax (1-888-452-8994) or mail it to the Voluntary Disclosures Program, 4695 Shawinigan-Sud Boulevard, Shawinigan, QC G9P 5H9.
Wait for the acknowledgement letter. It gives your effective date of disclosure. If your application qualifies, relief applies up to that date. Respond to any CRA questions quickly, because an incomplete application can be refused.
Get the decision. The CRA’s letter states the relief level and the periods covered, or the reason relief was refused.

Not sure yet? You can ask for a free, informal and anonymous pre-disclosure discussion using the CRA’s online callback request. It is non-binding and doesn’t guarantee relief.

If relief is refused, you can’t file an objection. You can ask for a second administrative review, apply to the Federal Court for judicial review within 30 days of the decision, or ask for taxpayer relief.

Payment

You pay the estimated tax with the application, or ask for a payment arrangement. Collections officials review those requests, and the CRA says approval is not guaranteed. So work out whether you can pay before you apply. See what to do if you can’t pay everything.

The alternative: register and file the missed returns

You don’t have to use the program. You can simply register, ask for the right effective date and file the missed returns.

Your effective date is the date you should have been registered. For a seller who passed $30,000, the threshold timing rules set it.
The online registration form won’t accept a date more than 30 days in the past. Pick a date within the last 30 days and then send the CRA a written request to backdate the registration, with a breakdown of your sales (spreadsheets or sales journals) showing when your taxable sales first passed $30,000. The CRA reviews it and tells you the decision.
You then file a return for every period since the effective date.
You pay the tax, the late filing penalty on each return with a balance owing (1% plus a quarter of 1% a month, up to 4%), and interest on everything from the original due dates, at 7% compounded daily for the quarter from 1 October to 31 December 2026. See late filing penalties and interest.
You can still ask for relief from penalties and interest under the taxpayer relief rules. That’s discretionary: the CRA looks for extraordinary circumstances, its own errors or inability to pay. Not realising you had to register is a hard case to win.

For a seller who owes tax and is a year or more behind, the VDP is usually the better deal, because its relief is set out in percentages and doesn’t depend on an excuse. Register and file on your own when the VDP doesn’t apply, for example when you’re not yet a period behind, the CRA has begun an audit, or you’d owe nothing.

The GST/HST you never charged

This is the part that stings. If you were required to charge GST/HST and didn’t, the CRA’s position is that you’re still liable for it, and you report it for the period you should have charged it. You owe it whether or not customers paid it.

For an online seller:

It generally comes out of your margin. Your customers paid the price you showed them, and most consumer sellers can’t practically go back to thousands of past buyers for more.
Don’t send customers a bill without advice. Talk to an accountant first, particularly for business customers who might want an invoice to claim ITCs.
Fix it going forward. From your effective date onward, charge the right rate for the province of delivery. See sales tax by province. Make sure your store and marketplace accounts show your new number.

That is the strongest argument for registering at the threshold rather than late.

ITCs for past purchases lower what you owe

The tax you owe is not your sales times the rate. It’s your sales tax minus the input tax credits on the GST/HST you paid on business costs in the same period.

You claim ITCs for the periods you’re treated as registered. With a backdated effective date, the GST/HST on inventory, packaging, platform fees, shipping and other business costs from that date count.
Inventory and capital property on hand on the effective date can also qualify. Services and rent from before your registration don’t.
You need the invoices. Gather supplier invoices, Shopify and Etsy fee statements, and shipping receipts that show the GST/HST you paid.
Time limit: for most small sellers, four years.
Alone, ITCs aren’t enough for the VDP. An application that only claims more ITCs and doesn’t increase the tax you owe isn’t eligible. Claiming them against the tax you’re disclosing is fine.

Worked example: Maple & Moss

Maple & Moss is a sole proprietor in Hamilton, Ontario, selling planters and candles on Shopify and Etsy. Its owner realises in November 2026 that she crossed the threshold in 2024 and should have been registered from January 1, 2025. She never registered and never charged HST. Assume she is an annual filer with a December 31 year end, and that everything is delivered to Ontario customers at 13% HST.

Her 2025 numbers

	Amount
Taxable sales, 2025 (prices customers paid, with no HST added)	$48,000
HST she should have charged: 13% × $48,000	$6,240
Business costs, 2025 (before tax)	$18,600
HST she paid on those costs: 13% × $18,600 (invoices on hand)	$2,418
Net tax owing for 2025 (HST owing minus ITCs)	$3,822

For this example we treat the prices customers paid as before tax, so the HST is on top. Her accountant should confirm that treatment on a real file.

The 2025 return was due April 30, 2026 (payment) and June 15, 2026 (filing). Nothing was filed. Her 2026 return isn’t due until 2027, so it isn’t late yet.

Route 1: register and file on November 30, 2026

Complete months late (June 15 to November 30): 5
Penalty: A = 1% × $3,822 = $38.22. B = 25% of A = $9.555 a month, so 5 months = $47.78. Penalty: $38.22 + $47.78 = $86.00
Interest: May 1 to November 30 is 214 days at 7% compounded daily: about $160
Total: $3,822 + $86 + $160 = about $4,068

Route 2: a VDP application on November 30, 2026? Not yet

The VDP only takes a period that is at least one reporting period past its filing due date. For an annual filer that’s a full year, so her 2025 return doesn’t qualify until June 15, 2027. The program isn’t a filing extension: an application now wouldn’t get VDP relief.

So Route 1 is her route: about $246 of penalty and interest on top of the tax. Sitting on a known problem for seven months to qualify is a gamble, not a plan: interest keeps building at 7%, and if the CRA contacts her first, her interest relief falls from 75% to 25%, or disappears if it opens an audit.

When the VDP pays off. Had she also missed 2024, that return would have been over a year past due by November 2026, so an unprompted application for it would qualify: its penalty cancelled and 75% of its interest waived. The saving grows with the amount owed and the number of years missed.

Either way, her 2026 sales are separate: she registers now, charges HST from here on, and reports the HST on her 2026 sales from January 1 on her 2026 return, on time.

Common mistakes

Waiting. Once the CRA contacts you about the issue, the unprompted tier is gone. An audit ends the program as an option.
Applying without the money. Payment of the estimated tax, or a payment arrangement request, is a condition of the application.
Forgetting the ITCs. Ignoring the GST/HST on your costs means paying more than you owe.
Forgetting the current year. The VDP fixes the past. Register and start charging now.
Leaving periods out. The application must be complete. Disclose all known errors.
Quebec sellers using the wrong agency. Most Quebec businesses deal with Revenu Québec for GST/HST and QST, not the CRA. If that’s you, start with Revenu Québec or an accountant. See the GST/QST return guide.

Official sources

Voluntary Disclosures Program, Canada Revenue Agency
Changes to the Voluntary Disclosures Program, Canada Revenue Agency
Who is eligible, Canada Revenue Agency
How to apply, Canada Revenue Agency
Our review and decision, Canada Revenue Agency
IC00-1R7, Voluntary Disclosures Program, Canada Revenue Agency
GST/HST Memorandum 16-5-1, Voluntary Disclosures Program, Canada Revenue Agency
Form RC199, VDP Application, Canada Revenue Agency
Request a GST/HST registration to be backdated by more than 30 days, Canada Revenue Agency
General information for GST/HST registrants (RC4022), Canada Revenue Agency