Canada rebuilt its Voluntary Disclosures Program effective 1 October 2025. The old General and Limited streams are gone; everything now turns on one distinction. An unprompted application — filed before the CRA has communicated with you about the specific issue — is normally eligible for 100% penalty relief, 75% interest relief, and protection from prosecution on what is disclosed. A prompted application — filed after the CRA has named the issue — can still earn full penalty relief, but interest relief drops to about 25%. Under audit or investigation, the program is closed for that issue. Same disclosure, three prices, and only the calendar decides which one you pay.
The nuance that changes everything for crypto
A general education letter — the broad "reminder about your crypto reporting obligations" the CRA sends at scale — does not make your disclosure prompted. The CRA has said so explicitly: general outreach naming no specific finding leaves the unprompted door open. This is the single most practically important fact on this page, because it reverses the instinct the letter creates. People read an education letter as "too late" and freeze. The rules say the opposite: it is the last cheap moment, formally recognised as such. What closes the unprompted door is targeted contact — a letter naming your issue, your years, your platform — and, on some readings, the CRA merely holding third-party data tying you to the issue. With court-ordered platform disclosures and CARF reporting filling that pipeline on a published schedule, "before they name it" is a window measured in data-processing time.
The education letter is not the door closing. It is the last time the door is guaranteed open — in writing.
What a valid disclosure requires
Substantively complete for the years affected, on the simplified application form, with payment of the estimated tax — or a payment arrangement — included. It must involve a penalty or interest exposure to be worth relieving, and information at least one year past due. Relief remains discretionary and the CRA screens out egregious non-compliance; disclosure protects candour, not gamesmanship. Interest relief also has a horizon — the deepest relief applies to the older years within the standard ten-year limitation, which is one more way waiting costs money.
The sequence
- Reconstruct everything first. Every platform and wallet, CAD values, ACB per coin, superficial-loss corrections, income events, and the T1135 question — a disclosure can and often should cover the missed form alongside the missed income.
- Answer the capital-vs-business question with an adviser. It halves or doubles the income at stake and shapes every year's numbers. Self-assessing it optimistically inside a disclosure invites exactly the scrutiny the VDP is meant to avoid.
- Read your correspondence with cold eyes. Education letter or specific-issue letter decides unprompted versus prompted. It is a legal reading, not a vibe — an adviser makes it in minutes, and the answer sets the price.
- File complete, once, with payment arranged. A disclosure that needs supplementing later invites re-examination of the whole file.
- If you are already under audit — stop; different playbook. The VDP is closed for that issue. What remains is audit defence and, for penalties, ordinary fairness relief — with representation, from the first response.
Quebec, briefly
Quebec runs its own tax system and its own voluntary disclosure practice through Revenu Québec. A federal VDP filing does not automatically fix the provincial side; residents of Quebec generally need the pair. That coordination is one more reason this is a with-an-adviser filing, not an evening project.
Eligibility and relief are determined by the CRA on facts this page does not have. It frames the decision; it does not make it, and reading it creates no professional relationship.