Changes to Quebec’s Voluntary Disclosure Program: Eligibility, Obligations, and Tax Forgiveness for Taxpayers

Recent Changes to Quebec’s Voluntary Disclosure Program: What Taxpayers Need to Know

On December 18, 2025, Quebec published changes to its Voluntary Disclosure Program, which is largely modelled after the federal Voluntary Disclosures Program administered by the Canada Revenue Agency. These changes apply to voluntary disclosure applications submitted after December 17, 2025. Revenu Québec has also indicated that an Interpretation Bulletin will be released to provide more detailed guidance on the scope and application of the new rules.

This article examines the current state of the Quebec Voluntary Disclosure Program following the recently published amendments, with the objective of enabling taxpayers to plan and manage tax affairs effectively in light of these changes, pending the release of the Interpretation Bulletin, which is expected to provide further clarification on the administration of the program.

Filing Requirements for a Valid Voluntary Disclosure Application to Revenu Québec

A taxpayer initiates a voluntary disclosure by completing and signing Form LM-15-V (Voluntary Disclosure Form) and submitting it to Revenu Québec, together with all required supporting documentation.

For a voluntary disclosure application to be accepted in Quebec, the application must be spontaneous, complete, and verifiable. It has to also include payment for your tax debt.

• Spontaneous: The disclosure must be made before the commencement of any tax audit, investigation, or enforcement action by a federal or provincial authority in respect of the taxpayer or a related person, insofar as the audit or investigation relates to the subject matter of the disclosure.
• Complete: The disclosure must include all instances of the taxpayer’s fiscal non-compliance under all applicable fiscal laws. The taxpayer must identify the relevant taxation years and reporting periods affected by the non-compliance. In addition, the application should include the taxpayer’s calculation of the unreported income and the corresponding taxes payable as a result of the non-compliance.
• Verifiable: The disclosure must be supported by sufficient documentation to substantiate the information provided and the amounts owing. This documentation generally includes tax returns, statements, forms, and supporting records such as contracts, invoices, and other relevant documents.
• The taxpayer must also include payment of the amounts owed with their Quebec Form LM-15-V. If the taxpayer’s circumstances make it difficult to determine the exact amount owed, the taxpayer is required to remit payment based on the taxpayer’s current estimate.

In certain cases, a payment agreement may be arranged that takes into account all amounts outstanding as of the date of the agreement, including amounts covered by the taxpayer’s voluntary disclosure as well as any other tax debt. Where applicable, interest will continue to accrue on the outstanding balance until the debt has been paid in full.

Prompted vs. Unprompted Applications: Relief and Obligations Under Quebec’s Voluntary Disclosure Program”

The taxpayer’s voluntary disclosure application may be processed as prompted or unprompted.

Treatment of Unprompted Applications Under Quebec’s Voluntary Disclosure Program

A taxpayer’s application is processed as unprompted where no provincial or federal authority has contacted the taxpayer regarding an identified compliance issue related to the subject matter of the disclosure. An application will still be considered unprompted where the taxpayer has received an education letter or other general communication from a tax authority that provides non-specific guidance or information relating to a particular topic, rather than addressing the taxpayer’s file directly.

Where a taxpayer’s application is accepted as unprompted, the following reliefs apply:

• The taxpayer is required to pay all taxes that should have been paid for the affected taxation years or reporting periods.
• The taxpayer receives full relief from penalties and immunity from criminal prosecution in respect of the disclosed facts.
• For the six calendar years preceding the year in which the disclosure takes effect:

• the taxpayer is required to pay 100% of the applicable interest for taxation years or periods that are not prescribed, meaning years or periods that remain legally collectible by Revenu Québec; and
• For taxation years or periods that are prescribed, and therefore no longer legally collectible by Revenu Québec, the taxpayer benefits from a 50% reduction in applicable interest.

Treatment of Prompted Applications Under Quebec’s Voluntary Disclosure Program

A taxpayer’s application is accepted as a prompted disclosure where the taxpayer or a related party has been contacted by a provincial or federal authority regarding an identified compliance issue related to the subject matter of the disclosure (excluding education letters), if the contact meets one of the following conditions:

• It identifies a specific error or omission on the taxpayer’s account.
• It provides a deadline within which the taxpayer is expected to correct an error or omission, such as filing a return or fulfilling other tax obligations.

An application is also considered prompted where Revenu Québec already possesses information from a third party regarding the taxpayer’s or a related person’s potential non-compliance.

Where a taxpayer’s application is accepted as prompted, the following reliefs apply:

• The taxpayer is required to pay all taxes owed for the affected years or periods.
• The taxpayer may receive up to 100% penalty relief and immunity from criminal prosecution in respect of the disclosed facts.
• For the ten calendar years preceding the year in which the disclosure takes effect:

• The taxpayer is charged 100% of applicable interest for the six calendar years immediately preceding the disclosure year.
• The taxpayer is charged 50% of applicable interest for the four calendar years prior to the six-year period mentioned above.

A taxpayer can generally benefit from the Quebec voluntary disclosure program only once. If the taxpayer seeks to benefit from the program a second time, it must be demonstrated that the disclosure relates to a different situation or contains no evidence of intentional non-compliance.

Pro Tax Tips:   One Chance Counts—Make It Matter

Generally, you can benefit from the Quebec Voluntary Disclosure Program only once. If you plan to disclose again, it must be for a completely separate situation or show no intentional wrongdoing. This makes your first disclosure extremely important: be thorough, accurate, and honest. Think of it as a “reset button” for your tax compliance. Proper planning now avoids complications later, ensures maximum relief, and protects your record. Keeping detailed documentation and consulting guidance (like the upcoming Interpretation Bulletin or an experienced tax lawyer) will help make your one opportunity truly count.

Frequently Asked Questions (FAQs):

Which is a Non-prescribed Year, under the Quebec Voluntary Disclosure Program?

A non-prescribed year is a tax year that Revenu Québec can still reassess under the normal limitation period. For individuals and Canadian-controlled private corporations (CCPCs), this period is generally three years; for mutual funds, non-CCPCs and Quebec Sales Tax, it is generally four years. See Section 1010(2) (a) & (a.0.1) of the Quebec Taxation Act.

What is a Prescribed Year under the Quebec Voluntary Disclosure Program?

A prescribed year is a tax year that is normally time-barred because the regular limitation period has expired, unless a legal exception applies. Exceptions include situations where the taxpayer has:

• Made a misrepresentation due to negligence or wilful default,
• Committed fraud in filing the return or providing information, or
• Signed a waiver agreeing to extend the reassessment period.

See Section 1010(2)(b) of the Quebec Taxation Act.

When does Disclosure take effect under the Quebec Voluntary Disclosure Program?

Under the Quebec Voluntary Disclosure Program, a disclosure takes effect on the date Revenu Québec receives the duly completed and signed disclosure application.

Is there a notable difference between the Quebec and CRA Voluntary Disclosure Programs?

Under the Quebec Voluntary Disclosure Program, regardless of whether an application is accepted as prompted or unprompted, the taxpayer is required to pay all taxes relating to all omissions for every other year or period in which tax obligations were not met. However, interest and penalties are fully waived.

This approach differs from the CRA’s Voluntary Disclosures Program. Under the CRA program, a standard look-back period generally applies depending on the type of tax issue—for example, four years for GST/HST, six years for income taxes, and ten years for foreign income or foreign assets.

Comparison of the CRA and Revenu Québec Voluntary Disclosure Programs

Disclaimer: This article just provides broad information. It is only up to date as of the posting date. It has not been updated and may be out of date. It does not give legal advice and should not be relied on. Every tax scenario is unique to its circumstances and will differ from the instances described in the article. If you have specific legal questions, you should seek the advice of a Canadian tax lawyer.

About the Author

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David J. Rotfleisch

David J. Rotfleisch, a leading Canadian tax lawyer, is not only a certified specialist in taxation but also a chartered professional accountant. Most recently, David is a pioneer in Canadian crypto taxation.

As of April 2020, he was one of 12 Ontario Certified Specialists In Taxation™.

Learn more about David J. Rotfleisch