Following recent changes to the Canada Revenue Agency’s (CRA’s) Voluntary Disclosures Program, Revenu Québec has introduced corresponding updates to its own program. For employers with mobile workforces, these changes reinforce the need to proactively review historical Québec payroll, withholding, and reporting obligations before the tax authorities identify compliance issues.
In October 2025, the CRA revised its Voluntary Disclosures Program to expand eligibility and increase relief for both prompted and unprompted disclosures. These federal changes were particularly relevant for employers managing expatriate assignments, shadow payrolls, and foreign income or asset reporting for mobile employees.
Revenu Québec has now followed with changes to its own Voluntary Disclosure Program, applicable to disclosures filed after December 17, 2025. Together, these updates highlight a broader federal–provincial shift toward encouraging earlier voluntary compliance, while still drawing a clear distinction between disclosures made before and after tax authority intervention.
Key changes under the Québec program include:
Prompted disclosures apply when Revenu Québec has already raised a specific compliance concern, or when third-party information suggests potential non-compliance. Penal proceedings and up to 100% of penalties may be waived, and Interest relief is more limited or may not apply.
In all cases, employers and employees remain responsible for paying the underlying Québec duties, source deductions, and related amounts for all affected years or periods.
For organisations with mobile employees, Québec tax exposure often arises indirectly through shadow payrolls, missed source deductions, or incomplete reporting for inbound or outbound assignees. The revised rules mean that once Revenu Québec (or another tax authority) initiates contact, the level of available relief may be significantly reduced.
Employers should review historical Québec payroll and reporting positions for mobile employees, including inbound assignees, outbound Canadians, and remote workers.
Shadow payroll arrangements and source deductions are common areas where voluntary disclosures may be appropriate.
Coordinating Québec disclosures with any related CRA voluntary disclosures is critical to managing overall exposure and ensuring consistent outcomes.
Acting early -- before any audit, investigation, or compliance notice -- provides the greatest opportunity for penalty and interest relief.
For more information on the changes to Quebec’s Voluntary Disclosures Program, please consult your regular BDO contact or the authors of this article.
Jason Ubeika
Joanne Sun
BDO in Canada
Background and Global Mobility Context
In October 2025, the CRA revised its Voluntary Disclosures Program to expand eligibility and increase relief for both prompted and unprompted disclosures. These federal changes were particularly relevant for employers managing expatriate assignments, shadow payrolls, and foreign income or asset reporting for mobile employees.Revenu Québec has now followed with changes to its own Voluntary Disclosure Program, applicable to disclosures filed after December 17, 2025. Together, these updates highlight a broader federal–provincial shift toward encouraging earlier voluntary compliance, while still drawing a clear distinction between disclosures made before and after tax authority intervention.
Key changes under the Québec program include:
- Disclosure applications must be spontaneous, meaning they must be filed before any audit or investigation of the information being disclosed is initiated;
- Audits or investigations are not limited to those conducted by Revenu Québec and may include actions by other regulatory or enforcement authorities;
- The former general and limited disclosure programs have been eliminated;
- Applications are now categorised as unprompted or prompted disclosures;
- Certain items commonly encountered in employer contexts, including wash transactions and duties on the transfer of immovable property, remain eligible under the revised framework.
Unprompted vs. Prompted Disclosures -- Employer Considerations
Unprompted disclosures generally apply when there has been no prior communication identifying a specific compliance issue (or when only general education letters have been issued). Penalties and penal proceedings are waived, and partial interest relief may apply, generally limited to a prescribed look-back period (often up to the six prior calendar years), depending on the circumstances.Prompted disclosures apply when Revenu Québec has already raised a specific compliance concern, or when third-party information suggests potential non-compliance. Penal proceedings and up to 100% of penalties may be waived, and Interest relief is more limited or may not apply.
In all cases, employers and employees remain responsible for paying the underlying Québec duties, source deductions, and related amounts for all affected years or periods.
Why This Matters for Employers and Global Mobility Programs
For organisations with mobile employees, Québec tax exposure often arises indirectly through shadow payrolls, missed source deductions, or incomplete reporting for inbound or outbound assignees. The revised rules mean that once Revenu Québec (or another tax authority) initiates contact, the level of available relief may be significantly reduced.
BDO Insights
Employers should review historical Québec payroll and reporting positions for mobile employees, including inbound assignees, outbound Canadians, and remote workers.Shadow payroll arrangements and source deductions are common areas where voluntary disclosures may be appropriate.
Coordinating Québec disclosures with any related CRA voluntary disclosures is critical to managing overall exposure and ensuring consistent outcomes.
Acting early -- before any audit, investigation, or compliance notice -- provides the greatest opportunity for penalty and interest relief.
For more information on the changes to Quebec’s Voluntary Disclosures Program, please consult your regular BDO contact or the authors of this article.
Jason Ubeika
Joanne Sun
BDO in Canada