Revenu Québec announces new Voluntary Disclosure Program

Introduction

On December 18, 2025, Revenu Québec (RQ) announced updates to its Voluntary Disclosure Program, effective December 17, 2025. These revisions bring the RQ process into closer alignment with the Federal Voluntary Disclosure Program changes announced on September 10, 2025. 

Background 

Historically, the RQ Voluntary Disclosure Program has mirrored the federal program only in part. Several differences have existed, including which types of returns are accepted (for example, the Federal program accepts certain information returns that RQ does not), the extent of penalty and interest relief available, and rules governing second disclosure applications. 

The newly announced changes maintain some of these differences but reflect the same overarching intent as the federal revisions: making the program more accessible and easier to navigate for a broader range of taxpayers. 

Changes aligned with federal updates 

Elimination of general and limited programs 

RQ has eliminated its former “general” and “limited” program streams. Disclosures are now categorized as either prompted or unprompted, consistent with the new federal framework. The voluntariness criteria for these streams have also been updated to match federal definitions. 

Revised definition of “spontaneous” 

Previously, an application was considered spontaneous only if submitted before any audit or demand to file had been initiated. RQ has broadened this definition so that a disclosure remains spontaneous if submitted before any audit or investigation has been started by any regulated authority (i.e., law enforcement agency, securities commission etc.). This aligns closely with the expanded federal definition. 

Updated application form (LM15) 

RQ is updating Form LM15 to reflect the program changes and to provide a simplified, more userfriendly application experience, similar to the revisions made to the federal program’s application form. 

Changes that differ from federal updates 

Despite the harmonization efforts, several important differences between the RQ and federal regimes remain. 

1. Calculation of penalty and interest relief 

Prompted applications: 

Unprompted applications: 

2. Documentation requirements 

Applicants must disclose all instances where an obligation was not met and provide all information necessary to determine the accuracy of the disclosed facts. This documentation threshold is more expansive than under the federal program which only requires the most recent 6 years for tax obligations in Canada and 10 years if the issue relates to assets or income outside of Canada. 

3. Payment requirements 

Payment is required for all omissions across all years where an obligation was not met. This differs from the federal program’s flexibility in requesting a payment plan. 

4. Second applications 

RQ will only consider a second voluntary disclosure when: 

• It relates to a different situation, or 

• The taxpayer can demonstrate no intentional misconduct occurred in relation to the previous disclosure. 

Practical implications 

Overall, the RQ revisions expand access to the program and bring it closer to the federal model, reducing administrative complexity for taxpayers and advisors. However, the programs are not fully aligned, and several key differences remain—particularly in the determination of interest relief, documentation expectations, and the handling of secondary applications. 

A thorough understanding of these distinctions will be critical, especially where a taxpayer must file disclosures under both the RQ and federal programs. Each application must be tailored to its respective set of rules to ensure accuracy, completeness, and eligibility for relief. 

Conclusion 

Overall, these changes are working to achieve a simpler and more balanced tax system and keep provincial and federal programs aligned. While RQ has preserved certain distinct features, alignment with federal principles should create a more predictable and navigable process for taxpayers. This represents a positive development for taxpayers, however, complexities remain, and careful analysis is required. Our Baker Tilly advisors are ready to help.