Tax Ombud Calls for Review of Bill C-31 Filing Rules

Office of the Taxpayers' Ombudsperson

OTTAWA, October 5 2026 - The Taxpayers' Ombudsperson is urging the Government of Canada and the Canada Revenue Agency (CRA) to ensure that automatic tax filing initiatives are designed to help Canadians receive the benefits and credits they are entitled to, on time and without interruption.

For many lower-income Canadians, benefits and credits provide essential financial support. While some individuals are not required to file a tax return, they must do so to establish and maintain eligibility for this support. In this context, automatic tax filing has the potential to reduce barriers and connect more Canadians with the support they need.

  • SimpleFile
  • Deemed filing
  • Pre-filled tax returns through CRA accounts

While SimpleFile is currently available, it requires a taxpayer's explicit consent. Proposed legislation in Bill C-31 would allow the CRA to implement deemed filing for certain taxpayers, enabling the CRA to file a return on an individual's behalf without the taxpayer's consent or involvement.

While the Office of the Taxpayers' Ombudsperson supports efforts to simplify tax filing they are concerned that deemed filing, as currently proposed, could create several service issues. Therefore, it is at this time, before the legislation is passed, that consideration be given to whether the legislation will deliver for lower-income Canadians.

The proposed legislation does not prescribe a specific date when taxpayers must be notified or when returns would be filed on their behalf, creating a risk of benefit interruptions. Further, continued participation in deemed filing will ultimately lead to ineligibility. This is because the proposed legislation stipulates to be eligible, a taxpayer must not have filed for one of the preceding three tax years. In addition, safeguards are also needed to ensure taxpayer information is accurate before benefit payments are issued.

In light of the above concerns, the Taxpayers' Ombudsperson recommends that the Government of Canada and the CRA prioritize pre-filled tax returns through CRA accounts. Expected to launch in March 2027, this service would allow taxpayers to review and approve returns using information already available to the CRA. It will also reach millions more individuals than deemed filing.

The Office of the Taxpayers' Ombudsperson has submitted a brief to the House of Commons Standing Committee on Finance outlining these concerns and recommendations for consideration during its review of Bill C-31.

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