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The CRA can review any crypto return and expects records for every transaction, kept at least six years. If you missed income in past years, the Voluntary Disclosures Program lets you correct it before the CRA acts. It must be voluntary and complete. This page is information only, not advice.
Why might the CRA review a crypto return?
We found no CRA list of audit triggers for crypto. What the CRA crypto guide does say is that earnings or losses from crypto-asset transactions must be reported, and that it expects you to keep records for every transaction. A review is simply a request to check that your return matches your records.
Several things can lead to a question, and we are careful to label which are confirmed and which are not.
- Confirmed: the CRA publishes detailed record keeping rules, which shows records are what it asks about.
- Proposed: Bill C-31 would require crypto platforms to report user details and yearly totals to the CRA from the 2027 calendar year. See our page on the Crypto-Asset Reporting Framework. It was not law on 12 November 2026.
- Confirmed in the bill summary: Part 1 of Bill C-31 includes a measure for more efficient information gathering during tax audits.
- Not confirmed by the CRA: stories about blockchain analysis tools or court orders to platforms. These come from law firm commentary, so we do not present them as CRA statements.
Our general pages on CRA audit red flags and what to do with an audit notice cover review letters in general.
What documents does a crypto review ask for?
The CRA books and records page tells you what it expects you to have. For each transaction: the units and type of coin, the date and time, the value in Canadian dollars, a description of the transaction and the other party, and the wallet addresses used. Add each year's opening and closing wallet balances with their cost, receipts for accounting, legal and software costs, exchange trade and transfer ledgers, and mining records such as hardware receipts and pool statements. Keep them at least six years from the end of the last tax year they relate to.
| Record | Why a reviewer wants it |
|---|---|
| Exchange trade and transfer ledgers | Shows every buy, sell, swap, deposit and withdrawal |
| Dollar value at the time of each transaction | Needed for proceeds and cost in Canadian dollars |
| Wallet addresses and balances | Links your wallets and shows what moved between them |
| Cost records for the opening balance each year | Supports the adjusted cost base |
| Bank statements matching deposits and withdrawals | Ties crypto activity to real money |
| Notes on any business activity (time spent, expenses) | Supports the business or capital classification |
The value page says to use a reasonable and consistent way to value each coin in Canadian dollars. A review will look for consistency, so write down your method once and use it every year.
What if you missed income or gains in past years?
The Voluntary Disclosures Program (VDP) lets a person correct a return before the CRA starts action on it. We read the CRA's GST/HST memorandum 16-5-1 on the program, which applies to applications received on or after 1 October 2025. The income tax side runs under its own CRA circular that we could not read directly, and summaries of it describe a similar structure. Read the circular for income tax before you apply.
From the memorandum, a valid application must:
- be voluntary, which fails if an audit or investigation has already been started against you or a related person;
- cover a period at least one period past its filing due date;
- include an error or omission with interest, penalties or both;
- be complete, with all known errors and supporting documents for the most recent four years;
- be made on Form RC199, with payment or a payment arrangement for the tax owing.
The memorandum describes relief of 75% of interest and 100% of penalties for an unprompted application, and 25% of interest with up to 100% of penalties for a prompted one. Relief is discretionary, taxes owing must still be paid in full, and the CRA says it is not required to grant relief on every application. These figures come from the GST/HST memorandum. Do not assume the income tax program is identical.
A simple illustration with made up numbers: an unreported gain of $8,000 makes $4,000 taxable, since half of a gain is included. At an assumed 30% rate that adds about $1,200 of tax before interest and penalties. The tax is owed either way. The program is about the penalties and interest on top of it.
What are the common disputes: business income or capital gain?
The most common argument over crypto is whether trading is business income or a capital gain, because half of a capital gain is taxed and all of business income is. The CRA lists factors it looks at: how often you trade, how long you hold, your knowledge of the market, the time you spend, whether you borrow to buy, and whether you advertise. No single factor decides it. Our pages on day trading taxes and crypto tax give examples.
Another common issue is value. If a reviewer values your coins differently than you did, the gain changes. Keep the price source and the time you used.
A third is missing records. If an exchange has closed or you lost access, export what you can now. The CRA says to export your history regularly because a platform may stop operating.
What are the time limits to object?
If you disagree with an assessment, the usual route is a notice of objection. Today the general window is 90 days from the notice of assessment, as our page on the notice of objection explains. Budget 2026 proposes one year for most taxpayers, and for individuals the later of one year or two years from the filing due date. The Budget 2026 annex says this would apply to assessments sent on or after the day three months after royal assent. It is a proposal, so the 90 day window applies today.
This page is information only. It is not legal advice, we do not represent anyone before the CRA, and we do not guarantee accuracy. Read any CRA letter carefully and note its deadline.
How can you prepare calmly?
- Export every platform history now and save a copy outside the platform.
- Build one ledger with date, coin, units, Canadian dollar value, and cost. Reconcile it to your bank statements.
- Write down how you classified your activity and why.
- Compare your ledger with your filed returns for each year. Note any gap before anyone else does.
- If a gap exists, speak with a professional about options such as the VDP before the CRA contacts you, since contact can change the options.
- If a letter arrives, reply by the date on it, and keep copies of everything you send.
Frequently asked questions
Does the CRA audit crypto traders?
The CRA can review any return, and its crypto guide says earnings and losses must be reported. It does not publish crypto audit triggers. Claims about blockchain tracking come from law firm commentary, not CRA pages. Platform reporting to the CRA is proposed for 2027 under Bill C-31 and is not law yet.
What records should I keep for crypto?
Keep each transaction with units, coin type, date, Canadian dollar value, the other party and wallet addresses, plus balances and costs, exchange ledgers, receipts and mining records. The CRA says to keep them at least six years from the end of the last tax year they relate to.
Can I fix unreported crypto from past years?
The Voluntary Disclosures Program is the CRA route for correcting returns before it acts. A valid application is voluntary, complete, includes a penalty or interest, and is paid or arranged. It must be made before an audit begins. Read the current CRA circular, and ask a professional first.
How much relief does the Voluntary Disclosures Program give?
For GST/HST applications received since 1 October 2025, the CRA memorandum describes 75% interest relief and 100% penalty relief if unprompted, and less if prompted. Relief is discretionary and tax owing is still payable. We could not read the income tax circular, so check it.
How long do I have to object to a CRA assessment?
Today the general window is 90 days from the notice of assessment. Budget 2026 proposes one year for most taxpayers, but only for assessments sent three months after royal assent, and it is not law yet. Check the date on your notice and act within it.
Is this page legal advice?
No. It is information only. We do not give legal or tax advice, we do not represent the CRA or any organization, and we do not guarantee accuracy. If you face a review or a past mistake, speak with a Chartered Professional Accountant or tax lawyer about your own facts.