The CRA TSlip Saga: An Update

Ruth Horst

This tax season has been particularly challenging for both taxpayers and tax professionals. The Canada Revenue Agency (CRA) provides tax information slips—such as T3, T4, T5, and their variations—through secure online portals: My Account and Represent a Client (RAC). This year, there were lots of problems with these portals, and now, it appears, CRA is not being quite transparent about when the slips were actually visible to clients and that doesn’t seem fair. Here’s an update on where we stand now.

The Backdrop. Taxpayers and their representatives can access and download the slips from these platforms. By early April, the majority of slips are usually available online, with the exception of some investment-related slips and those that are filed late or subsequently amended. Increasingly, taxpayers have come to rely on My Account and RAC for a complete listing of their tax slips, paying less attention to the physical or digital copies they may receive through other means.

In previous years, this system functioned reliably. However, in early 2025, the CRA undertook a major systems overhaul that was fraught with technical challenges. Many financial institutions and business owners encountered issues uploading tax slips or received confirmation receipts for submissions that were never completed. Additionally, successfully uploaded data was not moved into My Account or RAC in a timely manner. As a result, critical data needed to complete tax returns was often missing from these CRA portals.

The most common missing slips were T3s and T5s. Surprisingly; T5008 slips were largely complete in most cases. Other frequently missing slips included T4A, T4RIF, and T5013 slips.

Tax professionals were left to perform a significant amount of manual data entry and taxpayers were required to contact their financial institutions or employers directly to obtain the necessary slips. Tax professionals needed to use valuable time to manually input data which increased the possibility of transcription errors and increased the amount of time required to complete a tax return.

The Findings: I thought it would be interesting to compare the data that was available online when we originally completed tax returns with what is available today, so I conducted a sampling of clients with investment income.

In both My Account and Represent a Client (RAC), the CRA provides a listing of all tax slips on file for an individual, including the date each slip was processed. I noticed a significant discrepancy between the “processed” date and the date the slips actually became visible and available for viewing.

In most of the accounts I reviewed, the slips showed processing dates that predated the Auto-Fill My Return (AFR) dates. When we connect to the CRA through our software, the latest AFR date is time-stamped, and the available slips are imported into the tax return. Many of the returns I examined had AFR dates in late April—because we were still waiting for missing slips—while the CRA now shows those same slips as having been processed in late March. Despite the earlier processing dates, the slips were neither visible nor accessible in the portals until much later, usually after the tax returns were efiled.

One example involves a 95-year-old individual whose return was filed late because a required T5 slip was not available on Represent a Client (RAC). It took until May 5th to obtain the slip directly from the financial institution. At the time of efiling, the slip was not available on RAC. However, when I checked RAC today, the slip now shows a processing date of March 18th. While it may have been internally processed by CRA on that date, it clearly was not posted or accessible in the portal until sometime after May 5th.

The Consequences: Missing to report income is never ideal in the eyes of the CRA. While they are generally lenient the first time a slip is missed—given the taxpayer was unaware—the CRA will reassess the return and issue a bill for any additional tax owing.

However, the consequences are more severe if it happens again. The CRA applies the Repeated Failure to Report Income Penalty if a taxpayer fails to report income of $500 or more in the current year and also missed reporting income in one of the previous three tax years. In such cases, the taxpayer may be subject to both federal and provincial/territorial penalties.

The penalty is the lesser of:

• 10% of the unreported income (federally and provincially/territorially), or
• 50% of the difference between the understated tax or overstated credits and the amount of tax withheld on the unreported income.

The Bottom Line: It will be interesting to see how the CRA handles cases involving missing slips when they run their Matching Program in late summer and early fall. This program compares the information reported on tax returns with data received from third parties—such as banks, financial institutions, government programs, and employers.

Will the CRA impose penalties on taxpayers who missed slips because they were not yet available through CRA systems? Will they show leniency, given the circumstances? And next year, if a taxpayer again misses reporting a slip, will the 2024 omission be counted toward the Repeated Failure to Report Income Penalty? Most importantly, will they use the “processing date” or the “visibility date” in assessing interest and penalties?

It is probably a given that CRA will communicate that it is ultimately the taxpayer’s responsibility to file a complete and accurate tax return—even though the agency’s reliance on digital portals may have lulled many into a false sense of security. If you have concerns about the completeness of your tax return, it’s wise to book an appointment with a Tax Professional or Financial Advisor as there are steps that can be taken to rectify the filing before any penalties are levied.