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CRA Collections (2026): The Dates That Decide What Happens Next

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By Anita Rouzbeh·Tax & Business Law Contributor
··19 min read
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This article provides general information about CRA collections in Canada as of 2026 and is not legal advice. Statutory references are drawn from the consolidated Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) and Excise Tax Act, R.S.C. 1985, c. E-15, and the operational figures from the Canada Revenue Agency's own published pages, all read on 15 September 2026.

CRA collections is not one process. It is nine of them, and which one you are in depends on a question most people never think to ask: what kind of debt do you actually owe? A personal income tax balance gets a ninety-day window in which the CRA is legally barred from touching your bank account. GST you collected from customers and did not remit gets nothing. The letter looks the same. The law behind it is not.

That difference decides whether you have three months or three days. It also decides whether the debt expires in six years, ten years, or never. Before anything else, it helps to know which one is sitting in the envelope. If your balance is still in dispute and has not reached collections, our guide to objecting to a CRA assessment covers the earlier stage.

A bundle of unopened brown CRA envelopes held by a red elastic band on a kitchen table, with a wall calendar behind showing one date circled in blue ink

Quick answer: what CRA collections can do, and when

  • The ninety-day pause is real, but narrow. For personal and corporate income tax, Income Tax Act s. 225.1 bars the CRA from garnishing, certifying the debt or seizing anything until ninety days after your notice of assessment was sent.
  • Payroll and GST/HST get no pause at all. Those are amounts you withheld or collected from someone else. Collection can start the day after you are notified.
  • A garnishment does not need a court order. The CRA issues a requirement to pay directly to your bank or employer, and that third party becomes personally liable if it ignores it.
  • Income tax and GST/HST debt expires after ten years. Payroll, EI, customs, student loans and COVID-19 benefit repayments run six. CPP and OAS overpayments never expire.
  • Almost anything cooperative you do restarts that clock. A single payment, a letter proposing an arrangement, even asking about pre-authorized debit.
  • The CRA cannot forgive tax. It can cancel penalties and interest under s. 220 (3.1). The tax itself is not something it has the power to write off.
CRA Collections in Canada: What They Can Take, and How Fast, click to play video

Day zero: "payable forthwith" is not a figure of speech

Everything in CRA collections is measured from one date: the day your notice of assessment was sent. That notice may have arrived on its own or at the end of a CRA audit, but either way the date on it is the one that counts. On that day the amount becomes legally due in full. The CRA's own payment guidance puts it without any softening: any amount you owe is payable immediately upon assessment or reassessment.

What changes between debt types is not whether the money is owed. It is how long the CRA has to wait before it can take it from you without asking.

For income tax, that wait is written into the Act. Section 225.1 (1) lists six things the Minister "shall not" do until the collection-commencement day: start legal proceedings, certify the debt, require a payment from you or from your bank, demand money from a third party, or direct a seizure. A seventh paragraph sat in that list until it was repealed in 2006. Section 225.1 (1.1) (c) sets that day at ninety days after the notice was sent.

For GST and HST, no such section exists. The Excise Tax Act s. 315 (2) says only that once a notice of assessment is sent, the unpaid amount is payable forthwith. There is no waiting period to run out, because there was never one running.

Day one or day ninety-one: the split almost nobody is told about

This is the single most useful table in the subject, and it comes from the CRA's own collections limitation period page, last revised on 7 April 2026. Find your row before you do anything else.

DebtWhen the clock startsHow long the CRA has90-day pause?
Personal income tax91st day after the notice is sent10 yearsYes
Corporate income tax and COVID-19 business subsidies91st day after the notice is sent10 yearsYes
GST/HST you collected and did not remitThe day after the notice is sent10 yearsNo
Payroll deductions you withheldThe day after the notice is sent6 yearsNo
Employment insurance overpaymentThe day the overpayment happened6 yearsNo
COVID-19 benefit repayment (individual)Date of the decision or redetermination6 yearsNo
Customs debt91st day after the notice is sent6 yearsNo
Canada Student Loans and Apprentice LoansThe day the loan comes into effect6 years, with exceptionsNo
CPP or OAS overpaymentImmediatelyNo limitation periodNo

Two rows in the CRA collections table deserve a second look. The EI row starts from the overpayment itself rather than from any letter, so the clock can already be years old the first time you hear about it. And the CPP and OAS row has no end at all: that debt does not expire.

Consider a restaurant owner in Mississauga reassessed for $41,000 of HST she collected on meals and used to cover payroll during a slow winter. She reads that the CRA has to wait ninety days, plans around it, and three weeks later her operating account is frozen by a requirement to pay. Nothing went wrong with her reading of the rule. The rule she read simply was not the one that applied to her debt.

The payroll and GST/HST rows are the ones that catch business owners. Section 225.1 (6) (b) lifts the restrictions on any amount "required to be deducted or withheld" and remitted, and the reasoning is not hard to follow. That money was never the business's to begin with. It was an employee's income tax or a customer's sales tax, held on the government's behalf. The law treats keeping it differently from being unable to pay your own tax bill, and our guide to the legal issues that cost Canadian businesses most covers why directors carry personal exposure on exactly these amounts.

The clock you can restart without meaning to

Set your debt type and the date on your notice, and the three dates that govern your file fall out of it. Then look at the second panel, because that is where most of the damage gets done.

Your collections clock

Two inputs decide almost everything about a CRA debt: which debt it is, and when the notice was sent. Set both and the three dates that govern your file are derived below.

Collection can begin

September 1, 2024

91st day after the notice

Protected window

90 days

No garnishment, certificate or seizure during it

Collection must stop

September 1, 2034

10 years after it starts

Notice

10 years

June 3, 2024

September 1, 2034

protected window·collectible·today

The ninety-day window in Income Tax Act s. 225.1 applies, so the CRA cannot garnish, certify the debt or seize during it.

What puts the end date back to 10 years from today

The CRA lists these as acts that restart the period. Most of them are things a person does while trying to cooperate. Select one to see where it moves the end date.

This works out dates, not affordability. It does not estimate what the CRA will accept as a monthly payment, because the CRA publishes a budgeting worksheet and keeps its payment-arrangement calculator behind the My Account login without publishing the criteria it applies. Dates from the CRA's collections limitation period page (modified 7 April 2026), Income Tax Act s. 222 and s. 225.1, and Excise Tax Act s. 315. General information as of 2026, not legal advice about your file.

The CRA publishes the list of acts that restart the limitation period, and the striking thing is how ordinary most of them are. Making a voluntary payment. Writing to propose a payment arrangement. Providing a written acknowledgement of the debt. Asking whether you can pay by pre-authorized debit. Filing a notice of objection. Filing an appeal.

Section 222 (6) of the Income Tax Act is explicit about the first one. You acknowledge a tax debt if you promise in writing to pay it, if you make a written acknowledgement of it, or if you make a payment on account of it, including a payment by a cheque that bounces. A fifty dollar cheque that does not clear is enough to restart a ten-year period.

Say a graphic designer in Hamilton was assessed $18,000 in 2019, heard nothing for years, and in 2025 sent $200 with a note offering to pay what she could. She was being responsible. She also moved the end of the CRA's collection window from 2029 to 2035.

None of this means staying silent is the better plan. Interest keeps compounding either way, and a debt that is being actively collected does not become less real by being ignored. It means the decision about when to engage carries a measurable cost, and that cost is easier to weigh before you pick up the phone than after.

The 180-day warning, and the debts that get no warning at all

Before CRA collections moves to legal action, the agency says it will generally do two things: make at least one attempt at a verbal legal warning by phone, and send one written legal warning letter. That warning is then valid for 180 days, and the agency can act at any point inside that window even if your balance changes in the meantime.

The word carrying the weight is "generally". The same page states that where a business owes a payroll or GST/HST remittance debt, the CRA may begin legal actions right after the debt is notified. No call, no letter, no window.

A legal warning is also not a demand letter in the ordinary sense. A private creditor sending a demand letter in Ontario is asking you to pay before it goes to the expense of suing. The CRA is telling you that the step it does not need a court for is now available to it.

What the CRA can do once the window closes

A printed bank statement on a desk under a lamp with one line marked in yellow highlighter, the surrounding figures falling into soft focus

Garnishment, without going to court. Under s. 224 (1) the Minister can require anyone who owes you money, or who will owe you money within the next year, to pay it to the Receiver General instead. The CRA issues this itself as a requirement to pay, an enhanced requirement to pay, or a demand on a third party. Its published guidance for third parties lists what it reaches: salary, wages, commissions and bonuses, money held at a financial institution, expense reimbursements, rent and lease payments, dividends and investment income, accounts receivable, and the proceeds of an insurance claim.

The third party has no discretion. It must comply, and if it keeps paying you instead, it becomes personally liable for the amount up to the full garnishment. A copy goes to you at the same time it goes to them. The document itself sets the amount, either as a fixed sum per payment, a fixed sum per period, or a percentage, and it generally runs for ninety days, a year, or until the debt is paid.

There is a common claim online that the CRA takes a set share of wages. The agency does not publish a universal figure, and the amount appears on the face of the garnishment rather than in any rule you can look up in advance.

Set-off, which happens quietly. Refunds and credits you are owed, including the GST/HST credit, are applied automatically against a balance owing. Nothing needs to be served for this to happen.

A certificate that becomes a judgment. Under s. 223 the Minister may certify the debt and register it in the Federal Court, where it has the same effect as a judgment of that court. That is the step behind what people describe as the CRA putting a lien on a house, and the costs of registering it are recoverable from you as well.

72 hours: the jeopardy order that skips the queue

The ninety-day pause has an exception that removes it entirely. Where the CRA decides there is a risk of not collecting because of the collection restrictions, it can apply to the Federal Court or a provincial superior court for a jeopardy order allowing immediate collection.

The application is made without telling you, and you are not in the room when it is heard. If it is granted, the CRA has 72 hours to serve it on you. You then have 30 days to ask the court to review it, on at least a week's notice to the CRA, and the order stays in force while that review happens. Whatever the court decides at the end is final: neither side can object or appeal further.

This is rare, and aimed at situations where assets look likely to move. It is also the clearest sign that the ninety-day window restricts ordinary collection rather than guaranteeing ninety quiet days.

What "CRA debt forgiveness" actually means

This phrase gets searched constantly, and it describes something CRA collections has no power to do in the form people hope for.

The relief power in s. 220 (3.1) lets the Minister waive or cancel penalties and interest, and only within ten calendar years after the end of the taxation year in question. It says nothing about the tax. There is no provision anywhere in the Income Tax Act allowing the CRA to decide that an assessed tax debt no longer has to be paid because paying it would be hard.

Three things genuinely do reduce or end a tax debt, and none of them is forgiveness:

  • Taxpayer relief, which can remove penalties and the interest on them where circumstances beyond your control, financial hardship, or CRA error caused the problem. On the CRA's current figures the average processing time for these requests is sixteen months, and interest keeps running while you wait.
  • Being right about the assessment, through an objection or an appeal. That reduces the tax because the tax was wrong, which is a different thing from it being excused. Our guide on when a tax lawyer changes the outcome deals with when that argument is likely to succeed.
  • Insolvency, through a consumer proposal or bankruptcy, which can compromise ordinary income tax debt and pauses the limitation clock while it runs. It is a much weaker tool against payroll amounts: s. 227 (4) deems money you deducted to be held in trust for the Crown, and s. 227 (4.1) says that money forms no part of your estate even in bankruptcy, while directors stay personally liable under s. 227.1.

For the penalty and interest amounts themselves, and the RC4288 relief form, our post on CRA penalties and interest is the one that carries the numbers.

What it costs to wait: 7 per cent, compounded daily

The CRA sets its prescribed rates every quarter and publishes them, alongside the annual thresholds we track in our guide to the 2026 tax changes. For all four quarters of 2026, including the quarter running from 1 October to 31 December, the rate charged on overdue taxes is 7 per cent. On the same schedule, the rate the CRA pays an individual on money it owes them is 5 per cent, and 3 per cent for a corporation.

In CRA collections the number that matters more than the rate is the compounding. Section 248 (11) provides that interest under s. 161 (1) is compounded daily, and that unpaid interest itself then compounds daily. A balance left alone does not grow in a straight line.

Two practical consequences follow. A payment arrangement that takes four years to clear a balance is not the same as paying the balance in four years, because the interest is still accruing against the shrinking principal throughout. And a taxpayer relief request that takes sixteen months to decide is sixteen months of daily compounding on a balance you may ultimately not have owed in penalties at all.

The CRA does publish a Monthly Net Income and Expense Worksheet and offers a payment arrangement calculator inside My Account and My Business Account, but it does not publish the criteria it applies when deciding whether to accept what you propose. Anyone quoting you a guaranteed monthly figure the CRA will take is describing something the agency has not made public.

When to bring in a tax lawyer

Most balances in CRA collections do not need one. A modest amount, a clear assessment and the ability to pay it over a few months is a phone call, not a legal problem. The situations where professional help tends to change the outcome are narrower and fairly recognisable:

  • Your debt is payroll or GST/HST, where there is no waiting period and directors can be assessed personally.
  • A requirement to pay has already reached your bank or your employer.
  • The assessment itself looks wrong and the objection deadline has not passed.
  • An old debt may already be past its limitation period, and you are being asked to make a payment that would restart it.
  • The amount is large enough that a consumer proposal or bankruptcy is on the table.
  • You have been served with a jeopardy order, where the review clock is 30 days.

What a lawyer does here is rarely dramatic. It is working out which date applies to your file, whether the CRA is entitled to do what it says it is about to do, and which route costs you least in money and time. Our guide to what a lawyer costs in Ontario sets out the fee models, and the broader tax lawyer guide covers what the work involves, with tax law in Canada giving the wider picture.

You can also raise a service complaint with the Office of the Taxpayers' Ombudsperson, which reviews how the CRA treated you rather than whether the assessment was correct. It is a separate route from an objection, not a substitute for one.

How Olanur helps

We built Olanur because the hardest part of a problem like this is usually not the law, it is finding someone who handles this specific kind of file. Tax debt work is narrow, and CRA collections work narrower still. A lawyer who is excellent at corporate reorganisations may not be the right person for a requirement to pay that landed on your business account yesterday.

Describe what happened in plain language and our matching system puts your situation in front of lawyers who take collections and tax disputes. Matching is free for clients, every professional on our platform is licensed, and the lawyer sets their own fee. You can start from the business law page if the debt sits in a company, or from find a lawyer if it is personal. If you are not sure a lawyer is needed at all, our guide to finding a lawyer in Canada works through that question first.

For personal and corporate income tax, ten years from the 91st day after the notice of assessment was sent. Payroll debt, EI overpayments, customs debt and COVID-19 benefit repayments run for six years. CPP and OAS overpayments have no limitation period and never expire. The period restarts if you acknowledge the debt or make a payment, and pauses during bankruptcy or while you are non-resident.

The CRA can issue a requirement to pay directly to your financial institution without a court order, and it does not need your consent. It does send you a copy at the same time it sends the document to your bank. For personal income tax it cannot do this until 90 days after your notice of assessment, under Income Tax Act s. 225.1, but that restriction does not apply to payroll or GST/HST debt.

No. Section 220 (3.1) of the Income Tax Act lets the Minister cancel or waive penalties and interest, within ten calendar years after the end of the taxation year. There is no power to forgive the underlying tax. Tax debt is reduced by successfully disputing the assessment, or compromised through a consumer proposal or bankruptcy, but it is not written off on request.

The CRA lists making a voluntary payment, writing to propose a payment arrangement, giving a written acknowledgement of the debt, offering security, requesting a reassessment in writing, filing a notice of objection, filing an appeal, and asking about pre-authorized debit payments. Actions the CRA takes also restart it, including issuing a garnishment, applying a refund to the debt, or certifying the debt in the Federal Court.

Seven per cent on overdue taxes for every quarter of 2026, including the quarter running from 1 October to 31 December 2026. Under s. 248 (11) that interest is compounded daily, and unpaid interest itself compounds daily. On the same schedule the CRA pays five per cent on money it owes an individual and three per cent to a corporation.

Generally yes. Before legal action the CRA says it will make at least one attempt at a verbal warning by phone and send one written legal warning letter, and that warning stays valid for 180 days. The exception is a business payroll or GST/HST remittance debt, where the CRA states it may begin legal actions right after you are notified of the debt.

It stops enforcement while you keep to it, which is often the immediate priority, and the CRA lets you schedule pre-authorized debit payments through My Account. The trade-off is that proposing one restarts the limitation period, and interest continues to compound daily on the outstanding balance. Whether that trade makes sense depends on how old the debt is and what the alternative routes look like.

The most useful thing you can do this week costs nothing: find the notice, check the date it was sent, and work out which of the nine debt types you are actually dealing with. Those two facts decide whether you have three months or no time at all, and whether the debt has years left to run or is closer to expiring than the letter suggests. If the answer turns out to be payroll or GST/HST, or if a requirement to pay has already gone out, that is the point to get matched with a tax lawyer quickly, not eventually.

Disclaimer: Olanur is a technology platform that connects users with licensed legal professionals. We are not a law firm and this article does not constitute legal advice. Laws vary by province and circumstances. Consult a qualified lawyer for advice specific to your situation.
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Anita Rouzbeh

Tax & Business Law Contributor

Anita covers Canadian tax law and corporate legal matters, including CRA audits, tax disputes, business compliance, and tax planning for individuals and small businesses.

Tax LawBusiness LawCRA Disputes

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