The gateway to support
Some lower-income Canadians have no obligation to file a tax return but still need one to receive benefits and credits. For a household, that makes filing a gateway to income even when there is no tax liability to settle. Taxpayers’ Ombudsperson François Boileau’s October 5 appeal to parliament concerns that gateway. Bill C-31 proposes easier automatic filing; Boileau is asking for safeguards that preserve timely, uninterrupted access to support.[1]
Reducing the work of preparing a return offers this group a concrete benefit. The Canada Revenue Agency’s existing SimpleFile service requires explicit consent. The proposed deemed-filing route lets the agency file for certain people without their consent or involvement. Its attraction is straightforward for someone who needs a return to obtain support: the agency takes on the task at the entrance. My distributional question is where that convenience turns back into a responsibility for the person to keep track of the system.[1]
The cost of convenience without notice
The ombudsperson’s first concern is timing. The bill does not prescribe when a person must be notified or when the agency must file on their behalf. The office identifies a risk of interrupted benefit payments. Notification therefore matters to the use of an entitlement: knowing the stage of the filing process gives the recipient a basis for following the continuity of support. Handing the form to the agency leaves a household exposed if the timetable remains uncertain.[1]
The second concern is stranger. Eligibility requires a person not to have filed in at least one of the previous three tax years. According to the office, repeated filing on the person’s behalf eventually removes eligibility for that automatic route. A rule bringing a non-filer into the system creates another transition problem after sustained participation. For someone who struggles to navigate access independently, knowing which route remains available after the agency’s repeated filings matters as much as the initial admission.[1]
Who carries the burden of approval?
Boileau favors pre-filled returns through CRA accounts. The agency plans to launch this service in March 2027; the taxpayer reviews and approves a return using information the agency already holds. The office expects it to reach millions more people than deemed filing. Review also addresses the concern about issuing benefits on inaccurate information. Yet a route requiring approval needs to be assessed with attention to both the person who can complete that step and the person who struggles to do so.[1]
The strongest case for deemed filing remains persuasive: removing the need for participation reduces a barrier to receiving support. Pre-filled returns give the individual control while retaining an approval step. Choosing between these designs has different implications even within the lower-income group. I find a count of forms prepared by the agency an incomplete measure of convenience. The household measure is uninterrupted receipt of support and how the work of correction or switching routes is distributed. Boileau’s concerns about notice, eligibility and accurate information bring the debate back to that measure.[1]