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EFILE and electronic filers

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EFILE is the channel through which a registered professional transmits returns on behalf of clients, and it is governed differently from NETFILE because the person filing is not the person whose return it is. Filers apply, are screened, and hold privileges that CRA can suspend. They carry obligations their clients do not — record retention, a signed authorisation before transmitting, and responsibility for what they send. For an agent, this topic is as much about the boundary as the content: a preparer's question is often about their own registration, their own suspension, or their own software, and those are not the same as a question about a client's return. Knowing where the line falls prevents both unhelpful deflection and disclosure that should not happen.

How to work through this tutorial

This covers the professional channel and where an agent's part in it ends: 1. Learn what EFILE is and how it differs from NETFILE in kind, not just in scale. 2. Learn who can become an electronic filer and how privileges are obtained. 3. Learn the obligations a filer carries, especially the authorisation and retention rules. 4. Understand suspension and what it means for the filer's clients. 5. Learn the boundary: which preparer questions an agent can answer. 6. Work through an example where the preparer's question is really the client's. 7. Check your work against the common errors. 8. Verify every specific against CRA's published guidance before relying on it.

A different kind of service

NETFILE lets a person send their own return. EFILE lets a person send someone else's. That difference is not administrative; it is why the two services have different rules. Because the filer is acting for others, CRA screens who may do it, imposes conditions on how it is done, and retains the ability to withdraw the privilege. None of that applies to an individual filing for themselves, who is accountable only for their own return. The practical consequence is that a preparer has two distinct relationships with CRA: one as a taxpayer with their own affairs, and one as an electronic filer with privileges and obligations. Questions arrive mixed together, and separating them is the first move on these calls.

Becoming an electronic filer

A person or firm wanting to transmit returns for others applies to CRA for EFILE privileges. The application involves a screening process — CRA considers the applicant's suitability, and applicants are subject to checks — and successful applicants are issued the credentials they use to transmit. Privileges are renewed rather than granted once, and CRA publishes the renewal cycle. A filer who has not renewed cannot transmit, which produces a predictable seasonal wave of calls. Not everyone who prepares returns needs EFILE. A preparer who completes returns and gives them to clients to file themselves is not transmitting, and is not in this system at all. Establishing whether the caller actually holds EFILE privileges is worth doing before answering anything about them.

What a filer must do

Three obligations account for most of the questions. **Authorisation before transmitting.** The client must authorise the filer to transmit the return, on the prescribed form, before it is sent. This is distinct from an authorisation to access the client's account information in Represent a Client — a filer may be authorised to transmit a return without being authorised to discuss the account, and the two are separate permissions with separate paperwork. **Retention.** The filer keeps the signed authorisation and supporting documents for the period CRA specifies, and produces them on request. **Responsibility for what is sent.** The filer is accountable for transmitting what the client approved. A transmission that departs from what the client signed is a serious matter, not a clerical one. An agent does not need the detail of these to advise a preparer on them — CRA's EFILE pages carry it — but does need to know they exist, because they explain why the answer to "can you just change it for me" is usually no.

Suspension, and what it means for clients

CRA can suspend or revoke EFILE privileges, and does. The grounds are published and relate to the filer's conduct and continued suitability. What matters for calls is the effect on the filer's clients, because those clients are innocent third parties. A suspended filer cannot transmit, so their clients' returns are not going to be filed through that route, and the deadline does not move because of it. Clients in that position can file another way — themselves, or through another filer — and telling them so is the useful answer. A client asking why their return was not filed is asking about their own return and is entitled to know its status. They are not entitled to information about the preparer's standing with CRA, which is the preparer's business. Keep those apart.

The boundary for an agent

Preparer calls fall into three groups and they are answered differently. **About their own EFILE registration** — application status, renewal, suspension, the credentials they transmit with. This concerns them and can be discussed with them, subject to verifying who they are. **About a client's account or return** — status, balance, assessment. This is the client's information, and the ordinary rule applies: identity, authorisation on that account, and a level covering the request. Holding EFILE privileges is not an authorisation to discuss any client's account. **About their software** — errors, unsupported forms, transmission failures produced by the product. Certification is not support; that is the vendor's. The error to avoid is treating professional standing as a form of authorisation. A well-known accountant transmitting hundreds of returns is, in respect of any individual client's information, exactly as entitled as any other member of the public unless that client has authorised them.

A worked example: the preparer's question, the client's information

Teaching example. The figures below are invented to show the method. They are not CRA figures, and no amount here should be used for a real taxpayer.

The details in this example are invented for teaching. Nothing here should be quoted as CRA's position. Suppose Hélène is an electronic filer with a busy practice. She calls in April about a client, Sam. She transmitted Sam's return, received a confirmation number, and Sam has now called her to say the refund has not arrived. She wants to know whether the return was assessed and where the refund went. The first part of her question is about a transmission she made, and she has the confirmation number. The second part is about Sam's account. Suppose she holds a signed authorisation to transmit Sam's return, and no authorisation on Sam's account in Represent a Client. That is an entirely ordinary situation: she was engaged to prepare and file, not to deal with CRA on Sam's behalf. She is therefore not entitled to be told whether Sam was assessed, what the assessment said, or where a refund of — suppose — $2,340 was deposited. Her professional relationship with Sam is real and is not the authorisation that governs disclosure. What helps her: confirming that a transmission with that confirmation number was received, since that concerns her own filing; explaining that account information needs Sam's authorisation; and explaining how Sam can grant it or check it himself. The lesson: a preparer's entitlement to information about a client is decided by the client's authorisation, not by the preparer's role.

Common errors

Treating EFILE and NETFILE as one service with two names. Treating EFILE privileges as authorisation to discuss a client's account. They are different permissions. Assuming a preparer holds EFILE privileges. Many preparers do not transmit at all. Conflating the authorisation to transmit a return with authorisation to access the account. Separate forms, separate scope. Discussing a preparer's standing or suspension with their client. That is the preparer's information. Telling a client of a suspended filer that their deadline is extended. It is not. Supporting a certified product's own faults. That is the vendor's job. Quoting the EFILE renewal cycle, retention period, or the prescribed authorisation form number from memory. All are published and all are exactly the kind of specific that gets misremembered.

What to verify this tutorial against

This was drafted without a source document, and the specifics here — form numbers, retention periods, renewal cycles, suspension grounds — are precisely the material a model gets wrong. Confirm every one. CRA's EFILE pages for electronic filers are the primary reference: who may apply, the screening and renewal process, the obligations of a filer, and the grounds on which privileges may be suspended or revoked. CRA's guidance on the authorisation a filer must obtain before transmitting sets out the prescribed form, what it authorises, and how long it must be retained. Take the form number from the page. CRA's Represent a Client guidance is the reference for the separate account-access authorisation, and for the distinction this tutorial draws between the two. CRA's NETFILE pages are the reference for the contrast in the first section. CRA's list of EFILE-certified software is published by tax year, separately from the NETFILE list. The level 2 tutorial on Represent a Client in this line carries the authorisation rules this one relies on; check the two for consistency when either is revised.

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