Since the subsidies were introduced at the beginning of COVID-19, there has always been a relatively short timeline during which entities had to apply for the subsidy. Under the current law, it's 180 days from the end of the qualifying period. This is relevant to the wage subsidy, rent subsidy and the Canada recovery hiring benefit.
Over the course of the past couple of years, it has been the case that the CRA, at times, has received applications that are filed late. The CRA, under the Income Tax Act, has a general discretion to accept certain things on a late basis. They publish a detailed fairness guide setting out the circumstances in which they generally accept certain things on a late-file basis. Consistent with that, they have been accepting some late-filed applications in situations where it would be unfair not to do so. It's a very small number of applications in total in terms of the number of applications they have received.
The subsidy programs are unique relative to other things in the Income Tax Act. This legislative change is really meant to confirm that the CRA does have that discretion, consistent with the broader discretion it has in the Income Tax Act, to accept those late-filed subsidy claims. It's not expected to change their policy or their practice. It's really a retroactive change that is intended to confirm their existing practice.