Voluntary Disclosure Agreements (VDA): A 2026 Guide to Fixing Past Sales Tax Liability

A growing ecommerce brand adds a new fulfillment warehouse. A SaaS company signs its first customers in a dozen new states. A Shopify seller finally checks its sales-by-state report and realizes it crossed an economic nexus threshold two years ago, and never registered for sales tax anywhere outside its home state. None of this is unusual. It is, in fact, one of the most common discoveries a growing business makes.

If this sounds familiar, the natural next question is what to do about it. Filing everything retroactively on your own can mean surfacing years of unfiled returns and unpaid tax to a state that had no idea you existed. Waiting for the state to find you first is riskier still. Between those two extremes sits a third option that many states make available: a Voluntary Disclosure Agreement, or VDA.

A VDA is not a universal fix, and it does not erase the underlying tax owed. It is a formal process, defined separately by each state, that can limit how far back a state looks and, in many cases, reduce or eliminate certain penalties. Whether a VDA is the right move — and what it will actually accomplish — depends heavily on the state, the facts, and how the exposure arose. This guide explains what a sales tax VDA is, how the process generally works, what varies state by state, and where the informational trail runs out and a professional review becomes necessary.

What Is a Voluntary Disclosure Agreement?

A voluntary disclosure agreement is generally a written agreement between a taxpayer and a state tax authority under which the taxpayer voluntarily discloses previously unreported tax obligations, files required returns and pays the applicable tax and interest for an agreed lookback period in exchange for specified relief, which may include penalty relief and limitations on older periods.

The exact legal structure differs by jurisdiction.

Some states use the term Voluntary Disclosure Agreement (VDA). Others use Voluntary Disclosure Program (VDP) or similar terminology. The terminology should not automatically be assumed to mean that every program has identical legal terms.

The basic concept is straightforward:

Taxpayer identifies historical exposure → approaches the state voluntarily → discloses the liability → agrees to the state’s terms → pays the required amount → becomes compliant going forward.

The potential benefit is that the taxpayer may receive relief that would not necessarily be available if the state discovers the liability through an audit or enforcement process.

That relief can include:

• Waiver or reduction of certain penalties.
• A limited lookback period.
• Relief from assessment of periods before the agreed lookback, where the applicable program provides it.
• A structured process for becoming registered and compliant.

The underlying tax, however, generally remains due. Louisiana’s current VDA guidance, updated July 6, 2026, states explicitly that a VDA does not waive tax due and that tax and applicable interest must be paid.

What Is a Sales Tax VDA?

A sales tax VDA is a voluntary disclosure arrangement addressing historical sales and/or use tax obligations.

This can become relevant when a business has discovered:

• Unregistered sales tax nexus.
• Uncollected sales tax.
• Unfiled sales tax returns.
• Underreported taxable sales.
• Historical ecommerce exposure.
• Remote-seller obligations.
• Marketplace-related compliance issues.
• SaaS or digital-product taxability questions.
• Multistate sales tax compliance problems.

A VDA may involve sales tax, use tax, or both, depending on the state or program. The MTC’s Multistate Voluntary Disclosure Program expressly includes sales/use tax among the tax types that may be addressed.

The distinction between sales tax and use tax can matter significantly. California, for example, maintains specialized voluntary disclosure programs involving use-tax obligations, including a separate out-of-state program.

The important principle is:

A business must determine exactly what tax obligation exists before determining whether a VDA is appropriate.

When Should a Business Consider a Sales Tax VDA?

A business may want to investigate a sales tax VDA when it discovers historical sales tax non-compliance before the state has initiated the type of contact that could make the taxpayer ineligible.

Potential situations include:

1. Historical sales tax nexus

The business discovers that its activities created nexus in a state during an earlier period.

2. Unregistered nexus

The company should have registered for sales tax but never obtained the required registration.

3. Uncollected sales tax

The company had a collection obligation but did not collect tax from customers.

4. Unfiled returns

The business was registered or otherwise obligated to file but failed to submit required returns.

5. Underreported sales

Returns were filed, but taxable activity was omitted or understated.

6. Ecommerce expansion

A business grew from a local or regional operation into a multistate ecommerce seller and did not reassess its sales tax obligations.

7. Marketplace and direct-sales exposure

A seller relied heavily on marketplaces but also made direct sales, potentially creating separate compliance obligations.

8. SaaS or digital-product expansion

A technology business discovers that the taxability of its product differs among states and that historical nexus and taxability need to be analyzed together.

Not every one of these situations automatically qualifies for a VDA. Prior contact with a state, existing registration, or a history of collecting-but-not-remitting tax can all affect eligibility, and those rules are state-specific.

What Happens If You Never Collected Sales Tax?

The answer depends on the state, the type of transaction, the period involved and the taxpayer’s circumstances.

Potential consequences can include:

• Liability for the underlying tax.
• Interest.
• Penalties.
• Required historical returns.
• Registration.
• Additional compliance obligations.
• Potential audit or enforcement exposure.

A VDA may provide a mechanism for resolving some of that historical exposure, but it does not automatically erase the underlying tax.

The distinction between tax that was never collected and tax that was collected but never remitted is especially important.

Several state programs treat collected-but-unremitted tax more harshly. Under the MTC program, sales/use tax collected from customers must be remitted in full and can involve non-waivable penalties or a lookback beginning when the tax was first collected.

Examples from state programs illustrate the point:

• Maine can extend the lookback where tax was collected.
• Missouri can extend its four-year lookback when collected tax was not reported.
• Rhode Island can extend exposure to applicable liabilities where sales tax was collected but not paid.
• Washington provides for an unlimited lookback for collected-but-unremitted retail sales/use tax.
• Texas does not waive interest associated with collected-but-unremitted tax.

Therefore, a business should identify whether tax was collected before estimating its potential VDA liability.

How Does a Sales Tax VDA Work?

There is no single statutory sequence that every state follows, but the process below is directly supported by MTC guidance and multiple individual state programs. (MTC; Iowa DOR; Arizona DOR; Kentucky DOR)

General steps (common across most state programs)

1. Identify the potential liability:  tax type, state, the date the obligation began, whether tax was collected, whether returns were filed, and whether the state has already made contact.
2. Check eligibility: prior contact, existing registration, filing history, audit status, and whether tax was collected but not remitted can all affect qualification.
3. Apply: directly with the state, anonymously through a representative, or through the MTC’s coordinated process for participating states.
4. Negotiate or receive proposed terms: some programs issue a counteroffer rather than simply accepting the initial application.
5. Execute the agreement: the business signs the VDA and agrees to its conditions.

Steps that are state-specific and must be confirmed with the relevant authority

1. Registration: timing and method vary; some states require registration as part of qualifying, others handle it only after the agreement is signed.
2. Determining the exact lookback period that applies to the facts.
3. Calculating the liability under that state’s rules for collected-versus-uncollected tax.
4. Filing and paying the tax and any required interest for the covered periods.
5. Registering for and maintaining ongoing compliance after the VDA is executed.
6. Record retention: states generally retain audit or verification rights for the periods covered by the agreement.

What Is a VDA Lookback Period?

The lookback period is the number of past years a state agrees to review and assess under a VDA, in exchange for not reaching back further. It depends on the state. The MTC is explicit that each state determines its own lookback period based on that state’s laws, policies, and the taxpayer’s specific facts; there is no verified nationwide standard.

These are verified examples, not a nationwide rule. Where a state is not listed, a current, state-specific lookback figure was not verified for this article and should be confirmed directly with that state’s tax authority.

Does a VDA Eliminate Sales Tax Penalties or Interest?

Not automatically, and not uniformly. These three components need to be evaluated separately.

Tax

Generally still owed in full for the agreed lookback period. Louisiana’s July 2026 guidance states plainly that a VDA does not waive the tax due. (Louisiana DOR)

Penalties

Penalty relief is common but not universal or automatically complete:

• Arizona provides penalty abatement after tax and interest are paid on time
• Iowa allows for reduced penalties or other special consideration, at the Department’s discretion
• Kansas and Kentucky waive penalties/late-filing penalties under their programs
• Texas provides relief from penalties, subject to the program’s exceptions
• Washington can waive a substantial share of penalties but not automatically all of them
• Florida generally waives penalties, but a 5% penalty applies to collected-but-unremitted tax absent reasonable cause

Interest

Interest is the component least likely to be waived. The MTC states interest is generally due unless expressly waived by the state. Michigan and Kansas both confirm statutory interest cannot be waived or is due on all tax. Texas is a partial exception; most interest can be waived, except interest tied to collected-and-unremitted tax. (MTC; Michigan Dept. of Treasury; Kansas DOR; Texas Comptroller)

Safe rule of thumb: assume tax and interest are owed, and treat penalty relief as a possible — not guaranteed — benefit that depends on the state and the facts.

VDA vs. Sales Tax Audit

VDA treatment varies by state, so this comparison describes general tendencies supported by the research rather than a guarantee of outcome in any specific state.

Can You Apply for a VDA After the State Contacts You?

Generally, no — prior contact concerning the tax type is one of the most consistent disqualifying factors across state programs, though states define “contact” differently. (MTC)

• The MTC treats filing a return, paying tax, or receiving a state inquiry about the tax type as disqualifying prior contact
• Iowa considers prior contact that could lead to audit or assessment
• Kentucky requires no prior contact from its Department of Revenue or the MTC regarding the requested tax
• Connecticut treats previous contact of any kind by its Department of Revenue Services as potentially disqualifying
• Washington maintains separate, more detailed rules for prior registration versus prior enforcement contact

Because the definition of disqualifying contact differs by state, a business that has already received any communication from a state about its tax status should confirm eligibility with that state — or a professional familiar with that state’s program — before assuming a VDA is still available.

Should You Register for Sales Tax Before Applying for a VDA?

This is one of the most state-specific issues in the entire VDA process, and there is no single safe answer. Registration timing can affect eligibility differently depending on the state, and the correct sequence should be confirmed with that state’s program before taking action.

• California’s out-of-state program actually requires voluntary registration as part of qualifying.
• Florida instructs applicants not to register online if they intend to apply for voluntary disclosure — registration is handled inside the disclosure process instead.
• Michigan states that registration by itself does not affect Voluntary Disclosure eligibility.
• Virginia warns that sending returns or payments prematurely — before consulting the VDA program — may disqualify a business.

Given these differences, a blanket rule like “never register before applying for a VDA” is not accurate and could cost a business the benefits of an otherwise-available program in a state like California. The safe approach is to check the specific state’s current instructions, or work with someone who has, before registering, filing, or paying anything.

Which States Offer Sales Tax VDAs?

The table below reflects the current, publicly verified state of each state’s sales/use-tax voluntary disclosure program as of August 29, 2026. States marked “MTC participant” participate in the Multistate Tax Commission’s National Nexus Program, but that alone does not confirm the state’s individual eligibility, lookback, penalty, or interest terms — those must be verified directly with the state. Entries marked “Not verified” reflect gaps in currently available authoritative sourcing, not an assumption that no program exists.

Important: New Mexico does not have a voluntary disclosure program for its gross receipts tax; it instead accepts MTC applications through a managed audit program, which works differently from a conventional VDA. (MTC Member States)

Sales Tax VDA for Ecommerce Businesses

Marketplace facilitator laws require platforms such as Amazon, Etsy, and Walmart Marketplace to collect and remit sales tax on facilitated sales in most states. But the Streamlined Sales Tax Governing Board is explicit that marketplace sellers may still have independent registration and filing obligations, and that a seller making both marketplace and direct sales may need to register on its own if its direct-sale activity meets a state’s remote-seller threshold. (Streamlined Sales Tax Governing Board)

Two statements are not supported by current research and should not be relied on:

• “Amazon FBA inventory automatically creates nexus in every state” — this requires an individual, state-by-state analysis of where inventory is actually stored.
• “Amazon collects the tax, so an Amazon seller has no historical sales-tax exposure” — direct-to-consumer and multichannel sales are not covered by marketplace collection.

Hypothetical Example: Amazon FBA plus a direct Shopify store

A seller does 80% of its volume through Amazon FBA, with inventory spread across a dozen fulfillment centers, and 20% through its own Shopify storefront. Because Amazon collects and remits tax as the marketplace facilitator, the FBA sales are generally covered in states with marketplace facilitator laws. The Shopify sales are a different question: if the seller has crossed an economic nexus threshold in a state through the combination of FBA presence and direct sales, and never registered for the direct channel, that gap is exactly the kind of exposure a VDA is designed to address.

Hypothetical Example: A multichannel seller expanding fast

A home-goods brand starts on one marketplace, then adds its own site, a wholesale channel, and a second marketplace within eighteen months. Each channel and each new state adds its own nexus and taxability questions. By the time the founder reviews the full picture, the business has plausible historical exposure in several states — some from direct sales, some from wholesale, and some from inventory placement. This is the kind of multichannel, multistate pattern where a VDA is most often considered, precisely because the exposure did not come from one clean, easily explained event.

Sales Tax VDA for SaaS Companies

For SaaS companies, nexus and taxability have to be analyzed as two separate questions. Nexus asks whether a state has a basis to require registration at all. Taxability asks whether the specific product is subject to tax in that state — and the answer varies significantly. (Utah State Tax Commission; Washington DOR; Colorado DOR)

• Utah’s official guidance treats remotely accessed prewritten software — including SaaS and cloud computing applications — as taxable when used in Utah.
• Washington separately classifies digital automated services, including SaaS, as retail sales, and adjusted the tax treatment of certain software and IT services effective October 1, 2025.
• Colorado’s official guidance has historically treated application service providers and SaaS differently from other electronically delivered products.

Because SaaS taxability is not consistent nationwide, a claim like “SaaS is taxable in every state” or “SaaS is exempt in every state” is not supportable. A SaaS company evaluating VDA exposure needs a state-by-state review of both nexus and taxability, along with the effective date any relevant rule changed — since a product that wasn’t taxable in a state two years ago may be taxable there today.

Hypothetical Example: A subscription analytics platform

A B2B SaaS company grows quickly and picks up customers nationwide almost from day one. Years later, its finance team realizes it has likely crossed economic nexus thresholds in over a dozen states — but its product is only taxable as SaaS in some of them. Sorting out where nexus exists, where the product is actually taxable, and how far back exposure runs is a multi-layered analysis, and it’s the kind of fact pattern where several states’ voluntary disclosure programs may apply very differently to the same company.

What Information Is Needed for a Sales Tax VDA?

Exact documentation requirements vary by state, but based on the information multiple state programs request, a business preparing to evaluate a VDA should generally be ready to identify:

• Every state where nexus may exist, and the date each nexus trigger occurred (economic threshold, inventory placement, employee location, etc.)
• Whether sales tax was collected on transactions in each state, and if so, whether it was remitted
• Whether any returns have been filed, and for which periods
• Current registration status in each relevant state
• Any prior contact, correspondence, or notices received from a state’s tax authority
• Sales data by state and by channel (marketplace vs. direct vs. wholesale), organized by year
• Product or service taxability determinations for each state under consideration

How Much Does a Sales Tax VDA Cost?

There is no verified industry-average cost figure for a sales tax VDA, and any specific number should be treated with skepticism — the total cost depends entirely on the facts. The components that typically make up the total cost are:

• The underlying tax owed for the agreed lookback period
• Interest, which is due in most states regardless of penalty relief
• Any penalties that are not waived under the specific state’s program
• Professional fees for the nexus analysis, liability calculation, and negotiation of the agreement
• Ongoing compliance costs once the business registers and begins filing prospectively

Common Sales Tax VDA Mistakes

• Treating VDA rules as uniform nationwide, when state programs differ materially on eligibility, lookback, penalties, and interest
• Registering — or not registering — based on a rule that applies to a different state than the one actually at issue
• Assuming penalties are always waived, particularly on collected-but-unremitted tax
• Assuming interest is waived, when it is due in most verified state programs
• Assuming the lookback period is always three or four years, when verified examples range more widely and can be extended for collected tax
• Treating collected-but-unremitted tax the same as tax that was never collected — several states extend the lookback or apply stricter treatment specifically because the money was already in hand
• Assuming marketplace facilitator collection eliminates every seller obligation, when direct and wholesale channels are typically not covered
• Confusing nexus (whether a state can require registration) with taxability (whether the specific product is taxed there)
• Waiting too long to evaluate exposure — VDA eligibility generally depends on acting before the state makes contact

2026 VDA Developments Businesses Should Watch

The Streamlined Sales Tax proposal above is still in draft form. Any specific terms — including an often-cited 24-month lookback figure that traces back to earlier 2024 proposal documents — are not verified as the final 2026 version and should not be treated as current law.

Sales Tax VDA Checklist

Before Applying

• Identify every state where nexus may exist and when it began
• Determine whether tax was collected but not remitted, or never collected at all
• Check current registration status in each state under consideration
• Confirm no prior contact exists with the relevant state about this tax type
• Research that state’s specific eligibility rules, lookback, and registration sequence before taking any action

During the VDA

• Submit the application through the correct channel (direct, anonymous, or via the MTC)
• Calculate the liability accurately for the agreed lookback period
• Review any proposed terms or counteroffer before signing
• Confirm which penalties and interest, if any, are being waived under the specific agreement

After the VDA

• Register in the state per the agreement’s terms
• File and pay the tax and interest due for the covered periods
• Establish ongoing collection, filing, and remittance going forward
• Retain records — states generally keep audit/verification rights for the covered periods
• Continue monitoring nexus in other states, since resolving one state’s exposure does not address the rest

What Happens After a VDA?

Once an agreement is executed, the work is not finished. The business generally needs to register in the state (on whatever timeline the agreement specifies), file the agreed returns, and pay the tax and any required interest. From that point forward, ongoing compliance — correct rate collection, on-time filing, and remittance — becomes an active obligation, not a one-time event.

It’s worth being direct about one point: resolving historical exposure in one state through a VDA does not eliminate future compliance obligations, and it does not address exposure in any other state where the same underlying nexus or taxability issue may exist. A VDA closes a specific chapter for a specific state and tax type — it is not a permanent solution to multistate compliance.

When Should You Get Professional Help?

Sales tax automation software has genuinely improved compliance — rate calculation, return preparation, and threshold tracking are all faster and more reliable than they were a decade ago. But software works from the rules it has been programmed with, and it stops well short of judgment calls that carry real financial and legal consequences. It cannot tell you whether your specific product is taxable in a state with ambiguous digital-goods rules, whether registering now versus after a VDA application changes your outcome, or how a state will treat collected-but-unremitted tax on a specific fact pattern.

Professional guidance tends to matter most when:

• Multiple states are involved and the eligibility rules differ across all of them
• Historical exposure is significant or spans several years
• Records are incomplete or sales data isn’t cleanly broken out by state and channel
• A state has already made contact, which changes — and may eliminate — VDA eligibility
• Taxability is genuinely unclear, as is common with SaaS, digital products, and bundled services
• Marketplace and direct-sales channels overlap and need to be untangled

Regardless of how sophisticated the underlying automation tools are, the decision of whether, when, and how to disclose historical sales tax exposure to a state is ultimately a judgment call that benefits from an experienced human reviewing the specific facts — not a setting toggled in a piece of software.

How My Sales Tax Firm Can Help

Reading about Voluntary Disclosure Agreements is a reasonable first step. Deciding whether one applies to your specific facts — and getting the sequencing right in the state or states involved — is where the details in this guide stop being enough on their own. Every example above underscores the same point: the right move in one state can be the wrong move in another, and software that tracks thresholds cannot tell you which is which.

My Sales Tax Firm works with ecommerce sellers, SaaS companies, and multistate businesses to:

• Analyze nexus across every sales channel — marketplace, direct, and wholesale
• Assess historical exposure and distinguish collected-but-unremitted tax from tax that was never collected
• Research current VDA eligibility in each relevant state before any registration or disclosure step is taken
• Prepare and manage VDA documentation and applications
• Handle registrations and prepare ongoing returns once terms are settled
• Establish a compliance process so the same exposure doesn’t resurface in the next state you expand into

If you’ve discovered a gap in your sales tax history — or you’re not sure whether one exists — a free consultation with our team is a low-friction way to find out where you actually stand before deciding on next steps.

Conclusion

A Voluntary Disclosure Agreement can be one of the more manageable ways to resolve historical sales tax exposure, but it is not a one-size-fits-all fix, and it is not free. The tax itself is typically still owed, interest is usually due, and the specific rules governing eligibility, lookback, and penalty relief differ meaningfully from state to state. What consistently matters is getting the sequence right: understanding where nexus actually exists, distinguishing collected-but-unremitted tax from tax that was simply never collected, and confirming a given state’s current eligibility rules before registering, filing, or disclosing anything.

For a business discovering historical exposure in one state, the analysis rarely stops there — the same gap in monitoring that created one state’s exposure often exists in others. Treating a VDA as the end of the process, rather than the start of an ongoing compliance discipline, is one of the more common ways businesses end up back in the same position a few years later.

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43. Delaware Division of Revenue — Doing Business in Delaware — Gross Receipts Taxes. https://revenue.delaware.gov/business-tax-forms/doing-business-in-delaware/step-4-gross-receipts-taxes/ (Current page; accessed Aug 29, 2026)
44. New Hampshire Department of Revenue Administration — Does New Hampshire Have a Sales Tax?. https://www.revenue.nh.gov/faq/does-new-hampshire-have-sales-tax (Current page; accessed Aug 29, 2026)
45. Montana Department of Revenue — Sales Tax Guidance for Montana Business and Residents. https://revenue.mt.gov/taxes/general-sales-tax (Current page; accessed Aug 29, 2026)
46. Streamlined Sales Tax — State Taxability Matrix. https://www.streamlinedsalestax.org/Shared-Pages/State-taxability-matrix (Current system; accessed Aug 29, 2026)

Note: Where a specific state’s current lookback, penalty, or interest terms could not be verified through an authoritative source during this research pass, that state is marked “Not verified” in the tables above rather than described. Businesses should confirm current terms directly with the applicable state tax authority before relying on this article for a specific compliance decision.