CRA indicates that express consent to receiving T3 or T5 slips can be provided as part of the process of downloading them

In 2017-0730761I7, the Rulings Directorate indicated that, given the wording of Regs. 209(3) and (4), financial institutions cannot provide their clients with electronic copies of information slips (e.g., T3s, T5s or NR4s) on a secure website without the written or electronic consent of the clients, even where the T3s etc. have also been provided in written form (subject to a limited exception permitting the provision of T4s in electronic form).

In response to a follow-up query on this, the Directorate stated the required “consent can be granted by the Client on the website itself” and that:

where a Client signs up for online access to a secure website and downloads their tax information from the site, the express consent requirement in subsections 209(3) and (4) would be met provided the Client is duly informed and acknowledges that they are consenting to receive their information slips electronically.

This does not sound any more onerous than acknowledging that you are 19 when you buy wine online.

Neal Armstrong. Summary of 18 October 2018 External T.I. 2018-0768931E5 under Reg. 209(3).