Statement on the NSIRA Report on the Canada Revenue Agency’s Review and Analysis Division (RAD)

Statement on the NSIRA Report on the Canada Revenue Agency’s Review and Analysis Division (RAD)

November 10, 2025
News

On October 2, the National Security and Intelligence Review Agency (NSIRA) released its report on the Review of Canada Revenue Agency’s (CRA) Review and Analysis Division (RAD).

RAD is responsible for detecting and addressing the risks of the charitable sector being susceptible to terrorist abuse. NSIRA conducted this review to determine if RAD treats charities fairly and without discrimination when conducting audits. This review builds on previous investigations into the RAD, including the Taxpayers’ Ombudsperson’s report, which examined evidence of anti-Muslim bias within the Canada Revenue Agency’s (CRA) Review and Analysis Division (RAD).

For years, Muslim organizations have raised concerns about disproportionate scrutiny and Islamophobia within the auditing processes of the CRA. Many have raised concerns that the audit process is influenced by bias, not credible evidence of wrongdoing. This pattern has created a climate of fear and mistrust among Muslim-led charities, which undermines their ability to serve their communities effectively.

NSIRA’s review of RAD substantiates many of these concerns. Including the following findings, which highlight substantial deficiencies in RAD’s processes:

  • Disproportionate impact: 67% of audited charities are discernibly Islamic, and 19% were Sikh
  • Lack of Rigour: RAD’s processes have led them to audit charities that did not present a credible risk of terrorist abuse.
  • Inconsistent Documentation: There is no consistency in documentation for capturing and assessing risk 
  • Absence of Structured Decision-Making: RAD lacks a consistent approach for evaluating risk and informing decisions. 
  • No Evidence-Based Validation: RAD does not have an evidence-based method of validating the risk indicators that it relies on to justify scrutiny of a charity for terrorism related concerns.
  • Potential for Bias: RAD's selection of specific charities for audit is highly subjective, which makes it susceptible to bias. 

The findings of the NSIRA report are deeply troubling. The lack of rigour and transparency in the decision-making process within RAD is unacceptable, given the severe consequences that an audit or revocation can have on a charitable organization. These deficiencies are particularly concerning, given the disproportionate impact of audits on muslim-led organizations. The NSIRA report displays a clear pattern of systemic and structural bias in RAD audit processes, supporting the need for greater oversight.  

Ensuring there is fairness, accountability, transparency and consistency in the administration of oversight by government bodies is paramount, especially for vital sectors that contribute to community wellbeing, such as the charitable sector. The CRA has taken steps to communicate its audit processes and risk factors in other contexts, and the same commitment to transparency and procedural fairness should be applied to RAD to restore trust in their processes. No publicly funded agency should be conducting reviews using incomplete information or processes that are not informed by adequate information. The concerns raised in the NSIRA report are not new, as the charitable sector has repeatedly called on the government to take action to address concerns raised by Muslim-led organizations about RAD practices. 

We support the recommendations outlined in NSIRA’s report and urge the CRA to implement the following recommendations immediately to ensure fairness and transparency in RAD’s processes: 

Evidence-Based Risk Assessment:

  • Adopt a residual risk model that evaluates charities based on risk mitigation efforts as opposed to assumption-based classifications.
  • Develop and apply an evidence-based method for validating, on an ongoing basis, the risk indicators it relies upon to justify scrutiny of charities for terrorism-related concerns.

Enhance Transparency in Audit Processes:

  • Establish a structured process for charities to appeal and challenge audit decisions and risk classifications.
  • Provide greater clarity into audit criteria and procedures to foster trust and cooperation between regulators and the sector.

Formal Documentation of Decisions:

  • Formally document RAD’s decisions regarding when and on what basis it commences audits.

Structured, Informed Decision-Making:

  • Update RAD’s processes for assessing the risks of terrorist abuse in a charity’s activities to ensure:
    • Risks inform decision-making at all key stages.
    • Indicators are properly weighted and graded.
    • Risk assessments are updated with current intelligence before opening an audit.

A Call for Collaboration 
In addition to these recommendations, we call on the government, the CRA and RAD to work collaboratively with the charitable sector, especially Muslim-led organizations, to ensure anti-terrorist frameworks and audit practices are informed by relevant evidence to mitigate the disproportionate impact on Muslim-led organizations. We urge the CRA to engage in an open dialogue with the sector to ensure the concerns of Muslim-led organizations are heard, understood and addressed through meaningful reform. 

 

Empowering Empathy
Toronto Centre for Community Learning & Development
Board Voice Society of BC
Groundswell Operations Society
Inspirit Foundation
Arlene MacDonald, Charity Advisor & Consultant 
West Neighbourhood House
Oxfam Canada
Vantage Point
Women’s Shelters Canada
Professional Association of Canadian Theatres
Équiterre
Environmental Defence Canada
Cowichan Women's Health Collective
Community Sector Council of Newfoundland and Labrador
ECVO
Community Sector Network of PEI
MakeWay
Pillar Nonprofit Network
Imagine Canada