Executive Summary
In October 2025, the National Security and Intelligence Review Agency (NSIRA) released a landmark review that officially confirmed the Canada Revenue Agency’s (CRA) approach to terrorism-related charity audits is “deeply flawed,” lacks rigour, and introduces significant risks of bias and discrimination, potentially breaching the Charter of Rights and Freedoms.[i] This report validated decades of advocacy by Muslim, Arab, and Sikh communities, whose charitable organizations have faced disproportionate scrutiny based on weak or unsubstantiated leads.[ii]
Click here to download the full report as a PDF
The NSIRA report explicitly identified patterns of religious discrimination in how the CRA’s Review and Analysis Division (RAD) selected charities for terrorism-related audits. It found that 67% of the charities selected for audit during the review period were identified as “Muslim-led,” a targeting pattern NSIRA stated “raises concerns about bias” and suggested a discriminatory outcome even in the absence of direct proof of discriminatory intent. Moreover, the report criticized the CRA for relying on unsubstantiated and vague intelligence sources that disproportionately flagged Islamic charities, and warned that this selection practice “may infringe” Charter rights, including equality and religious freedom. It emphasized that such audits lacked proper documentation or justification and risked violating fundamental rights when focused predominantly on religious groups without transparent, evidence-based triggers.
While the NSIRA review was a necessary step toward accountability, its structural and methodological limitations prevent a full reckoning of the discriminatory nature of the CRA’s auditing regime. Civil society groups have rightly highlighted several persistent gaps that severely undermine the review's comprehensiveness and utility.[iii] Fundamentally, the CRA’s deliberate refusal to collect demographic data on the faith or ethnicity of the charities created a statistical vacuum,[iv] making it impossible for NSIRA to conclusively prove systemic discrimination with quantitative evidence, despite the overwhelming and consistent anecdotal and case-based testimony from affected communities.[v]
Compounding this opacity, the public version of the NSIRA report was heavily redacted, with critical details such as charity names, specific allegations, and the list of "high-risk countries" removed. [vi] This level of censorship prevents independent experts, journalists, and the affected communities themselves from scrutinizing the very evidence and rationale upon which the audits were based, shielding the process from the public accountability and transparency it desperately requires. Furthermore, the review’s findings on procedural failures remain damning even in their public report, confirming that the Review and Analysis Division (RAD) repeatedly launched audits based on weak or unsubstantiated claims, relied on outdated intelligence and overly broad criteria that could capture virtually all Islamic charities, and frequently initiated intensive investigations without a documented rationale.
Finally, and most critically for the victims of this system, the NSIRA review offered no pathway toward justice or reparations. It provided no mechanism for formal apologies, financial compensation for millions in legal fees, or reputational rehabilitation for charities that suffered profound and lasting damage because of the illegitimate reviews. As the International Civil Liberties Monitoring Group (ICLMG) notes, this absence of a remedy mechanism means that organizations that were wrongfully targeted and dismantled are left without recourse, cementing the injustice they endured.[vii]
Our analysis demonstrates that the NSIRA review critically overlooked a fundamental driver of this bias: the CRA audits function not merely as an instrument of religious profiling, but as a state mechanism to suppress political solidarity with oppressed groups abroad. This pattern reflects a deeper failure of Canadian policy: the outsourcing of domestic threat assessments to foreign allies. By adopting the security frameworks of nations like India and Israel, which frame political dissent as terrorism, Canadian agencies import foreign political conflicts onto domestic soil. This process effectively "others" Canadian citizens, treating them not as rights-bearing individuals but as extensions of foreign populations to be managed in the interests of allied governments. The audit regime, therefore, is a key tool in this practice, criminalizing transnational humanitarian and advocacy work that challenges Canada's geopolitical interests at the expense of civil liberties.
[i] National Security and Intelligence Review Agency (NSIRA), Review of Canada Revenue Agency Charities Directorate Audits Related to Terrorism Financing, October 2025.
[ii] Canadian Muslim Public Affairs Council (CMPAC), "CMPAC Statement on the NSIRA Report into the CRA's Targeting of Muslim Charities," October 4, 2025.
[iii] ICLMG. “New watchdog report finds government approach to counter-terror audits of Muslim charities is flawed, raises substantial concerns of bias and discrimination.” 2025. https://iclmg.ca/new-watchdog-report-finds-government-approach-to-counter-terror-audits-of-muslim-charities-is-flawed-biased-and-discriminatory/
[iv] It is important to acknowledge that the collection of such sensitive data carries its own risks of misuse and must be governed by strict privacy safeguards and ethical guidelines. However, the CRA's current approach, total opacity, is the greater evil. It allows systemic bias to flourish undetected and unaccountable, choosing willful ignorance over transparent, accountable governance.
[v] This stands in stark contrast to other government agencies, such as the police, who collect demographic data on arrests, a practice that has been essential for uncovering and proving the systemic over-representation of racialized groups in the criminal justice system. NSIRA. “Race-Based Data and the Collection of Demographic Information within the CRCC and NSIRA.” 2023. https://nsira-ossnr.gc.ca/en/publications/public-statements/race-based-data-and-the-collection-of-demographic-information-within-the-crcc-and-nsira/
[vi] ibid
[vii] ICLMG. “The CRA’s Prejudiced Audits.” 2021. https://iclmg.ca/prejudiced-audits/