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The National Security and Intelligence Review Agency (NSIRA) recently finished a review of how the Canada Revenue Agency’s (CRA) Review and Analysis Division (RAD) audits charities following serious concerns raised by Muslim-led charities about unfair treatment.
These concerns have been documented in research and advocacy reports, including a Senate report called Combatting Hate: Islamophobia and its Impact on Muslims in Canada. The report pointed out that Muslim charities were being targeted more often than others and recommended a close look at how RAD operates.
This review was done with NSIRA having full access to all the information they needed.
RAD is the part of the CRA responsible for making sure charities are not being used to fund terrorism.
NSIRA’s goal was to check if RAD audits charities fairly and without discrimination following Canada’s laws and the Charter of Rights and Freedoms.
Most charities audited by RAD were Muslim or Sikh. This raised questions about whether RAD might be unfairly targeting these groups.
Some charities were audited even though there was no clear risk of terrorist funding. This goes against CRA’s claim that RAD only investigates the highest-risk cases.
The CRA does not collect enough data about who they audit such as the religion or background of charities making it hard to say for sure whether discrimination is happening.
NSIRA gave six recommendations to help the CRA prevent bias and discrimination including starting to collect data about the charities they audit to make sure the process is fair and transparent.
RAD should only audit charities when there is a clear credible reason related to terrorist funding risks.
The CRA disagreed with collecting more data but NSIRA says this information is important for fair oversight.
NSIRA’s review does not say discrimination definitely happened but it shows there are serious risks and gaps that need fixing.
Making sure that audits are fair and unbiased is key to protecting all charities, building public trust and respecting Canadians’ rights.
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As part of its foreign intelligence mandate, the Communications Security Establishment (CSE) conducts a range of activities and programs, including the collection of foreign signals intelligence in support of the Government of Canada’s intelligence priorities. One such program, despite its significance, had never been subject to internal or external review. To assess its legality, necessity, and reasonableness, NSIRA undertook a comprehensive review of this program.
Given that CSE is not allowed to direct its activities at Canadians or individuals in Canada, the proper conduct of its targeting activities is critically important. In this context, NSIRA observed that target development formed part of the program’s activities, which involved a range of tools and techniques, including the use of SIGINT and open-source resources to conduct research on targets. NSIRA identified deficiencies underscoring the need for further examination of CSE’s targeting framework.
The program involves close collaboration with domestic and international partners, allowing CSE to benefit from shared expertise and resources. However, NSIRA found weaknesses in how these partnerships were managed, especially around information sharing. In some cases, CSE failed to appropriately apply its internal framework for assessing mistreatment risks, as required under the Avoiding Complicity in Mistreatment by Foreign Entities Act.
The review also identified significant gaps in the program’s governance and risk management, particularly in operations conducted jointly with partners. In addition, CSE failed to notify the Minister of National Defence about its intent to undertake certain testing and evaluation activities under the authority of a Ministerial Authorization. In addition, the review uncovered systemic issues in how the program is governed and raised concerns about how CSE reports its activities to the Minister of National Defence. NSIRA found that CSE did not fully explain its testing and evaluation activities, nor did it clearly communicate the extent of its operational involvement.
To address these concerns, NSIRA made 11 recommendations highlighting that CSE:
The report’s findings highlight the essential role of independent review in upholding accountability in national security operations. NSIRA has since received CSE’s responses to its recommendations as part of the review process. As CSE’s foreign intelligence activities continue to evolve, strong governance and full compliance with Canadian laws and policies must remain at the core of its work.
NSIRA has the mandate to investigate the following complaints:
You may file a complaint by sending the appropriate form under rule 5.01 to the NSIRA Registrar by mail or courier as well as the required documents (rules 5.03, 5.04 and 5.05). Should you prefer to file your complaint electronically, NSIRA would require your written consent as you would be providing your personal information.
The first step to a complaint is to determine whether NSIRA has jurisdiction (or the mandate) to investigate the complaint (rule 7). Upon receipt of a complaint, the Registrar will notify you that your complaint is deemed received and notify the respondent government department that a complaint has been received. A designated Member will conduct an independent review of the complaint in order to determine whether NSIRA has jurisdiction to investigate the complaint. Where the designated Member concludes it is necessary in order to make the determination on whether NSIRA may investigate the complaint, the Review Agency may request representations on the Review Agency’s jurisdiction to investigate the complaint from the parties.
In deciding whether it has jurisdiction in a CSE, CSIS or RCMP complaint, NSIRA independently inquires into (and verifies) your allegations. NSIRA provides a letter of decision to the parties on whether NSIRA will investigate the complaint. If a party is dissatisfied with NSIRA’s decision, it can ask the Federal Court to review it. This is done by filing an application for judicial review with the Federal Court of Canada within 30 days after the time the decision was first communicated by NSIRA to the parties. Please refer to the Federal Courts Rules – https://laws-lois.justice.gc.ca/eng/regulations/sor-98-106/.
A Member conducts an independent review of your complaint. NSIRA must determine whether your complaint falls within its mandate.
For example, if you submitted a complaint against CSIS (section 16 of the NSIRA Act) or CSE (section 17 of the NSIRA Act), the Review Agency will decide to investigate the complaint if:
– you have made a complaint to the Director or Chief, as the case may be, with respect to that activity and you have not received a response within a period of time that the Review Agency considers reasonable or is dissatisfied with the response given; and
– the Review Agency is satisfied that your complaint is not trivial, frivolous or vexatious or made in bad faith.
If your complaint against the RCMP has been referred to NSIRA (section 19 of the NSIRA Act), the Review Agency must investigate your complaint if it is satisfied that the complaint is not trivial, frivolous or vexatious or made in bad faith.
If you submitted a complaint relating to the denial or revocation of your security clearance, the Review Agency must investigate your complaint if:
Each NSIRA complaint investigation is conducted by an individual Member (or Members) designated by NSIRA’s Vice-Chair. The Member is the decision-maker in the investigation, assisted by NSIRA’s Investigations section. NSIRA’s Investigations section comprises a legal team of registry staff and legal counsel supporting the NSIRA Members assigned to investigate complaints. The Registry staff liaises with members of the public and complainants and acts as an intermediary between NSIRA and the parties. All letters, email correspondence and all material for complaints received and sent by NSIRA go through the Registrar.
NSIRA’s legal team assists the assigned NSIRA Members in their investigative role as independent decision-makers during an investigation. They ensure that the assigned Member has before them the most complete and accurate factual information relating to a complaint. In the course of an investigation, assigned Members review documentary evidence submitted by the parties and, where they decide it is necessary, will conduct an investigative interview of witnesses and/or will hold a hearing on some or all of the issues. The assigned Member may issue procedural guidance or directions throughout the investigation.
Once the investigation is concluded, the assigned Member will provide a final report to the parties which outlines the findings and/or recommendations NSIRA has made concerning the complaint. NSIRA may make findings, however it does not have the authority to issue binding remedial rulings, such as financial compensation.
The Review Agency will conduct its investigation by reviewing documentary evidence and, if needed, conducting investigative interviews (rule 8).
The Review Agency will first request documentary evidence from the parties (rule 9). This request will be included in the letter of decision that the Review Agency will investigate your complaint. This letter also specifies the Member who has been assigned to investigate your complaint.
Upon reviewing the evidence, the assigned Member will determine whether they need to conduct any investigative interviews of witnesses and/or whether a hearing is necessary.
Your file is not open to the public. Every investigation is conducted in private (section 25(1) of the NSIRA Act). Unless you are represented by counsel or you have provided written consent to be represented by another person, you are the only person present with NSIRA at the interview. If there is a hearing, the responding government party will be present and may present evidence to NSIRA. Whether NSIRA is conducting interviews or hearings, all proceedings are held in private.
You may withdraw your complaint at any time (rule 15.01). You may make your request to withdraw your complaint by notifying the Review Agency in writing. You will receive confirmation that your complaint is now closed.
Yes. You can file a complaint if you reside or are currently outside of Canada.
NSIRA cannot provide legal assistance. However, NSIRA may provide procedural guidance throughout the conduct of the investigation of your complaint to ensure fairness. You may seek representation of a lawyer at your own expense.
You may request an extension by submitting a motion to the Review Agency (rule 3.02). However, you may start by making an informal request for an extension, in writing, to the Registrar (rule 13.03).
The Strategic Plan lays out the NSIRA’s strategic goals and objectives in the further pursuit of excellence in national security review and complaints investigations. This roadmap comprises four key areas and reflects NSIRA’s unwavering commitment to independence, professionalism, transparency and inclusiveness.
The Agency’s dedication to adapting to evolving challenges and innovate is demonstrated by its focus on technological advancement, robust security protocols, continuous learning, and streamlined internal services.
Our roadmap for innovation, growth, and impact—guiding priorities, actions, and outcomes to achieve meaningful progress through 2027.
NSIRA’s Annual Reports provide an overview of our review findings, financial stewardship, and corporate performance each year.
NSIRA’s public statements provide timely updates and insights into our oversight of Canada’s national security activities. They promote transparency and help keep Canadians informed about our work and priorities.
Detailed information on the performance and progress of NSIRA’s ongoing projects and operations.
Learn about how NSIRA’s ensures that all members of the public have equal access to the information they need.
Information about the administration of Access to Information and Privacy Acts within NSIRA
July 30, 2025
The Honourable François-Philippe Champagne, P.C., M.P.
Minister of Finance and National Revenue
Department of Finance Canada
Subject: Notification of NSIRA’s Review of the Financial Transactions and Reports Analysis Centre of Canada’s Information Sharing
Dear Minister Champagne,
I am writing on behalf of the Members of the National Security and Intelligence Review Agency (NSIRA) to inform you that NSIRA has initiated a review of information sharing by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
This review is being conducted pursuant to paragraph 8(1)(b) of the National Security and Intelligence Review Agency Act (NSIRA Act). The NSIRA Act grants NSIRA full and timely access to all information held by reviewed departments and agencies, including classified and privileged information, with the exception of Cabinet confidences.
NSIRA’s review will focus on FINTRAC’s sharing of financial intelligence related to national security. It will examine whether FINTRAC’s information sharing, and related activities comply with applicable legal and policy requirements, as well as the reasonableness and necessity of these activities.
NSIRA will engage with your officials regarding this review. As the review progresses, NSIRA’s review team will be in regular contact with them with requests for information. Such requests may involve documents, system access, written explanations, briefings, interviews, surveys, and any other information that NSIRA determines to be of relevance to this review. This review may also include independent inspections of some technical systems. NSIRA’s expectations for responsiveness are available online at https://nsira-ossnr.gc.ca/
I thank you in advance for your cooperation and support to the independent review process, which is key to transparency and democratic accountability.
Sincerely,
The Honourable Marie Deschamps, C.C.
Chair, National Security and Intelligence Review Agency
Date of submission: September 11, 2023
Date of Online Publication: July 25, 2025
Caroline Xavier
Chief, Communications Security Establishment
Subject: Notification of NSIRA’s Review of CSE’s Vulnerabilities Equities Process
Dear Chief Xavier,
I am writing on behalf of the Members of the National Security and Intelligence Review Agency (NSIRA) to inform you that NSIRA has initiated a review of CSE’s vulnerabilities equities process, known by CSE as the Equities Management Framework (EMF).
This review will examine how CSE manages and governs equities in the context of weighing the benefits and risks of disclosing, versus retaining, information about vulnerabilities found in various kinds of technology. The review may involve other departments and agencies if determined as relevant. The review may look beyond the confines of the EMF, if deemed relevant.
This review is being conducted pursuant to section 8 of the NSIRA Act. The NSIRA Act grants NSIRA full and timely access to all information held by reviewed departments and agencies, including classified and privileged information, except for cabinet confidences. In particular, we expect that CSE will abide by section 9 of the NSIRA Act in enabling us to fulfill our mandate.
Please identify any specific contacts you deem relevant for the subjects addressed by this review. Our review team will be in regular contact with your agency with requests for information. These may include requests for documents, system access, written explanations, briefings, interviews, surveys, and other information NSIRA determines to be of relevance to this review. This review may also include conducting independent inspections of some technical systems or tools.
I thank you in advance for your cooperation and support to the independent review process, which is key to the transparency and accountability we provide to Canadians on behalf of the Government of Canada.
Sincerely,
John Davies
Executive Director, NSIRA Secretariat
Date of submission: September 27, 2023
Date of Online Publication: July 25, 2025
David Vigneault
Director, Canadian Security Intelligence Service
Subject: Notification of NSIRA’s Review of CSE’s Vulnerabilities Equities Process
Dear Director Vigneault,
I am writing on behalf of the Members of the National Security and Intelligence Review Agency (NSIRA) to inform you that NSIRA has initiated a review of CSE’s vulnerabilities equities process, known by CSE as the Equities Management Framework (EMF).
This review will examine how CSE manages and governs equities in the context of weighing the benefits and risks of disclosing, versus retaining, information about vulnerabilities found in various kinds of technology. NSIRA has scoped CSIS into the review to better understand the nature of any involvement CSIS may or may not have in the EMF and related topics. While information from CSIS may be relevant to this review, CSIS is not expected to be a major focus of this review.
This review is being conducted pursuant to section 8 of the NSIRA Act. The NSIRA Act grants NSIRA full and timely access to all information held by reviewed departments and agencies, including classified and privileged information, except for cabinet confidences.
Please identify any specific contacts you deem relevant for the subjects addressed by this review. Our review team will soon be in contact with your agency with requests for information. These are likely to include an introductory briefing, and may include requests for documents, written explanations, and other information NSIRA determines to be of relevance to this review.
I thank you in advance for your cooperation and support to the independent review process, which is key to the transparency and accountability we provide to Canadians on behalf of the Government of Canada.
Sincerely,
John Davies
Executive Director, NSIRA Secretariat
Date of submission: September 27, 2023
Date of Online Publication: July 25, 2025
Mike Duheme
Commissioner, Royal Canadian Mounted Police
Subject: Notification of NSIRA’s Review of CSE’s Vulnerabilities Equities Process
Dear Commissioner Duheme,
I am writing on behalf of the Members of the National Security and Intelligence Review Agency (NSIRA) to inform you that NSIRA has initiated a review of CSE’s vulnerabilities equities process, known by CSE as the Equities Management Framework (EMF).
This review will examine how CSE manages and governs equities in the context of weighing the benefits and risks of disclosing, versus retaining, information about vulnerabilities found in various kinds of technology. NSIRA has scoped RCMP into the review to better understand the nature of any involvement RCMP may or may not have in the EMF and related topics. While information from RCMP may be relevant to this review, RCMP is not expected to be a major focus of this review.
This review is being conducted pursuant to section 8 of the NSIRA Act. The NSIRA Act grants NSIRA full and timely access to all information held by reviewed departments and agencies, including classified and privileged information, except for cabinet confidences.
Please identify any specific contacts you deem relevant for the subjects addressed by this review. Our review team will soon be in contact with your agency with requests for information. These are likely to include an introductory briefing, and may include requests for documents, written explanations, and other information NSIRA determines to be of relevance to this review.
I thank you in advance for your cooperation and support to the independent review process, which is key to the transparency and accountability we provide to Canadians on behalf of the Government of Canada.
Sincerely,
John Davies
Executive Director, NSIRA Secretariat
