CRA Nudge Letters & Unnamed Persons Requirements (UPR): What Online Sellers Need to Know

If you sell on marketplaces like Shopify, Amazon, or Etsy, you may see more compliance messages from the Canada Revenue Agency (CRA) in 2025. Some are “nudge” (education/review) letters; others are driven by Unnamed Persons Requirements (UPR) where the CRA obtains transaction data from platforms. This guide explains what those letters mean, what to do next, and where we can help.

Short answer: no. “Nudge” or education letters generally ask you to confirm information or provide documents. A review is not a tax audit; however, you must respond on time and with accurate support. See CRA’s overview: Review of your tax return – after you file.

• Verify legitimacy before sending anything. CRA explains how it contacts taxpayers and how to spot scams: Recognize fraud, scams and tax schemes. For broader scam alerts: Canadian Anti‑Fraud Centre.
• Read the request carefully and note the deadline. CRA’s “what to do if we ask for information” quick guide: What to do if the CRA is asking you for information.
• Gather the exact documents requested (see checklist below) and respond using the channel shown on your letter (for example, Submit Documents, mail, or your CRA account).

• Marketplace/platform gross sales reports and payout statements (Shopify, Amazon, Etsy)
• Payment processor summaries (e.g., Stripe, PayPal) and bank deposits
• Invoices/receipts, refund logs, and sales tax (GST/HST/PST) reports
• Books/ledgers (general ledger, sales, A/R), inventory records, and year‑end working papers

A UPR is a court‑authorized request that lets the CRA obtain information about a group of taxpayers not named individually (for example, sellers on a given platform). CRA explains the tool here: About requirements for information.

In 2025, the Federal Court considered CRA requests directed at e‑commerce platforms. One publicly available decision is: Canada (National Revenue) v. Shopify Inc., 2025 FC 969. These cases illustrate how CRA can lawfully seek aggregate seller data via UPRs.

• Not automatically an audit: CRA may compare third‑party data to your filed returns.
• Expect reconciliation letters: CRA may ask you to reconcile reported platform sales to your tax filings.
• Be ready to explain differences: timing, refunds/chargebacks, shipping, and non‑taxable items.

A UPR is a court‑authorized request that lets the CRA obtain information about a group of taxpayers not named individually (for example, sellers on a given platform). CRA explains the tool here: About requirements for information.

1. Verify the letter and the sender; record the reference number and deadline.
2. Map the CRA request to the exact documents needed (see the checklist above).
3. Reconcile platform reports to your bookkeeping and tax filings (T1 business schedules/T2125, T2, GST/HST, payroll if relevant).
4. Prepare a brief cover note that explains any differences (refunds, fees, currency, timing) and points to the attached schedules.
5. Submit using the secure channel shown on your letter and save proof of submission.
6. “Diarize” follow‑up. If you need more time, contact the office listed before the deadline (see CRA’s guidance linked above).

If you discover omissions or mistakes, consider the CRA’s Voluntary Disclosures Program (VDP). Relief generally requires you to apply before CRA starts compliance action on the same issue. Details: Voluntary Disclosures Program (for taxpayers)

• Assess your letter and confirm exactly what the CRA is asking for.
• Build reconciliations from platform sales and payouts to your returns (income tax and GST/HST).
• Draft clear responses and organize supporting schedules the way CRA reviewers expect.
• Evaluate when VDP or amended filings are appropriate—and the risks/benefits.
• Set up processes so your future filings match third‑party data from platforms.

Questions or ready for help?
Contact Ralph & Levinson Chartered Professional Accountants or call 250‑727‑6444