CARM (the CBSA Assessment and Revenue Management system) is how the Canada Border Services Agency assesses and collects duties and taxes on commercial imports. It became the official system of record on 21 October 2024, and with it the old B3 coding form was replaced by the Commercial Accounting Declaration (CAD). The key takeaway for anyone shipping commercial goods into Canada: the importer now has to register in the CARM Client Portal itself, delegate access to its customs broker, and, if it wants goods released before duties are paid, post its own financial security. Since 20 May 2025 a broker's security no longer covers its clients. If you are still deciding whether you need a broker at all, start with our guide on broker vs forwarder vs filing yourself. This article covers the Canadian mechanics, as of October 2026.
What CARM changed, and the dates that matter
CARM went live for trade users in stages, and the transition is now finished. The milestones below come from the CBSA's own CARM pages, its 14 May 2025 news release and Memorandum D17-1-5 (Accounting for Commercial Goods, dated 21 October 2024).
| Date | What happened |
|---|---|
| 21 October 2024 | CARM (Release 3) became the system of record for duties and taxes. The CAD replaced Form B3 and Form B2 (adjustment requests). New harmonised billing cycles and payment due dates began. |
| 20 May 2025, 3 am EDT | The financial security transition period ended (originally planned for April 2025, extended by 30 days). From then, importers wanting release prior to payment had to post their own security in CARM. |
| 21 October 2025 | The transition allowance letting brokers account using their own BN15 in additional situations expired (Customs Notice 24-27). Broker BN15 use is now limited to a few cases such as casual high-value goods, trade show goods and auction house imports. |
| Every 20 October | RPP importers receive a notice of their recalculated security requirement. If it went up, the extra security is due by 15 January of the following year. |
That last row is the one to diary right now: the next recalculation notice lands on 20 October 2026, and any increase has to be posted by 15 January 2027 to keep release prior to payment.
Step one: a business number and an import-export (RM) account
Every commercial import must show a valid BN15: the 9-digit business number issued under the Canada Revenue Agency system, plus a six-character import-export program identifier (the "RM" account, for example 123456789RM0001). The CBSA states that most new resident commercial importers can now obtain the 9-digit business number directly through the CARM Client Portal and then register the RM account there. Non-resident importers, resident trusts and some other entity types must still get the business number from the CRA first.
Non-resident importers can import into Canada in their own name, but they still need the BN15, and Memorandum D17-1-5 notes they must get CBSA authorization to keep their books and records outside Canada or at a Canadian address connected to them, such as their broker's office.
Step two: the CARM Client Portal, and why your broker cannot do it for you
The CARM Client Portal (CCP) is the self-service site where the importer's account lives: statements, payments, CAD history, RPP enrolment and financial security. The CBSA is explicit that importers must register their business in the portal themselves and that customs brokers cannot register a client's business on its behalf.
- The person who registers becomes the business account manager (BAM). The CBSA recommends at least two BAMs so the business is not locked out if one person leaves.
- Sign-in is by GCKey or an Interac Sign-in Partner, with multi-factor authentication, and you must keep using the method you registered with.
- Employees request access using the company's 9-digit business number, and a BAM approves them.
Delegating to a customs broker
Once registered, the importer grants its broker a Delegation of Authority (DOA) in the portal. The broker first sends a business relationship request; the importer then chooses what the broker can do (for example submit CADs, view the account or make payments). Under D17-1-5, a broker may submit a CAD on an importer's behalf only if it holds that delegation. Review your delegations whenever you change brokers or add a second one for a different port or mode.
Release versus accounting: two separate events
Canadian clearance has always been a two-step process, and CARM makes the split more visible. Release is the CBSA authorizing the goods to leave customs control. Accounting is the CAD that declares tariff classification, value for duty, origin and tariff treatment, and calculates what is owed. Which route you use depends on whether you have Release Prior to Payment (RPP).
| With RPP (Type AB CAD) | Without RPP (Type C CAD) | |
|---|---|---|
| How goods are released | On minimum documentation, typically a release request transmitted by the broker before arrival | A release and accounting package presented to a CBSA office once the goods are available |
| When the CAD is due | Accepted by CARM within 5 business days of release | At the time of release, prepared in the portal (it cannot be sent by EDI or API) |
| When duties and taxes are paid | On the monthly Statement of Account due date | On release, usually at the port |
| Correction window | Yes, until 11:59:59 pm on the payment due date | No correction period; later changes are adjustments |
For the RPP route, the 5-business-day count starts with the day of release as day zero and excludes weekends, federal statutory holidays and provincial civic holidays. Goods released on Wednesday 14 October 2026, for example, need a CAD accepted by 11:59:59 pm on Wednesday 21 October. Miss it and CARM automatically applies a $100 late accounting penalty to the BN15 used on release. CARM no longer distinguishes high-value and low-value commercial shipments for this deadline.
The CAD you file is treated as a draft until the payment due date. Changes before then are corrections (with a reason code, and supporting documents if the change lowers what you owe). The version on file at midnight after the due date becomes final, and anything after that is an adjustment under Memorandum D17-2-1. That is the Canadian equivalent of what our guide to post-entry amendments describes for other regimes.
RPP and financial security: what you post, and how much
RPP is optional, but without it every shipment means paying duties and taxes at release, usually at a CBSA office. To keep goods moving, most regular importers enrol. The CBSA sets three conditions: register in the portal, enrol in RPP there, and post financial security that meets the amount CARM calculates.
The calculation starts from your highest monthly accounts receivable with the CBSA (duties, GST and surtax) over the previous 12 months. You then choose one of two forms of security:
| Option | Amount required | Who provides it |
|---|---|---|
| Written security agreement (a customs bond) | At least 50% of the system-calculated amount, with a minimum of $5,000 and a maximum of $10 million per BN15 | A financial security provider: surety or fidelity insurers, banks, credit unions or co-operatives, posted electronically in CARM |
| Security deposit | 100% of the highest monthly accounts receivable | The importer, as cash held on its CBSA account |
A worked example: if your highest month in the last year was CAD 80,000 in duties and GST, a bond needs to cover at least CAD 40,000, while a deposit would tie up the full CAD 80,000. The CBSA notes that a deposit may suit businesses that import infrequently, seasonally or in low amounts. Brokers can add credits to an importer's account, but the CBSA states they cannot post a security deposit on behalf of their clients. If you know the US system, note the difference: there is no single-entry bond here, and the formula is not the same as the one in our guide to US customs bonds.
Payment deadlines and the monthly statement
Under CARM every RPP importer is on the same harmonised billing cycle:
- Billing period: goods released from the 18th of one month to the 17th of the next.
- Statement of Account: issued on the 25th, in the portal or by EDI. A daily notice of posted transactions is also available by EDI.
- Due date: 10 weekdays (Monday to Friday, holidays counted) after the 17th. By that rule, goods released between 18 September and 17 October 2026 fall due on Friday 30 October 2026. The CBSA publishes the full list of due dates, so check it rather than counting yourself.
- Late payment: payments received after the due date may attract interest and penalties, and the CBSA says balances unpaid after 30 days trigger a notice of arrears and transfer to the CRA for collection.
- How to pay: online banking using the 15-digit BN RM number, the portal (credit card capped at $4,999.99 per billing cycle, debit or pre-authorized debit), EDI 820, or cheque. All payments must be in Canadian dollars.
Brokers can pay on an importer's behalf through EDI or with a payment delegation in the portal, which is common for non-resident importers. Either way, the debt sits on the importer's account.
Common misconceptions to correct
"My broker is liable if something is wrong"
No. Memorandum D17-1-5 says that although importers may use a customs broker, importers are ultimately responsible for the accounting documentation, the payment of duties and taxes, and later adjustments. The CAD is the official record of what you owe, and audits, re-determinations and penalties follow the BN15 on it. A broker's error is something to settle commercially with the broker; it does not move the CBSA's claim off you.
"I can keep using my broker's bond"
Not since 20 May 2025. Under the old system many importers relied on their broker's security for release. Today, an importer without its own security agreement or deposit loses RPP and pays at release.
"The CAD is just the B3 with a new name"
The data is similar, but the rules around it changed: one 5-business-day accounting deadline regardless of value, automatic late accounting penalties, a correction window before the payment due date, version history replacing the B2, and electronic filing as the default (a paper Form BSF946 is accepted only in exceptional circumstances). One naming quirk: CBSA documents call it both the Commercial Accounting Declaration and the Customs Accounting Declaration. They mean the same thing.
Licensed customs brokers: what they do in Canada
For most dealings any agent can represent a client, but under the CBSA definition only a licensed customs broker may account for goods and pay duties under section 32 of the Customs Act as the importer's agent. The CBSA publishes a list of licensed brokers. A broker typically transmits the release request, classifies goods, prepares and files the CAD, handles corrections and works with the other government departments whose permits apply. Broker fees are not regulated by the CBSA, so compare scope and pricing, and ask who checks tariff classifications and value for duty before the CAD goes in. Courier imports follow their own Courier Low Value Shipment program for goods valued up to CAD 3,300.
CUSMA (USMCA) origin claims, at a high level
Goods that qualify as originating under the Canada-United States-Mexico Agreement can be declared on the CAD under the United States Tariff (tariff treatment code 10) or the Mexico Tariff (code 11). According to the CBSA's CUSMA guidance:
- The certification of origin has no prescribed form. It is a set of minimum data elements and can be placed on an invoice or any other document.
- The exporter, the producer or the importer may complete it.
- The importer must have the certification in its possession when it makes the claim. A blanket certification can cover up to 12 months.
- No certification is required where the value for duty does not exceed CAD 3,300, subject to conditions.
- Importers who did not claim at entry have four years from the date of accounting to claim a refund, and Canada requires records to be kept for six years from the date of importation.
Qualifying is a separate question from paperwork: it depends on the product-specific rule of origin, not on where the goods shipped from. Our guides to rules of origin and certificates of origin cover the mechanics. On the policy side, law firms including Blakes and McMillan reported that the July 2026 joint review ended without a 16-year renewal, with the agreement remaining in force and moving to annual reviews. Separate tariff and surtax measures between Canada and the United States have also changed several times since 2025, so confirm the current treatment for your goods before you price a lane.
What to do next
- Confirm you have a BN15 and that your company, not your broker, is registered in the CARM Client Portal with at least two business account managers.
- Check the delegations your broker holds in the portal, and remove any for brokers you no longer use.
- If you rely on release prior to payment, look at the 20 October 2026 security notice when it arrives and arrange any increase with your surety or bank before 15 January 2027.
- For goods from the US or Mexico, make sure a valid CUSMA certification is on file before the CAD is filed, and keep it for six years.
If you are looking for a broker or forwarder to handle Canadian clearance, more than 29,300 logistics companies are searchable by country and service in the CargoLinked directory, and our roundup of logistics companies in Canada is a starting point. If you have a shipment ready to move, the public requests board lists freight that shippers have posted for forwarders to quote on directly.
This guide is general information based on CBSA publications available in October 2026, including Memorandum D17-1-5 and the CBSA's CARM and CUSMA web pages. It is not legal, tax, financial or customs advice. Rules, thresholds and due dates change; confirm your obligations with the CBSA or a licensed customs broker before you act.
