CARM Compliance in 2026: Importer's Guide to Financial Security, CADs, End of Broker-Bond Release

Every commercial shipment released into Canada now starts a clock. Under CARM, the Commercial Accounting Declaration for goods released under Release Prior to Payment has to be accepted within 5 business days of release, and a CAD that misses that window can draw an automatic $100 late accounting penalty. Since January 1, 2026, the importer of record carries liability for the duties and taxes owed on those goods along with the importer and owner. For importers who spent years letting a customs broker handle the bond, the accounting and the payment, CARM compliance in 2026 means owning those pieces directly or formally handing them off through the CARM Client Portal.

This guide walks through what changed, what the CBSA now expects from importers, and where companies are running into trouble this year.

What CARM Is, and Why It's the Biggest CBSA Change in Decades

CBSA Assessment and Revenue Management overview

CARM (CBSA Assessment and Revenue Management) is the Canada Border Services Agency's system for assessing, collecting and managing duties and taxes on commercial imports. As of October 21, 2024, CARM became "the official system of record for imposing or levying duties and taxes.” It replaced a mix of legacy processes, paper forms and broker-managed accounts with one portal and one set of rules for how importers register, post security, account for goods and pay.

Before CARM, many importers never interacted with the CBSA directly. Their broker posted a bond under the broker's own account, accounted for the shipment and paid the duties, then billed the importer. CARM moves the account, the security and the legal obligations to the importer, with the broker acting under a delegation the importer grants.

Past releases and where we are in 2026

CARM rolled out in phases. Release 1 opened the CARM Client Portal (CCP), where importers could register, view transaction history and see their Statements of Account. The CBSA's onboarding guides for that release date to April 2021. The main release went live externally on October 21, 2024, after an internal launch in May 2024. That release introduced the Commercial Accounting Declaration, importer-posted financial security and the new billing cycle

What matters for importers in 2026 is that the transition measures attached to that launch have now ended: the financial security grace period closed on May 20, 2025, late payment penalties and interest resumed on January 31, 2026, and the broker BN15 transition for commercial goods ran through December 31, 2025.

Why the January 1, 2026 milestone changed everything

On January 1, 2026, amendments to section 17 of the Customs Act came into force, made under the Budget Implementation Act, 2022, No. 1. Under Customs Notice 25-32, the importer of record is "the entity identified as the importer at the time of accounting,” and that entity is now liable, along with the importer and owner of the goods, for duties and taxes owing. The same date marked the end of the transition period that let brokers account for commercial goods under their own BN15.

For importers that had already registered and posted security, January 1 was mostly a legal formality. For importers that had kept relying on a broker's account, it was the date that workaround closed for most commercial shipments.

The End of Broker BN15 Release Model (January 1, 2026)

What changed and why

Under the old model, a broker could account for a commercial shipment using the broker's own business number and program account (BN15) and the broker's own security. The importer's identity mattered for the paperwork, but the financial relationship with the CBSA ran through the broker.

CARM ties each import account to the importer. Commercial importers, including non-resident importers, are expected to register in the CCP, obtain an import program account (BN15) and enroll in RPP before seeking release of goods. The CBSA's stated reason is accountability: the party that imports the goods holds the account, the security and the liability.

A few exceptions remain. Broker BN15 use continues for non-commercial goods and certain other cases described in paragraph 9 of Memorandum D17-1-5. Under the Courier Low Value Shipment (CLVS) program, a broker's BN15 may still be used on certain CADs while the broker gets the importer registered, and Customs Notice 26-13, issued June 12, 2026, extended those operational measures with a 12-month modified compliance approach.

Importer-posted financial security as the new normal

Importers who want their goods released before duties and taxes are paid must post their own financial security in CARM. The broker's bond no longer covers them. The CBSA's 180-day transition period for this requirement was extended to May 20, 2025, and importers without their own security after that date are not eligible for release prior to payment.

Security is posted electronically through the CCP as either an electronic bond (e-bond) from a surety or financial institution, or an electronic cash deposit. Paper forms of security are accepted only in exceptional circumstances.

Consequences of non-compliance (border holds, loss of RPP, LAPs)

An importer without RPP can still import, but the duties and taxes have to be paid at or before release, using a Type C CAD. Unregistered importers, or those that don't meet RPP and security requirements, could experience delays in release. 

Importers who do have RPP can lose it. CARM tracks security use in real time, and failing to keep security adequate "may result in the suspension or revocation" of RPP. 

On the accounting side, a CAD that is not accepted within 5 business days of release can trigger a $100 late accounting penalty applied to the importer's BN15. A CAD accounted for more than 31 days after release may be sent to the Canada Revenue Agency for collection. The grace period on late accounting penalties ended January 19, 2025.

Posting Your Own Financial Security

Electronic bond vs. 100% cash deposit

The two options cost very different amounts of working capital.

An electronic bond (the CBSA calls it a written security agreement) covers 50% of the importer's security requirement, with a minimum of CAN$5,000 per RM business account. The importer pays the surety a premium and the surety guarantees the amount.

An electronic cash deposit covers 100% of the requirement, with no minimum. The cash sits with the CBSA. There's no premium, but the money is tied up for as long as the importer uses RPP.

For both, the maximum security is CAN$10 million per RM business account. Importers whose goods are unconditionally duty and tax-free don't need to post security until duties apply.

Surety provider selection and CARM API connection

E-bonds must come from a provider on the CBSA's published list of financial security providers, and the security has to be submitted electronically through the CCP. When choosing a surety, the practical questions are whether the provider issues e-bonds for CARM today, how quickly it can post or increase a bond, what collateral or financial statements it requires, and how it handles a bond that needs to cover more than one RM account.

If a bond is cancelled, by the importer or the surety, the importer is removed from RPP until new security is posted, "subject to processing timelines.” That makes the surety relationship part of an importer's supply chain risk, since a lapse can affect release at the border.

Calculating your required security amount

The requirement is based on the importer's highest monthly accounts receivable balance from the previous 12 months, calculated for each RM business account. Accounts receivable includes duties and taxes, GST included, plus other debts such as adjustments and interest.

A simple example, using hypothetical numbers: an importer whose highest month in the past year carried CAN$80,000 in accounts receivable would need a CAN$40,000 e-bond (50%) or a CAN$80,000 cash deposit (100%) under the rules above.

Setting Up the CARM Client Portal

Importer registration and BN9 setup

The starting point is a nine-digit Business Number (BN9) from the Canada Revenue Agency. With a BN9, the importer creates a business account in the CCP, then adds the import-export program account (the BN15, ending in "RM"). RPP eligibility requires a BN9, a CCP account, a BN15 import account and enrolment in the RPP sub-program.

Non-resident importers follow the same path and face the same requirements as Canadian-resident importers.

Two-factor authentication and role assignment

Users sign in to the CCP with a GCKey or through a Sign-In Partner. The first person to set up the business account becomes its Business Account Manager, who controls which employees get access and at what level. Other employees are added as Business Account Users.

Assign at least two Business Account Managers where possible. If the only manager leaves the company or loses access, adding users, updating security or changing a broker delegation gets much harder.

Linking business numbers and program accounts

Each RM program account is its own unit for security and billing. A company that imports under several RM accounts, or a corporate group with several legal entities, needs each one linked to the right business account in the CCP and each one covered by security. Before posting a bond, confirm that the RM account on the bond matches the account the broker is declaring on the CAD.

Delegating Authority to Your Customs Broker

The delegation process (importer-initiated, not broker-initiated)

A customs broker can’t submit a CAD on behalf of an importer in the CARM system until the importer delegates them authority in the CARM Client Portal. The delegation of authority (DOA) starts with the importer. Some brokers send a request through the CCP that the importer then approves, but either way, the broker can't grant itself access.

Missing delegations caused real problems during the transition. Transactions sitting in "reject" status because of a missing DOA could be assessed late accounting penalties.

Scope of delegation and limits

Delegation is granted at the program account level, so an importer with several RM accounts can delegate each one separately. Only a licensed customs broker can be delegated to account and pay on an importer's behalf for compensation.

Delegating to a broker doesn't transfer liability. The importer of record remains liable for duties and taxes owed, so the importer still needs visibility into what the broker files.

When and how to revoke delegation

An importer can end a delegation in the CCP, for example when switching brokers. Set up the new broker's delegation before ending the old one so that no shipment arrives without a broker authorized to account for it, then check for open CADs or pending corrections the outgoing broker still needs to close.

The Commercial Accounting Declaration (CAD)

What replaced the B3 and B2 forms

The CAD replaced the B3-3 accounting document and the B2 adjustment request. Importers and brokers submit CADs through the CCP, EDI or the CARM API. The portal accepts up to 1,000 lines per CAD, while EDI and API files can run up to 50 MB, about 10,000 lines.

The two most common types are the Type AB CAD, used by RPP importers accounting after release, and the Type C CAD, used by importers without RPP or that choose to account and pay at release.

Filing windows and corrections

For a Type AB CAD, the CAD must be accepted by CARM within 5 business days of release, with release day counted as day zero and the deadline at 11:59:59 pm EST on the fifth day.

After acceptance, CARM separates two kinds of changes. A correction is a voluntary change made between initial acceptance and 11:59:59 pm on the payment due date, and it is penalty-free. Only RPP importers and their delegated broker can make corrections, and any correction that reduces the amount owed needs supporting documents. After the payment due date, changes become adjustments, which can carry penalties or interest.

The correction window favors importers who check their CADs early. A wrong tariff classification, value or origin claim caught before the due date costs a correction. The same error caught months later becomes an adjustment.

Mass adjustments and bulk processing

Adjustments after the payment due date follow the rules in Memorandum D17-2-1. For importers correcting the same error across many entries, such as a classification applied to a full product line, the bulk route is EDI or API submission through a broker or service provider, since those channels handle much larger files than the portal.

The New Harmonized Billing Cycle

Statement of Account issued on the 25th

The CBSA issues a Statement of Account (SOA) on the 25th of each month, available in the CCP. The SOA includes the duties and taxes from the billing period plus penalties, reassessments and adjustments posted within the billing period. The billing period runs from the 18th of one month to the 17th of the next.

Payment due 10 weekdays after the 17th

Payment is due 10 weekdays (defined as Monday to Friday, inclusive of holidays) after the 17th of the calendar month. Because holidays count as weekdays, a statutory holiday doesn't push the due date back.

Cheques must arrive by 4 pm ET on the due date, while electronic and in-person payments are accepted until 11:59 pm ET. The CBSA accepts Canadian currency only and does not accept EFT, direct deposit, wire transfers or ACH. Balances over $50,000 can't be paid at a port of entry.

Late Accounting Penalty (LAP) triggers and amounts

A late accounting penalty and a late payment penalty are separate charges.

The late accounting penalty applies when the CAD isn't accepted on time. It is a $100 penalty applied automatically to the importer's BN15.

A late payment applies when the SOA balance isn't paid by the due date. Late payment is a contravention under the Administrative Monetary Penalty System (C336), and late payment interest begins the day after the due date. Following the transition period, late payment penalties applied to overdue balances from the January 2026 SOA, effective January 31, 2026, and interest first appeared on the SOA issued February 25, 2026. Unpaid SOAs are referred to the Canada Revenue Agency for collection.

Release Prior to Payment (RPP) Enrollment

Eligibility requirements

To enrol in RPP, an importer needs a BN9, a CCP business account, a BN15 import account, enrolment in the RPP sub-program and posted financial security. RPP lets goods be released at the border and paid for on the monthly billing cycle rather than at the time of release.

Maintaining RPP status

Keeping RPP comes down to three habits: keep security at or above the requirement, file CADs within 5 business days of release, and pay each SOA by its due date. The CBSA can suspend RPP after the third late payment and can also suspend or revoke it based on risk.

Restoration after a lapse

How long an importer is locked out depends on what happened. Revocation for late payment with no claim against security means no RPP eligibility for one year; revocation that involves a claim against security means three years. When a bond is cancelled, the importer is removed from RPP and can be reinstated after posting new security, subject to processing time.

During any gap, shipments move on a Type C CAD with payment at release. Importers should plan cash and broker instructions for that scenario before it happens.

Common 2026 Pain Points and Workarounds

Surety connectivity issues

An e-bond that is approved by the surety but not yet reflected against the right RM account in CARM leaves the importer without RPP in practice. Ask the surety for confirmation once the bond is posted, then check the CCP to confirm the security appears on the correct account before the next shipment. When a bond increase is needed, start well ahead of a seasonal peak.

Multi-BN business structures

Because security is calculated and posted per RM business account, with a CAN$5,000 bond minimum per account, groups with several entities or several RM accounts carry several separate requirements. Some companies are reviewing whether every RM account is still needed. Others are aligning broker delegations so one broker can see all active accounts. Either way, map which entity is the importer of record on each flow of goods before deciding.

Cash flow shock from the new billing cycle

Under the old model, many importers paid their broker on the broker's terms. Now the CBSA bills the importer directly on a fixed monthly schedule, and the full month's duties and taxes come due on one date. Importers using a cash deposit also tie up 100% of their highest month's accounts receivable. Finance teams can reduce the shock by forecasting each SOA from the month's CADs as they're filed and by comparing the cost of a bond premium against the capital locked in a cash deposit.

CARM's correction window rewards getting the CAD right the first time, and classification is where many CAD errors start. Gaia Dynamics’ Classification Engine assigns tariff classifications for any product, for any country, in seconds, so brokers and importers can check codes before the payment due date turns a correction into an adjustment. Book a demo to see how it works with your Canadian entries.

FAQs

Can my broker still post a bond on my behalf?

Not for your own RPP account. Importers must post their own financial security in CARM and can no longer rely on a broker's security. A broker can help you arrange an e-bond with a surety, and broker BN15 use continues only in specific exceptions such as non-commercial goods and certain CLVS cases.

What if I can't get a surety bond?

You can post an electronic cash deposit equal to 100% of your security requirement, with no minimum. Without any security, you can still import by paying duties and taxes at release on a Type C CAD.

How do I check my CARM account balance?

Sign in to the CARM Client Portal. Your Statement of Account is posted there on the 25th of each month, and the portal shows transaction history for your program accounts.

What happens if I miss a payment?

Late payment penalties and interest apply to overdue SOA balances, unpaid balances can be referred to the Canada Revenue Agency for collection, and a third late payment can lead to suspension of RPP.

Do I need CARM if I only ship into Canada occasionally?

If the goods are commercial, yes. The CBSA directs all commercial importers, including non-resident importers, to register in the CCP, obtain a BN15 and enrol in RPP before seeking release. Without RPP, occasional importers can still pay at release on a Type C CAD. Whether a shipment counts as commercial or casual for non-resident importers is covered in Customs Notice 25-01.