CARM for Canadian Importers: Registering on the CBSA Portal and Posting Your Own Bond

If you imported into Canada before October 2024 and you have not looked at the CARM portal since, you are out of compliance and you may not know it. CARM (CBSA Assessment and Revenue Management) became the official system of record for commercial imports, and the rules changed in a way that affects every importer of record, not just the big ones. The headline change: you can no longer ride your customs broker’s bond. You have to post your own financial security to get goods released before you pay duty. This page is general information, not legal or financial advice. CARM has rolled out in phases and the details have shifted more than once, so confirm anything that matters with CBSA or a licensed customs broker before you rely on it.

Here is what actually changed and what you have to do.

What CARM Is and Why It Matters

CARM stands for CBSA Assessment and Revenue Management. It is the Canada Border Services Agency project that replaced the old paper and legacy accounting systems with a single online platform. The public face of it is the CARM Client Portal (CCP), a web account that every commercial importer is expected to have.

CARM reached its mandatory phase in October 2024. From that point, the CARM Client Portal became the system of record for commercial accounting. The old B3-3 coding form and the B2 adjustment request were folded into a new electronic document called the Commercial Accounting Declaration (CAD). Your broker still does most of this work, but the account it all hangs off now belongs to you, not the broker.

The reason this matters for an electronics importer is simple. If you are the importer of record into Canada, CBSA expects to see you in CARM. No portal account means problems posting security, problems delegating your broker, and problems if you ever need to see your own statement of account or dispute a charge.

The Big Change: You Post Your Own RPP Security

This is the part that catches people.

Release Prior to Payment (RPP) is the privilege that lets your goods leave the port before you have paid the duty and GST on them. Without RPP, CBSA can hold the shipment until payment clears, which adds days and storage cost to every entry. Almost every commercial importer wants RPP.

Under the old system, your customs broker’s bond covered RPP for you. You borrowed their security and never thought about it. CARM ended that arrangement. Now the importer of record must post its own RPP financial security to keep the release-before-payment privilege. The rules for the privilege are set out in CBSA memorandum D17-1-8, Release Prior to Payment Privilege.

You have two ways to meet the requirement:

• A financial security bond from a surety, equal to 50% of your highest monthly accounts receivable (your duty and tax owing), with a floor of CAD 5,000 per importer program account (BN15).
• A cash deposit equal to 100% of your highest monthly accounts receivable.

For most importers the bond route is far cheaper than tying up cash. A surety bond at 50% of your peak month, with that CAD 5,000 minimum, is the standard choice. You arrange it through a surety or a broker who places surety business, and the bond is registered against your import program inside the CARM portal.

CBSA gave a transition grace period after the October 2024 cutover so importers were not cut off from RPP overnight while they arranged their own security. That grace window has closed. If you are importing now and you have not posted your own RPP security, you are relying on a privilege you no longer technically hold, and a release hold is the kind of surprise that strands a container.

Step One: Get Your Business Number and RM Program

Before you can register on the portal, you need a Business Number (BN9) from the Canada Revenue Agency with an import-export program account, the RM identifier. This is the same BN15 (nine-digit BN plus the RM and a four-digit reference) that appears on your customs paperwork.

If you already import into Canada, you have this. If you are a non-resident importer setting up for the first time, you get the BN and the RM program from the CRA, not from CBSA. The import-export RM account is what CARM attaches your security and your transactions to. One RM program equals one CARM import program.

A non-resident importer can be the importer of record into Canada without a Canadian physical presence, but you still need the BN with an RM account and you still carry the CARM and RPP obligations. Do not assume your freight forwarder or your broker absorbs that for you. They act on your account. The account is yours.

Step Two: Register on the CARM Client Portal

Registration happens at the CARM Client Portal. CBSA documents the process in its onboarding guidance. The flow has a few moving parts that trip people up, so go in order.

First, an individual logs in. CARM uses a personal login, either a GCKey or a Sign-In Partner (your online banking credentials through Interac). The first person to log in and link the business becomes the Business Account Manager (BAM). Choose this person carefully. The BAM controls the whole account, approves other users, and delegates third parties. It should be someone inside your company, an owner or a trusted finance or operations lead, not your broker.

Second, link your business. You connect your BN9 to the portal. CARM then runs an identity check by asking about a recent transaction on your account, for example a dollar figure from a past CBSA statement or a balance. If you are brand new with no history, CBSA has an alternate path, but expect the verification question if you have imported before. Have a recent statement of account handy.

Third, set up users and roles. Once you are the BAM, you can add employees with their own logins and assign roles such as Program Director or Editor. Keep the BAM role tight and give day-to-day staff narrower roles.

The whole registration is free. CARM itself does not charge you. The cost is the RPP security you arrange separately.

Step Three: Delegate Your Customs Broker

This is the step people forget, and it is the one that breaks clearances.

In the old world your broker filed on your behalf and nobody had to formally connect the two accounts. In CARM, your broker is a separate business in the portal, and you have to grant them access to your account before they can transact for you. No delegation, no entries.

Inside the portal you go to the delegation of authority area, search for your broker (a service provider in CARM terms), and approve their request to act on your behalf. The broker usually initiates the request and you approve it, or you can extend access to them directly. You control what they can see and do.

Coordinate this with your broker before your first post-registration shipment. A common failure pattern: an importer registers the account, makes their own employee the BAM, and then never delegates the broker. The broker cannot file, the shipment sits, and everyone blames customs. Do the delegation the same week you register.

CARM Does Not Replace Your Other Canadian Obligations

CARM changes the accounting and security plumbing. It does not erase anything else you owe at the Canadian border. If you import electronics from China, the rest of the picture is unchanged.

Duty still depends on your tariff classification. Most consumer electronics enter Canada at 0% under Most Favoured Nation treatment and the Information Technology Agreement, but you still classify correctly to the 10-digit code. GST at 5% federal, plus HST in harmonized provinces, still applies to the customs value. ISED radio device authorization (the IC number on the label) is still mandatory for anything with Bluetooth, Wi-Fi, or cellular. None of that lives in CARM. For the full duty, GST, and ISED breakdown, see the Canada customs guide and the country setup walkthrough in importing into Canada.

What CARM does is give CBSA a cleaner view of your account. Your statement of account, your daily notices, your payment due dates, and your security position are all visible in one portal now. That cuts both ways. It is easier for you to see what you owe, and easier for CBSA to see when you are short.

Payment Timing Under CARM

CARM kept the billing cycle that importers were used to but moved it into the portal. RPP importers get a monthly statement of account. Your statement of account is issued on the 25th of each month, and the payment due date for the duties and taxes accounted for in that billing period is 10 weekdays after the 17th of the calendar month, with the exact date shown on your statement.

You can pay through the portal by pre-authorized debit, online banking, or other accepted methods. The point of RPP and your security is that you move the goods first and settle on that monthly cycle rather than paying entry by entry at the border. Miss the payment date and you risk interest and, eventually, a hit to your RPP standing.

Watch your statement inside CARM rather than waiting for your broker to forward a copy. The legal record of what you owe is the portal account in your name.

CARM and Your Customs Broker: Who Does What Now

A licensed customs broker is still worth having, arguably more so under CARM, because the Commercial Accounting Declaration and the portal mechanics are exactly the kind of detail you pay a broker to handle. What changed is the boundary of responsibility.

The broker handles the transactional work: classifying goods, filing the CAD, managing corrections, and advising on duty and GST. You hold the account, the BAM role, and the RPP security. The broker acts inside your portal under the delegation you granted, and you can revoke that access at any time.

One practical upside: because your security and your account belong to you, switching brokers is cleaner than it used to be. You are not unwinding their bond, you are revoking one delegation and granting another. If you want a deeper look at how brokers operate, see working with a customs broker. And if you also import into the US, note that the bond logic there is different and lives in a separate system, covered in the import bond guide.

What Happens If You Ignore CARM

For a small importer the temptation is to assume the broker has it covered and move on. That assumption is where the risk sits.

If you never register, you have no portal account, which means you cannot post your own RPP security, your broker cannot be formally delegated, and you have no direct line of sight into your statement of account or any disputed charge. If you imported on the old broker-bond model and never arranged your own security after the transition grace period closed, your RPP privilege is exposed, and a release hold can leave a container racking up storage and demurrage at the port while you scramble to post a bond.

None of this is hypothetical CBSA behavior. RPP is a privilege tied to security, and CARM is built specifically to track who has posted it. The fix is cheap relative to the downside: register the portal account, make an internal person the BAM, post a surety bond at the 50% / CAD 5,000 minimum, and delegate your broker. That is a day of admin that protects every shipment after it.

Frequently Asked Questions

Is CARM mandatory for importing into Canada? Yes. CARM became the system of record for commercial imports in October 2024. Every importer of record into Canada is expected to have a CARM Client Portal account, delegate any customs broker who acts for them, and post their own Release Prior to Payment financial security to keep the privilege of moving goods before paying duty.

Can I still use my customs broker’s bond under CARM? No. The old arrangement where importers borrowed the broker’s RPP security ended with CARM. The importer of record must now post its own financial security, either a surety bond equal to 50% of the highest monthly amount owing (minimum CAD 5,000 per importer program account) or a cash deposit equal to 100% of that amount. Confirm current figures with CBSA, as the program has changed in phases.

What is RPP and do I need it? RPP is Release Prior to Payment, the privilege that lets your goods leave the port before you pay the duty and GST. Most commercial importers want it because waiting for payment to clear adds days and storage cost. The rules are set out in CBSA memorandum D17-1-8. Under CARM you must post your own security to hold the privilege.

How do I register on the CARM Client Portal? You need a Business Number with an import-export RM program account from the CRA first. Then an individual logs in to the CARM portal with a GCKey or a Sign-In Partner, links the business, becomes the Business Account Manager, and sets up users. CBSA verifies your identity with a question about a past transaction, so have a recent statement of account ready. Registration is free.

Does my broker register me on CARM? No. Your broker is a separate business in CARM. You register your own account and make an internal person the Business Account Manager, then formally delegate the broker so they can transact for you. If you skip the delegation, the broker cannot file your entries and your shipments stall.

Do non-resident importers need CARM? Yes. A non-resident importer that is the importer of record into Canada needs a Business Number with an RM account, a CARM portal account, and its own RPP security, the same as a Canadian importer. Your freight forwarder or broker acts on your account, but the account and the obligations are yours.