If you import into Canada, your customs broker’s financial security no longer protects your shipments. Since May 20, 2025, every commercial importer must post their own financial security with the Canada Border Services Agency to participate in Release Prior to Payment. Your broker can file your declarations, but the debt to CBSA, and the security backing it, belong to you.
This is the single most misunderstood change in Canadian import compliance, and the consequences show up at the worst possible moment: when a truck is at the border and the goods will not release.
Who is the importer of record, and why does it matter?
The importer of record is the party who accounts for the goods to CBSA and is legally liable for duties, taxes, and the accuracy of the declaration. That is almost always the buyer, not the carrier and not the broker.
CBSA is explicit about where enforcement lands. In the Administrative Monetary Penalty System, penalties for incorrect declarations of value or tariff treatment are applied against the importer of record. Your broker prepared the entry. You own the error.
For non-resident importers (a U.S. company selling DDP into Canada and importing under its own name), this is the same. Acting as importer of record from outside Canada carries the identical obligations as a Canadian entity, including the security requirement below.
What exactly did CARM change?
CBSA Assessment and Revenue Management became the official system of record on October 21, 2024. Under the old model, small and mid-sized importers could clear goods on their broker’s bond. The broker posted security, the broker got the release, you paid the broker, the broker paid CBSA.
That arrangement no longer exists. Under CARM, a customs broker’s Release Prior to Payment security no longer covers commercial importers. To keep getting goods released before duties and taxes are paid, you must:
- Have a business account on the CARM Client Portal
- Post your own financial security under your own importer program (RM) account
- Delegate authority to your broker so they can continue transacting on your behalf
Step three is where importers misread the split. Delegating authority to file is not the same as delegating the obligation to be secured. The filing moves to your broker; the bond stays with you.
Without Release Prior to Payment, there is no deferral at all. Duties and taxes are payable at the port of entry before CBSA will release the shipment; this applies to every entry, every time. For a company running steady cross-border volume, that is a cash-flow problem and a dwell-time problem simultaneously.
How much security do you actually need?
CBSA calculates your requirement from your highest month of accounts receivable (duties, GST, and surtax) over the previous twelve months. From that system-calculated figure, you choose one of two routes:
Written security agreement (surety bond). Must correspond to at least 50% of the calculated amount, with a minimum of $5,000 per importer program account.
Cash deposit. Must be 100% of the highest monthly accounts receivable over the review period, with no minimum.
The practical read: a bond costs an annual premium and leaves your working capital alone. A cash deposit ties up the full amount with CBSA indefinitely, earning nothing. For anyone importing regularly, the bond is the normal choice.
One detail that trips up multi-entity businesses: security is calculated per RM account, not per company and not per broker. If you work with three brokers, you do not need three bonds. If you operate two import program accounts, you need coverage allocated to each.
The annual review that only notifies you if you owe more
This is the trap.
CBSA re-runs the calculation every year. The review period runs from October 20 of one year to October 19 of the next, and the newly calculated requirement is communicated through the CARM Client Portal, effective January 15 (the date by which importers must be compliant).
Here is the part that catches growing companies: CBSA notifies accounts whose requirement went up. If your import volume climbed through the year and you are not logging into the portal, the first sign of trouble can be the loss of Release Prior to Payment privileges in mid-January. At that point every shipment converts to pay-before-release until the security is topped up and processed, and bond processing is not same-day.
Put the October review and the January 15 deadline in your compliance calendar, and check the portal in November regardless of whether you received a notice.
What still lands on you after the goods clear
Release is not the end of your exposure. Three obligations survive the border crossing.
The 90-day correction rule. Under section 32.2 of the Customs Act, an importer who has reason to believe a declaration of origin, tariff classification, or value for duty is incorrect must correct it within ninety days and pay any duties and interest owing. The clock starts the day you receive the specific information (a supplementary invoice showing a higher price, for instance), not the day someone gets around to reviewing it.
A four-year correction window. The obligation to correct ends four years after the goods were accounted for. Records must be kept for six years and produced on request.
Interest and penalties, now live again. CBSA waived late payment penalties and interest through the CARM transition. That ended. Late payment interest began accruing on overdue balances as of January 31, 2026, and appeared on statements of account from February 25, 2026.
What to check this week
- Confirm you have an active CARM Client Portal account with a designated Business Account Manager
- Verify financial security is posted against every active RM account, not just your primary one
- Confirm your broker’s delegation of authority is current, and that it has not lapsed through a staffing change on either side
- Compare your posted security against your highest month of duties and GST in the last twelve months
- Set a reminder for the October review and the January 15 compliance date
If your freight is moving but nobody on your team has opened the portal this quarter, that is the gap worth closing first. A held shipment costs far more than a bond premium.
