The Canada Border Services Agency (CBSA) has announced that the implementation of Release 2 of the CBSA Assessment and Revenue Management (CARM) initiative will be delayed until October 2024 for trade chain partners.
To read the announcement in full, visit Government of Canada’s page for the news release.
The clock is ticking. Register for CARM now.
CARM affects all importers. Registration is mandatory. It’s also complex and time-consuming, so starting now is crucial.
All imports into Canada are affected.
If you import into Canada, you must register for the CARM Client Portal and delegate authority to your customs broker before Release 2 goes into effect in May 2024. Whether you have one shipment or many, you will be impacted.
CARM Release 2 introduces a new financial security model whereby all commercial importers must post their own financial security to benefit from the Release Prior to Payment program. To help importers adjust to this new financial security model, a 180-day transition period will be implemented allowing goods to be released prior to the payment of duties and taxes. To qualify for the transition period, importers must have a valid business number (BN15) before the go-live date of CARM Release 2, currently scheduled for May 13, 2024.
You'll face financial penalties.
Failure to register for the CARM Client Portal means that accounting can't be completed on your released shipments. You may incur a $100 late accounting penalty for each transaction until Portal registration, delegation of authority and retransmission of the commercial accounting declaration (CAD) is complete.
The window is closing.
Despite the obvious risk, most importers have yet to comply. Many will experience business disruption. Don’t be among them.
There's a lot at stake.
Business disruption is just the start. There will be disappointed customers, angry carrier partners, and tarnished reputations.
Take these steps immediately.
Register with CBSA and delegate authority to your broker.
You must register your business on the CARM Client Portal and delegate authority to your customs brokers. Delegating authority allows customs brokers to continue to transact with CBSA on your behalf.
Video: CARM Client Portal - Creating an Account
Guide: CARM Client Portal - Onboarding
Provide financial security.
Before CARM, customs brokers could provide financial security on your behalf. Now, all importers must provide their own surety. There are two ways: A bond equal to a minimum of $5,000 or 50% of your highest monthly duties/taxes in the 12 months before CARM Release 2 (whichever is highest). Or a cash deposit equal to 100% of your highest monthly duties/taxes in the 12 months before CARM.
What are my options?
Choose your payment preference.
Once you’ve registered for the CARM Client Portal and secured a bond (or posted your deposit), you’ll need to decide whether you want to pay the Receiver General directly or have your customs broker pay your duties and taxes on your behalf. If you choose to pay the Receiver General directly, you must carefully adhere to the due dates. Failure to remit payment could result in goods being held at the border until payment is received.
CARM: Frequently Asked Questions
What is CARM?
The Canada Border Services Agency (CBSA) is modernizing and streamlining the process of importing commercial goods. Learn more from these three videos and the links below.
Webinars
Our experts have some good advice.
On-Demand Webinars
- Jul 19, 2023CARM Timelines and Requirements
- Nov 16, 2021Surety Requirements: Changes & Impact of Release 2
- Jun 16, 2021Understanding the Changes and Impact of Release 2
- Jun 9, 2021Accessing the Client Portal
- Apr 8, 2021An Introduction to CARM
Attend an upcoming CARM webinar, hosted by the CBSA.
Frequently Asked Questions
What happens if I don’t complete one of the steps by the time CARM is implemented?
Registration must be complete, or the final accounting of your shipments can’t be submitted to CBSA, which will result in the issuance of late accounting penalties per shipment. That means that you must register for the CARM Client Portal and delegate authority to your customs broker(s). CBSA has stressed the importance of registering for the CARM Client Portal well in advance of the May 2024 deadline, to ensure commercial shipments are not disrupted.
CARM also impacts the way importers post financial security with the CBSA.
Although there’s a grace period planned, CBSA encourages importers to obtain their financial security in advance, to minimize disruptions. The process for obtaining a bond can be lengthy.
CARM also impacts the way importers post financial security with the CBSA.
- If you have a BN15 or are registered on the CARM Client Portal before Release 2 goes into effect on May 13, you’ll be able to take advantage of a 180-day grace period for the financial security requirement. This means you’ll be able to import without posting your own financial security for 180 days (6 months). However, if you’re not registered on the CARM Portal prior to the release of your goods, you must do so within five business days of your shipment’s release date so that accounting can be submitted to CBSA. If you fail to complete your registration and delegate authority to your customs brokers within five business days of your goods being released, you’ll incur a $100 late accounting fee for each transaction until Portal registration, delegation of authority and retransmission of the CAD are complete.
- If you obtain a BN15 after Release 2 goes live, you will still be able to participate in the Release Prior to Payment (RPP) program for the 180-day grace period. However, the process for CBSA to input the RPP indicator in its systems will be manual and therefore will take some time. In the time it takes the CBSA to input the RPP indicator, you will not have the benefits of RPP and may need to present a cash entry.
Although there’s a grace period planned, CBSA encourages importers to obtain their financial security in advance, to minimize disruptions. The process for obtaining a bond can be lengthy.
Can my customs broker still pay duties and taxes on my behalf?
Yes, but you must authorize your broker to access your CARM Client Portal account. See Delegation of Authority in the CARM Client Portal for instructions.
Where can I get a customs surety bond?
Livingston can help importers secure their bond, at a competitive rate. For details about Livingston’s bond services, contact [email protected].
You can also contact an approved provider to obtain your financial security (i.e., insurance companies, banks, credit unions, other financial institutions).
You can also contact an approved provider to obtain your financial security (i.e., insurance companies, banks, credit unions, other financial institutions).
What happens if I don’t get a bond or pay a cash deposit by the deadline?
Importers who are registered in the CARM Client Portal before the go-live date for Release 2 (scheduled for May 2024) or have a BN15, will have 180 days to post their financial surety.
If you obtain a BN15 after Release 2 goes live, you will still be able to participate in the Release Prior to Payment (RPP) program for the 180-day grace period. However, the process for CBSA to input the RPP indicator in its systems will be manual and therefore will take some time. In the time it takes the CBSA to input the RPP indicator, you will not have the benefits of RPP and may need to present a cash entry.
If you obtain a BN15 after Release 2 goes live, you will still be able to participate in the Release Prior to Payment (RPP) program for the 180-day grace period. However, the process for CBSA to input the RPP indicator in its systems will be manual and therefore will take some time. In the time it takes the CBSA to input the RPP indicator, you will not have the benefits of RPP and may need to present a cash entry.
Do I need a customs bond for each broker I work with?
No. You can have a single bond to cover all your duties and taxes (across all brokers) or choose to have multiple bonds. What’s critical is that your total surety (all bonds combined) is equal to 50% of your highest monthly duty/tax outlay in the 12 months preceding CARM Release 2, and a minimum of $5,000.
Where do I get a GCkey to sign up for the CARM Client Portal?
All users of the CARM Client Portal must create their individual Portal user accounts using a GCKey or Sign-on Partner.
If you don’t already have a GCKey - apply now.
Additional information on the GCKey is available in the Government of Canada GCKey - FAQ.
Livingston is offering a service to clients, to complete the CARM Client Portal registration. For details, contact [email protected]
If you don’t already have a GCKey - apply now.
Additional information on the GCKey is available in the Government of Canada GCKey - FAQ.
Livingston is offering a service to clients, to complete the CARM Client Portal registration. For details, contact [email protected]
We only import a few times a year, do we need to register for the CARM Client Portal?
Yes. All importers register in the CARM Portal, regardless of the number of shipments and frequency of imports. If you are not registered, you won’t be able provide full accounting and payment of all duties and taxes to CBSA and will incur late accounting penalties.
Registration can be a complex process requiring confidential business and legal information. Please register immediately, delegate authority to your broker, and begin the process to obtain your financial security. Your ability to import without delays depends on it.
Registration can be a complex process requiring confidential business and legal information. Please register immediately, delegate authority to your broker, and begin the process to obtain your financial security. Your ability to import without delays depends on it.
Questions about CARM
For more information on CARM, download Livingston's FAQ or contact us to speak to a representative. We're here to help!