Search for:

The launch of the Canada Border Services Agency (CBSA) Assessment and Revenue Management (CARM) project has officially been pushed back from October 2023 to May 2024. The regulatory amendments relating to electronic communication and payment, the provision of financial security electronically, and billing cycles that are necessary to support the launch and use of CARM are still on schedule and are planned to come into force in May 2024.

The purpose of CARM is to modernize the collection of duties and taxes for goods imported into Canada. CARM has been introduced through a phased approach. CARM Release 1 was launched in May 2021 and it allowed importers, brokers, and trade consultants to:

  • register their business accounts on the CARM Client Portal (CCP), an online self-service tool that is intended to simply the way industry transacts with the CBSA, by replacing many existing paper based processes and making it easier for the trade community to account for goods that are being imported into Canada;
  • delegate CCP access to employees and third parties (e.g. customs brokers and/or trade consultants) to manage commercial import activities;
  • view their transactions and statements of accounts;
  • request and track a ruling from the CBSA; and
  • pay invoices with new electronic payment options.

CARM Release 2 is intended to expand the features of the CCP by allowing users to:

  • submit, correct and adjust an electronic commercial accounting declaration (CAD) that will replace the current customs coding form (B3) and request for adjustment form (B2);
  • post and monitor security to participate in the Release Prior to Payment (RPP) program as importers will no longer be able to rely on their customs’ brokers bond to participate in the RPP program;
  • register for a Business Number and enrol in various CBSA commercial programs; and
  • electronically manage appeals and compliance actions.

CARM Release 2 will also introduce harmonized billing cycles. The Statement of Accounts (SOA) will be generated on the 25th of each month and generally the payment due date will be 10 weekdays after the 17th of the following month.

In preparation of CARM Release 2, all importers should register and become familiar with the CCP to minimize border delays and benefit from the RPP transition period. One of the biggest changes introduced by CARM is that importers will need to post their own financial security in order to be eligible for RPP and will no longer be able to rely on their customs broker’s bond. However, all importers who register on the CCP before May 2024, will be assigned RPP qualifying status for a 180 day transition period. During this time, commercial importers will be able to obtain RPP of duties and taxes even if they have not yet posted their own financial security.


Julia Webster is a disputes and international trade lawyer. She advises companies on trade remedies, free trade agreements, blocking measures, customs compliance, anti-corruption laws, economic sanctions, AML compliance, supply chain ethics, and cross-border M&A.


Jacqueline Rotondi practices commercial, regulatory, competition and international trade law as a member of Baker McKenzie's Global International Commercial and Trade Groups.

Write A Comment