CARM Release 2 (R2) went live on October 21, 2024 and fundamentally changed how Canada collects commercial duty and tax. The primary obligation landed on importers of record — every commercial importer now needs a CBSA CARM Client Portal account, a CRA Business Number with an RM import program account, and their own Release Prior to Payment security. Carriers feel the change indirectly: if your consignee isn't CARM-ready, your freight doesn't clear.
TL;DR
- CARM Release 2 went live October 21, 2024. Every commercial importer of record must have an active CARM Client Portal account with a CRA Business Number (RM account) and posted RPP security.
- Carriers don't need CARM accounts unless they act as importer of record — for return equipment, own-parts imports, or in-bond moves where the carrier holds the IOR role.
- The RPP (Release Prior to Payment) bond replaces the old broker-bond arrangement. Importers post surety or cash security directly; face values start around $25,000 for low-volume importers.
- Confirm CARM readiness for every new commercial customer before dispatching a border load. An importer who isn't registered or hasn't posted bond will hold your trailer at the port.
What is CARM Release 2?
CARM — CBSA Assessment and Revenue Management — is CBSA's multi-year program to modernize commercial duty and tax collection. The project launched in phases.
Release 1 (2021) gave importers and brokers access to the CARM Client Portal (CCP) for account management, statement of account viewing, and voluntary portal use. Under R1, the existing broker-bond arrangement stayed in place: brokers continued to remit duty on behalf of importers under their own bond.
Release 2 (October 21, 2024) ended the broker-bond model for commercial importers. Key changes:
- Commercial importers of record must register directly in the CCP using their CRA Business Number with the RM import program account.
- Every importer who wants Release Prior to Payment — meaning goods released before duty is paid, which almost all commercial importers need — must post their own RPP security directly with CBSA.
- Brokers no longer remit duty under their own bond on behalf of importers. Instead, brokers are delegated access inside the CCP and assist with entries, but the duty obligation sits with the importer.
- CBSA issues monthly statements of account through the CCP. Importers pay by the payment due date on a billing period cycle.
For a full overview of where CARM fits in the cross-border compliance stack, see the cross-border trucking Canada-US playbook.
Who has to register in CARM?
Commercial importers of record — mandatory. Any business importing goods into Canada for commercial purposes must register in the CCP. The account is tied to the CRA Business Number with a specific RM import program account designator (e.g., 123456789RM0001). If the importer doesn't have an RM account, they need to register one with CRA before completing CARM onboarding. No exceptions.
Brokers — delegated access. Customs brokers register separately as trade chain partners. Once an importer activates their CARM account, they delegate portal access to their broker inside the CCP. The broker can then prepare accounting entries and manage the importer's account, but the importer is the accountable party.
Carriers — conditional. A carrier hauling freight for a commercial importer has no CARM registration obligation — that's the importer's problem. A carrier needs their own CARM account only if they are themselves the importer of record, which happens in these scenarios:
- Return equipment and trailer repatriation. If a trailer is being re-imported with declared value (leased foreign equipment, for example), the carrier may hold the IOR role.
- Own-parts and own-goods imports. Carrier purchasing parts or supplies from a US vendor and importing them under their own name is an importer.
- In-bond flows where the carrier holds IOR. Certain bonded carrier moves require the carrier to act as importer at the point of final clearance.
If none of these apply, carriers don't register in CARM. But they absolutely need to know whether their commercial customers have.
How does CARM change the carrier's day-to-day?
Most of the CARM workflow impact hits at two points: before dispatch and at the port when something goes wrong.
Pre-dispatch verification. A Montreal broker operating a 15-truck cross-border fleet now asks every new commercial customer a set of questions before accepting the first load: Is your CARM account active? Is your broker delegated in the CCP? Is your RPP bond posted? These aren't paperwork niceties — an importer missing any one of these can hold a trailer at the port while you burn hours.
For established lanes, one-time verification is enough. For spot loads and new customers, a quick CCP confirmation (the importer can share their account status) prevents surprises.
Manifest-to-entry linkage. ACI eManifest filing is unchanged in mechanics — carriers still file through the same channels (EDI, ACI eManifest Portal, or a third-party service). But the entry side is now processed in the CCP, not by a broker under their bond. CBSA links the ACI trip to the accounting declaration the importer files. If the importer's account is inactive or their RPP bond is lapsed, the release gets blocked even after a clean ACI transmission.
Rate confirmation review. Before dispatching a Canada-bound load from the US, confirm the commercial invoice shows the correct importer of record (IOR), and that the named IOR is CARM-registered. A load dispatched with the wrong IOR on the paperwork is an entry amendment at the border — expect a 2-4 hour delay minimum.
Broker delegation. The delegation step inside the CCP is where a surprising number of importers stumble. An importer registers their account but forgets to authorize their broker. The broker then can't file entries on their behalf, and the shipment stalls. Carriers working regular lanes should verify delegation is active, not just that the CARM account exists.
For the step-by-step ACE filing process on the US-bound side, see ACE manifest filing: step-by-step walkthrough.
What is the RPP (Release Prior to Payment) bond?
Release Prior to Payment is the security mechanism that lets an importer get their goods released by CBSA before the duty and tax bill is actually paid. Without RPP security, an importer would have to pay duty at the time of release — impractical for high-volume commercial importing.
Before CARM R2, most importers operated under their broker's bond. The broker posted a blanket bond with CBSA covering their client base, and duty remittance flowed through the broker. That arrangement ended with R2.
Under CARM R2, each importer posts their own RPP security in one of two forms:
- Surety bond. A financial guarantee issued by a licensed surety company. Annual premium typically 1-3% of the bond face value, depending on the importer's financials and claims history. A $25,000 face value bond costs roughly $250-750/year for a creditworthy importer.
- Cash security (financial security deposit). Cash deposited directly with CBSA. No annual premium, but the capital is tied up. Smaller importers with limited credit history sometimes prefer this.
Face value sizing. The RPP bond must cover approximately three months of expected duty and tax liability. CBSA sets a minimum; importers with higher duty exposure post more. A small Ontario manufacturer importing US-made components might post a $25,000-50,000 bond. A high-volume Windsor parts distributor may post $100,000-500,000+.
Why carriers care. If an importer's RPP security is lapsed or insufficient, CBSA can require duty payment at the time of release, which most commercial importers cannot accommodate on short notice. The result: freight held at the port of entry until financial arrangements are made. That's your trailer sitting at the Ambassador Bridge.
Broker vs self-file under CARM
CARM R2 doesn't eliminate customs brokers — it repositions them. Brokers are now delegated agents within the CCP rather than the accountable party. For most commercial importers, that's a distinction without a practical difference: the broker still handles the B3 accounting declaration, classification, and valuation.
When a broker makes sense: The overwhelming majority of commercial importers should use a licensed customs broker under CARM R2. B3 filing requires correct HS classification (10-digit for most goods), valuation under CBSA's methods (transaction value, deductive, computed), and knowledge of which tariff treatments apply (CUSMA, MFN, GPT). Getting these wrong means penalty assessments, amended entries, and sometimes re-determination letters from CBSA.
A Windsor carrier running 30 loads/week of auto parts into Ontario is not going to self-classify HS codes and file B3s — broker cost ($30-80/entry for standard commercial shipments) is a rounding error on the freight revenue.
When self-filing makes sense: Large-volume importers with dedicated trade compliance staff and EDI connections to CBSA sometimes self-file. This requires a significant upfront investment in classification databases, CBSA EDI setup, and ongoing staff training. It pays off at very high transaction volumes (500+ entries/month) or for specialized goods where internal expertise already exists.
For occasional cross-border carriers: If your company rarely acts as importer of record — occasional equipment moves, a handful of own-goods imports per year — don't self-file. Use a broker. The CARM portal and B3 filing process have enough edge cases that a one-time learning investment is not worth it at low volume.
See the CBSA CSA program guide for how trusted-carrier programs interact with broker relationships at the port level.
Common CARM registration mistakes
Eighteen months after R2 launch, these errors keep showing up.
Wrong RM account on the CCP registration. A CRA Business Number can have multiple program accounts — RC (corporate income tax), RT (GST/HST), RM (import/export). CARM requires the RM import program account specifically. Importers who register their RC or RT account in the CCP end up with an account that can't process duty payments. Fix: verify the 9-digit BN plus the two-letter suffix (RM) plus the four-digit account number before submitting.
Broker delegation never completed. An importer registers in the CCP, considers the task done, and calls their broker to proceed. The broker can't access the account because the importer never completed the delegation step inside the CCP. These calls come in on the day a shipment is held. Fix: treat broker delegation as part of the registration checklist, not an afterthought.
Contact email not monitored. CBSA sends statement of account notices, payment due dates, and compliance communications to the CCP account's registered email. At too many companies, that email is a generic inbox no one checks, or it's the address of an employee who left. A missed payment notice starts a 30-day clock toward interest and penalties. Fix: use a monitored accounts-payable address and set a CCP notification delegate.
RPP bond too small for actual volume. An importer sizes the initial bond at the minimum, volume grows, and 8 months later CBSA flags the account for insufficient security. The importer gets a notice, scrambles to increase the bond, and meanwhile any releases are at risk. Fix: review bond adequacy annually against duty spend. Rule of thumb: bond face value should cover approximately 3 months of average monthly duty and tax.
Waiting for a problem to register. Some importers still haven't completed CARM registration as of 2026. They've been getting by because CBSA's enforcement ramp has been gradual. That patience will run out. Carriers who confirm CARM status before accepting a load protect their own operations and signal to customers that compliance isn't optional.
Need help with CARM workflow? BorderPro.ai handles CARM Release 2 submissions and links manifest data directly to entries — ACE manifests included.
Frequently Asked Questions
When did CARM Release 2 go live?
CARM Release 2 went live on October 21, 2024. From that date, every commercial importer of record in Canada was required to have an active CARM Client Portal account with their CRA Business Number (RM import program account) and, for goods released before duty payment, a posted Release Prior to Payment security bond.
Do carriers have to register in CARM?
Not by default. A carrier transporting freight for a commercial importer has no CARM registration requirement — the importer is the accountable party. A carrier must register only if the carrier itself is the importer of record, which occurs for own-equipment repatriation, own-goods imports, and certain in-bond moves where the carrier holds the IOR role. Most carriers should focus on verifying that their commercial customers are properly registered.
How much does an RPP bond cost?
Face value depends on the importer's duty and tax exposure — CBSA requires approximately three months of projected liability as the face amount. Annual premium for a surety bond runs roughly 1-3% of face value. A $25,000 bond costs approximately $250-750/year for a creditworthy applicant. Higher-volume importers with $100,000+ face values pay $1,000-3,000/year or more. Cash security deposits have no annual premium but tie up capital.
Can my broker still handle everything under CARM R2?
Yes, with a structural change: your broker is now a delegated agent within your CARM Client Portal account rather than the accountable party. You need to activate your own CCP account, post your own RPP security, and then delegate portal access to your broker. Once delegation is complete, the broker can continue to file B3 accounting declarations, manage valuation, and handle entry amendments largely as before. The day-to-day experience changes little — the accountability structure changed significantly.
What happens if I haul a load for an importer not registered in CARM?
The shipment will be held at the port of entry. CBSA won't release goods to an importer of record without an active CARM account and posted RPP security. The hold resolves only when the importer completes registration and posts bond — which cannot be done quickly from a truck stop phone. The carrier gets an unpaid detention clock and a damaged customer relationship. Verify CARM readiness before accepting cross-border loads from commercial importers you haven't worked with before.