TL;DR: Canadian carriers who import goods on their own account must be enrolled in the CBSA Assessment and Revenue Management (CARM) portal — with BN15 registration and financial security posted — or face clearance delays at the border. If your broker still handles this, confirm the delegation is in place in the Client Portal today.
The CBSA's multi-year customs modernization project has reached the stage where the legacy paper-and-phone processes are gone. CARM is now the live system of record for commercial import accounting in Canada. If you have not completed enrolment, you are not operating on borrowed time — you are already behind.
This guide cuts through the regulatory language and tells you exactly what to do, in what order, and what happens if you don't.
What Is CARM Phase 3?
CARM — the CBSA Assessment and Revenue Management system — is Canada's replacement for the decades-old Customs Automated Data Exchange (CADEX) and paper-based release prior to payment processes. CBSA launched the project in stages. Phase 1 introduced the Client Portal. Phase 2 (October 2024) made portal registration mandatory for trade chain partners and introduced new duty accounting rules. Phase 3 is the final enforcement step: the transition period that allowed importers to operate without a posted financial security bond has ended, and CBSA now enforces the full RPP (Release Prior to Payment) framework for all commercial importers.
Under the previous system, a broker's existing bond could cover your shipments by default. That automatic coverage is gone. Every importer of record — including carriers who import on their own account — must now hold their own financial security or formally delegate authority to a licensed customs broker who holds the security on their behalf. The CBSA source page for the program is at https://www.cbsa-asfc.gc.ca/services/carm-gcra/menu-eng.html.
What Is the Deadline Carriers Must Hit?
CBSA has not published a single fixed calendar date visible across all public pages — the cutover is described as a rolling enforcement ramp-up within the current Phase 3 window. What is documented is the enforcement mechanic: CBSA is applying a 30-day correction period after which importers who have not posted adequate financial security will face hold-for-payment processing rather than release-prior-to-payment processing at the border.
In practical terms this means:
- If you are enrolled with security posted, your freight releases on the normal duty-accounting cycle.
- If you are enrolled but security is inadequate, you may still clear, but CBSA can demand payment before release on individual shipments.
- If you are not enrolled at all, your shipments route to the examination bay pending manual processing, adding hours or days to every crossing.
Given that this is a breaking article, check Customs Notice 25-32 (available through the CARM portal news feed) for the most current enforcement dates applicable to your importer account type. The 30-day window referenced in CBSA guidance has already started for most commercial importers.
Note that this enforcement timeline is separate from — and compounding on top of — the tariff volatility Canadian cross-border carriers are already managing in 2026. For context on that environment, see our guide on how US-Canada tariffs are affecting trucking rates and carrier strategy.
What Do I Need to Do This Week?
Work through this checklist in order. Each step gates the next.
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Confirm your BN15 exists and is active. Your Business Number (BN) from CRA is a 9-digit root number. CARM requires the 15-character import/export sub-account (BN + "RM" + 4-digit suffix, e.g.
123456789RM0001). Log into the CARM Client Portal with your My Key credential or GCKey. If your BN15 does not appear, you must register it before any other step. -
Post your Release Prior to Payment (RPP) financial security. This is a bond or cash deposit held against your duty liability. The minimum amount is tied to your import volume — small importers typically post $5,000–$25,000; high-volume importers may be required to post significantly more. Your customs broker or a surety provider can arrange the bond. Upload the security instrument through the portal under the "Financial Security" section.
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Set up broker delegation in the Client Portal. If a licensed customs broker manages your clearances, you must formally grant them delegate access in the Client Portal — they cannot act on your CARM account without it, even if they have been filing B3 entries for you for years. Go to: Portal → Business Account → Delegates → Add Delegate. Provide your broker's BN15. They will accept the delegation on their end.
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Confirm importer-of-record decisions for every load type. Not every load you haul makes you the importer. But if you ever move freight where you are also the purchaser or consignee — common in owner-operator scenarios or where you move your own equipment across the border — you are the importer of record for those transactions. Identify which load types apply to you before the cutover window closes.
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Subscribe to CBSA CARM alerts. Email
[email protected]to get on the distribution list. System notices, downtime windows, and enforcement date updates arrive here before they show up anywhere else.
Who Is the Importer of Record on My Loads?
This is the question that trips up most carriers, because the answer depends on the specific transaction — not on what your company does in general.
The importer of record is the party who: - Owns the goods at the time of importation, or - Has purchased the goods and is responsible for duties and taxes, or - Is the consignee named on the customs entry (B3 form).
In a standard carrier-for-hire scenario, you are hauling someone else's freight. The shipper or their customer is the importer of record. Your customs broker files the B3 on their behalf. You are not the importer — you are the conveyance. In this case, CARM enrolment is still needed if you have a CBSA commercial account for any other purpose, but the RPP security requirement falls to the importer, not you.
The situation changes when:
- You purchase and move your own goods (e.g. parts, equipment, consumables crossing the border).
- You are the named consignee on a load, even if you will resell or pass through the goods.
- You operate as an agent importer under a power of attorney for a shipper who lacks a Canadian commercial presence.
Owner-operators who sometimes buy product in the US for resale in Canada are often unknowingly acting as importers of record. If that describes any of your cross-border activity, you need your own BN15 and RPP security — not just your broker's.
For a broader view of how trusted-trader status interacts with importer-of-record responsibilities and border clearance speed, see our comparison of FAST, CDRP, and PIP trusted-trader programs.
What Happens If I'm Not Enrolled by the Cutover?
The consequences are tiered, but they escalate quickly.
Immediate operational impact: Shipments where you are the importer of record will not qualify for release prior to payment. Instead, CBSA will require duty and tax payment — or a case-by-case bond — before the goods are released from the port of entry. For a carrier running multiple cross-border loads per day, this means cash tied up per shipment, processing delays at every crossing, and potential driver detention charges accumulating against your account.
Administrative penalties: CBSA has the authority to assess Administrative Monetary Penalties (AMPs) for non-compliance with CARM registration requirements. Penalties are tiered by violation type and repeat offence history. First-time failures typically result in lower-tier penalties, but the penalty clock starts from the enforcement date — not from when you eventually enrol.
Broker coverage is not a backstop: This is the most common misconception. Your broker's RPP bond covers their own accounting obligations. It does not extend to your importer account. If CBSA treats you as an unenrolled importer, your broker cannot shield you from the consequences by pointing to their own security.
Cascade effect on trusted-trader status: If you hold or are applying for FAST card, PIP, or CDRP membership, non-compliance with CARM can flag your commercial account and put program eligibility at risk. These programs are administered separately from CARM, but CBSA's internal risk scoring treats CARM compliance as a baseline.
Use our cross-border readiness tools to check which compliance gaps apply to your specific operation before the enforcement window closes.
Where Do I Get Help?
CBSA CARM Client Portal The primary resource. Registration, financial security submission, delegate management, and transaction history all live at https://ccp.cbsa-asfc.gc.ca/. CBSA has also published a full library of user guides, video walkthroughs, and webinar recordings accessible from the main CARM page.
CARM Helpdesk For portal access issues, BN15 registration questions, and security submission errors: 1-800-461-9999 (within Canada) or 204-983-3500 (international). Expect wait times during peak enforcement periods.
Your Licensed Customs Broker A broker licensed by CBSA can complete the enrolment process on your behalf, advise on the correct RPP security level for your import volume, and handle the delegation setup in the portal. If you do not currently work with a broker, the Canadian Society of Customs Brokers (CSCB) maintains a member directory at cscb.ca.
BorderPro — ACE and CARM Filings in One Place BorderPro is TruckerPro's standalone border-clearing service, built by the same team. It handles ACE electronic manifest filings for US Customs and is adding CARM workflow support for Canadian importers. If you are already using TruckerPro for dispatch, BorderPro connects directly to your load data — so driver info, vehicle details, and cargo descriptions flow through without re-keying. For carriers running cross-border regularly, having ACE and CARM filings managed in a single system that talks to your TMS is a meaningful operational advantage over juggling separate broker portals. Visit borderpro.ai to learn more or request early access to the CARM module.
Source: Canada Border Services Agency — CARM program page at https://www.cbsa-asfc.gc.ca/services/carm-gcra/menu-eng.html. Dates and enforcement thresholds are subject to CBSA notice updates — verify current deadlines through the CARM Client Portal news feed or Customs Notice 25-32.