Question Period Note: Canada Border Service Agency Assessment and Revenue Management System (CARM) – Release Prior to Payment Program (RPP)

• Canada Border Service Agency Assessment and Revenue Management System (CARM) and the Release Prior to Payment Program (RPP)

• Each year, the Canada Border Services Agency (CBSA) manages $40 billion in duties and taxes.

• Previously, the CBSA’s inability to claim against an importer’s debt resulted in significant annual losses to revenue.

• To address this liability, the CBSA’s CARM Client Portal now requires importers to post financial security in order to have their goods released prior to payment.

• This change is targeted to reduce debt write-off by $13 million annually.

Information to support statements made in the Key Messages
On October 21, 2024, Legislative and regulatory amendments came into effect making CARM the official system for managing the $40 B in duties and taxes collected by the CBSA. CARM provides businesses with an account view of their importing history, allows them to make payments, establish a financial security agreement and submit digital forms. It improves compliance with trade rules, protects Government of Canada revenue and simplifies the import process by replacing paper based processes.
Transitional measures were put in place to support trade chain partners as they adjust to CARM and, more specifically, changes to the regulations relating to financial security.
Guiding the process, Accounting for Imported Goods and Payment of Duties Regulations (SOR/86-1062) have been in place for years; compliance with the regulations had been satisfied by allowing the importer to use the financial security of a customs broker. While this model facilitated the movement of goods it impeded the CBSA from collecting on debts owing to the crown. The inability to claim against a customs brokers financial security to pay an importers bad debt resulted in annual debt write offs.
Following the deployment of the CARM system on October 21 2024, a transition period was introduced to give commercial importers additional time to post their financial security electronically while continuing to benefit from the Release Prior to Payment (RPP) Program. This transition period ended at 3 am EDT on May 20, 2025. The change in liability is targeted to reduce debt write off by $13M annually. The changes also align with legislative changes planned to come into force in January 2026 that will provide greater clarity between the role of the importer and the customs broker.
In order to support the continued flow of commercial shipments at the border after the transition period ends, the CBSA will allow goods to move in bond to an inland sufferance warehouse providing the transporting carrier is bonded. If an importer does not have RPP upon arrival of their goods, they may choose to either post the financial security required in order to benefit from RPP or submit a Commercial Accounting Declaration at a CBSA office and pay the applicable amounts owing. Importers may choose to pay the applicable amounts owing using a credit card, up to a maximum of $5,000.00, or a debit card or a cheque. The security deposit option may be suitable for businesses whom import infrequently, seasonally and/or have low amounts of duties and taxes payable. This deposit can be paid with a credit card.
Awareness sessions and outreach across a broad range of stakeholders including small, medium and large size importers, customs brokers and transportation companies proved to be effective in raising awareness and mitigating the risk of border delays. Border Wait Times for processing commercial shipments remains within service standards and as of May 2025, over 157,000 businesses have registered in the CARM Client Portal. Importers who have posted financial security to obtain Release Prior to Payment represent over 97% of the volume.

Most recently, the CBSA is using CARM to implement surtax and remission orders in a timely and targeted manner in response to U.S. trade actions and other global developments. Through automated tariff coding updates and centralized importer account management, CARM allows for immediate application of new fiscal measures without the delays previously caused by manual processing and dispersed systems.
The cost of the CARM system was $438.4 million – within an overall budget of $526M. Deloitte has been contracted in the design, development and implementation of CARM, and is now supporting the systems ongoing operation. Deloitte receives $22M annually to manage the CARM service.

None