Presently under CARM R1, the CCP was made accessible only to importers and customs brokers who wish to voluntarily set up a CCP account. Trade consultants “who currently submit ruling requests to the CBSA on behalf of importers” can also set up a CCP account upon request to the CBSA.

Once CARM R2 goes into effect (May 2024), other stakeholders such as surety companies, lawyers, accountants, carriers, freight forwarders, marine agents, sufferance warehouses, etc. will progressively be able to set up CCP accounts to conduct business with the CBSA.

Under CARM Release 1 (R1), which was launched in May 2021, importers can voluntarily register their business for a CCP account with limited functionalities.

Before CARM Release 2 (R2) goes into effect, which is scheduled for May 2024, all importers of commercial goods must have registered their business for a CCP account.

A CCP account under R1 (May 2021 to May 2024) is voluntary, whereas a CCP account under R2 (on or after May 2024) will be compulsory.

If your company imports goods commercially into Canada, there are no exceptions or opt-out possibilities. All importers of commercial goods will be required to set up a CCP account for their business before CARM R2 (May 2024) goes into effect.

W2C recommends that the Business Account Manager (BAM), who will carry out the initial registration of your business on the CCP, be the one who oversees your organization’s profile with the Canada Revenue Agency (e.g., knows the exact business name and business address that are linked to your federal Business Number – BN-9 and BN-15 importer program account). It is further recommended this person also possess a level of knowledge and involvement in the financial management of the company (e.g., authority to make payments to the government).

That said, the CBSA has not limited or specified which individuals within an organization can register a company in the CCP. However, the person who completes the initial registration of your business on the CCP automatically becomes a Business Account Manager (BAM). The BAM is granted full editing authority and control for the company’s CCP account as well as access to all CCP functionality for the account.

The BAM will have the responsibility for approving and setting up employee access to the business and program accounts in the CCP, including the approval of a secondary BAM and any program account managers (PAM).

Yes. A business may have more than one BAM.

A business account may only be registered once in the CCP. It is recommended that upon registration to the CCP, the BAM immediately delegate authority to at least one other individual within the company as a secondary BAM, to ensure continuity of the account in the absence of the primary BAM. Due the importance of the BAM role, having another BAM, with full functionality and authority over your CCP account, prevents the possibility of losing all access to your CCP management activities.

Managing employees within the CCP is an activity reserved for BAMs and PAMs, although only BAMs can remove or add users. Users cannot update or remove their own access to a CCP account. Remember that a BAM can manage access for the whole business account, whereas a PAM can only manage access for their specific program account (RM importer account).

Other users within your organization who may require access to your company’s CCP account, may include persons:

- who manage the relationship with your customs broker(s)

- who manage customs compliance activities

- who oversee post-entry corrections and adjustments

- who oversee duty deferral (e.g., drawbacks, bonded warehouse, or duties relief)

- who manage requests for rulings on HS tariff classifications, preferential origin treatments or customs valuation

- who are responsible for paying broker fees

- who are responsible for paying all amounts due the CBSA (e.g., duties, taxes, interest, penalties, etc.)

- who purchase imported goods

- who manage your receiving activities for imported goods

The BAM is responsible for:

• Registering your company on the CCP.
• Assuming ultimate oversight of the business account.
• Approving and assigning user roles to each subsequent user, including additional BAMs** and PAMs.

**Note: Once a BAM has approved another BAM, the BAMs all have equal access and functionality to manage all your business and program accounts.

The PAM role gives access to virtually all CCP functionality, but only for a specific program account (BN15 – RM000_ account). This role is useful if there is more than one RM program account for your company and the BAM wishes to give access to a certain RM program account only to a particular user. The purpose of this role is to assume the management of a specific RM program account alongside the BAM. However, the PAM cannot edit the business profile information, modify the list of linked program accounts, or modify the organization’s banking information, as set up on your CCP.

Delegation of Authority involves granting access, requesting or receiving access, as well as managing a user’s access to a CCP account. There are two parts to delegation of authority within the CCP: providing access to employees within your company by assigning user roles, and importers providing access to a customs broker (or third party trade consultant) by establishing a business relationship.

In other words, two forms of relationships are possible via the CCP:

1. Employer-to-employee relationships between a business account and a user of the same organization, and
2. Legal entity-to-legal entity relationships between an importer-client and their customs broker (or external third party trade consultant for rulings).

Delegation of Authority is used to assign users with user roles, which have predefined access rights that control what the user can view (visibility attributes), permissions, and the actions they can take in the CCP. The different roles and relationships between users fall under pre-set conditions that allow or prevent users from performing certain tasks (e.g., viewing notifications, making payments, submitting rulings, etc.) based on their assigned access level.

Therefore, your company must carefully consider which employees within the company and which customs broker(s) should have access to your program account(s) within the CCP and be prepared to select the appropriate access type for each employee or customs broker to whom you wish to delegate access or authority to.

Not necessarily. Depending on the size of the business and volume of importations, an importer may choose to only have a single BAM or two BAMs or assign the role of BAM to all internal users of their CCP.

Keep in mind that the role of BAM has all authority and full functionality for your CCP account. Therefore, if you have more than two individuals within your organization who need access to your CCP account, for additional users (beyond the first two BAMs) you may wish to delegate authority according to a role that has lower access functionality and/or lower visibility attributes than the BAM role, such as the PAM role or Read-Only role, depending on what those persons need to do within your CCP account.

Whether your company is a new importer or an existing importer of commercial goods to Canada, and you are the designated Business Account Manager (BAM) for your company who will make the initial registration of your business on the CCP, you will need to have the information listed below at your disposal. The first person who links their user profile to the business account automatically becomes the BAM.

The BAM should prepare and have at hand all the information needed prior to attempting to register the business on the CCP.

1. Full legal name of your company
2. Full legal address of the company

3. Your company’s BN-15: Nine-digit Business Number with “Importer” account identifier (e.g., 123456789 RM0001)

   Note: The name and address must be exactly as registered with the Canada Revenue Agency (CRA) with exact spelling, spaces, punctuation, upper- and lower-case letters. Any input that does not match CRA records exactly will result in an error from the CARM Client Portal (CCP).

   Note: If your business does not have a Business Number (BN), or the business has a BN (e.g., with RT program account for GST or a RC program account for income tax), but not an “importer/exporter” program account (RM), you will need to register with the CRA for an RM importer/exporter program account before the CCP registration of your business can be undertaken.

4. The CCP will ask you to provide a transaction number and the total duties and taxes for a B3 (Canada Customs Coding form) that was previously accepted by CBSA.

   Note: All information provided must be related to the BN and RM importer program account being used to register the business.

5. The CCP will ask you to select a date (MM/YYYY) and enter a payment amount made on the selected date.

6. The CCP will ask you to select a date (MM/YYYY) and enter the Statement of Account (SOA) balance for the selected date. A zero-dollar ($0.00) amount will not be accepted by the portal to answer this security question. Only a positive or a negative account balance is accepted by the CCP to answer this question.

   Note: Before undertaking registration of the business on the CCP, the designated BAM should seek guidance from its customs broker(s) to ensure the BAM is in possession of the accurate transactional information (IV, V and VI above) that will be needed to respond correctly to the CARM security questions that the portal will ask during the registration process.

7. As one of the first steps of every users’ registration on the CARM Client Portal (CCP), users must create login credentials. Each user, including the BAM, needs to create a user profile within the CCP using one of the two sign-in authentication processes recognized by the Government of Canada to access the online CCP.Users may:
   1. Use an existing GCKey that has been created for other CBSA portals (e.g., PIP, CERS, eManifest), or create a new GCKey specifically for the CCP; or
   2. Use the Sign-In Partner option where users authenticate themselves using their own banking credentials

According to the CBSA, the GCKey allows a user to access the CARM Client Portal (CCP) as well as other Canadian government platforms/portals. If you already have a GCKey, you may be able to use it to log onto the CCP. An existing GCKey for CBSA portals, such as CERS, e-Manifest and PIP, has been confirmed to also work for CARM. On the other hand, GCKeys for other government agency portals (e.g., MyCRA or MyCFIA) will not work for CARM and you may need to create a new GCKey specific to your CARM account. Even though you may have a pre-existing GCKey for another CBSA portal, it is not a d idea to create a new GCKey with a different username to use to login to your CCP account.

As many users as needed to manage your customs and CCP activity. There is no limit on the number of CCP users per business account or RM importer program account.

 Canadian residents and non-residents alike can act as the BAM or the PAM or take on other user roles within the CCP. Residents and non-residents can register for a GCKey, create their personal user profile on the CCP and request access (and be granted access) to their organization’s CCP account, and ultimately carry out actions in accordance with the access level that person has been granted by the BAM of the company.

Yes. All customs brokers will require a CARM Client Portal account.

CARM is designed to allow an importer registered on the CCP to delegate access to its portal account either internally to colleagues as well as externally to their acting customs broker to help manage their importation and CCP activities. Delegation of authority to your customs broker is necessary if the importer wishes the broker to continue to conduct “customs broker” business as usual.

For example, delegation of authority to your customs broker is required if you wish the broker to file ruling requests and submit corrections/adjustments. It is also possible to delegate authority to your customs broker with a level of access where the broker can act as the importer’s “proxy” BAM or PAM in the event the importer wishes the broker to perform operational activities such as view duty and tax accruals on importations, view statements of account or even make payments to the CBSA through the importer’s CCP account.

Of much greater importance, once CARM Release 2 goes live in May 2024, if the importer fails to delegate authority to its customs broker through the CCP, the custom broker will be unable to transmit Commercial Accounting Declarations (CAD) to the CBSA for the importer. Without the CCP delegation of authority from the importer the customs broker cannot finalize nor account for customs entries. In addition to holding a valid power of attorney or agency agreement from the importer, once CARM R2 goes into effect, the customs broker must also have received a delegation of authority through the CCP to account for entries and transmit CADs to the CBSA on behalf of the importer.

Note: Under CARM, B3 coding forms and B2 adjustment forms will be replaced by Commercial Accounting Declarations (CAD).  

Not necessarily.

Firstly, when an importer is managing its business relationships in the CCP, the importer should vet all requests for a delegation of authority it receives from various customs broker through the portal. Ensure the customs broker holds valid agency agreement or POA from your company. Verify that you wish for said customs broker to continue to conduct business on your company’s behalf. Then grant the customs broker the level of access and authority needed to deliver its services to your company. Generally, the importer should only delegate authority to a customs broker who processes customs clearances (release and accounting) for your import shipments.

 The CBSA has affirmed that the release process itself will not be affected by CARM. The filing of electronic manifests by carriers, the transmission of commercial documents to customs brokers and the filing of release requests by customs brokers will continue as they do today.

The only exception once CARM Release 2 goes into effect in May 2024 is for B3 Type C release entries, whereby the new enhanced CAD must be presented as part of the release package instead of the existing B3 coding form.

Important: As previously mentioned, while there is technically no change to the way release requests are processed today, once CARM R2 goes into effect, in order to finalize and account for released shipments the customs broker must have been granted a delegation of authority by the importer (through the CCP) for that broker to be able file CADs for that importer. 

At the earliest possible opportunity, but no later than May 1st, 2024. Once the designated person in your company, who will be the Business Account Manager, has compiled all the information needed to create the business profile on the portal and answer the security questions that will be posed by the system, the BAM should register the business unto the CCP without delay.

When the CARM Client Portal went into effect in May 2021, the following functionalities became available to portal users:

• Visibility of all financial activities (debits and credits) for an importer’s program account.
• Visibility of Statements of Account (SOA) and basic import transaction information.
• Ability to set up a Pre-authorized Debit (PAD) or credit card to remit direct payment to the CBSA using the CCP.
• Ability to file and manage ruling requests with the CBSA.
• Ability to receive notifications from the CBSA through the CCP.
• Ability to delegate access to the CCP internally to employees or delegate authority externally to customs brokers.
• New tools such as Customs Tariff search. 

When CARM Release 2 is introduced (May 2024), more robust functionalities of existing features will be implemented. The following Release 2 features are expected to go into effect:

• Importer must have posted a financial security instrument (Customs Bond) or a cash deposit with the CBSA to continue to receive Release Prior to Payment (RPP) privileges.
• An importer can manually enter the details of their existing paper bond (D120 Customs Bond) into their CCP account. Transition of non-expired paper bonds to the electronic bond environment under R2 remains to be determined. Paper bonds may require a new endorsement by the applicable surety.
• CARM R2 will automate the process for capturing financial security via the CCP using an API connection with surety providers.
• Minimum security amount, determined by the CBSA based on the importer’s transaction history and duty/tax payable’s history, will be identified in the importer’s CCP account.
• CARM R2 will introduce a new Commercial Accounting Declaration (CAD). The CAD enhances and replaces the existing B3 coding forms and B2 adjustment forms.
• Duties and taxes will be calculated based on information transmitted on the CAD.
• Delegation of authority must be granted by the importer to enable their customs broker to prepare and transmit CADs on their behalf to CBSA.
• Corrections and adjustments will henceforth be done by submitting a corrected/adjusted version of the CAD. Electronic versioning of the CAD replaces the legacy paper B2 adjustment process.
• Filing of the initial CAD or subsequent changes to a CAD can be performed manually via the CARM Client Portal using an API downloaded on the CCP or via EDI (e.g., through the customs broker’s entry processing system).
• New billing cycle and correction period will be introduced under CARM R2.

Release Prior to Payment (RPP) is a privilege that entitles importers and customs brokers who have posted financial security and obtained an account security number with CBSA to:

1. obtain the release of goods before paying duties and taxes;
2. defer accounting for released goods; and
3. defer payment of duties and taxes.

Presently, importers without account security, who are using a customs broker with RPP privileges to transact business with the CBSA on their behalf, may also benefit from release prior to payment and deferred accounting and payment. Once CARM R2 goes into effect, importers may no longer rely on a customs broker’s financial security for RPP privileges.

The current RPP programme will remain in force until May 2024, at which point the new requirements are expected to take effect. In anticipation of these changes, the CBSA has developed a transition plan to support importers who onboard to CARM before the new RPP requirements take effect in May 2024.

To benefit from the transition period, importers must register to the CARM Client Portal before the R2 deadline (e.g. before May 1st, 2024). An importer who registers on the CCP after the R2 deadline will not benefit from the transition period and security will need to be posted at time of CCP registration to receive RPP privileges.

Transition period: On the date that CARM R2 becomes the official system of record, importers who are registered on the CCP before the R2 deadline, will have 180 calendar days to post security with CBSA and link the security to their CCP account. If financial security is not provided within the 180 days transition period, the importer will be removed from the RPP program (at day 181).

The D120 Customs Bond is a financial security instrument accepted by the CBSA to grant Release Prior to Payment (RPP) privileges to an importer or a customs broker.

Once CARM R2 goes into effect, importers of commercial goods may no longer rely on their customs broker’s bond to secure RPP privileges. Once CARM R2 becomes effective, the financial security obligation is set at the importer level.

A Customs Bond is deemed a legal contract between a principal (importer), a surety company, and the CBSA.

The customs bond guarantees the CBSA that it will be able to collect all amounts owed by an importer such as customs duties, GST, SIMA duties (ADD and CVD), surtaxes, excise, and redeterminations owed to the CBSA for imported goods as well as any penalties and interest charges assessed by the CBSA to the importer. If the importer fails to pay, the CBSA can compensate itself by filing a claim against the surety company who underwrote the Customs Bond, who in turn can use legal means to recover the unpaid amounts from the importer.

Presently under CARM R1, Customs Bond are obtained through a “paper” process. Once CARM R2 goes into effect, Customs Bonds will become a fully electronic process.

The latest an importer can post financial security with the CBSA in the form of a cash deposit or a D120 Customs Bond will be at the CARM Release 2 “go-live” date which is scheduled for May 2024.

However, importers with registered accounts on the CCP before the CARM R2 implementation date of May 2024, will benefit from a 180-day extended period (up to ~ November 2024) to post financial security with CBSA to continue to receive RPP privileges.

Those importers who register their business on the CCP after the R2 go-live date, will need to post security as soon as they register on the CCP (in the form of cash or bond) to receive RPP privileges. Once R2 begins, an importer without security and who is not entitled to the 180-day extension, will no longer receive RPP privileges and such importer will need to pay all duties and taxes before a shipment/transaction is customs-released by CBSA.

Based on the limited number of sureties in Canada who can underwrite Customs Bonds, the early stage of technology development around the new electronic bond process, as well as the significant number of bonds that will be contracted by the importing community when CARM R2 is launched, there is potential for delays in issuance of bonds. Importers should be proactive to secure their bonds as early as possible.

For cash deposits, the minimum amount of financial security must be equal to 100% of the highest monthly SOA payable by the importer (including duties, GST, SIMA duties, surtaxes, excise, and redeterminations) over the prior 12 months.

For customs bonds, the minimum amount of financial security must be equal to 50% of the highest monthly SOA payable by the importer (including duties, GST, SIMA dutiesnd redeterminations) over the prior 12 months.

Once CARM R2 comes into effect, if the importer has 12 months of history with the CBSA, CARM will automatically calculate and provide the minimum financial security requirement as part of its RPP enrollment through the CARM Client Portal. If an importer does not have 12 months of payables history with the CBSA when CARM R2 goes into effect, the importer will be prompted to self-assess its financial security requirement based on estimated duties and taxes payable. The security requirement is updated by the CARM system on an annual basis from July 25 to July 24. 

Although much rumor has circulated on the issue of single transaction bonds (i.e., Single Entry Bonds), as of writing this FAQ document, the CBSA has yet to confirm whether a single entry bond option will be made available.

Presently, the only two available options for posting security with the CBSA for RPP privileges under CARM R2 are:

• cash deposit via the CCP; or
• Customs Bond.

Once CARM R2 goes into effect (May 2024), if an importer has not posted adequate financial security with the CBSA (or if the importer is not entitled benefit from the 180-day extended transition period offered by CBSA – See questions 21 and 23), importations of commercial goods will not get released at the border or at the port of entry (air, ocean, or inland sufferance terminal) without paying all applicable duties and taxes before customs release.

Per our current understanding of CARM R2, goods can still be imported to Canada without posting financial security. However, without financial security in place the importer would not benefit from Release Prior to Payment (RPP) privileges. Consequently, the importer must pay in advance (prior to release) through one of the authorized “electronic” payment options available under CARM R2 or pay a CBSA cashier** at an authorized CBSA point-of-sale location at time of import.

Whether or not financial security for RPP privileges has been posted, the importer must still have set up the CCP account for its business and have delegated authority to its customs broker for the broker to be able to process the customs clearance. However, the CBSA will not release the shipment until it can confirm receipt of the full payment of all duties and taxes owing for the live transaction, as well as any unpaid debt on the importer’s file.

**Note: Under CARM R2, for payments at authorized point-of-sale cashier locations, the CBSA will have phased out “cash” payments, bank drafts and certified cheques. CBSA cashiers will only accept payment by credit card or by debit card up to maximum amount of $5,000 CAD. For amounts greater than $5K, online banking or pre-authorized debit via a CBSA-Approved bank would be the only payment options available to an importer who hasn’t posted financial security with the CBSA beforehand. For an importer who has not posted financial security, payment options need to be considered and set up well in advance of the live importation as customs release will be withheld until all amounts due the CBSA are paid. 

Most importers will apply for, purchase, or renew their annual customs bond through their customs broker, who will have made arrangements with authorized surety companies. Basically, customs brokers will be re-sellers of customs bonds. Alternatively, an importer can apply and purchase an annual customs bond directly from a surety company, insurer or financial institution recognized by the Government of Canada for the issuance of importer bonds for purposes of RPP privileges.

During CARM R1, RPP privileges can still be secured through a customs broker’s bond. During R1, brokers can still pay duties and taxes on behalf of an importer and recharge CBSA outlays paid on behalf of the importer on its brokerage invoice. Alternatively, during R1 brokers can pay the duties with the GST on imported goods being carried over to the importer’s monthly statement under the existing “GST Direct” program.

However, once CARM R2 goes into effect (May 2024), some customs brokers may stop paying any duties, GST or other CBSA disbursements on behalf of importers. Under CARM R2, the “GST Direct” program will be discontinued. Under R2, all importers are responsible for paying the CBSA for all amounts owing to the CBSA. If the importer wants to continue benefitting from RPP privileges as it does today, the importer will need to post adequate financial security (e.g., cash deposit or customs bond) with the CBSA.

That said, if agreed with the importer, a customs broker can remit payment to the CBSA for an importer’s monthly Statement of Account (SOA). However, the CBSA has informed us that upon receiving a payment from a broker for a given importer account, the payment will be applied towards outstanding debt on the account as per CARM R2 offsetting business rules. Therefore, it is possible when a broker submits a payment on behalf of an importer and provided the payment is posted “correctly” to the importer’s account, that such a payment would offset debts on the importer’s SOA, which are not attributed to the broker who made the payment.

Electronic Payment	** Online via CCP (Credit or Interac™)	$5K for credit card $100K for Interac	N/A
	Online Banking	Unlimited	YES
	Electronic Data Interchange (EDI)	Unlimited	YES
	** Pre-Authorized Debit (PAD) (One-time setup and ongoing)	$100 million	YES
	Bank Remittance (To be phased out in 2022)	Unlimited	N/A
Point-of-Sale (POS) Cashier Payment	Credit Card or Debit	$5K	N/A
	Cash (To be phased out as of R2)	$50K	N/A
	Bank Draft or Certified Cheque (To be phased out as of R2)	$25 million	N/A

Unless the importer sets up Pre-Authorized Debit (PAD), most payments under CARM R1 and CARM R2 will be in the form of discrete, ad-hoc (one-time) payments by either Online Banking, Credit Card, or Interac™.

Arrangements can be made for the customs broker to make payment for an importer’s SOA. However, the broker and importer must agree to this and establish appropriate business rules with terms and conditions under which the broker would make payments to the CBSA on behalf of an importer and charge back the importer for said disbursements. Whether the importer or broker pays, financial security for the RPP is set at the importer level and the importer is legally liable to ensure amounts owed to the CBSA are paid in totality and within statutory time limits.

Non-resident importers (NRIs) are subject to the same CARM requirements as Canadian-resident importers (e.g., being registered with the CRA for a Business Number – Importer account, registering with the CBSA for a CCP account and posting financial security for RPP privileges, etc.). There is no distinction under CARM between resident and non-resident importers.

Presently, exportations from Canada are not affected by the CARM initiative.

Yes. Your company must have registered for a CARM Client Portal account, and you will need to delegate authority to your customs broker to enable the broker to account for your entries and file CADs with the CBSA for your import transactions. If your company has a history of duties and taxes payable (even nominal amounts) in the prior 12 months, you will need to post financial security in the form of a cash deposit or a customs bond to benefit from the RPP.

The only exception to the financial security requirement is if the importer has a history of zero payables to the CBSA in the prior 12 months. In other words, the importer has not been assessed any duties, GST, SIMA duties, surtaxes, excise, redeterminations, penalties or interest in the 12 months prior. The instant an importer hascurity in the form of a cash deposit or a customs bond to benefit from RPP privileges.

Yes. Your company must have registered for a CARM Client Portal account, and you will need to delegate authority to your customs broker to enable the broker to account for your entries and file CADs with the CBSA for your import transactions. If your company has a history of GST payable for imported goods in the prior 12 months, you will need to post financial security in the form of a cash deposit or a customs bond to benefit from the RPP.

The only exception to the financial security requirement is if the importer has a history of zero payables to the CBSA in the prior 12 months. In other words, the importer has not been assessed any duties, GST, SIMA duties, surtaxes, excise, redeterminations, penalties or interest in the 12 months prior. The instant an importer has an amount payable to the CBSA of any kind, that importer will be prompted to pay in advance of customs release or post financial security in the form of a cash deposit or a customs bond to benefit from RPP privileges.

Yes. You will need to be registered for a CCP account. The customs broker (or the importer if it files its own C-Type entries), will need to have access to the importer’s CCP to prepare a fully completed "C-Type" Commercial Accounting Declaration (CAD) to obtain the release of the goods. It is our understanding that “C-Type” CADs cannot be submitted to the CBSA using the broker’s EDI system. We further understand that there will be a computer terminal available at the CBSA office that will allow the importer or their customs broker to access the Importer’s CCP to prepare the “C-Type” CAD. Alternatively, the importer or customs broker can prepare and print the CAD ahead of the goods arrival, to avoid completing the CAD at the CBSA office.

Please refer to the hyperlinks below:

CBSA CARM Information Page

CBSA CARM Information Guides

CBSA CARM YouTube Channel

W2C CARM Blogs

W2C Webinar – CARM Intro

W2C Webinar – How to Register on the CCP

W2C Webinar – CARM Financial Security

W2C Webinar Package – CARM Package

Glossary CARM – Acronyms & Definitions