In late 2024, the Canada Border Services Agency (CBSA) implemented the Assessment and Revenue Management system (CARM), the official system of record used to account for imported commercial goods and pay duties and taxes owed to the CBSA. All companies importing into Canada must register for CARM in order to continue importing goods into Canada.
The CARM Client Portal is now the sole platform to communicate with the CBSA and the central location for importers, or their designated trade partners, to submit Declarations for Commercial Goods imported into Canada directly to the CBSA, delegate access and permissions, view account information, apply for advanced customs rulings, make electronic payments directly to CBSA for duties and taxes and obtain Statements of Accounts (SOAs).
As the official system of record, all designated trade partners such as: Freight Forwarders, Customs Brokers, exporters, sufferance warehouses, lawyers, accountants, carriers or other service providers, will be able to use the portal to conduct business with the CBSA.
The CARM Client Portal gives traders uninterrupted access to border services and is designed to streamline trade processes and enable the CBSA to better engage importers while also gathering and analyzing trade-related data.
Importers will need to register on the CARM Client Portal and properly delegate access to employees and their designated trade partners to manage both imports and CARM procedures.
One of the focuses of the CARM initiative is to shift duty and tax liability to the importers through Release Prior to Payment (RPP) privileges. If importers do not obtain their own RPP security (through a customs bond), they will not be eligible for RPP benefits and will have to establish ways to pay duties and taxes at time of entry, hindering the flow of goods.
Beyond conducting customs business through the CARM Client Portal, the major disruption for importers will be the shifting financial liability and the changes to importer’s accounting processes.
Under CARM, the Importer of Record (IoR) will be required to have their own portal account as well as a security bond in place. Payments to CBSA for duties and taxes will be required to come directly from the importer rather than from a designated Freight Forwarder or Customs Broker, which is a discontinued practice. Importers must have payment arrangements in place, such as pre-authorized debit payments or the Release Prior to Payment (RPP) program.
The RPP program, managed by CBSA, allows commercial importers to receive their goods from customs before paying duties and taxes, provided they post financial security through the CARM Client Portal. This streamlines the import process by deferring the accounting and payment of duties and taxes, enabling faster, fully electronic release of commercial goods at the border. To participate, importers must enroll in the program and provide financial security via a cash deposit or written security agreement, calculated based on their highest monthly accounts receivable.
Designated Freight Forwarders or Brokers who provide customs-related services to their customers, can request a business relationship in the portal to:
• Delegate authority to continue to act on their behalf,
• Submit rulings on behalf of importers,
• Review customer accounts and submit adjustments,
• Continue to provide importers with Release Prior to Payment (RPP) bonds,
• Set up and electronically send financial security information to transact with the CBSA.
Companies must submit baseline inventory counts to fully enroll, participate and communicate within the CARM system. Companies that fail to register and submit a baseline inventory may experience significant problems with their importing and exporting activities.
To deter non-compliance, the CBSA uses the Administrative Monetary Penalty System (AMPS) to issue penalties to commercial clients for violating CBSA’s trade and border legislation. AMPS penalties may be applied to commercial clients including importers, exporters, brokers, warehouses, carriers, freight forwarders or their representatives for:
• Failure to pay duties or to provide required information to the CBSA,
• Unauthorized removal of goods from a warehouse,
• Direct delivery of goods prior to release from CBSA control,
• Failure to report goods to the CBSA,
• Failure to self-correct an incorrect declaration,
• Failure to submit the final accounting for released goods within five (5) days.
AMPS penalties can vary significantly depending on the nature of the violation, ranging from a small penalty to potentially thousands of dollars for serious, repeated violations.
The CBSA may reverse an AMPS penalty within 90 days if there was an error in the assessment or if the contravention did not occur. A correction may be requested by submitting a formal appeal within the 90-day timeframe.
The CBSA issues Late Accounting Penalties (LAPs) to enforce the timely submission of final accounting documents and the payment of duties and taxes on imported goods, ensuring compliance with trade legislation under the AMPS program. These penalties encourage importers and their designated representatives to submit their final accounting within the prescribed timeframe after goods have been released. Failure to do so can result in a monetary penalty for each overdue transaction, as well as, the subsequent assessment of duties, taxes and interest.
2026 Update – CARM Compliance Is Now Part of Canadian Importing
CARM is now fully integrated into Canada’s commercial importing environment and has become a standard operational requirement for businesses importing goods into Canada. Importers continue adapting to the administrative, financial and compliance responsibilities associated with managing duties, taxes, Release Prior to Payment (RPP) security and account access through the CARM Client Portal.
As import procedures continue evolving, maintaining accurate commercial documentation, customs declarations, delegated portal access and payment arrangements remains essential for avoiding delays, penalties and compliance issues with the Canada Border Services Agency (CBSA).
Many Canadian importers continue working closely with their designated Freight Forwarders, Customs Brokers and trade service providers to navigate CARM requirements, manage customs processes and maintain efficient cargo movement into Canada.
Learn more about Cargo Spectrum’s Customs Clearance, Ocean Freight, Air Freight and international freight forwarding services to and from Canada.
The CBSA’s CARM program modernizes and streamlines revenue collection on commercial goods imported into Canada, shifting the financial responsibility for payments directly to importers. The CARM Client Portal improves compliance, fraud detection and overall border security while simplifying the importing process for businesses. CARM replaces older, less efficient methods with a digital platform and supports the CBSA’s mandate to increase border security and protect the billions of dollars in trade revenue collected at the border each year.
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