CBSA Assessment and Revenue Management
Guiding you through important regulatory changes
The CBSA Assessment and Revenue Management (CARM) project is a multi-year initiative that will transform the collection of duties and taxes for commercial goods imported into Canada. Through CARM, you will be able to interact directly with the Canada Border Services Agency (CBSA) through an online portal. Registration on the CARM Client Portal is mandatory to imports commercial goods into Canada.
CBSA has provided an update to their timeline for CARM Release 2 originally slated for October 2023.
The Canada Border Services Agency (CBSA) has announced that CARM Release 2 is now scheduled for October 2023.
As a valued client of Preferred Service Customs Brokers, we wanted to ensure you were prepared for ongoing changes to our importing community with CARM (CBSA Assessment and Revenue Management project). With many of you seeking step-by-step support in this 2-phase modernization project to streamline the process of importing commercial goods into Canada, we’ve developed these service packages to support you.
The Canada Border Services Agency has announced that CARM Release 2 is now scheduled to be launched no earlier than January 2023. A specific date will be announced at a later time. In the meantime, please ensure that you and your staff are registered on the CARM Client Portal.
Are you ready for CARM? To avoid significant delays or interruptions, now is the time to register on the CARM Client Portal.
The CBSA hosts regular webinars and Open Mic forums on onboarding to the CARM Client Portal. Here’s how to register. Next webinar: Nov 16, 2021
One of the biggest changes with CARM is the need for importers to secure and post their own importing bond if they would like to participate in the Release Prior To Payment Privilege (RPP). Here’s what you need to know.
The Canada Border Services Agency’s CARM Client Portal is now open for registration. Here’s the information you need to have on hand to register.
What do I need to do to get ready for CARM Release 2? By when?
One of the biggest changes with CARM is the need for importers to secure and post their own importing bond if they would like to participate in the Release Prior To Payment Privilege (RPP).
With CARM Release 2 now scheduled for October 2023, we are urging you to get your financial security in place now to avoid any potential disruptions to your business. All importers must have their financial security in place by CARM Release 2 to continue doing business.
What is an Importer Security Bond? Why do I need one? What if I don’t get one?
Historically, customs brokers were allowed to extend use of their own customs bond to any importer that wanted it. This all changes under CARM and Importers will be required to post their own financial security — with either a Customs bond or CBSA cash deposit — to obtain release of their goods prior to accounting and payment of any applicable duties and taxes with the CBSA.
IMPORTANT: The CBSA will display the required bond amount on the CARM Client Portal on the day of CARM Release 2. Considering that the Release Prior to Payment Privilege (RPP) will be mandatory as of Day 1 of CARM Release 2, you will need to calculate your required bond amount and set up a bond well before CARM Release 2.
Financial security may be posted in the following ways:
- A cash deposit
- A Customs bond
Without RPP security, an importer will be required to pay in advance on the CARM Client Portal or pay a CBSA cashier at the time of clearance, in order for the goods to be released by CBSA.
The posted financial security will secure all accounts payable, including duties and taxes (GST), interest, adjustments, ascertained forfeitures, and Special Import Measures Act (SIMA) fees.
The bond will secure any penalty fees. However, penalties are not used in the calculation of the amount of bond required to cover the account.
How do I get an Importer Security Bond?
With your authorization, Preferred Service Customs Brokers can obtain a Customs bond on your behalf. Please see our update: CARM Service Packages: Providing you step-by-step support.
Alternatively, importers can contact their bank or insurance company to inquire about Customs bonds. If the bond is obtained by a party other than us, you will need to forward a copy to us if you want us to file with the CBSA. The CBSA will notify both you and Summit of your security number as soon as this has been issued, and your entries will then be processed under your financial security starting with the next accounting period after the launch of CARM Release 2. Depending on the number of imports, the minimum bond is $25K and you can monitor your imports to ensure you have enough bonds to cover your duties and taxes.
Here is the CBSA’s Memorandum D17-1-8, which also outlines the process for securing a Customs bond.
How much does my Importer Security Bond have to be?
That depends on how you are posting your financial security. There are 3 options.
1. Cash Deposit: Must be equal to or greater than 100% of the importer’s highest monthly accounts payable to the CBSA within the most recent 12-month period. The cash bond can be posted to the account by making a deposit through the CARM Client Portal.
Note: Posting a cash bond is not possible until Release 2 goes live in June 2022.
2. Customs Bond: Must be 50% or more of the highest monthly accounts payable to the CBSA within the most recent 12-month period. Importers without a 12-month history will need to estimate the amount of duties and taxes. The bond is subject to a minimum of $25,000 and a $10 million maximum.Examples: The highest monthly accounts payable is determined to be $100,000, the importer is to post a surety bond for $50,000. Alternatively, the highest monthly accounts payable is $20,000, the importer is to post a surety bond for $25,000.
3. One-time Single Entry Bond: Details on this have not yet been released by the CBSA.
Zero accounts payable: If an importer’s highest monthly accounts payable is zero within the most recent 12-month period, no bond is required. If the importer starts to import goods which results in a payable, or if the importer is issued a penalty within the Administrative Monetary Penalty System (AMPS) or an adjustment, the CARM system will monitor and measure the importer’s security utilization and nudge them to provide increased security.
If the importer does not normally have dutiable/taxable goods but has a dutiable and taxable shipment coming in, they can choose to apply a single one-time entry bond or make an interim payment of duties and taxes.
What will the importing process be like using my own Importer Security Bond?
Importing using your own importer security bond with the CBSA is easy. Preferred Service Customs Brokers will continue to make the entries to Customs, as well as rate and finalize the entry, using your financial security number as opposed to ours. Once your Customs bond is approved and in place with the CBSA, you will be approved for month end payment of your duties, taxes, and GST directly to the CBSA.
You will receive a daily recap of transactions plus your own Statement of Account at the end of each Customs accounting period. Statement of Accounts (SOA) are generated on the 25th of calendar month 2 for all goods released between the 18th of calendar month 1 to the 17th of calendar month 2.
The payment due date is 10 weekdays from the 17th of calendar month 2.
What is CARM Release 1 and what do I need to do as an Importer?
On May 25, 2021, the Canada Border Services Agency (CBSA) launched the CARM Client Portal at: https://ccp-pcc.cbsa-asfc.cloud-nuage.canada.ca/en/homepage
It is a self-service website that facilitates accounting and revenue management processes with the CBSA.
In Release 1, it is available to: Customs Brokers, Trade Consultants, and Importers. It will allow businesses to:
- Manage account data and delegate authority to customs brokers, trade consultants, and staff.
- View statements of account and make payments online: pre-authorized debit, credit card, etc.
- Request advance rulings
- Classify goods, and estimate duties and taxes
You will need to register yourself, link your account to your business, then delegate authority to your staff and to us, as an authorized third party, to allow us to continue to act on your behalf with the Canada Border Services Agency. See Onboarding to the CARM Client Portal.
What information do I need to have ready to register on the CARM Client Portal?
To set up your account on the CARM Client Portal, you will need the following information:
- The 9-digit BN and importer RM extension registered to your legal business
- The exact legal corporate name and complete address
- The answers to 2 of 3 following questions:
- What is the transaction number, and total duties and taxes of one of your recent transactions?
This is a recent transaction for the RM importer account (15-character Importer Number) that you are using to register your account. You can find the transaction number on your invoice under the heading: Transaction Number
- What is the exact value of your most recent payment?
This is the most recent payment on your RM importer account that you are using to register your account.
- What is the balance of your last Statement of Account?
This is the last Statement of Account for your RM importer account that you are using to register your account.
What is a BAM? And who should be assigned this role?
The Business Account Manager (BAM) manages the daily customs operations and has full access to all business and program accounts on the CARM Client Portal. They are responsible for approving access requests from either employees or third parties, such as your customs broker, and for assigning user roles for each new user. Business accounts can only be set up by a BAM.
The BAM should be an individual with active involvement in the management of its business account i.e. manages employee access, manages third party service providers, manages business and program accounts information.
The role of BAM is automatically given to the individual who links their user account to their business when completing the registration process.
It is HIGHLY recommended to set up more than one BAM with complete management access to cover any absences, and to share in the administration of your business account(s).
What is a PAM? What does a PAM do?
The Program Account Manager (PAM) has the ability to create, edit and view all program account information and is responsible for approving and granting program access to employees. For example:
Company Fancy Shoes & Socks (the 9-digit legal entity) has two import divisions:
RM 0001 Fancy Shoes
RM 0002 Fancy Socks
The Business Account Manager (BAM) could assign a different Program Account Manager (PAM) to each of the divisions or program accounts, or appoint the same person as the PAM to both divisions. Alternatively, the BAM could also be the sole person responsible for all RM accounts, with no need to appoint a PAM.
What is a delegation of authority? How do I do this?
As the Business Account Manager (BAM), you give access or delegate authority to both staff and third parties such as your customs broker and/or trade consultant. Those you “delegate authority” to can access your Client Portal and have the ability to perform actions on your Client Portal
Just as you appoint someone to be a BAM (and PAM) in your company, you can also delegate the same permissions by proxy to your customs broker so that they can manage or perform actions on your Client Portal on your behalf.
Proxy Business Account Manager (pBAM)
The pBAM gives the customs broker (or other third party) near full access to all CARM Client Portal functionality for a client’s business account, but with the following exceptions:
A pBAM does NOT have access to the client’s sensitive information such as bank account information.
A pBAM CANNOT see or manage the employees or business relationships of the client.
A pBAM can only manage access only for its own employees — NOT the employees of the client.
The pBAM role is automatically given to the BAM of the customs broker.
Proxy Program Account Manager (pPAM)
The pPAM gives the customs broker (or other third party) near full access to a client’s specific program account (RM). The same exceptions for the pBAM above apply. And the pPAM role is also automatically given to the BAM of the customs broker.
- You can only delegate authority to a customs broker or trade consultant after they have registered on the CARM Client Portal.
- Delegate authority only to those who are trusted partners and know your business to avoid costly mistakes.
Why is it important to register early (well before Release 2) on the CARM Client Portal?
It is important to register early (after Customs Brokers have registered) to ensure that there are no disruptions to your import activity. This will likely not happen in Release 1, but you will experience delays in Release 2, which is scheduled for Spring 2022.
It is also important to become familiar and comfortable using the portal.
Lastly, registering early will ensure you have the correct parties as delegated authorities set up.
What happens if I don’t register on the CARM Client Portal?
Ultimately, you will not be able to import. Here is the answer from the CBSA:
If an importer has not registered and included RPP security (either a bond or cash deposit) details, the importer’s goods will not be released.
At time of release, CBSA’s system will check to see that the importer is registered with RPP security in place.
There is no deadline to register, but after Release 2, an importer will not be able to import without having registered in the portal.
What happens after I register on the CARM Client Portal?
The importing process with us will remain the same until Release 2 when changes come into effect. These changes are:
- A new electronic form call the Commercial Accounting Declaration (CAD) will replace the current B3 (customs coding form) and B2 (adjustment request), and related processes. The CBSA has not yet outlined what the CAD will entail.
- Importers will be required to post their own financial security directly to their accounts to get Release Prior to Payment (RPP) privileges.
CARM Release 0: January 2021
The existing ARL system was moved from its current data centre configuration to the more robust SAP S4/HANA system.
CARM Release 1:
Release 1 launched the CARM Client Portal, a self-service, online tool to facilitate accounting and revenue management processes with the CBSA. CARM Release 1 will enable you to:
- Manage account data and delegate authority to customs brokers
- View statements of account and make payments online
- Classify goods and estimate duties and taxes
- Request advance rulings
CARM Release 2: October 2023
Release 2 will expand on the functionalities of the CARM Client Portal. You will be able to:
- Customize electronic notification options
- Submit new commercial accounting declarations, make corrections and adjustments
- Harmonize billing cycle to align with payment due dates, provide more time to make interest-free corrections
- Submit appeals
- Register and enroll in CBSA programs
CBSA’s CARM Resources
- CBSA’s CARM website
- What is CARM?
- What is CARM? (Video Introduction)
- The CBSA would like your input on CARM
- Features and Benefits of the CBSA Assessment and Revenue Management (CARM) Initiative
- Delegation of Authority, CARM Release 1
- Questions for the CBSA? Contact the CARM project directly via email.