On October 21, 2024, CARM will become the official system of record for imposing or levying duties and taxes. This will introduce: 

• changes to the Release Prior to Payment (RPP) Program 

• electronic commercial accounting declarations that you can correct and adjust 

• harmonized billing cycles 

• new offsetting options 

• electronic management of appeals and compliance actions 

• the ability for resident trade chain partners to register for a Business Number (BN9) 

• enrolment in various CBSA commercial programs 

Benefits and features 

Once fully implemented, CARM will simplify the overall importing process by: 

• providing a modern interface for importing into Canada 

• giving importers self-service access to their information 

• improving consistency of compliance with trade rules  

Changes to the Release Prior to Payment Program 

The Release Prior to Payment (RPP) Program allows participants to obtain the release of goods from the CBSA before the final accounting and payment of duties and taxes. 

When CARM becomes the official system of record, obtaining the release of imported goods prior to accounting and payment of duties will significantly change for importers. They will no longer be able to use their customs broker’s RPP security to clear shipments in advance of paying duties and taxes. Importers who want to participate in the RPP program to continue these privileges will be required to post their own financial security. They will have the following options: 

• Option 1: a financial security instrument for 50% of their highest monthly accounts receivable (inclusive of GST) with a minimum financial security of $5,000 per import program (RM) 

• Option 2: cash security deposit for 100% of their highest monthly accounts receivable (inclusive of GST) 

The current RPP program will remain in effect until October 21, 2024, at which point the new requirements are expected to take effect. In anticipation of these changes, the CBSA has developed the RPP Transition Plan to help importers transition to the new requirements. This plan includes instructions on how to: 

• calculate their security 

• post a bond 

• make a cash security deposit 

Transitioning to a new model for meeting financial security requirements  

The Canada Border Services Agency (CBSA) has developed a transition plan to support importers when the new Release Prior to Payment requirements take effect in October 2024. All importers with a CARM Client Portal account or a history of importing commercial goods into Canada and an account in good standing will automatically benefit from the transition period. 

Once CARM becomes the official system of record, importers will have 180 calendar days to make their own financial security arrangements. 

Steps you must take NOW! 

• CARM Client Portal: Register your business 

• CARM Client Portal: Delegate authority to business employees needing access 

• CARM Client Portal: Delegate authority to LCS as your service provider 

• Financial Security: Understand the financial security options and decide which option is best for your company 
• Financial Security: Understand the RPP Transition period and what is required

        1. CARM Client Portal: Register your business 

If you haven’t yet registered, we recommend doing so immediately. We’ve seen many importers run into issues with the CARM Portal registration process that require CBSA support. As we get closer to October, the CBSA response time may take 1-2 weeks or longer.  

The most important role to assign internally is that of the Business Account Manager (BAM). This does not need to be the owner of the company but should be the employee directly responsible for CARM duties. The first employee to register on the Portal will be automatically assigned as the BAM. It is recommended for businesses to have a minimum of 2 BAMs.

Review the User Guide – Onboarding to the CARM Client Portal. 

       2. CARM Client Portal: Delegate authority to business employees needing access 

Once your CARM Portal registration is done, you must delegate authority to the other employees at your business that will need access. At minimum, a second Business Account Manager (BAM) should be registered.  

Review the following guides: User Guide – Delegation of Authority and Linking Employees to Your Company’s CARM Client Portal Account  

       3. CARM Client Portal: Delegate authority to LCS as your service provider 

You will also need to delegate authority to LCS as a third party service provider. As your broker, we’re still clearing and accounting for your shipments, but as of October 21, 2024 we cannot ‘finalize’ the entries with customs. This will result in late accounting and possible penalties.  

Review the User Guide – Delegation of Authority. 

      4. Financial Security: Understand the financial security options and decide which one is best for your company 

Get familiar with the new requirements that will begin on Oct 21st, options for posting security to CBSA and plan which one you will obtain during the upcoming RPP transition period. 

Review the following guides:  User Guide – Financial Information and Payments and Frequently Asked Questions – CARM Financial Security. 

      5. Financial Security: Understand the RPP Transition period and what is required 

Importers will have 180 days to post their chosen financial security to the CARM Client Portal beginning on October 21, 2024. During this time, importers must still make payments on a monthly basis for any GST and/or customs duties owing on their shipments. However, the requirement to have posted security is waived for 180 days.  

Review the User Guide: Release Prior to Payment (RPP) at CARM Release 2- Transition Plan 

Check out these other user guides:

• Post financial security for Release Prior to Payment privileges
• View your Release Prior to Payment financial security information