Tax Insights: Businesses importing goods into Canada must register for CARM – Action required!

August 29, 2023

Issue 2023-04R

August 29, 2023 update: On August 11, 2023, the Canada Border Services Agency (CBSA) released an update on Release 2 of the CBSA Assessment and Revenue Management (CARM) initiative. In:

  • October 2023, the CARM Release 2 system will be available for selected industry partners who want to test their own internal systems, and for software service providers to continue to certify their software with CARM
  • May 2024, the CARM will come into force and it is expected that the 180 day transition plan for the Release Prior to Payment (RPP) program will begin  
  • October 2024, further enhancements to the CARM are expected to be available 

Importers should register with the CARM Client Portal before the coming-into-force date in May 2024 to minimize border delays and benefit from the RPP transition period (i.e. importers will be assigned RPP qualifying status for a 180 day transition period allowing them to adapt to this new model, while ensuring that border disruptions are mitigated). 

In addition, on August 17, 2023, the CBSA released “What we heard report: Proposed regulatory amendments to support the implementation of CBSA Assessment and Revenue Management (CARM).”* The report summarizes key themes from comments that the CBSA received from interested parties (between November 26, 2022 and January 10, 2023) on the proposed regulations and regulatory amendments to fully implement CARM.  

The remainder of this Tax Insights was published on January 24, 2023. It has not been altered to reflect the CBSA’s August 11, 2023 update or the release of the CBSA’s report on August 17, 2023. 

* CBSA “What we heard report: Proposed regulatory amendments to support the implementation of CBSA Assessment and Revenue Management (CARM)” available at


In brief

The CBSA Assessment and Revenue Management (CARM) is an initiative by the Canada Border Services Agency (CBSA) to transform and modernize the collection of duties and taxes for commercial goods being imported into Canada. The initiative targets the revenue and cash management systems that are currently in place for assessing and collecting duties and taxes, and replaces them with a simplified process that includes electronic payment options.

Participation in the CARM is mandatory for all Canadian-resident and non-resident businesses that import goods into Canada and their trade chain partners (TCPs) that interact with the CBSA. Importers that do not participate will be prohibited from bringing goods into Canada. The CARM is expected to be operational in October 2023; importers should start preparing to meet the new requirements under the CARM to avoid unnecessary delays and interruptions to their importation activities.

In detail


In May 2021, as part of Release 1 of the CARM initiative, the CBSA launched the CARM Client Portal (CCP), a self-service tool to facilitate accounting and revenue management processes with the CBSA. The CCP can be accessed by importers, customs brokers and certain trade consultants.  

Under Release 1, organizations are required to:

  • register their business on the CCP, create a user profile/business account, and identify and designate a Business Account Manager (BAM)
  • delegate authority to all their TCPs so that they can continue managing the organization’s commercial importation activities under the CARM

A TCP includes:

  • employees that are responsible for customs and trade compliance activities, and for the payment of the organization’s duties and taxes 
  • service providers that help with any customs and trade-related activities (i.e. trade consultants and customs brokers)  

The CBSA website for the CCP1 provides many tools2 to help businesses, including a worksheet for collecting the required information and completing the registration steps.

It is important to know that the new measures being implemented by the CARM will not impact the process for releasing imported goods. This function remains with the business’ customs broker (if those services are utilized).

Release 2 of the CARM initiative (expected October 2023)

Release 2 of the CARM initiative is currently scheduled for October 2023 and will expand the functionality of the CCP, including the ability for an importer to post and monitor security to participate in the Release Prior to Payment (RPP) program, among other functions.   

The RPP program allows goods to be released before duties and taxes are paid and facilitates the movement of goods across the border. To participate in the program, importers will need to post their own financial security (i.e. a surety bond or cash deposit) and pay the Statement of Account (SOA) to the CBSA.

PwC observes

Importers who fail to comply with the new requirements under Release 1 may be prohibited from bringing goods into Canada until the CCP registration process has been completed and all other requirements have been met, including the posting of financial security under Release 2.

Businesses should pay attention to, and properly manage, the requirements of Release 2, because goods may be held at the border if they do not post the appropriate financial security or miss paying the SOA.

The takeaway

If your business interacts with the CBSA, you should ensure that you meet the requirements under the CARM by October 2023. You should start the process to meet these requirements by: 

  • identifying a BAM
  • creating a user profile
  • registering your business on the CCP
  • delegating authority to all your TCPs
  • posting the appropriate financial security
  • paying your duties and taxes to the CBSA through the CCP


1. CBSA, CARM Client Portal at
2. CBSA, CARM Client PortalOnboarding documentation includes:
Registering a Business on the CBSA Assessment and Revenue Management (CARM) Client Portal
User Guide - Onboarding to the CARM Client Portal
User Guide - Delegation of Authority in the CARM Client Portal

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Martha Goncalves

Martha Goncalves

Partner, Tax, Customs & International Trade, PwC Canada

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Dean Landry

Dean Landry

National Tax Leader, PwC Canada

Tel: +1 416 815 5090