CBSA moves import accounting to CARM

Summary#

These proposed regulations would let the Canada Border Services Agency move much of commercial import accounting and payment into a new electronic system called CARM (CBSA Assessment and Revenue Management). They would require most accounting and many financial-security transactions to be done electronically, simplify billing cycles and payment dates, and set rules for electronic guarantees. The proposal was published on November 26, 2022 and is tied to the planned CARM Release 2 (target October 2023).

What it does#

• Require most commercial import accounting to be submitted electronically through the CARM Client Portal (CCP) or by Electronic Data Interchange (EDI), with limited exceptions for outages or other extraordinary circumstances.
• Create a new regulation, the Financial Security (Electronic Means) Regulations, that:
  • lets importers or other trade parties confirm or post financial security electronically instead of using paper bonds, certified cheques or cash;
  • sets what information must be provided about a security and how a surety must be notified if an agreement changes or ends.
• Simplify billing and payment timing:
  • reduce billing options from three to two periods (one running 1st–last day of month, the other 18th–17th);
  • set a single harmonized payment due date: 10 weekdays after the 17th of the month in which the statement is issued;
  • require accounting for many shipments within 5 business days of release for some streams;
  • allow a penalty-free correction period up to the payment due date (so declarations can be revised online before payment is due).
• Require the Canada Post Corporation to make certain customs payments electronically (subject to exceptions for system problems).
• Add a temporary transition rule letting importers get release prior to payment for up to 180 days after the rules come into force if they register in the CCP.
• Make smaller housekeeping updates across many customs regulations (name changes, remove some paper-only rules, etc.).

Who's affected#

• Importers (the source estimates about 228,000 importers interact with CBSA processes).
• Trade chain partners such as customs brokers, carriers, freight forwarders, and warehouse operators (bonded and sufferance).
• Duty free shop operators and participants in special programs like Customs Self-Assessment (CSA) and courier low-value shipments.
• Surety companies and other financial security providers who back importers’ obligations.
• Canada Post Corporation for mail-related duties.
• The Canada Border Services Agency itself — it will run and maintain the CARM system.
• Many affected businesses are small: the source estimates roughly 97% of businesses in affected sectors are small firms. The rules include exceptions for parties who cannot use electronic means (for example because of limited internet access) and allow service providers to submit data on a client’s behalf.

Why it matters#

• Less paper and fewer in-person steps: businesses that import goods should spend less time on paperwork, and customs brokers can move more operations online.
• Money and scale: over a 10-year period the agency estimates total implementation costs of $545.8 million and total benefits of $1.6 billion, giving a net benefit of about $1.06 billion (discounted at 7%).
• Upfront work and costs: companies will need to update IT and train staff to use CARM. Some small businesses may face short-term costs even though the analysis predicts overall long-term savings.
• Faster fixes and fewer penalties: the ability to correct declarations online before the payment date should reduce late adjustments, interest and administrative hassle.
• Revenue and enforcement: electronic confirmation of surety should make it easier for the CBSA to claim unpaid duties and reduce lost revenue.
• This is a regulatory proposal (Part I notice). It was published for comment on November 26, 2022 and the CBSA tied the coming-into-force to the readiness and launch of CARM Release 2 (target October 2023).