AMPS Grace Period Ended June 16 — Penalty Enforcement Resumes

The Grace Period Is Over

CBSA announced June 16, 2026 as the end date for the AMPS grace period that covered contraventions during the spring service interruptions. Between April 19 and June 16, electronic transmission errors caused by the CBSA’s own system delays weren’t penalized. That window closed two weeks ago.

Any contravention identified after June 16 is back in normal penalty scope. If your broker or in-house team has been filing CADs with looser data validation during the grace period, that practice just became expensive.

What the Grace Period Covered

The service interruptions hit commercial messaging systems in mid-April. PARS releases, RMD processing, and eManifest acknowledgments all saw delays. Importers and brokers who missed electronic filing deadlines or submitted incomplete CADs because CBSA’s own infrastructure was lagging weren’t hit with Administrative Monetary Penalties for those specific contraventions.

That was the right call. You can’t penalize a filer for missing a deadline when the system that receives the filing is down.

But the grace period was never a blanket amnesty. It only applied to contraventions directly caused by the service interruptions. If you filed a CAD with the wrong HS classification, incorrect CUSMA origin claim, or missing commercial invoice reference during that period, those errors were still in scope. The grace period wasn’t a hall pass for sloppy compliance work.

AMPS Enforcement Is Back to Normal

Starting June 17, CBSA’s penalty issuance is back to standard enforcement. The contraventions that trigger AMPS haven’t changed. Late CAD filings, incorrect accounting declarations, missing or incomplete supporting documents, and eManifest errors all carry fixed penalties under the Master Penalty Document.

For context, a late CAD filing is CAD 200 for a first contravention, CAD 500 for a second, and CAD 1,000 for subsequent. Missing or incomplete commercial invoice details start at CAD 400. Incorrect origin claims under CUSMA or CETA can run higher depending on the value impact.

Those penalties apply per contravention. If you’re filing 40 CADs a week and your data validation has been coasting, the math gets uncomfortable fast.

Where Importers Should Focus Now

The end of the grace period is a good forcing function to audit your CARM Client Portal practices. Three areas worth checking:

CAD Filing Deadlines

Release prior to payment doesn’t mean file whenever. The CAD is due within five business days of release for most commercial importations. If your broker is filing at day four as a routine practice, you’re one system hiccup away from a late-filing penalty.

We file CADs within 48 hours of release unless there’s a specific documentation delay. That buffer matters when CBSA’s acknowledgment system lags or a carrier’s manifest data is incomplete.

Supporting Document Completeness

The CAD must reference every commercial invoice, packing list, and certificate of origin that supports the declared value and classification. If your freight forwarder is consolidating shipments and your broker is filing against a summary invoice without the underlying line-item detail, that’s incomplete documentation.

CBSA doesn’t care if the missing detail is sitting in your ERP system. If it’s not attached to the CAD or referenced in a way CBSA can retrieve, it’s incomplete.

HS Classification and Origin Claims

This is where most first-time AMPS penalties land. An HS code that’s off by two digits can shift the duty rate and invalidate a CUSMA preference claim. If your classification is based on a supplier’s tariff suggestion rather than a formal ruling or broker analysis, expect that to surface in a CBSA verification.

We see this most often with dual-use goods that sit on the line between two HS chapters. A product marketed as industrial equipment might classify as machinery (Chapter 84) or as electrical apparatus (Chapter 85) depending on its primary function. The difference can be a 6% duty swing and a CUSMA eligibility question.

The CARM Transition Context

The spring service interruptions happened during CARM’s first full quarter of mandatory use. The CBSA moved all commercial importers from the legacy ACROSS system to the CARM Client Portal in October 2024, and the transition has been rough in places.

The grace period was a practical acknowledgment that the new system still has bugs. Commercial messages that used to process in minutes were taking hours. Release notifications that should trigger automatically were getting stuck in queue.

That’s mostly resolved now. PARS and RMD releases are processing at normal speed. The CARM Client Portal’s uptime is solid. But the grace period bought CBSA time to stabilize the infrastructure without penalizing filers for delays outside their control.

The trade-off is that filers also had two months to test their CARM workflows without penalty risk. If your brokerage process still has gaps, this is the last low-stakes window to fix them.

Practical Next Steps

Pull your CAD filings from the last 90 days and check three things: filing timeline from release to submission, completeness of supporting documents, and classification accuracy on your top 20 import lines by volume. If any of those show patterns of late filings, missing details, or classification guesses, that’s what CBSA’s post-grace-period enforcement will hit.

For importers using sufferance warehouse services in Montreal or other major ports, coordinate with your warehouse operator on documentation handoff timing. A container that clears CBSA exam on Thursday but doesn’t get its commercial invoice uploaded to CARM until the following Tuesday is a late-filing risk. FENGYE LOGISTICS runs dock-to-CARM uploads same-day to avoid exactly that gap — if your current setup doesn’t, that’s worth fixing.

The grace period gave everyone breathing room. Penalty enforcement is back. If your CARM data practices have been coasting, tighten them up now before the first penalty notice lands.

We run AMPS audits for clients who want a second set of eyes on their filing patterns before CBSA does. Get in touch if that’s useful.

Source: CSCB