AMPS Grace Period Still Open After April 2026 CBSA System Outage

What Happened on April 19

CBSA rolled out a system update on April 19, 2026 that broke commercial message processing across multiple platforms. Cargo control documents, eManifest ACI submissions, PARS releases, and CAD filings all backed up for days. Some brokers couldn’t transmit release requests. Some importers couldn’t see their CARM Client Portal dashboards refresh. Some freight forwarders couldn’t close cargo control numbers because the inbound message queue was stalled.

The agency acknowledged the problem within 48 hours and issued TCC26-0090, which announced an AMPS grace period for any contraventions tied to the outage. That bulletin has been updated 57 times since April. As of the most recent BCCC reminder on May 4, the grace period remains open. CBSA has not set an end date.

What the Grace Period Covers

The grace period applies to Administrative Monetary Penalty System contraventions that stem directly from the April 19 system failure. That includes:

• Late CAD accounting (filing past the five-day deadline because the portal was unavailable or the broker couldn’t transmit)
• Missed RMD or PARS release windows where the cargo control document wasn’t processed in time
• Late corrections or amendments where the importer couldn’t access the CARM Client Portal to submit adjustments
• Coding errors on declarations that would normally trigger C-class infractions, if the error arose because reference data (tariff tables, D-memo guidance, or HS lookup tools) wasn’t loading

The grace period does not excuse substantive compliance failures. If you misclassified steel pipe under the wrong HS heading and CBSA opens a verification two months later, the April outage won’t save you. The grace period covers process breakdowns caused by the system going down, not underlying trade compliance mistakes.

Why the Bulletin Is Still Open

CBSA hasn’t closed TCC26-0090 because the backlog isn’t fully cleared. Some commercial messages from late April are still being processed in mid-May. The agency is working through queued cargo control updates, delayed examination requests, and CAD transmissions that timed out and had to be resubmitted manually. Until every message in the April queue is cleared and CBSA confirms that all downstream penalty assessments have been reviewed, the grace period stays open.

For brokers, that means you can’t assume the problem is over just because your own filings are going through today. If you filed a CAD on April 22 and it didn’t post until May 1, and CBSA’s automated penalty engine flagged it as late on April 27, you’re still covered under the grace period even though the system looks fine now. Keep the TCC bulletin reference and your transmission logs.

What to Document Right Now

If any of your April or early May filings were delayed, document the timeline and keep the proof. CBSA has said it will review penalties manually, but that review depends on you being able to show that the delay was caused by the outage and not by your own late submission.

Save:

• Transmission timestamps from your broker software (the time you hit “send” vs the time CBSA acknowledged receipt)
• Screenshots of error messages or portal downtime notices
• Email or phone correspondence with CBSA’s technical support line
• Cargo control numbers and the dates they were opened vs closed
• Any internal notes your broker made about retry attempts or system timeouts

If CBSA issues an AMPS notice six months from now for a late CAD filed in April, you’ll need that paper trail to invoke the grace period. The Master Penalty Document will show the contravention date, but it won’t automatically flag that the filing was delayed by the outage unless you provide context.

How This Affects CARM Compliance Scoring

CARM’s compliance scoring engine tracks penalty frequency and assigns risk ratings to importers and brokers. A single late CAD isn’t catastrophic, but repeated infractions move you up the risk ladder and increase the odds of a full compliance audit or a bond review.

The grace period should prevent April-outage penalties from landing on your compliance record, but only if CBSA’s manual review process works as intended. If you see a penalty appear in your CARM portal for a filing that was clearly affected by the April 19 outage, dispute it immediately and cite TCC26-0090. Don’t let it sit. Once a penalty is assessed and the 90-day dispute window closes, you lose the ability to challenge it, grace period or not.

For brokerage clients who handle their own CAD filings under a direct-representation setup, this is especially important. CBSA’s automated system doesn’t know you’re covered by the grace period until you tell it. The bulletin is open, but enforcement is decentralized, and not every CBSA officer reviewing penalties six months later will remember the April outage without a prompt.

When the Grace Period Will Close

CBSA hasn’t published a target date. The BCCC reminder from May 4 says the bulletin remains in open status, but offers no timeline. Historically, grace periods tied to system outages stay open until the agency confirms that (a) all delayed messages are processed, (b) all affected importers and brokers have been notified, and (c) the penalty review queue is cleared.

That usually takes three to six months. If you’re filing CADs today and the system is stable, you’re almost certainly outside the grace period window for new filings. The protection applies to transactions that were in flight during the outage, not to everything filed afterward.

If you’re not sure whether a specific filing is covered, check the cargo control creation date and the CAD transmission date. If both fall between April 19 and roughly April 30, and you experienced delays, you’re likely covered. If the cargo arrived May 10 and you filed May 12 with no system issues, the grace period doesn’t apply.

What to Do If You Receive an AMPS Notice

If CBSA issues a penalty notice for a contravention that occurred during the April outage window, respond within 90 days and cite TCC26-0090 Update 57. Include your documentation: transmission logs, error messages, cargo control timelines, and any correspondence with your broker or CBSA support.

The notice will include a contravention code (e.g., C011 for late accounting, C035 for incorrect HS classification). If the contravention is procedural (late filing, missed deadline, incomplete documentation) and the delay maps to the April 19 outage, the grace period should apply. If the contravention is substantive (wrong tariff treatment, missed SIMA duty, incorrect origin claim), the grace period won’t help unless the error was caused by reference data being unavailable during the outage.

For clients working with us on compliance reviews, we’re flagging every April and early May filing for documentation review before CBSA’s penalty engine catches up. If you’re doing this in-house, do the same. Don’t wait for the notice to arrive.

Ongoing CBSA System Stability

The April 19 outage was the third significant CARM-related system disruption since the portal went live in October 2024. The first two were short (under 24 hours). This one lasted weeks and required manual intervention at scale. CBSA’s technical updates have been more frequent since the April incident, which suggests the agency is still working through stability issues as transaction volume ramps up.

If your import volume is high enough that a multi-day portal outage would stall releases and cost detention fees, that’s a planning problem worth solving now. Some importers are pre-positioning inventory at Montreal sufferance warehouses so that a CBSA system hiccup doesn’t freeze their entire inbound pipeline. Others are building buffer stock domestically. Neither option is cheap, but both are cheaper than explaining to your VP of ops why 40 containers are sitting at the port accruing per-diem because the CARM portal is down and you can’t file a CAD.

We’re not seeing widespread outages in May, but the system is still fragile. If you’re filing CADs manually or relying on broker portals that pull live data from CBSA, assume another outage will happen and document everything.

If you’re still cleaning up April filings or you want a second look at your AMPS dispute strategy, get in touch. We’ve filed disputes under TCC26-0090 for a dozen clients already, and CBSA’s review process has been consistent so far.

Source: CSCB