Auditor General Says CARM Didn't Deliver Efficiency — Brokers Aren't Surprised
Karen Hogan's report confirms CARM works but missed its value-for-money targets. After nearly two years of filing CADs, here's what that finding actually means for your operation.
The Report That Landed Today
Auditor General Karen Hogan tabled a report in the House of Commons concluding that CBSA’s CARM system processes customs duties and taxes but didn’t generate the expected efficiencies and value for money. If you’ve been filing Commercial Accounting Declarations since CARM Release 3 went live on October 21, 2024, that finding probably tracks with your own experience.
CARM works. The Statement of Account posts monthly. RPP bonds clear. The revenue machinery runs. But the promise was modernization that would make customs clearance faster, cheaper, and less administratively painful. Nearly two years in, most brokers and importers would struggle to name where that efficiency landed.
Where CARM Actually Improved Things
The CARM Client Portal consolidated what used to be scattered across multiple CBSA touchpoints. Importers with a Business Number can see their full duty and tax position in one place, pull Statements of Account without calling their broker, and track financial security requirements without guessing. That part works better than the old regime.
Release prior to payment under an RPP bond is cleaner than it was under the B3 system, assuming your bond was sized correctly from the start. The math is transparent: average monthly duties and taxes over the trailing twelve months, times the coverage factor CBSA assigns to your compliance profile. If your brokerage set that up properly in late 2024, you’ve had uninterrupted clearance authority since.
The CAD itself is a better instrument than the B3. Line-level detail on value for duty, tariff treatment, origin claims, and SIMA applicability makes it easier to audit your own filings after the fact. When a CBSA verification notice arrives eighteen months later asking about transaction value adjustments on a specific entry, you can pull the CAD and see exactly what was declared.
Where the Efficiency Promise Fell Apart
Processing times didn’t compress the way CBSA projected. PARS releases that used to clear in under an hour still take the same time. RMD releases are no faster. Exam-flagged shipments still lose two to three working days, and the examination booking process is identical to what it was before CARM.
The administrative burden on importers went up, not down. Every importer now needs a CARM Client Portal account, a mapped relationship to their broker, and enough internal process to reconcile monthly Statements of Account against what their broker filed. Small and mid-market importers who used to treat customs as a fully delegated function now have compliance overhead they didn’t budget for.
Non-Resident Importer registrations are more complex under CARM. The old SIN/BN15 path still exists, but the handoff between the importer of record, the resident agent, and the financial security arrangement requires more coordination. We see NRI setups that used to take a week now stretching past two.
SIMA duty assessments and corrections take longer to resolve. The process for disputing a Normal Value ruling or challenging an anti-dumping margin used to involve a phone call to the SIMA officer and a follow-up letter. Now it’s a multi-step workflow in the Client Portal with longer reply windows. If you’re importing subject goods and get hit with an unexpected AD/CVD assessment, the clock to file a re-determination request under section 60 hasn’t changed, but the mechanics are slower.
What Importers Should Actually Care About
The AG report won’t change your day-to-day clearance process. CARM isn’t going anywhere. CBSA isn’t rolling back to the B3. The finding is a policy and budget question for Parliament, not an operational signal for importers.
What you should care about: your RPP bond is probably undersized if your import volumes have grown since the trailing-twelve-month calculation CBSA ran in 2024. The Statement of Account will show when you’re approaching your coverage limit, but by the time that warning appears, you’re already close to a release hold. If your monthly duty and tax liability has climbed, get your bond recalculated before CBSA flags it.
If you’re still reconciling Statements of Account manually, that’s a compliance risk you can fix. The portal exports to CSV. Your ERP or trade management system should be ingesting that data and matching it against purchase orders, commercial invoices, and freight bookings. Importers who treat the Statement of Account as a monthly surprise instead of a reconciled control total are the ones CBSA verification teams target.
Origin claims under CUSMA, CETA, and CPTPP haven’t gotten easier under CARM. The CAD captures your tariff treatment election and your certifying statement, but the substantiation burden is identical. If CBSA sends a verification of origin request, you still need the supplier’s certification, the production records, and the regional value content calculation. The only difference is that the request arrives through the Client Portal instead of by registered mail.
For importers running bonded warehouse programs or using duty deferral mechanisms, CARM changed the reporting cadence but not the rules. If you’re moving goods in bond from the port to a sufferance warehouse for release as needed, the accounting declaration still happens at the point of release. Importers working with our partner’s Montreal facility have seen the same clearance windows and the same dwell-time economics as before CARM.
The Real Question the Report Raises
CBSA spent years building CARM and sold it as a transformation. The AG is saying it works but didn’t deliver the return. That gap matters because the next phase of customs modernization—whatever CBSA builds after this—will face harder scrutiny on whether the investment is worth it.
For importers, the lesson is simpler. CARM is the system you have. It’s stable, it processes revenue correctly, and it’s not going to revert. The efficiency gains CBSA promised didn’t materialize, which means you’re still paying for the same level of broker support, the same compliance overhead, and the same friction at the border you had before October 2024. Budget accordingly.
If your CARM Client Portal setup still feels like a bolt-on instead of a working part of your trade operation, that’s worth fixing now rather than waiting for CBSA to improve it. Get in touch.
Source: CSCB