CARM at Two Years: What Works and What Still Needs Fixing

CARM marked two years this month. The system replaced the old B3 form with the CAD (Commercial Accounting Declaration), moved revenue collection online, and retired decades-old IT infrastructure. The CBSA posted an update calling it a modernization success.

From the broker side, after filing CADs daily for two years straight, here’s what actually changed.

The Statement of Account Works

The monthly Statement of Account in the CARM Client Portal replaced the K84. Importers see duties, taxes, adjustments, and payment deadlines in one place. The old K84 was a batch report that showed up in the mail or via EDI, sometimes weeks after the assessment. The Statement of Account updates in real time.

For importers with RPP (Release Prior to Payment) bonds, the Statement is the single source of truth for what’s owed. You file a CAD on the 5th, goods release the same day, duties post to the Statement, and you pay by the 24th of the following month. The rhythm is predictable. Payment fails or misses the deadline, and the bond gets drawn. That part is clean.

The GST remittance piece also landed where it should. Import GST shows up on the Statement, and importers with a GST account number on file can self-assess instead of paying upfront. That’s a cash-flow win for anyone moving volume.

RPP Bond Sizing Is Still a Guess for Some

RPP bond requirements are calculated on a rolling 12-month average of duties and taxes owing. CBSA pulls that number monthly and adjusts the bond floor. In theory, your bond scales with your import volume.

In practice, we still see importers surprised by bond shortfalls after a quarter of higher volume or a tariff rate change. SIMA duties on subject goods can jump the average fast, especially if a CITT review raised the NRM or dumping margin mid-year. The Statement of Account shows the updated bond requirement, but by then you’re already filing CADs against a bond that might not cover the next batch.

The fix is to review your Statement every month and flag your broker if the bond utilization is running north of 80%. We run that math for clients, but it’s not automatic. If you’re self-filing or using a broker who doesn’t track it, you’ll find out when a release stalls.

Filing CADs Is Faster Than the Old B3 Workflow

The CAD itself is cleaner than the B3. CBSA’s CARM portal validates HS classification, origin claims, and vendor codes before submission. If you fat-finger a CUSMA cert number or use an expired FIRMS code, the system kicks it back immediately. The old B3 would accept the filing, and you’d get a request for information (RFI) three weeks later.

For PARS releases (Pre-Arrival Review System), we file the CAD before the truck crosses, CBSA clears it electronically, and the carrier hauls straight through. RMD (Release on Minimum Documentation) still exists for low-value commercial shipments, and that process hasn’t changed much under CARM. The real improvement is on the accounting side, where payment deadlines and corrections flow through one system instead of three.

Corrections and Adjustments Are Still Slow

CBSA’s correction process for CADs is better than the old B2 (amendment to a B3), but it’s not fast. If you underpaid duty because of a misclassified HS code or missed a SIMA application, you file a voluntary correction. CBSA reviews it, posts the adjustment to your Statement, and you pay the difference.

The problem is the review timeline. Routine corrections, where the importer is self-reporting an underpayment, should process in days. We’ve seen them sit for weeks. Complex ones, like a D-memo interpretation dispute or a CUSMA origin challenge, can stretch into months. The old B2 system was also slow, so this isn’t a CARM regression. It’s just not faster.

For overpayments, you file a refund request under section 74 of the Customs Act. CBSA has four years from the date of the accounting document (now the CAD) to process it. We’re still working duty refund claims from 2024 CADs filed in the first weeks of CARM Release 3. The backlog is real.

NRI Penalties Are Enforced More Consistently Now

Non-Resident Importer (NRI) programs got tighter under CARM. If a foreign supplier is importing into Canada as the importer of record, they need a CBSA-assigned Business Number with an RM account identifier. CARM won’t accept a CAD without one.

Pre-CARM, we saw NRIs slide by with incomplete registrations or using a Canadian consignee’s BN. CBSA would catch it on audit, levy penalties under AMPS (Administrative Monetary Penalty System), and demand proof of registration. Under CARM, the system stops the filing upfront. That’s a good thing. It forces compliance at the point of entry instead of two years later on a verification letter.

The penalty rates haven’t changed. AMPS penalties for NRI violations still reference the Master Penalty Document, and the baseline for an unregistered NRI is in the mid four figures. The difference is that CBSA’s system architecture now makes it harder to file incorrectly in the first place.

What’s Next

CBSA’s update this week mentioned closing revenue gaps and improving compliance. Both are true. The Auditor General flagged billions in uncollected duties over the prior decade, and CARM’s payment enforcement and bond framework are designed to capture that. For importers, the system works if you keep your bond sized correctly, file CADs on time, and review your Statement of Account every month.

The part that still needs work is the correction and refund cycle. If CBSA can bring that review timeline down from weeks to days, CARM will be the system it was designed to be. Until then, it’s faster to file and slower to fix.

Importers who haven’t reviewed their RPP bond sizing since CARM went live should pull their last three Statements of Account and check the utilization percentage. If you’re over 80%, you’re one high-value shipment away from a release delay. That’s the kind of review we run for clients weekly. Get in touch.

Source: CSCB