The CARM cutover playbook for importers who waited too long
CARM R2 is fully in force. If your team is still filing on the old financial security model, here is the 14-day sprint to get compliant without stalling shipments.
CARM — the CBSA Assessment and Revenue Management system — is no longer a project. It is the way you file, pay duty, post security, and get release now. Importers who delayed are running into shipments held because their financial security is not posted correctly.
What breaks first
The first thing that breaks is cash flow. Under the old Release Prior to Payment (RPP) program, your broker posted a bond on your behalf and you settled monthly. Under CARM, you post your own financial security — either a surety bond or cash deposit — equal to 50% of your highest monthly duty + GST in the last 12 months.
If that posting is wrong or missing, CBSA switches you to cash-on-release. Every shipment pays duty before the container moves. For a mid-market importer, that’s six figures of cash locked up at any moment. This is exactly the kind of operational drag that proper trade compliance work is meant to prevent.
The 14-day sprint
- Day 1–2. Log in to the CARM Client Portal. Confirm your BN9 and program account. Confirm your broker is delegated with the right permissions.
- Day 3–5. Pull your 12-month duty + GST history from your broker. Calculate 50% of the highest month. That’s your security posting requirement.
- Day 6–8. Contact a surety. Most importers use a CBSA-approved bond; the alternative is a cash deposit held by CBSA. Bonds usually beat cash on annual cost.
- Day 9–11. Post the security in the portal. Confirm the status shows “Active.”
- Day 12–14. Run a test shipment and verify your broker can file under RPP again. Switch any parked shipments back to normal flow.
The trap
The trap is thinking your broker is handling this. Under CARM, the importer of record is the responsible party. Your broker can advise and file, but the security must be posted against your BN9, not theirs. If you discover this the week a container lands, you will pay cash for that release.
If you’re staring at a CARM notice right now, contact us — we’ve done this cutover for dozens of importers and can compress the 14-day sprint into 3 days if we have to. Our customs brokerage team handles the portal setup, security posting, and re-activation end to end.
Frequently Asked Questions
How much financial security do I need to post under CARM?
You must post security equal to 50% of your highest monthly duty plus GST over the last 12 months, per CBSA's CARM requirements. This replaces the old broker-held RPP bond model. Calculate it by pulling your 12-month import history and identifying your peak duty month.
What happens if I don't post CARM financial security before my shipment arrives?
CBSA switches you to cash-on-release. You pay full duty and GST before each container moves, locking up working capital. For mid-sized importers, this can freeze six figures in cash flow at any given time.
Is my customs broker responsible for posting my CARM security?
No. Under CARM, the importer of record must post security against their own BN9. Your broker can advise and help with portal setup, but they cannot post security on your behalf like under the old RPP program.
Should I use a surety bond or cash deposit for CARM financial security?
Most importers use a CBSA-approved surety bond because it costs less annually than tying up cash in a deposit held by CBSA. Compare the surety's annual premium against the opportunity cost of depositing 50% of your peak monthly duty.
How long does it take to get CARM compliant if I haven't started yet?
A methodical approach takes 14 days: portal setup, duty calculation, surety arrangement, security posting, and test shipment. If a container is already en route, an experienced broker can compress this to 3 days with expedited surety placement.
Do I still get release prior to payment under CARM?
Yes, but only if you have active financial security posted in the CARM Client Portal. Without it, CBSA reverts you to pay-before-release. Once security is posted and shows Active status, your broker can file Commercial Accounting Declarations under RPP again.
Where do I post financial security for CARM?
You post it directly in the CARM Client Portal using your BN9 and program account. After posting, confirm the status shows Active. Your broker needs delegation permissions in the portal to file entries on your behalf.