CARM Exchange Rate Errors Hit December 2025 and July 2026 CADs

The CARM exchange rate discrepancy bulletin (5423) is not the usual “we’re aware and working on it” noise. This one has direct cash consequences. CADs filed with direct shipment dates of December 20, 2025 (all currencies) and July 21, 2026 (EUR, HKD, INR, JPY, KRW, MXN, MYR, NOK, NZD) used incorrect exchange rates pulled from a source system that didn’t sync properly with CARM’s assessment engine. That means duties and taxes calculated at the wrong rate. Some importers underpaid, some overpaid. Both groups need to reconcile.

What the discrepancy means in practice

CBSA uses daily exchange rates published by the Bank of Canada for duty and GST calculations. The rate that applies is the rate in effect on the direct shipment date. When the source feed doesn’t match what CARM actually used, the math goes sideways.

If you filed CADs on those dates, the duty/tax line on your CAD confirmation doesn’t match what it should have been. For importers on Release Prior to Payment (RPP) bonds, the immediate issue is whether you underpaid. CARM debits your financial security account based on the filed CAD. If the filed amount was too low, you’re short. If it was too high, you overpaid and CBSA owes you.

The currencies hit on July 21, 2026 are heavily used in Canadian import flows: EUR for European supplier invoices under CETA, JPY for Japanese automotive and electronics, MXN for CUSMA goods, KRW for Korean steel and consumer products. December 20, 2025 hit everything, including USD.

RPP bond and K84 reconciliation

If you’re filing under an RPP bond, your monthly K84 statement is where this surfaces. The K84 reconciles what CBSA debited against what you actually owe. If the exchange rate error caused an underpayment, the shortfall shows up as a balance owing. You’ll need to top up your financial security or settle the difference.

If you overpaid, the K84 should reflect a credit. CBSA doesn’t auto-refund. You request it through the CARM Client Portal. The refund process has been slow since CARM went live.

For importers who don’t use RPP and pay duties at time of filing, the reconciliation is simpler but still manual. You compare the CAD confirmation to what the correct rate should have been (Bank of Canada daily rate for the direct shipment date), calculate the difference, and either submit a refund request or wait for CBSA to issue a demand.

Check your CADs filed on those dates

Pull your filed CADs for December 20, 2025 and July 21, 2026 direct shipment dates from the CARM Client Portal. Look at the duty and GST lines. Cross-check the exchange rate used against the Bank of Canada daily average for that date (https://www.bankofcanada.ca/).

If the variance is small, it’s probably not worth the administrative lift. If the variance is material, you need to act.

For underpayments, CBSA will eventually catch it and issue a reassessment. You can self-correct by filing an adjustment request through CARM, which keeps you ahead of an AMPS penalty for under-declaration. For overpayments, CBSA won’t volunteer the refund. You request it.

Why this keeps happening

CARM’s exchange rate feed architecture is fragile. The system pulls rates from a central source (Bank of Canada), but the handoff between the source and CARM’s assessment engine has failed before.

The December 20, 2025 incident hit all currencies, which suggests the entire feed dropped or stalled. The July 21, 2026 incident hit nine specific currencies, which suggests a partial sync failure.

CBSA’s fix is always retroactive. They issue a bulletin, importers scramble to check filed CADs, and reconciliation happens manually. There’s no auto-correct in CARM for this. The system doesn’t flag affected CADs in your portal view. You have to know the dates, pull the records, and do the math yourself.

Freight and warehousing timing

If you’re working with a Montreal sufferance warehouse or cross-dock operation, direct shipment date disputes come up when cargo sits in storage before release. The direct shipment date is the date the goods started their journey to Canada, not the date they arrived at the warehouse or cleared customs.

For ocean freight, that’s typically the on-board date at origin. For air, it’s the departure date. If the carrier’s manifest or house bill has one date and your commercial invoice has another, CBSA defaults to the manifest. That matters here because the exchange rate error is keyed to specific calendar dates. If your shipment’s direct date falls on December 20, 2025 or July 21, 2026, you’re in scope. If it’s one day earlier or later, you’re not.

What to do now

Run a query in CARM for CADs filed with direct shipment dates of December 20, 2025 and July 21, 2026. Export the list. For each entry, compare the duty and GST calculated to what it should have been using the correct Bank of Canada rate.

If you underpaid, file an adjustment request or wait for CBSA’s reassessment. If you overpaid, submit a refund request through the Client Portal. Include the CAD transaction number, the incorrect rate used, the correct rate, and the dollar variance.

If you’re on an RPP bond, check your next K84 statement for discrepancies tied to those dates. If your bond security margin is tight, an unexpected debit from the December 20 error could put you below the required threshold, which triggers a bond top-up demand from CBSA.

For compliance program work, this is a good test case for your CAD review controls. Most importers run monthly duty reconciliation, but exchange rate errors are easy to miss if you’re not cross-checking the rate used against the Bank of Canada daily average. The CAD confirmation doesn’t show the rate explicitly. You have to back-calculate it from the invoice total and the duty assessed.

If your RPP bond drew down more than expected in December 2025 or your July 2026 K84 looks off, this bulletin is probably why. Get in touch.

Source: CSCB