CBSA CARM Client Portal: Release Prior to Payment and Financial Security Under the New System

Key Takeaways

• CBSA CARM Phase 2 went live October 2024, replacing B3 forms with CADs filed through the CARM Client Portal.
• Release Prior to Payment now requires a registered RPP bond with CBSA-calculated financial security minimums, recalculated monthly via K84 statements.
• Importers without portal access or sufficient security face RMD holds and delayed cargo release.
• The 90-day CAD correction window remains, but AMPS penalties for late or incorrect filings now tie directly to portal audit trails.

CBSA rolled out the CARM Client Portal in October 2024 and retired the legacy B3 form the same month. If you’re still wondering what changed, here’s the short version: you now file Commercial Accounting Declarations through a portal, your Release Prior to Payment bond is tied to a monthly recalculated security figure, and cargo sits until CBSA sees both correct delegation and sufficient financial security in the system. We’ve been filing CADs since day one of Phase 2 Release 3, and the switch has been less about new rules and more about new plumbing.

What CBSA CARM Actually Is

CARM stands for Customs Assessment and Revenue Management. It’s the system CBSA built to replace paper B3s, faxed corrections, and the old mainframe accounting ledger. Under CARM every Commercial Accounting Declaration is filed electronically through the CARM Client Portal, validated in real time, and tied to your importer account. The portal tracks your duty payments, your broker delegations, your RPP bond status, and your monthly K84 security statements in one place.

Phase 1 was a soft launch in 2023 for voluntary portal registration. Phase 2 Release 3 went mandatory in October 2024. If you import commercial goods into Canada you need a CARM account, period. Non-Resident Importers based outside Canada also need to register and delegate a Canadian broker through the portal.

The biggest operational shift is that CBSA now knows your payment history in real time. The old system let brokers file B3s and settle duties weeks later through periodic statements. CARM closes that loop. Your account balance, your security sufficiency, and your filing compliance are visible to CBSA the moment a CAD hits the system.

Release Prior to Payment Under CARM

Release Prior to Payment has not disappeared. It works differently. Under the legacy process you posted a customs bond with your broker and CBSA released cargo on the strength of that bond without checking your balance every time. Under CARM your RPP bond is registered directly in the portal, and CBSA calculates a financial security minimum based on your trailing two-month duty average. If your posted security falls below that minimum, CBSA holds your next shipment on RMD until you top up the bond or pay duties in full.

The monthly K84 statement tells you whether your security is sufficient. CBSA issues K84s by the 15th of each month through the portal. We tell clients to check the K84 the day it posts, because a shortfall notice means your next container sits at the port until you fix it. Topping up a bond takes anywhere from same-day to three business days depending on your surety, so waiting until cargo arrives is too late.

RPP bond minimums vary by importer. CBSA looks at your actual duty and tax payments over the prior 60 days and sets the security floor at roughly two months of estimated liability. High-volume importers clearing multiple containers per week will see six-figure bond requirements. Occasional importers bringing in a few shipments per quarter may qualify for the program minimum, which sits around 25,000 CAD as of early 2025. The number is not static—it recalculates every month based on your real activity.

If you don’t want to manage RPP at all, you can pay duties upfront on every CAD. CBSA calls this Release on Full Payment. No bond, no monthly statements, no security recalculations. The trade-off is cash flow: you wire funds to CBSA before taking possession of the goods. Most mid-market importers stick with RPP because the working capital advantage outweighs the administrative load.

Filing CADs Through the CARM Client Portal

The Commercial Accounting Declaration replaced the Customs Coding Form (commonly called the B3) as of CARM Phase 2. Your licensed customs broker files the CAD on your behalf through their portal integration. You as the importer do not file CADs yourself unless you hold a customs broker license, which almost no importers do.

What you must do is delegate your broker in the portal. CBSA will not accept a CAD from a broker who is not on your delegation list. Delegation happens once per broker relationship. Log into your CARM Client Portal account, navigate to Business Delegations, add your broker’s business number, and assign them the Commercial Client Delegate role. Your broker then links your file in their system and can begin submitting CADs.

CADs contain the same data points the old B3 required: HS classification, customs value, country of origin, tariff treatment, applicable duties and taxes. The filing deadline is the same: within five business days of cargo arrival at a sufferance warehouse or bonded facility. The 90-day correction window under Customs Act section 32.2 also carried over. If you discover a valuation error, a missed CUSMA certificate, or a wrong HS code within 90 days of the accounting date, your broker can file an adjustment through the portal without triggering an AMPS penalty, provided the correction is voluntary and complete.

The portal does add one new failure mode: if your account is suspended, your broker cannot file. Account suspensions happen when CBSA flags repeated non-compliance, unpaid balances older than 90 days, or incomplete registration information. We have seen importers locked out of the portal mid-quarter because they ignored a compliance letter. Once suspended you cannot clear cargo until CBSA reinstates the account, which can take weeks.

Financial Security, K84 Statements, and Monthly Reconciliation

The K84 monthly statement is the single most important document in the CARM workflow. It tells you three things: your trailing two-month duty average, your current posted security, and whether CBSA considers your security sufficient. If the statement shows a shortfall, you have until the end of the month to increase your bond or risk RMD holds on future shipments.

CBSA does not call you when your security drops below the threshold. The K84 posts in the portal and sits there. If you don’t check it, your broker will find out when the next CAD is rejected for insufficient security and cargo sits at the terminal accruing demurrage. We run the K84 for every active client the day it posts and flag shortfalls immediately.

Increasing your RPP bond requires filing an amendment with your surety. Some sureties process amendments same-day if the increase is modest. Larger jumps—say doubling a 100,000 CAD bond to 200,000 CAD—can require underwriting review and take three to five business days. If you are ramping up import volumes heading into Q4 peak season, review your bond in August, not October.

Decreasing your bond is also possible but less urgent. If your import activity drops and your K84 shows excess security, you can request a bond reduction to free up credit capacity. CBSA does not automatically lower your requirement; you have to ask.

AMPS Penalties and Audit Trails

CARM did not rewrite the Administrative Monetary Penalty System, but it did make contraventions easier for CBSA to detect. The portal logs every CAD submission, every correction, every delegation change, and every payment. CBSA can pull a complete audit trail for your account in seconds. Under the old system a pattern of late B3 filings might go unnoticed for months. Under CARM the pattern is visible in real time.

The AMPS Master Penalty Document still governs penalty amounts. A Level 1 infraction for a paperwork error starts around 250 CAD. A Level 5 infraction for deliberate misclassification to evade duties can run into five figures. The penalty schedule did not change. What changed is that CBSA now has better data to identify repeat offenders.

Voluntary corrections within the 90-day window remain penalty-free under Customs Act section 32.2, provided you disclose the error before CBSA opens an audit. If CBSA contacts you first, the voluntary disclosure window closes and AMPS applies. The correction itself is still required—you just pay a penalty on top of the duty adjustment.

We file CADs against the CARM portal daily and handle the monthly K84 reconciliation for clients who want the admin work off their desk. If your security picture is shifting or you are unsure whether your broker delegation is set up correctly, get in touch.

Frequently Asked Questions

What does CBSA CARM stand for and when did it launch?

CARM is the Customs Assessment and Revenue Management system. CBSA launched Phase 2 Release 3 in October 2024, making the CARM Client Portal mandatory for all commercial importers and replacing the legacy Customs Coding Form (B3) with the Commercial Accounting Declaration (CAD).

What is Release Prior to Payment and do I need an RPP bond?

Release Prior to Payment lets you take cargo before paying duties. Under CARM you need a registered RPP bond with financial security equal to at least two months of estimated duties and taxes. CBSA recalculates your security requirement monthly via the K84 statement.

How do I file a CAD instead of the old B3?

CADs are filed through the CARM Client Portal by your licensed customs broker. The broker submits the CAD electronically; CBSA validates it in real time and issues a release decision. The CAD replaced the B3 form entirely as of CARM Phase 2.

What happens if my financial security is too low?

CBSA will hold your cargo on RMD (Release on Minimum Documentation) until you top up your security or pay duties upfront. We’ve seen two-day delays turn into week-long holds when importers don’t monitor their K84 monthly statements.

Can I still correct a CAD after filing?

Yes. CBSA allows corrections within 90 days of the original accounting date under Customs Act section 32.2. After that window you need a formal adjustment request, and AMPS penalties may apply if the error resulted in underpayment.

Who needs CARM Client Portal access?

Every importer of record, including Non-Resident Importers (NRI), must register a CARM account and delegate their broker via the portal. Without delegation your broker cannot file CADs on your behalf and your shipments sit at the border.

What is a K84 statement and how often does CBSA send it?

The K84 is your monthly security assessment statement. CBSA calculates your rolling two-month duty average and tells you whether to increase or decrease your RPP bond. Importers receive K84s through the CARM Client Portal by the 15th of each month.

Does CARM change AMPS penalties or audit risk?

AMPS penalty amounts did not change, but CBSA now has real-time audit trails from the portal. Late CAD filings, repeated valuation errors, and missed origin certificate uploads are easier to flag. The Master Penalty Document still governs Level 1 through Level 5 contraventions.