CBSA Extends CLVS BN15 Workaround Through June 2027
Customs Notice 26-13 gives importers another year to complete their CARM registration for courier low-value shipments, but the financial security risk still sits with your broker. If you're running high-volume CLVS and haven't registered for Release Prior to Payment, now is the time to fix that.
On June 12, 2026, CBSA issued Customs Notice 26-13, extending operational measures for the Courier Low-Value Shipment (CLVS) program for another twelve months. In plain terms: if your importer hasn’t finished their CARM registration for Release Prior to Payment (RPP), your broker’s BN15 can continue to secure the release of courier shipments through mid-2027.
This is the second extension. The original grace period was supposed to end this summer. CBSA kicked it down the road again.
What the Extension Actually Does
Under normal CARM rules, every importer needs their own CARM Client Portal account and their own RPP bond to release goods before paying duties. That’s the post-CARM baseline.
But CLVS is a different animal. Courier shipments move fast, volumes are high, and a lot of smaller importers never bothered to set up their CARM accounts properly. The extension lets brokers continue using their own BN15 (their business number for import-export) to backstop releases when the importer’s registration isn’t complete.
Practically speaking: if you’re a Canadian ecommerce operation importing 500 parcels a week via FedEx or UPS, and you still haven’t finished your CARM RPP setup, your broker is carrying your release risk on their books. The shipments clear. But the financial security, the bond that covers duties, GST, and penalties if something goes wrong, is tied to the broker’s BN15, not yours.
That works until it doesn’t.
Where the Risk Actually Sits
The moratorium is a practical necessity. Without it, courier volumes would grind to a halt while thousands of importers scrambled to finish CARM registration. CBSA knows this. So does every broker who files CLVS entries.
But the risk didn’t go away. It just moved.
When your broker’s BN15 is on the hook, their RPP bond is covering your release. If CBSA reassesses a shipment, finds a classification error, or hits you with an Administrative Monetary Penalty, the liability flows through to the broker’s financial security pool first. The broker then recovers from you, but recovery takes time. And if your importer account goes sideways (missed payments, financial trouble, compliance flags), the broker’s bond takes the hit.
Most brokers price this risk into their CLVS fee structure. But not all of them surface it clearly. If you’re running volume through CLVS and your broker hasn’t had a conversation with you about RPP registration timelines, that’s a yellow flag.
What Importers Should Do
The extension buys time. Use it.
If you import via courier, parts, samples, ecommerce inventory, warranty replacements, anything that moves through CLVS, and you haven’t completed your CARM RPP registration, put it on the calendar now. The process involves setting up your CARM Client Portal account, linking your business number, and securing your own RPP bond. It’s not complex, but it’s not instant either.
Your broker should be walking you through this. If they’re not, ask. The baseline question: “Are we releasing under your BN15 or ours?” If the answer is “ours” (the broker’s), the follow-up is “What’s the timeline to move this to our own CARM account?”
The other piece: RPP bond sizing. Once you’re registered, you need your own financial security. The bond amount is based on your estimated annual duties and taxes. CBSA calculates it as a percentage of your projected CAD filings (Commercial Accounting Declarations, the CARM-era replacement for the old B3 form). If you undersize the bond, CBSA won’t let you release. If you oversize it, you’re tying up capital or paying premium on coverage you don’t need.
Most brokers will help you size this. Some will arrange the bond directly. Either way, it’s a conversation worth having before the moratorium ends.
The Bigger CARM Picture
This extension is one piece of a bigger transition. CARM fundamentally changed how customs brokerage works in Canada. Pre-CARM, brokers filed entries and managed bonds on behalf of importers by default. Post-CARM, the model shifted: importers own their CARM accounts, brokers file on their behalf, but the financial security and compliance risk sit with the importer.
Except when they don’t. And CLVS is the biggest exception.
The moratorium exists because the transition hit a practical wall. Thousands of small and mid-market importers didn’t register in time. CBSA had a choice: enforce the rule and choke off courier volumes, or extend the grace period and let brokers continue carrying the load. They chose the latter.
That’s fine for now. But it’s a temporary fix. The financial security model is still moving toward importer-owned accounts. The extension just delays the inevitable.
Feedback Deadline
The Canadian Society of Customs Brokers (CSCB) is collecting member feedback on the extension and related CARM impacts through July 24, 2026. If you’re a broker or an importer working closely with one, this is the window to weigh in on how the moratorium is playing out in practice.
Most of the feedback will focus on operational friction: how the BN15 workaround affects bond utilization, whether the 12-month timeline is realistic for importer registration, and what happens when the extension finally ends. CBSA listens to CSCB input. If you have a take, pass it along.
If your import volumes touch both courier and commercial streams, you’re probably also dealing with warehouse release timing, drayage windows, and cross-dock scheduling at Montreal’s port facilities. The CARM transition affects all of it, but CLVS has its own quirks.
The extension runs through June 2027. If your CLVS shipments are still releasing under your broker’s BN15, the financial security risk is on their books, not yours. Get your CARM RPP registration sorted before the moratorium ends.
Source: CSCB