CBSA Grace Period for April 2026 System Outage: What Actually Gets Waived (and What Doesn't)

The Outage

CBSA pushed a system update on April 19, 2026 that took down eManifest, ACI highway, marine CCN processing, and parts of the CARM Client Portal for the better part of 72 hours. Carriers couldn’t file cargo control documents. Brokers couldn’t pull release records. Warehouse operators couldn’t report arrivals or submit A8A amendments. The backlog is still working through as of this writing.

The Border Commercial Consultative Committee sent a note confirming what most of us heard informally by Monday morning: CBSA is implementing a grace period for late filings and reporting failures tied directly to the outage. That grace period started April 19 and runs until CBSA declares the backlog cleared.

The question everyone is asking: what does “grace period” actually cover?

What Gets Waived

The grace period applies to AMPS contraventions that stem from inability to file or report due to system unavailability. Specific scenarios where penalties will not be issued:

• Late cargo control document submission (eManifest, ACI) when the carrier attempted to file during the outage window and the system rejected or timed out.
• Late arrival reports at sufferance warehouses when the operator could not access ACROSS or the warehouse module in CARM.
• Failure to amend a CCN (cargo control number) within the usual 5-day window if the amendment function was unavailable.
• Late CAD (Commercial Accounting Declaration) transmission if the CARM Client Portal was down and the importer or broker could not authenticate or submit.

CBSA has said it will review the system logs. If your transaction hit a 503 error or a timeout during the outage, you’re covered. If you just forgot to file and are hoping to blame the outage, the logs will show that too.

One clarification worth noting: the grace period applies to reporting failures, not to substantive compliance gaps. If your CAD was filed late because the portal was down, the late-filing penalty is waived. If the CAD itself is missing a CUSMA certificate of origin that should have been on file before the goods moved, that’s a separate D11-4-2 verification issue and the grace period does not touch it. CBSA is waiving penalties for late paperwork; they are not waiving audits.

What Still Bites

Three things the grace period does not cover:

Interest on duties and GST. If your RPP bond covered release on April 18 and your K84 monthly statement shows the goods cleared, the payment clock started then. CBSA’s system outage does not extend the payment due date on the statement. If you miss the payment window because you couldn’t log in to make the transfer, call the CBSA CARM support line and get a case number. Interest accrual is a CRA rule, not an AMPS penalty, and the grace period language does not address it.

OGD holds. If CFIA or Health Canada flagged your shipment for examination and you couldn’t retrieve the hold notice because the portal was down, the hold is still live. The goods do not move until the OGD clears them. The grace period means you won’t get penalized for a late response to the hold notice, but it does not make the hold go away. If you’re sitting on perishable goods under a CFIA stop, get on the phone. The examination will happen whenever the inspector is available, and the grace period does not buy you extra shelf life.

SIN/BN15 registration deadlines for new NRIs. If you’re a non-resident importer setting up a new program and your compliance filing deadlines fell during the outage, the grace period applies to the filing, but it does not extend the substantive 30-day registration window from first import. If you missed the window entirely, you still have an NRI penalty exposure. File as soon as the portal is back up and document the outage in your submission notes.

Backlog Strategy

Most of the delayed messages are ACI highway and short-sea eManifest. CBSA is processing them in submission order, not arrival order. If your broker filed a PARS release request at 6:00 AM on April 20 and the truck crossed at 9:00 AM, but the system didn’t accept the ACI until April 21, the release is still valid. The grace period covers the late acceptance.

The problem is dwell time. If your drayage carrier is sitting at the port waiting for release and the system is still catching up, you’re bleeding detention even though the paperwork is clean. CBSA is not reimbursing commercial detention. If you’re moving temperature-controlled freight into Montreal, this is where it gets expensive. We’ve seen two-day delays on reefer containers that should have released same-day, and the carrier is still billing hourly.

If you have a high-value or time-sensitive shipment that arrived during the outage window and is still sitting unreleased, escalate through your broker to the CBSA Commercial Client Services Unit for your region. The grace period does not guarantee fast processing; it just means you won’t be penalized for the delay. The squeaky wheel still gets released first.

Documentation

Keep everything. If you attempted to file during the outage, save the error message, the timestamp, and the transaction ID. If you called CBSA and got a case number, note it on the file. If your broker sent you a status update saying the portal was down, keep that email.

CBSA will review these cases retroactively when the backlog clears. The grace period is a blanket announcement, but individual penalty assessments still go through the normal AMPS review process. If you get a C-14 notice six weeks from now and you know the late filing was outage-related, you’ll need to show proof. “The system was down” is not enough if the logs show you never tried to file.

For warehouse operators, make sure your sufferance processes include a timestamped record of every attempt to report arrival or file an A8A. If CBSA questions a late report in July, you want a log entry that says “Attempted arrival report 2026-04-20 08:15 EDT, ACROSS unavailable, retry at 14:30 successful.”

What Happens When the Grace Period Ends

CBSA has not published an end date. The grace period runs “until further notice,” which in practice means until the backlog is cleared and the systems are stable for 48-72 hours. When they do announce the end, expect a 24-hour notice at most.

After the grace period closes, the usual AMPS timelines and contravention codes are back in force. Late eManifest is a C-40 violation (CAD 250 to CAD 2,500 depending on history). Late CAD is a C-10 (CAD 100 to CAD 5,000). Late warehouse arrival report is a C-60 (CAD 200 to CAD 2,000). If you’ve been skating on late filings during the grace period because the system was flaky, clean it up now. The window is temporary.

One other wrinkle: if you have a CBSA audit or SIMA verification in progress and the outage delayed your document submission, notify the reviewing officer in writing and reference the grace period announcement. The grace period applies to AMPS penalties, not to audit timelines, but most officers will extend your response deadline if you flag it early. If you just go silent and miss the deadline, the grace period does not save you from an adverse ruling.

If your RPP bond sizing felt tight before the outage and the backlog pushed your K84 statement into a higher-than-usual single-month total, run the math now. The bond requirement is based on peak monthly exposure, and April 2026 might be an outlier. That’s a separate conversation, but the outage is a good excuse to pull the numbers.

Source: CSCB