CBSA Just Sent RPP Bond Adjustment Notices — You Have Until January 15

CBSA posted a notice on the CARM homepage this week: if you received a letter about a new RPP financial security requirement, you have until January 15, 2027 to make the adjustment. No enforcement action before that date.

This is CBSA’s first full annual review cycle since CARM Release 3 went live in October 2024. The RPP bond math changed under CARM, the Statement of Account replaced the old K84, and CBSA now has twelve months of actual data on your payment behavior and duty volumes. If your bond was sized based on pre-CARM estimates or your first few months of filings, this review is the catch-up.

What Drives a Higher Security Requirement

The RPP bond covers the gap between release and payment. Under CARM, that window is wider than it used to be. The old B3 system had tighter reconciliation cycles; the CAD and monthly Statement of Account structure means CBSA is carrying more exposure on each importer’s account.

Your bond requirement is a function of your average monthly duties and taxes owing, multiplied by CBSA’s risk assessment. If your import volumes climbed in 2025 or 2026, if you had late payments on your Statement of Account, or if you’re filing CADs with deferred duty elections (SIMA provisional periods, tariff preference verifications under review, goods subject to anti-dumping margins where the final NRM hasn’t been established), your exposure number went up.

CBSA runs the annual review using the trailing twelve months of CAD data. If you started the year with a bond sized for CAD 80,000 per month and you’re now consistently at CAD 120,000, the math doesn’t work anymore. The notice you received isn’t punitive — it’s actuarial.

What the January 15 Deadline Means

You have until January 15, 2027 to post the additional security or adjust your bond with your surety. CBSA won’t suspend your RPP privileges before that date, which means you can still file CADs and release goods prior to payment as usual.

After January 15, if the shortfall isn’t covered, CBSA can require payment before release on new shipments until the security is brought current. That’s not a formal suspension, but it has the same operational effect: your containers sit at the port or the Montreal sufferance warehouse until the CAD is paid, which kills your inbound scheduling and turns every shipment into a cash flow event.

Most commercial sureties will adjust an existing RPP bond without re-underwriting the whole facility, as long as the increase is under 50% and your payment record is clean. If you’re jumping from CAD 200,000 to CAD 450,000, expect more scrutiny and possibly a collateral requirement.

The Part CBSA Doesn’t Say

The notice is careful to frame this as routine annual maintenance, but the timing tells a different story. CARM is now fourteen months old. CBSA has live data on who pays on time, who routinely maxes out their Statement of Account balance, and who’s filing CADs with aggressive tariff classifications or origin claims that later get adjusted after verification.

If your notice shows a big jump in the required security, it’s worth pulling your last six months of Statements of Account from the CARM Client Portal and seeing where the exposure is actually sitting. Sometimes it’s straightforward volume growth. Sometimes it’s a string of late payments that you didn’t flag as a pattern. Sometimes it’s SIMA subject goods where the provisional dumping margin is still under review and CBSA is treating the full potential liability as outstanding exposure.

That last one is common with steel, aluminum, certain fasteners, and a rotating cast of Chinese-origin goods subject to anti-dumping orders. If you’re importing subject goods and deferring the final SIMA duty pending a Normal Value determination, that deferred amount is counting against your bond even though you haven’t been assessed yet.

What You Actually Need to Do

Pull the notice and check the new amount against your current bond. If the gap is under CAD 50,000 and your payment history is clean, your surety can usually endorse the increase in a week. If it’s a six-figure jump, start the conversation now — January 15 is closer than it sounds once you factor in year-end underwriting slowdowns.

If you’re not sure why the number moved, ask for the calculation. CBSA’s bond unit will walk you through the trailing twelve-month average and the risk multiplier they applied. Sometimes the number is off because a one-time high-value shipment (machinery, aircraft parts, a consolidated entry that should have been split) is skewing the monthly average. If that’s the case, you can make the argument for an adjustment.

If you’re running tight on cash and a higher bond premium isn’t in the budget, the alternative is to move some or all of your imports to a pay-before-release workflow. That kills the RPP advantage, but it zeroes out your bond requirement. Some importers do this seasonally: RPP during high-volume quarters, cash payment during slow months to reduce the surety cost.

The Bigger CARM Pattern

This is the first annual review under the new system, but it won’t be the last. CBSA is clearly using the CARM data infrastructure to tighten the risk management side of customs compliance. The old B3 world had annual reviews too, but they were slower and less data-driven. The CARM Client Portal gives CBSA real-time visibility into every importer’s payment behavior, and the bond review process is catching up to that.

If your import program is scaling, if you’re adding new product lines with different HS classifications or origin profiles, or if you’re bringing in goods subject to SIMA or other trade remedy measures, expect your bond requirement to move every year. Budget for it the same way you budget for brokerage fees — it’s not optional, and it’s not static.

The importers who get caught are the ones who set the bond once in 2024 and assumed it would hold. It won’t.

If you want a second look at your RPP bond sizing or you’re not sure why the number jumped, that’s the kind of file we walk through daily. Get in touch.

Source: CSCB