If you import commercial goods into Canada, or file on behalf of someone who does, CARM now sits at the centre of how you account for duties and taxes. It changed who is responsible for financial security, where you manage your account, and how disputes and payments flow. This guide explains what CARM is, what changed, and the steps to stay compliant.
What CARM stands for and what it does
CARM stands for the CBSA Assessment and Revenue Management system. It is the digital backbone the Canada Border Services Agency (CBSA) uses to assess and collect duties and taxes on commercial imports. Instead of paper statements and broker-mediated accounting, importers now manage their own customs accounting electronically through the CARM Client Portal (CCP).
In practical terms, CARM is where an importer registers their business, links to their RM import account, delegates authority to a customs broker, reviews Statements of Account, pays duties and taxes, and submits corrections or appeals.
What changed in 2024
CARM rolled out in stages. The CARM Client Portal first opened in 2021, but the system became the CBSA's official system of record for the commercial trade community in October 2024. That milestone, often called CARM Release 2, introduced the changes importers feel most:
- Mandatory registration. Importers of record must be registered in the CARM Client Portal to import commercially.
- Importer-held financial security. To benefit from Release Prior to Payment (clearing goods before duties are paid), the importer, not the broker, must post their own financial security.
- Electronic accounting. The Commercial Accounting Declaration (CAD) replaces the older B3 and B2 forms for accounting and adjustments.
- Self-service corrections and appeals. Adjustments, rulings, and disputes are managed inside the portal.
Honest assessment: CARM has had a rough go
If you've been fighting the portal and wondering if it's just you, it's not. As of August 2026, CARM is still generating real headaches for importers and brokers alike. The portal has been plagued by glitches, and that tracks with what we're hearing from clients on the ground.
Common complaints include payment posting delays, delegation of authority requests that disappear into the void, and Statement of Account figures that don't reconcile cleanly. CBSA has acknowledged issues and pushed fixes, but the system isn't where it needs to be yet.
What does that mean for you? Don't assume a payment went through just because you submitted it. Check your Statement of Account. Follow up. Keep your own records. The portal being buggy is not a defence CBSA will accept if your account falls into arrears.
There's also a separate, very real problem making the rounds right now: Canada is reportedly struggling to collect $311 million in duties on fraudulently labelled U.S. chicken. That's a CARM revenue collection failure, and it signals CBSA is going to be under pressure to tighten enforcement across the board — not just on poultry. CBSA has also just updated its trade verification priorities to expand focus on steel, aluminium, and trade agreement compliance. If your classification or valuation has any soft spots, now is a genuinely bad time to leave them unaddressed.
Who must register for CARM
Any business that is the importer of record for commercial goods entering Canada must register in the CARM Client Portal. That includes:
- Resident and non-resident importers of commercial goods.
- Customs brokers and trade consultants who transact on a client's behalf (they request delegated authority through the portal).
- Businesses that previously relied entirely on their broker's account and security.
Casual, personal imports are not the target here. CARM is about the commercial import stream.
Financial security: the biggest change for importers
Before CARM, many importers cleared goods on their broker's security and never thought about it. Under CARM, that responsibility moves to the importer of record. Here is the shift at a glance:
| Area | Before CARM Release 2 | After CARM Release 2 |
|---|---|---|
| Who posts security | Often the customs broker | The importer of record |
| Accounting forms | B3 (accounting), B2 (adjustment) | Commercial Accounting Declaration (CAD) |
| Account management | Broker-mediated, paper statements | Self-service in the CARM Client Portal |
| Disputes & rulings | Manual submissions | Managed in the portal |
CBSA provided a transition period for importers to put their own security in place after Release 2. Because timelines and security options can change, confirm current requirements on the official CBSA CARM page before you act.
One more thing making CARM harder right now: tariff chaos
CARM was designed for a relatively stable tariff environment. That's not what we have in August 2026. Canada's retaliatory surtaxes on U.S. goods, ongoing steel and aluminium tariff actions, and CBSA guidance trying to narrow the scope of tariff remission programs mean the duty amounts flowing through your CARM account are more complicated than they were two years ago.
CBSA recently extended surtax remission for two additional months, which sounds like good news, but it also means importers need to track which goods qualify, under which remission order, and for how long. Get that wrong and you'll owe duties you thought were remitted, plus interest. That shows up in your CARM Statement of Account and it's not a fun conversation.
CBSA has also expanded its trade verification priorities this summer to include steel, aluminium, and trade agreement compliance more explicitly. That means more audits, more requests for origin documentation, and more scrutiny on the exact numbers sitting in your CARM account. Your broker should be flagging this if they haven't already.
The short version: your CARM account is only as clean as your tariff classification and your understanding of which surtaxes apply to your goods. One feeds the other.
How to get CARM-ready
- Register in the CARM Client Portal. Create a business account, verify your business number, and link your RM import program.
- Set up delegation of authority. If a broker files for you, approve their request to act on your account. Check that it actually went through — don't assume.
- Post your financial security. Choose a financial security bond or cash deposit that meets CBSA's requirements for Release Prior to Payment.
- Reconcile your accounting. Learn the Commercial Accounting Declaration and your Statement of Account cycle so payments are never late. Given current portal issues, verify payments posted correctly.
- Know which surtaxes apply to your goods. With remission programs shifting and CBSA tightening guidance, you need to know your exposure before goods arrive, not after.
- Keep classification audit-ready. CBSA's expanded verification priorities make this more urgent than it was six months ago. Accurate HS classification and documented reasoning reduce the corrections and penalties that show up in your portal.
Where CustomsLogIQ fits
CARM does not classify your goods or defend your tariff decisions. That is still on you. CustomsLogIQ classifies a product with full GIR reasoning, screens it against participating government agencies, and writes the audit trail — so the accounting you push into CARM rests on defensible, CARM-ready classification. When CBSA questions a line, and given the current enforcement climate, they will, you have the reasoning ready instead of rebuilding it under audit pressure.