The amendment to subsection 69(2) of the Regulations Amending Certain Regulations Administered and Enforced by the Canada Border Services Agency changes the coming into force date of a key regulatory repeal related to financial security requirements under the Canada Border Services Agency’s (CBSA) Assessment and Revenue Management (CARM) system. Originally, the regulations established a 180-day transition period starting from October 21, 2024 — the official launch of the CARM system — during which importers or owners of commercial goods registered in the CARM portal were temporarily exempt from the requirement to provide financial security in order to obtain Release Prior to Payment (RPP) of duties. This transition period was meant to help importers adapt to the new electronic processes and requirements under the modernized CARM framework. The transition provision was scheduled to be automatically repealed 180 days after coming into force, on April 19, 2025. However, the newly introduced amendment delays that repeal, now setting the termination of the RPP transition period for May 20, 2025, at precisely 3:00:01 a.m. Eastern Daylight Time.

This regulatory change is necessary because, as of March 19, 2025, a significant majority — 86% — of the 197,414 active importers have not yet posted financial security. Without an extension of the transition period, these importers would be forced to use a cumbersome paper-based process to release goods at the border after April 19, potentially causing serious disruptions and delays. The CBSA seeks to avoid such operational issues by giving importers additional time to fulfill the new financial security requirements. The CARM project itself is a multi-year initiative aimed at transforming and modernizing how commercial goods are imported into Canada. Central to this modernization is the CARM Client Portal, which enables importers to handle their accounting, tax payments, and security requirements online.

Prior to CARM, importers who were part of the RPP Program often relied on customs brokers’ bonds or traditional paper-based customs bonds. The temporary exemption introduced in October 2024 was meant to allow these importers time to transition from relying on third-party bonds or paper-based processes to independently providing electronic financial security through the CARM Client Portal. Importers are not obligated to participate in the RPP Program, but doing so allows for more efficient border clearance of goods prior to duty payments — a key incentive for many businesses engaged in regular cross-border trade. At the start of the transition period, many importers were enrolled in the RPP Program by the CBSA without needing to post security, a temporary measure that facilitated a smoother changeover to the new system. Yet by March 19, only 14% of importers had secured their own financial guarantees, signaling that more time is needed to avoid a logistical bottleneck.

The goal of the regulatory amendment is twofold: to prevent disruptions in the flow of commercial goods and to enable the CBSA to continue its outreach strategy encouraging participation in the updated RPP Program.

Canada (2025-116) April 9, 2025
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