CARM: Release schedule, features and benefits

Importers must meet their financial security requirements by posting a written security agreement (WSA) or a security cash deposit in the CARM client portal. WSA in paper format will no longer be accepted. Other forms of financial security (beyond cash security deposit and Financial Security Agreement) that are currently in use may still be available in exceptional circumstances.

A Written Security Agreement (e.g. Customs Bond) is provided by a financial security provider to act as a guarantee against importer debt.

There are 2 ways to link a written security agreement to the importer’s RPP program:

• the Bond Application Program Interface (API) by the Financial Security Provider
• the CARM Client Portal (CCP) by the importer, subsequently approved by the Financial Security Provider

If the importer posts the bond directly on the portal, the CARM solution pushes the information entered by the importer to the surety provider for validation via the portal.

There are multiple types of financial security agreements that can be issued by different security providers. Please refer to the list of financial institutions regulated by the Office of the Superintendent of Financial Institutions made up of institutions that are CBSA approved. This list includes banks (domestic and foreign), trust companies and loan companies.

Importers can use this approved list to find sureties to secure financial security.

Cash security deposit: set at 100% of the highest monthly accounts receivable (inclusive of GST) within the last 12 months.

• There is no minimum required.
• An importer may choose to make a single deposit for multiple importer program accounts associated to a business (BN9) however they will need to identify the security breakdown for each importer program.

Financial security agreement: set at equal to or greater than 50% of the importer's highest monthly accounts receivable within the last 12 months.

• A minimum amount of $5,000 is required per RM importer program account.
• An importer may choose to obtain a single financial security for multiple importer program accounts associated to a business (BN9) however they will need to identify the security breakdown for each importer RM number, while meeting the minimum threshold of $5,000.
• The maximum amount of security required will be capped at $10 million for each RM importer program account number. An importer may choose to post a higher security amount if their account receivable exceeds the cap, but it is not mandatory.

Accounts Receivable (AR) includes assessment transactions accounted for on a CAD, corrections or adjustments and any CBSA-initiated transactions posted to a TCPs account including applicable AMPs, CBSA-initiated corrections or adjustments, drawbacks or manual bills such as licence fees and ascertained forfeitures.

Existing financial security agreements have been transferred to CARM by the CBSA. When the amount is not enough to meet the new CARM requirement, an importer will have the option to post additional security. System nudges will activate when the balance due is equal or higher than 75% of the total expected security coverage.

Importers that registered on the CARM Client Portal (CCP) before October 4, 2024 or had a history of importing commercial goods into Canada did not need to enrol in the Release Prior to Payment (RPP) program. These importers were automatically provided the RPP indicator by the CBSA and all they have to do to remain in this program is post their required financial security prior to the end of the 180-day transition period.

Importers that registered on the CARM Client Portal (CCP) after October 4, 2024 can also benefit from the transition period, but must enrol in the Release Prior to Payment (RPP) program in the portal. Once enrolled, the importer will be able to select "lower than recommended amount".

If financial security is not provided within the 180 day transition period, the importer will be removed from the RPP program (at day 181).

The CARM system will automatically calculate the financial security requirement an importer must post, based on the last 12 months of historical payments to the CBSA at the time of enrolment.

Yes. Financial Security Agreements can be continuous or for a set duration. Continuous agreements do not expire; however, they are monitored to ensure they sufficiently cover the security required. Financial Security Agreements for a specific duration are only considered active for the timeframe for which they are underwritten and are considered inactive after the end date of the agreement.

The CARM system uses a nudging framework for RPP importers to encourage real-time compliance of financial security requirements. When an RPP importer's financial security utilization is approaching (for example, greater than 75%) or over capacity (greater than 100%), the CARM system will nudge the importer to either increase the financial security posted or post payment to reduce the account balance.

The CBSA will conduct an annual review of the financial security requirement for each importer’s RM business account. The review period is from July 25 of the previous year to July 24 of the current year. The new minimum financial security amount determined will be communicated to the importer by way of notification on the CCP.

The Financial Security Dashboard will allow importers to view and manage their program security requirements. The Financial Security Dashboard provides an overview of the importers total security required and current security coverage. The dashboard lists financial security by program (RM).

The RPP utilization compares the real-time account balance against the security posted for importation activities.

More information: Changes to the Release Prior to Payment Program