What changed under CARM
The CARM Client Portal became CBSA's system of record on October 21, 2024. For years, many importers cleared goods under their customs broker's security. CARM ended that. Each importer now posts its own security at the importer program account level, in the legal name registered against its business number.
The 180-day transition ended April 19, 2025. Importers without their own security lost RPP and pay duties and taxes at the border, through a slower, paper-based process. For a client who imports every week, that is a cash flow problem, and it lands on your desk as a bond request.
How CBSA sets the bond amount
CBSA calculates the requirement from the importer's highest monthly account receivable over the previous 12 months, for each RM program account. The receivable includes duties, taxes including GST, and other debts such as adjustments and interest. A surety bond only has to cover half of it: one dollar of bond covers two dollars of debt.
| Form of security | Amount | Limits |
|---|---|---|
| Written security agreement (surety bond) | 50% of the requirement | Minimum $5,000 per RM account, maximum $10 million |
| Deposit (cash or credit card) | 100% of the requirement | No minimum, maximum $10 million |
| Combination | Bond and deposit together | Must add up to the requirement |
Worked example. An importer's highest month in the last year carried $90,000 in duties and GST. A cash deposit would be $90,000, held by CBSA. A surety bond would be $45,000, and the importer keeps its cash.
New importers with no history submit a self-assessed estimate based on import projections. They remain responsible for keeping the security adequate as volume grows.
How the bond gets posted
The bond is electronic. There is no paper certificate to courier to CBSA.
- The importer gets a business number from CRA and registers an import (RM) program account in the CARM Client Portal.
- The importer enrols in the RPP sub-program under its program account profile.
- The surety issues the written security agreement. It is either submitted to CBSA by the surety through the bond API, or entered by the importer in the portal and then approved by the surety.
- Until the surety approves, the portal shows the bond as "Under guarantor approval". Once approved, it shows as active.
- The importer submits the security on its RPP enrolment. One bond can cover several RM accounts if each is entered against the same security number.
Annual review, alerts and limits
CBSA reviews the requirement every year. The review period runs October 20 to October 19, and the new requirement takes effect January 15. If your client's volume grew, expect a higher number in January. Increases do not need CBSA approval. Reductions do, and CBSA may ask for evidence.
The portal sends notifications when the importer reaches 75% and 100% of its security. Utilization has to stay under 100%. If it does not, the importer pays down the balance or raises the security, and CBSA can suspend or revoke RPP. The surety can raise the bond amount through the portal or the API without replacing the bond.
What happens on a demand
If an importer does not pay and CBSA cannot collect, or the importer goes bankrupt, CBSA sends a demand notice to the surety. The surety has 60 days to pay or provide information that rebuts the demand. Whatever the surety pays, it recovers from the importer under the indemnity.
A surety that wants off the risk gives notice through the portal, and termination takes effect 30 days after CBSA receives it. That is why underwriters look at the importer's payment record with CBSA as closely as its balance sheet.
Importer files we see most often
Approved places RPP bonds for resident and non-resident importers. CBSA requires security from both.
- The broker-security orphan. An importer that cleared under its customs broker's bond for years and now needs its own.
- The January increase. Volume grew, the annual review raised the requirement, and the current bond no longer covers it.
- The non-resident importer. A foreign company importing into Canada under its own business number.
- The new importer. No 12-month history, so the amount comes from a projection.
- The cash-to-bond switch. A client that posted a cash deposit to keep RPP and wants the cash back.
