CARM requirements for non-resident importers are now the single biggest administrative hurdle between a foreign brand and a clean Canadian border crossing. Since the CBSA Assessment and Revenue Management system became the official system of record on October 21, 2024, every commercial importer — resident or not — accounts for duties and taxes through its own CARM account instead of sheltering under a customs broker’s. If you are a US, Indian, UK or Australian brand shipping goods into Canada as the importer of record, the CARM requirements for non-resident importers apply to you in full: your own business number, your own portal registration, your own financial security, and your own payment deadlines. Miss one and your freight sits at the border while your customers refresh a tracking page.
What is CARM, and why do non-resident importers have to care?
CARM is the Canada Border Services Agency’s digital platform for assessing and collecting duties and taxes on commercial goods imported into Canada. It replaced a paper-and-broker-mediated model with a self-serve portal in which the importer of record — not the broker — holds the account, sees the ledger, and owes the money. That shift is exactly why CARM requirements for non-resident importers hit foreign brands harder than domestic ones: you are being asked to establish a formal financial relationship with a border agency in a country where you may have no legal entity, no bank branch, and no staff.
What CARM requirements for non-resident importers actually cover
In practice, the obligations break into five buckets: obtaining a Canadian business number with an import-export (RM) program account, registering that business in the CARM Client Portal, designating a business account manager, delegating authority to your broker or fulfillment partner, and posting financial security if you want your goods released before you pay. The CBSA is explicit that a business number and RM account must be in place before you import.
Who counts as a non-resident importer?
A non-resident importer (NRI) is a business located outside Canada that acts as the importer of record on Canadian customs entries. You are almost certainly an NRI if you sell delivered-duty-paid to Canadian consumers, if you ship inventory into a Canadian fulfillment centre before any sale occurs, or if you send stock to Amazon.ca under your own name. NRI status is a customs role, not a tax residency test — you can be an NRI without ever setting foot in Canada.
What has changed since CARM became the system of record?
Three deadlines have already passed, and each one removed a workaround that non-resident importers had been leaning on. Understanding the sequence matters, because a lot of the advice still circulating online describes a grace period that no longer exists.
Timeline of the CARM transition
| Date | What changed | What it means for non-resident importers |
|---|---|---|
| October 21, 2024 | CARM became the official system importers use to account for imported goods and pay duties | Portal registration and an RM account became the baseline for commercial importing |
| May 20, 2025 | The Release Prior to Payment transition ended | Importers who want goods released before payment must post their own financial security in the portal — a broker’s bond no longer covers you |
| August 9, 2025 | The RPP contingency plan for time-sensitive, perishable and health-related goods expired at 11:59 pm | No remaining fallback for unsecured importers; goods release requires a Customs Accounting Declaration with payment |
| December 31, 2025 | Temporary allowance for customs brokers to use their own BN15 on commercial declarations ended | Your entries must be filed under your business number, not your broker’s |
| January 1, 2026 | Importer of record legislative changes came into force | Liability sits squarely with the named importer of record |
The importer of record change is the one that catches brands out
Until the end of 2025, a broker could file under its own business number for new or one-time importers. That door is closed for commercial goods. If you have been quietly importing under a broker’s BN15 because setting up your own account looked like paperwork you could defer, the CARM requirements for non-resident importers have already caught up with you. The CBSA ran a public consultation on broker BN use following the importer of record legislative changes, and the changes came into force on January 1, 2026.
How much financial security do non-resident importers need to post?
Financial security is the piece that surprises most foreign brands, because it is a real cash or credit commitment rather than a form. Under the Release Prior to Payment sub-program, you choose between a written security agreement (a surety bond) and a cash security deposit.
Surety bond versus cash deposit
| Dimension | Written security agreement (surety bond) | Cash security deposit |
|---|---|---|
| Amount required | At least 50% of the CBSA system-calculated amount | 100% of your highest monthly accounts receivable in the last 12 months, including GST, duties and surtax |
| Minimum | $5,000 per importer program account (BN15) | Set by your own import volume |
| Maximum | $10 million per importer program account (BN15) | Not capped by the bond ceiling |
| Cash impact | Annual premium only | Full amount locked with the CBSA |
| Best suited to | Steady or growing import volumes | Very low or one-off volumes |
| Underwriting | Surety review; harder for a foreign entity with no Canadian credit history | No underwriting |
| Review cadence | Recalculated annually on October 20 | Recalculated annually on October 20 |
How the CBSA calculates your number
The required amount is driven by the highest monthly accounts receivable you have carried with the CBSA over the previous 12 months, and it is updated annually on October 20. A brand with no Canadian import history starts from the floor and grows into a larger obligation, which is why the $5,000 minimum feels comfortable in year one and considerably less so after a strong peak season. Model this into your landed cost before you commit to a price point on your Canadian storefront.
How does the CARM billing cycle work?
CARM harmonised billing into a single monthly cycle, which is genuinely simpler once you know the two dates that govern it.
Statement of account and payment due date
Your Statement of Account is available in the CARM Client Portal or through EDI on the 25th of each month. The payment due date is 10 weekdays, holidays included, after the 17th of the month. Cheque payments must arrive by 4 pm Eastern on the due date; electronic payments made through the portal are accepted until 11:59 pm Eastern. For a non-resident importer working across time zones, that Eastern-time cutoff is a genuine operational detail, not a footnote.
What happens when a payment is late
Late payments may attract penalties and interest. If an amount stays unpaid for 30 days, the CBSA issues a notice of arrears and transfers the account to the Canada Revenue Agency for collection. For a foreign brand, a CRA collections file is a materially worse problem than a missed shipping day, and it is entirely avoidable with a calendar reminder.
A CARM compliance checklist for non-resident importers
Work through these in order
- Obtain a Canadian business number with an import-export (RM) program account before your first shipment.
- Register the business in the CARM Client Portal and complete the affinity questions that validate your legal entity.
- Designate a business account manager, and appoint at least two people with business account manager privileges where possible so a single departure does not lock you out.
- Delegate authority in the portal to your customs broker and your 4PL partner, with the narrowest role that lets them do their job.
- Decide between a surety bond and a cash deposit, then enrol in Release Prior to Payment and post the security.
- Confirm who is named as importer of record on every entry — you, not your broker.
- Diarise the 25th (statement) and the payment due date each month, and reconcile the Statement of Account against your own duty accruals.
- Review your security amount every October, when the CBSA recalculates it.
Where non-resident importers most often get caught out
Assuming the broker’s account still covers you
This is the most common and most expensive misunderstanding in the CARM requirements for non-resident importers. Brokers can act on your behalf once you delegate authority, but they cannot be you. Since May 20, 2025, release prior to payment runs on your posted security. A brand that discovers this at the border during peak season has already lost the week. If your goods move under DDP terms, you are the importer of record by definition and the exposure is yours.
Claiming preferential origin you cannot actually support
CUSMA duty-free treatment applies to goods that originate in Canada, the United States or Mexico under the agreement’s rules of origin. It does not apply because your shipment was routed through a US warehouse. Goods manufactured in India, China or Vietnam do not become CUSMA-originating by transiting North America, and claiming otherwise creates a correction obligation. Under AMPS contravention C350, failing to pay duties owing from a correction to an origin declaration within 90 days of having reason to believe it was wrong draws a first-level penalty from $500 up to a maximum of $5,000 per issue or $25,000 per occurrence, rising to a maximum of $200,000 on a second occurrence and $400,000 on a third. If you ship from India, plan around the actual duty and HS code position rather than a hoped-for exemption.
Treating Canada as an extension of the US entry
Two borders, two systems, two sets of paperwork. The collapse of the US de minimis exemption reshaped US inbound economics, but it changed nothing about CARM. Brands running a single North American plan need both compliance tracks live at once, which is the core argument for a unified cross-border fulfillment model.
How Transway Xpress Global helps non-resident importers stay compliant
Transway Xpress Global operates warehouses in Oakville and Etobicoke, Ontario and in Buffalo, New York, with an office in Pendleton, Indiana, and is backed by the trucking parent Transway Transport, based in Oakville since 2014. That footprint means a brand entering North America can hold inventory on both sides of the border and choose which entity imports, rather than being forced into an NRI structure it is not ready to administer.
On the operational side, we work alongside your customs broker within your CARM account under delegated authority: receiving goods, reconciling entries against the Statement of Account, and flagging discrepancies before they age into arrears. Services span D2C and B2B fulfillment, Amazon FBA prep, warehousing, order and inventory management, cross-border shipping, returns and custom packaging — so the same team that clears your inventory also stores, preps and ships it. For brands shipping from India, our India to USA and Canada programme is built around exactly this problem.
The short version
What to do this quarter
The grace periods are gone. Meeting the CARM requirements for non-resident importers now means a business number and RM account in your own name, an active CARM Client Portal registration, a designated business account manager, delegated authority for your partners, and posted financial security of at least $5,000 if you want release prior to payment. Add the 25th-of-the-month statement and the payment due date to your finance calendar, re-check your security amount every October, and never claim CUSMA origin you cannot document. Done once, properly, this becomes background noise. Done late, it becomes a border hold in your busiest week.
Frequently Asked Questions
What are the CARM requirements for non-resident importers?
A non-resident importer must obtain a Canadian business number with an import-export (RM) program account, register the business in the CARM Client Portal, designate a business account manager, delegate authority to any broker or logistics partner acting on its behalf, and post its own financial security to use Release Prior to Payment. Duties and taxes are then settled on the harmonised monthly billing cycle. These obligations apply whether or not the business has any physical presence or legal entity in Canada.
Do non-resident importers need a Canadian business number for CARM?
Yes. The CBSA requires a business number with an import-export (RM) program account before you import commercial goods, and that number is what your CARM account is built on. Since the temporary allowance for customs brokers to file under their own BN15 on commercial declarations ended on December 31, 2025, there is no longer a compliant way to import commercially without your own number. Registration is free and can be completed from outside Canada.
How much financial security must a non-resident importer post under CARM?
If you choose a written security agreement, the bond must cover at least 50% of the CBSA’s system-calculated amount, with a minimum of $5,000 and a maximum of $10 million per importer program account. If you choose a cash security deposit instead, you post 100% of your highest monthly accounts receivable over the previous 12 months, including GST, duties and surtax. The CBSA recalculates the required amount annually on October 20, so a growing import programme should expect the number to move.
Can my customs broker handle CARM on my behalf?
A broker can do most of the day-to-day work once you delegate authority to them inside your CARM Client Portal, including submitting declarations and viewing your account. What a broker cannot do is be the importer of record for you or lend you its financial security. Since May 20, 2025, release prior to payment depends on security posted by the importer. Treat your broker as an operator of your account, not a substitute for it.
When are duties and taxes due under the CARM billing cycle?
Your Statement of Account appears in the CARM Client Portal or via EDI on the 25th of each month, and payment is due 10 weekdays after the 17th of the month, with holidays counted in that window. Cheques must arrive by 4 pm Eastern on the due date and electronic payments through the portal are accepted until 11:59 pm Eastern. Late payment can trigger penalties and interest, and an amount unpaid after 30 days moves to the Canada Revenue Agency for collection.
Get your Canadian import setup reviewed
If you are entering Canada for the first time, or you have been importing under an arrangement that predates these deadlines, it is worth a second pair of eyes before your next container lands. Book a consultation with Transway Xpress Global and we will walk through your CARM position, your importer of record structure, and where inventory should sit across our Ontario and Buffalo facilities. You can also review our fulfillment pricing or read how we handle cross-border returns.
Primary sources: CBSA — CARM, Customs Notice 24-27, CBSA — Release Prior to Payment: get ready to enrol, CBSA — Commercial import payments and AMPS contravention C350. Verified August 2026. Regulatory thresholds change — confirm current requirements with the CBSA before acting.
