What Happened on October 20
Since CARM became the CBSA's system of record in October 2024, every commercial importer that wants its goods released before paying duties and taxes has to post its own financial security. The amount is not fixed once and forgotten. On October 20 of each year CARM looks back at the previous 12 months, finds the single highest month of accounts receivable the business ran up with the CBSA (duties, GST and any surtax), and resets the minimum from that figure.
The 2026 review covered October 20, 2025 to October 19, 2026. If an importer's requirement went up, a notification was posted in its CARM Client Portal that day. If it went down, nothing has to change; reducing the security is the importer's choice.
The new amount takes effect on January 15, 2027. The CBSA's wording is that the security must be updated by then "to continue to benefit from RPP".
How the Number Is Calculated
The calculation is the same one CARM runs when a business first enrols in RPP:
- Written security agreement (a surety bond from an approved provider): at least 50% of the system-calculated amount, with a floor of $5,000 and a ceiling of $10 million per BN15 import account. You can post more if your receivables exceed the ceiling.
- Security deposit (cash held by the CBSA): 100% of the highest monthly accounts receivable, including GST, duties and surtax, over the last 12 months.
- One security can cover several BN15 accounts, but the amount has to be allocated to each account in the portal.
Because the formula uses the highest month, one unusually large month, a surtax-heavy quarter or a year of growth is enough to push the requirement up even if the average month looks the same. Businesses that started paying the September 2026 counter-tariff surtaxes on U.S. goods should expect to see that in the figure, since surtax counts as accounts receivable.
What to Do Now
Open the CARM Client Portal and read the notification
It is in the Notifications section of the business account, and the dashboard shows the new requirement. If your broker has delegated access to your account, ask them to check it with you.
Compare the new minimum with what you have posted
The portal shows both. If what you hold already meets the new figure, there is nothing to do.
If it went up, decide bond or deposit
A bond at 50% of the figure ties up less cash than a deposit at 100%, which is why most importers use one. If you already have an electronic security agreement, your provider can increase it through CARM.
Paper bonds: start now
A legacy paper bond cannot be increased electronically. It needs a signed endorsement under Memorandum D17-5-2 mailed to the CBSA's Financial Security Unit, and brokers have been told to allow about 25 business days for processing. Counting back from January 15, that means mailing it in early December at the latest. An endorsement submitted by January 15 that meets the new amount keeps RPP in place even if the CBSA has not finished processing it.
Confirm it in the portal
Once the provider's increase or your deposit top-up is accepted, the portal shows the account as meeting the requirement. Keep a screenshot with your January records.
What Happens If You Miss It
RPP is a privilege, not a right. An importer whose security is below the minimum on January 15 can have RPP suspended or revoked, which means goods are no longer released before payment: each shipment waits until the duties and taxes on it are paid through CARM at the time of release. For a business bringing in several trucks a week that is a cash-flow problem and a delay problem at once. Getting RPP back means posting the security and waiting for the CBSA to reinstate it.
Where Garden City Fits
The security is yours, in your name, and so is the portal notification; a broker's bond has not covered importers' RPP since CARM launched. What we do is make sure nobody is surprised in January: we review the new requirement with clients who have delegated their CARM account to us, explain the bond-versus-deposit choice, and coordinate with the surety when an increase or a paper endorsement is needed. If you are not sure whether your account was notified, contact our team or call 888-481-2048.
New to all of this? Our guide to Release Prior to Payment in Canada explains how the program works, and CARM for Canadian importers covers the portal itself.
Frequently asked questions
I didn't get a notification. Does that mean I'm fine?
Only accounts whose requirement increased are notified, so no notice usually means your current security still meets the minimum. Check the business account dashboard in the CARM Client Portal anyway; it shows the calculated requirement and what you hold.
My requirement went down. Do I have to do anything?
No. Reducing your security is optional. Many importers leave the higher amount in place so next year's review is less likely to catch them short.
Can my customs broker's bond cover me?
Not under CARM. Each importer posts its own financial security against its own BN15 account. Your broker can help you choose and arrange it, and can review the requirement with you if you have delegated your account, but the security is in your name.
What counts toward the highest monthly accounts receivable?
Duties, GST and surtax assessed to your account in a calendar month. Surtax paid on U.S.-origin goods under the counter-tariff orders counts, which is one reason requirements have risen for some importers this year.
I have a paper bond from before CARM. What are my options?
Ask your provider for a signed endorsement under Memorandum D17-5-2 and mail it to the CBSA, allowing about 25 business days; replace the paper bond with a new electronic security agreement posted in CARM; or add a deposit to cover the difference. The endorsement has to be submitted by January 15, 2027.
Official sources
This update is general information, not legal advice. Tariff measures change often; the official source is the authority, and how a measure applies depends on your specific goods, so confirm with a licensed customs broker before you ship.