Recent CBSA updates to CARM guidance and service information do not appear to create a new general release-prior-to-payment requirement for commercial importers. For importers in Brampton, Toronto and Mississauga, the practical issue is readiness: whether the importer’s own CARM Client Portal account, importer BN15, RPP enrolment, financial security and accounting controls are in place before goods are presented for release.
What the recent CARM updates actually change
CBSA’s guide on releasing, accounting for and paying duties and taxes was updated on September 17, 2026. The updated guidance describes two paths: release before payment through the Release Prior to Payment program when the applicable conditions are met, or release after the goods have been accounted for and duties and taxes have been paid. The page does not state a new effective date for a different general RPP rule. Read the CBSA release, account and pay guide.
CBSA also refreshed its CARM features and benefits information on August 7, 2026. That page reiterates that importers using RPP are required to post financial security. The refresh is informational; it does not identify a new RPP eligibility standard or a new release procedure. Review the CARM features and benefits information.
A further service-information update, dated September 25, 2026, reported CARM Client Portal availability of 99% between January 1, 2025 and June 30, 2026. The page continues to identify RPP enrolment and financial-security issues as matters that may be handled through CARM support. Availability reporting is not a change to the importer’s release obligations. Review CARM client service information.
The release-prior-to-payment operating test
For an importer seeking release before paying duties and taxes, the relevant question is not whether a CARM page was recently refreshed. The question is whether the importer can satisfy the existing RPP process for the shipment and account on time.
- An importer generally needs to be enrolled in RPP through the CARM Client Portal.
- The importer generally needs to provide the financial security calculated through CARM.
- The goods generally need to be accounted for within the applicable deadlines.
- The resulting balance generally needs to be paid by the applicable payment due date.
Importers without the required financial security generally account for and pay duties and taxes at release rather than obtaining release under RPP. The CBSA guide describes these alternative paths; it does not create a GTA-specific exception for importers routing freight through Pearson or distributing goods from Peel Region warehouses. See the official release and payment guidance.
Check the importer, not only the broker
RPP readiness should be checked against the legal importer’s own CARM setup. A broker’s involvement in preparing or transmitting release information does not, by itself, establish that the importer has completed its own RPP enrolment or provided its own required financial security.
This distinction matters when a broker is arranging release for a shipment moving through Pearson to a distribution operation in Mississauga or Brampton. Before relying on release before payment, the importer and broker should confirm which importer account is being used, whether the importer’s BN15 is active for the transaction, whether RPP enrolment is complete and whether the required security is available.
What to verify before asking for release
A practical pre-release review can be organized around five questions. These are controls to discuss with the customs broker and the internal finance or trade-compliance team, not a substitute for shipment-specific advice.
- Is the CARM account active? Confirm that the intended importer is registered in the CARM Client Portal and that the appropriate internal users and broker relationship are in place.
- Is the importer’s BN15 being used? Confirm that shipment instructions identify the importer’s own BN15 where required, rather than assuming a broker account can serve as a permanent substitute.
- Is RPP enrolment complete? Confirm that the importer is enrolled for the release-prior-to-payment process before the shipment is presented for electronic release.
- Is financial security available? Confirm the required security position in CARM and identify who is responsible for monitoring it when import volumes change.
- Can accounting and payment deadlines be met? Confirm how the CAD accounting will be reviewed, approved, reconciled and paid after release.
For a Toronto importer managing several inbound shipments at once, the key control is usually ownership of these checks. A shipment can be physically ready for delivery while the importer’s portal, security or accounting workflow is not ready for the requested release method.
Do not treat the CLVS measure as a general RPP change
The closest specific RPP-related operational development identified in the supplied CBSA material is Customs Notice 26-13, dated June 12, 2026. It applies to the Courier Low Value Shipment Program and falls outside the review period addressed here. Read Customs Notice 26-13.
Under that courier-specific measure, commercial importers are still expected to register in CARM, obtain a BN15, enrol in RPP and post security before seeking electronic release. Where an importer has not completed registration, a broker’s BN15 may temporarily be used to account for goods while the broker assists with CARM and RPP enrolment. The notice describes a modified compliance approach for a 12-month period beginning June 12, 2026.
That limited CLVS treatment should not be read as a general relaxation for ordinary commercial entries. An importer moving courier shipments into Toronto or the western GTA should first determine whether the shipment actually falls within the CLVS program and the notice’s conditions. Other air-cargo, truck and freight movements should not be assumed to receive the same treatment.
Questions to take to the customs broker
Before the next shipment is routed through Pearson, the 401/407 corridor or a GTA warehouse, an importer may want to document answers to these questions:
- Which importer account and BN15 will be used for the release?
- Is the importer enrolled in RPP, or will duties and taxes be paid at release?
- What financial-security requirement is shown in CARM, and who monitors it?
- What accounting information will the broker need to complete the CAD?
- Who approves the accounting and payment, and how are due dates tracked?
- Does a courier shipment qualify for the CLVS-specific treatment in Customs Notice 26-13?
The central conclusion from the recent page updates is operational rather than geographic: no new general GTA rule was identified in the reviewed material. Importers should not wait for a portal announcement to test their RPP readiness. They should validate the importer account, security, accounting and payment workflow with their broker before release is requested.
Sources and scope
This article addresses the CBSA and CARM material identified as updated or relevant through October 10, 2026. The cited pages should be checked again before acting on a shipment, particularly where a program-specific process, courier treatment or account configuration may apply.