Recent CBSA updates to CARM guidance did not introduce a new release-prior-to-payment (RPP) requirement. They did, however, restate the conditions that determine whether a commercial shipment can be released before duties and taxes are paid. For importers moving freight through Pearson, GTA sufferance warehouses or other Ontario release locations, the practical issue is control: the CARM Client Portal and the importer’s internal shipment process should agree before a release request is made.
What the recent CARM updates actually changed
The CBSA’s CARM features and benefits page was updated on August 7, 2026. The page continues to state that importers seeking RPP have to post financial security. The update does not state a new effective date or announce a new RPP model. CBSA CARM schedule and features information
CBSA guidance titled “Release, account and pay duties and taxes” was updated on September 17, 2026. It restates that an importer seeking release before payment should enrol in RPP, provide the required financial security, account within the required timeframe and pay by the applicable due date. The page does not announce a new effective date for those requirements. CBSA release, accounting and payment guidance
That distinction matters. A page revision can be operationally important without changing the legal or administrative rule. Importers should update their procedures when guidance is clarified, but should not treat the August or September page updates as a newly effective RPP obligation.
The release gate importers should test
For a shipment intended to move before duties and taxes are paid, the release decision can be organized around four questions. The answers should be available before the broker or self-clearing importer relies on RPP for that shipment.
| Control question | What the current guidance indicates | Operational discussion point |
|---|---|---|
| Is the importer enrolled in RPP? | Release before payment is associated with RPP enrolment. | Confirm that the importer’s CARM status supports the intended release method. |
| Has the importer provided the required financial security? | Importers seeking RPP are required to provide financial security. | Confirm that the security arrangement is in place before planning release on credit. |
| Can the importer account within the required timeframe? | RPP guidance requires accounting within the applicable timeframe. | Align entry review, document collection and accounting responsibility before release. |
| Is payment scheduled by the applicable due date? | Duties and taxes remain payable by the applicable CARM due date. | Confirm who monitors the due date and who authorizes payment. |
The table is a workflow aid, not a substitute for the importer’s account-specific CARM records or broker instructions. The applicable release treatment can depend on whether the importer is using RPP or paying duties and taxes upon release. CBSA release, accounting and payment guidance
How this applies to GTA shipment planning
Pearson and air cargo
An importer receiving commercial air cargo through Pearson may be coordinating a broker, carrier, warehouse and receiving location on a tight timeline. In that setting, “release before payment” should not be treated as an assumed delivery milestone. Importers generally should confirm the RPP conditions first, particularly where the shipment is being routed from the airport to a Mississauga or Brampton warehouse.
A portal or account issue discovered after the freight has arrived can create a mismatch between the planned pickup and the available release treatment. The practical control is to identify the intended payment method during shipment planning and have the broker confirm what information or action is needed from the importer.
GTA warehouse and distribution operations
Importers receiving goods into Mississauga, Brampton or Toronto distribution operations should separate two decisions: whether the goods can be released before payment, and whether the warehouse is ready to receive them. RPP addresses the first decision; it does not replace the importer’s responsibility to account and pay by the applicable deadline.
That separation is useful for importers moving freight along the 401/407 corridor. A transport plan can remain unchanged while the customs payment control is reviewed independently. Conversely, a confirmed warehouse appointment does not establish that the shipment qualifies for release before payment.
What importers should discuss with their broker
- Whether the shipment is intended to use RPP or whether duties and taxes will be paid upon release.
- Whether the importer’s CARM Client Portal status supports the intended release method.
- Whether the required importer-provided financial security is in place for RPP.
- Who is responsible for confirming accounting within the required timeframe.
- Who monitors the applicable payment due date and what internal approval is required.
- What should happen if the shipment arrives before the intended CARM or payment control has been confirmed.
These questions are especially relevant when a broker is coordinating release but the importer controls the CARM account, financial security and payment. Importers generally should not assume that a broker’s involvement transfers the importer’s RPP or payment responsibilities.
Timeline: the dates still governing the workflow
The current operating framework is based on earlier CARM milestones, not on the August and September 2026 page updates. CARM became the official system of record on October 21, 2024, and the CARM-based RPP model came into force at that time. The RPP transition period ended on May 20, 2025; importers requiring release before payment were expected to have their own financial security in place through CARM. Importer-of-record legislative changes came into force on January 1, 2026. CBSA Customs Notice 24-27
Those dates are not new changes during the recent guidance-update period. They are useful reference points when an importer is reviewing an old procedure, a new ERP workflow or an account handoff between finance and customs personnel.
Recommended internal control
A practical procedure is to add a release-method field to the shipment record: RPP or payment upon release. For RPP shipments, the importer can then require confirmation of enrolment, financial security, accounting responsibility and payment monitoring before treating customs release as available. The broker can be asked to identify any account-specific issue, while the importer retains responsibility for decisions tied to its CARM account.
The main takeaway is narrow but important: the recent CARM page updates do not create a new RPP rule. They reinforce an existing release gate. Importers in Brampton, Toronto, Mississauga and elsewhere in Canada should use the updated guidance as a prompt to test whether their shipment, broker instructions, CARM account controls and payment process all point to the same release method.