For importers using Release Prior to Payment (RPP), the important CARM change for the 2026–27 cycle is not a new Ontario release rule. It is the annual review of the financial security supporting RPP. Importers whose required security increased were to receive a notification in the CARM Client Portal on October 20, 2026, and generally need to increase that security by January 15, 2027 to retain RPP privileges. CBSA RPP guidance
What changed for the 2026–27 RPP cycle
CARM now recalculates an RPP importer’s required financial security annually. For the current cycle, the calculation uses the importer’s highest monthly CBSA accounts receivable during the period from October 20 of the previous year through October 19 of the current year. The annual notification date for the 2026–27 cycle was October 20, 2026. CBSA RPP guidance
Where the revised requirement is higher than the importer’s existing security, the importer generally needs to increase the security by January 15, 2027 to retain RPP privileges. Where the requirement is lower, reducing the security is optional. The guidance does not make a reduction mandatory. CBSA RPP guidance
This is a change in the amount of security that may support an existing RPP arrangement. It is not, by itself, a new tariff, a new Ontario threshold or a new release filing. The CBSA’s October 29, 2026 CARM update described portal and program functionality but did not announce a new RPP transition period or replace the existing security framework. CBSA CARM operational update
Why the notification matters to release before payment
Importers seeking release before payment are generally expected to be enrolled in RPP and provide the required financial security. Importers outside RPP generally pay duties and taxes at release. The standing framework does not generally allow an importer to rely on a customs broker’s RPP security instead of maintaining its own required security. CBSA: Release Prior to Payment
That makes the portal notification an operational control point. An importer can have a shipment ready for release while its financial-security position is being reviewed. If the revised amount is higher and the increase is not arranged by the deadline, the importer’s ability to continue using RPP may be affected. The notification should therefore be routed to the people responsible for customs, treasury and shipment release—not left only with the portal administrator.
What to confirm in the CARM Client Portal
- Whether the importer received an annual financial-security notification for the 2026–27 cycle.
- Whether the revised requirement is higher, lower or unchanged compared with the current bond or cash deposit.
- Which security instrument supports the account and whether its current amount matches the portal requirement.
- Whether the importer’s CARM account, RPP enrolment and delegated broker authority remain correctly represented in the portal.
The CARM Client Portal supports direct RPP enrolment, centralized importer information, program enrolment and access to trade-verification and audit information. Customs brokers can act for importers through delegated authority, but the importer remains responsible for its CARM account and RPP financial security. CBSA CARM operational update
A practical workflow for importers
1. Preserve the notification and establish ownership
Download or otherwise retain the portal notification with the account’s customs records. Record who is responsible for confirming the amount, arranging any increase and communicating the result to the customs broker. A broker may help interpret the operational effect, but the importer generally remains the party responsible for its account and security.
2. Compare the amount against the existing instrument
Compare the portal amount with the security currently supporting RPP. The relevant comparison is not simply the value of one upcoming shipment. The annual review uses the highest monthly CBSA accounts receivable in the specified review period, so finance and customs should reconcile the portal result to the importer’s own import activity and account records. CBSA RPP guidance
If the amount is higher, discuss with the broker and the issuer of the bond or other security how the increase will be completed and evidenced. If the amount is lower, the importer can discuss whether a reduction is commercially useful; the guidance identifies that reduction as optional. CBSA RPP guidance
3. Connect the decision to shipment planning
Do not treat the security review as separate from release planning. Importers moving freight through Toronto-area commercial facilities, including businesses distributing from Mississauga or Brampton, may have multiple shipments in transit while the review is being completed. A customs team should identify shipments that depend on RPP and confirm the intended release process with its broker before the January 15, 2027 deadline.
This is particularly important where a company’s customs account is managed centrally but goods are received at different GTA locations. The warehouse or transportation team may not see the portal notification, while the finance team may not know which inbound shipments depend on release before payment. A short internal escalation process can prevent those functions from working from different assumptions.
What to discuss with your customs broker
- Whether the importer’s RPP status and delegated authority appear correctly in CARM.
- Whether the revised security amount changes the planned release process for shipments arriving before or after January 15, 2027.
- What evidence the broker needs that an increased security requirement has been satisfied.
- Whether any planned cash-flow or release contingency is needed if the increase is still being arranged.
- Whether a lower revised amount should be left unchanged or reduced, taking into account the importer’s operating plans.
The broker discussion should focus on the importer’s specific account and shipment timing. The annual review does not create a separate Brampton, Toronto or Mississauga rule; Ontario and GTA importers are treated under the national CARM framework. CBSA RPP guidance
What this update does not mean
The October 20 notification should not be read as a new general payment rule for every commercial importer. It applies to the annual RPP financial-security review. Nor did the October 29 CARM operational update announce a new Ontario-specific procedure, a new general rule allowing importers to use a broker’s RPP security, or a replacement for the existing RPP framework. CBSA CARM operational update
The actionable question for an RPP importer is narrower: did CARM set a higher security requirement for the account, and if so, has the importer arranged the increase by January 15, 2027? That answer should be documented in the customs file and shared with the teams controlling release, payment and inbound receiving.
General information only: RPP eligibility, financial security and release decisions depend on the importer’s account and circumstances. Importers should discuss their specific CARM notification and security position with their customs broker and other appropriate advisers.