Did you know? Release Prior to Payment (RPP) Program (English)
Canadian importers risk immediate supply chain halts after missing the January 15, 2026 deadline to post personal financial security under the overhauled Release Prior to Payment program.
Key takeaways
- •The CBSA's CARM initiative, fully enforced from January 1, 2026, requires importers to secure their own bonds for RPP, eliminating dependence on customs brokers' guarantees.
- •Non-compliance leads to withheld goods releases until full payment, imposing delays that could cost businesses thousands in storage fees and lost sales.
- •Smaller firms face disproportionate burdens from minimum $5,000 security requirements and annual reviews, potentially reshaping broker-importer relationships.
Import Security Overhaul
Canada's border agency has transformed how importers handle duties and taxes. The Release Prior to Payment (RPP) program, long a staple for expedited goods clearance, underwent major changes with the rollout of the CBSA Assessment and Revenue Management (CARM) system. Transition measures expired on December 31, 2025, and new rules kicked in the next day.
Importers now must post their own financial security—either a bond or cash deposit—to participate in RPP. Previously, they could piggyback on their customs brokers' security. This shift stems from legislative updates to Section 17 of the Customs Act, effective January 1, 2026. The required security amount is 50% of the highest monthly accounts receivable, including GST, with a $5,000 minimum per import program.
The stakes hit hard in early 2026. By January 15, importers needed to align their security with recalculated figures from October 2025 notifications. Those who didn't comply face suspension of RPP privileges. Goods get held at the border until duties are paid upfront, disrupting just-in-time inventories. For industries like manufacturing and retail, this means potential stockouts and revenue losses running into millions.
Beyond the obvious delays, tensions simmer between stakeholders. Customs brokers lose a revenue stream from providing security, while importers shoulder new costs and administrative hurdles. Smaller enterprises, lacking economies of scale, might consolidate or exit markets. Annual security reviews, now set for October, add ongoing compliance pressure. Surprising data shows CARM portal uptime at 99.5%, yet early glitches in calculations have sparked disputes over accuracy.
Sources
- https://www.cbsa-asfc.gc.ca/services/carm-gcra/schedule-calendrier-eng.html
- https://www.ghy.com/trade-compliance/cbsa-rpp-financial-security-january-15-deadline
- https://www.willsonintl.com/news/cbsa-carm-rpp-have-you-verified-your-financial-security-requirements-2
- https://www.nasbp.org/post/ongoing-changes-to-canadas-importing-process
- https://www.cbsa-asfc.gc.ca/publications/cn-ad/cn25-32-eng.html
- https://nearnorthcustoms.com/carm-update-rpp-transition-period-coming-to-a-close
- https://www.chrobinson.ca/en-us/chrglobal/resources/insights-and-advisories/client-advisories/2025q3/08-08-2025-client-advisory-canada-cbsa-rescheduling-annual-review-financial-security-rpp
- https://www.roanokegroup.com/blog/cbsa-annual-review-what-canadian-importers-need-to-know-about-financial-security-updates
- https://www.fedex.com/en-ca/shipping-services/international/regulatory/carm.html
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