Release Prior to Payment Bonds
Since CARM became CBSA’s system of record on 21 October 2024, importers can no longer rely on their customs broker’s security to get goods released before duties and taxes are paid. Every importer wanting the privilege must post a release prior to payment bond, or cash, in its own name, against its own import account. A release prior to payment bond is how most businesses do that without tying up the cash.
What Is a Release Prior to Payment Bond?
A release prior to payment bond — CBSA calls it a written security agreement, and the CARM portal labels it a “non-cash bond” — guarantees that the duties and taxes an importer owes will be paid. It is what lets goods leave the border before the money changes hands, under the Release Prior to Payment privilege.
The alternative is a cash deposit. Both are accepted, but a release prior to payment bond covers the requirement at fifty per cent while a deposit covers it dollar for dollar. That single difference is the whole commercial argument.
- A release prior to payment bond secures your obligations, at your importer program account level, in the legal entity name registered against your business number.
- It must be posted electronically. Certified cheques, money orders and paper agreements are permitted in exceptional circumstances only, and require approval.
- A release prior to payment bond is a guarantee, not insurance. If CBSA demands payment under it, the surety pays the Crown and then recovers from you under the indemnity you signed.
- It has to stay adequate. CARM measures your release prior to payment bond against your open balance continuously, not once a year.
What changed
The Change Every Canadian Importer Had to Make
For years an importer could move goods on its broker’s security and never think about a bond. CARM ended that. CBSA has said so three separate ways — in a customs notice, a news release and its own memorandum — and the change was enforced, not merely announced.
21 October 2024
CARM became CBSA’s system of record for commercial imports and the electronic financial security regulations came into force. From this date, as Customs Notice 24-27 puts it, importers “have not been able to use a broker’s RPP security to obtain the release of imported goods.” A 180-day transition period began.
28 February 2025
CBSA issued a public reminder stating plainly that importers “can no longer use the financial security posted by their customs brokers,” and that the transition would end in April.
March 2025
CBSA granted a thirty-day extension, moving the end of the transition to 20 May 2025. It was the last extension.
20 May 2025, 3:00:01 a.m.
The hard cut-off. Customs Notice 25-22 records that importer accounts with dutiable and taxable importations since October 2024 but no security of their own were “removed from RPP on May 20, 3:00:01am EDT” and would “need to submit a CAD C-Type and pay applicable duties and taxes at time of release.”
8 August 2025
CBSA quietly revised memorandum D17-5-2 and moved the annual review window. This is the change most importers have not noticed, and CBSA’s two memoranda still disagree with each other about it.
1 January 2026
Amendments to section 17 of the Customs Act came into force, making the importer of record jointly liable with the owner and importer for duties, including amounts reassessed after final accounting.
Two points follow. An importer without security today is not late to a deadline — it is simply outside the programme, paying at the border on every shipment. And CBSA’s guidance is explicit that brokers cannot post security for their clients. Whatever your broker does for you, the release prior to payment bond is yours.
How it works now
Getting a Release Prior to Payment Bond in Place
The sequence is fixed and every step of it sits with the importer. A customs broker can transact on your behalf all day long, but it cannot register your business, enrol you, or post your release prior to payment bond.
Register the Business
You need a business number with an import-export (RM) program account, business information that matches CRA records, and a person nominated as Business Account Manager in the CARM Client Portal. The first user to register the business becomes that manager.
Enrol in RPP
Release Prior to Payment is an optional sub-programme under the Importer Program. The Business Account Manager or a Program Account Manager enrols the business through the portal — not the broker.
Choose Bond or Cash
Two forms are accepted: a release prior to payment bond from an approved provider, shown in the portal as a non-cash bond, or an electronic deposit, shown as a cash bond. You may post a mixture of the two to reach the total requirement.
Post It Electronically
The security provider can file the agreement directly into CARM by portal or API, or you can enter it yourself and the provider approves it. The status shows as under guarantor approval until they do, then becomes active and you submit it.
Use an Approved Provider
CBSA publishes a live list of registered electronic financial security providers — insurers approved by OSFI or a provincial superintendent, Payments Canada members, CDIC-insured institutions and credit unions. If your surety is not on the list, the release prior to payment bond cannot be filed.
Get the Name and Account Right
Security must be posted at the importer program account level and in the legal entity name registered against the business number. A mismatch between the name on the release prior to payment bond and the name on the account is the most common reason a filing is rejected.
One release prior to payment bond can serve more than one import account under the same business number, but CBSA requires it to be entered separately against each RM account using the same security number, and the amount must satisfy each account’s own requirement. The CBSA instructions set out the process field by field.
The numbers
Release Prior to Payment Bond Versus Cash Deposit
CBSA calculates one requirement and then lets you satisfy it two ways — with a release prior to payment bond, or with cash. The forms are not equivalent, and the difference is worth real money to an importer of any size. Everything below is from memorandum D17-5-2, revised 8 August 2025.
Written Security Agreement (the Bond)
- Covers the requirement at 50% — in CBSA’s words, “one dollar of the security agreement will cover two dollars of debts.”
- Minimum $5,000 per RM business account.
- A release prior to payment bond costs a premium rather than cash. The Surety Association of Canada told the House of Commons trade committee in April 2024 that minimum premiums for small and medium importers run $250 to $400 a year, with rates of 0.4% to 1.5% for larger importers.
- Typically issued in one to three days once the file is complete, and filed electronically by the provider.
- Leaves your bank line and your cash untouched — which is the point.
Cash Deposit
- Covers the requirement at 100% — “one dollar of the deposit will cover one dollar of debt.”
- No minimum, so it can suit a very small or occasional importer.
- Costs nothing in premium, but the money sits with CBSA instead of working in the business.
- Posted through the portal only, then allocated as credit against what you owe.
- Can be increased or decreased as the requirement moves, and can be combined with a release prior to payment bond.
A worked example. On a calculated requirement of $400,000, a cash deposit means $400,000 sitting with CBSA. A release prior to payment bond means a bond of $200,000 — half the requirement — at 0.4% to 1.5%, so roughly $800 to $3,000 a year. The maximum required is $10 million per import account, though CBSA notes an importer whose receivables exceed that may post more.
For Importers
Why the Release Prior to Payment Bond Usually Wins
Half the Face Amount
Because a release prior to payment bond covers at fifty per cent and cash at one hundred, the release prior to payment bond you buy is half the size of the deposit you would otherwise post. On a large requirement that difference alone is decisive.
Cash Stays in the Business
A deposit is money sitting with CBSA. A premium is an expense. For an importer with seasonal working capital swings, the difference is the ability to fund inventory in the months that matter.
It Scales With You
The amount can be modified mid-term. Your provider can file an increase to the release prior to payment bond directly into CARM, and you can bolt a cash top-up onto an existing bond while an endorsement is processed rather than losing release privileges in the meantime.
Operational Continuity
Prevents disruptions in the supply chain, ensuring timely delivery to end-users or customers.
What CBSA Expects
Staying Compliant Once the Bond Is in Place
Coverage Above Your Open Balance
Your total security must always exceed your account net open balance — debts minus available credits. CARM sends notifications when utilisation reaches 75% and again at 100%, and CBSA reserves the right to suspend or revoke the privilege if coverage is inadequate.
Pay on Time
The billing period runs from the 18th of one month to the 17th of the next, statements issue on the 25th, and payment is due 10 weekdays after the 17th. Portal payments are accepted until 11:59 p.m. Eastern on the due date; cheques must arrive by 4 p.m.
Late Payment Has a Long Tail
Importers may be suspended after a third late payment. Where privileges are revoked for late payment and no claim has been filed, the importer is ineligible for a year. Where a claim has been filed against the security, privileges are revoked for three years.
The annual review
How the Amount Is Calculated, and When It Moves
This is the part that catches importers out, because the trigger is a portal notification rather than a letter, and it only goes to the importer. Your broker does not get it. Your surety does not get it. And CBSA moved the dates in August 2025.
Highest Month, Not Average
Your release prior to payment bond requirement is set from your highest monthly accounts receivable balance over the previous twelve months, per import account, including GST, duties and surtax. It is not an average, so a single heavy month sets the number for the year that follows.
New Importers Self-Assess
Where there is no import history to calculate from, CBSA requires an estimated amount based on your own projections. In practice a new importer usually starts at the $5,000 minimum for a written agreement.
The Review Window Moved
The review period now runs 20 October to 19 October, with the new requirement effective 15 January. That is the current rule in D17-5-2 as revised in August 2025 — and CBSA’s memorandum D17-1-8 has not been updated, so it still shows the old July window. Work from the revised memorandum.
Only Increases Are Notified
The new figure appears as a notification in the CARM Client Portal, and only accounts whose requirement went up receive one. If nobody is watching the portal between late October and mid-January, the first sign of a problem is a release being refused.
Seasonality Is Not Forgiven
A business whose fourth quarter is four times its second quarter carries a fourth-quarter-sized requirement for twelve months. The fifty per cent bond ratio is the main lever available to blunt that, and it is a good reason to look hard at a release prior to payment bond rather than defaulting to cash.
Surtax Counts
Accounts receivable includes surtax. With Canada’s steel, aluminium and other surtax orders in force, an importer of affected goods can see next October’s calculation land far above what its duty profile alone would suggest.
Over-securing costs a little premium; under-securing costs you the programme. Between those two errors the cheap one is obvious. Check the requirement against your own projections each autumn rather than waiting for the portal, and treat any acquisition, new product line or tariff change as a reason to re-check. CBSA’s enrolment guidance carries the current amounts and dates.
The consequences
What Actually Happens at the Border Without It
Importers tend to imagine the downside as an administrative nuisance. It is not. Losing the privilege changes how every single shipment clears, and the workarounds are narrower than most businesses expect.
You Pay Before Release
Without a release prior to payment bond or a cash deposit you are ineligible. Each shipment needs a C-type commercial accounting declaration with duties and taxes paid at the time of release — either at a CBSA office before the goods move, or after an in-bond movement.
The Card Cap Bites
Credit card payments are capped at $4,999.99 — per billing cycle in the portal, and per transaction at a port of entry. An importer standing at a border office with a $30,000 duty and GST bill cannot simply put it on a corporate card.
The In-Bond Route Needs a Bonded Carrier
Moving goods in bond to an inland sufferance warehouse is the alternative to paying at the frontier — but only if the transporting carrier is bonded. That is a decision made long before the truck reaches the border, and it is not yours to make in the moment.
Paper Processing
CBSA warned in February 2025 that importers without security lose electronic release privileges and face longer paper-based processing times. On a perishable or just-in-time supply chain, that is the real cost.
The Contingency Is Nearly Closed
CBSA’s post-deadline contingency covers a narrow list — time-sensitive and perishable goods, and health and well-being goods. The wider measure that once covered all goods in a sufferance warehouse expired in August 2025.
A Claim Costs Three Years
If CBSA demands payment under your release prior to payment bond and a claim is filed, RPP privileges are revoked for three years — against one year where privileges are lost for late payment with no claim. That asymmetry is the strongest argument for keeping payments current.
Re-entry is possible — CBSA confirms that future enrolment with the required security can be arranged — but the gap is measured in shipments, not paperwork. Where CBSA demands payment under a release prior to payment bond, the provider has sixty days to pay the Crown or rebut the demand, and its obligation stands regardless of any dispute with you.
Adjacent requirements
Other CBSA and CRA Security an Importer May Meet
A release prior to payment bond is the security most importers encounter, but it is not the only one in the customs chain. These are separate programmes with their own formulas, and most of them now post through the same CARM portal.
Sufferance Warehouse Licence
Security is set at $1,000 for each 1,000 shipments or releases destined to the facility per year, and will not be less than $20,000 per warehouse. Bonds name the warehouse’s own account, and the amount is reviewed annually against the prior year’s volume.
Customs Bonded Warehouse
Security equal to 60% of the maximum duties and taxes that would otherwise be payable at any time in the year following licence issuance, reviewed not less than annually. One bond may cover all warehouses operated by the same company within a CBSA office area.
Duty Free Shop Licence
25% of the highest projected total inventory value for the first year, then 25% of the highest total inventory value for the previous year, with a minimum of $10,000 per licence. Posted through the portal like everything else.
Customs Broker Licence
A security deposit of $50,000, provided through the portal in the final stages of the licence application. One national licence covers the whole country.
Bonded Highway Carrier
$5,000 per vehicle up to a maximum of $25,000, as a continuous bond or a bond for a specified period. Relevant to importers as well as carriers — without a bonded carrier there is no in-bond movement to a sufferance warehouse.
Excise Duty Security
Excise licences sit with the Canada Revenue Agency rather than CBSA and are not in CARM. A spirits licence runs from a $5,000 minimum to a $2 million maximum; tobacco from $5,000 to $5 million. Original paper surety bonds are still accepted here.
Where a business holds several of these at once, review them together rather than renewing each in isolation. The underwriting and the indemnity are usually the same; the renewal dates rarely are.
Release Prior to Payment Bond FAQs
Can I still use my customs broker’s bond?
No. Since CARM became CBSA’s system of record on 21 October 2024, importers have not been able to use a broker’s security to obtain release, and brokers cannot post security for their clients. Accounts without their own security were removed from the programme at 3:00:01 a.m. Eastern on 20 May 2025.
How much security do I need?
CBSA calculates the requirement from your highest monthly accounts receivable balance over the previous twelve months, per import account, including GST, duties and surtax. A release prior to payment bond must cover at least fifty per cent of it, minimum $5,000 per account. Cash must cover one hundred per cent, with no minimum. The maximum required is $10 million per account.
Is a release prior to payment bond better than a cash deposit?
For most importers, yes. It covers the requirement at half the face amount and costs a premium rather than locking up cash. The Surety Association of Canada has published minimum premiums of $250 to $400 a year for small and medium importers, and rates of 0.4 to 1.5 per cent for larger ones.
I am a new importer with no history. What amount applies?
Where CBSA has no data to calculate from, you provide an estimate based on your own import projections. In practice a new importer usually starts at the $5,000 minimum and revisits the figure at the first annual review.
Can one bond cover several import accounts?
Yes, under the same business number — but it must be entered separately against each RM account using the same financial security number, and must satisfy each account’s own calculated requirement.
When does CBSA recalculate my requirement?
The review period runs 20 October to 19 October, effective 15 January. CBSA revised this in August 2025; its other memorandum still shows the old July window. Only accounts whose requirement increased get a notification, and it appears in the CARM portal — not by letter, and not to your broker or surety.
My volumes have grown. Can I increase the bond mid-year?
Yes. You can request an updated requirement through the portal, and your provider can file a modification directly into CARM, changing the amount and validity period. You can also add a cash deposit alongside an existing release prior to payment bond while an endorsement is processed.
What if my security runs out mid-cycle?
Coverage must always exceed your account net open balance. CARM notifies you at 75 and 100 per cent utilisation, and CBSA reserves the right to suspend or revoke the privilege where coverage is inadequate.
What happens at the border if I have no security?
Every shipment needs a C-type accounting declaration with duties and taxes paid at release — either at a CBSA office, or after an in-bond move to a sufferance warehouse, which is only possible if your carrier is bonded. Credit card payments are capped at $4,999.99.
When is payment due under CARM?
The billing period runs the 18th to the 17th, statements issue on the 25th, and payment is due ten weekdays after the 17th, holidays included. Portal payments are accepted to 11:59 p.m. Eastern; cheques by 4 p.m.
What if I pay late, or CBSA claims on the release prior to payment bond?
Interest runs at the prescribed rate plus six percentage points, compounded daily. Importers may be suspended after a third late payment. Revocation for late payment with no claim means one year out of the programme; where a claim has been filed against the security, it is three years.
Are paper bonds still accepted?
Effectively no — security must be given electronically, with paper permitted in exceptional circumstances only and by approval. Canada Revenue Agency excise security is a separate regime and does still take original paper surety bonds.
