Business Number Transition Guide: From Legacy to BN15

If you're still importing under your old RM account number and haven't completed the BN15 transition in CARM, you're on borrowed time. CBSA has been clear: the legacy importer numbering system is going away, and if your business number isn't properly linked in the CARM Client Portal, your shipments will start having problems at the border. Not eventually. Now.

This guide walks you through exactly what changed, what a BN15 is, and how to make sure your account is set up correctly before a release hold teaches you the hard way.

What Was the Old System — and Why It's Being Replaced

For decades, CBSA identified importers using a Business Number with an RM program account identifier — something like 123456789 RM 0001. That number came from the CRA and was used across your B3 entries, your accounting documents, everything.

The problem is that the old system was fragmented. CBSA, CRA, and the importer were all working off slightly different records. Corrections were manual. Reconciling duty accounts was a nightmare. A furniture importer we worked with had two different RM accounts — one from an old amalgamation — and spent three months untangling which one CBSA had on file before CARM launched.

CARM fixes this by tying everything to a single, verified BN15 — your 9-digit CRA Business Number plus a 6-character program account identifier. For most importers, that looks like 123456789 RM 0001 formatted as a 15-character string. The "15" just refers to the total character length of the identifier CARM uses internally to anchor your account.

The goal is one importer, one account, one source of truth. Clean in theory. Messy in practice if you haven't done the transition work.

What "BN15 Transition" Actually Means

The transition isn't just a terminology change. There are real steps involved, and skipping any of them creates gaps in your CARM account that will cause problems.

Here's what the transition actually involves:

1. Registering in the CARM Client Portal — If you haven't done this, stop reading and go do it. Portal access is at ccp.cbsa-asfc.cloud-nuage.canada.ca. You'll need your CRA My Business Account credentials or a Sign-In Partner login.
2. Linking your BN to your CARM account — During registration, you confirm your 9-digit Business Number. CARM then creates your BN15 account structure automatically. This is where a lot of importers run into trouble — if your BN has multiple RM accounts (common after mergers or restructuring), you need to make sure the right one is linked.
3. Confirming your program account identifier — The RM 0001 part matters. If you have RM 0001 and RM 0002, they're treated as separate import accounts. Your broker needs to know which one to use on entries.
4. Delegating access to your broker — This is the step most importers forget. Your broker cannot act on your CARM account without a delegation of authority. You have to go into the portal and grant them access. They can't do it for you.
5. Verifying your financial security is posted under the right account — If your bond or cash deposit is sitting under the wrong BN, your entries won't release on account. CBSA will want cash up front.

All five of those steps need to be done. Not most of them. All of them.

Finding Your BN15 in the CARM Portal

Once you're logged into the CARM Client Portal, your BN15 is displayed in your account profile. It's not always obvious where to look the first time.

Go to your account dashboard, then look for "Business Account" or "Profile" — the exact label has shifted through portal updates. Your 15-character identifier will be displayed there. It should match what your broker has on file. If it doesn't, that's a problem worth fixing today, not next month.

Print it out or write it down. Send it to your broker explicitly. Don't assume they have the right number just because entries have been filing without errors — CARM's validation rules have been tightening, and a mismatch that slipped through in 2024 may not slip through now.

Common Problems During the Transition

I've seen a lot of these. Here are the ones that come up most often.

Multiple BNs from Corporate Restructuring

If your company went through a merger, acquisition, or name change, you might have more than one CRA Business Number in play. CARM will only let you register one BN per portal account. If you're importing under two different legal entities, those need to be two separate CARM accounts with two separate security instruments.

A client in the food import space came to us after a merger with three different BNs, two brokers, and no one who knew which entries were filed under which number. Sorting that out took six weeks and a lot of phone calls to the CARM Help Desk. Don't let that be you.

The Broker Has the Wrong RM Account

This is more common than it should be. Your broker might have been filing under RM 0001 for years, but your CARM account is linked to RM 0002 — because that's the one that was active when you registered. The entries look fine until CARM tries to match them to your account for duty billing, and they don't match.

Fix: Ask your broker which RM account they're using on your B3s. Log into the portal and confirm that's the same one tied to your CARM account. If they don't match, talk to your broker about correcting it going forward and consider whether past entries need amendment.

Delegation of Authority Not Completed

Your broker has probably reminded you about this. If they haven't, I'm reminding you now. Without a delegation of authority in the portal, your broker cannot view your account, post security on your behalf, or respond to CARM notices. They're flying blind.

Log in, go to "Manage Relationships" or "Delegate Access" (again, the label varies by portal version), search for your broker's BN, and grant them the appropriate access level. Your broker can tell you exactly which permissions they need — ask them.

Security Posted Under the Wrong Account

If you posted a surety bond or cash deposit before you completed the BN15 linkage, there's a chance the security is sitting under an old account identifier that doesn't match your CARM account. CBSA won't tell you this proactively. You'll find out when a shipment gets flagged for cash-before-release.

Check your portal. Under "Financial Security," you should see your active bond or deposit listed with a status of "Active" and tied to your correct BN. If it's missing, call your surety company and your broker the same day.

What Happens If You Don't Complete the Transition

CBSA isn't going to send you a warning letter with a grace period. The system just stops working for you.

Practically speaking, here's what you're looking at:

• Release holds at the border — If CARM can't match your entry to a valid, secured account, your goods don't move until you pay cash. A container of electronics sitting at the port for three days while you sort out a portal issue is a very expensive lesson.
• Duty billing problems — CARM issues your monthly Statement of Account based on your BN15. If your account isn't properly set up, your duty and tax amounts may not be billed correctly — and CBSA will eventually catch up with you, with interest.
• Compliance flags — Repeated account mismatches can trigger a trade compliance review. That's not a conversation you want to have, especially right now when CBSA has explicitly updated its trade compliance verification priorities to focus on goods subject to retaliatory tariffs. If your account is already messy, you don't want to be on that list.
• Broker liability issues — If your broker files under a BN that doesn't match your CARM account, they may be filing on an unregistered importer account. That creates liability for them and headaches for you.

None of this is hypothetical. These are things that have happened to real importers since CARM's Release 2 went live.

One More Reason to Get This Right in 2026

The trade environment right now is not forgiving. Canada's retaliatory tariffs on U.S. goods are still in play, CBSA has updated its compliance verification priorities specifically targeting goods subject to those surtaxes, and CBSA has been extending surtax remission provisions on a short-term basis — most recently by two additional months. That means the rules keep shifting, and CBSA is actively looking at importers in affected categories.

If your CARM account has BN mismatches, missing security, or incomplete delegation, you're already starting from a weak position. Add a compliance verification on top of that and you're looking at a very bad quarter.

Get your account clean now, while it's a routine fix. Don't wait until CBSA is already asking questions.

Step-by-Step: Completing Your BN15 Transition Right Now

Here's the short version you can actually act on today.

1. Log into the CARM Client Portal. If you can't, reset your credentials through CRA My Business Account. If you've never registered, do that first — it takes about 20 minutes.
2. Find your BN15 in your account profile. Write it down. Confirm it matches your CRA Business Number plus the correct RM account.
3. Call or email your broker. Ask them: "What BN are you using on my entries right now?" Compare it to what's in your portal. If there's a mismatch, flag it immediately.
4. Check your delegation of authority. Under account management, confirm your broker is listed with active access. If they're not, add them today.
5. Check your financial security status. Confirm your bond or deposit shows as active and tied to your correct BN. If anything looks off, contact your surety and your broker.
6. If you have multiple BNs or RM accounts, talk to your broker about which ones are in use and whether you need separate CARM accounts for each legal entity.

That's it. Thirty minutes of focused attention now versus a release hold at the worst possible moment.

A Note on CRA vs. CBSA Account Numbers

One thing that trips people up: your BN is issued by CRA, not CBSA. CARM uses it, but CBSA doesn't control it. If your BN has an error — wrong legal name, wrong address, inactive status — you need to fix that with CRA first, then make sure CARM reflects the correction.

If your company changed its legal name and you never updated CRA, your CARM account might be registered under the old name. That creates mismatches on entries. The fix is a CRA business registration update, which can take a few weeks to process. Start that now if it applies to you.

Brokers: What You Need From Your Clients

If you're a broker reading this, you already know the pain. Here's the short list of what you need from every importer client to file correctly under CARM:

• Their confirmed BN15 from the CARM portal (not just their CRA BN — confirm the RM account)
• Active delegation of authority in the portal
• Confirmation that financial security is posted and active under that BN
• Clarity on whether they have multiple legal entities importing under different BNs

Honestly, send your clients a one-page checklist. Half of them won't do it until something breaks, but the other half will thank you — and you'll have documentation that you asked.

Frequently Asked Questions

I've been importing for years without issues. Do I really need to do this?

Yes. The old RM-based system is being phased out. CARM is the live system now, and CBSA is tightening account validation. Entries that processed without issue in 2023 may not process the same way in mid-2026. The transition isn't optional — it's just that some importers haven't felt the consequences yet.

My broker handles everything. Can't they just do this for me?

Your broker can guide you through it and help you troubleshoot, but they cannot register your CARM account for you or grant themselves delegation of authority. That has to come from you, as the account holder. It's a CBSA security requirement, not your broker being difficult.

What if I have two companies that both import? Do I need two CARM accounts?

If they're two separate legal entities with two separate BNs, yes — two separate CARM accounts, two separate security instruments. If it's one legal entity with two RM accounts, you may be able to manage it under one CARM account, but talk to your broker about how entries should be filed. This is one of those situations where getting it wrong creates a mess that's hard to unwind.

I registered in CARM but I'm not sure if my BN15 is set up correctly. How do I check?

Log into the portal, go to your account profile, and look for your Business Number display. It should show your 9-digit BN and your RM account. Then ask your broker what number they have on file for you. If they match, you're in good shape. If they don't, that's the conversation to have right now.

My company was recently acquired. The old owner registered in CARM under their BN. What do I do?

You need to register a new CARM account under your BN. The previous owner's account doesn't transfer with the business — CARM accounts are tied to the legal entity, not the physical business. You'll also need to post your own financial security. Talk to your broker and your surety company as soon as the acquisition closes, not after you've already tried to import.

Is there a penalty for not being registered in CARM?

CBSA can assess Administrative Monetary Penalties under the AMPS program for non-compliance with CARM requirements. The specific penalty amounts depend on the contravention and whether it's a first or repeat offence — but AMPS penalties for importer registration issues can run into the thousands of dollars per occurrence. More practically, the operational disruption of having shipments held is often more expensive than any fine. Just get it done.