CBSA has been quietly ramping up trade compliance verifications since CARM went live, and 2026 is shaping up to be the year they start collecting on that investment. If you haven't had a verification letter yet, don't take that as a sign you're clean. It might just mean your number hasn't come up.
Here's what the agency is actually focused on this year, and what you should be doing about it before they show up in your inbox.
Why 2026 Is Different
CARM Release 2 gave CBSA something they didn't have before: a centralized, searchable database of importer accounts, security levels, payment histories, and declaration patterns. They can now cross-reference your B3 history against your HS codes, your declared values, and your tariff treatments — at scale, without a team of auditors manually pulling paper files.
That changes the math on enforcement. Verifications that used to take weeks of prep work can now be flagged algorithmically. A furniture importer we worked with got a verification letter in January 2026 — not because someone reported them, but because their declared values on upholstered goods were statistically low compared to similar importers in the same HS range. That's the new reality.
CBSA's Trade Compliance Verification Plan is published annually. The 2025–2026 plan (updated and available on the CBSA website) lists the commodity groups under active review. If your goods are on that list, you're not being paranoid — you're being realistic.
The Retaliatory Tariff Factor — New for Mid-2026
This is the update that matters most if you're importing goods with any US connection. In June 2026, CBSA updated its Trade Compliance Verification priorities to specifically target goods subject to Canada's retaliatory tariffs. McMillan LLP flagged this publicly, and it's not subtle — CBSA is actively cross-referencing entries to confirm that importers are correctly applying surtaxes where they're required.
Canada's retaliatory tariffs — the 25% surtax on a broad range of US-origin goods introduced in response to US steel and aluminum tariffs — have created a new classification and origin problem. Some importers are misidentifying the country of origin to avoid the surtax. Others are genuinely confused about which goods are caught. CBSA is not treating either situation charitably right now.
There's also been movement on remissions. EY reported in June 2026 that CBSA extended surtax remission for certain goods by two additional months — but remission eligibility is narrow, and CBSA has been tightening the scope of what qualifies. McCarthy Tétrault noted that recent CBSA guidance is deliberately narrowing relief from retaliatory tariffs, not expanding it.
If you're importing US-origin goods and claiming any exemption or remission from the surtax, make sure your documentation is airtight. This is exactly the kind of claim CBSA is pulling right now.
The Top Audit Priorities CBSA Has Signalled for 2026
1. Valuation — Especially Transfer Pricing Between Related Parties
This is the big one. CBSA has been vocal about customs valuation being their top compliance gap. D-Memorandum D13-4-5 covers related-party transactions, and a lot of importers are either ignoring it or handling it wrong.
If you're buying from a parent company, subsidiary, or any entity you have a financial relationship with, CBSA wants to see that you've documented why your declared value reflects a fair market price. "We've always done it this way" is not documentation.
The verification process typically starts with a request for your purchase orders, invoices, and any transfer pricing agreements. If your declared values look low relative to your industry, expect follow-up questions. Penalties under the Customs Act for valuation errors can hit $25,000 per occurrence for repeat violations — and CBSA can go back four years.
What to do: Pull your last 12 months of entries for any related-party supplier. Check whether you've filed a D13-4-5 compliant valuation method declaration. If you haven't, talk to your broker or a trade lawyer before CBSA asks you to.
2. Tariff Classification — High-Risk HS Chapters
CBSA's 2025–2026 verification plan specifically calls out several chapters that are seeing active review. Textiles and apparel (Chapters 50–63), plastics (Chapter 39), and steel and aluminum products (Chapters 72–76) are consistently on the list. So are certain agricultural goods.
Misclassification isn't always intentional — sometimes it's just a broker who used the wrong heading three years ago and nobody caught it. But CBSA doesn't distinguish between "we made a mistake" and "we were trying to reduce duty" when they calculate what you owe. The duty plus interest plus penalties lands the same way.
One steel parts importer we know had been classifying a specific bracket under a general heading for two years. When CBSA reviewed it, the correct heading carried a 6.5% MFN duty instead of free. On $2.1 million in imports, that was a $136,500 exposure — before interest.
What to do: Do a classification review on your top 20 SKUs by import volume. Not a quick glance — actually trace the HS number through the Schedule to confirm it's defensible. If you're not sure, request a National Customs Ruling (NCR) through CBSA. It takes time, but it protects you.
3. Origin Claims and Free Trade Agreement Eligibility
CUSMA origin claims are under a microscope right now — and the current trade environment has made this worse, not better. With retaliatory tariffs applying to US-origin goods, there's a financial incentive to misrepresent origin that didn't exist at the same scale before. CBSA knows this.
Claiming CUSMA tariff treatment means you need to have a valid certificate or written certification of origin from your supplier at the time of import. Not after the fact. Not "we'll get it eventually." At the time.
CBSA's notice to importers on origin documentation requirements is clear: if you can't produce the certification during a verification, the preferential rate gets denied and you pay the difference plus interest. On a high-volume importer, that retroactive assessment can be brutal.
CPTPP and CETA claims are getting similar scrutiny. If you've been claiming preferential rates under any FTA, make sure your supplier certifications are current, on file, and actually cover the goods you're importing.
What to do: Audit your FTA claims for the last two years. For each claim, confirm you have the origin certification in your records. If your supplier hasn't sent one, request it now — not when CBSA asks.
4. CARM Account Compliance and Security Adequacy
This one is specific to the CARM transition. CBSA is now verifying that importers who are required to hold their own financial security are actually holding it — at the right level.
Under CARM, importers with a Release Prior to Payment (RPP) privilege need to post security equal to 50% of their highest monthly duty and tax liability over the past 12 months, subject to a minimum of $5,000. Some importers posted security when they registered and haven't revisited it since. If your import volumes have grown, your security requirement may have grown with it.
An importer who posted $25,000 in security two years ago and has since doubled their import volume could be holding inadequate security without realizing it. CBSA can suspend your RPP privilege if your security is insufficient — which means goods sit at the border until you pay cash upfront. That's a supply chain problem, not just a paperwork problem.
What to do: Log into your CARM Client Portal account and review your current security level. Run your monthly duty and tax totals for the last 12 months. If your required security has increased, file an amendment before CBSA flags it.
5. Importer of Record Accuracy
CBSA is paying attention to situations where the importer of record on the B3 doesn't match the actual commercial reality of who owns the goods. This comes up a lot with drop-shipping arrangements, third-party logistics setups, and e-commerce importers who use a broker's BN as a shortcut.
If your business name and BN aren't on the entry, but you're the one receiving and selling the goods, you have an exposure. CBSA's position is that the legal importer of record is responsible for the accuracy of the declaration — and if that's not actually you, there's a compliance gap that needs fixing.
What to do: Review your current import setup with your broker. If goods are being cleared under someone else's account, understand why and whether it creates a compliance risk for your business.
How CBSA Selects Who Gets Audited
It's not random, and it's not purely complaint-driven. CBSA uses a risk-scoring model that looks at your import history, commodity type, country of origin, declared values relative to benchmarks, and your compliance history.
CARM has made this more sophisticated. The portal gives CBSA visibility into payment patterns, security levels, and account activity that they didn't have before. Importers who are consistently late on duty payments, who have had previous verification findings, or who import from high-risk origin countries for their commodity type are more likely to be selected.
The retaliatory tariff situation has added another layer. If you're importing goods that fall under the surtax categories and your declared duties look low, that's now a flag. CBSA is specifically cross-referencing surtax-eligible goods against what importers are actually paying.
That said, random sampling still happens. Don't assume a clean history means you're immune.
What Happens When You Get a Verification Letter
You'll receive a letter from a CBSA trade compliance officer asking you to provide documentation for a specific set of transactions — usually a defined date range and commodity group. You typically have 30 days to respond.
Honestly, most importers panic at this point. Don't. A verification isn't an accusation. It's a request for information. How you respond matters a lot.
Get your broker involved immediately. Pull the B3s, the commercial invoices, the bills of lading, and any supporting documents for the period in question. If there are errors, it's almost always better to disclose them proactively than to have CBSA find them — voluntary disclosure under the Customs Act can reduce or eliminate penalties.
If the verification finds a compliance gap, CBSA will issue a Detailed Adjustment Statement (DAS) outlining the additional duties, taxes, and interest owed. Penalties are assessed separately under the Administrative Monetary Penalty System (AMPS).
AMPS Penalties: What You're Actually Risking
The AMPS penalty schedule is public. CBSA Memorandum D22-1-1 lays out the penalty amounts by contravention type and whether it's a first, second, or third occurrence.
A few examples to make this concrete:
- Failure to report goods accurately (C016): $150 to $1,500 per occurrence at the first level, escalating to $4,500 on a third.
- Failure to keep records (C370): $150 to $1,500, escalating to $25,000 for repeat violations.
- Incorrect tariff classification where duty is evaded: calculated as a percentage of the unpaid duties, which can add up fast on high-volume importers.
The $40,000 penalty situations I mentioned at the top? Those are usually not one big mistake. They're a pattern of the same error repeated across hundreds of entries, each one generating its own AMPS hit.
Getting Ahead of This: A Pre-Audit Checklist
You don't have to wait for CBSA to find problems. A self-audit — even an informal one — is worth doing now.
- Review your top 10 HS codes by duty paid. Are they still correct? Have your products changed?
- Check your FTA certifications. Do you have them on file for every preferential claim in the last two years?
- Look at your declared values. Are they consistent? Do they match your invoices?
- Confirm your CARM security level. Log in and check it against your actual duty volumes.
- Review your importer of record setup. Is your BN on the entries? Should it be?
- Check your record-keeping. CBSA requires you to keep import records for six years. Are yours accessible?
- If you import US-origin goods, review your surtax treatment. Are you applying the retaliatory tariff where required? If you're claiming a remission, do you have documentation that supports it?
If you find something, consider a voluntary self-adjustment or a voluntary disclosure before CBSA comes to you. It's not fun to write a cheque, but it's a lot cheaper than an AMPS penalty on top of the back-duties.
Frequently Asked Questions
How do I know if my business is on CBSA's audit list?
You won't know in advance — CBSA doesn't publish individual target lists. What you can do is check the annual Trade Compliance Verification Plan on the CBSA website to see if your commodity group is under active review. If it is, assume you could be selected and make sure your records are in order.
Can my customs broker handle the verification on my behalf?
Yes, and you should involve them immediately when you receive a verification letter. Your broker can help gather documentation, communicate with the CBSA officer, and identify any compliance gaps before they become formal findings. That said, you as the importer of record are legally responsible for the accuracy of your declarations — your broker can help, but they can't absorb your liability.
What's the difference between a trade compliance verification and a full audit?
A trade compliance verification is CBSA's standard tool — it focuses on a specific commodity, date range, or compliance area. A full audit is broader and less common. Most importers will deal with verifications, not full audits. The process is similar: document request, review, findings, and if applicable, a Detailed Adjustment Statement.
If CBSA finds an error, do I have to pay immediately?
When CBSA issues a Detailed Adjustment Statement, you'll have an opportunity to respond before it's finalized. If you disagree with the finding, you can file a request for re-determination. If the DAS is confirmed, payment is required — but there are options for payment arrangements in some cases. Talk to your broker or a trade consultant about your options before the DAS is finalized.
Does CARM affect how CBSA conducts audits?
Directly, yes. CARM gives CBSA a much cleaner view of your import account — payment history, security levels, declaration volumes, and account activity are all visible in the portal. This makes it easier for them to flag anomalies and select accounts for verification. It also means your compliance record is more visible than it used to be. Keep your CARM account current and your security adequate.
Is voluntary disclosure actually worth it if I find an error?
In most cases, yes. Under the Customs Act, a voluntary disclosure made before CBSA initiates a verification can reduce or eliminate AMPS penalties. You'll still owe the back-duties and interest, but avoiding the penalty layer makes a real difference. The key is that it has to be genuinely voluntary — if CBSA has already contacted you about the issue, it's too late for voluntary disclosure to apply.
Do the retaliatory tariffs change my AMPS exposure?
Yes, potentially. If CBSA determines you should have applied a 25% surtax and didn't, the unpaid duties are the base — and AMPS penalties layer on top. On high-volume US-origin imports, that math gets uncomfortable quickly. The surtax remission extensions give some relief in specific situations, but remission is narrow and the documentation requirements are real. Don't assume you qualify without checking.