CBSA Clarifies Record-Keeping Requirements for Canadian Importers

blog | Feb 24, 2023

The Canadian Border Service Agency (CBSA) Clarifies Record-Keeping Requirements for Canadian Importers

The Canadian Border Service Agency (CBSA) recently updated their mandatory requirements for importers maintaining customs records elsewhere than their place of business in Canada. 

In accordance with Departmental Memorandum D17-1-21, importers maintaining customs and entry records outside of Canada or importers who maintain their records at a place other than their place of business in Canada, must submit Form BSF900Agreement to Maintain Records Elsewhere Than the Place of Business in Canada. This information should be submitted to the CBSA as soon as possible to support the importer’s record-keeping responsibilities. 

At Delmar’s request, the CBSA has further clarified its definition of place of business for the purpose of this regulatory requirement: Importers who maintain their digital import records on a network data server(s) physically located anywhere other than the importer’s Canadian primary place of business must also submit Form BSF900. This requirement especially applies to Canadian importers using third-party data centers and cloud-storage service providers such as Amazon® web services or Microsoft® Azure. 

Completing the CARM Portal Registration Before October 2023 

Furthermore, the CBSA is requiring all importers to file a compliant BSF900 form as a condition of completing their CBSA Assessment and Revenue Management (CARM) portal registration. Full implementation of CARM Phase 2 is scheduled for October 2023. Learn more about CARM on our dedicated CARM webpage. 

Guidance on Proper Record-Keeping 

Importers are also encouraged to review their current record-keeping policies considering CBSA’s requirements on the matter. Delmar's Advisory Services team can conduct complete record-keeping audits and facilitate the filing of the BSF900 form with the CBSA to ensure ongoing compliance with applicable regulations. 


For assistance, please contact your local Delmar Representative or visit our website.