CARM statement of account: when is payment due, and how do you tie it to your CADs?

When is a CARM statement due?

The rule comes from regulation, not from the statement. Section 10.1 of the Accounting for Imported Goods and Payment of Duties Regulations says that for commercial goods released before payment "during a period beginning on the 18th day of a month and ending on the 17th day of the following month", the duties must be paid "by the 10th weekday after the end of that period". CBSA Memorandum D17-1-5 restates it and defines weekdays as "Monday to Friday and includes holidays". A statutory holiday does not push the date.

The CBSA's commercial import payments page publishes the resulting dates. For 2026:

July 1, 2026 is Canada Day and is still a due date: holidays count as weekdays, so the date does not move. The cut-off times on the due date, from the same CBSA page: portal payments "until 11:59 pm ET", cheques by mail or courier "by 4 pm ET". Online banking and EDI 820 payments depend on your bank's own cut-off. Memorandum D17-5-1, dated May 25, 2021 and marked as under review since CARM, still gives 16:00 Eastern as the payment deadline for all payments; the CBSA's payments page, updated January 6, 2026, is the later statement.

What is on the statement, and what is not?

The CBSA's account management page describes three documents:

The last row is why a broker's statement cannot be your control. The CBSA's page says brokers "cannot view the importer's due payables or account balance" on it, and encourages importers to request their own statements "even if you receive statements from a broker or service provider".

The SOA is also a snapshot. D17-1-5 says goods released in the billing period but accounted for after the SOA is issued are due on the same date, and a correction made on or after the SOA date "will not be reflected on that SOA" but is payable in the current billing cycle. The CBSA's own worked example in D17-1-5 Appendix B ends with a payment amount that "will not be what is shown on the SOA". Check the portal balance on the due date, not the PDF from the 25th.

Which due date applies to adjustments and other postings?

Not everything posts to the release-date cycle:

• Adjustments that leave money owing follow the posting date. Memorandum D17-2-1 says an adjustment posted between the 18th of month 1 and the 17th of month 2 is due 10 weekdays after the 17th of month 2.
• Interest on a pre-CARM blanket posts as a Form K23 miscellaneous invoice and follows the same posting-date rule, according to Memorandum D17-2-4.
• Refunds post as credits. D17-5-1 says credits offset debts on the account before the statement is issued, so a refund usually shows up as a smaller balance, not a payment to you. A disbursement is paid only when the account has a credit and no debt, and D17-5-1 sets the threshold at CAD 1,000 or a credit balance held for two consecutive months.
• GST refunds do not post at all. D17-2-1 says the CBSA decides them but does not credit the account; registrants recover the GST as an input tax credit with the Canada Revenue Agency.

What does a late payment cost since January 31, 2026?

During the CARM transition there was no cost. Customs Notice 25-02 says the CBSA did not issue late payment penalties or late payment interest between October 21, 2024 and January 30, 2026. From January 31, 2026:

• Penalty. Accounts with an overdue balance from the January 2026 statement onward are subject to late payment penalties. AMPS contravention C336 is a flat CAD 200 per instance, assessed against the importer's BN15 when the CAD transactions on the SOA are not paid in full by the due date, including CADs the broker filed.
• Interest. Interest accrues on overdue balances and appeared first on the statement issued February 25, 2026. Under section 33.4 of the Customs Act, for goods released before accounting, interest at the specified rate runs from the day after a prescribed day that section 2.1 of the regulations ties to the 10th weekday after a 17th, and D17-5-1 describes late payment interest as running "from the calendar day immediately following the payment due date". Section 2 of the Act defines the specified rate as the prescribed rate plus 6% a year, and section 3.1 compounds it daily. The prescribed rate changes each quarter under the Interest Rate for Customs Purposes Regulations, based on three-month Treasury bill yields; the CBSA's Customs Interest Calculation Program uses the current rates.
• Collection. The CBSA's payments page says that after 30 days unpaid a notice of arrears issues and the account goes to the Canada Revenue Agency for collection. D17-5-1 adds that a claim on your security and a lien preventing further releases are possible, and Memorandum D17-1-8 allows suspension from Release Prior to Payment after a third late payment.

What the security behind your account has to cover, and how a surtax raises it, is in CARM financial security and release prior to payment.

How does one billing period work out?

An importer with Release Prior to Payment, November 2026 statement. The amounts and the interest rate are illustrative.

The GST line checks out: value for tax is value for duty CAD 640,000 plus duty and surtax, CAD 700,300, and 5% of that is CAD 35,015.00. Paying the SOA figure of CAD 89,115.00 on December 1 would leave CAD 2,047.50 overdue. That exposes the importer to the CAD 200 C336 penalty, because a CAD transaction due on that date was not paid in full, and to interest from December 2. At an illustrative specified rate of 8.5% a year compounded daily, the CAD 2,047.50 paid ten days late, on December 11, costs about CAD 4.77 in interest. The interest is small; the penalty and the late-payment count toward the RPP suspension rule are not. The November 20 adjustment belongs to the next posting period and is due on December 31, 2026.

How do you reconcile the statement to your CADs?

1. Download the SOA and the transaction history from the portal for the billing period. If you are on EDI, keep the Daily Notices.
2. Match each transaction to a CAD transaction number (14 digits) and its version. A transaction with no CAD is a penalty, an interest charge or a miscellaneous invoice; identify it.
3. Tie each CAD to your books: the invoice behind it, the duty and surtax you accrued, and the GST you will claim as an input tax credit.
4. List the credits from refunds and check each against its Statement of Adjustment.
5. Add what the SOA missed: CADs accounted after the 25th for releases in the period, and corrections made after the 25th.
6. Compare with the broker's invoice. The broker bills disbursements for duties it paid or advanced; if you pay the CBSA directly, the same CAD must not be paid twice. How to read the broker's side is in auditing a customs broker invoice.
7. Pay the portal balance, not the PDF total, before 11:59 pm Eastern for portal payments.

A statement that reconciles is not the same as CADs that are right. A wrong classification, a missed remission code or a surtax on non-covered goods reconciles perfectly and still costs money. Those errors are found on the CAD fields themselves, as set out in the CAD field by field, and fixed with the codes in CARM adjustment reason codes.

What should you do next on your own entries?

Put the due dates for the rest of the year in your payables calendar, request your own SOA and Daily Notices if only your broker receives them, and reconcile each statement before the due date rather than after it. Then audit the CAD lines behind the totals. TariffSense reads your CAD lines and checks each one against the tariff measures in force on its date, so the statement you pay reflects the right duty, surtax and GST, and every overpayment found becomes a credit against the next one. The line checks are in the CAD audit guide, and the post-entry audit page shows what goes in and what comes back. Confirm payment arrangements with your licensed customs broker.