CBSA trade compliance verifications: how to prepare and what gets checked

What is a CBSA trade compliance verification?

A trade compliance verification is the CBSA checking, after the fact, that what you declared on your entries was right. Section 42.01 of the Customs Act lets a designated officer verify the origin, tariff classification or value for duty of imported goods. CBSA Memorandum D11-6-8, revised on September 9, 2026 for CARM, describes how those verifications run. Origin verifications under free trade agreements such as CUSMA, CETA and the CPTPP follow their own provisions, and appear in the CBSA's compliance priorities alongside the others.

A verification is not the only way the CBSA follows up. Its trade compliance verification page also lists trade advisory notices, compliance validation letters and directed compliance letters, which target specific transactions and are meant to get errors corrected early. It describes verifications as "the CBSA's most comprehensive compliance tool". It also says the CBSA will use CARM data to validate duties and taxes and to run compliance interventions where it knows or suspects non-compliance, so every line on every Commercial Accounting Declaration (CAD/B3) is visible to the agency in structured form.

How does the CBSA choose what to verify?

The CBSA sets verification priorities through what it calls a "risk-based, evergreen process" and adds new targets during the year. Each priority names a program area and a group of goods. For most of them the CBSA publishes the number of importers targeted, the cases closed, the cases in error and the revenue assessed. Those published results are the clearest public evidence of where Canadian entries go wrong.

Results as published on the CBSA's verification page at the check date:

The CBSA's compliance priorities add further areas without published results: GST exemption codes, vaping products and precious metals; CUSMA origin verifications in the automotive industry; origin under CETA, CUKTCA and the CPTPP short supply list; supply-managed goods under the Duties Relief Program; the United States Surtax Order (Motor Vehicles 2025); and the Steel Derivative Goods Surtax Order. Its page also points to the United States Surtax Order (2026), in force from September 8, 2026.

The United States Surtax Order (2025-1) has since been repealed, and its surtaxes ended on September 1, 2025; the priority covers entries made while it applied.

Two things stand out. Surtaxes dominate the recent list, and the share of closed cases found in error is high across almost every priority. If you import goods covered by any of these, assume your lines will be looked at and check them first.

What does a verification letter ask for?

Memorandum D11-6-8 lists four methods the CBSA may use, alone or together: a questionnaire, a verification letter, a verification visit (on site, from the officer's workplace, or both), and review of other information from the importer or whoever accounted for the goods. The CBSA chooses the method based on its program needs and your activities. It can also use information it already holds, such as your CADs, product information or analysis, and trade literature.

The memorandum speaks of "a request for certain documents or information" without listing them, and it does not set a standard response time. [OWNER REVIEW: what response period do CBSA verification letters usually give? Section 40 of the Customs Act leaves it to the officer, D11-6-8 states none, and the CBSA's verification page gives 30 days only for compliance validation letters. Ask a broker for a typical figure, or keep the page saying none is published.] In practice the request follows the declarations being verified. You should be able to produce, for any line:

• For classification: what the goods are and how they work, from product specifications, technical sheets, catalogues or samples, and the reasoning behind the tariff item used.
• For value for duty: the commercial invoice, the purchase order or contract, proof of what was actually paid, and anything paid outside the invoice such as royalties, assists or commissions, plus the exchange rate used.
• For origin: the certification or proof of origin that supported any preferential claim. CBSA Memorandum D11-4-2 requires the relevant proof to be in your possession when the claim is made, and to be retained for six years.
• For surtaxes and quotas: the country of origin, the schedule of the order the goods fall under, any exception or remission relied on, and import permits for quota goods.

Which records must you be able to produce?

Section 40 of the Customs Act requires anyone importing goods for commercial use to keep records at their place of business in Canada and to make them available to an officer within the time the officer specifies. The Imported Goods Records Regulations set the period: six years following importation.

The CAD itself is part of the record. CBSA Memorandum D17-1-5 describes it as the official invoice and says all corrections, adjustments, audits and appeals are based on its data. If your broker accounts for you, get the full line-level accounting data from them; you cannot answer a verification about lines you cannot see.

How do you audit the same lines before the letter arrives?

A verification checks the same declarations a self-audit checks. Running your own first has two advantages. You find the errors while you still control the timing. And under the CBSA's rules, a self-found error is treated better than one the CBSA finds.

1. Map your imports to the priorities. Take the tariff items and origins on your CADs for the last four years and compare them with the CBSA's priority list above. Every match is a first-pass target.
2. Pull the full accounting export, not a sample. The CBSA's reassessment covers same and similar goods, so your audit needs every line of each product, not a few. The line-by-line CAD audit guide lists the checks.
3. Check each targeted line: tariff item, tariff treatment and proof of origin, value for duty and exchange rate, surtax and its schedule, SIMA, quota status and GST. Use the rules in force on each entry's date; rates by tariff item, origin and date are in the free duty calculator.
4. Assemble the evidence file per product, using the list in the previous section. Gaps in the file are findings even when the declaration was right.
5. Write up the findings, with each line, what was declared, what it should be, and the duty difference in both directions.
6. Correct and claim. Underpayments in origin, classification or value go to a section 32.2 correction within 90 days. Overpayments go to a section 74 refund. The routes, reason codes and deadlines are in correcting a Canadian entry.
7. Fix the cause. Update the product data, origin files and surtax rules your broker uses so future entries are right.

TariffSense reads CAD/B3 lines and broker entry exports, checks each line against the measures in force on its entry date, including surtax orders, SIMA and tariff treatment, and returns per-line findings with the reason and the corrected value. Your broker or your own filer submits the corrections. See the post-entry audit page for what goes in and what comes back.

What changes if you find errors before the CBSA does?

Timing changes the treatment in three ways.

Your own audit can define the reason-to-believe date. Memorandum D11-6-6 accepts the final report of an importer-initiated audit as specific information that starts the 90-day correction period, if you had no earlier reason to believe, the CBSA has not already started a verification, and the report identifies only corrections that are revenue neutral or owed to the CBSA. Memorandum D11-6-10 then lets you correct going forward from the report, unless specific information existed earlier.

Voluntary disclosure stays open until the notification letter. Memorandum D11-6-4 says importers do not breach the "voluntary" condition if they apply before a verification notification letter is issued, "even if they may be aware of CBSA's verification priorities". An accepted disclosure waives penalties and reduces interest from the specified rate to the prescribed rate. To be complete, it must cover all incidences of non-compliance within the four-year reassessment window.

Self-adjustments are treated as conditionally penalty-free. D11-6-4 says penalties on voluntary self-adjustments are conditionally waived. The waiver can be withdrawn if a later verification shows the adjustment covered a period already under reassessment, or the disclosure conditions were not met.

What happens after the verification report?

At the end of a verification, D11-6-8 says the CBSA explains the results and its reasons through an exit interview, a disclosure meeting or written correspondence. An officer may then re-determine origin, tariff classification or value for duty under section 59 of the Customs Act, within four years of the original determination.

The importer's obligations are set by Memorandum D11-6-10:

• The clock. If you had no specific information before the verification, the date of the final report is your reason-to-believe date. The 90-day period runs from there.
• The scope. Corrections for "same and similar goods" and the "same issues" must be filed within 90 days of the final report. Same and similar goods are goods with the same purpose or function, differing in things like size or colour, under the same eight-digit tariff item.
• The period. Without earlier specific information, you correct the verification period named in the notification letter and going forward. With it, you correct back to the date of that information, up to four years.
• Extensions. A request must be sent no later than 45 days after the final report, showing that corrections have started. An extension is "for a maximum of 30 days", and the corrections for the first year of the reassessment period are still due by day 90.

Under CARM, the corrections are adjustments to each CAD, filed individually or as a mass adjustment, and they must reference the case number on the verification final report (Memorandum D17-2-1). Amounts owing post to your account with interest at the specified rate, the prescribed rate plus 6% a year, and fall due on the normal monthly billing cycle.

Verifications can also find overpayments, for example a surtax charged on goods outside the order. Those are not refunded automatically; you claim them as refunds under section 74, within its time limits.

What penalties apply?

Failing to correct within 90 days of reason to believe is a contravention under the Administrative Monetary Penalty System (AMPS). The CBSA's penalty pages set out two parallel sets with the same scale: C350 to C353 where the correction would leave duties or taxes owing, which is the usual audit finding, and C080 to C083 where it would not. Penalties under the two sets combined share one cap per level.

Per issue means each good wrongly declared and not corrected, however many CADs it appears on. Per occurrence means each CAD. The C080 page explains how the two bases apply. It also caps first-level penalties at CAD 1,000 for a group of repeated errors caused by a single keystroke or data-entry error, where you can show that and the corrections are made within 90 days of the verification final report.

How do you dispute the outcome?

The appeal route runs through the Customs Act:

1. Re-determination. The officer's re-determination comes with a notice under section 59(2) that gives the reasons.
2. Request to the President, section 60. Within 90 days after the notice, you may request a further re-determination of origin, classification or value for duty. The request can be made only after the duties and interest are paid or security is given.
3. Canadian International Trade Tribunal, section 67. Within 90 days after notice of the President's decision, you may appeal to the Tribunal, filing with both the President and the Tribunal.
4. Federal Court of Appeal, section 68. Within 90 days after the Tribunal's decision, any party may appeal on a question of law.

SIMA duties follow their own route under the Special Import Measures Act (CBSA Memorandum D14-1-3). Confirm the route and the deadline with a licensed customs broker or trade counsel before filing.

What should you do next on your own entries?

Compare the tariff items and origins on your last four years of CADs with the CBSA's current priority list, and audit every matching line before a notification letter arrives. If you find underpayments, the 90 days start when your report gives you specific information, so plan the corrections before you finalise it. If you also import into the US, the equivalent preparation for CBP requests is in CF-28 and CF-29: how to audit yourself first, and the line-by-line Form 7501 audit is in the US post-entry audit guide.