CBSA Confirms End of RPP Transition Period, Enforces Financial Security Requirements

With the transition period officially over and financial security rules now in effect, importers should take immediate action to ensure compliance, avoid disruptions, and maintain access to RPP privileges.

The Canada Border Services Agency (CBSA) updated Customs Notice 25-22 on May 22, 2025, to confirm the end of the transition period for the Release Prior to Payment (RPP) program and the full enforcement of financial security requirements under the CBSA Assessment and Revenue Management (CARM) system.

The transition period ended at 3:00:01 a.m. Eastern Daylight Time (EDT) on May 20, 2025, making financial security a mandatory requirement for accessing RPP privileges.

Here’s what you need to know regarding this update.

Importers who submitted financial security by the deadline can continue using RPP

Canadian importers remain eligible to use RPP after the transition period if they:

• Hold a BN15 program account,
• Enrolled in the RPP program during the transition period, and
• Submitted the required financial security before 3:00:01 a.m. EDT on May 20, 2025.

If you fall under this category, you do not need to take further action.

Importers of non-dutiable goods may keep RPP privileges without security

Importers may retain access to RPP even without financial security if they:

• Enrolled in RPP during the transition period,
• Have not submitted any financial security, and
• Have had only transactions without duties or taxes payable (for example, zero-rated transactions) since October 21, 2024.

If you fall under this category, you must provide financial security in the future if your shipments include goods subject to duties or taxes. 

Importers who did not submit financial security and had taxable transactions have been removed from RPP

Importers have lost RPP access after the transition deadline if they:

• Enrolled in RPP,
• Did not submit financial security, and
• Had dutiable or taxable imports on or after October 21, 2024.

If you fall under this category, you must re-enroll in RPP and provide the required financial security to regain access.

Importers with no activity and no financial security were also removed

Importers were removed from RPP despite no recent transactions if they:

• Enrolled in RPP,
• Have not submitted financial security, and
• Had no import activity since October 21, 2024.

If you fall under this category, you can re-enroll in the RPP program and provide financial security in the future. 

Importers can still enroll in the RPP program

Importer program accounts (BN15) that are not currently enrolled in the RPP program can still do so.

To enroll, you can follow the steps outlined in the RPP enrollment process via the CCP. Detailed instructions are available in this guide.  

Financial security requirements are recalculated at re-enrollment

Any importer who re-enrolls in RPP will be subject to a new requirement, provided they:

• Do not currently have valid financial security on file, and
• Are reapplying after the May 20, 2025, deadline.

The CCP will generate a new system-calculated financial security amount based on your most recent 12 months of activity.

Reduction requests that were not approved before the deadline must be resubmitted

Financial security reduction requests are no longer valid if they:

• Were under review at the time of the transition deadline, and
• Were not approved by 3:00:01 a.m. EDT on May 20, 2025.

In this case, you must file a new request with updated rationale and supporting documentation through the CCP.

Next steps for importers

With financial security now mandatory, here are the steps you can take to maintain access to RPP privileges:

• Log in to the CCP to check your RPP status and confirm whether your financial security is active.
• Re-enroll in RPP if you were removed, and be prepared to submit a newly calculated financial security amount.
• If necessary, resubmit any pending financial security reduction requests that were not approved before the May 20 deadline.
• Consult your customs broker for help assessing your compliance risks and determining the financial security required for future imports.

How Cole International can help

At Cole International, we offer customs and compliance consulting and customs brokerage services to help importers navigate changing regulations and streamline their import processes.

We also provide guidance on all CARM-related issues to ensure your business is compliant and ready for CARM. 

If you need support meeting the new requirements or would like to discuss how this may impact your operations, please reach out to one of our trade professionals.