When you enrol in the importer program on the CARM Client Portal, the CBSA asks a yes-or-no question: are the books and records for this program kept in Canada? Answer yes only if your import records genuinely sit at a place of business your company operates in Canada. Everyone else answers no, and that answer opens the upload for the BSF900 agreement that makes an alternative arrangement official.
The question reads like routine onboarding, but the address you enter beside it is where the CBSA shows up when they want your records.
What the CBSA is actually asking
The Customs Act requires importers to keep the records behind every shipment, covering origin, marking, purchase, importation, costs and value, for six years following importation. CBSA Memorandum D17-1-21 sets the default location for those records: a place of business in Canada, meaning premises actually used for carrying on your business. The CARM question is where you declare how you’ll meet that obligation.
PO boxes and mail-forwarding services don’t qualify, and the memorandum says so explicitly.
When you can honestly answer yes
Answer yes if your company has its own Canadian premises, an office or facility you actually operate, and the import records are kept there and can be produced when the CBSA asks for them. A Canadian-resident importer with a real office is the standard case.
That’s a shorter list than most people expect.
The addresses that don’t qualify
Here’s the trap. Businesses reach for the first Canadian address connected to their operation, and most of those addresses fail the test.
- Your customs broker’s office. A broker clearing your shipments isn’t keeping your books and records. A broker can take on that role, but only through an approved agreement naming them, which means the honest answer to the portal question was no.
- A 3PL or fulfilment warehouse. The building holding your goods isn’t holding your records. Storage isn’t custody.
- A registered office or mail-forwarding address. The CBSA rejects these outright; an address that only receives mail can’t produce records on request.
- A customer’s or distributor’s address. They have no obligation to keep your records, and no reason to answer for them during a verification.
If the address you’re about to type belongs to anyone who hasn’t agreed in writing to maintain and produce your records, the honest answer is no.
What answering no triggers
Answering no doesn’t flag you as a problem importer. It routes you into the arrangement the CBSA built for exactly this situation. The portal opens an attachment upload, and the document it wants is the BSF900, the agreement that records where your books will be kept and who answers for them.
Non-resident importers have two compliant routes. Appoint a Canadian records custodian, such as an accountant or licensed customs broker, whose office becomes your books and records address. Or get CBSA authorization to keep the records at your own premises in the United States or Mexico. A head office anywhere else in the world doesn’t qualify, which is why most overseas importers end up with the custodian.
Timing matters more than it used to. Since May 13, 2024, the CBSA won’t issue a new import-export account until the BSF900 is approved, so the records question gates everything that comes after it. Importers who registered before then add or update a books and records address through their program account profile instead.
We prepare the BSF900 and the custody engagement for non-resident importers, you upload the package through your CARM portal, and our office becomes the Canadian address you enter beside that question. The custodian rules and the upload path are covered in our BSF900 guide.
Frequently asked questions
What happens if I answer yes but my records are kept outside Canada?
You’ve made an inaccurate declaration to the CBSA, and it surfaces the day a trade verification asks for records at the address on file. Record-keeping failures carry monetary penalties, and fixing it after the fact means updating your program account and putting a BSF900 in place anyway. Answer it correctly the first time.
Is my customs broker’s address automatically my books and records address?
No. Hiring a broker to clear your shipments doesn’t make them your records custodian. A broker can be designated to maintain your records, but that designation runs through an approved BSF900, not through your brokerage agreement.
Can I use my Canadian warehouse as the books and records address?
Only if it’s genuinely your own place of business and the records are actually kept there. A third-party fulfilment centre storing your inventory doesn’t meet the test. Goods sitting in Canada and records sitting in Canada are two different questions.
What address do non-resident importers enter in the books and records field?
The address of the approved arrangement. For most, that’s the Canadian records custodian named in their BSF900. If the CBSA has authorized records at your own premises in the United States or Mexico, it’s that location.
Related guides
- Non-resident importer to Canada: the complete setup guide
- The BSF900 form: custodian rules and the CARM upload
- CARM Client Portal for importers: setup guide
- CBSA record keeping: the six-year rule
- CBSA records custodian service
Need a Canadian address for that question?
Our CBSA records custodian service gives non-resident importers a compliant books and records address. We prepare the BSF900 and the custody engagement, you upload them through your CARM portal, and your import setup stops waiting on the records question. Contact us and tell us where you ship from.
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