A Canadian records custodian is a firm in Canada, usually an accountant or a licensed customs broker, that a non-resident importer formally designates to keep its import books and records. The designation runs through the BSF900, the CBSA’s Agreement to Maintain Records Elsewhere than the Place of Business in Canada, and once that agreement is approved, the custodian’s office becomes the address where the CBSA expects to find six years of your import records. For a business importing into Canada with no premises here, the custodian arrangement is usually the piece that lets the rest of the setup move.
Who needs a records custodian
The Customs Act default is that importers keep their records at a place of business in Canada. CBSA Memorandum D17-1-21 allows two alternatives: authorization to keep the records at your own premises in the United States or Mexico, or a designated person in Canada who keeps them for you.
That leaves a short list. A company importing from the UK, Europe, Asia or anywhere else outside North America with no Canadian office needs a custodian, because its own premises don’t qualify. A US or Mexican business can apply to keep records at home instead, though many still choose a custodian so someone local answers when the CBSA calls.
Timing is what catches new importers. After May 13, 2024, the CBSA stopped issuing import-export program accounts until the BSF900 is approved, so a non-resident importer can’t clear its first commercial shipment until the custodian arrangement exists. We cover the CARM enrolment question that triggers all this, and which addresses qualify, in separate guides.
Who can act as the custodian
D17-1-21 names licensed customs brokers, accountants, and other authorized agents. The custodian has to operate a real place of business in Canada; PO boxes and mail-forwarding services are rejected outright.
Importers get one thing wrong more than anything else here. Designating a custodian doesn’t move your compliance obligations, and the memorandum says so plainly: the importer continues to be responsible for all of the legislative requirements. The custodian keeps and produces the records, but if the file is incomplete when the CBSA opens it, the penalties land on you.
So pick someone who’ll tell you what’s missing from your records, not a mailbox with a licence.
What the custodian actually holds
The records behind every shipment, covering the origin, marking, purchase, importation, costs and value of the goods, kept for six years following importation. In practice that means commercial invoices, customs accounting documents, proof of payment, shipping documents, and the paper trail showing what happened to the goods after they arrived in Canada.
Electronic records are fine as long as they can be tied back to the supporting source documents, which is how most custodian arrangements run today. When the CBSA conducts a trade verification, the production request goes to the custodian’s office, with a deadline attached.
How the arrangement gets set up
Two documents do the work. The BSF900 names the custodian and the Canadian address and goes to the CBSA for approval through the CARM Client Portal. The custody engagement between you and the custodian sets out what they hold, how records reach them, and what they do when the CBSA asks for production.
For our non-resident importer clients, we prepare the BSF900 and the custody engagement, you submit the BSF900 through your own CARM portal, and once the CBSA approves it, our office becomes your books and records address. Importers who registered before the May 2024 cutoff handle it differently: they add a books and records address to their existing CARM program account profile.
What goes wrong without one
An importer with no compliant records arrangement is exposed on four fronts. The CBSA can assess monetary penalties for record-keeping failures, detain imported goods until the importer complies, withdraw preferential tariff treatment claimed on past shipments, and cancel an existing records agreement that isn’t being honoured.
For a new importer the consequence is simpler: no approved BSF900, no import account, nothing ships.
Frequently asked questions
Is a records custodian the same as an importer of record?
No. The importer of record is the business responsible for the import itself, including the duties, taxes and declarations. The custodian only keeps the books and records that back those declarations up. A non-resident importer is typically both its own importer of record and the client of a custodian.
Does appointing a custodian transfer my CBSA obligations to them?
No. D17-1-21 is explicit that the importer remains responsible for every legislative requirement even after a custodian is designated. The custodian maintains and produces the records on your behalf, but compliance failures are assessed against you.
Can my head office outside North America keep the records instead?
No. The only own-premises option outside Canada is the United States or Mexico, with CBSA authorization. A head office anywhere else doesn’t qualify, which is why most overseas importers end up appointing a Canadian custodian.
How long does the custodian keep my records?
Six years following the importation of the goods, and the clock runs from each importation rather than from your tax year end. Records retained on a tax-year schedule can fall short on the customs side, so the custody engagement should track shipments, not fiscal years.
Related guides
- Non-resident importer to Canada: the complete setup guide
- The BSF900 form: custodian rules and the CARM upload
- Books and records kept in Canada? How to answer CBSA’s CARM question
- CARM Client Portal for importers: setup guide
- CBSA records custodian service
Need a Canadian records custodian?
Our CBSA records custodian service gives non-resident importers a compliant books and records address in Canada. We prepare the BSF900 and the custody engagement, you submit them through your CARM portal, and your import account stops waiting on the records requirement. Contact us and tell us where you ship from.
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