CARM for Non-Resident Importers: Order Your CBSA Records Custodian Online, Usually Ready Within One Business Day

Non-resident importers can now appoint Jones & Cosman as their CBSA books and records custodian online, and have it set up fast. The sign-up takes about ten minutes. Rob emails you within one business day. Usually that email carries your completed Form BSF900 and engagement letter, so your officers can sign them and upload them in the CARM Client Portal the same week. If something on the form needs a second look, it carries his questions instead. It costs US$999 a year. Order your custodian online here.

Until now, getting this set up meant writing to us and waiting for a reply before anything moved. The importers who contact us are based everywhere from Sweden and the UK to Israel and Thailand, and some of them are wholesalers without a website. Most of them wanted a price and a way to start, so we built one. If you’d like the background on the service first, our CBSA record custody page covers it.

Who needs a records custodian under CARM

Under Memorandum D17-1-21, a non-resident importer whose records are physically kept outside Canada, the United States or Mexico has to do one of two things: keep them at a place of business in Canada, or appoint a Canadian custodian using Form BSF900.

The trigger is where the records are kept. Where the company is incorporated doesn’t decide it.

That catches people out. A company incorporated in Delaware but run from Bangkok, with its invoices and bank records in Bangkok, is in the same spot as a Thai company. And an address you rent in Canada from a registered agent or a mail-forwarding service doesn’t fix it, because the CBSA doesn’t treat that kind of address as a place of business (paragraph 12 of the memo).

If your records really are kept in the United States or Mexico, you may not need a Canadian custodian at all. The CBSA can accept an undertaking for that situation instead, though approval is at its discretion. Our sign-up form asks you to confirm your records are kept outside all three countries, and if they aren’t, talk to us before you pay.

What the ten-minute sign-up asks for

The form at jonescosman.com/carm-custodian collects what goes onto your BSF900 and our engagement letter. It works for corporations, sole proprietors and partnerships. You’ll be asked for:

• your company’s legal name and type of business
• your registered address, plus the address where the business actually operates if that’s somewhere else
• your website and any online storefronts (if you don’t have one, there’s a box for that)
• a link to your company’s page on its corporate registry, or its registration number
• where you are with CARM: already registered, registering now, or not started
• the names, titles and email addresses of your signing officers

Then you pay by card through Stripe, in US dollars. There’s no quote to wait for.

Type names and addresses exactly as they appear on your corporate registry, so your BSF900 matches your registration records.

What happens after you pay

Rob emails you within one business day. If anything on the form needs a second look, that email has his questions. If it doesn’t, it has your documents:

• your completed Form BSF900
• the custodian engagement letter, signed by Ecommerce Accounting Services Ltd., operating as Jones & Cosman CPA
• our CARM portal registration guide
• our client upload guide

Your company’s officers sign the documents and upload them in your CARM Client Portal account. We prepare the paperwork. The upload comes from your own portal account.

If you haven’t registered in CARM yet, the registration guide walks you through it. CARM needs a Canadian business number with an import-export account first, and if you don’t have one, you can add our business number service at checkout (see the pricing section below).

Where your records are kept, and for how long

You’ll also get an invitation to a secure portal hosted in a Canadian data centre. That’s where your import documents are hosted.

We keep your records for six years after the year of importation, which covers the CBSA’s six-year retention period. If the CBSA asks for the records, we’re the ones who respond to the request.

It doesn’t matter who moves your goods. We work with any courier and any customs broker. The BSF900 is about who keeps your records and where, not who clears your shipments, so changing carriers or brokers later leaves the arrangement as it is.

In our view that’s the better setup for most overseas importers anyway. Your records shouldn’t be tied to whichever carrier has the best rate this year.

What it costs

US$999 a year, billed annually. The plan renews each year, and you manage it from a billing portal.

If your company doesn’t have a Canadian business number yet, there’s an optional add-on at checkout for US$499, one time. We file the business number and RM import-export account application with the CRA for you. GST/HST registration is included in that fee if you want it.

GST/HST registration is a separate question from customs, and the answer depends on how you sell to customers in Canada, not on the fact that you import. If you’re not sure, tick “not sure” on the form and Rob will ask a couple of questions about your Canadian sales before recommending yes or no. Our guide to GST registration for non-residents has the background.

Frequently asked questions

Do we need a Canadian records custodian if our company is incorporated in the United States?

It depends on where the books and records are kept, not where the company is incorporated. If a US company keeps its import records in the United States, the CBSA may accept an undertaking instead, at its discretion. If the records are kept anywhere outside Canada, the United States or Mexico, you need a place of business in Canada or a Canadian custodian named on a BSF900.

Can a registered agent or mail-forwarding address be our place of business in Canada?

No. The CBSA doesn’t treat a registered-agent or mail-forwarding address as a place of business (paragraph 12 of Memorandum D17-1-21). If that’s the only Canadian address you have and your records are kept outside Canada, the United States and Mexico, you’ll need a custodian.

How long does the online sign-up take, and how do we pay?

About ten minutes. You pay by card through Stripe in US dollars, and Rob emails you within one business day with any questions or with your documents.

What if we don’t have a Canadian business number yet?

You can still sign up. Add the one-time US$499 registration service at checkout and we’ll file the business number and RM import-export account application with the CRA, with GST/HST registration included if you want it. If you’d rather apply to the CRA for the business number yourself, you can, and the CARM registration guide in your documents covers the portal steps once you have it.

Does it matter which courier or customs broker we use?

No. We work alongside any courier and any customs broker, and switching later doesn’t change your custodian arrangement.

How long do you keep our records?

Six years after the year of importation, in a secure portal hosted in a Canadian data centre. If the CBSA asks to see them, we respond to the request.

Related guides

• Non-resident importer to Canada: the complete setup guide
• Books and records kept in Canada? How to answer CBSA’s CARM question
• The BSF900 form: custodian rules and the CARM upload
• Canadian records custodian for importers: who needs one
• CBSA CARM Client Portal for importers: 2026 setup guide

Ready to appoint your custodian?

Start your online sign-up. It takes about ten minutes, and Rob will be in touch within one business day. Want to ask something first? Send us a question and we’ll answer it before you pay.