Compliance Service

CBSA Record Custody for Non-Resident Importers

CBSA requires every importer to maintain records in Canada, the U.S., or Mexico. If your business is based elsewhere, you need a Canadian record custodian. We are that custodian.

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Who Is This For

International companies selling into Canada

If your import books and records are kept outside Canada, the U.S., or Mexico and you ship goods into Canada, you are required to appoint a Canadian record custodian under CBSA regulations. The test is where the records are maintained, not where the company is incorporated: a US LLC whose books are kept from overseas still needs one.

This applies whether you sell through Amazon FBA, Shopify, Walmart, 3PL warehouses, or direct distribution.

Your Compliance Obligation

Under CBSA Memorandum D17-1-21 and the Imported Goods Records Regulations (SOR/86-1011), every importer must:

  1. Keep all import records (invoices, CARM accounting documents, duty/tax receipts, permits) for 6 years following the importation of the goods
  2. Store those records in Canada, the U.S., or Mexico
  3. File Form BSF900 if records are stored anywhere other than your Canadian business location

Companies outside North America must designate a Canadian record custodian. Non-compliance can result in penalties, seizure of goods, or loss of import privileges.

What We Handle

Your authorized Canadian record custodian

We serve as your authorized Canadian record custodian and tax compliance partner, so your import operations run without interruption.

  • CBSA BSF900 preparation: the signed custodian package, ready to upload in your CARM portal
  • Secure record storage: encrypted, Canadian-hosted cloud storage with a dedicated upload portal
  • GST/HST filing: monthly, quarterly, or annual returns available as an add-on
  • Audit support: we respond to CBSA and CRA requests on your behalf
  • CARM portal delegation: direct access and reporting handled on your behalf
  • Global accessibility: clear, documented communication via email, built for international clients across all time zones
Pricing

One plan, everything included

Simple annual pricing in USD. No setup fee, no hidden fees. Cancel with 30 days notice.

Annual
$999/yr
Setup included. One invoice a year.
  • CBSA BSF900 preparation
  • Custodian engagement letter
  • Encrypted Canadian cloud storage
  • Secure upload portal
  • Audit support
  • CARM portal delegation
  • Annual compliance review
Get Started
Why Choose Us

Not just another customs broker

Many record custodians are customs brokers, and some expect you to clear your goods through their brokerage. Your records then sit with whoever clears your goods, and moving to a new broker can mean setting up the records arrangement again.

We are CPA-designated specialists with 15+ years in Canadian e-commerce. Record custody, GST/HST filing, and compliance in one integrated service, with no carrier or broker lock-in. Ship with FedEx, UPS, DHL, Purolator or any freight forwarder, delegate any broker in the CARM portal, and switch whenever you like. The records arrangement with CBSA stays exactly where it is.

  • Canadian data residency: records stored exclusively on servers in Canada
  • End-to-end compliance: from import documentation through GST/HST filing
  • Built for international clients: clear, documented email communication across all time zones and languages
  • Government liaison: we communicate directly with CBSA and CRA on your behalf
  • No carrier or broker lock-in: use any courier, freight forwarder or customs broker you choose, and change them any time; we hold the records independently
How It Works

Four steps to compliance

  1. Onboarding: complete client intake documents and engagement paperwork
  2. Authorization: authorize us as your representative with CRA and CBSA
  3. Portal access: receive your secure, encrypted portal and begin uploading documents
  4. BSF900 upload: we prepare your BSF900 and engagement letter; you sign and upload them in your CARM portal with our screen-by-screen guide
RobMarsha
Rob & Marsha Cosman, CPAYour authorized Canadian record custodian. Encrypted storage and CARM delegation.
Client Results

What our clients say

★★★★★
"Rob and Marsha have been providing tax services for my companies and family for over 4 years. Highly recommend!"
CP
Calvin Parker
Corporate & Personal Client
★★★★★
"What used to take me 6+ hours to piece together, they handle in about an hour. Incredible team."
MT
Mehdi Tihani
Amazon Seller
★★★★★
"They took care of everything - corporate tax, personal tax, GST filing. I just focus on selling now."
AR
Amanda R.
Shopify Seller
Frequently Asked Questions

Common questions about CBSA record custody

Form BSF900 ("Agreement to Maintain Records Elsewhere Than the Place of Business in Canada") is the official notification to CBSA identifying where your import records are stored and who is responsible for maintaining them. We prepare this form and the custodian engagement letter as part of every engagement; you sign and upload the package in your CARM portal.
Under current CBSA policy, in Canada, the United States or Mexico. A head office in Europe, Asia, Australia or anywhere else does not qualify, and the declarations stored in the CARM portal do not replace your own books and records. If you have no place of business in Canada and your records sit outside the US and Mexico, the clean route is a Canadian custodian named on the BSF900.
Six years following the importation of the goods. That covers the commercial invoices, purchase and payment records, origin documents, customs accounting documents and records of the sale or other disposal of the goods in Canada, not just the paperwork your broker filed.
You do not need a place of business in Canada to be a non-resident importer. You need a business number with an import-export (RM) program account, financial security in the CARM portal if you want goods released before duties are paid, and a CBSA-approved place for your records. A PO box or mail-forwarding address does not count as a place of business for records purposes.
Clearing your goods and keeping your books and records are two separate obligations. FedEx's own guide for non-resident importers says records must be kept in Canada, the US or Mexico, and that an importer with no place of business in Canada can designate an authorized agent, with the request for approval sent to CBSA on form BSF900. Neither FedEx nor UPS offers to be that agent on their CARM pages. The accounting declarations your courier or broker files are only part of your records; CBSA also requires the purchase, payment, origin and sale or disposal records behind each shipment. A licensed customs broker, an accountant or another authorized agent in Canada can be named on the BSF900. We can be that agent once CBSA approves your BSF900, and your courier keeps clearing your shipments exactly as before.
Yes. The records arrangement is independent of who moves or clears your goods. Ship with FedEx today and UPS, DHL, Purolator or a freight forwarder next year, and delegate whichever broker you like in the CARM portal. The BSF900 names us as the records agent, not your carrier, so changing carriers or brokers does not mean redoing the records arrangement with CBSA. You are not tied to one provider, and your records do not depend on staying with any one of them.
No. Delegation of authority lets a broker transact on your CARM account, such as filing accounting declarations and viewing your statement of account. It does not move the record-keeping obligation. Under Memorandum D17-1-21 the importer remains responsible for maintaining the records even when an agent holds them, and UPS's own CARM page notes that delegation does not replace a power of attorney. Records need their own arrangement, and that is the BSF900.
A licensed customs broker can be named on the BSF900 if it agrees to hold your books and records. FedEx and UPS do not offer it on their CARM pages, and a broker that does may expect you to keep clearing through it. Ask yours directly. If the answer is no, or you would rather not tie your records to your clearance provider, that is what this service is for.
Either party can terminate with 30 days written notice. During that period, you can transfer your records to another custodian or download them directly. Your data remains archived for 12 months after termination. We notify CBSA that we are no longer custodian, so there is no gap in your compliance record.
You receive a private, password-protected portal with 24/7 access to upload, download, and view your records. Each client folder is fully isolated and every action is logged for audit traceability.
All records are hosted on encrypted servers in Canadian data centres. Data is encrypted in transit and at rest, every access event is logged, and backups are maintained in a geographically separate Canadian facility. Only you and our compliance team have access.
Yes. GST/HST filing is available as a separate service, giving you one point of contact for all Canadian import compliance.
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Sell into Canada with confidence

We prepare your BSF900, store your records, and handle the government communication. You focus on growing your Canadian sales.

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