If you import goods into Canada and your business is not based in Canada, the US, or Mexico, the CBSA requires you to file Form BSF900 before you can keep your import records on your own overseas servers. Since May 13, 2024, CBSA will not issue or maintain an import-export business account without an approved BSF900 on file. No BSF900, no Business Number for imports, no shipments cleared.
This is the question we field most often from Amazon FBA and Shopify sellers in Singapore, the UK, Germany, China, and Vietnam who are getting set up to import into Canada. The form is short. The rules behind it are not. This guide walks through who needs to file, what the form actually asks for, how to submit it through the CARM portal, and the most common reason CBSA bounces it back.
What is the BSF900 form?
The full legal name is the Agreement to Maintain Records Elsewhere than the Place of Business in Canada. CBSA uses it to record an agreement between you (the importer) and the agency about where your import records are physically held and who is responsible for producing them at audit.
The underlying rule is Memorandum D17-1-21, which says importers must keep their CBSA-related records in Canada for six years following importation. The BSF900 is the only legal way to keep those records somewhere else, including on your own overseas servers or with a designated Canadian agent.
The form itself is two pages. The work is in the supporting documents and in the relationship you set up with whoever holds the records.
Who needs to file the BSF900?
You need to file the BSF900 if both of these are true:
- You import goods into Canada (whether or not you sell through Amazon, Shopify, Walmart, or any other channel).
- Your records are not physically kept at a place of business inside Canada.
That second point captures almost every non-resident e-commerce seller. If your accounting team is in Manila and your sales records live in QuickBooks Online (which is hosted in the US), you are not keeping records at a Canadian place of business, even though QBO is “cloud” software. CBSA reads “place of business in Canada” literally.
Three quick scenarios:
| Your setup | Need to file BSF900? |
|---|---|
| UK company, Amazon FBA Canada, records in UK cloud accounting | Yes |
| Canadian-resident corporation with a Toronto office, records on Canadian servers | No |
| Singapore parent with a Canadian subsidiary that operates the import account from a Vancouver office | No (records are at the Canadian place of business) |
What happens if you do not file it?
Since May 13, 2024, CBSA has tied BSF900 approval directly to the issuance and maintenance of import-export business accounts. No approved BSF900 means no active RM account, which means your shipments do not clear customs.
The chain of consequences if you do not file:
- New importers: CBSA will not issue your RM account. You cannot import.
- Existing importers without a BSF900: CBSA may suspend or cancel your import-export program account. Your customs broker cannot release shipments under your account.
- At audit: if CBSA asks for records and you cannot produce them in Canada, the failure to file BSF900 makes the breach significantly worse. Penalties under the Customs Act can apply.
In practice, most non-resident sellers discover this when their first shipment gets held at the border and their broker says “you do not have an active import account.” By then the goods are accruing storage fees at the port.
Who can be your record custodian?
This is where most BSF900 applications fall down. The custodian is the person or company responsible for producing your import records when CBSA asks. Not every party in your supply chain qualifies.
Allowed:
- You (if your records are physically held by your own employees or systems, anywhere).
- A designated Canadian agent with their own Canadian business address. This is the most common option for non-resident sellers.
- A Canadian-licensed customs broker, but only if they are formally engaged as your record custodian (not just as your shipment clearer).
Not allowed:
- Your freight forwarder, logistics company, or carrier if their role is limited to transportation of the shipment. CBSA states this explicitly on the form: “the importer and business number on this form cannot be that of the freight forwarder, logistics company, carrier, or third party service provider involved only in the transportation of the shipment.”
- A cloud storage provider with no Canadian business presence and no Canadian business number.
Your freight forwarder cannot be your record custodian for BSF900 purposes. CBSA prohibits it. If your plan was “the forwarder will handle the records too,” your application will be rejected and you will need a separate custodian arrangement before CBSA will activate your import account.
Step by step: how to file the BSF900
The submission happens entirely inside the CARM Client Portal. CBSA stopped accepting paper or email submissions of BSF900 once CARM went live.
Step 1. Get a Canadian Business Number (BN)
If you do not already have a 9-digit Business Number, apply through the Canada Revenue Agency (CRA) first. You need a BN before you can register on the CARM portal. Most non-resident sellers apply for the BN at the same time they apply for their GST/HST account.
Step 2. Register on the CARM Client Portal
Go to the CBSA CARM portal and create a portal account using your BN. CBSA verifies your business identity through CRA-side data, so the corporate information you give CARM must match exactly what CRA has on file. Typos in your legal entity name are the most common reason approvals stall.
Step 3. Complete the form
Inside CARM, navigate to your importer profile and start the BSF900. The form has two pages:
- Page 1: importer details, custodian details, location of records, retention commitment.
- Page 2 (non-residents only): additional declaration confirming your non-resident status, where records will be physically held, and acknowledgment of the agent relationship.
Step 4. Attach the supporting documents
For non-resident importers, CBSA requires:
- A copy of your articles of incorporation or formation (the document that legally created your entity).
- Proof of current-year corporate registry status, typically a paid annual registration confirmation from your home jurisdiction.
- If you are using an agent, a letter or service agreement showing the agent has accepted the custodian role.
Step 5. Submit and wait for approval
CBSA approval normally lands within two to six weeks. The timeline drifts longer if anything in your supporting documents does not match CRA records, or if your agent relationship is not clearly documented. Plan for at least one round of follow-up questions.
What CBSA actually checks when they show up
The point of the BSF900 is to make audits work. What does an audit actually look like? In our experience handling these on behalf of clients, CBSA typically asks for:
- Commercial invoices for each shipment.
- Packing lists and bills of lading.
- Proof of payment to the foreign supplier (wire receipts, bank statements).
- The HS tariff classification you used and how you got there.
- Any rulings or correspondence with CBSA on classification or valuation.
- Inventory records that tie the imported quantity to what you eventually sold.
The custodian has to produce all of this within the response window CBSA gives, which is usually 30 days. If your custodian is your own overseas team and you are nine time zones away, that window gets tight fast.
Choosing a custodian: CPA versus logistics company
Most freight forwarders and customs brokers offer some form of record-storage add-on, since the demand for BSF900-compliant custody is high. Their offers are usually transactional. A CPA offers a different kind of relationship:
| Logistics company as custodian | CPA firm as custodian | |
|---|---|---|
| BSF900 filing & approval | Yes | Yes |
| Canadian-hosted record storage | Yes | Yes |
| 7-year retention | Yes | Yes |
| Audit response support | Sometimes (extra fee) | Included |
| GST/HST input tax credit recovery on the same imports | No | Yes |
| Integration with corporate or personal tax filings | No | Yes |
| Independent of any transportation provider | No (conflict of interest) | Yes |
At Jones & Cosman, our CBSA Record Custody service is built around the CPA model. We file the BSF900 on your behalf, host your records on Canadian servers, give you a private upload portal, and represent you to CBSA if an audit comes calling. Because the same firm prepares your GST/HST returns, the import records flow straight into your input tax credit calculations rather than sitting in a separate logistics company silo.
Pricing starts at $49 USD per month when bundled with our Non-Resident GST/HST service, or $999 USD per year standalone (setup waived). Full pricing on the pricing page.
Frequently asked questions
Can my freight forwarder file the BSF900 for me?
They can file the paperwork on your behalf as a service, but they cannot be named as your record custodian if their relationship with you is limited to transportation. CBSA is explicit on this. You need a separate custodian arrangement.
How long does CBSA take to approve the BSF900?
Typically two to six weeks once the application is complete and the supporting documents match CRA records. Allow longer if there are name or address discrepancies between your CARM submission and what CRA has on file.
Do I need to file the BSF900 if I use a Canadian customs broker?
Using a customs broker for shipment clearance does not satisfy the record retention rule. You still need an approved BSF900 unless your records are physically held at a place of business in Canada.
Is the BSF900 different from registering for GST/HST?
Yes, completely. GST/HST registration is a CRA tax-side registration. BSF900 is a CBSA customs-side records agreement. Many non-resident sellers need both, but they are filed with different government agencies and serve different purposes.
How long do I have to keep my import records?
Six years from the date of importation, per the Customs Act and Memorandum D17-1-21. If you change custodians or move records during that window, you remain responsible for continuity.
Do I file the BSF900 once or do I have to renew it?
You file it once. It remains valid as long as the underlying arrangement (custodian, record location) does not change. If you change custodians, switch agents, or move records to a new jurisdiction, you must file a new BSF900.
What does CBSA actually do with the BSF900?
They use it during audits and verifications. When CBSA decides to verify your import records, they go to whoever you named on the BSF900 and request the documents. If the custodian cannot produce them within the response window, CBSA treats it as a records failure and penalties apply.
What to do next
If you are a non-resident e-commerce seller who imports into Canada and you do not have an approved BSF900 on file, this should be the first thing you fix. Without it, every shipment is at risk and every audit becomes a serious problem.
If you would like Jones & Cosman to handle the BSF900 filing and act as your Canadian record custodian, get in touch. Send us a short note about where you import from, what platforms you sell on (Amazon, Shopify, Walmart, other), and your current Canadian Business Number status if you have one. We respond within one business day with a fixed-fee quote.
You can also read our overview of CBSA Record Custody as a service, including the full feature set and pricing tiers.