The BSF900 Form: Custodian Rules and the CARM Upload for Non-Resident Importers (2026)

If you import goods into Canada and have no place of business here, CBSA still expects your import records to be kept in Canada or, with its approval, in the US or Mexico. That approval is Form BSF900. For a business based anywhere else, it means naming a record keeper in Canada and getting the BSF900 approved. Since May 13, 2024, CBSA will not issue an import-export (RM) program account until that BSF900 is approved. No approved BSF900, no RM account, and no RM account means you cannot clear commercial shipments as the importer of record.

This is the question we field most often from businesses outside Canada that import into the country: wholesalers supplying Canadian retailers and distributors, direct-to-consumer brands shipping to Canadian customers, and marketplace sellers. This guide covers who needs to file, who is actually allowed to keep your records, exactly where the upload happens inside the CARM portal, and the mistakes that get the package sent 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 import records at their place of business in Canada for six years following the importation of the goods. The BSF900 is how CBSA approves any other arrangement: records held by a designated agent in Canada, such as a customs broker or accountant, or records kept in the US or Mexico. Records kept anywhere else, including on your own servers in Europe or Asia, do not qualify.

One thing worth knowing before you go looking for it inside the portal: the BSF900 is not an online form. It is a two-page agreement you complete and sign as a document, then upload to the CARM Client Portal as an attachment. 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 as the importer of record, whether you sell through a marketplace, your own website, or entirely B2B with no website at all.
• Your records are not physically kept at a place of business inside Canada.

That second point captures almost every non-resident importer. If your accounting team is in Stockholm or Bangkok and your sales records live in QuickBooks Online (hosted outside Canada), you are not keeping records at a Canadian place of business, even though QBO is “cloud” software. Being able to log in to your records from Canada does not make them records kept at a place of business in Canada.

Four quick scenarios:

What happens if you do not file it?

The chain of consequences if you do not file:

1. New importers: CBSA will not issue your RM account. You cannot import as the importer of record.
2. Existing importers: CBSA expects you to add a books and records address to your program account in CARM and submit the BSF900. If you fall short of the record-keeping rules, CBSA can assess penalties under the Administrative Monetary Penalty System (AMPS) and hold your goods at the border until you comply.
3. At audit: if you cannot produce the records CBSA asks for, it can assess AMPS penalties, detain your goods until you comply, and deny or withdraw lower trade-agreement duty rates on the goods involved. If you have an approved BSF900 and do not honour it, CBSA can cancel the agreement.

In practice, many non-resident importers 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 keep your records?

This is where BSF900 applications often go wrong. The record keeper is the person or company responsible for producing your import records when CBSA asks. Not every arrangement qualifies.

Allowed:

• A designated Canadian agent with their own Canadian business address, such as a licenced customs broker, an accountant, or another authorized agent. This is the most common option for non-resident importers.
• You, at your own premises or servers in the US or Mexico. This still needs an approved BSF900, and on the form you agree to pay CBSA’s travel costs if officers audit you there. Records kept at your own offices in Europe or Asia do not qualify.

Not allowed:

• Your freight forwarder, logistics company, or carrier named as the importer. The BSF900 is your own agreement with CBSA, under your business name and Business Number. The form says: “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.”
• Any location outside Canada, the US and Mexico, including cloud storage hosted in Europe or Asia. The form asks for the server’s physical location and the hosting company.
• A PO box or mail-forwarding address. CBSA does not accept either.

Step by step: how to submit the BSF900

The submission happens only inside the CARM Client Portal. The sequence is: sign the form as a document, answer one specific question in the portal, then upload the signed package as attachments.

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 link your business in the CARM portal. Most non-resident importers apply for the BN at the same time they apply for their GST/HST account.

Step 2. Register on the CARM Client Portal

An owner or officer of your company creates the portal account and becomes the Business Account Manager (BAM) for your business. 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 a common reason approvals stall.

Step 3. Complete and sign the BSF900 package

The form itself has two pages: your company details, where the records will be kept and who keeps them, the server location if the records are electronic, and your promise to make the records available in Canada when CBSA asks. Two authorized officers sign it. If your company has only one signing officer, that person signs and writes “sole signing officer” under the signature. If a third party will hold your records, the package also includes their signed confirmation that they will keep custody of the records and make them available on request.

Step 4. Answer the books and records question, then upload

The portal asks one specific question: “Are the books and records for this program kept in Canada?” Answering No is what opens the door to attach the BSF900. Where you meet that question depends on where you are in the process:

• New importers hit it while enrolling in the Importer (RM) program, in the Books and records section of the enrolment. Answer No, complete the enrolment, then use Add attachment(s) on the Confirmation of submission page to upload the package. CBSA does not issue the RM account until it has approved the BSF900.
• Existing importers go to Menu, then Accounts and profiles, then Program account profile. Open the Addresses tab, edit the Books and records address, answer No to the kept-in-Canada question, submit, then use Add attachment(s).
• Uploading later: if you submitted the answer without the documents, the request sits under the Requests tab as Pending documentation. Use the upload icon there.

What goes in the upload: the signed BSF900, the record keeper’s signed confirmation, a copy of your company’s entry in its home corporate registry, and proof that the registration is current for this year (for example, a paid annual registration fee or a certificate of good standing). The form also asks non-residents for a link to that registry, your company website, and a short description of your business and main imports to Canada. CBSA updates the portal layout from time to time, so if a menu name looks different, head for the books and records address on your program account profile.

Step 5. Submit and wait for approval

CBSA does not publish a processing time for the BSF900. Approval takes longer if anything in your supporting documents does not match CRA records, or if the record-keeping arrangement is not clearly documented. Plan for at least one round of follow-up questions. When CBSA approves the agreement it issues an approval letter; keep it with your records as proof.

What CBSA actually checks when they show up

The point of the BSF900 is to make audits work. 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 records have to be produced by the deadline in CBSA’s request, and CBSA also expects access to someone who can explain them. If the only people who understand your files are nine time zones away, that deadline gets tight fast.

Choosing a custodian: CPA versus logistics company

Many 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:

At Jones & Cosman, our CBSA Record Custody service is built around the CPA model. We prepare the BSF900 and the custodian agreement with our details already completed, host your records on Canadian servers, give you a private upload portal, and respond to CBSA if you are audited. You sign the package and upload it in your own CARM portal; we send a screen-by-screen guide, so the submission itself takes minutes. 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.

The service is $999 USD per year, setup included, everything in one plan. Details on the pricing page.

Frequently asked questions

Where do I upload the BSF900 in the CARM portal?

On your program account profile. Open the Addresses tab, edit the books and records address, answer No to whether the records are kept in Canada, submit, then use Add attachment(s). New importers meet the same question during Importer program enrolment and upload on the Confirmation of submission page. If the documents were not attached at the time, the request appears under the Requests tab as Pending documentation.

Can my freight forwarder handle the BSF900 for me?

Not under its own name. The BSF900 is your agreement with CBSA, filed in your business name and Business Number, and the form says it cannot be in the name of a freight forwarder, logistics company or carrier involved only in transporting the goods. It is uploaded from your own CARM business account. A third party can prepare the package and can hold your records, as long as it signs a document agreeing to keep them and produce them on request.

How long does CBSA take to approve the BSF900?

CBSA does not publish a processing time. Approval takes longer if there are name or address discrepancies between your CARM submission and what CRA has on file, or if the record-keeping arrangement is not clearly documented. When CBSA approves the agreement it issues an approval letter; keep it with your records.

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 importers 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 following the importation of the goods, under the Imported Goods Records Regulations and Memorandum D17-1-21. If you change record keepers or move records during that period, you remain responsible for them.

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. On the form you agree to tell CBSA about any change.

What does CBSA actually do with the BSF900?

They use it during audits and verifications. When CBSA decides to verify your import records, they can 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 can apply.

What to do next

If you are a non-resident business that 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 prepare your BSF900 package and act as your Canadian record custodian, get in touch. Send us a short note about where you import from, how you sell into Canada (wholesale to distributors, direct to consumers, marketplaces, or a mix), 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.