CBSA Importer of Record – Coming Into Force January 1, 2026
The CBSA’s Border Commercial Consultative Committees (BCCC) has recently announced that the Governor In Council has fixed the date for implementation of the Importer of Record (IOR) amendment as January 1, 2026.
This notice can be found at Canada Gazette, Part 2, Volume 158, Number 22: Order Fixing January 1, 2026 as the Day on Which Section 307 of the Budget Implementation Act, 2022, No. 1 Comes into Force
The CBSA has stated that the section 17 amendment will remain inactive until January 1, 2026, and that this implementation date reflects the need for industry to have time to adapt their business models, and risk management practices in preparation for the introduction of IOR liability.
In keeping with the in-force date of January 1, 2026, the two policy instruments that will guide and govern implementation of the IOR amendment. will also come into effect on January 1, 2026. These documents are:
D17-2-5 Duty Liability of Importer of Record
This confirms that the CBSA considers the Importer of Record as the primary contact for verifications and the entity with direct liability for payment of duties
Memorandum D11-6-11 Post-Accounting Obligations of Authorized Agents
Authorized Agents as Importer of Record provides information about the liability for post-accounting duties assumed by Authorized Agents who are the Importer of Record in accordance with an agreement with commercial entities.
Consistent with CBSA’s culpability framework, the CBSA has stated that their compliance objective during the early phases of implementation will be to provide feedback to the IOR on their compliance performance. Their goal is for this to be achieved principally through highly targeted, less obtrusive compliance interventions (i.e., compliance validation letters, trade advisory notices).
It is the CBSA’s intent that through early compliance feedback to IORs, this will help companies to assess their risk exposure, and determine whether changes or investments to improve compliance, are warranted.
In relation to the four-year reassessment period under the Customs Act, the CBSA confirms the following:
“”…although IOR liability is effective as of January 1, 2026, the full four-year impact of shared liability will not be experienced by industry until January 1, 2030. “
Doug Band
Director General, Trade and Anti-dumping Programs Directorate Commercial and Trade Branch
Canada Border Services Agency
If you have any questions with the CBSA’s Importer of Record amendments coming into force in January 2026, please feel free to reach out to your Dominion representative or our use our contact form.
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