The Grace Period Is Over
CBSA closed its Systems Outage Contingency Plan on June 9 at 23:59 ET. The seven-day AMPS grace period expired June 16 at 23:59 ET, which means penalties for ACI cargo reporting errors, eManifest transmission failures, and CAD filing mistakes are back in full force. If your broker was filing under relaxed data-quality rules during the outage, that latitude ended last week.
The Technical Commercial Client Unit bulletin TCC26-0090 is now formally closed, and the BCCC Systems Outage Ad Hoc Working Group that ran weekly stakeholder calls during the outage has wrapped. For most importers, that means one thing: whatever workarounds you or your broker put in place to handle transmission delays, manual entry, or partial data sets need to be rolled back before the first penalty notice lands.
What Changed During the Outage
CBSA invoked the contingency plan to allow manual workarounds when electronic systems for cargo reporting, release, and payment couldn't accept or process data reliably. Brokers could submit partial manifests, delay CAD transmission windows, and lean on phone or email coordination with local offices when CARM Client Portal or PARS wouldn't load. CBSA suspended AMPS penalties for contraventions tied directly to system failures.
That suspension covered ACI data errors when the pre-arrival reporting system rejected transmissions, late eManifest filings when the highway carrier manifest portal timed out, and delayed CAD submissions when the CARM portal dropped sessions mid-entry. It did not cover substantive errors like wrong HS classification, incorrect CUSMA origin claims, or missing SIMA declarations. Those penalties stayed live throughout the outage.
The one-week grace period gave brokers and importers time to audit their backlog, clean up incomplete filings, and resolve discrepancies before AMPS enforcement resumed. If your brokerage team flagged deferred CADs or partial manifests during the outage, June 16 was the hard deadline to close them out.
AMPS Penalty Exposure Post-Resumption
AMPS penalties for cargo reporting and CAD transmission errors follow the Master Penalty Document schedule. ACI errors typically trigger CAD 250 to CAD 1,000 per contravention depending on whether it's a first offense or a repeat within 24 months. eManifest errors for highway carriers run CAD 500 to CAD 2,000. CAD filing errors, incorrect tariff treatment claims, or missing supporting documents on origin verification can pull CAD 1,000 to CAD 5,000 per entry.
If your broker filed a dozen entries under contingency rules with partial data or delayed transmission, and CBSA's automated review flags any of them for incomplete ACI or eManifest correlation, you'll see penalty notices in the next thirty to sixty days. CBSA usually batches these assessments monthly, and the first round post-resumption will pull from filings made in the final week of the grace period.
The practical exposure sits with repeat offenders. If your broker has had ACI timing issues or manifest mismatches in the past 24 months, post-outage penalties escalate to the higher tier automatically. That's where a single fumbled CAD during the grace period can pull a CAD 2,000 assessment instead of CAD 500.
What to Audit Now
Pull a list of all entries filed between the outage start date and June 16. Cross-check that every CAD has a matching ACI cargo control number, that eManifests for highway shipments show received status in the CBSA system, and that any manual workarounds during the outage (phone approvals, emailed entry summaries, paper RMD requests) have been formalized in the CARM Client Portal.
If you're an NRI (Non-Resident Importer), check that your broker uploaded supporting documents for every entry filed during the outage. CBSA's document retention requirement didn't pause, and missing commercial invoices or CUSMA certificates will trigger penalties even if the CAD itself transmitted cleanly.
For PARS shipments that released prior to payment during the outage, confirm your broker reconciled the RPP bond draw and filed the final accounting within the standard seven-day window. CBSA extended transmission deadlines during the outage but did not extend the bond accounting clock. If your broker missed that window, you're carrying an open liability that CBSA will assess interest on once they run the next monthly K84 statement.
Inbound Freight and Drayage Timing
If the systems outage delayed release at the port or caused your drayage carrier to sit while your broker sorted manual entry, those containers are either cleared or still in sufferance. For Montreal importers using our sufferance facility, we saw a two-to-three-day lag on exam-flagged shipments during the outage because CBSA couldn't schedule exams through the portal. That backlog cleared by mid-June, but if you have containers that arrived during the outage and are still sitting, check whether the hold is a system artifact or an open verification request.
Drayage carriers invoiced detention for delays caused by the outage. Some of that is recoverable if your contract includes force majeure language covering government system failures, but most carriers treated CBSA portal downtime as a normal delay and billed standard rates. If you're disputing those charges, pull the CBSA bulletin date range and your broker's transmission logs to show the delay was outside your control.
Filing Discipline Going Forward
The outage exposed how fragile just-in-time CAD filing is when the portal goes down. Brokers who file at 4:00 PM on arrival day lost the ability to release same-day when the system dropped. Brokers who file ACI 24 hours pre-arrival and have the CAD ready to transmit at time of arrival kept freight moving even when the portal was intermittent.
If your broker was scrambling during the outage, that's a sign your filing window is too tight. The standard practice is ACI transmission no later than two hours before arrival for highway, 24 hours for ocean freight coming into Montreal. CAD should be ready to file within one hour of cargo release by CBSA. Anything tighter than that assumes perfect system uptime, which June proved is not a safe assumption.
CBSA has not said whether they'll invoke contingency measures again if the CARM portal has another multi-day outage, but the June resumption notice makes it clear they consider the current system stable enough for full enforcement. That means your compliance process needs to assume the portal is live and AMPS penalties are active, every day.
If your broker filed under the contingency plan and you're not sure whether your entries are clean, pull the audit now before the penalty notices start landing. We run that review for clients every quarter as a matter of course, and post-outage is a good time to do it if you haven't in the past six months. Get in touch.
Originally published at https://www.canflow-global.com/en/insights/cbsa-systems-outage-contingency-ends-june-16-amps-penalties-resume-in-full/.
