Nobody is forced to hire a broker. What is restricted is a narrow set of activities — and the liability never moves off the importer either way.
Key takeaways
No. The CBSA states plainly that importers may choose to prepare and submit their own release and accounting documentation, and may instead authorise an agent to transact business on their behalf. There is no rule that an importer must retain a broker, however small or however frequent the shipments.
What is restricted is narrower than most people assume. Only a licensed customs broker may account for goods and pay duties under section 32 of the Customs Act as an agent of an importer or owner. Section 32(1) is the provision that says no goods are released until they have been accounted for by the importer or owner in the prescribed manner and all duties on them have been paid. So the real question is not whether you are allowed to self-file; it is whether you want to own that work.
The CBSA lists the business an authorised agent may transact for a client: registering for a Business Number import/export account, assisting in cases under the Special Import Measures Act, submitting refund and adjustment requests, preparing release (interim accounting) documentation, preparing final accounting documentation, and remitting duties and taxes to the Receiver General. The last three of those are the section 32 activities reserved to licensed brokers.
Two practical consequences follow. First, a consultant, a freight forwarder or an in-house trade specialist can do a great deal of the work — classification research, ruling requests, record keeping, supplier documentation — without a broker licence. Second, the moment somebody is filing the accounting and paying the duty in your name, they need the licence. Acting as a customs broker without one may attract an AMPS penalty (C011), and the CBSA runs a mailbox for reporting firms that advertise brokerage services without a licence.
Note also that separately incorporated divisions of a single company are separate legal entities, and may not transact business under section 32 on behalf of one another. Groups that centralise imports into one entity should check that the entity on the accounting document is the one that actually imported.
This is the part that changes how you should shop. The CBSA is explicit that although importers may use an agent, the importer is ultimately responsible for the accounting documentation, payment of duties and taxes, and subsequent corrections such as re-determination of classification, origin and valuation, and remains liable for all duties owing until either the importer or the agent pays them. Importers who use a broker are responsible for the accuracy and completeness of the transactions, including any AMPS penalties for non-compliance.
A broker is therefore a capacity decision and a competence decision, not an indemnity. If you are buying a business that imports, unpaid duty and tariff exposure sits with the importing entity — a point Treadstone’s sister law firm covers in its answer on discovering unpaid customs duties before closing.
Section 40(1) of the Customs Act requires every person who imports commercial goods to keep records at their place of business in Canada and produce them on request. The Imported Goods Records Regulations set the period: all records relating to the commercial goods must be kept for six years following the importation. A licensed broker has a parallel obligation to keep its own accounting documents, supporting documents and transmitted data for six years after the importation of the goods.
The overlap is not a duplication you can drop. Your broker’s file is their record, not yours. If your only copy of a commercial invoice lives in a broker’s portal and you change brokers, you have a six-year problem waiting for a verification letter.
Understanding the bar helps you judge a provider. Under the Customs Brokers Licensing Regulations, an individual applicant must be a citizen or permanent resident, of good character, at least 18, with sufficient financial resources and sufficient knowledge of import and export law — established by passing the Customs Brokers Professional Examination with a grade of at least 60 per cent. A corporation must be incorporated in Canada, with a majority of Canadian directors and at least one officer who meets the knowledge test.
Before a licence issues or is renewed, the applicant must give security in the amount of $50,000. Licences expire on 31 March following the date they take effect. The CBSA notes that the transition to national licensing happened automatically on 1 April 2024, so a broker with a single licence may operate at all customs offices in Canada, and that effective 1 April 2026 the annual licence fee is $751.65.
Worked example: a Kitchener manufacturer with 40 entries a year
The company imports components from two suppliers, on the same two tariff classifications, in roughly 40 shipments a year, all by highway from Michigan. There is no anti-dumping exposure, no free trade certification complexity beyond one CUSMA origin statement per supplier, and no permits.
That profile is a plausible self-file candidate: repetitive, low variety, and the classification work is done once. The costs are real but bounded — someone has to learn the accounting requirements, hold the six-year records, and be available when a verification arrives.
Change one variable and the answer flips. Add thirty suppliers, seasonal SKUs, textile origin rules and a remission claim, and the same 40 entries become forty different problems. The decision rule that holds up is variety and consequence, not volume: repetitive imports reward self-filing, varied and consequential imports reward a licensed broker who does this daily.
Carriers are frequently told they need a broker. They do not, for the act of crossing. What a carrier needs is a carrier code — a four-character unique identifier assigned by the CBSA, issued once to each legal entity per mode of transport — and the ability to transmit advance data on the freight it is hauling. Freight forwarders get their own carrier code on the same basis.
The CBSA’s carrier programme pages walk through eligibility and enrolment. A carrier that also wants to account for its customers’ goods would need a broker licence, which is why most carriers do not.
The clerical load of importing is document reconciliation: matching a commercial invoice to a packing list, to the accounting document, to the carrier’s manifest, to the supplier’s payment. Extraction tools read those documents and populate fields; rules flag a value that does not match the purchase order, a classification that differs from the one you used last month, or a shipment with no origin statement on file.
What software does not do is decide. Classification, valuation and origin are legal determinations with penalties attached. A tool can surface an inconsistency and draft the correction; a person — your own trade lead or your licensed broker — makes the call and signs it.
Only if that forwarder also holds a customs broker licence. Many do, as separate operations. A forwarder without one can arrange transport, consolidate, and hold its own carrier code, but cannot account for your goods under section 32.
No. The CBSA advises that importers who use a broker remain responsible for the accuracy and completeness of import and export transactions, including any AMPS penalties.
No. A single commercial shipment can be self-accounted, and the CBSA also licenses sufferance warehouses and other release options. Whether it is worth the learning curve for one shipment is a different question from whether it is permitted.
Not the CBSA. It states that brokerage fees are a private business transaction and that it does not intervene unless the client can show the broker has contravened the Customs Brokers Licensing Regulations.
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