CBSA Trade Compliance Verification (TCV) is the CBSA audit program for Canadian importers. CBSA selects importers based on risk targeting and verifies tariff classification, customs valuation, country of origin, and tariff treatment. Findings can result in reassessments and AMPS penalties. The program is risk-based; not every importer is verified, but high-volume or pattern-flagged importers are selected periodically.
CBSA Trade Compliance Verification is the Canadian equivalent (in concept) of CBP Focused Assessments – the formal audit program through which CBSA verifies importer compliance with the Customs Tariff and related regulations.
This guide explains how CBSA selects importers, what the verification covers, what timelines look like, and what outcomes typically result.
How CBSA selects importers for TCV
CBSA risk targeting uses a mix of factors: entry volume, prior compliance posture, sector-specific risk priorities, classification patterns flagged in CBSA review, and intelligence-based selection. CBSA also runs sector-wide verification rounds where multiple importers in the same industry are verified concurrently.
Verification scope
Scope is set in the initial notice. Common verification topics: HTS classification accuracy across high-volume entries, customs valuation (particularly related-party pricing), country of origin under USMCA / CETA / CPTPP / CKFTA, surtax applicability (Chinese EVs, Chinese steel/aluminum), AD/CVD scope.
Documentation expectations
CBSA expects: complete entry summaries, commercial invoices, bills of lading, supplier affidavits where origin is claimed, BOM analyses for complex products, related-party pricing studies where applicable, and broker correspondence.
Timeline
Initial notice → 30-day response → CBSA review → potential additional document requests → preliminary findings → response window → final determination. Typical end-to-end: 6-18 months.
Outcomes
Three outcomes: (1) no reassessment, audit closes; (2) reassessment with additional duty owed (and potentially AMPS penalties); (3) reassessment with refund owed (less common but does occur). Reassessments can be appealed.
Self-audit before CBSA does
Importers can run self-audits to identify compliance gaps before CBSA verification. Common self-audit categories: HTS classification across high-volume SKUs, USMCA/CUSMA documentation completeness, surtax compliance on Chinese-origin goods. We run self-audits as fixed-fee engagements.
Frequently asked questions
Will my company be selected for a TCV?
CBSA does not publish criteria. High-volume importers (>$10M annual import value), importers in flagged sectors, importers with prior compliance issues, and importers with classification patterns inconsistent with peers are more likely to be selected.
What triggers a reassessment after TCV?
CBSA finding that classification, valuation, or origin was incorrect. The reassessment is the additional duty owed plus any AMPS penalties.
Can I appeal a TCV reassessment?
Yes. Section 60 of the Customs Act allows appeals to the President of CBSA, then to CITT, then to Federal Court. Each step has procedural requirements and deadlines.
How does TCV interact with CARM?
CARM is the platform; TCV is the program. CARM facilitates entry filing and payment; TCV operates within CARM data plus broader CBSA visibility into importer activity.
What does a self-audit cost?
Depends on scope. Targeted self-audit (specific HTS classes, specific entry period): $4,500-$10,000. Comprehensive self-audit covering 12 months of entries: $15,000-$35,000.
Get started
Want to assess your TCV exposure before CBSA does? Send us a sample of entries; we will run a self-audit on a fixed-fee basis.