Customs broker bookkeeping: disbursed duty is never your revenue

The brokerage fee is revenue. The duty you disburse is not.

A customs broker's invoice mixes two entirely different things, and the books need to separate them at the source. The brokerage fee — the charge for classifying goods, valuing the shipment, and transmitting the entry to CBSA — is the firm's revenue, subject to GST/HST like any other taxable service. The duty, any surtaxes, excise tax, and the 5% GST paid to CBSA on the client's behalf are not revenue at all: they are a client cost the brokerage advances and recovers, and they belong on the balance sheet as a disbursement receivable, never in the income statement.

Recording the full disbursed amount as revenue, with the CBSA payment booked as an offsetting expense, does more than gross up the P&L for no reason. It can misstate the GST/HST return, since gross throughput and true taxable fee income are two different numbers, and it makes year-over-year revenue comparisons meaningless the moment tariff rates or import volumes shift.

CARM changed who fronts the money — track both models at once

Under CBSA's Assessment and Revenue Management system, each importer now has its own account in the CARM Client Portal and can see its own statement of duties and taxes owed directly to CBSA. Historically, a brokerage's own bond funded Release Prior to Payment, so goods moved before duty cleared and the brokerage billed the client afterward out of its own disbursement account, carrying the float itself. As CARM pushes more importers to post their own Release Prior to Payment security instead of leaning on a broker's bond, more clients are expected — as at the time of writing — to settle directly with CBSA over time, which gradually shrinks, but does not eliminate, the disbursement-financing role many brokerages have built their billing habits around.

We set the books up to track both models side by side: a disbursement ledger per client for accounts the brokerage still funds, and a fee-only ledger for clients who pay CBSA directly, so the transition doesn't quietly blur into the fee revenue line while it plays out.

USD disbursements to US broker partners

When a shipment continues on to a US destination, or a Canadian brokerage uses a US partner to complete clearance on the other side, disbursements and referral payments settle in USD. Those need a dedicated USD clearing account, translated at the Bank of Canada rate on the day of payment, with any balance still open at month end revalued at the closing rate — the same discipline an importer runs on USD supplier terms, applied to the disbursement side of the ledger instead of inventory. We keep a clean answer for how to record USD transactions in Canadian books so this doesn't get treated as a rounding error. Skipping the revaluation buries a real FX gain or loss inside "disbursements recoverable," and the account never quite reconciles to what a client actually owes.

Age the disbursement receivable like the risk it is

A disbursement receivable is a short-term loan to the client for as long as it sits open, and thin brokerage fee margins do not absorb a bad debt gracefully — one client that goes under owing weeks of fronted duty can erase a quarter's fee income. We age disbursement receivables separately from ordinary trade receivables, flag accounts drifting past normal terms before the exposure compounds across multiple shipments, and size a bad-debt reserve to real client risk rather than folding it into a generic allowance that hides which accounts are actually the problem.

Reconciling the CARM statement of account to the general ledger every month — the same discipline an importer runs on its own file — catches CBSA-side discrepancies while a client's account manager can still explain what happened, instead of chasing a mismatch back through a stack of old entries at year end.

For the trade-compliance side of the business — US partner referral fees, CUSMA origin work, and USD-denominated cross-border operations — see our cross-border tax guide for customs brokers. The monthly close behind all of this runs as described on our bookkeeping services page, fixed fee after a discovery call.