The April 28 Revision
CBSA published a revised D23-1-1 covering the Partners in Protection (PIP) program. The memo still sits at the same URL, but the April update brings three practical changes worth noting if you're mid-application or planning one.
First, the documentation checklist for initial applications now explicitly calls out the supply chain security profile section that was previously buried in Appendix A. If you submitted drafts under the old memo and got kicked back for incomplete profile descriptions, this is why. The new version front-loads it.
Second, the physical security requirements table (formerly Table 2) now includes warehouse access control language that applies to both owned and third-party facilities. If your Montreal or Toronto warehousing partner isn't already PIP-certified or working under a compliant security protocol, CBSA expects you to document the gap and the mitigation steps. That's new language. It doesn't disqualify you, but it does mean your application narrative needs to address it.
Third, the renewal timeline shifted from 90 days before expiry to 120 days. Not a major change, but if you've got a PIP certificate expiring in Q3 2026, start the renewal file now, not in June.
Who Cares About PIP in 2026
PIP membership has always been a mixed value proposition. The benefit isn't tariff relief or duty drawback, it's mostly operational: access to the commercial FAST lanes at land borders, priority treatment during CBSA verification audits, and a reputational signal when you're bidding on contracts with U.S. clients who want a "trusted trader" box ticked.
For importers running high-frequency LTL or FTL shipments through Windsor, Sarnia, or Pacific Highway, the FAST lanes are real time savers. A driver with a valid FAST card and a shipment linked to a PIP-certified importer can shave 30 to 90 minutes off border wait times during peak hours. That's measurable when you're scheduling tight dock windows or managing perishable goods.
For everyone else, PIP is overhead. The application takes 60 to 90 days if CBSA is moving quickly, longer if your corporate structure is complex or your supply chain touches high-risk origin countries. The annual compliance requirements include updating your security profile whenever you change warehousing partners, carriers, or senior staff, and CBSA can audit your PIP compliance independently of any import verification. If you're a mid-market importer doing ocean freight twice a month and not running cross-border trucking, PIP is probably not worth the filing burden.
What CBSA Actually Reviews
The revised D23-1-1 doesn't change the minimum security requirements, but it does clarify how CBSA scores your application narrative. You're expected to document seven areas: business partner screening, physical security at all facilities where imported goods are handled, personnel security (background checks, access control, training), procedural security (how you handle documentation, cargo seals, exception reporting), conveyance security if you own or lease your own trucks, IT security (especially access to CARM Client Portal and eManifest systems), and crisis management or business continuity planning.
Most applicants stumble on the business partner screening section. CBSA wants to see that you vet your foreign suppliers, your freight forwarders, your drayage carriers, and your warehouse operators. A one-paragraph policy statement isn't enough. They want evidence: supplier questionnaires, signed agreements that include security language, records of site visits or third-party audits. If you use a Montreal sufferance warehouse operated by a third party, CBSA expects you to confirm that the warehouse meets PIP-equivalent security standards or document what you're doing to fill the gap.
The physical security table now includes specific language around perimeter fencing, lighting, access logs, and alarm systems. If you're importing into a shared commercial warehouse, you don't need to own the fence, but you do need to know whether the facility meets the standard and be prepared to explain it in your application.
The FAST Lane Linkage
PIP certification is the importer-side prerequisite for FAST eligibility. Drivers still need their own FAST cards (a separate application through CBSA and CBP), and the truck itself still needs to be enrolled in the FAST program. But without a PIP-certified importer on the CAD, the shipment won't qualify for the FAST lane at the border, even if the driver and truck are both approved.
This matters if you're managing a mixed carrier pool. Your dedicated contract carriers might all be FAST-enrolled, but if you occasionally use spot market trucks or backup carriers, those shipments will process through the standard commercial lane. The time savings evaporate. If FAST access is part of your value proposition to customers or part of your internal delivery SLA, you need tight coordination between your brokerage team and your carrier dispatch to make sure every shipment is booked with a FAST-eligible truck and driver.
When to Apply
If you're already PIP-certified and your renewal is coming up, start the file 120 days out. The revised D23-1-1 pushes the deadline earlier, and CBSA has been slower than usual processing renewals in Q1 and Q2 2026. We've seen 90-day turnarounds stretch to 120 when the application hits during peak filing season or when CBSA flags a minor documentation gap and the back-and-forth eats weeks.
If you're considering a new PIP application, the calculus is straightforward: add up the border crossing time you're losing on high-frequency shipments, multiply by your hourly drayage and driver cost, and compare that to the cost of preparing the application and maintaining annual compliance. For most importers running daily or weekly cross-border LTL, the math works. For occasional shippers or ocean-only importers, it doesn't.
The updated D23-1-1 is posted on the CBSA publications page. If you're mid-application under the old version, CBSA will generally accept filings that meet the old standard as long as they were submitted before April 28, but expect a request for supplemental documentation if your security profile narrative is thin.
We review PIP applications and handle the renewal filings for about thirty clients. If your current application is stalled or you're trying to figure out whether PIP makes sense for your shipment profile, get in touch.
Originally published at https://www.canflow-global.com/en/insights/d23-1-1-update-what-changed-in-the-pip-application-process-and-why-it-matters/.
