Eighty percent of all international customs declarations cleared in the UK in 2025 were handled by a third-party intermediary. Ninety-nine percent of traders relied solely on an intermediary to declare all of their trade. Those two figures, tucked into HMRC’s own consultation document, say a lot about how central this industry has become to UK trade — and they help explain why HMRC is now taking a closer look at how the sector is regulated.
In the space of a few weeks this summer, two developments moved that conversation forward. On 2 June 2026, BSI published BSI Customs intermediaries, the UK’s first standard for customs intermediaries, sponsored by HMRC. Three weeks later, HMRC opened a consultation on mandatory registration for customs intermediaries — a proposal that would require anyone filing customs declarations on behalf of traders to meet minimum fitness-to-practise requirements before accessing the Customs Declaration Service.
We think both developments are a positive and overdue step for the industry, and we’d like to explain why — including what other countries already do in this space, and where we think this could sensibly go next.
What’s Actually Landed So Far
PAS 41201:2026 Customs intermediaries – Preparation and submission of customs declarations is a voluntary specification, developed by BSI with a steering group including BIFA, the Chartered Institute of Export & International Trade, the Federation of Small Businesses, the Customs Practitioners Group, and HMRC.
It sets out good practice across four areas: due diligence, continuing professional development, systems and data, and transparency. It asks intermediaries to audit a sample of their own declarations quarterly, correct their own errors within 90 days at no charge to the client, apply standardised due diligence to the businesses they act for, and publish clear pricing.
There is no certification scheme yet. HMRC has confirmed one is being developed, with UKAS providing accreditation above it, but that infrastructure doesn’t exist today. For now, the standard describes direction of travel rather than a badge anyone can currently hold.
The mandatory registration consultation goes further. It proposes that anyone submitting customs declarations on a trader’s behalf — agents, brokers, freight forwarders, express operators — would need to register with HMRC and meet baseline fitness checks before being allowed to interact with CDS.
The proposed bar mirrors requirements introduced for tax advisers in May 2026: up-to-date tax affairs, no disqualification as a company director, no unspent convictions for relevant offences, and no history of serious customs non-compliance. Enforcement would be graduated — guidance and warnings first, escalating through suspension to penalties, with removal from the system as a last resort.
Read together, the direction is clear. PAS 41201 describes what good practice looks like. The consultation asks whether HMRC should be able to stop the sector’s worst actors from accessing the border system at all.
Why We Think This Is the Right Direction
We’ll be upfront about our position: we already operate a compliant agency that does much of what PAS 41201 describes — documented due diligence, standard operating procedures, transparent pricing, long-term record retention. None of this feels like a burden to us. It’s simply how we’ve tried to operate, because the alternative is a client facing an unexpected demand because something wasn’t checked properly.
But the case for these changes isn’t really about any one firm’s practice. It’s about the position traders are currently in. Under UK customs law, liability for a declaration generally sits with the trader whose EORI it’s filed under — not the intermediary who prepared it.
A trader who appoints an undertrained or careless agent takes on real financial exposure, often without realising it, because nothing currently requires that agent to demonstrate basic competence before acting.
That’s a significant gap for an activity of this scale. With such a high proportion of UK trade relying entirely on intermediaries, having no minimum entry standard at all leaves genuine room for inconsistency across the sector.
It can also make it harder for traders to distinguish between agencies that invest in training and internal audit, and those that don’t — particularly when price is the only visible point of comparison. A baseline standard, even a modest one, gives traders a clearer signal to look for.
We’d also suggest this is best read as two steps in a sequence rather than a finished picture. Registration, as currently proposed, checks conduct and standing — clean tax affairs, no relevant convictions, no live insolvency. It says less about technical competence on its own. That’s where PAS 41201, and the certification scheme still being developed on top of it, has real potential: to move the industry from a conduct check toward a more meaningful assessment of classification, valuation, and origin knowledge over time.
We’d also see value in AEO-authorised agents having a clearly differentiated status within this framework, given the scrutiny that authorisation already involves, and in keeping any transition period reasonably short, so a compliant agency isn’t undercut on price for longer than necessary by one that isn’t.
The UK’s current position — no licence, no exam, no minimum bar to act as a customs broker — is unusual by international standards, not typical.
The United States has required a licensed customs broker since 1930. Candidates sit the Customs Broker License Exam, an 80-question test on the Harmonized Tariff Schedule and federal customs regulations, administered twice a year by US Customs and Border Protection, alongside a background check. Around 14,000 brokers currently hold an active licence.
Türkiye requires most commercial import declarations to be filed by a licensed customs broker, who carries professional and personal responsibility for the accuracy of what’s declared. For all but the largest importers with in-house authorisation, using a licensed broker isn’t optional.
Australia also operates a licensing system, administered by the Australian Border Force under the Customs Act. Customs brokers must pass a qualifying exam covering tariff classification, valuation, and customs procedure, and hold a licence before they can lodge declarations on a client’s behalf.
Each of these are substantial, high-volume trading nations, and none appears to have found that licensing brokers created unmanageable friction at the border. What it did create was a profession with a floor — a baseline a trader can rely on before price ever enters the conversation.
The UK has built an increasingly complex post-Brexit customs landscape — CDS, GVMS, IPAFFS, the Border Target Operating Model — largely on top of a sector with no equivalent minimum standard. Closing that gap, gradually and proportionately, looks like sensible catching-up rather than a radical step.
A Fair Hearing for the Concerns
It’s worth acknowledging the concerns raised by smaller operators in particular. Compliance requirements do carry a cost, and some worry this could squeeze smaller, otherwise capable brokers. Looking at what PAS 41201 and the registration proposals actually ask for — documented procedures, standardised due diligence, good tax standing, no relevant unspent convictions — none of it should be onerous for a business already operating properly. It becomes a real cost mainly for firms whose current approach relies on not doing those things.
There’s also a fair point that registration alone, being a conduct check rather than a competence test, won’t catch every source of error — an agent can have a clean record and still be out of their depth on a complex classification. That’s precisely why we see this as a starting point rather than the finished article, with the certification scheme still to come carrying the more meaningful test of technical capability.
HMRC’s consultation remains open until 21 September 2026, and we’d encourage anyone with a view — supportive or sceptical — to respond directly, since this is a decision that will shape the industry for years to come.
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Fn Customs Limited is an AEO-authorised customs broker and freight forwarding agency based in Nottingham.