On 14 and 16 July 2026, two panel discussions hosted by HMRC highlighted the significance of the newly published Customs Intermediary Standard.
The voluntary standard is being billed as a practical step towards improving quality, transparency and trust across the UK customs intermediary market and wider supply chain.
The standard is published as a Publicly Available Specification (PAS) under PAS 41201 on the British Standards Institution (BSI) website.
Panellists included
· Mark McGuire, head of customs intermediary strategy team at HMRC
· Pawel Jarza, policy, compliance and external affairs director at the British International Freight Association (BIFA)
· Anna Doherty, technical director at the Chartered Institute of Export & International Trade
· Emma Coker, manager of indirect tax, Menzies LLP (member of the steering group)
The standard follows earlier HMRC engagement, including a 2022 call for evidence and a 2023 consultation, which concluded that, while the market generally has sufficient capacity, the consistency and quality of services provided to traders vary.
In his opening remarks Mark McGuire recognised that, even though much of the sector provides a good-quality service, the evidence showed mixed experiences of service quality. The standard has therefore been developed to set out what a ‘best-in-class’ service should look like, giving intermediaries a benchmark for improving their own processes and giving importers and exporters a clearer basis for selecting, instructing and reviewing their customs agents.
What is the standard trying to achieve?
A recurring theme over the two webinars was that intermediaries should not be viewed simply as data-entry providers. A good intermediary needs clear instructions, accurate information and an effective working relationship with the trader to make compliant declarations.
The standard is intended to support that relationship by setting expectations around due diligence, transparency, service delivery, professional competence, complaints handling and communication.
It also gives traders a practical reference point for understanding why compliant intermediaries ask detailed questions about classification, valuation, origin, licensing, preferential duty claims and representation arrangements.
Are AEO and the Customs Intermediary Standard the same?
Another topic discussed during the two webinars was the difference between the Authorised Economic Operator Customs Simplification (AEO(C)) often referred to simply as AEO, and the Customs Intermediary Standard.
Pawel Jarza explained that AEO is primarily a compliance-focused HMRC-granted authorisation for a business, whereas the Customs Intermediary Standard is more customer-facing and focuses on the service relationship between the intermediary and the trader.
There is some overlap, particularly for businesses that already hold AEO and have established documented controls. However, the standard focuses more directly on matters such as transparency of service, customer instructions, complaints, communication and the practical expectations of both parties.
Jarza also stated that if intermediaries already have AEO status, they should be well placed to meet many of the requirements of the Standard.
Mark McGuire added that AEO and the standard are different but complementary. HMRC wants alignment where appropriate to support compliance.
Anna Doherty pointed out that holding AEO status does not necessarily always mean good practice, so the Standard will also help raise quality of service.
Will there be a move from current self-certification to independent certification in the future?
For now, intermediaries can review the standard, assess their existing arrangements and self-certify where they are confident that they meet the requirements.
The panel was clear that businesses should not wait for a formal certification scheme before engaging with the standard. The immediate opportunity is to use it as a service improvement tool, a staff development framework and a basis for more informed conversations with clients.
Formal independent third-party certification is expected to follow within the next year, with further detail to be provided as the process develops. The aim is to create a credible and recognised way for intermediaries to demonstrate that they meet the standard while giving traders greater confidence when choosing a provider.
HMRC indicated that fees will apply but will not create an unnecessary barrier for smaller customs intermediaries.
How can importers and exporters use the standard?
Doherty emphasised that the standard is not just for intermediaries. Importers and exporters should read it closely and perhaps look at the annexes to help them better understand their responsibilities as principals.
The standard can help traders understand why an intermediary asks for certain information, and it reinforces that importers and exporters retain legal responsibility for their declarations.
Accurate information is essential because customs declarations affect duties, taxes and compliance. The standard is an opportunity to bring all parties together and improve consistency.
Intermediaries need to be able to tell traders when information or processes are not compliant.
Customs intermediaries and traders need to work together, and both sides need to upskill. The standard should clarify roles across the supply chain and help customers understand their responsibilities.
Challenges and next steps
For Coker, it is important that those operating in the market “embrace the standard positively” and avoid taking a negative approach. Coker feels as a trading community we need to work together to upskill both the intermediary and trade sectors to be able to achieve a high level of customs declaration compliance.
For Doherty, “visibility is the biggest challenge”: making sure not only customs intermediaries know about the standard, but also importers and exporters.
Customs intermediaries need to engage with their customers, and organisations such as the Chartered Institute and BIFA will play a big role in spreading the word and ensuring their members are informed about the standard. Ongoing education will be important.
HMRC is also open to feedback on any parts of the standard that are difficult to meet.
The Q&A focused on several practical concerns, such as agents clearing goods without clear instructions or authorisation, including the use of a trader’s EORI without proper appointment or power of attorney. HMRC confirmed that declarations made without proper appointment or instructions sit outside the voluntary standard and may already raise legal and liability issues.
The wider message was that the standard can help define good practice, but separate regulatory measures may still be needed to deal with poor conduct and bad-faith operators.
Practical key takeaways
The panel agreed that the standard should be treated as a starting point, not a tick-box exercise.
· For intermediaries, the priority is to review current processes against PAS 41201, identify any gaps, strengthen evidence of due diligence and service delivery, and use the standard to support client conversations.
· For traders, the key action is to understand their own customs responsibilities and use the standard as a checklist when selecting or reviewing intermediaries.
The strongest outcome from the discussion was the need for a more balanced relationship: intermediaries must provide competent, transparent and professional services, but traders must also provide accurate instructions and the information needed to support compliant declarations.
Opportunities to engage with HMRC on this topic
HMRC is currently running a consultation on mandatory registration for customs intermediaries, which closes on 21 September 2026. This consultation seeks views on which intermediaries should be in scope, what baseline requirements should apply, how enforcement should work and how registration could be implemented proportionately.
In addition, HMRC has launched a call for evidence on modernising the UK customs regime, which closes on 15 September 2026. This is relevant to traders, intermediaries, software providers, representative bodies and other stakeholders with views on the future of international trade, customs data and customs authorisations.
Anyone with feedback on the standard can contact HMRC directly through the Customs Intermediaries team – customsintermediariesconsultation@hmrc.gov.uk
The Chartered Institute will be hosting a member exclusive webinar to continue the discussion on the Customs Intermediary Standard on Monday 11 August 2026 at 1:00pm. Further details and registration information can be found here.
Member exclusive
