UK Customs Intermediary Registration Proposal 2026

HMRC is consulting on a proposal to introduce mandatory registration for customs intermediaries that submit customs declarations on behalf of traders. The consultation is aimed at customs agents, brokers, freight forwarders, express operators and the traders that rely on them.

This is not a current registration law. The consultation ran from 22 June 2026 to 21 September 2026 and is now shown on GOV.UK as closed. HMRC says it will consider responses, publish a summary of feedback and then confirm next steps on legislation and implementation. No final commencement date, application form, fee or completed compliance test has been published.

What Is HMRC Consulting On?

The proposal would create a common mandatory registration process for customs intermediaries that interact with HMRC on behalf of traders. HMRC says the aim is to raise minimum standards, protect revenue and give traders greater confidence in the businesses handling their declarations.

The consultation is a policy-development document. It does not itself create a legal obligation to register, and a business cannot yet rely on it as a complete operational rulebook.

Who May Be in Scope?

HMRC proposes that mandatory registration would apply UK-wide to intermediaries that interact with HMRC and submit customs declarations on behalf of traders. The proposed scope covers both imports and exports and is not limited to one declaration type.

Potentially affected businesses include:

• customs agents and brokers;
• freight forwarders;
• express operators;
• other businesses submitting declarations for traders; and
• software or service providers where their role includes acting with HMRC on the trader's behalf.

The exact legal scope is not final. A company that offers customs advice only, without interacting with HMRC on behalf of a trader, is proposed to be outside scope. Hauliers and carriers acting to fulfil their own legal obligations, rather than making or amending declarations for traders, are also proposed to be excluded.

Proposed Registration Checks

If the government proceeds, HMRC proposes common minimum requirements at registration, with automated checks at registration and periodic checks afterwards. The consultation suggests requirements could include that the intermediary:

These are consultation proposals, not a final checklist. HMRC says it wants to align the system with information businesses already maintain and avoid duplicative or unnecessarily burdensome checks.

Proposed Enforcement Model

HMRC is considering a graduated, risk-based enforcement model. The consultation describes a possible sequence of:

1. preparation support, guidance and webinars;
2. registration as a prerequisite for interacting with HMRC systems;
3. risk-based monitoring;
4. early engagement, warnings and opportunities to remedy problems;
5. temporary suspension where issues are not resolved;
6. financial penalties for persistent or serious non-compliance; and
7. restriction or removal of the ability to submit declarations as a last resort.

The proposal also refers to safeguards such as clear guidance, remediation opportunities and rights of review and appeal. The final enforcement powers, thresholds, appeal route and penalties would need legislation or final guidance before they can be treated as operational requirements.

What Should Traders Do Now?

Traders do not currently need to apply for the proposed registration merely because they use a customs intermediary. They should, however, understand who submits their declarations, who holds the evidence and how errors are corrected.

Intermediaries can use the consultation to review tax compliance, director status, insolvency records, criminal-conviction policies, customs error controls and the quality of declaration evidence. These are sensible preparation steps, not proof that the proposed registration has been enacted.

The consultation welcomed responses from traders, intermediaries, software providers and representative bodies. The response deadline was Monday 21 September 2026 and has now passed. The next authoritative milestone is HMRC's response summary and any subsequent legislation or implementation guidance; the consultation email address should not be treated as an open application or registration route.

Existing customs responsibilities continue

The proposal does not remove the customs responsibilities that already apply to a trader or its intermediary. An EORI number remains an identifier for customs activity, not evidence that a business has passed a future suitability test. A power of attorney or intermediary contract authorises an agent to act, but it does not automatically transfer every customs debt, classification error or record-keeping duty away from the importer or exporter.

Before onboarding an intermediary, a trader should identify whether the agent is acting directly or indirectly, who is named on the customs declaration, who provides the commodity code and origin evidence, who instructs the customs value, and who receives HMRC queries. The contract should say how corrections, post-clearance amendments, duty repayments, audits and record retention are handled. A future registration scheme may add intermediary-specific checks, but it will not make an inaccurate invoice or an unsupported origin claim correct.

HMRC's consultation also refers to a Standard for Customs Intermediaries developed with industry and the British Standards Institution, published on 3 June 2026. The Standard is a voluntary best-practice framework and should not be presented as the proposed mandatory registration. A broker may use it to demonstrate processes or quality, but a voluntary certification or membership does not create a statutory registration number.

What to monitor after the consultation

Businesses should monitor four separate documents rather than relying on headlines:

1. HMRC's summary of consultation responses;
2. any primary or secondary legislation creating the registration duty;
3. the final scope, exclusions, transitional period and commencement date; and
4. operational guidance explaining the application, automated checks, fees, appeals and interaction with HMRC customs systems.

A final law could differ from the consultation in the categories of intermediary covered, the treatment of software providers or the evidence required for suitability. Until those documents exist, do not add a mandatory-registration fee to a customer invoice, refuse a trader solely because it has no proposed registration number, or promise that an existing EORI and customs-declaration account will be migrated automatically.

If implementation is announced, create a dated gap analysis: current intermediary role, proposed in-scope activity, existing EORI and customs-service access, compliance records, director and insolvency checks, criminal-conviction policy, customs error history, staff training and the transitional deadline. Keep the consultation version that informed the analysis so the business can explain which assumptions changed when final guidance appears.

For traders, the practical control is supplier due diligence rather than premature registration. Obtain the intermediary's legal name, EORI, authorisation arrangements, service scope, escalation contact and record-retention policy. Confirm whether the intermediary acts for the trader on every shipment or only selected declarations, and review a sample of entries against the commercial invoice. That evidence will remain useful whether the proposal is enacted, amended or withdrawn.

Label every internal document with its status: current customs duty, consultation proposal, or future implementation assumption. This prevents a draft checklist from being mistaken for a legal requirement and makes customer communications easier to correct when HMRC publishes the response. Set a review owner and date, and link the next review to the official consultation collection rather than an undated industry summary.

How This Relates to Other UK Customs Changes

Do not tell a client that an EORI number, VAT number or voluntary industry standard is already the proposed mandatory registration. The final scheme may connect with existing data, but the consultation does not establish the final legal relationship.

Frequently Asked Questions

This page explains a closed HMRC consultation and should be refreshed when the response summary, legislation or implementation guidance is published. Related reading: low-value imports UK 2029, UK VAT registration 2026/27 and CBAM UK 2027.

Official sources

• HMRC: Customs intermediaries — introduction of Mandatory Registration
• HMRC: Introduction of mandatory registration for customs intermediaries
• HMRC: Tax Update 2026