HMRC has opened a 13-week consultation on proposals to introduce mandatory registration for customs intermediaries, outlining minimum eligibility requirements, enforcement measures and the scope of a new regulatory framework aimed at raising standards across the sector.
The UK’s HMRC has launched a consultation on plans to introduce mandatory registration for customs intermediaries that submit customs declarations on behalf of traders, as part of wider efforts to improve compliance, protect revenue and strengthen confidence in the customs system.
Published by HM Revenue & Customs (HMRC) on 23 June 2026, the consultation seeks views on the proposed registration regime, including who should be covered, the minimum requirements intermediaries would need to meet, enforcement measures and how the framework could be implemented proportionately.
The proposals build on previous government engagement with the sector, including the 2022 call for evidence on an independent customs regime and the 2023 consultation on a Voluntary Standard for customs intermediaries. A voluntary industry standard, developed with the British Standards Institution, was published on 3 June 2026.
Why the changes are proposed
According to HMRC, customs intermediaries play a key role in helping businesses meet customs obligations, with 80% of international customs declarations cleared in 2025 submitted through third-party intermediaries. Additionally, 99% of traders relied solely on an intermediary to complete customs declarations.
While most intermediaries provide reliable services, HMRC said previous consultations identified inconsistent service quality across the sector. The government believes the absence of minimum entry requirements allows poor-performing operators to remain in the market, creating risks for traders, customs compliance and government revenue.
The proposed registration regime is intended to complement the existing voluntary standard by establishing mandatory baseline requirements for intermediaries acting on behalf of traders.
Proposed scope
The government proposes that mandatory registration would:
- apply across the UK to intermediaries interacting with HMRC on behalf of traders;
- cover both import and export customs activities; and
- apply across all customs declaration activity rather than being limited to specific declaration types.
The following would be excluded from the proposals:
- advisers providing customs advice without interacting with HMRC on behalf of traders;
- hauliers and carriers acting solely to meet their own legal obligations; and
- businesses making customs declarations on their own behalf through self-representation.
Proposed registration requirements
Under the consultation, customs intermediaries would be required to satisfy several minimum conditions before registering with HMRC. The proposed requirements broadly mirror those introduced for tax advisers in May 2026 and include confirming that applicants:
- have up-to-date tax affairs;
- are not subject to an HMRC decision refusing to deal with them;
- are not disqualified from acting as a company director;
- are not subject to insolvency proceedings;
- have no unspent criminal convictions for relevant offences; and
- have no history of serious customs non-compliance.
HMRC said automated checks would be carried out during registration and periodically afterwards to ensure continued compliance.
If implemented, legislation would require customs intermediaries to register with HMRC before acting on behalf of traders.
Enforcement proposals
The consultation outlines a graduated enforcement model designed to address non-compliance proportionately. Proposed measures include:
- guidance, webinars and communications to support businesses before registration;
- making registration a prerequisite for accessing HMRC customs systems;
- risk-based compliance monitoring;
- warnings and opportunities to remedy non-compliance;
- temporary suspension where issues remain unresolved;
- financial penalties for persistent or serious non-compliance; and
- removal or restriction of an intermediary’s ability to submit customs declarations as a final enforcement measure.
HMRC said the regime would include safeguards such as clear guidance, opportunities to correct issues, and rights of review and appeal.
Consultation seeks stakeholder views
The consultation invites comments on:
- the proposed scope of mandatory registration requirements;
- which customs intermediaries should be included or excluded;
- the proposed mandatory requirements and associated checks;
- the proposed enforcement approach; and
- how the new regime could be introduced proportionately.
HMRC said the consultation is expected to be of particular interest to customs agents, brokers, freight forwarders, express operators, traders, software providers and representative bodies, although responses are welcomed from any individual or business with relevant views.
Next steps
Following the close of the consultation on 21 September 2026, the government will review responses, publish a summary of feedback, refine the policy where appropriate and confirm the next steps for legislation and implementation. If adopted, the proposals would introduce a mandatory registration framework intended to align customs intermediaries with the registration regime already introduced for tax advisers.
