Open call for evidence

Modernising the UK Customs Regime

Published 23 June 2026

Summary

Subject of this call for evidence

This call for evidence seeks views on the future of international trade and the impacts of digitalised and modernised trading practices on the UK customs regime.

Scope of this call for evidence

This call for evidence invites respondents’ views on 3 areas:

1. the future of international trade and its impacts on commercial operations and the UK customs regime
2. the future of customs data and how the UK customs model aligns or could better align with digitalised business operations
3. whether the UK’s approach to customs authorisations supports a modernised trading world, now and into the future

Respondents should focus on these topics rather than more general improvements to HM Revenue and Customs (HMRC) systems and processes. We are happy to discuss the latter as part of our more regular engagement outside of this call for evidence.

We are aware that other government departments are also considering the impacts of digitalised and modernised trading practices. Our call for evidence focusses on the impacts of trade digitalisation and global developments on HMRC customs processes and systems.

Who should read this

The government welcomes engagement from any individual or business with views on the future of international trade and modernisation of the UK customs regime. We are keen to hear from businesses of all sizes and of all levels of experience importing to and exporting from the UK.

This call for evidence is likely to be of particular interest to traders and intermediaries (including freight forwarders, hauliers and customs software providers). Representative bodies (including those who represent businesses that do not currently trade internationally, but may consider doing so in future), trade bodies or customs consultancies that help traders with their customs affairs will also have an interest.

Duration

The call for evidence will run for 12 weeks starting on 23 June 2026 and ending on 15 September 2026.

Lead official

This is a joint call for evidence led by HMRC and HM Treasury. The lead official for HMRC is R Holt. The lead official for HM Treasury is T Smiles.

How to respond or enquire about this call for evidence

We strongly encourage that responses are made via our online form.

If you cannot respond via the online form, you can send your responses to customsmodernisation@hmrc.gov.uk.

Not all questions in this call for evidence will be relevant to everyone and respondents may choose to answer some or all of the questions. HMRC and HM Treasury welcome partial responses, focussed on aspects of the customs regime that are most relevant to the respondent. Some questions are for specific stakeholders and we signpost where this is the case.

Additional ways to be involved

HMRC and HM Treasury are keen to collaborate with a wide range of stakeholders on this call for evidence. We will be holding a webinar on 1 July 2026, where we will present the call for evidence, its aims and how you can respond. You will be able to ask any questions about the call for evidence to support you responding. You can access the link to the webinar here.

After the call for evidence

The government will aim to publish a summary of responses within 12 weeks of the call for evidence closing. Evidence submitted will be considered as part of the customs policymaking process and may lead to further consultation in the future.

Foreword

An effective UK goods border and customs regime is crucial for facilitating international trade. Enabling legitimate businesses to operate seamlessly across borders reduces friction in vital supply chains and helps position the UK as a globally competitive and open trading nation. An effective regime also protects British businesses and citizens and our domestic market, as well as contributing funding toward our vital public services.

Since the UK left the European Union (EU), the UK customs regime has changed significantly to keep the border functioning effectively as we establish independent customs requirements, systems and enforcement approaches. This has included the introduction of the Customs Declaration System (CDS) to enable traders to easily meet their customs requirements at the border, and the delivery of the customs aspects of the Windsor Framework to provide stability for traders operating in and through Northern Ireland. The UK risk-based model of customs compliance and controls supports legitimate international trade whilst identifying illicit and non-compliant activity.

However, the international trade and customs landscape is continuing to evolve. Technological change and digital trade processes offer opportunities to reduce costs, complexity and administrative burdens for businesses trading across the UK border and interacting with the UK customs system. As the UK customs regime continues to mature, the government is committed to continuing to innovate and improve businesses’ experience in line with the needs of a modern trading world.

That is why the government has announced impactful initiatives to test and scale digitally-powered customs processes, including delivering services for HMRC to process Electronic Trade Documents (ETDs) and exploring how artificial intelligence (AI) can support real-time border documentary checks.

But we want to go further. The government has set out an ambitious programme to modernise the state and harness the potential of digital technology. As part of this, we are committed to developing a customs regime that is effective today and fit for the future. This means a regime that is resilient, modern and responsive to evolving technology and trading practices, and that continues to balance the need to facilitate trade and combat illicit and non-compliant activity.

How we deliver our ambition for the customs regime should be informed by those who interact with the system every day. Businesses, intermediaries and others have invaluable insight into how effective customs processes are, where the challenges lie and where there are opportunities to adapt and improve.

Through this call for evidence the government wants to hear about your experience interacting with the UK customs system and your views on how it could evolve. Your insight will help shape the future of the UK customs regime, ensuring it continues to support businesses and meet the needs of a modern, digital economy. Thank you in advance for your input.

Dan Tomlinson MP
Exchequer Secretary to the Treasury

1. Introduction

The UK customs regime has undergone significant change following EU Exit, and the government has already delivered major transformations to establish an independent customs system, safeguard the UK economy and enable businesses and people to continue trading internationally.

We have stood up key customs systems in the form of the Customs Declaration System (which cleared over 91 million customs declarations into and out of the UK in 2025) and the Goods Vehicle Movement Service and updated these digital services to make them easier for customers to use. We have ensured stability for traders in Northern Ireland through delivery of the customs aspects of the Windsor Framework and taken steps to facilitate new requirements, such as decreasing the mandatory information required across safety and security and import and export declarations. We have made regular improvements to reduce burden and improve customer experience through announcements such as the 2025 and 2026 Tax Updates and HMRC’s Transformation Roadmap. The latter set out our plans for a more modernised, efficient and automated customs system which collects the right duty and protects the goods border whilst supporting trade.

Delivering the foundations of an effective and resilient customs regime lays the groundwork for future innovation. We are now turning our attention to further evolving the customs system to reflect the trading landscape. We know that customs and global trade are changing quickly. From systems sharing real-time data throughout supply chains to software that pre-populates customs declarations, new technology is reshaping how businesses trade and interact with customs authorities. At the same time, recent global events have changed how countries think about international trade and how they use their customs systems to support wider policy objectives.

These patterns are part of an international move towards trade digitalisation, which we define as the use of digital technologies and structured trade data to improve or enable trade processes and information flows. This is supported by changes to laws and policies, including the UK’s Electronic Trade Documents Act (ETDA) in 2023 which granted ETDs the same legal status as physical documents.

Alongside the UK’s reforms, a growing number of countries have introduced, or are in the process of introducing, legal changes to enable digital trade processes. These are often aligned to international frameworks, such as the United Nations Commission on International Trade Law (UNCITRAL) Model Law on Electronic Transferable Records.

These legal reforms have been accompanied by an increasing move towards digital practices within certain sectors. For example, major container shipping carriers have committed to achieving 100% adoption of electronic Bills of Lading by 2030, while a 2024 survey of a cross‑section of supply chain participants suggests that around half now use electronic Bills of Lading in some capacity. Together, these developments signal a wider move towards paperless trade, creating the conditions for more efficient, data-driven customs and border processes.

This increased digitalisation can bring significant benefits. When trade information is exchanged using structured, machine-readable data, it can move easily and securely between businesses, and between businesses and government. This makes trade cheaper, faster and simpler. The ETDA is estimated to deliver a net benefit of around £1.14 billion to the British economy over a decade from reduced administrative costs for businesses.

We want to further unlock the benefits of trade digitalisation for traders and government, developing HMRC systems and processes to provide a customs regime that is truly fit for the future. This includes long-term ambitions to explore integration with commercial digital trade systems, improve the interoperability of UK customs processes with those of key international partners, and leverage AI to better automate processes.

The government has already begun adapting the customs system to reflect this increasingly digital landscape. At the Tax Update 2025, we announced 2 customs digitalisation pilots. One tested how digital trade data and documents could be used in HMRC systems. The other, delivered with US Customs and Border Protection, tested how data exchange and digital verifiable credentials could be used to build greater trust. At Tax Update 2026 we set out how we are now moving to design and deliver customs services that support the use of ETDs for customs processes, such as documentary checks. This will ensure UK customs processes are aligned with digitalised trading processes. On top of this and, as announced in the HMRC Transformation Roadmap, HMRC has begun an ambitious programme to improve the Online Trade Tariff service using AI tools.

However, as set out in the 2025 Trade Strategy, there are opportunities to go further. We want to work with businesses and international partners on more innovative changes that build on our progress so far, leveraging opportunities of fully digitalised trade and uncovering further potential uses of AI.

These ambitions will sit alongside and support our ongoing obligations, as well as continued improvements to ensure we have resilient, high-performing systems and processes for the here and now. This includes continuing to fulfil our commitments under the Windsor Framework and international obligations under our Free Trade Agreements and other memberships, such as the Common Transit Convention.

With this in mind, we have published this call for evidence on customs modernisation, which investigates the impact of trade digitalisation on business practices and your experience of the UK customs regime, now and into the future. Your views will support the government to better understand the modernised trading world in which the UK customs regime exists, and to ensure its systems and processes continue to meet the needs of its users. Your views will be used to assess whether our long-term ambitions match those of our stakeholders and to identify any potential gaps for future customs policymaking.

This work is part of a wider government intention to recognise the value of trade digitalisation. We know that other government departments are exploring digitalised trade through their own pieces of work. This includes the Department for Business and Trade’s Smart Data Strategy (which sets out government’s long-term vision for secure, consented, sharing of customer or business data) and Digital Trade Corridors programme (a government-sponsored initiative running live digitalised shipments on real trading lanes between the UK and key trading partners), amongst other initiatives.

We know this call for evidence may prompt comments about the Single Trade Window (STW). The government remains committed to a STW and recently restarted engagement with industry to ensure any ambitions for a UK STW meet customers’ needs today. This call for evidence is a separate piece of work intended to supplement that STW engagement. We focus here on HMRC systems and processes in the context of increasing trade digitalisation and regulatory change. We therefore encourage respondents to consider whether a single portal through which to share data with government would best meet your needs, against other changes considered here. We will ensure that insights on data, processes and user experience gathered during the course of this work are shared with teams working on STW, subject to confidentiality.

Alongside this call for evidence, respondents may also wish to contribute to the Consultation on Introduction of Mandatory Registration for Customs Intermediaries, which seeks views on new mandatory registration requirements to be introduced for customs intermediaries who submit customs declarations on behalf of traders.

This call for evidence is structured across 5 main chapters, including the introduction. Chapter 2 asks questions to understand more about your business or organisation, before chapter 3 explores the future of international trade and its impacts on commercial operations and the customs regime. Chapter 4 interrogates the future of customs data and how the UK customs model aligns or could better align with digitalised business operations. Finally, chapter 5 investigates how the UK’s customs authorisations best fit with the needs of a modernised trading world.

2. About you

The following questions help us understand more about the nature of your business or organisation and how you interact with the UK’s customs regime, to contextualise your responses.

Question 1: What is the name of your business/organisation?

Question 2: What type of business/organisation are you?

• a UK business trading internationally
• a business based outside of the UK that exports to/imports into the UK
• a customs intermediary
• a trade association or representative body
• other (please specify)

Question 3: If you selected ‘customs intermediary’, what type of intermediary are you? (Select all that apply)

• customs agent or broker
• express operator
• freight forwarder
• warehouse operator
• haulier
• other (please specify)

Question 4: What is the size of your business?

• sole trader
• micro (1 to 9 employees)
• small (10 to 49 employees)
• medium (50 to 249 employees)
• large (over 250 employees)

Question 5: How long has your organisation been involved in UK import or export activity? (Select one)

• I am not involved
• less than 1 year
• 1 to 3 years
• 4 to 10 years
• over 10 years

Question 6: What role does your organisation play in this activity? (Select one)

• imports goods
• exports goods
• both imports and exports
• supports others to import and/or export (for example, intermediary)
• other (please specify)

Question 7: Do you use a customs intermediary to support your customs processes? (Select one)

• yes
• no
• not applicable

Question 8: Which types of goods does your organisation trade or support trade of? (Select all that apply)

• food and agriculture
• manufactured goods
• chemicals
• pharmaceuticals
• consumer goods
• mixed goods
• not applicable
• other (please specify)

Question 9: Which regions do you trade with or support trade with? (Select all that apply)

• EU
• Rest of Europe (non-EU)
• North America
• Australia
• Asia
• Africa
• South America
• Global/multiple regions
• not applicable

Question 10: Approximately how many cross-border movements does your organisation make or support each year? (Select one)

• fewer than 100
• 100 to 999
• 1,000 to 9,999
• 10,000 or more
• don’t know

Question 11: What is the approximate annual value of these movements? (Select one)

• less than £1 million
• £1 million to £10 million
• £10 million to £100 million
• over £100 million
• don’t know

Question 12: Do you hold any customs authorisations? (Select all that apply)

• Duty Deferment Account (DDA)
• Temporary Storage
• Temporary Admission
• Customs Warehouse
• Inward Processing
• Outward Processing
• End Use/Authorised Use Relief
• Customs Comprehensive Guarantee (CCG)
• Simplified Import VAT Accounting (SIVA)
• Freeport Customs Special Procedure
• Freeport Customs Site Operator
• Individual Guarantees
• Guarantee Waiver
• BIRDS (Bulk Import Reduced Data Set)
• Entry In Declarants Records (EIDR)
• Simplified Declaration Procedure (SDP)
• Approved Exporter/Registered Exporter
• Authorised Banana Weigher
• Customs Supervised Exports (CSE)
• Designated Export Place (DEP)
• Fixed Transport Installations (FTIs) approvals
• AEO Customs simplifications (AEOC)
• AEO Security and Safety (AEOS)
• AEO C and S Combined (AEOF)
• Authorised Consignee
• Authorised Consignee (TIR)
• Authorised Consignor
• Use of Special Loading Lists
• Use of Seals as a Special Type
• Transit Declaration using Electronic Transport Document
• Seaport/Wharf Approvals
• Airport Approvals
• Rail Terminal Approvals
• UK Internal Market Scheme (UKIMS)
• UKIMS EIDR (Entry in Declarants Records)
• UK Carrier Scheme (UKC)
• I do not hold a customs authorisation or AEO

3. The future of trade

Background

This chapter seeks your views on how global trading practices are evolving and how this impacts the way businesses interact with the UK customs regime. This will help us assess whether business practices and customs solutions are evolving at a similar pace and where further evolutions should be considered to address challenges or make the most of new opportunities.

As noted in the introduction, global trade is becoming increasingly digitalised, underpinned for example by legal changes to put fully digitalised trade processes on the same footing as paper. Alongside benefits from speeding up and simplifying processes, this allows trade and trade compliance capabilities to be enhanced.

Supply chain traceability is one such area. We know that businesses are increasingly expected by their customers, supply chain partners and government authorities to take greater responsibility for their supply chains. Supply chain traceability helps businesses show where their products come from, track goods and raw materials across borders, meet safety standards and complete customs declarations correctly. As a result, many businesses are collecting more data on how goods move and are sharing this information with more parties across the supply chain.

These traceability processes are increasingly being digitalised. From 2027, the EU will begin introducing ‘Digital Product Passports’ (a form of digital product record) for certain product categories using standardised, machine-readable data formats and common technical standards. The United Nations (UN) is also developing a digital framework to support trusted and interoperable data sharing and sustainability information across global supply chains. We want to understand the challenges and opportunities digitalised business practices present for UK customs administration.

Several countries are improving their customs systems, so they integrate more effectively with digital supply chains and better support compliance with customs and goods market regulations. A key example is the EU Customs Union reforms, which set out plans to replace traditional declarations with data flowing directly from digitalised trade systems and to develop more advanced, AI-enabled risking systems.

Meanwhile, US Customs and Border Protection is continuing to modernise its centralised platform for imports and exports, with one focus being improving interoperability and enabling trusted data sharing across supply chains, to increase visibility and support earlier decision making.

While these reforms reflect a common direction of travel towards supporting trade digitalisation, countries are taking different approaches to how they implement this in practice. We want to understand how traders are responding to these developments today, and how they expect their response to evolve in the future. We are also interested in how traders think the UK customs regime compares to other jurisdictions in its approach to trade digitalisation and customs modernisation.

Question 13: In your experience, how well does the UK customs regime support your use of digital trade processes? (Select one)

• supports very well
• supports somewhat
• neither supports nor restricts
• restricts use of digital processes
• don’t know

Please explain your reasoning for your answer.

Question 14: In your experience, what challenges do you face, or would anticipate when using digital trade processes to interact with the UK customs regime? (Select all that apply)

• incompatible systems
• unclear processes
• complex data requirements
• lack of guidance
• no challenges
• other (please specify)

Question 15: How do you expect your organisation’s cross-border trade operations to change over the next 10 years? (Select all that apply)

• increase in trade volumes
• greater use of digital processes
• greater supply chain complexity
• expansion into new markets
• no significant change
• other (please specify)

Please explain your reasoning for your answer.

Question 16: What are the main opportunities that future changes in trade may create for customs processes?

Question 17: What are the main challenges that future changes in trade may create for customs processes?

Question 18: Where does the UK customs regime most need to change to adapt to the needs of digitalised trade?

Question 19: In your experience, how does the UK customs regime’s approach to trade digitalisation compare to those of other countries you trade with? (Select one)

• much more efficient
• somewhat more efficient
• about the same
• somewhat less efficient
• much less efficient
• no experience of other jurisdictions

Please explain your reasoning for your answer.

Question 20: In your experience, are there features of other countries’ customs regimes that work well in terms of digitalised trade and that should be applied in the UK? What are these, if so?

Question 21: Should the UK take its own approach to customs modernisation and digitalisation, or align with approaches used by other countries? (Select one)

• it should take its own approach to customs modernisation and digitalisation, even if it means diverging from approaches used by other countries
• it should only explore approaches to customs modernisation and digitalisation that align with other countries
• it should take its own approach on certain elements and align with other countries on others
• other (please specify).

Please explain your reasoning for your answer.

Question 22: Would there be benefits to businesses if the UK shared customs data with other countries’ customs authorities to reduce burdens on trade and tackle non-compliance? Please describe any benefits or barriers this would present.

4. The future of customs data

Background

The government needs access to accurate and timely information about goods movements. This data is used for risk assessment, enforcing prohibitions and restrictions, protecting revenue and producing trade statistics.

As businesses become increasingly digitalised, we want to understand if HMRC’s current approach to collecting customs data aligns with how information is created, stored and shared across modern supply chains and commercial systems.

The current model mainly relies on information being submitted through customs declarations at a particular point in the movement of the goods. Previous UK border technology pilots have shown that most customs risking data requirements can be met from ETDs and other supply chain data from digital trade systems. Using supply chain data from commercial systems could reduce the cost to businesses of preparing and submitting data for UK border requirements. It could also provide additional data and assurance to help authorities operate a more effective goods border.

Beyond ETDs, we are also interested in data held in other digital systems, such as inventory systems used to manage commercial and logistical processes. We want to understand whether customs models that draw on this data could support a more proportionate and effective approach to sharing customs data.

Any future approach would need to ensure that data is accurate, consistent and usable, and that legal responsibilities are clear. This is essential to support effective decisions on goods movements and to identify and respond to illicit and non-compliant activity.

Customs intermediaries currently complete the vast majority of customs declarations or processes on behalf of traders. This includes customs brokers or agents, freight forwarders, express operators, warehouse operators and hauliers. We are interested in how trade digitalisation is affecting the intermediary sector, how intermediaries’ roles may change, and how the customs system can continue to support a professional, capable and trusted intermediary market where traders choose to use them as digitalisation increases.

Interoperability and standards

To assess the benefits and challenges of using more digital supply chain and commercial data, we also need to understand how data standards, system compatibility, security and accountability would work in practice.

Interoperability is likely to be central to any future model that relies on data shared from supply chains and commercial systems. This would allow data to move more easily between traders, logistics providers, intermediaries and HMRC systems, and to be reused at different stages of the goods movement process. Without interoperability, improved data sharing would not necessarily lead to a more effective or proportionate customs model.

International institutions like the World Customs Organisation, World Trade Organisation, UN and World Wide Web Consortium, alongside trade bodies like the International Chamber of Commerce, Digital Shipping Association and International Federation of Freight Forwarders Associations have developed digital data standards that can be applied to trade. These standards are already being used in ETDs such as Bills of Lading and air waybills, and in digital regulatory documents, such as EU Digital Product Passports. We are interested in stakeholder views on how effective these standards are in improving data sharing.

Purpose of this chapter

We recognise that experiences will differ across the border industry. This will affect the opportunities and challenges that may arise if customs processes move towards greater data sharing or reduced reliance on traditional declarations. The questions in this chapter explore 4 issues: how well current declaration requirements align with business processes, whether greater use of existing digital supply chain data could support a better future model, what barriers or safeguards would need to be addressed, and how different actors in the border ecosystem might be affected.

Question 23: Are there any areas where current customs processes are not well aligned with how your organisation manages or shares trade data with customers or other parties in your supply chain?

• yes, in multiple areas
• yes, in a limited number of areas
• no, processes are broadly aligned
• not sure

Question 24: If yes, what areas are not well aligned? (Select all that apply)

• data format or standards
• timing of data submission
• duplication of information
• system compatibility/interoperability
• other (please specify)

Please explain your reasoning for your answer.

Question 25: Do you think any changes to the UK customs regime or customs declaration data requirements are needed to reflect increasing use of trade data and supply chain systems?

• yes, significant changes are needed
• yes, some changes are needed
• no changes are needed
• not sure

Question 26: If changes are needed, what areas might they relate to? (Select all that apply)

• data requirements for customs processes
• how data from commercial or supply chain systems is accessed and used
• risking and compliance processes
• interactions with customs systems (for example, submission processes)
• other (please specify)

Please explain your reasoning for your answer, including the timeframe over which changes would be needed.

Question 27: Looking ahead, do you expect the way your organisation uses trade data to change in ways that could have implications for customs processes?

• yes, significant changes expected
• yes, some changes expected
• no significant changes expected
• not sure

Question 28: If applicable, what types of changes do you expect? (Select all that apply)

• increased use of ETDs and structured data
• increased data sharing across supply chains
• greater use of automated systems
• no expected changes
• other (please specify)

Please set out the timeframe over which you expect these changes to take place.

Question 29: In your view, how (if at all) should data generated through commercial or supply chain systems be taken into account in customs processes?

• it should not be used
• it should be used in a limited way alongside existing processes
• it should play a more significant role alongside existing processes
• it should play a primary role
• not sure   Please explain your reasoning for your answer.

Question 30: What would be the benefits to your business if customs processes made greater use of supply chain data?

Question 31: What would be the risks to your business if customs processes made greater use of supply chain data?

Question 32: Are there any alternatives to the current declaration based approach that we should consider beyond those that focus on supply chain data?

Question 33: Does your organisation face interoperability issues when sharing supply chain data? (Select one)

• frequently
• sometimes
• rarely
• never

Question 34: Where do these issues most often occur? (Select all that apply)

• between internal systems
• with logistics providers
• with customs intermediaries
• with financial institutions and intermediaries
• with customers
• with government systems
• with non-governmental regulators and licencing authorities
• no issues
• other (please specify)

Question 35: Are you familiar with digital interoperability frameworks (such as UN/CEFACT, Peppol or TradeTrust)? (Select one)

• yes
• no

Question 36: If yes, how effective do you think these frameworks are in improving data sharing? (Select one)

• very effective
• somewhat effective
• not very effective
• not effective at all
• too early to say
• don’t know

Please explain your reasoning for your answer.

Question 37: If you use a customs intermediary, would greater use of supply chain data change how you work with your customs intermediary?

• yes
• no
• not sure
• I don’t use an intermediary/I am an intermediary

Over what timeframe you would expect these changes to take place?

Question 38: What opportunities could this create for your relationship with your intermediary?

Question 39: What challenges could this create for your relationship with your intermediary?

Question 40: If you are an intermediary, community system provider (CSP) or software provider, would greater use of supply chain data change the way your organisation operates? (Select one)

• yes, significantly
• yes, to some extent
• no
• not sure

Please explain your reasoning for your answer, including the timeframe over which you would expect these changes to take place.

Question 41: If you are an intermediary, CSP or software provider, is your organisation already developing ways to support new approaches to sharing customs data?

• yes, actively developing solutions
• exploring options
• not currently
• don’t know

Question 42: What actions from government would most help your organisation to support new approaches to customs data sharing?

5. The future of trust and authorisations

Background

The questions in this chapter explore HMRC’s trusted trader model and seek views on whether the current approach works well for businesses, now and in the future, as trade becomes more digital. For this call for evidence, HMRC uses the term ‘trusted trader model’ to mean the full range of customs authorisations available to businesses, including Authorised Economic Operator (AEO) status.

The customs regime offers businesses a wide selection of authorisations that provide access to specific facilitations and benefits, where eligibility criteria is met and trust can be demonstrated. Businesses can choose which customs authorisations best meet their needs.

We do not mandate that all traders hold specific customs authorisations or AEO status and we do not enforce AEO status as the foundation for access to further simplifications and facilitations, as is the approach elsewhere. We believe that giving businesses choice over what best fits their needs is a strength of our trusted trader model.

The trusted trader relationship is balanced with effective monitoring and controls. This helps ensure continued confidence that authorised traders are meeting their responsibilities and complying with their authorisations. This also helps maintain a fair and consistent trading environment.

In this chapter, we want to understand whether the way trust is managed across the customs regime continues to work well for businesses so that the trust model is attractive and incentivises good customer systems and behaviours. This will reduce burdens for compliant traders while ensuring access to trusted trader processes is granted appropriately. We are keen to hear views on how the trust model could develop in line with and support developments in technology and data explored in other chapters.

When answering these questions, it would also be helpful to hear views on what benefits businesses would expect from trusted trader status, and what features would make a trust model attractive and proportionate.

Question 43: In the UK, we have a flexible and decentralised approach to trust where traders can select and apply for a range of customs authorisations that support their needs. We do not mandate that all traders hold specific customs authorisations. In your experience, how beneficial is the current UK approach to customs authorisations? (Select one)

• very beneficial
• somewhat beneficial
• not very beneficial
• not beneficial at all
• don’t know

Please explain your reasoning for your answer.

Question 44: In your experience, what benefits does the current approach provide? (Select all that apply)

• flexibility to choose relevant authorisations
• lower administrative burden
• easier access to customs processes
• supports business growth
• no clear benefits
• other (please specify)

Question 45: In your view, should alternative approaches to customs authorisations be considered? (Select one)

• yes
• no
• not sure

Question 46: If yes, what alternative approaches should be considered?

Question 47: In your experience, how easy is it to apply for and maintain customs authorisations? (Select one)

• very easy
• somewhat easy
• neither easy nor difficult
• difficult
• very difficult
• not applicable

Please explain your reasoning for your answer.

Question 48: In your experience, what are the main challenges in applying for or maintaining customs authorisations? (Select all that apply)

• application process is complex
• requirements are unclear
• processing times are long
• you have to submit the same information multiple times
• ongoing compliance is burdensome
• no challenges
• other (please specify)

Question 49: What changes would make customs authorisations easier to use and comply with?

Question 50: In your view, should the UK approach to customs authorisations change to reflect developments in technology and trade? (Select one)

• yes
• no
• not sure

Please explain your reasoning for your answer.

Question 51: If yes, what types of changes would you most like to see? (Select all that apply)

• greater use of digital/data-based processes
• faster or simplified authorisation processes
• more tailored authorisations for different business types
• greater alignment with other countries’ trusted trader models
• other (please specify)

Please explain your reasoning for your answer, including the timeframe over which changes would be needed.

Question 52: In your experience, what benefits would encourage you to adopt new or adapted authorisations? (Select all that apply)

• faster processing of goods
• reduced administrative burden
• greater certainty in compliance
• no additional benefits needed
• other (please specify)

Question 53: In your experience, how effectively does the customs intermediary sector support businesses in using customs authorisations? (Select one)

• very effectively
• somewhat effectively
• neither effectively nor ineffectively
• somewhat ineffectively
• very ineffectively
• not applicable

Please explain your reasoning for your answer.

Question 54: What improvements could be made to how intermediaries interact with customs authorisations?

6. Further suggestions

HMRC and HM Treasury are interested in hearing any other ideas from stakeholders about the future of trade and the opportunities or challenges increasing digitalisation and modernisation poses for the UK customs regime.

We regularly engage stakeholders on more general improvements to the UK customs regime, so would encourage responses here which focus on the purpose of this call for evidence.

Question 55: Do you have any other suggestions that haven’t been captured by the above questions?

7. Assessment of impacts

Summary of impacts

Year	2026 to 2027	2027 to 2028	2028 to 2029	2029 to 2030	2030 to 2031	2031 to 2032
Exchequer impact (£m)	Not applicable	Not applicable	Not applicable	Not applicable	Not applicable	Not applicable

Exchequer Impact Assessment

No Exchequer Impact.

Impacts	Comment
Economic impact	This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families	Individuals can respond to the call for evidence; however we anticipate interest to primarily be from businesses. There is no expected impact on individuals, households or families in the immediate term.
Equalities impacts	The publication of this call for evidence does not have any equalities impacts.
Impact on businesses and Civil Society Organisations	Businesses can provide responses to the call for evidence. There is no expected impact on businesses or Civil Society Organisations from publishing the call for evidence.
Impact on HMRC or other public sector delivery organisations	The publication of this call for evidence does not have any impact on HMRC or other public sector delivery organisations.
Other impacts	Not applicable.

8. Summary of questions

Question 1: What is the name of your business/organisation?

Question 2: What type of business/organisation are you?

• a UK business trading internationally
• a business based outside of the UK that exports to/imports into the UK
• a customs intermediary
• a trade association or representative body
• other (please specify)

Question 3: If you selected ‘customs intermediary’, what type of intermediary are you? (Select all that apply)

• customs agent or broker
• express operator
• freight forwarder
• warehouse operator
• haulier
• other (please specify)

Question 4: What is the size of your business?

• sole trader
• micro (1 to 9 employees)
• small (10 to 49 employees)
• medium (50 to 249 employees)
• large (over 250 employees)

Question 5: How long has your organisation been involved in UK import or export activity? (Select one)

• I am not involved
• less than 1 year
• 1 to 3 years
• 4 to 10 years
• over 10 years

Question 6: What role does your organisation play in this activity? (Select one)

• imports goods
• exports goods
• both imports and exports
• supports others to import and/or export (for example, intermediary)
• other (please specify)

Question 7: Do you use a customs intermediary to support your customs processes? (Select one)

• yes
• no
• not applicable

Question 8: Which types of goods does your organisation trade or support trade of? (Select all that apply)

• food and agriculture
• manufactured goods
• chemicals
• pharmaceuticals
• consumer goods
• mixed goods
• not applicable
• other (please specify)

Question 9: Which regions do you trade with or support trade with? (Select all that apply)

• EU
• Rest of Europe (non-EU)
• North America
• Australia
• Asia
• Africa
• South America
• Global/multiple regions
• not applicable

Question 10: Approximately how many cross-border movements does your organisation make or support each year? (Select one)

• fewer than 100
• 100 to 999
• 1,000 to 9,999
• 10,000 or more
• don’t know

Question 11: What is the approximate annual value of these movements? (Select one)

• less than £1 million
• £1 million to £10 million
• £10 million to £100 million
• over £100 million
• don’t know

Question 12: Do you hold any customs authorisations? (Select all that apply)

• Duty Deferment Account (DDA)
• Temporary Storage
• Temporary Admission
• Customs Warehouse
• Inward Processing
• Outward Processing
• End Use/Authorised Use Relief
• Customs Comprehensive Guarantee (CCG)
• Simplified Import VAT Accounting (SIVA)
• Freeport Customs Special Procedure
• Freeport Customs Site Operator
• Individual Guarantees
• Guarantee Waiver
• BIRDS (Bulk Import Reduced Data Set)
• Entry In Declarants Records (EIDR)
• Simplified Declaration Procedure (SDP)
• Approved Exporter/Registered Exporter
• Authorised Banana Weigher
• Customs Supervised Exports (CSE)
• Designated Export Place (DEP)
• Fixed Transport Installations (FTIs) approvals
• AEO Customs simplifications (AEOC)
• AEO Security and Safety (AEOS)
• AEO C and S Combined (AEOF)
• Authorised Consignee
• Authorised Consignee (TIR)
• Authorised Consignor
• Use of Special Loading Lists
• Use of Seals as a Special Type
• Transit Declaration using Electronic Transport Document
• Seaport/Wharf Approvals
• Airport Approvals
• Rail Terminal Approvals
• UK Internal Market Scheme (UKIMS)
• UKIMS EIDR (Entry in Declarants Records)
• UK Carrier Scheme (UKC)
• I do not hold a customs authorisation or AEO

Question 13: In your experience, how well does the UK customs regime support your use of digital trade processes? (Select one)

• supports very well
• supports somewhat
• neither supports nor restricts
• restricts use of digital processes
• don’t know

Please explain your reasoning for your answer.

Question 14: In your experience, what challenges do you face, or would anticipate when using digital trade processes to interact with the UK customs regime? (Select all that apply)

• incompatible systems
• unclear processes
• complex data requirements
• lack of guidance
• no challenges
• other (please specify)

Question 15: How do you expect your organisation’s cross-border trade operations to change over the next 10 years? (Select all that apply)

• increase in trade volumes
• greater use of digital processes
• greater supply chain complexity
• expansion into new markets
• no significant change
• other (please specify)

Please explain your reasoning for your answer.

Question 16: What are the main opportunities that future changes in trade may create for customs processes?

Question 17: What are the main challenges that future changes in trade may create for customs processes?

Question 18: Where does the UK customs regime most need to change to adapt to the needs of digitalised trade?

Question 19: In your experience, how does the UK customs regime’s approach to trade digitalisation compare to those of other countries you trade with? (Select one)

• much more efficient
• somewhat more efficient
• about the same
• somewhat less efficient
• much less efficient
• no experience of other jurisdictions

Please explain your reasoning for your answer.

Question 20: In your experience, are there features of other countries’ customs regimes that work well in terms of digitalised trade and that should be applied in the UK? What are these, if so?

Question 21: Should the UK take its own approach to customs modernisation and digitalisation, or align with approaches used by other countries? (Select one)

• it should take its own approach to customs modernisation and digitalisation, even if it means diverging from approaches used by other countries
• it should only explore approaches to customs modernisation and digitalisation that align with other countries
• it should take its own approach on certain elements and align with other countries on others
• other (please specify).

Please explain your reasoning for your answer.

Question 22: Would there be benefits to businesses if the UK shared customs data with other countries’ customs authorities to reduce burdens on trade and tackle non-compliance? Please describe any benefits or barriers this would present.

Question 23: Are there any areas where current customs processes are not well aligned with how your organisation manages or shares trade data with customers or other parties in your supply chain?

• yes, in multiple areas
• yes, in a limited number of areas
• no, processes are broadly aligned
• not sure

Question 24: If yes, what areas are not well aligned? (Select all that apply)

• data format or standards
• timing of data submission
• duplication of information
• system compatibility/interoperability
• other (please specify)

Please explain your reasoning for your answer.

Question 25: Do you think any changes to the UK customs regime or customs declaration data requirements are needed to reflect increasing use of trade data and supply chain systems?

• yes, significant changes are needed
• yes, some changes are needed
• no changes are needed
• not sure

Question 26: If changes are needed, what areas might they relate to? (Select all that apply)

• data requirements for customs processes
• how data from commercial or supply chain systems is accessed and used
• risking and compliance processes
• interactions with customs systems (for example, submission processes)
• other (please specify)

Please explain your reasoning for your answer, including the timeframe over which changes would be needed.

Question 27: Looking ahead, do you expect the way your organisation uses trade data to change in ways that could have implications for customs processes?

• yes, significant changes expected
• yes, some changes expected
• no significant changes expected
• not sure

Question 28: If applicable, what types of changes do you expect? (Select all that apply)

• increased use of ETDs and structured data
• increased data sharing across supply chains
• greater use of automated systems
• no expected changes
• other (please specify)

Please set out the timeframe over which you expect these changes to take place.

Question 29: In your view, how (if at all) should data generated through commercial or supply chain systems be taken into account in customs processes?

• it should not be used
• it should be used in a limited way alongside existing processes
• it should play a more significant role alongside existing processes
• it should play a primary role
• not sure   Please explain your reasoning for your answer.

Question 30: What would be the benefits to your business if customs processes made greater use of supply chain data?

Question 31: What would be the risks to your business if customs processes made greater use of supply chain data?

Question 32: Are there any alternatives to the current declaration based approach that we should consider beyond those that focus on supply chain data?

Question 33: Does your organisation face interoperability issues when sharing supply chain data? (Select one)

• frequently
• sometimes
• rarely
• never

Question 34: Where do these issues most often occur? (Select all that apply)

• between internal systems
• with logistics providers
• with customs intermediaries
• with financial institutions and intermediaries
• with customers
• with government systems
• with non-governmental regulators and licencing authorities
• no issues
• other (please specify)

Question 35: Are you familiar with digital interoperability frameworks (such as UN/CEFACT, Peppol or TradeTrust)? (Select one)

• yes
• no

Question 36: If yes, how effective do you think these frameworks are in improving data sharing? (Select one)

• very effective
• somewhat effective
• not very effective
• not effective at all
• too early to say
• don’t know

Please explain your reasoning for your answer.

Question 37: If you use a customs intermediary, would greater use of supply chain data change how you work with your customs intermediary?

• yes
• no
• not sure
• I don’t use an intermediary/I am an intermediary

Over what timeframe you would expect these changes to take place?

Question 38: What opportunities could this create for your relationship with your intermediary?

Question 39: What challenges could this create for your relationship with your intermediary?

Question 40: If you are an intermediary, community system provider (CSP) or software provider, would greater use of supply chain data change the way your organisation operates? (Select one)

• yes, significantly
• yes, to some extent
• no
• not sure

Please explain your reasoning for your answer, including the timeframe over which you would expect these changes to take place.

Question 41: If you are an intermediary, CSP or software provider, is your organisation already developing ways to support new approaches to sharing customs data?

• yes, actively developing solutions
• exploring options
• not currently
• don’t know

Question 42: What actions from government would most help your organisation to support new approaches to customs data sharing?

Question 43: In the UK, we have a flexible and decentralised approach to trust where traders can select and apply for a range of customs authorisations that support their needs. We do not mandate that all traders hold specific customs authorisations. In your experience, how beneficial is the current UK approach to customs authorisations? (Select one)

• very beneficial
• somewhat beneficial
• not very beneficial
• not beneficial at all
• don’t know

Please explain your reasoning for your answer.

Question 44: In your experience, what benefits does the current approach provide? (Select all that apply)

• flexibility to choose relevant authorisations
• lower administrative burden
• easier access to customs processes
• supports business growth
• no clear benefits
• other (please specify)

Question 45: In your view, should alternative approaches to customs authorisations be considered? (Select one)

• yes
• no
• not sure

Question 46: If yes, what alternative approaches should be considered?

Question 47: In your experience, how easy is it to apply for and maintain customs authorisations? (Select one)

• very easy
• somewhat easy
• neither easy nor difficult
• difficult
• very difficult
• not applicable

Please explain your reasoning for your answer.

Question 48: In your experience, what are the main challenges in applying for or maintaining customs authorisations? (Select all that apply)

• application process is complex
• requirements are unclear
• processing times are long
• duplication of inputting information
• ongoing compliance is burdensome
• no challenges
• other (please specify)

Question 49: What changes would make customs authorisations easier to use and comply with?

Question 50: In your view, should the UK approach to customs authorisations change to reflect developments in technology and trade? (Select one)

• yes
• no
• not sure

Please explain your reasoning for your answer.

Question 51: If yes, what types of changes would you most like to see? (Select all that apply)

• greater use of digital/data-based processes
• faster or simplified authorisation processes
• more tailored authorisations for different business types
• greater alignment with other countries’ trusted trader models
• other (please specify)

Please explain your reasoning for your answer, including the timeframe over which changes would be needed.

Question 52: In your experience, what benefits would encourage you to adopt new or adapted authorisations? (Select all that apply)

• faster processing of goods
• reduced administrative burden
• greater certainty in compliance
• no additional benefits needed
• other (please specify)

Question 53: In your experience, how effectively does the customs intermediary sector support businesses in using customs authorisations? (Select one)

• very effectively
• somewhat effectively
• neither effectively nor ineffectively
• somewhat ineffectively
• very ineffectively
• not applicable

Please explain your reasoning for your answer.

Question 54: What improvements could be made to how intermediaries interact with customs authorisations?

Question 55: Do you have any other suggestions which haven’t been captured by the above questions?

9. The call for evidence process

Tax Policy Making principles

Tax Policy Making

The following principles underpin the government’s approach to tax policy making:

• predictability and stability: the single major fiscal event cycle will provide a predictable and stable framework for the delivery of tax changes
• a smart and agile approach to consultation: the government will engage stakeholders fully and flexibly when developing tax policy, prioritising dynamic and frequent engagement with tax professionals at both ministerial and official levels — where formal consultation is required, it will be targeted and precise, only seeking information that is genuinely needed, and will last a proportionate amount of time
• transparency: the government is committed to transparency, and will make sure that its rationales for tax policy changes and assessments of policy impacts are clear

These principles will enable the government to deliver change quickly, whilst making sure that the impacts of tax policy changes are fully understood.

How to respond

A summary of the questions in this consultation is included at chapter 8.

Responses should be sent by 15 September 2026, via our online form.

If you cannot respond via the online form, you can send your responses to customsmodernisation@hmrc.gov.uk. Any enquiries should also be sent to this address.

Please do not send responses to the Consultation Coordinator.

Paper copies of this document or copies in Welsh and alternative formats (large print, audio and Braille) may be obtained free of charge from the above address.

When responding please say if you are a business, individual or representative body. In the case of representative bodies please provide information on the number and nature of people you represent.

Confidentiality

HM Revenue and Customs and HM Treasury are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act (DPA) 2018.

Information provided in response to this call for evidence, including personal information, may be published or disclosed in accordance with the access to information regimes. These are primarily the Freedom of Information Act 2000 (FOIA), the DPA 2018, UK GDPR and the Environmental Information Regulations 2004.

If you want the information that you provide to be treated as confidential, please be aware that, under the Freedom of Information Act 2000, there is a statutory Code of Practice with which public authorities must comply and which deals with, amongst other things, obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on HM Revenue and Customs or HM Treasury.

Call for evidence Privacy Notice

This notice sets out how we will use your personal data, and your rights. It is made under Articles 13 and 14 of the UK GDPR.

Your data

The joint data controllers for your personal data are HM Revenue and Customs and HM Treasury. We will process the following personal data:

Name
Email address
Postal address
Phone number
Job title

Purpose

The purposes for which we are processing your personal data is: Call for Evidence on Customs Modernisation.

Legal basis of processing

The legal basis for processing your personal data is that the processing is necessary for the exercise of a function of a government department.

We do not intend to collect special categories of personal data; respondents are advised not to include sensitive information in free text-fields.

Recipients

The personal data will only be made available to those with a legitimate business need to see it as part of the call for evidence process.

This call for evidence is being run jointly by HM Revenue and Customs and HM Treasury.

We will share your personal data with the following types of recipients:

• HM Treasury and HM Revenue and Customs staff and ministers who have a business need to access the data as part of the call for evidence process
• other government departments who have policy functions relevant to the consultation topic. Sharing in this context will ordinarily be anonymised unless information about the respondent is necessary to inform policy

An anonymised version or a summary of your response may be published, or otherwise shared with third parties, during the consultation in subsequent review reports, and where otherwise required by law (for example, in response to a Freedom of Information Act 2000 request). As such, consultation respondents are advised not to include personally identifiable information in any free-text fields. If you elect to complete the digital form, this will be conducted using SmartSurvey, an industry-leading online survey provider with the highest standards of data security. As with other organisations processing personal data, SmartSurvey is subject to data protection compliance requirements.

Although SmartSurvey uses an automated system, the responses you give will not lead to any decisions being made about you and they will not have a direct impact upon you. In this context, SmartSurvey acts solely as a data processor under instruction from HM Treasury and will not use your personal data for any purposes other than to provide the service to HM Treasury. For more information on how SmartSurvey handles respondents’ data, please refer to their privacy policy.

As the personal data is stored on our IT infrastructure, it will be accessible to our IT service providers. They will only process this personal data for our purposes and in line with the contractual obligations they have with us.

Retention

We will retain your personal data until work on the call for evidence is complete and your data is no longer needed.

Responses submitted via the SmartSurvey digital form will be kept by SmartSurvey for as long as we need them. Once the deadline for completion of the survey has passed, all responses will be transferred from SmartSurvey to HM Treasury and HM Revenue and Customs.

Your rights

You have the right to request information about how your personal data are processed, and to request a copy of that personal data.

You have the right to request that any inaccuracies in your personal data are rectified without delay.

You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement.

You have the right to request that your personal data are erased if there is no longer a justification for them to be processed.

You have the right in certain circumstances (for example, where accuracy is contested) to request that the processing of your personal data is restricted.

Complaints

If you consider that your personal data has been misused or mishandled, you may make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113 casework@ico.org.uk

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

Contact details

The data controllers for your personal data are HM Revenue and Customs and HM Treasury.

The contact details for HM Revenue and Customs are:

HMRC
100 Parliament Street
Westminster
London
SW1A 2BQ

The contact details for HM Revenue and Customs’ Data Protection Officer are:

The Data Protection Officer
HMRC
14 Westfield Avenue
Stratford
London
E20 1HZ

advice.dpa@hmrc.gov.uk

The contact details for HM Treasury are:

HM Treasury
1 Horse Guards Road
Westminster
London
SW1A 2HQ

The contact details for HM Treasury’s Data Protection Officer are:

The Data Protection Officer
HM Treasury
1 Horse Guards Road
Westminster
London
SW1A 2HQ

privacy@hmtreasury.gov.uk

Consultation principles

This call for evidence is being run in accordance with the government’s Consultation Principles.

The Consultation Principles are available on the Cabinet Office website.

If you have any comments or complaints about the consultation process, please contact the Consultation Coordinator.

Please do not send responses to the consultation to this link.

Annex: Glossary

Air Waybill	A legal document used in international air shipping that serves as a contract between the shipper and the carrier. Unlike a Bill of Lading, this does not transfer ownership of the goods to the carrier.
Authorised Economic Operator (AEO)	An internationally recognised customs status given to businesses that meet certain compliance and security standards. It allows them to access simplifications and faster processing at the border.
Bill of Lading	A legal shipping document issued by a carrier that serves as a receipt for goods, a contract of carriage, and can act as a document of title during transit.
Community System Provider	A commercial entity that provides IT and messaging services linking traders and intermediaries to HMRC frontier systems (including CDS). They provide network services to specific port and airport communities.
Customs Authorisation	Formal approvals from HMRC that allow businesses to use special customs procedures, simplifications or facilitations.
Customs Declaration	Information submitted to customs authorities about goods being imported or exported, including their value, origin and classification.
Customs Intermediary	Individuals or businesses who act on behalf of traders to complete customs formalities, including submitting declarations and dealing with HMRC. Most traders hire an intermediary to manage customs requirements. These may include specialist customs agents or brokers, as well as other operators (such as freight forwarders or fast parcel operators) where they provide customs representation services.
Electronic Trade Documents (ETDs)	Digital and machine-readable versions of trade documents, such as contracts or shipping documents, which can be shared electronically instead of on paper, and may be legally equivalent to paper where statutory conditions are met.
EU Digital Product Passport	A standardised digital record of product information, developed under EU legislation (the Ecodesign for Sustainable Products Regulation). It contains structured data on a product’s origin, composition, lifecycle and compliance, and supports transparency, traceability and sustainability across supply chains, with requirements being phased in across product categories over time.
Interoperability	The ability of different systems or organisations to exchange data, interpret it consistently, and use it effectively and securely across processes or contexts.
Smart Data	Secure and consent-driven sharing of consumer and business data with authorised third parties, which can be used to provide information, products and services, or reduce burdens to benefit the consumer or business.
Supply Chain Data	Information generated and exchanged across the end-to-end movement of goods, including shipment and logistics data, commercial documents (such as contracts and invoices), financial data (for example, payments and insurance), and regulatory or compliance information.
Trade Digitalisation	The use of digital technologies and structured trade data to improve or enable trade processes and information flows.
Trusted Trader Model	HMRC’s approach to facilitating trade by providing access to benefits and simplified customs processes to businesses that meet certain criteria, compliance and security standards. Access is granted through various customs authorisations, including AEO status.
Verifiable Credentials	Cryptographically secured digital credentials that contain information about a person or product and can be independently verified.