Guidance

PAS 41201:2026 Customs intermediaries: Preparation and submission of customs declarations — Specification

Published 4 June 2026

Background

Customs intermediaries play a critical role in the UK border and trade system. They support traders to move goods efficiently and meet their customs obligations. A competitive, effective and high-quality customs intermediary sector is essential to the government’s border ambitions.

Following a call for evidence in 2022 and a public consultation in 2023, HMRC committed to developing a Customs Intermediaries Standard. The aim is to improve quality and consistency of services provided by the customs intermediary sector and to help traders make more informed choices when selecting an intermediary.

HMRC sponsored the development of the Standard in partnership with the British Standards Institution (BSI) and sector representatives to ensure it has been developed ‘by industry, for industry’. This is the first time best practice for customs intermediaries has been formally set out.

What the Standard covers

The Customs Intermediaries Standard sets out clear robust good practice. It promotes consistency across the sector, including in areas such as:

• transparency of service offerings
• continued professional development
• due diligence

The Standard is intended to raise service quality across the sector. High-quality intermediaries help reduce errors, delays and avoidable costs, providing greater certainty for traders and supporting the overall flow of goods across the border. It is not a legislative requirement and cannot replicate or list all legislative requirements.

Launch of the Standard

HMRC supports the launch of the Customs Intermediaries Standard on 2nd June 2026.

The Standard is published as a Publicly Available Specification (PAS) under PAS 41201 on the BSI website.

The Standard uses specific terminology in line with BSI editorial conventions. The guidance document assists how to interpret this language and structure.

What the launch means for intermediaries

The Standard is publicly available and can be reviewed by customs intermediaries or anyone who has an interest. Intermediaries can assess whether their existing processes meet the requirements and make changes where appropriate.

PAS 41201 aims to raise quality and consistency across the sector without introducing mandatory regulation. Aligning with the Standard will help intermediaries provide confidence to customers about the service they offer.

What the Standard means for customers

The Standard helps traders make more informed choices when selecting a customs intermediary.

It sets expectations for intermediaries, including transparency of offerings and customer service standards.

The Standard also requires intermediaries to ask questions and verify the accuracy of information and documentation provided by customers. Correct due diligence by intermediaries is essential. It helps customers comply with HMRC requirements and can protect against incorrect duties payments and subsequent HMRC compliance activity.

Importers and exporters are encouraged to review the Standard so they understand what they can expect from a customs intermediary.

Certification

During the 2023 public consultation, HMRC responded to feedback and committed to developing a Standard that would be suitable for accredited certification.

The publication of the Standard is the first step. A separate certification scheme will be developed to sit alongside it. This Certification scheme will set out how compliance with the Standard can be evidenced, including what checks are required to demonstrate that an intermediary meets the requirements.

HMRC is working with external bodies to develop the certification scheme. Certification will be delivered by certification bodies independent of HMRC and accredited by the United Kingdom Accreditation Service (UKAS).

Once available, certification will be voluntary. Any intermediary may apply to be assessed against the Standard by an accredited certification body. Successful applicants will receive certification endorsed by the UKAS. This will help ensure certification is applied consistently and fairly across the sector.

Before certification is introduced

While the certification scheme is being developed, intermediaries can review and work towards meeting the Standard. Intermediaries that meet the requirements may state that they are compliant with the Standard.

Requirements of the Standard must be provable, therefore customers choosing an intermediary may ask for evidence of how an intermediary meets specific requirements that are important to them.

What is the difference between the Customs Intermediaries Standard and AEO?

Authorised Economic Operator (AEO) is an internationally recognised authorisation focused on supply chain security. To gain AEO status, an intermediary must demonstrate that its customs controls meet specific criteria, including areas such as:

• financial standing and solvency
• record keeping
• procedures for controlled goods

The Customs Intermediaries Standard differs from AEO because it is designed to be customer-facing. It aims to be visible to customers and support informed decision-making when choosing an intermediary.

The Standard does not replace AEO or any other existing authorisations. Instead, it differs by focusing on areas such as customer experience, transparency, best practice and the ongoing development of staff. The Standard has been developed for industry, by industry.

If you have any questions regarding the Customs Intermediaries Standard please contact customsintermediariesstrategyteam@hmrc.gov.uk.

Annex 1: Understanding the sections of the BSI PAS

What is a PAS?

A PAS is a document published by the BSI. It is developed through consensus with trade representatives and sets agreed best practice or requirements for a specific area — in this case Customs Intermediaries who prepare and submit declarations.

This PAS applies to the UK and is at organisational level, not individual.

Normative and informative references

Normative content

Normative content is mandatory. It sets out the rules, requirements, and obligations that must be followed by the organisations to claim compliance with the PAS. It uses mandatory language such as:

• ‘shall’ — something is required
• ‘shall not’ — something is prohibited

If an intermediary does not meet all normative requirements, they cannot claim to be compliant with the PAS.

Informative content

Informative content is optional or is provided to help users understand or interpret the PAS and provides further information which may be useful. It also provides areas which go beyond normative content, containing information which organisations are recommended to use for best practice.

Notes, examples and commentary

These appear throughout the PAS to help explain the requirements. They provide clarification, practical illustrations and further detail on requirements, but they are not mandatory.

Annexes

Annexes provide further details, clarifications or recommendations that go beyond the normative requirements of the PAS. As such, annexes are informative but recommended as best practice.

Annex 2: Understanding the sections of the document which make the Standard

Foreword and publishing information

This section provides information about the document, including the title, PAS number, year of publication, along with who was involved in its development.

Introduction

The introduction explains the aims of the document and who it is for. Like the foreword, this section is background information only.

1. Scope

The scope explains who the PAS is intended for, areas it covers and who it is aimed at.

2. Normative references

This section lists other standards or documents that must be used alongside the PAS. In this case, there are no such documents or standards.

3. Terms and definitions

This section defines key words and phrases used in the PAS. These definitions explain exactly what certain terms mean in the context of the document and helps to ensure everyone understands the requirements in the same way.

4 to 9.2. Main clauses (requirements)

This is the most important part of the PAS. The main clauses set out the requirements that organisations must meet. These statements use the word ‘shall’ and are normative, although the notes or commentary are informative and designed to assist or point to other information the reader may find useful. All normative requirements in this section must be met to claim compliance with the PAS.

4. Good practice

4.1. General

Requires intermediaries to promote transparency and positive relationships with their customers (principal), facilitating a smoother relationship.

4.2. Auditing

Auditing requires intermediaries to conduct annual audits of systems and processes and quarterly quality control audits on submitted declarations at a minimum sample size of 5% up to a maximum of 25000. These assists intermediaries to identify and rectify any mistakes made.

As a principal this offers a layer of protection to ensure declarations have been submitted correctly, but also that complaints are handled appropriately. Intermediaries also use auditing to rectify any systemic issues and amend practices to improve business behaviors.

4.3. Principal appointment and instruction

This section requires intermediaries to obtain and maintain appointment instructions if they are empowered to act on behalf of the principal. It sets length of time this appointment is expected to last or is limited to a specific number of declarations.

Intermediaries are also expected to act on the instructions of the principal, except if they have reason to believe there is fraudulent behavior taking place.

Where instruction has taken place but there has been an error which requires an amendment; this requires clear communication with the principal on charges (if it is the fault of the principal) or no charges (if it is the fault of the intermediary).

Appointment records must be retained for 6 years from the last declaration, not from the start of the relationship.

4.4. Communication

This section requires intermediaries to clearly communicate with a customer regarding the hours of service, how an intermediary can be contacted and relevant contact details. It also requires intermediaries to provide evidence of declaration submission along with its status.

5. Due Diligence

5.1. Principals

This section requires an intermediary to conduct checks on establishment and business activities. This fulfills legal obligations on establishment and helps protect against hijacking attempts. These records will also be kept by the intermediary and subject to internal audits.

5.2. Contact by a representative of the principal

If an intermediary is contacted by unknown people purporting to represent the principal they have established dealings with, this requires the intermediary to verify this person is representing that principal. This helps protect against hijacking attempts or principals details.

5.3. Documents accompanying the customs declaration

This section requires an intermediary to conduct checks and verify information in documents accompanying a customs declaration.

As a principal, due diligence is essential and offers a layer of protection to ensure your declaration is submitted correctly. HMRC may pursue principals for incorrect payment of duties, so principals should work with an intermediary to answer questions and provide evidence to their intermediary, as this behavior is in the principals best interests.

6. Crisis response

6.1 and 6.2

This section requires an intermediary to have in place crisis response measures and resilience planning to maintain operations relevant to their business in the event of planned or unplanned outages.

7. Training for employees submitting customs declarations

All sub sections in section 7 are required for employees submitting customs declarations or conducting related due diligence.

7.1. Induction training

This section requires an intermediary to have in place training for new employees in the first 3 months of employment, including requirements in section 4 (Good practice), section 5 (Due diligence) and how to detect and identify suspicious behaviors (Annex A may assist with this).

7.2. Continuing Professional Development

This section requires an intermediary to have in place Continuing Professional Development (CPD) structures for employees who submit declarations and conduct due diligence. As each employee’s role is different, it is left for the intermediary to decide how best to provide relevant opportunities for CPD. There are no prescribed minimum number of CPD hours. CPD examples, roles and systems which may be relevant can be found within the Annexes.

7.3. Annual performance reviews and training

Employees are required to have annual reviews of how they have updated their knowledge and evidence CPD requirements. Intermediaries should also provide annual training on how to identify and report suspicious activities as per induction training.

7.4. Relevance

Changes in customs, landscape, rules and regulations are required to be included within training. Intermediaries should also use output from internal audits and principal feedback to shape training within their organisations.

7.5. HMRC help and support

This section requires an intermediary to provide staff with a directory of assistance for help and support. These may include those listed in the notes but may also include other guidance related to your business activities.

7.6. Customs knowledge

The requirement to provide training and case studies for employees to gain knowledge of the World Customs Organization (WCO) Harmonized Commodity Description and Coding System.

8. Systems, process and data

8.1. Standard Operating Procedures (SOPs)

Requires an intermediary holds and reviews clearly written SOPs specific to the intermediaries business activities ensure all staff have guidance on procedures relating to declaration completion and how data is collected and managed.

8.2. Recording of personal experience qualifications and training

Intermediaries are required to keep records of staff qualifications, experience and training. This allows both employees and intermediaries to establish gaps in knowledge and learning opportunities if required.

8.3. Documentation accompanying a customs declaration

This section requires an intermediary to establish procedures on how to compile and retain documents relating to customs declarations.

8.4. Recording of complaints

Sets requirements for intermediaries to have systems for recording complaints and resolutions. There is a retention period of 6 years, so these are available if required in the future.

8.5. Knowledge of customs declarations requirements and data elements

All sections under 8.5 set requirements on the intermediary to have in place documents, procedures and practices in place to inform employees of these customs requirements. In places, they also require the employees to check relevant evidence (such as non-manipulation evidence), check details (such as classification) or have an understanding of risks and how to escalate any concerns (such as sanctions). These checks are beneficial to the principal as they help ensure correct declaration submission.

8.6. Import VAT

Requirement for written agreement between principal and intermediary on how the principal wishes to treat import VAT such as postponed vat accounting.

8.7. Principal data

Procedures to record and update principal information. This may be contact details, submitted declarations, or any other relevant information.

9. Transparency

9.1. Service offering

These sections require an intermediary to be transparent in their product offerings and services specific to customs declarations. They enable the principal to have a clear understanding of what they can expect from an intermediary during the declaration submission process but also after the relationship has ended in the event of a customs audit. If you are using AI to assist with declaration completion, this should be disclosed to the principal.

Whilst also setting the requirements for a documented complaints resolution process, this is for the intermediary to decide this process relevant to their business size and activities.

9.2. Fees and pricing

Fees and pricing should be clearly available for a principal to view. This section also requires clear communication between intermediary and principal on any intended changes.

Annex A: Due diligence in practice

This section is informative and provides recommended due diligence checks that can be conducted on data, principal behavior, or documentation relating to a movement.

• A.1: table contains data elements within a customs declaration along with an explanation and recommended due diligence requirements for that data element
• A.2: provides due diligence requirements that should be applied for and documentation submitted by the principal
• A.3: shows indicators or principal behavior which should prompt further due diligence.

Annex B

This section is informative and whilst dependent on the size of the organisation or role of the employee, provides recommendations of CPD opportunities which could be used for section 7 (normative) on Training for employees 7.2 Continual Professional Development.

Annex C

This section is informative and details other customs systems and processes which are often used in intermediaries’ business activities. Training against these systems or procedures is also recommended for employees CPD requirements.

Bibliography

The bibliography lists documents and sources that were useful in developing the PAS. These are for information only and are not required to meet the requirements of the Standard.