
Anna Doherty is the Customs Practice director at the Chartered Institute of Export & International Trade.
Customs intermediaries play a key and underappreciated role in international supply chains.
The services they provide to traders of all sizes often serve as a link between customs authorities and traders and help keep goods moving across borders.
A good intermediary must keep up to date with changing customs legislation, understand the various systems operating at the border and how they interact with each other, while providing customs clearance services to their clients.
Why is it needed?
The important role of the customs intermediary sector was further highlighted post-Brexit: a substantial number of traders faced customs formalities for the first time.
This exposed the difference in the quality of services provided by intermediaries. Some have excellent standards, knowledge and experience while others lacked expertise and understanding of the changing customs landscape.
Complaints were made about the varying quality of these firms, with concerns arising about a few bad actors that hurt the image of the rest of the industry.
Now, the government is seeking to change this by exploring what a standard for the sector could look like.
Background
With this in mind, in February 2022, the government published a ‘Call for Evidence: An Independent Customs Regime’, which included a chapter seeking industry views on the customs intermediary sector.
A summary of responses was published in July, with industry by-and-large calling for a voluntary standard rather than a government-backed regulator.
At Spring Budget 2023, then-chancellor Jeremy Hunt set out a package of measures to simplify import and export processes, including a consultation on introducing a standard for customs intermediaries with the aim of improving the quality of the service for the overall sector.
The responses to the consultation were published in December 2023 and the work on the standard began in 2024 when HMRC appointed British Standards Institution (BSI) to develop a Publicly Accessible Specification (PAS).
The standard
To ensure that the PAS meets the requirements of the industry, HMRC and BSI formed a Steering Group. The Chartered Institute, as well as other leading trade associations, and representatives from trade, were part of this group and helped shape this PAS.
The PAS has now been published for public consultation, to ensure that everyone with an interest in it can review it and comment on it.
While it is designed for customs intermediaries, it also must meet the needs of exporters and importers and guarantee these traders receive a high-quality service.
The PAS covers six areas:
- due diligence
- continued professional development
- systems, processes and data
- complaints resolution
- standard operating procedures
- transparency
Public consultation is open until 3 October 2025 and can be viewed here. Anyone with an interest in the standard can comment and provide feedback.
What is it and what it is not?
As the standard is still in its draft stages, any industry feedback is crucial in helping the standard develop into a set of guidelines that are fit for purpose.
However, it should be noted the standard does not replace any existing legal obligations that a customs intermediary must comply with, and any definitions included in the standard are only for the purposes of the standard itself.
It is also not meant to replace any existing authorisations, such as Authorised Economic Operator (AEO) status. Instead, it aims to go beyond AEO, focusing on areas such as customer experience, transparency and continuous professional development of staff.
SIGs
To help members understand how to engage with the standard and explain its purpose, the Chartered Institute invited representatives from HMRC’s Customs Intermediaries policy team to our Customs Special Interest Group (SIG) on 18 September 2025.
Commenting ahead of the SIG, a HMRC spokesperson said:
"We're working collaboratively with industry and the BSI to develop a standard that will encourage quality improvements and help traders distinguish between service providers."