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CUSTOMS MODERNISATION & CUSTOMS INTERMEDIARIES MANDATORY REGISTRATION CONSULTATION - YOUR FEEDBACK


The Chartered Institute of Export & International Trade (CIOE&IT) is the leading professional body representing traders, customs professionals, intermediaries, and organisations involved in international trade. Through our policy, advisory, training, and industry engagement activities, we work closely with government and industry stakeholders to support a more effective, resilient, and competitive trading environment.

We are currently gathering industry views to inform CIOE&IT's responses to two important UK government consultations:

Modernising the UK Customs Regime – a call for evidence exploring how the UK customs system should evolve to support digital trade, modern supply chains, improved customs data, and future customs authorisations.
Introduction of Mandatory Registration for Customs Intermediaries – an HMRC consultation seeking views on proposals to introduce mandatory registration requirements for customs intermediaries, including customs agents, brokers, freight forwarders, and other organisations that submit customs declarations on behalf of traders.

Your feedback will help us understand the practical opportunities, challenges, and potential impacts of these proposals across industry. The insights gathered will be analysed in aggregate and used to support the development of evidence-based consultation responses submitted by CIOE&IT on behalf of the trade community.

The survey should take less than 20 minutes to complete. Individual responses will be treated confidentially and reported only in a summarised and anonymised format.

This survey will close on 6th of September (Sunday).

For more information on how we collect, use, and protect personal data, please refer to our Privacy Policy: CIOE&IT policies

Thank you for contributing your expertise and helping shape the future of UK customs and international trade.
Section 1: Business Profile
1.Which of the following best describes your organisation? Select all that apply to you.(Required.)
2.What is the size of your business?
3.Are you already a member of the Chartered Institute of Export & International Trade?
4.Which best describes your digital customs process maturity?
Section 2: Mandatory Registration for Customs Intermediaries
5.What is your overall view of introducing mandatory registration for customs intermediaries?
Strongly support
Support
Neutral
Oppose
Strongly oppose
6.As mandatory requirements for registration, HMRC suggests mirroring the "fit and proper" criteria used for tax advisers, which would include checks ensuring that:

- that their tax affairs are up to date
- they are not subject to a decision by HMRC to refuse to deal with them
- they are not disqualified to act as a director of a company
- they do not have an insolvency practitioner acting in relation to them
- they do not have an unspent criminal conviction for relevant offences
- they do not have a history of serious customs non-compliance

Do you agree with the suggested scope of mandatory requirements?
Please choose the correct answer and provide feedback in the additional box.
7.If mandatory registration is implemented, in your opinion, what is the maximum acceptable processing time for HMRC to approve a new intermediary registration without disrupting commercial operations?
8.Do you agree with the proposed enforcement approach under the graduated model, which would include:

- working with industry to help businesses prepare for registration, including guidance, webinars and appropriate communications
- registration as a prerequisite for interacting with HMRC systems
- a risk-based approach to monitoring compliance
- early engagement, including warnings and opportunities to remedy non‑compliance
- temporary suspension where issues are not resolved
- staged escalation to financial penalties in cases of persistent or serious non‑compliance
- as a last resort, remove or restrict an intermediary’s ability to submit declarations
9.What transition period should be provided?
10.What do you see as the greatest impact of mandatory registration? Please choose all that apply and select ‘Other’ for additional comments.
Section 3: Customs Modernisation
11.Overall, how well does the UK customs regime support your organisation’s use of digital trade processes?
12.Compared with customs regimes in other countries you trade with, how efficient is the UK’s approach to trade digitalisation?
13.Where should the UK customs regime prioritise change to support digitalised trade? Select all that apply.
14.Which future customs model would deliver the greatest overall benefit to businesses?
15.What benefits would be most beneficial for your commercial and supply chain processes? Select all that apply.
16.What risks or concerns do you foresee with greater use of commercial and supply-chain data for your industry? Select all that apply.
17.Which approach should the UK take to customs modernisation and international data sharing?
18.What changes would most improve customs authorisations? (Select up to 3)(Required.)
19.If you are a customs intermediary or use customs intermediaries, how would greater use of supply-chain data affect your working relationships? Select all that apply.
20.What actions from government would most help your organisation adopt new digital customs approaches? Select up to five that apply.(Required.)
21.Where do interoperability problems most commonly occur for your business? Select all that apply.
22.When should the highest-priority changes identified above be implemented?
23.Do you want to share any other feedback that has not been covered so far? Please elaborate in the box below.
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