HMRC Customs Intermediary Registration: A Complete Compliance Guide for 2026

Introduction

HMRC has launched an open consultation on introducing mandatory registration for customs intermediaries – including customs brokers, agents, and freight forwarders – who submit customs declarations on behalf of traders. This is a significant shift from the current voluntary system and will affect thousands of businesses involved in UK import and export activities. The consultation, which closes on 21 September 2026, seeks views on scope, requirements, enforcement, and implementation proportionality. This guide explains what the proposed changes mean, who needs to register, the step-by-step process, ongoing compliance obligations, and penalties for non-compliance. It also offers practical tips to help your business prepare.

Who Needs to Register

The proposed mandatory registration applies to any person or business that acts as a customs intermediary – i.e., someone who submits customs declarations on behalf of another trader. This includes:

• Customs brokers – licensed professionals who handle customs clearance for importers/exporters.
• Freight forwarders – companies that arrange the shipment of goods and often handle customs documentation.
• Agents – any individual or entity that represents a trader in customs matters, including online marketplace facilitators.
• Indirect representatives – those who act in their own name but on behalf of another person for customs purposes.

Exemptions may apply for traders who submit their own declarations (direct representation) and for certain low-volume or occasional intermediaries. The consultation specifically asks which categories should be included or excluded. Businesses should monitor HMRC announcements and consider responding to the consultation to shape the final rules.

Step-by-Step Registration Process

While the final process will be determined after the consultation, based on HMRC's proposals, registration will likely involve the following steps:

1. Determine if you need to register – Review your business activities: if you submit customs declarations on behalf of others, you are likely in scope. Check for any exemptions that may apply.
2. Gather required information – Prepare details such as your business name, address, VAT number, Economic Operator Registration and Identification (EORI) number, details of directors/partners, and evidence of professional competence (e.g., customs training certificates).
3. Submit an online application – HMRC is expected to create a digital portal (likely integrated with the Customs Declaration Service – CDS) for registration. You will need to provide the information gathered in step 2 and declare that you meet the fit and proper person criteria.
4. Undergo background checks – HMRC will conduct checks on the applicant and key personnel, including criminal record checks, financial probity, and compliance history. This may involve providing additional documentation.
5. Receive registration and unique identifier – Upon approval, you will receive a customs intermediary registration number (CIRN) or similar identifier. This must be used on all declarations you submit on behalf of traders.
6. Maintain registration – Registration will need to be renewed periodically (e.g., every 3 years) and updated if your business details change.

Ongoing Compliance Obligations

Once registered, intermediaries must comply with several ongoing obligations. These are expected to include:

• Record-keeping – Maintain records of all customs declarations, client instructions, and supporting documents for at least 4 years (as per current customs rules). Records must be available for HMRC inspection.
• Reporting – Submit accurate and timely customs declarations via the Customs Declaration Service (CDS). The legacy CHIEF system is being phased out; all declarations must be made through CDS.
• Due diligence on clients – Verify the identity and customs status of each trader you represent. Keep records of client due diligence.
• Professional competence – Ensure staff involved in customs declarations are adequately trained and up to date with changes in customs regulations.
• Notification of changes – Inform HMRC of any changes to business details (e.g., address, directors, insolvency events) within a specified timeframe.
• Compliance with customs legislation – Adhere to all relevant customs laws, including correct classification, valuation, and origin of goods.

Penalties for Non-Compliance

HMRC proposes a tiered penalty regime for non-compliance. Potential penalties include:

• Failure to register – Operating as an unregistered intermediary could result in fines, suspension of customs privileges, or criminal prosecution.
• Inaccurate declarations – Penalties for incorrect or false declarations can be up to 100% of the duty evaded, plus interest. HMRC may also impose civil penalties under the Customs (Criminal Offences etc.) Act 2025.
• Record-keeping failures – Fines of up to £3,000 for failing to maintain adequate records.
• Non-compliance with due diligence – Penalties for failing to verify client identities or for representing non-compliant traders.
• Persistent or serious breaches – HMRC may revoke registration, preventing the intermediary from operating legally. Directors could face personal liability.

HMRC has indicated a proportionate approach, with higher penalties for deliberate or repeated violations. The consultation seeks views on penalty levels and mitigation factors.

How AIGovHub Can Help

Preparing for mandatory customs intermediary registration involves significant compliance effort. AIGovHub's CCM Module (Continuous Compliance Monitoring) can help you automate and streamline customs compliance controls. The CCM Module connects to your ERP systems (SAP S/4HANA, Microsoft Dynamics 365, Oracle Cloud Fusion, and others) to monitor customs declaration processes, track record-keeping obligations, and detect anomalies in real time. With AI-native rule engines and automated evidence collection, you can ensure your customs compliance is audit-ready. The CCM Module also supports remediation workflows and escalation management, helping you respond promptly to any compliance gaps. By integrating customs compliance monitoring into your broader compliance framework, you reduce the risk of penalties and demonstrate robust governance to HMRC.

Conclusion

HMRC's proposed mandatory registration for customs intermediaries marks a major step toward enhanced oversight and compliance in UK customs. Businesses that act as intermediaries should start preparing now: review their operations, gather necessary documentation, and ensure their staff are trained. The consultation closing on 21 September 2026 offers an opportunity to influence the final rules. By taking proactive steps and leveraging compliance technology like AIGovHub's CCM Module, you can navigate these changes smoothly and stay ahead of regulatory requirements.

This content is for informational purposes only and does not constitute legal advice.