Five years on from Brexit, UK businesses face a customs environment that continues to evolve. While many organisations have successfully adapted to the new normal of customs declarations, tariff classifications, and border controls, 2026 brings fresh developments that demand attention. For importers and exporters navigating this landscape, staying compliant isn’t just about avoiding penalties—it’s about protecting margins, maintaining supply chain efficiency, and building resilience in an uncertain trading environment.

The Current State of UK Customs

The transition from single market member to independent trading nation fundamentally changed how UK businesses move goods. What was once domestic trade with EU partners now requires full customs procedures, bringing documentation requirements, duty calculations, and regulatory compliance into sharp focus.

The numbers tell the story: customs declarations have surged to approximately 250 million annually, a dramatic shift that has tested both businesses and infrastructure. While many companies have adapted well, HMRC’s increasing focus on post-clearance audits suggests that not all declarations have been as accurate as they should be. The taxman is particularly interested in reviewing declarations made since 1 January 2021, especially where EU origin preference has been claimed under the Trade and Cooperation Agreement.

What’s Changed in 2026: Key Developments

The End of MSS/CDS Reports and the Rise of TRE

Perhaps the most significant development for 2026 is HMRC’s transition to the Trade Reporting and Extracting (TRE) service. From 31 March 2026, all existing Management Support System (MSS) and Customs Declaration Service (CDS) report contracts expire, making TRE the only way to access your official customs declaration data.

This isn’t just a technical change—it’s a fundamental shift in how businesses can monitor their customs footprint. Under the old system, accessing your data meant completing applications, nominating responsible parties, and paying annual fees that could reach £960 plus VAT for full access to all four CDS reports. TRE eliminates these barriers entirely. It’s free to use, accessible through your existing Government Gateway account, and provides on-demand access to both import and export data.

Here’s what makes TRE significant: you can now retrieve comprehensive reports covering CHIEF and CDS systems whenever you need them, typically within 48 hours of requesting. No more waiting for monthly scheduled reports or paying subscription fees. For businesses managing significant import volumes, this represents not just cost savings but also enhanced agility in monitoring compliance.

However, access to data is only half the battle. The real challenge lies in what you do with that data once you have it. TRE provides raw declaration information, but turning that into actionable compliance insights requires analysis, context, and expertise. Identifying miscoded commodities, spotting overpaid duties, or benchmarking broker performance across thousands of declaration lines demands more than spreadsheet skills.

Continued Focus on Rules of Origin

The Trade and Cooperation Agreement with the EU established zero-tariff, zero-quota trade for goods that meet the rules of origin. While this sounds straightforward, the reality is considerably more complex. The origin rules are product-specific and compliance can be onerous, requiring detailed documentation and a thorough understanding of how goods qualify.

Research shows that utilisation of preferential rates varies significantly by sector. In textiles and clothing, for instance, only between 10% and 53% of UK exports to the EU claimed zero tariffs in 2022. This suggests that many businesses either cannot comply with the origin requirements or find the administrative burden too heavy relative to the duty savings.

HMRC auditors are scrutinising origin claims closely. To qualify for preference, goods must be of EU origin and meet specific requirements set out in the TCA. For goods valued over €6,000, you need a statement on origin supported by a REX (Registered Exporter) number. Getting this wrong can result in backdated duty payments, interest charges, and penalties that far exceed any initial savings.

Low-Value Import Duty Changes on the Horizon

While not immediate, businesses should be aware that the UK Government has confirmed the removal of customs duty relief for low-value imports (goods valued under £135) by March 2029 at the latest. A consultation process closing on 6 March 2026 will shape the implementation details, but the direction of travel is clear. This will particularly affect e-commerce operations and businesses with high volumes of small-value consignments.

Border Target Operating Model Refinements

The Border Target Operating Model (BTOM) continues to evolve, bringing a risk-based approach to imports of live animals, products of animal origin, plants, and plant products. Agrifood goods now face identity and physical checks based on the biosecurity risk they pose, with different requirements for low-, medium-, and high-risk categories.

Understanding where your products sit in this risk matrix is essential, as is ensuring you have the correct supporting documentation. DEFRA has published guidance on common errors to help businesses avoid delays caused by incomplete or incorrect paperwork.

The Enduring Importance of AEO Status

Authorised Economic Operator status has become increasingly relevant in the post-Brexit environment. While AEO isn’t mandatory, it demonstrates to HMRC and trading partners worldwide that your customs controls are robust, your supply chain is secure, and your commitment to compliance is genuine.

There are two main types of AEO certification in the UK:

AEOC (Customs Simplifications) focuses on customs compliance, record-keeping standards, financial solvency, and competence in customs operations. While some benefits have diminished since Brexit due to simplified access to certain authorisations, AEOC remains valuable for maintaining customs compliance and supporting internal audit processes.

AEOS (Security and Safety) emphasises supply chain security measures, storage facility integrity, and access controls. This certification is mutually recognised by many countries including the EU and USA, potentially reducing the likelihood of customs inspections and delays at foreign ports.

Many businesses hold both certifications (sometimes referred to as AEOF—full AEO status), gaining the widest range of benefits. The application process involves a detailed examination of your customs procedures, finances, HR processes, and security measures, with HMRC typically visiting your premises as part of the assessment.

For businesses facing customs audits or managing complex supply chains, AEO status can demonstrate good faith and a structured approach to compliance. It’s increasingly seen as a baseline expectation rather than a nice-to-have credential.

Building a Compliance Framework That Works

With the regulatory environment continuing to develop, businesses need a structured approach to customs compliance. Here’s a practical framework to consider:

1. Know Your Declarations

You cannot manage what you cannot measure. With TRE now providing free access to your complete customs declaration history, there’s no excuse for not regularly reviewing what’s being declared on your behalf. This is especially critical if you use multiple customs brokers or agents.

Key questions to ask include: Are commodity codes consistent across similar products? Are origin claims properly supported? Is the declared value aligned with your commercial invoices? Are you claiming all applicable reliefs and preferences?

2. Verify Commodity Classifications

Commodity codes determine the duty rate you pay, what reliefs you can claim, and what additional requirements might apply. Misclassification is one of the most common customs errors and can result from both innocent mistakes and inadequate verification processes.

The UK Trade Tariff tool is your starting point, but for complex products or where significant duty is at stake, professional classification advice is often worthwhile. Remember that classifications can change as products evolve or tariff structures are updated.

3. Document Your Origin Determinations

If you’re claiming preferential origin under any free trade agreement, documentation is essential. This includes understanding how your products meet the origin rules, maintaining evidence of the calculation, and ensuring your statements on origin are correctly formatted and supported where required.

For goods you export, providing proper origin documentation to your customers enables them to claim preferential treatment in the destination market. Failing to do so can make your products less competitive versus suppliers who provide this documentation.

4. Monitor Your Brokers and Agents

If you use customs intermediaries, remember that under direct representation (the most common arrangement for UK importers), you remain liable for the accuracy of declarations and any customs debt. Your broker is your agent, but the responsibility is yours.

Regular performance reviews should be standard practice. Are declarations accurate? Are they submitted on time? Are errors corrected promptly? How does one broker’s performance compare to others you might use? Having visibility across your entire customs operation is essential for effective oversight.

5. Prepare for Audits

HMRC’s post-clearance audit activity has increased significantly. When the auditors arrive, they’ll want to see that you have robust systems, clear procedures, and adequate records. They’ll also expect you to have conducted your own compliance reviews rather than waiting for HMRC to identify issues.

Maintaining audit-ready records means having clear links between commercial documents, customs declarations, and financial systems. It means being able to demonstrate how origin determinations were made, why particular duty reliefs were claimed, and what checks were in place to ensure accuracy.

The Role of Technology in Modern Customs Compliance

The volume and complexity of modern customs operations make manual management increasingly impractical. Businesses handling significant import or export volumes need tools that can process large datasets, identify anomalies, and provide meaningful insights.

This is where modern customs management software becomes invaluable. Rather than manually reviewing thousands of declaration lines in spreadsheets, analytical platforms can automatically flag potential issues such as duplicate duty payments, missed preference claims, inconsistent commodity codes, or declarant errors.

The best solutions don’t just present data—they enrich it with context, apply compliance rules, and highlight both risks and opportunities. They enable you to benchmark broker performance, track duty under management across multiple entities, and maintain the kind of comprehensive oversight that HMRC expects to see during audits.

With TRE making data access free and straightforward, the question is no longer whether you can access your customs data, but whether you can analyse it effectively enough to drive real compliance improvements and cost savings.

Practical Steps for 2026

As we move through 2026, here are concrete actions UK businesses should consider:

Transition to TRE now. Don’t wait until your MSS/CDS contract expires. Familiarise yourself with the new system, understand how to request and interpret reports, and ensure key personnel have the necessary Government Gateway access.

Review your declarations comprehensively. Use your historical data to identify patterns, inconsistencies, or potential issues before HMRC does. This is particularly important if you’ve been trading under the TCA and claiming origin preference.

Assess your documentation. Ensure you can support every origin claim, duty relief, and special procedure you’ve used. If gaps exist, address them proactively rather than waiting for an audit to expose them.

Invest in capability. Whether that’s training your team, engaging customs consultants, or implementing analytical technology, ensuring you have the right capabilities is essential for sustainable compliance.

Consider AEO status. If you haven’t already, evaluate whether AEO certification makes sense for your business. The application process itself often reveals process improvements and compliance gaps that are valuable to address.

Engage with the low-value consultation. If your business imports significant volumes of low-value goods, participate in the consultation process before it closes on 6 March 2026. Understanding and preparing for these changes early will ease the eventual transition.

Looking Ahead

Post-Brexit customs compliance isn’t getting simpler—if anything, requirements continue to develop and become more sophisticated. However, businesses that embrace this reality and build robust compliance frameworks are finding that good customs management delivers real competitive advantages beyond just avoiding penalties.

Reduced duty costs through accurate claims and optimal procedures, faster clearances through cleaner declarations, better supplier relationships through proper documentation, and enhanced resilience through comprehensive supply chain visibility all contribute to business performance.

The customs landscape of 2026 demands more from UK businesses than ever before, but it also provides better tools and access to data than we’ve previously had. Success lies in combining that access with the right expertise, technology, and commitment to getting it right.

For businesses serious about customs compliance, the message is clear: reactive management is no longer sufficient. The winners will be those who take a proactive, data-driven approach to understanding their customs footprint, identifying risks before they become problems, and continuously improving their processes. In an environment where margins are tight and supply chain efficiency is critical, effective customs management isn’t optional—it’s essential.

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This article is intended for informational purposes and does not constitute legal or professional customs advice. Businesses should consult with qualified customs professionals regarding their specific circumstances.