You might think your role as a customs agent ends once the declaration is submitted. But a recent tribunal ruling proves otherwise, and the consequences could leave you footing the VAT bill.
If you’re acting as a customs agent and using Postponed VAT Accounting (PVA) on behalf of your clients, stop and ask yourself two questions:
Is the importer definitely VAT registered?
Do you have written authorisation to use PVA?
If the answer to either is “I assume so” or “probably”, you’re walking into a compliance minefield, HMRC just proved they’re willing to blow it up!
This Case Changes Everything
In a recent tribunal case, Roseline Logistics Ltd v HMRC [2025] UKFTT 427 (TC), a customs broker was held jointly liable for unpaid import VAT.
Their mistake was using PVA for an importer who wasn’t VAT registered and did not have written authorisation to do so. The broker thought they were simply facilitating the declaration, but the tribunal disagreed. They were treated as having “purported to act” as a direct representative, which resulted in consequences.
What This Means for Customs Agents
Many agents, especially those who’ve scaled up fast or handle high volumes, rely on systems and SOPs that assume things are in order. But assumptions don’t hold up in court.
- You need written permission from the importer to use PVA. Verbal isn’t good enough.
- You must confirm VAT registration, not just trust the client’s word or EORI.
- If you get this wrong, you could be held personally liable for the VAT due.

Protecting Yourself: Actions to Take Immediately
- Get your authorisations in writing. If you’re using PVA, have a signed statement from the importer every time.
- Verify VAT registration. Use HMRC tools or request evidence before using PVA.
- Review your declaration instructions. Make sure they cover who’s responsible for what, especially regarding PVA.
- Educate your team. Your junior declarants might not know this level of risk exists.
The Bigger Picture for Customs Agents
This case isn’t a one-off. It’s a sign that HMRC is looking closely at how PVA is used and who’s responsible when things go wrong. Agents aren’t just postboxes anymore. You’re part of the compliance chain, and now, very clearly, part of the liability chain. As expectations tighten, relying on assumptions or informal processes is no longer enough. Strengthening your authorisation and verification procedures isn’t just good practice, it’s essential protection.
If you’re acting as a customs agent, take this as your prompt to tighten controls. Revisit your use of PVA, confirm VAT registrations, and ensure written authorisations are in place. The cost of getting it wrong is no longer theoretical … it’s enforceable.
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