Your customs broker has a new standard to meet. The liability is still yours. 

On 2 June 2026, the customs intermediary sector got its first standard. If you import into the UK and someone else files your declarations, you may not have heard about it, because it was written for them, not for you. 

The standard is PAS 41201:2026, sponsored by HMRC and published by BSI. It sets out, for the first time, what good practice looks like for customs agents, freight forwarders, express operators and anyone else who submits declarations on a trader’s behalf. Compliance is voluntary. There is no law behind it, and for now no certificate to earn. But HMRC’s name is on it, and that tends to turn ‘voluntary’ into ‘expected’ faster than most people plan for. 

Here is the part that makes it your concern and not just your broker’s. When a declaration goes in under your EORI, the responsibility for it is yours. If the commodity code is wrong, the duty underpaid or the valuation off, HMRC comes to you for the money and the penalty, not to the agent who keyed it in. A standard that raises the bar for how your broker works is, in the end, a standard about how exposed you are. 

What the standard asks for 

PAS 41201 runs to nine clauses. Most of it is the kind of housekeeping a serious intermediary should already have in place, but four points are worth a senior reader’s attention. 

The first is auditing. Clause 4.2 requires an intermediary to audit a sample of the declarations it submits every quarter, select a random 5% (capped at 25,000), examine specific data elements, document what it finds, report it to management, and notify any client who has been negatively affected within one month. In plain terms, your broker is now expected to check its own work on a schedule and put the results in writing. 

There is a trap in all of this. A broker’s audit checks that they filed what you instructed, accurately. It does not check whether your instruction was right. Getting classification and valuation correct depends on detailed knowledge of your products, your suppliers and your contracts, knowledge the broker does not hold and you do. So the errors most likely to cost you are the ones a broker’s audit is least able to catch. Their quarterly check is welcome, but it is their work being checked, not yours. The responsibility for what is declared stays with you, and so does the bill if it is wrong. 

The second is error correction. The standard expects an intermediary to fix its own mistakes within 90 days, at no charge to you. That is a clean, concrete thing to hold a broker to. 

The third is due diligence. Clause 5 expects documented, standardised checks on the businesses an intermediary acts for, and on the documents that arrive with a shipment, so that inconsistencies get caught before a declaration is filed rather than after. 

The fourth is transparency. Clause 9 expects intermediaries to disclose when they subcontract work, to disclose their use of AI, and to publish rate cards. For any importer who has never seen behind the curtain of how their declarations are produced, that is a useful shift. 

Underneath all of it sit six-year record retention, version-controlled procedures, and trained staff who understand the consequences of the wrong commodity code, which reach well beyond duty into VAT, excise, licensing and health controls. 

The badge is coming, but it is not here yet 

It is worth being precise about status, because the language gets used loosely. PAS 41201 is a standard, not an accreditation. Right now, a broker cannot be certified or ‘accredited’ against it, because the scheme to do that does not exist yet. HMRC has confirmed that a certification scheme is being developed so intermediaries can prove they meet the standard, with UKAS providing the accreditation layer above it. 

So the question to ask your broker today is not ‘show me your certificate’. No one has one. The question is whether they are adopting the standard now and preparing for certification when it arrives. A broker who is already moving is telling you something about how they run. A broker who shrugs at an HMRC-backed standard written for their own trade is telling you something too. 

Why this matters to you 

If you are a Senior Accounting Officer, the declarations filed in your name are part of the tax accounting arrangements you sign off. ‘Reasonable steps’ is the test, and the bar for what counts as reasonable rises the moment a recognised standard exists. ‘We left it to the broker’ reads very differently after 2 June 2026 than it did before. 

If you sit in finance, the exposure is cash. A wrong code can mean duty overpaid, money you will struggle to recover beyond HMRC’s three-year window. Or it can mean duty underpaid, in which case the C18 demand and the penalty land on your balance sheet, not the agent’s. Quarterly auditing exists to catch both before they compound across a year of entries. 

And if customs sits in your remit, the awkward question is one of evidence. If HMRC asked you tomorrow to show how the declarations filed under your EORI are checked, and by whom, could you answer with a document rather than a hope? 

A fair question, fairly asked 

None of this is a reason to assume the worst of your broker. There are honest reasons a smaller intermediary moves slowly on a new standard: cost, resource, a full plate. The point is not to catch anyone out. It is to give you a reason to ask, and a way to read the answer. 

What to do now 

Ask your broker, in writing, whether they are adopting PAS 41201:2026 and where they have got to. 

  • Ask how, and how often, they audit the declarations they file for you, and whether you can see the results.
  • Ask what happens, and who pays, when an error is theirs.
  • Ask them to disclose any subcontracting and any use of AI in preparing your declarations.
  • Look inward as well: could you evidence today, on paper, that someone checks the declarations filed in your name? 

 Now is a sensible time to ask, while the standard is new and the answers tell you something, rather than after HMRC has asked the question first. 

If you work with more than one broker, you can also compare them against each other. CAT360 reviews every declaration filed under your EORI and surfaces the anomalies, so you can see which of your agents’ files clean and which does not, before it becomes a demand. 

Talk to us about a review of how your customs declarations are filed, checked and evidenced.