2026: A Year for Stronger Customs Governance

Customs is undergoing rapid change. With HMRC reinforcing importer accountability and new access to free TRE data, the start of 2026 is the ideal time for businesses to step back, review their entire customs landscape and strengthen governance. This article explains why the new year offers a unique planning window, and how importers can use it to reduce risk, improve efficiency and uncover hidden savings.

As 2025 comes to a close, it’s worth reflecting on how significantly the customs landscape has shifted. The rulings we’ve commented on this year, from classification disputes to HMRC’s increasingly assertive stance on importer accountability, all point in one direction:

The cost of poor customs decisions is rising, and businesses can no longer afford to treat customs as an operational afterthought.

What’s been most notable, however, is how business behaviour has evolved. For several years, customs activity was dominated by tactical, savings-led initiatives such as duty deferment optimisation, preference use, and reclaim projects. Useful, certainly, but reactive.

This year, something different has emerged. More organisations are prioritising governance-led programmes, driven by two clear pressures:

HMRC’s increasingly explicit message that liability sits squarely with the importer.
High-profile cases where misclassification and weak controls have resulted in multi-million-pound adjustments.

Compliance is no longer “good housekeeping”. It is becoming a strategic necessity.

Planning For 2026: Three Practical Steps to Take Now

To make the most of this planning window, every importer should consider the following:

1. Use the New TRE Data Request Process

For the first time, HMRC’s Trader Request for Entry (TRE) data is free, fast, and accessible. This removes a historic barrier, meaning leaders no longer need to make strategic decisions with incomplete information. The full customs dataset is now available at no cost and it should be the starting point for any governance or planning discussion.

See TRE Makes Customs Data Free: The Next Step in Customs Data Transparency – CAT360 Insights

HMRC (Her Majesty Treasury) sign in London, UK

2. Begin With a Holistic View

Before diving into classification reviews, agent oversight checks, preference checks or audit preparation, step back and assess the entire customs landscape.

The most significant risks and most valuable opportunities typically sit at the intersections between processes, suppliers, systems, and data. A whole-picture review consistently outperforms isolated fixes.

3. Use Analytics to Accelerate Discovery

Historically, analysing a year of import data could take weeks. Today, our analytics platform CAT360 can identify patterns, inconsistencies, reclaim opportunities, and risk areas in seconds.

To support businesses planning their 2026 strategy, we are offering large businesses an initial data review free of charge, enabling leaders to gain instant clarity before allocating resources.

Find out more about our free trial of CAT360 here.

a laptop with a screen showing the dashboard for cat360 customs analytics software

Why This Matters For 2026

All of this leads to a simple conclusion: 2026 will reward businesses that take control of their customs landscape and penalise those that don’t.

HMRC’s expectations are rising.
Audit activity is increasing.
Classification decisions now carry real financial and reputational consequences.
For the first time, businesses have immediate access to the data needed to understand their true customs position.

If the insight is available, why wait? By using TRE data and taking a holistic review now, businesses can:

Identify liabilities before HMRC does.
Validate the work of customs agents.
Strengthen governance without adding operational burden.
Improve efficiency through cleaner, more reliable data.
Surface reclaim opportunities that directly improve margins

And because analytics can now deliver weeks of insight in seconds, the barrier to starting has all but disappeared. A new year presents a practical opportunity to reset, reduce risk, and establish a customs strategy that is compliant, resilient, and cost-effective.

Those who invest time in January to understand their landscape will enter 2026 with clarity and confidence.
Those who delay will spend the year reacting.