Build the response before the deadline.

What is HMRC proposing—and what can you do now?

HMRC opened a 13-week consultation on proposed mandatory registration for customs intermediaries that interact with HMRC on behalf of traders. It was published on 23 June 2026 and closes on 21 September 2026. The consultation asks about scope, exclusions, minimum requirements, checks, enforcement, and proportionate implementation. HMRC says respondents may answer only the questions relevant to them.

The practical job now is to turn operational experience into evidence: which entities and activities are affected, what the proposed checks would change, where a rule could duplicate an existing control, and what a proportionate alternative could look like. The free files below give that work a structure before drafting begins.

Which operating models are in the consultation?

Map the firm once. Reuse the evidence across the response.

• List every legal entity, brand, branch, and subcontracted operating model involved in intermediary work.
• Separate declaration submission, amendment, advice-only, carrier, warehousing, and self-representation activities.
• Record the HMRC services, EORIs, badges, authorisations, systems, and permissions used by each role.
• Name who owns professional standards, staff competence, supervision, complaints, errors, and corrective action.
• Estimate implementation work for evidence collection, registration, periodic checks, changes, and appeals.
• Identify where a proportionate rule needs distinctions by size, service, risk, or operating model.

Give every material view an operating example.

For each consultation point, record the proposal, the affected workflow, a concrete example, the likely benefit or burden, supporting evidence, and a practical alternative. Separate facts about the current operation from forecasts about a future scheme. If a requirement would duplicate an existing control, name the control and explain how HMRC could rely on or align with it.

HMRC invites partial responses. A focused response on the parts your firm understands well can be more useful than an answer that guesses across every question. Responses and enquiries go to the address published in the consultation; check the official page before sending because the source controls the process.

Registration and the industry Standard are related, not identical.

HMRC published the Standard for Customs Intermediaries in June 2026. It describes expectations for professional conduct, capability, and service delivery. The mandatory-registration consultation proposes a legal registration framework and minimum requirements. Firms should track both workstreams without presenting voluntary good-practice material as if it were already a statutory registration test.

This page changes when the source changes.

Declarix will review this resource when HMRC updates the consultation, closes responses, publishes a response summary, or announces legislation and implementation. After 21 September 2026, the page must not continue to describe the consultation as open. It will be updated into an outcome tracker or redirected to a current resource after the official next step is known.