# Customs intermediary registration consultation — response working draft Edition: 17 July 2026 Consultation deadline shown by HMRC: Monday 21 September 2026 Official consultation: Use this editable file to prepare an evidence-backed response. Keep the official consultation open while drafting because its wording, deadline, submission address, and process are the source of truth. ## Before drafting - Name the response owner and final reviewer. - Decide whether the response represents a business, individual, or representative body. - Map the legal entities, brands, branches, and subcontracted models involved. - Separate declaration submission and amendment from advice-only, carrier, warehousing, and self-representation activity. - Gather movement volumes, systems, permissions, current controls, implementation estimates, and concrete examples. - Answer only the questions your organisation is equipped to answer. HMRC says partial responses are welcome. ## Organisation snapshot **Responding organisation:** **Response owner:** **Final reviewer:** **Business / individual / representative body:** **Operating model in one paragraph:** **Legal entities and locations covered:** **Customs intermediary roles covered:** **Imports, exports, or both:** **Annual movement range:** **Current customs systems and HMRC services:** --- ## Question 1 — Organisation name **Working answer:** **Evidence or note:** ## Question 2 — Type of business or organisation Describe the business in operational terms: for example customs broker, freight forwarder, express operator, warehouse operator, haulier, trader, software provider, professional body, or a combination. **Working answer:** **Evidence or note:** ## Question 3 — Annual movements and direction Record an evidenced range where a precise count is not practical. Separate imports and exports if that distinction affects the response. **Working answer:** **Evidence or note:** ## Question 4 — Intermediary type and activities Map all applicable intermediary roles. Explain mixed operating models and distinguish activity undertaken for traders from a business meeting its own obligations. **Working answer:** **Evidence or note:** ## Question 5 — Business size Use the employee-size bands in the official consultation. **Working answer:** **Evidence or note:** ## Question 6 — Time operating in trade or customs support State the relevant operating history and explain material changes in model or ownership where helpful. **Working answer:** **Evidence or note:** ## Question 7 — Benefits and challenges of mandatory registration For each material benefit or challenge, add a real workflow, the affected parties, an estimate of impact, and any evidence available. **Working answer:** **Operating example:** **Quantified impact:** **Practical alternative or improvement:** ## Question 8 — Proposed scope Test the proposal against every entity and activity in the organisation map. Identify ambiguous boundaries, exclusions that work as intended, and edge cases that could create inconsistent treatment. **Working answer:** **Operating example:** **Quantified impact:** **Practical alternative or improvement:** ## Question 9 — Minimum requirements and proportionality Compare the proposed requirements with evidence or checks the organisation already maintains. Explain where alignment could avoid duplicate work and where a requirement should be added, removed, or amended. **Working answer:** **Existing control or evidence:** **Implementation impact:** **Practical alternative or improvement:** ## Question 10 — Graduated enforcement approach Test the proposed approach through realistic scenarios: early engagement, remediation, temporary suspension, escalation, restriction, review, and appeal. **Working answer:** **Operating example:** **Trade or customer impact:** **Practical alternative or safeguard:** ## Question 11 — Transitional period Build the estimate from actual implementation work: entity mapping, evidence collection, systems changes, training, registration, review, remediation, and dependencies on HMRC guidance or service readiness. **Recommended period:** **Implementation work and elapsed time:** **Dependencies:** ## Question 12 — Unintended consequences or impacts on trade Consider capacity, cost, competition, access to representation, service interruptions, border flow, small-business effects, subcontracting, consolidation, and changes in risk behaviour. Include only impacts your evidence supports. **Working answer:** **Evidence or operating example:** **Scale or likelihood:** **Mitigation:** ## Question 13 — Other design considerations Set out practical implementation support, safeguards, data reuse, guidance, testing, communications, review routes, or measures that would help high-quality intermediaries prepare. **Working answer:** **Evidence or operating example:** **Recommended action:** --- ## Final review - [ ] The response identifies who it represents. - [ ] Material statements distinguish current facts from forecasts about a future scheme. - [ ] Important views include an operating example or evidence. - [ ] Impacts use ranges or assumptions where exact figures are unavailable. - [ ] Proposed alternatives are specific enough to assess. - [ ] The reviewer removed unsupported claims and answers outside the organisation’s expertise. - [ ] Confidentiality requests are deliberate and explained rather than relying on an automatic email footer. - [ ] The current official deadline and submission instructions have been checked immediately before sending. - [ ] A final copy and the evidence used are saved in the organisation’s normal record. ## Primary sources 1. HM Revenue & Customs, “Customs intermediaries: introduction of Mandatory Registration”, published 23 June 2026: 2. HM Revenue & Customs, “Standard for Customs Intermediaries”: Prepared as a free operational working file by Declarix Limited. This file organises a response; it is not HMRC guidance and does not predict the final policy.