The proposed EU customs reform and its impact on AEO accreditation is one of the most pressing questions for authorised economic operators right now. The European Commission’s reform of the Union Customs Code – planned for phased implementation between 2028 and 2037 – introduces a new trader status called ‘Trust and Check’.
For companies that currently hold AEO authorization, the question is straightforward: will your accreditation survive the transition, and what do you need to do now? What is the EU customs reform proposing?
The reform replaces the current AEO framework with a broader ‘Trust and Check’ (T&C) status. Trusted traders will be granted far-reaching simplifications: the ability to release goods into free circulation without a customs declaration at the border, self-assessment of customs duties, and direct access to a centralised EU Customs Data Hub. In exchange, T&C traders take on significantly more responsibility: real-time data sharing with customs authorities, continuous compliance monitoring, and full transparency of supply chain data – including information about suppliers, manufacturers, and beneficial ownership structures. What happens to your current AEO status?
The Commission has indicated that existing AEO authorisations will form the basis for the new T&C status – but they will not transfer automatically. Companies will need to demonstrate compliance with the new, more demanding criteria.
Key differences include: Data requirements are significantly broader under T&C. Where AEO focuses on internal controls and compliance history, T&C requires structural data integration with the EU Customs Data Hub. SME access is a concern. The current AEO framework is accessible to smaller companies; the T&C data infrastructure requirements risk excluding businesses without dedicated IT resources.
Customs representatives face an uncertain position: if their clients hold T&C status and self-assess duties, the traditional role of the customs agent changes fundamentally.
What should AEO holders do now? The 2028 start date may seem distant, but preparation takes time. Companies that want to transition smoothly should start now with a gap analysis between their current AEO framework and the expected T&C criteria. If you are already working on your AEO re-assessment, our post on preparing for an AEO re-assessment without disrupting operations covers the practical steps in detail.
Review your current AEO self-assessment (SAQ) against the proposed T&C criteria. Assess your IT infrastructure: can your systems connect to a centralised data hub? Map your supply chain transparency: do you have full visibility of your suppliers and manufacturers? Monitor the legislative process – the final regulation is expected in late 2026 or early 2027.
Smart Trade Compliance supports AEO holders in maintaining and strengthening their authorization in a changing regulatory environment.
Questions about your specific situation? Get in touch.
Geef een reactie