In July 2026, the government announced a package of measures intended to simplify and modernise the customs system, including: 

• launching a call for evidence on trade digitalisation and the opportunities and challenges it poses for the future of the UK customs regime; and
• publishing a consultation on mandatory registration with HMRC for customs intermediaries who submit customs declarations on behalf of traders.  

ICAEW has now responded to the call for evidence (in ICAEW Representation 78/26) and to the consultation (in ICAEW Representation 83/26). The representations will be published at 2026 Tax Representations | ICAEW in due course.

Trade digitalisation 

ICAEW supports a modern customs regime that is digital, proportionate and internationally connected. The success of modernisation should ultimately be judged by whether it makes international trade simpler, more efficient and more accessible for compliant businesses while maintaining effective border controls and protecting revenue. 

ICAEW recommends that future reforms are focused on: 

• reducing administrative burdens; 
• making better use of existing commercial data;
• maintaining a risk-based approach to compliance; and 
• aligning with international standards where appropriate. 

It is important that any further digitalisation simplifies compliance and facilitates trade, rather than introducing additional complexity or reporting requirements, and that customs modernisation is designed around the needs of the businesses that use the system. In particular, application processes should be streamlined, duplication reduced and existing government-held information reused wherever possible. 

Mandatory registration 

ICAEW believes that mandatory registration for customs intermediaries should help address errors and poor behaviour by customs agents. ICAEW understands that, compared to tax agents, customs intermediaries are less likely to be affiliated to a professional body, and therefore may not be subject to the same level of professional oversight and supervision. This is a significant difference that needs to be addressed. 

ICAEW recommends that: 

• to avoid duplication and additional costs for both HMRC and agents, customs intermediary registration is incorporated into the existing mandatory tax adviser registration regime (MTAR), rather than developed as a separate regime; and
• to ensure that the same standards apply across the board, the same minimum requirements for registration should apply for MTAR and any extension to customs intermediaries.