Check if Authorised Economic Operator status could benefit you

Checks HMRC will carry out against the criteria

Guide

HMRC will carry out the checks below to see if you meet the criteria for receiving the status. All businesses must meet the criteria.

These checks will take place after you’ve applied and HMRC will take into account the size, nature and complexity of the business when carrying out the assessment.

Approval for AEO status involves audit visits from HMRC staff. Before you apply make sure you’re ready for HMRC officers to attend your premises. They will call you shortly after your application has been accepted to arrange these visits.

Tax and customs compliance

HMRC will check your business has complied with tax and customs rules over the last three years. If your business has been running for less than three years, they will use the latest available information. HMRC need to know if there have been any serious or repeated breaches of customs rules.

You’ll need to show evidence that you have:

  • procedures that identify and report any customs irregularities or errors to HMRC
  • taken appropriate action to deal with any irregularities
  • procedures that report any customs business changes to HMRC
  • clear procedures for handling controlled goods

Customs record keeping

HMRC will ask to see an efficient system for managing commercial and in some cases, transport records.

When applying for the status you’ll need to provide evidence that you have:

  • a well-maintained logistics system with a full audit trail
  • methods to allow HMRC to access your customs records
  • a logical administrative system
  • documented procedures to manage the flow of goods
  • internal controls that detect illegal or irregular transactions
  • procedures to handle licences and authorisations
  • archive and retrieval procedures in place
  • trained staff to tell HMRC of any system errors
  • procedures for checking customs declarations submitted by third parties on your behalf
  • Information Technology security measures in place

If you make declarations on behalf of others you’ll need to provide evidence that you have:

  • understood your contractual responsibilities and obtain written instructions from business partners
  • understood your legal responsibilities if acting in the capacity as an indirect or direct representative
  • processes for choosing business partners
  • documented procedures to validate the valuation, classification and origin of goods
  • procedures to manage or review relationships with clients who are non compliant

If you’re a small or medium sized business, you do not need complex systems, but they must be appropriate to the size, nature and complexity of the business.

Proven financial solvency

HMRC will check the financial records of your business covering the last 3 years. This is to make sure you have the ability to meet your commitments to both HMRC and other creditors.

If you have traded for less than 3 years you can still apply.

HMRC will need to:

  • see your full management accounts and projections
  • see your letter of conformity from your chartered accountant or bank
  • check if your business is subject to bankruptcy proceedings or liquidation

HMRC expect your current net assets to be positive. They will take into account any special circumstances that mean it’s normal for you to have any net negative assets.

If your business is not required to file accounts, you can provide other financial statements to show HMRC your proven financial solvency.

Practical standards of competence or professional qualifications

Before you make your customs simplification application, you must be able to show and give evidence of practical competence in customs matters for the previous 3 years. You’ll need to give evidence of how you’ve maintained the roles, responsibilities and competences.

The person responsible for customs matters should be based in the UK, as customs matters should be seen daily and all risks managed in the UK.

If your business has been running for less than 3 years, we’ll use the latest available information.

If you have a small business, you must have at least one person with responsibility for customs matters. This can be part of their role and not dedicated solely to customs.

You can use a customs agent to deal with your customs matters. You must be able to give accurate information so the agent can complete declarations on your behalf.

Security and safety

When applying for AEOS, HMRC will check the procedures you’ve put in place to protect your business and the supply chain from any risks. You’ll need to make sure your procedures are robust and appropriate to the size and nature of your business. For example, a small business with a secure outer fence and intercom may not need full time security staff.

If you apply for AEOS status you’ll need to show evidence that you:

  • have a safety and security risk assessment in place
  • have secured external boundaries with documented procedures to control access to your premises
  • have measures in place to inspect and protect your cargo units
  • prevent unauthorised access to shipping areas, loading docks and cargo areas
  • check the security and safety of your goods during storage, manufacture and transport
  • agree appropriate safety and security measures with your suppliers
  • carry out security screening and procedures for prospective employees and contracted parties
  • train your staff in the security and safety requirements
  • have contracts for temporary personnel
  • have details of owners of cargo units
  • have all outsourcing contracts (including cleaning, security, maintenance and any others)
  • regularly check and review your processes

You can also provide evidence when HMRC visit, that you have a safety and security certificate from one of the following:

  • an international convention
  • an international standard of the International Organisation for Standardisation

If you are a:

  • regulated agent
  • known consignor
  • International ship and port facility security (ISPS)
  • secure operator

The criteria for the issue of a security and safety authorisation are deemed to be met for those areas which are covered by that status.

If you hold:

  • an internationally recognised security and safety certificate issued on the basis of international conventions
  • a relevant International Standard of the international Organisation for standardisation,
  • a European Standard of the European Standards Organisations
  • other internationally recognised security and safety certificates

HMRC will take them into account in assessing the level of checks needed to verify the AEO criteria

This means HMRC may be able to carry out less checks on your application.

HMRC will expect you to have a strong recruitment policy that stands up to scrutiny.

You should have a pre-employment check in place for all staff. This should cover the previous 3 years at least. You’ll need to show evidence of this.

A regulated agent or known consignor should have a 5 year employment history check.

If an employee is in a security sensitive position or a high risk area, they must have received security screening. The same level of background checks apply to agency workers you employ.