Customs simplifications
Fewer controls, access to simplified procedures, reduced guarantees, priority handling of authorisation applications.
Who it suits operators handling a significant volume of declarations and using customs authorisations.
Authorised Economic Operator is the highest level of trust a European customs administration can place in a business. We support the whole process end to end: preliminary audit, bringing you into compliance, filing the application, being there during the customs audit, then keeping the status alive.
Authorised Economic Operator status certifies that a business has command of its customs compliance, its operational risks and the security of its supply chain. It stems from the SAFE standards of the World Customs Organization and sits in Articles 38 and 39 of the Union Customs Code (Regulation (EU) No 952/2013), carried over into Articles 29 and 30 of the new Code (Regulation (EU) 2026/2108). The status is retained: Trust and Check does not replace it, it is added alongside.
This is not a marketing label. It is a formal partnership between the business and customs, built on transparency, command of processes and the quality of internal control. The administration agrees to lighten its supervision because the business demonstrates that it supervises itself.
That is also what explains how demanding the procedure is: this is not an administrative form to fill in, it is a level of command to be demonstrated, with evidence.
Fewer controls, access to simplified procedures, reduced guarantees, priority handling of authorisation applications.
Who it suits operators handling a significant volume of declarations and using customs authorisations.
Facilitations at controls on entry to and exit from the Union, reduced ENS data, mutual recognition outside the EU.
Who it suits players present at the Union's points of entry and exit, and exporters to countries with mutual recognition.
Combines the benefits of AEOC and AEOS. The most complete status, and the most widely recognised internationally.
Who it suits manufacturers importing and exporting, running both flows under authorisation and cross-border supply chains.
Choosing the status is not a matter of preference: it follows from the real profile of your flows. It is one of the first questions the preliminary audit settles.
Guarantee on potential debts
Complete waiver. Without AEO, you must guarantee 100 %.
Guarantee on debts already incurred
Against 100 % without the status. The effect on cash flow is immediate.
Authorisations made lighter
The criminal record extract is no longer required: SDE, EIR, CGU, CVA, AWB, ACR, ACE, ACT, ACP,
ETD, SSE.
Measure the effect on your own guarantees →
The application is filed through the EU Trader Portal with the AGD&A — the Belgian customs and excise administration — at the office responsible for the place where the main customs records are kept.
The official European form, the Belgian self-assessment — a six-section questionnaire covering the criteria of Article 39 UCC — and ten compulsory annexes.
Once the application is found admissible, the file passes to the CRES (Senior Enterprise Risk Coordinator) at the competent regional centre.
The CRES has 120 calendar days, extendable, to carry out the audit: review of documents, site visits, interviews and tests of operational effectiveness.
The audit leads to an external control plan signed by the operator, then to the decision granting the status.
The authorisation is valid without time limit and across the 27 Member States. It is reviewed periodically, in practice every three years.
Where the audit ends in an unfavourable decision, the operator cannot file a new application for three full years. Filing too early does not just cost the time invested: it shuts the door for three years.
That is the whole purpose of the preliminary audit. The file is filed only once the criteria of Article 39 are actually met — not when one hopes they are.
Article 39 sets out five criteria. The first four govern AEOC; the fifth, specific to safety and security, governs AEOS. An AEOF application must meet them all. In our audits each one receives a score — green, amber or red — by criterion and by department.
No serious or repeated infringement over three financial years. Cross-checks with AGFisc (the Belgian tax administration), the ONSS (social security) and the criminal records of the applicant and its directors, together with a review of pending disputes.
Traceability, archiving, audit trail, the Union / non-Union distinction, IT interfaces and intra-group flows.
The ability to meet customs commitments. Calculation of the 22 ratios used by the AGD&A, review of accounts and guarantees, and consistency between customs value and transfer pricing.
Specific to AEOC. Customs competence of the managers and declarants, training completed, and HR procedures attached to the customs function.
Specific to AEOS. Premises and access, cybersecurity — including strong authentication on remote access — and the security of staff, carriers and business partners.
The criteria say what is assessed. These lines say where we go looking for the evidence. They are not worked through one after another: we cross them. A risk almost always arises where two of them meet — a physical flow the records do not reflect, a record the declaration contradicts.
Receipt, storage, production, dispatch. The Union / non-Union distinction, and mapping of intra-group and international flows.
Methodsite visits, interviews with logistics and production.
Stock records, internal traceability, interfaces between information systems, consistency across sites.
Methoda sample of movements, consistency tests between the physical flow, the records and the declarations.
Import and export declarations, authorisations, tariff classification and BTI, customs value, preferential and non-preferential origin, dual-use goods licences.
Methoda sample of declarations, measurement of the error rate, and a full review of authorisations.
Internal procedures, corrective actions, indicators, segregation of duties, internal audit, physical security and cybersecurity.
Methodreview of written procedures, cyber audit, tests of operational effectiveness.
Five stages, which can be taken one at a time, with a decision on whether to continue at the end of the first. You do not have to commit to the whole cycle to find out where you stand.
A full picture of your customs compliance, scored by criterion, guidance on which status to aim for, and a prioritised action plan by department. This is the stage that prevents filing too early.
Drafting and putting procedures in place, bringing you into compliance along the four lines of analysis, and following corrective actions through to closure with documentary evidence.
Building the file, completing the self-assessment questionnaire and the annexes, filing through the EU Trader Portal and following up on admissibility.
Support while the CRES examines the file: preparing your teams for the interviews, answering requests, and being present during site visits.
Putting into effect the control plan set by the administration, moving into routine, and preparing for the review. The status is not acquired once and for all.
Delivered alongside. The aim is not only to meet the criteria, but for your teams to be able to hold the status without us — tariff classification, origin and value under control day to day. See our training →
An AEO process runs for months and cuts across the whole business. Without governance it bogs down. We impose one from the outset.
Customs, supply chain, finance, IT, human resources, security, quality: each area names a lead contact, and ideally a deputy. Every action in the plan is attached to one of them by name.
Agenda circulated five working days ahead, minutes within 48 hours setting out actions, owners and deadlines. Any major blockage reaches management within 72 hours.
The same one for you and for us: score by criterion as a heat map, action plan by criticality, register of non-conformities, segregation-of-duties matrix, customs risk indicators.
Audit report, AEO plan, minutes, action sheets: each follows a template proven on assignment. You know in advance what you will receive.
This is no longer a proposal. Regulation (EU) 2026/2108 of 16 September 2026, published in the Official Journal on 19 September and in force since the 20th, establishes the new Union Customs Code and repeals Regulation 952/2013. General application is set for 21 September 2027, with provisions phased in through to 2034.
The EU Customs Authority (EUCA), an agency based in Lille: running the Data Hub, risk analysis at Union level, coordination of controls.
The EU Customs Data Hub: a single entry point, data filed once, a real-time view of supply chains. It will replace the national systems.
The certified trusted economic operator — Trust and Check trader, Article 31 — alongside AEO, retained in Articles 29 and 30.
Note the official wording: texts and administrative decisions will speak of a certified trusted economic operator. “Trust and Check” will remain the working name.
Only an importer, an exporter or an indirect representative established in the Union may apply (Article 31(1)). AEO remains open to any established economic operator.
Two years of regular customs operations, and access for the authorities to the data of the last three years (Article 31(2)). A distance-sales importer must also have been registered for IOSS for two years (paragraph 3(g)).
The foundation is the one you know — record of compliance, control of operations, financial solvency, competence, safety and security — but set higher: solvency is assessed notably on three years of payment of duties, VAT and excise; competence now includes interacting with the Data Hub.
Article 31(3)(f) requires an electronic system communicating to the authorities, or making available to them, the data on the movement of goods and on compliance “within a timeframe as close to real time as technological means allow”.
It covers customs records — including those allowing the customs debt to be verified — the accounting system, commercial records and transport documents, logistics tracking (Union or non-Union status, location), and the licences and authorisations arising from other legislation.
This is not a file to assemble, it is an information system to put in order. A business that keeps its customs compliance in spreadsheets and e-mails will struggle to qualify, even where its declarations are correct.
The facilitations in Article 31(8) are not conveniences: several of them condition access to entire lines of business.
Certain controls and release on receipt at your premises, based on real-time data (Article 78, applicable from 1 July 2028).
Periodic determination of the customs debt (Article 205(5)) and deferment of payment (Article 212(2)): a direct effect on cash flow.
The competent authority is that of your Member State of establishment (Article 6(2)(b)), whatever borders your goods cross.
Movement under a suspensive procedure and supervision through to destination, without using transit (Article 31(8)(f)).
Lighter controls and a favourable risk profile (Article 31(10)), reduced comprehensive guarantee or waiver (Article 200), priority treatment in a crisis (paragraph 11).
Part of the data may be supplied after release, in duly justified cases relating to accompanying documents or customs value (Article 74(5)).
Article 145 reserves to certified trusted economic operators — or to their certified indirect representatives — the ability to store distance-sales goods in a dedicated private customs warehouse, provided IOSS is used.
The interest is economic: handling fees are lower than the €2 per item applied since 21 September 2026, the reduced amount still to be set by delegated act. The legislator's logic is plain: encourage bulk importation rather than the individual parcel shipped from a third country. Applicable from 1 July 2028.
| AEO (C / S) | Trust and Check | |
|---|---|---|
| Legal basis | Arts. 38-39 UCC; Arts. 29-30 of the new Code | Art. 31 of the new Code |
| Who may hold it | Any established economic operator | Importers, exporters, indirect representatives |
| Track record | None required | 2 years of regular operations; data of the last 3 years |
| Criteria | The five criteria | The same, raised, plus near-real-time data |
| Monitoring | At least every 3 years, with an on-site visit | At least every 2 years |
| Role of the EU authority | — | Verification on indications, recommendation to suspend or revoke |
| Distance-sales warehouse | No | Reserved to the status |
| Centralised clearance | Reserved to AEOC, until 1 March 2034 | Release on site, with no expiry date |
| Mutual recognition | AEOS, eight agreements with third countries | No basis provided for as yet |
The two statuses do not substitute for one another: they cover neither the same scope nor the same benefits. A number of operators will have reason to hold both.
From 21 September 2027, releasing a distance-sold good for free circulation will be reserved to AEOC or Trust and Check representatives (Article 33(7)(b)). Without one of the two, not a single B2C consignment in representation.
The same rule applies to representing a client in a Member State other than your own (paragraph 7(a)) — which is structural for a provider serving several markets. And from 1 July 2028, two providers doing the same work will no longer carry the same cost per item, depending on whether they hold the distance-sales warehouse.
The obstacles are real: the IT investment needed to transmit accurate, time-stamped data that reconciles with stock; the track record required; a scope limited to three capacities; and monitoring every two years.
The body of criteria is shared, and businesses that genuinely hold their AEO status — rather than endure it — will treat Trust and Check as an extension. The others will meet the full set of requirements at once, the IT ones included.
It is also the only item on this list that takes several months of audit and remediation before the application is even filed. September 2027 is not far off.
Considering certification, or is your status due for review?
We always begin with the preliminary audit: within a few weeks it tells you whether the file is ready, what still needs building, and in what order.
Let's talk about your situation →