Trust and Check trader status: requirements and benefits

What is Trust and Check?

Trust and Check (T&C) is a new trader certification introduced by the EU Customs Reform. It replaces and extends the current Authorised Economic Operator (AEO) programme. T&C traders gain the highest level of facilitation available under the new customs framework, including self-release of goods and periodic duty payments.

The certification becomes available from 2032, when the Data Hub opens for voluntary use by all traders.

Requirements

Trust and Check builds on AEO requirements but adds significant new obligations, particularly around IT infrastructure:

Operational history

• Minimum 3 years of regular customs operations
• Existing AEO status does not automatically convert to T&C. A separate application and assessment process is required.

IT infrastructure

This is the most demanding aspect of T&C certification. Traders must have:

1. Real-time data transmission. An electronic system that provides customs authorities with real-time data on the movement of goods, compliance status, safety and security information, and commercial transaction details.
2. Direct system access. Customs authorities must be able to access the trader's electronic systems directly for audit and verification purposes.
3. Data Hub integration. Systems must transmit data to the EU Customs Data Hub (not just national systems). This means EUCDM-compliant data structures and API connectivity.
4. Machine-readable data quality. All data must be structured according to EUCDM specifications. Manual entry or unstructured formats are not acceptable.

Training and compliance

• Mandatory participation in training programmes provided by competent authorities
• Ongoing compliance monitoring systems must be in place
• Internal customs expertise is required (reduced broker dependency, but higher internal capability needed)

Benefits

The benefits of T&C status are substantial for high-volume traders:

• Self-release of goods. Goods are released without prior customs intervention. No waiting for customs clearance before moving your shipments.
• Periodic duty payment. Pay duties periodically rather than per consignment. This improves cash flow and reduces administrative overhead.
• Advance binding decisions. Receive binding decisions on tariff classifications and customs valuations before goods arrive, eliminating uncertainty.
• Centralised clearance. Import goods through a single member state regardless of the point of entry into the EU. No need to clear goods in every country where they cross the border.
• Simplified transit. Avoid transit formalities for goods entering or exiting the customs territory.

Cost considerations

T&C certification requires significant investment:

• IT infrastructure. Building real-time data integration with the EU Customs Data Hub is a major technical project. Depending on the complexity of your current systems, this could take 12 to 24 months.
• Data security. Because customs authorities get direct access to your systems, you need robust security infrastructure and access controls.
• Ongoing compliance. Continuous monitoring systems must track compliance status and flag issues proactively.
• Internal expertise. While T&C reduces dependency on customs brokers for routine declarations, you need stronger internal customs knowledge to manage the programme.

Is it worth it?

T&C makes the most sense for businesses that:

• Handle large volumes of cross-border trade within the EU
• Already have modern ERP or WMS systems with API capabilities
• Currently spend significant time and money on customs clearance across multiple member states
• Want to reduce dependency on customs brokers for routine operations

For smaller traders with occasional cross-border shipments, the standard Data Hub portal access (available from 2032, mandatory from 2038) is likely sufficient.

Getting started

Even though T&C certification opens in 2032, preparation should start well before that:

1. Assess your current AEO status. If you are already AEO-certified, you have a head start on compliance requirements, but the IT infrastructure demands go well beyond current AEO levels.
2. Audit your systems. Map your current data flows and identify what needs to change for real-time EUCDM-compliant data transmission.
3. Build a roadmap. Plan the technical work in phases. Start with data model compliance, then build API integration, then add real-time capabilities.
4. Engage customs authorities early. Authorities will provide guidance on the certification process and may offer pilot programmes as the 2032 date approaches.