Under the new EU Union Customs Code, AEO holders must continuously monitor compliance with every authorisation criterion. Annual SAQ submissions no longer satisfy the obligation. Customs authorities will audit in-depth every three years, with site visits. MyCustomsInfo® is the platform that keeps your AEO authorisation audit-ready 365 days a year.
If you hold an AEOC, AEOS or AEOF authorisation, the obligation applies to you.
The European Court of Auditors flagged inconsistent AEO monitoring across Member States. The new UCC writes continuous self-monitoring into law for every authorisation holder, not just Trust and Check traders.
What actually changed
The political agreement reached on 26 March 2026 retains AEO status (the Commission\u2019s original proposal to abolish it was rejected) but adds binding obligations on every authorisation holder. Here is what matters operationally.
CHANGE 1
The annual Self-Assessment Questionnaire no longer satisfies the obligation. Your internal organisation must prevent, limit and correct errors on an ongoing basis. You must be audit-ready every working day of the year.
CHANGE 2
Customs authorities will carry out in-depth reviews of every AEO authorisation at least once every three years, with physical visits to locations covered by the authorisation. All audit results report into the EU Customs Authority.
CHANGE 3
Audit findings flow into the EU Customs Data Hub from 2028. Customs authorities across Member States will see a consolidated compliance picture. Inconsistent monitoring will become visible faster than before.
Important caveat on text references
This page is based on the politically agreed text of the UCC reform as of 26 March 2026. Final article numbering and exact wording may change before publication in the Official Journal (expected by end of 2026). We update this page as the text is formally adopted. Subscribe to our regulatory alerts to be notified when changes occur.
Before and after
| Obligation | Under current UCC (Reg. 952/2013) | Under reformed UCC (from 2027\u201328) |
|---|---|---|
| Self-monitoring cadence | Annual Self-Assessment Questionnaire. Periodic internal review encouraged. | Continuous self-monitoring mandated in law. Organisation must prevent, limit and correct errors year-round. |
| Customs reassessment | Variable by Member State. Often light-touch. | In-depth audit at least every 3 years with site visits. Reports into EU Customs Authority. |
| Evidence retention | Documents retained per national rules. | Audit-ready evidence pack expected on demand. Findings flow into EU Customs Data Hub from 2028. |
| Internal control framework | Procedural compliance with criteria. | Learning organisation expected, with active error correction. Equivalent of a continuous improvement system. |
| Risk of authorisation withdrawal | Withdrawal possible for serious infringements. | Same trigger, but findings visible across Member States via Data Hub. Faster escalation likely. |
Self-monitoring cadence
Annual Self-Assessment Questionnaire. Periodic internal review encouraged.
Continuous self-monitoring mandated in law. Organisation must prevent, limit and correct errors year-round.
Customs reassessment
Variable by Member State. Often light-touch.
In-depth audit at least every 3 years with site visits. Reports into EU Customs Authority.
Evidence retention
Documents retained per national rules.
Audit-ready evidence pack expected on demand. Findings flow into EU Customs Data Hub from 2028.
Internal control framework
Procedural compliance with criteria.
Learning organisation expected, with active error correction. Equivalent of a continuous improvement system.
Risk of authorisation withdrawal
Withdrawal possible for serious infringements.
Same trigger, but findings visible across Member States via Data Hub. Faster escalation likely.
Verified timeline
Every date below traces back to a Council of the EU, European Commission or European Parliament document. Status flags show whether a date is confirmed in published EU material or is currently expected.
Council and European Parliament agree the UCC reform text. AEO retained alongside new Trust and Check status. EUR 150 de minimis abolished. Source: European Commission and Council of the EU.
Co-legislators expected to formally adopt the agreed text. Final article numbers will be locked at this point.
EUR 150 de minimis abolished. Transitional flat EUR 3 duty per item on sub-EUR 150 consignments enters into force.
Commission to publish Delegated Act setting EU handling fee amount. Member States must apply the fee no later than 1 November 2026.
Once published, the Regulation enters into force 20 days later. Main body becomes applicable 12 months after publication.
Once the Regulation applies, every AEO authorisation holder is legally obliged to continuously monitor compliance with each criterion. Implementing Acts will set operational detail.
New decentralised agency takes over coordination of national customs authorities. EU Customs Data Hub opens for e-commerce in first operational phase.
Voluntary Trust and Check status opens for highest-transparency traders. Data Hub opens to other importers on a voluntary basis.
How MyCustomsInfo\u00ae helps
Our AEO Compliance Module turns the new continuous monitoring obligation into a structured operational workflow. Four integrated tabs cover every dimension Customs will assess.
Live dashboard mapping every AEO criterion against your current evidence. Visual heat-map of where you stand today versus the legal requirement.
Automated comparison between your operational data and the AEO criteria framework. Surface gaps before Customs does.
Generate an on-demand audit-ready evidence bundle for any AEO criterion. Designed to be handed directly to your customs authority during an in-depth review.
Workflow for scheduling, preparing for and tracking customs monitoring visits. Captures findings and tracks corrective actions to closure.
Available in MCI Audit and MCI Audit and CBAM tiers. Book a demo to see the module in action.
Two ways to get ready
Larger or more complex AEO programmes usually need advisory work alongside the platform. Smaller programmes can start with the platform alone. We will help you decide on the call.
Advisory route
For organisations with complex AEO programmes, multi-site authorisations, or significant gaps to close before the new rules apply. Delivered by Conor Anderson, with 70+ AEO engagements across EU and UK.
Platform route
For organisations with a working AEO programme that needs to move from annual self-assessment to continuous monitoring. Self-serve onboarding, demo data, and full configuration in under a week.
Tell us about your AEO position. We will route you to the right person, advisory or platform, based on your answers. No sales call until you have what you need to decide.
Common questions
US Regulatory Notice. MyCustomsInfo® is an independent compliance auditor. It does not conduct customs business as defined under 19 U.S.C. §1641. The specific tariff classification to be applied to any entry of merchandise is to be determined by a licensed Customhouse broker. MyCustomsInfo® output does not constitute entry preparation, classification advice, or customs broker services. Preparation and filing of Post-Entry Amendments, Post-Summary Corrections, protests, and drawback claims must be performed by a licensed customs broker. US broker records are held in US AWS regions in compliance with 19 C.F.R. §111.23. Primary authority: CBP HQ H272798 (January 2017). Supporting authority: CBP HQ H350722 (January 2026).
