Independent compliance auditor

Post-clearance audit support for UK, EU and US importers

Every customs declaration you have filed in the last three to five years is auditable. HMRC, Revenue and CBP are increasing scrutiny. MyCustomsInfo® audits your declarations proactively, identifies errors and prepares correction-ready documentation before the authorities find the problems for you.

We identify classification errors, valuation discrepancies, origin misstatements and underused preference schemes across CDS, AES and ACE. Your licensed broker files the correction. Per-tenant data isolation. Mutual NDA from day one.

UK CDSEU UCC / AESUS ACEIreland RevenuePer-tenant isolation

What is a post-clearance audit?

A post-clearance audit (PCA) is the systematic examination of customs declarations, supporting documents and commercial records after goods have been released from customs control. Every major customs authority operates a PCA programme:

  • HMRC (UK) — Post-clearance audits under the Customs Act 2018, with a three-year retrospective window. HMRC announced 5,500 additional customs officers in 2025 and has publicly stated that post-clearance compliance activity is increasing.
  • Revenue (Ireland) — Audits under the Union Customs Code via the Automated Import System (AIS), three-year retrospective window.
  • EU member states — Post-clearance controls under UCC Article 48, with audit capacity varying by member state. Germany (Hauptzollamt), the Netherlands (Douane) and France (DGDDI) are particularly active.
  • US CBP — Focused Assessment programme and Compliance Assessment under 19 USC §1509, with a five-year lookback window. Penalties under 19 USC §1592 can reach four times the lost revenue for negligence.

The purpose of a PCA is to verify that the importer correctly declared the commodity classification (HS/TARIC/HTS code), the customs value (transaction value plus adjustments), the country of origin, the preference claim (if any), the customs procedure code and the quantity. Errors in any of these fields create either underpaid duty (which the authority will assess with interest and potential penalties) or overpaid duty (which the importer can reclaim through a formal correction).

Why proactive post-clearance audit, not reactive compliance

Most businesses only think about customs audit when they receive a notice from HMRC or CBP. By that point, the authority has already identified anomalies in your data and is asking you to justify them. The conversation starts on their terms.

A proactive post-clearance audit reverses this dynamic. You review your own declarations first, identify errors, and submit corrections through the formal voluntary disclosure or correction mechanisms that every customs authority provides. The benefits are concrete:

Reduced penalties

HMRC’s penalty framework explicitly rewards voluntary disclosure. A trader-initiated C285 correction typically attracts no penalty. An authority-initiated assessment on the same error carries penalties of 15% to 100% of the duty shortfall depending on culpability.

Duty recovery within the correction window

Overpaid duty is only recoverable within the statutory window: three years for UK and EU, 315 days (PSC) or 180 days (protest) for US. Every month you delay is a month of expired recovery opportunity.

Audit-ready documentation

When the authority does arrive, you present a complete audit trail: declarations, source documents, reconciliation reports and a history of corrections already filed. This reduces the scope and duration of the authority’s review.

AEO and compliance programme protection

AEO holders (UK), AEO-C/AEO-S (EU) and C-TPAT members (US) must demonstrate continuous compliance. A proactive PCA programme is evidence that you are meeting this obligation. The absence of one is a red flag.

What a post-clearance audit identifies

A thorough post-clearance audit examines every field on every declaration against the supporting commercial documentation. The most common findings, ranked by frequency and financial materiality, are:

Classification errors

The wrong HS code applied to the goods. This is the single largest source of both overpaid and underpaid duty. A 4-digit heading error can shift the duty rate by 10 percentage points or more. Post-Brexit, UK and EU tariff schedules have diverged on hundreds of subheadings, creating systematic misclassification risk for importers filing in both regimes.

Section 232 tariff classification audit

Valuation discrepancies

Customs value is the transaction value plus statutory adjustments for freight, insurance, royalties, assists and buying commissions (WTO Valuation Agreement, Article 1). Errors in declared value are common when the importer uses ex-works pricing and the broker applies freight and insurance estimates rather than actual costs. Overvaluation creates overpaid duty; undervaluation creates compliance risk.

Origin misstatements and underused preferences

Preferential rates under free trade agreements (UK-EU TCA, EU GSP, USMCA) are frequently unclaimed because the importer or broker did not hold the correct origin documentation at the time of entry. A post-clearance audit identifies entries where a preferential rate was available but not claimed, and quantifies the recoverable duty.

Duty recovery service for UK importers

Procedure code errors

Incorrect customs procedure codes (CPC in the UK, additional procedure code in the EU) mean goods entered under the wrong relief or suspension scheme. IPR, OPR, temporary admission and returned goods relief all depend on correct procedure coding. Errors here create both financial exposure and compliance risk.

IEEPA, Section 301 and Section 232 tariff exposure (US)

US importers face stacking tariff regimes where multiple additional duties apply to the same entry. IEEPA tariffs, Section 301 China lists, Section 232 steel, aluminium and copper duties, and AD/CVD overlays compound on each other. A single misclassified subheading can flip a 0% rate to 25% or higher.

IEEPA tariff audit

CBAM reporting gaps (EU and UK)

The EU CBAM definitive regime is live from January 2026, with certificate surrender from 2027. UK CBAM starts January 2027. Importers of iron, steel, aluminium, cement, fertiliser, hydrogen and electricity face embedded carbon reporting obligations that are linked to customs declarations. Gaps in CBAM data are increasingly surfacing during post-clearance audits.

CBAM compliance platform

Correction mechanisms by jurisdiction

Every customs regime provides formal mechanisms for correcting errors identified through post-clearance audit. The correction window and process differ by jurisdiction:

RegimeCorrection mechanismWindowAuthorityLegislation
UK CDSC285 (Customs Duty Adjustment)3 years from acceptanceHMRCCustoms Act 2018, s.29
EU UCCAmendment / Invalidation (Art. 173/174)3 years from acceptanceMember state customsUCC Regulation 952/2013
IrelandRevenue amendment via AIS3 years from acceptanceRevenue CommissionersUCC + national implementing rules
US ACEPost-Summary Correction (PSC)315 days from entry summaryUS CBP19 CFR §10.112
US ACEProtest (19 USC §1514)180 days from liquidationUS CBP19 USC §1514

How MyCustomsInfo® supports post-clearance audit

MyCustomsInfo® is an independent compliance auditor. We do not file declarations, we do not act as a customs broker, and we do not submit corrections to any customs authority. We identify the errors. Your licensed broker or customs agent acts on the findings. This separation is architecturally enforced and legally required in regulated markets including the United States (19 USC §1641).

1

Data ingestion

Your declaration data is uploaded from CDS, AES, ACE or your broker's system into your dedicated, isolated MyCustomsInfo® tenant. Every client receives dedicated AWS infrastructure: a private S3 bucket, a customer-managed KMS key, an Aurora PostgreSQL schema with row-level security, and dedicated processing queues. No data is co-mingled with any other tenant under any failure mode.

2

Document reconciliation

Our FastNet™ Intelligent Document Processing engine extracts structured data from commercial invoices, bills of lading, certificates of origin, packing lists and broker worksheets. Each document is reconciled against the corresponding declaration fields: classification, value, origin, quantity and procedure code.

3

AI-powered compliance analysis

Piers, our AI risk-classification engine, analyses every declaration against the applicable tariff schedule, trade agreements, preferential rate eligibility, anti-dumping and countervailing duty orders, and special tariff programmes (IEEPA, Section 301, Section 232). Anomalies are flagged with a confidence score and a financial materiality estimate.

4

Compliance report and correction data

You receive a compliance report identifying every exception, the estimated financial impact (overpaid or underpaid), the applicable correction mechanism and the supporting evidence. For overpaid duty, the correction data and evidence pack are prepared ready for your broker to file the C285, PSC, protest or member state amendment.

5

Continuous monitoring

On an ongoing subscription, new declarations are audited as they are filed. Recurring errors (such as a systematically misclassified product or an undervalued freight component) are flagged as patterns so the root cause can be addressed with your broker, not just the individual declarations.

Compliance boundary: what we do and what we never do

What MyCustomsInfo® does

  • Audit declaration data against source documents
  • Identify classification, valuation and origin errors
  • Quantify overpaid and underpaid duty exposure
  • Prepare correction data and evidence packs
  • Monitor ongoing declarations for recurring errors
  • Maintain audit-ready documentation per-tenant

What MyCustomsInfo® never does

  • File or submit customs declarations
  • Submit corrections to any customs authority
  • Act as a customs broker in any jurisdiction
  • Determine or confirm HS classifications
  • Charge fees linked to individual entries (US)
  • Prepare or file CBP drawback claims

This boundary is not policy. It is architecture. See our trust and compliance credentials for full detail including US regulatory basis (CBP HQ H272798 and HQ H350722).

Who needs post-clearance audit support?

SME importers with 400+ declarations a year

If you file more than 400 customs declarations annually, the probability of classification or valuation errors across that volume is near certain. A single misclassified product line can create thousands of pounds in overpaid duty over a 3-year window.

Multi-jurisdiction importers

Filing in the UK, EU and US simultaneously means three different tariff schedules, three different preferential rate regimes and three different correction mechanisms. Errors in one jurisdiction often repeat in others.

Businesses using multiple brokers

Different brokers apply different classification judgements. Without a single audit layer across all brokers, inconsistencies go undetected. Post-clearance audit creates the oversight your brokers cannot provide for themselves.

AEO holders and C-TPAT members

AEO and C-TPAT require demonstrable continuous compliance. A proactive post-clearance audit programme is evidence of this. The absence of one is a finding in itself.

Frequently asked questions about post-clearance audit

What is a post-clearance audit?+
A post-clearance audit (PCA) is a systematic review of customs declarations after goods have cleared the border. Customs authorities including HMRC in the UK, Revenue in Ireland, EU member state customs administrations and US CBP all conduct PCAs to verify that importers correctly declared duties, classifications, transaction values and countries of origin. HMRC typically reviews declarations going back three years under the Customs Act 2018; CBP can look back five years under 19 USC §1592.
What triggers a post-clearance audit from HMRC?+
HMRC selects traders for post-clearance audit based on risk profiling, random selection, intelligence from other agencies, anomalies in declaration data (such as statistical outliers in declared values or classification patterns), sector-specific campaigns, and referrals from Border Force. AEO holders are audited on a scheduled basis as part of their continuous compliance obligation. HMRC announced 5,500 additional customs officers in 2025, increasing audit frequency significantly.
How far back can HMRC audit my customs declarations?+
Under Section 29 of the Customs Act 2018, HMRC can review declarations up to three years from the date of acceptance. If fraud or deliberate non-compliance is suspected, this extends to four years. In the EU, member states typically apply a three-year retrospective window under the Union Customs Code (Article 105). US CBP can audit entries up to five years back under 19 USC §1592, with penalties of up to four times the lost revenue for negligence.
What is the difference between a trader-initiated audit and an authority-initiated audit?+
A trader-initiated audit is when you proactively review your own declarations, identify errors and submit corrections before the customs authority finds them. This is what MyCustomsInfo® supports. An authority-initiated audit is when HMRC, Revenue or CBP contacts you with a notice of intent to audit. Trader-initiated corrections typically attract lower or no penalties. HMRC's C285 process and CBP's Post-Summary Correction both provide formal mechanisms for voluntary correction.
What documentation do I need for a post-clearance audit?+
You need the original customs declaration (CDS entry, AES declaration or CBP Form 7501), the commercial invoice, packing list, bill of lading or airway bill, certificate of origin (if claiming preferential rates), any broker worksheets showing how the classification and value were determined, and evidence of payment. MyCustomsInfo® reconciles all of these documents against each declaration and flags discrepancies.
Can I recover overpaid duty through a post-clearance audit?+
Yes. If a post-clearance audit identifies that you overpaid duty due to a classification error, incorrect valuation, or failure to claim a preferential rate, you can submit a correction and claim a refund. In the UK, this is done via HMRC form C285. In the EU, the process varies by member state but follows Article 117 of the UCC. In the US, you can file a Post-Summary Correction within 315 days or a protest within 180 days under 19 USC §1514.
How does MyCustomsInfo® support post-clearance audit?+
MyCustomsInfo® is an independent compliance auditor. We ingest your declaration data from CDS, AES or ACE, reconcile every entry against source documents using our Piers AI engine, and produce a compliance report identifying classification errors, valuation discrepancies, origin misstatements and underused preference schemes. We prepare the correction data and supporting evidence. Your licensed broker or customs agent files the correction with the authority. We identify; your broker acts.
Do I need a subscription to use post-clearance audit support?+
Ongoing post-clearance audit monitoring requires an active MyCustomsInfo® subscription (Essentials or above). For a one-off historical audit of up to three years of declarations, we offer a standalone engagement through the Historical Audit Module on the pricing page. Both options include per-tenant data isolation, a mutual NDA and a Data Processing Agreement before any data is exchanged.

Start your post-clearance audit

Send us your annual declaration volume and jurisdiction mix. We will return a tailored quote within 48 hours. Mutual NDA and Data Processing Agreement executed before any data is exchanged.

Per-tenant data isolationMutual NDA from day oneFirst results within 48 hours

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).