The Trust and Check trader: the successor to AEO in the customs reform
Trust and Check is a proposed new class of trusted traders that give customs real-time access to their systems. It builds on AEO but is not yet in force — a phased roll-out runs towards 2032-2038.
Short answer: Trust and Check is a proposed new category of trusted traders in the EU customs reform, designed as an evolution of today's AEO status. These traders give customs real-time access to their own systems and can release goods into free circulation with minimal intervention. Note: this is a proposal still under consideration and not yet law — the roll-out is phased towards 2032-2038.
What is Trust and Check?
In the proposal for the EU customs reform (COM(2023) 258), the European Commission introduces a new class of traders on top of the existing system. The essentials:
- Real-time system access: instead of filing declarations per shipment, the Trust and Check trader gives customs continuous visibility into their own logistics and commercial systems. Customs pulls the data it needs.
- Minimal intervention: under conditions, goods can be released into free circulation without each shipment being handled separately, whether physically or administratively.
- Link to the EU Customs Data Hub: all data flows through a central, EU-wide data platform intended to replace today's fragmented national IT systems.
This is explicitly a proposal. It has not yet been adopted, so the regime is not yet in force.
How does it relate to AEO?
Today's AEO status (Authorised Economic Operator) is the highest form of customs trust: fewer controls, faster handling, priority treatment. Trust and Check builds on this but goes further.
- AEO remains the foundation: the criteria you meet for AEO — reliable record-keeping, financial soundness, demonstrable compliance, security — also form the basis for Trust and Check.
- From after-the-fact control to continuous transparency: where AEO bases trust on periodic audits, Trust and Check demands ongoing, data-driven transparency.
What does this mean for data-mature traders?
The regime is written for large traders with mature IT and data management. Those who invest now will be ahead:
- Data quality is the entry ticket: real-time access only works if your systems deliver reliable, consistent and traceable data.
- AEO as a stepping stone: a current AEO status, with well-ordered processes and records, is the most concrete preparation for a future Trust and Check role.
- Time to build: with a horizon out to 2032-2038, there is room to get data flows, governance and system links ready step by step.
Read more: the Transport & Logistics overview. Take the scan.
Sources
- https://taxation-customs.ec.europa.eu/customs-4/eu-customs-reform_en
European Commission — EU customs reform and Trust and Check. - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023PC0258
Proposal COM(2023) 258: Customs Code reform (not yet adopted).
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