PAS 41201: Have Your Say on UK Customs Standards

HMRC and BSI are shaping a new UK customs standard — PAS 41201. Here’s why you must review it before 3 October 2025.

UK Customs is on the brink of a significant shift. HMRC has sponsored the development of PAS 41201, a Publicly Available Specification drafted by the British Standards Institution (BSI), aimed at improving the quality, consistency, and professionalism of customs intermediaries. This is not a law, but if you work in customs, trade compliance, or logistics, it could set the operational benchmark for years to come. And right now, it’s open for public consultation until 3 October 2025.

Arne’s Takeaways

PAS 41201 could shape the future of UK customs intermediary standards. Read the draft. Submit your feedback. Don’t miss the chance to influence it.

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Key Questions Covered in This Blog

• What is PAS 41201 and why is HMRC backing it?

• Which operational areas does the draft cover?

• Why should customs intermediaries care?

• How and when can you give feedback to BSI?

Abbreviations Used in This Blog

• PAS – Publicly Available Specification

• HMRC – His Majesty’s Revenue and Customs

• CPD – Continuing Professional Development

• SOPs – Standard Operating Procedures

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"Standards like PAS 41201 set the tone for how the UK’s customs sector operates. Ignore them at your own risk."Arne Mielken, Managing Director, Customs Manager

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What is PAS 41201 and why is HMRC backing it?

PAS 41201 is a fast-track, consensus-building standard produced by BSI, the UK’s national standards body. HMRC’s sponsorship signals that it sees a need for higher, more consistent professional standards in customs intermediary work. While not legally binding, PAS 41201 could become the go-to reference for demonstrating compliance, competence, and due diligence.

Which operational areas does the draft cover?

The PAS sets expectations in six areas:

• Due diligence – checking the accuracy of data and legitimacy of clients.

• Continuing professional development – keeping staff skills current.

• Systems, processes, and data – ensuring secure, efficient workflows.

• Complaints resolution – handling client issues professionally.

• Standard operating procedures – documented steps to minimise errors.

• Transparency – clear communication and disclosure with clients.

Bold recommendation: Audit your current procedures now against these six points. It’ll make adoption easier later.

Why should customs intermediaries care?

This PAS is designed for organisations that prepare and submit customs declarations for others — including customs agents, freight forwarders, express operators, and warehouse providers. By aligning with PAS 41201, you could:

• Improve operational quality and reduce compliance risk.

• Demonstrate professionalism to clients and HMRC.

• Differentiate yourself in a competitive marketplace.

It’s also relevant to importers and exporters who rely on intermediaries — you’ll know exactly what good practice looks like.

How and when can you give feedback to BSI?

The public consultation is running now until 3 October 2025. To review the draft and submit comments:

1. Go to the BSI Standards Development Portal.

2. Create a free account if you’re a new user.

3. Submit your feedback electronically — only online comments will be considered.

BSI recommends that each organisation consolidate its comments to avoid duplication. All feedback will be reviewed before finalising the PAS.

Bold recommendation: Don’t wait until the deadline. The sooner you comment, the more time you have to refine your position internally.

PAS 41201 Focus Area	What It Means	Actions to Take Now
Due diligence	Verifying client identity, data accuracy, and legitimacy before submitting declarations.	- Create a checklist for client onboarding.- Validate EORI, VAT, and licensing details before filing.- Keep proof of checks for audit defence.
Continuing professional development (CPD)	Ongoing training to keep staff up to date with customs rules and systems.	- Set mandatory annual CPD hours.- Track completion through a training log.- Subscribe to trusted trade intelligence services.
Systems, processes, and data handling	Secure, efficient handling of customs data and declaration workflows.	- Map your current declaration process.- Review system security and backup protocols.- Introduce version control for key documents.
Complaints resolution	Transparent, timely handling of client issues.	- Document a complaints policy.- Set clear timelines for resolution.- Log and analyse complaints for recurring issues.
Standard operating procedures (SOPs)	Clear written processes for all key customs activities.	- Write SOPs for each step of the declaration process.- Include who is responsible and when checks occur.- Review SOPs annually or after major regulatory changes.
Transparency	Clear communication about services, limitations, and responsibilities.	- Update client terms of engagement.- Provide written service scope before starting work.- Share compliance responsibilities in plain English.

Recap & Next Steps

PAS 41201 could reshape UK customs intermediary standards. Whether you’re a service provider or a client, now’s the time to read the draft and have your say. If you ignore this consultation, you may have to live with a standard you could have influenced.

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