Policy & Compliance
HMRC steps up customs enforcement HMRC has been expanding its compliance workforce, indicating that it intends to proactively enforce fi scal and potentially customs regulations rather than merely offering guidance
ports without the need to submit a full customs declaration for the affected shipment. This rejection policy marks a clear move toward a stricter customs procedure standard across all freight movements. New detection approach Additionally, it came to BIFA’s attention that Home Office Intelligence investigators have developed a new detection approach that combines information from the HMRC Compliance and Risk Engineering Solutions Team (CREST) with Companies House data, enhancing its ability to flag suspicious activity or inconsistent trading behaviour. This signals a more joined-up approach between government agencies aimed at identifying non- compliant traders. The above indicators demonstrate HMRC’s commitment to enforce compliance in a more data-driven and proactive manner. It is also sending a clear message to traders operating in the customs and logistics sectors: adapt quickly to this stricter regulatory environment or face operational challenges leading to potential penalties as a consequence.
F ollowing the last major update under the Border Target Operating Model (BTOM) – the introduction of the Safety & Security (S&S) declaration requirement – recent developments suggest a shift towards a fi rmer approach from government of fi cials, with growing attention on compliance enforcement. HMRC’s strategic shift from guidance to action places emphasis on ensuring that traders meet their customs obligations and follow the correct customs procedures. One of the recently announced changes is HMRC’s commitment to expand its compliance workforce by an additional 500 officers per year over the next five years. As a result, by 2029/30 HMRC will have increased the number of compliance officers by 5,500 since July 2024. This scaling up of human resources clearly reflects HMRC’s intention to proactively enforce fiscal and potentially customs regulations rather than merely to offer guidance.
Penalties From 7 April 2025, HMRC began issuing civil penalties of up to £2,500 to hauliers failing to present Transit Movement Reference Numbers (MRN) in the Goods Movement Reference (GMR) when using Goods Vehicle Movement Service (GVMS) ports. According to the Customs Transit Procedures (EU Exit) Regulations 2018, the inclusion of all MRN is a legal requirement to enable proper Office of Transit checks. Since January 2025, HMRC and Border Force have been distributing educational flyers to raise awareness. However, this grace period has come to an end and non-compliance will have direct financial consequences. In another significant development, HMRC has started rejecting C21 Customs Clearance Requests with 9-series Additional Procedure Codes (91U & 96M) for short shipments, closing a loophole previously used to release short- shipped goods from inventory linked
“ In another signi fi cant develop - ment, HMRC has started rejecting C21 Customs Clearance Requests with 9-series Additional Procedure Codes (91U & 96M) for short shipments
8 | May 2025
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