The EU is fundamentally changing how customs authorities and businesses interact. The new EU Customs Reform, established by Regulation (EU) 2026/2108 and adopted by the European Parliament and the Council on September 16, 2026, replaces the existing Union Customs Code with a more digital, data-driven system. It aims to simplify legitimate trade while giving authorities better tools to identify high-risk transactions. 

A key element of the reform is the Trust and Check (T&C) trader concept, intended for highly reliable businesses that give customs authorities extensive information about their activities, supply chains, and internal systems.

How Trust and Check Fits into the EU Customs Reform

The T&C system is an integral part of the EU Customs Reform, alongside the EU Customs Data Hub, which will become the central environment for customs data and interactions between businesses and customs authorities. The Data Hub will serve as a single entry point for customs information, letting businesses submit data once instead of navigating multiple national systems. In addition to the T&C system and the EU Customs Data Hub, the EU also establishes the EU Customs Authority, which will coordinate customs risk management at the EU level and manage the Data Hub. 

Why Is the EU Introducing Trust and Check?

The current EU customs system was designed for a different trading environment. The growth of e-commerce, increasingly complex supply chains, rising import volumes, and new security and geopolitical risks have made it more difficult for customs authorities to supervise trade effectively using traditional declaration-based processes.

The EU therefore wants customs decisions to rest largely on continuously available data and risk analysis.s. Instead of relying primarily on individual customs declarations, the new model will give authorities a broader view of businesses, goods and supply chains.

T&C, which builds on the existing Authorised Economic Operator (AEO) model, is designed as the partnership element of this transformation. Businesses that demonstrate a high level of compliance and transparency will receive greater simplification. In turn, customs authorities will be able to allocate resources to transactions and operators more prone to higher risks.

Comparison Between Trust and Check and AEO

Both T&C and AEO certification aim to make international trade more secure and efficient, but they represent different levels of customs facilitation and have different requirements. 

AEO certification is based on a trader demonstrating that it is a reliable and compliant economic operator. To qualify, a business generally needs a strong history of compliance with customs rules, appropriate professional competence, financial solvency, and effective internal controls over its operations and the movement of goods. These controls should allow customs authorities to assess and manage risks effectively, including through reliable commercial and, where relevant, transport records.

T&C, on the other hand, goes further than AEO status. The system allows customs authorities to rely significantly on the business's internal systems and data transparency. Because the two systems differ in their eligibility criteria, AEO status does not automatically convert into T&C status. This means those who are part of the AEO system will have to meet additional requirements to qualify for the T&C regime.

How Trust and Check Trader Status Works 

The T&C trader status is available to importers, exporters, and indirect representatives established in the EU who have carried out regular customs operations for at least two years and meet a range of compliance, financial, professional, security, and data-management requirements.

To qualify, traders must meet extensive requirements. In particular, traders must have no serious or repeated infringements of customs, tax, or other relevant legislation, maintain strong control over their operations and goods flows, and have appropriate procedures for licences and other regulatory requirements. 

Additionally, traders must ensure that employees can report compliance problems, suspicious movements, or unauthorized handling of goods to customs authorities. Finally, they must be financially solvent and have the necessary professional competence and qualifications.

One key feature of the T&C system is real-time data transparency. Traders must have an electronic system capable of making information available to customs authorities as close to real time as technically possible. This can include customs records, accounting systems, commercial and transport records, tracking and logistics systems, and relevant licences and authorizations.

Monitoring is another significant feature of the T&C system. Once authorized, T&C traders are subject to ongoing monitoring rather than a one-time certification. Customs authorities must conduct an in-depth review at least every two years, including an on-site visit, and traders must report significant changes to their corporate structure, ownership, financial position, business model, or activities. Their status can also be suspended or revoked in cases of fraud or serious non-compliance.

Key Benefits of Trust and Check Status

In return for this high level of transparency and control, T&C traders can receive significant customs simplifications. These may include providing certain data and documents after the goods have already been released, carrying out certain customs controls themselves and releasing goods at their own premises, periodically determining and deferring customs debt, and avoiding certain transit formalities for goods entering or leaving the EU customs territory.

What Businesses Should Do Now

The first step businesses involved in significant EU import or export activity should take is to assess existing customs governance. Businesses should examine the quality of their customs records, classification and valuation processes, tax compliance, authorizations, internal controls, and procedures for identifying and reporting compliance problems.

Since technology is central to this system, businesses should determine whether their ERP, customs, accounting, warehouse, and logistics systems can provide the information required by the new framework. Additionally, businesses should also consider their existing AEO position. Because T&C builds on the AEO concept, businesses with established AEO controls may already have part of the required governance framework in place.

Ultimately, the new status represents a shift from customs compliance based primarily on declarations towards continuous trust supported by data. Businesses that invest early in accurate data, strong internal controls, and transparent supply-chain processes will be better positioned to take advantage of the simplifications offered by the new EU customs system.