Updated Rules for Brokerage Authorization
On October 16, 2025, the State Customs Service of Ukraine introduced updated recommendations governing the authorization process for customs brokerage activities.
The revisions primarily address the correct completion of self-assessment questionnaires by enterprises and the submission of accompanying documents when applying for authorization.
These updates are intended to streamline the procedure, ensure consistent interpretation of authorization requirements, and enhance compliance with the Customs Code and government resolutions.
Key Clarifications in the Questionnaire
Clause 1.1.3 – Designation of Responsible Employee
Enterprises must now designate one officially appointed employee responsible for customs-related issues.
This appointment must be formalized through an official order, instruction, or other administrative document issued by the company’s head.
Clause 1.1.8 – Substitution During Absence
Up to three employees may be identified as substitutes authorized to perform the duties of the main responsible person during temporary absences.
Their appointments must also be formally documented within the enterprise, and relevant information must be included in Clause 1.1.8 of the self-assessment questionnaire.
Specific Provisions for Individual Entrepreneurs
For individual entrepreneurs (IEOs) conducting customs brokerage activities independently, there is no requirement to designate substitute personnel.
In such cases, the entrepreneur should explicitly indicate in Clause 1.1.8 that:
“There is no need to identify replacement persons, as the activity is carried out by a single individual. In the entrepreneur’s absence, brokerage activity is not performed.”
Background and Legal Framework
This update follows the first issuance of brokerage authorizations under the new procedure on May 27, 2025.
The framework is based on amendments introduced to the Customs Code of Ukraine and the Cabinet of Ministers’ Resolution No. 1092 (dated September 27, 2022), as revised by Resolution No. 454 of April 15, 2025.
The modernization of brokerage authorization procedures aims to:
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Increase transparency and accountability in customs mediation;
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Simplify compliance for businesses and sole proprietors;
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Ensure alignment with EU customs standards and Ukraine’s ongoing integration process.
The State Customs Service emphasized that these clarifications are part of a broader effort to enhance procedural clarity for businesses engaged in international trade and to promote professionalization within the customs brokerage sector.
