Authorised Economic Operators (AEO) Completion of the C118 for VAT Groups

Authorised Economic Operators (AEO) completion of the C118 for VAT groups.

Customs Information Paper 07 (2016)

Who should read: / All businesses who are intending to apply for AEO status.
What is it about: / AEO applications covering more than one legal entity (registered VAT Groups).
When effective: / Immediately
Extant until/ Expires / Until further notice

1. Introduction.

This Customs Information Paper (CIP) concerns the procedure for submitting AEO applications where the application covers more than one legal entity in a VAT group.

2. Background.

Current HMRC guidance requires the submission of a separate C117 application form for each legal entity within a VAT group, but allows for a single C118 Self Assessment Questionnaire (SAQ) covering all the customs related activities of the group.

Recent experience has shown that the submission of a single C118 for a VAT group can sometimes result in the omission of certain information related to the individual legal entities within the group. This can result in unnecessary delays in the processing of an application or even an initial rejection of an application.

An increase in the number of applications for AEO authorisation also makes verification of the application and the information provided challenging for the AEO Central Site and the auditors who will undertake the work.

3. Changes

To facilitate the processing of an application, the subsequent audit visit and to ensure that the decision can be made within the legal timelines, applicants for a VAT group are now encouraged to complete a separate C118 for each legal entity within the group. The C118 must always be signed by a person with the legal capacity to act for all of the legal entities covered by the C118. Otherwise, individual signatures will be required.

The facility to submit a single C118 for a VAT group will not be removed but applicants need to be aware that this is a facilitation only available to those VAT groups where the individual legal entities are applying the same corporate standards/procedures for their customs related activities. If this cannot be clearly demonstrated this is likely to lead to a delay in processing the application.

Please note that each individual legal entity within the VAT group must hold their own EORI number.

4. Further information

Information on AEO can be found here:

https://www.gov.uk/guidance/authorised-economic-operator-certification

Issued on 26 January 2016 by Customs Directorate, HMRC.

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