AEO and distance sales: fewer customs guarantees in the EU from 2026

Key data

If your company has Authorized Economic Operator status and sells at distance in the EU, this regulation frees up capital for you. The Commission Implementing Regulation (EU) 2026/2403, published on 29 October 2026, amends Regulation 2015/2447 —the rules for the application of the Union Customs Code— by reducing the global guarantees that AEO must deposit to operate in cross-border distance sales.

The second change affects the data elements that must appear in customs declarations in relation to the Union management fee. Both amendments are technical but have direct consequences for the liquidity and administrative burden of certified companies.

What does this regulation establish?

Regulation 2026/2403 introduces two specific changes to Regulation 2015/2447:

In practical terms: AEO selling at distance will have to provide less capital as a guarantee to customs authorities, and must update the data fields they include in their customs declarations to reflect the new requirements of the Union management fee.

Economic and operational impact

The reduction in global guarantees has a direct effect on the liquidity of AEO companies. Customs guarantees are funds or guarantees that are immobilized while operations are processed; reducing them means that capital can be allocated to other business needs.

• Lower capital immobilization: AEO companies in distance sales will be able to release funds that were previously blocked as a guarantee to customs.
• Competitive advantage over non-AEO: Companies without AEO certification do not benefit from this reduction, which widens the operational cost gap between both profiles.
• Update of declaration systems: The change in data elements of the Union management fee requires adapting ERP or customs management systems to include the new required fields. Failure to do so may cause issues in declarations.
• Special relevance for cross-border e-commerce: The impact is greater for e-commerce companies that make frequent shipments within and outside the EU, where guarantees accumulate more rapidly.

Who does it affect?

• Authorized Economic Operators (AEO) conducting distance sales within the EU or to third countries.
• Cross-border e-commerce companies with AEO certification that manage significant volumes of international shipments.
• Customs and logistics departments of AEO companies that must update their customs declarations with the new data elements of the Union management fee.
• CFOs and financial directors of AEO companies, who must recalculate required guarantees and release excess immobilized capital.
• Companies without AEO certification operating in distance sales: not directly affected, but the change reinforces the economic incentive to obtain AEO accreditation.

Practical example

Imagine a Spanish e-commerce company with AEO certification that sells products to end consumers in France, Germany and Poland. Until now, it had to maintain a high global guarantee with customs to cover potential tariff duties on its continuous shipments.

With Regulation 2026/2403, that global guarantee is reduced. If the company had, for example, €200,000 immobilized in bank guarantees as a customs guarantee, the new regulation allows it to reduce that amount —releasing liquidity that can be reinvested in inventory, marketing or expansion to new markets.

At the same time, its operations team will need to review customs declaration templates to incorporate the new data elements required for the Union management fee, avoiding rejections or issues in future clearances.

What should companies do now?

1. Verify if you have active AEO certification: Only companies with current AEO status benefit from the guarantee reduction. If you don't have it, evaluate the accreditation process with the Tax Agency (AEAT).
2. Review the amount of your current global guarantees: Contact your customs broker or customs advisor to recalculate the level of guarantee required after Regulation 2026/2403 enters into force.
3. Request the reduction or adjustment of bank guarantees: Once the new guarantee level is confirmed, process with your bank the reduction of the guarantee or security deposited, thus releasing liquidity.
4. Update customs declaration systems: Coordinate with your IT team or customs software provider the incorporation of the new data elements required for the Union management fee.
5. Train your operations and customs team: Ensure that the people managing customs declarations know the new required fields to avoid errors in clearances.
6. Evaluate AEO certification if you don't have it yet: If your company conducts cross-border distance sales with significant volume, the guarantee reduction offered by AEO status represents real financial savings that justify the accreditation process.

Official source

Consult full regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602403