HMRC: State Aid Customs Duty Waiver Reporting Requires Beneficiary Details

• Businesses in Northern Ireland must report non-customs de minimis state aid to HMRC online, separate from Customs Duty waivers.
• Undertaking administrators must confirm beneficiary details for all businesses within their undertaking via the Customs Duty Waiver Online Service between September 14 and September 25, 2026.
• Failure to confirm beneficiary details by September 25, 2026, will prevent businesses from using the Customs Duty Waiver Scheme.
• De minimis state aid allowances are generally 300,000 euros over three rolling years, but vary by sector and apply to the entire undertaking.
• All undertakings must select a NACE sector classification on the Customs Duty Waiver Scheme digital service, a requirement introduced in December 2025.

Between 8am on September 14, 2026, and September 25, 2026, administrators must log into their Customs Duty Waiver Online Service accounts.

Businesses operating in Northern Ireland, particularly those involved in the Customs Duty Waiver Scheme, face updated reporting obligations concerning state aid. While HMRC automatically records de minimis state aid received through Customs Duty waivers, undertakings must actively report all other forms of de minimis state aid. This includes financial assistance such as subsidised contracts, loans, or grants from bodies like Invest NI or NI Direct, which are unrelated to Customs Duty waivers.

These reporting duties apply to businesses that have claimed Customs Duty waivers for goods brought into Northern Ireland from Great Britain (England, Scotland, and Wales) or from countries outside the UK and EU. The online service provided by HMRC is the designated platform for reporting these non-customs de minimis state aid payments and for viewing an undertaking's overall state aid allowance. The responsibility for ensuring accurate reporting and compliance rests with a designated 'undertaking administrator,' who must have the necessary authority and access to information for all businesses within their undertaking.

A significant administrative requirement is fast approaching for undertaking administrators. Between 8am on September 14, 2026, and September 25, 2026, administrators must log into their Customs Duty Waiver Online Service accounts. During this period, it is mandatory to verify and confirm the beneficiary details for every business operating under their undertaking.

Failure to confirm these beneficiary details by the September 25, 2026, deadline will result in businesses within that undertaking being unable to utilise the Customs Duty Waiver Scheme until the required information is accurately provided. Should any beneficiary details appear incorrect, administrators are advised to contact HMRC promptly via email at customs.duty-waivers@hmrc.gov.uk. It is important to note that the fundamental process for claiming a Customs Duty Waiver itself will remain unchanged.

The total amount of de minimis state aid an undertaking can claim, encompassing both Customs Duty waivers and other forms of de minimis aid, is subject to specific HMRC state aid allowance limits. For the majority of businesses, this allowance is capped at 300,000 euros over a rolling three-year period. However, certain industry sectors may be subject to lower allowances or different subsidy calculation methods, necessitating careful review of applicable limits.

In a move to enhance transparency and compliance, the Customs Duty Waiver Scheme digital service was updated in December 2025. This update now mandates all undertakings, whether new registrants or those already registered, to select a specific sector that accurately reflects their operations. This selection aligns with the Statistical Classification of Economic Activities (NACE) as outlined on the ShowVoc website. Undertakings that have not yet completed this NACE sector classification will be prompted to do so upon signing in, and failure to select a specific sector will prevent the undertaking from using the waiver until this requirement is met. HMRC is legally bound to ensure transparency, requiring limited information on state aid awards under the Customs Duty Waiver Scheme to be publicly accessible.

Source: HMRC guidance on state aid reporting.