Will AI replace customs brokers?

The declarant still answers for what is lodged in a customs declaration, however it was prepared; what AI changes is the preparation. Under the Union Customs Code, lodging a declaration makes the person concerned responsible for the accuracy and completeness of the information in it, and a customs representative who lodges it is bound by the same obligations [1]. Whether AI will replace customs brokers is a forecast this guide does not make. What it can set out is where the law puts the responsibility, and which part of the work that leaves open to software.

Who answers for a declaration

The Code names the roles. The declarant is the person lodging a customs declaration in their own name, or the person in whose name it is lodged [1]. A customs representative is any person appointed by another person to carry out the acts and formalities the customs legislation requires in that person's dealings with the customs authorities [1]. Any person may appoint one, either as a direct representative, acting in the name of and on behalf of another person, or as an indirect representative, acting in its own name but on behalf of another person [1].

The Code gives these roles to persons, and defines a person as a natural person, a legal person, or an association of persons recognised under Union or national law as having the capacity to perform legal acts [1]. Read this way, an AI customs broker is not a role the Code knows: software cannot itself be the declarant or the representative; the person using it can.

Three duties follow from lodging:

• Accuracy. The person lodging is responsible for the accuracy and completeness of the information, for the authenticity, accuracy and validity of the supporting documents, and, where applicable, for compliance with the obligations of the procedure [1].
• The debt. For release for free circulation, the declarant is the debtor, and under indirect representation so is the person on whose behalf the declaration is made [1]. Where a declaration is drawn up on information that leads to all or part of the import duty not being collected, the person who provided that information and knew, or ought reasonably to have known, that it was false is a debtor too [1].
• The documents. Supporting documents must be in the declarant's possession and at the disposal of customs when the declaration is lodged [1].

What AI customs brokerage can prepare

Most of a declaration is assembled from documents: the commercial invoice, the packing list and the transport document. That assembly is where software, AI included, can take on work:

• reading the documents and filling in the declaration's data from them;
• proposing a commodity code where the invoice line holds the facts the tariff classifies on, with the path that leads to it;
• noticing where it does not, and drafting the question for the supplier;
• keeping each figure next to the document line it came from.

Each of these produces a draft for the declarant. How to judge a proposed code is in the guide on AI customs classification, and what the declaration takes from the invoice is in the guide on the commercial invoice.

What stays with the declarant

The decisions the declaration records remain the declarant's: the code for a line the invoice leaves open, the value, the origin and whether a preference is claimed, and the decision to lodge. So does the answer when customs ask. To verify an accepted declaration, customs may examine the declaration and the supporting documents, require the declarant to provide other documents, examine the goods, and take samples [1]. Customs declaration AI can prepare the file for those questions; they are put to the declarant.

AI customs clearance is customs' decision

Clearance is not a step on the declarant's side. Where the conditions for the procedure are fulfilled, any restriction has been applied and the goods are not prohibited, the customs authorities release the goods as soon as the particulars in the declaration have been verified or accepted without verification [1]. Customs use automation too: the new Union Customs Code, which applies from 21 September 2027, defines risk analysis as the processing of data using, where relevant, analytical methods and AI systems as defined in the EU's Artificial Intelligence Act [2].

What the reform says about automation

Regulation (EU) 2026/2108 replaces the current code. It applies from 21 September 2027, and from 1 March 2034 importers, exporters and holders of the transit procedure must provide their data through the EU Customs Data Hub [2]. Representation stays: any person may still appoint a customs representative, direct or indirect, and an indirect representative acting for an importer established in the EU is jointly and severally responsible with that importer for the importer's obligations, which include providing the information for the procedure and ensuring payment of the duties [2].

On automation, the regulation is explicit. Acts performed by persons, the Commission, the customs authorities, the EU Customs Authority or other authorities using the functionalities of the EU Customs Data Hub remain the acts of those persons and authorities, even if they have been automated [2]. That provision has applied since the regulation entered into force, on 20 September 2026 [2]. The other dates of the reform are in the guide on the EU customs reform.

Athren prepares the case from the shipment email and proposes a code for clear lines; your declarant checks what is open and files it. Athren files nothing.