Key Discussion Points
The discussion, moderated by Vita Miroshnychenko, Director and Head of Customs Regulation and International Trade Practice at PwC Ukraine, centred on:
- Setting up and adapting business processes to secure authorisations;
- Common mistakes and pitfalls in preparing for AEO status;
- Typical application shortcomings leading to rejection or refusal of authorisation;
- Actions to take if issues are found during AEO monitoring;
- The procedure and implications of suspending authorisation—either voluntarily or by customs decision.
Key Questions Answered by Ukraine's State Customs Service
Communication with our guest speaker, Andrii Teplyi, Deputy Director of the Department and Head of the AEO and Simplifications Unit, Department of Authorisation, Administrative Services and Control, State Customs Service of Ukraine, proved valuable for businesses. Mr. Teplyi provided detailed answers to various questions, including:
Do you need to demonstrate an understanding of the use of simplifications and future accounting at the AEO assessment stage?
Yes. It is necessary to demonstrate awareness and readiness to use simplifications, even if they have not yet been applied. The responsible person must understand the logic of the processes, as well as present the concept of future goods accounting.
Does the customs authority have expectations regarding the audit trail and data format?
Yes. The presence of a clear audit trail is expected. The company's accounting system must reflect the entire chain of transactions with goods, with references to primary documents, ensuring continuous tracking and confirmation.
How to confirm that employees are familiar with the procedures and record procedure reviews without changes?
Enterprises independently determine their internal procedures for familiarising employees with applicable documents. In practice, for small enterprises, written acknowledgement of a relevant management order is usually sufficient. By contrast, larger companies—with sizeable workforces and procedures that may be centrally updated by a parent company—tend to implement more advanced, technologydriven approaches. These may include the use of specialised software, email systems or other digital platforms.
What changes in the company's activities is the company obliged to inform the customs authority about after receiving authorization?
All changes affecting the conditions and criteria for AEO authorization (changes in the accounting system, financial condition, responsible person, or extraordinary events, etc.) should be reported. Changes that do not affect the criteria do not need to be reported.
PwC Ukraine continues to foster constructive dialogue between businesses and the state, aiding the development of effective customs practices and enhancing the competitiveness of Ukrainian enterprises globally. The B2G dialogue format is instrumental in facilitating this exchange.
Stay informed by following our announcements and engaging with the PwC Ukraine Customs Regulation and International Trade team: https://www.pwc.com/ua/en/services/tax/customs.html
Contact us
Vita Miroshnychenko
Director, Head of Customs and International Trade practice, PwC in Ukraine
Tel: +380 44 354 0404
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