Authorised Economic Operator (AEO)


Authorised Economic Operator (AEO)

Application of special customs simplifications

The concept of Authorised Economic Operator was created to facilitate and improve customs declaration and clearance procedures. It is widely and successfully used in many jurisdictions, in particular, in the European Union, where over 17,500 companies operate under the AEO status (as of March 2020).

In Russia, the concept has become effective in 2012; however, when the Customs Code of the Eurasian Economic Union took effect in 2018, it changed significantly, both in terms of simplifications granted to AEOs and requirements for companies applying for the AEO status. Requirements and the available simplifications differ depending on the type of AEO certificate (currently, there are three types of certificates instead of one).

After a transition period ended on 1 January 2020, the AEO status is granted under the new rules only.

Benefits for AEOs

  • Low-risk status
  • Clearance of goods prior to declaration filing
  • Customs control procedures (inspections/checks) on a priority basis
  • Waiver of security deposit for customs payments (e.g., during customs value control or when a payment deferral is granted)
  • Special simplifications related to customs transit (for Type 1 AEOs) and customs operations on AEOs’ own sites (for Type 2 AEOs)

Key requirements for AEOs

  • Foreign trade record and volume (at least three years with at least 10 customs declarations/customs declarations worth EUR 500 thousand filed annually)
  • No outstanding customs and tax payments
  • No record of certain administrative or criminal offenses
  • Requirements for the inventory record keeping  system: separate accounting for operations with foreign goods, granting access (including remotely) to the customs authorities, security of the information system
  • Providing security (for Type 1 AEOs) or meeting the financial stability criteria (for Type 2 AEOs)
  • Meeting requirements for sites (for Type 2 AEOs)
  • Other requirements (simplified tax regime not allowed, no bankruptcy indicators, certain requirements for employees/vehicles, etc.)

Remote access to inventory record keeping system data

To be eligible for the AEO status, a company should meet specific criteria. The most complicated ones are those related to the inventory record keeping system (separate inventory accounting, remote access).

The Russian Federal Customs Service is currently piloting remote data exchange between information systems of the customs authorities and companies engaging in foreign trade activities. One of the tools that can be piloted in this project is datamart.

How Deloitte can help

  • Analyse the feasibility of obtaining the AEO status and assess its impact on business processes
  • Analyse your company’s eligibility for the AEO status
  • Assist your company in preparing and filing the AEO application and other required documents
  • Provide support in drafting and signing the agreement on simplifications with the customs authorities
  • Provide a datamart to meet the remote access requirement.

Deloitte also offers customs analytics tools to assess the company’s performance and compliance with the customs regulations, including by verifying the data submitted by customs representatives.

Key contacts

Yulia Orlova

Yulia Orlova

Partner, Tax & Legal

Yulia is a tax and legal partner at Deloitte CIS, leading the Manufacturing Industry Group, the Chemical Industry Group and the Japanese Service Group. Yulia joined Deloitte in 2002 from the Moscow Di... More

Tamara Arkhangelskaya

Tamara Arkhangelskaya


Tamara is a Tax Partner leading Deloitte Russia Indirect Tax team of 20 experts. Tamara has over 15 years of experience in advising a broad range of Russian and multinational businesses on complexitie... More

Ramil Shafigulin

Ramil Shafigulin

Manager, Tax & Legal

Ramil is a Manager at the Tax & Legal department of Deloitte CIS in Moscow. Prior to joining Deloitte, Ramil worked for one of the leading international law firms and another Big Four firm. Ramil focu... More