New requirements for customs agents: data quality and documentation are becoming even more important
As of September 1, 2026, freight forwarders and customs brokers must meet stricter requirements. The reason for this is the new Section 4d of the Tax Advisory Services Act (StBerG). For the first time, this provision establishes a clear legal basis for the provision of assistance in customs matters by logistics service providers and customs brokers. At the same time, it raises the requirements for professional competence, documentation, and continuing education.
In the future, customs brokers, freight forwarders, and logistics service providers must be able to demonstrate that the employees responsible for customs-related activities possess sufficient qualifications and regularly update their knowledge. If the necessary technical, personnel, or organizational requirements cannot be demonstrated, restrictions on the provision of such services may apply.
While this may at first glance seem to affect primarily freight forwarders, it highlights a trend that is already a concern for many companies today: Decisions regarding customs law must be documented in a traceable manner and consistently justified within the company itself. Standardized processes and a robust database are essential prerequisites for this.
In this article, you’ll learn about the requirements set forth in Section 4d of the StBerG and how companies can design their customs and compliance processes to be efficient, transparent, and legally compliant.
At a glance
- Section 4d of the StBerG introduces stricter legal requirements for customs agents and freight forwarders.
- Companies must document their specialist knowledge and continuing professional development.
- Inaccurate data increases the risk of compliance breaches and incorrect decisions.
- SAP-integrated solutions help companies to implement customs and compliance requirements efficiently.
1. What changes will Section 4d of the Tax Advisers Act bring about?
Until now, customs representation has operated in a legal grey area: whilst many freight forwarders and logistics service providers were already assisting their clients with customs-related activities, there was no clear legal basis for this.
With Section 4d of the StBerG, the legislator is now providing legal certainty, whilst linking the provision of assistance in customs matters to clear requirements regarding specialist knowledge, further training, and personnel and organisational conditions. The service providers concerned must be able to demonstrate that they meet these requirements.
For businesses, this means that customs-related processes must be documented with a clear allocation of responsibilities in order to avoid ambiguous liability issues.
Customs-related decisions must be documented in a traceable manner and, where necessary, justified to the authorities or business partners. Consistent master data, transparent processes and traceable documentation are essential for this.
2. Why the new requirements demand more than just specialist knowledge
Customs-related activities involve far more than simply completing the customs declaration.
Rather, companies must make a multitude of decisions on a daily basis, based on expert assessments and accurate data. These include, for example:
- Classification of goods
- Verification of export control regulations
- Determination of preferential treatment
- Preparation of customs declarations
Incorrect or inconsistent data can lead to erroneous decisions, increased audit workload and compliance risks.
As Section 4d of the StBerG raises the requirements for professional competence and verifiability, it must be possible in future to document and justify decisions even more effectively. This requires consistent master data and standardised processes. Only on this basis can customs assessments be made in a legally compliant manner and, where necessary, substantiated in a traceable way.
Example: Incorrect tariff classification
Incorrect classification of goods can have implications for customs duties, export controls, preferential trade arrangements and customs declarations. This makes it all the more important to document the underlying decision in a way that is transparent and traceable.
3. SAP-supported processes create transparency and traceability
To meet the increased demands for documentation, transparency and data quality, companies need standardised processes and a centralised database.
Many companies still rely on disparate data sources, manual processes or siloed solutions. This results in data inconsistencies, which make it difficult to trace decisions.
Integrating relevant foreign trade and compliance processes directly into SAP, on the other hand, ensures greater transparency and a uniform data foundation. Information is maintained centrally and can be utilised across different processes.
This enables decisions to be documented in a traceable manner, workflows to be standardised and compliance requirements to be implemented more efficiently.
4. How Mercoline helps
To meet the growing demands for transparency, traceability and standardised processes, many companies rely on end-to-end support for their foreign trade and compliance processes within the SAP system. This is precisely where Mercoline comes in.
With the M.SecureTrade Suite, Mercoline offers solutions for key customs and trade compliance processes. These include, amongst others, tariff classification, export control, sanctions list checks, preferential trade management and customs clearance.
The individual trade compliance modules draw on a unified master data base. This means, for example, that information from tariff classification can be reused in downstream foreign trade and compliance processes. At the same time, checks can be automated, decisions documented in a traceable manner and manual effort reduced.