Recognition
Told you need a guarantee, not sure if that's still true
Since 1 January 2021, HMRC has waived the guarantee requirement for most UK-established businesses using a duty deferment account in Great Britain (see gov.uk's guarantee waiver guidance). If you've been told otherwise, the advice may predate that change.
Why it happens
Old guidance hasn't caught up with the 2021 change
Plenty of published content still describes duty deferment guarantees as mandatory across the board, because that used to be true. The rule changed; the content mostly hasn't.
Where this fits
The guarantee-specific question within Trade & Import Finance
See Trade & Import Finance for the wider picture, and Freight Forwarding for how this shows up sector-wide.
Specialist insight
What the waiver is actually tested on
Not just how long you've been trading. HMRC looks at the past 3 years: no serious or repeated customs or tax infringements, no serious criminal offences related to the business, and positive net assets excluding goodwill (see gov.uk guidance on duty deferment guarantee waivers). Fail any of those and a real guarantee is still needed to get a deferment account at all.
Decision helper
Your situationUsual outcomeNot this
UK-established, clean three-year record→Guarantee waived under the GB rules→Paying for an unneeded guarantee
Northern Ireland deferment account→Guarantee always required→Assuming the GB waiver applies
Fails the waiver test→A real guarantee, or use a forwarder's account→Applying without a guarantee
Where this tends to go wrong: failing the waiver test can read as a solvency judgement when it isn't one. The test also covers the business's customs and tax compliance record and any serious criminal offences, either of which can trip a financially strong business. Worth checking exactly which part of the test wasn't met before assuming the worst.
If you don't want your own account
The alternative to holding your own account: using a freight forwarder's existing deferment account on your behalf is normal, established practice, not a workaround. Whether that ends up cheaper or simpler than qualifying for your own account depends on volume, how often you're importing, and how much.
Who still needs a guarantee
In short: businesses that fail the waiver test (a serious or repeated customs or tax infringement in the past 3 years, a relevant serious criminal offence, or net assets that weren't positive), Northern Ireland deferment accounts regardless of the GB waiver, and non-UK-established traders, who don't qualify for the GB waiver at all.
Talk it through
Need another perspective?
You may already know which facility you think fits. The more valuable question is whether it's actually the right structure for what's happening in the business. We'll review the situation before suggesting possible routes. It costs nothing to have that conversation.
Thank you. It's with our team now.
A person reads every enquiry and we'll come back to you with what we think the right next step is. No obligation at any point.
Practical questions
Before you get in touch
What is a guarantee waiver?
HMRC's guarantee waiver lets a UK-established business run a GB duty deferment account without putting up a financial guarantee, provided that, over the past 3 years, it has had no serious or repeated infringements of customs or tax rules, no serious criminal offences related to its business activities, and positive net assets (excluding goodwill). Fail any part of that test and a real guarantee is still needed. See gov.uk's guidance on checking whether you can get a guarantee waiver.
What is a customs comprehensive guarantee (CCG)?
A CCG is a single guarantee covering customs duty, excise duty and import VAT across regular imports or transit movements, rather than guaranteeing one shipment at a time. A CCG is always required to run a duty deferment account in Northern Ireland, and it can be applied for alongside a duty deferment account in the same application. A business that does not get CCG authorisation can use individual guarantees to cover each customs debt instead. See gov.uk's CCG guidance.
What are duty deferment statements?
Duty deferment statements are the weekly statements HMRC sends showing the transactions deferred through your account, so you can check them before the monthly Direct Debit is taken. They're available through the Customs Declaration Service (gov.uk removed references to the retired CHIEF system in August 2024), and you get an email notification when a new one is ready. See gov.uk's guidance on getting copies of your statements.
What is a duty deferment account?
It's an HMRC account that lets you pay customs duty, excise duty and import VAT once a month by Direct Debit, instead of paying HMRC separately for every consignment as it arrives. GB accounts usually run guarantee-free under the waiver above; Northern Ireland accounts need a CCG regardless.
Is a premises guarantee the same as a duty deferment guarantee?
No. A premises guarantee is a separate HMRC security specific to excise warehouses, not to a duty deferment account. It covers HMRC against a chargeable loss on warehoused excise goods, and can itself be reduced or waived after a period with no claims against it and no significant irregularities (gov.uk describes no guarantee being needed after 4 consecutive years), on different terms to the deferment guarantee waiver above. See gov.uk's guidance on premises guarantees for excise warehouses.
How long does it take?
It varies by facility, so there isn't one number that fits every case. Some drawdowns against an existing facility complete within a day or two; arranging something new from scratch usually takes longer. We'll give you a realistic timeline once we understand your situation.
What information do I need?
To start, just a description of what’s actually happening in the business. If it progresses, the specialist partner will ask for the usual things: recent accounts, a sense of turnover and trading history, and details of the specific need.
