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2016 OAS Guidelines

Section VII: Recommendations for conducting an audit or supervision visit to an AEO of an EU Member State

One of the essential parts of negotiating the MRA with partner countries, as well as monitoring its implementation, is the AEO's on-site audit or monitoring visits.

The objective of the on-site visit is to observe how the EU AEO programme is practically implemented by the different EU Member States. These visits are carried out as part of the negotiations of the ARM (Phase 2) and as part of the implementation of the ARM once it has entered into force.

Overall, the main focus is on ensuring that EU Member States comply with EU legislation on AEOs in a uniform manner.

The visit consists of two parts: Firstly, a presentation of the national structure and organisation of the AEO and an overview of the company to be visited, and secondly, the actual visit to the company.

Debate on the implementation of the EU AEO programme in the Member States

The main interest is to see how the AEO programme is implemented from an operational point of view in the Member States.

It should include a brief summary of:

  • Customs Administration in general;
  • the organisational structure of the AEO, e.g. the number of staff members dedicated to the EU AEO (full-time and part-time, the training system, outreach to the business community);
  • the authorization procedure, including the application and self-assessment questionnaire, the way of checking the security requirements;
  • monitoring and post-audit;
  • cooperation with other EU Member States (during authorisation and monitoring).

Company visit

The purpose of the company visit is to observe Member States' AEO auditors conducting an audit at an applicant's premises or a supervisory visit to an AEO company. Representatives from the ARM partner country, the Commission, and the customs administrations of the EU Member States will participate in the visit.

It is essential that companies understand the purpose of the exercise and that the objective is to confirm that the application of the AEO in the visited Member State complies with EU standards.

The visit to the applicant's or AEO company's premises is usually structured as follows:

  • The visit will consist of an audit of a genuine situation conducted, in particular, by the AEO auditors, not by the company;
  • The company will be informed in advance of the visit and how it will be carried out;
  • The auditors will perform their normal duties;
  • In case of audit during an AEO request:
  • In the case of a follow-up visit (with an existing AEO authorization), questions will be asked about recent developments that have had an impact on AEOs and the company will be asked to explain or demonstrate the security procedures;
  • If a translation is required, time will be allowed to translate the content of the auditors' questions and the company's responses. The company will be informed in advance of this approach;
  • Observers (from the ARM partner country) will only have a snapshot of the EU AEO audit and oversight process;
  • The validation visit will conclude with recommendations to the applicant;
  • The audit exercise should focus on safety and security (Section 2.V of these Guidelines).