Preparations for a potential “no-deal” Brexit

While the chances of a “no-deal” Brexit on 31 October seem less likely following the prorogation of Parliament, it is still a possibility in the future. Charities may wish to take steps now to prepare for a possible “no-deal” Brexit.


HMRC is running a series of Brexit readiness events – full details can be found here.

Guidance on VAT for businesses if there’s no Brexit deal can be read here.

There is also guidance on getting your business ready to

HMRC is running webinars which provide an overview for UK businesses involved in the movement of goods between the EU and the UK – register here.

NCVO hosted a free webinar with DCMS on 11 September 2019 that explored areas where charities may be affected if the UK leaves the EU without a deal, suggesting practical steps that organisation may wish to take. The webinar can be watched here.

HMRC has confirmed that it plans to remove a key administrative burden for businesses who trade with the EU by auto-enrolling nearly 90,000 VAT-registered businesses with an essential Economic Operators Registration and Identification (EORI) trading number – further information on EORI numbers can be found below.

HMRC also published Brexit guidance for tax agents and advisers.

HMRC published two letters to VAT-registered businesses trading with the EU and/or the rest of the world explaining how to prepare for changes to customs, excise and VAT if the UK leaves the EU without a deal.

EORI number

You’ll need an Economic Operator Registration and Identification (EORI) number that starts with GB to move goods in or out of the UK if there’s no Brexit deal.

If you already have an EORI number that starts with GB, you can continue to use it. It will be 12 digits long. If you’re registered for VAT it will include your VAT registration number. You do not need an EORI number if you’ll only move goods between Northern Ireland and Ireland. If you’ll be dealing with EU customs then you’ll need an EU EORI number. Get this from the customs authority in the EU country you first conduct trade with or that you request a customs decision from.

To apply you may need your:

  • VAT number and effective date of registration – these are on your VAT registration certificate
  • National Insurance number – if you’re an individual or a sole trader
  • Unique Taxpayer Reference (UTR) – find your UTR if you do not know it
  • business start date and Standard Industrial Classification (SIC) code – these are in the Companies House register
  • Government Gateway user ID and password

If you do not already have a user ID, you’ll be able to create one when you apply.

It takes 5 to 10 minutes to apply for an EORI number and you can do so here. You’ll get it either:

  • straight away
  • within 5 working days (if HMRC needs to make more checks)

Transitional Simplified Procedures for customs

In a no-deal Brexit, UK businesses that import goods will need to apply the same procedures to EU trade that apply when trading with the rest of the world. Under import rules for trading with the rest of the world, goods are not released from customs control until you’ve made a full import declaration and paid customs duty in full.

One thing that has been introduced by HMRC is Transitional Simplified Procedures (TSP) for customs, which allows organisations to defer submissions until after goods have passed through customs. Transitional simplified procedures reduce the amount of information you need to give in an import declaration when the goods are crossing the border from the EU. They do this by letting you delay submitting a full declaration and paying any duty.

Organisations can register for TSP as long as they:

  • have an EORI number that starts with GB
  • are established in the UK, this means:
    • you’re a sole trader who is resident in the UK
    • your company or partnership has a registered office in the UK
    • your company or partnership has a permanent place of business in the UK where they carry out their business activities
  • are importing goods from the EU into the UK (including goods travelling through the EU from the rest of the world as long as they’ve cleared EU customs formalities)

You should not register if:

  • the only goods you import are coming into the UK directly from outside the EU
  • you choose to use a customs special procedure for your goods

If you already trade outside the EU and have a customs agent or software, you can use these to make declarations for your EU-UK trade. You can also choose to register for transitional simplified procedures, but check with your software provider or customs agent about any additional customs rules you’ll need to comply with after Brexit.