HMRC's CDS report contracts expired 31 March 2026 — are you still using TRE?

By Saurabh Goyal, Founder & CEO of Phlo Systems. Published 10 August 2026.

Most finance and compliance teams never think about how they get their own customs declaration history back out of HMRC's systems — until the day they need it for an audit, a duty reclaim, or an origin verification, and the report they always used to pull it stops working. That is what happened on 31 March 2026: the legacy report contracts that let UK importers and customs brokers extract declaration data from the Customs Declaration Service (CDS) expired, and the Trade Reporting Extract (TRE) API became the only supported route to that data going forward.

The 30-second answer:

• What expired: the CDS report contracts inherited from the old MSS (Management Support System) reporting model, which many importers and brokers used to pull historical declaration data.
• What replaced it: the TRE API is now HMRC's sole supported route to official CDS declaration data — there is no fallback report format.
• Who is affected: any importer, exporter, or customs broker who relied on the old report contracts and has not integrated with TRE directly or through a declarations system that has.
• What breaks without it: pulling your own declaration history for a duty overpayment claim (C285), an HMRC audit request, or origin/preference verification — all of which start with "show us the declaration data."

Why this matters more than a routine system retirement

CDS itself has been live for several years, replacing the older CHIEF system for filing new declarations. That migration got attention because it changed how declarations go in. The 31 March 2026 deadline is different: it changes how declaration data comes back out. An importer who filed every declaration correctly on CDS can still be locked out of their own historical data if the reporting route they used to retrieve it no longer exists.

This distinction matters because the moments an importer actually needs bulk access to past declaration data are exactly the moments that carry the most financial or compliance weight:

• A duty overpayment claim (C285) under HMRC's Duty Reimbursement Scheme requires evidence of what was actually declared and paid on the specific entries being reclaimed.
• An HMRC compliance audit typically requests declaration history across a period, not a single entry, and expects it in a consistent, checkable format.
• Origin or preference verification, particularly under a free trade agreement, often needs to be reconstructed from historical declaration data to prove which rate applied and why.

If the only tool that used to produce that history is the retired report contract, none of these tasks have a working starting point.

What actually changed on 31 March 2026

	Old route (MSS-era report contracts)	Current route (TRE API)
How you got declaration data	Scheduled report contract, often set up years earlier	Direct API call against HMRC's TRE endpoint
Who typically held the contract	Whoever originally configured CDS reporting — sometimes the importer, sometimes the broker	Whoever has built or bought TRE integration
What happens if nobody re-integrated	Reports simply stop being produced — no error, no default fallback	N/A — this is the only route now
Format consistency	Varied by original contract configuration	Standardised API response

The practical risk is not a dramatic outage. It is quieter than that: a report contract that used to run quietly in the background simply stops, and nobody necessarily notices until someone asks for the data it used to produce.

Who is most exposed

Three groups carry the most risk from this transition, for different reasons:

1. Self-filing importers who set up CDS reporting once and never revisited it. If the original setup predates the person who now handles compliance, there may be no institutional memory that a report contract even exists, let alone that it expired.
2. Customs brokers managing declaration history on behalf of multiple clients. A broker relying on the old report contracts is exposed across their entire client book at once, not just one account — and a client asking for five-year-old declaration data for an audit will not accept "the report stopped working" as an answer.
3. Finance teams running duty recovery or overpayment reviews. A C285 claim is only as strong as the declaration evidence behind it. If that evidence cannot be pulled at all, the claim cannot be filed, regardless of how much duty is genuinely reclaimable.

What to check before your next reclaim, audit, or verification

1. Confirm who, specifically, is pulling declaration data today — not who was responsible when CDS first went live, but who actually runs the report or API call now. If the answer is "nobody's checked since the contract was set up," that is the finding.
2. Ask whether the retrieval path is TRE-based or a leftover report contract. A working report today does not confirm the underlying route; contracts can continue producing output right up until they silently fail.
3. Test retrieval against a real historical period, not just current-month declarations, before an audit or reclaim actually depends on it. A gap surfaces faster in a deliberate test than in the middle of a live HMRC request.
4. If a broker holds the reporting relationship, ask them directly whether their retrieval path has been migrated, and for which of your declarations. A broker migrating their own book does not automatically cover every client's historical contract the same way.

Frequently Asked Questions

What was the 31 March 2026 HMRC deadline?

It was the expiry of the legacy MSS-era report contracts that many UK importers and customs brokers used to extract historical declaration data from the Customs Declaration Service (CDS). After that date, the Trade Reporting Extract (TRE) API is HMRC's only supported route to that data.

Does this affect my ability to file new customs declarations?

No — filing declarations through CDS is unaffected. This deadline is specifically about retrieving historical declaration data, not submitting new entries.

How would I know if I am affected?

If nobody at your organisation (or your customs broker) can confirm that declaration-data retrieval runs through the TRE API rather than an older report contract, the safest assumption is that you have not verified it — and the way to find out is to actually try pulling a historical declaration, not to assume the old process still works because nothing has visibly broken.

Why does this matter for a duty overpayment claim?

A C285 overpayment claim to HMRC has to be evidenced against the specific declarations being reclaimed. If the tool that used to produce that declaration history has quietly stopped working, there is no data to build the claim from, independent of whether the underlying overpayment is real.

How Phlo Systems helps

tradePhlo's Declarations module integrates directly with CDS through the current API surface, including TRE, so declaration history stays retrievable as HMRC retires legacy reporting routes underneath it — not dependent on a report contract someone configured years ago and never revisited. For finance teams looking at duty recovery specifically, that same declaration history is the evidence base a C285 overpayment claim needs. See how tradePhlo handles UK customs declarations.

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Related reading:

• What is the UK Customs Declaration Service (CDS), and how do you submit an import declaration in 2026?
• What is landed cost, and why is my customs broker's number always wrong?

Saurabh Goyal is the Founder & CEO of Phlo Systems. He spent 12 years building CTRM and ERP systems for global commodity trading houses before founding Phlo in 2016.