Customs Broker explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
A customs broker licence is tied to the qualified people behind it. Regulations 11 to 13 of the Customs Brokers Licensing Regulations, 2018 say what must be done when a firm or company changes its constitution, when a sole proprietor changes to a firm or dies, and how the broker may engage staff, who gets an F, G or H card, and who may sign documents.
This article reads them as amended up to the CBIC text updated 24 June 2022, which carries Notification No. 8/2019-Cus. (N.T.) dated 6 February 2019, Notification No. 62/2021-Customs (N.T.) dated 23 July 2021 and Notification No. 52/2022-Cus. (N.T.) dated 24 June 2022. No later amendment was found up to 3 October 2026. Later notifications should be checked.
A firm or company whose constitution changes so that its licence becomes invalid must report it forthwith and apply afresh within sixty days. If the examined partner, director or authorised employee dies or retires, a replacement who has passed the examination may be named, or a G card holder may be authorised to pass the examination within two years. A broker may employ any number of persons after verifying them, each of whom must pass a written test within four attempts to earn a G card, and only F or G card holders may sign bills of entry and shipping bills.
Change in constitution of a firm or company (regulation 11)
11(1). Where a firm or company licensed under the regulations undergoes a change in constitution that makes the holding of the licence invalid in view of the condition in regulation 7(2)(b) (that at least one director, partner or authorised employee has passed the regulation 6 examination), even though the examined person continues in engagement, the firm or company must report the change forthwith to the Commissioner and make a fresh application within sixty days of the change. The Commissioner may, if there is nothing adverse, grant a fresh licence.
11(2). The new application is subject to the same regulation 7(2)(b) condition. Proviso: if the licensee itself moves an application for such changes, it may be allowed to carry on business with the Commissioner's approval until a decision is taken on the fresh application.
11(3). Where a licence has ceased to be in force because of the death or retirement of the partner, director or authorised employee who passed the examination, the firm or company may apply to replace that name with another partner, director or authorised employee who has passed the examination.
- First proviso. If there is no such person, the firm or company may authorise any other partner, director or authorised employee who is a G card holder (as in regulation 13(5)) to pass the examination within two years from the death or retirement, and may carry on business with the Commissioner's approval until he passes.
- Second proviso. If the G card holder has appeared in the written examination within those two years, the period to clear the examination is deemed extended until the declaration of the result.
Example: Konkan Clearing Services Private Limited has a licence resting on its director Mr A, who passed the examination. Mr A retires. The company applies to replace his name with Ms B, an authorised employee who has also passed the examination. If no one has, it authorises Ms C, a G card holder, to pass the examination within two years of Mr A's retirement. If Ms C sits the written paper within those two years but the result is awaited when the period ends, her time is deemed extended until the result is declared.
Change in the constitution of a concern (regulation 12)
12(1). If a licence granted or renewed in favour of a person who is not a firm or company changes the constitution of his concern to a firm or company, the new firm or company may, pending a fresh licence, act as customs broker through an employee duly qualified under regulation 6, with the Commissioner's approval.
12(2). If the licence has ceased to be in force because the licensee died, his legal heir who is a major and a G card holder may be permitted to work as a customs broker with the Commissioner's approval, and must pass the regulation 6 examination within two years from the date of death.
- First proviso. If the G card holder has appeared in the written examination within the two years, the period is deemed extended until the declaration of the result.
- Second proviso. If the G card holder does not meet the educational qualification in regulation 5, relaxation is allowed only if he has held the G card for a minimum of five years before the licensee's death.
Compare regulations 11 and 12: regulation 11 is for firms and companies, while regulation 12 is for a licence held by a person other than a firm or company. In both, continuation of business is by approval of the Commissioner, not by right.
Engagement and employment of persons (regulation 13)
| Sub-reg | Rule |
|---|---|
| 13(1) | A person who has qualified in the regulation 6 examination may engage himself in clearance work for a licensed firm or company |
| 13(2) | A customs broker licensed under regulation 7(2) is issued a photo identity card in Form F by the Deputy or Assistant Commissioner. For a firm or company licence, the F card goes to the person or persons who actually passed the examination |
| 13(3) | A broker may, according to the volume of his business, employ any number of persons (other than F card holders) to assist him after verifying antecedents and identity at the declared address with reliable, independent, authentic documents. The employee must hold an Aadhaar number and a minimum qualification of 10+2 or equivalent |
| 13(4) | The employment is made only with the approval of the Deputy or Assistant Commissioner, who considers antecedents and character |
| 13(5) | The employee must, within four attempts from the date of appointment, pass a written examination conducted by the Deputy or Assistant Commissioner on the provisions under which goods and baggage are cleared, and on passing is issued a photo identity card in Form G |
| 13(6) | A G card holder moving to another customs broker may, with the approval or no-objection of the Deputy or Assistant Commissioner, be exempted from passing the examination again |
| 13(7) | The broker shall authorise only an employee holding an F or G card to sign the declaration on bills of entry, shipping bills, annexures and other documents generated in proceedings |
| 13(8) | Where he has authorised an employee to sign documents, he files a written authority with the Deputy or Assistant Commissioner of each customs station and gives prompt written notice of any modification or withdrawal |
| 13(9) | A photo identity card in Form H is issued to every person employed who has not passed the examination, for five years; minimum qualification 10+2 |
| 13(10) | Every card holder carries the card at the customs station and produces it on demand |
| 13(11) | Any change in persons holding F, G or H cards and actually engaged at the station must be communicated forthwith; no one other than F, G or H card holders may work as an authorised employee |
| 13(12) | The broker must supervise the conduct of employees and is responsible for all their acts or omissions during employment |
Regulation 13(9) refers to the examination "referred to in sub-regulation (4)"; the examination for G cards is in sub-regulation (5). Read the cross-reference with that in mind.
The employer's responsibility in 13(12) is the most important point for brokers, and it sits alongside the duties in regulation 10 and the action regulations in regulations 14 to 21. Because the broker is held responsible for employees' acts, supervision and documented training are a compliance necessity, not an option. Our compliance advisory team can help brokers build a staff register that tracks card type, test attempts, authorisation filings and approvals for each customs station.
Need help with customs broker staffing and compliance?
If a partner has left, a director has retired or you are onboarding new clearing staff, our compliance advisory team can plan the replacement, the sixty-day fresh application and the card and authority filings.
Key takeaways
- A change in constitution that invalidates the licence must be reported forthwith, with a fresh application within sixty days.
- On death or retirement of the examined person, replacement is possible, or a G card holder gets two years to pass the examination.
- A sole licensee's legal heir who is a major and a G card holder may continue and has two years to pass.
- Employees are engaged with approval; they must pass the G card test within four attempts.
- Only F or G card holders may sign customs documents; H card holders are those who have not passed.
- The broker answers for everything his employees do.
Read next
- Regulations 8-10: bond, surrender, validity and obligations
- Regulations 14-21: suspension, revocation, penalty and appeal
- Customs broker licence: CBLR 2018
Disclaimer: Based on the customs regulations named above as published on the CBIC Tax Information Portal or in the Gazette and, for sets amended since 2023, the amending notifications (read through a TaxClue consolidated reading text; no official consolidated text exists), as consulted on 3 October 2026. Later notifications, fees and the Customs Act, 1962 provisions referred to should be checked. This article is general information, not legal advice; check the official text before acting.