Information for Individually Licensed Customs Brokers about The CE Requirement

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Register Here for Government Continuing Education Activities

Background: Continuing Education for Licensed Customs Brokers Final Rule and FRN

Recordkeeping Requirements for Brokers Regarding Continuing Education

The Broker Management Branch will not ask all 13,500+ brokers to prove they have taken the CE credits. There will be an audit with a percentage of brokers chosen to show their records once the triennial reporting period has ended. This will be after March 2027.

The current triennial period ends January 31, 2027. CBP gives brokers the month of February 2027 to file the TSR, which includes a section on completing the CE credit hours.
Please see below for what information you need to keep for your continuing education records from the regulations.
Please note that where it states you need to keep documentation from the provider or host, this includes, The Continuing Education Code.

The information below is pulled from the Code of Federal Regulations. A spreadsheet with this information would be a good way to keep a record of your CE credits. Also, a file folder on your computer with any completion certificates would be a good idea.

Title 19 —Customs Duties

Chapter I

U.S. Customs and Border Protection, Department of Homeland Security;
Department of the Treasury

Part 111 - Customs Brokers

Subpart F - Continuing Education Requirements for Individual Brokers
https://www.ecfr.gov/current/title-19/chapter-I/part-111/subpart-F/section-111.102

General. Individual brokers who are subject to the continuing broker education requirement must retain the following information and documentation pertaining to the qualifying education completed during a triennial period for a period of three years following the submission of the status report required under § 111.30(d):
1. The title of the qualifying continuing broker education attended;
2. The name of the provider or host of the qualifying continuing broker education;
3. The date(s) attended;
4. The number of continuing education credits accrued;
5. The location of the qualifying continuing broker education; and
6. Any documentation received from the provider or host of the qualifying continuing broker education that evidences the individual broker's registration for, attendance at, completion of, or other activity bearing upon the individual broker's participation in and completion of the qualifying continuing broker education.
Availability of records. In order to ensure that the individual broker has met the continuing broker education requirement, upon CBP's request, the individual broker must make available to CBP the information and documentation described in paragraph (d)(1) of this section on or before 30 calendar days from the date of receipt of CBP's request. CBP can request that the information and documentation be made available for in-person inspection or be delivered to CBP by either hard-copy or electronic means, or any combination thereof.

Activities that Qualify for Continuing Education Credit

Additional Resources

Question of the Week

Have a question? Please submit it to: ContinuingEducation@cbp.dhs.gov.

See below for some frequently asked questions about the broker continuing education requirement. This section of our website will be updated periodically as we receive more questions.

Question: I am both a licensed customs broker and a licensed attorney. I already have continued education requirements for my law license. Based on the five currently approved providers, it’s unclear if any of their courses will be approved for the continuing legal education (CLE) required for US lawyers. Will there be any opportunity to attend courses that can count for both requirements? Can CLE courses related to US imports or trends in trade compliance related to imports be eligible to petition for continued ed for LCBs?

Answer: Unless an educator gets their course accredited for Continuing Education credit from one of the five accreditors, it cannot count for CE credit.

Question: Can an individual broker obtain all the required continuing education credits in one year or do they have to be spread over all three years?

Answer: The 36 continuing education credits can be completed at any time during the triennial period. The new regulations also do not require individual brokers to fill the 36 continuing education credits with specific trainings.

For example, if a broker wants to attend a week-long trade conference sponsored by the U.S. Government, an association, or a private company, that conference will likely cover, or come close to, covering the 36 hours for that reporting period. If instead a broker wants to obtain their education in smaller units that does not involve travel, hotel stays or time away from their workplace, they could choose shorter, virtual options like webinars and online courses.

The purpose of the regulatory requirements as finalized is to encourage individual brokers to seek the trainings, educational activity, and topics that best suit their needs during each triennial period.

CBP encourages individual brokers to “take stock” of the activities they already do that would likely qualify for continuing education credit and continue attending trainings, conferences and webinars involving customs business that provide them knowledge and value.

Question: I am an active broker, and I am about to leave my company to work for another company where I will also be an active broker. Is my current employer required to report my continuing education credits I’ve earned this triennial period to my new employer?

Answer: No. Earning credits, recording credits, and maintaining documentation of credits earned is your responsibility as the individual licensed broker. If employers maintain a system for their brokers to record and maintain their credits, that is fine, but when an employee leaves one company to work at another, it is not the responsibility of the old employer to communicate with the new employer on continuing education credits.

Question: I own a brokerage with a corporate license, and I am the individual license holder. I am the only license holder in my company as well. Would I have to complete the new continuing education requirements for my individual license only, or would I not need to complete any at all?

Answer: As an individual license holder, you will be responsible for completing the continuing education requirement each triennial period.

Question: My association is having a Lunch-and-Learn for our local brokers. I submitted my activity to an accreditor, and it was approved for 1 hour of continuing education. A guest speaker will come talk to us about how to submit an allegation of dumping under EAPA. At the last minute, my speaker had to cancel. A new speaker can take her place, but the new speaker will be presenting on importation and how to identify and report potential fentanyl smuggling. Can the attendees still get credit for coming to my association’s activity?

Answer: Further instructions are coming soon from CBP regarding what to expect in the event a speaker for an approved accredited activity is changed last minute. Expect that if the course’s content is still relevant to the work of a licensed customs broker, it will still qualify for credit.

Question: If I create a training course, can I earn credit for the work I put into the course creation?

Answer: Yes, with some limitations. An educator may only claim one credit hour for preparing the training, regardless of how long you spent in preparation or how long the training is. Per triennial period, you may claim a combined total of 12 credit hours spent preparing training materials. This is contained in §111.103(b). CBP created this limitation because we want individual brokers to also seek out education opportunities, not just conduct training. We recognize that preparing training does have a benefit, particularly if it is internal company training where compliance is an important factor in operations. As an instructor, you can get some continuing education credits, but you cannot have instruction constitute all 36 credits in one triennial period.

Question: If I don’t file my TSR or complete my continuing education. Will CBP suspend my license?

Answer: Yes. Under § 111.30(d)(4), if a broker fails to file the TSR by March 1 of the reporting year, the broker's license is suspended by operation of law on that date. By March 31 of the same reporting year, CBP will transmit written notice of the suspension to the broker by certified mail, return receipt requested, at the address reflected in CBP records. If the broker files the required report and pays the required fee within 60 calendar days of the date of the notice of suspension, the license will be reinstated. If the broker does not file the required report and pay the required fee within that 60-day period, the broker's license is revoked by operation of law without prejudice to the filing of an application for a new license. Notice of the revocation will be published in the Federal Register.

The new continuing education requirement follows the same timeframe as the TSR, for convenience of reporting and tracking, but it is not directly tied to the TSR. If you fail to file your TSR, then CBP follows the procedure above contained in § 111.30(d)(4). If you take corrective action within the 60-day period, then your license is no longer suspended. If you fail to complete and certify your continuing education credits, then you follow the procedures outlined in § 111.104. You will receive notice of failure to report (§ 111.104(a)). You will then have 30 days to respond to CBP with a corrective action (§ 111.104(b)). If you fail to act, your license will then be suspended (§ 111.104(c)). You will then have 120 days from the suspension date to take the corrective action to complete and certify your continuing education (§ 111.104(d)); otherwise, your license will be revoked, and you’ll need to apply for a new license. If it has been more than three years since you’ve passed the Customs Broker License Exam, you would need to retake the exam as well.

Question: Is there an email list or newsletter that brokers can sign up for to be kept aware of training and educational opportunities?

Answer: CBP plans on using this website to keep brokers up to date on CBP offerings, PGA offerings, and links to the accreditors' websites for their lists of approved activities. Bookmark this page and please visit often!

Question: Will the ACE Biweekly meetings count toward the continuing education requirement to complete at least 36 continuing education credits per triennial period?

Answer: No, they will not. Based on the accreditation parameters determined by CBP’s selected accreditors, government-led meetings such as COAC, ITAC, TSN, and Biweekly Trade Meetings will not qualify for accreditation.

Question: Can anyone in our company, including our owners and officers, participate in continuing education for credit or is it only for our in-house brokers?

Answer: The continuing education requirement is mandatory for individual licensed customs brokers. The requirement does not apply to the corporate or organizational license. If you are the qualifier for the corporate or organizational license, then you hold an individual license, and the continuing education requirement applies to you.

If non-licensed employees would like to take part in the same continuing education activities as license holders, there is no CBP-mandated restriction in participating. Since only individual licensed brokers have a continuing education requirement, only these participants would receive continuing education credit. For example, a company may hold a training session that covers customs business, but all employees working in customs activities, whether they hold a license or not, would benefit from taking the training. However, only employees with a customs broker license would get credit for their continuing education requirements.

As another example, multiple employees could all benefit from participating in a CBP webinar on classifying a certain commodity. Unless accredited private-sector activities have an explicit restriction on who can participate, attendance is open to all; but only the individual license holders will need or want to count it as continuing education credit, since they are the one with the requirement.

Question: I just passed the Customs Brokers License Exam and will soon be submitting my application to become a broker. Will the continuing education requirement apply to me?

Answer: Yes, but only after the 2027 Triennial Reporting cycle is complete. You will need to obtain, record, and report the continuing education credits you receive from January 2027 to January 2030 in your 2030 Triennial Status Report.

Per 19 CFR 111.102, individual license holders do not need to complete continuing education when they have not held their license for an entire triennial period at the time of the status report. If you receive your individual license between now and 2027, you will not need to obtain any continuing education credits. However, even though credits are not required, CBP encourages new brokers to take full advantage of the many opportunities available online and in-person to enhance their professional credentials in the field of customs business. New brokers should also adhere to their company’s training policies, if applicable.

Question: I own a brokerage with a corporate license, and I am the individual license holder. CBP says that corporate license holders do not have a continuing education requirement. Is this correct?

Answer: Yes, the new continuing education requirements apply only to individual license holders. Corporate, or organizational, licenses do not have a continuing education requirement under 19 CFR Part 111 Subpart F.

Education at the corporate level is already one of the factors that is considered under Responsible Supervision and Control under 19 CFR 111.28(a)(1). This employee training was a factor considered under Responsible Supervision and Control for several decades.

Question: Will training taken in January 2027 count toward the 2027 triennial submission? Can that same training be counted again in the 2030 triennial submission?

Answer: CBP will provide additional guidance on this upcoming situation as the date draws closer.

Once you have submitted your triennial status report in eCBP, any course you take after that will count toward the credit for the next triennial period.

Please note: for the 2027 triennial period, only those activities that have occurred after the Federal Register Notice has published will be considered eligible for credit.

No activity will receive credit in two different triennial periods.

Question: We are interested in becoming a partner with CBP to administer continuing education courses for licensed customs brokers as an accredited partner. Will CBP partner with licensed customs brokers to host trainings, seminars, and classes?

Answer: CBP does not partner with licensed customs brokers or other private, non-governmental entities to host trainings, seminars and classes of any kind. While any organization can host educational events and activities brokers, for that event to host the activity must be submitted to one of the five selected accreditors through their websites (see the information at the top of this page for more details).

Question: I am going to retire in February 2027 to coincide with the triennial period. I do not plan to keep my license active after this point. Do I need to comply with the new requirements?

Answer: Yes. As long as your license is in an active status, you will be required to meet the continuing education requirement. This is because it important to keep your knowledge bank fresh during the time that you are transacting customs business. Additionally, plans change, and if you decide you’re not going to retire in 2027 after all, and it is already close to the reporting deadline, you may have difficulty completing all the required hours. If you do not intend to file a triennial report or pay your fee, you should still submit the information that you completed the continuing education requirement. CBP plans to modify eCBP.gov to capture a scenario such as this one.

Question: I offer training for customs brokers. How do I get my course offerings accredited?

Answer: For course offerings to be accredited, they must be submitted through one of the five selected accreditors through their websites. The websites for the five accreditors are on the Continuing Education webpage.

Question: Can you tell me how to find continuing education courses so that I can get my broker’s license?

Answer: The continuing education requirement will be for individuals who already have a customs broker license. The new requirement does not apply to anyone who is not already a license holder. In order to obtain a license, you can get more information at this CBP website which explains what a customs broker is and how you become one. In general:

You must pass the Customs Broker License Examination.
You must submit a broker license application with appropriate fees.
Your application must be approved by CBP.

Question: Would trade compliance conferences like ICPA be considered for accreditation?

Answer: CBP cannot say what will be approved or not because CBP is not an accreditor. Associations should submit the activity materials ir draft agendas to one of the accreditors for full consideration. In general, CBP finds conferences and symposia to be valuable educational and networking opportunities for all trade professionals, whether public or private sector.

Question: Is continuing education required for an inactive license?

Answer: Yes. Unless your license is in voluntary suspension, you will be required to complete the 36 hours of continuing education every three years and report that with your triennial report.

Question: What would be required to suspend a license if an individual is not conducting customs business and chooses not to be subject to the CE requirements?

Answer: Per § 111.52, the Office of Trade Broker Management Branch may accept a broker’s written voluntary offer of suspension of the broker’s license or permit for a specific period of time under any terms and conditions to which the parties may agree.

Question: Will there be opportunities to add additional accreditors if an accreditor is not selected in the initial process?

Answer: CBP has determined that the initial term of being an approved accreditor will be three years. If a party is not selected in the first selection cycle, they can respond to future Requests for Proposals for consideration. CBP has determined three years is an appropriate period of time and allows CBP to ensure that the accreditor selection process does not interfere with the close of a triennial period. CBP may adjust the term in future Requests for Proposals as circumstances and hindsight dictate the best practice.

Question: Will I have to send proof of credit to accreditors or just keep it for CBP/Broker Management Branch auditing purposes?

Answer: You will not have to provide anything to an approved accreditor proving that you completed any educational offering. Individual Licensed Customs Brokers must retain the following information and documentation for continuing education credits:

The title of the qualifying continuing education attended.
The date(s) attended.
The location of the qualifying continuing education (“online” if the activity is web-based).

Any documentation received from the provider or host of the activity that proves you attended and completed the activity.

(See § 111.102(d)(1))

Note that CBP is not requiring any specific format for this information. A simple spreadsheet or electronic table with accompanying certificates or receipts (paper or electronic) would be considered acceptable, so long as it can be provided to CBP upon request (See § 111.102(d)(2)).

Question: If a broker earns credit for information that becomes obsolete, will the earned credit still be acceptable?

Answer: Any accredited continuing education credit or government-hosted activity designated as good for continuing education that is taken during the triennial period will count, no matter at what point during the period that the credit was earned. CBP notes that the accreditation period for any training of educational activity is 1 year. If the trainer or education provider would like the activity to be valid for longer than 1 year, then they will need to resubmit their materials to one of the approved accreditors for consideration and reaccreditation. However, if you took the accredited training in the year it was approved, you do not need to take it again the next year unless you find the activity useful or of value to you. It is the responsibility of the education providers, through accreditation, to keep their materials fresh. It is your responsibility as a broker to obtain the education when it is offered and of value to you.

Question: Will a certain number of credits be required for a specific topic?

Answer: CBP is not requiring that a minimum or specified number of continuing education credits be on any specific topic. These regulations do not require individual brokers to fill the 36 continuing education credits with specific training or educational activities, such as ethics training. Individual brokers are encouraged to seek the training, educational activity, and topics that best suit their needs during each triennial period.

Question: What happens if I fall just short of completing the continuing education credit hours in the given triennial reporting period? If I don’t complete the continuing education credits 2027 and my license is suspended, how do I reinstate my license?

Answer: If you do fall short of credit hours, then your license is at risk of being suspended. Unless you take corrective action to make up the credit hours, then CBP will move to suspend your license (See § 111.104(b)(2)). You will be given notice that your license is about to be suspended, and you will then have 30 days to take corrective action (See § 111.104(c)). If you fail to take corrective action during this 30-day window, then your license will be suspended.

If an individual broker license is suspended, you can still take corrective action on or before 120 calendar days from the date of issuance of the order of suspension (See § 111.104(d)). Corrective action can range from certifying completion of the requirement to completing 36 continuing education credits.

In setting this 120-day window (approximately four months), CBP believes that we have provided sufficient time in the most extreme situation for a broker to complete all 36 hours of education and return to good standing. You as an individual broker should be aware that CBP is serious about compliance with the continuing broker education requirement. CBP also wants to ensure minor mistakes and life circumstances can be addressed and mitigated with a limited effect on your license.

Question: I have retired but would like to keep up my license. Will I have to meet the continuing education requirement?

Answer: Yes. If you would like to keep your license active even if you are no longer working as a customs broker, you will need to obtain the continuing education credits (36 hours over 3 years) and continue to meet all reporting requirements and payment of applicable fees. Even brokers who are not actively engaged in transacting business as a broker might be leveraging their broker license in other ways—for example, as an employee of a company or as a consultant. A broker can become active at any point after a period of inactivity and then must meet the same levels of professionalism and knowledge as any other broker who has been actively engaged in transacting business.

If you expect to not actively engage in transacting business as a broker for an extended period of time, you may want to consider having your license voluntarily suspended (see 19 CFR 111.52) and, thereby, not be subject to the broker continuing education requirement during the period of voluntary suspension.

Question: Will the Certified Customs Certification (CCS) and the Certified Export Specialist (CES) designations/certifications count toward the new continuing education requirement in Part 111?

Answer: CBP cannot say for certain whether the education requirement for a CCS or CES will meet the new continuing education requirement. CBP has not evaluated the specific training materials required to attain these certifications. As of now, there are no qualified trainings or educational activities because CBP has not identified nor have any CBP-selected accreditors approved any such activities. However, CBP envisions future accreditors will likely determine that trainings and activities designated for CCS and CES will qualify as continuing education under § 111.103, given the history of these certificate programs and their reputation in the broker community.

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Information for Individually Licensed Customs Brokers about The CE Requirement

Register Here for Government Continuing Education Activities

Background: Continuing Education for Licensed Customs Brokers Final Rule and FRN

Recordkeeping Requirements for Brokers Regarding Continuing Education

Title 19 —Customs Duties

Chapter I

Part 111 - Customs Brokers

Activities that Qualify for Continuing Education Credit

Qualifying Activities

Non-Qualifying Activities

Additional Resources

Question of the Week

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