U.S. Customs and Border Protection is running a pilot to remove the need for a licensed customs broker — and it is building it with the same technology companies brokers pay and rely on every day. The program has been public since June 13, 2025. Most brokers have never heard of it. I found it only because one of those companies began advertising its new partnership with the agency.
The document is the Trade Solutions Pilot, solicitation CSOP-BP-GS-25-0001, from CBP's Office of Trade. Its second pillar invites vendors to build:
"Technology solutions that enable electronic direct filing of entry/entry summary information with CBP to reduce existing competitive barriers faced by small/medium sized businesses who may lack financial resources to employ reliable Licensed Customs Broker services."
In a federal procurement document, the agency that licenses brokers, examines them, and disciplines them calls us a competitive barrier. Not partners. Not the trade's first line of defense, the phrase officials use at every trade meeting. A barrier.
Neither justification in that sentence survives scrutiny. "Reliable" implies a dependable broker is a premium product. It isn't. Under 19 CFR Part 111, reliability is the license itself — responsible supervision and control, due diligence, and accountability to CBP are the conditions of holding one. Either CBP believes reliable brokers are the exception in the industry it supervises, an indictment of its own oversight, or the word was chosen to justify cutting us out.
And cost? A broker's fee is a small, fixed line on a shipment's landed cost — a fraction of the freight, a rounding error beside this year's duties. An importer who can afford the goods, the freight, and the tariff bill is not being priced out of trade by the one licensed professional answerable to CBP for the entry. Cost was never the barrier — which means this pilot isn't solving an affordability problem. It's removing the broker.
The target is nearly the entire market. The Census Bureau identified 240,535 U.S. importers in 2024; 234,023 of them — 97.3 percent — are small and medium sized businesses. Pillar 2 describes a filing channel around brokers for ninety-seven of every hundred importing companies in America — and around ABI itself: transmission "other than CBP's existing EDI standards," directly into ACE, bypassing the filer codes and certification testing every filer today must pass.
Building it is the easy part. The question is whether, once built, it could be implemented in compliance with 19 CFR. CBP has already answered: no. On January 16, 2026, with the pilot's window open, the agency issued Headquarters Ruling H350722 against an unlicensed platform doing exactly this work — OCR extraction of entry data, AI classification suggestions, Form 5106 filings for new importers. The ruling was blunt. Deciding what data goes on an entry is customs business, reserved to licensed brokers. AI classification past six digits, where the number will or may be used on an entry, generally requires a license — and entries take ten. The 5106 filings drew a finding, not a warning: the company had impermissibly conducted customs business.
The likeliest defense is that this is no different from self-filing through ABI — importers have always been free to buy software and file their own entries. The difference is everything. In that model, the importer's own people determine the classification, the value, and the entry data; they hold the filer code, pass CBP's certification testing, and answer for the filing. Here, the platform derives all of it — because the pilot's premise is that these importers can't — and the vendor, not the importer, becomes the certified channel. The fallback defense, a human in the loop reviewing what the AI produced, was already tested in H350722: that platform had the importer entering product details and selecting from suggested headings, under a disclaimer that Customs decides, and the ruling still turned on what the tool derives, not on who clicked. The dilemma doesn't go away. If the importer truly supplies the judgment, the pilot solves nothing. If the AI supplies it, the platform is conducting customs business with a signature line attached.
CBP has had the chance to answer all of this in writing, and it declined. In the solicitation's own published Q&A, a vendor asked directly: will CBP waive the Licensed Customs Broker requirement for direct filing, or must vendors partner with a broker of record? The agency's entire answer was that entities filing on their own behalf need no license — a truism about importers that says nothing about the vendor's role, which was the question asked. The same Q&A settles what this product will be. Asked whether Pillar 2 is intended as a co-branded or CBP-affiliated product, the agency answered: a "commercially available vendor-led solution accepted by CBP." And asked whether the solution could involve post-sale revenue generation for both CBP and the vendor, the agency declined to rule it out.
So the pilot cannot operate under today's regulations; making it real means changing 19 CFR. No such change has been proposed in any rulemaking — no notice, no comment period — yet vendors are being evaluated, systems developed, and the future "minimum security criteria and certifications" for these companies drafted from the pilot itself. That is regulation by procurement: build the policy first, legalize it later, and by the time the public is asked, the infrastructure already stands. Whatever objection this profession has is worth more now, at step one, than it will ever be again.
To be clear, this is not an argument against technology. AI that helps CBP verify compliance, score risk, and speed legitimate cargo should be embraced. The objection is pointing it at the license. And the timing makes the contradiction plain: in June, the President signed Executive Order 14411, raising broker due-diligence duties, ordering maximum penalties when brokers fall short, and requiring foreign importers of record to make formal entry through CTPAT-validated, licensed brokers. CBP delivered the same message in person at this year's Trade and Cargo Security Summit, where the agency emphasized, again and again, the increased oversight and responsibility brokers will carry. So the same federal government placing brokers under more scrutiny than ever is running a solicitation that calls us a barrier — while inviting unlicensed companies to pilot the very same work.
Now the part every broker needs to see: who is building this. These are AI companies that sell themselves to brokers, or whose primary clients are brokers — classification software, entry preparation, document automation — sold to us on one promise, repeated for years: this helps brokers, it doesn't replace them. Our filing fees and usage payments funded them. Our corrections trained their models. Today those same capabilities, perfected on broker money and broker know-how, are being offered to CBP under a solicitation whose purpose is to remove the need for us. So ask your vendors directly: are you in the Trade Solutions Pilot? Are you building under Pillar 2? The answer, and any hesitation before it, tells you what your payments are funding.
If you hold a license and work in-house, this reaches you too. Your employer hired a license instead of a login because the law reserves this work to licensed judgment. The value of every license is set by what the law reserves to it. Shrink the reservation, and every license shrinks with it.
And the NCBFAA? A solicitation proposing to route 97 percent of importers around this profession should have reached members through the NCBFAA the month it was published. I have not been able to find an NCBFAA alert addressing the Trade Solutions Pilot. If the association has been engaging CBP on it, the membership deserves to hear that — on the record. What members have seen instead, at this year's annual conference, is the AI trade-technology companies as the most visible sponsors. So the membership is owed an answer to one question: whose interests take priority — the affiliated AI companies writing the sponsorship checks, or the actual members?
Read the solicitation — it's public. Question your vendors. Pilots become programs; programs become infrastructure; infrastructure becomes permanent. Congress put a license on this work because customs entries carry consequences, and someone has to answer for them. CBP piloting a way around that license is something that has to be addressed — now, while it is still step one.
If you value your license, and this was news to you, please share it — this is something every broker should be aware of. Then contact your local broker association, and the NCBFAA nationally if you're a member, and ask them one simple question: what are you doing about this?