Import Compliance Review for Commercial Importers: A 12-Month Self-Audit

CLEARON LOGISTICS | Import Compliance Review for Commercial Importers: A 12-Month Self-Audit

An import compliance review is the cheapest insurance a commercial importer can buy, because KRA can reopen a shipment up to five years after it cleared, and the burden of proof sits with you. Kenya’s rules have changed more in 2026 than in several years before it, so a review of the last year’s imports is worth doing even if nothing has gone wrong. Here is a practical self-audit you can run, and what a clearing agent can add.

Why Review Now

Post-clearance audits can examine tariff classification, valuation, origin, exemptions and supporting documents for imports up to five years old, as our post-clearance audit guide explains. New documentary requirements, from Certificates of Origin to export declaration documents, mean shipments from different months may face different expectations. A review turns surprises into a to-do list.

Step One: Rebuild the File for Each Shipment

For each import in the last 12 months, gather the commercial invoice, packing list, bill of lading, customs entry, proof of duty payment, certificates, permits and correspondence. Missing items are your first finding. If your documents sit in an agent’s files only, request copies and keep your own organised set.

Step Two: Test Classification and Valuation

Compare the HS code used on each entry against the product and its specification, and check declared values against invoices and payments. Pay particular attention to mixed shipments, to products that classify by processing level, and to anything an agent has previously flagged. Our HS code guide and valuation guide help you spot weak points.

Step Three: Check the 2026 Documents

For shipments after each requirement took effect, confirm you held the Certificate of Origin, the export declaration document (which must be retained for five years), an Advance Cargo Declaration for containerised sea cargo, valid local marine insurance and CFS nomination. Our 2026 compliance overview lists what changed and when.

Step Four: Check Sector Rules

Match each product to its regulators: KEBS certification, PPB, EPR, Communications Authority, environmental or other permits. Our guides to EPR, Certificates of Conformity and the sector pages in this series show where requirements commonly hide. A product that has cleared repeatedly may still have been missing a permit that nobody asked for.

Step Five: Reconcile Costs

Compare the landed cost you planned with what you actually paid, using our landed cost formula. Unexplained gaps may reveal avoided or over-paid charges, or an agent fee that no longer matches your quote; see our quote reading guide. Consistent records across invoices, bank payments and customs documents also reduce anti-money-laundering friction.

If You Find a Problem

Don’t ignore it and don’t improvise. Get professional advice on whether and how to correct it, and keep a record of what you found and did. If you disagree with an assessment, there’s a structured route: objection to KRA, then appeal to the Tax Appeals Tribunal within strict deadlines, as in our valuation disputes guide. Early advice improves every option.

Working With Clearon Logistics

We can walk through a sample of your recent shipments with you, flag classification, documentation and sector-rule gaps, and set up a cleaner process going forward. Our role is practical review and process, not legal advice on specific disputes.

Want a second pair of eyes on your last year of imports? Talk to Clearon Logistics about reviewing a sample of your shipments and tightening your process.


Frequently Asked Questions

How far back can KRA review my imports? Up to five years after clearance, and longer where fraud is suspected.

Who has to prove the declaration was correct? The importer. You must be able to substantiate your declared classification, value and origin on request.

Should I keep my own copies of documents? Yes. Relying only on an agent’s files leaves you exposed if the relationship ends.

What if I disagree with an assessment? You can object to KRA and, if necessary, appeal to the Tax Appeals Tribunal, subject to strict deadlines.

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