The World Customs Organization predicted what kinds of challenges would impede the AEO Programs under during the COVID-19 pandemic:

• 1.“Customs AEO staff in many countries are under government-imposed stay-at-home orders”.  AEO Program should be operated on -site, because of the COVID-19, the customs would not be allowed to go outside.
• 2.“In the absence of AEO staff at the company or customs levels, the traditional in-person physical AEO validation cannot be reasonably conducted”. The physical validation is an important step in AEO Program, the customs staff must check the documents, staffing at the company.
• 3.“As companies and Customs authorities emerge from the impact of the virus crisis, there will likely continue to be significant restrictions on travel, especially air travel”. Thus, the viability of traveling to conduct traditional validations and revalidations will be significantly reduced.  
• 4.“Many AEO companies, especially those engaged in non-essential business, in the face of government stay-at-home orders, have been forced to close or reduce their operations, with a corresponding significant reduction in their workforce. Even companies engaged in essential business are reducing staff or implementing “work-from-home” rules that may limit the company’s ability to prepare and engage in an AEO compliance validation”.
• 5.SMEs have been especially impacted by the complexities that have been added to the business environment during the COVID-19 pandemic. The burden that they must assume to participate and remain compliant with AEO programs has increased dramatically.

PSCG (Private Sector Consultative Group of WCO) gives the following contents and recommendations of the development of AEO Program during this period:

• 1.AEO programs should develop and implement immediate extensions to AEO certifications, for a reasonable period, with additional extensions based on country stay-at-home orders and other considerations. 
• 2.The WCO’s SAFE WG, with the support of the PSCG, and using the WCO’s Validator Guide and other WCO related instruments, should begin the process of developing WCO validation guidelines on conducting virtual (remote) validations. Such guidelines should be consistent with the existing standards found in traditional in-person validations but should support the move to a digitized process and approach.
• 3.As virtual validation protocols are developed, they should include a written agreement between the customs administration and the Member company, in which the terms and conditions of the virtual validation are spelled out, understood, and agreed upon by both customs and the AEO member company.
• 4.A virtual validation process should utilize secure technology that meets the requirements of both the company and customs administrations.
• 5.Customs should review their Mutual Recognition Agreements in light of the COVID-19 crisis to ensure all MRA commitments remain in place to permit the joint recognition of each other’s validations and revalidations.
• 6.Virtual validation methodologies should be thoroughly tested on a pilot basis before implementation. The PSCG may offer assistance to the WCO in identifying parties that could collaborate in this regard.
• 7.AEO programs, especially in light of the pandemic, should take advantage of technology, to the extent possible, to complement traditional “on-site” physical verifications.
• 8.The use of technology will also increase the reach of programs in regions where AEO programs are not growing due to the remoteness of companies from where AEO staff is located.
• 9.Given that fraudulent and unscrupulous traders are increasing their activities during the pandemic it is more important than ever that AEO programs and MRAs be promoted by the WCO and PSCG as an effective tool for companies to employ in mitigating the threat of security breaches.