EUROPEAN COMMISSION Brussels, 14.12.2020 SWD(2020) 339 final COMMISSION STAFF WORKING DOCUMENT Accompanying the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for under the Code {COM(2020) 806 final}



Table of Contents 1. Introduction 2. Completed Projects 2.1 UCC Registered Exporter System (REX) 2.2 UCC Customs Decisions 2.3 UCC Direct Trader Access to the European Information Systems (UUM&DS) 2.4 UCC Economic Operator Registration and Identification System Upgrade (EORI2) 2.5 UCC Surveillance 3 (SURV3) 2.6 UCC Binding Tariff Information (BTI) 2.7 UCC Authorised Economic Operators (AEO) Upgrade 2.8 UCC Information Sheets (INF) for Special Procedures 3. Ongoing Projects: Detailed Planning and progress Information 3.1 UCC Notification of Arrival (NA), Presentation Notification (PN) and Temporary Storage (TS) 3.2 UCC National Import Systems Upgrade 3.3 UCC Special Procedures 3.4 UCC Guarantee Management (GUM) 3.5 UCC Import Control System 2 (ICS2) 3.6 UCC Proof of Union Status (PoUS)

3.7 UCC Centralised Clearance for Import (CCI) 3.8 UCC New Computerised Transit System (NCTS) Upgrade 3.9 UCC Automated Export System (AES) 4. Annex 1 – Planning Overview – UCC Work Programme Projects 5. Annex 2 – Acronyms, Abbreviations & Key Terms



Table of Figures Figure 3‑1: Project Status as per Survey – NA Figure 3‑2: Project Status as per Survey – PN Figure 3‑3: Project Status as per Survey – TS Figure 3‑4: Summary of Responses per Milestone – NA Figure 3‑5: Summary of Responses per Milestone – PN Figure 3‑6: Summary of Responses per Milestone – TS Figure 3‑7: Percentage of Completion per Phase – NA Figure 3‑8: Percentage of Completion per Phase – PN Figure 3‑9: Percentage of Completion per Phase – TS Figure 3‑10: Summary of Survey Responses – National Import Systems Upgrade Figure 3‑11: Summary of Responses per Milestone – National Import Systems Upgrade Figure 3‑12: Percentage of Completion per Phase – National Import Systems Upgrade

Figure 3‑13: Project Status as per Survey – Component 1 National SP EXP Figure 3‑14: Project Status as per Survey – Component 2 National SP IMP Figure 3‑15: Summary of Responses per Milestone – SP – Component 1 Nat SP EXP Figure 3‑16: Summary of Responses per Milestone – SP – Component 2 Nat SP IMP Figure 3‑17: Percentage of Completion per Phase – SP – Component 1 Nat SP EXP Figure 3‑18: Percentage of Completion per Phase – SP – Component 2 Nat SP IMP Figure 3‑19: Summary of Survey Responses – GUM – Component 2 Figure 3‑20: Summary of Responses per Milestone – GUM – Component 2 Figure 3‑21: Percentage of Completion per Phase – GUM – Component 2 Figure 3‑22: Summary of Survey Responses – ICS2 – Release 1 Figure 3‑23: Summary of Survey Responses – ICS2 – Release 2 Figure 3‑24: Summary of Survey Responses – ICS2 – Release 3 Figure 3‑25: Summary of Responses per Milestone – ICS2 – Release 1 Figure 3‑26: Summary of Responses per Milestone – ICS2 – Release 2 Figure 3‑27: Summary of Responses per Milestone – ICS2 – Release 3 Figure 3‑28: Percentage of Completion per Phase – ICS2 – Release 1 Figure 3‑29: Percentage of Completion per Phase – ICS2 – Release 2 Figure 3‑30: Percentage of Completion per Phase – ICS2 – Release 3 Figure 3‑31: Summary of Survey Responses – CCI – Phase 1 Figure 3‑32: Summary of Survey Responses – CCI – Phase 2

Figure 3‑33: Summary of Responses per Milestone – CCI – Phase 1 Figure 3‑34: Summary of Responses per Milestone – CCI – Phase 2 Figure 3‑35: Percentage of Completion per Phase – CCI – Phase 1 Figure 3‑36: NCTS-P5 National Administrations entry into operations Figure 3‑37: Project Status as per Survey – NCTS – Component 1 or Phase 5 Figure 3‑38: Project Status as per Survey – NCTS – Component 2 or Phase 6 Figure 3‑39: Summary of Responses per Milestone – NCTS – Component 1 Figure 3‑40: Summary of Responses per Milestone – NCTS – Component 2 Figure 3‑41: Percentage of Completion per Phase – NCTS – Component 1 or Phase 5 Figure 3‑42: AES-P1 National Administrations entry into operations Figure 3‑43: Project Status as per Survey – AES – Component 1 Figure 3‑44: Project Status as per Survey – AES – Component 2 Figure 3‑45: Summary of Responses per Milestone – AES – Component 1 Figure 3‑46: Summary of Responses per Milestone – AES – Component 2 Figure 3‑47: Percentage of Completion per Phase – AES – Component 1 Figure 3‑48: Percentage of Completion per Phase – AES – Component 2 Figure 4‑1: Planning Overview: UCC Work Programme Projects – Status Q4 2020 Table of Tables

Table 1: Comparison of Planned and Actual Dates – REX1 Table 2: Comparison of Planned and Actual Dates – UCC Customs Decision Table 3: Comparison of Planned and Actual Dates – UUM&DS Table 4: Comparison of Planned and Actual Dates – EORI2 Table 5: Comparison of Planned and Actual Dates – SURV3 Table 6: Comparison of Planned and Actual Dates – BTI Table 7: Comparison of Planned and Actual Dates – AEO Upgrade Table 8: Comparison of Planned and Actual Dates – INF Table 9: Comparison of Planned and Actual Dates – NA Table 10: Comparison of Planned and Actual Dates – PN Table 11: Comparison of Planned and Actual Dates – TS Table 12: Comparison of Planned and Actual Dates – National Import Systems Upgrade Table 13: Comparison of Planned and Actual Dates – SP – Component 1 Nat SP EXP Table 14: Comparison of Planned and Actual Dates – SP – Component 2 Nat SP IMP Table 15: Comparison of Planned and Actual Dates – GUM – Component 1 Table 16: Comparison of Planned and Actual Dates – GUM – Component 2 Table 17: Comparison of Planned and Actual Dates – ICS2 – Release 1 Table 18: Comparison of Planned and Actual Dates – ICS2 – Release 2 Table 19: Comparison of Planned and Actual Dates – ICS2 – Release 3 Table 20: Comparison of Planned and Actual Dates – CCI – Phase 1

Table 21: Comparison of Planned and Actual Dates – CCI – Phase 2 Table 22: Comparison of Planned and Actual Dates – NCTS – Component 1 Table 23: Comparison of Planned and Actual Dates – NCTS – Component 2 Table 24: Comparison of Planned and Actual Dates – AES – Component 1 Table 25: Comparison of Planned and Actual Dates – AES – Component 2 Table 26: Abbreviations and Acronyms



1.Introduction The Union Customs Code (UCC) requires the European Commission and the Member States to upgrade some existing electronic systems and introduce a number of new systems for the completion of a modern and digital environment of customs formalities. In total, the UCC requires the upgrading or creation of fourteen trans-European systems and three national systems. The UCC entered into force on 1 May 2016. The deadline for completion of the systems is set for the end of 2020, 2022 or 2025, depending on the system. In view of the reporting requirement established by Article 278(a) of the Regulation (EU) 2019/632 amending Regulation (EU) 2013/952, the Commission is committed to provide an annual report to the European Parliament and the Council on the progress in developing the electronic systems of the UCC. The report assesses the progress of the Commission and the Member States in developing each of the electronic systems, taking particular note of the following milestones: (a)The date of publication of the technical specifications for the external communication of the electronic systems; (b)The period of conformance testing with economic operators; (c)The expected and actual dates of deployment of the electronic systems. The legal deadlines for finalising the technical specifications and for deploying the electronic systems are laid down in the UCC Work Programme (UCC WP). The detailed planning per project, containing additional milestones such as for the business case, business process modelling, vision document, conformance testing, etc. are defined in the Multi-Annual Strategic Plan for Customs (MASP-C). The first UCC Annual Progress Report was published on 13/12/2019. In preparation for this year’s UCC Annual Progress Report 2020, the Commission continued with the approach taken in 2019 and made use of the bi-annual national planning information provided by the Member States’ customs authorities and the projects’ state of play provided by the project managers in DG TAXUD. The annual report covers a reflection of the progress status achieved on 30 June 2020 including a view on the expected progress by December 2020 in order to have a full picture of the progress made in 2020. The progress information was provided against the baseline milestones indicated in the UCC WP and MASP-C 2019. In addition, the Commission oversaw the collection of the additional progress reporting information by means of an EU survey launched in May 2020. The information gathered from the survey to which both the Member States and key stakeholders/project managers in the Commission responded, consists of progress information, qualitative comments and quantitative measurements of the assessment of complexity and risk in relation to the seventeen projects listed in the UCC WP. Finally, also specific information was gathered from the more detailed project reporting and monitoring programmes in place since 2020 for the core decentralised trans-European systems in the area of transit and export. As background information it is important to recall that the seventeen electronic systems listed in the UCC Work Programme were divided into three categories: I)eleven central trans-European systems to be developed or upgraded by the Commission (often also requiring developments or upgrades by the Member States of their corresponding national systems); II)three decentralised trans-European systems that have to be developed or upgraded by the Commission but have a major national component to be implemented by the Member States; and

III)three national systems that have to be developed or upgraded exclusively by the Member States. The progress information has been collected, analysed and reported in this accompanying Commission Staff Working Document, which presents the detailed overview of the progress of the various individual projects as follows: ·For the trans-European systems, the analysis and reporting refers to the Commission’s activities only when central, while for the systems that involve national input, and even in some cases national components, the analysis refers to both the Commission’s and Member States’ activities. For the national systems, only Member States’ activities are reported; ·For projects that have already been initiated or entirely completed, an overview of the project progress, a summary of the survey responses, as well as a visual illustration of progress against planned milestones is provided; ·For projects that have not yet been initiated, an overview of the planned project progress together with a summary of the responses from the survey is provided. By means of the survey, the Member States were also requested to give an indication of: ·The degree of complexity of each project on a scale from 1 to 6, where: 1 and 2 refer to low complexity, 3 and 4 - medium complexity and 5 and 6 - high complexity. ·The risk of not deploying the IT systems by the dates set in the baselines of the UCC WP and MASP-C 2019 according to three levels: low, medium and high. The consolidation of the survey results, including the abovementioned indicators of complexity and risk, as well as information regarding risks for delays and mitigating measures and any changes in planning in comparison with the planning provided in 2019, are the main outcomes of the progress reporting exercise for 2020 and are included in this Commission Staff Working Document. Reporting information that summarises the current project status, key risks and mitigating actions is found in the Report from the Commission to the European Parliament and the Council pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for under the Code. In the sections below, there is first a representation of the completed projects, followed then by an overview of the ongoing projects.



2.Completed Projects 2.1UCC Registered Exporter System (REX) The UCC Registered Exporter System (REX) is a trans-European system that contains information both on Registered Exporters established in GSP countries and on EU economic operators in partner countries Switzerland, Norway and Turkey exporting to GSP countries and certain other countries. The main purpose of the system is to replace the paper-based certification process by an IT-supported self-certification process. The system includes a central database that contains the registered exporters and provides the Member States with the opportunity to enhance their national systems with an automated verification of REX members. There are currently three releases planned. REX1 is the only release covered in the scope of the UCC Work Programme. No risks were identified during the implementation of REX1 and the project was successfully concluded on 1 January 2017. Some statistical information on the use of the REX system – situation on 15/06/2020: ·44,524 active REX registrations in Member States and Partner Countries; ·48,421 active REX registrations in the Beneficiary Countries (REX BC) module; ·139 REX registrations added by OCTs; ·549 T-REX system local users;

·304 T-REX local administrators. 2.1.1Overview of Project Progress Table 1 compares the actual dates to those set in the UCC Work Programme (WP). Despite there being a slight delay in the finalisation of the Technical Specifications, REX was deployed on time.



2.2UCC Customs Decisions The UCC Customs Decisions System (CDS) is designed to achieve harmonisation of the processes relating to the application for a customs decision, the decision taking and the decision management. This harmonisation is put into practice via the standardisation and electronic management of the application and decision/authorisation data across the Union. The system covers all applications and decisions that may have an impact/are valid in more than one Member State. Member States also have the right to use the Customs Decisions System to manage their national customs decisions, if they so wish. In regards to the submission of an application, economic operators need to possess an “Economic Operator Registration and Identification” (EORI) number and then connect to the EU Trader Portal on the Europa website by authenticating themselves via the Uniform User Management & Digital Signature (UUM&DS) (see project 2.3. hereafter). The system is vital to ensure the Union-wide validity of applications and decisions and it simplifies the conduct of business for economic operators. It thus creates a level playing field among all economic operators irrespective of their size and ensures that all EU businesses can compete in the global market. The project was fully deployed on 02/10/2017. The Commission published training modules, user guides and an e-Learning module in support of the deployment and the usage of the system. The e-Learning module is available on the Europa website, allowing economic operators to learn about the approach selected by each Member State (i.e. central, combined or hybrid). The Commission has implemented mitigating measures to correct IT implementation errors compared to the baseline and to address issues regarding the User Interface (UI) design as identified by the Member States and to address differences between the baseline project documentation and the legislation. Further to the deployment of additional releases of CDS, some enhancements have been carried out to keep the Trader Portal on the Europa website efficient and up-to-date. Some statistical information on the use of the CDS – since the deployment on 02/10/17 till June 2020: ·The number of applications grew to 1,300 by the end of 2017. The number of applications then increased to 15,300 by the end of 2018. Since mid-2019 there are on average 26 applications submitted per working day, totalling up to approximately 32,000 applications by mid 2020; ·60% of all applications were submitted by an economic operator and 40% by representatives; ·Approximately 18,700 decisions have been taken, and more than 28,000 pre-existing authorisations were entered (in view of the UCC legal requirement to ensure the reassessment of authorisations by 01/05/2019). 2.2.1Overview of Project Progress

Table 2 highlights that there were no divergences in the planning compared to the dates set in the Work Programme. 2.3UCC Direct Trader Access to the European Information Systems (UUM&DS) The Direct Trader Access to the European Information Systems system comprises Uniform User Management and Digital Signature (UUM&DS) components. The system aims to provide a service for user-to-system interfaces targeted to the electronic customs systems provided for in the UCC. In essence, the UUM&DS system facilitates a direct and EU harmonised trader access to the customs systems as stipulated in the UCC. Both components will be integrated into the portals of all pertinent systems on deployment of the latter, providing support for issues regarding identity, access and user management. In this way, the processes will be fully compliant with security policies. The first deployment of the project was completed and implemented together with the UCC Customs Decisions system on 2/10/2017 as agreed in the context of the UCC Work Programme. The system has also been incorporated into other electronic projects such as UCC Binding Tariff Information (BTI), the UCC Authorised Economic Operators (AEO) and the new Information Sheets (INF) system for special procedures. The project will further evolve to include system-to-system interfaces and digital signature. Their use will be particularly relevant to the Import Control System (ICS2) and the Proof of Union Status (PoUS) system. All Member States have completed the connectivity configuration. The Commission has delivered operational documentation to the Member States and has created an economic operator’s manual and Service Desk guidelines. In the survey, the Commission reports no risks pertaining to on-time delivery. The system is now in place, but the existence of multiple stakeholders, as well as the complex integration of this system with other UCC projects mentioned above, may carry some risks for future projects. Some statistical information on the use of the UUM&DS – situation 24/09/2020: ·The number of UUM&DS calls for the CDS trader portal, since its operation on 1 October 2017 are 392.000. 2.3.1Overview of Project Progress Table 3 highlights that there are no divergences in the planning compared to the dates set in the Work Programme. 2.4UCC Economic Operator Registration and Identification System Upgrade (EORI2) This system upgrade provided minor changes to the existing trans-European Economic Operator Registration and Identification system. These changes enabled the registration and identification of economic operators of the Union, as well as third-country operators and persons apart from economic operators. EORI2 has been in operation since 05/03/2018. Some statistical information on the use of the EORI2 system – situation 20/07/2020:

·The total number of economic operators registered with a valid EORI as recorded in EORI2 is 7,310,365. 2.4.1Overview of Project Progress Table 4 highlights that there are no divergences in the planning compared to the dates set in the Work Programme.



2.5UCC Surveillance 3 (SURV3) The SURV3 system introduces an upgrade to the standard exchange of information in the earlier Surveillance 2 (SURV2) system to align the system with UCC requirements. This database records and centralises all EU trade data (imports and exports) that national customs authorities provide on a daily basis. The upgrade implements electronic data-processing techniques and establishes adequate functionalities needed for processing and analysing the full surveillance dataset obtained from Member States. The new system will improve the customs risk analysis, the fight against fraud, market analysis, post-clearance controls and statistical analysis. The system was successfully deployed on 01/10/2018. The data will be gathered via SURV-RECAPP in different formats until the moment that all the national systems are fully aligned to the UCC. 2.5.1Overview of Project Progress Table 5 highlights that there were no divergences in the planning compared to the dates set in the Work Programme. 2.6UCC Binding Tariff Information (BTI) The project for a UCC Binding Tariff Information system aims to upgrade the existing trans-European (EBTI-3) database containing all binding tariff information that has been issued by customs authorities of Member States. The customs authorities concerned must then record their decisions in the BTI database. Economic operators apply for binding tariff decisions in order to have legal certainty that they are applying the correct classification to goods they are importing to or exporting from the EU. The changes covered the following aspects: (a)Alignment of the EBTI-3 system to the UCC requirements;

(b)Alignment of the system to the new Customs Decisions system; (c)Addition of declaration data required for surveillance purposes; (d)Monitoring of the usage by economic operators of BTI decisions, which is compulsory for Member States; (e)Monitoring and management of the extended usage of BTI. The BTI project was divided into two phases: The first phase consists of two steps. Step 1 aims to allow Member States to input the datasets in customs declarations, as provided for under the UCC, until the deployment of the Automated Export System (AES) and the upgrade of the National Import Systems. Step 2 addresses the obligation of Member States to control the BTI usage based on the newly required declaration datasets and on the alignment of the BTI system to the customs decisions process. The second phase implements the electronic means for economic operators to make BTI applications and receive decisions. Economic operators will thus benefit from an EU-harmonised and electronic trader interface for their applications and decisions. Concerning the status of the project, by October 2017 both steps 1 and 2 of the first phase were successfully completed. The second phase faced a delay of two quarters during the elaboration phase (vision document, technical specifications and application specifications). Nevertheless, the overall planning still remained on target and the system entered into operation on 01/10/2019. The construction of the access for this system to the EU Customs Trader Portal was also completed on 01/10/2019. Some statistical information on the use of the EBTI system – situation as of 01/10/2019: ·The Trader Portal (central EU or national) is used by all traders in all Member States; ·All BTI applications and decisions are sent electronically; ·Eight BTI core processes consisting of more than 20 sub-processes have been digitalised (related to the BTI application, the issuing and invalidation of the BTI decision and the Right To Be Heard procedure); ·More than 29,000 BTI applications (5,000 via the EU TP and 24,000 via the national TP) have been submitted by the traders and more than 33,000 BTI decisions (11,000 via the EU TP and 22,000 via the national TP) were issued to the traders; ·Other BTI related communications between traders and Decision Taking Customs Authorities (DTCA) were sent electronically via the EU TP (26,000 notifications, 10,000 BTI invalidations, etc.). 2.6.1Overview of Project Progress

Table 6 highlights that there were no divergences in the planning compared to the dates set in the Work Programme.

2.7UCC Authorised Economic Operators (AEO) Upgrade Following the legal changes adopted in the UCC, the Authorised Economic Operators (AEO) upgrade aims to improve the system of applications and authorisations for AEO status. The project consists of two phases. Phase 1 implemented major enhancements to the existing AEO system, in light of the harmonisation of the decision-taking procedure for customs. Phase 2 implemented the electronic form with a view to provide a harmonised interface for economic operators to submit their AEO applications and to receive their AEO decisions electronically. The upgraded system was deployed in two releases: Part 1 for the submission of the AEO applications and the decision-taking process (Phase 2 Part 1) and Part 2 for the other processes (Phase 2 Part 2). For the second phase, the Commission delivered a new version of documentation to the Member States at the end of March 2019. The Commission reported that implementation started on 25/01/2019, deployment preparation took place in June 2019 and conformance testing took place in July 2019. The first phase containing all features for the management of the Submitted Applications was delivered on 01/10/2019. The consultation of Economic Operator System (EOS) artefacts (EORI, AEO Applications and AEO authorisations) was also made possible via the eAEO-STP. The second phase, introducing the entire workflow between the traders and customs officers was completed on 16/12/2019. Some statistical information on the use of the AEO system – situation on 27/05/2020: ·350 applications have been submitted; ·800 Economic Operators have accessed the EU eAEO Trader Portal; ·60+ processes have been digitalised; ·700+ documents have been exchanged; ·24 Member States are leveraging the EU eAEO Trader Portal and the remaining Member States are utilising their own National Trader Portal; ·The Online User Manual for the eAEO Trader Portal and eAEO eLearning courses for the traders and Customs Officers are available. 2.7.1 Overview of Project Progress Table 7 highlights that there are no divergences in the planning compared to the dates set in the Work Programme. 2.8UCC Information Sheets (INF) for Special Procedures

The aim of the UCC Information Sheets (INF) for Special Procedures project is to develop a new trans-European system to support and streamline the data management processes and the electronic handling of data in the domain of Special Procedures. This new system will harmonise the approach for the efficient management of inward and outward processing procedures and improve the monitoring and control amongst customs offices. Specifically, some of the expected benefits are as follows: ·Harmonised approach for the processing procedures and related information exchange across the EU; ·Simplification for the national Customs administrations and holders of authorisation as the complex paper-based procedures will no longer be necessary due to the electronic support of the INF system; ·Increased accuracy as the INF data will be processed electronically and validated against various databases; ·Improved application of customs policy measures and facilitation for the calculation of customs duties; ·Reduction in the risk of undetected fraud and irregularities associated to the current paper-based information exchange; ·Cost optimisation for the implementation and operation of the INF system; ·Assurance of information integrity as access will be granted based on specific roles and tasks of the competent authorities. The technical specifications were completed on 30/06/2018. For this project, the Commission used an iterative delivery method and deployed a pilot version, including the deployment of the EU Customs Trader Portal, on 15/01/2019. Thanks to the iterative approach, requirements for improvements on the graphical user interface INF trader portal for economic operators could be collected up front and changes to the processes and further improvements could be implemented prior to full deployment. To support the start of operations of the INF system several other actions were prepared, namely: -a landing page on the Europa website; -a business and end user guide (accessible via the landing page); -an e-learning module; -Frequently Asked Questions (FAQ’s); -communication material; Notwithstanding the difficult and unforeseen working circumstances during the 2nd quarter of 2020 requiring – due to the COVID-19 pandemic - the cancellation of the planned physical meetings and training sessions with the stakeholders of the system, the INF central system was successfully deployed on 01/06/2020. The INF Specific Trader Portal (INF STP) component was also successfully integrated into the EU customs trader portal (EU CTP) and deployed on 01/06/2020. The EU CTP is the single portal at Union level to provide traders unique access to a number of centralised trans-European systems (EBTI, AEO, INF). Although most Member States were able to join the INF system, 2 Member States have reported a delay due to problems related to the preparation of training for their staff and the trade community, lack of time for testing and issues related to the COVID-19 crisis (FI and NL). However, they envisaged joining in the second half of 2020. Close contacts between the Commission and the Member States are kept to provide the necessary support, assistance and supervision. A project group with Member States and trade associations is holding regular meetings to address possible remaining business issues.

Some statistical information on the use of the INF system: ·From the start of operations on 01/06/2020 until 15/09/2020, 3,690 requests were inserted by economic operators, for which 2,730 INFs were treated and processed by the customs authorities. ·In the month of September 2020, there was an average of 55 requests per day and 50 INFs created in 16 MS and the UK. The National Administrations handling most INFs have been Romania and Poland. 2.8.1Overview of Project Progress Table 8 highlights that there were no divergences in the planning compared to the dates set in the Work Programme. 3.Ongoing Projects: Detailed Planning and progress Information 3.1UCC Notification of Arrival (NA), Presentation Notification (PN) and Temporary Storage (TS) The goal of this project is to define the processes at the national level in respect to the notifications known as Notification of Arrival (NA), Presentation Notification (PN) and Declaration for Temporary Storage (TS), as described in the UCC. This project will ensure the customs formalities related to the entry of goods concerning safety and security exist and that customs supervision begins at the appropriate time and is duly performed. It also aims to support harmonisation across the Member States regarding the data exchange between trade and customs. Furthermore, the project covers the automation of processes at the national level. The development activities are a national responsibility (‘national development’) and are planned to be operational before the end of 2022. The processes and data requirements for the external domain have been defined and agreed upon on at the EU-level. A work package of an expert team in Member States collaboration (ETCIT WP2 – Expert Team on new approaches to develop and operate Customs IT systems) financed by the Customs Programme has been put in place to define and agree upon the business process models and discuss the legal/business/functional requirements. The project is closely interlinked with other projects/systems such as the national import systems and the Import Control System 2 (ICS2). This is often reported by Member States as the reason for assessing the project as medium to highly complex. The timely delivery of the required national systems by all Member States was already at risk in last year’s report. Some additional delays in comparison with the UCC Annual Progress Report 2019 are noted, though several Member States reported that measures are taken to have the deployment still on time. Besides the complexity of the project, other reasons are given such as resource constraints, further adaptations to the UCC Annex B, impact and re-planning due to the e-Commerce file and Brexit, and also the specific working circumstances caused by the COVID-19 pandemic. Further intense collaboration work in the form of an Expert Team on new approaches to develop and operate Customs IT systems (ETCIT) is ongoing in order to share expertise and resources amongst interested Member States and to join forces in the development work. However, it should be noted that as this type of collaboration is relatively new, the Member States are still learning along the way how to improve their working methods and find ways for optimising resources/joint procurement/etc. and this in parallel to the challenges inherent to the project itself. 3.1.1Summary of Responses Notification of Arrival (NA) AT finds the NA project to have a medium (3) complexity rating with a high risk level. AT explains that the high risk is caused by the extensive functional interaction and the tough timing between projects in parallel (ICS2, NA, Adjustment of existing import application and the eCommerce Programme). AT also mentions implications to the timeline caused by the COVID-19 pandemic, all milestones could be impacted. Despite this, AT is working on defining national user requirements, technical specifications, conformance and user test preparation and training. BG rates the complexity level as high (5) but with a low risk level. Their national technical specifications should be approved by the end of 2020. BG will implement NA as part of ICS2 – Release 2, which will cover the implementation of the complete new Entry Summary Declaration (ENS) obligations and related business and risk management processes for all goods in air traffic. CY denoted the project complexity as high (6) yet a low risk level. CY explained that the complexity is caused by insufficient resources, dependencies with other systems and the development of other projects in parallel. CY participates in the working group and has moved the deployment date so that it does not coincide with other core projects. CZ reports that the NA project as having a high (5) complexity and medium risk level. CZ also finds the application complex and has indicated that it requires a large amount of financial resources. CZ highlighted a risk that the national project plan may have to be updated due to the COVID-19 pandemic and delays it is causing. The changes will depend on the evolution of the situation. DE did not provide a complexity assessment however indicated that the project had a low risk level. DE explained that this message will be updated in line with ICS2 – Release 2. The preparation activities for Release 10.1 of their national IT system, ATLAS, has not yet started. External milestones affecting economic operators will be considered for the ICS2 – Release 2.

ES rates the complexity level as medium (3) with a medium risk level. ES will not develop a national message but will use the NA integrated in Release 2 of ICS2. Therefore, their conformance tests will be integrated with the ICS2 – Release 2 planned for in 2022. FI notes the project as having a medium (3) complexity rating and a medium risk level, commenting that their plans have not changed. However, they anticipate several risks and due to this, changes in planning will most likely be needed. It is anticipated that the volume of declarations will rise dramatically for Low Value Consignments (LVC). This will then require a considerable amount of upgrades to the platforms and supporting IT systems in addition to an adjustment to the internal processes in the Declaration Management System (DMS). Due to necessary changes, there has been a need to postpone the development of some functionalities in the national import system. This will also affect the planning and implementation of future UCC projects. The complete impact is not yet clear but risks concerning timetables and resources have increased. Lastly, FI mentions that the resources were already scarce from the beginning and that the additional effects of the COVID-19 pandemic are unclear. These comments apply to all UCC projects. GR indicated a high complexity level (6) and a high risk level. GR indicated that the project is currently delayed compared to the planning in the 2019 report, however the overall delivery is still expected within the deployment deadline set in the UCC Work Programme. GR is facing procurement delays. IE notes that the project is not applicable to the MS as arrival data are directly provided to their customs authorities by Airport and Maritime authorities and thus, carriers are not required to submit Notifications of Arrival. IT indicated a low complexity rating (2) and a medium risk level. IT identifies a risk pertaining to the economic operators, underlining that requests for changes might arise later in the process due to their lack of readiness. LV identifies the project as having a medium complexity rating (4) but with a low risk level. LV will be implementing NA as part of their national TS system. Necessary corrections will be performed in the context of the ICS2 implementation. NL indicated this project as having a high complexity rating (6) and medium risk level. The complexity is caused by the large number of external stakeholders (e.g. carriers, freightforwarders and their software providers), and internal stakeholders (e.g. policy makers, risk analysts, control officers) with whom national requirements need to be defined. Furthermore, NL stressed that their process is vastly different from the process that is prescribed by the UCC. This complexity could cause an impact to all project milestones. NL will integrate NA into ICS2 – Release 2. NL also iterated that they use the Scaled Agile Framework (SAFe) development methodology for all UCC projects. They use features, which are part of the IT solution, and do not rely on technical specifications. A bundle of features adds up to the epic solution. Given their development methodology, technical specifications are not applicable. PT rates the complexity as high (6) with a medium risk level. PT indicated that the project is currently delayed compared to the planning in the 2019 report, however the overall delivery is still expected within the deployment deadline set in the UCC Work Programme. The review of Annex B DA/IA- UCC lead to uncertainty as to the correctness and applicability of the work already carried out and the time/cost associated with a reassessment of this work. The instability of Annex B data also contributes to the complexity of activities developed and those still to be developed. This situation, in addition to the lack of consolidation of the data elements to be required (which, how and when) and the subsequent rules and conditions to treat them in the ‘global system’ contribute to the delay. The risk level mainly stems from a lack of resources in addition to the complexity of the required updates. PT will use Agile development to reduce the implementation timeframe. PT plans to increase their internal resources and to continue to support the Commission’s work related to the consolidation of the UCC-IA/DA Annex B. SE identified the project as a medium risk rating (3) and a medium risk level, commenting on the unstable situation regarding processes, the European Union Customs Data Model (EUCDM) and Annex B. Currently their planning is not fully in line with the timelines set forth in the UCC Work Programme but since the project has not yet started they are unable to assess. SK rated the project’s complexity as low (2) with a low risk level. Currently their project is delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline stated in the UCC Work Programme. They have identified risks related to a lack of human and financial resources. No mitigation actions have been considered at this moment in time. Figure 3‑1 provides an overall summary of the survey responses received from the Member States regarding the status of their project activities. Presentation Notification (PN) AT, CY, CZ, GR, IT, LV, NL, PT and SK provided the same comments as for NA. BE finds that the project has a high project complexity (6) with a medium risk level. BE is taking the lead of the pilot project and has started with the technical specifications required for the messages to the traders. SE also commented that they were participating in this pilot. Due to the complexity of managing a large group and finding compromises, BE anticipates some months of delay in the development. BE also highlights the risk that the COVID-19 pandemic may also affect the timeline however they are currently still on target. BG rates the project complexity level as high (5) yet with a low risk level. BG intends to implement PN as part of TS and their import declaration system.

DE did not provide a complexity assessment however indicated that the project had a low risk level. DE marked the project as delayed in comparison to the planning in the 2019 report, but the overall delivery date is still expected within the deployment deadline set in the UCC Work Programme. The business roadmap of the national IT-System ATLAS had to be replanned due to various unexpected factors, e.g. the implementation of the eCommerce initiative. The national import system will be implemented as part of the national IT-System ATLAS - Release 10.1. The expected date of deployment is in December 2022. ES noted PN’s complexity rating as high (5) with a high risk level mainly due to the integration with eCommerce by the beginning of 2021. ES plans to use an iterative development methodology. Development has not yet started. However, the technical specifications are complete and progress is being made on the design. ES also noted that they plan to only test the functionality for eCommerce and for ICS2 – Release 1 and that additional conformance testing will be needed for the deployment of TS and ICS2 – Release 2. FI indicated that, in addition to the comments made for NA, the basic functionality already exists but that more features and intensive testing need to be performed. FR assessed the PN project as moderately complex (3) with a low risk level. FR intends to use the application built on the Expert Teams on new approaches to develop and operate Customs IT systems (ETCIT), functional and technical specifications are ongoing. FR actively participates to the ETCIT working group. IE rated the PN project’s complexity as high (5) with a low risk level. Testing and refinement of functionality and business rules is ongoing. Work is also continuing on providing a platform to allow testing by economic operators and on change management functions including engagement with economic operators and customs officer training. IE mentioned that the project is currently delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline. The delay has been caused by instability of Annex B, deployment of resources to Brexit-related work and restrictions imposed by the COVID-19 pandemic. IE underlines the fact that mitigating measures will be considered if the project is delayed beyond the planned deployment date. RO indicated the project complexity as high (6) with a low risk level. RO explains that the PN project is included in their development of the national system of import and follows the implementation established for that system. Figure 3‑2 provides an overall summary of the survey responses received from the Member States regarding the status of their project activities. Temporary Storage (TS) AT, BE, BG, CY, CZ, DE, FR, GR, IE, IT, NL, PT, RO and SK provided the same comments as for PN. ES identifies the TS project’s complexity as high (6) with a medium risk level. ES mentioned that their project is currently delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline. Technical specifications are not defined yet, but they still expect to have it operational before the end of 2022. Changes have been made to the conformance testing and deployment milestones. FI noted the project complexity as high (6) with a high risk level. In addition to the risks mentioned for NA, FI explained that the whole system will be built from scratch and that it will contain numerous integrations. FI has not started with the deployment of the Temporary Storage Declaration (TSD). LV rated the project complexity as high (5) but with a low risk level. As from 24/09/2017, their national TS system has been updated according to the UCC data elements. Additional functionality for movements between TS places (if located in LV) was added on 05/03/2018. LV also mentioned that further developments, such as EUCDM changes, will be implemented in the timeframe between 2021 and 2023. SE considers the project to have a medium complexity rating (4) with a medium risk level. SE attributes the complexity of the project to the changes in the EU Customs Data Model (EU CDM) and the Annex B. SE further mentions that its system was ready for deployment in December 2018, but decided to wait for the stabilisation of the EU CDM and a formalisation of the decision regarding Annex B. SE is participating in the Expert Teams on new approaches to develop and operate Customs IT systems (ETCIT) lead by BE. Figure 3‑3 provides an overall summary of the survey responses received from the Member States regarding the status of their project activities.

3.1.2Overview of Project Progress Table 9, Table 10 and Table 11 highlight any known divergences in the planning compared to the dates set in the Work Programme. As regards the implementation of the Notification of Arrival, the following 9 Member States have a planned deployment date which is later than the deadline in the UCC Work Programme: BE, BG, DE, EE, ES, FI, FR, NL and RO. No planned date was provided by DK for the deployment of the NA. More specifically, 4 Member States (BG, DE, ES and NL) have reported that they will use the NA integrated in ICS2 – Release 2 (planned deployment 01/03/2023) which will cause a delay limited to two months. In comparison to the planned end dates provided in the 2019 report, the following Member States postponed their deployment date by more than one quarter: CZ, MT, RO and SK. The specific dates can be found in Table 9. CZ indicated that their national project plan is not yet final. Table 9: Comparison of Planned and Actual Dates – NA

As regards the implementation of the Presentation Notification, the following 3 Member States have indicated a planned deployment date for PN, which is later than the deadline in the Work Programme: BE, FR and NL. More specifically, NL has reported to integrate PN into ICS2 – Release 2 (planned deployment 01/03/2023) which will cause a delay limited to two months. No planned date was provided by DK for the deployment of the PN. In comparison to the planned end dates provided in the 2019 report, the following Member States postponed their deployment date by more than one quarter: CZ, DE, MT, PL and SK. The specific dates can be found in Table 10 below. CZ indicated that their national project plan is not yet final. DE mentioned that the business roadmap of their national IT system, ATLAS had to be replanned due to various unforeseen factors, e.g. the implementation of the eCommerce initiative. However, as reported, none of these postponements are currently leading to a delay of the deployment dates as set by the UCC Work Programme. ES advanced their planned deployment date one year earlier (31/01/2022 to 15/02/2021) due to the eCommerce project. As regards the implementation of the Temporary Storage, the following 3 Member States have indicated a planned deployment date for TS, which is later than the deadline in the Work Programme : BE, FR and NL. More specifically, NL has reported to integrate TS into ICS2 – Release 2 (planned deployment 01/03/2023) which will cause a delay limited to two months.

In comparison to the planned end dates provided in the 2019 report, the following Member States postponed their deployment date by more than one quarter: CZ, DE, MT, PL and SK. The specific dates can be found in Table 11 below. CZ indicated that their national project plan is not yet final. DE mentioned that the business roadmap of their national IT system, ATLAS had to be replanned due to various unforeseen factors, e.g. the implementation of the eCommerce initiative, etc. 3.1.3Analysis of Progress against Milestones Figure 3‑4, Figure 3‑5 and Figure 3‑6 summarise the status per milestone (technical specifications, conformance testing and deployment). The sum of each bar is 27 (responses from the 27 Member States). Additional details regarding the specific percentage of completion per milestone can be seen Figure 3‑7, Figure 3‑8 and Figure 3‑9. Regarding the Notification of Arrival, the following Member States have not yet started: CZ, DE, EE, FI, GR, IT, LT, NL, PL, PT, SE and SK. BE, DK, HU, LU and MT did not provide information. Lastly, IE marked Notification of Arrival as Not Applicable.





Regarding the Presentation Notification, the following Member States have not yet started: CZ, GR, IT, LT, NL, PT, SE and SK. DK, HU, LU and MT did not provide information. Regarding the Temporary Storage, the following Member States have not yet started: CZ, GR, IT, LT, NL, PT, SE and SK. DK, HU, LU and MT did not provide information. 3.2UCC National Import Systems Upgrade The project will implement all processes and data requirements deriving from the UCC, which relate to the import of goods into the Union. The existing national import systems must be upgraded in line with these new UCC requirements. The upgrade mainly relates to the changes for the "Release for free circulation" procedure (standard procedure and the simplifications) and changes in the related exchanges of information, but also covers the impact of changes in other electronic systems. This project covers the national customs declarations processing systems, as well as national accountancy and payment systems. Some Member States planned this project as a priority and have already upgraded their national import system in line with the UCC. Due to this early deployment, these Member States will need to make an additional effort for a second upgrade in view of the changes to be adopted early 2021 as part of the revised Annex B of the UCC delegated and implementing regulation. Other Member States have decided to concentrate first on other projects and wait for further progress in the specifications for the trans-European system related to import, being the Centralised Clearance at Import (CCI). In particular, those Member States that decided not to upgrade their existing national declaration system but to build a completely new one. The availability of the technical specifications provided by the Commission for the Centralised Clearance at Import system and the harmonisation across entry/import-transit-export/exit (supported by the revision of the UCC annex B data requirements and the EU Customs Data Model) were crucial achievements in 2020 to push this project forward on a national level. Although a few Member States have reported a small delay in the interim project milestones and progress is a bit doubtful for a number of Member States that didn’t start yet with the technical specifications, no Member States reported at this stage a delay in the deployment of the national import systems planned by 31/12/2022. Careful project risk management by the Member States and supervision by the Commission, in its role of coordinator, is to be envisaged for the next two years. 3.2.1Summary of Responses AT rates the project complexity as high (5) with a medium risk level. The milestone most at risk is deployment. AT is developing a new customs declaration system and the transformation process and integration with their existing application is complex. The restrictions put in place during the COVID-19 pandemic have had an impact on the onboarding and project progress. AT is currently working on the technical specifications and requirements. Furthermore, the SAFe development methodology will now be used. BE indicated that the project has a high complexity rating (6) however, a low risk level. BE explained that they will be rewriting their whole import declaration process while not having clarity on the impacts that other projects, like UCC Centralised Clearance for Import (CCI), will have on inter-system communication. BE is currently developing the system that will be used for eCommerce declarations, which will later be expanded to handle all import declarations. Afterwards, it will be adapted to handle the CCI declarations as well. BG’s system has been in production since 07/01/2019. Maintenance activities are ongoing and an upgrade to implement the review of Annex B (to be adopted early 2021), will be needed. CY denoted the project complexity as high (6) yet a low risk level. CY explained that the complexity is caused by insufficient resources, dependencies with other systems, the development of other projects in parallel and the required migration from an existing system. CY will take a phased approach and has moved the deployment date so that it does not coincide with other core projects. CZ rates the project complexity as high (5) with a medium risk level. CZ has indicated that the project requires a large amount of financial resources. In addition, there is a risk that the national project plan may have to be updated due to the COVID-19 pandemic and the delays it is causing. The required changes will depend on the development of the situation. DE did not provide a complexity assessment however indicated that the project had a low risk level. DE marked the project as delayed in comparison to the planning in the 2019 report, but the overall delivery date is still expected within the deployment deadline set in the UCC Work Programme. The business roadmap of the national IT-System ATLAS had to be replanned due to various unforeseen factors, e.g. the implementation of the eCommerce initiative. The national import system will be implemented as part of the national IT-System ATLAS - Release 10.1. The expected date of deployment is in December 2022. FI considers the project complexity as high (6) with a high risk level. Currently there is a risk that their deployment and integration testing will be impacted. A rescoping exercise is ongoing and some components have already been postponed to Q4 2021. This will also affect the planning and implementation of future UCC projects.

GR rates the complexity as high (5) with a medium risk level. GR explains that there is no contract in place yet and that a new technical data sheet is being studied and drafted. HR indicated the project complexity as high (6) with a high risk level citing the many interdependencies among systems. Furthermore, HR explained that the project is very complex and human resources are limited as team members are involved in other MASP/national projects. The COVID-19 pandemic has also raised concerns regarding the implementation of phase 1 of the eCommerce project. IE rated the project complexity as high (6) with a high risk level. Testing and refinement of functionality and business rules is ongoing. Work is also continuing on providing a platform to allow testing by economic operators and on change management functions including engagement with economic operators and customs officer training. IE mentioned that the project is currently delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the UCC Work Programme deployment deadline. The delay has been caused by the instability of Annex B, new requirements for Low Value Consignments, the VAT directive, deployment of resources to Brexit-related work and restrictions imposed by the COVID-19 pandemic. IE underlines the fact that mitigating measures will be considered if the project is delayed beyond the planned deployment date. LV informed that their national import system has been aligned with UCC DI/IA Annex B and EUCDM V2.0 as from 03/06/2018. Further developments such as EUCDM changes, eCommerce, integration with ECMS, are planned to be implemented in 2021-2023. PT rates the project complexity as high (6) with a medium risk level. PT explains that the development of this system is not only related with the system itself, but also to the development of all national, central and other MS´s systems/modules. This increases the interdependencies and the complexity of the “global system”. The review of Annex B DA/IA-UCC makes it difficult to determine whether their work completed continues to be correct and applicable. Consequently, additional costs are created by the need to reassess the aforementioned developments thus further adding to the complexity of the deliverables. The deadline for the end of the work related to the harmonisation / modification of Annex B - Columns H and I, was the end of 2019, however at the time of writing this report, the new version of Annex B is still not approved. PT also mentions that the creation of new obligations/deadlines for Member States, like reviewing the package related with column H7 to be implemented in 2021, also creates a constraint in updating their national import system because they have developed a new system to deal with the eCommerce package. SI reports the project complexity as high (6) and a high risk level. SI was expecting the Commission to prepare the technical specifications for the import declaration, code list for the Automated Import System (AIS) in the Central Services Reference Data 2 (CSRD2), etc. SI explains that they have limited human resources and that their team members work on several projects simultaneously. Furthermore, there is a concern over financial resources as the COVID-19 pandemic unfolds. SI is convinced that the customs environment will be ready on time however, they have doubts regarding the testing readiness of the external environment (economic operators). SK’s system has been in production since 30/06/2019. An upgrade to implement the review of Annex B (to be adopted early 2021), will be needed. Figure 3‑10 provides an overall summary of the survey responses received from the Member States regarding the status of their project activities. 3.2.2Overview of Project Progress Table 12 highlights any divergences in the planning compared to the dates set in the Work Programme. In comparison to the planned end dates provided in the 2019 report, the following Member States postponed their deployment date by more than one quarter: DE, DK, MT and PL, however, for none of them a final delay in the date of deployment beyond the date set in the UCC Work Programme is marked. The specific dates can be found in Table 12 below. DE mentioned that the business roadmap of their national IT system, ATLAS had to be replanned due to various unforeseen factors, e.g. the implementation of the eCommerce initiative. 3.2.3Analysis of Progress against Milestones Figure 3‑11 summarises the status per milestone (technical specifications, conformance testing and deployment). The sum of each bar is 27 (responses from the 27 Member States).





Additional details regarding the specific percentage of completion per milestone can be seen in Figure 3‑12. The following Member States have not yet started: CZ, GR, HU, LT, LU, MT, NL and PT. 3.3UCC Special Procedures This national project aims to accelerate, facilitate and harmonise Special Procedures across the Union by means of providing common business process models. The national systems will implement all UCC changes required for all the special procedures (customs warehousing, end-use, temporary admission and inward/outward processing). It should be noted that, in many Member States, the implementation of this project occurs within the context of the upgrades of the national import and export systems. In terms of planning, this project will be implemented in two parts. The first component is the "National Special Procedures EXP" (NSP EXP) with the view to providing the required national electronic solutions for the export-related special procedure activities. The second component is the "National Special Procedures IMP" (NSP IMP) with the view to providing the required national electronic solutions for the import-related special procedures activities. 3.3.1Summary of Responses Special Procedures EXP – Component 1 AT rates the project complexity as medium (4) with a medium risk level. The milestone most at risk is deployment. AT is developing a new customs declaration system and the transformation and the integration with their existing application are complex. The restrictions put in place during the COVID-19 pandemic have had an impact on the on boarding and project progress. AT is currently working on analysing and elaborating the technical specifications. An Agile development methodology (SAFe) will now be used. BG, IE and RO rated the project complexity as high (5, 5 and 6 respectively) however, a low risk level. The Member States confirmed that they will implement this project as part of the UCC Automated Export System (AES) project. CY denoted the project complexity as high (6) yet a low risk level. CY explained that the complexity is caused by insufficient resources, dependencies with other systems and the development of other projects in parallel. CY explained that a phased approach will be taken and that the deployment date was moved so that it does not coincide with other core projects. CZ reports the project complexity as high (6) with a medium risk level stating that it requires a large amount of financial resources. CZ also highlighted a risk that the national project plan may have to be updated due to the COVID-19 pandemic and the delays it is causing. The changes will depend on the evolution of the situation. In line with their national project plan, they are preparing detailed national technical and functional specifications. No major changes were made to the planning and their national project plan is stable. EE indicated the project complexity as high (6) yet the risk level is low. Currently the preparation for the call for tender is ongoing. EE considers the project delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline set in the UCC Work Programme. The procurement process is delayed, however, mitigation actions are considered. FI notes the project complexity as high (6) with a high risk level, commenting that their plans have not changed however, they anticipate several risks and due to this, changes in planning will most likely be needed. The project to deliver AES will be organised during 2020 and SP – Component 1 will be a part of it. The preliminary planning has already started. GR indicated a high complexity level (6) and a medium risk level. GR indicated that the project is currently delayed compared to the planning in the 2019 report, however the overall delivery is still expected within the deployment deadline set in the UCC Work Programme. GR is facing procurement delays.

HR rated the project complexity as high (5) with a medium risk level citing the many interdependencies among systems. HR plans to complete the main components of the technical specifications and they have shortened the overall project duration by five months. HR plans to go into production on 01/01/2023. LV noted that the project complexity as medium (3) with a high risk level mentioning that there is currently no budget allocated to support the development of AES. Once this is solved, LV will use an iterative development approach. The development scope and plan for AES, including the transition model and functionality, are under review. NL reported the project complexity as medium (4) with a low risk level. NL comments that an agile development approach will be used. They are currently describing project features based on the Design Document for National Transit Application (DDNTA). The selection of the IT provider for development is in progress. PL indicated the project complexity as high (5) with a medium risk level explaining that this project includes the creation of a new national IT system for managing and settlement of SP and integration with other IT national customs systems, which are currently being expanded. The complexity is particularly due to the integration with the national IMP and EXP systems in the field of online transfer of data from customs declarations. SI noted the project complexity as medium (4) with a high risk level, citing the COVID-19 pandemic as a major risk. This situation could cause the postponement of the deployment date. Their external contractor is currently preparing the detailed technical specifications for AES. SK rated the project complexity as low (2) with a low risk level. Currently, their project is delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline stated in the UCC Work Programme. They have identified risks related to a lack of human and financial resources. No mitigation actions have been considered at this moment in time. The achievement of some milestones is dependent on the progress of other projects. System tests have recently been performed, without integration with other systems. Feedback submitted by testers is currently being analysed. The COVID-19 pandemic has had an impact on their training plan. Figure 3‑13 provides an overall summary of the responses received from the Member States regarding the status of their project activities. Special Procedures IMP – Component 2 AT, CY, GR, PL and SK provided the same comments as for Special Procedures - Component 1. CZ has indicated the project complexity as high (5) with a medium risk level. CZ reported no progress on Component 2 and stated their national project plan is not yet finalised. DE did not provide a complexity assessment however indicated that the project had a low risk level. DE explained that they will implement this component as part of the "National Import Systems upgrade", which will be covered by the national IT-System ATLAS - Release 10.1. The expected deployment date is in December 2022. EE rated the SP – Component 2 project’s complexity as high (6) with a medium risk level regarding limited resources. System development is currently ongoing, with a plan to be complete by the end of 2020. FI noted the project complexity as high (6) with a high risk level. A re-scoping exercise is ongoing. Simplifications are postponed to Q4 2021. This will also affect the planning and implementation of future UCC projects. IE indicated the project complexity as high (5) yet with a low risk level. Testing and refinement of the system functionality, business rules, etc. is ongoing. Work is also continuing on providing a platform to allow testing by traders and on change management functions including engagement with trade and customs officer training. IE mentioned that the project is currently delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline. The delay has been caused by the instability of Annex B, new requirements for Low Value Consignments, the VAT directive, deployment of resources to Brexit-related work and restrictions imposed by the COVID-19 pandemic. IE underlines the fact that mitigating measures will be considered if the project is delayed beyond the planned deployment date. LV’s national import system has been aligned with UCC DA/IA Annex B and EUCDM V2.0 as of 03/06/2018,

PT made the same comments as in section 3.2 UCC National Import System Upgrade. RO rated the project complexity as high (6) yet with low risk level as SP – Component 2 will be incorporated into their new national import system. SE identified the project complexity as high (5) and with a medium risk level commenting on the unstable situation regarding processes, EU CDM and Annex B. There is a risk that the conformance testing and deployment milestones are impacted. SI reports the project complexity as high (6) with a high risk level. SI was expecting the Commission to prepare the technical specifications for the import declaration, code list for the Automated Import System (AIS) in Central Services – Reference Data 2 (CSRD2), etc. SI explained that they have limited human resources and that their team members work on several projects simultaneously. Furthermore, there is a concern over financial resources as the COVID-19 pandemic unfolds. SI is convinced that the customs environment will be ready on time however has doubts regarding the testing readiness of the external environment (economic operators). Figure 3‑14 provides an overall summary of the responses received from the Member States regarding the status of their project activities. 3.3.2Overview of Project Progress Table 13 highlights any known divergences in the planning of the UCC Special Procedures EXP compared to the dates set in the Work Programme . In comparison to the planned end dates provided in the 2019 report, the following Member States postponed their deployment date by more than one quarter: LT, MT and SK. BG moved their deployment date earlier by two months (01/08/2023 to 05/06/2023). HR and FR moved their planned deployment dates earlier by six months, and NL and SE by one year. The specific dates can be found in Table 13 below.



In comparison to the planned end dates provided in the 2019 report for the UCC Special Procedures IMP, the following Member States postponed their deployment date by more than one quarter: CZ, DE, EE, MT, SE and SK. CZ indicated that their national project plan is not yet final. DE explained that this component will be implemented as part of the "National Import Systems upgrade", which will be covered by their national IT-System ATLAS - Release 10.1. 3.3.3Analysis of Progress against Milestones Figure 3‑15 and Figure 3‑16 summarise the status per milestone (technical specifications, conformance testing and deployment). The sum of each bar is 27 (all Member States).

Additional details regarding the specific percentage of completion per milestone can be seen in the following figures. Regarding Special Procedures EXP - Component 1, the following Member States have not yet started: EE, FI, IE, LT, NL, PT, SE and SK. The following Member States did not provide information: BE, DK, FR, HU, LU and MT. Regarding Special Procedures IMP - Component 2, the following Member States have not yet started: CZ, DE, GR, HR, LT, NL, PT, SE and SK. The following Member States did not provide information: BE, DK, FR, HU, LU, and MT.



3.4UCC Guarantee Management (GUM) The UCC Guarantee Management (GUM) project aims to assure the effective and efficient management of the different types of guarantees. The main objective is to ensure that the data of guarantees, which are used in more than one MS, are made electronically accessible to the MS where a customs declaration is lodged and accepted when such guarantee is used. This will require new interfaces between GUM and national systems. One advantage of the solution is that the traders can provide one guarantee that can be used across the Union. Moreover, the improved processing speed, traceability and monitoring of guarantees electronically between customs offices is expected to lead to a faster identification of cases where guarantees are deemed invalid or insufficient to cover the incurred or potential debt. The system is comprised of two components. The first component is "GUM". GUM is a trans-European system that will cover the management of the comprehensive guarantees that may be used in more than one Member State. Transit is an exception to the above and is handled as part of the NCTS project. At the moment of drafting this UCC annual report, the project initiation phase is still ongoing and the exact scope and implementation approach is taking form in the context of the approval of the business case document. Alternative ways of re-using a part of an existing system (such as the Customs Decisions System) and maintaining more processes decentralised at national level (in the National Guarantee Management systems) are considered, mostly due to the uncertainty of the real interest from trade for such kind of comprehensive guarantees. A new survey was launched which contributed to a decision in favour of a light IT implementation option instead of building a new self-standing trans-European system. This decision may then also affect the second component of the project, which is the "National Guarantee Management" system. In addition to GUM, the electronic systems existing at the national level, which manage the valid guarantees in one Member State, are to be upgraded. 3.4.1Summary of Responses This project is still in the early stages of development with a decision on the implementation option just finalised. Based on the decision, a legislative change and project re-scoping and re-planning may be needed. Even if the business case and scope discussions are putting some risks of delay for the project, it should be considered that going for the use of existing IT systems rather than developing a new one will most likely bring benefits in terms of development time and might not necessarily impact the planned start of deployment. The planning aspect will need to be carefully examined and addressed in the coming years by the Commission and the Member States to keep this project on track.

GUM – Component 1 The European Commission sent the revised business case for external review to the Member States and trade associations on 21 April 2020. Following this review the business case was approved on 25/09/2020. The chosen option to use the Customs Decisions System might require less effort in the IT implementation but will on the other hand require a legislative change. This could potentially be a risk so it will become necessary to identify and initiate the required changes as early as possible. National GUM – Component 2 National GUM – Component 2 refers to the development of Member States’ National Guarantee Management systems, which will potentially link to GUM – Component 1, again depending on the solution chosen. This work can mainly be done in parallel with GUM – Component 1. There is a project interdependency on the National Import System of each Member State, where they have multi-Member States’ guarantees involved. AT and BG view the project complexity as medium (ratings of 3 and 4 respectively) however, with a low risk level since the National GUM – Component 2 project is dependent on the decisions taken at the level of the Commission. The countries are waiting for the technical specifications to be provided by the Commission. AT identified that they will be using the SAFe-Framework for development. EE identifies the project complexity as high (6) with a medium risk level, identifying a lack of resources as their main concern. ES confirms the completion of their national guarantee management system, which went live on 01/09/2016. Future modifications to ensure the link to GUM – Component 1 are foreseen. FI considers the project complexity as high (5) with a high risk level, commenting that it requires a large number of integrations. FI further reiterates the comments made in section 3.1. FR indicates the project complexity as medium (4) with a high risk level, which could potentially affect their ability of achieving their planned dates for the Technical Specifications and Conformance Testing. Reasons for this delay are due to dependencies on their legal department and new resources that are being recruited. FR also noted that an iterative development approach would most likely be used. HR rates the project complexity as high (5) with a medium risk level, stating that there are limited dedicated human resources. IE assesses the project complexity as high (5) but with a low risk level. Testing and refinement of the system functionality, business rules, etc. are ongoing. Work is also continuing on providing a platform to allow testing by traders and on change management functions including engagement with trade and customs officer training. Currently, they consider the project as delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline. The causes of delay are due to the instability of the data in Annex B, new requirements for LVCs, the VAT directive, redeployment of resources to other projects and restrictions imposed by the COVID-19 pandemic. IE iterated that mitigation measures are considered if the project becomes delayed beyond the planned deployment date. NL considers the project complexity as low (1) with a low level of risk. NL explains that an agile development approach will be used. This approach will start with describing a high-level design of the requirements (features) and IT solution, in the so-called ‘Epic’ format. The start date of the activity is still to be decided and is dependent on other priorities. PT considers the project complexity as high (6) with a high level of risk, as this project is the implementation of a completely new national system. PT identifies a risk due to a lack of resources however confirms that an Agile development approach will be used in order to reduce the implementation timeframe. SE determines the project complexity as medium (3) with a medium risk level. SE considers the project as delayed in comparison to the planning in the 2019 report, however, the overall delivery is still expected within the deployment deadline. There is an interface to the new national import declaration system and the deployment of this system is not yet stable. They are investigating the possibility to establish a temporary interface to their current import declaration system. SI considers the project complexity as medium (4) with a high risk level. The main risk is due to the COVID-19 pandemic. The potential impact is unknown however, there could be an impact on the deployment date.

Figure 3‑19 provides an overall summary of the survey responses received from the Member States regarding the status of GUM – Component 2. 3.4.2Overview of Project Progress Table 15 and Table 16 highlight any known divergences in the planning compared to the dates set in the Work Programme. Regarding GUM – Component 1, there is some delay in the initiation of the project due to the re-orientation and business case discussion, however, the overall delivery is still expected within the deployment deadline. Regarding National GUM – Component 2, compared to last year’s planning provided in their survey response, SE has postponed their deployment date by one quarter (01/10/2020 to 01/01/2021). The project is delayed in comparison to the planning in the 2019 report, but the overall delivery is still expected within the deployment deadline. There is an interface to the new national import declaration system and the deployment of this system is not yet stable. SE is investigating the possibility to establish a temporary interface to their current import declaration system. 3.4.3Analysis of Progress against Milestones Figure 3‑20 summarises the status per milestone (technical specifications, conformance testing and deployment) for the National GUM – Component 2. The sum of each bar is 27 (responses from the 27 Member States). Regarding National GUM - Component 2, the following Member States have not yet started: AT, CY, DE, FI, GR, HR, NL, PT, RO, SI and SK.

The following Member States did not provide information: BE, CZ, DK, HU, LU and MT. LV updated their National Guarantee System together with their National Import System on 03/06/2018. Also BG, IE and ES have implemented a national GUM system. 3.5UCC Import Control System 2 (ICS2) The goal of the UCC Import Control System 2 (ICS2) programme is to strengthen the safety and security of the supply chain for goods moved via all modes of transport. The aim is to do so through better targeted risk based controls of EU customs authorities based on improved Entry Summary Declaration (ENS) data quality, data filing, data availability and data sharing and through real-time collaborative risk analysis and co-ordinated safety and security controls at the EU entry points. The main purpose of the system is to implement the new requirements resulting from the UCC and strategic objectives endorsed by the Member States in the Risk management strategy and action plan of 2014. This multi-annual programme will lead to a complete new architecture of the existing ICS trans-European system. In terms of planning, the programme will be implemented in three releases. Release 1 will cover the obligation on the relevant economic operators (postal operators and express carriers in air transport) to provide the minimum data i.e. ENS pre-loading dataset. Release 2 will cover the implementation of new ENS obligations and related business and risk management processes for all the goods in air traffic. Release 2 is planned to cover also Safety and Security analytics capabilities, subject to the policy endorsement by the Member States scheduled for December 2020. Release 3 will cover the same implementation as Release 2 but for all goods in maritime and inland waterways, road and rail traffic (this also includes goods in postal consignments transported in these means of transport). 3.5.1Summary of Responses The Commission centrally develops common components (Shared Trader Interface and Common Repository) and the common functional system and technical specifications. The baseline functional and technical specifications for all three releases were completed on 30/06/2018. As regards implementation of the ICS2 programme, the Commission continued with ICS2 trans-European coordination activities throughout the year 2020. Work focused on ICS2 Release 1 implementation with a view of facilitating operational preparedness by Member States customs authorities, express carriers and EU postal operators as from 15 March 2021. The Commission provided support to the national administrations and economic operators in their development activities via a set of activities which continued in the year 2020 and include: ·Creation of a dedicated forum and organisation of dedicated webinars, support via frequently asked questions and organisation of regular ICS2 trans-European coordination plenary meetings with participation of all Member States customs national ICS2 project management and risk management representatives, individual economic operators, trade associations and international organisations; ·Close and continuous monitoring, planning of national and trade project plans to ensure their alignment with the Commission’s central planning across relevant IT delivery milestones (conformance testing campaigns, end-to-end testing, dry run testing). This consisted of continuous support to coordination of conformance test activities and stimulating national administrations and economic operaotrs to co-ordinate their individual projects; ·Preparation for the launch of communication campaigns, with different activities implemented in the year 2020 and throughout the ICS2 programme implementation, including creation of ICS2 programme specific content on DG TAXUD webpage; ·Preparation of the training material that will be based on the compendium of ICS2 Release 1 common operational guidance. The Commission and the Member States categorise the complexity of ICS2 – Release 1 as high (6), mainly due to the very high required availability and real-time business and risk analysis processes that affects the infrastructure requirements. Furthermore, the Commission underlined the dependencies on other systems, as well as the fact that conformance testing with economic operators systems is required. A number of Member States reported to have some issues on the national implementation side, in particular in view of the tight conformance testing framework.

Taking into account that the Member States reported certain risks for timely implementation of ICS2 Release 1 of their national components, the Commission will continue to closely monitor overall progress of the project implementation on the side of the MS for release 1 based on the below results and tables and the additional info available on COM side. The Commission classifies the risk level as medium, reporting that on-time delivery is probable. ICS2 – Release 1 AT considers the project complexity as medium (3) highlighting the high level of risk regarding the functional interaction and tight timeline between relevant projects. In addition to this, concerns with the ongoing COVID-19 pandemic were highlighted. AT mentioned that there is a risk that all milestones could be impacted. Currently work is ongoing on the national user requirements, technical specifications, conformance testing, user tests, training and deployment preparation. BG indicates the project complexity as high (5) however with a low risk level. BG explains that it is necessary to upgrade their national import system, national risk analysis system and the national part of CCN in conjunction. BG has decided to use an agile/iterative approach for development. They have chosen to apply an adapted and combined implementation of two methodology frameworks – Adaptive Development Methodology (ADM) and Rational Unified Process (RUP). ADM is for the implementation and maintenance of the overall architecture while RUP is used to manage the software lifecycle of the software solution. According to RUP, the inception phase was completed and they should be in the transition phase by the end of 2020. CY notes the project complexity as high (6) yet with a low risk level. The reasons given for the high complexity rating being insufficient resources and the development of other projects in parallel. CY also indicates that the system will be ready by the end of June 2020 and that end-to-end testing is planned for Q4 2020. CZ considers the project complexity as high (6) with a medium level of risk. The main risk to their planning is the COVID-19 pandemic. However, they are currently in the development phase as per their national project plan. They reported that their national system for ICS2 – Release 1 will be available in a national test environment no later than September 2020. From October 2020, they will conduct conformance testing with the European Commission. ES identifies the project complexity as high (6) with a medium risk level. ES noted that the complexity is due to the integration of multiple nodes and the fact that not all components are fully defined, such as the risk analysis process. ES further explained that the dates of conformance testing may be impacted if not all components are ready on time (UUM&DS, CCN2, etc.). ES are using an Agile development methodology and they are currently preparing the message interface for conformance testing. FI indicated the project complexity as high (6) with a high risk level for all ICS2 releases. FI noted that deployment, including the presentation of goods, is completed and that testing is about to start. FI further reiterates the comments made in section 3.1. GR indicated a high complexity level (6) and a high risk level. GR indicated that the project is currently delayed compared to the planning in the 2019 report, however the overall delivery is still expected within the deployment deadline set in the UCC Work Programme. GR is facing procurement delays. HR highlighted the project complexity as high (6) with a high risk level for all ICS2 releases. There are many interdependencies among supporting systems. The main risks are completing the tests on time, the COVID-19 pandemic and a limited number of human resources. IT considers the project complexity as high (5) with a low risk level. IT explained that an iterative approach is used and periodical releases have been planned. IT highlights a risk that the COVID-19 pandemic could cause a delay in Release 1, which could then affect Releases 2 and 3. LV noted the project complexity as high (6) yet with a low risk level. LV is employing an iterative development approach and will divide Release 1 into three phases. The first phase, which includes the new IT architecture, the general database, two mock-up web services and the starter GUI, was delivered. The second phase, which includes a functional GUI, underlying business processes and functional web services, is currently under development. LT considers the project complexity as high (5) with a medium risk level. LT highlighted a risk regarding a tight conformance testing timeframe. LT is using an iterative development approach. NL rated the ICS2 project complexity as high (5) with a medium risk level. The complexity is due to the transnational (common) specifications of ICS2 (e.g. message structures, process flows) being quite complex. Furthermore, each Member State is required to define their national requirements together with many user groups (e.g. policy makers, risk analysts, control officers) and outside of their organisation (e.g. the postal operator). NL foresees a risk to the conformance testing because almost all stakeholders, including several development teams, are simultaneously required to run the tests and solve the test findings. This will require extensive communication and collaboration. Lastly, this project has a fixed deadline of 15 March 2021 and solving the test findings may require more time. NL expects to be solving potential conformance testing findings by October 2020 and to be ready for the end-to-end testing in November 2020. RO noted the project complexity as high (6) with a high risk level indicating that the deployment date is at risk to be delayed beyond the deadline in the UCC Work Programme. The reasons RO mentioned were due to the lack of personnel, their organisational structure and ongoing activities related to the procurement of a contractor. RO is taking actions to reduce the delay as much as possible. Furthermore, considering the COVID-19 pandemic, RO has requested the European Commission to consider delaying the deployment date.

SI rated the project complexity as high (6) with a high risk level. SI is facing delays with an external contractor in addition to constraints caused by the COVID-19 pandemic. Despite this, development and conformance testing are ongoing. Figure 3‑22 provides an overall summary of the survey responses received from the Member States and the Commission regarding the status of each ICS2 release. ICS2 – Release 2 AT considers the project complexity as medium (3) with a low risk level. AT has started working on the technical specifications. BG rated the project complexity as medium (4) with a low risk level. BG is analysing the functional and technical specifications provided by the European Commission, which will be further enhanced with national requirements. CY states the same reasons for the high project complexity rating (6) yet low risk level as for Release 1. CY also noted that a phased approach will be taken and the date of operations has been reassessed to ensure it will not coincide with other core projects. CZ considers the project complexity as medium (4) with a medium risk level. CZ finds the application complex and has indicated that it requires a large amount of financial resources. CZ highlighted a risk that the national project plan may have to be updated due to the COVID-19 pandemic and delays it is causing. The changes will depend on the evolution of the situation. CZ is waiting for the European Commission to provide the technical and functional specifications. DE did not provide a complexity assessment however indicated that the project had a low risk level. DE mentions that ICS2 – Release 2 will be implemented in the major release of their national IT-System ATLAS (Releases 10.1) for which the preparatory activities have not yet started. The expected deployment date is Q1 2023. ES rated the project complexity as high (6) with a medium risk level. ES indicated that they believe Release 2 will be more complex than Release 1. ES plans to start Release 2 after Release 1 is in production on March 2021. FI indicated the project complexity as high (6) with a high risk level. FI has not yet started work on Release 2 however explained that multi-filing will be demanding and that the size of the risk analysis request messages will increase drastically. This will be a challenge for the national risk analysis system. FI further reiterates the comments made in section 3.1. HR noted the project complexity as high (6) with a high risk level as they do not currently have national planning dates for Releases 2 and 3. LV considers the project complexity to be high (5) with a high risk level. LV explained that there is currently no budget allocated to support the development of ICS2 – Releases 2 & 3. LV did note though, that ICS2 – Release 2 would use the database and GUI that were already deployed in the conformance environment for ICS2 – Release 1. LT considers the project complexity as high (5) with a low risk level. LT is using an iterative development approach and has started working on the technical specifications. NL reiterates the same reasons for the high project complexity (6) and high risk ratings and explains that work has not yet started on Releases 2 & 3. Figure 3‑23 provides an overall summary of the survey responses received from the Member States and the Commission regarding the status of each ICS2 release.

ICS2 – Release 3 The comments for the following Member States are the same as for ICS2 – Release 2: CY, CZ and HR. DE did not provide a complexity assessment however indicated that the project had a low risk level. DE mentions that ICS2 – Release 2 will be implemented in the major release of their national IT-System ATLAS (Releases 10.2) for which the preparatory activities have not yet started. LT considers the project complexity as high (5) with a low risk level. LT is using an iterative development approach and has started working on the functional requirements. Figure 3‑24 provides an overall summary of the survey responses received from the Member States and the Commission regarding the status of each ICS2 release. 3.5.2Overview of Project Progress Table 17, Table 18 and Table 19 indicate the percentage of completion as of the end of 2020 in comparison to the target dates set forth in the UCC Work Programme.

The target date set for the technical specifications is in reference to the common technical specifications. Member States have reported the percentage of completion regarding their own national technical specifications, which are to be prepared incrementally for the three releases. The Commission will perform adjustments to the specifications for Releases 2 and 3 as per the MASP-C. The planned completion dates for the Conformance Testing are included for Release 1 based on the national plans submitted by the Member States at the end of July 2020.

3.5.3Analysis of Progress against Milestones Figure 3‑25, Figure 3‑26 and Figure 3‑27 summarise the status per milestone (technical specifications, conformance testing and deployment). The sum of each bar is 28 (responses from the 27 Member States plus the European Commission). Regarding ICS2 - Release 1, all Member States have started their technical specifications. BE, DK, HU, IE, LU and MT did not provide information. See fig 3-28 below: Regarding ICS2 - Release 2, the only Member States which have started their technical specifications are AT, ES, FI, FR, LT, LV, RO and SI. BE, DK, HU, LU, and MT did not provide information.





Regarding ICS2 - Release 3, the only Member States, which have started their technical specifications, are LT and LV. AT marked the release as N/A and BE, DK, FR, HU, LU and MT did not provide information. 3.6UCC Proof of Union Status (PoUS) PoUS is a new trans-European system, which is designed to allow storage, management and retrieval of certain types of documents (e.g. T2L, T2L/F, customs goods manifest) that traders provide to prove the Union status of their goods. The system will improve the uniformity of the procedures across the European Union and contribute to the establishment of a more consistent, harmonised and thus simplified process related to customs clearance for Union goods. A system will be created that will include a Central Repository for the storage and exchange between Customs Authorities across all Member States of data and documents dealing with proof of Union status. The project is split into two phases: • Implementing the electronic T2L (F) document with all the necessary functionalities (planned deployment 01/03/2024); • Implementing the electronic Customs Goods Manifest (CGM), including the information exchange with the European Maritime Single Window environment (planned deployment 02/06/2025). 3.6.1Summary of Responses The Commission reported that the business process models and the package of functional specifications were approved by the Member States in quarter 1 of 2020. In addition, the vision document was completed in Q3 2020. An agile development approach is in place to be used for the project. The project is progressing according to the planning set by the UCC Work Programme. Member States will have the option of using the central PoUS system or developing their own national application. From the 2019 survey results, several Member States conveyed their intention to use the system developed by the European Commission: BG, DE, EE, ES, FI, LT, LV, RO, SE and SI. DK expressed the view that Member States opting to use the Commission system will be subject to the delivery dates indicated in the Work Programme. In terms of the overall project status, PT thought it might be necessary to develop national technical specifications for the purpose of communications with economic operators. Those Member States opting to develop national versions of PoUS identified risks for compliance with the timeline and the predicted milestones. The process of awarding the tender is still in progress for CY, while CZ reported that the business documentation was recently completed and the technical documentation is still being finalised. CY views the risk as low and the project complexity as high (6). CZ marks both project complexity (3) and the risk level as medium. During a follow-up communication, CZ, along with other Member States, indicated that they would follow the latest deadlines provided by the Work Programme, yet revealed that they had not yet appointed a National Project Manager. IE expressed the same willingness to readjust national planning deadlines to comply with the timeline. SK voiced a concern regarding the sufficiency and expertise of its human resources, identifying the project as medium risk with a medium complexity (3). It does not yet foresee any mitigating actions, as its impact analysis is still ongoing. 3.6.2Overview of Project Progress

Taking into account the new developments during the second half of 2019 in regards to the implementation approach for the PoUS project, it is not possible to report any firm divergences in planning compared to the dates set in the Work Programme. In the final version of the UCC Work Programme, a two-phased approach was agreed in order to allow the customs goods manifest implementation to be linked to the European Maritime Single Window implementation. At the time of writing the report, National Planning information has not yet been collected per phase of the project.



3.7UCC Centralised C