A series of delays in customs IT systems : what went wrong? Special report No 26, 2018.
Date: 2019-01-24
Institutions: European Court of Auditors
Subjects: EU customs procedure, audit, commercial code, customs cooperation, customs harmonisation, customs union, information system, information technology applications, report

EN 

2018 

NO 26

Special Report  A series of delays in 
Customs IT systems: 
what went wrong?

(pursuant to Article 287(4), second subparagraph, TFEU) 

AUDIT TEAM 

The ECA’s special reports set out the results of its audits of EU policies and programmes, or of 

management-related topics from specific budgetary areas. The ECA selects and designs these audit 

tasks to be of maximum impact by considering the risks to performance or compliance, the level of 

income or spending involved, forthcoming developments and political and public interest. 

This performance audit was carried out by Audit Chamber V Financing and administration of the EU, 

headed by ECA Member Lazaros S. Lazarou. The audit was led by ECA Member Eva Lindström, 

supported by Katharina Bryan, Head of Private Office and Johan Stålhammar, Private Office Attaché; 

Alberto Gasperoni, Principal Manager; José Parente, Head of Task; Jitka Benešová, Josef Edelmann, 

and Ilze Ozola, Auditors.  

From left to right: Jitka Benešová, Alberto Gasperoni, Ilze Ozola, José Parente, Eva Lindström, 
Johan Stålhammar, Katharina Bryan, Josef Edelmann. 

TABLE OF CONTENTS 

Abbreviations 

Glossary 

Executive summary 

Introduction 

The Customs Union is one of the pillars of the Single Market in the 
European Union 

Since 2003 the modernisation of the Customs Union has been on the EU 
agenda 

The Customs 2020 programme is the current financial tool for 
implementing the necessary IT systems 

Governance of the implementation of IT systems in the Customs Union is 
multi-layered 

Audit scope and methodology 

Observations 

2 

Paragraph 

1 - 11 

1 - 3 

4 - 7 

8 - 10 

11 

12 - 15 

16 - 47 

Implementation of new IT systems for customs suffered a series of delays 

16 - 22 

Delivery of some key IT systems required by the Union Customs Code 
is delayed beyond 2020 

There is a risk of not meeting the newly proposed 2025 deadline 

Changing scope, insufficient resources allocated and a lengthy decision-
making process were the main reasons for delays 

The Commission was late in reporting the delays 

The initial development approach selected was not the most cost 
efficient 

The Customs 2020 programme objectives and reporting arrangements 
are not suitable for monitoring the IT systems’ implementation 

Conclusions and recommendations 

19 - 21 

22 

23 - 36 

37 - 40 

41 - 42 

43 - 47 

48 - 50 

 
Annex I - IT projects' description 

Annex II - Additional number of years needed to deliver each IT project as compared to the 

initial planning 

3 

Commission’s replies 

 
 
 
 
4 

ABBREVIATIONS  

CPG: Customs Policy Group 

DG TAXUD: Directorate-General for Taxation and Customs Union 

ECCG: Electronic Customs Coordination Group 

EIS: European Information Systems 

IT: Information Technology 

MCC: Modernised Customs Code 

PMF: Performance Measurement Framework 

TCG: Trade Contact Group 

UCC: Union Customs Code  

 
 
 
5 

GLOSSARY  

The description of the IT projects mentioned in the report can be found in Annex I. 

Business Case and Vision Document: Documents for the initial IT system development 

project phases, which contain the detailed specification of the scope of each project and 

precede the decision to launch the technical IT works. 

Customs 2020 programme progress report: Annual report that monitors the 

implementation of the programme pursuant to Article 17 of Regulation (EU) No 1294/2013. 

e-Customs progress reports: Annual report that evaluates the progress made towards a 

paperless environment in customs pursuant to Article 12 of Decision 70/2008/EC. 

EU components of the IT systems (Union components): Assets (such as hardware, software, 

network connections) and services to support IT systems that are common to participating 

countries (Annex II B of Regulation (EU) No 1294/2013). The EU pays for acquisition, 

development, installation, maintenance and day-to-day operation of the Union components. 

Expert team: Expert teams are a tool from the Customs 2020 programme joint actions to 

pool expertise in a variety of ways; on a regional, thematic, temporary or permanent basis. 

This tool allows Member States to enhance their cooperation when implementing policy. 

National components of the IT systems (non-Union components): All those components of 

IT systems that are not identified as Union components (Annex II C of Regulation (EU) No 

1294/2013). The Member States pay for the cost of acquisition, development, installation, 

maintenance and day-to-day operation of the non-Union components. 

Modernised Customs Code: It entered into force on 24 June 2008, with a provision that it 

would be applicable on 24 June 2013 at the latest. However, it was never applied since it was 

repealed and replaced with the Union Customs Code. 

Multi-Annual Strategic Plan: Management and planning tool drawn up by the Commission in 

partnership with the Member States in accordance with Article 8(2) of the e-Customs 

Decision. It sets down a strategic framework and milestones for managing IT projects 

coherently and effectively. 

 
6 

Performance Measurement Framework: A monitoring system that measures the progress of 

the Customs 2020 programme by means of 86 indicators, made up of 68 output/result 

indicators and 18 impact indicators. 

Project scope: What is included in, or excluded from, a project. The Project Management 

Institute defines project scope as “The work that needs to be accomplished to deliver a 

product, service, or result with the specified features and functions.” 

Trade representatives: These are operators such as importers, customs brokers, transport 

companies and logistic operators. They are members of the Trade Contact Group, which is 

an informal meeting platform for trade consultations at Union level on the implementation 

of customs-related issues and developments of customs policy. 

Union Customs Code: It provides a comprehensive framework for customs rules and 

procedures in the EU customs territory adapted to modern trade realities and 

communication tools. It entered into force on 1 May 2016, but some transitional 

arrangements still apply, most notably for customs formalities which are still in the process 

of being gradually transitioned to electronic systems. 

Union Customs Code Work Programme: The work programme was established according to 

Article 280 of the UCC. It includes transitional measures related to the electronic systems 

and timing for cases where systems were not yet operational by the date of application of 

the UCC (1 May 2016). 

 
 
 
7 

EXECUTIVE SUMMARY 

I. 

The Customs Union is one of the pillars of the Single Market. The modernisation of 

customs processes, based on the development of new Information Technology (IT) systems, 

is an important element for the functioning of the European Union (EU). This modernisation 

should notably enhance economic activity and growth, and increase the safety and security 

of the EU citizens. These benefits should provide the necessary incentives for Member States 

to invest in customs IT systems.  

II.  The Commission’s e-Customs Decision, the Modernised Customs Code (MCC) and 

ultimately the Union Customs Code (UCC) paved the way towards and outlined the required 

IT systems for modernising the Customs Union. The Customs 2020 programme finances the 

Union components of the IT systems. Member States should develop the related national 

components (non-Union components) and pay the associated costs. The implementation of 

the IT systems is governed by a multi-layer decision-making process, involving a number of 

bodies. 

III.  Our audit looked at whether the Customs 2020 programme, together with the related 

customs legislation, are likely to deliver the IT systems necessary for improving customs 

operations in the EU. We carried out this audit during the implementation stage with the 

view to contribute to the discussions on the next Customs programme, that will start in 

2021. We examined whether the programme ensures that IT systems are implemented in a 

timely manner and, where applicable, we identified the reasons for delays. The audit was 

mostly based on the analysis of Commission documents, minutes and reports of Committees 

and Working Groups, and on the results of a survey sent to the Member States. 

IV.  We found that the implementation of the new IT systems for the Customs Union 

suffered a series of delays, so that some of the key systems will not be available at the 2020 

deadline set in the UCC. The delays are due to several factors, in particular: changing project 

scope, insufficient resources allocated by the EU and Member States, and a lengthy decision-

making process due to the multi-layered governance structure. We also noted that the 

Commission did not report appropriately on delays, and that the Customs 2020 programme 

objectives and reporting arrangements are not suitable for monitoring the implementation 

 
8 

of the IT systems. The initial development approach of IT systems was mostly decentralised, 

with the view of reducing the risk of non-delivery but at the cost of decreased efficiency. 

V.  We recommend that the Commission:  

(a)  propose that the next Customs programme’s objectives relate explicitly to the planned 

IT systems to be developed and propose objectives that are precise and measurable; 

(b)  ensure that lessons from previous programmes are duly taken into account and provide 

Member States with adequate information to take an informed decision on the scope of 

the projects in due time; 

(c)  monitor the risks that a Member State might not be able to meet the deadlines for 

implementing the national components and, at an early stage, identify potential 

solutions and facilitate their application at national level; and facilitate a wider use of 

collaborative IT development; 

(d)  streamline the governance of customs IT systems’ development, by ensuring more 

efficient and swift communication with Member States, for example by using additional 

information exchange solutions to allow decisions to be taken without delay; 

(e)  inform all the stakeholders concerned with implementing IT systems at EU and Member 

State level, in a timely and transparent manner, about delays in the implementation and 

spending for Union and national components, and set appropriate reporting 

arrangements and indicators on the overall level of implementation and on individual 

projects. 

 
9 

INTRODUCTION 

The Customs Union is one of the pillars of the Single Market in the European Union 

1. 

In 2018, the European Union (EU) celebrates the 50th anniversary of the Customs 

Union. The essence of the Customs Union is the absence of customs duties at internal 

borders between Member States, and the establishment of common customs duties on 

imports from third countries. 

2.  To operate as a major trading block, the EU is dependent on the efficient flow of goods 

into and out of the Customs Union, as well as the free movement of goods within the area of 

the Single Market. According to the latest available statistics, combined imports and exports 

represented approximately €3,7 trillion1. This demonstrates the importance of trade and of 

the Customs Union to the prosperity of the EU. 

3. 

In addition, the customs duties on imports are an important part of EU revenue. In 

2017, they amounted to €20,3 billion, representing 15 % of the total EU budget. 

1 

Source: Eurostat statistics on World trade for 2017. 

 
 
                                                      
10 

Since 2003 the modernisation of the Customs Union has been on the EU agenda 

4. 

Several key players have expressed the need to modernise the Customs Union since its 

creation. Improvement should include digitalisation2, the introduction of a paperless 

environment and reducing red tape, thus enhancing economic activity and growth. It should 

also increase the safety and security of EU citizens, and allow for more efficient collection of 

duties. The benefits for EU consumers and business of improved EU trade are expected to 

provide an incentive for the Member States to invest in the customs Information Technology 

(IT) systems. 

5. 

In 2003, the Commission set out the objective of achieving a simple and paperless 

environment for customs and trade3. The publication of the e-Customs Decision4 in 2008 

further emphasized the importance of this objective. In June 2008, the Modernised Customs 

Code (MCC)5 entered into force. It aimed at modernising the Customs Union, including the 

development of a number of IT systems that were intended to be fully operational by June 

2013. For several reasons, including delays in implementing the required IT systems6, the 

MCC was never applied in practice. 

2 

3  

4 

5 

6 

The World Customs Organization (WCO) also considers digitalisation a key feature of 
modernised customs having developed a Digital Customs Maturity Model. 

See the Commission’s Communication of 24 July 2003 entitled "A simple and paperless 
environment for customs and trade". 

Decision No 70/2008/EC of the European Parliament and of the Council of 15 January 2008 on a 
paperless environment for customs and trade (OJ L 23, 26.1.2008, p. 21) (the e-Customs 
Decision). 

Regulation (EC) No 450/2008 of the European Parliament and of the Council of 23 April 2008 
laying down the Community Customs Code (Modernised Customs Code) (MCC) (OJ L 145, 
4.6.2008, p. 1), repealed by Regulation (EU) No 952/2013 of the European Parliament and of the 
Council of 9 October 2013 (OJ L 269, 10.10.2013, p. 1). MCC entered into force on 24 June 2008, 
but provided that it would be applicable on 24 June 2013 at the latest. 

See proposal for a Regulation of the European Parliament and of the Council laying down the 
Union Customs Code (recast) (COM (2012) 64 final), adopted by the Commission on 20 
February 2012. 

 
                                                      
11 

6. 

In October 2013 the Union Customs Code (UCC)7 was adopted, replacing the MCC and 

again pursuing the objective of moving towards a paperless environment and information 

exchange based on IT systems. The UCC has been applicable since May 2016, with a 

transitional period until end 2020 for implementing the IT systems. The IT systems related to 

the UCC were similar to those previously required for the MCC. 

7. 

In order to comply with the requirements of the e-Customs Decision and UCC, the 

Commission established strategic planning documents for developing the relevant customs 

IT systems; the Multi-Annual Strategic Plan8 and the UCC Work Programme9. The Multi-

Annual Strategic Plan takes account of the UCC Work Programme implementation schedule, 

but includes additional IT systems which require development. 

The Customs 2020 programme is the current financial tool for implementing the necessary 

IT systems  

8.  The EU funds the development of new IT systems indicated in the Multi-Annual 

Strategic Plan as well as the maintenance of existing IT systems under a general programme 

in the area of customs. This “Customs 2020” programme10 provides funds for the EU 

components of the IT systems (Union components). These are assets (such as hardware, 

software, network connections) and services to support IT systems that are common to the 

7 

8 

9 

10 

Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 
laying down the Union Customs Code (recast) (OJ L 269, 10.10.2013, p. 1) (UCC Regulation). 

The Multi-Annual Strategic Plan is a management and planning tool drawn up by the 
Commission in partnership with the Member States in accordance with Article 8(2) of the e-
Customs Decision. It sets down a strategic framework and milestones for managing IT projects. 
When approved, each revision is published by DG TAXUD. 

Commission Implementing Decision of 29 April 2014 establishing the Work Programme for the 
Union Customs Code (2014/255/EU) (OJ L 134, 7.5.2014, p. 46) (UCC Work Programme 2014), 
repealed by Commission Implementing Decision (EU) 2016/578 of 11 April 2016 establishing the 
Work Programme relating to the development and deployment of the electronic systems 
provided for in the Union Customs Code (OJ L 99, 15.4.2016, p. 6) (UCC Work Programme 2016). 

Regulation (EU) No 1294/2013 of the European Parliament and of the Council of 
11 December 2013 establishing an action programme for customs in the European Union for the 
period 2014-2020 (Customs 2020) and repealing Decision No 624/2007/EC (OJ L 347, 
20.12.2013, p. 209). 

 
                                                      
12 

EU and Member States. Member States are expected to develop the national components 

(non-Union components) and bear the associated costs11. 

9.  The Commission set up the Customs 2020 programme to “support the functioning and 

modernisation of the Customs Union in order to strengthen the internal market by means of 

cooperation between participating countries, their customs authorities and their officials.” 

The total budget of this programme amounts to €523 million over seven years (i.e. around 

€75 million per year)12. Customs 2020 is a continuation of the previous “Customs” 

programmes which started in 1991 and the last of which was closed in 2013. The 

Commission proposes an envelope of €950 million for the Customs programme within the 

Multi-annual Financial Framework 2021-2027. 

10.  Three-quarters of the Customs 2020 budget are devoted to IT capacity building, 

referred to as European Information Systems (EIS) in the Customs 2020 regulation. This 

budget covers the development, operation and maintenance of the EU parts of these EIS 

(Union components). The remaining 25 % of the budget is for other actions related to the 

functioning and modernisation of the Customs Union, namely joint actions (such as project 

groups and expert teams) and training.  

Governance of the implementation of IT systems in the Customs Union is multi-layered 

11.  Figure 1 shows the governance of the IT systems’ implementation in the Customs 

Union. Governance is based on a number of interacting bodies involving the Commission, 

Member States and trade interests, notably the Customs Policy Group (CPG), the Electronic 

Customs Coordination Group (ECCG) and the Trade Contact Group (TCG). The Directorate-

General for Taxation and Customs Union (DG TAXUD) is responsible for the implementation 

of Customs 2020 and chairs these groups. Reaching an agreement on individual projects 

requires a number of discussions on technical, operational, legal and financial matters, and 

involves experts from the Commission and Member States. 

11 

12 

Certain Member States are using EU structural funds to cover some of these costs. 

This budget does not include IT developments financed solely by Member States (national 
components). We could not report on the total systems’ costs (see paragraph 47). 

 
                                                      
Figure 1 – Governance for implementing the Multi-Annual Strategic Plan and e-Customs 

projects 

13 

Source: ECA, based on the Annex III - Governance Scheme of Multi-Annual Strategic Plan Rev. 2017.  

AUDIT SCOPE AND METHODOLOGY 

12.  Our audit assessed whether the Customs 2020 programme, together with the related 

customs legislation, are likely to deliver the IT systems necessary for improving customs 

operations in the EU. We focused on the development of the Union components of new IT 

systems. With regards to the national components, we only examined the Commission’s 

supervisory role in coordinating the Member States’ implementation in their national IT 

systems. We did not cover the other actions provided for in Customs 2020 programme, 

notably the joint actions, the training activities and the operation and maintenance of 

existing IT systems.  

13.  Our audit was carried out during the implementation stage of the programme. This 

approach allowed us performing a mid-term review of IT systems’ development and to 

provide an input in due time for the discussions on the next Customs programme, which will 

start in 2021 (see paragraph 9). 

 
 
14 

14.  We examined whether the programme ensures that IT systems are developed and 

implemented in a timely manner. Where applicable, we identified reasons for delays. We 

also reviewed related aspects of the design, monitoring and reporting arrangements13. The 

audit was based on an analysis of Commission documents, minutes and reports of 

Committees and Working Groups in which the Commission and Member States participate, 

and interviews with Commission staff in DG TAXUD.  

15.  In order to have an insight into the implementation of the national components of new 

IT systems by Member States, we carried out a survey of the 28 national customs 

authorities. 

OBSERVATIONS 

Implementation of new IT systems for customs suffered a series of delays 

16.  The rapid development of IT continuously presents new opportunities, challenges and 

demands from users in general. This is also true in the area of customs, which requires the 

Commission and Member States to provide flexible solutions and remain agile in response to 

external events. Ten years after the adoption of the e-Customs Decision, we noted progress 

in the development of IT systems. However, a certain number of these systems are not yet 

fully implemented. 

17.  The Multi-Annual Strategic Plan 2017 includes 31 IT projects for implementation by the 

Commission and Member States. They are designed to develop new systems or upgrade the 

current ones, with a view to modernising the Customs Union and ensuring the full 

application of the UCC. The deadlines for the delivery of the IT projects were gradually 

postponed. The 2016 and 2017 Multi-Annual Strategic Plan revisions resulted in the delivery 

dates for the IT systems being postponed for 28 % and 42 % projects respectively. 

13  We also took into account the conclusions and recommendations included in special report 
19/2017 “Import procedures: shortcomings in the legal framework and an ineffective 
implementation impact the financial interests of the EU”.  

 
                                                      
  
15 

18.  Annex II presents a graph with the additional number of years needed to deliver each 

IT project. This resulted from the comparison of the deadlines for delivery between the 

Multi-Annual Strategic Plan 2017 and the initial planning. Our analysis shows that for four 

projects the initial delivery date was maintained, but many suffered delays and four projects 

were postponed by five or more years.  

Delivery of some key IT systems required by the Union Customs Code is delayed beyond 

2020 

19.  Full implementation of the UCC is dependent on the availability of a number of IT 

systems at the Commission and in the Member States. Although the UCC has been 

applicable from 2016, it provides for a transitional period until 31 December 2020 at the 

latest, to allow for the 17 IT systems required to be developed by the Commission and the 

Member States. 

20.  According to the Multi-Annual Strategic Plan 2017, seven of these IT systems14 will be 

fully delivered only after the 2020 deadline. According to the Commission, the overall rate of 

implementation of the UCC at the end of 2020 will be approximately 75 %. However, such 

calculation is based on the delivery of the milestones for the Union components, not taking 

into consideration when the systems will be ready to use. In addition, we found that the 

delayed projects include key systems for the operation of core customs procedures (import, 

transit and export), or their upgrades. Member States, in their replies to our survey, 

considered these systems to be crucial for the efficient functioning and modernisation of the 

Customs Union (see Figure 2). 

14   UCC projects postponed beyond 2020: UCC Automated Export System, UCC New Computerised 
Transit System upgrade, UCC Guarantee Management, UCC Special Procedures, UCC Centralised 
Clearance for Import, UCC Proof of Union Status and UCC Import Control System upgrade.  

 
                                                      
Figure 2 – Multi-Annual Strategic Plan 2017 for 17 UCC-related projects15 

16 

2017     2018 2019     2020     2021    2022     2023     2024    2025     2026   

UCC Registered Exporter System

UCC Binding Tariff Information

UCC Customs Decisions

UCC Uniform User Management & Digital Signatures

UCC Authorised Economic Operators

UCC Economic Operators Registration and Identification 2

UCC Surveillance 3

UCC Proof of Union Status

UCC New Computerised Transit System upgrade

UCC Automated Export System

UCC Information Sheets for Special Procedures

UCC Special Procedures

UCC Notification of arrival

UCC National Import Systems

UCC Centralised Clearance for Import

UCC Guarantee Management

UCC Import Control System upgrade

Red columns indicate projects with delivery date postponed beyond 2020.

Blue columns indicate projects expected to be delivered by 2020.

Source: ECA, based on the Multi-Annual Strategic Plan 2017 (for a detailed description of the IT 
projects, please see Annex I)  

21.  In January 2018, the Commission reported to the European Parliament and the Council 

on the implementation of the UCC and informed them that the UCC 2020 deadline will not 

be met. In March 2018, it presented a proposal to amend the UCC including an extension of 

the transitional period for the application of certain provisions until 2025. 

15 

Import Control System upgrade planning refers only to the first part of the project. The 
remaining parts will be delivered after 2020. 

 
 
                                                      
17 

There is a risk of not meeting the newly proposed 2025 deadline 

22.  The 2017 Multi-Annual Strategic Plan revision led to a significant concentration of the 

Commission’s work in the 2023 to 2025 period, when six systems16 resulting from extensive 

projects are planned to become operational17. In addition, a substantial number of Member 

States are late in implementing their IT systems18. As a result, there is a risk that the 

rescheduled deadlines will also not be met and that the UCC deadline is further extended 

beyond 2025. 

Changing scope, insufficient resources allocated and a lengthy decision-making process 

were the main reasons for delays 

23.  Our examination of the implementation of the customs IT projects, including an in-

depth analysis of five projects19 and the Member States’ replies to our survey, revealed that 

the main reasons for the delays were the following: 

•  Changes in the scope of some projects, which added to their complexity (see 

paragraphs 24 to 25); 

• 

Insufficient resources allocated by the Commission and the Member States for 

implementing the IT systems (see paragraphs 26 to 32); 

16  

17 

In addition, the second part of the UCC Import Control System upgrade will also fall into this 
period, although the planning of the second part of the project is not yet included in the Multi-
Annual Strategic Plan 2017. 

This type of concentration is contrary to the conclusions of the Customs 2020 project group on 
impacts of the UCC requirements on Member States according to which “overlap of deployment 
of several major systems within the same time span is to be avoided”. The Commission also 
acknowledged that the EU has never before experienced such a massive transition, and that it 
will have many operational risks at both the technical and coordination levels.  

18  We compared the current stage (as reported by the Member States to our survey) with the 

Multi-Annual Strategic Plan milestone foreseen for the first quarter 2018.  

19 

Four UCC projects: Registered Exporter System, Surveillance 3, Import Control System upgrade  
and Centralised Clearance for Import and one additional non-UCC project: EU Single Window 
(see Annex I). 

 
                                                      
18 

• 

Lengthy decision-making process due to the multi-layered governance structure20 

involving the Commission and Member States (see paragraph 33 to 36). 

Changes in the scope of some projects 

24.  The Commission based the timeline for the development and deployment of customs 

systems on the IT Master Plan study completed in 2012, and concluded that the 2020 

deadline was realistic for the implementation of the IT projects planned at that time. 

25.  12 of the 17 projects, which had already been planned in the MCC, which preceded the 

UCC, were relatively mature21. However, during the discussions which followed, the 

Commission and Member States agreed to significantly change the scope of some IT 

systems. In addition, some IT developments were shifted from the Member States to the EU 

level. This resulted in a substantial increase in the workload of the Commission, and the 

original timeline set turned out to be unattainable. 

Insufficient resources allocated by the Commission and the Member States 

Commission’s budget (Union components) 

26.  The Commission based resource needs for the Customs 2020 programme on the 

implementation of the EU’s IT strategy for the customs policy area, set out in the Multi-

Annual Strategic Plan 2012. 

27.  The first major indication that the budget available under the Customs 2020 programme 

might not be sufficient appeared in 2015 in relation to the Import Control System upgrade 

project. The Vision Document agreed by the Commission and the Member States suggested 

that a more centralised approach be taken to develop the system, as compared with the 

original plans. It suggested a revised total budget for implementation of approximately €170 

20 

21 

19 out of 24 Member States which provided replies to our survey indicated that the current 
governance structures are appropriate taking into account the circumstances, however 14 
Member States admitted that the working method and the decision-making process could be 
further improved. 

According to the Business Process Modelling (BPM), the systems already had user or functional 
requirements defined. 

 
                                                      
19 

million, more than doubling the previous estimates. As a consequence, the Commission 

concluded that the remaining IT capacity-building budget for Customs 2020 programme was 

too low to cover the cost of implementing this system. 

28.  The Commission decided to mitigate the problem by: 

•  Dividing the project into blocks and setting a longer implementation period going 

beyond 2020 with the intention, therefore, of using the budget for future Customs 

programmes; and 

• 

Securing additional resources for the IT capacity-building budget under the Customs 

2020 programme. These efforts were only partially successful. 

29.  The Commission’s forecasts for budgetary requirements for 2021-2025 are significantly 

higher than the ones for 2014-2020. Figure 3 illustrates the estimated budget needs for IT 

systems until the end of the Customs 2020 programming period and the greater budgetary 

needs envisaged after 2020. The Commission estimates that for the next Customs 

programme period, it will need approximately €100 – 115 million per year in order to keep 

all IT systems operational and to finish the remaining projects from the Multi-Annual 

Strategic Plan postponed beyond 2020. 

 
Figure 3 – Estimated budget needs to implement the 2017 Multi-Annual Strategic Plan 

revision 

20 

r
a
e
Y
/
o
r
u
e

f
o

s
n
o

i
l
l
i

M

120.0

100.0

80.0

60.0

40.0

20.0

0.0

Budget needed

C2020 IT Budget

Source: Commission’s working documents. 

Member States’ budget (national components)  

30.  Our survey of Member States showed that for most of them (67 %) one of the main 

reasons leading to the late implementation of the UCC was insufficient budget allocated at 

national level. The Commission became aware that some Member States would not make 

sufficient funds available to customs administrations to enable them to comply with the 

Multi-Annual Strategic Plan immediately after the approval of the UCC Work Programme in 

2014. The Commission informed us that this was partially due to the international 

macroeconomic crisis starting in 2008. In special report 19/2017, we had already highlighted 

that underfinancing of trans-European IT systems may delay the Union Customs Code 

implementation22. 

31.  The Commission continued to call upon Member States to make national resources 

available and investigated other options for resolving the problem of insufficient budgets in 

22 

See paragraphs 33 to 38 of special report 19/2017. 

 
 
                                                      
 
 
 
 
21 

the Member States, for example by facilitating cooperation among Member States 

(see Box 1). 

Box 1 – Collaborative development of national components by a group of Member States 

The Commission promoted the option for Member States to collaborate on developing national 

components together, rather than each Member State working on its own. In the area of taxation, 

DG TAXUD has had positive experience with such collaborative IT development. 

In 2017, Estonia prepared a project for setting up a new expert team composed of several Member 

States’ representatives to develop the national components of the customs IT systems together. Such 

an expert team would, for example, prepare common procurement procedures to achieve 

economies of scale. The project was approved by the Commission and will receive financing from the 

Customs 2020 Work Programme for 2018. 15 Member States expressed their interest in participating 

in this kind of action. 

At the time of the audit, the expert team had not yet started the work, therefore it was not possible 

to fully assess the results of this initiative. 

32.  Member States keep 20 % of the funds collected from customs duties as collection costs 

and the remaining 80 % goes to the EU budget as revenue. The retention rate for collection 

costs would be enough23 to contribute to covering expenditure incurred by Member States 

for implementing customs IT systems. We noted, however, that no Member States indicated 

that they had done so. Instead, they used funds from the national budget and EU structural 

funds to finance the customs IT systems development. 

Lengthy decision-making process due to the multi-layered governance structure involving 

the Commission and Member States  

33.  The development of the customs IT systems requires the involvement, close 

coordination and agreement of a large number of players at several levels in the Commission 

and Member States (see paragraph 11). In addition to the complexity of the IT development 

23 

In 2017 Member States retained more than €4 billion as collection costs. At the level of 
individual Member State, the amounts retained varied between €3 million and €1 billion. 

 
                                                      
22 

in itself, decision-making is further complicated by the specific national features of customs 

operations, and by differences between the Member States regarding their progress and 

capacities in customs IT. 

34.  The Commission, in its coordinating role, has already experienced this governance 

structure in the context of the implementation of the existing customs systems, most 

importantly the first generation of the transit system (the New Computerized Transit 

System). This demonstrated that seeking an agreement on all aspects of project 

implementation is a challenging and time-consuming task24. 

35.  Given the complexity of customs IT projects, the Commission applied a set of detailed 

milestones for each project to facilitate operational planning and monitoring. These 

milestones are divided according to the main project phases, and refer to approval of the 

related documents or actions by the Member States represented in the governance 

bodies25. 

36.  We looked at the application of these milestones in our sample of five projects (see 

paragraph 23). In all cases, the Commission’s agreement with the Member States on the 

initial milestones (Business Case and/or a Vision Document) was delayed26. 

The Commission was late in reporting the delays 

37.   The feasibility of the timelines for completing the IT projects started to be questioned 

by some Member States and trade representatives (such as importers, customs brokers, 

transport companies and logistic operators) immediately after the key planning documents 

had been adopted in 2013 and 2014. Despite this, in 2016 the Commission’s official strategic 

24 

25 

26 

The time needed for the development of the New Computerized Transit System - 12 years - was 
taken into account when estimating the time needed to develop the new systems in the 
Iteration 1 Global Estimation Study Document for the IT Master Plan.  

Customs Policy Group (CPG) and Electronic Customs Coordination Group (ECCG).  

In two cases (Surveillance 3 and Registered Exporters System), it was possible to catch up and 
maintain the original (Multi-Annual Strategic Plan 2014) deadline for delivery. In another two 
cases (Centralised Clearance for Import and Import Control System upgrade), the projects were 
split into phases extending the final delivery beyond 2020. As regards the EU Single Window, 
the project was split into several sub-projects and its full delivery is not yet known.  

 
                                                      
23 

planning documents and reports continued to indicate that all UCC IT systems and several 

other non-UCC Multi-Annual Strategic Plan projects would be delivered by 2020 (see Box 2). 

Box 2 – Commission’s reporting (until 2016) indicated that IT systems would be delivered by 2020 

The Commission did not mention the risk of failure to deliver the UCC IT systems by 2020 in any of 

the Customs 2020 progress reports for the years 2014, 2015 and 2016 (see paragraph 46). 

In the 2016 e-Customs progress report (published in July 2017), the Commission recognised that 

several projects had been delayed. However, taking into account the progress made in 2016, it stated 

that timely implementation of the projects was still feasible.  

Similar information was presented in the e-Customs progress reports for the years 2014 and 2015. 

38.  When the Commission identified issues related to the availability of resources and 

potential delays in implementing the UCC Work Programme in June 2014, it did not change 

the deadlines in the UCC Work Programme or in the Multi-Annual Strategic Plan. Instead, it 

created a new internal resource-based operational plan and proposed to manage it in 

parallel. This resulted in the Multi-Annual Strategic Plan / UCC Work Programme being used 

externally and the operational plan, which depicted reality, mainly being used internally. 

From 2015 onwards, the internal operational plan indicated longer deadlines than those in 

the Multi-Annual Strategic Plan / UCC Work Programme, and included projects to be 

implemented after the 2020 UCC deadline. 

39.  The two planning tools co-existed in customs IT development until 2017 when they 

were reconciled following a review (“reality check”) performed by the Commission. The 

outcome of this review exercise was the 2017 Multi-Annual Strategic Plan revision, which 

moved the deadlines for deployment of several IT systems beyond the UCC’s legally binding 

2020 deadline. As a result, the Commission was obliged to prepare an update of the UCC 

Work Programme and to propose an amendment to the UCC Regulation (see paragraph 21). 

40.  The existence of the two planning tools shows that the Commission was aware of the 

delays. The decision not to include this information in its official reporting prevented the 

stakeholders (such as the European Parliament, other EU institutions not represented in the 

 
24 

governance structure of Customs 2020 as well as interested companies and citizens) from 

being fully informed of the risk of delays in real time. 

The initial development approach selected was not the most cost efficient  

41.  When the Customs 2020 programme was designed, the Commission carried out a study 

to determine the deadlines for implementing the IT systems and the budget required for the 

Union components (see paragraph 26). The development approach selected was mostly 

decentralised. This was despite the fact that centralised implementation was the most cost 

efficient option (see Box 3). 

Box 3 – Centralised development approach rejected by Member States 

In its Impact Assessment the Commission presented four scenarios for the Customs 2020 

programme, which differed essentially in the degree of centralised development by the Commission 

or decentralised development by each individual Member State. The option with the most 

centralised implementation of IT systems involved shared common development of full core 

clearance process implementation and of its trader interface. 

This centralised solution required a higher budget for the Customs 2020 programme (estimated at 

around €200 million more, as compared with the option selected). However, it also offered 

significant economies of scale (one euro invested centrally could generate a saving of four euros for 

Member States).  

This scenario was not selected because Member States considered that a decentralised solution 

could more appropriately meet specific national requirements and mitigate the risk of project failure. 

42.  Later, during the individual project scope discussions, Member States requested that 

the EU develops certain components of IT systems at central level. This led to a more cost 

efficient solution because of economies of scale, but required more resources from the 

Customs 2020 programme which were unplanned (see paragraph 27).  

 
25 

The Customs 2020 programme objectives and reporting arrangements are not suitable for 

monitoring the IT systems’ implementation  

43.  The specific and operational objectives for IT implementation in the Customs 2020 

programme are too general to be used for monitoring and reporting (e.g. “computerization” 

or “to develop, improve, operate and support the European Information Systems for 

customs”). In addition, because the specific IT systems to be developed were not set among 

the above objectives of the Customs 2020 programme, they are not appropriately monitored 

in the existing reports.  

44.  The Performance Measurement Framework (PMF) developed to assess the Customs 

2020 programme prescribes four indicators for the implementation of new IT systems:  

1.  number of IT projects in the “research” phase;  

2.  number of IT projects in the “development” phase; 

3.  number of new IT systems in the “operation” phase; and 

4.  ratio of IT projects with “green” status.  

45.  We found that the first three indicators do not have a target and the target set for the 

fourth indicator was only that 50 % of the IT projects should be in line with requirements 

(status “green”). This target was not meaningful because a project can receive a “green” 

status simply as a consequence of a Multi-Annual Strategic Plan revision, without any actual 

progress in the implementation of the IT system. Therefore, the four indicators developed to 

assess IT implementation do not enable delays to be detected and reported.  

46.  The Commission publishes annual progress reports on the implementation of the 

Customs 2020 programme. In the three Customs 2020 progress reports published by the 

time of the audit (2014, 2015 and 2016), the information on the implementation of the IT 

systems is limited. All three reports state that new developments are largely taking place in 

line with the planning. The e-Customs progress reports for the three above years contain 

more detailed information on the level of deployment of the IT systems, but do not provide 

information on the risk of not meeting the planned deadlines. Given the delays in developing 

 
26 

and deploying new IT systems, the Customs 2020 progress reports did not provide a 

balanced and comprehensive view27 of the programme implementation. 

47.  The Commission receives information on the costs incurred by Member States for 

developing the national components of the IT systems on a regular basis. This information is 

compiled and presented in the e-Customs progress reports. However, the information 

provided by Member States is neither complete nor comparable. We confirmed this 

limitation in our survey, which prevented us from estimating the total costs (Union and 

national components) to develop the IT systems. Unreliable information on amounts spent 

prevents the Commission from properly evaluating whether the implementation of the IT 

projects is effective and provides value for money for the modernisation of the Customs 

Union. 

27 

The Customs 2020 progress reports only dedicate one page to the new IT systems (out of 
around 15 pages) as only 4 out of 68 (output and results) indicators are related to new IT 
systems. 

 
                                                      
27 

CONCLUSIONS AND RECOMMENDATIONS 

48.  Customs processes can have a very significant influence on trade, the collection of 

duties, and the safety and security of citizens. Modernising these processes is key to the 

functioning of the EU. Ten years after the adoption of the e-Customs Decision, we noted 

progress in the development of IT systems towards creating a paperless customs and trade 

environment. However, these systems are not yet fully implemented. 

49.  We conclude that: 

•  Delivery of 7 out of the 17 UCC IT systems will miss the 2020 deadline. Some of 

them are key systems such as UCC Import Control System upgrade and UCC 

Centralised Clearance for Import (see paragraphs 19 to 21). 

•  There is a risk that the new 2025 deadline is not met (see paragraph 22). 

•  The original timeline to implement the IT systems, set by the Commission, became 

unfeasible due to changes in the scope of some projects (see paragraphs 24 to 25). 

•  The actual costs of developing the IT systems for the Union components were 

significantly higher than those estimated in the initial plan, and the Commission did 

not allocate sufficient resources for these projects (see paragraphs 26 to 29). 

• 

Insufficient budget allocated by the Member States was one of the main reasons for 

delays (see paragraphs 30 to 32). 

•  The lengthy decision-making process delayed the implementation of some IT 

systems due to the multi-layered governance structure involving the Commission 

and the Member States (see paragraphs 33 to 36). 

•  The Commission was late in reporting the delays in the implementation of the IT 

systems (see paragraphs 37 to 40). 

•  The decision of how much of IT development to centralise at EU level was not 

always driven by cost-efficiency considerations, but also by Member States’ specific 

 
28 

national requirements and by the risks of project failure (see paragraphs 41 

and 42). 

•  The Customs 2020 programme objectives and reporting arrangements are not 

suitable for monitoring the implementation of IT systems properly (see 

paragraphs 43 to 47). 

50.  We recommend that the Commission should take account of the lessons learnt with the 

Customs 2020 programme and its approach to managing IT projects as outlined in the Multi-

Annual Strategic Plan for the future Customs Programmes.  

Recommendation 1 - Gear programme design towards IT implementation 

For the next Customs programme, the Commission should propose: 

(a)  objectives that relate explicitly to the planned IT systems to be developed; and 

(b)  objectives which are precise and measurable. 

Timeframe for implementation: 2020 

Recommendation 2 - Improving IT project time, resource and scope estimates  

For future Customs programmes, the Commission should: 

(a)  when preparing the timelines and resource allocations, ensure that the lessons from 

previous programmes (such as risks related to the IT environment and project 

complexity) are duly taken into account; and  

(b)  provide Member States with adequate information to take an informed decision on the 

scope of the projects in due time. 

Timeframe for implementation: 2020 

 
 
 
29 

Recommendation 3 - Facilitate cooperative IT development 

The Commission should: 

(a)  monitor the risk that a Member State might miss deadlines for implementing the 

national components and, at an early stage, identify potential solutions and facilitate 

their application at national level; and 

(b)  facilitate a wider use of collaborative IT development between Member States.  

Timeframe for implementation: 2020  

Recommendation 4 - Streamlining governance by enhancing communication 

The Commission should streamline the governance of customs IT systems development, by 

ensuring more efficient and swift communication with Member States, for example by using 

additional information exchange solutions to allow decisions to be taken without delay.  

Timeframe for implementation: 2020 

 
 
 
30 

Recommendation 5 - Transparent reporting on IT implementation 

The Commission should: 

(a)  inform all stakeholders concerned with implementing IT systems at EU and Member 

State level, in a timely and transparent manner, about delays in the implementation and 

spending of Union and national components; and 

(b)  set appropriate reporting arrangements and indicators on the overall level of 

implementation and on individual projects in the next Customs programmes’ 

Performance Measurement Framework, and issue the required reporting documents. 

Timeframe for implementation: 2021  

This Special Report was adopted by Chamber V, headed by Mr Lazaros S. LAZAROU, Member 

of the Court of Auditors, in Luxembourg at its meeting of 26 September 2018 

For the Court of Auditors 

Klaus-Heiner LEHNE 

President 

 
 
 
 
 
 
 
 
1 

ANNEX I 

IT PROJECTS’ DESCRIPTION 

UCC SYSTEMS 

UCC Customs 
Decisions 

The project aims at harmonising the processes related to the 
application for a customs decision, the decision taking and the 
decision management across the EU. 

UCC Binding Tariff 
Information (BTI) 

The goal of the project is to upgrade the existing trans-European 
EBTI-3 system and Surveillance 2 system in line with the UCC and 
its provisions (e.g. changes of validity period). The project is 
closely linked to the Surveillance 3. 

UCC Authorised 
Economic Operators 
(AEO) upgrade 

The project aims at improving the business processes related to 
AEO applications and authorisations, taking into account the 
changes to the legal provisions of the UCC. 

UCC Automated 
Export System (AES) 

This project implements the UCC requirements for export and exit 
and is composed of two components: trans-European (AES) and 
national (National Export Systems upgrade). 

UCC New 
Computerised Transit 
system (NCTS) 
upgrade 

The aim of the trans-European project is to upgrade the existing 
system, which automates the transit procedures and control of 
the movements covered under the TIR procedure within the EU. 

UCC Registered 
Exporter System 
(REX) 

The REX project aims at implementing a system that will provide 
up-to-date and complete information on registered exporters 
established in non-EU countries exporting goods to the EU under 
preferential trade arrangements. 

UCC Economic 
Operators 
Registration and 
Identification 
subsystem 2 (EORI2) 

This project aims at upgrading the existing trans-European EORI 
system, which registers and identifies EU and third country 
economic operators. 

UCC Notification of 
Arrival, Presentation 
Notification and 
Temporary Storage 

The goal of this project is to define the processes for Notification 
of Arrival of the means of transport, Presentation of the goods 
and Declaration for Temporary Storage and to support 
harmonisation across the Member States. 

UCC Guarantee 
Management (GUM) 

This project aims at assuring the effective and efficient 
management of the different types of guarantees. The project has 
both a trans-European and a national component. 

 
2 

UCC Information 
Sheets (INF) for 
Special Procedures 

The aim of this project is to develop a new trans-European system 
for administrative cooperation and the standardised exchange of 
information between customs authorities across Member States. 

UCC Special 
Procedures 

This project aims at accelerating, facilitating and harmonising 
Special Procedures across the Union by means of providing 
common business process models. 

UCC Surveillance 3 

This project aims at providing an upgrade of the Surveillance 2+ 
system to allow processing of additional data elements from the 
declarations for improved customs risk analysis, the fight against 
fraud, market analysis, post-clearance controls and statistical 
purposes. 

UCC Import Control 
System upgrade 
(ICS2) for 
strengthening the 
Security of the Supply 
Chain at Entry 

The project aims at creating a new trans-European system 
replacing the existing ICS. The main objective is to strengthen the 
security of the supply chain by optimising the exchange of 
advanced cargo information and by addressing the weaknesses of 
safety and security processes and/or data quality in order to 
improve risk analysis. 

UCC National Import 
Systems (NIS) 
upgrade 

The project aims at implementing all UCC requirements related to 
the national import domain. It covers the national customs 
declarations processing systems as well as other related systems. 

UCC Centralised 
Clearance for Import 
(CCI) 

The project aims at creating a trans-European system to allow 
traders to centralise lodging of their customs declarations for 
imports within one customs administration whilst goods will be 
physically presented in other Member State(s). 

UCC Proof of Union 
Status (PoUS) 

The project aims at the creation of a new trans-European system 
to store, manage and retrieve the electronic Proof of Union 
Status documents. 

UCC Uniform user 
management & 
digital signatures – 
UUM&DS (Direct 
Trader Access to EIS) 

The UUM&DS Project aims at implementing a system that 
provides traders with direct and harmonised access to new EU-
wide services, including the central services. 

Non - UCC SYSTEMS (mentioned in the report) 

EU Single Window 
environment for 
customs 

The objective of the EU Single Window environment for customs 
is to enable economic operators to electronically lodge all the 
information required by customs and non-customs legislation for 
the EU cross-border movements of goods at the same time. 

 
3 

COPIS (Anti-
Counterfeiting and 
Piracy System) 

COPIS is intended to enhance intellectual property rights 
protection by improving the cooperation and sharing of 
information between right-holders and Member States’ customs 
administrations and between all the customs offices of the 
Member States. 

Classification 
Information System 
(CLASS) 

The project aims at developing a tariff classification information 
system which would provide a single platform where all the 
classification information is made available and easy accessible. 

Common 
Communication 
Network 2 (CCN2) 

CCN2 is an evolution of the current CCN, which is a closed, 
secured network infrastructure provided by the Commission to 
facilitate the exchange of information between the national 
authorities of the customs and taxation area. 

High availability DG 
TAXUD operational 
capabilities 

Under this project, the Commission intends to provide high 
availability infrastructure capabilities for the hosting of EU 
customs systems components and IT services. 

 
 
ADDITIONAL NUMBER OF YEARS NEEDED TO DELIVER EACH IT PROJECT AS COMPARED TO 

THE INITIAL PLANNING 

1 

ANNEX II 

UCC New Computerised Transit System (NCTS) upgrade

UCC Proof of Union Status (PoUS)

UCC Import Control System upgrade (ICS2)

UCC Centralised Clearance for Import (CCI)

UCC Automated Export System (AES)

UCC Guarantee Management (GUM)

UCC Uniform user management & digital signatures (UUM&DS)

UCC Special Procedures (SP)

EU Single Window (EU SW)

Common Communication Network 2 (CCN2)

UCC Customs Decisions (CD)

UCC Authorised Economic Operators (AEO)

Anit-Counterfeiting and Anti-Piracy System (COPIS)

UCC Binding Tariff Information (BTI)

UCC Notification of arrival, Presentation notification and Temporary storage

High availability DG TAXUD operational capabilities (Bronze service)

UCC Surveillance 3 (Surv3)

Classification Information System (CLASS)

UCC Registered Exporter System (REX)

0

1

2

3

4

5

6

7

Number of years

Note: Only projects planned in both the 2014 and 2017 Multi-Annual Strategic Plans were included in the graph. We took into account all project 
phases, the final delivery date of each project and/or deployment windows. Projects without set deadlines were excluded. 
The UCC Import Control System upgrade project was included with the deadlines set in the 2016 Multi-Annual Strategic Plan because the 2014 plan 
had not included a deadline. It was compared with the 2017 Multi-Annual Strategic Plan and project documentation.

Source: ECA, based on the Multi-Annual Strategic Plans 2017, 2016 and 2014; and UCC Import 
Control System upgrade project documentation (for a detailed description of the IT projects, please 
see Annex I).  

 
 
REPLIES OF THE COMMISSION TO THE SPECIAL REPORT OF THE EUROPEAN 
COURT OF AUDITORS 

“A SERIES OF DELAYS IN CUSTOMS IT SYSTEMS: WHAT WENT WRONG?” 

EXECUTIVE SUMMARY  

V. In relation to the recommendations taken up in the executive summary, the Commission refers to 
its replies concerning each recommendation at the end of the report. 

INTRODUCTION 

5. The Commission wishes to highlight other reasons than the ones specified by the ECA, such as 
the need for an alignment to the Lisbon Treaty. 

10.  The  Commission  would  like  to  clarify  that  the  audit  is  focused  on  the  development  of  new 
customs  IT  systems,  which  represents  10-30  %  (depending  on  the  year)  of  the  programme's  IT 
expenditure.  The  rest  of  the  IT  expenditure  finances  the  already  existing  European  Information 
System (EIS) (operations, infrastructure, maintenance and support services). 

OBSERVATIONS 

23. IT projects, such as the ones connected to the Centralized Clearance and EU Single Window, 
are characterised by a particularly high level of complexity. In relation to the EU Single Window 
environment for customs, it should furthermore be noted that it is part of a possible future initiative, 
to be adopted by 2020 (subject to confirmation by the next Commission). 

25. The Commission would like to stress that there was a need for discussions and further definition 
of the scope of the IT systems between the Commission and the Member States. These additional 
efforts to define the scope contributed to delays, because the implementation of the projects could 
not start immediately after the adoption of the UCC decision. For some systems, the decision was to 
agree  that  additional  developments  should  be  carried  out  at  the  EU  level.  The  changes  of  scope, 
coupled with the constraints of sequencing of systems’ development due to their interdependencies, 
as  well  as  Member  States’  constraints  expressed  during  the  survey  performed  in  2016,  made  the 
timeline as set originally in the UCC unattainable. 

28. In order to mitigate the problem of insufficient budget, the Commission decided also to review 
the organisation and reinforce the human resources allocated to the projects.  

As  an  example,  since  the  different  mitigating  measures  were  put  in  place  in  2016-17,  all  the 
milestones  set  for  the Import  Control  System  upgrade  (ICS2)  project in  the  current  Multi-Annual 
Strategic Plan (MASP) have been successfully met. 

29. It should be underlined that based on the current forecast and the requested IT developments, 
the Commission proposed a global amount of € 950 million for the 2021-2027 programming period, 
in comparison with the amount of € 522.9 million for the 2014-2020 period. 

36.  It  should  be  noted  that,  as  recognised  by  the  ECA  in  footnote  26,  the  reported  delays  only 
concern  the  initial  project  steps  and  not  the  legally  binding  milestones  of  the  availability  of  the 
technical specifications and of the start of the IT system deployment. It is worth mentioning that it 
was  decided  to  approach  the  EU  Single  Window  environment  for  customs  as  part  of  a  possible 
future legal initiative, to be adopted by 2020 (subject to confirmation by the next Commission). For 
this reason, it cannot be planned for the time being and its full delivery is not yet known. From this 
starting point, it is currently not an activity subject to a legally binding timeframe. 

37. The Commission would like to highlight that, since the adoption of the UCC, the discussions on 
the planning of the IT projects, the interdependencies, the prioritisation and the feasibility have been 
part  of  an  open  and  constructive  dialogue  between  the  representatives  of  the  Commission,  the 

1 

 
Member  States  and  the  EU  trade  associations.  This  information  exchange  occurred  within  the 
established  governance  scheme  for  e-Customs.  Recital  (10)  of  the  Implementing  Decision 
establishing  the  UCC  Work  Programme  of  11  April  2016  refers  explicitly  to  the  need  of  paying 
attention  to  the  progress  achieved  in  meeting  the  agreed  targets,  given  the  ambitious  and 
challenging  nature  of  the  electronic  systems  to  be  finalised  in  2019  and  2020.  As  a  follow-up  to 
this, in mid-2016 the Commission launched a survey to collect the views of the Member States and 
trade representatives on the feasibility and prioritisation. This was the basis for further agreements 
on a revised planning, as established and agreed within the MASP 2017. Once the detailed planning 
was agreed, the Commission issued its proposal to amend Article 278 of the UCC. 

38. The Commission created an internal resource-based plan to establish the implications of delays 
and to study the options to tackle them. 

Although  the  UCC  deadlines  remained  unchanged,  the  Commission  discussed  them  with  the 
Member  States  and  trade  representatives  while  preparing  the  second  version  of  the  UCC  Work 
Programme (starting mid-2015, COM decision April 2016, within the context of the legal deadline 
in the UCC of the end of 2020). The Commission considers that it remained fully transparent in this 
regard towards the Member States and trade representatives. 

40. The Commission remains in full transparency with the Member States. Since the first planning 
stages, the administrations of the Member States concerned and the Commission have been openly 
discussing the risk of delays. It is in this context that an understanding was reached with them to 
maintain the planning for the first systems and to closely monitor, by both the Commission and the 
Member States, the planning for the other systems.  

43.  With  regard  to  the  ECA's  comment  on  the  suitability  of  the  Customs  2020  programme 
its  reply  concerning 
objectives  and  reporting  arrangements, 
recommendation 1. 

the  Commission  refers 

to 

46.  The  Commission  would  like  to  clarify  that  regarding  the  reporting  on  the  operating  and 
development of customs IT systems, the Customs 2020 progress reports contain limited information 
in order to avoid duplication, as they are complemented by the e-Customs progress reports. Both the 
Customs  2020  progress  reports  and  the  e-Customs  progress  reports  are  available  on  the  Europa 
website. 

CONCLUSIONS AND RECOMMENDATIONS 

49. 

First bullet point:  

In order to minimise the impact of the delays, the Commission and the Member States agreed on the 
priorities to be set and the deliveries to be sequenced. This was performed in 2016 by means of a 
survey and resulted in the new MASP 2017. 

Ninth bullet point:  

Please see the Commission’s reply to paragraph 46. 

Recommendation 1 - Gear programme design towards IT implementation  

The Commission accepts the recommendation.  

In the context of its proposal for the next Multiannual Financial Framework, the Commission has 
applied  the  Better  Regulation  principle  to  set  precise  and  measurable,  both  general  and  specific, 
objectives of the programmes. These proposals are now being negotiated by the co-legislators. 

Recommendation 2 - Improving IT project time, resource and scope estimates  

2 

 
The Commission accepts the recommendation. 

The Commission wishes also to highlight that it evaluates its programmes at the interim and final 
stage,  making  sure  that  lessons  learnt  from  evaluations  feed  into  the  policy  preparation  of  new 
programmes. This has been the case for the current programme and resulted notably in setting up a 
performance  measurement  framework  for  Customs  2020  as  well  as  developing  specific  and 
measurable goals. All the recommendations resulting from the final evaluation of the Customs 2014 
programme have been addressed. The ECA should also note that the Customs 2020 objectives are 
the result of thorough legislative negotiations. 

Recommendation 3 - Facilitate cooperative IT development 

The Commission accepts the recommendation. 

Recommendation 4 - Streamlining governance by enhancing communication 

The Commission accepts the recommendation. 

Recommendation 5 - Transparent reporting on IT implementation 

The Commission accepts the recommendation. 

Regarding point (a), the Commission  would like to  point  out  that it can only  inform stakeholders 
about spending on national components insofar as the Member States provide such information to 
the Commission. 

In relation to point (b), the Commission wishes to stress that it is already working on an update of 
the current Customs 2020 Performance Measurement Framework, following the conclusions of the 
Mid-Term  Evaluation,  with  a  view  to  simplify  the  current  set  of  indicators  and  to  give  more 
emphasis to IT indicators. For the future post-2020 Customs programme, the core indicators have 
been established in Annex 2 of the Commission proposal. Four out of eight core indicators relate to 
IT  systems,  including  a  new  indicator  "UCC  completion  rate",  which  measures  the  percentage  of 
milestones  reached  for  implementing  the  UCC  electronic  systems.  In  relation  to  the  reporting 
arrangements,  the  Customs  2020  progress  report  for  2017  contains  clear  cross-references  to  the 
complementary e-Customs progress report and a more extensive coverage of the state of play of the 
EIS implementation. 

3 

 
Event 

Date 

Adoption of Audit Planning Memorandum (APM) / Start of audit 

29.11.2017 

Official sending of draft report to Commission (or other auditee) 

12.7.2018 

Adoption of the final report after the adversarial procedure 

26.9.2018 

Commission’s (or other auditee’s) official replies received in all 
languages 

English: 5.10.2018 
Other languages: 7.11.2018 

PDF 

ISBN 978-92-847-0926-7 

doi:10.2865/595268  QJ-AB-18-023-EN-N 

HTML 

ISBN 978-92-847-0960-1 

doi:10.2865/351921  QJ-AB-18-023-EN-Q 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In this audit we looked at whether the Customs 2020 
programme, together with the related customs legislation, 
are likely to deliver the IT systems necessary for improving 
customs operations in the EU. We found that the 
implementation of these systems suffered a series of delays 
so that some of them will not be available at the 2020 
deadline set in the Union Customs Code. The delays were 
due to several factors, in particular: changing project scope, 
insufficient resources allocated by the EU and Member 
States, and a lengthy decision-making process due to the 
multi-layered governance structure.

EUROPEAN COURT OF AUDITORS 
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