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
Date: 2019-12-13
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU Member State, customs cooperation, customs territory (EU), customs union, information system, simplification of formalities

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.12.2019  COM(2019) 629 final  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 {SWD(2019) 434 final}  
 
 
Table of Contents 

1. 
INTRODUCTION ................................................................................................................................ 2 
2.  BACKGROUND ................................................................................................................................. 2 
3.  GLOBAL OVERVIEW OF PROGRESS WITH THE UCC ELECTRONIC SYSTEMS .................................... 3 
5.  CONCLUSION ................................................................................................................................. 10 

1 

 
 
 
 
 
 
1.  INTRODUCTION 
The Union Customs Code (UCC)1, which is the main legal framework for customs rules and 
procedures  in  the  EU  customs  territory,  prescribes  moving  fully  to  a  paperless  environment 
for customs formalities. The use of electronic systems for all interactions between economic 
operators and customs authorities reduces administrative costs and red tape and leverages the 
role  of  customs  to  support  the  competitiveness  of  European  business.  At  the  same  time 
automated  processes  in  the  electronic  systems  allow  for  reinforced  collaboration  among 
customs  authorities  and  interoperability  between  the  different  electronic  systems  which 
should  provide  better  protection  of  financial  and  economic  interests  and  greater  protection 
against fraud, security and safety risks and import point shopping.  

To  achieve  this  objective,  the  UCC  requires  the  European  Commission  and  the  Member 
States to upgrade most of the existing electronic systems, interconnect some of these systems 
at  trans-European  level  and  introduce  a  number  of  new  systems  to  complete  the  full 
automation  of the customs  procedures  and formalities.  Article 280 of the UCC refers to  the 
obligation to establish a UCC Work Programme2 (UCC WP) which lists all the UCC projects 
and  systems  and  the  envisaged  dates  for  deployment.  In  total,  the  UCC  WP  defines  the 
upgrading or creation of fourteen trans-European systems and three purely national systems.  

This  first  annual  report  from  the  Commission  on  progress  in  developing  the  electronic 
systems  describes  the  developments  since  the  UCC  entered  into  force.  For  this  purpose,  it 
draws on the UCC WP which sets out a phased and coherent timetable reflecting the stages of 
development  for  each  of  the  seventeen  electronic  systems  and  which  is  considered  as  the 
baseline for reporting progress. 

The projects listed in the UCC WP can be divided into three system categories:  

i) 

ii) 

iii) 

eleven  trans-European  central  systems  to  be  developed  or  upgraded  by  the 
Commission (often also requiring developments or upgrades by the Member States 
of national systems); 
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  
three  national  systems  that  have  to  be  developed  or  upgraded  by  the  Member 
States themselves.  

This report analyses the progress for all three system types, outlining also the objectives 
to be met by each project, the project architecture and the planning approach. On that 
basis, it highlights potential delays as well as mitigating measures envisaged. The overall 
assessment of the progress of the implementation of the UCC WP is summarised in the 
conclusion section of this report.   

2.  BACKGROUND 

The UCC entered into force on 1 May 2016 and set an initial deadline of 31 December 2020 
for  the  progressive  completion  of  the  work  in  terms  of  IT  transition  and  implementation. 
Article  278  of  the  UCC  provides  that  existing  electronic  and  paper-based  systems  can 

1The UCC was adopted on 9 October 2013 as Regulation (EU) No 952/2013 of the European Parliament and of the Council. 
Its  legal  package  consists  of  the  following:  the  UCC  Delegated  Act,  the  UCC  Implementing  Act,  the  UCC  Transitional 
Delegated Act, the UCC Implementing Act on technical arrangements, and the UCC Work Programme. 
2Article 280 UCC and European Commission Implementing Decision No 2016/578, currently being updated. 

2 

 
 
 
 
                                                      
continue  to  be  used  for  the  completion  of  customs  formalities  (the  so-called  ‘transitional 
measures’) until  the relevant  new  or  upgraded electronic  systems  envisaged  under  the  UCC 
are operational.  
The  Council  and  the  European  Parliament  adopted  a  Regulation  in  early  20193  establishing 
new deadlines  of 2020, 2022 and 2025 for cessation  of the use  of transitional  arrangements 
and therefore the relevant electronic systems must be in place by the same deadlines. Article 
278(a)  requires  the  European  Commission  to  provide  an  annual  report  on  progress  with 
deployment of the outstanding systems.  

As  the  first  annual  report  is  due  by  31  December  2019,  the  Commission  decided  to  collect 
information  on  such  progress  based  on  (1)  reports  that  Member  States  are  required  to 
provide  twice  a  year  and  (2)  a  survey  circulated  among  its  services  and  among  the 
Member  States.  The  survey  asked  recipients  to  indicate  any  known  delays  in  the  planning 
schedules  for  the electronic systems. The national plans as well as  the progress information 
from the survey to the Member States reflects mainly the situation at the end of June 2019. 
The data yielded from the survey are both quantitative in the form of deadlines and milestones 
met  or  missed,  and  qualitative  in  the  form  of  detailed  descriptions  regarding  the  challenges 
faced, the anticipated risks and the estimated complexity of the projects. 

3.  GLOBAL  OVERVIEW  OF  PROGRESS  WITH  THE  UCC  ELECTRONIC 

SYSTEMS 

The work of developing IT systems involves several phases. First, a business case is prepared, 
which  provides  the  project  justification  and  defines  budgetary  requirements.  Typically,  the 
business case would include the business context, problem description, project description and 
scope, possible alternative solutions, costs and timescale. Next a vision document is produced, 
which  provides  more  detailed  information  regarding  the  project  definition  in  terms  of 
architecture, cost, time, and risk, as well as information such as milestones, deliverables and 
project  organisation.  Subsequently,  Business  Process  Modelling,  the  practice  whereby  the 
business processes from the legislation are graphically represented in process flows or process 
models  is  used  to  help  develop  the functional  specifications  for  the  systems.  The  benefit  of 
graphically depicting process models is to enable common understanding and analysis. In this 
context  the  technical  specifications  are  developed  which  identify  in  more  detail  how  the 
system  will  be  constructed,  the  architecture  to  be  used,  the  messages  to  be  submitted  by 
economic operators, the interfaces to other systems, test plans etc.  

The  Commission  and  the  Member  States  meet  regularly  to  define  and  agree  these  project 
documents  for  each  trans-European  system,  systematically  involving  consultations  with  the 
trade  community  through  the  Trade  Contact  Group.  A  major  challenge  is  to  ensure  that 
existing systems continue to function smoothly while the new systems are under development 
and to ensure smooth IT transitions from existing systems to upgraded ones. This is vital so 
that trade and customs operations do not come to a standstill. 

The  Commission  has  successfully  upgraded  or  deployed  six  central  systems  and  will 
complete two further central systems by 31 December 2020. Thus, in total, by end 2020, 
the  Commission  will  have  completed  eight  of  the  fourteen  trans-European  systems  for 
which it is responsible. The six  remaining trans-European projects, three  of  which are 

3 Regulation (EU) 2019/632 of the European Parliament and of the Council of 17 April 2019 amending Regulation (EU) No 
952/2013  to  prolong  the  transitional  use  of  means  other  than  the  electronic  data-processing  techniques  provided  for  in  the 
Union Customs Code (OJ L 111, 25.4.2019, p. 54–58). 

3 

 
 
 
                                                      
decentralised and include major components for completion by Member States, are on 
track for the deadlines agreed in the context of the UCC, UCC WP and MASP-C 2019. 
The  activities  performed  by  the  Commission  so  far  represent  about  62%  of  its 
development work due by 2025 as represented in the graph below. 

100%

90%

80%

70%

60%

50%

40%

30%

20%

MASP2019 Baseline

Actual Completion

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Fig 1: Percentage of achievement of Commission tasks in the implementation of the UCC WP 

Member States are due to complete the upgrade of their three national systems by 2022, 
other  than  the  export  component  of  the  National  Special  Procedures  system,  which  is 
closely linked to the trans-European Automated Export System and therefore should be 
deployed at the same time as the latter.  

The six completed trans-European central systems (new systems and upgrades) are as follows: 

 

 

 

UCC  Registered  Exporter  System  -  REX  (new):  makes  available  up-to-date 
information  on  both  registered  exporters  established  in  GSP  countries  (countries 
that  benefit  from  the  EU's  Generalised  Scheme  of  Preferences  that  provides 
preferential  access  to  the  EU  market)  and  European  Union  operators  exporting  to 
GSP countries and certain other countries. A first phase of the system, REX1, was 
deployed  in  2015  even  before  the  UCC  entered  into  force  and  the  full  system, 
REX2, was successfully deployed in 2018. 

UCC  Customs  Decisions  -  CDS  (new):  aims  to  harmonise  across  the  Union  the 
processes for customs decisions related to the application of customs legislation, by 
allowing  for  the  electronic  submission  of  applications  through  a  unique  European 
customs  trader  portal,  by  facilitating  consultations  among  customs  authorities 
during  the  decision-taking  period  and  the  management  of  the  authorisations 
process. This system was successfully deployed in 2017. 

Direct  Trader  Access  to  the  European  Information  Systems  –  UUM&DS 
(Uniform User Management & Digital Signature)(new): aims to provide a technical 
enabler for authentication and user management of economic operators and allows 
for  the  implementation  of  the  EU-harmonised  trader  access  to  the  different 

4 

 
 
 
 
 
 
 

 

 

electronic customs systems provided for in the UCC. This system was successfully 
deployed in 2017. 

UCC  Economic  Operator  Registration  and  Identification  System  Upgrade  – 
EORI  (upgrade):  aims  at  providing  a  minor  upgrade  to  the  existing  system  that 
enables the registration and identification of economic operators of the Union and 
third country persons active in customs matters in the Union.  This upgrade of the 
existing system was successfully deployed in 2018. 

UCC Surveillance 3 – SURV3 (upgrade): aims to upgrade, so as to align with UCC 
requirements,  the  existing  database  that  records  and  centralises  all  EU  trade  data 
(imports and exports) provided on a daily basis by the national customs authorities. 
This upgrade of the  existing system was successfully deployed in October 2018. 
However,  full  implementation  of  this  project  requires  the  deployment  of  Member 
States’ upgraded import and export system (see projects below). 

UCC Binding Tariff Information – BTI (upgrade): aims to align with UCC rules 
the  long-standing  database  that  contains  all  binding  tariff  information  issued  by 
customs  authorities  of  Member  States.  Steps  1  and  2  were  completed  by  October 
2017. The second phase faced a delay of two quarters during the elaboration phase. 
Nevertheless,  the  overall  planning  remained  on  target  and  the  UCC  aligned  eBTI 
system was completed in October 2019. This entailed also the construction of the 
access to this system through the EU Customs Trader Portal. 

The  two  trans-European  central  systems  that  should  be  completed  by  31  December  2020 
pursuant to Article 278(1) UCC are: 

 

 

UCC  Authorised  Economic  Operators  –  AEO  (upgrade):  aims  to  improve  the 
business processes related to AEO applications and authorisations taking account of 
the legislative changes in the UCC. Phase 1 was completed on 5 March 2018 and 
phase  2,  part  1  was  completed  on  1  October  2019,  including  the  new  UCC 
requirements  in  terms  of  electronic  submission  through  the  EU  Customs  Trader 
Portal  and  the  changes  in  relation  to  the  decision-taking  process.  Phase  2,  part  2 
(subsequent processes) is planned for 16 December 2019. 

UCC  Information  Sheets  for  Special  Procedures  -  INF  (new):  develops  a  new 
system  to  support  and  streamline  the  processes  of  data  management  and  the 
electronic  handling  of  data  required  in  connection  with  the  customs  formality 
known  as  Special  Procedures.  The  technical  specifications  were  completed  on  30 
June 2018. No risks have been identified for deployment by 1 June 2020. 

The  three  Member  States’  systems  that  are  due  by  31  December  2022  pursuant  to  Article 
278(2) UCC are as follows: 

 

UCC  Notification  of  Arrival  (NA),  Presentation  Notification  (PN),  and 
Temporary  Storage  (TS)  (upgrade):  defines  the  automation  of  processes  at 
national  level  in  respect  of  Notifications  of  Arrival  of  means  of  transport, 
Presentation of goods and declarations for Temporary Storage, as described in the 
UCC,  and  supports  harmonisation  across  the  Member  States  as  regards  the  data 
exchange  between  trade  and  customs.  Belgium  has  established  a  collaboration 
initiative with 12 other interested Member States in order to prepare specifications. 
An  expert  team,  co-funded  by  the  Customs  2020  Programme,  will  continue 

5 

 
 
 
 
 

 

delivering  the  appropriate  technical  documentation.  So  far,  no  delays  have 
materialised.  However,  risks  for  delays  have  been  pointed  out  by  a  few  Member 
States  as  referred  to  in  the  Member  States  national  planning  and  progress 
information.  

UCC National Import Systems – NIS: (upgrade) aims at implementing all process 
and  data  requirements  deriving  from  the  UCC  which  relate  to  imports.  Member 
States must develop technical specifications at their level as a first step towards the 
completion  of  the  systems.  They  have  informed  the  Commission  that  these 
specifications are in progress and should be completed by various dates up to 1 July 
2021. So far, no delays have been reported, as regards the 2022 deadline.  

UCC Special Procedures (SP) (upgrade): aims at harmonisation and facilitation of 
special  procedures  (customs  warehousing,  end-use,  temporary  admission  and 
inward  and  outward  processing).  Member  States  will  have  to  implement  in  their 
national systems  all  UCC changes required for these  special  procedures. The first 
(export) component of the SP will be implemented in-line with and as part of the 
national  UCC  Automated  Export  System  (AES)  project  (with  a  2025  deadline), 
while  the  second  (import)  component  will  be  part  of  the  upgrade  of  the  National 
Import Systems (with a 2022 deadline). Five Member States have started working 
on  the  technical  specifications  for  Component  1.  Five  Member  States  have 
completed  the  technical  specifications  for  Component  2  while  eight  others  are  in 
progress.  New  functionalities,  a  new  data  structure  and  a  transitional  period  all 
contribute to the complexity of this project. Furthermore, delays may be triggered 
by the interdependencies with AES and the National Import Systems Upgrade. So 
far, no risks have materialised, and the first deadline is now 2022.  

The  six  trans-European  projects  with  their  specific  architecture,  requiring  in  some  cases  a 
combination of central and national components or linked to a national system, and containing 
sometimes more than one phase or project component, due by 31 December 2025 pursuant to 
Article 278(3) UCC are as follows: 

 

 

 

UCC Guarantee Management – GUM (new): aims to allow a real time allocation 
and management across the EU of comprehensive customs guarantees that traders 
lodge  where  there  are  risks  that  duties  might  not  be  paid.  The  technical 
specifications  are  planned  to  be  completed  by  30  September  2022  for  the  project 
Component 1 related to the  trans-European GUM and 30 November 2024 for the 
project  Component  2 related to  the  National  Guarantee  Management  system.  The 
project has just started. 

UCC Import Control System Upgrade – ICS2 (upgrade): aims  to strengthen the 
safety  and  security  of  the  supply  chain  by  means  of  improving  data  quality,  data 
filing,  data  availability  and  data  sharing  in  regard  to  pre-arrival  notifications 
(“Entry  Summary  Declarations”)  and  related  risk  and  control  information.  The 
technical specifications were completed on 30 June 2018 so work is on track and no 
risks for delays are reported. The project will be delivered in three releases to allow 
a feasible transition per mode of transport. 

UCC  Proof  of  Union  Status  -  PoUS  (new):  will  store,  manage  and  retrieve  all 
declarations  that  traders  provide  to  prove  the  Union  status  of  their  goods.  This 
project can be deployed either centrally or nationally but many Member States have 
explicitly  conveyed  their  intention  to  use  the  central  system  developed  by  the 
European Commission. In view of the dependency between the implementation of 

6 

 
 
 

 

 

the UCC customs  goods manifest as  a proof of Union status and of the European 
Maritime  Single  Window  the  project  in  two  phases  to  avoid  inconsistency  and 
reduce  risks.  For  those  Member  States  that  prefer  to  deploy  a  system  component 
nationally, they reported to have difficulty in predicting if their implementation will 
follow the timeline indicated in the Work Programme due to the early project stage.  

the  processing  of  customs  declarations  and 

UCC Centralised Clearance for Import – CCI (new): aims to coordinate between 
relevant  customs  offices 
the 
authorisation  to  release  goods  so  that  economic  operators  can  centralise  their 
dealings  with  customs  authorities.  The  system  will  be  based  on  the  new  national 
import  systems  and  enable  an  automated  functioning  of  the  centralised  clearance 
process at European level. The functional specifications for CCI Phase 1 have been 
approved  in  March  2019,  so  the  project  is  on  track.  The  technical  specifications 
should be completed by 30 September 2020 for Phase 1 and 30 June 2022 for Phase 
2. 

UCC  New  Computerised  Transit  System  –  NCTS  (upgrade):  The  New 
Computerised Transit System aligns the existing Union and common transit system 
to the new UCC requirements, the alignment of information exchanges to UCC data 
requirements and the upgrade and development of interfaces with other systems. So 
far,  no  delays  have  materialised  for  NCTS  Phase  5,  the  technical  specifications 
were completed in December 2019 and the project is currently on track. The plan is 
to finalise the business case for NCTS Phase 6 (interconnection with other systems) 
in 2020. 

(project  Component  1)  entails 

UCC  Automated  Export  System  –  AES  (upgrade  of  both  the  existing  trans-
European system and of the existing National Export Systems): aims to implement 
the UCC requirements for export and exit of goods. The project related to the trans-
European  AES 
the  UCC 
simplifications  offered  to  trade  to  facilitate  export  of  goods  for  European 
companies,  such  as  centralised  clearance,  and  the  UCC  obligations  to  better 
monitor what exits the EU customs territory to prevent fraud. So far, no delays have 
materialised,  the  technical  specifications  for  Component  1  (Trans-European  AES) 
were  completed  in  December  2019  and  the  project  is  currently  on  track.  For  the 
project Component 2 as regards the National Export Systems upgrade, the technical 
specifications  should  be  completed  by  1  September  2022.  Member  States  should 
complete the Export Component of their Special Procedures systems (see above) at 
the same time as the AES. 

implementing 

Risks for delays 

In 2018, the European Court of Auditors looked at the reasons for the delays in delivering the 
electronic systems of the UCC in their Special Report N°264. They highlighted that 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.  They  also  noted  that  the  Commission  did  not  report 
appropriately  on  delays,  and  that  the  Customs  2020  programme  objectives  and  reporting 
arrangements  were  not  suitable  for  monitoring  the  implementation.  Meanwhile  the 

4 European Court of Auditors (2018) A series of delays in Customs IT systems: what went wrong? 

7 

 
 
 
                                                      
Commission  and  the  Member  States  have  taken  important  steps  in  improving  oversight  of 
implementation  and  delivering  and  as  such  are  now  in  a  better  position  to  avoid  risks  of 
further  delays  in  the  implementation  of  the  UCC  WP  and  ensure  follow  up  to  the 
recommendations in the Special Report. 

On a general note,  it should be kept  in mind that any new  political initiatives adopted 
between now and 2025 that impose obligations on customs systems would risk leading to 
a delay in the completion of the UCC electronic systems by the relevant deadlines. The 
world  is  changing  rapidly  and  it  may  become  crucial  –  for  example  for  safety  and  security 
reasons  –  to  require  customs  authorities  to  perform  additional  tasks  at  the  EU’s  borders. 
However, such new tasks may require further changes to electronic systems.    

Turning to the survey, a key finding is a common pattern of difficulties and risks of delays 
in  Member  States  due  to  their  lack  of  resources  and  to  the  complexity  of  the  UCC 
projects.  A  considerable  number  of  the  Member  States  have  reported  a  lack  of  national 
preparation  in  relation  to  project  management.  There  are  cases  where  tenders  have  not  yet 
been awarded for any of the projects and in some cases national project managers have not yet 
been assigned to the projects. Member States have pointed to the lack of human resources as a 
particular risk for the successful and timely implementation of the projects. The problem of 
human  resources  is  observed  not  only  in  a  quantitative  context,  but  also  qualitatively,  with 
some Member States stating that their personnel lack the required customs expertise.  

In addition, a number of Member States have expressed their concern about the perceived 
instability  of  the  common  data  requirements  to  be  utilised  for  the  purpose  of  the 
electronic  systems.  These  common  data  requirements  are  set  out  in  Annex  B5  of  the  UCC 
Delegated Act package (UCC-DA). During the development of some trans-European systems 
it emerged that in some cases Annex B could not be implemented in view of the functional 
needs  or  it  could  be  implemented  only  with  disproportionate  costs.  For  example,  in  the 
context of ICS2 it was necessary to insert additional columns into Annex B in order to reflect 
all  data  sets  that  are  possible  in  ICS2.  This  led  to  a  review  of  Annex  B  to  align  it  with 
functional and technical specifications for trans-European systems and to ensure cross-system 
harmonisation, as requested by the Member States and the trade community. This review will 
naturally have an impact on national systems, even though a joint effort was made to keep the 
impact on these systems minimal. This is regretted by those Member States that are advanced 
with their national systems developments despite the fact that the revision of Annex B is in 
general appreciated.  

It is envisaged that an agreement with Member States on the revised Annex B will be reached 
by the end of 2019 and the related legislation will then be adopted in 2020. However, Member 
States  are  concerned  that  this  instability  negatively  impacts  their  national  planning  efforts. 
Specifically,  they  agree  that  the  frequent  addition  of  new  obligations  and  deadlines  via  the 
updates to the UCC WP jeopardises their ability to reflect the common data requirements in 
their national systems. However, it should be noted that the current review of the UCC WP 
has become necessary in order to properly implement the amended Article 278 of the UCC. 
The amendment to Article 278 of the UCC is the result of the compromise found between the 
European  Parliament,  the  Council  and  the  Commission.  The  applicability  of  the  different 
columns  of  Annex  B  to  the  UCC-DA  is  linked  to  the  deployment  dates  of  the  electronic 
systems defined in the UCC WP. 

5European Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No 952/2013 
of the European Parliament and of the Council as regards detailed rules concerning certain provisions of the Union Customs 
Code (OJ L 343, 29.12.2015, p. 1). 

8 

 
 
                                                      
Another  concern  that  Member  States  have  expressed  is  the  instability  created  and  the 
difficulties to plan due to the ongoing review cycles of business and IT documentation. 
These review cycles (where documents go through iterative updates as a result of input from 
experts) are necessary to ensure a common understanding and implementation of the systems. 
Where  Member  States  depend  on  the  finalisation  of  the  project  documentation,  they 
sometimes  do  not  yet  have  any  form  of  national  planning  for  some  projects.  Though  many 
Member States express their willingness to take mitigating actions to ensure that they respect 
the planning deadlines set out in the UCC WP, their impact assessment processes are long and 
complex and are slowing down their efforts.  

Member States reported that they operate based on an “Agile”6 approach, which allows for 
flexibility. However, such an approach means that at the same time some projects are planned 
only six quarters in advance. Hence, these Member States do not yet have an accurate view on 
their ability to meet the target deployment dates for some systems.  

Finally, new challenges will emerge, requiring new customs policy, legal and IT measures to 
be  put  in  place,  sometimes  with  urgency,  and  often  endanger  the  already  agreed  planning 
schemes for the UCC WP implementation (e.g. e-commerce, etc.). 

As  a  conclusion,  there  is  for  the  moment  no  critical  risk  identified  concerning  the 
deadline for finishing the implementation of the UCC systems by the end of 2025. This 
said,  the  IT  teams  of  the  Commission  and  of  the  Member  States  Customs  Administrations 
need  to  be  provided  with  the  appropriate  resources  to  mitigate  the  existing  high  risks  of 
missing  deadlines  for  some  of  the  systems,  notably  concerning  national  systems.  There  is  a 
need  to  ensure  appropriate  statutory  staff  in  the  IT  teams  to  lead  the  projects,  and  financial 
resources  in  the  current  Customs  2020  and  future  replacement  programme  to  ensure  the 
delivery  by  outsourcing  partners.  There  is  also  a  need  to  avoid  scope  creep  and  new 
legislation with an impact on Customs systems before the end of 2023. If these measures are 
in place, as per the recommendations of the European Court of Auditors report, the risk level 
should be reasonably under control. 

Mitigation actions 

A Multi-Annual Strategic Plan for Customs (MASP-C) dashboard is used as a progress 
tracking and information tool from the Commission side on its progress. The baseline for 
the  dashboard  milestones  is  the  MASP-C  2019  and  the  UCC  WP  2019.  The  dashboard  is 
presented on a quarterly basis to the Member States (Electronic Customs Coordination Group) 
and the trade community (Trade Contact Group) for information and steering purposes. 

The  Commission  is  now  not  only  monitoring  progress  against  the  main  project 
milestones as in the UCC WP and MASP-C but is also setting specific interim milestones 
per  project  (e.g.  milestones  by  which  all  Member  States  should  have  completed  the 
conformance testing). Such closer monitoring is needed in order to make the deployment of 
the  decentralised  trans-European  systems  manageable  and  to  avoid  additional  costs  for 
operating  old  and  new  systems  in  case  of  an  extended  deployment  window.  As  these  core 
trans-European  systems  with  their  decentralised  architecture  will  only  be  successful  if  all 
Member  States  have  switched  to  the  new  environment,  the  Commission  has  urged  Member 
States  not  to  wait  until  the  end  of  the  deployment  window  to  make  the  switch  to  the  new 

6A  method  of  project  management,  used  especially  for  software  development,that  is  characterised  by  the  division  of  tasks 
into short phases of work and frequent reassessment and adaptation of plans. 

9 

 
 
                                                      
systems.  A  “National  Administration  quarterly  monitoring  programme”  for  the  trans-
European systems AES  and NCTS with Key Performance Indicators will run from 2020, in 
order to measure progress on a regular basis and raise flags well in advance where problems 
might occur.  

As  another  accompanying  measure, 
the  Commission  will  establish  a  “National 
Administration  coordination  programme” in  early  2020  to  support  Member  States  in  the 
development  and  deployment  of  their  national  components  for  the  trans-European  systems. 
These systems are specifically targeted because, Member States agreed in 2016-2017 that the 
import, transit and export systems were the core systems and should be considered as the top 
priorities for deployment. As a number of Member States have pushed their  transition work 
on the national systems and components related to import, transit and export procedures to the 
very end of the deployment windows, there is a risk that they haven't foreseen sufficient time 
for  testing  and  finalising  the  deployments  according  to  the  common  specifications  and  IT 
transition policy. As the trans-European systems will only function properly when all Member 
States  have  joined  in,  national  deployment  issues  or  delays  will  impact  the  trans-European 
system layer and endanger the timely completion.  

In addition, based on feedback from the Member States the Commission already identified a 
risk of completion of the national systems due by 2022, in particular in relation to the entry of 
goods and import domain, which would negatively impact the completion of CCI.   

These  programmes  will  help  to  steer  the  IT  transition  process  from  2020  with  a  dedicated 
helpdesk,  webinars,  bilateral  visits,  training,  conformance  testing  follow  up,  quarterly 
progress  reporting,  service  delivery  management,  etc.  Member  States  and  the  Commission 
need to be well equipped to face the challenges ahead.  

The  output  of  these  programmes  is  considered  to  bring  valuable  progress  information 
and  will  be  used  for  the  future  annual  progress  reports.  It  will  provide  for  detailed 
progress information per project and per Member State.  

4.  CONCLUSION 

In  conclusion,  it  is  evident  that  the  Commission  and  Member  States  face  challenges  in 
ensuring the full deployment of the UCC electronic systems by the relevant deadlines. There 
are resource issues in Member States, the systems are complex and interconnected, and there 
must  be  a  smooth  transition  from  existing  systems  to  upgraded  ones,  so  that  the  impact  on 
trade is minimised.  

Nevertheless, it is also clear that tangible progress is being made. An important number of 
electronic systems have already been deployed and are now fully operational.  

The  remaining  ones  are  mostly  on  track  and  planned  to  be  completed  in  the  period 
2020-2025 in line with the planning of the projects defined in the UCC WP. A summarised 
overview of the planning and progress can be found in Fig 2 below.  

10 

 
 
 
Fig 2: Planning for UCC WP projects 

With  regard  to  these remaining  systems,  while  a  number  of  issues  have  been  highlighted  at 
Member  States  level,  no  critical  risks  have  been  identified  at  the  time  of  writing  of  this 
report. The Commission and the Member States will continue their regular meetings to steer 
and monitor the projects via the MASP-C dashboards and via the reinforced planning and 
progress reporting requirements for the UCC WP implementation. The Commission and the 
Member  States  will  also  continue  the  elaboration  and  development  work  for  the  remaining 
trans-European systems in terms of business cases and vision documents, as well as to prepare 
the  functional  and  technical  specifications  (including  transitional  technical  specifications  in 
some cases) as the basis for the systems rollouts and deployments.  

The Commission is planning additional mitigating actions as of early 2020, in the form of a 
coordination  programme  to  assist  Member  States  in  the  deployment  of  their  components  of 
the  AES  and  NCTS  systems,  in  particular,  and  a  monitoring  programme  to  assess  their 
progress in this area. With these managerial instruments, the Commission is confident that it 
has  the  appropriate  mechanisms  in  hand  to  face  the  upcoming  dynamic  challenges.  Many 
Member  States,  for  their  part,  have expressed  their  willingness  to  take  mitigating actions  to 
ensure that they respect the planning deadlines set out in the UCC WP.  

More details of the planning and status of each project are provided in a  Commission staff 
working document published alongside this report.  

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