REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 14(3) of Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 2019 on the introduction and the import of cultural goods
Date: 2020-07-30
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: administrative cooperation, cultural heritage, exchange of information, fight against crime, heritage protection, illicit trade, import (EU), information system, surveillance concerning imports, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.7.2020  COM(2020) 342 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 14(3) of Regulation (EU) 2019/880 of the European Parliament and of the Council of  17 April 2019 on the introduction and  the import of cultural goods    
 
 
Table of Contents 

1. 
INTRODUCTION ........................................................................................................................... 2 
2.  OBJECTIVES TO BE MET ............................................................................................................ 3 
3.  PROJECT ARCHITECTURE AND PLANNING APPROACH .................................................... 4 
4.  PROGRESS OVERVIEW .................................................................................................................. 5 
5.  RISKS FOR DELAYS..................................................................................................................... 7 
6.  CONCLUSIONS ............................................................................................................................. 8 
Annex I: Multi annual strategic planning ................................................................................................ 9 
Annex II: Main project phases and critical milestones timeline ........................................................... 11 

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1.  INTRODUCTION 
Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 20191 
on  the  introduction  and  the  import  of  cultural  goods  (“the  Regulation”)  aims  to  prevent  the 
illicit  trade  in  cultural  goods,  in  particular  when  it  contributes  to  the  financing  of  terrorist 
activities,  and  to  prohibit  the  import  into  the  Union  customs  territory  of  cultural  goods 
exported illegally from third countries.  

The  Regulation  subjects  the  import  of  certain  cultural  goods,  considered  to  be  particularly 
endangered heritage, to import licences and others, which are considered as less endangered, 
to importer statements and ensures that they undergo uniform controls when imported into the 
Union. Furthermore, any physical introduction, for instance, through transit, into the Union of 
cultural  goods  which  have  been  removed  from  the  territory  of  the  third  country  where  they 
were  created or discovered in  breach of its laws  and regulations is  prohibited (the so-called 
‘general prohibition rule’).  
The  material  scope  of  the  Regulation  is  inspired  by  the  1970  UNESCO  Convention2  and 
defined  in  its  Annex,  by  listing  the  categories  of  cultural  goods  for  which  the  general 
prohibition rule applies (part A), and those which are subject to import licences (part B) and 
importer statements (part C), respectively. 

The  Commission’s  original  proposal  provided  for  the  possibility  -  without  prescribing  a 
specific  timeframe  -  for  an  electronic  system  to  be  developed,  in  order  to  facilitate  the 
administrative co-operation between the Member State authorities in charge of implementing 
the  Regulation.  However,  following  the  request  of  the  European  Parliament  and  of  the 
Council  during  the  adoption  negotiations,  an  obligation  for  the  Commission  to  establish  a 
centralised electronic system within a specific timeframe was introduced in the Regulation.  

The centralised electronic system is to become operational at the latest within a period of six 
years  from  the  entry  into  force  of  the  Regulation  (28.06.2019),  i.e.  by  28  June  2025  at  the 
latest.  Furthermore,  the  system  will  not  only  serve  as  a  means  for  the  storage  and  the 
exchange  of  information  between  Member  States  administrations,  but  also  for  the 
accomplishment of formalities by operators, namely the submission of applications for import 
licences to the Member States competent authorities and the issue of those licences, and the 
submission of importer statements to customs.  

Moreover, the development and functioning of the centralised electronic system for the import 
of cultural goods (hereafter ‘the ICG system’) is closely linked with another major initiative 
of  the  Commission  in  the  field  of  customs:  the  EU  Single  Window  Certificate  Exchange 
System (EU-CSW CERTEX)3.  

The  EU-CSW  CERTEX  aims  at  interconnecting  EU  centralised  systems  for  Union  non-
customs formalities, with national customs systems in view of allowing a digital exchange of 
supporting  documents,  results  of  controls  and  the  outcome  of  customs  and  non-customs 
procedures.  Operators  will  benefit  from  this  mechanism  by  not  having  to  carry  physical 
copies  of  documents,  and  competent  authorities  will  not  have  to  deal  with  verifying  the 
authenticity of importer statements and import licences. 

To achieve these objectives, the Regulation  requires the European Commission to lay down 
by  means  of  implementing  provisions  the  arrangements  for  the  deployment,  operation  and 
maintenance of the centralised electronic ICG system, as well as the detailed rules regarding 

1 OJ L 151, 7.6.2019, p. 1–14 
2 The UNESCO Convention on Preventing and Prohibiting the Illicit Import, Export and Transfer of Ownership 
of Cultural Property, signed in Paris in 1970. 
3 https://ec.europa.eu/taxation_customs/general-information-customs/electronic-customs/eu-single-window-
environment-for-customs_en  

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the  submission,  processing,  storage  and  exchange  of  information  between  the  authorities  of 
the Member States through the same electronic system. 

Despite  of  the  project  progressing  on  several  levels  at  the  same  time,  it  can  be  figuratively 
divided into three phases: 

  Phase 1 – Conceptualisation: in this phase the Commission has to study how the ICG 
system  is  going  to  work,  and  determine  the  detailed  rules  regarding  the  submission, 
processing and storage of the information between the authorities of the Member States. 
As a result of this phase, the Commission will produce an implementing act and a parallel 
set of technical documents detailed in Table 1 (see Annex I); 

  Phase 2  – System development: following the provisions of the implementing act  and 
the  technical  documents  describing  the  system  requirements,  the  Commission  has  to 
produce  detailed  technical  system  specifications,  develop  the  ICG  system  and  its  link 
with  the  EU  Customs  Single  Window  Certificates  Exchange  System  (EU-CSW 
CERTEX); 

  Phase 3 – Deployment and Operations: this last phase consists in the deployment and 
test  of  the  ICG  system,  including  specific  training  activities  in  each  Member  State  to 
ensure  that  by  28  June  2025,  operators  and  competent  authorities  are  capable  and  well 
trained in the use of the system. To this phase will follow a 6 months after-care period, in 
which  the  system  will  be  fine-tuned  to  match  any  operational  need  that  may  become 
evident  only  after  an  IT  system  becomes  mandatory,  and  to  ensure  that  operations  are 
running smoothly. 

The  Regulation  provides  that  by  28  June  2020  and  every  12  months  until  the  electronic 
system becomes operational, the European Commission is to present a report to the European 
Parliament  and  to  the  Council  on  the  progress  made  in  adopting  the  relevant  implementing 
provisions and establishing the electronic system. 

This first annual progress report focuses mainly on Phase 1, and describes the developments 
during the first year after the Regulation entered into force. It analyses the progress made, 
outlining  also  the  objectives  to  be  met,  the  project  architecture  and  the  planning 
approach.  On  that  basis,  it  highlights  the  risks  for  potential  delays,  as  well  as  the 
mitigating measures envisaged.  

The overall assessment of the progress made is summarised in the conclusions section of 
this report.  

2.  OBJECTIVES TO BE MET 

The  electronic  system  will  have  to  become  operational  by  28  June  2025  at  the  latest,  as  on 
that  date  it  will  become  mandatory  for  all  operators  to  obtain  import  licences  or  submit 
importer  statements  through  that  electronic  system,  in  order  for  them  to  be  able  to  import4 
cultural goods legally into the Union.  

The  Regulation  entered  into  force  on  28  June  2019  and  has  set  a  final  deadline  of  28  June 
2021 for the adoption via the examination procedure of implementing provisions laying down 
the detailed rules for the electronic system.  

Following  the  adoption  of  the  implementing  provisions,  the  development  phase  of  the 
electronic system will cover about two years, at the end of which, the third phase will start, 
during which the ICG system will be interconnected to the EU-CSW CERTEX, to allow the 

4  The  placement  of  goods  under  the  following  customs  procedures  is  defined  as  ‘import’  in  the  Regulation: 
release for free circulation; storage in customs warehouses or free zones; temporary import; end use, including 
inward processing. 

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exchange  of  documents  with  Member  States’  customs  systems.  Training  sessions  will  be 
organised to familiarise their administrations with the systems operational functionalities.  

Alongside other activities of the Commission in the field of customs, the project on the import 
of  cultural  goods  is  also  planned  in  detail  through  the  Multiannual  Strategic  Plan  for 
electronic Customs 2019 revision5 (MASP-C rev. 2019). The MASP-C is a management and 
planning instrument, based on existing legislation or international agreements, which is drawn 
up by the Commission in partnership with Member States in accordance with Article 8(2) of 
the e-Customs Decision6. An excerpt of the planning of the project on the import of cultural 
goods from MASP-C rev. 2019 is provided in Annex I to this report. 

Part  of  the  project  on  the  import  of  cultural  goods  is  developed  also  within  the  EU  Single 
Window  Environment  for  Customs  (MASP-C  rev  2019  Fiche  1.13)  of  which  EU  CSW-
CERTEX  is  the  key  IT  system.  An  excerpt  of  the  planning  of  EU  CSW-CERTEX  from 
MASP-C Fiche 1.13 is provided in Annex I to this report. 

In fact,  the import of cultural  goods entails a close cooperation between  national  competent 
authorities  who  issue  the  import  licences,  and  customs,  who  need  those  licences  to  clear 
cultural goods at the border. The Commission has carried out (starting already in Q1 2017) a 
preliminary  analysis  on  the  possible  interconnection  between  the  ICG  system  and  customs. 
This analysis fed the initial work for the conceptual phase of the ICG system, and progresses 
in parallel to the milestones detailed in Table 1 (see Annex I). 

3.  PROJECT ARCHITECTURE AND PLANNING APPROACH 

The Project Architecture is based on the methodology provided for in MASP-C rev. 2019 and 
its  Annexes,  including  the  Governance  Scheme7,  the  EU  Customs  Business  Process 
Modelling  Policy8  and  the  IT  strategy9.  A  comprehensive  roadmap,  with  the  main  project 
phases and the critical milestones is detailed in Annex II. 

Phase 1 – Conceptualisation: 

The  work  of  developing  IT  systems  involves  several  phases.  Initially,  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, 
to  enable  common 
understanding and analysis, Business Process Modelling (BPM) is used, the practice whereby 
the  business  processes  from  the  legislation  are  graphically  represented  in  process  flows  or 
process models, to help develop the functional specifications for the system. 

Phase 2 -  System development: 

Following this, 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. 

5 See https://ec.europa.eu/taxation_customs/general-information-customs/electronic-customs_en. 
6  Decision  No  70/2008/EC  of the  European  Parliament  and  of  the  Council  of  15  January  2008  on  a  paperless 
customs environment for customs and trade, OJ 2008, Nº L23, p. 21. 
7 https://ec.europa.eu/taxation_customs/sites/taxation/files/2019_masp_annex3_en.pdf  
8 https://ec.europa.eu/taxation_customs/sites/taxation/files/2019_masp_annex4_en.pdf  
9 https://ec.europa.eu/taxation_customs/sites/taxation/files/2019_masp_annex5_en.pdf  

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Once the design of the system is ready from the conceptual perspective and the deliverables 
listed in Table 1, Milestones 1 and 3 (see Annex I) are produced, a more in-depth work begins 
and more technical aspects are taken into account in the Application & Service specifications 
and  Technical  System  Specification  documents,  which  are  the  natural  evolution  of  the 
deliverables produced during the Business Analysis and Project Initiation phases. 

Phase 3 – Deployment and Operations: 

Lastly, the actual IT development phase begins (Construction Phase), which is followed by a 
Transition  phase  where  the  early  versions  of  the  system  are  gradually  rolled  out  to  the 
different  groups  of  users  and  tests  are  performed.  Parallel  to  the  roll-out  and  testing,  the 
training activities and communication on the functioning of the system take place. 

In the case of the electronic system for the Import of Cultural Goods (ICG), it is not foreseen 
to  integrate  the  service  with  national  cultural  goods  licencing  systems  already  existing  in 
some  Member  States,  nor  a  national  technical  implementation,  due  to  the  fact  that  the  ICG 
system  will  be  centrally  managed  by  the  Commission.  Operators  and  competent  authorities 
alike  will  be  able  to  access  and  use  the  system  through  the  Graphic  User  Interface  (GUI) 
provided by the Commission.  

From  a  policy  perspective,  this  choice  is  considered  the  best-fitting  solution,  given  the 
complexity of the cultural goods subject to trade. In fact, customs systems on their own are 
ill-equipped  to  allow  for  a  complete,  detailed  description  of  each  piece  of  cultural  heritage 
which is, in most cases, unique in itself. 

On  the  other  hand,  the  ICG  system  will  be  interconnected  with  Member  States’  customs 
administrations  via  the  EU  CSW-CERTEX,  to  allow  customs  automated  controls  on  the 
documents  issued  for  the  import  of  cultural  goods.  This  activity  will  require  Conformance 
Testing. 

4.  PROGRESS OVERVIEW  

Consultation and discussions 

In  the  first  phase  the  Commission  is  preparing  the  adoption  of  implementing  provisions  for 
the establishment of the electronic system. In order to get a better perspective from a practical 
implementation point of view, it consults regularly on policy options with the Members States 
delegates at the Expert Group on customs issues related to cultural goods.  

The Expert Group is a forum for the discussion of implementation issues of Union legislation 
on  cultural  goods  pertaining  to  customs  and,  in  particular,  the  Regulation  on  the  export  of 
cultural goods10, a set of rules that also provides for a licencing system – at export - which has 
been in force since 199311.  

The  Commission  informs  art  market  associations  about  the  progress  of  work  at  every 
opportunity, listens to their concerns and has taken them into consideration, in order to ensure 
that  the  practical  implementation  of  the  Regulation  is  well  adapted  to  the  realities  of  the 
market. 

As the drafting of the implementing act  progresses, the Commission will  carry out  the final 
consultations  with  the  Committee  of  Regulation  2019/880,  as  this  would  be  the  body 
ultimately voting on the implementing act. 

10  Council  Regulation  (EC)  No  116/2009  of  18  December  2008  on  the  export  of  cultural  goods  (OJ  L  39, 
10.2.2009, p. 1–7) 
11  Before  the  creation  of  Expert  Groups  for  the  purposes  of  the  Lisbon  Treaty,  these  same  discussions  were 
taking  place  within  the  Committee  of  Regulation  (EC)  No  116/2009.  The  members  of  the  Expert  Group  are 
mostly the same authorities that are meeting within that Regulation’s Committee. 

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In  parallel,  the  Commission  has  created  a  ‘Customs  2020  Project  Group  on  the  import  of 
cultural  goods’  (“PGICG”),  which  serves  as  a  discussion  platform,  where  experts  from 
national  customs  administrations  and  competent  (cultural)  authorities  with  experience  in 
carrying out licencing formalities in heritage matters, in particular digitally, come together to 
provide support with drafting the implementing act, defining the parameters and elaborating 
the criteria for the functional specifications of the system. 

The  Project  Group  consists  of  18  delegates  from  11  Member  States  (AT,  BE,  BG,  ES,  LV, 
PT, RO, DE, NL, IT, FR) and to-date it has met six times. 

Specifically, the Project Group provides support and expertise on: 

(a)  The preparation and progressive refinement of the implementing act in what concerns the 

creation of a centralised electronic system; 

(b) The  development  of  system  functionalities  for  an  interoperable  electronic  licensing 
system at EU level to ensure uniform controls for the import of cultural goods upon their 
entry into the customs territory of the Union;   

(c)  Technical arrangements on the deployment and maintenance of the centralised electronic 
system and detailed rules concerning the submission, processing, storage and information 
exchange between national authorities; 

(d) Roles  and  responsibilities  of  the  actors  involved  in  the  processing  of  import  licensing 

procedures for cultural goods; 

(e)  Creation  of  the  standard  electronic  template  for  the  import  licence  and  development  of 

the format for the importer statement; 

(f)  Procedural  rules  for  the  submission  and  processing  of  the  application  for  the  import 

licence and registration of the importer statement; 

(g) Consultation on the business case for future system development. 

Design challenges 

Several  challenges  have  been  encountered  with  designing  the  architecture  of  the  electronic 
system.  One of them is the best  way for applicants (for import licences) and declarants  (for 
importer statements) to describe a cultural good, given the particular and unique nature of the 
product, which distinguishes it from regular commodities that can be exhaustively described 
through Common Nomenclature tariff codes. The cultural  goods that come within the scope 
of the Regulation are not mass-produced products and their creation and historical origin dates 
back several centuries, if not millennia.  

That is why the standard data set that will have to be provided by operators will need to be 
particularly  adapted  in  order  to  allow,  on  the  one  hand,  the  adequate  identification  of  the 
objects  for  the  purposes  of  e-licencing  and  declarations  and,  on  the  other,  to  take  into 
consideration  the  reality  of  the  market  and  the  difficulty  in  certain  cases  to  obtain  all  the 
required  provenance  information.  The  Commission,  in  co-operation  with  the  Project  Group 
are making efforts to define these core data. 

Another identified challenge is the design of the import licence ‘lifetime’ stages in such a way 
within this digital  framework, that all possible eventualities and needs of the applicants  and 
the  competent  authorities  are  anticipated  while,  at  the  same  time,  the  procedures  and  the 
related  implementing  provisions  do  not  become  overly  complicated  and  remain  applicant-
friendly,  in  particular  in  the  case  of  applicants  who  will  only  import  cultural  goods  on  an 
occasional basis and who are not art market professionals. 

A  third  matter  to  consider  is  the  compatibility  with  existing  national  administrative 
procedures and practices, as all Member States have been implementing since 1993 the Union 
legislation  on  authorising  the  export  of  Union  cultural  goods,  which  also  provides  for  a 

6 

 
 
licencing  scheme.  Although  those  export  licences  still  have  to  be  issued  on  paper,  a 
significant  number  of  Member  States  have  developed  electronic  means  to  process  the 
applications. In fact, the experience of certain Member States with the export licence system 
and controls of trade in cultural goods in general has been particularly useful in analysing the 
requirements for the import electronic system. 

In the process of designing the architecture of the electronic system for the import of cultural 
goods, it is taken into consideration that in the future and, provided that the necessary human 
and  financial  resources  become  available,  the  same  system  should  be  scalable  to  allow  the 
digitalisation and electronic issue of export licences as well. 

Operational considerations and functionalities 

As  the  Project  Group  is  comprised  by  both  customs  and  cultural  authorities  representatives 
with  experience  with  cultural  goods,  they  have  been  actively  contributing  by  analysing  and 
discussing  proposals  from  the  Commission,  and  providing  statistics/information  on  how 
procedures involving cultural goods are designed at national level. 

In  particular,  the  Project  Group  provided  useful  insights  to  estimate  the  number  of  import 
licences the ICG system could end up managing every year, and the average estimated value 
per  licence;  in  2019  the  number  of  estimated  licences  seems  to  amount  to  49,610  for  an 
average total value of 29.4 billion EUR, limited to the 11 Member States participating in the 
Project Group.  

Moreover, the Project Group is working on a Frequently Asked Questions master-document, 
to feed the communication process afterwards and to anticipate potential hindrances and gaps 
in the development of the ICG system. 

Lastly, the Project Group is constantly reviewing and providing feedback to the data set and 
the BPMs produced for the system and for innovative approaches to the description of cultural 
goods through Image Recognition and Artificial Intelligence. 

5.  RISKS FOR DELAYS 

Project Summary 

The Commission is tasked to develop a centralised electronic licensing system and interface it 
with  national  customs  within  6  years  after  the  entry  into  force  of  the  Regulation.  Two 
Administrator (AD) posts in DG TAXUD are required to deliver on this initiative, as set out 
in the relevant Legislative Financial Statement.  

Risk title & Description 

The delivery of the ICG system is dependent upon the approval by Member States and by the 
European Parliament of appropriate funding for the customs programme which will succeed 
Customs 2020 in the next Multiannual Financial Framework (MFF), and upon the allocation 
of resources in DG TAXUD taking into account the various priorities facing that Directorate 
General. 

Risk 1 – Staff allocation 

The initial proposal from the Commission did not foresee the creation of an IT system. Thus, 
resources were not  allocated accordingly. However, in  the course of the  negotiations  and at 
the  request  of  the  co-legislators,  the  creation  of  the  ICG  system  was  included  in  the 
Regulation, which called for unforeseen at that point, additional resources. The needs for this 
six-year project in terms of IT development personnel in DG TAXUD were estimated at the 
time of the final political trilogues in December 2018 to be two full time Administrator posts. 
However,  based  on  financial  availabilities  sourced  from  the  current  Multiannual  Financial 
Framework (MFF), only one contract staff could be allocated, from late September 2019. 

7 

 
 
Moreover, the objective complexity of the project, the specific knowledge required in terms of 
policy  and  the  technical  tools  used  to  develop  the  ICG  system,  made  the  preparation  and 
training  of  a  resource  to  be  able  to  work  on  the  file  considerably  lengthy.  However,  the 
progress on business functional specifications and system design is only slightly delayed. 

Risk 2 – Budget availability 

Budget uncertainty due to the negotiations on the new MFF render progress very challenging. 
Depending  on  the  outcome  of  the  MFF  negotiations,  and  in  the  worst-case  scenario  the 
development  and  roll-out  phases  risk  to  come  to  a  halt  or  be  significantly  delayed  and  the 
legal deadlines to establish the ICG system impossible to meet. 

In  addition  to  the  risks  identified  above,  the  COVID-19  public  health  crisis  is  affecting  to 
some extent the team’s capacity to deliver and especially the project activities and meetings 
with  the  Expert  Group  and  the  Project  Group  with  the  Member  States.  In  particular,  one 
meeting of the Expert Group was cancelled, which had a direct impact on the progress of the 
work of the Project Group, and the next session of the latter can only be held remotely and for 
a  third  only  of  the  time  initially  scheduled.  Moreover,  the  public  health  crisis  forced  a 
rescheduling of priorities within Member States, thus limiting their capacity to provide input 
and feedback to the file. Such impact will depend on the duration of the public health crisis. 

Mitigation actions 

The risks have been documented within DG TAXUD. A post for an Administrator (AD) has 
been allocated on a temporary basis (2 years).  

6.  CONCLUSIONS 

This very first progress report of the Commission regarding the development of a centralised 
electronic system for the import of cultural goods (ICG) records the actions undertaken so far, 
namely,  

(a)  the ongoing preparation for adopting the necessary implementing provisions,  
(b) the consultation with the Member States via the Expert Group for customs issues related 
to  cultural  goods  and the specifically established for this  purpose Project Group for the 
import of cultural goods. 

As potential risks for delay of delivering the ICG system within the set deadline of 28 June 
2025 the Commission has so far identified the uncertainty surrounding the staff allocated to 
the project, as this depends on current budget availabilities, overall customs IT development 
priorities12 and the future allocation in the next MFF.  

12 Such as the Union Customs Code (UCC) digitalisation exercise. 

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ANNEX I: MULTI ANNUAL STRATEGIC PLANNING 

The  MASP-C  ensures  an  effective  and  coherent  management  of  IT  projects  by  setting  out 
both a strategic framework and milestones. It is ultimately endorsed by the Member States in 
the Customs Policy Group (CPG) based on expert advice provided by the Electronic Customs 
Coordination Group (ECCG) and consultations with trade at the Trade Contact Group (TCG). 

The  planning  for  the  electronic  system  has  been  discussed  and  approved  by  the  Member 
States and is described in detail in Fiche 1.18 of the MASP-C rev. 2019. 

Table  1  below  provides  an  excerpt  of  the  planning  of  the  project  on  the  import  of  cultural 
goods from MASP-C rev. 2019 Fiche 1.18. 

Table 1 - Excerpt of MASP-C rev. 2019 Fiche 1.18 

Milestones 

Estimated completion date 

1 

Business Analysis and Business Modelling 

- Business Case Document 

- Level 3 (User Requirements BPM) 

- Level 4 (Functional Requirement detailed BPM) 

2 

Legal Provisions 

- Current provisions adopted* 

- Future provisions adopted** 

3 

Project Initiation Phase 

- Vision Document 

- GO decision 

4 

IT Project 

- Application & Service Specifications 

- Technical System Specifications 

Construction Phase 

- Central services implementation 

- Service integration in National Systems 

- National implementation 

Transition Phase 

- Deploy and rollout 

- Conformance tests 

5  Operation 

- Commission, Member States administrations and Traders 

- Non-EU Countries and non-EU traders (in case required) 

6 

Implementation support (training and communication) 

- Centrally developed training and communication 

- National training and communication 

Q4 2020 

Q1 2022 

Q1 2022 

Q2 2019 

Q2 2021 

Q2 2021 

Q2 2021 

Q2 2023 

Q2 2023 

Q3 2024 

N/A 

N/A 

Q4 2024 

Q2 2025 

Q2 2025 

N/A 

Q4 2024 

Q4 2024 

*Current provisions refer to Regulation (EU) 2019/880 
**Future provisions refer to the implementing provisions to be adopted according to Regulation (EU) 2019/880 

Table 2 provides an excerpt of the EU CSW-CERTEX project, with a focus on Component 2 
of the EU-CSW CERTEX project, interconnecting the ICG system. 

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Table 2 - Excerpt of MASP-C rev. 2019 Fiche 1.13 – Component 2 “EU CSW- CERTEX” 

Milestones 

Estimated completion date 

1 

Business Analysis and Business Modelling 

- Business Case Document 

- Business Case Annex 

- Level 3 (User Requirements BPM) 

- Level 4 (Functional Requirement detailed BPM) 

2 

Legal Provisions 

- Current provisions adopted* 

- Future provisions adopted** 

3 

Project Initiation Phase 

- Vision Document 

- Vision Document Annex 

- GO decision 

4 

IT Project 
- Application & Service Specifications 
- Technical System Specifications 
Construction Phase 
- Central services implementation 
- Service integration in National Systems 
- National implementation 
Transition Phase 
- Deploy and rollout 
- Conformance tests 

5  Operation 

Q1 2017 

Q2 2023 

Q1 2024 

Q1 2024 

In force 

2021 

Q3 2017 

Q3 2023 

Q3 2023 

Q2 2024 
Q2 2024 

Q3 2024 
From Q4 2024 onwards 
From Q4 2024 onwards 

Q4 2024 
From Q1 2025 onwards 

- Commission, Member States administrations and Traders 
(NB: This is the Operations date for the Commission, MS will 
conformance test from Q2 2020) 
- Non-EU Countries and non-EU traders (in case required) 
Implementation support (training and communication) 
- Centrally developed training and communication 
- National training and communication 

6 

Q2 2025 

N/A 

N/A 
N/A 

*Current provisions refer to Regulation (EU) 2019/880 
**Future provisions refer to the implementing provisions to be adopted according to Regulation (EU) 2019/880 

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ANNEX II: MAIN PROJECT PHASES AND CRITICAL MILESTONES TIMELINE 

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