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: 2020-12-14
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU customs procedure, activity report, customs cooperation, customs formalities, electronic government, information system, technological change

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.12.2020  COM(2020) 806 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(2020) 339 final}  
 
 
Table of Contents 

1. 
INTRODUCTION ......................................................................................................................... 2 
2.  BACKGROUND ............................................................................................................................ 2 
3.  PROJECT METHODOLOGY FOR THE UCC ELECTRONIC SYSTEMS ........................ 3 
4.  GLOBAL OVERVIEW OF PROGRESS WITH THE UCC ELECTRONIC SYSTEMS..... 4 
5  MANAGEMENT SUMMARY AND CONCLUSIONS ........................................................... 15 

1 

 
 
 
 
 
 
 
1.  INTRODUCTION 
The  first  Annual  Progress  Report1  from  the  Commission  on  the  implementation  of  the 
electronic systems of the Union Customs Code (UCC) and its accompanying Staff Working 
Document2 were published on 13 December 2019. This year’s annual report will elaborate on 
the continuing progress  in  developing the electronic systems  and describe the developments 
towards  a  fully  digital  customs  environment  since  the  UCC  entered  into  force.  For  this 
purpose,  it  draws  on  the  UCC  Work  Programme  (UCC  WP)3,  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  central  trans-European  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  exclusively  by  the 
Member States.  

This  report  analyses  the  tangible  progress  made  for  all  three  system  types,  outlining  the 
objectives to be met by each project, the project architecture and the planning approach. On 
that  basis,  it  highlights  potential  delays,  where  identified,  as  well  as  envisaged  mitigating 
measures.  The  overall  assessment  of  the  progress  of  the  implementation  of  the  UCC  WP  is 
summarised  in  the  conclusion  section  of  this  report  and  demonstrates  that  the  remaining 
projects are mostly on track for completion in line with the planning schedule.  More details 
of  the  planning  and  status  of  each  project  are  provided  in  a  Commission  Staff  Working 
Document4 published alongside this report.  

2.  BACKGROUND 
The  UCC  entered  into  force  on  1  May  2016  and,  following  its  amendment  in  2019,5  
establishes the deadlines of 2020, 2022 and 2025 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  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 transitional measures must 
cease once the relevant electronic systems are in place. 

1 Report from the Commission to the European Parliament and the Council pursuant to Article 278a of the Union Customs 
Code, on progress in developing the electronic systems provided for under the Code, COM(2019) 629 final. 
2 Commission Staff Working Document Accompanying the Report from the Commission to the European Parliament and the 
Council pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for 
under the Code, SWD(2019) 434 final.  
3 Commission Implementing Decision (EU) 2019/2151 of 13 December 2019 establishing the work programme relating to 
the development and deployment of the electronic systems provided for in the Union Customs Code (OJ L 325, 16.12.2019, 
p. 168–182). 
4 Commission Staff Working Document Accompanying the Report from the Commission to the European Parliament and the 
Council pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for 
under the Code, SWD(2020) XXX final. 
5 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). 

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To  support  this  complex  electronic  transition  process  towards  a  full  digital  customs 
environment, the UCC WP sets deadlines for each electronic system (and its possible phases) 
during the period 2020 to 2025.  

Article  278(a)  requires  the  Commission  to  provide  an  annual  report  on  the  deployment 
progress  of  the  outstanding  electronic  systems.  For  this  purpose,  the  Commission  collected 
information on progress  based on (1) national plans that Member States are required to 
provide twice a year (January and June) and (2) a survey circulated among its services 
and among the Member States to capture the progress.  

The  planning  and  progress  information  collected  from  the  Member  States  and  the 
Commission and incorporated into this report reflects the actual situation  at the end of June 
and  provides  an  estimation  of  progress  achieved  by  the  end  of  2020.  As  announced  in  the 
2019  report,  the  2020  report  also  contains  an  analysis  based  on  more  detailed  information 
reported by the Member States in the framework of the national coordination programmes 
in  place  since  2020  for  the  core  decentralized  trans-European  systems  in  the  area  of  transit 
and export.  

The data collected was also compared with the 2019 data in order to detect major shifts. The 
survey asked the project managers to indicate any known delays in the planning schedules for 
the  electronic  systems,  the  reasons  for  any  such  delays  and  the  measures  taken.  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.  PROJECT METHODOLOGY FOR THE UCC ELECTRONIC SYSTEMS 

The work of developing electronic systems involves several steps:  

  First, a business case is prepared, which provides the project justification and defines 
budgetary  requirements.  Typically,  the  business  case  includes  the  business  context, 
problem  description,  project  description/scope,  alternative  solutions,  costs  and  a 
timescale.  

  Next,  a  vision  document  is  created,  which  provides  more  detailed  information 
regarding the project definition in terms of architecture, cost, time, and risks, as well 
as information such as milestones, deliverables and project organization.  

  Subsequently, business process modelling takes place, whereby the business processes 
from the legislation are visually represented in process flows or process models to help 
develop the functional specifications for the systems. The benefit of visually depicting 
process models is to ensure a common understanding and analysis.  
In  this  context,  the  technical  specifications  are  developed,  to  detail  how  the  system 
will  be  constructed,  the  architecture  to  be  used,  the  messages  to  be  submitted  by 
economic  operators  and  customs  offices,  the  interfaces  to  other  systems,  test  plans, 
etc.  

 

In recent developments of UCC projects, the project methodology has been optimised and the 
business process modelling, data modelling and technical specifications have been developed 
more in parallel and through close collaboration from the start with experts from the legal, 
business and IT side, both on the side of the Commission and of the National Administrations, 
and  in  consultation  with  trade  representatives.  Moreover,  iterative  development  and 
deployment models have been gradually rolled out over several projects. 

The  Commission  and  the  Member  States  meet  regularly  to  define  and  agree  these  project 
documents  for  each  trans-European  system.  In  addition,  the  Commission  systematically 

3 

 
 
 
 
consults  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 being 
developed. Once ready, it is then of utmost importance to ensure a smooth  transition from the 
existing  systems  to  the  upgraded  ones.  This  is  vital  to  ensure  that  trade  and  customs 
operations are not impacted. 

4.  GLOBAL  OVERVIEW  OF  PROGRESS  WITH  THE  UCC  ELECTRONIC 

SYSTEMS 

The  UCC  WP  contains  seventeen  projects  leading  to  the  deployment  of  the  required 
electronic  systems  including  fourteen  trans-European  systems  for  which  the  Commission, 
together with the Member States, is responsible and three falling under the sole responsibility 
of the Member States. 

4.1 As of the end of 2020, the Commission can report the successful upgrade or deployment 
of eight systems out of the seventeen.  

Notably, the succesfull deployment of the UCC Information Sheets for Special Procedures 
(INF SP) system on 1 June 2020 is to be highlighted in this year’s report.  This new system 
harmonises  the  approach  for  the  efficient  management  of  inward  and  outward  processing 
procedures and improves the monitoring and control amongst customs offices.  

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

 

 

 

 

 

 

 

UCC Registered Exporter System – REX (new): Deployed in 2017.  

UCC Customs Decisions – CDS (new): Deployed in 2017. 

UCC Direct Trader Access to the European Information Systems – UUM&DS 
(Uniform User Management & Digital Signature) (new): Deployed in 2017. 

UCC  Economic  Operator  Registration  and  Identification  System  Upgrade  – 
EORI2 (upgrade): Deployed in 2018. 

UCC Surveillance 3 – SURV3 (upgrade): Deployed in 2018.  

UCC Binding Tariff Information – BTI (upgrade): aims to align the long-standing 
database that contains all binding tariff information issued by customs authorities of 
Member States with the UCC rules. Better control mechanisms will ensure that all 
customs  duties  and  related  VAT  that  are  legally  due  are  properly  collected  and 
fraud  can  be  more  effectively  detected.  Steps  1  and  2  of  the  first  phase  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 deployed in October 2019. This also entailed the 
construction of the access to this system through the EU Customs Trader Portal. 

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) was deployed in December 2019. 

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 

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. Having taken into account the experience of the pilot, 
some further adjustments were made and the full INF system was deployed in time 
on 1 June 2020. 

4.2 For the nine still ongoing projects, this report aims to highlight the 2020 achievements 
and prove the continuous collaboration between the Commission and the Member States.  

4.2.1  The six trans-European projects 
A series of IT project documents were prepared and agreed upon in 2020 as the basis for the 
systems’ development work – see below the progress per project.  

The  six  trans-European  projects  with  their  specific  architecture,  sometimes  requiring  a 
combination of central  and national  components and one or more project  phases, due by 31 
December 2025 pursuant to Article 278(3) UCC, are described and progressing as follows: 

 

UCC Guarantee Management – GUM (new): aims to assure real time allocation 
and management of the different types of guarantees across the EU. The improved 
processing speed, traceability and monitoring of guarantees electronically between 
customs  offices  is  expected  to  lead  to  a  faster  identification  of  cases  where 
guarantees are deemed invalid or insufficient to cover the incurred or potential debt.  

Progress:  In  view  of  the  legal  milestones  in  the  UCC  WP,  the  technical 
specifications are to be completed by 30 September 2022 for Component 1 related 
to the trans-European GUM and 30 November 2024 for Component 2 related to the 
National Guarantee Management system. The business case for the trans-European 
GUM  was  subject  to  several  rounds  of  discussions  around  the  scope  and 
implementation options. Finally, the Commission agreed with the Member States in 
2020 on the re-use of an existing system with the addition of specific requirements 
for  GUM.  As  regards  the  National  Guarantee  Management  system,  four  Member 
States  reported  the  deployment  of  the  national  system  and  three  other  Member 
States  are  progressing  on  the  technical  specifications.  However,  the  scope  re-
orientation of the trans-European GUM might require some further adjustments. 

 

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.  In 
particular,  the  project  will  facilitate  collaboration  amongst  Member  States  in  the 
process  of risk analysis.  The project  will be delivered in  three  releases to allow a 
feasible transition per mode of transport.  

Progress: The technical specifications for ICS2 -  Releases 1 and 2 were completed 
on 30 June 2018. ICS2 - Release 1 is planned for 15 March 2021 and will cover the 
obligation on the relevant economic operators (postal operators and express carriers 
in air transport) to provide the minimum data i.e. ENS pre-loading dataset. Work is 
on track in view of the timely deployment of the central ICS2 repository and Shared 
Trader  Interface.  however,  some  risks  of  delays  have  been  highlighted  by  a  few 
Member States because of the ambitious conformance testing period. 

 

UCC  Proof  of  Union  Status  –  PoUS  (new):  will  store,  manage  and  retrieve  all 
proofs 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 

5 

 
 
 
conveyed  their  intention  to  use  the  central  system  developed  by  the  European 
Commission.  In view of the dependency between the implementation  of the UCC 
customs goods manifest  as a proof of Union status and of the European Maritime 
Single Window, the project will be completed in two phases to avoid inconsistency 
and reduce risks.  

Progress:  As  in  last  year’s  report,  those  Member  States  that  prefer  to  deploy  a 
system  component  nationally  reported  having  difficulty  in  predicting  if  their 
implementation  will follow the timeline indicated in  the Work Programme due to 
the early stage of the project. The business processes and functional specifications 
for PoUS - Phase 1 were approved by the Member States in Q1 2020 and the vision 
document was completed in Q3 2020. 

UCC Centralised Clearance for Import – CCI (new): aims to allow goods to be 
placed under a  customs  procedure using centralised clearance, allowing  economic 
operators to centralise their business from a customs viewpoint. The processing of 
the  customs  declaration  and  the  physical  release  of  the  goods  will  be  coordinated 
between the related customs offices. The system will be based on the new national 
import  systems  and  enable  an  automated  functioning  of  the  centralised  clearance 
process at the European level.  

Progress:  The  technical  specifications  for  CCI  -  Phase  1  were  completed  and 
approved  in  2020  in  view  of  the  planned  deployment  date  of  1  March  2022  with 
forerunner  Member  States.  Two  Member  States  have  reported  the  completion  of 
their Phase 1 technical specifications while five others are in progress.  

The business case for CCI - Phase 2 was finalised in October 2019. The business 
processes and functional specifications for Phase 2 were completed in 2020 and the 
technical  specifications  are  expected  by  30  June  2022  in  view  of  the  planned 
deployment date of 2 October 2023. 

UCC  New  Computerised  Transit  System  –  NCTS  (upgrade):  The  New 
Computerised Transit System aligns the existing Union and common transit system 
to the new UCC legal provisions including the alignment of information exchanges 
to  UCC  data  requirements  and  the  upgrade  and  development  of  interfaces  with 
other systems.  

Progress:  No  delays  have  materialised  for  NCTS  -  Phase  5:  the  technical 
specifications were completed and approved as was the IT transition strategy. The 
project is currently on track and is due by 1  December 2023 pursuant to the UCC 
WP,  with  first  deployments  by  forerunner  Member  States  envisaged  as  of  March  
and December 2021. Four Member States have reported completing their technical 
specifications for Phase 5 while nine others are in progress. 

For  NCTS  -  Phase  6  (interconnection  with  other  systems),  a  feasibility  study  was 
carried  out  in  2020  which  will  provide  input  for  the  business  case  due  to  be 
completed in early 2021.  

UCC  Automated  Export  System  –  AES  (upgrade  of  both  the  existing  trans-
European system (project Component 1) and the existing National Export Systems 
(project  Component 2)): aims to  implement  the UCC requirements for export and 
exit of goods. The project related to the trans-European AES entails implementing 
the UCC simplifications offered to trade to facilitate export of goods for European 
companies,  such  as  centralised  clearance  for  export,  and  the  UCC  obligations  to 
better monitor goods that exit the EU customs territory, in order to prevent fraud.  

6 

 

 

 

 
 
 
Progress: The technical specifications for the trans-European AES were completed 
and approved as was the IT transition strategy. The project is currently on track and 
is  due  by  1  December  2023  pursuant  to  the  UCC  WP,  with  first  deployments  by 
forerunner  Member  States  envisaged  as  of  March  2021.  Regarding  Component  2, 
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 at the same time as the AES. Four 
Member  States  have  reported  completing  their  technical  specifications  for 
Component 1 while eight others are in progress. 

To  summarise,  for  the  six  remaining  trans-European  projects,  the  Commission  and  the 
Member States are on track to meet the legal deadlines agreed in the context of the UCC 
and  UCC  WP,  and  the  project  milestones  set  out  in  the  Multi-Annual  Strategic  Plan  for 
Customs (MASP-C) of 2019.  

In view of upcoming deployments in 2021 and 2022, it is important to point to some key 
progress achievements:  

First, decisive progress was achieved in the preparation for and testing of the first release of 
the Import Control System 2 (ICS2) and the project is on track to be implemented by March 
2021.  

Second,  the  technical  specifications  have  been  completed  for  the  core  decentralised  trans-
European systems on import, transit and export, being Centralised Clearance at Import (CCI) 
– Phase 1, the New Computerised Transit System (NCTS) Phase 5 and the Automated Export 
System  (AES)  and  the  development  work  on  the  side  of  the  Member  States  and  the 
Commission  is  on  track.  In  addition  the  business  case  has  been  approved  for  Guarantee 
Management (GUM). 

For  NCTS  –  Phase  5  and  AES,  the  UCC  WP  foresees  a  deployment  window  starting  as  of 
March 2021. Forerunner Member States are joining in March and December 2021, with more 
Member States gradually joining in till the end of 2023. 

All National Administrations confirmed their planning to start operations for AES and NCTS-
Phase 5 during the deployment window from Q1 2021 until Q4 2023, in full alignment with 
the UCC WP. This is illustrated in Figure 1 and Figure 2. The yellow bar indicates the time-
limit for the Member States to prepare the closure of the existing export and transit systems 
and start operating the new ones in order to be ready for the legal deadline indicated by the 
red bar.  

7 

 
 
 
 
 
Figure 1 - AES  National Administrations entry into operations 

Figure 2 – NCTS - Phase 5 National Administrations entry into operations 

The Commission also submitted to the Member States an updated package of documentation 
on the Terms of Collaboration and Service Level Agreements for the operation of the service 
desks and for the availability and continuity management of the systems. This is an important 
body of work which underpins the proper functioning and availability of the trans-European 
Systems. 

8 

 
 
 
 
 
 
 
Finally, it is  important  to  highlight  that in  view  of the implementation  of the UCC WP, the  
activities  performed  by  the  Commission  represent  approximately  79%  by  December 
2020 (in last year’s report it represented 66%) of the totality of its development work due by 
2025. This percentage is based on key performance indicators for the activities assigned to the 
Commission  only  and  does  not  reflect  the  activities  required  by  the  Member  States.  In  the 
overview below you can find the prospects in view of the progress and planning provided by 
the services of DG TAXUD. 

By end 2020 

By end 2021 

By end 2022 

By end 2023 

By end 2024 

By end 2025 

% completed 

79% 

85% 

90% 

95% 

97% 

100% 

Figure 3 – Approximation of % of the Commission’s development activities completed 

4.2.2  The three national projects 
Member States are due to complete the upgrade of their three national systems by 2022. 
However, this excludes the export component of the national Special Procedures system, for 
which the activity and planning is interlinked to the Automated Export System (AES). 

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,  Presentation  Notification  and  Temporary 
Storage  (NA,  PN  and  TS)  –  (upgrade):  define  the  automation  of  processes  at  the 
national  level  in  relation  to  Notifications  of  Arrival  of  means  of  transport, 
Presentation of goods and declarations for Temporary Storage, as described in the 
UCC. This project supports harmonisation across the Member States in regards to 
the data exchange between trade and customs.  

Progress:  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 collaborating to deliver the 
appropriate functional and technical documentation and test packages. NA, PN and 
TS have been completed by one, four and three Member States, respectively. In 
comparison to the planning provided last year, some Member States have chosen to 
integrate this project into ICS2. Because of this, some Member States have reported 
deployment dates which are later than the deadline in the UCC WP.  

 

UCC National Import Systems  – NIS (upgrade): aims to implement 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.  

Progress:  All  Member  States  have  reported  to  the  Commission  that  these 
specifications are in progress and will be completed by 1 July 2021. Nine Member 

9 

 
 
 
 
 
 
States  have  completed  their  technical  specifications  and  seven  others  are  in 
progress.  In  comparison  to  last  year’s  report,  some  re-planning  of  intermediate 
milestones  have  been  reported  but  all  the  Member  States  are  still  on  track  to 
achieve the 2022 deployment milestone. 

 

UCC Special Procedures – SP (upgrade): aims to harmonise and facilitate special 
procedures  (customs  warehousing,  end-use,  temporary  admission  and  inward  and 
outward processing). Member States will have to implement all the required UCC 
changes  for  these  special  procedures  in  their  national  systems.  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 deployment deadline), 
while  the  second  (import)  component  will  be  part  of  the  upgrade  of  the  UCC 
National Import Systems project (with a 2022 deployment deadline).  

Progress:  One  Member  State  has  completed  their  technical  specifications  for  SP 
Components  1  while  nine  have  completed 
for  Component  2. 
Interdependencies  exist  with  AES  and  the  National  Import  Systems  Upgrade.  So 
far, no delays have been reported by the Member States and all the Member States 
are on track with the first deadline being 2022.  

them 

To summarise: For the national systems, Member States are making strong efforts, sometimes 
through  intense  collaboration,  to  progress  the  implementation  of  the  requirements  for 
NA/PN/TS,  the  adjustments  to  the  National  Import  Systems,  and  the  interrelated  Special 
Procedures. As the deployment deadlines are approaching (31 December 2022 for all three), 
Member States should pay carefull attention to this matter, in particular the ten Member States 
that could not confirm a timely deployment for AN, the four Member States for PN, and the 
three Member States for TS as displayed in table 9, 10 and 11 of the Staff Working Document 
accompanying this report. 

4.3 Risks for delays 

The Commission presented the first UCC Annual Progress Report 2019 to the Council on 12 
February 2020. The main feedback received was as follows: 

  The report seemed overly optimistic; 
  The  report  was  missing  the  financial  sustainability  of  the  UCC  implementation  (in 

particular the viability of ICS2); 

  The stability of Annex B (common data requirements) of the UCC is paramount. 
In response to the feedback from the Council, the Commission is confident that the  current 
reporting presents a correct overview of the situation, as it is based, on the one hand, on its 
own  activities  leading  to  progress  for  the  trans-European  central  systems,  and,  on  the  other 
hand,  on  the  activities  of  the  Member  States,  as  communicated  to  the  Commission.  In  their 
reporting on the decentralised elements of the trans-European systems  and on their national 
systems,  Member  States  were  requested  to  provide  a  realistic  view  of  project  progress  and 
identified risks.  

Regarding  the  financial  situation  and  sustainability,  in  the  Council  Conclusions  on  the 
Multi-Annual  Financial  Framework,  the  budget  allocation  for  the  Customs  Programme  was 
approved  at  €950  m.  This  represents  a  significant  commitment  to  deliver  and  financially 
support the work of customs and in particular the development of electronic systems during 
the period up to 2027. With these developments, the Commission is no longer seeing a risk of 
lack  of  EU  budget  for  developing  the  system  components  for  which  it  is  responsible.  It  is 

10 

 
 
 
 
noted  that  at  the  time  of  writing  this  report  the  budget  negotiations  are  ongoing  with  the 
European Parliament so this figure may not be final. 
The instability of the Annex B of the UCC-DA6 and UCC-IA7 and the upcoming amendments 
were raised by the Council and the Member States’ customs administrations as an important 
risk in the context of last year’s report. The common data requirements of Annex B are used 
for the trans-European and national systems and 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. The Commission is pleased to report that thanks to the progress made in 
2020  the  risk  has  been  diminished.  The  work  on  the  harmonisation  of  the  common  data 
requirements  for  declarations,  notifications  and  proof  of  the  customs  status  of  Union  goods 
was finalised and reflected in the amendments to the UCC-DA and the UCC-IA which will be 
adopted  by  the  Commission  early  2020.  The  amendments  were  necessary  to  ensure  full 
alignment between the legal provisions and the functional and technical specifications for the 
trans-European systems and to ensure the necessary stability. 

Turning  to  the  survey  of  progress  in  2020,  the  Commission  is  progressing  well  on  the 
developments  under  its  responsibility  and  no  delays  beyond  the  legal  deadlines  have 
been  identified  or  materialised.  Moreover,  no  major  risks  have  been  reported  which 
would lead to late deployment.  

The  Member  States  are  also  advancing  significantly  with  the  developments  under  their 
responsibility.  However,  as  stated  in  section  4.2,  there  is  one  project  for  which  a  delay 
beyond the legal deadline (in this case 31/12/2022) has been reported, being the project 
NA,  PN  and  TS,  categorised  as  a  purely  national  project.  The  delays  reported  by  the 
Member  States  are  depicted  in  table  9,  10  and  11  of  the  Staff  Working  Dopcument 
accompanying this Report and can be summarised as follows: 

  For  the  implementation  of  the  Notification  of  Arrival,  the  following  Member  States 
have  a  planned  deployment  date  which  is  later  than  the  deadline  in  the  UCC  Work 
Programme: BE, BG, DE, EE, ES, FI, FR, NL and RO. No planned date was provided 
by DK for the deployment of the NA. 
More  specifically,  four  Member  States  have  reported  that  they  will  use  the  NA 
integrated  in  ICS2  –  Release  2  (planned  deployment  01/03/2023).  For  8  Member 
States, the delay is limited to two-three months.  

  For  the  implementation  of  the  Presentation  Notification  and  the  Temporary  Storage, 
the following Member States have indicated a planned deployment date for PN, which 
is later than the deadline in the Work Programme: BE, FR and NL. No planned date 
was provided by DK for the deployment of the PN. 
More  specifically,  for  two  Member  States  the  estimated  delay  is  limited  to  two 
months.  

As  regards  the  project  National  Import  Sytems,  the  risk  for  delays  mentioned  by  a  few 
Member  States  in  last  year’s  report  seem  to  be  under  control  and  no  longer  translate  into  a 
non-timely completion, potentially impacting the trans-European CCI project.   

6 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. 1-557). 
7 Commission Implementing Regulation (EU) 2015/2447 of 24 November 2015 laying down detailed rules for implementing 
certain provisions of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union 
Customs Code (OJ L 343, 29.12.2015, p. 1-558-893). 

11 

 
 
 
                                                      
As regards the national  project on Special Procedures, all Member States indicated to be on 
time, except for the Export component for which 1 Member State (DK) did not provide a date.  

On the side of the  Member States,  a number of overall risks have been  repeated since last 
year,  potentially  impacting  the  progress  of  their  activities.  A  key  source  of  difficulties  and 
risks  of  delays  indicated  by  the  Member  States  is  their  lack  of  resources  and  the  need  for 
further integration of the UCC projects. In comparision to last year’s report, only a few cases 
remain where tenders have not yet been awarded, for others the risk related to procurements 
has disappeared. As regards the lack of financial resources, the Commission’s adoption of the 
UCC  WP  and  of  the  Annual  Progress  Report  at  the  end  of  2019  helped  Member  States  to 
receive  additional  budget.  A  Member  State  explicitly  reported  on  the  succesfull  outcome. 
Concerning  the  human  resources,  the  Member  States  have  reiterated  the  lack  of  human 
resources  as  a  particular  risk  for  the  successful  and  timely  implementation  of  the  projects. 
Human  resources  are  often  working  on  other  IT  projects  in  parallel.  In  addition,  there  are 
many  contributing  factors  to  the  complexity  of  the  UCC  projects  (in  terms  of  project 
dependencies, transition and testing with the economic operators, system integrations).  

that 

In the 2019 Annual Progress Report, the Member States already pointed at the difficulties in 
meeting  the  obligations  on  customs  systems  imposed  by  the  VAT  eCommerce  package 
adopted  on  5  December  20178.  The  Member  States  mentioned 
the  parallel 
implementations  would  risk  leading  to  a  delay  in  the  completion  of  the  UCC  electronic 
systems by the relevant deadlines. The Commission has further monitored the situation this 
year. On 8 May 2020, the Commission proposed to postpone the introduction of the new rules 
by six months (1 January 2021 to 1 July 2021 or later). On 20 July 2020 the Council accepted 
this  proposal  and  adopted  the  necessary  legislation9.  With  this  postponement,  the  Member 
States  have more time to meet  the legal  deadlines for the national  developments, and fewer 
Member  States  reported  in  2020  the  risk  of  collateral  impact  of  the  VAT  eCommerce 
initiative  on  the  UCC  implementation.  Primarly  2  Member  States  reported  the  need  for 
replanning of some UCC activities and for upscaling platforms and  supporting  IT systems. 
However, they also stated considering mitigating measures to avoid a real delay in the start of 
deployment. It is to be noted that the risk by Member States was considered in combination 
with other external factors as COVID-19 and Brexit (see p 29, p 35, p 41 of the Staff Working 
Document accompanying this report).  

As  regards  the  challenges  brought  about  due  to  the  COVID-19  pandemic  and  the 
withdrawal of the United Kingdom from the EU, the Commission reported that for its own 
activities no impact is to be noted from COVID-19 and that mitigating actions were taken to 
counter  the  impact  from  the  Withdrawal  Agreement.  The  Member  States  reported  that  the 
effects were unclear at the moment but that additional pressure on their national planning and 
on  the  number  of  human  resources  available  internally  and  externally  (IT  contractors, 
economic operators) were to be expected.  

In  conclusion,  the  assessment  of  the  main  risks  for  the  timely  implementation  of  the 
UCC  systems  revealed  that  the  risks  are  situated  mostly  on  the  side  of  the  Member 
States and   linked to the complexity of the projects, procurement and contractual issues, 

8 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33) 
9 Council Decision (EU) 2020/1109 of 20 July 2020 amending Directives (EU) 2017/2455 and (EU) 2019/1995  as regards 
the  dates  of  transposition  and  application  in  response  to  the  COVID-19  pandemic  (OJ  L  244,  29.7.2020, p.  3–5),  Council 
Regulation  (EU)  2020/1108  of  20  July  2020  amending  Regulation  (EU)  2017/2454  as  regards  the  dates  of  application  in 
response to the COVID-19 pandemic (OJ L 244, 29.7.2020, p. 1–2) and Council Implementing Regulation (EU) 2020/112 of 
20  July  2020  amending  Implementing  Regulation  (EU)  2019/2026  as  regards  the  dates  of  application  in  response  to  the 
COVID-19 pandemic (OJ L 244, 29.7.2020, p. 9–10). 

12 

 
 
 
                                                      
resource constraints, the transformation process, and some external factors as COVID-
19  and  Brexit.  The  Commission  will  continue  to  support  the  Member  States  with 
applying  mitigating  actions  to  avoid  the  risks  materialise  into  late  deployments  of 
electronic systems as described in the section 4.4 below.  

4.4 Mitigation actions 

As regards the national projects, the planning and progress provided by the Member States 
shows on the one hand a better situation than last year for the national import systems with no 
longer an indication of delays, but on the other hand, for the national project on AN/PN/TS, 
the situation is slightly deteriorating. In view of the risks assessed, the Commission intends 
to scale up the support to the Member States by means of several actions. As a number of 
Member States link their national activities to those planned in the context of ICS2 Release 2, 
the Commission will study this misalignment of 2 months in the planning in more details. It 
will monitor the progress more regularly, take bilateral  contacts  to  understand the problems 
and  issue  formal  letters  to  the  Member  States  concerned  to  mitigate  the  risks  of  delays. 
Meanwhile,  the  Member  States  are  advised  to  continue  and  accelerate  further  their  intense 
collaboration work for the implementation of the project AN/PN/TS and to join forces in the 
expert  team.  The  Commission  continues  with  the  co-funding  from  the  Customs  Programme 
for the Expert Team on new approaches to develop and operate Customs IT systems (ETCIT). 
Ultimately, the timely implementation of the national components remains the responsibility 
of the Member States. 

As announced in last year’s report, the Commission has intensified its support to the Member 
States  for  the  development  of  the  trans-European  systems  by  establishing  innovative 
development  and  deployment  mechanisms,  by  refining  the  governance  approach  and  by 
providing    trans-European  coordination  and  monitoring  programmes.  This  is  described  in 
more details below.  

The  Commission  continues  to  utilise  an  agile  approach  concerning  the  development  and 
deployment  of  the  UCC  electronic  systems  in  order  to  deliver  and  review  project 
documentation  and  application  software  in  more  manageable  iterations  or  packages.  This 
allows for quicker fixes and a more balanced workload for the Commission and the Member 
States. This method has been pioneered in the AES, NCTS – Phase 5 and ICS2 projects and 
has been welcomed by the Member States and traders. Following the request to generalise the 
approach,  it  was  utilised  for  other  UCC  projects  such  as  PoUS  and  CCI.  Furthermore,  the 
Commission  has  established  a  mechanism  for  enhanced  collaboration  between  all 
stakeholders  from  the  outset  of  the  projects,  to  improve  the  quality  of  the  preparatory 
activities and to avoid difficulty in decision-taking and additional requirements at later stages 
in the projects.  

A  Multi-Annual  Strategic  Plan  for  Customs  (MASP-C)  dashboard  is  used  for  progress 
tracking and as an 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 indicated 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 close monitoring is needed in order to make the deployment of 

13 

 
 
 
 
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 regards implementation of the  ICS2 programme,  the Commission  continued with  ICS2 
“trans-European  coordination  activities”  throughout  the  years  2019  and  202010.  Work 
focused  on  ICS2  -  Release  1  implementation  with  a  view  to  facilitating  operational 
preparedness by Member States customs authorities, express carriers and EU postal operators 
as from 15 March 2021.  

The Commission provided support to the national administrations and economic operators in 
their development activities via a set of activities which included: 

  Creation  of  a  dedicated  forum  and  organisation  of  dedicated  webinars,  support  via 
frequently  asked  questions  and  organisation  of  regular  ICS2  trans-European 
coordination plenary meetings with participation of all Member States national ICS2 
project  management  and  risk  management  representatives,  individual  economic 
operators, trade associations and international organisations;  

  Close  and  continuous  monitoring,  planning  of  national  and  trade  project  plans  to 
ensure  their  alignment  with  the  Commission’s  central  planning  across  relevant  IT 
delivery  milestones  (conformance  testing  campaigns,  end-to-end  testing,  dry  run 
testing).  This  ranged  from  continuous  support  to  coordination  of  conformance  test 
activities  and  stimulating  national  administrations  and  economic  operators  to  co-
ordinate their individual projects; 

  Preparation  for  the  launch  of  communication  campaigns,  with  different  activities 
which  were  implemented  in  year  2020  and  throughout  the  ICS2  programme 
implementation,  including  creation  of  ICS2  programme  specific  content  on  DG 
TAXUD webpage; 

  Preparation  of  the  training  material  that  will  be  based  on  the  compendium  of  ICS2 

Release 1 common operational guidance. 

Furthermore,  the  Commission  launched  at  the  end  of  2019  a  “National  Administration 
quarterly monitoring programme” for the trans-European systems NCTS – Phase 5 and 
AES  with  Key  Performance  Indicators  to  regularly  assess  progress  and  raise  alerts  well  in 
advance where problems might occur.  

As  a  complementary  instrument,  the  Commission  also  established  for  these  projects  a 
“National Administration coordination programme” to support the Member States in the 
development  and  deployment  of  their  national  components  for  the  trans-European  systems. 
These  programmes  will  help  to  steer  the  IT  transition  process  as  of  2020  with  a  dedicated 
helpdesk, webinars, bilateral visits (where possible), training, conformance testing follow-up, 
quarterly progress reporting, service delivery management, etc.  

During the programme’s first six months of application, the following results can be reported: 

  All  national  administrations  have  complied  with  the  provisions  of  the  Coordination 
Programme for NCTS  - Phase 5 and AES, providing detailed National  Project  Plans 
using the proposed templates and reporting any deviations to their baseline plan; 

  The overall Coordination Programme was discussed with all national administrations 
in  four  virtual  and  physical  meetings  and  was  accepted  by  the  Electronic  Customs 
Coordination Group (ECCG); 

10 ICS2 trans-European coordination activity strand, as integral element of the ICS2 programme, was launched in 
year 2018. 

14 

 
 
 
 
                                                      
  Three bilateral missions took place and six bilateral webinars were held with national 

administrations; 

  The  Commission  reported,  to  the  ECCG  and  Customs  Policy  Group  (CPG),  the 
current report providing  the Key Performance  Indicators overview of the aggregated 
national plans. 

The output of both programmes is considered to bring valuable progress information and will 
continue  to  be  used  for  the  future  Annual  Progress  Reports.  It  will  provide  for  detailed 
progress information per project and per Member State.  

5  MANAGEMENT SUMMARY AND CONCLUSIONS 

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.  The 
assessment of the progress and risks reveal that these challenges are situated primarly on the 
side of the Member States. The Member States refer to uncertainty regarding the impact of 
the COVID-19 pandemic, to many other obligations to be implemented via customs systems, 
to resource issues in Member States, to the complexity and interconnectivity of systems, and 
to the need for a smooth transition from the existing systems to the upgraded ones so that the 
impact  on trade is  minimised. The Commission  engages to  support, coordinate and monitor 
the  progress  on  the  side  of  the  Member  States  more  carefully  and  profoundly  during  the 
coming years and to undertake some specific actions to ensure a timely implementation of the 
national as well as trans-European systems. 

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

The  INF  SP  project  was  successfully  deployed  this  year  and  significant  progress  has  been 
made  on  finalising  technical  and  functional  specifications  for  four  and  two  projects 
respectively, completing two business cases and preparing for major upcoming releases. 

As  mentioned  above,  the  remaining  projects  are  mostly  on  track  and  planned  to  be 
completed 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 Figure 4 below.  

15 

 
 
 
 
 
 
Figure 4: Planning for UCC WP projects 

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 will continue with the National Administration quarterly monitoring and 
coordination programmes. With these managerial instruments, the Commission is confident 
that it has the appropriate mechanisms in place to face the upcoming challenges.  

All  Member  States  have  expressed  their  willingness  to  define  and  undertake  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.  

16