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
Date: 2021-12-14
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU customs procedure, activity report, customs cooperation, customs formalities, electronic document management, electronic government, information system, innovation, technical specification

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.12.2021  SWD(2021) 382 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for under the Code {COM(2021) 791 final}  
 
 
Table of Contents 

1. 

INTRODUCTION ................................................................................................................................ 5 

2.  PROJECTS COMPLETED BEFORE 2021 .............................................................................................. 7 

2.1 

2.2 

UCC REGISTERED EXPORTER SYSTEM (REX) ............................................................. 7 

UCC CUSTOMS DECISIONS ............................................................................................... 8 

UCC DIRECT TRADER ACCESS TO THE EUROPEAN INFORMATION SYSTEMS 

2.3 
(UUM&DS) ......................................................................................................................................... 9 

UCC ECONOMIC OPERATOR REGISTRATION AND IDENTIFICATION SYSTEM 

2.4 
UPGRADE (EORI2) ......................................................................................................................... 10 

2.5 

2.6 

2.7 

2.8 

UCC SURVEILLANCE 3 (SURV3) .................................................................................... 11 

UCC BINDING TARIFF INFORMATION (BTI) ............................................................... 12 

UCC AUTHORISED ECONOMIC OPERATORS (AEO) UPGRADE .............................. 13 

UCC INFORMATION SHEETS (INF) FOR SPECIAL PROCEDURES ........................... 14 

3.  PROJECTS COMPLETED/PLANNED TO BE COMPLETED BY THE END OF 2021 .................................. 15 

3.1 

UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 1 ........................................... 15 

4.  ONGOING PROJECTS: DETAILED PLANNING AND PROGRESS INFORMATION ................................. 21 

UCC NOTIFICATION OF ARRIVAL (NA), PRESENTATION NOTIFICATION  (PN) 

4.1 
AND TEMPORARY STORAGE (TS) ............................................................................................. 21 

4.2 

4.3 

4.4 

4.5 

4.6 

4.7 

4.8 

4.9 

UCC NATIONAL IMPORT SYSTEMS UPGRADE .......................................................... 36 

UCC SPECIAL PROCEDURES ........................................................................................... 43 

UCC GUARANTEE MANAGEMENT (GUM) ................................................................... 54 

UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASES 2 AND 3 ............................ 60 

UCC PROOF OF UNION STATUS (POUS) ....................................................................... 69 

UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) .............................................. 78 

UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE ......................... 89 

UCC AUTOMATED EXPORT SYSTEM (AES) .............................................................. 103 

5.  ANNEX 1 – PLANNING OVERVIEW – UCC WORK PROGRAMME PROJECTS ................................ 118 

6.  ANNEX 2 – ACRONYMS, ABBREVIATIONS & KEY TERMS ........................................................... 119 

1 

 
 
 
 
 
 
 
Table of Figures 
Figure 1: Project Status as per Survey – ICS2 – Release 1 ................................................................... 18 
Figure 2: Summary of Responses per Milestone – ICS2 – Release 1 ................................................... 19 
Figure 3: Percentage of Completion per Phase – ICS2 – Release 1 ...................................................... 20 
Figure 4: Project Status as per Survey – NA ......................................................................................... 24 
Figure 5: Project Status as per Survey – PN .......................................................................................... 26 
Figure 6: Project Status as per Survey – TS .......................................................................................... 29 
Figure 7: Summary of Responses per Milestone – NA ......................................................................... 31 
Figure 8: Summary of Responses per Milestone – PN .......................................................................... 32 
Figure 9: Summary of Responses per Milestone – TS .......................................................................... 32 
Figure 10: Percentage of Completion per Phase – NA .......................................................................... 33 
Figure 11: Percentage of Completion per Phase – PN .......................................................................... 34 
Figure 12: Percentage of Completion per Phase – TS ........................................................................... 35 
Figure 13: Summary of Survey Responses – National Import Systems Upgrade ................................. 40 
Figure 14: Summary of Responses per Milestone – National Import Systems Upgrade ...................... 41 
Figure 15: Percentage of Completion per Phase – National Import Systems Upgrade ......................... 42 
Figure 16: Project Status as per Survey – NSP EXP ............................................................................. 46 
Figure 17: Project Status as per Survey – NSP IMP ............................................................................. 48 
Figure 18: Summary of Responses per Milestone – NSP EXP ............................................................. 50 
Figure 19: Summary of Responses per Milestone – NSP IMP ............................................................. 51 
Figure 20: Percentage of Completion per Phase – NSP EXP ................................................................ 52 
Figure 21: Percentage of Completion per Phase – NSP IMP ................................................................ 53 
Figure 22: Summary of Survey Responses – GUM – Component 2 ..................................................... 56 
Figure 23: Summary of Responses per Milestone – GUM – Component 2 .......................................... 58 
Figure 24: Percentage of Completion per Phase – GUM – Component 2 ............................................ 59 
Figure 25: Summary of Survey Responses – ICS2 – Release 2 ............................................................ 62 
Figure 26: Summary of Survey Responses – ICS2 – Release 3 ............................................................ 64 
Figure 27: Summary of Responses per Milestone – ICS2 – Release 2 ................................................. 65 
Figure 28: Summary of Responses per Milestone – ICS2 – Release 3 ................................................. 66 
Figure 29: Percentage of Completion per Phase – ICS2 – Release 2 .................................................... 67 
Figure 30: Percentage of Completion per Phase – ICS2 – Release 3 .................................................... 68 
Figure 31: Project Status as per Survey – PoUS – Phase 1 ................................................................... 71 
Figure 32: Project Status as per Survey – PoUS – Phase 2 ................................................................... 72 
Figure 33: Summary of Responses per Milestone – PoUS – Phase 1 ................................................... 74 
Figure 34: Summary of Responses per Milestone – PoUS – Phase 2 ................................................... 75 
Figure 35: Percentage of Completion per Phase – PoUS – Phase 1 ...................................................... 76 
Figure 36: Percentage of Completion per Phase – PoUS – Phase 2 ...................................................... 77 
Figure 37: Summary of Survey Responses – CCI – Phase 1 ................................................................. 81 
Figure 38: Summary of Survey Responses – CCI – Phase 2 ................................................................. 83 
Figure 39: Summary of Responses per Milestone – CCI – Phase 1 ...................................................... 85 
Figure 40: Summary of Responses per Milestone – CCI – Phase 2 ...................................................... 86 
Figure 41: Percentage of Completion per Phase – CCI – Phase 1 ........................................................ 87 
Figure 42: Percentage of Completion per Phase – CCI – Phase 2 ........................................................ 88 
Figure 43: NCTS – P5 National Administrations entry into operations as of 1 July 2021 ................... 91 
Figure 44: Project Status as per Survey – NCTS – P5 .......................................................................... 97 
Figure 45: Key milestones: Planned value versus earned value – NCTS – P5 ................................... 100 
Figure 46: Summary of Responses per Milestone – NCTS – P5 ........................................................ 100 
Figure 47: Percentage of Completion per Phase – NCTS – P5 as of 1 July 2021 ............................... 101 
Figure 48: NCTS – P5 Transitional Period ......................................................................................... 102 
Figure 49: AES – Component 1 National Administrations entry into operations as of 1 July 2021 ... 104 
Figure 50: Summary of Survey Responses – AES – Component 1 .................................................... 108 
Figure 51: Project Status as per Survey – AES – Component 2 .......................................................... 111 
Figure 52: Key milestones: Planned value versus earned value – AES – Component 1 ..................... 112 
Figure 53: Summary of Responses per Milestone – AES – Component 1 .......................................... 113 

2 

 
 
Figure 54: Summary of Responses per Milestone – AES – Component 2 .......................................... 114 
Figure 55: Percentage of Completion per Phase – AES – Component 1 as of 1 July 2021 ................ 115 
Figure 56: AES – Component 1 Transitional Period ........................................................................... 116 
Figure 57: Percentage of Completion per Phase – AES – Component 2 ............................................ 117 
Figure 58: Planning Overview: UCC Work Programme Projects – Status Q4 2021 .......................... 118 

3 

 
 
Table of Tables 
Table 1: Comparison of Planned and Actual Dates – REX1 ................................................................... 7 
Table 2: Comparison of Planned and Actual Dates – UCC Customs Decisions ..................................... 8 
Table 3: Comparison of Planned and Actual Dates – UUM&DS ........................................................... 9 
Table 4: Comparison of Planned and Actual Dates – EORI2 ............................................................... 10 
Table 5: Comparison of Planned and Actual Dates – SURV3 .............................................................. 11 
Table 6: Comparison of Planned and Actual Dates – BTI .................................................................... 12 
Table 7: Comparison of Planned and Actual Dates – AEO Upgrade .................................................... 13 
Table 8: Comparison of Planned and Actual Dates – INF .................................................................... 14 
Table 9: Detailed responses from Member States – ICS2 – Release 1 ................................................. 18 
Table 10: Comparison of Planned and Actual Dates – ICS2 – Release 1 ............................................. 19 
Table 11: Detailed responses from Member States – NA ..................................................................... 24 
Table 12: Detailed responses from Member States – PN ...................................................................... 26 
Table 13: Detailed responses from Member States – TS ...................................................................... 28 
Table 14: Comparison of Planned and Actual Dates – NA ................................................................... 29 
Table 15: Comparison of Planned and Actual Dates – PN .................................................................... 30 
Table 16: Comparison of Planned and Actual Dates – TS .................................................................... 31 
Table 17: Detailed responses from Member States – National Import Systems Upgrade .................... 40 
Table 18: Comparison of Planned and Actual Dates – National Import Systems Upgrade .................. 41 
Table 19: Detailed responses from Member States – NSP EXP ........................................................... 46 
Table 20: Detailed responses from Member States – NSP IMP ............................................................ 48 
Table 21: Comparison of Planned and Actual Dates – NSP EXP ......................................................... 49 
Table 22: Comparison of Planned and Actual Dates – NSP IMP ......................................................... 50 
Table 23: Detailed responses from Member States – GUM – Component 2 ........................................ 56 
Table 24: Comparison of Planned and Actual Dates – GUM – Component 1 ...................................... 57 
Table 25: Comparison of Planned and Actual Dates – GUM – Component 2 ...................................... 57 
Table 26: Detailed responses from Member States – ICS2 – Release 2 ............................................... 62 
Table 27: Detailed responses from Member States – ICS2 – Release 3 ............................................... 63 
Table 28: Comparison of Planned and Actual Dates – ICS2 – Release 2 ............................................. 64 
Table 29: Comparison of Planned and Actual Dates – ICS2 – Release 3 ............................................. 65 
Table 30: Detailed responses from Member States – PoUS – Phase 1 ................................................. 71 
Table 31: Detailed responses from Member States – PoUS – Phase 2 ................................................. 72 
Table 32: Comparison of Planned and Actual Dates – PoUS – Phase 1 ............................................... 73 
Table 33: Comparison of Planned and Actual Dates – PoUS – Phase 2 ............................................... 74 
Table 34: Detailed responses from Member States – CCI – Phase 1 .................................................... 81 
Table 35: Detailed responses from Member States – CCI – Phase 2 .................................................... 83 
Table 36: Comparison of Planned and Actual Dates – CCI – Phase 1 .................................................. 84 
Table 37: Comparison of Planned and Actual Dates – CCI – Phase 2 .................................................. 85 
Table 38: Detailed responses from Member States – NCTS – P5 ......................................................... 95 
Table 39: Risk Assessment: NCTS – P5 ............................................................................................... 96 
Table 40: Project Status – NCTS – P5 as of 1 July 2021 ...................................................................... 98 
Table 41: Comparison of Planned and Actual Dates – NCTS – P5 ...................................................... 99 
Table 42: Detailed responses from Member States – AES – Component 1 ........................................ 106 
Table 43: Risk Assessment: AES – Component 1 .............................................................................. 107 
Table 44: Project Status – AES – Component 1 as of 1 July 2021 ...................................................... 109 
Table 45: Detailed responses from Member States – AES – Component 2 ........................................ 110 
Table 46: Comparison of Planned and Actual Dates – AES – Component 1 ...................................... 111 
Table 47: Comparison of Planned and Actual Dates – AES – Component 2 ...................................... 113 
Table 48: Abbreviations and Acronyms .............................................................................................. 120 

4 

 
 
1.  INTRODUCTION 

The Union Customs Code (UCC) requires the European Commission and the Member States to upgrade 
some existing electronic systems and introduce a number of new systems for the completion of a modern 
and digital environment of customs formalities. In total, the UCC requires the upgrading or creation of 
fourteen trans-European systems and three national systems.  

The UCC entered into force on 1 May 2016. The deadline for completion of the systems is set for the 
end of 2020, 2022 or 2025, depending on the system.   

In  view of the reporting requirement established by Article 278(a) of the Regulation (EU) 2019/632 
amending Regulation (EU) 2013/952, the Commission1 is committed to provide an annual report to the 
European Parliament and the Council on the progress in developing the electronic systems of the UCC. 
The report assesses the progress of the Commission and the Member States in developing each of the 
electronic systems, taking particular note of the following milestones: 

(a)  The date of publication of the technical specifications for the external communication2 of the 

electronic systems; 

(b)  The period of conformance testing with economic operators; 
(c)  The expected and actual dates of deployment of the electronic systems.   

The legal deadlines for finalising the technical specifications and for deploying the electronic systems 
are laid down in the UCC Work Programme (UCC WP)3. The detailed planning per project, containing 
additional  milestones  such  as  for  the  business  case,  business  process  modelling,  vision  document, 
conformance testing are defined in the Multi-Annual Strategic Plan for Customs (MASP-C).  

The first  and second UCC Annual Progress Reports4 were published on 13/12/2019 and 14/12/2020 
respectively.  The  details  of  the  completed  projects  are  limited  in  this  report,  however  additional 
information can be found in the previous year’s reports. 

In preparation for this year’s UCC Annual Progress Report 2021, the Commission continued with the 
approach taken the previous years and made use of the bi-annual national planning information provided 
by  the  Member  States’  customs  authorities  and  the  projects’  state  of  play  provided  by  the  project 
managers in DG TAXUD.  

This annual report covers a reflection of the progress status achieved on 30 June 2021 including a 
view on the expected progress by December 2021 in order to have a full picture of the progress 
made in 2021. 

The progress information was provided against the baseline milestones indicated in the UCC WP and 
MASP-C 2019 (unless otherwise specified). In addition, the Commission oversaw the collection of the 
additional  progress  reporting  information  by  means  of  an  EU  survey  launched  in  April  2021.  The 
information gathered from the survey to which both the Member States and key stakeholders/project 
managers in the Commission responded, consists of progress information, qualitative comments and 
quantitative measurements of the assessment of complexity and risk in relation to the seventeen projects 
listed  in  the  UCC  WP.  Finally,  specific  information  was  gathered  from  the  more  detailed  project 

1 In the context of this report, ‘The Commission’ refers to the European Commission. 
2 External communication with the economic operators. 
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, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019D2151. 
4 Report from the Commission to the European Parliament and the Council:  
2019: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0629 
2020: https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:52020DC0806  
Commission Staff Working Document:  
2019: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1589134753023&uri=CELEX:52019SC0434 
2020: https://eur-lex.europa.eu/legal-content/NL/ALL/?uri=CELEX:52020SC0339 

5 

 
 
                                                      
reporting  and  monitoring  programmes  in place  since 2020 for  the core  decentralised trans-European 
systems in the area of transit and export. 

As background information, it is important to remind that the seventeen electronic systems listed in the 
UCC Work Programme were divided into three 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 
their corresponding 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. 

The progress information has been collected, analysed and reported in this accompanying Commission 
Staff Working Document, which presents the detailed overview of the progress of the various individual 
projects as follows: 

  For the trans-European systems, the analysis and reporting refers to the Commission’s activities 
only when central, while for the systems that involve national input, and even in some cases 
national  components,  the  analysis  refers  to  both  the  Commission’s  and  Member  States’ 
activities. For the national systems, only Member States’ activities are reported; 

  For projects that have already been initiated or entirely completed, an overview of the project 
progress, a summary of the survey responses, as well as a visual illustration of progress against 
planned milestones is provided; 

  For  projects  that  have  not  yet  been  initiated,  an  overview  of  the  planned  project  progress 

together with a summary of the responses from the survey is provided. 

By means of the survey, the Member States were also requested to give an indication of:  

  The degree of complexity of each project on a scale from 1 to 6, where: 1 and 2 refer to low 

complexity, 3 and 4 - medium complexity and 5 and 6 - high complexity.  

  The risk of not deploying the IT systems by the dates set in the baselines of the UCC WP and 

MASP-C 2019 according to three levels: low, medium and high.  

The consolidation of the survey results, including the abovementioned indicators of complexity and risk, 
as well as information regarding risks for delays and mitigating measures and any changes in planning 
in  comparison  with the  planning  provided in  2020, are  the  main  outcomes  of the  progress  reporting 
exercise  for  2021  and  are  included  in  this  Commission  Staff  Working  Document.  Reporting 
information that summarises the current project status, key risks and mitigating actions is found in the 
Report from the Commission to the European Parliament and the Council pursuant to Article 278a 
of the Union Customs Code, on progress in developing the electronic systems provided for under the 
Code.  

The report is structured as follows: 

  Section 1: Introduction; 
  Section 2: Projects completed before 2021; 
  Section 3: Projects completed or planned to be completed during 2021; 
  Section 4: Projects ongoing during 2021.  

6 

 
 
 
2. 

PROJECTS COMPLETED BEFORE 2021 

UCC REGISTERED EXPORTER SYSTEM (REX) 

2.1 
The UCC Registered Exporter System (REX) is a trans-European system that contains information both 
on  Registered  Exporters  established  in  GSP  countries5  and  on  EU  economic  operators  in  partner 
countries Switzerland, Norway and Turkey exporting to GSP countries and certain other countries. The 
main purpose of the system is to replace the paper-based certification process by an IT-supported self-
certification process. The system includes a central database that contains the registered exporters and 
provides the Member States with the opportunity to enhance their national systems with an automated 
verification of REX members. 

There were three releases planned. REX1 is the only release covered in the scope of the UCC Work 
Programme.  No  risks  were  identified  during  the  implementation  of  REX16  and  the  project  was 
successfully completed on 1 January 2017.  

Some statistical information on the use of the REX system since operations – situation on 13/06/2021:  

  The REX Trader Portal, as part of the EU Customs Trader Portal (EUCTP) was launched on 

25 January 2021; 

  63,374 active REX registrations in Member States and Partner Countries; 
  60,032 active REX registrations in the Beneficiary Countries (REX BC) module; 
  1,548 applications for a REX registration submitted by the EU Economic Operators through 

the REX Trader Portal; 

  700 T-REX system local users; 
  388 T-REX local administrators. 

2.1.1 Overview of Project Progress 

Table 1 compares the actual dates to those set in the UCC Work Programme (WP). Despite there being 
a slight delay in the finalisation of the Technical Specifications, REX was deployed on time. 

Table 1: Comparison of Planned and Actual Dates – REX1 

5 Countries benefiting from the EU Generalised Scheme of Preferences (GSP) that provides preferential access to 
the EU market. 
6 For the scope of EU GSP, in parallel with the GSP scheme for of Switzerland, and Norway as partner countries. 

7 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/03/201530/06/2015100%31/12/2016100%01/01/201701/01/2017100%Technical SpecificationsConformance TestingDeployment 
 
 
 
 
 
 
                                                      
UCC CUSTOMS DECISIONS 

2.2 
The  UCC  Customs  Decisions  System  (CDS)  is  designed  to  achieve  harmonisation  of  the  processes 
relating to the application for a customs decision, the decision taking and the decision management. This 
harmonisation is put into practice via the standardisation and electronic management of the application 
and decision/authorisation data across the Union. The system covers all applications and decisions that 
may have an impact/are valid in more than one Member State. Member States also have the right to use 
the Customs Decisions System to manage their national customs decisions, if they wish to do so.  

The project was fully deployed on 02/10/2017.  

Some statistical information on the use of the CDS: 

  Since the start of deployment on 02/10/2017, the number of applications increased from 1,300 
in the last three months of 2017 to 14,655 per year in 2018. With an average of 26 applications 
in 2019, the number of requests dropped significantly in the 2nd quarter of 2020, most likely due 
to the pandemic situation. The situation stabilised after the summer break to an increase of 28 
applications per day. 

  On 29 June 2020, a second major release of the CDS system was deployed, to fully align the 

system with the current legislation. 

  From the start of operations until mid-2021, around 39,600 applications were submitted and 
23,300  decisions  were  taken.  More  than  32,500  decisions  were  entered  as  pre-existing 
authorisations. 

2.1.2 Overview of Project Progress 

Table 2 highlights that there were no divergences in the planning compared to the dates set in the Work 
Programme.   

Table 2: Comparison of Planned and Actual Dates – UCC Customs Decisions 

8 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/12/201531/12/2015100%30/09/2017100%02/10/201702/10/2017100%Technical SpecificationsConformance TestingDeployment 
 
  
 
 
UCC  DIRECT  TRADER  ACCESS  TO  THE  EUROPEAN  INFORMATION 

2.3 
SYSTEMS (UUM&DS) 
The  Direct  Trader  Access  to  the  European  Information  Systems  system  comprises  Uniform  User 
Management and Digital Signature (UUM&DS) components. The system aims to provide a service for 
user-to-system interfaces targeted to the electronic customs systems provided for in the UCC. In essence, 
the UUM&DS system facilitates a direct and EU harmonised trader access to the customs systems as 
stipulated in the UCC.  

The first deployment of the project was completed and implemented together with the UCC Customs 
Decisions system on 2/10/2017 as agreed in the context of the UCC Work Programme.  

The  system  has  also  been  incorporated  into  other  electronic  projects  such  as  UCC  Binding  Tariff 
Information (BTI), the UCC Authorised Economic Operators (AEO) and the Information Sheets (INF) 
system for special procedures. The project will further evolve to include system-to-system interfaces 
and digital signature. Their use will be particularly relevant to the Import Control System (ICS2) and 
the Proof of Union Status (PoUS) system. 

All Member States have completed the connectivity configuration.  

2.1.3 Overview of Project Progress 

Table 3 highlights that there are no divergences in the planning compared to the dates set in the Work 
Programme.   

Table 3: Comparison of Planned and Actual Dates – UUM&DS  

9 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/12/201530/09/2015100%30/09/2017100%02/10/201702/10/2017100%Technical SpecificationsConformance TestingDeployment 
 
 
 
UCC  ECONOMIC  OPERATOR  REGISTRATION  AND  IDENTIFICATION 

2.4 
SYSTEM UPGRADE (EORI2) 
This  system  upgrade  provided  minor  changes  to  the  existing  trans-European  Economic  Operator 
Registration  and  Identification  system.  These  changes  enabled  the  registration  and  identification  of 
economic operators of the Union, as well as third-country operators and persons apart from economic 
operators. EORI2 has been in operation since 05/03/2018. 

Some statistical information on the use of the EORI2 system – situation 31/05/2021: 

  The total number of economic operators registered with a valid EORI is 7,328,000. 
  471,000 EORI numbers have been created during the period of 01/01/2021 to 31/05/2021. 

2.1.4 Overview of Project Progress 

Table 4 compares the actual dates to those set in the UCC Work Programme. Despite there being a slight 
delay in the finalisation of the Technical Specifications, EORI2 was deployed on time. 

Table 4: Comparison of Planned and Actual Dates – EORI2 

10 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 30/06/201631/07/2016100%28/02/2018100%05/03/201805/03/2018100%DeploymentTechnical SpecificationsConformance Testing 
 
 
 
 
UCC SURVEILLANCE 3 (SURV3) 

2.5 
The  SURV3  system  introduces  an  upgrade  to  the  standard  exchange  of  information  in  the  earlier 
Surveillance 2 (SURV2) system to align the system with UCC requirements. This database records and 
centralises all EU trade data (imports and exports) that national customs authorities provide on a daily 
basis.  The  upgrade  implements  electronic  data-processing  techniques  and  establishes  adequate 
functionalities needed for processing and analysing the full surveillance dataset obtained from Member 
States. The new system will improve the customs risk analysis, the fight against fraud, market analysis, 
post-clearance controls and statistical analysis. 

The system was successfully deployed on 01/10/2018. The data will be gathered via SURV-RECAPP 
in different formats until the moment that all the national systems are fully aligned to the UCC. Seven 
MS are sending full UCC data by the end of 2021 and they are: BG, CZ, EE, FI, IE, LV and MT. 

2.1.5 Overview of Project Progress 

Table 5 highlights that there were no divergences in the planning compared to the dates set in the Work 
Programme.   

Table 5: Comparison of Planned and Actual Dates – SURV3 

11 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 30/09/201630/09/2016100%30/09/2018100%01/10/201801/10/2018100%Technical SpecificationsConformance TestingDeployment 
 
 
 
UCC BINDING TARIFF INFORMATION (BTI) 

2.6 
The project for a UCC Binding Tariff Information system aims to upgrade the existing trans-European 
(EBTI-3) database containing all binding tariff information that has been issued by customs authorities 
of  Member  States.  The  customs  authorities  concerned  must  then  record  their  decisions  in  the  BTI 
database. Economic operators apply for binding tariff decisions in order to have legal certainty that they 
are applying the correct classification to goods they are importing to or exporting from the EU.  

Concerning the status of the project, the first phase was completed by October 2017. The second phase 
entered into operation on 01/10/2019. The construction of the access for this system to the EU Customs 
Trader Portal was also completed on 01/10/2019. 

Some statistical information on the use of the EBTI system since the go-live of the Trader Portal on 
01/10/2019: 

  The Trader Portal (central EU or national) is used by all traders in all Member States; 
  All BTI applications and decisions are sent electronically; 
  Eight  BTI  core  processes  consisting  of  more  than  20  sub-processes  have  been  digitalised 
(related to the BTI application, the issuing and invalidation of the BTI decision and the Right 
To Be Heard procedure); 

  More than 73,000 BTI applications (11,000 via the EU TP and 62,000 via the national TP) have 
been submitted by the traders and more than 73,000 BTI decisions were issued to the traders; 
  Other BTI related communications such as notifications and BTI decision invalidations between 
traders and Decision Taking Customs Authorities (DTCA) were sent electronically via the EU 
TP. 

2.1.6 Overview of Project Progress 

Table 6 compares the actual dates to those set in the Work Programme. Despite there being a slight delay 
of the Technical Specifications for Step 2, all phases were deployed on time. 

Table 6: Comparison of Planned and Actual Dates – BTI 

12 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 30/06/201610/06/2016100%21/02/2017100%01/03/201701/03/2017100%30/06/201602/09/2016100%25/02/2017100%02/10/201702/10/2017100%30/06/201830/06/2018100%01/07/2019100%01/10/201901/10/2019100%Technical SpecificationsConformance TestingDeployment 
 
 
 
 
UCC AUTHORISED ECONOMIC OPERATORS (AEO) UPGRADE 

2.7 
Following the legal changes adopted in the UCC, the Authorised Economic Operators (AEO) upgrade 
aims to improve the system of applications and authorisations for AEO status. The project consists of 
two  phases.  Phase  1  implemented  major  enhancements  to  the  existing  AEO  system,  in  light  of  the 
harmonisation of the decision-taking procedure for customs. Phase 2 implemented the electronic form 
with a view to provide a harmonised interface for economic operators to submit their AEO applications 
and to receive their AEO decisions electronically. The upgraded system was deployed in two releases: 
Part 1 for the submission of the AEO applications and the decision-taking process (Phase 2 Part 1) and 
Part 2 for the other processes (Phase 2 Part 2). 

Some statistical information on the use of the AEO system – situation on 21/06/2021: 

Since the EU eAEO Trader Portal has been deployed in October 2019: 

  970 AEO applications have been submitted via the EU eAEO Trader Portal; 
  2,500 Economic operators have accessed (125 the first quarter of 2021) the EU eAEO Trader 

Portal; 

  2,400+ documents have been exchanged via the EU eAEO trader Portal; 
  24 Member States are leveraging the EU eAEO Trader Portal and the remaining Member States 

are utilising their own National Trader Portal. 

On 31/03/2021, 18,000 valid AEO authorisations are granted to Economic Operators in the EOS 
central system. 

2.1.7 Overview of Project Progress 

Table 7 highlights that there are no divergences in the planning compared to the dates set in the Work 
Programme.    

Table 7: Comparison of Planned and Actual Dates – AEO Upgrade 

13 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/03/201631/03/2016100%28/02/2018100%05/03/201805/03/2018100%31/12/201831/12/2018100%29/07/2019100%01/10/201901/10/2019100%31/12/201831/12/2018100%06/11/2019100%16/12/201916/12/2019100%DeploymentTechnical SpecificationsConformance Testing 
 
 
 
UCC INFORMATION SHEETS (INF) FOR SPECIAL PROCEDURES 
2.8 
The aim of the UCC Information Sheets (INF) for Special Procedures project is to develop a new trans-
European system to support and streamline the data management processes and the electronic handling 
of  data  in  the  domain  of  Special  Procedures.  This  new  system  will  harmonise  the  approach  for  the 
efficient management of inward and outward processing procedures and improve the monitoring and 
control amongst customs offices.  

The INF central system was successfully deployed on 01/06/2020.  

The  INF  Specific  Trader  Portal  (INF  STP)  component  was  also  successfully  integrated  into  the  EU 
customs trader portal (EU CTP) and deployed on 01/06/2020. The EU CTP is the single portal at Union 
level to provide traders unique access to a number of centralised trans-European systems (EBTI, AEO, 
INF). 

Close  contacts  between  the  Commission  and  the  Member  States  are  kept  to  provide  the  necessary 
support,  assistance  and  supervision.  A  project  group  with  Member  States  and  trade  associations  is 
holding regular meetings to address any remaining business issues. 

Some statistical information on the use of the INF system: 

  As from October 2020, all Member States are using the INF system. 
  From the start of operations on 1/06/2020 until 21/06/2021, around 16,600 requests were 
created by economic operators, and approximately 15,000 INFs were treated and processed.  
  The average number of requests and authorisations has increased over the past six months 

by 15%. 

  80%  of the  INFs  are  related  to  the  standard  outward processing  procedures.  Poland  and 

Romania take the lead in handling the most INFs.  

2.1.8 Overview of Project Progress 

Table 8 highlights that there were no divergences in the planning compared to the dates set in the Work 
Programme.   

Table 8: Comparison of Planned and Actual Dates – INF 

14 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 30/06/201830/06/2018100%29/05/2020100%01/06/202001/06/2020100%DeploymentTechnical SpecificationsConformance Testing 
 
 
 
3. 

PROJECTS COMPLETED/PLANNED TO BE COMPLETED BY THE END OF 
2021 

UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 1 

3.1 
The goal of the UCC Import Control System 2 (ICS2) programme is to strengthen the safety and security 
of  the  supply  chain  for  goods  moved  via  all  modes  of  transport. The aim  is to  do  so through  better 
targeted risk based controls of EU customs authorities on improved Entry Summary Declaration (ENS) 
data  quality,  data  filing,  data  availability  and  data  sharing  and  through  real-time  collaborative  risk 
analysis and co-ordinated safety and security controls at the EU entry points. The main purpose of the 
system is to implement the new requirements resulting from the UCC and strategic objectives endorsed 
by the Member States in the Risk management strategy and action plan of 2014.  

This  multi-annual  programme  will  lead  to  a  complete  new  architecture  of  the  existing  ICS  trans-
European system. In terms of planning, the programme will be implemented in three releases. Release 
1 covers the obligation on the relevant economic operators (postal operators and express carriers in air 
transport)  to  provide  the  minimum  data  i.e.  ENS  pre-loading  dataset.  Release  2  will  cover  the 
implementation of new ENS obligations and related business and risk management processes for all the 
goods  in  air  traffic.  Release  2  is  planned  to  also  cover  Safety  and  Security  analytics  capabilities, 
following  a  positive  endorsement  (‘Go  decision’)  by  the  Commission  and  the  Member  States  in 
December 2020. Release 3 will cover the same implementation as Release 2 but for all goods in maritime 
and inland waterways, road and rail traffic (this also includes goods in postal consignments transported 
in these means of transport). Please see section 4.5 for the detailed status of Releases 2 and 3. 

3.1.1 Summary of Reponses 

Summary from the Commission: 

The Commission centrally developed the common components (Shared Trader Interface and Common 
Repository) and the common functional system and technical specifications. The baseline functional 
and technical specifications for all three releases were completed on 30 June 2018.  

Regarding  the  implementation  of the  ICS2  programme,  the  Commission  continued  with  ICS2  trans-
European coordination activities throughout 2021. Work focused on ICS2 Release 1’s implementation 
through  the  facilitation  of  operational  preparedness  of  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 that 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  customs  national  ICS2  project 
management  and  risk  management  representatives,  individual  economic  operators,  trade 
associations and international organisations;  

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

  Communication  campaigns,  with  different  activities  implemented  throughout  the  ICS2 
programme implementation, including the creation of ICS2 programme specific content on 
DG  TAXUD’s  webpage,  a  social  media  campaign  and  direct  communication  to 
stakeholders and multipliers;  

  Bilateral meetings with national customs administrations of those Member States that were 
delayed  and  missed  the  legally  expected  date  to  start  operation  as  of  15  March  2021  in 

15 

 
 
accordance  with  the  UCC  Work  Programme.  The  Commission  and  affected  national 
administrations  discussed  necessary  mitigation  actions  and  measures 
to  ensure 
implementation of Release 1 as early as possible and prior to the expiry of the deployment 
window (1 October 2021) that could be granted to the economic operators to connect to 
ICS2 and start lodging ENS in ICS2; 

  Online training sessions and training material.  

ICS2  Release  1  started  operation  on  15  March  2021.  Since  15  March  1  billion  different  types  of 
messages  was  exchanged  by  ICS2.  It  is  operated  24  hours  a  day,  7  days  a  week,  as  of  March  it  is 
operating without any major incident. Short downtimes were mainly related to planned changes in the 
Commission datacentre and had no impact on the business. In July nearly 6.5 million postal filings and 
3.5 million express filings were exchanged. 

The Commission reported that all national customs administrations will be fully operational before the 
expiry  of  the  deployment window  (1  October  2021).  This date  was  granted for  the  migration  of the 
economic operators/postal operators under conditions set in the UCC Work Programme. By that date, 
all economic operators concerned need to be connected to the new ICS2. The Commission expects that 
this will materialise based on the information received. However, for the postal operators of IT and HU, 
the Commission identified a risk of non-compliance with the deadline of 1 October 2021 for applying 
the new entry summary declaration obligations under the Union Customs Code. Therefore, the relevant 
Member States were contacted and urged to ensure the timely start of implementation and to provide 
updated planning till full operation. 

As from end of deployment window of 1 October 2021 for ICS2 Release 1, the EU postal operators will 
in the short term face certain difficulties to receive electronic data from the third country operators for 
all goods contained in postal consignments that are subject to entry summary declaration requirements. 
The Commission will work in close collaboration with the Member States customs administrations to 
minimize the impact on entry processes, within the scope of applicable provisions of the Union Customs 
Code.  

Summary from the Member States: 

The data below is the status which was collected as of the end of June 2021. The following Member 
States reported some delay with deployment: AT, BG, CY, DK, FR, GR, LV, MT, PL and RO.  

Besides the complexity of the project, other reasons for the delay were given such as: the tight timelines 
between related projects, a complex data migration, resource constraints, impact and re-planning due to 
the  VAT  eCommerce  package7  and  the  specific  working  circumstances  caused  by  the  COVID-19 
pandemic. 

Table 9 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

AT 

3 

High 

AT highlighted the high level of risk regarding the functional  interaction and 
tight timeline between relevant projects. In addition to this, concerns with the 
ongoing COVID-19 pandemic were highlighted. AT mentioned that there is a 
risk the deployment milestone could be impacted. AT is currently working on 
deployment, user tests, trainings and operations preparation. 

BE 

Information not provided. 

7 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33) 

16 

 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

BG 

5 

Low 

BG marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline set in the UCC Work Programme. The delay is caused by a complex 
data  migration  from  a  national  application,  which  requires  additional  human 
resources.  BG  uses  an  agile/iterative  approach  for  development.  They  have 
adapted and combined the implementation of two methodology frameworks – 
Adaptive  Development  Methodology  (ADM)  and  Rational  Unified  Process 
(RUP).  ADM  is  for  the  implementation  and  maintenance  of  the  overall 
architecture while RUP is used to manage the software lifecycle of the software 
solution.  
CY explained that the complexity is caused by dependencies with other systems, 
the high availability requirements and limited human resources. 

Low 

Low  CZ completed the deployment on 15/03/2021. 
Low  DE completed the deployment on 06/03/2021. 

High 

DK noted that deployment should be completed in 2021. The complexity stems 
from  the  fact  that  there  are  a  number  of  systems  that  must  be  implemented, 
modified  and  integrated  for  ICS2  to  work.  The  technical  solutions  are  being 
prepared  for  national  testing  before  EU  conformance  testing  begins.  The 
individual applications and the integrations between them are being developed, 
configured, and simultaneously tested. 
High  EE completed the deployment on 15/03/2021. 
Low  ES is currently improving the risk analysis activities at the national level. 
High  FI's ICS2 Release 1 was deployed on-time. 

Med 

FR used iterative development. FR explained that they had an issue with the 
performance  of  non-mandatory  scenarios,  which  impacted  the  date  of 
deployment in production. 

Med  None. 
Low  HR noted that they successfully completed testing and the production release. 
High  HU completed the deployment on 15/03/2021.  

Low 

IE  reported  ongoing  work  with  their  external  contractor  along  with 
communications with their national postal operator. 

Information not provided. 

Low  LT faced some delay with CT however, they were operational on 15/03/2021. 

Low 

LU explained that the project was on-track although they learned in December 
2020 that despite the fact that they considered the detail of being responsible 
MS  to  be  very  low,  they  nevertheless  had  to  implement  this  scenario.  The 
development of ICS2 – R1 was pushed with high priority in order to keep the 
plan foreseen by DG TAXUD. 

CY 

CZ 
DE 

DK 

EE 
ES 
FI 

FR 

GR 
HR 
HU 

IE 

IT 
LT 

LU 

6 

6 
4 

6 

6 
6 
6 

4 

6 
6 
5 

1 

5 

4 

LV 

6 

High 

MT 

6 

Low 

At the time of writing, LV marked the project as delayed in comparison to the 
planning in the 2020 report, but the overall delivery date is still expected within 
the deployment deadline set in the UCC Work Programme. They had a late start 
to development due to a delay with allocating finances, the overall complexity 
of  the  system  and  new  underlying  technology.  No  mitigating  measures  are 
necessary  as  LV  plans  to  go  into  production  before  the  deadline.  CT  is  still 
ongoing. 
At the time of writing, MT marked the project as delayed in comparison to the 
planning in the 2020 report, but the overall delivery date is still expected within 
the deployment deadline set in the UCC Work Programme. MT explained that 
their contractor has already initiated deployment and the configuration of the 
system. 

17 

 
 
MS 

NL 

Complexity 
Rating 
5 

Additional Comments 

Risk 
Level 
Med  None. 

PL 

PT 
RO 

SE 

SI 

SK 

5 

6 
6 

4 

6 

6 

Low 

At the time of writing, PL marked the project as delayed beyond the deployment 
deadline due to their contractor's failure to deliver both the software and system 
documentation. PL is starting acceptance testing.  

Low  PT completed the deployment on 15/03/2021. 
Low  RO’s go-live was postponed to 01/10/2021. 

Low 

SE  noted  that  they  use  the  central  STI  system  and  that  their  only  economic 
operator started using the system at the end of March 2021. The submission of 
ENS will gradually increase. 

High  None. 

Low 

The deployment of ICS2 Release 1 was delayed due to problems with new local 
legislation, financial constraints as well activities relating to eCommerce and 
Brexit. SK is experiencing low data quality from the post operators side. 

Table 9: Detailed responses from Member States – ICS2 – Release 1 

Figure 1 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase8.  

Figure 1: Project Status as per Survey – ICS2 – Release 1 

3.1.2  Overview of Project Progress 

Table 10 indicates the estimated percentage of completion as of the end of 2021 in comparison to the 
target dates set forth in the UCC Work Programme.  

Even if no operational dates were provided by BE and IT as part of the reporting, it was confirmed that 
they were ready by the end of the deployment window. 

8 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

18 

 
 
 
                                                      
Table 10: Comparison of Planned and Actual Dates – ICS2 – Release 1 

3.1.3  Analysis of Progress against Milestones 

Figure  2  summarises  the  status  per  milestone  (technical  specifications,  conformance  testing  and 
deployment).  The  sum  of  each  bar  is  28  (responses  from  the  27  Member  States  plus  the  European 
Commission). 

Figure 2: Summary of Responses per Milestone – ICS2 – Release 1 

Regarding ICS2 - Release 1, BE and IT did not provide information. See Figure 3 below: 

19 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion European Commission30/06/2018100%31/12/2020100%15/03/2021100%AT31/08/2020100%20/12/2020100%09/06/2021100%BENot providedNot providedNot providedNot providedNot providedNot providedBG19/08/2019100%21/12/2020100%17/04/2021100%CY31/01/2020100%31/03/2021100%15/05/2021100%CZ26/11/2020100%14/03/2021100%15/03/2021100%DE23/10/2020100%27/11/2020100%06/03/2021100%DK15/04/2021100%05/09/2021100%01/10/2021100%EE30/09/2020100%10/03/2021100%15/03/2021100%ES02/09/2019100%02/09/2020100%15/03/2021100%FI21/01/2020100%28/02/2021100%15/03/2021100%FR01/09/2021100%28/02/2021100%05/03/2021100%GR09/04/2021100%27/08/2021100%27/09/2021100%HR15/12/2019100%15/12/2020100%15/02/2021100%HU12/03/2021100%12/03/2021100%15/03/2021100%IE31/12/2020100%26/02/2021100%15/03/2021100%ITNot providedNot providedNot providedNot providedNot providedNot providedLT02/02/2020100%22/02/2021100%15/03/2021100%LU15/12/2020100%17/02/2021100%05/03/2021100%LV15/03/2021100%15/04/2021100%15/04/2021100%MT15/03/2021100%31/07/2021100%31/08/2021100%NL31/12/2019100%15/01/2021100%15/03/2021100%PL15/06/2021100%02/07/2021100%02/08/2021100%PT01/12/2020100%01/03/2021100%14/03/2021100%RO21/07/2021100%30/06/2021100%01/10/2021100%SEN/AN/AN/AN/A15/03/2021100%SI01/10/2019100%13/03/2021100%15/03/2021100%SK04/01/2021100%19/02/2021100%15/03/2021100%Deployment(Start of the deployment window)Conformance Testing30/06/2018RespondeeTechnical Specifications15/03/2021 
 
 
 
Figure 3: Percentage of Completion per Phase – ICS2 – Release 1 

20 

 
 
  
 
4. 

ONGOING  PROJECTS:  DETAILED  PLANNING  AND  PROGRESS 
INFORMATION 

 UCC 

ARRIVAL 

NOTIFICATION  OF 

4.1 
NOTIFICATION  (PN) AND TEMPORARY STORAGE (TS) 
The goal of this project is to define the processes at the national level in respect to the notifications 
known as Notification of Arrival (NA), Presentation Notification (PN) and Declaration for Temporary 
Storage (TS), as described in the UCC. This project will ensure the customs formalities related to the 
entry  of  goods  concerning  safety  and  security  exist  and  that  customs  supervision  begins  at  the 
appropriate time and is duly performed. It also aims to support harmonisation across the Member States 
regarding the data exchange between trade and customs. Furthermore, the project covers the automation 
of processes at the national level.  

PRESENTATION 

(NA), 

4.1.1 Summary of Responses 

Notification of Arrival (NA) 

Summary from the Commission: 

The development activities are a national responsibility (‘national development’) and are planned to be 
operational before the end of 2022. The processes and data requirements for the external domain have 
been  defined  and  agreed  upon  on  at  the  EU-level.  An  expert  group of Member  States,  ETCIT  WP2 
(Expert Team on new approaches to develop and operate Customs IT systems), financed by the Customs 
Programme, has been put in place to define and agree upon the business process models and discuss the 
legal/business/functional  requirements.  The  expert  team  is  also  actively  working  on  joining  the 
specifications for PN and TS. 

Summary from the Member States: 

The project is closely interlinked with other projects/systems such as the national import systems and 
the Import Control System 2 (ICS2). This is often reported by Member States as the reason for assessing 
the project as medium to highly complex. The timely delivery of the required national systems by all 
Member States was already at risk in last year’s report. Some additional delays in comparison with the 
UCC Annual Progress Report 2020 are noted, though several Member States reported that measures are 
taken to keep the deployment within the deadline. Some examples include changing the organisational 
setup with contractors to achieve a more effective development process and/or implementing an Agile 
development  methodology  to  reduce  the  implementation  timeframe.  Besides  the  complexity  of  the 
project, other reasons for potential delay are given such as resource constraints, further adaptations to 
the UCC Annex B, impact and re-planning due to the VAT eCommerce package9 and also the specific 
working circumstances caused by the COVID-19 pandemic. Intense collaboration in the ETCIT expert 
group is ongoing in order to share expertise and resources amongst interested Member States and to join 
forces in the development work. This summary also applies to PN and TS. 

The following Member States plan to implement NA as part of ICS2 Release 2: AT, BG, CY, DE, EE, 
ES, FI, HU, LT and RO. The following Member States are developing or have developed a national 
solution: CZ, FR, IT, LU, LV, NL, PL, PT, SI and SK. DK, GR, HR and SE have not yet taken a decision 
on how to implement NA. NA is not applicable for IE while BE and MT did not provide information. 

Detailed Responses: 

Table 11 provides the individual Member States’ responses to the survey: 

MS 

AT 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

4 

Low 

AT is working on defining the technical specifications. AT will implement NA 
as part of ICS2 – Release 2. 

9 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33) 

21 

 
 
                                                      
Complexity 
Rating 

Risk 
Level 

MS 

BE 

Additional Comments 

Information not provided. 

BE 

6 

Low 

BG 

5 

Low 

CY 

6 

Low 

CZ 

5 

Med 

DE 

4 

Low 

BE explained that the complexity is due to the exchanges with other systems 
and the harmonisation with other MSs participating in the collaboration group 
(ETCIT WP2). BE has already deployed a light version of PN to be able to send 
the PI of postal operators to the CR. They will later deploy the PN component, 
which at a later stage will be able to manage irregularities and finish with the 
revoke PN and PI. Lastly, BE mentioned that the re-export notification will be 
part of the PN/TS project. 
BG’s national technical specifications were approved at the end of 2020. BG 
will  implement  NA  as  part  of  ICS2  –  Release  2,  which  will  cover  the 
implementation  of  the  complete  new  Entry  Summary  Declaration  (ENS) 
obligations and related business and risk management processes for all goods in 
air traffic. 
CY  will  implement  NA  as  part  of  ICS2  –  Release  2.  CY  explained  that  the 
complexity  is  caused  by  interdependencies  between  core  and  supporting 
systems,  the  high  availability  requirements  of  the  systems  and  insufficient 
resources. CY explained that their national planning is not yet stable. 
CZ  finds  the  application  complex  and  has  indicated  that  it  requires  a  large 
amount of financial resources. CZ indicated that the project is currently delayed 
compared to the planning in the 2020 report, however the overall delivery is still 
expected within the deployment deadline set in the UCC Work Programme. CZ 
also highlighted a risk that the national project plan may have to be updated due 
to the COVID-19 pandemic and capacity of their contractor.  

DE explained that the NA message will be updated in line with ICS2 – Release 
2.  The  preparation  activities  for  Release  10.1  of  their  national  IT  system, 
ATLAS, has not yet started. External milestones affecting economic operators 
will be considered for the ICS2 – Release 2. 

DK 

EE 

ES 

4 

3 

3 

Low 

FI 

3 

Med 

Low 

DK noted that Deployment is needed but NA is included in many releases (VAT 
on  eCommerce,  Import,  ICS2,  Transit)  so  it  not  possible  to  provide  a  single 
status.  The  coordination  and  implementation  between  multiple  projects  and 
national legal requirements makes NA rather complex. The project is managed 
according  to  the  Scaled  Agile  Framework  (SAFe)  in  cooperation  with  the 
current national operations contractor. 

Low  EE will implement NA as part of ICS2 – Release 2. 

ES will implement NA as part of ICS2 – Release 2. ES will be using an Agile 
development methodology. 
FI will implement NA as part of ICS2 – Release 2. FI's plans have not changed 
drastically  compared  to  last  year,  however,  they  anticipate  several  risks.  The 
upgrade  of  the  platform  due  to  the  increase  of  the  volume  of  declarations  is 
ongoing. Furthermore,  there has been a need to postpone the development of 
some  functionalities  in  the  national  import  system.  This  will  also  affect  the 
planning and implementation of future UCC projects. The complete impact is 
not  yet  clear  but  risks  concerning  timetables  and  resources  have  increased. 
Lastly, FI mentions that the resources were already scarce from the beginning 
and that the additional effects of the COVID-19 pandemic have only increased 
the pressure.  These comments apply to all UCC projects.  
FR explained that this project will be aligned with ETCIT's AN/PN/TS solution 
from BE. The production timeline has been aligned with ICS2 Release 2. 

Low 

FR 

GR 
HR 

3 

6 
1 

Med  GR is facing a delay with budget allocation. 
High  HR explained that they have a lack of human resources. 

22 

 
 
Complexity 
Rating 
5 

Risk 
Level 
Med  None. 

Additional Comments 

MS 

HU 

IE 

IT 

LT 

1 

2 

6 

Low 

Med 

Low 

LU 

2 

Med 

4 

Low 

LV 

MT 

NL 

5 

Med 

IE noted that the project is not applicable to the MS as arrival data are directly 
provided to their customs authorities by Airport and Maritime authorities and 
thus, carriers are not required to submit Notifications of Arrival. 

IT  identified  a  risk  pertaining  to  the  economic  operators,  underlining  that 
requests for change might arise later in the process due to their lack of readiness. 
LT will implement NA as part of ICS2 – Release 2. LT is currently initiating the 
public procurement procedure for this project. 
LU explained that the complexity is due to the connections of this system with 
other systems namely TS and Import. The main risks are related to the limited 
number of customs experts both inside the customs administration and available 
for the software development. The requirements and specifications are planned 
to  be  completed  by  the  end  of  2021.  LU  also  explained  that  the  arrival 
notification  is  included  in  the  combined  project  with  the  presentation 
notification and temporary storage. 
LV  has  implemented  NA  as  part  of  their  national  TS  system.  Necessary 
corrections will be performed in the context of the ICS2 implementation.  

Information not provided. 

The  complexity  is  caused  by  the  large  number  of  external  stakeholders  (e.g. 
carriers,  freight  forwarders  and  their  software  providers),  and  internal 
stakeholders  (e.g.  policy  makers,  risk  analysts,  control  officers)  with  whom 
national requirements need to be defined. Furthermore, NL stressed there are a 
lot  of  projects  running  in  parallel  which  are  using  the  same  development 
expertise. This complexity could cause an impact to all project milestones. NL 
also  iterated  that  they  use  the  Scaled  Agile  Framework  (SAFe)  development 
methodology for all UCC projects. They use features, which are part of the IT 
solution, and do not rely on technical specifications. A bundle of features adds 
up  to  the  epic  solution.  Given  their  development  methodology,  technical 
specifications are often not applicable.   

PL 

PT 

RO 

SE 

SI 

SK 

4 

6 

4 

3 

4 

1 

Low  Analysis is ongoing and technical documentation is being prepared. 

Med 

Low 

Med 

Low 

Med 

PT gave a high complexity rating as they are updating an existing National NA 
system and are incorporating the changes from the review of Annex B DA/IA- 
UCC. The risk level mainly stems from a lack of resources in addition to the 
complexity of the required updates. PT will use Agile development to reduce 
the implementation timeframe.  

RO will implement NA as part of ICS2 – Release 2. Once the IT contractor is 
identified, RO will begin the analysis, design and development. 
Currently, SE’s planning is not fully in line with the timelines set forth in the 
UCC Work Programme but since the project has not yet started, they are unable 
to assess. 
SI explained that once their new import declaration system is completed, they 
will  upgrade  the  existing  electronic  messages  to  be  in  accordance  with  the 
updated Annex B. 

SK’s project is delayed in comparison to the planning in the 2020 report, but the 
overall delivery is still expected within the deployment deadline stated in the 
UCC Work Programme. They have identified risks related to a lack of human 
and financial resources and administrative burdens. No mitigation actions have 
been considered at this moment in time. 

Table 11: Detailed responses from Member States – NA 

23 

 
 
Figure 4 provides the percentage of Member States in each development phase.  

Figure 4: Project Status as per Survey – NA 

Presentation Notification (PN) 

Summary from the Commission: 

The summary is the same as for NA. 

Summary from the Member States: 

Please see the summary from NA. 

BG implemented PN as part of TS and their import declaration system. As it was implemented based on 
requirements from Annex D to Delegated Regulation (EU) 2015/2446, it will be updated by 31/10/2023. 
EE has also completed development. ES has already deployed PN for the VAT eCommerce package. 
The development  of  PN for  the rest  of  the use  cases is  ongoing.  FI  explained that  PN  is  completed 
however, upgrades may be required to align with ICS2 – Releases 2 and 3. FR will be implementing 
ETCIT’s NA/PN/TS solution, for which the production timeline has been aligned with ICS2 – Release 
2. IE deployed PN as part of their national import system and they expect to align it to the revised Annex 
B by 01/07/2021. LV implemented PN as part of their national TS system; necessary corrections will be 
performed in the context of the ICS2 implementation. 

Detailed Responses: 

Table 12 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

AT 

4 

High 

BE 

6 

Low 

Additional Comments 

AT explained that the functional interaction and the tight timelines for ICS2, 
NoA  and  the  adjustment  of  their  existing  import  system  along  with  the 
implementation of the VAT eCommerce package is challenging. Furthermore, 
the  COVID-19  pandemic  has  added  additional  pressure.  AT  notes  that  the 
planned timeline will be difficult to maintain. The main milestone in concern 
is Deployment.  
BE explained that the complexity is due to the exchanges with other systems 
and the harmonisation with other MSs participating in the collaboration group 
(ETCIT II). BE has already deployed a light version of PN to be able to send 
the PI of postal operators to the CR. They will later deploy the PN component, 
which at a later stage will be able to manage irregularities and finish with the 
revoke PN and PI. Lastly, BE mentioned that the re-export notification will be 
part of the PN/TS project. 

24 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

BG 

CY 
CZ 

5 

6 
5 

DE 

4 

DK 

EE 

ES 

FI 

FR 
GR 

HR 

HU 

IE 

IT 
LT 
LU 
LV 
MT 
NL 

4 

5 

5 

4 

2 
6 

4 

5 

5 

2 
6 
2 
4 

5 

Low 

PN was implemented as part of TS and their import declaration system. As it 
was  implemented  based  on  requirements  from  Annex  D  to  Delegated 
Regulation (EU) 2015/2446, it will be updated by 31/10/2023. 

Low  Same response as for NA. 
Med  Same response as for NA. 

Low 

DE marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline  set  in  the  UCC  Work  Programme.  The  business  roadmap  of  the 
national  IT-System  ATLAS  had  to  be replanned  due  to  various  unexpected 
factors,  e.g.  the  implementation  of  the  VAT  eCommerce  package.  This 
message  will  be  updated  in  the  major  release  of  the  national  IT-System 
ATLAS  -  Release  10.1  being  part  of  the  ‘National  Entry  System’.  The 
expected  date  of  deployment  is  December  2022.  No  mitigating  actions  are 
required as the annual release-cycle management will ensure delivery within 
the deployment deadline. 
Low  Same response as for NA. 

Low 

Low 

EE indicated that their development is complete. EE further iterates that this 
project is closely linked to ICS2 and the project deadlines should be amended 
accordingly.  The  end  date  of  the  deployment  window  of  PN  should  be 
01/03/2024. 
ES  is  using  an  iterative  development  methodology  and  already  has  PN 
deployed for the VAT eCommerce package. The development of PN for the 
rest of the cases is ongoing.  

Med 

FI explained that the project is completed. However, upgrades may be required 
to align with the ICS2 – Release 2 and 3 implementations. 

Low  Same response as for NA. 
Med  Same response as for NA. 

Med 

Progress  has  been  made  according  to  the  project  plan  and  the  team  has 
achieved the main milestones pertaining to delivery of project documentation 
and development. However, there is a risk that the planning for the technical 
specifications  and/or  conformance  testing  may  be  affected  due  to  a  lack  of 
human resources. HR explains that there are numerous EU projects that have 
to be carried out simultaneously.  

Med  None. 

Low 

PN has been deployed as part of their national import system update and is 
currently  in  operation  for  the  majority  of  economic  operators.  CT  for  the 
remaining  economic  operators  is  expected  to  be  completed  by  30/06/2021. 
Development was based on EUCDM 5.2 however the system is scheduled to 
be aligned to the revised Annex B on 01/07/2021. The other import declaration 
types will be updated with the implementation of CCI – Phase 1. 

Med  Same response as for NA. 
Low  Same response as for NA. 
Med  Same response as for NA. 
Low  Same response as for NA. 

Med  Same response as for NA. 

Information not provided. 

25 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

PL 

4 

Med 

PL explained that the difficulties in planning the construction of the system are 
related to the changes in the data set specified in Annex B to Delegated Act 
2015/2446. Agreements with contractors are based on applicable regulations, 
which is to ensure the contractor’s stability of work. Subsequent versions of 
data matrix projects, as well as changes to data regulations, introduced during 
the implementation of the project contract, necessitate constant changes in the 
systems  and  generate  additional,  unforeseen  costs  for  both  countries  and 
economic operators. It also affects the delays in system implementation. An 
additional obstacle to the timely implementation of the import system is the 
COVID-19 pandemic, which disorganises design work in many areas. 

PT 

RO 

SE 

SI 
SK 

6 

6 

4 

3 
1 

Med  Same response as for NA. 

Low 

Med 

RO  explained  that  the  PN  project  is  included  in  their  development  of  the 
national system of import and follows the implementation established for that 
system. 
SE noted that they are participating in the ETCIT pilot project lead by BE for 
the development of PN/TS and they will most likely use this IT application. 

Low  Same response as for NA. 
Med  Same response as for NA. 

Table 12: Detailed responses from Member States – PN 

Figure 5 provides the percentage of Member States in each development phase. 

Figure 5: Project Status as per Survey – PN 

Temporary Storage (TS) 

Summary from the Commission: 

The summary is the same as for PN. 

Summary from the Member States: 

Please see the summary from PN. 

BG implemented PN and TS as part of their national import declaration system. As it was implemented 
based on requirements from Annex D to Delegated Regulation (EU) 2015/2446, it will be updated by 
31/10/2023. EE, IE and LV have also implemented TS. 

Detailed Responses: 

Table 13 provides the individual Member States’ responses to the survey: 

26 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

AT 

3 

High 

Additional Comments 

The  milestone  most  at  risk  is  Deployment.  AT  is  developing  a  new  customs 
declaration system. The transformation process and integration with the existing 
application  are  complex.  Furthermore,  the  COVID-19  pandemic  and  the 
restrictions  that  have  been  put  in  place  have  had  an  impact  on  the  project 
progress. 
BE explained that the complexity is due to the exchanges with other systems 
and the harmonisation with other MSs participating in the collaboration group 
(ETCIT II). BE will first deploy the TSD component and at a later stage they 
will be able to manage irregularities and finish with the movement between TSF. 
The re-export notification will be part of the PN/TS project. 

Low 

BE 

BG 
CY 
CZ 
DE 

6 

5 
6 
5 
4 

Low  None. 
Low  Same response as for PN. 
Med  Same response as for PN. 
Low  Same response as for PN. 

The high risk rating is due to many dependencies with other systems, parallel 
development, limited resources and numerous stakeholders. DK mentioned that 
their  project  is  currently  delayed  in  comparison  to  the  planning  in  the  2020 
report, but the overall delivery is still expected within the deployment deadline. 
DK  is  fully  focused  on  their  national  import  systems  upgrade,  including 
configuration and validation of necessary functionality. However, this has been 
delayed  due  to  the  COVID-19  pandemic  and  their  focus  on  finishing 
implementing the requirements from the VAT eCommerce package. Mitigating 
measures  are  foreseen  and  will  be  implemented  during  Q2  2021.  Mitigation 
measures include changing the organisational setup with the supplier in terms of 
staffing and teams, primarily to achieve a more effective development process 
and  to  promote  deeper  understanding  of  the  software  at  earlier  stages  of  the 
process  to  avoid  problems.  Furthermore,  initiatives  in  order  to  secure  more 
robust release/deployment processes for standard software has been initiated in 
order to reduce the waiting time in relation to configuration and test. The project 
is  handled  within  the  Scaled  Agile  Framework  (SAFe).  Temporary  Storage 
compliance will be built on top of a configured standard solution handling the 
H7 declaration type. The solution will also support the UCC Special Procedures 
and UCC CCI projects. Full focus on Temporary Storage has been delayed due 
to  COVID-19  and  due  to  focus  on  finishing  the  implementation  of  the  VAT 
eCommerce package within deadline. People who are working on Release 1 are 
the same people who are going to work at Release 2. R1 is delayed which means 
R2 will be delayed as well because the people who  are  going to work on R2 
cannot be allocated full time before R1 is completed.   
EE  indicated that they  have  limited  resources  and tight  deadlines.  EE further 
iterated  that  testing  activities  are  ongoing  in  preparation  for  the  deployment 
window  start  date,  which  is  set  for  01/07/2021.  EE  further  iterates  that  this 
project is closely linked to ICS2 and the project deadlines should be amended 
accordingly.  The  end  date  of  the  deployment  window  of  TS  should  be 
01/03/2024. 
ES  mentioned  that  their  project  is  currently  delayed  in  comparison  to  the 
planning in the 2020 report, but the overall delivery is still expected within the 
deployment deadline. Technical specifications are not completed yet, but they 
still expect to have it operational before the end of 2022. Changes have been 
made  to  the  conformance  testing  and  deployment  milestones.  ES  will  use 
iterative development. 

27 

DK 

6 

High 

EE 

5 

Med 

ES 

6 

Med 

 
 
MS 

FI 

FR 

GR 

HR 
HU 
IE 
IT 
LT 
LU 

LV 

MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

6 

2 

5 

4 
5 
5 
2 
4 
2 

5 

5 
4 
6 
6 
4 
3 
1 

High 

In addition to the risks mentioned for NA, FI explained that the whole system 
will be built from scratch and that it will contain numerous integrations.  

Low  Same response as for NA and PN. 

Med 

GR  mentioned  that  their  project  is  currently  delayed  in  comparison  to  the 
planning in the 2020 report, but the overall delivery is still expected within the 
deployment  deadline.  GR  is  facing  a  delay  due to budget  allocation  however 
hopes to have a contract in place by the end of 2021. 

Med  Same response as for PN. 
Med  None. 
Low  Same response as for PN. 
Med  Same response as for PN. 
Low  None. 
Med  Same response as for PN. 

Low 

As from 24/09/2017, their national TS system has been updated according to the 
UCC data elements. Additional functionality for movements between TS places 
(if located  in  LV)  was  added  on  05/03/2018.  LV  also  mentioned  that further 
developments, such as EUCDM changes, will be implemented in the timeframe 
between 2021 and 2023. 

Information not provided. 

Med  Same response as for PN. 
Med  Same response as for PN. 
Med  Same response as for PN. 
Low  Same response as for PN. 
Med  Same response as for PN. 
Low  Same response as for PN. 
Med  Same response as for PN. 

Table 13: Detailed responses from Member States – TS 

Figure 6 provides the percentage of Member States in each development phase. 

Figure 6: Project Status as per Survey – TS 

4.1.2  Overview of Project Progress 

Table 14, Table 15 and Table 16 highlight any known divergences in the planning compared to the dates 
set  in  the  Work  Programme.  As  this  project  has  a  deployment  window,  the  ‘Deployment’  and 

28 

 
 
 
‘Operations’ columns are shown. If there is a difference in these two dates, this implies that a migration 
period is planned. 

In regards to the implementation of the Notification of Arrival, the following Member States have a 
planned operations date that is later than the deadline in the UCC Work Programme: BE, BG, EE, ES, 
NL and SE. SE plans a timely deployment of the national system but with a gradual migration of all 
economic operators). DE and IE marked NA as not applicable.  

Subsequent to the gathering of the data in Table 14, DK have indicated that they intend to  meet the 
deployment deadline of 31/12/2022. 

More specifically, nine Member States (AT, BG, CY, DE, EE, ES, FI, LT and RO) have reported that 
they will use the NA integrated in ICS2 – Release 2 (planned deployment 15/03/2023). The specific 
dates can be found in Table 14.  

Table 14: Comparison of Planned and Actual Dates – NA 

In regards to the implementation of the Presentation Notification, the following Member States have 
indicated a planned operations date for PN, which is later than the deadline in the Work Programme: 
BE, EE, NL and SE. However, it should be noted that for these 4 Member States, the delay relates only 
to  the  migration  of  all  their  economic  operators  and  not  to  the  deployment  of  the  national  system. 
Moreover, all Member States will have a timely deployment of their national system. 

29 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateAT01/11/202190%01/12/20220%01/12/20220%01/01/2023BENot providedNot provided01/02/2023Not provided01/03/2023Not provided01/03/2023BG04/10/2020100%20/02/20230%01/03/20230%01/03/2023CY05/10/202090%02/06/20220%03/06/20220%03/10/2022CZ01/03/202250%31/12/20220%31/12/20220%31/12/2022DEN/AN/AN/AN/AN/AN/ANot providedDKBlankN/ANot providedN/ANot providedN/ANot providedEEN/A0%N/A0%01/03/20230%01/03/2024ES31/12/2020100%15/03/20230%15/03/20230%15/09/2023FI30/06/20220%Not provided0%31/12/20220%31/12/2022FR31/03/2022100%31/12/2022N/A31/12/20220%31/12/2022GR30/09/20220%31/12/2022N/A31/12/20220%31/12/2022HR31/12/202220%01/07/20220%01/12/20220%31/12/2022HU30/06/202230%30/11/202210%31/12/202210%31/12/2022IEN/AN/AN/AN/AN/AN/AN/AIT15/07/20200%15/11/20210%31/12/20210%31/12/2022LT01/06/2020100%30/09/20220%31/12/20220%31/12/2022LUNot provided80%01/03/20210%02/03/202130%02/03/2021LV05/06/201750%22/09/2017100%24/09/2017100%25/09/2017MT31/08/2021Not provided31/07/2022Not provided01/10/2022Not providedNot providedNL31/12/2021100%14/02/2023N/A01/03/20230%01/03/2023PL30/06/202250%31/12/202230%01/01/202330%01/01/2023PT15/01/2022100%15/11/20220%31/12/20220%31/12/2022RONot provided80%Not provided0%01/08/20210%01/10/2021SENot provided0%Not provided0%01/10/20220%30/09/2024SI12/06/2019100%01/12/202290%01/12/202290%01/12/2022SK01/03/20220%31/12/20220%31/12/20220%Not providedTo be defined by MS and for Notification of Arrival in line with ICS2 planningRespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)To be defined by MS as part of the national planOperations(End of the deployment window)31/12/2022 
 
 
 
Table 15: Comparison of Planned and Actual Dates – PN 

In regards the implementation of the Temporary Storage, the following Member States have indicated 
a planned operations date for TS, which is later than the deadline in the Work Programme: BE, EE and 
NL.  

More  specifically,  NL  has  reported  that  they  will  integrate  TS  into  ICS2  –  Release  2  (planned 
deployment 15/03/2023) which will cause a delay limited to two months. 

Table 16: Comparison of Planned and Actual Dates – TS  

30 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateAT31/08/2020100%20/12/2020100%09/06/2021100%31/10/2021BE04/01/202170%01/02/202333%01/03/202360%01/03/2023BG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY05/10/202090%02/06/20220%03/06/20220%03/10/2022CZ01/03/202250%31/12/20220%31/12/20220%31/12/2022DE31/03/202260%30/09/20230%31/12/20220%31/12/2022DK01/03/2021N/A01/06/2021N/A01/06/2021N/A01/07/2021EE05/10/2020100%15/03/2021100%15/03/2021100%01/03/2024ES06/04/2020100%30/09/20220%30/09/20220%30/09/2022FI01/03/2020100%30/12/2021100%15/03/2021100%31/03/2021FR30/06/2022100%Not provided100%31/12/202270%31/12/2022GR30/09/20220%31/12/2022N/A31/12/20220%31/12/2022HR01/09/202080%01/07/20220%01/12/20220%31/12/2022HU30/06/202230%30/11/202210%31/12/202210%31/12/2022IE04/10/2019100%30/06/2021100%23/11/2020100%01/07/2021IT15/07/20200%15/11/20210%31/12/20210%31/12/2022LT20/01/202250%30/09/20220%31/12/20220%31/12/2022LUNot provided80%01/03/20210%02/03/202130%02/03/2021LV05/06/2017100%22/09/2017100%24/09/2017100%25/09/2017MT31/08/2021Not provided31/07/2022Not provided01/10/2022Not provided31/09/2022NL01/01/2022100%14/02/2023N/A01/03/20230%01/03/2023PL15/06/202170%08/07/202150%02/08/202140%Not providedPT15/01/2022100%15/11/20220%31/12/20220%31/12/2022RO30/09/2021100%31/12/20220%31/12/20220%Not providedSENot provided0%Not provided0%01/09/20210%30/09/2024SI12/06/2019100%01/12/202290%01/12/202290%01/12/2022SK01/03/20220%31/12/20220%31/12/20220%Not providedConformance TestingTo be defined by MS as part of the national planTo be defined by MS and for Notification of Arrival in line with ICS2 planningDeployment(Start of the deployment window)RespondeeTechnical SpecificationsOperations(End of the deployment window)31/12/2022Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateAT01/02/2021100%01/06/20220%01/06/20220%01/12/2022BE04/01/202170%01/02/202333%01/03/202360%01/03/2023BG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY05/10/202090%02/06/20220%03/06/20220%03/10/2022CZ01/03/202250%31/12/20220%31/12/20220%31/12/2022DE31/03/202260%30/09/20230%31/12/20220%31/12/2022DK26/10/202125%31/12/20225%10/10/20220%Not providedEE05/10/2020100%30/06/2021100%01/07/2021100%01/03/2024ES30/06/2021100%30/09/20220%30/09/20220%30/09/2022FI02/11/2020100%Not providedN/A30/09/202295%30/09/2022FR30/06/2022100%Not provided0%31/12/20220%31/12/2022GR30/09/20220%31/12/2022N/A31/12/20220%31/12/2022HR01/09/202080%01/07/20220%01/12/20220%31/12/2022HU30/06/202230%30/11/202210%31/12/202210%31/12/2022IE04/10/2019100%30/06/2021100%23/11/2020100%01/07/2021IT15/07/20200%15/11/20210%31/12/20210%31/12/2022LT01/03/20220%30/09/20220%31/12/20220%31/12/2022LUNot provided80%01/03/20210%02/03/202130%02/03/2021LV05/06/2017100%22/09/2017100%24/09/2017100%25/09/2017MT31/08/2021Not provided31/07/2022Not provided01/10/2022Not provided31/09/2022NL02/01/2022100%14/02/2023N/A01/03/20230%01/03/2023PL01/02/202190%01/07/202270%30/12/202240%Not providedPT15/01/2022100%15/11/20220%31/12/20220%31/12/2022RO30/09/2021100%31/12/20220%31/12/202250%Not providedSENot provided0%Not provided0%30/06/20220%31/12/2022SI12/06/2019100%01/12/202270%01/12/202290%01/12/2022SK01/03/20220%31/12/20220%31/12/20220%Not provided31/12/2022RespondeeTechnical SpecificationsConformance TestingTo be defined by MS and for Notification of Arrival in line with ICS2 planningTo be defined by MS as part of the national planDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
4.1.3  Analysis of Progress against Milestones 

Figure  7,  Figure  8  and  Figure  9  summarise  the  status  per  milestone  (technical  specifications, 
conformance testing and deployment). The sum of each bar is 27 (responses from the 27 Member States). 

Figure 7: Summary of Responses per Milestone – NA 

Figure 8: Summary of Responses per Milestone – PN 

Figure 9: Summary of Responses per Milestone – TS 

Additional details regarding the specific percentage of completion per milestone can be seen Figure 10, 
Figure 11 and Figure 12.  

31 

 
 
 
 
 
 
Regarding the Notification of Arrival, the following Member States have not yet started: EE, FI, GR, 
IT, SE and SK. BE and MT did not provide percentage of completion information. Lastly, DE and IE 
marked Notification of Arrival as Not Applicable. 

32 

 
 
 
Figure 10: Percentage of Completion per Phase – NA 

33 

 
 
 
 
Regarding the Presentation Notification, the following Member States have not yet started: GR, IT, 
SE and SK. MT did not provide percentage of completion information. 

Figure 11: Percentage of Completion per Phase – PN 

34 

 
 
 
Regarding Temporary Storage, the following Member States have not yet started: GR, IT, LT, SE and 
SK. MT did not provide percentage of completion information. 

Figure 12: Percentage of Completion per Phase – TS 

35 

 
 
 
 
 
UCC NATIONAL IMPORT SYSTEMS UPGRADE 

4.2 
The project will implement all processes and data requirements deriving from the UCC, which relate to 
the import of goods into the Union. The existing national import systems must be upgraded in line with 
these  new  UCC  requirements.  The  upgrade  mainly  relates  to  the  changes  for  the  "Release  for  free 
circulation" procedure (standard procedure and the simplifications) and changes in the related exchanges 
of information, but also covers the impact of changes in other electronic systems. This project covers 
the  national  customs  declarations  processing  systems,  as  well  as  national  accountancy  and  payment 
systems.  

4.1.4 Summary of Responses 

Summary from the Commission: 

The  availability  of  the  technical  specifications  provided  by  the  Commission  for  the  Centralised 
Clearance at Import system and the harmonisation across entry/import-transit-export/exit (supported by 
the revision  of the  UCC  annex  B  data requirements and  the  EU  Customs  Data  Model)  were  crucial 
achievements to push this project forward on a national level. 

Summary from the Member States: 

Some Member States planned this project as a priority and have already upgraded their national import 
system in line with the UCC. Due to this early deployment, these Member States will need to make an 
additional effort for a second upgrade in view of the revised Annex B10.  

Other Member States have decided to concentrate first on other projects and wait for further progress 
on the specifications for the trans-European system related to import, being the Centralised Clearance 
at Import (CCI). In particular, those Member States that decided not to upgrade their existing national 
declaration system but to build a completely new one. 

BG, EE, IE, LV, SI and SK have completed their system upgrades. If not already done, updates to align 
their systems with the latest Annex B will happen between 2021 and 2023. Furthermore, many Member 
States advanced their planning. This can be seen in section 4.2.2. 

BE and MT have reported a planned operations date beyond the one in the UCC Work Programme and 
GR and LT have reported no progress on their technical specifications. Careful project risk management 
by the Member States and supervision by the Commission, in its role of coordinator, is to be envisaged 
for the next year.  

Detailed Responses: 

Table 17 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

AT 

5 

High 

Additional Comments 

The  milestone  most  at  risk  is  deployment.  AT  is  developing  a  new  customs 
declaration  system  and  the  transformation  process  and  integration  with  their 
existing application is complex. The restrictions put in place during the COVID-
19  pandemic  have  had  an  impact  on  the  project  progress.  AT  is  currently 
working  on  the  technical  specifications  and  requirements.  Furthermore,  the 
SAFe development methodology will now be used. 

10  Annex  B  to  Delegated  Regulation  (EU)  2015/2446  -  regarding  common  data  requirements,  as  amended  by 
Delegated Regulation (EU) 2021/234 

36 

 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

BE 

6 

Med 

BG 

6 

Low 

CY 

6 

Low 

CZ 

5 

Med 

DE 

6 

Low 

DK 

6 

High 

EE 

6 

Low 

BE  marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline  set  in  the  UCC Work  Programme.  They  have  experienced  delays in 
receiving final specifications (especially for H7), in addition to lack of clarity in 
the dataset. A lot of rework was required. Furthermore, there has been delays 
with  other  applications  and  new 
their 
implementation. All milestones are impacted. BE noted the following mitigating 
actions: using an Agile development methodology, adapting the scope, assessing 
incremental progress and working in phases with several releases. 
BG’s system has been in production since 07/01/2019. During 2020, the national 
import  system  was  upgraded  to  implement  the  VAT  eCommerce  package, 
including the use of CD as per Art. 143a of the UCC-DA and the new column 
H7 in Annex B. All updates will be deployed and used from 01/07/2021, in-line 
with the postponement of the application of the VAT eCommerce package. 

technologies  are 

impacting 

CY explained that the complexity is caused by dependencies with other systems, 
the  high  availability  requirements  and limited  human  resources. The  national 
planning is not yet stable and is dependent on the details in the future contract.  

CZ  marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline set in the UCC Work Programme. Their national plans are not yet stable 
due  to  capacity  constraints  with  their  contractor.  CZ  has  indicated  that  the 
project requires a large amount of financial resources. In addition, there is a risk 
that  the  national  project  plan  may  have  to  be  updated  due  to  the  COVID-19 
pandemic and the delays it is causing. The required changes will depend on the 
development of the situation. 
DE marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline set in the UCC Work Programme. The business roadmap of the national 
IT-System ATLAS had to be replanned due to various unforeseen factors, e.g. 
the  implementation  of  the  VAT  eCommerce  package.  The  national  import 
system will be implemented as part of the national IT-System ATLAS - Release 
10.1. The expected date of deployment is in December 2022.  

The complexity is high due to many dependencies with other systems, parallel 
development,  numerous  stakeholders  and  limited  resources.  DK  marked  the 
project  as  delayed  in  comparison  to  the  planning  in  the  2020  report,  but  the 
overall delivery date is still expected within the deployment deadline set in the 
UCC Work Programme. Full focus on this project including configuration and 
validation of necessary functionality, has been delayed due to the COVID-19 
pandemic and due to focus on finishing requirements from the VAT eCommerce 
package.  Mitigating  measures  including  organisational  changes  with  the 
supplier  to  ensure  an  effective  development  process  are  foreseen  to  be 
implemented during Q2 2021. Furthermore, initiatives in order to secure more 
robust releases/deployments processes of standard software has been initiated in 
order to lower full stack teams waiting time in relation to configuration and test. 
The project is handled within the Scaled Agile Framework (SAFe). 
EE explained that testing activities are ongoing. EE further iterated that CT and 
deployment  were  postponed  by  six  months  due  to  the  VAT  eCommerce 
package. 

37 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

ES 

5 

Med 

FI 

6 

High 

FR 

6 

Med 

GR 

6 

Med 

HR 

6 

High 

HU 

6 

High 

IE 

5 

Med 

IT 
LT 

LU 

3 

5 

Additional Comments 

ES explained that this project requires coordination with other projects such as 
Centralised  Clearance  for  Import  and  a  sufficient  window  for  economic 
operators  to  upgrade  while  limiting  business  impact.  ES  uses  an  iterative 
development methodology and has updated their planning to be in-line with the 
CCI-Phase 1 activities. 
FI  marked  the  project  as  delayed  beyond  the  deployment  deadline.  Their 
planning  has  changed  as  a  result  of  the  volume  of  Low  Value  Consignment 
(LVC) declarations which have risen dramatically. This was not anticipated at 
the moment of the acquisition of UCC IT systems. Because of this, there will be 
a  considerable  amount  of  upgrades  to  be  performed  on  the  platforms  and 
supporting IT systems and a need to adjust the declaration management system’s 
internal  processes.  Due  to  these  necessary  changes,  there  has  been  a  need  to 
postpone the development of some functionalities in national import system. 
FR  marked  the  project as delayed in  comparison  to  the  planning  in the  2020 
report, but the overall delivery is still expected within the deployment deadline. 
FR explained that a comprehensive review of import and export processes was 
undertaken  to  define  a  schedule  in  order  to  optimise  the  use  of  available 
resources. FR is leading the overhaul of the import and export system, which 
entails  more  work  explaining  the  slight  delay  with  the  completion  of  the 
technical specifications. 
GR  mentioned  that  their  project  is  currently  delayed  in  comparison  to  the 
planning in the 2020 report, but the overall delivery is still expected within the 
deployment deadline. GR is facing a delay due to budget allocation. 

HR explained that the project is very complex and human resources are limited 
as  team  members  are  involved  in  other  MASP/national  projects.  HR  is  now 
defining the business process for simplified declarations and the impact on the 
other  systems  related  to  the  national  import  system.  They  are  also  defining 
messages  to  economic  operators  according  to  the  new  Annex  B.  They  are 
analysing the impact of the introduction of the EUR  envisaged for the day of 
application of the new import customs declarations system in HR. 
HU explained that the IT development done for eCommerce will be used as a 
basis for the national import system which will ultimately be the basis for the 
upgrade developments as well. 
IE’s system is in operation for the majority of economic operators and CT for 
the remaining economic operators is expected to be completed by 30/06/2021. 
Development  was  based  on  EUCDM  5.2  and  the  system  is  scheduled  to  be 
aligned to the revised Annex B for the H7 on 01/07/2021, and for all other import 
declaration types in conjunction with the implementation of CCI Phase 1. Due 
to the late adoption of revised Annex B and publication of EUCDM 6, there is 
a risk that the target date of 01/07/2021 for implementation of the H7 may not 
be met. 

Information not provided. 

Low  LT is currently initiating the public procurement procedure for this project. 

High 

LU marked the project as delayed in comparison to the planning in the 2020 
report, but the overall delivery is still expected within the deployment deadline. 
The various procedures in the various business cases both on the national and 
European-level are more complex than foreseen. More time is needed to analyse 
and document the various use cases. Additional internal resources have been put 
on this project in order to avoid further delays. 

38 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

LV 

5 

Low 

MT 

6 

Med 

NL 

3 

Low 

PL 

6 

Med 

PT 

6 

Med 

Additional Comments 

LV informed that their national import system has been aligned with UCC DI/IA 
Annex B and EUCDM V2.0 as from 03/06/2018. Further developments such as 
EUCDM changes, the VAT eCommerce package, integration with ECMS, are 
planned to be implemented in 2021-2023. 

MT marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline  set  in  the  UCC  Work  Programme.  MT  explained  that  this  is  due  to 
various  projects  running  in  parallel  in  addition  to  limited  resources.  As  a 
mitigating action, MT explained that some of the development of the upgrades 
will be outsourced. MT further noted that the compliancy to EUCDM is very 
complex and it involves various critical systems. 
NL commented that an agile development approach is being used. NL explained 
that they are currently developing and testing the system together with their IT 
developer. 
PL provided the same explanation for the risk level as in section 4.1 NA/PN/TS. 
PL  further  explained  that  they  are  now  focusing  on  the  VAT  eCommerce 
package, which they aim to implement by 01/07/2021. In IT terms, the plans are 
related to the development of a new module AIS/eCommerce, which will be a 
separate  component  within  the  import  system  (that  handles  regular  import 
declarations). The AIS/eCommerce module will handle customs declarations in 
postal and courier traffic (i.e. declarations with the H7 and H6 data scope). 
PT explained that the risk level is due to the implementation of a new system 
and a lack of resources. PT stated that an Agile development methodology will 
be  used  to  help  reduce  the  implementation  timeframe.  PT  iterates  that  the 
development of this system is not only related with the system itself, but also to 
the development of all national, central and other MS´s systems/modules. This 
increases the interdependencies and the complexity of the “global system”. The 
review of Annex B DA/IA-UCC makes it difficult to determine whether their 
work  completed  continues  to  be  correct  and  applicable.  Consequently, 
additional  costs  are  created  by  the  need  to  reassess  the  aforementioned 
developments  thus  further  adding  to  the  complexity  of  the  deliverables.  The 
deadline for the end of the work related to the harmonisation / modification of 
Annex B - Columns H and I, was the end of 2019, however the new version of 
the  Annex  B  was  only  published  on  23/03/2021.  PT  also  mentions  that  the 
creation  of  new  obligations/deadlines  for  Member  States,  like  reviewing  the 
package  related  with  column  H7  to  be  implemented  in  2021,  also  created  a 
constraint in updating their national import system because they have developed 
a new system to deal with the VAT eCommerce package. 

RO 
SE 

6 
4 

Low  RO is currently defining the technical specifications. 
Med  None. 

SI 

6 

High 

SI was expecting the Commission to prepare the technical specifications for the 
import  declaration,  code  list  for  the  Automated  Import  System  (AIS)  in  the 
Central Services Reference Data 2 (CSRD2). SI explains that they have limited 
human  resources  and  that  their  team  members  work  on  several  projects 
simultaneously. Furthermore, there is a concern over financial resources as the 
COVID-19  pandemic  unfolds.  SI  is  convinced  that  the  customs  environment 
will be ready on time however, they have doubts regarding the testing readiness 
of the external environment (economic operators). 

39 

 
 
MS 

SK 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

3 

Low 

SK’s system has been in production since 30/06/2019. An upgrade to implement 
the updated version of Annex B will be needed. 

Table 17: Detailed responses from Member States – National Import Systems Upgrade 

Figure 13 provides the percentage of Member States in each development phase. 

Figure 13: Summary of Survey Responses – National Import Systems Upgrade 

4.1.5 Overview of Project Progress 

Table 18 highlights any divergences in the planning compared to the dates set in the Work Programme. 
As this project has a deployment window, the ‘Deployment’ and ‘Operations’ columns are shown. If 
there is a difference in these two dates, this implies that a migration period is planned. 

In regards to the implementation of the National Import Systems Upgrade, the following Member States 
have a planned operations date that is later than the deadline in the UCC Work Programme: BE and MT. 
The  specific  dates  can  be found in  Table  18  below.  The  delay  for  BE is limited  to a  few  days.  MT 
explained that this is due to various projects running in parallel in addition to limited resources. As a 
mitigating action, some of the development of the upgrades will be outsourced. MT further noted that 
the compliancy to EUCDM is very complex and it involves various critical systems. For BE and MT, 
the deployment of the system at national level is planned to be on time; though the gradual migration to 
full operations is estimated to go beyond the date of 31 December 2022. 

40 

 
 
 
 
Table 18: Comparison of Planned and Actual Dates – National Import Systems Upgrade 

4.1.6  Analysis of Progress against Milestones 

Figure  14  summarises  the  status  per  milestone  (technical  specifications,  conformance  testing  and 
deployment). The sum of each bar is 27 (responses from the 27 Member States). 

Figure 14: Summary of Responses per Milestone – National Import Systems Upgrade 

Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
15. The following Member States have not yet started with the technical specifications: GR and LT.  

41 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateAT01/02/2021100%01/02/20220%01/06/20220%01/10/2022BE01/01/202150%01/01/202220%31/08/202215%12/01/2023BG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY30/12/202080%01/08/20210%01/06/20220%03/10/2022CZ01/03/202250%31/12/20220%31/12/20220%31/12/2022DE31/03/202280%31/03/20230%31/12/202220%31/12/2022DK01/06/202150%01/03/202210%31/12/20220%Not providedEE31/12/2020100%01/12/2020100%30/06/2021100%01/07/2021ES31/03/2021100%31/03/20220%31/12/20220%01/09/2022FI30/06/2019100%Not provided80%Not provided95%30/09/2022FR30/09/2021100%N/A0%N/A0%31/12/2022GR30/09/20220%Not providedN/ANot provided0%31/12/2022HR31/12/2021100%01/01/20220%01/06/202240%31/12/2022HU30/06/202230%01/07/202210%30/11/202210%31/12/2022IE04/10/2019100%30/04/2020100%23/11/2020100%01/07/2021IT30/09/2019Not provided30/06/2020Not provided30/06/2021Not provided30/06/2021LT01/03/20220%30/09/20220%30/09/20220%31/12/2022LUNot provided100%31/03/20220%31/12/202230%02/01/2023LV30/10/2017100%01/06/2018100%03/06/2018100%04/06/2018MT31/01/20225%01/02/20220%30/06/20225%01/09/2023NL22/06/2021100%01/02/202220%31/12/20220%31/12/2022PL01/02/202270%30/07/202250%30/12/202240%Not providedPT01/07/202275%15/11/20220%31/12/20220%31/12/2022RO30/09/2021100%30/09/20220%31/12/20220%Not providedSE15/09/2021100%Not provided0%15/03/20220%31/12/2022SI01/07/2019100%01/10/2021100%01/10/2021100%01/10/2021SK11/06/2016100%30/04/2017100%30/06/2019100%Not providedRespondeeTechnical SpecificationsOperations(End of the deployment window)To be defined by MSTo be defined by MS as part of the national planDeployment(Start of the deployment window)Conformance Testing31/12/2022 
 
 
 
Figure 15: Percentage of Completion per Phase – National Import Systems Upgrade 

42 

 
 
 
 
 
UCC SPECIAL PROCEDURES 

4.3 
This national project aims to accelerate, facilitate and harmonise Special Procedures across the Union 
by means of providing common business process models. The national systems will implement all UCC 
changes required for all the special procedures (customs warehousing, end-use, temporary admission 
and inward/outward processing). It should be noted that, in many Member States, the implementation 
of this project occurs within the context of the upgrades of the national import and export systems. 

In terms of planning, this project will be implemented in two parts. The first component is the "National 
Special  Procedures  EXP"  (NSP  EXP)  with  the  view  to  providing  the  required  national  electronic 
solutions  for  the  export-related  special  procedure  activities.  The  second  component  is  the  "National 
Special  Procedures  IMP"  (NSP  IMP)  with  the  view  to  providing  the  required  national  electronic 
solutions for the import-related special procedures activities. 

4.1.7 Summary of Responses 

Special Procedures – Component 1 (NSP EXP) 

Summary from the Member States: 

DE and PL plan to deploy the updates to their systems by the end of 2021. The following Member States 
specified that they will implement this project as part of AES (Section 4.9): BG, FI, IE, PT, RO, SI and 
SK. 

The potential causes for delay are the following: the implementation of a new import system and/or 
dependencies with other systems, lack of resources and procurement delays along with specific working 
circumstances caused by the COVID-19 pandemic. Some additional delays in comparison with the UCC 
Annual Progress Report 2020 are noted, though several Member States reported that measures are taken 
to have the deployment still on time. For example, many Member States have also implemented Agile 
development methodologies to reduce the implementation timeframe. 

Detailed Responses: 

Table 19 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

AT 

4 

Med 

The  milestone  most  at  risk  is  deployment.  AT  is  developing  a  new  customs 
declaration system and the transformation and the integration with their existing 
application  are  complex.  The  restrictions  put  in  place  during  the  COVID-19 
pandemic have had an impact on the on boarding and project progress. AT is 
currently  refining  their  technical  analysis,  defining  national  requirements, 
establishing  a  cooperation  team  and  coordinating  planning  with  Belgian 
Customs. 

BE 

Information not provided. 

BG 

5 

Low 

CY 

6 

Low 

CZ 

6 

Med 

BG  stated  that  the  technical  specifications  are  completed.  The  award  for 
implementation is now ongoing and will be completed by July 2021. The project 
will be implemented as part of the AES project to cover all the export operations 
for SP. 
CY explained that the complexity is caused by dependencies with other systems, 
the  high  availability  requirements  and  limited  human  resources.  The 
development approach will be decided in cooperation with the contractor. The 
national planning is not yet stable and is dependent on the details in the future 
contract.  
CZ's national plan is stable. However, the COVID-19 pandemic does present a 
risk. In line with their national plan, CZ is currently preparing detailed national 
technical  and  functional  specifications.  The  national  specifications  will  be 
completed in Q2 2021. 

43 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

DE 

4 

Low 

DK 

6 

High 

EE 

6 

Med 

ES 

FI 

FR 

GR 

HR 

HU 

IE 

IT 
LT 

LU 

5 

6 

5 

5 

6 

3 

5 

5 

4 

DE is making use of an agile development approach in defined software release 
cycles. The ongoing activities concern the finalisation and fine-tuning of AES 
(e.g.  adaptation  of  Surveillance),  the  monitoring  of  operations  as  well  as  the 
preparation of remaining Conformance Tests (Mode 2) for new functionalities 
of  AES  (e.g.  centralised  clearance)  and  the  start  of  the  Conformance  Test 
(certification) of economic operators. The period for CT with Trade has been 
shifted  from  March  2021  -  July  2022  to  October  2021  -  November  2022. 
Therefore, November 2022 is the end of the deployment window for trade. After 
this date, no ECS phase 2 messages will be accepted in the external domain. 

DK assessed the complexity as very high due to many dependencies with other 
systems, parallel development and many stakeholders. The milestones most at 
risk are CT and the final test phase, due to alignment and dependencies with 
other systems. The CT dates have not been set yet. The project is handled within 
the Scaled Agile Framework (SAFe). Currently the project is scaling-up with 
consultant  assistance  to  configure/test  the  national  adjustments  on  top  of  a 
standard solution. 
EE considered the project delayed in comparison to the planning in the 2020 
report, but the overall delivery is still expected within the deployment deadline 
set in the UCC Work Programme. The procurement process is delayed, however, 
mitigation  actions  are  foreseen.  A  contract  with  a  developer  is  in  place,  the 
technical  specifications  have  been  completed,  a  detailed  analysis  has  been 
carried out, and the export core flow is completed. EE explained that the changes 
in national planning are due to delays in procurement. 

ES noted that they are using an agile/iterative development methodology. ES 
further suggests that this project should be the subject of a specific project group 
to clarify the tasks and milestones to be achieved. 

FI explained that they are building AES and  NSP-EXP from scratch and that 
several other IT projects are ongoing. AES will contain numerous integrations. 
The implementation is planned to start in Q2 2021. 

FR noted that the complexity comes from the project’s link to the import/export 
clearance system. This project will use the same planning for Import and Export. 
At the time of collecting this information, FR is working on the links between 
Annexes B and A. They are also analysing their Customer Reference Service, 
the INF system and the national ROSA components to ensure consistency and 
to consider the possibility of a new web service. 

Med 

High 

Low 

Low  GR is facing a delay with budget allocation. 

Med 

HR noted that the TS and CT milestones may be affected due to a lack of human 
resources. Many EU projects have to be carried out simultaneously.  

Low  None. 

Low 

IE  explained  that  this  project  will  be  deployed  as  part  of  the  AES  project. 
Discussions will commence with external contractors this year. 

Low  None. 

Information not provided. 

Med 

LU marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline set in the UCC Work Programme. The procedure for the call for tenders 
and the negotiations with the software provider took longer than planned.  LU 
noted that their software provider is also servicing another Member State ,which 
should help to progress faster than planned. The main risks are related to the 
limited number of customs experts both inside the customs administration and 

44 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

LV 

MT 

NL 

4 

3 

Low 

Low 

PL 

5 

Med 

PT 

6 

High 

Med 

RO 

SE 

SI 

2 

4 

4 

available for the software development. LU has started internal analysis on the 
business  processes.  LU  also  iterated  that  it  is  challenging  to  give  the  details 
according  to  the  MASP-C  planning  as  their  internal  planning  for  the  Export 
formalities is following a different logic. LU noted that indeed there will be a 
first  phase  with  AES-P1  including  the  special  procedures  but  excluding  all 
simplified  procedures,  while  there  will  be  second  phase  with  all  simplified 
procedures including simplified procedures for the special procedures. 
LV plans to develop the database, messages for the export/re-export declarations 
and the graphical user interface for Customs users in 2021. 

Information not provided. 

NL commented that an agile development approach is being used. NL explained 
that they are currently developing and testing the system together with their IT 
developer. 
The medium level risk is caused by the creation of a new IT national Regulatory 
Procedure with Scrutiny (RPS) system and its integration with other IT national 
customs  systems  (inter  alia  Import  and  Export  systems),  which  are  currently 
being expanded. Therefore, the milestones also depend on the progress of other 
IT  projects.  Moreover,  there  is  still  a  risk  connected  with  the  COVID-19 
pandemic which has impact on the work. Recently, the RPS system was tested 
by internal users – customs officers and a few economic operators in terms of 
integration  with  related  systems.  Testers  submitted  comments  to  the  external 
contractor  regarding  the  system's  functionalities.  The  new  version  of  the 
software will be installed in Q2 2021. The project team is currently preparing 
wider test scenarios for the RPS system in terms of business services covering 
UCC Special Procedures. These business services will be available for testing 
for economic operators on the national customs and tax portal. This year's plan 
of implementation, deployment of the RPS national IT system and other related 
IT systems is postponed to the end of 2021 due to the situation caused by the 
COVID-19 pandemic. Part of the functionalities/requirements resulting from the 
provision  of  UCC  Special  Procedures  will  be  covered  under  subsequent 
implementations in 2023.  
PT explained that the risk level is due to the implementation of a new  export 
system  and  a  lack  of  resources.  PT  explained  that  an  Agile  development 
methodology will be used to help reduce the implementation timeframe. This 
project is an integrated part of ‘UCC Trans-European Automated Export System 
(AES):  Component  1’, consequently the comments  made in  section  4.9.1  are 
also applicable. 
RO noted that this project will be an AES component. RO mentioned that the 
project is currently delayed in comparison to the planning in the 2020 report, but 
the overall delivery is still expected within the deployment deadline. This is due 
to a delay in approving the budget for the current year. No mitigating measures 
are foreseen yet since the overall delivery is still foreseen within the deployment 
deadline. 

Med  SE noted that they performed a pre-study in Autumn 2020. 

Med 

The project is ongoing according to their national plan. However, the COVID-
19 pandemic is still indicated as a risk that could cause a delay to the deployment 
of the project. The external contractor is currently preparing detailed technical 
specifications for the entire AES system. In 2020, their contractor prepared a 
detailed analysis on how to move from SIAES/ECS phase 2 to SIAES phase 1, 
with realistic and reachable dates. These dates have been reflected in the project 
plans  at  the  end  of  2020.  The  production  environment  date  for  AES  is 
01/05/2023. 

45 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

SK 

3 

Med 

Additional Comments 

SK's project is delayed in comparison to the planning in the 2020 report, but the 
overall delivery is still expected within the deployment deadline  stated in the 
UCC Work Programme. This project will be developed together with AES. The 
milestone most at risk is technical specifications. CT is planned for Q2 2022 
however, the procurement procedure is still not finished. Their aim is to have 
the technical specifications completed by the end of 2021. 

Table 19: Detailed responses from Member States – NSP EXP 

Figure 16 provides the percentage of Member States in each development phase. 

Figure 16: Project Status as per Survey – NSP EXP 

Special Procedures – Component 2 (NSP IMP) 

Summary from the Member States: 

BG’s system in production is currently being aligned with the latest Annex B. IE and LV also deployed 
this component as part of their National Import System.  EE, PL SI and SK expect to be completed by 
the end of 2021. DE, DK, FI, HR and PT noted that they will implement this component as part of their 
National Import Systems upgrade. 

The potential causes for delay are the following: the implementation of a new import system and/or 
dependencies with other systems, lack of resources and procurement delays along with specific working 
circumstances caused by the COVID-19 pandemic. Some additional delays in comparison with the UCC 
Annual Progress Report 2020 are noted, though several Member States reported that measures are taken 
to have the deployment still on time. For example, many Member States have also implemented Agile 
development methodologies to reduce the implementation timeframe.  

Detailed Responses: 

Table 20 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

AT 

4 

Med 

Additional Comments 

The  milestone  most  at  risk  is  deployment.  AT  is  developing  a  new  customs 
declaration  system  and  the  transformation  process  and  integration  with  their 
existing application is complex. The restrictions put in place during the COVID-
19 pandemic had an impact on the project progress. AT is currently working on 
the technical specifications and requirements. 

BE 

Information not provided. 

46 

 
 
 
MS 

BG 

CY 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

5 

6 

Low 

BG's  national  system  is  currently  being  adapted  to  conform  with  the 
amendments introduced by Delegated Regulation (EU) 2021/234. 

Low  Same response as for NSP EXP. 

CZ 

5 

Med 

CZ  marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline set in the UCC Work Programme. Their national plans are not yet stable 
due  to  capacity  constraints  with  their  contractor.  CZ  has  indicated  that  the 
project requires a large amount of financial resources. In addition, there is a risk 
that  the  national  project  plan  may  have  to  be  updated  due  to  the  COVID-19 
pandemic and the delays it is causing. The required changes will depend on the 
development of the situation. The indicative date for technical specifications is 
01/03/2022. 
DE explained that they will implement this component as part of the "National 
Import Systems upgrade", which will be covered by their national IT-System 
ATLAS - Release 10.1. The expected deployment date is in December 2022. 

Low 

High  Same comments as for the National Import Systems Upgrade (section 4.2). 

Low 

EE  noted  that  conformance  testing,  training  and  deployment  activities  are 
ongoing. The CT and deployment have been postponed by six months due to the 
implementation of the VAT eCommerce package. 

Med  Same response as for NSP EXP. 

High 

Same comments as for the National Import Systems Upgrade (section 4.2). FI 
further noted that the deployment and integration testing dates will be impacted. 
This  year,  they  plan  to  deploy  and  test  new  versions.  FI  also  explained  that 
simplifications are postponed to Q1 2022. 

Low  Same response as for NSP EXP. 

Med 

GR  mentioned  that  their  project  is  currently  delayed  in  comparison  to  the 
planning in the 2020 report, but the overall delivery is still expected within the 
deployment  deadline.  GR  is  facing  a  delay  due to budget  allocation  however 
hopes to have a contract in place by the end of 2021. 

High  Same comments as for the National Import Systems Upgrade (section 4.2). 
Low  None. 

Low 

IE explained that this is deployed as part of their National Import system and it 
is  in  operation  for  the  majority  of  economic  operators.  CT  for  the  remaining 
economic  operators  is  expected  to  be  completed  by  30/06/2021.  A  phased 
transition of traders was implemented rather than a 'big bang' approach. 

Low  None. 

Information not provided. 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HR 
HU 

IE 

IT 
LT 

4 

6 

6 

5 

6 

5 

6 

6 
3 

5 

5 

The main risks are related to the limited number of customs experts both inside 
the  customs  administration  and  available  for  the  software  development.  The 
activities are ongoing together with the upgrade of the national import system. 
LU also iterated that it is challenging to give the details according to the MASP-
C planning as their internal planning for the Export formalities is following a 
different logic. LU noted that indeed there will be a first phase with AES-P1 
including the special procedures but excluding all simplified procedures, while 
there will be second phase with all simplified procedures including simplified 
procedures for the special procedures. 
LV’s national import system has been aligned with UCC DA/IA Annex B and 
EUCDM V2.0 as of 03/06/2018. 

Information not provided. 

LU 

5 

Med 

5 

Low 

LV 

MT 

47 

 
 
MS 

NL 
PL 

Complexity 
Rating 
3 
5 

Risk 
Level 
Low  Same response as for NSP EXP. 
Med  Same response as for NSP EXP. 

Additional Comments 

PT 

RO 
SE 
SI 

SK 

6 

6 
4 
6 

5 

Med 

PT mentioned the same comments as for the National Import System Upgrade 
(section 4.2). There has been some changes to their national plan such as the 
date of technical specifications publication for economic operators and the CT 
start date for economic operators. 

Low  RO is currently defining the technical specifications. 
Med  None. 
High  Same comments as for the National Import Systems Upgrade (section 4.2). 

Low 

SK explained that an upgrade to implement the updated version of Annex B is 
required. This is planned to take place by the end of the deployment of CCI, as 
defined by the Work Programme. 

Table 20: Detailed responses from Member States – NSP IMP 

Figure 17 provides the percentage of Member States in each development phase. 

Figure 17: Project Status as per Survey – NSP IMP 

4.1.8 Overview of Project Progress 

Table 21 highlights any known divergences in the planning of the NSP EXP compared to the dates set 
in the Work Programme. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ 
columns are shown. If there is a difference in these two dates, this implies that a migration period is 
planned.  

48 

 
 
 
Table 21: Comparison of Planned and Actual Dates – NSP EXP 

Table 22 highlights any known divergences in the planning of the NSP IMP compared to the dates set 
in the Work Programme. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ 
columns are shown. If there is a difference in these two dates, this implies that a migration period is 
planned. 

49 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateAT01/08/202150%01/12/20220%01/12/20220%01/06/2023BE04/07/2020Not provided31/07/2022Not provided01/04/2022Not provided01/08/2022BG05/01/2021100%31/05/20230%05/06/20230%05/06/2023CY10/01/202290%01/02/20230%02/02/20230%03/04/2023CZ30/06/2021100%02/04/20230%03/04/20230%03/04/2023DE23/10/2020100%05/03/2021100%06/03/2021100%31/07/2022DKNot provided30%01/02/20230%01/09/20230%Not providedEE31/03/2022100%01/06/20230%30/06/20230%30/06/2023ES31/12/202265%01/07/202330%31/07/20230%30/11/2023FI31/03/202295%31/12/20220%31/03/202350%30/09/2023FR30/06/202180%31/03/20230%31/03/20230%30/09/2023GR30/09/20220%Not providedN/A31/12/20220%31/12/2022HR31/12/202185%30/09/20220%01/01/20230%01/01/2023HU31/05/20230%01/11/20230%01/12/20230%01/12/2023IE28/01/2022100%30/03/20230%30/01/20230%31/03/2023IT30/06/2020Not provided30/06/2022Not provided05/09/2022Not provided03/04/2023LT01/09/20220%02/11/20230%02/11/20230%01/12/2023LUNot provided50%01/04/20230%01/04/20230%01/04/2023LV01/02/202280%31/08/202380%05/02/202380%01/12/2023MT31/01/2021Not provided31/12/2021Not provided31/01/2022Not providedNot providedNL22/06/2021100%31/12/202220%01/04/20220%31/12/2022PL23/10/2020100%04/05/2021100%01/07/2021100%01/10/2021PT01/06/2022100%01/08/20230%01/12/20230%01/12/2023RO19/03/2021100%31/08/20230%15/05/20230%31/08/2023SENot provided0%30/09/20230%01/10/20220%30/11/2023SI18/12/202095%31/01/20230%01/05/20230%01/05/2023SK01/12/202295%01/11/20230%01/12/20230%01/12/2023Deployment(Start of the deployment window)Operations(End of the deployment window)01/12/202301/03/2021RespondeeTechnical SpecificationsConformance TestingTo be defined by MS 
 
 
Table 22: Comparison of Planned and Actual Dates – NSP IMP 

4.1.9 Analysis of Progress against Milestones 

Figure  18  and  Figure  19  summarise  the  status  per  milestone  (technical  specifications,  conformance 
testing and deployment). The sum of each bar is 27 (all Member States). 

Figure 18: Summary of Responses per Milestone – NSP EXP 

50 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateAT01/02/2021100%01/06/20220%01/06/20220%01/12/2022BE01/10/2019Not provided01/04/2020Not provided01/03/2020Not provided15/04/2020BG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY30/12/202085%01/06/20220%03/06/20220%03/10/2022CZ01/03/202250%31/12/20220%31/12/20220%31/12/2022DE31/03/20220%30/09/20230%31/12/20220%31/12/2022DK01/06/202125%01/10/20225%01/10/20220%Not providedEE31/12/2020100%30/06/2021100%01/07/2021100%01/07/2021ES31/03/2022100%31/12/20220%31/05/20220%30/11/2022FI30/06/2019100%Not providedN/A30/09/202395%30/09/2022FR30/09/202180%N/A0%30/09/20220%31/12/2022GR30/09/20220%Not providedN/A31/12/20220%31/12/2022HR31/12/2021100%01/06/20220%31/12/202240%31/12/2022HU30/06/20220%30/11/20220%31/12/20220%31/12/2022IE04/10/2019100%30/06/2021100%23/11/2020100%01/07/2021IT30/09/2019Not provided15/06/2021Not provided15/12/2020Not provided30/06/2021LT01/03/20220%30/09/20220%31/12/20220%31/12/2022LUNot provided100%30/12/20220%02/01/202330%02/01/2023LV30/10/2017100%01/06/2018100%03/06/2018100%04/06/2018MT31/01/2021Not provided31/12/2021Not provided31/01/2022Not provided31/01/2022NL22/06/2021100%31/12/202220%01/04/20220%31/12/2022PL16/11/2020100%04/05/2021100%01/07/2021100%01/10/2021PT15/01/202275%15/11/20220%31/12/20220%31/12/2022RO30/09/2021100%31/12/20220%31/12/20220%Not providedSENot provided0%Not provided0%01/05/20220%31/12/2022SI01/07/2019100%01/10/2021100%01/10/2021100%01/10/2021SK01/10/2020100%01/11/2022100%01/12/2022100%Not providedRespondeeTo be defined by MS as part of the national planOperations(End of the deployment window)31/12/2022To be defined by MSTechnical SpecificationsConformance TestingDeployment(Start of the deployment window) 
 
 
 
 
Figure 19: Summary of Responses per Milestone – NSP IMP 

Additional  details  regarding  the  specific  percentage  of  completion  per  milestone  can  be  seen  in  the 
following figures. Regarding NSP EXP, the following Member States have not yet started: GR, HU, LT 
and SE. The following Member States did not provide percentage of completion information: BE, IT 
and MT. 

51 

 
 
 
Figure 20: Percentage of Completion per Phase – NSP EXP 

52 

 
 
 
 
 
Regarding NSP IMP, the following Member States have not yet started: DE, GR, HU, LT and SE. The 
following Member States did not provide percentage of completion information: BE, IT and MT.  

Figure 21: Percentage of Completion per Phase – NSP IMP 

53 

 
 
 
 
 
UCC GUARANTEE MANAGEMENT (GUM) 

4.4 
The UCC Guarantee Management (GUM) project aims to assure the effective and efficient management 
of the different types of guarantees. The main objective is to ensure that the data of guarantees, which 
are used in more than one MS, are made electronically accessible to the MS where a customs declaration 
is lodged and accepted when such guarantee is used. This will require new interfaces between GUM and 
national systems. One advantage of the solution is that the traders can provide one guarantee that can be 
used  across  the  Union.  Moreover,  the  improved  processing  speed,  traceability  and  monitoring  of 
guarantees electronically between customs offices is expected to lead to a faster identification of cases 
where guarantees are deemed invalid or insufficient to cover the incurred or potential debt. 

The system is comprised of two components. The first component is "GUM". GUM is a trans-European 
system that will cover the management of the comprehensive guarantees that may be used in more than 
one Member State. Transit guarantees monitoring is an exception to the above and is handled as part of 
the NCTS project.  

4.1.10  Summary of Responses 

GUM – Component 1 

Summary from the Commission: 

In September 2020, the updated Business Case was approved by the Member States with the preferred 
implementation  option  being  a  decentralised  system  architecture  with  light  central  IT  support.  This 
option will be implemented through the UCC Customs Decisions System. The central GUM component 
is expected to be operational in the second quarter of 2025. On the basis of the systems architectural 
change, the hybrid-Member States, using the UCC Customs Decisions system should be ready and test 
their systems before the central GUM component goes live in 2025. Member States with hybrid solutions 
are expected to start operations in the first quarter of 2024. This creates a window of one year to develop 
their system after the component specifications of the GUM central system are made available. 

The planning was significantly updated based on the architecture approved by the Member States in the 
Business Case. The milestones for updating the L4 BPMs and the Vision document were delayed by 
one quarter due to the anticipation of long discussions with MSs, the change in the architecture of the 
GUM system, a longer time period foreseen for the external reviews, etc. These activities are planned 
to be completed in 2021. The milestones of application and technical specifications also had to be revised 
since a draft of the Annex A data elements needed for GUM will only be ready during the first half of 
2022. The planning aspect will need to be carefully examined and addressed in the coming years by the 
Commission and the Member States to keep this project on track. 

The  chosen  option  to  use  the  Customs  Decisions  System  might  require  less  effort  in  the  IT 
implementation, but will on the other hand require a legislative change. As this could potentially be a 
risk, it will become necessary to identify and initiate the required changes as early as possible.  

National GUM – Component 2 

Summary from the Member States:  

GUM – Component 2 refers to the development of Member States’ National Guarantee Management 
systems.  This  work  can  mainly  be  done  in  parallel  with  GUM  –  Component  1.  There  is  a  project 
interdependency on the National Import System of each Member State, where they have multi-Member 
States’ guarantees involved. 

Numerous Member States commented that they are waiting for the Level 4 BPMs to be provided by the 
Commission. These BPMs will elaborate the national business concept. Many Member States indicated 
that the Technical Specifications milestone was at risk due to this. 

BG, IE and ES implemented national GUM systems. LT noted that system improvements are taking 
place  and  that  they  plan  to  launch  the  system  in  production  by  the  end  of  2021.  The  guarantee 
management systems for LV and PL have also been implemented in their National Import systems. SE’s 
system will be deployed in April 2021. 

54 

 
 
The potential causes for delay are the following: lack of transparency and information on the change in 
concepts with regards to GUM, lack of human and financial resources and delays in budget allocation. 
Many Member States updated their planning and none provided  deployment dates later than what is 
specified in the Work Programme.  

Detailed Responses: 

Table 23 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

AT 

BE 
BG 
CY 

CZ 

3 

4 
6 

6 

Low 

AT explained that they are waiting for the Level 4 BPMs to be provided by the 
Commission. These will elaborate the national business concept. 

Information not provided. 

Low  None. 
Low  CY stated that development has not yet started. 

High 

CZ marked the project as delayed beyond the deployment deadline stating that 
the delay is caused by the Commission. CZ mentions that the milestone most 
at risk is Technical Specifications. No mitigating actions have been foreseen. 

DE 

4 

Low 

DE explained that this project will be implemented in the major release of their 
national IT-System ATLAS (Release 10.3 / 2026) for which the preparatory 
activities have not yet started. DE also mentioned that until now, only transit 
guarantee monitoring has been implemented for NCTS. The working group to 
handle a new overall guarantee system has just resumed.  

DK 

EE 

ES 

FI 

FR 
GR 
HR 
HU 
IE 
IT 

LT 

LU 

LV 

MT 

6 

3 

5 

6 
5 
6 
5 
6 
3 

5 

4 

1 

5 

Information not provided. 

Med 

Low 

Med 

EE marked all milestones as at risk due to a lack of resources. Despite this, 
business analysis is ongoing and the development phase is planned to start in 
the second half of 2021. 

ES confirmed the completion of their national guarantee management system, 
which went live on 01/09/2016.  
FI commented that this project will require a large amount of integrations and 
that they have not yet started. 

Med  FR mentioned that the milestone most at risk is technical specifications. 
Low  GR is facing a delay with budget allocation. 
Med  HR is in the analysis phase. 
Low  None. 
Low  Same response as for SP2 (see section 4.3). 
Low 

IT explained that project activities have not yet started. 
LT explained that system improvements are taking place and that they plan to 
launch the system in production by the end of 2021. LT reported a delay in 
conformance testing with economic operators. 

LU explained that the complexity of the system is mostly determined by the 
integration  with  their  national  accounting  system.  The  ongoing  discussion 
regarding the details for GUM make it challenging to estimate the project’s 
complexity. The limited number of customs experts both inside the customs 
administration  and  available  for  the  software  developers  is  currently  the 
biggest risk. 
LV explained that this project has been implemented in their National Import 
System. 
MT  explained  that  their  planning  will  be  updated  once  analysis  and 
requirements  elicitation  are  completed.  MT  noted  a  risk  due  to  the  lack  of 
transparency and information on the change in concepts with regards to GUM. 

55 

Low 

Low 

Low 

High 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

NL  explained  that  they  will  build  a  new  Guarantee  Management  System 
(DZA) for all UCC, Excise and other types of guarantees. DZA will replace 
their current GMS (KIS and GMS for NCTS). They plan to start in Q3 2021 
and the development will be iterative and agile. In Q2 2022 the updated Annex 
A will be approved. The updated data elements and data structure are inputs 
for the UCC guarantees for which they need to register, manage and monitor 
in their national GMS (DZA). The reference amount in Annex A and CDS-
GUM  will  be  split  per  customs  procedure  and  per  Member  State.  Every 
Member  State  where  the  guarantee  is  used  is  responsible  for  the  audit  or 
transaction based monitoring. Transit is out-scope of GUM. One of the open 
GUM  issues  is  if  the  reference  amount  for  customs  procedure  80  (Transit) 
should  be  split  per  Member  State.  These  kind  of  issues  are  impacting  the 
design, data model and rules & conditions of their national GUM component. 
In addition, the impact of delay could be large, because if their national GUM 
component  is  not  ready  in  June  2025,  NL  cannot  monitor  the  part  of  the 
reference amount for guarantees established in another MS.  
PL's system is in production and they are adapting the  system to applicable 
laws while also incorporating necessary improvements. 
PT explained that the risk level is due to the implementation of a new national 
GUM System and a lack of resources. PT explained that an Agile development 
methodology will be used to help reduce the implementation timeframe. 

Low  None. 
Low  SE explained that this project will be completely deployed in April 2021. 
Low  None. 

Med 

SK's project is delayed in comparison to the planning in the 2020 report, but 
the overall delivery is still expected within the deployment deadline stated in 
the  UCC  Work  Programme.  They  have  identified  risks  related  to  a  lack  of 
human and financial resources. No mitigation actions have been considered at 
this moment in time. 

NL 

3 

Low 

Low 

Med 

PL 

PT 

RO 
SE 
SI 

SK 

4 

6 

5 
3 
3 

2 

Table 23: Detailed responses from Member States – GUM – Component 2 

Figure 22 provides the percentage of Member States in each development phase. 

Figure 22: Summary of Survey Responses – GUM – Component 2 

56 

 
 
 
4.1.11  Overview of Project Progress 

Table 24 and Table 25 highlight any known divergences in the planning compared to the dates set in the 
Work Programme.  

Table 24: Comparison of Planned and Actual Dates – GUM – Component 1 

As GUM – Component 2 has a deployment window, the ‘Deployment’ and ‘Operations’ columns are 
shown. If there is a difference in these two dates, this implies that a migration period is planned. In 
regards to the implementation, the following Member States have a planned operations date that is later 
than the deadline in the UCC Work Programme: FI and FR (approximately 1 month of delay). 

Table 25: Comparison of Planned and Actual Dates – GUM – Component 2 

4.1.12  Analysis of Progress against Milestones 

Figure  23  summarises  the  status  per  milestone  (technical  specifications,  conformance  testing  and 
deployment) for the National GUM – Component 2. The sum of each bar is 27 (responses from the 27 
Member States).  

57 

Target date from WPPlanned/Actual End Date2021 % of CompletionPlanned/Actual End Date2021 % of Completion Target date from WPPlanned/Actual Date2021 % of Completion 30/09/202201/08/20220%29/05/20250%02/06/202531/03/20240%Conformance TestingTechnical SpecificationsDeploymentTarget date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateAT01/05/20230%01/09/20240%01/09/20240%01/03/2025BENot providedNot providedNot providedNot providedNot providedNot providedNot providedBG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY01/02/20230%01/09/20240%02/10/20240%01/02/2025CZNot provided0%Not provided0%Not provided0%01/06/2025DENot provided0%Not provided0%Not provided0%Not providedDKNot providedNot provided01/05/2025Not provided01/05/2025Not provided01/06/2025EEN/AN/AN/AN/A30/06/20230%30/06/2023ES30/06/2016100%01/07/2016100%01/09/2016100%01/05/2019FI31/12/20210%30/06/20250%30/06/20250%30/06/2025FRNot provided60%Not provided0%Not provided0%30/06/2025GR31/12/20240%Not provided0%31/03/20250%31/03/2025HRNot provided10%Not provided0%Not provided0%Not providedHU30/11/20240%01/05/20250%01/06/20250%01/06/2025IE04/10/2019100%30/06/2021100%23/11/2020100%01/07/2021IT15/09/20190%15/12/20200%15/12/20200%15/12/2020LT01/11/2021100%10/11/2021100%10/12/2021100%15/12/2021LUNot provided0%01/01/20250%01/01/20250%01/01/2025LVN/AN/AN/AN/A03/06/2018100%04/06/2018MT31/01/20220%15/12/20220%31/03/20230%31/03/2023NLNot provided0%Not providedN/ANot provided0%01/06/2025PL31/12/2021100%02/06/2025100%31/12/2023100%02/06/2025PT15/01/2022100%15/11/20220%31/12/20220%31/12/2022RO30/06/20240%31/03/20250%01/06/20250%Not providedSEN/AN/ANot providedN/A17/04/2021100%17/04/2021SI01/01/20220%20/05/20250%01/06/20250%01/06/2025SK01/09/20230%01/06/20250%01/06/20250%Not providedOperations(End of the deployment window)02/06/2025Technical SpecificationsConformance TestingDeployment(Start of the deployment window)RespondeeTo be defined by MSTo be defined by MS as part of the national plan 
 
 
 
 
Figure 23: Summary of Responses per Milestone – GUM – Component 2 

Regarding National GUM - Component 2, the following Member States have not yet started: AT, CY, 
CZ, DE, FI, GR, HU, IT, LU, MT, NL, RO, SI and SK.  

58 

 
 
 
Figure 24: Percentage of Completion per Phase – GUM – Component 2 

59 

 
 
 
 
 
UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASES 2 AND 3 

4.5 
4.1.13  Summary of Responses 

ICS2 – Release 2 

Summary from the Commission: 

As a second phase, ICS2 release 2 will cover the implementation of new ENS obligations and related 
business and risk management processes for all the goods entering the EU by air traffic. From this release 
onwards, and following a positive policy decision of the Commission and Member States in December 
2020, the ICS2 system will implement a Safety and Security Analytics capability and Shared Trader 
Portal. As part of Release 2, the Safety and Security Analytics capability will be integrated within the 
ICS2 common repository component and will implement the analytics platform accessible by MSs via 
CCN2 (and the Commission via UUM&DS) integrated by a dedicated portal and a data factory for real 
time analytics (enrichment of ENS data) connected to a common repository. Shared Trader Portal will 
provide  the  User  interface  to  Economic  Operators  allowing  the  file  ENS  information  and  run  ICS2 
Conformance testing for their own IT systems.  

The Commission’s development activities for Release 2 are organised using as iterative process. Two 
major releases are planned to take place during 2021 and a following release is planned for 2022. The 
testing of the first major release is planned to be finished in September. Development for second major 
Release is ongoing. (Those releases includes also corrective and evolutive changes related to the ICS2 
Release 1 scope).  

ICS2 Release 2 Conformance Testing is planned to start in Q3 2022.  

In addition to the ICS2 safety and security analytics capabilities project, Release 2 poses new challenges 
compared to Release 1 such as the addition of three new types of economic operators acting in the air 
transportation supply chains and thirteen different types of ENS filings, to bring into the system more 
and better quality trade data of goods moving towards the EU. Release 2 will also include new business 
models with their own business needs, rules and user interfaces. There will be an increasing complexity 
of timers, data quality, data consistency rules and linking for multiple filings and arrival notifications. 
Furthermore,  there  will  be  a  larger  volume  of  messages  and  complex  conformance  testing  with 
numerous stakeholders. Lastly, the migration strategy between Release 1 and 2 will be complex with 
different  transition  windows.  The  Commission  has  initiated  coordination  meetings  to  ensure smooth 
development of the system. Additional complexity is raised by Safety and Security Analytics capabilities 
as well as implementation of Shared Trader Portal functionality   

Summary from the Member States: 

Member States are preparing the national functional and technical specifications based on the common 
EU specifications provided by the Commission, participating in webinars and reviewing documentation. 
The Member States also mentioned the increase in complexity compared with Release 1, citing the same 
potential causes of delay as mentioned for ICS2 – Release 1 (see section 3.1). 

Detailed Responses: 

Table 26 provides the individual Member States’ responses to the survey: 

MS 

AT 
BE 

BG 

Complexity 
Rating 
4 

Additional Comments 

Risk 
Level 
Low  AT reported that they are working on the technical specifications. 
Information not provided. 

4 

Low 

BG  explained  that  they  are  using  the  functional  and  technical  specifications 
provided by the Commission. They are currently upgrading them with national 
requirements. 

60 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

CY 

6 

Low 

CZ 

DE 

DK 

EE 

ES 

FI 
FR 

GR 

HR 
HU 
IE 
IT 
LT 

LU 

LV 

MT 

NL 

PL 

PT 

6 

4 

3 

6 

6 
5 

6 

1 
4 
2 

6 

4 

5 

6 

5 

6 

6 

CY explained that the complexity is caused by dependencies with other systems, 
the  high  availability  requirements  and  limited  human  resources.  The 
development approach will be decided in cooperation with the contractor. The 
national planning is not yet stable and is dependent on the details in the future 
contract.  
CZ assessed the application complex and has indicated that it requires a large 
amount of financial resources. CZ highlighted a risk that the national project 
plan may have to be updated due to the COVID-19 pandemic and delays it is 
causing. The changes will depend on the evolution of the situation.  

DE mentioned that ICS2 – Release 2 will be implemented in the major release 
of their national IT-System ATLAS (Releases 10.1) for which the preparatory 
activities have not yet started. The expected deployment date is Q1 2023. 

Med 

Low 

Information not provided. 

Med 

Low 

EE indicated that they have limited resources in the development team. EE is 
applying for financial resources and is planning to start to analyse the process. 
ES explained that they will start with Release 2 once they complete the activities 
for Release 1. They will develop Release 2 through several sprints. 

High  FI noted that preliminary analysis is ongoing. 
Low  FR noted that iterative development will not be used for Release 2. 

Low 

GR  mentioned  that  their  project  is  currently  delayed  in  comparison  to  the 
planning in the 2020 report, but the overall delivery is still expected within the 
deployment deadline. GR is facing a delay due to budget allocation. 

High  HR reported high risk due to a lack of human and financial resources. 
High  None. 
Low 

IE is participating to webinars and is reviewing the relevant documentation. 

Information not provided. 

Low  LT is currently initiating the public procurement procedure for this project. 

LU  explained  that  the  limited  number  of  customs  experts  both  inside  the 
customs administration and available for the software developers is currently 
the biggest risk. Furthermore, the agile development methodology that they are 
using  makes  it  challenging  to  already  give  an  indication  as  to  when  certain 
activities might start. 
LV  plans  to  start  the  development  for  the  transition  from  ICS2  Release  1  to 
Release 2 / Release 3 in 2021. 

Med 

Med 

Low  None. 

The  complexity  is  caused  by  the  large  number  of  external  stakeholders  (e.g. 
carriers,  freight  forwarders  and  their  software  providers),  and  internal 
stakeholders  (e.g.  policy  makers,  risk  analysts,  control  officers)  with  whom 
national requirements need to be defined. Furthermore, NL stressed there are a 
lot  of  projects  running  in  parallel  which  are  using  the  same  development 
expertise. This complexity could cause an impact to all project milestones. The 
starting date for the development is still to be decided. 
PL explained that Release 2 seems more complex than Release 1 because there 
will be a transition period between the two for carriers and Economic Operators 
in addition to more types of Product Disclosure Statements (PDS) lodged. The 
ICS2 implementation date has been postponed to 02/03/2028. 

PT explained that the risk level is due to the implementation of a new import 
system  and  a  lack  of  resources.  PT  explained  that  an  Agile  development 
methodology will be used to help reduce the implementation timeframe. 

Med 

Low 

High 

61 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

RO 

SE 
SI 
SK 

2 

4 
6 
1 

Low 

RO marked the project as delayed in comparison to the planning in the 2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline set in the UCC Work Programme. RO is still developing Release 1 and 
will initiate procurement procedures for Release 2 as soon as possible. 

Med  None. 
Low  SI is preparing technical specifications. 
Low  None. 

Table 26: Detailed responses from Member States – ICS2 – Release 2 

Figure 25 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase11. 

Figure 25: Summary of Survey Responses – ICS2 – Release 2 

ICS2 – Release 3 

Summary from the Commission: 

The aim of the trans-European project on UCC ICS2 Release 3 is to enhance the functional scope of 
ICS2 with support for further modes of transport and implement the complete UCC requirements for all 
‘entry of goods’ use cases building on ICS2 Release 1 and Release 2.  

As a third phase, this release will cover the implementation of new ENS obligations and related business 
and risk management processes for all goods entering the EU by maritime, inland waterways, road and 
rail  traffic  (including  goods  in  postal  consignments  transported  by  these  means  of  transport).  With 
Release 3, all modes of transports are supported. 

The Common Functional  System Specifications were published in Q2 2021.The Common Technical 
Specification is planned to be published by Q4 2021 and development will start in 2022. 

Summary from the Member States: 

Member States are currently focused on Releases 1 and 2. 

Detailed Responses: 

Table 27 provides the individual Member States’ responses to the survey: 

11 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

62 

 
 
 
                                                      
MS 

AT 
BE 
BG 
CY 
CZ 

DE 

DK 
EE 
ES 
FI 
FR 
GR 
HR 
HU 
IE 
IT 
LT 

LU 

LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Complexity 
Rating 
3 

Additional Comments 

Risk 
Level 
Low  None. 

4 
6 
4 

4 

3 
6 
6 
5 
6 
1 
3 
2 

6 

3 

5 
6 
5 
6 
6 
1 
3 
6 
1 

Information not provided. 
Low  Same comments as for ICS2 - Release 1. 
Low  Same comments as for ICS2 - Release 1. 
Med  Same comments as for ICS2 - Release 2. 

Low 

DE mentioned that ICS2 – Release 3 will be implemented in the major release 
of their national IT-System ATLAS (Releases 10.2) for which the preparatory 
activities have not yet started. 

Information not provided. 

Low  EE is planning financial resources. 
Low  ES is currently improving specifications. 
High  None. 
Low  None. 
Low  GR specified that a contract is in place yet there is a delay in budget allocation. 
High  Same comments as for ICS2 - Release 2. 
High  None. 
Low  None. 

Low  None. 

Information not provided. 

Med 

LU  explained  that  the  limited  number  of  customs  experts  both  inside  the 
customs administration and available for the software developers is currently 
the biggest risk. Furthermore, the agile development methodology that they are 
using  makes  it  challenging  to  already  give  an  indication  as  to  when  certain 
activities might start. The conception phase is foreseen to start during 2021. 

Med  Same comments as for ICS2 – Release 2. 
Low  None. 
Med  Same comments as for ICS2 – Release 2. 
Low  PL started a preliminary analysis of the necessary changes to ICS2. 
High  Same comments as for ICS2 – Release 2. 
Low  None. 
Med  None. 
Low  None. 
Low  None. 

Table 27: Detailed responses from Member States – ICS2 – Release 3 

Figure 26 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase12. 

12 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

63 

 
 
                                                      
Figure 26: Summary of Survey Responses – ICS2 – Release 3 

4.1.14  Overview of Project Progress 

Table 28 and Table 29 indicate the percentage of completion as of the end of 2021 in comparison to the 
target dates set forth in the UCC Work Programme.  

The target date set for the technical specifications is in reference to the common technical specifications. 
Member  States  have  reported  the  percentage  of  completion  regarding  their  own  national  technical 
specifications,  which  are  to  be  prepared  incrementally  for  the  three  releases.  The  Commission  will 
perform adjustments to the specifications for Releases 2 and 3 as per the MASP-C. In regards to the 
implementation of ICS2 – Release 2, the following Member State has a planned deployment date that is 
later than the deadline in the UCC Work Programme: MT. 

Table 28: Comparison of Planned and Actual Dates – ICS2 – Release 2 

64 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion European Commission31/09/2020100%01/02/20230%01/03/20230%AT28/02/202290%31/12/20220%01/03/20230%BENot providedNot providedNot providedNot providedNot providedNot providedBG30/12/2020100%15/12/20220%01/03/20230%CY30/06/202180%31/03/20230%01/03/20230%CZ30/06/202280%28/02/20230%01/03/20230%DEN/AN/AN/AN/AN/AN/ADK01/09/2021Not provided14/02/2023Not provided01/03/2023Not providedEE30/06/202215%31/03/20230%01/03/20230%ES01/06/2021100%01/10/20220%01/03/20230%FI01/03/202255%01/10/20220%01/03/20230%FR31/03/2022100%31/12/20220%01/03/20230%GR01/04/202230%Not provided0%Not provided0%HR31/12/202210%31/12/20220%01/02/202310%HU25/11/202075%10/02/20230%01/03/202310%IE31/12/202220%31/01/20230%01/03/20230%ITNot providedNot providedNot providedNot providedNot providedNot providedLT01/03/202290%15/12/20220%01/03/20230%LU01/01/20220%01/02/20230%01/03/20230%LV01/03/202375%01/03/20230%01/03/202375%MT31/05/20220%31/03/20230%31/05/20230%NL31/12/202170%14/02/20230%01/03/20230%PL30/06/2021100%31/12/20220%01/03/20230%PT01/09/202275%01/02/20230%28/02/20230%RONot provided0%Not provided0%Not provided0%SEN/AN/AN/AN/A01/03/20230%SI01/02/202290%18/02/20230%01/03/20230%SKN/A10%N/A0%01/03/20230%Respondee30/06/2018Technical SpecificationsConformance TestingDeployment(Start of the deployment window)01/03/2023 
 
 
 
In regards to the implementation of ICS2 – Release 3, no Member States have a planned deployment 
date that is later than the deadline in the UCC Work Programme. 

Table 29: Comparison of Planned and Actual Dates – ICS2 – Release 3 

4.1.15  Analysis of Progress against Milestones 

Figure  27  and  Figure  28  summarise  the  status  per  milestone  (technical  specifications,  conformance 
testing and deployment). The sum of each bar is 28 (responses from the 27 Member States plus the 
European Commission). 

Figure 27: Summary of Responses per Milestone – ICS2 – Release 2 

65 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion European Commission30/06/20220%01/02/20240%01/03/20240%AT30/11/20220%30/11/20230%01/03/20240%BENot providedNot providedNot providedNot providedNot providedNot providedBG30/12/2021100%15/12/20230%01/03/20240%CY30/06/20220%31/03/20240%01/03/20240%CZ30/06/20230%28/02/20240%01/03/20240%DEN/AN/AN/AN/AN/AN/ADKN/ANot providedN/ANot providedNot providedNot providedEE01/06/20230%01/02/20240%01/03/20240%ES01/06/202280%01/10/20230%01/03/20240%FINot provided0%Not provided0%01/03/20240%FR31/03/20230%31/12/20230%01/03/20240%GR01/04/20230%Not provided0%Not provided0%HR31/12/20230%31/12/20230%01/02/20240%HU30/06/20220%30/11/20220%01/03/20240%IE31/12/20230%31/01/20240%01/03/20240%ITNot providedNot providedNot providedNot providedNot providedNot providedLT01/03/202350%15/12/20230%01/03/20240%LU01/12/20220%15/11/20230%15/12/20230%LV01/03/202475%01/03/20240%01/03/202475%MTN/AN/AN/AN/AN/AN/ANL31/12/202270%14/02/20240%01/03/20240%PLNot provided100%Not provided0%01/03/20240%PT01/09/20230%01/02/20240%29/02/20240%RON/A0%N/A0%N/A0%SEN/AN/AN/AN/A01/03/20240%SI01/02/20230%17/02/20240%01/03/20240%SKN/A0%N/A0%01/03/20240%RespondeeDeployment(Start of the deployment window)Technical SpecificationsConformance Testing30/06/201801/03/2024 
 
 
 
Figure 28: Summary of Responses per Milestone – ICS2 – Release 3 

Regarding ICS2 – Release 2, the following Member States have not yet started: LU, MT and RO. BE, 
DK and IT did not provide percentage of completion information. 

66 

 
 
 
Figure 29: Percentage of Completion per Phase – ICS2 – Release 2 

67 

 
 
 
 
 
 
Regarding ICS2 – Release 3, the only Member States, which have started their technical specifications, 
are BG, ES, LT, LV, NL and PL. DE and MT marked the release as N/A and BE, DK and IT did not 
provide information. 

Figure 30: Percentage of Completion per Phase – ICS2 – Release 3 

68 

 
 
 
 
 
UCC PROOF OF UNION STATUS (POUS) 

4.6 
PoUS is a new trans-European system, which is designed to allow storage, management and retrieval of 
certain types of documents (e.g. T2L, T2L/F, customs goods manifest) that traders provide to prove the 
Union  status  of  their  goods.  The  system  will  improve  the  uniformity  of  the  procedures  across  the 
European  Union  and  contribute  to  the  establishment  of  a  more  consistent,  harmonised  and  thus 
simplified process related to customs clearance for Union goods.  

A system will be created that will include a Central Repository for the storage and exchange between 
Customs Authorities across all Member States of data and documents dealing with proof of Union status. 

The project is split into two phases: 

• Implementing the electronic T2L (F) document with all the necessary functionalities (planned 
deployment 01/03/2024); 

•  Implementing  the  electronic  Customs  Goods  Manifest  (CGM),  including  the  information 
exchange  with  the  European  Maritime  Single  Window  environment  (planned  deployment 
02/06/2025). 

4.1.16  Summary of Responses 

PoUS – Phase 1 

Summary from the Commission: 

The Commission reported that the  Vision Document and the Architecture Overview for both phases 
were approved by the Member States in Q3 2020. The Level 3 and Level 4 BPMs for Phase 1 were 
updated and accepted by the Member States in March 2020. Three separate external review packages 
were launched in 2021. As soon as the technical documentation is approved (estimated around February 
2022), Member States will be able to start development to connect with the central system. An agile-
like development approach is  being used for the project. The project is progressing according to the 
planning set by the UCC Work Programme.  

Summary from the Member States: 

Member  States  have  the  option  of  using  the  central  PoUS  system  or  developing  their  own  national 
application.  Several  Member  States  conveyed  their  intention  to  use  the  system  developed  by  the 
European Commission: AT, BE, BG, CY, CZ, DE, DK, FR, HR, IE, LT, LU, NL, PT, RO, SE, SI and 
SK. ES and PL indicated that they would use a national system. 

Detailed Responses: 

Table 30 provides the individual Member States’ responses to the survey: 

MS 

AT 
BE 
BG 

CY 

CZ 

Complexity 
Rating 
3 

Additional Comments 

Risk 
Level 
Low  AT explained that no activities are planned for 2021. 

3 

6 

3 

Low  None. 

Information not provided. 

CY explained that the complexity is caused by dependencies with other systems, 
the  high  availability  requirements  and  limited  human  resources.  The 
development approach will be decided in cooperation with the contractor. The 
national planning is not yet stable and is dependent on the details in the future 
contract.  
CZ explained that the application, service and technical specifications are not 
yet available. They are unable to predict if they will have time to implement as 
per the deadlines in the UCC WP. 

Low 

Med 

69 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

DE 

DK 
EE 

ES 

FI 
FR 
GR 

HR 

HU 
IE 

IT 

LT 

LU 

LV 
MT 

NL 

4 

3 
2 

3 

3 

5 

5 

3 
2 

2 

3 

1 

2 

3 

Low 

DE  noted  that  this  project  will  be  implemented  as  part  of  their  national  IT-
System ATLAS – Release 10.2. The preparatory activities have not yet started. 
The expected date of deployment is March 2024. 

Med  None. 
Low  None. 

Med 

ES noted that the replication system needs to be implemented efficiently, this 
could  be  a  risk.  ES  will  use  iterative  development.  Their  planning  remains 
indicative at this stage. 

Low  None. 

Low  GR is facing a delay with budget allocation. 

Information not provided. 

Med 

HR will use the centrally developed solution. HR further iterated that TS and 
CT might be affected due to a lack of human resources. Many EU projects have 
to be carried out simultaneously by the same staff. 

Low  None. 
Low 

Med 

Low 

Low 

IE will use the centrally developed solution. 
IT  identified  a  risk  pertaining  to  the  economic  operators,  underlining  that 
requests for change might arise later in the process due to their lack of readiness. 
LT will use the centrally developed solution. At the national level, the following 
tasks will need to be completed: establishing an interface with the national risk 
management system, translation of user interfaces and user manuals and user 
training. LT representatives take part in the PoUS project group activities. 

LU  explained  that  due  to  the  very  limited  use  of  PoUS  by  the  economic 
operators (less than 20 per year), they will use the centrally developed system. 
LU will advise their economic operators  to create the PoUS needed by them 
through the solution provided by the Commission. 

Low  LV will use the centrally developed solution. 

Information not provided. 

Med 

NL explained that no activities are planned for 2021. NL noted that there are a 
large number of external stakeholders and that it will be necessary to have a 
communication campaign to inform them. NL also stressed there are a lot of 
projects running in parallel which are using the same development expertise.  

PL 

5 

 Med 

PT 

RO 

5 

2 

High 

PL  marked  the  project  as delayed  in  comparison  to  the  planning  in the  2020 
report,  but  the  overall  delivery  date  is  still  expected  within  the  deployment 
deadline set in the UCC  Work  Programme. As of 10/09/2018, their National 
Revenue Administration implemented the new e-service called “e-Status”. The 
e-Status allows for electronic authentication of T2L/T2LF data by exchange of 
XML  messages  in  the  national  Automated  Export  System/STATUS  (the 
AES/STATUS). However, the new PoUS System is planned to be implemented 
in 2024 as new contracts have already been signed. It covers the deployment of 
a  new  PoUS  System.  The  most  important  impact  on  the  delivery  and 
implementation of products is the lack of technical documentation at the central 
level.  Another  factor  is  the  necessity  to  connect  the  PoUS  System  with  new 
national  systems  created  simultaneously 
the  country.  An  iterative 
development methodology will be used. 
PT will use the centrally developed and operationalised system. PT explained 
that the milestone most at risk is CT. Agile development will be used to reduce 
the implementation timeframe.  

in 

Low  RO explained that they will use the centrally developed solution. 

70 

 
 
MS 

SE 

SI 

SK 

Complexity 
Rating 
3 

Additional Comments 

Risk 
Level 
Low  None. 

4 

1 

Low 

SI explained that their planning takes into consideration delays caused by the 
ongoing review of documents and the phased approach.  

Med  None. 

Table 30: Detailed responses from Member States – PoUS – Phase 1 

Figure 31 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase13. 

Figure 31: Project Status as per Survey – PoUS – Phase 1 

PoUS – Phase 2 

Summary from the Commission: 

The functional specifications and the L4 BPMs for the Customs Goods Manifest, PoUS Phase 2 were 
developed and accepted by the MSs with written procedure on 21 June 2021. 

Summary from the Member States: 

Please see the summary from PoUS – Phase 1. Additionally, AT explained that PoUS – Phase 2 is not 
relevant for them. 

Detailed Responses: 

Table 31 provides the individual Member States’ responses to the survey: 

MS 

AT 
BE 
BG 
CY 
CZ 

DE 

DK 

Complexity 
Rating 
N/A 

Additional Comments 

Risk 
Level 
N/A  AT explained that PoUS – Phase 2 is not relevant for them. 

3 
6 
3 

4 

Information not provided. 

Low  None. 
Low  Same comments as for PoUS – Phase 1. 
Med  Same comments as for PoUS – Phase 1. 

Low 

DE  noted  that  this  project  will  be  implemented  as  part  of  their  national  IT-
System ATLAS. The preparatory activities have not yet started. 

Information not provided. 

13 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

71 

 
 
 
                                                      
MS 

EE 
ES 

FI 

FR 
GR 
HR 
HU 
IE 
IT 

LT 

LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Complexity 
Rating 
2 
3 

Additional Comments 

Risk 
Level 
Low  EE started analysing the processes. 
Med  Same comments as for PoUS – Phase 1. 

4 

5 
5 
3 
2 
2 

3 

1 

3 
5 
5 
2 
3 
5 
1 

Low 

FI explained that they intend to only implement the integration to the central 
PoUS. 

Information not provided. 
Low  Same comments as for PoUS – Phase 1. 
Med  Same comments as for PoUS – Phase 1. 
Low  None. 
Low  Same comments as for PoUS – Phase 1. 
Med  Same comments as for PoUS – Phase 1. 

Low 

LT will use the centrally developed solution. LT representatives participate in 
the PoUS project group activities. The L4 BPMs and functional requirements 
are planned to be completed by Q2 2021. 
Low  Same comments as for PoUS – Phase 1. 
Information not provided. 
Information not provided. 
Med  Same comments as for PoUS – Phase 1. 
Med  Same comments as for PoUS – Phase 1. 
High  Same comments as for PoUS – Phase 1. 
Low  Same comments as for PoUS – Phase 1. 
Low  None. 
Low  None. 
Med  None. 

Table 31: Detailed responses from Member States – PoUS – Phase 2 

Figure 32 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase14. 

Figure 32: Project Status as per Survey – PoUS – Phase 2 

14 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

72 

 
 
 
                                                      
4.1.17  Overview of Project Progress 

Table 32 and Table 33 highlight any known divergences in the planning compared to the dates set in the 
Work Programme. In regards to the implementation PoUS – Phase 1, the following Member States have 
a planned deployment date that is later than the deadline in the UCC Work Programme: CZ and HU. 

Table 32: Comparison of Planned and Actual Dates – PoUS – Phase 1 

In regards to the implementation PoUS – Phase 2, no Member States have a planned deployment date 
that is later than the deadline in the UCC Work Programme. 

73 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion European Commission31/03/202280%29/02/20240%01/03/20240%AT01/08/20220%01/08/20230%01/12/20230%BENot providedNot providedNot providedNot providedNot providedNot providedBG12/12/20220%29/02/20240%01/03/20240%CY01/03/20220%31/12/20230%01/03/20240%CZ01/02/202250%30/03/20240%30/03/20240%DEN/AN/AN/AN/AN/AN/ADKNot provided0%Not provided0%Not provided0%EE31/03/20220%N/A0%01/03/20240%ES30/09/20220%28/02/20240%01/03/20240%FINot provided0%Not provided0%01/03/20230%FR31/03/2023Not provided31/12/2023Not provided01/03/2024Not providedGR30/06/20220%31/10/20230%01/03/20240%HR31/03/20230%31/12/20230%01/03/20240%HU31/12/20210%01/05/20250%01/06/20250%IEN/AN/AN/AN/A01/01/2024N/AITNot provided0%Not provided0%Not provided0%LTNot providedNot providedNot providedNot providedNot providedNot providedLUN/AN/A01/03/20240%N/AN/ALVN/AN/AN/AN/AN/AN/AMTNot providedNot providedNot providedNot providedNot providedNot providedNL01/02/20220%01/03/20240%01/03/20240%PLNot providedNot providedNot providedNot providedNot providedNot providedPT01/06/20230%01/12/20230%01/03/20240%RON/AN/AN/AN/AN/AN/ASENot provided0%Not provided0%01/03/20240%SI01/01/20220%20/02/20240%01/03/20240%SK31/03/20220%01/01/20240%01/03/20240%RespondeeTechnical SpecificationsConformance TestingDeployment30/06/202201/03/2024 
 
 
Table 33: Comparison of Planned and Actual Dates – PoUS – Phase 2 

4.1.18  Analysis of Progress against Milestones 

Figure  33  and  Figure  34  summarise  the  status  per  milestone  (technical  specifications,  conformance 
testing and deployment). The sum of each bar is 28 (responses from the 27 Member States plus the 
European Commission). 

Figure 33: Summary of Responses per Milestone – PoUS – Phase 1 

74 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion European Commission30/06/20230%02/06/20250%02/06/20250%ATN/AN/AN/AN/AN/AN/ABENot providedNot providedNot providedNot providedNot providedNot providedBG20/12/20230%30/05/20250%02/06/20250%CY01/06/20230%31/03/20250%02/06/20250%CZ01/04/20230%30/06/20250%02/06/20250%DEN/AN/AN/AN/AN/AN/ADKNot providedNot providedNot providedNot providedNot providedNot providedEE31/03/20240%N/A0%02/06/20250%ES31/01/20240%01/06/20250%02/06/20250%FINot provided0%Not provided0%02/06/20250%FR30/06/2024Not provided31/03/2025Not provided02/06/2025Not providedGR31/12/20230%01/10/20240%01/03/20250%HR31/12/20230%31/12/20240%31/05/20250%HU31/12/20220%01/05/20250%02/06/20250%IEN/AN/AN/AN/A01/01/2025N/AITNot provided0%Not provided0%Not provided0%LTNot providedNot providedNot providedNot providedNot providedNot providedLUN/AN/A01/03/20250%N/AN/ALVNot providedNot providedNot providedNot providedNot providedNot providedMTNot providedNot providedNot providedNot providedNot providedNot providedNL01/07/20230%01/06/20250%02/06/20250%PLNot providedNot providedNot providedNot providedNot providedNot providedPT01/06/20240%01/03/20250%02/06/20250%RON/AN/AN/AN/AN/AN/ASENot provided0%Not provided0%02/06/20250%SI01/03/20230%30/05/20250%02/06/20250%SK31/03/20230%02/06/20250%02/06/20250%RespondeeTechnical SpecificationsConformance TestingDeployment30/06/202202/06/2025 
 
 
 
Figure 34: Summary of Responses per Milestone – PoUS – Phase 2 

Regarding PoUS – Phase 1, the only Member State which has started their technical specifications is 
CZ. BE, FR, LU, MT and PL did not provide percentage of completion information. DE, LV and RO 
marked PoUS – Phase 1 as Not Applicable. 

75 

 
 
 
Figure 35: Percentage of Completion per Phase – PoUS – Phase 1 

76 

 
 
 
 
 
 
 
Regarding PoUS – Phase 2, no Member States have started their technical specifications yet. AT, DE, 
HU, IE and RO marked the release as N/A. BE, DK, FR, HU, LT, LU, LV and MT did not provide 
information. 

Figure 36: Percentage of Completion per Phase – PoUS – Phase 2 

77 

 
 
 
 
 
UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) 

4.7 
The UCC Centralised Clearance for Import (CCI) project aims to allow for goods to be placed under a 
customs procedure using centralised clearance, enabling economic operators to centralise their business 
from a customs point of view. The processing of the customs declaration and the physical release of the 
goods will be coordinated between the related customs offices. 

The implementation of the concept of Centralised Clearance for Import by a new trans-European System 
will strengthen the trade facilitation by enabling economic operators with the “centralisation” of their 
business related to import and the reduction of the interactions with customs by using the customs office 
of supervision as the main contact partner. In addition, the new CCI system will introduce harmonisation 
and standardisation of processes and electronic exchange of information across the Union for centralised 
clearance  at  import.  It  is  also  expected  to  reduce  the  administrative  burden  for  the  customs 
administration  with  automated  processes  and  to  allow  tax  authorities  to  have  better  supervision  and 
control on the collection of import VAT. 

In  terms  of  the  planning  approach,  as  a  trans-European  system,  the  project  contains  components 
developed centrally and nationally. The project will be implemented in two phases.  

Phase 1 will cover the combination of centralised clearance with standard customs declarations and with 
simplified  customs  declarations  and  related  supplementary  declarations  (which  regularise  simplified 
customs  declarations).  In  addition,  this  phase  will  cover  the  placing  of  goods  under  the  following 
customs procedures: release for free circulation, customs warehousing, inward processing and end-use. 
In regards to the types of goods involved, this phase will cover all types of goods with the exception of 
excise goods and goods subject to common agricultural policy measures.  

Phase 2 will cover everything that is not covered by Phase 1, namely: 

  The  combination  of  centralised  clearance  with  customs  declarations  through  an  entry  in  the 
declarant’s records and related supplementary declarations, including the recapitulative one; 

  Supplementary declarations regularising more than one simplified customs declaration; 
  The placing of goods under the temporary admission procedure; 
  Goods subject to common agricultural policy measures and excise goods; 
  Goods in the context of trade with special fiscal territories; 
  The communication of supporting/additional documents between the related customs offices.  

4.1.19  Summary of Responses 

Summary from the Commission: 

The Business Case, Vision Document, L4 BPMs, Functional System Specifications (FSS) and Technical 
Systems Specifications (TSS) have been approved, including an updated package of CCI Phase 1 TSS 
documentation approved in 2021 under the change mangement procedure. The system development has 
started.  The  planned  deployment  date  for  forerunner  Member  States  is  1  March  2022.  These 
“forerunner”  Member  States  have  been  identified  to  work  closely  with  the  Commission  for  the 
development activities and with a view to start operations soon after the start of the deployment window 
planned for the project in the UCC Work Programme.  

CCI  is  the  first  trans-European system  using  the  new  network  architecture,  CCN2ng.  Other  projects 
supporting conformance testing activities need to be aligned with the new architecture and approach. 
Currently, all Phase 1 activities are synchronised and managed between the various responsible project 
teams. A number of technical documents for Phase 2 have been approved internally in DG TAXUD in 
preparation for publication as part of a package for approval by Member States in 2022. 

Summary from the Member States: 

Most Member States are analysing the technical and functional specifications and some have cited that 
there  may  be  a  risk  in  meeting  the  CT  and  deployment  milestones.  Many  Member  States  have 
commented that the planning is tight in the context of import systems. In addition to the complexity of 
the project, other reasons for potential delay are given such as human and financial resource constraints, 

78 

 
 
impact  and  re-planning  due  to  the  VAT  eCommerce  package15  and  also  the  specific  working 
circumstances caused by the COVID-19 pandemic. 

Detailed Responses: 

Table 34 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

5 

4 

6 

6 

5 

3 

6 

6 

6 

4 

Med 

Low 

Low 

Low 

Low 

AT explained that they are preparing their technical specifications. The 
milestones most at risk are CT and deployment. The timing is tight in the 
context of import systems. 
BE explained that the implementation period for the project is intense due 
to  a  number  of  IT  systems  that  need  to  be  implemented  in  the  same 
timeframe.  BE  is  currently  performing  analysis  on  the  functional  and 
technical specifications. 
BG noted that this project will be implemented jointly with a project to 
align the national import system with the data requirements in Annex B 
of the Commission Delegated Regulation (EU) 2015/2446 as amended by 
Delegated Regulation (EU) 2021/234. 
CY explained that the complexity is caused by dependencies with other 
systems, the high availability requirements and limited human resources. 
The  development  approach  will  be  decided  in  cooperation  with  the 
contractor. The national planning is not yet stable and is dependent on the 
details in the future contract.  

Information not provided. 

DE noted that this project will be implemented as part of their national IT-
System ATLAS – Release 10.2. The preparatory activities have not yet 
started. The expected date of deployment is in September 2024. Due to 
the  requirements  from  the  VAT  eCommerce  Package,  DE  had  to  push 
back all future planning. 

Low  None. 

Low 

Med 

High 

Med 

EE noted that the requirements of CCI will be taken into consideration 
during the development of their national import declaration system. 
ES explained that the high complexity rating is because there is no history 
of  a Trans-European  system  for  import  and  this  project requires  strong 
coordination  between  countries.  ES  will  use  an  agile/iterative 
development methodology. Lastly, ES is a forerunner for this project and 
their planning has been aligned with the project agreements. 

FI noted that this project will not be started in 2021. 
FR marked the project as delayed compared to the planning in the 2020 
report,  however  the  overall  delivery  is  still  expected  within  the 
deployment deadline set in the UCC Work Programme. The review of the 
national  import  applications  has  increased  the  complexity  and  need  for 
additional  human  resources.  Furthermore,  there  are  numerous  projects 
ongoing  in  parallel  that  are  utilising  shared  resources.  FR  is  currently 
progressing on the technical and functional specifications. 
GR  noted  risks  related  to  a  lack  of  personnel,  having  many  projects 
running  simultaneously  and  delay  with  budget  allocation.  According  to 
their planning, GR should have a contract in place by the end of 2021. 

GR 

6 

Med 

15 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33) 

79 

 
 
                                                      
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

HR 

HU 

IE 

IT 
LT 

LU 

6 

5 

5 

3 
6 

6 

High 

Med 

Low 

Med 
Low 

Low 

LV 

6 

High 

HR explained that the project is very complex and human resources are 
limited. Many team members are involved in other MASP and national 
projects  in  parallel.  Furthermore,  the  COVID-19  pandemic  has  added 
additional pressure. 
HU highlighted that a potential lack of  human resources may impact the 
timely  completion of the technical specifications. HU further explained 
that the IT development done for eCommerce will be used as a basis for 
the national import system which will ultimately be the basis of CCI. 
IE noted that this project is at an early stage with technical specifications 
expected to be published at the end of Q3 2021. 
IT noted that they are working on the technical specifications. 
LT explained that they are working on the technical specifications. 
At the time of writing, LU marked the project as delayed in comparison 
to  the  planning  in  the  2020  report,  but  the  overall  delivery  date  is  still 
expected  within  the  deployment  deadline  set  in  the  UCC  Work 
Programme.  LU  explained  that  the  call  for  tender  took  more  time  than 
initially foreseen. 
At the time of writing, LV marked the project as delayed in comparison 
to  the  planning  in  the  2020  report,  but  the  overall  delivery  date  is  still 
expected  within  the  deployment  deadline  set  in  the  UCC  Work 
Programme.  LV  explained  that  their  financial  resources  were  only 
approved  during  Q3  2020.  Furthermore,  they  need  to  create  new  IT 
systems  which  can  be  integrated  since  the  current  ones  cannot  be 
upgraded, scaled-up or integrated with each other. LV continued stating 
that they need to adapt other systems like those for risk management and 
statistics  and  integrate  with  other  systems  and  Trade.  A  procurement 
process is ongoing to allocate the IT development activities before the end 
of 2021. There is a risk of delay with hand-over/take-over activities. Some 
mitigating  actions  are  to  break  the  project  up  into  several  stages  and 
prioritise a core scope, use agile development and do testing step-by-step. 

MT 

NL 

PL 

PT 

RO 
SE 

6 

4 

5 

6 

6 
4 

Med  None. 

Low 

Med 

Low 

NL explained that they are using an agile development approach and that 
they are currently describing features. 
PL noted that CT has been delayed by three quarters and deployment by 
one.  The  risks  pertain  to  the  COVID-19  pandemic  and  its  impact  on 
financial  and  human  resources.  PL  explained  that  this  project  will  be 
developed and implemented within their National Import System. Lastly, 
PL  iterated  that  the  development  of  this  system  is  linked  to  the 
development of all national, central and other Member States’ systems, 
which increases the interdependencies and the complexity of the “global 
system”.  
PT  explained  that  the  risk  level  is  due  to  the  implementation  of  a  new 
system  and  a  lack  of  resources.  PT  stated  that  an  Agile  development 
methodology will be used to help reduce the implementation timeframe. 

Low  RO noted that they are working on the technical specifications. 
Med  None. 

80 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

SI 

6 

Med 

SK 

2 

Med 

SI  noted  the  high  complexity  rating  as  the  project  will  include  47 
electronic  messages  and  16  BPMs.  The  financial  and  social  situation 
depend on the situation with the COVID-19 pandemic. It is difficult  to 
predict how many people will be able to work smoothly on this project, 
both from the customs administration and from the IT contractor’s side. 
SI explained that they need to implement a new import declaration system 
by 01/06/2021 after which they will actively engage in CCI. 
SK’s project is delayed in comparison to the planning in the 2020 report, 
but the overall delivery is still expected within the deployment deadline 
stated in the UCC Work Programme. They have identified risks related to 
a lack of human and financial resources. No mitigation actions have been 
considered at this moment in time. 

Table 34: Detailed responses from Member States – CCI – Phase 1 

Figure 37 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase16. 

Figure 37: Summary of Survey Responses – CCI – Phase 1 

CCI – Phase 2 

Summary from the Commission: 

The Business Case document for Phase 2 was completed and approved during Q3 2019. The package 
of  L4  BPMs  and  functional  specifications  was  created  and  approved  by  Member  States  and  Trade 
Contact Group in August 2020. The Vision Document and Architecture Overview were approved in Q4 
2020. Representatives of 10 Member States17 have been actively involved in the CCI Phase 2 project 
group,  identifying  and  developing  proposals  for  the  processes  and  the  new  functionalities  to  be 
implemented. The business processes and functional specifications for Phase 2 were approved during 
2020 and the technical specifications are expected by June 2022 in view of the planned date for starting 
the deployment window for initial MSs in October 2023. 

Summary from the Member States: 

Please see the summary from CCI Phase 1. 

Detailed Responses: 

16 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 
17  AT, BE, CZ, DE, DK, ES, FI, FR, NL and PT. 

81 

 
 
 
                                                      
Table 35 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 
4 

Additional Comments 

Risk 
Level 
Low  None. 

MS 

AT 

BE 

BG 
CY 
CZ 

DE 

DK 
EE 
ES 
FI 

FR 

GR 

HR 
HU 
IE 
IT 
LT 

LU 

LV 
MT 

NL 

PL 

5 

5 
6 

5 

6 
6 
6 

4 

6 

6 

5 
5 
6 

5 

5 
6 

5 

6 

Low 

BE commented that the procedures to be implemented in CCI – Phase 2 
are more complex than the ones in Phase 1. 

Low  None. 
Low 

Same comments as for CCI – Phase 1. 

Information not provided. 

Low 

DE noted that this project will be implemented as part of their national IT-
System ATLAS – Release 10.3. The preparatory activities have not yet 
started.  The  expected  date  of  deployment  is  Q3/Q4  2025.  Due  to  the 
requirements from the VAT eCommerce Package, DE had to push back 
all future planning. 

Information not provided. 

Low  None. 
Med 
High 

ES will also be a forerunner for CCI – Phase 2. 
Same comments as for CCI – Phase 1. 
FR is currently working on a national review regarding topics such as an 
Entry in the Declarant’s Records (EIDR) solution. 
GR mentioned that their project is currently delayed in comparison to the 
planning in the 2020 report, but the overall delivery is still expected within 
the deployment deadline. GR is facing a delay due to budget allocation. 

Low 

Low 

High 

Same comments as for CCI – Phase 1. 

Information not provided. 

Low  None. 
Med  None. 
Low 

Low  None. 
Low  None. 

Med 

Low 

Med 

Same comments as for CCI – Phase 1. 
LU explained that the call for tender was launched in 2020. The limited 
number  of  customs  experts  both  inside  the  customs  administration  and 
available for the software developers is currently the biggest risk. 

NL explained that they are using an agile development approach and that 
they are currently describing the features based on the DDNCA. 
Same comments as for CCI – Phase 1. 
PT  explained  that  the  risk  level  is  due  to  the  implementation  of  a  new 
system and a lack of resources. This project phase will treat all the matters, 
which were left outside of phase 1 due their complexity. This project will 
be developed and implemented "inside" of the National Import System. 
Since this system is a highly complex system, the integration of  CCI – 
Phase 2 will be also complex. The development of this system, is not only 
related with the system itself, but it is also related to the development of 
all  national,  central  and  other  MS´s  systems/modules,  national  and  EU 
entities  connections,  which  increases  the  inter-dependencies  and  the 
complexity of the “global system.  PT stated that an Agile development 
methodology will be used to help reduce the implementation timeframe. 

PT 

6 

Low 

RO 
SE 
SI 

6 
4 
6 

Low  None. 
Med  None. 
Med 

Same comments as for CCI – Phase 1. 

82 

 
 
MS 

SK 

Complexity 
Rating 
2 

Risk 
Level 
Med 

Additional Comments 

Same comments as for CCI – Phase 1. 

Table 35: Detailed responses from Member States – CCI – Phase 2 

Figure 38 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase18. 

Figure 38: Summary of Survey Responses – CCI – Phase 2 

4.1.20  Overview of Project Progress 

Table 36 and Table 37 highlight any known divergences in the planning compared to the dates set in the 
Work  Programme.  As  this  project  has  a  deployment  window,  the  ‘Deployment’  and  ‘Operations’ 
columns are shown. If there is a difference in these two dates, this implies that a migration period is 
planned.  

Regarding CCI – Phase 1, the following Member State has a planned deployment and operations date 
that is later than the deadline in the UCC Work Programme: DE. DE has indicated that experience with 
the implementation of eCommerce and the new UCC systems for AES and NCTS Phase 5 has shown 
that the current architecture and infrastructure of the national import system is not sufficient and requires 
a  fundamental  renewal  and  modernisation  in  order  to  meet  the  requirements  of  UCC  (CCI).  The 
implementation plans take into account the simultaneous deployment of CCI Phase 1 and Phase 2 in a 
new import system. A completely new application will be developed based on the new and harmonised 
EU Customs Data Model and the European Commission specifications. The work will be carried out 
with the involvement of external IT support services and developed using the agile method in order to 
increase transparency and development speed, proactively minimise possible risks and misdevelopments 
in the process and thus lead to a faster deployment of CCI. The necessary resources are available for 
this purpose. With this approach, DE is convinced that it has taken all necessary remedial measures to 
ensure the simultaneous implementation of CCI Phase 1 and Phase 2 at the latest by September 2024 
which is within the deployment window for Phase 2. The specific date can be found in Table 36 below.  

18 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

83 

 
 
 
                                                      
Table 36: Comparison of Planned and Actual Dates – CCI – Phase 1 

84 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateEuropean Commission09/10/2020100%30/11/20230%01/03/20220%01/12/2023AT01/02/202170%01/06/20220%01/06/20220%01/12/2022BE01/01/202125%31/08/20230%09/01/20230%12/01/2023BG15/12/2021100%29/09/20230%27/11/20230%27/11/2023CY01/10/202180%01/06/20230%01/09/20230%01/10/2023CZ01/06/2022Not providedNot providedNot provided01/06/2023Not provided01/06/2023DE30/06/20230%31/03/20240%30/09/20240%30/06/2025DK01/01/202250%01/08/20230%01/08/20230%01/12/2023EE01/10/2022100%30/06/20230%01/10/20230%01/10/2023ES30/03/2021100%30/09/20220%01/10/20220%01/04/2023FI31/12/20220%31/12/20230%31/12/20230%01/12/2023FR30/09/2021100%Not provided0%30/09/20220%01/12/2023GR30/09/20220%31/12/20220%31/12/20220%31/12/2022HR30/06/202220%01/04/20230%01/12/20230%01/12/2023HU30/09/202015%01/11/202310%01/12/20230%01/12/2023IE07/10/2022100%08/09/20230%08/09/20230%09/10/2023IT01/10/202020%30/09/20230%01/03/20220%01/12/2023LT01/03/202210%30/09/20230%01/12/20230%01/12/2023LUNot provided0%01/04/20230%01/04/20230%01/04/2023LV01/10/20220%08/09/20230%10/09/20230%25/09/2023MT01/01/202125%31/05/20220%01/08/20220%01/08/2022NL22/06/2021100%01/12/20235%01/12/20230%01/12/2023PL01/02/2022100%30/07/20220%01/09/202310%01/09/2023PT15/12/202250%15/10/20230%01/12/20230%01/12/2023RO30/06/202350%31/12/20230%Not Provided0%01/12/2023SENot provided0%Not provided0%01/10/20230%Not ProvidedSI01/03/20210%20/11/20230%01/12/20230%01/12/2023SK01/12/20220%01/12/20230%01/12/20230%01/12/2023Conformance TestingDeployment(Start of the deployment window)Technical Specifications30/09/2020Respondee01/03/2022Operations(End of the deployment window)01/12/2023 
 
 
  
 
 
 
For the implementation of CCI – Phase 2, DE’s planned deployment date in Table 37 is one month later 
than the target date set in the  UCC WP and they will be providing a migration period which runs to 
30/06/2026. DE explained that this project will be implemented in the major release of their national IT-
System ATLAS (Release 10.3) for which the preparatory activities have not yet started. Subsequent to 
the collection of the data in Table 37, DE has indicated that it intends to deploy Phase 2 in Q4 2024 
which is well within the deployment window laid down in the UCC Work Programme. This info was 
provided to the Commission just before finishing the report and is not reflected in the table below which 
reflects the outcome of the survey. 

Table 37: Comparison of Planned and Actual Dates – CCI – Phase 2 

4.1.21  Analysis of Progress against Milestones 

Figure  39  and  Figure  40  summarise  the  status  per  milestone  (technical  specifications,  conformance 
testing and deployment). The sum of each bar is 28 (responses from the 27 Member States plus the 
European Commission). 

Figure 39: Summary of Responses per Milestone – CCI – Phase 1 

85 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateEuropean Commission30/06/202290%15/07/20230%02/10/20230%02/06/2025AT01/05/20230%01/09/20240%01/09/20240%01/03/2025BENot provided0%Not provided0%Not provided0%Not providedBG09/01/20230%24/03/20250%14/04/20250%14/04/2025CY01/02/20230%01/12/20240%06/01/20250%01/03/2025CZ01/06/2023Not providedNot providedNot provided01/02/2025Not provided01/02/2025DE30/06/20240%31/03/20250%30/06/20250%30/06/2026DK01/02/2024Not provided01/01/2025Not provided01/01/2025Not provided01/03/2025EE31/12/20230%31/12/20240%31/03/20250%31/03/2025ES30/09/20220%30/09/20240%01/10/20240%01/04/2025FI31/12/20240%30/06/20250%30/06/20250%02/06/2025FR31/03/20230%Not provided0%31/12/20240%31/12/2024GR31/12/20220%31/12/20240%31/03/20250%31/03/2025HR30/06/20230%01/02/20250%01/03/20250%01/03/2025HU30/06/2022Not provided01/05/2025Not provided01/06/2025Not provided01/06/2025IE07/10/20230%08/09/20240%08/09/20240%09/11/2024IT01/01/202310%31/12/20240%01/03/20250%01/06/2025LT01/03/20230%02/05/20250%01/06/20250%01/06/2025LUNot provided0%01/01/20250%01/01/20250%01/01/2025LV01/04/20240%20/02/20250%23/03/20250%23/03/2025MT01/01/20230%31/05/20240%01/08/20240%01/08/2024NLNot providedN/ANot provided0%Not provided0%01/06/2025PL30/09/20230%01/01/20250%01/06/20250%01/06/2025PT01/06/20240%15/04/20250%01/06/20250%01/06/2025RO30/06/20240%30/06/20250%Not provided0%02/06/2025SENot provided0%Not provided0%01/10/20240%Not providedSI01/10/20230%20/05/20250%01/06/20250%01/06/2025SK01/06/20230%01/06/20250%02/06/20250%02/06/2025Operations(End of the deployment window)02/06/2025Technical Specifications30/06/202202/10/2023Deployment(Start of the deployment window)Conformance TestingRespondee 
 
 
 
Figure 40: Summary of Responses per Milestone – CCI – Phase 2 

Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
41. 

Regarding CCI – Phase 1, the following Member States have not yet started: DE, FI, GR, LU, LV, SE, 
SI and SK. The following Member State did not provide percentage of completion information: CZ. 

86 

 
 
 
Figure 41: Percentage of Completion per Phase – CCI – Phase 1 

Regarding CCI – Phase 2, the only Member State, which has started their technical specifications is IT. 
The following Member States did not provide percentage of completion information: CZ, DK and HU.  

87 

 
 
 
 
Figure 42: Percentage of Completion per Phase – CCI – Phase 2 

88 

 
 
 
 
 
 
UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE 
4.8 
The  aim  of  this  project  is  to  align  the  existing  trans-European  New  Computerised  Transit  System 
(NCTS) to the UCC legal provisions. The scope of the project includes the alignment of information 
exchanges to UCC data requirements, the upgrade and development of interfaces with other systems 
such as AES in addition to new safety and security requirements. 

In terms of the planning approach, the project is divided into two components. Component 1, the ‘NCTS-
Phase 5 (P5)’ includes steps to upgrade and extend the current NCTS processes in alignment with UCC 
legal  provisions,  to  introduce  new  processes  such  as  the  pre-lodgement  of  Customs  declarations,  to 
provide for the registration of ‘en-route’ events, align information exchanges to UCC data requirements 
and  the  upgrade  and  development  of  interfaces  with  other  systems.  The  system  includes  some 
components to be developed centrally but the main components are to be developed at the national level. 

NCTS – Component 1 will meet the following objectives19: 

  Data harmonisation across customs domains (import, export, transit) – New Customs EU Data 

Model; 

  Harmonisation in the external domain resulting in trade facilitation; 
 
Interoperability across customs and taxation/excise; 
  Alignment to operational practices for export and transit; 
  Business continuity and facilitation of the transition for national administrations and Trade; 
  New  IT  architecture  for  customs  trans-European  systems  for  Member  States  and  Common 

Transit Convention (CTC) countries. 

Additionally, NCTS – Component 1 will improve the following processes: 

  Transit guarantees monitoring; 
  The enquiry process; 
  Business statistics for transit: The current collection of business statistics will be optimised in 

order to ensure support of measurements of the Customs Union Performance system; 

  Strengthen the safety and security for entry/exit. 

Lastly, a number of new functionalities are being incorporated: 

  Transit declaration pre-lodgement; 
  Lodgement of transit declaration with reduced data-set; 
  Management of ‘en route’ incidents; 
  Export process followed-up by the transit TES and better monitoring of trade flows. 

Component 2, the ‘NCTS-Phase 6 (P6)’, aims to include potential new requirements in the field of safety 
and security data elements in transit customs declarations. These requirements relate to goods brought 
into the customs territory of the Union and are also incorporated in the UCC Import Control System 
Upgrade 2 (ICS2).  

4.1.22  Summary of Responses 

NCTS – Component 1 

Summary from the Commission: 

The  Commission  and  the  MSs’  customs  authorities  launched  an  important  transition  for  the  trans-
European customs systems for export and transit, starting with the successful deployment of the new 
UCC NCTS-Phase 5 and UCC AES IT systems in DE in March 2021. This opened the path to the next 
generation of interconnected trans-European systems for the trade community and the national customs 
authorities.  The  new  export  and  transit  systems  offer  significant  benefits  and  enable  simplifications 
while  ensuring  the  business  continuity  with  the  systems  in  operation  so  far.  This  important  UCC 

19 The same objectives will also be met by UCC Automated Export System (AES) – Component 1. 

89 

 
 
                                                      
milestone has been achieved thanks to the close collaboration between the Commission and the national 
customs and trade associations.  

The Commission highlighted in its ‘Overview of the Customs Information Systems’ report20 that the 
NCTS and ECS are already in operation, with multiple stakeholders and that the business continuity of 
these existing systems cannot be jeopardised.  

Under the umbrella of the “National Administration coordination programme” the Commission assists 
and monitors the development and deployment of the national components for the NCTS-P5 and AES-
P1  trans-European systems by the Members States and by the Signatory Parties of the Common Transit 
Convention. During the years 2020 and 2021, the following results can be reported for NCTS and AES: 

  All national administrations have provided an initial National Project Plan by the end of 2020 
as their baseline and most of them with subsequent quarterly updates. All plans remain within 
the deadline set by the UCC work programme. However, the latest plans show a shift of more 
than one quarter for the deployment of AES-P1 and NCTS-P5. Some Administrations already 
announced  that  further  delays  will  be  reported  in  the  next  two  quarters.  The  Coordination 
Programme has proven instrumental to maintain a high level of transparency on the progress of 
the Member States and to report on the collective progress of the Member States; 

  The Commission accompanies each Member State individually as to provide them with an as 
seamless  as  possible  testing  experience,  speeding  up  their  readiness  and  mitigating  their 
technical risks; 

  Hundreds of virtual meetings took place with the Member States, at operational, middle and 

senior management levels, as to mitigate the risks of delay of the Member States; 

  The Member States approved an ambitious training programme for the next two years. This 

programme is now operationalised by the Commission; 

  The trader Community is systematically informed of the progress and the plans of the Member 

States; 

  The Commission has reported, to the ECCG and CPG, the ongoing progress of the Member 
states  and  other  Signatory  Parties  to  the  Common  Transit  Convention,  providing  the  Key 
Performance Indicators of the aggregated national plans. The Commission has issued a quarterly 
consolidated  progress  report  of  the  transition  of  both  NCTS-P5  and  AES-P1  as  from  the  1st 
quarter of 2021. 

For NCTS-P5 and AES-P1, the challenge is to ensure business continuity and smooth Member State and 
trade  transition  while  applying  significant  changes  in  the  applicable  Data  and  Process  models.  The 
National Administrations approved a new set of specifications which will cover the quality, technical 
support,  business  continuity,  security  and  capacity  of  the  future  AES-P1  and  NCTS-P5  operations 
(Service Management, Service Level Agreement, Terms of Reference, Crisis management, Capacity 
Plan, Security Plan). So far,  no delays have materialised on the central components and the project is 
currently on track. For both NCTS-P5 and AES-P1 projects, the quality of technical specifications are 
continuously  improved  in  an  agile  manner  to  take  advantage  of  the  findings  of  the  numerous  tests 
conducted.  

The National plans are published on Europa and the trader community is kept regularly informed on the 
progress achieved. Their feedback will be welcomed regarding the progress reported by the Member 
States.  

From a technical point of view, the NCTS-P5 and AES-P1 projects pioneered a collaborative, iterative 
and agile working method that has been praised by all Member States and traders involved. It has been 
requested to have this method expanded to other projects of the UCC. The Agile approach adopted since 
the start of the project pays off in terms of functional and technical quality. The collective intelligence 
of the Member States is a critical asset for the success of the transition at stake. 

20 DG TAXUD Customs Information Systems Overview of the Status of the MASP-C Projects Brussels, 22 August 2019 

90 

 
 
                                                      
The conformance testing started as planned in Q3 2020, leading to the entry in operation of DE in March 
2021.  Several  MS  will  enter  in  conformance  Testing  before  the  end  of  2021,  aiming  at  entering  in 
operation during 2022.  

DE and PL have conducted intensive bilateral testing sessions with the Commission. In addition, all 
Member  States  and  the  Commission  successfully  tested  a  key  central  technical  component  (the 
converter) in peak operation load and conditions during the month of June 2021. It provided an increased 
confidence of the system maturity ahead of its entry in operation in 2022. 

The real-life test conducted so far confirms the fitness of the common specifications and systems to meet 
the  challenge  of  business continuity  over  the  transition.  Learning  from  each  and  every  test  with the 
Member States increases the maturity of the overall technical set up. 

Regular releases of the central converter of NCTS were also delivered to improve its maturity in light 
of the findings of the tests. 

All documents, systems and services are in place to support the start in earnest of the transition to the 
two new systems as soon as a second Member State will join DE in operation in 2022.  

A number of Member States have reacted positively to the call of the Commission to bring forward the 
deployment date, as also pointed out in the ‘Overview of the Customs Information Systems’. National 
project plans are available and most maintained up to date, all national administrations have indicated 
to be ready within the deployment window in the UCC Work Programme, starting operations in Q1 
2021 until Q4 2023, as illustrated in Figure 43. DE is the leading Member State, having entered operation 
in March 2021, as planned. A group of six Member States (AT, BE, LU, NL, PL and SE) will comprise 
the first wave of Member States entering into operations in 2022. The transition will spread over five 
quarters.  

However, it is likely to further steepen during the 2nd half 2021 considering the announced delays and 
other risks at play. It will place an increasing risk on the capacity of the Commission to  adequately 
support such a steep transition and will put under pressure the date of 01 December 2023 set by the UCC 
Work  programme  for  the  entry  into  force  of  the  final  arrangements  of  the  UCC.  The  Commission 
monitors closely the Member States’ projects and invites the Member States to take all mitigation actions 
to avoid that their risks materialise. 

Figure 43: NCTS – P5 National Administrations entry into operations as of 1 July 2021 

Summary from the Member States: 

91 

 
 
 
NCTS-P5 is regarded as a highly complex project due to the dependencies with other systems, high 
availability requirements and competing priorities. Despite this, all Member States remain on-track for 
the ‘big bang’ transition planned for 1 December 2023. The main risks reported by the Member States 
relate to: 

  Procurement and service providers; 
  Competing priorities and inter-dependencies within and outside the UCC Work programme i.e. 

eCommerce and ICS2; 

  Lack of resource (staff & budget); 
  The COVID-19 pandemic; 
  Transition; 
  Delay from the traders; 
  Changes in the specifications. 

Detailed Responses: 

Table 38 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

AT 

BE 

BG 

CY 

6 

6 

4 

6 

Med 

Med 

Low 

Low 

CZ 

6 

Med 

DE 

6 

Low 

DK 

6 

High 

AT explained that the high complexity is due to their  cooperation with 
Belgium, including the settlement of cooperation procedures and system 
integration  with  a  national  environment.  AT  is  refining  their  technical 
analysis, preparing information for the traders, establishing a cooperation 
team and coordinating the planning of product increments with Belgian 
customs. 
BE marked the project as delayed beyond the deployment deadline. BE 
will provide an updated planning as soon as possible. Furthermore, they 
have asked their contractor to expand their development team. 

BG  noted  that  their  functional  and  technical  specifications  are  under 
approval in accordance with their national procedures. They are planning 
to start development by the end of 2021. 

CY explained that the complexity is caused by dependencies with other 
systems, the high availability requirements and limited human resources. 
The  development  approach  will  be  decided  in  cooperation  with  the 
contractor. The national planning is not yet stable and is dependent on the 
details in the future contract.  
CZ  gave  a  high  complexity  rating  explaining  that  the  application  is 
complex  and  has  indicated  that  it  requires  a  large  amount  of  financial 
resources. CZ’s national plan is stable however, the COVID-19 pandemic 
does present a risk. CZ is finalising their detailed national technical and 
functional  specifications.  Development  started  in  January  2021  and 
should be completed by December 2021. 
DE is making use of an agile development approach in defined software 
release cycles. The ongoing activities concern the finalisation and fine-
tuning of NCTS, the monitoring of operations as well as the preparation 
of  remaining  Conformance  Tests  (Mode  2)  and  the  start  of  the 
Conformance Test (certification) of economic operators. The period for 
CT with Trade has shifted from March 2021 – July 2022 to October 2021 
–  November  2022.  Therefore,  November  2022  is  the  end  of  the 
deployment window for trade. After this date, no NCTS-P4 messages will 
be accepted in the external domain. 
DK assessed the complexity as very high due to many dependencies with 
other  systems,  parallel  development  and  many  stakeholders.  The 
milestones most at risk are CT and the final test phase, due to alignment 

92 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

EE 

6 

Med 

ES 

FI 

5 

6 

Med 

High 

FR 

5 

Med 

Med 

Med 

GR 

HR 

HU 
IE 
IT 

LT 

LU 

6 

6 

4 
5 

3 

3 

and dependencies with other systems. The CT dates have not been set yet. 
The project is handled within the Scaled Agile Framework (SAFe). 
EE considered the project delayed in comparison to the planning in the 
2020  report,  but  the  overall  delivery  is  still  expected  within  the 
deployment deadline set in the UCC Work Programme. The procurement 
process is delayed, however, mitigation actions are foreseen. A contract 
with  a  developer  is  in  place,  the  technical  specifications  have  been 
completed, a detailed analysis has been carried out and the user interface 
has been tested. EE explained that the changes in national planning are 
due  to  delays  in  procurement,  milestones  have  been  postponed  by  six 
months. 
ES  explained  that  the  high  complexity  rating  is  because  this  project 
requires  strong  coordination  between  countries and  significant effort  in 
transition  management.  ES  will  use  an  agile/iterative  development 
methodology.  
FI explained that they are re-building NCTS from scratch and that several 
other IT projects are ongoing. NCTS will contain numerous integrations. 
The implementation is planned to start in Q2 2021. 

FR explained that this project requires many changes in message structure 
and rules. The complexity is increased by the support required during the 
transition  period.  FR  marked  the  project  as  delayed  compared  to  the 
planning in the 2020 report, however the overall delivery is still expected 
within the deployment deadline set in the UCC Work Programme. The 
reasons for delay are multiple: the prioritising of ‘Smart border’ during 
the second half of 2020, the COVID-19 pandemic (remote working, etc.), 
prioritisation  of  other  projects  such  as  the  VAT  eCommerce  package, 
ICS2  and  internal  projects.  Mitigating  actions  include  mobilising  more 
resources  after  September  2021.  The  main  milestone  impacted  is 
deployment.  FR  currently  has  two  iterations  planned,  the  first  without 
Export followed by Transit. The start of the technical specifications has 
been delayed however defining the interface specifications with traders is 
ongoing. 
GR marked the project as delayed compared to the planning in the 2020 
report,  however  the  overall  delivery  is  still  expected  within  the 
deployment deadline set in the UCC Work Programme. GR is facing a 
delay due to budget allocation however hopes to have a contract in place 
by the end of 2021. 
HR noted that the TS and CT milestones may be affected due to a lack of 
human  resources.  Many  EU  projects  have 
to  be  carried  out 
simultaneously.  

Low  HU is preparing technical specifications. 
Low 

IE expects to finalise their technical specifications by November 2021. 

Information not provided. 

Med 

Low 

LT  noted  that  their  procedure  for  public  procurement  is  planned. 
Deployment is planned for 02/11/2023. 
Some of the challenges which LU faces are related to the integration of 
export with various other systems (EOS, AEO, etc.). LU plans to be in the 
middle of conformance testing by the end of 2021 and to have finalised 
all requirements for their software provider. 

93 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

LV 

5 

High 

LV explained that they are securing a contract with a system developer 
and that this could potentially impact all stages of the project planning. In 
2021, LV plans to have the following completed: design of the database 
structure  and  client  interface for  submitting  transit  declarations and the 
data download from CS/RD. The technical specifications for the system-
to-system interface for NCTS-P5 was published at the end of February 
2021.  Furthermore,  LV  hopes  that  the  message  exchange  between  the 
trader’s module and the risk management system will also be completed 
this year. 

MT 

Information not provided. 

NL explained that the high complexity rating is due to the fact that it is a 
new  application  and  it  requires  interaction  with  many  other  national 
applications.  Furthermore,  many  related  MASP  projects  are  ongoing  at 
the  same  time.  NL  listed  the  following  risks  that  could  impact  all 
milestones: stability of the specifications, uncertain volumes (for example 
iOSS not used in eCommerce) and the priority in Agile development. NL 
explained that they are using an agile development approach and that they 
are currently describing the features based on the DDNTA. The decision 
has been made to build the system themselves. 
PL  explained  that  the  biggest  risk  to  the  project  is  that  their 
support/development  contract  for  the  NCTS  system  is  ending.  Another 
risk is the fact that the ongoing tender procedure for a new contract under 
which their new National Transit Application (NTA) will be updated for 
future changes and implemented into production has not yet been settled. 
The implementation of the new application is also influenced by changes 
related to the work on central documentation. 
An  additional  difficulty  is  related  to  the  COVID-19  pandemic  and 
restrictions  at  work.  In  May  2020,  PL  adapted  their  project  plan  and 
updated the deployment date to Q4 2021. 
PT  explained  that  the  risk  level  is  due  to  the  implementation  of  a  new 
system  and  a  lack  of  resources.  PT  stated  that  an  Agile  development 
methodology will be used to help reduce the implementation timeframe. 

RO marked the project as delayed in comparison to the planning in the 
2020  report,  but  the  overall  delivery  date  is  still  expected  within  the 
deployment deadline set in the UCC Work Programme. This is due to a 
delay in approving the budget for the current year. No mitigating measures 
are  foreseen  yet  since  the  overall  delivery  is  still  foreseen  within  the 
deployment deadline. RO has completed the procurement documentation 
and are awaiting budget approval. 
SE performed a pre-study in the second half of 2020. 

NL 

5 

Med 

PL 

5 

High 

PT 

6 

High 

RO 

SE 

6 

3 

Med 

Med 

94 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

SI 

5 

High 

SK 

3 

Med 

SI  explained  that  this  long-lasting  project  became  less  important  in 
comparison  to  new  initiatives/priorities,  also  considering  the  lack  of 
human resources and the undervaluation of the complexity. SI changed 
the  national  project  manager  in  February  2021,  which  added  another 
challenge. SI marked the project as delayed in comparison to the planning 
in the 2020 report, but the overall delivery date is still expected within the 
deployment deadline set in the UCC Work Programme. New planning was 
announced in November 2020 and only minimal corrections are required 
to stabilise it. The final deployment date is fixed. SI will implement strict 
monitoring  and  will  split  activities  into  smaller  tasks  with  defined 
deadlines  and  regular  reporting  requirements.  The  development  of  the 
application and mode-0 CT is planned to be completed in 2021. In 2022, 
SI will start with Mode-1 CT, followed by Mode-2 and Mode-3. These 
campaigns will include tests with Member States as well as with economic 
operators. 
SK’s project is delayed in comparison to the planning in the 2020 report, 
but the overall delivery is still expected within the deployment deadline 
stated in the UCC Work Programme. They have identified risks related to 
a lack of human and financial resources. No mitigation actions have been 
considered at this moment in time. SK assumes that the most impacted 
milestone will be the technical specifications. CT is planned for Q2 2022. 
Procurement is still ongoing however they aim to finalise the technical 
specifications by the end of 2021. 

Table 38: Detailed responses from Member States – NCTS – P5 

The risk assessment of National Project Plans of the Member States by the Commission is shown and 
substantiated in the table below: 

95 

 
 
Table 39: Risk Assessment: NCTS – P5 

96 

in procurementNPP in reviewNPP in preparationShift from 2020 BaselineConformance Test too shortStart of Depl in Last 3 QtrsStart of Depl in Last 2 QtrStart of Depl in Last QtrCommentsATCollab w/ BEBEBGCYLittle contingencyCZDEDKDelay announcedEEESFIFRShift 5 QtrsGRHigh riskHRHUOutdated NPPIEITLTLittle contingencyLULVLittle contingencyMTOutdated NPPNLPLPTNo contingencyROSESparce NPPSISKXINo NPPNCTS-P5 (01.07.21) 
 
 
 
Figure 44 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase21. 

Figure 44: Project Status as per Survey – NCTS – P5 

The table below lists the status as of 1 July 2021 of the Member States according to their latest National 
Project Plans: ten Member States published their National Trader Specifications already, one Member 
State opened a conformance testing environment to qualify its traders, the remaining 15 Member States 
having either not started yet, or are in the procurement stage, or in the process of producing their trader 
specifications, or in an unknown status.  

21 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

97 

 
 
 
                                                      
Table 40: Project Status – NCTS – P5 as of 1 July 2021 

NCTS – Component 2 

Summary from the Commission: 

For NCTS - Phase 6 (interconnection with other systems), the Commission launched the inception early 
2021 in close collaboration with the MS. The definition of the scope turned out much more challenging 
than anticipated considering the complexities at stake: 

 
 

 

 

the reconciliation of the process, data and technology of NCTS and ICS2, 
alignment of the deployment planning of ICS2 and NCTS-P6 with with the capacity of the 
Member States,  
securing the business continuity of NCTS just after having gone through its major transition 
to NCTS-P5; 
compromise between the interest of the “inland” Member States on the one hand and the 
“external  border”  Member  States  and  other  signatory  parties  of  the  Common  Transit 
Convention on the other hand as far as the road traffic is concerned. 

98 

NCTS-P5National administrationsnot startedin Tech Specificationin CTin Deploymentin operationNA Status as perceived from TradeBGTRUEFALSEFALSEFALSEFALSEa. Not StartedCYTRUEFALSEFALSEFALSEFALSEa. Not StartedDKTRUEFALSEFALSEFALSEFALSEa. Not StartedEETRUEFALSEFALSEFALSEFALSEa. Not StartedESTRUEFALSEFALSEFALSEFALSEa. Not StartedFITRUEFALSEFALSEFALSEFALSEa. Not StartedFRTRUEFALSEFALSEFALSEFALSEa. Not StartedGRTRUEFALSEFALSEFALSEFALSEa. Not StartedHRTRUEFALSEFALSEFALSEFALSEa. Not StartedHUTRUEFALSEFALSEFALSEFALSEa. Not StartedIETRUEFALSEFALSEFALSEFALSEa. Not StartedLTTRUEFALSEFALSEFALSEFALSEa. Not StartedNLTRUEFALSEFALSEFALSEFALSEa. Not StartedPTTRUEFALSEFALSEFALSEFALSEa. Not StartedROTRUEFALSEFALSEFALSEFALSEa. Not StartedATFALSETRUEFALSEFALSEFALSEb. Tech Spec completedBEFALSETRUEFALSEFALSEFALSEb. Tech Spec completedCZFALSETRUEFALSEFALSEFALSEb. Tech Spec completedITFALSETRUEFALSEFALSEFALSEb. Tech Spec completedLUFALSETRUEFALSEFALSEFALSEb. Tech Spec completedLVFALSETRUEFALSEFALSEFALSEb. Tech Spec completedMTFALSETRUEFALSEFALSEFALSEb. Tech Spec completedPLFALSETRUEFALSEFALSEFALSEb. Tech Spec completedSIFALSETRUEFALSEFALSEFALSEb. Tech Spec completedSKFALSETRUEFALSEFALSEFALSEb. Tech Spec completedDEFALSEFALSETRUEFALSEFALSEc. Conf Test openSEN/AN/AFALSEFALSEFALSEx. Unknown1510100 
 
 
  The policy objectives of the UCC, in particular of NCTS, ICS2, trade faciliation. 

The objective is to seek an adoption of the Member States of the inception package (Business Case and 
Vision  Document)  before  end  2021.  However,  this  milestone  is  at  significant  risk  considering  the 
substantial issues remaining to be resolved. 

4.1.23  Overview of Project Progress 

Table  41  highlights  any  known  divergences  in  the  planning  compared  to  the  dates  set  in  the  Work 
Programme22. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ columns 
are shown. If there is a difference in these two dates, this implies that a migration period is planned. 

Table 41: Comparison of Planned and Actual Dates – NCTS – P5 

The deployment of NCTS-P5 shows a delay of 1+ quarters in comparison with the initial national plans 
filed at the end of 2020 (respectively Earned and Planned Value in the chart below). The Planned and 
Earned  Values  are  built  on  a  basket  of  12  key  milestones  across  all  the  Member  States  and  other 
Signatory Parties of the Common Transit Convention. The deployment of NCTS-P5 is currently at 26% 
(Earned Value) while it should be at 38% (Planned Value). The Member States will have to speed up 
their project and contain their risks to reach the milestones of the entry into force of the final arrangement 
of the UCC on 1 December 2023. It will result in a sharper and shorter transition. 

22 The percentage of deployment refers to DG TAXUD preparation and the aggregated progress of National Administrations 
based on their National Project Plans. 

99 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual Start Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion Target date from WP2021 Planned/ Actual DateEuropean Commission30/06/2020100%04/10/2020100%01/03/2021100%01/12/2023AT01/06/2021100%01/03/20220%01/11/20220%01/08/2023BE01/02/2020100%01/03/20220%01/11/20220%01/11/2022BG10/06/202210%06/02/20230%12/06/20230%12/06/2023CY01/03/2022100%01/07/20230%16/10/20230%16/10/2023CZ30/06/2021100%03/01/20220%03/04/20230%03/04/2023DE26/10/2020100%19/04/2021100%01/10/2021100%30/10/2022DK01/11/202110%01/06/20220%01/02/20230%30/08/2023EE31/03/2022100%01/10/20220%30/06/20230%30/06/2023ES30/11/2021100%15/09/20220%01/05/20230%30/08/2023FI31/08/202195%01/09/20220%01/03/202350%31/03/2023FR01/09/202160%01/02/202230%01/10/20220%01/04/2023GR31/05/20220%01/04/20230%01/11/20230%30/11/2023HR31/12/202180%01/10/20220%01/01/20230%01/01/2023HU01/01/2022Not provided01/01/2023Not provided30/08/2023Not provided30/08/2023IE12/08/2022100%24/03/2023100%20/08/20230%20/10/2023IT15/02/2021Not provided01/02/2022Not provided30/06/2022Not provided31/12/2022LT30/09/20220%01/09/20230%02/11/20230%02/11/2023LU01/06/2021100%01/04/202220%01/10/202230%01/07/2023LV01/03/202150%02/01/20230%02/10/202333%02/10/2023MT31/12/2020Not provided31/01/2023Not provided31/03/2023Not provided01/12/2023NL01/10/2021100%01/01/20225%01/06/20220%30/08/2023PL31/05/202150%15/07/20220%30/09/20220%31/12/2022PT01/01/2023100%15/03/20230%01/12/20230%01/12/2023RO28/02/2022100%30/06/20220%15/05/20230%31/08/2023SEN/A0%N/A0%01/10/20220%30/09/2023SI15/02/2020100%03/01/2022100%01/02/202350%01/02/2023SK01/06/202175%01/06/20220%01/10/20220%31/12/2022Deployment(Start of the deployment window)31/12/201901/12/202301/03/2021Conformance TestingRespondeeTechnical SpecificationsOperations(End of the deployment window) 
 
 
    
 
                                                      
Figure 45: Key milestones: Planned value versus earned value – NCTS – P5 

4.1.24  Analysis of Progress against Milestones 

Figure  46  summarises  the  status  per  milestone  (technical  specifications,  conformance  testing  and 
deployment).  The  sum  of  each  bar  is  28  (responses  from  the  27  Member  States  plus  the  European 
Commission). 

Figure 46: Summary of Responses per Milestone – NCTS – P5 

Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
47.  

Regarding NCTS Phase 5 or Component 1, the following Member States have not yet started with the 
technical  specifications:  GR,  LT,  and  SE.  HU  and  MT  did  not  provide  percentage  of  completion 
information. 

100 

 
 
 
 
Figure 47: Percentage of Completion per Phase – NCTS – P5 as of 1 July 2021  

The figure below illustrates the four milestones set in Article 278(a) of the Regulation (EU) 2019/632 
amending Regulation (EU) 2013/952 as reported by each Member State in their national plans, ranked 
by their entry in deployment window for the traders. It illustrates how the deployment window for the 
trader shortens with its later start, the entry into force of the final arrangements of the UCC being a 
legally set milestone by the UCC work programme. 

101 

 
 
 
Figure 48: NCTS – P5 Transitional Period 

102 

 
 
 
 
 
UCC AUTOMATED EXPORT SYSTEM (AES) 

4.9 
The AES project consists of an upgrade of both the existing trans-European Export Control System and 
the existing national export systems. It aims to implement the UCC requirements for export and exit of 
goods, including export and re-export declarations; EXS and centralised clearance for Export, re-export 
notifications  and  an  interface  with  EMCS  and  NCTS.  The  project  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 what exits the EU customs territory to 
prevent fraud. The export declaration, and all linked message exchanges as well as the Arrival At Exit 
Notification and Exit Summary declaration are subject to considerable rework. The proposed message 
structures are fully convertible from/to “Legacy”/To Be” ones, guaranteeing a smooth transition and 
fostering business continuity from Q1 2021 until Q4 2023. 

The following processes will be implemented: 

  Export declaration pre-lodgement; 
  Handling of simplified/supplementary declarations; 
  Centralised clearance for export; 
  Re-export notification; 
  Export process followed-up by the transit TES and better monitoring of trade flows; 
  Export handling of goods under excise duties suspension interoperability with EMCS; 
  Facilitate legitimate trade & combat fraud; 
  Strengthen the safety and security for exit. 

In terms of planning, the system is comprised of two components. The first component relates to the 
“trans-European AES”. The aim of the project is to further develop the existing trans-European Export 
Control System (ECS) in order to implement a full AES that would cover the business requirements for 
processes and data brought about by the UCC. These processes and data will include the coverage of 
simplified  procedures  and  centralised  clearance  for  export.  It  will  also  cover  the  development  of 
harmonised interfaces with the Excise Movement and Control System (EMCS) and NCTS. As such, 
AES will enable the full automation of export procedures and exit formalities. The system includes some 
parts to be developed centrally but the main components are to be developed at the national level.  

The second component relates to the upgrade of the National Export Systems. 

4.1.25  Summary of Responses 

AES – Component 1 

Summary from the Commission: 

Please refer to the “Summary from the Commission” section for NCTS-P5 above which applies equally 
to NCTS-P5 and AES-P1 as both projects are managed as twins, maximising their shared activities and 
leveraging any synergy between them. 

For NCTS-P5 and AES-P1, the challenge is to ensure business continuity and a smooth transition for 
Member States and trade while applying significant changes in the applicable Data and Process models. 
The National Administrations approved a set of specifications which will  cover the quality, support, 
business  continuity,  security  and  capacity  of  the  future  AES-P1  and  NCTS-P5  operations  (Service 
Management, Service Level Agreement, Terms of Reference, Crisis management, Capacity Plan and 
Security Plan). So far, no delays have materialised on the central components and the project is currently 
on track. For both NCTS-P5 and AES-P1 projects, the quality of technical specifications is continuously 
improved in an agile manner to recycle the finding of the numerous tests conducted.  

Member States should complete the export component of their Special Procedures systems at the same 
time as the AES. 

The National plans are published on Europa and the trader community is kept regularly informed of the 
progress achieved. Their feedback will be welcomed regarding the progress reported by the Member 
States.  

103 

 
 
A number of Member States have reacted positively to the call of the Commission to bring forward the 
deployment date, as also pointed out in the ‘Overview of the Customs Information Systems’. National 
project plans are available and most maintained up to date, all national administrations have indicated 
to be ready within the deployment window in the UCC Work Programme, starting operations in Q1 
2021 until Q4 2023, as illustrated in Figure 49. DE is the leading Member State having entered operation 
in March 2021, as planned. A group of 6 Member States (AT, BE, ES, NL, PL and SE) will comprise 
the first wave of Member States entering into operations in 2022. The transition will spread over five 
quarters. However, it is likely to further steepen during the 2nd half of 2021 considering the announced 
delays and other risks at play.  It will place an increasing risk on the capacity of the Commission to 
adequately support such a steep transition and will put under pressure the date of 01 December 2023 set 
by  the  UCC  Work  programme  for  the  entry  into  force  of  the  final  arrangements  of  the  UCC.  The 
Commission closely monitors the Member States’ projects and invites the Member States to take all 
mitigation actions to avoid that their risks materialise. 

Figure 49: AES – Component 1 National Administrations entry into operations as of 1 July 2021 

Summary from the Member States: 

As the same transition strategy is applied as for NCTS-P5, however with slightly different planning, 
many Member States provided the same commentary. Please see the summary for NCTS-P5 (section 
4.8). 

Detailed Responses: 

Table 42 provides the individual Member States’ responses to the survey: 

MS 

AT 

Complexity 
Rating 
6 

Additional Comments 

Risk 
Level 
Med  Same response as for NCTS-P5 (see section 4.8). 

BE 

6 

Med 

BE marked the project as delayed in comparison to the planning in the 2020 
report, but  the  overall  delivery  date is  still  expected within the  deployment 
deadline set in the UCC Work Programme. The main cause of delay has been 
due to regulatory requirements for financing which require a lot of up-front 
work from their contractor. As a mitigating action, a Minimal Viable Product 
(MVP)  will  be  developed  to  allow  conformance  testing  while  additional 
functionalities are still being added. 

104 

 
 
 
 
MS 

BG 
CY 
CZ 
DE 
DK 
EE 
ES 
FI 

FR 

GR 
HR 

HU 

IE 

IT 
LT 

Complexity 
Rating 
4 
6 
6 
6 
6 
6 
5 
6 

Additional Comments 

Risk 
Level 
Low  Same response as for NCTS-P5 (see section 4.8). 
Low  Same response as for NCTS-P5 (see section 4.8). 
Med  Same response as for NCTS-P5 (see section 4.8). 
Low  Same response as for NCTS-P5 (see section 4.8). 
High  Same response as for NCTS-P5 (see section 4.8). 
Med  Same response as for NCTS-P5 (see section 4.8). 
Med  Same response as for NCTS-P5 (see section 4.8). 
High  Same response as for NCTS-P5 (see section 4.8). 

6 

6 
6 

6 

5 

6 

Low 

FR  explained  a  delay  has  been  applied  to  review  their  national  export 
clearance application and to amend the functional and technical specifications. 
Their development team is currently implementing new messages. 

Med  Same response as for NCTS-P5 (see section 4.8). 
Med  Same response as for NCTS-P5 (see section 4.8). 

High 

Low 

HU’s IT development based on eCommerce, will be used as a basis for the 
national  import  system  which  will  ultimately  be  the  basis  for  the  AES 
developments. 
IE expects to start the analysis and design discussions with external contractors 
this year. 

Low  None. 

Information not provided. 

LU 

4 

Med 

4 

High 

LV 

MT 

NL 

4 

Low 

PL 

5 

High 

LU marked the project as delayed in comparison to the planning in the 2020 
report, but  the  overall  delivery  date is  still  expected within the  deployment 
deadline  set  in  the  UCC  Work  Programme.  The  procedure  for  the  call  for 
tenders  and  the  negotiations  with  the  software  provider  took  longer  than 
planned.    LU  noted  that  their  software  provider  is  also  servicing  another 
Member State ,which should help to progress faster than planned. The main 
risks  are  related  to  the  limited  number  of  customs  experts  both  inside  the 
customs administration and available for the software development. LU has 
started internal analysis on the business processes. 
LV explained that they plan to develop a database, messages for export/re-
export declarations and the graphical user interface for customs users during 
2021. 

Information not provided. 

NL explained that the high complexity rating is due to the fact that Export and 
Exit  are  supported  by  different  applications.  Export  is  an  upgrade  of  an 
existing system and Exit will become a new application. Furthermore, many 
related MASP projects are ongoing at the same time. NL explained that they 
are using an agile development approach and that they are currently describing 
the features based on the DDNXA. 
PL explained that the biggest risk to the project are changes in the technical 
documentation at the central level. PL iterates that internal factors also play a 
role, such as the lack of a contract with an external company to implement and 
deploy  the new  systems.  Another  key  factor  is the necessity  to  connect the 
export  system  with  the  new  national systems  that  are  being  simultaneously 
created.  Furthermore,  the  COVID-19  pandemic  also  influences  the  project 
progress. PL supports agile and iterative development of new systems. In May 
2020, PL updated their national project plan changing the system development 
date to Q4 2021. 

PT 
RO 

6 
6 

High  Same response as for NCTS-P5 (see section 4.8). 
Med  Same response as for NCTS-P5 (see section 4.8). 

105 

 
 
MS 

SE 
SI 
SK 

Complexity 
Rating 
4 
4 
3 

Additional Comments 

Risk 
Level 
Med  Same response as for NCTS-P5 (see section 4.8). 
Med  Same response as for SP1 (see section 4.3). 
Med  Same response as for NCTS-P5 (see section 4.8). 

Table 42: Detailed responses from Member States – AES – Component 1 

The risk assessment of National Project Plans of the Member States by the Commission Services is 
shown and substantiated in the table below: 

Table 43: Risk Assessment: AES – Component 1 

106 

in procurementNPP in reviewNPP in preparationShift from 2020 BaselineConformance Test too shortStart of Depl in Last 3 QtrsStart of Depl in Last 2 QtrStart of Depl in Last QtrCommentsATCollab w/ BEBEBGCYLittle contingencyCZDEDKDelay announcedEEESFIFRBrexit aftercareGRHigh riskHRHUOutdated NPPIEITLTLittle contingencyLUPreliminary NPPLVLittle contingencyMTOutdated NPPNLPLPTNo contingencyROSESparce NPPSISKXINo NPPAES-P1 (01.07.21) 
 
 
Figure 50 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase23. 

Figure 50: Summary of Survey Responses – AES – Component 1 

The table below lists the status at 1 July 2021 of the Member States according to their latest National 
Project Plans: nine Member States published their National Trader Specifications already, one Member 
State opened a conformance testing environment to qualify its traders, the remaining 16 Member States 
having  either  not  started  yet,  or  being  in  procurement,  or  in  the  process  of  producing  their  trader 
specifications, or in an unknown status.  

23 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States. 

107 

 
 
 
                                                      
Table 44: Project Status – AES – Component 1 as of 1 July 2021 

AES – Component 2 

Summary from the Commission: 

The Commission has provided the Member States with functional and technical specifications, Annex 
B data and the required legal text. This was provided for the external domain with trade and for the 
national domain between the national applications and the common domain. Furthermore, the required 
interfaces and the proposed architecture were also provided. 

Summary from the Member States: 

Please see the summary for AES – Component 1. 

Detailed Responses: 

Table 45 provides the individual Member States’ responses to the survey: 

108 

AES-P1National administrationsnot startedin Tech Specificationin CTin Deploymentin operationNA Status as perceived from TradeBGTRUEFALSEFALSEFALSEFALSEa. Not StartedCYTRUEFALSEFALSEFALSEFALSEa. Not StartedDKTRUEFALSEFALSEFALSEFALSEa. Not StartedEETRUEFALSEFALSEFALSEFALSEa. Not StartedFITRUEFALSEFALSEFALSEFALSEa. Not StartedFRTRUEFALSEFALSEFALSEFALSEa. Not StartedGRTRUEFALSEFALSEFALSEFALSEa. Not StartedHRTRUEFALSEFALSEFALSEFALSEa. Not StartedHUTRUEFALSEFALSEFALSEFALSEa. Not StartedIETRUEFALSEFALSEFALSEFALSEa. Not StartedLTTRUEFALSEFALSEFALSEFALSEa. Not StartedLUTRUEFALSEFALSEFALSEFALSEa. Not StartedLVTRUEFALSEFALSEFALSEFALSEa. Not StartedNLTRUEFALSEFALSEFALSEFALSEa. Not StartedPTTRUEFALSEFALSEFALSEFALSEa. Not StartedROTRUEFALSEFALSEFALSEFALSEa. Not StartedATFALSETRUEFALSEFALSEFALSEb. Tech Spec completedBEFALSETRUEFALSEFALSEFALSEb. Tech Spec completedCZFALSETRUEFALSEFALSEFALSEb. Tech Spec completedESFALSETRUEFALSEFALSEFALSEb. Tech Spec completedITFALSETRUEFALSEFALSEFALSEb. Tech Spec completedMTFALSETRUEFALSEFALSEFALSEb. Tech Spec completedPLFALSETRUEFALSEFALSEFALSEb. Tech Spec completedSIFALSETRUEFALSEFALSEFALSEb. Tech Spec completedSKFALSETRUEFALSEFALSEFALSEb. Tech Spec completedDEFALSEFALSETRUEFALSEFALSEc. Conf Test openSEN/AN/AFALSEFALSEFALSEx. Unknown169100 
 
 
MS 

AT 
BE 
BG 
CY 

CZ 

DE 

DK 

EE 
ES 
FI 

FR 

GR 
HR 
HU 
IE 
IT 
LT 

LU 

LV 

MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Complexity 
Rating 
6 

Additional Comments 

Risk 
Level 
Med  Same response as for AES - Component 1. 

Information not provided. 

Low  Same response as for AES - Component 1. 
Low  Same response as for AES - Component 1. 

Med 

CZ gave a high complexity rating explaining that the application is complex and 
has indicated that it requires a large amount of financial resources. CZ's national 
plan  is  stable  however,  the  COVID-19  pandemic  does  present  a  risk.  CZ  is 
preparing their detailed national technical and functional specifications. Their 
national specifications will be completed in Q2 2021. 

Low  Same response as for AES - Component 1. 

High 

DK  explained  that  they  are  currently  working  on  the  development  and 
implementation of standard software. The product is developed using an agile 
approach.  Deploying  prior  to  the  onboarding  of  customs  and  economic 
operators is a risk. 

Med  Same response as for AES - Component 1. 
Med  Same response as for AES - Component 1. 
High  Same response as for AES - Component 1. 

Low 

FR  has  completed  the  functional  and  technical  specifications  and  has  started 
development. FR explained that a delay has been applied to review their national 
export clearance application. 

Med  Same response as for AES - Component 1. 
Med  Same response as for AES - Component 1. 
High  Same response as for AES - Component 1. 
Low  Same response as for AES - Component 1. 

Information not provided. 

Low  None. 

Med 

High 

Some of the challenges which LU faces are related to the integration of export 
with various other systems (Tariff, Surveillance, EOS, AEO, REX, etc.). The 
main risks are related to the limited number of customs experts both inside the 
customs  administration  and  available  for  the  software  development.  LU 
expressed that using an Agile methodology makes it difficult to already provide 
an indication for when certain activities might start. 
At the time of writing, LV marked the project as delayed beyond the deployment 
deadline. They had a late start to development due to a delay with allocating 
finances, Some mitigating actions are foreseen: usage of ECS P2 (where it is 
possible), return to the previous non-automated data exchange (manual labour). 
All milestones are impacted. 

Med  None. 
Low  Same response as for AES - Component 1. 
High  Same response as for AES - Component 1. 
High  Same response as for AES - Component 1. 
Med  Same response as for AES - Component 1. 
Med  Same response as for AES - Component 1. 
Med  Same response as for AES - Component 1. 
Med  Same response as for AES - Component 1. 

4 
6 

6 

5 

4 

6 
5 
6 

6 

6 
6 
5 
5 

6 

4 

4 

6 
4 
5 
6 
6 
4 
4 
3 

Table 45: Detailed responses from Member States – AES – Component 2 

Figure 51 provides the percentage of Member States in each development phase. 

109 

 
 
Figure 51: Project Status as per Survey – AES – Component 2 

4.1.26  Overview of Project Progress 

Table  46  highlights  any  known  divergences  in  the  planning  compared  to  the  dates  set  in  the  Work 
Programme. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ columns are 
shown. If there is a difference in these two dates, this implies that a migration period is planned.  

Table 46: Comparison of Planned and Actual Dates – AES – Component 1 

The deployment of AES-P1 shows a delay of 1+ quarters in comparison with the initial national plans 
filed at the end of 2020 (respectively Earned and Planned Value in the chart below). The Planned and 
Earned  Values  are  built  on  a  basket  of  12  key  milestones  across  all  the  Member  States  and  other 
Signatory Parties of the Common Transit Convention. The deployment of AES-P1 is currently at 27% 
(Earned Value) while it should be at 34% (Planned Value). The Member States will have to speed up 
their project and contain their risks to reach the milestones of the entry into force of the final arrangement 
of the UCC on 1 December 2023. It will result in a sharper and shorter transition. 

110 

 
 
 
 
Figure 52: Key milestones: Planned value versus earned value – AES – Component 1 

In regards to the implementation AES – Component 2, no Member States have a planned deployment 
date that is later than the deadline in the UCC Work Programme. 

111 

 
 
 
 
 
 
 
 
Table 47: Comparison of Planned and Actual Dates – AES – Component 2 

4.1.27  Analysis of Progress against Milestones 

Figure  53  and  Figure  54  summarise  the  status  per  milestone  (technical  specifications,  conformance 
testing and deployment). The sum of each bar in Figure 53 is 28 (responses from the 27 Member States 
plus the European Commission). The sum of each bar in Figure 54 is 27 (responses from the 27 Member 
States). 

Figure 53: Summary of Responses per Milestone – AES – Component 1 

112 

Target date from WP 2021 Planned/ Actual End Date2021 % of Completion2021 Planned/ Actual End Date2021 % of Completion Target date from WP 2021 Planned/ Actual Date2021 % of Completion AT01/08/202150%01/12/20220%01/12/20220%BE04/07/2020Not provided31/07/2022Not provided01/04/2022Not providedBG10/06/202210%31/05/20230%05/06/20230%CY10/01/202280%24/02/20230%02/02/20230%CZNot provided100%30/03/20210%03/10/20220%DE23/10/2020100%05/03/2021100%06/03/2021100%DKNot provided33%Not provided10%Not provided0%EE31/12/2021100%28/02/20230%30/06/20230%ES31/03/2021100%28/02/202330%31/08/20220%FI31/03/202295%31/12/20220%31/03/202350%FR31/03/2021100%31/01/2023N/A31/01/2023N/AGR30/09/20220%Not provided0%01/11/20230%HR31/12/202084%30/09/20220%01/01/20230%HU31/05/202310%01/11/202310%01/12/202310%IE01/11/2021100%31/10/20230%01/09/20230%IT30/06/2020Not provided30/06/2022Not provided05/09/2022Not providedLT01/03/20220%30/09/20230%01/12/20230%LUNot providedNot provided01/04/2023Not provided01/04/2023Not providedLV01/02/20220%31/08/20230%05/02/20230%MT31/01/2022N/ANot providedN/A01/09/2023N/ANL01/01/2021100%01/12/20235%01/04/20220%PL31/03/2020100%31/12/2020100%31/03/202170%PT15/12/20220%15/10/20230%01/12/20230%RO19/03/2021100%31/08/20230%15/05/20230%SENot provided0%30/09/20230%01/10/20220%SI18/12/202095%31/01/20230%01/05/20230%SK01/12/202295%01/11/20230%01/12/20230%01/03/2021Deployment(Start of the deployment window)Conformance TestingTo be defined by MSTechnical SpecificationsRespondee 
 
  
 
 
Figure 54: Summary of Responses per Milestone – AES – Component 2 

Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
55 and Figure 57. Regarding AES - Component 1 (trans-European), the following Member States have 
not  yet  started:  CY,  GR,  IE,  LT  and  SE.  IT,  LU  and  MT  did  not  provide  percentage  of  completion 
information. 

113 

 
 
 
Figure 55: Percentage of Completion per Phase – AES – Component 1 as of 1 July 2021 

The figure below illustrates the four milestones set in Article 278(a) of the Regulation (EU) 2019/632 
amending Regulation (EU) 2013/952 as reported by each Member State in their national plans, ranked 
by their entry in deployment window for the traders. It illustrates how the deployment window for the 
trader shortens with its later start, the entry into force  of the final arrangements of the UCC being a 
legally set milestone by the UCC work programme. 

114 

 
 
 
Figure 56: AES – Component 1 Transitional Period 

115 

 
 
 
 
 
Regarding AES - Component 2 (National Export Systems), the following Member States have not yet 
started: GR, LT, LV, PT, and SE. BE, IT and LU did not provide percentage of completion information. 

Figure 57: Percentage of Completion per Phase – AES – Component 2 

116 

 
 
 
5.  ANNEX 1 – PLANNING OVERVIEW – UCC WORK PROGRAMME PROJECTS  

Figure 58 provides a visual overview of the planning of the UCC Work Programme projects. There has 
been no change compared to Q4 2020. The overview provides the timeline of the development of the 
projects. The ‘N’ symbol identifies the national projects. The other projects are related to trans-European 
systems, which might have a central or decentralised architecture. 

Figure 58: Planning Overview: UCC Work Programme Projects – Status Q4 2021 

117 

 
 
 
 
 
 
6.  ANNEX 2 – ACRONYMS, ABBREVIATIONS & KEY TERMS 

Common Transit Convention 
Delegated Act 
Design Document for National Transit Application 
Design Document for National Export Application 

Customs Duties Calculation 
Customs Data Model 
Customs Decisions Management System 
Customs Decisions System 
Customs Goods Manifest 
European Commission 
Customs Policy Group 
Customer Reference Services 
Central Services – Reference Data; Central Services – Reference Data 2  

Description 
Authorised Economic Operator 
Adaptive Development Methodology 
Automated Export System 
Automated Import System 
Automated Customs Tariff and Local Processing Application System 
Business Process Model 
Binding Tariff Information 
Common Agricultural Policy 
Customs Business Group 
Centralised Clearance for Import 

Acronym 
AEO 
ADM 
AES 
AIS 
ATLAS 
BPM 
BTI 
CAP 
CBG 
CCI 
CCN; CCN2  Common Communication Network; Common Communication Network 2 
CDC 
CDM 
CDMS 
CDS 
CGM 
COM 
CPG 
CRS 
CS/RD; 
CS/RD2  
CTC 
DA 
DDNTA 
DDNXA 
DG TAXUD   Directorate General for Taxation and Customs Union 
DMS 
DTCA 
EBTI 
ECCG 
ECS 
EIDR 
EMCS 
EMSW 
ENS 
EORI 
EOS 
ETCIT 
EUCDM 
EUCTP 
EXP 
EXS 
FTA 
GSP 
GUM 
IA 
ICS; ICS2 
IMP 
INF 
INF SP 

Declaration Management System 
Decision Taking Customs Authority 
European Binding Tariff Information 
Electronic Customs Coordination Group 
Export Control System 
Entry in the Declarant's Records  
Excise Movement and Control System 
European Maritime Single Window 
Entry Summary Declaration 
Economic Operators Registration and Identification 
Economic Operator System 
Expert Teams on new approaches to develop and operate Customs IT systems 
European Union Customs Data Model 
EU Customs Trader Portal 
Export 
Exit Summary Declaration 
Free Trade Agreement 
Generalised Scheme of Preferences 
Guarantee Management 
Implementing Act 
Import Control System; Import Control System 2 
Import 
Information Sheet 
Standardised Exchange of Information for Special Procedures 

118 

 
 
Acronym 
iOSS 
LVC 
MASP-C 
MS 
MVP 
NCTS 
NES 
NoA 
NSP 
NTA 
OCT 
PDS 
PG 
PN 
Q1/2/3/4 
REX 
RPS 
RUP 
SAFe 
SP 
STI 
T2L 

T2LF 

TAPAS 
TARIC3 
TP 
TS 
TSD 
UCC 
UI 
UUM&DS 
VAT 
WP 

Description 
Infinite Open Source Solutions 
Low Value Consignments 
Multi-Annual Strategic Plan for Customs 
Member State 
Minimal Viable Product 
New Computerised Transit System 
National Export System 
Notification of Arrival 
National Special Procedures 
National Transit Application 
Overseas Countries and Territories 
Product Disclosure Statement 
Project Group 
Presentation Notification 
Quarter 1/2/3/4 
Registered Exporters System 
Regulatory Procedure with Scrutiny 
Rational Unified Process 
Scaled Agile Framework 
Special Procedures 
Shared Trader Interface 
Means of proof of the Customs status of Union goods 
Means of proof of the Customs status of Union goods for goods transported to, from 
or between the non-fiscal areas 
TAXUD AS4 Profile 
Integrated Tariff of the European Communities 3 
Trader Portal 
Temporary Storage 
Temporary Storage Declaration 
Union Customs Code 
User Interface 
Uniform User Management & Digital Signature 
Value Added Tax 
Work Programme 

Table 48: Abbreviations and Acronyms 

119