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

1. INTRODUCTION ......................................................................................................................... 2 

2. BACKGROUND ............................................................................................................................ 2 

3. PROJECT METHODOLOGY FOR THE UCC ELECTRONIC SYSTEMS ........................ 3 

4. GLOBAL OVERVIEW OF PROGRESS WITH THE UCC ELECTRONIC SYSTEMS..... 4 

4.1 

Projects completed before 2021 ............................................................................................ 4 

4.2  Ongoing projects .................................................................................................................... 4 

4.2.1  Trans-European projects ...................................................................................................... 4 

4.2.2  National projects .................................................................................................................... 9 

4.3 

Risks for delays .................................................................................................................... 10 

4.4  Mitigation actions ................................................................................................................ 12 

5. MANAGEMENT SUMMARY AND CONCLUSIONS ........................................................... 14 

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1.  INTRODUCTION 

The  first  and  second  Annual  Progress  Reports1  from  the  Commission  on  the  implementation  of  the 
electronic  systems  of  the  Union  Customs  Code  (UCC)  and  their  accompanying  Staff  Working 
Documents2 were published on 13 December 2019 and 14 December 2020 respectively. This year’s 
annual  report  elaborates  on  the  continuing  progress  in  developing  the  electronic  systems  by  the 
Commission and the Member States3, and describes the developments towards a fully digital customs 
environment since the UCC entered into force. For this purpose, it draws on the UCC Work Programme 
(UCC WP)4, which is considered as the baseline for reporting progress. 

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

i) 

ii) 

iii) 

Eleven central trans-European systems to be developed or upgraded by the Commission 
(often also requiring developments or upgrades of the national systems by Member States, 
depending on the system architecture); 
Three decentralised trans-European systems that have to be developed or upgraded by 
the Commission but have a major national component to be implemented by the Member 
States; and  
Three national systems that have to be developed or upgraded exclusively by the Member 
States.  

This report analyses the tangible progress made for all three system types, outlining the objectives to be 
met  by  each  project,  the  project  architecture  and  the  planning  approach.  On  that  basis,  it  highlights 
potential delays, where identified, as well as envisaged mitigating measures. The overall assessment of 
the  progress  of  the  implementation  of  the  UCC  WP  is  summarised  in  the  conclusion  of  this  report 
(section 5) and demonstrates that the remaining projects are mostly on track for completion in line with 
the planning schedule, though highlighting that some risks  require urgent action. More details of the 
planning and status of each project are provided in a Commission Staff Working Document5 published 
alongside this report.  

2.  BACKGROUND 

The UCC entered into force on 1 May 2016 and following its amendment in 20196, it established the 
deadlines of 2020, 2022 and 2025 for the progressive completion of the projects in terms of IT transition 
and implementation. Article 278 of the UCC provides that existing electronic and paper-based systems 
can continue to be used for the completion of customs formalities (the so-called ‘transitional measures’) 
until the new, relevant or upgraded electronic systems envisaged under the UCC are operational. The 
transitional measures must cease once the relevant electronic systems are in place. 

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

1 Reports 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  
2 Commission Staff Working Documents:  
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 
3  When  mentioning  in  this  report  the  “Member  States”,  it  is  meant  to  refer  to  the  national  customs  administrations  of  the 
Member States. 
4 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). 
5 Commission Staff Working Document Accompanying the Report from the Commission to the European Parliament and the 
Council pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for 
under the Code, SWD(2021) XXX final. 
6 Regulation (EU) 2019/632 of the European Parliament and of the Council of 17 April 2019 amending Regulation (EU) No 
952/2013 to prolong the transitional use of means other than the electronic data-processing techniques provided for in the Union 
Customs Code (OJ L 111, 25.4.2019, p. 54–58). 

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

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. 

This report also contains an analysis based on more detailed information reported by the Member States 
in  the  framework  of  the  national  coordination  programmes  in  place  since  2020  for  the  core 
decentralised trans-European systems in the area of transit and export.  

The data collected were also compared with the 2020 data in order to detect any major changes. The 
survey  asked  the  project  managers  to  indicate  any  known  delays  in  the  planning  of  their  electronic 
systems, the reasons for any such delays and the mitigating measures taken. The data yielded from the 
survey are both quantitative in the form of deadlines and milestones met or missed, and qualitative in 
the form of detailed descriptions regarding the challenges faced, the anticipated risks and the estimated 
complexity of the projects.  

3.  PROJECT METHODOLOGY FOR THE UCC ELECTRONIC SYSTEMS 

The work of developing electronic systems involves several steps:  

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

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

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

 

  The  projects  are  then  rolled  out  in  different  phases,  from  preparation  and  development  to 

construction, conformance testing, migration and operations. 

In recent developments of the UCC projects, the project methodology has been optimised. The business 
process  modelling,  data  modelling  and  technical specifications  have  been  developed  in  parallel  and 
through  close  collaboration  from  the  start  with  experts  from  legal,  business  and  IT,  both  from  the 
Commission  and  the  National  Administrations,  and  in  consultation  with  trade  representatives.  The 
Commission is adopting more agile processes for the development of UCC electronic systems, providing 
incremental user functionality through swifter and more manageable software releases. 

The Commission and the Member States meet regularly to define and agree these project documents for 
each trans-European system (in the Electronic Customs Coordination Group (ECCG)). In addition, the 
Commission systematically consults the trade community through the Trade Contact Group. A major 
challenge is to ensure that existing systems continue to function smoothly while the new systems are 
being developed. Once ready, it is then of utmost importance to ensure a smooth transition from the 
existing systems to the upgraded ones. This is vital to ensure that trade and customs operations are not 
impacted. 

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4.  GLOBAL  OVERVIEW  OF  PROGRESS  WITH  THE  UCC  ELECTRONIC 

SYSTEMS 

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

4.1  Projects completed before 2021 

As of the end of 2021, the Commission can report the successful upgrade or deployment of eight out of 
the seventeen systems.  

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

 

 

 

 

 

 

 

 

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

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

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

UCC Economic Operator Registration and Identification System 2 – EORI2 (upgrade): 
Deployed in 2018. 

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

UCC Binding Tariff Information – BTI (upgrade): Deployed in 2019.  

UCC Authorised Economic Operators – AEO (upgrade): Deployed in 2019. 

UCC Information Sheets for Special Procedures – INF (new): Deployed in 2020. 

From  the  other  nine  projects,  six  concern  trans-European  systems  from  which  three  had  first 
deployments in 2021 (see 4.2.1) though the projects were not yet completed in their totality. Similarly 
for  the  three  projects  relating  to  the  national  systems  for  which  some  Member  States  have  started 
operations (see 4.2.2) though the projects were not yet completed in their totality (by all the Member 
States). 

4.2  Ongoing projects 

For the nine ongoing projects, this section of the report highlights the achievements and progress made 
by end 2021 and demonstrates the extensive collaboration between the Commission and the Member 
States.  

4.2.1 Trans-European projects 

Regarding the six trans-European projects, a series of IT project documents were prepared and agreed 
upon in 2021 as the basis for the systems’ development work – see below the progress per project.  

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

1) 

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

Progress: The business case for the trans-European GUM on the re-use of an existing system 
with the addition of specific requirements for GUM was approved in September 2020. The 
process models and functional specifications as well as the vision document were finalised 
in 2021.  

4 

 
 
 
In  view  of  the  legal  milestones  in  the  UCC  WP,  the  technical  specifications  are  to  be 
completed by 30 September 2022 for Component 1 related to the trans-European GUM and 
30 November 2024 for Component 2 related to the National Guarantee Management system.  

Concerning the National Guarantee Management system, seven Member States reported the 
deployment  of  the  national  system  and  two  other  Member  States  are  progressing  on  the 
technical specifications. This can be seen in Table 25 of the Staff Working Document.  

2) 

UCC Import Control System 2 – ICS2 (upgrade): aims to strengthen the safety and security 
of the supply chain by means of improving data quality, data filing, data availability and data 
sharing  in regard to  pre-arrival  notifications (“Entry Summary  Declarations”)  and  related 
risk and control information. In particular, the project will facilitate collaboration amongst 
the  Member  States  in  the  process  of  risk  analysis.  The  project  will  be  delivered  in  three 
releases to allow a feasible transition per mode of transport.  

(1)  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. Entry Summary 
Declaration  (ENS)  pre-loading  dataset.  The  primary  focus  of  customs  in  this  first 
release is to risk assess, detect and mitigate risks of potential introduction of improvised 
explosive  or  incendiary  device  (‘bomb-in-a-box’)    into  the  air  cargo  and  air  mail 
consignments, before goods are loaded onto an airplane in a third country. Customs thus 
provides  via  ICS2  a  complementary  layer  of  security  to  the  existing  civil  aviation 
security regime applicable for transport of cargo and mail to the EU. 

(2)  Release 2 covers the implementation of new ENS obligations and related business and 
risk management processes for all the goods entering the EU by air traffic (addition of 
new  types  of  economic  operators  and  ENS  filings,  linking  for  multiple  filings  and 
arrival notifications) and the Safety and Security Analytics capability.  

(3)  Release 3 extends this to 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.  

Progress:  The  successful  deployment  by  the  Commission  of  the  centrally  developed 
components of ICS2 – Release 1, i.e. the Shared Trader Interface, Common Repository and 
Business Statistics & Monitoring tool, on 15 March 2021 is a significant achievement.  

As  regards  the  readiness  of  Member  States  nationally  developed  components  of  ICS2  – 
Release 1, i.e. the national entry systems, it can be reported that all 27 Member States started 
operations in October 2021 as planned  (Section 3.1.1 Staff Working Document) with the 
express couriers and postal operators. 

The first release is the largest business and IT project that DG TAXUD has ever undertaken, 
ensuring  24/7  availability  to  economic  operators  and  Member  States  and  processing  the 
largest volume of business messages with a response time of only seconds. Furthermore, this 
is  the  first  time  that  DG  TAXUD  is  using  digital  certificates  for  system-to-system 
communication. ICS2 – Release 1 also delivers advanced monitoring and business statistics 
for the Member States.  

The Commission is working with the Member States and the Union Postal Union (UPU) to 
manage the impact of the lack of electronic data from third country operators on the entry 
formalities  that  EU  postal  operators  need  to  comply  with.  A  temporary  and  targeted 
derogation based on Article 6(4) of the Union Customs Code might be appropriate for this 
purpose. 

Further Releases: 

Development of Release 2, using Release 1 as the baseline, has started. Member States are 
preparing  the  national  functional  and  technical  specifications  based  on  the  common  EU 
specifications  provided  by  the  Commission.  The  Commission  has  initiated  coordination 
meetings to ensure smooth development of Release 2 and requested the National Customs 

5 

 
 
 
Administrations  to  provide  the  National  Project  Plans  covering  information  on  both  the 
national entry systems and the relevant economic operator’s systems.  

For Release 3 the functional specifications were published in Q2 2021. With this release all 
modes of transport will be supported and ICS Phase 1 will be phased out. 

3) 

UCC Proof of Union Status – PoUS (new): will store, manage and retrieve all proofs to 
demonstrate that traders provide the Union status of their goods. This project can be deployed 
either  centrally  or  nationally  but  many  Member  States  have  explicitly  conveyed  their 
intention to use the central system developed by the Commission. In view of the dependency 
between the implementation of the UCC customs goods manifest as a proof of Union status 
and of the European Maritime Single Window, the project will be completed in two phases 
to avoid inconsistency and reduce risks.  

Progress:  The  vision  and  architecture  overview  documents  of  Phase  1  (T2L/F)  were 
approved  on  30  September  2020.  Three  separate  external  review  packages  containing 
technical documentation 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  to  the  central  system.  The  functional  specifications  of  Phase  2  (CGM)  were 
accepted on 21 June 2021. 

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. As in last year’s report, those 
Member States that prefer to deploy a national system component reported having difficulty 
in  predicting  if  their  implementation  will  follow  the  timeline  indicated  in  the  Work 
Programme due to the early stage of the project.  

4) 

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

Progress:  Regarding  CCI  –  Phase  1,  the  business  case,  vision  document,  L4  BPMs, 
functional  specifications  and  technical  specifications  have  been  approved  and  are  in 
alignment with the MASP-C 2019 and the UCC WP. An updated package of the technical 
documentation was approved in 2021 under the change management procedure. The system 
development has started, with a planned deployment date for forerunner Member States in 
2022.  Eight  Member  States  have  reported  the  completion  of  their  Phase  1  technical 
specifications while eleven others are in progress.  

The business case for CCI - Phase 2 was finalised in October 2019. The business processes 
and  functional  specifications  for  Phase  2  were  also  completed  in  2020.    A  number  of 
technical documents were approved internally in DG TAXUD in preparation for publication 
of a technical specifications package by 30 June 2022 ahead of the planned deployment date 
for starting the deployment window in October 2023. 

5) 

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

Progress: The NCTS – Phase 5 project is currently on track with the successful deployment 
by the first Member State in March 2021. The Member States also approved a new set of 
specifications which cover the quality, technical support, business continuity, security and 
capacity of the future NCTS-P5 operations (Service Management, Service Level Agreement, 
Terms of Reference, Crisis management, Capacity Plan, Security Plan). This is an important 
body of work which underpins the proper functioning and availability of this trans-European 

6 

 
 
 
System. In parallel, intensive testing with the Member States across the system, confirms the 
fitness  for  purpose  and  resilience  of  the  specifications  and  central  system.  This  further 
reduces the risks for the technical aspects of the transition in an agile way. 

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

Fourteen7 Member States have reported completing their technical specifications for NCTS-
Phase 5 while eight others are in progress. 

       Figure 1 – NCTS – Phase 5 National Administrations entry into operations 

For NCTS - Phase 6, the business case and the vision document have been finalised in parallel 
by  the  end  of  2021.  As  Member  States  needed  more  information  to  make  an  informed 
decision a technical study has also being carried out.  

6) 

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

Progress: The trans-European AES – Component 1 is currently on track with the successful 
deployment by the first Member State in March 2021. The Member States also approved a 
new  set  of  specifications  which  cover  the  quality,  technical  support,  business  continuity, 
security  and  capacity  of  the  future  AES  operations  (Service  Management,  Service  Level 
Agreement, Terms of Reference, Crisis management, Capacity Plan, Security Plan). This is 
an important body of work which underpins the proper functioning and availability of this 

7 Situation on 30 September 2021. (Table 41 Staff Working Document indicates twelve by end June) 

7 

 
 
 
 
 
 
 
                                                      
trans-European  System.  Business  guidance  and  eLearning  material  are  also  under 
preparation. In parallel, intensive testing with the Member States across the system, confirms 
the fitness for purpose and resilience of the specifications and central system. This further 
reduces the risks for the technical aspects of the transition in an agile way. 

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

Figure 2 – AES – Phase 1 National Administrations entry into operations 

To summarise the status of the six remaining trans-European projects, the Commission is on track to 
meet the legal deadlines agreed in the context of the UCC and UCC WP, and the project milestones set 
out in the Multi-Annual Strategic Plan for Customs (MASP-C) of 2019. The Member States are also 
mostly on track, however five Member States have indicated delays in deployment of some systems 
ranging from one month to more than two years in one case8. Two Member States have indicated that 
they will allow their traders a longer transition period after deployment to connect to their systems than 
what is legally defined  – one by a  month and the other by one year9. As the systems concerned are 
planned for 2023, 2024 and 2025 there is still time for mitigating actions to be undertaken to address the 
delays currently envisaged. The Commission will work closely with those Member States to this end.  

Finally, it is important to highlight that in view of the implementation of the UCC WP, the Commission 
will  have  performed  approximately  84%  of  its  activities  by  December  2021.  This  represents  an 
increase  from  79%  reported  last  year  of  the  totality  of  its  development  work  due  by  2025.  This 
percentage is based on key performance indicators for the activities assigned only to the Commission 
and does not reflect the activities performed by the Member States. In the overview below one can find 
the prospects in view of the progress and planning of DG TAXUD. 

8 Tables 25, 28, 32, 36 & 37 Staff Working Document. 
9 Tables 25, 36 & 37 Staff Working Document. 

8 

 
 
 
 
 
 
 
 
                                                      
Figure 3  – Approximation of the percentage of completion of the Commission’s development activities 

4.2.2 National projects 

Member States are due to complete the upgrade of their three national systems by 2022. This excludes 
the export component of the national Special Procedures system, for which the activity and planning is 
interlinked to the Automated Export System (AES), and the national guarantee component as part of the 
GUM project. 

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

1) 

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

Progress:  BE  has  established  a  collaboration  initiative  with  12  other  interested  Member 
States  in  order  to  prepare  the  specifications.  An  expert  team,  funded  by  the  Customs 
Programme, will continue collaborating to deliver the appropriate functional and technical 
documentation and test packages. NA, PN and TS have been completed by one, six and 
four Member States, respectively. Because of the nature of the development, some Member 
States have decided to make use of ICS2 – Release 2 to implement the requirements for the 
Notification of Arrival, ultimately leading to some planned dates being past the UCC WP 
deadline. 

2) 

UCC National Import Systems – NIS (upgrade): aims to implement all process and data 
requirements  deriving  from  the  UCC  that relate to imports.  Member  States  must  develop 
technical specifications at their level as a first step towards the completion of the systems.  

Progress: Fifteen Member States have completed their technical specifications. Two have 
not yet started and another Member State did not provide information. All Member States, 
with the exception of two, are on track to achieve the 2022 operations milestone. 

3) 

UCC  Special  Procedures  –  SP  (upgrade):  aims  to  harmonise  and  facilitate  special 
procedures (customs warehousing, end-use, temporary admission and inward and outward 
processing). Member States will have to implement all the required UCC changes for these 

9 

 
 
 
 
 
special procedures in their national systems. The first (export) component of the SP will be 
implemented in-line with and as part of the national UCC Automated Export System (AES) 
project (with a 2025 deployment deadline), while the second (import) component will be part 
of  the  upgrade  of  the  UCC  National  Import  Systems  project  (with  a  2022  deployment 
deadline).  

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

To  summarise  for  the  national  systems,  Member  States  are  making  strong  efforts,  sometimes 
through intense collaboration, to progress the implementation of the requirements for NA/PN/TS, 
the adjustments to the National Import Systems and the interrelated Special Procedures. As the 
deployment deadline is approaching, 31 December 2022 for all three, Member States should pay careful 
attention to this matter, in particular the six Member States that could not confirm a timely deployment 
for NA, the four Member States for PN, the three Member States for TS and the two Member States for 
NIS as displayed in tables 14, 15, 16 and 18 of the Staff Working Document accompanying this report. 

4.3  Risks for delays 

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

The Member States are also advancing significantly with the developments under their responsibility. 
However, as stated in section 4.2.2, some Member States have reported some delay beyond the legal 
deadlines. The tables in the accompanying Staff Working Document, where the reported delays by the 
Member States can be viewed, are mentioned for each project listed below.  

  For 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 (Table 14). More specifically, three of these Member States (BG, EE and 
ES)  have  reported  that  they  would  use  the  NA  integrated  in  ICS2  –  Release  2  (planned 
deployment 01 March 2023). For BE and NL, the delay is limited to two months. DE and IE 
marked as not applicable and no planned date was provided by DK, MT and SK. 

  For the implementation of the Presentation Notification, the following Member States have 
indicated  a  planned  operations  date  for  PN  that is  later  than  the  deadline  in  the  UCC  Work 
Programme: BE, EE, NL and SE (Table 15). More specifically for BE and NL, the estimated 
delay is limited to two months. EE and SE plan to have a timely deployment of their national 
system but the migration of all economic operators would be gradual and ending beyond the 
deadline of 31 December 2022. No planned date was provided by PL, RO and SK.  

  For the implementation of Temporary Storage, the following Member States have indicated a 
planned operations date that is two months later than the deadline in the UCC Work Programme: 
BE, EE and NL (Table 16). BE and NL reported a delay of 1 quarter; EE would have a timely 
deployment of their system but the migration of all economic operators would be gradual and 
ending beyond the deadline of 31 December 2022. No planned date was provided by DK, PL, 
RO or SK. 

  For  the  implementation  of  the  National  Import  Systems  Upgrade,  the  following  Member 
States have indicated a planned operations date that is later than the deadline in the UCC Work 
Programme: BE (limited to few days) and MT (2 quarters) (Table 18). No planned date was 
provided by DK, PL, RO or SK. Furthermore, GR and LT have reported not having started yet 
with the technical specifications which could also be problematic in terms of progress achieved 
in view of the deadline of 31 December 2022.  

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  For  the  implementation  of  ICS2  –  Release  2,  the  following  Member  State  has  indicated  a 
planned  deployment  date  that  is  later  than  the  deadline  in  the  UCC  Work  Programme:  MT 
(Table 28). No planned date was provided by BE, GR, IT, or RO. 

  For  the  implementation  of  PoUS  –  Phase  1,  the  following  Member  States  have  indicated  a 
planned deployment date that is later than the deadline in the UCC Work Programme: CZ and 
HU (Table 32). No planned date was provided by BE, DK, GR, IT, LT, MT, or PL. 

  For the implementation of CCI – Phase 1, the following Member State has indicated a planned 
deployment and operations date that is later than the deadline in the UCC Work Programme: 
DE (Table 36). This planning is later in comparison to the 2020 report. DE has indicated 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, see Section 4.7 of Staff Working Document. No planned date was provided by SE. 

  For the implementation of CCI  – Phase 2, the following Member State indicated a planned 
operations date which is later than the deadline in the Work Programme: DE (Table 37). DE’s 
planned deployment date in that table is one month later than the target date set in the WP and 
they will be providing a migration period that runs to 30 June 2026. However, subsequent to the 
collection of the data in Table 37, DE has indicated that it intends to deploy Phase 2 within the 
deployment window of the UCC WP. 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. No planned date was provided by BE or SE. 

  For  the  implementation  of  NCTS-P5  and  AES-P1,  while  Member  States  are  making  good 
progress and all Member States confirmed that they will be ready by 1 December 2023, there is 
growing evidence that several might face considerable difficulties to meet their commitments 
due  to  late  starts,  procurement  difficulties,  implementation  delays,  insufficient  resources, 
COVID-19 and trade transition.  

Collectively, the Member States have reached 26% of the transition milestones, from 18% by 
end 2020 underlining the significant progress. However, it is short of the anticipated 36%. A 
significant number of Member States are facing difficulties to meet the legal obligations.  The 
transition of the Member States has already shifted by more than one quarter since end 2020 
and may slip further as 40% of the Member States are currently reviewing their national plans 
and others face significant difficulties to get the necessary resources. The Commission considers 
that half of the Member States plans present serious risks for the orderly and timely deployment 
of  the  AES-P1  and  NCTS-P5  by  the  deadline  of  the  1  December  2023.  This  situation  may 
expose the deadline if left without a dynamic and powerful response of the Member States. It is 
essential that  all Member States are ready in time  with proper contingency to enter  into full 
operations on 1 December 2023. 

  For the implementation of NCTS-P6, the Member States raised some concerns on the planning 
as the misalignment of the NCTS-P6 and ICS2 - Release 3 deployment dates as reflected in the 
MASP-C and the UCC Work Programme raises implementation difficulties. The Commission 
has taken the necessary actions to resolve the issue, whilst keeping the dates within the deadlines 
set in the UCC. 

  For  the  implementation  of  the  GUM  national  component  2,  most  Member  States  are 
scheduling a timely deployment and operation, except for FI and FR (approximately 1 month 
of delay) (Table 25). As this is one of the systems to be implemented only by 2025 and the 
delays reported are limited, there is still time to address this risk. 

On the side of the Member States, a number of overall risks continue to be repeated year after year. A 
continuing source of difficulties is their lack of resources and the need for further integration of the UCC 
projects. They have also provided several mitigating actions to avoid a delay in the start of operations. 
It is to be noted that the risk by Member States was considered in combination with other external factors 
(see  Tables  12,  13,  17,  34,  35  and  38  of  the  Staff  Working  Document  accompanying  this  report).  

11 

 
 
 
 
Furthermore, in the 2020 Annual Progress Report, the Member States pointed already at the difficulties 
in meeting the obligations on customs systems imposed by the VAT eCommerce package adopted 
on  5  December  201710.  With  the  postponement  of  the  new  rules  by  six  months  (01/01/2021  to 
01/07/2021),  the  Member  States  had  more  time  to  meet  the  legal  deadlines  for  the  national 
developments, though a few Member States reported collateral impact of the VAT eCommerce initiative 
on  the  UCC  implementation.  Five  Member  States  reported  the  need  for  re-planning  of  some  UCC 
activities and for upscaling platforms and supporting IT systems.  

Concerning the challenges brought about due to the COVID-19 pandemic, the Commission reported 
again that for its own activities, no impact is to be noted. The Member States reported that there has 
been additional pressure on their national planning and on the number of human resources available 
internally and externally (IT contractors and economic operators). 

In  conclusion,  the  assessment  of  the  main  risks  for  the  timely  implementation  of  the  UCC  systems 
revealed that the risks are situated mostly on the side of the Member States and linked to resource 
constraints,  the  complexity  of the  projects  and their integration,  procurement  and  contractual 
issues and some external factors such as the COVID-19 pandemic. The Commission will continue 
to  support  the  Member  States  to  avoid  that  the  risks  materialise  into  late  deployments  of  electronic 
systems as described in section 4.4 below.  

4.4  Mitigation actions 

Further to the mitigation actions started in 2020 to reduce the risk on the data instability, the Commission 
adopted the necessary amendments to UCC-DA11 and UCC-IA12 on 07 December 2020 and 08 February 
2021 respectively and published in the Official Journal (OJ) on 23/02/2021, entering into force on 15 
March  2021.  With  these  amendments  the  Annex  B  data  requirements  are  stabilised  for  further 
implementation in the electronic systems.  An annual Annex B change management exercise was put in 
place during 2021 to handle possible further corrections. 

To  enable  the  timely  IT  implementation  of  the  UCC  and  the  MASP-C,  the  Commission  put  a  new 
framework  contract  in  place  in  2021  for  the  external  outsourcing  of  its  IT  development  activities, 
incorporating an IT modernisation track based on innovation and agility. The IT modernisation process 
underway in DG TAXUD  allows for quicker fixes, parallel work and a more balanced workload  by 
splitting  into  digestible  work  packages  and  iterations.  The  mechanism  for  enhanced  collaboration 
between  all  stakeholders  from  the  outset  of  the  projects  continues  to  improve  the  quality  of  the 
preparatory activities and avoids difficulty in decision-taking and additional requirements at later stages.  

In terms of monitoring the progress of the UCC WP implementation, several instruments were used by 
the Commission. 

Firstly, the  Multi-Annual Strategic  Plan for  Customs  (MASP-C)  dashboard continues  to  be  used for 
progress tracking of all ongoing projects in order for the Commission to identify potential delays at an 
early stage. The baseline for the dashboard milestones is the MASP-C 2019 and the UCC WP 2019. The 
dashboard is presented on a quarterly basis to the Member States (Electronic Customs Coordination 
Group) and the trade community (Trade Contact Group) for information and steering purposes.  

Secondly, the Commission established coordination and monitoring programmes for the decentralised 
trans-European systems. 

For instance, for the implementation of the ICS2 programme, the Commission continued with the “ICS2 
trans-European coordination activities”13 to ensure the successful deployment of ICS2 – Release 1. The 
focus then shifted from ICS2 – Release 1 to the Releases 2 and 3. The Commission provided support to 

10 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33) 
11 Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No 952/2013 of the 
European Parliament and of the Council in regard to the detailed rules concerning certain provisions of the Union Customs 
Code (OJ L 343, 29.12.2015, p. 1-557). 
12 Commission Implementing Regulation (EU) 2015/2447 of 24 November 2015 laying down detailed rules for implementing 
certain provisions of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union 
Customs Code (OJ L 343, 29.12.2015, p. 1-558-893). 
13 ICS2 trans-European coordination activity strand, as integral element of the ICS2 programme, was launched in 2018. 

12 

 
 
 
                                                      
the Member States and economic operators in their development activities via a set of activities that 
included: 

  Organisation of webinars involving participants from Member States, economic operators 

and international organisations in addition to the provision of guidance material;  

  Close and continuous monitoring, support to the coordination of conformance test activities 
and  stimulating  national  administrations  and  economic  operators  to  co-ordinate  their 
individual projects;  

  Online  training  sessions  and  training  material,  communication  campaigns,  including  the 
creation  of  ICS2  content  on  the  Europa  website,  a  social  media  campaign  and  direct 
communication to stakeholders and multipliers;  

  Bilateral meetings with those Member States that were delayed and missed the  expected 
date  to  start  operation  as  of  15  March  2021  in  accordance  with  the  UCC  WP.  The 
Commission  and  affected  Member  States  discussed  necessary  mitigation  actions  and 
measures to ensure implementation of Release 1 as early as possible and prior to the end of 
the deployment window (1 October 2021) defined in the UCC WP. The deployment window 
from  15  March  2021  to  1  October  2021  could  be  granted  to  the  economic  operators  to 
connect to ICS2 and start lodging ENS in ICS2. 

Also for the trans-European systems NCTS-P5 and AES, the Commission continued with the “National 
Administration coordination and monitoring programme” using key performance indicators to regularly 
assess progress and raise alerts. The quarterly monitoring includes setting interim milestones per project 
(e.g. milestones by which all Member States should have completed the conformance testing). Such 
close monitoring is needed in order to make the deployment of the decentralised trans-European systems 
manageable and to avoid additional costs for operating old and new systems in  case of an extended 
deployment window. 

Additionally, in order to support the Member States in the development and deployment of their national 
components  for  the  trans-European  NCTS-P5  and  AES  systems,  the  Commission  extended  this 
coordination  programme  in  2021  with  a  personalised  support  and  coaching  for  each  of  the Member 
State,  to  assist  them  to  de-risk  the  national  projects  and  to  provide  them  with  a  seamless  testing 
experience, speeding up their readiness and mitigating technical risks while deploying their national 
systems into the trans-European systems. An ambitious training programme has been put in place by the 
Commission.  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 results achieved during the years 2020 and 2021 can be found in the Staff Working 
Document, section 4.8.1.  The output of these programmes brings valuable progress information and 
will continue to be used for the future Annual Progress Reports.  

In its coordinating role, the Commission has highlighted the progress and the risks to the Member States 
and urged the Directors-General of the Member States’ administrations to take the necessary actions to 
address these issues.  The Member States that plan to enter into operation during the last two quarters 
of 2023 were invited to take all necessary steps to advance their plans and to de-risk them to avoid that 
they  end  up  withholding  the  end  of  the  transition  planned  for  1  December  2023  at  the  costs  of  the 
Member States which have invested to reap the full benefit of the UCC from this date. 

Throughout 2021 the Commission also supported the Member States that expressed concerns about the 
timely implementation of their national projects. The Commission held bilateral meetings to discuss 
the  individual  Member  States’  concerns  and  needs  including  providing  clarifications  on  legal issues 
relevant  to  their  national  developments,  as  well  as  providing  support  to  respond  to  questions  raised 
during the course of the business and IT analysis and of the development performed by the Member 
States. Some Member States were able to advance their planning and reduce the risk for delays. Others 
continued their intense collaboration work for the implementation of the project AN/PN/TS and to join 
forces in the Expert Team. The Commission continues with the funding from the Customs Programme 
for the Expert Team on new approaches to develop and operate Customs IT systems (ETCIT).  

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Furthermore, the Member States have mentioned the following types of mitigating actions: use of an 
Agile  development  methodology,  outsourcing  more  development  activities,  mobilising  additional 
resources,  breaking  the  projects  up  into  several  stages  and  prioritising  a  core  scope  and  potentially 
changing the organisational set-up with their suppliers to achieve a more efficient development process. 

The Commission has and will continue to regularly monitor the situation, through bilateral contacts to 
understand the problems, assist where possible and emphasise to the Member States concerned the need 
to mitigate the risk of delays. 

The Directors-General of the National Administrations have been informed at the Customs Policy Group 
of the need for quarterly monitoring for all IT systems development, not just trans-European. This will 
augment  the  current  twice  yearly  reporting  of  national  planning  information  provided  under  Article 
278a(4) UCC in the lead up to the critical period for the implementation of these changes to national 
systems. Ultimately, the timely implementation of the national components remains the responsibility 
of the Member States.  

5.  MANAGEMENT SUMMARY AND CONCLUSIONS 

Tangible  progress  is  being  made  in  the  implementation  of  the  UCC  WP.  An  increasing  number  of 
electronic systems were deployed and are now fully operational.  

More details of the planning and status of each project are provided in the Commission Staff Working 
Document published alongside this report. A summarised overview of the planning and progress can 
be found in Figure 4 below.  

Figure 4 – Planning for the UCC Work Programme projects 

14 

 
 
 
 
 
 
 
 
In 2021, the following key elements for progress and risks were reported: 

ICS2 – Release 1 was successfully deployed in 2021 by the Commission, all Member States and all 
postal operators and express couriers involved. The system is processing large amount of data with about 
10 million ENS per month. 

NCTS-P5 and AES were also successfully put in production this year with the entry in operation 
of its first Member State. Intensive collaborative testing de-risks the technicalities of the transition. 
Collective intelligence and agility with Member States and trade are the key asset fuelling these projects 
towards  their  targets.  The  projects  are  on  track  and  the  Member  States  started  to  publish  their 
specifications for the traders.  

However,  the  Commission  considered  that  half  of  the  national  plans  present  serious  risks  for  the 
orderly  and  timely  deployment  of  the  NCTS-P5  and  AES  by  the  legal  deadline  and  invited  the 
Member  States  to  take  all  necessary  steps  to  advance  their  plan  and  de-risk  them  to  avoid 
compromising  the  end  date  of  the  deployment  window,  establishing  the  end  of  the  transitional 
arrangements.  

Similar  warning  for  the  national  projects  where  risks  for  delays  were  reported  by  some  Member 
States, in particular in the domain of entry of goods into the EU. The deployment date as well as the roll 
out and full operation with all economic operators should fall within the deployment windows set by the 
UCC WP.  

Economic operators referred to the trans-European system for Centralised Clearance at import as one of 
the key projects contributing to the trade facilitation objective of the UCC. This system will have its first 
deployments in 2022. All Member States, except for one, reported to be able to implement this system 
within the deployment window of the UCC WP. However, in case serious delays occur on the national 
projects, there might also be an impact on this  flagship project of the UCC. Close monitoring of the 
progress of the national activities will be important in the years to come. 

The  assessment  of  the  progress  and  risks  continues  to  indicate  that  the  challenges  to  meet  the  legal 
deadlines  are  situated  primarily  on  the  side  of  the  Member  States.  The  Member  States  refer  to 
resource issues, the impact of the COVID-19 pandemic, to many other obligations to be implemented 
via customs systems and to the complexity and interconnectivity of systems. As highlighted throughout 
the report, all Member States have expressed their willingness to define and undertake mitigating actions 
to ensure that they respect the planning deadlines set out in the UCC WP.  

In conclusion, the projects continue to be mostly on track and feasible for completion in line with 
the planning of the projects defined in the UCC WP as far as priority is given to address the risks by 
means of a strong engagement in urgent and concrete actions. The Commission commits to continue 
to support, coordinate and carefully monitor the progress on the side of the Member States during the 
coming years and to undertake some specific actions to ensure a timely implementation of the national 
as well as trans-European systems. 

15