REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278(a) of the Union Customs Code, on progress in developing the electronic systems provided for under the Code
Date: 2023-02-10
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, 10.2.2023  COM(2023) 68 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278(a) of the Union Customs Code, on progress in developing the electronic systems provided for under the Code {SWD(2023) 29 final}  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

pursuant to Article 278(a) of the Union Customs Code, on progress in developing the 
electronic systems provided for under the Code 

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 by 2022 .................................................................................................. 4 

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

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

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

4.3 

Risks for delays to the UCC IT implementation ................................................................. 9 

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

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

1 

 
 
 
 
 
 
 
 
 
 
1.  INTRODUCTION 

This is the fourth report from the Commission pursuant to Article 278(a) of the Union Customs Code 
(UCC)1  on  progress  in  developing  the  electronic  systems  provided  for  under  the  UCC2.  This  year’s 
report  elaborates  on  the  continuing  progress  in  developing  the  electronic  systems  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)3, 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); 
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.  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 illustrates that while some of the remaining projects are on track for completion in line with the 
planning  schedule,  others  (primarily  national  systems)  are  experiencing  delays  beyond  the  legal 
deadlines which required the Commission to grant derogations. More details of the planning and status 
of  each  project  are  provided  in  the  Commission  Staff  Working  Document4  published  alongside  this 
report.  

2.  BACKGROUND 

The UCC entered into force on 1 May 2016 and following its amendment in 20195, 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 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 Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down 
 the Union Customs Code (OJ L 269, 10.10.2013, p. 1–101). 
2 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  
2021: https://eur-lex.europa.eu/legal-content/GA/ALL/?uri=CELEX:52021DC0791 
3 Commission Implementing Decision (EU) 2019/2151 of 13 December 2019 establishing the work programme relating to the 
development and deployment of the electronic systems provided for in the Union Customs Code (OJ L 325, 16.12.2019, p. 
168–182). 
4 Commission Staff Working Document Accompanying the Report from the Commission to the European Parliament and the 
Council pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for 
under the Code, SWD(2023) 29 final. 
5 Regulation (EU) 2019/632 of the European Parliament and of the Council of 17 April 2019 amending Regulation (EU) No 
952/2013 to prolong the transitional use of means other than the electronic data-processing techniques provided for in the Union 
Customs Code (OJ L 111, 25.4.2019, p. 54–58). 

2 

 
 
 
 
                                                      
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  relevant  information 
through the following sources:  

(1) national plans that Member States are required to provide twice a year (January and June).  

(2) a survey circulated amongst its services and to the Member States to capture the progress. 

Through the survey, information was collected from both the Member States and the Commission on 
the actual progress against the plans. 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  estimated  complexity  of  the  projects,  the  challenges  faced,  the  anticipated  risks,  the  delays  and 
reasons for any such delays and the mitigating measures planned and/or taken.  

(3) a dedicated survey on the implementation of national projects. 

The  dedicated  survey  on  the  progress  in  the  implementation  of  the  national  projects  gave  a  broad 
perspective  on  the  advancements  made  by  the  Member  States  related  to  Notification  of  Arrival, 
Presentation Notification, Temporary Storage, Special Procedures Component 2 and National Import 
Systems Upgrade in the light of the upcoming UCC deadline of 31 December 2022. 

(4)  bilateral  high-level  meetings  between  the  Commission’s  Directorate-General  for  Taxation  and 
Customs Union (DG TAXUD) and the Member States Customs IT Directorates. 

The outcome of the surveys gave the Commission a clear view on the status of each system. Though it 
was found important to gain up to date knowledge to have a full and accurate picture of the status of 
each of the UCC projects on the side of the Member States, to understand the issues they were facing 
and to provide ideas for improving problematic situations. Therefore, bilateral high-level meetings were 
organised with each Member State’s Customs IT Directorate. 

(5) outputs from the trans-European coordination and monitoring programmes. 

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

This annual report covers a reflection of the progress achieved on 30 June 2022 including a view 
on the expected progress by 31 December 2022 to have a full picture of the progress made in 2022. 

3.  PROJECT METHODOLOGY FOR THE UCC ELECTRONIC SYSTEMS 

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  more in parallel 
and through close collaboration from the start with experts from legal, business and IT, both from the 
Commission and the Member States. The Commission and the Member States are 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 addition, the Commission systematically consults the trade community 
through the Trade Contact Group. Member States have the responsibility to be in direct contact with 
their  traders  about  the  national  plans  and  trade  documentation.  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. 

3 

 
 
 
 
 
 
 
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 projects 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 by 2022 

The Commission can report the successful deployment of the following new systems or upgrades:  

 

 

 

 

 

 

 

 

 

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. 

UCC Import Control System 2 - Release 1 – ICS2 - Release 1 (upgrade): Deployed in 
2021. 

4.2  Ongoing projects 

For the ongoing projects, this report aims to highlight the achievements made in 2022 but also to identify 
the issues which have arisen with the implementation of the national projects.  

The trans-European projects planned for deployment between 2023 and 2025 are outlined in Section 
4.2.1. Four of these projects have deployment windows ending in 2023.  

The focus of this report is put on the implementation of the three national projects mentioned in Section 
4.2.2,  namely  Notification  of  Arrival,  Presentation  Notification  and  Temporary  Storage,  Special 
Procedures – Component 2 and National Import Systems Upgrade. These are planned to be operational 
by the 31st of December 2022, as defined in the UCC. However, many Member States have reported to 
the Commission an inability to meet the date provided for in the UCC further building upon the risk 
outlined in previous UCC Annual Progress Reports.  

4.2.1 Trans-European projects 

Regarding the trans-European projects, a series of IT project documents were prepared and agreed upon 
in 2022 as the basis for the systems’ development work. 

These  trans-European  projects  have  a  specific  architecture,  sometimes  requiring  a  combination  of 
central and national components and one or more project phases, due by 31 December 2025 at the latest, 
pursuant to Article 278(3) UCC. The description and progress for each project is presented below. 

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. The decentralized component 

4 

 
 
 
GUM 2 is to be developed at national level, giving Member States the possibility to include 
functionalities6 that are needed only at national level (for example, national guarantees). 

Progress: In view of the legal milestones in the UCC WP, the Commission has completed 
the  technical  specifications  by  30  September  2022 for  Component  1  related to the  trans-
European GUM and the Member States should complete theirs by 30 November 2024 for 
Component 2 related to the National Guarantee Management system.  

Concerning  the  National  Guarantee  Management  system,  Member  States  have  indicated 
predominantly a low risk level on the on-time delivery of the project, with a medium/low 
complexity level. Four Member States have reported that their national component for the 
system is now deployed, having only two Member States with anticipated delays regarding 
the operations milestone. 

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

Progress: The development of Release 2, using Release 1 as the baseline, is ongoing. This 
second release includes new business models reflecting the business needs, rules and user 
interfaces, adding an increased complexity of timers, data quality, data consistency rules and 
linking for multiple filings and arrival notifications.  

A challenge at the current moment is the migration from Release 1 to Release 2, considering 
its different transition windows. The transition strategy was finalised and published in 2021 
and  the  crisis  management  protocols  and  procedures  24/7/365  were  agreed  upon  and 
distributed to all Member States. Currently, the Member States are preparing the national 
functional and technical specifications based on the common EU specifications provided by 
DG TAXUD. An increased complexity level has been indicated by Member States in their 
development progress, in particular concerning the increased number of third country trade 
stakeholders  to  be  reached  and  their  readiness  for  testing.  This  entails  risks  for  timely 
readiness by Member States and trade.  

The work on the ‘Operational guidance compendium’ for Release 2 has been completed as 
of Q1 2022 and at the same time, the ‘Business continuity plan’ was updated to cover Release 
2 operations. The ‘End-to-End organisation document’ was published for Member States and 
economic operators in April 2022. To prepare Member States’ customs administrations for 
the ICS2 Conformance Testing training campaigns took place in Q2 2022. The Conformance 
Testing activities themselves started in Q3 2022.  

Concerning the status reported on the development for ICS2, the Member States are currently 
focused on Release 2.  

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.  

6 Apart from the common functionalities for GUM Component 1. 

5 

 
 
 
                                                      
Progress: For PoUS – Phase 1 the Technical and System Specifications were completed in 
Q1  2022.  An  agile-like  development  approach  is  being  used  for  this  project,  progressing 
according to the planning set by the UCC WP7.  

At  the  time  of  writing,  the  construction  phase  is  in  progress  and  it  is  planned  to  end  in 
November 2022. Conformance testing is envisaged to start still in 2022. 

As regards PoUS – Phase 2, the Functional Specifications for the Customs Goods Manifest 
(“CGM”)  were  accepted  by  the  Member  States  in  Q2  2021,  with  Technical  and  System 
Specifications  planned  to  start  in  Q1  2023.  As  a  result  of  the  work  on  the  technical 
implementation and recent legal discussions, a change management activity was undertaken 
to align the functional specifications.  

It was highlighted that the deployment date of the PoUS Phase 2 CGM (2 June 2025) is not 
fully aligned to the European Maritime Single Window environment (EMSWe) deployment 
date  (15  August  2025).  Considering  that  the  PoUS  system  is  envisaged  to  receive 
considerable volume of the CGM through the EMSWe and the gap between the dates would 
create  unnecessary  burden  for  Trade,  it  is  envisaged  to  ensure  the  alignment  of  the 
deployment dates for these two projects. 

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,  as  of  Q1  2022  pre-conformance  test  activities  have 
started with “forerunner” Member States and one Member State envisaged to finish its testing 
activities by December 2022 and to deploy CCI with a standard declaration in Q1 2023.  

In terms of assessing the level of completeness of the system, approximatively 75% of the 
Member States reported that the system development is on target. However, there are several 
Member States that have indicated that at the current stage their deployment will be delayed 
beyond the deadline defined in the UCC WP. This may mean that some traders wishing to 
avail  of  centralised  clearance  for  all  their  operations  may  be  delayed  in  doing  so  for 
transactions in some Member States. 

The Commission finalised the Technical Specifications for CCI - Phase 2 by 30 June 2022, 
well ahead of the planned start of 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.  

Progress: Since the acceptance of the Technical Specifications, the national  development 
part of NCTS – Phase 5 has been struggling to get the necessary resources as the Member 
States’  focus  was  shifted  to  higher  priority  areas.  The  entry  in  operation  experiences  a 
significant  shift  to  2023  and  in  particular  to  Q4  of  2023,  raising  further  the  pressure  on 
milestone  of  1  December  2023.  Overall,  all  Member  States  have  progressed  in  the 
deployment of their systems. However, the slow progress achieved in the deployment of their 
national systems indicate a great risk for delays in the completion of NCTS - Phase 5. At the 
current  moment,  the  level of  completeness  of  the  transition is  currently  at  48%,  with  the 
envisaged percentage initially being set for 72%. Despite this, the majority of Member States 
have reported to remain on-track for the “Big Bang” transition planned for 1 December 2023. 

7 According to the UCC Work Programme, the component is anticipated to enter into production on 2 June 2025. 

6 

 
 
 
                                                      
As regards NCTS – Phase 5, all Member States but three confirmed their planning to start 
operations during the deployment window from Q1 2021 until Q4 2023. This is illustrated 
in Figure 1. The yellow bar indicates the time-limit for the Member States to prepare the 
closure of the existing export and transit systems and start operating the new ones in order 
to be ready for the legal deadline indicated by the red bar.  

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

For  NCTS  -  Phase  6 (interconnection  with  other  systems),  the  Business  Case  and  Vision 
Document were approved by the ITSC, ITCB and ECCG in Q4 2021. The functional and 
technical specifications are being elaborated in parallel, in iterations. Conformance Testing 
and Deployment may be affected by some Member States deploying the  NCTS - Phase 5 
later than planned. 

6) 

UCC Automated Export System – AES, the 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.  

Progress: The highlight of the 1st half of 2022 is the start of the international operation for 
AES  –  Component  1,  with  two  Member  States  in  April  2022.  Another  five  will  join  the 
operation by end 2022, early 2023. A representative number of Member States have either 
progressed or completed their Technical Specifications, while four Member States have not 
yet  initiated  the  activities  related  to  them.  The  transition  periods  offered  by  the  Member 
States to their trader communities are increasingly squeezed, if not downright suppressed, by 
imposing  a  “Big  Bang”  transition  caused  by  lack  of  time.  All  Member  States  but  three 
confirmed their planning to start operations during the deployment window from Q1 2021 
until Q4 2023. This is illustrated in Figure 2.  

7 

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

For AES – Component 2, the National Export Systems upgrade, a representative number of 
Member States have either progressed or completed their Technical Specifications, while six 
Member States reported to have not yet initiated the activities related to them. 

To summarise the status of the 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 MASP-C of 2019. As regards the Member States’ deployments of the national components of these 
trans-European systems, some risks for delays have been identified, in particular for ICS2 – Release 2, 
CCI - Phase 1, AES and NCTS – Phase 5 (see Section 4.3). 

Finally, it is important to highlight that in view of the implementation of the UCC WP, the Commission 
will have performed approximately 87% of its activities by December 2022 (last year 84% of the totality 
of its development work was completed). 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 reflecting the progress and planning 
of DG TAXUD. 

Timing 
By end 2022 
By end 2023 
By end 2024 
By end 2025 

% Completed 
87% 
95% 
97% 
100% 

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

Whilst for most of the Commission’s own project activities the roll-out is not dependent on the national 
progress,  there  is  an  impact  for  some  type  of  activities  performed  in  close  collaboration  by  the 
Commission and the Member States such as the conformance testing of a national component of a trans-
European system. Via this collateral impact, one can say that the delays by specific Member States on 
the implementation of their national components do have an impact on the overall achievements in the 
delivery of the UCC. 

8 

 
 
 
 
 
 
 
 
 
4.2.2 National projects 

Member States are due to complete the upgrade of their three fully national projects8. The development 
activities are a national matter, with processes and data requirements for the external domain defined 
through Union legislation.  

The three national projects 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 (AN, 
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: The timely delivery of the required national systems by all Member States was 
already identified as at risk in last year’s report. Additional delays in comparison with the 
UCC  Annual  Progress  Report  2021  are  noted.  By  end  2022,  AN,  PN  and  TS  have  been 
completed  only  by  4,  7  and  6  Member  States,  respectively  –  see  section  3.1.2  of  the 
Commission Staff Working Document accompanying this Report. 

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: Additional delays in comparison with the UCC Annual Progress Report 2021 are 
noted. By end 2022, NIS has been upgraded to the UCC requirements only by 10 Member 
States – see section 3.2.2 of the Commission Staff Working Document accompanying this 
Report. 

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 
special  procedures  in  their  national  systems.  The  Import  Component  will  be  part  of  the 
upgrade of the UCC National Import Systems project, while the Export Component of the 
SP  will  be  implemented  in-line  with  and  as  part  of  the  national  UCC  Automated  Export 
System (AES) project.  

Progress:  Considering  the  existing  interdependencies  with  the  National  Import  Systems 
(upgrade), and other specific circumstances, several Member States are unable to meet the 
legal deadline  for SP Import  Component. 15 Member States envisaged completion of the 
development activities for SP  Import  Component by  end 2022  – see section 3.3.2. of the 
Commission Staff Working Document accompanying this Report. However, some might not 
have met this milestone in view of the latest developments reported for their NIS upgrade. 
For SP Export Component with a deadline of 1 December 2023 the situation looks better 
with most Member States planning the deployment within the deadlines. 

To summarise, despite the efforts made, many Member States experienced delays and will therefore 
not  be  able  to  meet  the  deadline  provided  by  the  UCC  for  national  systems  to  be  operational  (31 
December 2022).  

4.3  Risks for delays to the UCC IT implementation 

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 which would lead to 
late deployment have been reported. However, though we have differentiated in this report the progress 
on the side of the Commission from the progress on the side of Member States, there is a degree of spill-

8 This timeline excludes the export component of the national Special Procedures system, for which the activity and planning 
is interlinked with the Automated Export System (AES). 

9 

 
 
 
                                                      
over from the national delays on the progress of the trans-European systems such as ICS2, CCI, AES 
and  NCTS,  and  consequently  also  in  a  limited  way  on  the  Commission  activities.  This  occurs  for 
instance  in  terms  of  longer  resource  investment  for  conformance  testing,  for  trans-European 
coordination  support  and  monitoring,  in  terms  of  providing  assistance  in  alternative  national 
development and deployment schemes, and even of the prolonged maintenance of central components 
put in place for the transition.   

Looking at the Member States’ overall progress in implementation, they are advancing gradually 
with the developments under their responsibility, but most of them more slowly than planned, which 
leads  to  the  situation  that  delays  have  been  reported  for  one  or  more  projects  beyond  the  legal 
deadlines.   
The Member States presented a variety of reasons as justification for the delays reported. Most of the 
issues  and  risks  have  been  observed  year  after  year,  impacting  the  progress  of  their  activities  and 
ultimately causing delays in their systems development. Key sources of difficulties and risks for delays 
indicated by the Member States are their lack of financial and human resources, the impact and re-
planning  due  to  the  VAT  eCommerce  package9,  specific  working  circumstances  caused  by  the 
COVID-19  pandemic,  competing  priorities  and  the  impact  of  Brexit  and  the  war  in  Ukraine  on 
customs. Member States also referred to national IT infrastructures not being able to cope with the 
needs  of  the  projects,  contractors’  capacity  issues  and  dependencies  with  other  stakeholders, 
transition and testing with the economic operators, late or unsuccessful calls for tenders to outsource 
pieces of work, and complex system integrations of the UCC projects.  

Considering  that  the  UCC  Work  Programme  was  established  in  April  2019  and  the  Commission 
delivered its functional and technical specifications on time for the trans-European systems, it seems 
problematic from a governance perspective that there are still a few Member States where tenders have 
not  yet  been  awarded  (at  the  time  of  our  assessment  with  the  Member  States)  or  where  there  are 
substantial problems in the national procurement process.   

The Commission held bilateral meetings to discuss with all the individual Member States their issues, 
to reiterate that priority should be put on the UCC projects and to advice on possible follow-up actions 
and measures. In this context, twenty-four Member States sent formal requests for derogations to 
the  Commission  in  accordance  with  Article  6(4)  of  the  UCC  concerning  the  delay  of  the  national 
projects  beyond  the  deadline  of  31  December  2022.  An  overview  of  the  derogations  requested  by 
Member States is provided below: 

  For  the  implementation  of  the  Notification  of  Arrival,  the  following  Member  States  have 
requested a derogation: AT, BG, BE, CY, CZ, DK, EE, ES, FR, EL, HU, HR, LU, MT, NL, PL, 
PT, RO, SE, SI and SK. At the same time, AT, BG, CY, DE, EE, ES, FI, FR, HR, HU, LT, LV, 
NL, PL, RO, SE and SI have reported that they would use the AN integrated in ICS2 – Release 
2  (planned  deployment  1  March  2023).  DE  and  IE  marked  Notification  of  Arrival  as  not 
applicable. 

  For the implementation of the Presentation Notification, the following Member States have 
requested a derogation: AT, BE, CY, CZ, DK, EE, ES, FR, EL, HU, HR, LU, MT, NL, PL, PT, 
RO, SE, SI and SK.   

  For the implementation of Temporary Storage, the following Member States have requested a 
derogation: AT, BE, CY, CZ, DK, EE, ES, FR, EL, HU, HR, LT, LU, MT, NL, PL, PT, RO, 
SE, SI and SK.  

  For  the  implementation  of  the  National  Import  Systems  Upgrade,  the  following  Member 
States have requested a derogation: AT, BE, CY, CZ, DK, ES, FR, EL, HU, LT, LU, MT, NL, 
PT,  RO  and  SE.  These  delays  will  impact  the  trans-European  CCI  project  and  Special 

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

10 

 
 
 
 
                                                      
Procedures – Component 2, which follows the same timeline as the National Import System 
Upgrade. 

The Commission carefully assessed the requests received by each Member State and the justifications 
provided by them in terms of specific circumstances and adopted Implementing Decisions granting 
derogations to the requesting Member State for a limited period of time, lasting until not later than 31 
December 2023, for the Notification of Arrival, Presentation Notification,Temporary Storage, National 
Import System.. Furthermore, for the national entry project, an iterative approach will be allowed for 
the maritime transport mode in view of the alignment to the date set in the UCC Work Programme for 
ICS2 - Release 3.  

Besides the information collected for this Annual Progress Report, and as reflected in the accompanying 
Staff Working Document, several Member States have informed the Commission separately and in 
a formal manner (through derogation request) about delays on the other (mainly trans-European) 
projects: 

  For the implementation of ICS2 – Release 2, the following Member States have requested a 
derogation: AT, DK, EE, FR, EL, NL and RO. On the same note, CY, FI, FR, EL and NL have 
reported delays regarding ICS2 – Release 3. See section 4.3.1 and 4.3.2 of the accompanying 
document to this Report. 

  For the implementation of PoUS – Phase 1, the following Member State has indicated a planned 
deployment date that is later than the deadline in the UCC Work Programme: EL. For Phase 2 
FI  has  reported  delays in  its  system  implementation. See  section  4.4.2  of  the  accompanying 
document to this Report. 

  For  the  implementation  of  CCI  –  Phase  1,  the  following  Member  States  have  indicated  a 
planned operations date that is later than the deadline in the UCC Work Programme: DE, DK, 
FI, FR and EL. For CCI – Phase 2, EE and FI indicated a planned operations date which is later 
than the deadline in the Work Programme. See section 4.5.2 of the accompanying document to 
this Report. 

  For NCTS – Phase 5, AT, LT and NL have indicated delays regarding the deployment of the 

system. See section 4.6.2 of the accompanying document to this Report.  

  For  the  implementation  of  AES  –  Component  1,  AT,  FI  and  SE  have  indicated  a  planned 
operations date later than in the UCC Work Programme. See section 4.7.2 of the accompanying 
document to this Report. 

  For the implementation of GUM – Component 2, the following Member States have indicated 
a planned operations date that is later than the deadline in the UCC Work Programme: FI and 
FR. See section 4.2.2 of the accompanying document to this Report. 

The Commission is analysing and monitoring the situation very closely for the above projects and is 
taking measures to increase its support –(see Section 4.4. below). 

In conclusion, a majority of the Member States have not been able to mitigate properly the risks 
outlined in the previous Reports and delays did actually occur for the national entry and import 
projects  with  implementation  date  31  December  2022.  The  delays  being  experienced  on  these 
projects  risk  having  a  negative  effect  on  the  delivery  of  the  national  components  of  trans-European 
systems as the various deployments are further compacted in a shorter time window. Moreover, these 
delays hamper both Member States’ and EU’s capacity to collect relevant data and carry out critical data 
analysis, leading to undermining our collective effort to effectively tackle fraud. Finally, the benefits for 
trade  as  envisaged  by  the  UCC  from  the  full  digitalisation  of  customs  procedures  and  from  trade 
facilitation projects such as CCI will only materialise at a later stage towards the end of the transition 
period.  

11 

 
 
 
 
4.4  Mitigation actions 

Regarding the national projects, the planning and progress info provided by the Member States shows 
that for AN/PN/TS, National Import Systems Upgrade and Special Procedures – Component 2 (NSP 
IMP) the situation has deteriorated in 2022 in comparison with the planning provisions made in 2021.  

In view of the situation, the Commission has been increasing the support to the Member States by 
means of several actions. Closer supervision was carried by the Commission by means of collecting 
more  frequent  progress  reporting  from  the  Member  States  and  of  organising  bilateral  meetings  at 
Director level with each Member State to discuss progress and planning. The UCC IT implementation 
has been maintained as a recurring subject on the agenda of most of the missions carried out by the 
Director General with his counterparts and on the agenda of the plenary meetings with the Directors 
General  of the Member  States.  Member  States  were encouraged  to  take  all  the necessary  mitigating 
measures  and  to  submit  requests  for  funding  under  the  Recovery  and  Resilience  Fund  to  help  with 
customs IT work, however, not many of them have made use of this possibility. 

The  Commission  provided  additional  guidance  to  Member  States  for  the  implementation  of  the 
national projects, for instance by issuing a documentation package on the reuse of CCI specifications 
for the National Import Systems and by establishing a helpdesk function in DG TAXUD for addressing 
questions  on  legal,  procedural  and  technical  issues.10  The  Commission  also  proposed  additional 
support to the Member States at each bilateral meeting held. The reply by the Member States to 
such proposals was systematically that their situation is particular, the systems concerned are national 
systems with their national specificities, and therefore that support from the Commission is not really 
required.  Trying  to  involve  more  stakeholders  in  the  existing  national  projects  might  even  create 
additional delays. The support that the Member States expect from the Commission is exclusively in the 
area  of  reviewing  the  relevant  UCC  target  delivery  dates,  following  their  official  requests  for 
derogations. Despite this feedback, the Commission will continue to look during the period of 2023 to 
2025  at  the  possibility  of  providing  additional  support  to  willing  Member  States,  possibly  making 
available  advice  via  consulting  experts  in  such  areas  as  governance,  project  management,  business 
processes  change  management,  procurement, communication, etc. The  Member  States that  might  be 
interested in such advice or support are invited to send relevant requests to the Commission. 

The  Member  States  have  mentioned  that  they  are  putting  in  place  the  following  types  of  mitigating 
actions:  the  use  of  an  Agile  development  methodology,  outsourcing  more  development  activities  or 
running  several  activities  in  parallel,  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. These actions were referred to for national 
and trans-European projects. 

Regarding  the  projects  related  to  trans-European  systems,  the  Commission  has  continued  and 
reinforced its support to the Member States by establishing innovative development and deployment 
mechanisms, by refining the governance approach and by providing trans-European coordination and 
monitoring programmes. This is described in more detail below.  

In  order  to  reduce  the  risk  of  delays,  the  Commission  utilises  an  agile  approach  concerning  the 
development  and  deployment  of  the  UCC  electronic  systems,  particularly  during  the  software 
development  phase  of  each  project.  This  allows  for  prototyping,  quicker  fixes  and  a  more  balanced 
workload for the Commission and the Member States. This method was pioneered in the AES, NCTS – 
Phase 5 and ICS2 projects and has been welcomed by the Member States and traders. Furthermore, the 
Commission has established a mechanism for enhanced collaboration between all stakeholders from the 
outset of the projects, to improve the quality of the preparatory activities and to avoid difficulties in 
decision-taking and additional requirements at later stages in the projects.  

A  Multi-Annual  Strategic Plan  for  Customs  (MASP-C)  dashboard  continues to be  used for tracking 
progress 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 

10 21 February 2022, Ref. Ares (2022) 1297882. 

12 

 
 
 
                                                      
to  the  Member  States  (Electronic  Customs  Coordination  Group)  and  the  trade  community  (Trade 
Contact Group) for information and steering purposes. 

The Commission is not only monitoring progress against the main project milestones, as indicated in 
the UCC WP and MASP-C, but is also setting specific interim milestones per project (e.g. milestones 
by which all Member States should have completed the conformance testing). Such close monitoring is 
needed 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.  

For the implementation of the ICS2 programme, after the successful deployment of ICS2 – Release 
1, the focus shifted to ensuring the smooth development of Releases 2 and 3. Member States are now 
turning their efforts to the timely implementation of Release 2. 

The Commission provided the following support to the national administrations and economic operators 
in their ICS2 Release 2 development activities: 

  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, 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. 
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.  

  Online training sessions and training material. 
  Publication  of  factsheets  specifically  prepared  for  third  country  economic  operators, 
presentations at events organised by DG TAXUD or trade actors, having the ICS2 Release 2 
documentation available in the public library on CIRCABC. 

For  the  trans-European  systems  NCTS  –  Phase  5  and  AES,  the  Commission  continues  with  the 
“National  Administration  quarterly  monitoring  programme”  using  key  performance  indicators  to 
regularly assess progress and raise alerts well in advance where problems might occur. Additionally, to 
support the Member States in the development and deployment of their national components for the 
trans-European  systems,  the  Commission  established  a  “National  Administration  coordination 
programme” the following activities:  

  Dedicated helpdesk. 
  Hundreds of virtual meetings took place with the experts and managers at operational, middle 
and  senior  management  levels,  so  as  to  mitigate  the  risks  of  delays  of  the  Member  States. 
Individual  support  to  each  Member  State  with  a  view  to  provide  them  a  seamless  testing 
experience, to speed up their readiness and to mitigate their technical risks.  

  Training programme with focus on the onboarding of the first wave of Member States which 

start the conformance tests in 2022.  
Information to trade on 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 and  the current report 
providing the KPIs overview of the aggregated national plans. The Commission has issued a 
quarterly consolidated progress report of the transition of both NCTS - Phase 5 and AES as from 
Q1 of 2021. 

Regarding  CCI  –  Phase  1,  following  the  outcome  of  the  recurring  meetings  organised  by  the 
Commission, the Member States are being encouraged to select their IT provider in time and to plan the 
internal resources in advance to allow sufficient time for development, testing and deployment. At the 
same time, the Commission recommends that the connectivity tests with CCN2 take place in parallel 
with or prior to the development, and for the pre-conformance tests to be executed concomitantly with 
development activities. 

13 

 
 
 
Most Member States are experiencing the renewal of their entire IT Customs systems, aligning them to 
the new Customs processes as mandated by the UCC. However, a majority of the Member States plan 
to remain on time for 1 December 2023 for the trans-European systems. Member States have progressed 
in  their  specification  and  development,  some  through  their  conformance  tests  and  others  in  their 
connectivity with the central services. For CCI – Phase 1, AES and NCTS – Phase 5, most Member 
State are planning to enter into operation only during the last two quarters of 2023 (clear shift towards 
the  end  of  the  deployment  window).  From  this  perspective,  extraordinary  efforts  and  a  timely 
response will be required by Member States to recover the delays. Member States are asked to be 
transparent  with  their  National  Project  Plans,  while  raising  the  priority  of  these  projects  and  having 
prepared a ‘plan B’ to secure their business continuity. 

5.  MANAGEMENT SUMMARY AND CONCLUSIONS 

After  carefully  evaluating  the  progress  of  the  UCC  IT  implementation,  using  various  instruments 
(surveys, bilateral meetings, virtual calls, national planning etc.), it can be observed that the Member 
States are facing delays and challenges in ensuring the deployment of the UCC electronic systems 
by  the  specified  deadlines.  In  2022,  the  main  focus  was  on the  national  projects  of  Notification  of 
Arrival,  Temporary  Storage,  Presentation  Notification,  of  National  Import  Systems  Upgrade  and  of 
Special Procedures – Component 2 for which the UCC legal deadline is set for the end of the reporting 
year.  

In view of the risks identified in the previous report, the Commission has taken steps to monitor more 
closely the progress of the national projects and to provide support to the Member States in relation to 
the national import processes and systems. However, a majority of the Member States have not been 
able to mitigate properly the risks outlined in the previous reports and delays did actually occur 
for  the  national  entry  and  import  projects  with  implementation  date  31  December  2022.  
Considering the setback in the implementation progress, many Member States have reported delays for 
these projects and submitted a formal derogation request to the Commission, in accordance with Article 
6(4) of the UCC, asking for an extension of the systems’ deployment deadlines. Member States have 
reported that the resource constraints, the complexity of the projects and their integration, the numerous 
obligations to be implemented via customs systems,  the contractual issues and some external factors 
such as the impact of the COVID-19 pandemic, Brexit and the war in Ukraine on customs, have been 
the most important reasons for these delays. The Commission carefully assessed the derogation requests 
and the justifications provided by each Member States in terms of specific circumstances. This resulted 
in  the  acceptance  of  a  number  (not  all)  of  Member  States  derogation  requests,  as  reflected  in  the 
corresponding Commission implementing decisions11 for the national systems related to entry and/or 
import.  The  delays  on  the  deployment  of  those  national  systems  put  the  timely  deployment  of  the 

11 Commission Implementing Decision (EU) 2023/235 of 1 February 2023 granting a derogation requested by certain 
Member States pursuant to Regulation (EU) No 952/2013 of the European Parliament and of the Council to use means other 
than electronic data-processing techniques for the exchange and storage of information for the notification of arrival of a sea-
going vessel or of an aircraft. 
Commission Implementing Decision (EU) 2023/234 of 1 February 2023 granting a derogation requested by certain Member 
States pursuant to Regulation (EU) No 952/2013 of the European Parliament and of the Council to use means other than 
electronic data-processing techniques for the exchange and storage of information for the Presentation Notification related to 
goods brought into the customs territory of the Union.  
Commission Implementing Decision (EU) 2023/236 of 1 February 2023 granting a derogation requested by certain Member 
States pursuant to Regulation (EU) No 952/2013 of the European Parliament and of the Council to use means other than 
electronic data-processing techniques for the exchange and storage of information for the Temporary Storage declaration 
related to non-Union goods presented to customs. 
Commission Implementing Decision (EU) 2023/237 of 1 February 2023 granting a derogation requested by certain Member 
States to use means other than electronic data-processing techniques for the exchange and storage of information related to 
the customs declaration for goods brought into the customs territory of the Union laid down in Articles 158, 162, 163, 166, 
167, 170 to 174, 201, 240, 250, 254 and 256 of Regulation (EU) No 952/2013 of the European Parliament and of the Council 
laying down the Union Customs Code.   

14 

 
 
 
 
                                                      
remaining trans-European systems at risk as the various deployments are further compacted in a shorter 
time window and closer towards the final deadline.  

In addition, compared to last year, the trans-European systems are impacted as well, with additional 
Member States reporting delays in their developments for ICS2 – Release 2, CCI – Phase 1, AES and 
NCTS  –  Phase  5.  In  this  light,  the  transition  periods  offered  by  the  Member  States  to  their  trader 
communities are threatened to be increasingly squeezed if not downright suppressed by imposing a “Big 
Bang” transition.  It impacts the ongoing preparations of the trade community to implement the new 
systems  and  their  interfaces  to  customs  whilst  the  real  benefits  for  trade  obtained  from  this  digital 
transformation of the UCC and from projects such as CCI will only materialise at a later stage towards 
the end of the overall UCC transition period. The longer transitional period will also negatively impact 
those Member States that are ready on time and those traders that operate in several Member States in 
view of the prolonged period of non-harmonisation.   

Member  States  will  have  to  reassess  their  strategies,  resources  and  governance  approaches  to 
avoid further spill-over of delays on other projects.  

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, and 
the red flagged risks, can be found in Figure 4 below.  

Figure 4 – Planning for the UCC Work Programme projects 

The Member States and the Commission continue to work towards the legal deadlines, with both parties 
keeping each other, and trade, informed about their progress on a regular basis. It should be stated that 
despite of the delays encountered, the Member States are showing strong willingness and great efforts 
to undertake additional mitigating actions to address the challenges.  

The Commission will continue to regularly monitor the situation, through the UCC reinforced reporting 
requirements, through the National Administrations quarterly monitoring and coordination programmes 
for the trans-European systems and through plenary and bilateral meetings with Member States, to steer 
the UCC IT implementation towards a successful completion by end 2025.   

The Commission will also reflect upon other specific actions to reinforce its support to Member States 
during the upcoming years, for instance by offering technical assistance. 

15