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

1. 

INTRODUCTION ................................................................................................................................ 4 

2.  PROJECTS COMPLETED BEFORE 2022 .............................................................................................. 6 

2.1 

2.2 

UCC REGISTERED EXPORTER SYSTEM (REX) ............................................................. 6 

UCC CUSTOMS DECISIONS ............................................................................................... 7 

UCC DIRECT TRADER ACCESS TO THE EUROPEAN INFORMATION SYSTEMS 

2.3 
(UUM&DS) ......................................................................................................................................... 8 

UCC ECONOMIC OPERATOR REGISTRATION AND IDENTIFICATION SYSTEM 

2.4 
UPGRADE (EORI2) ........................................................................................................................... 8 

2.5 

2.6 

2.7 

2.8 

2.9 

UCC SURVEILLANCE 3 (SURV3) ...................................................................................... 9 

UCC BINDING TARIFF INFORMATION (BTI) ............................................................... 10 

UCC AUTHORISED ECONOMIC OPERATORS (AEO) UPGRADE .............................. 11 

UCC INFORMATION SHEETS (INF) FOR SPECIAL PROCEDURES ........................... 12 

UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 1 ........................................... 13 

3.  PROJECTS TO BE COMPLETED BY THE END OF 2022 ....................................................................... 14 

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

3.1 
AND TEMPORARY STORAGE (TS) ............................................................................................. 14 

3.2 

3.3 

UCC NATIONAL IMPORT SYSTEMS (NIS) UPGRADE ................................................ 33 

UCC SPECIAL PROCEDURES – COMPONENT 2 (NSP IMP) ........................................ 42 

4.  ONGOING PROJECTS: DETAILED PLANNING AND PROGRESS INFORMATION ................................. 48 

4.1 

4.2 

4.3 

4.4 

4.5 

4.6 

4.7 

UCC SPECIAL PROCEDURES – COMPONENT 1 (NSP EXP) ....................................... 48 

UCC GUARANTEE MANAGEMENT (GUM) ................................................................... 53 

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

UCC PROOF OF UNION STATUS (POUS) ....................................................................... 73 

UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) .............................................. 83 

UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE ......................... 96 

UCC AUTOMATED EXPORT SYSTEM (AES) .............................................................. 111 

5.  ANNEX 1 – PLANNING OVERVIEW – UCC WORK PROGRAMME PROJECTS ................................ 127 

6.  ANNEX 2 – ACRONYMS, ABBREVIATIONS & KEY TERMS ........................................................... 128 

1 

 
 
 
 
 
 
 
Table of Figures 
Figure 1: Project Status as per Survey – AN ......................................................................................... 19 
Figure 2: Project Status as per Survey – PN .......................................................................................... 22 
Figure 3: Project Status as per Survey – TS .......................................................................................... 25 
Figure 4: Percentage of Completion per Phase – AN ............................................................................ 28 
Figure 5: Percentage of Completion per Phase – PN ............................................................................ 29 
Figure 6: Percentage of Completion per Phase – TS ............................................................................. 30 
Figure 7: Summary of Survey Responses – National Import Systems Upgrade ................................... 36 
Figure 8: Percentage of Completion per Phase – National Import Systems Upgrade ........................... 38 
Figure 9: Project Status as per Survey – NSP IMP ............................................................................... 42 
Figure 10: Percentage of Completion per Phase – NSP IMP ................................................................ 44 
Figure 11: Project Status as per Survey – NSP EXP ............................................................................. 48 
Figure 12: Percentage of Completion per Phase – NSP EXP ................................................................ 49 
Figure 13: Summary of Survey Responses – GUM – Component 2 ..................................................... 54 
Figure 14: Percentage of Completion per Phase – GUM – Component 2 ............................................ 56 
Figure 15: Summary of Survey Responses – ICS2 – Release 2 ............................................................ 62 
Figure 16: Summary of Survey Responses – ICS2 – Release 3 ............................................................ 66 
Figure 17: Percentage of Completion per Phase – ICS2 – Release 2 .................................................... 68 
Figure 18: Percentage of Completion per Phase – ICS2 – Release 3 .................................................... 69 
Figure 19: Project Status as per Survey – PoUS – Phase 1 ................................................................... 75 
Figure 20: Project Status as per Survey – PoUS – Phase 2 ................................................................... 77 
Figure 21: Percentage of Completion per Phase – PoUS – Phase 1 ...................................................... 79 
Figure 22: Percentage of Completion per Phase – PoUS – Phase 2 ...................................................... 80 
Figure 23: Summary of Survey Responses – CCI – Phase 1 ................................................................. 86 
Figure 24: Summary of Survey Responses – CCI – Phase 2 ................................................................. 89 
Figure 25: Percentage of Completion per Phase – CCI – Phase 1 ........................................................ 92 
Figure 26: Percentage of Completion per Phase – CCI – Phase 2 ........................................................ 93 
Figure 27: NCTS – P5 National Administrations entry into operations as of 23 August 2022 ............ 96 
Figure 28: Project Status as per latest national project plans – NCTS – P5 ........................................ 103 
Figure 29: Conformance tests: Planned value versus earned value –KPI1- NCTS – P5..................... 106 
Figure 30: Conformance tests: Planned value versus earned value – KPI2-NCTS – P5..................... 106 
Figure 31: Percentage of Completion per Phase – NCTS – P5 ........................................................... 107 
Figure 32: NCTS – P5 Transitional Period ......................................................................................... 108 
Figure 33: AES – Component 1 National Administrations entry into operations as of 23 August 2022
 ............................................................................................................................................................. 111 
Figure 34: Project status as per latest national project plans – AES – Component 1 .......................... 116 
Figure 34: Project Status as per Survey – AES – Component 2 .......................................................... 119 
Figure 35: Key milestones: Planned value versus earned value – AES – Component 1 ..................... 120 
Figure 36: Conformance Tests: Planned value versus earned value – AES – Component 1 .............. 120 
Figure 37: Percentage of Completion per Phase – AES – Component 1 ............................................ 122 
Figure 38: AES – Component 1 Transitional Period ........................................................................... 123 
Figure 39: Percentage of Completion per Phase – AES – Component 2 ............................................ 124 
Figure 40: Planning Overview: UCC Work Programme Projects – Status Q2 2022 .......................... 125 

2 

 
 
Table of Tables  

Table 1: Comparison of Planned and Actual Dates – REX1 ................................................................... 7 
Table 2: Comparison of Planned and Actual Dates – UCC Customs Decisions ..................................... 7 
Table 3: Comparison of Planned and Actual Dates – UUM&DS ........................................................... 8 
Table 4: Comparison of Planned and Actual Dates – EORI2 ................................................................. 8 
Table 5: Comparison of Planned and Actual Dates – SURV3 ................................................................ 9 
Table 6: Comparison of Planned and Actual Dates – BTI .................................................................... 10 
Table 7: Comparison of Planned and Actual Dates – AEO Upgrade .................................................... 11 
Table 8: Comparison of Planned and Actual Dates – INF .................................................................... 12 
Table 9: Comparison of Planned and Actual Dates – ICS2 - Release1 ................................................. 13 
Table 10: Detailed responses from Member States – AN ..................................................................... 18 
Table 11: Detailed responses from Member States – PN ...................................................................... 21 
Table 12: Detailed responses from Member States – TS ...................................................................... 25 
Table 13: Comparison of Planned and Actual Dates – AN ................................................................... 26 
Table 14: Comparison of Planned and Actual Dates – PN .................................................................... 26 
Table 15: Comparison of Planned and Actual Dates – TS .................................................................... 27 
Table 16: Detailed responses from Member States – National Import Systems Upgrade .................... 36 
Table 17: Comparison of Planned and Actual Dates – National Import Systems Upgrade .................. 37 
Table 18: Detailed responses from Member States – NSP IMP ............................................................ 42 
Table 19: Comparison of Planned and Actual Dates – NSP IMP ......................................................... 43 
Table 20: Detailed responses from Member States – NSP EXP ........................................................... 47 
Table 21: Comparison of Planned and Actual Dates – NSP EXP ......................................................... 48 
Table 22: Detailed responses from Member States – GUM – Component 2 ........................................ 53 
Table 23: Comparison of Planned and Actual Dates – GUM – Component 1 ...................................... 54 
Table 24: Comparison of Planned and Actual Dates – GUM – Component 2 ...................................... 55 
Table 25: Detailed responses from Member States – ICS2 – Release 2 ............................................... 61 
Table 26: Detailed responses from Member States – ICS2 – Release 3 ............................................... 64 
Table 27: Comparison of Planned and Actual Dates – ICS2 – Release 2 ............................................. 65 
Table 28: Comparison of Planned and Actual Dates – ICS2 – Release 3 ............................................. 66 
Table 29: Detailed responses from Member States – PoUS – Phase 1 ................................................. 71 
Table 30: Detailed responses from Member States – PoUS – Phase 2 ................................................. 73 
Table 31: Comparison of Planned and Actual Dates – PoUS – Phase 1 ............................................... 74 
Table 32: Comparison of Planned and Actual Dates – PoUS – Phase 2 ............................................... 75 
Table 33: Detailed responses from Member States – CCI – Phase 1 .................................................... 82 
Table 34: Detailed responses from Member States – CCI – Phase 2 .................................................... 85 
Table 35: Comparison of Planned and Actual Dates – CCI – Phase 1 .................................................. 86 
Table 36: Comparison of Planned and Actual Dates – CCI – Phase 2 .................................................. 87 
Table 37: Detailed responses from Member States – NCTS – P5 ......................................................... 96 
Table 38: Risk Assessment: NCTS – P5 ............................................................................................... 97 
Table 39: Comparison of Planned and Actual Dates – NCTS – P5 ...................................................... 99 
Table 40: Detailed responses from Member States – AES – Component 1 ........................................ 108 
Table 41: Risk Assessment: AES – Component 1 .............................................................................. 109 
Table 42: Detailed responses from Member States – AES – Component 2 ........................................ 112 
Table 43: Comparison of Planned and Actual Dates – AES – Component 1 ...................................... 113 
Table 44: Comparison of Planned and Actual Dates – AES – Component 2 ...................................... 115 
Table 45: Abbreviations and Acronyms .............................................................................................. 121 

3 

 
 
1.  INTRODUCTION 

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

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

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

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

electronic systems; 

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

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

The first, second and third UCC Annual Progress Reports4 were published on 13/12/2019, 14/12/2020 
and 14/12/2021 respectively. The details of the completed projects are limited in this report, however 
additional information can be found in the previous year’s reports. 

In preparation for this year’s UCC Annual Progress Report 2022, the Commission continued with the 
approach taken the previous years and made use of the bi-annual national planning information provided 
by  the  Member  States’  customs  authorities  and  the  projects’  state  of  play  provided  by  the  project 
managers in DG TAXUD.  

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

The progress information was provided against the baseline milestones indicated in the UCC WP and 
MASP-C 2019 (unless otherwise specified). In addition, the Commission oversaw the collection of the 
additional progress reporting information by means of an EU survey launched in March 20225, the EU 
survey on Implementation of National Projects launched in December 2021 and the bilateral high-level 
meetings between DG TAXUD and the Member States Customs IT Directorates on the state of play of 

1 In the context of this report, ‘The Commission’ refers to the European Commission. 
2 External communication with the economic operators. 
3 Commission Implementing Decision (EU) 2019/2151 of 13 December 2019 establishing the Work Programme relating to the 
development and deployment of the electronic systems provided for in the Union Customs Code, OJ L 325, 16.12.2019, p. 
168-182, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019D2151. 
4 Report from the Commission to the European Parliament and the Council:  
2019: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0629 
2020: https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:52020DC0806  
2021: https://eur-lex.europa.eu/legal-content/GA/ALL/?uri=CELEX:52021DC0791 
Commission Staff Working Document:  
2019: https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1589134753023&uri=CELEX:52019SC0434 
2020: https://eur-lex.europa.eu/legal-content/NL/ALL/?uri=CELEX:52020SC0339 
2021: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=SWD:2021:382:FIN  
5 The information was collected between March 2022 and June 2022. 

4 

 
 
                                                      
the UCC IT Implementation. The information gathered from the survey to which both the Member States 
and key stakeholders/project managers in the Commission responded, consists of progress information, 
qualitative  comments  and  quantitative  measurements  of  the  assessment  of  complexity  and  risk  in 
relation to the projects listed in the UCC WP. Finally, specific information was gathered from the more 
detailed project reporting and monitoring programmes in place since 2020 for the core decentralised 
trans-European systems in the area of transit and export. The 2021 Survey on the Implementation of 
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. The survey follows an identical structure with the March 2022 
Survey, giving the Commission a clear view on the status of each system.  

At the same time, DG TAXUD conducted bilateral high-level meetings with Member States Customs 
IT Directorates, focusing on having a conversation with each Member State in order to gain the full 
picture of their status and to see what can be done to support them in their work, especially in the light 
of the upcoming deadlines for several projects. In this light, UCC Notification of Arrival (AN), UCC 
Presentation Notification (PN), UCC Temporary Storage (TS), UCC National Import Systems Upgrade 
and UCC Special Procedures (SP): Component 2 - National SP IMP are foreseen to be operational by 
the end of 2022. 

In view of all this, it can be seen that constant communication has been maintained with the Member 
States  in  order  to  regularly  monitor  the  progress  of  the  UCC  projects  and  to  provide  the  necessary 
support in order to meet the deadlines. 

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

i) 

ii) 

iii) 

eleven  central  trans-European  systems  to  be  developed  or  upgraded  by  the 
Commission (often also requiring developments or upgrades by the Member States of 
their corresponding national systems);  
three decentralised trans-European systems that have to be developed or upgraded 
by the Commission, but have a major national component to be implemented by the 
Member States; and  
three  national  systems  that  have  to  be  developed  or  upgraded  exclusively  by  the 
Member States. 

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

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

  For projects that have already been initiated or entirely completed, an overview of the project 

progress, a summary of the survey responses; 

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

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

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

  The degree of complexity from their perspective of each project on a scale from 1 to 6, where: 
1 and 2 refer to low complexity, 3 and 4 - medium complexity and 5 and 6 - high complexity.  
  The risk of not deploying the IT systems by the dates set in the baselines of the UCC WP and 

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

The consolidation of the survey results, including the abovementioned indicators of complexity and risk, 
as well as information regarding risks for delays and mitigating measures and any changes in planning 
in  comparison  with the  planning  provided in  2021, are  the  main  outcomes  of the  progress  reporting 
exercise  for  2022  and  are  included  in  this  Commission  Staff  Working  Document.  Reporting 

5 

 
 
information that summarises the current project status, key risks and mitigating actions is found in the 
Report from the Commission to the European Parliament and the Council pursuant to Article 278a 
of the Union Customs Code, on progress in developing the electronic systems provided for under the 
Code.  

The report is structured as follows: 

  Section 1: Introduction; 
  Section 2: Projects completed before 2022; 
  Section 3: Projects to be completed by the end of 2022; 
  Section 4: Projects ongoing during 2022.  

2. 

PROJECTS COMPLETED BEFORE 2022 

UCC REGISTERED EXPORTER SYSTEM (REX) 

2.1 
The UCC Registered Exporter System (REX) is a trans-European system that contains information both 
on  Registered  Exporters  established  in  GSP  countries6  and  on  EU  economic  operators  in  partner 
countries Switzerland, Norway and Turkey exporting to GSP countries and certain other countries. The 
main purpose of the system is to replace the paper-based certification process by an IT-supported self-
certification process. The system includes a central database that contains the registered exporters and 
provides the Member States with the opportunity to enhance their national systems with an automated 
verification of REX members. 

There were three releases planned. REX1 is the only release covered in the scope of the UCC Work 
Programme.  No  risks  were  identified  during  the  implementation  of  REX17  and  the  project  was 
successfully completed on 1 January 2017.  

Some statistical information on the use of the REX system since operations – situation as of May 2022:  

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

25 January 2021; 

  66304 active REX registrations for Beneficiary countries of the EU, Overseas Countries and 

Territories as well as CH GSPs, NO GSPs, TR GSPs (REX BC) module; 

  85611 active REX registrations for Member States (REX MS) module (including 485 

registrations from Partner Countries CH, NO and TR as well as Andorra and San Marino) ; 

  4972 applications submitted by the EU Traders in the REX Specific Trader Portal; 
  729 T-REX Local Users are configured in T-REX module and able to use REX BC; 
  403 T-REX Local Administrators are configured in T-REX module and can manage Local 

Users. 

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

6 

 
 
 
 
                                                      
2.1.1 Overview of Project Progress 

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

Table 1: Comparison of Planned and Actual Dates – REX1 

UCC CUSTOMS DECISIONS 

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

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

Some statistical information on the use of the CDS: 

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

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

system with the current legislation. 

  Until the first semester of 2022, almost 47,300 applications were submitted and 27,900 decisions 
were taken. Approximatively 43,700 decisions were entered as pre-existing authorisations. 

2.1.2 Overview of Project Progress 

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

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

7 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/03/201530/06/2015100%31/12/2016100%01/01/201701/01/2017100%Technical SpecificationsConformance TestingDeploymentTarget date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/12/201531/12/2015100%30/09/2017100%02/10/201702/10/2017100%Technical SpecificationsConformance TestingDeployment 
 
 
 
  
 
 
UCC  DIRECT  TRADER  ACCESS  TO  THE  EUROPEAN  INFORMATION 

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

The first deployment of the project was completed and implemented together with the UCC Customs 
Decisions system on 02/10/2017 as agreed in the context of the UCC Work Programme.  

The  system  has  also  been  incorporated  into  other  electronic  projects  such  as  UCC  Binding  Tariff 
Information (BTI), the UCC Authorised Economic Operators (AEO) and the Information Sheets (INF) 
system  for  special  procedures. The  project  further  evolved  to  include  system-to-system  interfaces  in 
view of the ICS2 deployment. It will also be used for future projects such as the one related to the Proof 
of Union Status (PoUS) system. 

All Member States have completed the connectivity configuration.  

2.1.3 Overview of Project Progress 

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

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

UCC  ECONOMIC  OPERATOR  REGISTRATION  AND  IDENTIFICATION 

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

Some statistical information on the use of the EORI2 system – situation until 01/06/2022: 

  The total number of economic operators registered with a valid EORI is 8,024,368. 
  295,036 EORI numbers have been created during the period of 01/01/2022 to 01/06/2022. 

2.1.4 Overview of Project Progress 

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

Table 4: Comparison of Planned and Actual Dates – EORI2 

8 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/12/201530/09/2015100%30/09/2017100%02/10/201702/10/2017100%Technical SpecificationsConformance TestingDeploymentTarget date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 30/06/201631/07/2016100%28/02/2018100%05/03/201805/03/2018100%DeploymentTechnical SpecificationsConformance Testing 
 
 
 
UCC SURVEILLANCE 3 (SURV3) 

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

The  system  was  successfully  deployed  on  01/10/2018,  with  all  the  data  being  gathered  in  different 
formats  via  Surveillance  Recap,  having  all  the  national  systems  fully  aligned  to  the  UCC,  therefore 
giving the system the ability to work at its full potential.  

An emphasis should be made on the need to extend the use of the system, given that for those Member 
States who are going to be delayed or partially delayed for the National Import Systems, it will have a 
direct consequence on the collection of the data via SURV RECAP and on the functioning of the reports 
of the Surveillance 3 system. Therefore, the system will have to be prolonged in use until all MSs are 
on board. 

2.1.5 Overview of Project Progress 

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

Table 5: Comparison of Planned and Actual Dates – SURV3 

9 

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

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

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

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

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

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

2.1.6 Overview of Project Progress 

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

Table 6: Comparison of Planned and Actual Dates – BTI 

10 

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

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

Some statistical information on the use of the AEO system – situation on 31/07/2022: 

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

  1450 AEO applications have been submitted via the EU eAEO Trader Portal; 
  ~3500 Economic operators have accessed (125 the first quarter of 2021) the EU eAEO Trader 

Portal; 

  5500 documents have been exchanged via the EU eAEO trader Portal; 
  25 Member States are leveraging the EU eAEO Trader Portal and the remaining Member States 

are utilising their own National Trader Portal. 

On 31/07/2022, 18,150 valid AEO authorisations are granted to Economic Operators in the EOS 
central system. 

2.1.7 Overview of Project Progress 

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

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

11 

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

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

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

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

Some statistical information on the use of the INF system: 

  As from October 2020, all Member States are using the INF system. 
  From the start of operations on 1/06/2020 until March 2022, around 39,700 requests were 
created by economic operators, and approximately 36,000 INFs were treated and processed.  
  The average number of requests and authorisations increased over the first half of 2021 and 

then stabilised. 

2.1.8 Overview of Project Progress 

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

Table 8: Comparison of Planned and Actual Dates – INF 

12 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 30/06/201830/06/2018100%29/05/2020100%01/06/202001/06/2020100%DeploymentTechnical SpecificationsConformance Testing 
 
 
 
UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 1 

2.9 
The goal of the UCC Import Control System 2 (ICS2) programme is to strengthen the safety and security 
of  the  supply  chain  for  goods  moved  via  all  modes  of  transport. The aim  is  to  do  so  through  better 
targeted risk based controls of EU customs authorities on improved Entry Summary Declaration (ENS) 
data  quality,  data  filing,  data  availability  and  data  sharing  and  through  real-time  collaborative  risk 
analysis and co-ordinated safety and security controls at the EU entry points. The main purpose of the 
system is to implement the new requirements resulting from the UCC and strategic objectives endorsed 
by the Member States in the Risk management strategy and action plan of 2014. 

In  terms  of  planning,  the  programme  will  be  implemented  in  three  releases.  Release  1  covers  the 
obligation on the relevant economic operators (postal operators and express carriers in air transport) to 
provide the minimum data i.e. ENS pre-loading dataset. Release 2 will cover the implementation of new 
ENS  obligations  and  related  business  and  risk  management  processes  for  all  the  goods  in  Full  Air 
(postal, express, cargo)” traffic. At the same time Release 2 will include Safety and Security analytics 
capabilities delivering Offline analytics capabilities (Data Lab/ Risk List/ Risk Indication Enrichment 
Catalogue)  and  Online/Real  Time  Enrichment  capabilities.  Following  a  positive  endorsement  (‘Go 
decision’)  by  the  Commission  and  the  Member  States  in  December  2020  the  project  activities  have 
started. Release 3 will cover the very similar business process as Release, but for all goods in maritime 
and inland waterways, road and rail traffic (this also includes goods in postal consignments transported 
in these means of transport). Please see Section 4.3 for the detailed status of Releases 2 and 3. 

The first  ICS2  release,  ICS2  –  Release  1  started  operation  on  15th  of March  2021  with  majority  of 
National Entry System connected. Most of the economic operators had connected to the ICS2 Release 
1 before the end of the Release 1 deployment window 01/10/2021. All remaining NES system and EO 
system has connected by the December 2021, with exception of UK (Northern Ireland). All national 
customs authorities have implemented customs risk management processes on the basis of the applicable 
common risk criteria and standards and in accordance with harmonised operational guidance. During 
the  6  months  of  EO  deployment  window  it  was  observed  that  ENS  data  quality,  completeness,  its 
coverage and implementation of air cargo security referrals presented a challenge to affected economic 
operators  (in  particular  in  postal  sector).  These  critical  compliance  issues  had  and  will  have  to  be 
continuously addressed in the coming months to ensure compliance with the new UCC requirements. 

By the time of writing, ICS2 is used by 30 National Customs Administrations: All EU Member States, 
CH, NO and UK8. All Postal operators, including the postal operators of CH and NO, are connected to 
ICS2, apart from the UK postal operator, that is not operational9. 

By end of December 2021 all national administrations (NAs) were fully operational.  

2.1.9  Overview of Project Progress 

Table 9 compares the actual dates to those set in the UCC Work Programme (WP).  

Table 9: Comparison of Planned and Actual Dates – ICS2 - Release1 

8 As part of implementation of the Protocol on Ireland and Northern Ireland; 
9 UK is currently not in operations due to the standstill arrangement during the ongoing discussions about the application of 
the Northern Ireland Protocol. 

13 

Target date from WPActual End Date2021 % of CompletionActual End Date2021 % of Completion Target date from WPActual Date2021 % of Completion 30/06/201801/09/2021100%05/09/2021100%15/03/202115/03/2021100%Technical SpecificationsConformance TestingDeployment 
 
 
 
 
                                                      
3. 

PROJECTS TO BE COMPLETED BY THE END OF 2022 

UCC NOTIFICATION OF ARRIVAL (AN), PRESENTATION NOTIFICATION  

3.1 
(PN) AND TEMPORARY STORAGE (TS) 
The goal of this project is to define the processes at the national level in  respect to the notifications 
known as Notification of Arrival (AN), Presentation Notification (PN) and Declaration for Temporary 
Storage (TS), as described in the UCC. This project will ensure the customs formalities related to the 
entry  of  goods  concerning  safety  and  security  exits  and  that  customs  supervision  begins  at  the 
appropriate time and is duly performed. It also aims to support harmonisation across the Member States 
regarding the data exchange between trade and customs. Furthermore, the project covers the automation 
of processes at the national level.  

The  development  activities  related  to  this  project  are  a  national  matter,  with  processes  and  data 
requirements for the external domain to be defined and agreed at EU level. In this light, the systems are 
planned to be operational by 31 December 2022 as defined in the UCC basic Regulation. If the deadline 
cannot be met, Member States are required to address this in writing to the European Commission and 
request a derogation as stated in Art 6(4) of the UCC. Member States will have to address a formal 
request, with a temporary nature10, stating a scope and a clear justification. 

By the time of writing, several derogation letters were received from Member States for Notification of 
Arrival, Presentation Notification and Temporary Storage. 

3.1.1 Summary of Responses 

Notification of Arrival (AN) 

Summary from the Commission: 

The development activities for this project are a national responsibility.  

An  expert  group  of  Member  States,  ETCIT  WP2  (Expert  Team  on  new  approaches  to  develop  and 
operate  Customs  IT  systems),  financed  by  the  Customs  Programme,  has  engaged  to  establish  the 
business process models and the legal/business/functional requirements for AN, PN and TS and to make 
this available to interested Member States. 

In view of the legal deadline of 31/12/2022, the risks identified in the 2021 Annual Progress Report for 
the  national  entry  projects  were  brought  to  the  attention  of  the  Directors  General  of  the  Customs 
Administrations with the demand to address the risks and ensure timely deployment.  

Closer supervision was carried by DG TAXUD by means of collecting more frequent progress reporting 
from the Member States and organising a range of bilateral meetings with each Member State at CIO 
level.   

Summary from the Member States: 

The project is closely interlinked with other projects/systems such as the national import systems and 
the Import Control System 2 (ICS2). This is often reported by Member States as the reason for assessing 
the project as medium to highly complex. The following Member States reported to implement AN as 
part of ICS2 Release 2 (in particular through the EU Shared Trader Interface): AT, BG, CY, DE, EE, 
ES, FI, FR, HR, HU, LT, LV, NL, RO, PL, SE and SI. The following Member States are developing or 
have developed a national solution (often in conjunction with the National Import System): CZ, IT, MT, 
PT and SK.  Some Member States did not provide any information in this respect. 

10 By temporary nature it should be understood a limited and reasonable period of time, which will be assessed following the 
justification provided. 

14 

 
 
 
 
                                                      
The timely delivery of the required national systems by all Member States was already at risk in last 
year’s report. Additional delays in comparison with the UCC Annual Progress Report 2021 are noted, 
though  several  Member  States  reported  that  measures  are  taken  to  keep  the  deployment  within  the 
deadline. Some examples include changing the organisational setup with contractors to achieve a more 
effective development process and/or implementing an Agile development methodology to reduce the 
implementation timeframe.  

Recurrently identified causes of delay related to the project are: the interdependencies between core and 
supporting systems, delays in public procurement procedure, dependencies with other stakeholders, the 
contractor’s  capacity  and  unexpected  delays  caused  by  the  system  development  intrinsically.  Other 
activities have taken resources, notably BREXIT for which important efforts had to be made to ensure 
the traffic flow at the borders.  

Besides the complexity of the project per se, other reasons for potential delay are  provided, such as 
resource constraints, both workforce and financially related, further adaptations to the UCC Annex B11, 
impact and re-planning due to the VAT eCommerce package12 (which needed a new development, given 
the large volumes) and also the specific working circumstances caused by the COVID-19 pandemic. At 
the  same  time,  many  Member  States  have  attributed  the  increased  complexity  level  to  parallel 
development of systems and to the many dependencies and stakeholders involved. Intense collaboration 
in  the  ETCIT  expert  group  is  ongoing  in  order  to  share  expertise  and  resources  amongst  interested 
Member States and to join forces in the development work.  

The above summary also applies to PN and TS. 

Important remark: 

Further to the planning and progress data collected from Member States and Commission services during 
Q1  and  Q2  2022,  new  information  has  been  communicated  to  the  Commission  which  has  not  been 
represented  in  this  accompanying  staff  working  as  it  was  not  part  of  the  methodological  approach 
established for this document. They key information will be taken on board and reflected in the main 
Report itself.  

Several Member States have submitted a written notification asking for derogation under Article 6(4) 
UCC to DG TAXUD concerning the delay for AN beyond the deadline 31/12/2022, regardless of the 
option made to implement the system with ICS2 Release 2. The derogation requests from the Member 
States were assessed by the Commission services in terms of the justifications provided by the specific 
situation of the Member States requesting it and in view of a set of common assessment criteria.  

In this light the Commission has proposed an Implementing Decision13 granting a derogation to Austria, 
Belgium,  Bulgaria,  Croatia,  Cyprus,  Czechia,  Denmark,  Estonia,  France,  Greece,  Hungary, 
Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden 
for the Notification of Arrival provided for in Article 133 of the Union Customs Code. The derogation 
is proposed to apply from 1 January 2023 until the deployment of the AN system, but not later than 31 
December 2023 in respect of goods entering the customs territory of the Union by air, and 1 March 2024 
in  respect  of  goods  entering  the  customs  territory  of  the  Union  by  maritime  transport  or  inland 
waterways, whichever date is sooner. This differentiation by transport mode aligns with Release 2 and 
3 of ICS2 respectively as the projects are closely linked.  

Detailed Responses14: 

Table 10 provides the individual Member States’ responses to the survey: 

11  Annex  B  to  Delegated  Regulation  (EU)  2015/2446  -  regarding  common  data  requirements,  as  amended  by  Delegated 
Regulation (EU) 2021/234; 
12 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33); 
13 This reflects the state of play at the moment of the finalisation of the Report on 11 November 2022. 
14 Fields marked in grey mean that no information was provided on that specific topic. 

15 

 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

1 

Low 

AT indicated that AN will be lodged using the EU-Portal (STI) and CR and that 
a  hybrid  approach  will  be  used,  combining  an  agile  development  and  the 
integration of the existing software solutions. 

AT 

BE 

BG 

5 

Low 

CY 

6 

Med 

CZ 

6 

Med 

In the case of BG, AN will not be deployed as a separate project, being in line 
with  ICS2  -  Release  2  planning.  Regarding  the  ICS2  -  Release  2  national 
components development, Bulgarian customs administration is using an agile 
and an iterative approach. BG applies an adapted and combined implementation 
of two methodological frameworks –TOGAF/ADM and RUP. 
In relation to NA/PN/TS, CY indicated15 that these projects would follow the 
same plan as for the National Import System which envisaged publication of 
technical  specifications  on  30/07/2022,  conformance 
testing  between 
08/03/2023 - 21/03/2023 and deployment into operation on 31/03/2023 in a “big 
bang”  approach.  A  development  contract  has  been signed  and the  dates  have 
been agreed. At the same time, the decision to align the development to EUCDM 
6.1 means that there will be a delay of three months involved, however it was 
considered that this was a better approach than updating to version 5.2 and then 
to  6.1  soon  after.  They  intend  to  re-use  a  system  already  developed  by  their 
contractor and in use in another Member State so this should mean that they 
won’t experience any problems with implementation. 
According to the last updated information the development approach envisaged 
will be decided in cooperation with the contractor. 
CZ mentioned that several years ago a full computerization of customs systems 
took place. For example National Import System (NIS) incl. AN, PN, TS and 
interfaces with other systems (ICS, ECS, NCTS, GMS, NDS, ERIAN, ECDC, 
TARIC  etc.)  were  deployed  in  November  of  2010.  Purposes  of  these  many 
interfaces between NIS and other systems are automatic verification of various 
data elements in customs declarations in relation to data in other systems and 
transmission  of  information  relevant  to  other  systems.  Most  of  the  new 
processes based on UCC have already been incorporated into the systems in the 
past. Nowadays, the  subject of development within the NIS  modernization is 
mainly a change in the general data requirements in the formats and structure of 
individual  data  elements  and  data  groups  used  in  the  existing  electronic  data 
messages. Due to the interconnectedness, the systems for AN, PN, TS, NIS and 
SP IMP are being developed and will be deployed in parallel. The high level of 
computerization and interconnection of customs systems in the Czech Republic 
that  has  existed  in  the  past  brings  a  negative  impact  to  the  present  moment. 
Therefore,  for  further  development  that  has  a  high  degree  of  complexity  in 
implementing  changes  in  individual  systems  the  impact  will  be  translated  in 
increased cost of personnel and/or financial resources. 
At the time of writing, the project is delayed due to the complexity of the system 
and the IT contractor related activities. Therefore, the deadline of publication of 
technical specifications will be postponed and the new indicative milestones in 
the  National  Project  Plan  (NPP)  will  be  modified  as  follows:  Technical 
Specifications  =  01/08/2022,  The  period  of  Conformance  Testing  with 
Economic Operators = 01/11/2022-31/12/2022 and Deployment = 31/12/2022. 
CZ explained the background related to the technical specifications date being 
set for 01/08/2022, just 5 months before the deployment deadline date by stating 
that due to numerous UCC requirements and the need to update those systems 
accordingly  and  given  the  complex  nature  caused  by  the  level  of  inter-

15 According to the planning file which was sent to TAXUD on 16/03/2022. 

16 

 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

to  system  complexity  milestones  related 

connection  with  many  different  systems,  the  date  of  publication  of  technical 
specifications had to be postponed.  
Considering the applicability of deployment activities, this information will be 
updated in line with the ICS2 planning for Release 2 starting 01/03/2023 and 
implemented  in  a  major  release  of  the  national  IT-Systems  ATLAS  (Release 
10.1). External Milestones affecting economic operators will be considered in 
line with the ICS2 planning for Release 2, especially in relation to the STI. 
DK is facing a reprioritization of the Danish UCC program and the underlying 
projects reflected in the UCC Work Programme. Based on the initial phases of 
the implementation of the UCC there is a considerable risk that Denmark will 
not be able to meet all the deadlines in the UCC. This is due in part to the overall 
complexity of the task and the implementation schedule, and in part because the 
Danish national supplier has not been able to deliver the standard system at the 
expected quality and speed.  
AN will not be deployed as a separate project, being in line with ICS2 - Release 
2 planning. EE advised that due to COVID-19 related financial challenges they 
had to postpone the ICS2 - Release 2 and AN project deadline. The new planned 
deployment date is 01/10/2023. Mitigating measures are under discussion with 
the Ministry of Finance.  
ES indicated that they will be developing the AN with ICS2 R2 system, using 
an agile development approach. 
FI  indicated  that  the  system  will  be  implemented  with  ICS2  Release  2  on 
01/03/2023  and  that  most  of  the  Conformance  Testing  activities  have  been 
executed.  However,  due 
to 
conformance testing and deployment activities will be impacted. 
FR will use the application developed by BE and will deploy AN concomitantly 
with the release of ICS2-R2 (this applies for PN and TS as well). 
It was expressed that a delay of 6 months is expected for AN/PN/TS.  
GR  explained  that  due  to  call  for  tender  procedures,  PN/AN/TS  are  at  risk, 
having all milestones impacted. Internal discussions to assess and mitigate the 
situation are underway. No partial deployment is envisaged. 
HR indicated that Notification of Arrival is part of ICS2 specifications and will 
be deployed according to ICS2 deadlines for different modes of transport (R2 
and R3). 
HU advised that the implementation of AN/PN would in fact take place at the 
same time as ICS2 Release 2 in March 2023. HU is planning a full functionality 
deployment for AN.  
IE  explained  that  in  accordance  with  Article  133  of  the  UCC,  where  the 
information on arrival is available to the customs authorities they may waive 
this notification. IE is already being provided with this information from their 
port  and  airport  authorities  and  will  not,  therefore,  require  the  operators  to 
submit notifications of arrival. In this light, AN will not be applicable for IE and 
is currently examining how this will work with the Shared Trader Interface 
for ICS2. 
The eManifest system in Italy covers the formalities for AN/PN/TS and they are 
working  on  the  connection  between  this  and  ICS2  for  the  management  of 
AN/PN.  They  plan  publication  of  technical  specifications  for  01/06/2022, 
testing  with  traders  between  05/09/2022  and  12/12/2022  followed  by 
deployment on 13/12/2022. 
LT  expressed  that  AN  will  be  aligned  with  ICS2  functionality  (for  which 
deadline  for  production  is  01/03/2023).  Considering  this,  if  the  EU  system 

DE 

4 

Low 

DK 

4 

Med 

EE 

ES 

FI 

FR 

GR 

HR 

HU 

4 

1 

3 

5 

6 

6 

5 

High 

Low 

Med 

Low 

High 

High 

Med 

IE 

3 

Low 

IT 

LT 

4 

6 

Low 

Med 

17 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

LU 

LV 

4 

Med 

MT 

6 

High 

NL 

PL 

5 

4 

High 

Low 

PT 

6 

High 

RO 

6 

Low  

SE 

3 

Low 

functionality will not be in place, national functionality will not be able to handle 
AN. 

For Notification of Arrival, Latvia uses Port and Airport systems according to 
the Article 133 (2) of the UCC.  
AN and PN will be harmonized with the implementation of ICS2 R2 and R3. At 
the time of writing LV is managing the procurement procedure, having adopted 
an iterative development approach. In the risk spectrum, the development and 
Conformance Testing activities are being impacted. 
Due  to  numerous  activities  concerning  various  systems  happening  all  in  the 
same  period  the  system  is  being  delayed.  Therefore,  the  upgraded  National 
Import System will be deployed in around Q1/Q2, 2023 instead of Q4 2022. The 
launch of the Notification of Arrival will be coordinated with the launch of the 
upgraded NIS. The system will be deployed with full functionality. 
Regarding the AN/PN/TS projects, it was confirmed that the planning envisages 
the deployment along with ICS2 Release 2 on 01/03/2023.  
NL  has  decided to  combine  AN  with  ICS2  -  Release  2,  while  using  an agile 
development approach. This approach starts with describing a high level design 
of the requirements (features) and the IT-solution, in a so called “Epic” format.  
AN/PN deployment will be linked to ICS2 Release 2. PL mentioned that both 
an  agile  and  an  iterative  approach  are  going  to  be  used  for  the  system 
development. 
PT  indicated  that  Technical  Specifications  Publication  for  EO,  Conformance 
Testing  and  Deployment  activities  were  postponed,  due  to  the  complexity  of 
developments with ports and airports and due to the definition of a longer period 
for conformance testing activities. PT explained that the Notification of Arrival 
of the means of Transport is waived to the EO, under the terms of Article 133 
of the UCC. The Administration receives the information regarding the arrival 
notification,  sent  by  the  airport  managing  authorities  and  the  maritime 
authorities.  Therefore,  the  new  system  has  to  be  interconnected  with  the 
operational  systems  of  ports  and  airports,  adding  complexity  to  the 
developments. At the same time, the integration with ICS2 R2 is also complex. 
Projects  like  Presentation  Notification  and  Temporary  Storage  will  be 
implemented in the same national system, integrated with several other systems 
(ICS2,  NIS,  Risk  Management,  Temporary  Storage  Facilities).  Within 
mitigation measures PT mentioned: providing technical specifications as soon 
as possible to Traders and providing support, assistance and close training to all 
Traders  and  Port  Authorities.  An  agile  development  will  be  used  to  reduce 
implementation timeframe and no partial deployment is envisaged. 
A  delay  of  9  to  12  months  is  being  envisaged  for  AN/PN/TS/NIS  and  SP 
Component 2. 
AN will be implemented along with ICS2 - Release 2. RO indicated that an agile 
approach is being used for the development of AN. However, in the derogation 
letter provided for DG TAXUD, it was indicated that for ICS2 Release 2 there 
will  be  a  delay  of  maximum  7  months,  but  not  more  than  the  deployment 
window  given  to  economic  operators  for  their  own  system-to-system 
developments. 
SE confirmed that they will use the ICS2 functionality for AN to be deployed 
on  01/03/2023  with  full  operation  from  01/10/2023  for  air  transport  (ICS2 
Release 2) and for maritime in Q1 2025 (ICS2 Release 3). An iterative approach 
is being used for the system development.  

18 

 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

SI 

SK 

4 

1 

Low 

High 

SI is upgrading the existing electronic messages for AN, PN and the national TS 
system in accordance with Annex B IA/DA (G2, G3 and G4). AN/PN will be 
implemented at the same time with ICS2 Release 2 on 01/03/2023. 

Regarding AN/PN/TS and NIS, SK confirmed that they will be a year late with 
the deployment due to lack of human resources. They are currently performing 
analysis  of  the  situation  with  their  IT  supplier  and  crisis  manager.  For  the 
moment no mitigating measures are foreseen. 

Table 10: Detailed responses from Member States – AN 

Figure 1 provides the percentage of Member States in each development phase for AN.  

Figure 1: Project Status as per Survey – AN 

Presentation Notification (PN) 

Summary from the Commission: 

The summary is the same as for AN. 

Summary from the Member States: 

Please see also the summary from AN. 

As  regards  the  alignment  of  the  system  development  with  the  data  requirements  in  Annex  B  of  the 
Commission  Delegated  Regulation  (EU)  2015/2446  as  amended  by  Delegated  Regulation  (EU) 
2021/234, BG and IE mentioned that they plan to conform with the new requirements as of 31/10/2023, 
respectively 01/10/2023. All of the other MS that had provided additional comments in the table below 
have complied with the requirements of the new Annex B. 

At the moment of writing BG, IE and LV have marked the project as complete, with the particularity 
that  for  BG  which  implemented  PN  as  part  of  TS  and  their  import  declaration  system  based  on 
requirements  from  Annex  D  to  Delegated  Regulation  (EU)  2015/2446,  the  system  will  have  to  be 
updated by 31/10/2023.  

DE explained that PN and TS will conform to the data requirements of the new Annex B as set out in 
the Delegated Act, not however for the moment with the formats and codes in the Implementing Act. 

19 

 
 
 
 
DE added that the Annex B (DA) requirements are being implemented in the existing national import 
systems so the deadline of 31/12/2022 can be achieved. 

The other Member States that also reported to envisage PN implementation by end 2022 are: FI, IT, LT  
(see table 14 below and adjusted to the latest information available).  

Important remark: 

Further to the planning and progress data collected from Member States and Commission services during 
Q1  and  Q2  2022,  new  information  has  been  communicated  to  the  Commission  which  has  not  been 
represented  in  this  accompanying  staff  working  as  it  was  not  part  of  the  methodological  approach 
established for this document. The key information will be taken on board and reflected in the main 
Report itself.  

Several Member States have submitted a written notification asking for derogation under Article 6(4) 
UCC to DG TAXUD considering the delay for PN beyond the deadline 31/12/2022, regardless of the 
option made to implement the system with ICS2 Release 2. The derogation requests from the Member 
States were assessed by the Commission services in terms of the justifications provided by the specific 
situation of the Member States requesting it and in view of a set of common assessment criteria.  

In this light the Commission has proposed an Implementing Decision16 granting a derogation to Austria, 
Belgium, Croatia, Cyprus, Czechia, Denmark, Estonia, France, Greece, Hungary, Luxembourg, Malta, 
Netherlands,  Poland,  Portugal,  Romania,  Slovakia,  Slovenia,  Spain  and  Sweden  for  the  Presentation 
Notification provided for in Article 133 of the Union Customs Code. The derogation is proposed to 
apply from 1 January 2023 until the deployment of the PN system, but not later than 31 December 2023 
in respect of goods entering the customs territory of the Union by air, and 1 March 2024 in respect of 
goods entering the customs territory of the Union by maritime transport, inland waterways, road and rail 
transport, whichever date is sooner.  

Detailed Responses: 

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

MS 

AT 

BE 

BG 

CY 
CZ 

DE 

DK 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

4 

5 

6 
6 

4 

4 

Low 

A  hybrid  approach  will  be  used,  combining  an  agile  development  and  the 
integration of the existing software solutions. 
BE would like to give traders the opportunity to align with ICS2 in the utmost 
way. Therefore the plan is to go into production with PN/TS on 01/03/2023, 
however only for the transport modes covered by ICS2 Release 2 and expand 
to the other modes of transport as of ICS2 Release 3. 
Presentation Notification was implemented as part of Temporary Storage and 
import declaration system. PN/TS update has been in production since January 
2019 aligned to requirements at that time. A plan to update the national import 
systems  to the new  Regulation  2021/234  is  ongoing with a  deadline  set for 
31/10/2023. 
The implementation of IT projects is being made using the TOGAF/ADM and 
RUP methodologies. 
Med  Same response as for AN. 
Med  Same response as for AN. 

Low 

Low 

DE  indicated  that  the  2021  national  planning  was  updated  following  the 
national planning update for the UCC Work Programme sent on 03/02/2022. 

Med  Same response as for AN. 

16 This reflects the state of play at the moment of the finalisation of the Report on 11 November 2022. 

20 

 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

EE 

5 

Med 

ES 

6 

High 

EE implemented timely the national system, but the migration of all economic 
operators would be gradual and ending beyond the deadline of 31 December 
2022. EE draws the  attention on the fact that  PN is closely linked to ICS2, 
therefore the project deadlines should be amended accordingly, meaning that 
the  end  date  of  the  deployment  window  of  PN  for  traders  (EO)  will  be 
01/03/2024. 
Estonia  has  deployed  Temporary  Storage/Presentation  Notification  (TS/PN) 
systems. However, not all traders will be using TS/PN system from the 1st of 
January 2023. The deadlines for TS and ICS2 are being synchronized (mainly 
because  of  the  datasets).  In  that  case,  traders  dealing  with  air  cargo  would 
migrate  at  the  latest  accordingly  to  the  national  deployment  date  of  ICS2 
release 2 and other traders accordingly to the ICS2 release 3. 
Data changes in the Annex B and other ongoing UCC projects have delayed 
the completion of the Technical Specifications which poses a high risk of delay 
on  the  activities  related  to  EO  and  the  port  systems.  In  this  context,  a  full 
deployment is expected only in 2024, namely 15/03/2024.  
There are several reasons for delays including the complexity of implementing 
the changes in their environment, the number of projects running in parallel 
and managing the changes with the traders. 
The current PN contains a reference to the ENS, however there are no issues 
envisaged regarding the ICS2 process. 

FI 
FR 
GR 
HR 
HU 
IE 
IT 
LT 
LU 

4 
5 
6 
6 
5 
6 
4 
6 

Med  According to Finland, PN is already in operation.  
Low  Same response as for AN. 
High  Same response as for AN. 
High  Same response as for AN. 
Med  Same response as for AN. 
Low  PN & TS had already been implemented in November 2020. 
Low  Same response as for AN. 
Med  Same response as for AN. 

LV 

5 

Med 

LV expressed that the level of complexity is increased due to numerous and 
complicated projects that are ongoing at the same time. 
For  Notification  of  Presentation  LV  uses  TSD  for  goods  arriving  by  air 
(according to the Article 145 (8) of the UCC) and Port system administered by 
the Ministry of Transport for goods arriving by maritime transport (according 
to the Article 190 of IA of the UCC) where notification for unloading (incl. 
PN  data  set)  is  submitted.  The  process  will  be  harmonised  along  with  the 
implementation of ICS2 R2 and R3. 
At  the  time  of  writing  LV  is  managing  the  Procurement  procedure,  having 
adopted an iterative development approach. 
In the risk spectrum, the Development and Conformance Testing activities of 
the system are being impacted. 

MT 
NL 

PL 

5 
5 

4 

High  Same response as for AN. 
High  Same response as for AN. 

Low 

PL mentioned that there are many provisions for presenting goods throughout 
the  UCC,  in  various  configurations  and  different  procedures,  for  pre-
presentation declarations, both in standard and simplified declarations. Taking 
into  account  the  above-mentioned  scope  of  regulations,  Poland  emphasized  
that their focus is on the presentation for ICS2 purposes and on the Free Zones 
(G3 and G4 in AIS / IMPORT PLUS). 

21 

 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

Regarding the development method, both an agile and an iterative approach 
are being used for the system development. 

High  Same response as for AN. 

PT 

RO 

6 

6 

Med 

SE 

4 

Med 

RO indicated in their last updated that currently they are staged at completion 
of procurement procedure. At the same time, they explained that PN, TS and 
Special Procedures Component 2 are included in the project of development 
of the national system of import and follows the implementation established 
for that system. In their derogation letter, RO mentioned a possible delay of 6 
months from the deadline (31/12/2022) for NIS, NSP IMP, PN and TS. 
According to SE, the solution for PN for postal consignments is in production 
since September 2021. The deployment for the other modes of transport will 
begin as of 01/03/2023. One of the considered options is the re-use of the ENS. 
The  operational  date  will  follow  for  each  transport  mode  for  ICS2,  while 
bearing a risk for delay with the traders. Concerning the maritime sector, there 
is  the  dependency  with  the  EMSW  and  deployment  in  August  2025. 
Concerning the NO border, there is a dependency to the Smart Border project 
and how to manage a smooth transition to a new process. 
SE informed that they are going to use the application developed by BE in the 
ETCIT co-operation. SE are at the moment analysing and considering the most 
efficient  way  to  integrate  the  application  into  the  existing  IT  infrastructure, 
bearing in mind the alternative of investigating the possibility to use a national 
application at least to a certain extent.    

SI 
SK 

4 
1 

Low  Same response as for AN. 
High  Same response as for AN. 

Table 11: Detailed responses from Member States – PN 

Figure 2 provides the percentage of Member States in each development phase for PN. 

Figure 2: Project Status as per Survey – PN 

22 

 
 
 
 
 
 
Temporary Storage (TS) 

Summary from the Commission: 

The summary is the same as for AN. 

Summary from the Member States: 

Please see also the summary from PN. 

BG implemented PN and TS as part of their national import declaration system. As it was implemented 
based on requirements from Annex D to Delegated Regulation (EU) 2015/2446, it will be updated by 
31/10/2023.  All  of  the  other  MS  that  had  provided  additional  comments  in  the  table  below17  have 
complied with the requirements of the new Annex B. 

DE explained that AN, PN and TS will conform to the data requirements of the new Annex B as set out 
in  the  Delegated  Act  by  end  2022,  not  however  for  the  moment  with  the  formats  and  codes  in  the 
Implementing Act. DE added that the Annex B (DA) requirements are being implemented in the existing 
national import systems so the deadline of 31/12/2022 is considered to be achieved. 

The other Member States that also reported to envisage TS implementation by end 2022 are: FI, IE, IT 
and LV (see table 15 below and adjusted to the latest information available).  

Important remark: 

Further to the planning and progress data collected from Member States and Commission services during 
Q1  and  Q2  2022,  new  information  has  been  communicated  to  the  Commission  which  has  not  been 
represented  in  this  accompanying  staff  working  as  it  was  not  part  of  the  methodological  approach 
established for this document. The key information will be taken on board and reflected in the main 
Report itself.  

Several Member States have submitted a written notification asking for derogation under Article 6(4) 
UCC to DG TAXUD considering the delay for TS beyond the deadline 31/12/2022, regardless of the 
option made to implement the system with ICS2 Release 2. The derogation requests from the Member 
States were assessed by the Commission services in terms of the justifications provided by the specific 
situation of the Member States requesting it and in view of a set of common assessment criteria.  

In this light the Commission has proposed an Implementing Decision18 granting a derogation to Austria, 
Belgium,  Croatia,  Cyprus,  Czechia,  Denmark,  Estonia,  France,  Greece,  Hungary,  Lithuania, 
Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden 
for the Temporary Storage referred to in Article 145 of the Union Customs Code. The derogation is 
proposed to apply from 1 January 2023 until the deployment of the TS system, but not later than 31 
December 2023 in respect of goods entering the customs territory of the Union by air, and 1 March 2024 
in  respect  of  goods  entering  the  customs  territory  of  the  Union  by  maritime  transport  or  inland 
waterways, road or rail transport, whichever date is sooner. 

Detailed Responses: 

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

MS 

AT 
BE 
BG 
CY 
CZ 

Complexity 
Rating 
6 

5 
6 
6 

Risk 
Level 
High  Same response as for PN. 
Same response as for PN. 
Low  Same response as for PN. 
Med  Same response as for PN. 
Med  Same response as for PN. 

Additional Comments 

17 Idem12. 
18 This reflects the state of play at the moment of the finalisation of the Report on 11 November 2022. 

23 

 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

DE 

4 

Low 

DK 

6 

High 

Regarding  the  Confomance  Testing,  this  "message"  is  updated  as  part  of 
"National Entry System" of the national IT-System ATLAS (Release 9.1) for 
which the Economic Operator is allowed to carry out migration from 01/05/2021 
until 14/10/2022. 
DE indicated that the data model is not in line with EU-CDM (FMS) and will 
be updated following the approach of CCI and the national import system being 
the basis for the new and modernized import application. The electronic message 
is  aligned  with  the  data  requirements  of  the  new  Annex  B  as  set  out  in  the 
Delegated  Act,  however  for  the  moment  with  the  formats  and  codes  in  the 
Implementing Act. 
The 2021 national planning was updated following the national planning for the 
UCC Work Programme sent on 03/02/2022. 
DK is facing a reprioritization of the Danish UCC program and the underlying 
projects reflected in the UCC Work Programme. Based on the initial phases of 
the implementation of the UCC there is a considerable risk that Denmark will 
not be able to meet all the deadlines in the UCC. This is due in part to the overall 
complexity of the task and the implementation schedule, and in part because the 
Danish national supplier has not been able to deliver the standard system at the 
expected quality and speed.  
Mitigation measures include change of organizational setup with the supplier in 
terms  of  staffing  and  teams,  primarily  in  order  to  achieve  a  more  effective 
development process and to also achieve deeper understanding of the standard 
software at earlier stages of the proces to avoid problems.  
Furthermore,  initiatives  in  order  to  secure  more  robust  releases/deployment 
processes of standard software have been initiated in order to lower waiting time 
in relation to configuration and testing. DK informed that Conformance Testing 
is under planning and the possibility to use a partial deployment approach with 
limited functionality is being analysed. 

EE 
ES 

FI 

FR 
GR 

5 
6 

6 

5 
6 

Med  Same response as for PN. 
High  Same response as for PN. 

High 

FI  explained  that  the  system  deployment  is  on  target,  with  an  estimated 
deployment date set for 01/03/2023. 

Low  Same response as for PN. 
High  Same response as for PN. 

HR explained that the deployment for TS is delayed beyond UCC deadline due 
to project complexity and  dependencies with other projects and stakeholders. 
An  additional  contributing  factor  was  the  decision  to  align  NA,  PN  and  TS 
timeline  with  ICS2  R2.  AN  was  already  part  of  ISC2  specifications  and  HR 
made the decision that by end of 2021/beginning of 2022 to also deploy PN as 
part of ICS2. As a result the deployment of TS was aligned with  the  deployment 
of AN and PN (01/03/2023). Additional factors for delays were the COVID19 
pandemic  and  overload  of  business  and  IT  staff  due  to  engagement  of  same 
teams in multiple UCC IT projects. 
HR indicated that no mitigation actions have been considered in the reporting 
period  and  that  according  to  the  current  state  of  the  progress  the  timely 
development of the economic operators systems is the most impacted.  
Future activities include the publication of Technical Specifications by the end 
of Q1 2022 and the completion of Conformance Testing in Q4 2022/Q1 2023. 
According  to  HU,  TS  will  be  delayed,  having  the  new  deadline  set  for 
30/09/2024. HU submitted a derogation request letter in this regard. 

HR 

5 

High 

Med 

HU 

IE 
IT 

5 

6 
4 

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

24 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

LT 

6 

High 

Additional Comments 

LT explained that regarding the current planning and progress, a delay of 12 
months  is  envisaged  for  the  system  deployement,  with  the  main  reason 
expressed  being  the  complex  and  time  consuming  service  procurement 
procedures.  Within  mitigating  measures  foreseen  are  discussions  with  the 
contractor. 

LU 

LV 

MT 

NL 

PL 

4 

5 

5 

4 

PT 

6 

Low 

As from 24/09/2017 Temporary Storage has been updated according to the UCC 
data  elements. Additional functionality for movements between TS places (if 
located in Latvia) has been added on 05/03/2018. The system's updated version 
according to the latest changes of EUCDM is in production starting 15/02/2022. 

Low 

High 

High  Same response as for PN. 
Same response as for PN. 
In addition, NL is considering to combine TS maritime with ICS2 – Release 3 
in 2024, as requested by trade. 
According to PL some projects are being developed as a component within their 
national import system e.g. TS, SP Component 2(IMP), PoUS. 
PT indicated that the national system that will cover the AN, PN and TS projects 
is an integrated system with many other features in addition to the NA, PN and 
TS. The  system  integrates all  the  information regarding  the  entry  and  exit of 
means  of  transport  (air  and  sea),  and  also  the  entry  and  exit  of  goods 
(import/export manifest). This national system also includes the control of ETD, 
RSS  and  ACP  authorizations,  in  the  import/export  manifest.  At  the  entry  of 
goods, the system will be integrated with ICS2, the risk management system and 
the national import system. At the exit of goods, the system will be integrated 
with AES 1 and AES 2, and the risk management system, to control the exit of 
goods, with automatic exit certification for export. 
At the same time, on maritime traffic, the customs system is interconnected with 
the system of the port authorities, in a single window environment similar to 
EMSW, requiring that the port system will be completely reformulated to follow 
the developments of UCC WP. 
Temporary Storage will be implemented in the same national system, integrated 
with several other systems (ICS2, NIS, Risk Management, Temporary Storage 
Facilities). Milestones related to Technical Specifications Publication for EO, 
Conformance Testing and Deployment were postponed, due to the complexity 
of developments,  and due to the definition of a longer period for conformance 
testing activities.  
An agile development approach is envisaged in order to reduce implementation 
timeframe and no partial deployment approach will be used given the high level 
of  integration  with  diferent  systems  (ICS2,  National  Import  System,  Risk 
Management System, Temporary Storage Facilities systems, Ports Authorities 
and Airport Authorities). 
A  delay  of  9  to  12  months  is  being  envisaged  for  AN/PN/TS/NIS  and  SP 
Component 2. 

High 

RO 

SE 

SI 
SK 

6 

4 

4 
1 

Med  Same response as for PN. 

Med  

SE is going to use the application developed by BE in the ETCIT co-operation. 
At the moment the SE team is analysing and considering the most efficient way 
to  integrate  the  application  into  the  existing  IT  infrastructure  and  still 
considering as an alternative the possibility to use a national application at least 
to a certain extent.    
Low  Same response as for PN. 
High  Same response as for PN. 

25 

 
 
 
 
 
Table 12: Detailed responses from Member States – TS 

Figure 3 provides the percentage of Member States in each development phase for TS. 

Figure 3: Project Status as per Survey – TS 

3.1.2  Overview of Project Progress 

Table 13, Table 14 and Table 1519 highlight any known divergences in the planning compared to the dates 
set  in  the  Work  Programme.  As  this  project  has  a  deployment  window,  the  ‘Deployment’  and 
‘Operations’ columns are shown. If there is a difference in these two dates, this implies that a migration 
period is planned. 

Further to the planning and progress data collected from Member States and Commission services during 
Q1  and  Q2  2022,  new  information  has  been  communicated  to  the  Commission  which  has  not  been 
represented  in  this  accompanying  staff  working  as  it  was  not  part  of  the  methodological  approach 
established for this document. Some dates might have been adjusted by Member States in the light of 
the derogation requests and the derogation decisions.  

The key information will be taken on board and reflected in the main Report itself.  

19 For delays less than 6 months, the deployment and/or the operation dates will be marked in orange. Delays exceeding 6 
months will be marked in red. 

26 

 
 
 
 
   
 
                                                      
In regards to the implementation of the Notification of Arrival, the following Member States have a 
planned operations date that is later than the deadline in the UCC Work Programme: AT, BG, BE, CY, 
EE, ES, FI, FR, DE, GR, HU, LU, LT, MT, NL, PL, PT, RO, SE, SI and SK. DK and HR did not provide 
information.  Please  note  that  the  dates  of  operations  reflected  in  the  table  below  indicate  the  full 
implementation of the project. Some Member States decided to deliver the project in several iterations 
or releases, linked to the ICS2 Releases.  

The specific dates can be found in Table 13. 

Table 13: Comparison of Planned and Actual Dates – AN20 

20 Several dates provided may differ given the derogation process undergoing. 

27 

Target date  2022 Planned/ 2022 % of 2022 Planned/ 2022 % of Target date  2022 Planned/ 2022 % of Target date 2022 Planned/ AT01/11/2021N/AN/AN/A01/03/2023N/A01/03/2023BENot providedNot providedNot providedNot providedNot providedNot provided01/03/2023BG31/03/2022100%15/12/2022100%01/03/20230%01/03/2023CY30/07/2022100%21/03/20230%31/03/20230%31/03/2023CZ01/09/2022100%31/12/2022Not started 31/12/2022100%31/12/2022DEN/AN/AN/AN/AN/AN/A02/10/2023DKNot provided70%Not provided70%Not provided70%Not providedEEN/A40%N/A0%03/10/20230%03/10/2023ESN/AN/AN/AN/A01/03/2023N/A02/10/2023FI30/06/2022100%Not provided95%31/03/202395%31/03/2023FR31/03/2022100%31/12/20220%31/12/20220%01/06/2023GR30/06/202150%N/AN/A31/12/20220%01/01/2025HRNot provided100%Not provided20%Not provided85%Not providedHU30/06/2022100%30/11/2022100%01/03/2023100%01/03/2023IEN/AN/AN/AN/AN/AN/AN/AIT15/07/2020100%15/11/2021100%31/12/2021100%31/12/2022LT01/06/2020100%30/11/2022100%31/12/2022100%31/12/2022LU14/12/2021Not provided20/02/2023Not provided01/03/2023Not provided01/03/2023LV05/06/2017100%22/09/2017100%24/09/2017100%25/09/2017MT31/03/2022100%Not provided0%15/11/202275%01/03/2023NL31/12/2021100%15/09/2023N/A01/11/20230%01/06/2024PL01/01/2023100%30/09/20230%01/12/20230%01/12/2023PT31/07/2022100%31/07/202340%30/11/20230%01/12/2023RO30/11/2021Not provided31/01/2023Not provided01/03/2023Not provided30/09/2023SEN/AN/ANot provided0%01/03/20230%31/03/2025SI01/10/2022100%01/02/2023100%01/03/2023100%01/03/2023SK01/12/20220%01/11/20230%01/12/20230%01/12/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)To be defined by MS and for Notification of Arrival in line with ICS2 planningTo be defined by MS as part of the national plan31/12/2022 
 
  
 
 
 
                                                      
In regards to the implementation of the Presentation Notification, the following Member States have 
indicated a planned operations date for PN, which is later than the deadline in the Work Programme: 
AT, BE, CY, EE (deployment on time), ES, FR, GR, HU (deployment on time), HR, LU, MT, NL, PL, 
PT, RO, SE, SI and SK. Please note that the dates of operations reflected in the table below indicate the 
full  implementation  of  the  project.  Some  Member  States  decided  to  deliver  the  project  in  several 
iterations or releases, linked to the ICS2 Releases. 

The specific dates can be found in Table 14. 

Table 14: Comparison of Planned and Actual Dates – PN21 

21 Idem 21. 

28 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateAT01/11/202190%N/A0%01/03/20230%01/03/2023BE12/10/2021Not Provided01/03/2023Not Provided01/03/2023Not Provided01/03/2023BG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY30/07/2022100%21/03/20230%31/03/20230%31/03/2023CZ01/09/2022100%31/12/2022100%31/12/2022100%31/12/2022DE09/10/2020100%14/10/202250%06/03/2021100%31/10/2022DK01/03/202170%01/06/202170%01/06/202170%01/07/2021EE31/12/2020Not Provided31/12/2023100%15/03/2021100%01/03/2024ES30/06/2022100%15/03/20240%15/03/20240%16/09/2024FI01/03/2020100%12/03/2021100%15/03/2021100%31/03/2021FR30/06/2022100%30/06/202275%01/03/20230%01/06/2023GR30/06/202150%N/AN/A31/12/20220%01/01/2025HR01/04/2022100%31/12/202220%01/03/202385%Not providedHU30/06/2022100%30/11/2022100%31/12/2022100%01/03/2023IE04/10/2019100%04/10/2021100%23/11/2020100%05/10/2021IT15/07/2020100%15/11/2021100%31/12/2021100%31/12/2022LT01/07/2022100%30/11/2022100%31/12/2022100%31/12/2022LU14/12/2021Not Provided20/12/2022Not Provided10/01/2023Not Provided10/01/2023LV05/06/2017100%22/09/2017100%24/09/2017100%25/09/2017MT31/03/2022100%N/AN/A15/11/202275%01/03/2023NL01/09/2022100%15/09/2023N/A01/11/20230%01/06/2024PL01/01/202390%30/09/202340%01/12/202350%01/12/2023PT31/07/2022100%31/07/202340%30/11/20230%01/12/2023RO31/03/20220%31/12/20220%31/12/20220%30/06/2023SE30/09/2022100%01/03/20240%01/03/20230%01/03/2023SI01/10/2022100%01/02/2023100%01/03/2023100%01/03/2023SK01/12/20220%01/11/20230%01/12/20230%01/12/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)To be defined by MS and for Notification of Arrival in line with ICS2 planningTo be defined by MS as part of the national plan31/12/2022 
 
 
 
 
 
 
 
 
                                                      
 
In regards the implementation of the Temporary Storage declaration, the following Member States have 
indicated a planned operations date for TS, which is later than the deadline in the Work Programme: 
BE, CY, ES, FR, GR, HR, LT, LU, MT, NL, PL, PT, RO, SE, SI and SK. AT and DK did not provide 
information. Some Member States decided to deliver the project in several iterations or releases, linked 
to the ICS2 Releases. 

Table 15: Comparison of Planned and Actual Dates – TS 22 

22 Idem 22. 

29 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateATNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedBE12/10/2021Not Provided01/03/2023Not Provided01/03/2023Not Provided01/03/2023BG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY30/07/2022100%21/03/20230%31/03/20230%31/03/2023CZ01/09/2022100%31/12/2022100%31/12/2022100%31/12/2022DE09/10/2020100%14/10/202250%06/03/2021100%31/10/2022DKNot Provided100%N/AN/ANot provided70%Not providedEE31/12/2020Not Provided31/12/2023100%01/07/2021100%01/07/2021ES30/06/2022100%15/03/20240%15/03/20240%16/09/2024FI02/11/2020100%Not Provided100%31/12/2022Not Provided30/09/2022FR30/06/2022100%30/09/202275%31/12/20220%01/06/2023GR30/06/202150%N/AN/A31/12/20220%01/01/2025HR31/03/2022100%28/02/202390%01/12/2022Not ProvidedNot ProvidedHU30/06/2022100%30/11/2022100%31/12/2022100%31/12/2022IE04/10/2019100%04/10/2021100%23/11/2020100%05/10/2021IT15/07/2020100%15/11/2021100%31/12/2021100%31/12/2022LT04/05/202380%01/12/20230%01/12/20230%01/12/2023LU14/12/2021Not Provided20/12/2022Not Provided10/01/2023Not Provided10/01/2023LV05/06/2017100%22/09/2017100%24/09/2017100%25/09/2017MT31/03/2022100%Not Provided50%15/11/202250%01/03/2023NL01/09/2022100%N/AN/A01/11/20230%01/06/2024PL01/01/202390%30/09/202310%01/12/202310%01/12/2023PT31/07/2022100%31/07/202340%30/11/20230%01/12/2023RO31/03/2022Not Provided31/12/2022Not Provided31/12/2022Not Provided30/06/2023SENot Provided0%Not Provided0%01/10/20240%15/08/2025SI01/10/2022100%01/02/2023100%01/03/2023100%01/03/2023SK01/12/20220%01/11/20230%01/12/2023Not Provided01/12/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)To be defined by MS and for Notification of Arrival in line with ICS2 planningTo be defined by MS as part of the national plan31/12/2022 
 
 
 
 
 
                                                      
Regarding  the  Notification  of  Arrival,  additional  details  regarding  the  specific  percentage  of 
completion per milestone can be seen in Figure 4. 

Figure 4: Percentage of Completion per Phase – AN 

30 

 
 
 
Regarding the Presentation Notification, additional details regarding the specific percentage of 
completion per milestone can be seen in Figure 5. 

Figure 5: Percentage of Completion per Phase – PN 

31 

 
 
 
Regarding Temporary Storage, additional details regarding the specific percentage of completion per 
milestone can be seen in Figure 6. 

Figure 6: Percentage of Completion per Phase – TS 

32 

 
 
 
UCC NATIONAL IMPORT SYSTEMS (NIS) UPGRADE 

3.2 
The project will implement all processes and data requirements deriving from the UCC, which relate to 
the import of goods into the Union. The existing national import systems must be upgraded in line with 
these  new  UCC  requirements  within  the  legal  deployment  deadline  until  the  end  of  2022.  The 
development activities related to this project are a national matter, with processes and data requirements 
for the external domain to be defined and agreed at EU level. If the deadline cannot be met, Member 
States are required to address this in writing to the European Commission and request a derogation as 
stated in Art 6 (4) of the UCC. Member States will have to address a formal request, with a temporary 
nature23, stating a scope (UCC articles) and a clear justification.24 

The upgrade mainly relates to: 

a)  Changes  to support the different possibilities for lodging a  customs declaration  (e.g. 
standard, simplified, including pre-lodged one, declaration made through entry in the 
declarant's records, supplementary) and its processing in the customs systems; 

b)  Changes for Centralised clearance at national level; 
c)  Changes related to the exchange of information; 
d)  Adjustments of the respectful messages with the datasets in Annex B to UCC DA/IA; 
e)  The impact of changes in other electronic systems at national level.  

3.1.3 Summary of Responses 

Summary from the Commission: 

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

Following  the  finalisation  and  acceptance  of  the  Technical  Specifications  for  CCI  Phase  1  and 
Functional Specifications for CCI Phase 2, the Commission has received enquiries from the Member 
States related to CCI specifications and their reusability for the NIS’s upgrade. 

DG TAXUD provided timely support to Member States for their developments on the National Import 
Systems.  Therefore,  a  documentation  package  was  issued  on  the  reuse  of  CCI  specifications  and  a 
support function was established in DG TAXUD for legal, procedural and technical issues.25 

In view of the legal deadline of 31/12/2022, the risks identified in the 2021 Annual Progress Report for 
the national import system (and the related projects such as special procedures at import) were brought 
to the attention of the Directors General of the Customs Administrations with the demand to address the 
risks and ensure timely deployment.  Member States were encouraged to submit requests for funding 
under the Recovery & Resilience Fund to help with customs IT work, however, not many of them have 
requested support. 

Since mid 2021, closer supervision was carried by DG TAXUD by means of collecting more frequent 
progress reporting from the Member States and organising a range of bilateral meetings in 2022 with 
each Member State at CIO level.   

Summary from the Member States: 

23 By temporary nature it should be understood a limited and reasonable period of time, which will be assessed following the 
justification provided. 
24 At the moment of writing the following Member States have sent derogation letters: AT, BE, CY, CZ, DK, ES, FR, GR, LU, 
LT, MT, PT, RO and SE.  
25 21st of February, Ref. Ares (2022) 1297882. 

33 

 
 
 
 
                                                      
Some Member States (BG, IT, LV) planned this project as a priority and have already upgraded their 
national import system in line with the UCC and the Annex B that was in force at that moment. They 
have implemented the NIS project within the legal deadline of 31/12/2022. However, due to this early 
deployment, these Member States will need to make an additional effort for a second upgrade in view 
of the revised Annex B by December 2023. 

Most Member States have indicated that the system development is following the new data requirements 
in  Annex  B  of  the  Commission  Delegated  Regulation  (EU)  2015/2446  as  amended  by  Delegated 
Regulation (EU) 2021/234,  

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

If  not  already  done,  updates  to  align  their  systems  with  the  latest  Annex  B  provisions  will  happen 
between 2021 and 2023.   

Furthermore, quite some Member States progressed well, with technical specifications either completed 
or in progress26 for almost 75% of the MSs. Member States that are currently developing the system 
have reported using an agile development approach in order to reduce the implementation timeframe 
and to minimise the impact on milestones. This can be linked to the fact that a representative majority 
has indicated a high level of complexity associated with the many interdepencies with other systems at 
national level.  

The Member States that reported to envisage NIS implementation by end 2022 are:  BG, DE, EE, FI, 
HR, IE, IT, LV, SI and SK (see table 16 below and adjusted to the latest developments).  

Important remark: 

Further to the planning and progress data collected from Member States and Commission services during 
Q1  and  Q2  2022,  new  information  has  been  communicated  to  the  Commission  which  has  not  been 
represented  in  this  accompanying  staff  working  as  it  was  not  part  of  the  methodological  approach 
established for this document. The key information will be taken on board and reflected in the main 
Report itself.  

Several Member States have submitted a written notification asking for derogation under Article 6(4) 
UCC to DG TAXUD considering the delay for NIS beyond the deadline 31/12/2022. The derogation 
requests from the Member States were assessed by DG TAXUD in terms of the justifications provided 
by the specific situation of the Member States requesting it and in view of a set of common assessment 
criteria.  

In this light the Commission has proposed an Implementing Decision27 granting a derogation to Austria, 
Belgium,  Cyprus,  Czechia,  Denmark,  France,  Greece,  Hungary,  Lithuania,  Luxembourg,  Malta, 
Netherlands, Portugal, Romania, Spain and Sweden for the National Import System to use means other 
than electronic data-processing techniques for the exchange and storage of information. The derogation 
is proposed to apply from 1 January 2023 until the deployment of the NIS system, but not later than 31 
December 2023, whichever date is sooner. 

Detailed Responses: 

Table 16 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

MS 

AT 

Same response as for TS. 

Additional Comments 

26 The majority of MSs have completed Technical Specifications activities while AT, DK, GR, LT, PL, HU, IE, FR and PL 
reported to be in progress.  
27 This reflects the state of play at the moment of the finalisation of the Report on 11 November 2022 

34 

 
 
 
 
 
                                                      
Complexity 
Rating 

Risk 
Level 

MS 

BE 

BG 

5 

Low 

Additional Comments 

BG is planning an update of the National Import System in accordance to the 
new requirements set out by Annex B. The IT projects are implemented using 
the TOGAF/ADM and RUP methodologies. According to internal plans, a test 
version  of  the  updated  import  system  is  expected  middle  of  2023,  with  a 
completed implementation by 31/10/2023. 
Same response as for TS. 
In addition CY  explained that all milestones are going to be impacted due to 
delay in the public procurement procedure and given that the contract with the 
awarded economic operator was recently signed. Mitigating measures such as 
the allocation of extra human and other resources, are planned.   

Med 

CY 

CZ 

6 

6 

Med  Same response as for TS. 

DE 

4 

Low 

DK 

EE 

6 

Low 

ES 

5 

Med 

Accoding to DE, this project is implemented in the major release of the national 
IT-ATLAS (Release 9.1) to ensure that all data requirements from Annex B are 
covered, especially to provide the information required by Surveillance 3. The 
Economic  Operator  is  allowed  to  carry  out  migration  from  01/05/2021  until 
14/10/2022. 
The datamodel is not in line with the new EUCDM version (FMS) and will be 
updated following the approach of CCI and the National Import System being 
the basis for the new and modernized import application. The electronic message 
conforms  to  the  data  requirements  of  the  new  Annex  B  as  set  out  in  the 
Delegated Act, however, for the moment, not with the formats and codes in the 
Implementing Act.  
Due  to  the  need  to  prioritise  the  implementation  of  the  most  critical  systems 
(ICS2,  AES  and  NCTS),  DK  will  not  be  able  to  go  live  with  NIS  on  31 
December 2022. A new date of 31/12/2024 has been selected, however DK is 
intensifying the focus on contract management in order to avoid further delays. 
The new national import system was implemented by Estonian Tax and Customs 
Board and is operational since 01/07/2021. 
According to ES planning, Conformance Testing for operators will be open from 
July 2022, having the first deployment focused on declarations to support CCI, 
therefore creating a dependency with the system, the planning being adjusted in 
order to fit CCI system’s needs.  
The phased approach to the upgrade of the National Import  System was also 
confirmed with the first deployment on 30/09/2022. Listed here for information: 
03/10/2022: Additional Declaration Type A & D, (with CCI Phase 1) 
01/06/2023: Additional Declaration Type A, D, Z & U (national domain) 
01/03/2024: Additional Declaration Type V (with I2), (national domain) 
01/06/2024: Additional Declaration Type B, E, C, F, X, Y (national domain) 
ES  advised  that  the  initial  implementation  will  be  for  CCI  Phase  1.  The  full 
functionality  will  be  gradually  rolled  out,  but  they  will  need  to  keep  the  old 
system running in parallel until all functionality is switched over. This will have 
implications for the SURV dataset that they will further submit. 

35 

 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

FI 

6  

High 

FR 

6 

Med 

GR 

6 

High 

HR 

6 

Low 

HU 

6 

Med 

FI  explained  that  the  system  was  upgraded  in  phases  from  early  2020  with 
traders using it since April 2021. The last phase covering simplifications and 
special procedures enters operation in Q3 this year. It was also mentioned that 
for the low value consignments, they had developed a mobile solution for use 
by private individuals which had proven very successful. 
At  the  same  time,  the  SURV  schema  needs  to  be  updated,  foreseen  in  the 
relevant deadline. FI mentioned the huge impact that the work on the low value 
consignments  had  on  their  development  plans  and  the  huge  increase  in  the 
volume  of  declarations.  Upgrading  the  current  system  and  integrating  the 
necessary changes into future systems was a great effort. However, FI reassured 
that there are no risks identified for the national systems. Current activities are 
focused on the system testing phase. 
In  order  to  prevent  Economic  Operators  transition  problems  between  the 
applications, FR chose to stagger the transition period. Thus, it was decided to 
deploy a first partial version of the application in October to allow the EOs to 
test the application before the release of the final version expected in December. 
The project is made of five iterations. The 1st iteration was completed on time, 
with NIS expected to be deployed in production by the end of December 2022. 
Overall,  the  schedule  is  compressed,  having  unexpected  events  as  one  of the 
primary causes for delays on the planning. 
According to GR, new fields will be added in the current system, in order to be 
compliant  with  the  UCC  requirements,  expecting  a  full  implementation 
alongside CCI Phase 1. 
GR  indicated  delays  to  the  start  call  for  tender  procedures,  with  internal 
discussions under way to assess the situation and the already confirmed impact 
on  all  milestones.  Subsequent  information  indicates  a  delay  until  the  end  of 
2024. 
HR explained that the project is national and testing will be conducted with EOs. 
All  messages  and  business  processes  are  defined  and  the  functionalities  that 
have been defined are being developed. 
The  elevated  risk  of  complexity  is  due  to  many  interdependencies  among 
systems. 
At the time of writing, specifications are currently being defined for NIS with 
the  necessary  adjustments to  the  existing  import system  to  be  ready  with  the 
UCC requirements by 31/12/2022. The necessary IT needs have been completed 
by the customs profession and Legal and IT barriers have been identified, having 
the  necessary  measures  in  place  to  overcome  them.  In  parallel,  development 
work is underway. 
In  a  second  phase  they  plan  some  further  internal  development  for  February 
2023 and in a third phase to introduce national centralised clearance in March 
2023. 

36 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

IE 

4 

Med 

IT 

6 

Low 

The  National  Import  System  it  was  confirmed  had  been  implemented  in 
November 2020 with the dataset applicable before the change to the new Annex 
B dataset. IE will update to the new dataset along with the update for CCI, being 
currently  on  track,  however  pressure  exists  with  many  parallel  developments 
under way. They are also working closely with the IT solution providers for the 
traders to ensure they can meet all the new requirements. Those providers are 
also under a lot of pressure as there are a small number of companies. The IE 
administration has a good working relationship with the trade community and 
meets with them regularly. 
A possible risk on the on-time delivery of the project could be related to the 
existing pressure on all parties as EOs will be moving to AES and NCTS P5 
during a similar timeframe. 
For  National  Import  IT  already  has  a  system  in  place  which  was  updated  by 
01/07/2021 with a migration period for traders until 08/06/2022. This is based 
on EUCDM 5.2 and covers standard declarations only, simplified and EIDR will 
come  later  in  2022.  This  will  also  need  to  be  updated  to  the  latest  Annex  B 
requirements,  being  planned  for  November  2023  along  with  CCI.  The  H7 
dataset for low value consignments is already based on the new requirements 
and traders are well informed about the changes. The old import system will be 
closed for new declarations starting 08/06/2022. 

6 

High  A delay of 12 months is envisaged. 

LT 

LU 

LV 

6 

Low 

MT 

6 

High 

NL 

3 

Low 

LU indicated a delay less than 6 months regarding the implementation of NIS in 
accordance  with  the  previous  Annex  B,  therefore  the  new  Upgrade  was  not 
provided with a planning. 
LV explained that as from 03/06/2018 National Import System has been aligned 
with Annex B and EUCDM V2.0. In order to implement updates according to 
the  EUCDM  latest  version  and  CCI  until  01/12/2023,  a  totally  new  National 
Import System should be developed. This could cause delays on the deployment 
of the system given several external issues such as COVID-19 pandemic and 
Ukraine war, which have impacted the costs of getting a new contract in place. 
MT indicated that NIS will be deployed with full functionality, being alligned 
with EUCDM V6.1 and that Conformance Testing will not be applicable for the 
deployment of National systems.  
Given the numerous activities concerning various systems that are happening all 
in the same period, MT expressed that a high level of risk on the on-time delivery 
of  the  project  is  imminent,  with  an  anticipated  delay  on  Deployment  into 
production of 1 Quarter. Technical Specifications will be impacted, therefore, 
the  upgraded  National  Import  System  will  be  deployed  around  Q1/Q2  2023, 
instead of Q4 2022. 
NL indicated that an agile approach is being used for the system development. 
The overall status for the system deployment is appreciated as being on target. 
NL will provide a transition period for their traders until June 2023 as all traders 
will not be ready in time for the end of 2022. NL will also meet the SURV3 
requirements using a converter from 01/01/2023. 

37 

 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

PL emphasized that for NIS, functionalities will be implemented for production 
requiring  data  exchange  with  EU  countries  and  at  the  same  time,  data  to  be 
supplied to the European Commission. 
NIS  deployment  is  envisaged  for  31/12/2022.  PL  has  an  external  contractor 
working on the development and no major risks have been identified yet. The 
system will be UCC compliant, the new Annex B data requirements have been 
already  implemented,  but  not  made  operational  yet.  The  attributes  from  the 
original  Annex  B  have  been  already  implemented  in  the  current  national 
specification for some time, but they were blocked. National system for special 
procedures  called  RPS  (for  economic  operators  for  the  settlement  of  special 
procedures) has already been implemented. 
In the system development, PL will use both an agile and an iterative approach. 
PT indicated that regarding the Conformance Testing activities, national domain 
tests and tests with Central Systems will be performed.  
According  to  PT,  a  partial  deployment  approach  cannot  be  envisaged  for the 
system,  given  the  high  probability  of  causing  the  disruption  of  the  National 
Import System. 
A delay of 9 to 12 months is being envisaged for NIS. 

PL 

6 

Low 

High 

PT 

RO 

6 

6 

Med  Same response as for TS. 

SE 

3 

Low 

SI 

6 

Low 

SK 

3 

Low 

SE  reiterated  their  intention  of  performing  a  phased  implementation.  The 
information  provided  by  SE  regarding  NIS  is  applicable  regarding  standard 
customs declaration. The simplfied declaration and EIDR will be implemented 
2023/2024. The low value declaration H7 will be deployed during summer 2023. 
SE advised that for the standard customs declaration (excl. Special Procedures), 
they already deployed this on 15/03/2022. There is a migration period for traders 
until 31/12/2022. The Special Procedures and H5 dataset will be implemented 
in February 2023 with migration until 30/06/2023. The H7 is in 2 development 
phase and will be deployed in summer 2023. For simplified declaration/EIDR, 
development and deployed are envisaged for 2023/2024, with migration until 
Q4 2024. Customs warehousing was already updated, but needs to be updated 
again to the new Annex B requirements and this is envisaged for 2024. 
SI  explained  that  an  increased  complexity  level  was  alloted  to  the  system 
development considering the had to harmonise the data of the import declaration 
with the new Annex B requirements. Given the considerable change of data it 
was necessary to reprogram about 1000 national rules and conditions and about 
2000 risk analysis instructions. At the same time, a great impact was generated 
considering the data changes from EUCDM  V3.1 to EUCDM V6.1. This has 
caused to postpone the use of the renewed import system, having the external 
environment  not  prepared  and  very  difficult  to  work  with.  On  the  same  note 
communication was highly affected due to the situation created by the COVID 
19 pandemic, adding to the system development complexity. 
Regarding AN/PN/TS and NIS, SK confirmed that they will be a year late with 
the deployment due to lack of human resources. They are currently performing 
analysis  of  the  situation  with  their  IT  supplier  and  crisis  manager.  For  the 
moment no mitigating measures are foreseen. 
In  addition,  SK  indicated  that  the  system  wil  be  in  accordance  with  the  new 
Annex  B  Delegated  Regulation  (EU)  2015/2446  requirements  starting 
01/12/2023. 

Table 16: Detailed responses from Member States – National Import Systems Upgrade 

38 

 
 
 
Figure 7 provides the percentage of Member States in each development phase. 

Figure 7: Summary of Survey Responses – National Import Systems Upgrade 

3.1.4 Overview of Project Progress 

Table 17 highlights any divergences in the planning compared to the dates set in the Work Programme. 
As this project has a deployment window, the ‘Deployment’ and ‘Operations’ columns are shown. If 
there is a difference in these two dates, this implies that a migration period is planned. 

On the delivery of the Technical Specifications, most Member States reported the work done. However, 
the Member States and the economic operators need at least an additional 12 months from that moment 
till the full operation of their upgraded NIS and the interconnection with trade.   

In regards to the implementation of the National Import Systems Upgrade, the following Member States 
have a planned operations date that is later than the deadline in the UCC Work Programme: BE, CZ, 
CY, ES, FR, GR, LT, NL, PL, PT and RO. AT and DK did not provide data. The specific dates can be 
found in Table 17 below. MT explained that the provided date for operation is the “happy flow” date, 
however the months of October/November/December are very busy for trade prior to Christmas so this 
brings  with  it  some  risks  for  delays.  Due  to  latest  developments,  some  more  Member  States  have 
reported to have a full deployment and transition beyond the legal deadline such as HU, LU, MT, SE. 

39 

 
 
 
 
 
 
 
Table 17: Comparison of Planned and Actual Dates – National Import Systems Upgrade28 

28 Several dates provided may differ given the derogation process undergoing. 

40 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateATNot provided80%Not provided0%Not provided0%Not providedBE01/11/2021Not provided01/09/2023Not provided01/10/2023Not provided01/10/2023BG28/02/2018100%01/12/2018100%07/01/2019Not provided07/01/2019CY30/07/2022100%21/03/20230%31/03/20230%31/03/2023CZ31/03/2023100%30/11/2023100%01/12/2023100%01/12/2023DE09/10/2020100%14/10/202250%06/03/2021100%31/10/2022DKNot provided25%Not Provided0%Not provided0%Not providedEE30/09/2020100%30/06/2021100%01/07/2021Not provided01/07/2021ES14/03/2022100%30/06/202450%30/09/2022100%30/06/2024FI30/06/2019100%Not provided100%31/12/2019100%31/12/2022FR01/02/2022100%N/A100%30/09/2022100%31/03/2023GR31/03/202170%N/AN/A31/12/20220%01/01/2025HR31/12/2021100%31/12/2022100%01/01/2023100%01/01/2023HU31/07/2022100%31/12/2022100%31/12/2022100%31/12/2022IE04/10/2019100%04/10/20210%23/11/20200%05/10/2021IT02/12/2019100%30/06/2021Not Provided01/07/2021Not provided30/06/2021LT04/05/202380%01/12/20230%01/12/20230%01/12/2023LU22/02/2022Not provided20/12/2022Not provided10/01/2023Not provided10/01/2023LV30/10/2017100%01/06/2018Not Provided03/06/2018Not Provided04/06/2018MT31/03/2022100%N/AN/A15/11/202275%15/11/2022NL22/06/2021100%31/12/2022100%01/04/2022100%30/06/2023PL01/01/202390%30/09/2023Not provided01/12/202350%01/12/2023PT01/07/2022100%31/07/202340%30/11/2023Not provided01/12/2023RO31/03/20220%31/12/20220%31/12/20220%30/06/2023SE15/09/2021100%31/12/2022100%15/03/2022100%31/12/2022SI01/07/2019100%01/10/2021100%01/01/2022Not provided01/01/2022SK06/06/2016100%01/11/2023Not Provided30/06/2019100%Not providedRespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)To be defined by MSTo be defined by MS as part of the national plan31/12/2022 
 
 
 
 
                                                      
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
8. 

Figure 8: Percentage of Completion per Phase – National Import Systems Upgrade 

41 

 
 
 
UCC SPECIAL PROCEDURES – COMPONENT 2 (SP IMP) 

3.3 
This national project aims  to accelerate, facilitate and  harmonise Special Procedures (SP) across the 
Union by means of providing common business process models. The national systems will implement 
all  UCC  changes  required  for  all  the  special  procedures  (customs  warehousing,  end-use,  temporary 
admission  and  inward/outward  processing).  It  should  be  noted  that,  in  many  Member  States,  the 
implementation  of  this  project  occurs  within  the  context  of  the  upgrades  of  the  national  import  and 
export systems. 

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

The implementation of these projects will occur through the projects UCC Automated Export System 
(AES) and UCC National Import Systems upgrade.29 Therefore the information provided for under these 
projects also applies in this context. 

3.1.5 Summary of Responses 

Summary from the Member States: 

The majority of the Member States have assessed the complexity as being medium or high, mentioning 
as the primary cause the many interdependences with the systems at national level. 

The potential causes for delay evoked are the following: the implementation of a new import system 
and/or dependencies with other systems,  the alignment with the new Annex B requirements,  lack of 
resources and procurement delays along with specific working circumstances caused by the COVID-19 
pandemic.  Many  Member  States  have  also  informed  that  an  Agile  development  methodology  was 
adopted in order to reduce the implementation timeframe. 

According to the analysed data the following Member States are envisaging completion of the project 
by the end of 2022: BG, CY, DE, EE, FI, FR, GR, HR, HU, IE, IT, LV, MT, PL and SI. However, due 
latest developments on the side of the NIS implementation, some of these Member States might not have 
met this envisaged milestone. 

Detailed Responses: 

Table 18 provides the individual Member States’ responses to the survey: 

MS 

AT 
BE 

BG 

CY 
CZ 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

Same response as for NIS. 

Low 

BG is planning an update of the National Import System (NSP IMP system being 
a part of it) in accordance to the new Annex B requirements. The IT projects are 
being  implemented  using  the  TOGAF/ADM  and  RUP  methodologies. 
According  to  internal  planing,  a  test  version  of  the  updated  import  system  is 
expected middle of 2023, with an implementation date set for 01/10/2023. 

Med  Same response as for NIS. 
Med  Same response as for NIS. 

5 

6 
6 

29 UCC Special Procedures – Component 2 (NSP IMP) is following the planning for UCC National Import Systems upgrade, 
therefore it is foreseen to be operational by the end of 2022. 

42 

 
 
 
 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

DE 

DK 
EE 

ES 

FI 

4 

6 

4 

6 

Low 

DE explained that this component is implemented in the major release of the 
national  IT-System  ATLAS  (Release  9.1)  being  part  of  the  National  Import 
Systems  upgrade.  The  Economic  Operator  is  allowed  to  carry  out  migration 
from 01/05/2021 until 14/10/2022. 

Low  The system is in operation since 01/07/2021. 

Low 

ES indicated that a risk of delay exists due to system coordination with National 
Import Systems upgrade. An agile approach is being used in order reduce impact 
on the implementation timeframe. 

High  Same response as for NIS. 

Concerning FR, the functionalities will be delivered in iterations. The Special 
Procedures (SP IMP) project is backed by the NIS application, therefore it was 
decided  that  a  first  iteration  to  be  delivered  to  ensure  non-regression  for 
operators and another batch for the rest of the functionalities. 
A medium risk level was associated with the system’s on-time delivery, having 
indicated  Technical  Specifications  and  Conformance  Testing  as  the  most 
impacted milestones.  
It was decided by FR to shift the planning, opening the pilot phase in December 
2022, deploying the complete application at the end of March 2023 and ending 
the transitional period in June 2023. This delay was necessary considering the 
evolving nature of Annex A (application for authorization on declaration) for 
example. 

HR stated that Special Procedures Component 2 (SP IMP) is a national project, 
being developed together with the import customs declaration, following testing 
to be conducted with EOs. 
Delays are envisaged due to many interdependences among systems. 
Messages  and  business  processes  are  defined  and  the  already  established 
functionalities are being developed. All other functionalities will be developed 
by the end of the year. 
According  to  HU  the  necessary  IT  needs  have  been  completed  by  customs. 
Legal and IT barriers have been identified and the necessary measures have been 
put in place to overcome them. In parallel, development work is underway. 
IE explains that considering EOs will be moving to AES and NCTS P5 during 
a similar timeframe there will be pressure on all parties. 

Low  None. 

High 

A delay of 12 month is possible due to complex and lengthy service procurement 
procedures. As mitigating measures LT mentioned that they are carrying open 
discussions with the contractor in order to assess the situation. The most affected 
will  be  Conformance  Testing  (date  being  pushed  to  01/07/2023)  and 
Deployment (with new planned end date set for 01/12/2023). 

FR 

5 

Med 

GR 

HR 

6 

Low 

Low 

Med 

3 

4 

6 

6 

HU 

IE 

IT 

LT 

LU 

LV 

6 

Low 

MT 

4 

Low 

LV stated that as from 03/06/2018 the National Import system has been aligned 
with UCC DI/IA Annex B and EUCDM V2.0.  An elevated risk for delays is 
anticipated  considering  that  in  order  to  implement  updates  according  to  the 
EUCDM latest version and CCI until 01/12/2023, a brand new national import 
system should be developed.  
According  to  MT  the  system  will  be  deployed  with  full  functionality,  being 
integrated with the Central System. 
The  upgraded  National  Import  System  will  be  deployed  around  Q1/Q2  2023 
instead of Q4 2022. 

43 

 
 
 
 
 
 
 
 
 
 
 
MS 

NL 

Complexity 
Rating 
3 

Risk 
Level 
Low  An agile development approach is being used in the system development. 

Additional Comments 

PL 

5 

Med 

PT 

6 

High 

The implementation of the UCC Special Procedures system (Components 1 and 
2) is carried out in stages. The System has been made available only to Customs 
Officers from 01/07/2021 (in terms of monitoring the use of SP by Economic 
Operators). Then, the System was made available voluntarily for interested EOs 
from 29/11/2021 (in terms of submitting the Bill of Discharge and Inventory).  
The  RPS  system  has  been  implemented  for  all  currently  available  business 
functions  and  is  mandatory  for  EOs  starting  28/03/2022.  Moreover,  relevant 
business  functions  concerning  the  special  procedures  were  implemented  into 
national IMP and EXP systems. 
The identified risk for delay is due to the creation of a new IT national system 
RPS,  with  new  functionalities  and  the  integration  with  other  IT  national 
customs. PL expressed that this new system was needed in order to achieve the 
complex business goal. SP depends on system RPS for managing and settlement 
and is integrated with other IT national customs systems, which are currently 
being  expanded.  The  complexity  is  particularly  due  to  the  integration  with 
national  IMP  and  EXP  systems  in  the  field  of  online  transfer  of  data  from 
customs declarations regarding SP to RPS system. 
Additionally  development based  on the  data requirements  in  Annex  B  of  the 
Commission Delegated Regulation (EU) 2015/2446 as amended by Delegated 
Regulation (EU) 2021/234 is in progress. 
The  project  is  delayed  due  to  implementation  of  a  completely  new  National 
Import  System,  with  Conformance  Testing  and  Deployment  being  the  most 
impacted milestones. 
Still  PT  indicated  that  the  situation  will  be  managed  by  providing  Technical 
Specifications, support, assistance and close training to all Traders as soon as 
possible. 
According  to  PT  no  partial  deployment  approach  is  envisaged  given  that  it 
would cause the disruption of the National Import System. 
An  agile  development  approach  will  be  used  to  reduce  implementation 
timeframe.  
The  major  changes  that  were  brought  to  the  2021  national  planning  concern 
conformance testing activities. The tests of integration with the other national 
systems  only  can  be  done  after  those  systems  are  ready  to  connect  with  the 
National Import System. The impact of the delay in the other systems is reflected 
in a delay in NIS. Consequently, the tests with traders have to be extended to 
allow  the  Economic  Operators  to  be  ready  to  implement  their  systems 
accordingly.  
Relating  to  deployment  into  production,  as  the  actual  NIS  is  an  integrated 
system,  since  the  beginning  of  the  project  it  was  decided  that  no  partial 
deployment would be possible in order to avoid any kind of disruption that could 
cause  impact  on  clearance  with  potential  financial  costs  for  Traders  and  for 
customs administration. 
This project is an integrated part of the project UCC National Import Systems 
Upgrade. 
A delay of 9 to 12 months is being envisaged for SP Component 2. 

RO 

SE 

6 

3 

Med  Same response as for NIS. 

Low 

SE  reported  delays  compared  to  the  deadlines  indicated  in  the  UCC.  The 
indicated operational date for SP IMP is 30/06/2023. 
Regarding  Customs  Warehousing  the  system  is  developed,  but  must  be 
upgraded to the new Annex B. Preliminary operational stage is planned for 2024. 
For more detailed information please see as well the dedicated section for NIS. 

44 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

SI 

SK 

6 

4 

High 

High 

Special Procedures are part of the Slovenian upgraded import declaration system 
(SIAIS2), which has been in use since 01/01/2022. SI expressed that a high risk 
of delay was inevitable due to the need to harmonize the import declaration data 
with Annex B IA / DA (H2, H3, H4). 
SK  explained  that  a  high  risk  for  delays  is  identified  due  to  the  required 
alignment with Annex B. Considering the lack of financial and human resources 
these requirements are not reflected at the time being. 

Table 18: Detailed responses from Member States – NSP IMP 

Figure 9 provides the percentage of Member States in each development phase. 

Figure 9: Project Status as per Survey – SP IMP 

45 

 
 
 
 
 
 
3.1.6 Overview of Project Progress 

Table 19 highlights any known divergences in the planning of the SP IMP compared to the dates set in 
the Work Programme. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ 
columns are shown. If there is a difference in these two dates, this implies that a migration period is 
planned. 

Table 19: Comparison of Planned and Actual Dates – NSP IMP 

46 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateATNot Provided80%Not Provided0%Not Provided0%Not ProvidedBE01/11/2021Not Provided01/10/2023Not Provided01/10/2023Not Provided01/10/2023BG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CY30/12/2020100%01/06/20220%03/06/20220%03/10/2022CZ31/03/2023100%30/11/2023100%01/12/2023100%01/12/2023DE09/10/2020Not Provided14/10/202250%06/03/2021100%31/10/2022DK01/06/202125%Not Provided0%Not Provided0%Not providedEE30/09/2020100%30/06/2021100%01/07/2021100%01/07/2021ES01/04/202290%30/06/20240%30/09/202295%30/06/2024FI30/06/2019Not ProvidedNot ProvidedNot Provided31/12/2022100%31/12/2022FR30/06/202280%N/A75%30/09/202280%12/2022GR30/06/2021Not ProvidedNot ProvidedNot Provided31/12/2022Not Provided31/12/2022HR31/12/2021Not Provided31/12/2022100%01/01/2023100%01/01/2023HU31/07/2022100%31/12/2022100%31/12/2022100%31/12/2022IE04/10/2019100%04/10/20210%23/11/20200%05/10/2021IT02/12/2019100%30/06/2021100%01/07/2021100%30/06/2021LT04/05/202380%01/12/20230%01/12/20230%01/12/2023LU22/02/2022Not Provided20/12/2022Not Provided10/01/2023Not Provided10/01/2023LV30/10/2017100%01/06/2018100%03/06/2018100%04/06/2018MT31/03/2022100%Not Provided50%15/11/202250%15/11/2022NL22/06/2021100%31/12/2022100%01/04/2022100%30/06/2023PL16/01/2020Not Provided04/05/2021100%01/07/2021100%28/03/2022PT31/07/2022100%31/07/202340%30/11/20230%01/12/2023RO31/03/20220%31/12/20220%31/12/20220%30/06/2023SE01/06/2022100%30/06/20230%28/02/20230%30/06/2023SI01/07/2019100%01/10/2021100%01/01/2022100%01/01/2022SK01/12/2022100%01/11/2023100%01/12/2023100%Not ProvidedRespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)To be defined by MSTo be defined by MS as part of the national plan31/12/2022 
 
 
 
 
Regarding SP IMP, additional details regarding the specific percentage of completion per milestone can 
be seen in the figure below. 

Figure 10: Percentage of Completion per Phase – NSP IMP 

47 

 
 
 
 
4. 

ONGOING  PROJECTS:  DETAILED  PLANNING  AND  PROGRESS 
INFORMATION 

UCC SPECIAL PROCEDURES – COMPONENT 1 (SP EXP) 

4.1 
4.1.1  Summary of Responses 

Summary from the Member States: 

Member  States  have  indicated  predominantly  a  low,  respectively  medium  risk  level  on  the  on-time 
delivery of the project, while assessing the complexity as being medium.  

The potential causes for delays identified are the following: dependencies with other systems, especially 
AES, lack of resources and procurement delays along with specific working circumstances caused by 
the COVID-19 pandemic, complex and lengthy service procurement procedures. Many Member States 
have also implemented Agile development methodologies to reduce the implementation timeframe. 

All Member States that have provided updated information have indicated that the system development 
is  following  the  new  data  requirements  in  Annex  B  of  the  Commission  Delegated  Regulation  (EU) 
2015/2446 as amended by Delegated Regulation (EU) 2021/234. 

According to the data analysed the following Member States have marked the project as complete: DE, 
ES, HR, HU, NL and PL.  

SE has reported progress on their technical specifications reached only 25% and the planned date of 
operations has shifted to end 2024. LV indicated that technical specifications are not applicable for them 
considering that AES will not have External Domain Application Programming Interface (API). 

In  terms  of  assessing  the level  of  completeness  of the  system,  approximatively  three  quarters  of the 
Member States that have provided updated information reported that the system is on target. FI indicated 
that currently the development of the system is being delayed beyond the Deployment deadline, while 
CZ, GR, LT and SK mentioned that the overall Deployment is still planned to meet the deadline. 

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

CY 

4 

6 

Low 

Low 

CZ 

6 

Med 

At  the  moment  the  Elaboration  Phase  is  underway.  By  the  end  of  2022  it  is 
expected a full completion of the Elaboration and the Construction Phase. 
According  to  CY,  the  analysis,  the  preparation  of  specifications,  the 
implementation and a part of the conformance testing of the system will take 
place  in  2022.  The  public  procurement  process  has  been  concluded  and  the 
contract has been signed with the contractor. The project initiation document 
has been agreed and the relevant project plans and timelines for all the UCC 
systems have been updated and agreed.   
The Czech Republic will use the “big bang” method for the SP EXP. According 
to the National Project Plan of CZ a test environment will be ready in July 2022. 
Since  that  date  CZ  will  be  able  to  start  testing  of  commercial  software  and 
Conformance Testing will begin (Mode 1 being scheduled June-September 2022 
and Mode 2, October 2022 - February 2023). 
A  partial  deployment  approach  with  limited  functionality  is  not  envisaged, 
operations will start in AES on 03/04/2023 an the transitional period for traders 
will not be used.  
Issues on the developer's side have been indentified, however it is assumed that 
the  delay  will  not  have  a  major  impact  and  that  the  development  will  be 

48 

 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

completed at the end of September 2022. If the development will be delayed, 
there is a risk that the internal methodology will not be prepared in time. In this 
light,  CZ  has  meetings  with  the  contractor  on  a  weekly  basis,  where  they 
evaluate progress in development. 
The UCC Special Procedures EXP is developed together with the national AES 
Component 1 (which corresponds to the national ATLAS Release AES 3.0.1). 
The  acceptance  test  AES  3.0.1  started  on  18/01/2021  and  was  carried  out 
without interruption until 05/03/2021. 
DE is making use of an agile development approach in defined software release-
cycles. The ongoing activities concern the finalisation and fine-tuning of AES 
(e.g.  adaptation  of  Surveillance),  the  monitoring  of  operations  as  well  as  the 
preparation  of  remaining  Conformance  Tests  for  new  functionalities  of  AES 
(e.g. centralised clearance) and the start of the Conformance Test (certification) 
of Economic Operators. 
The end-date of the transition window for trader has been shifted from end 2022 
to June 2023 to allow maximum flexibility to migrate from ECS-P2 to AES. 

DE 

4 

Low 

DK 
EE 
ES 

FI 

5 
4 

6 

Med  None. 
Low  None. 

High 

FR 

5 

Med 

6 

3 
3 

6 

3 

4 

GR 

HR 
HU 

IE 

IT 

LT 

LU 

FI expressed that Special Procedures EXP is being developed together with the 
national AES Component 1.  
AES will be built from scratch which will cause a significant impact on the on-
time  delivery  of  the project,  given  its  many  integrations  with  several  parallel 
projects. At the same time, AES will be put on hold and an updated NPP will be 
presented due to prioritization of NCTS. To this it can be added COVID-19 and 
shortage of resources especially on suppliers side. 
FR expressed that an iterative approach will be used for the system development. 
One delivery (80% of SP EXP) will be made with the AES delivery (October 
2023)  and  the  other  features  will  be  delivered  in  a  later  batch  with  another 
version (during 2024). 
A medium level of risk was associated with the on-time delivery of the project, 
having  an  imminent  impact  on  Technical  Specifications  and  Conformance 
Testing. 
One major cause of delay in deployment with impact on Conformance Testing 
and  Deployment  indicated  by  GR  is  the  actual  delay  in  call  for  tender 
procedures. GR stated that internal discussions are ongoing in order to assess 
the situation. 

High 

Low  HR stated that Special Procedures EXP is being developed together with AES. 
Low  Same response as for Special Procedures – Component 2 (NSP IMP). 

Med 

Low 

Med 

IE explained that the testing of AES and the Transition Handler will be complex 
and  could  present  some  challenges  due  to  the  new  concept.  Internal  system 
testing started end of April 2022 with Conformance Testing starting 13/06/2022. 
Italy  stated  that  SP  EXP  is  being  developed  together  with  the  national  AES 
Component 1 and that National Conformance Testing will be performed. 
Thus, the deployment date of this project has been updated compliant to the new 
deployment  date  of  AES  Component  1.  Therefore,  the  deployment  date  of 
National SP EXP has been slipped from 20/02/2023 to 08/05/2023. 
According to LT, the deployment deadline as set in the current version of their 
NPP is 01/09/2023. Complex and lengthy service procurement procedures will 
have  an  impact  on  Conformance  Testing  and  Deployment.  In  this  light, 
mitigating measures are to be assessed with the contractor. 

49 

 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

LV 

MT 

NL 

PL 

PT 

RO 
SE 

SI 

4 

4 

3 

5 

6 

4 

4 

Med 

LV expressed that SP EXP is being developed together with the national AES 
Component  1.  Considering  that  AES  will  not  have  External  Domain  API, 
Technical  Specifications  for  Trade  will  not  be  needed,  therefore  will  not  be 
delivered. At the same time LV expressed concern related to possible delay for  
Deployment.  In  order  to  mitigate  this  hypotesis,  AES  will  be  deployed  with 
limited capability, therefore an iterative approach is being used for the system 
development. 

Low  Same response as for Special Procedures – Component 2 (NSP IMP). 

Low 

At the time of writing, NL is developing and testing the system with the supplier. 
An agile development approach is envisaged. 

Med  Same response as for Special Procedures – Component 2 (NSP IMP). 

High 

PT is developing the SP EXP system as an integrated part of the UCC Trans-
European Automated Export System (AES). Considering this, a high risk will 
be  associated  with  the  on-time  delivery  of  the  project,  due  to  a  brand  new 
implementation of the National AES System. 
PT  indicated  that  related  to  further  activities,  Conformance  Testing  will  be 
organised as Mode 1, 2 and 3 and that an agile development approach will be 
used to reduce implementation timeframe. 

Low  SE indicated that the operational date will be Q4/2024. 

Low 

The  first  version  of  SIAES2  (Slovenian  Automated  Export  System  -  2nd 
generation) was successfully installed in the test environment on February 23rd, 
2022. 
Technical  documentation  is  finalised  and  the  development  of  the  new  export 
application is under completion stage. 
SI has performed National Domain Testing, Mode 0 and Mode 1, both finalised 
on  03/05/2022,  with  the  deadline  for  launching  AES-P1  maintained  for 
01/05/2023. 
According  to  SK  activities  schedule  procurement  on  technical  analysis  is 
completed, having Conformance Testing planned for Q2/2023. At the time of 
writing, the project is delayed due to lack of financial and human resources 

SK 

3 

High 

Table 20: Detailed responses from Member States – SP EXP 

50 

 
 
 
 
 
 
 
Figure 11 provides the percentage of Member States in each development phase. 

Figure 11: Project Status as per Survey – NSP EXP 

4.1.2 Overview of Project Progress 

Table 21 highlights any known divergences in the planning of the SP EXP compared to the dates set in 
the Work Programme.  This project has a deployment window from 01/03/2021 till 01/12/2023. The 
‘Deployment’ and ‘Operations’ columns are shown as well. If there is a difference in the dates of these 
columns, this implies that a migration period is planned.  

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

51 

 
 
 
 
 
 
Additional  details  regarding  the  specific  percentage  of  completion  per  milestone  can  be  seen  in  the 
following figure.  

Figure 12: Percentage of Completion per Phase – SP EXP 

52 

 
 
 
UCC GUARANTEE MANAGEMENT (GUM) 

4.2 
The UCC Guarantee Management (GUM) project aims to assure the effective and efficient management 
of the different types of guarantees. The main objective is to ensure that the data of guarantees, which 
are used in more than one MS, are made electronically accessible to the MS where a customs declaration 
is lodged and accepted when such guarantee is used. This will require new interfaces between GUM and 
national systems. One advantage of the solution is that the traders can provide one guarantee that can be 
used  across  the  Union.  Moreover,  the  improved  processing  speed,  traceability  and  monitoring  of 
guarantees electronically between customs offices is expected to lead to a faster identification of cases 
where guarantees are deemed invalid or insufficient to cover the incurred or potential debt. 

The system is comprised of two components. The first component is "GUM". GUM is a trans-European 
system that will cover the management of the comprehensive guarantees that may be used in more than 
one Member State. Transit guarantees monitoring is an exception to the above and is handled as part of 
the NCTS project. The second component of the system is "National Guarantee Management". This will 
manage the upgrade for the electronic systems existing at national level to manage the guarantees valid 
in one Member State. 

4.1.3  Summary of Responses 

GUM – Component 1 

Summary from the Commission: 

The decentralised system with light central IT support will be implemented through the UCC Customs 
Decisions system. The central GUM component is expected to be operational in the second quarter of 
2025, as legally required. 

On the basis of the systems architectural change, the hybrid-Member States, using the UCC Customs 
Decisions system, should be ready and test their systems before the central GUM component goes live. 
Member States with hybrid solutions are expected to start operations in the first quarter of 2024. This 
creates a window of one year to develop their system after the component specifications of the GUM 
central system are made available. 

The  UCC  GUM  Application,  Service  and  Technical  Systems  Specifications  for  the  UCC  Customs 
Decisions system, the Trader Portal & the Customs Reference Service was approved in Q3 2022. 

Even though Implementation Support is not scheduled to start until Q4 2023, a GUM Business User 
Guide has been created and will be submitted for review to the Member States in the first half of 2023.   

An initial draft of the Annex A data elements needed for GUM was finalised in the first half of 2022. 
Extensive review of the draft Annex A is in progress.  

The Commission presented the plannning as well as the new requirements under the UCC to the Member 
States in several meetings.  

The planning will need to be carefully examined and adjusted in the coming years by the Commission 
and the Member States to keep this project on track. In this light, the GUM project team coordinated the 
collection of a list of MSs’ appointed National Project Managers for the UCC GUM project, and updated 
the UCC Projects NPM Master list with the confirmed appointees. 

National GUM – Component 2 

Summary from the Member States:  

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

53 

 
 
 
BG, IE and ES implemented national GUM systems. The guarantee management systems for LV and 
PL have also been implemented in their National Import systems. EE, FI, LV and SE have indicated that 
technical specifications will not be applicable in their case given that there is no interface in the external 
domain  to  the  trader.  All  of  the  other  Member  States  interrogated  have  reported  that  the  activities 
associated with the technical specifications stage are not yet initiated.   

Member States have indicated predominantly a low risk level on the on-time delivery of the project, 
while assessing the complexity as being medium/low.  

The potential causes  evoked  for delay are the following:  complex functionalities and interfaces with 
other customs systems, lack of transparency and information on the change in concepts with regards to 
GUM,  lack of human and financial resources and  delays in budget allocation. Many Member States 
updated their planning and while most of them are still in line with the dates specified in the Work 
Programme, there are some Member States which are reporting delays in operations30. 

Detailed Responses: 

Table 22 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

MS 

AT 
BE 

BG 

4 

Low 

CY 

CZ 

DE 

DK 

EE 

ES 

6 

2 

4 

5 

4 

1 

Low 

Low 

Low 

Med 

Med 

Low 

Additional Comments 

According to BG, GUM Component 2 is part of the import system, therefore 
will be updated at that time. BG indicated that during the conformance testing 
activities of GUM Component 2 connectivity with National Import Customs 
System and National Accounting System was also tested.  
For Component 1, BG is anticipating to start work in summer 2022 to meet the 
deadline, having the June 2025 deadline included in the tender.  
BG  is  implementing  IT  projects  using  the  TOGAF/ADM  and  RUP 
methodologies. 
For  GUM  Component  2,  the  national  part  CY  intends  to  be  operational  by 
02/06/2025. Component 1 is centralised. 
CZ  mentioned  that  no  technical  specifications  are  available,  therefore  no 
development is planned for the moment, having provided indicative dates at 
this  stage:  technical  specifications  on  01/01/2024,  conformance  testing 
starting in January 2025 and deployment on 01/06/2025. 
According to DE this project will be implemented in the major release of the 
national IT-System ATLAS (Release 10.3) for which the preparatory activities 
have not yet started. 
As regards current planning of DE, Conformance Testing activities are not yet 
initiated nor planned, with no determined Deployment approach. 
The  project  is  currently  undergoing  planning  regarding  all  Conformance 
Testing and Deployment related activities.  
EE indicated that the original start of the project was planned for 2021, but the 
intial plan could not be reached due to lack of financial resources. 
Depending on the situation with funding, EE has the intention to implement 
the national component in the first half of 2023. 
An iterative approach is envisaged for the system development. 
For GUM, ES advised that they had implemented their national part in May 
2019  and  will  be  able  to  meet  the  planning  for  Component  1.  System  is 
currently in production. 

30 FI and FR reported in their NPP possible delays regarding operations deadline, due to complex integrations required for the 
system. 

54 

 
 
 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

FI 

5 

Med 

FR 

GR 

3 

Low 

HR 

5 

Med 

5 

3 

6 

6 

Med 

Low 

Low 

Low 

HU 

IE 

IT 

LT 

LU 

LV 

5 

Low 

MT 

5 

Low 

NL 

3 

Low 

For GUM, a new system is being developed and will be integrated with NCTS 
first and then with the national import system. At the moment FI does not have 
detailed plans for the connection to CRS for multi-MS guarantees. 
FI  explained  that  given  that  there  is  no  interface  to  customers  from  GUM 
Technical Specifications will not be needed. A medium level of risk on the on-
time  delivery  of  the  project  is  indicated,  considering  the  many  integrations 
required for GUM.  

GR mentioned that regarding GUM Component 2, the activities related to all 
milestones  are  not  yet  initiated,  given  the  delay  to  start  the  call  for  tender 
procedure was identified. 
HR indicated that they have not yet nominated a project team for the GUM 
national component. An analysis of available documentation and of the current 
implementation of the guarantee system is underway   
Overlapping activities on other projects and limited budget are being identified 
as possible primary causes for delays on the on-time delivery of the project. 
At the time of writing, HR is in the analysis phase regarding the approach to 
development. 
In relation to GUM, HU has already implemented a national system, while also 
having the NCTS guarantee system. Currently it is uncertain which system will 
handle the new requirements, therefore this work has not been planned yet. 
There is already a national system for national guarantees, therefore IE are not 
actively looking at the planning of this work yet as it comes later in the overall 
UCC IT planning. They also need more clarity on what they will have to do 
regarding the connection to the central system in due course. 
At  the  moment  no  strategy  has  been  defined  for  the  system  development, 
however  within  further  activities  IT  has  mentioned  the  concretisation  of 
Technical Specifications. It is envisaged the completion of both components 
within  the  deadlines  provided  with  the  national  component  updated  for  Q4 
2024. 
For the GUM project, all functionalities required for the national Component 
2 have been developed and are being tested, with a view to go in production in 
September 2022. 
Regarding  GUM,  LU  stated  that  as  Component  1  would  be  largely 
implemented in CDS, the development is progressing according to planning 
and it has been included in the tender and the indicative deployment date of 
01/10/2024. 
For GUM a new system for all revenues and payments and not just for customs 
is being developed by LV. Currently they are focusing to be on-time with the 
national import system for the trans-European aspect. LV has already updated 
nationally in conjunction with their existing import system. 
According  to  MT  difficulties  were  encountered  related  to  identifying  the 
necessary  information/documentation  for  this  project.  At  the  same  time 
regarding the planned deployment strategy, the system will be deployed with 
full functionality. At the current stage MT has not identified any issues related 
to the timely development of the system. 
NL explained that for GUM Component 2 there is no Conformance Testing 
campaign foreseen, having only the national component without S2S (server-
to-server) connection with TAXUD or other MSs.  
Q2 2022 marked the start for the development of the system, using  both an 
iterative and agile approach. In 2022 the updated Annex A will be approved, 
having  the  updated  data  elements  and  data  structure  as  input  for  the  UCC 

55 

 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

PL 

4 

Low 

PT 

6 

High 

Low 

RO 

SE 

SI 

SK 

1 

4 

1 

guarantees  that  will  need  to  be  registered,  managed  and  monitored  in  the 
national GMS (DZA). 
The complexity for GUM will depend on the BPM’s, updated Annex A, data 
structure and all the answers to the open issues in the PG CDS-GUM. 
NL will build  the  new Guarantee Management System (DZA) for all UCC, 
Excise and other types of guarantees. DZA will replace the current GMS (KIS 
and GMS for NCTS).  
PL indicated that they already have their national system implemented. The 
system will need to be updated once the common specifications for the trans-
European aspects are published, however PL does not envisage any risks of 
delay. 
According to PT all Conformance Testing activities will be organised as Mode 
1,  2  and  3.  An  imminent  risk  for  the  on-time  delivery  of  the  project  was 
identified due to the need of the implementation of a completely new National 
GUM System. An agile development approach will be used in order to reduce 
the implementation timeframe. 
RO expressed that under the national import system contract RO will update 
the existing national guarantee system and then connect to the Central System. 
Concerning GUM, the national system was already deployed in April 2021. 
Currently SE are analysing the needs for Component 1 to meet a March 2024 
deployment date. 
It  was  indicated  that  Technical  Specifications  and  Conformance  Testing 
activities in the external domain to the trader are not applicable.  

Low  None. 

High 

SK advised that GUM is also linked to the entry/import system contract. SK 
stated that due to lack of financial and human resources the project is marked 
as delayed, however overall delivery is still foreseen within the Deployment 
deadline.  Technical  Specifications,  Conformance  Testing  and  Deployment 
activities are expected to be impacted. 

Table 22: Detailed responses from Member States – GUM – Component 2 

56 

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

Figure 13: Summary of Survey Responses – GUM – Component 2 

4.1.4 Overview of Project Progress 

Table 23 and Table 24 highlight any known divergences in the planning compared to the dates set in the 
Work Programme.  

Table 23: Comparison of Planned and Actual Dates – GUM – Component 1 

57 

Target date from WPActual/Planned End Date2022 % of CompletionActual/Planned End Date2022 % of Completion Target date from WPActual/Planned Date2022 % of Completion 30/09/202201/08/2022100%29/05/20250%02/06/202505/09/20230%Technical SpecificationsConformance TestingDeployment 
 
 
 
 
 
 
As GUM – Component 2 has a deployment window, the ‘Deployment’ and ‘Operations’ columns are 
shown. If there is a difference in these two dates, this implies that a migration period is planned. The 
table below shows that the progress on the side of the technical specifications is going slow. In addition, 
there is also quite some missing information. Therefore, it is difficult to make assumptions on the timely 
delivery at this early stage.  

In regards to the implementation, the following Member States have indicated a planned operations date 
that is slightly later than the deadline in the UCC Work Programme: FI and FR. 

Table 24: Comparison of Planned and Actual Dates – GUM – Component 2 

58 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateATN/ANot Provided31/12/2024Not Provided01/03/2025Not Provided01/03/2025BENot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedBG28/02/2018100%01/12/2018100%07/01/2019100%07/01/2019CYN/AN/AN/AN/A02/06/20250%02/06/2025CZ01/01/20240%31/05/2025Not Provided01/06/2025Not provided01/06/2025DENot provided0%Not Provided0%Not Provided0%Not ProvidedDKNot provided5%Not Provided0%Not provided0%Not providedEEN/AN/AN/AN/A30/09/20230%30/09/2023ES30/06/2016100%31/08/2016Not Provided01/09/2016100%01/05/2019FINot ProvidedNot ProvidedNot Provided0%30/06/202580%30/06/2025FRNot Provided80%Not Provided0%Not Provided0%30/06/2025GR31/12/20240%Not Provided0%31/03/20250%31/03/2025HR31/12/20220%N/A0%Not Provided0%To be definedHU30/11/20240%01/05/20250%01/06/20250%01/06/2025IE04/10/2019100%04/10/2021Not Provided23/11/2020Not provided05/10/2021IT15/09/201915%15/12/20200%15/12/20200%15/12/2020LT01/11/2021100%31/08/2022100%08/11/2022100%10/10/2022LUNot ProvidedNot ProvidedNot ProvidedNot Provided01/06/2025Not Provided01/06/2025LVN/AN/AN/ANot Provided03/06/2020100%04/06/2018MT30/06/20230%30/04/20240%01/05/20240%01/05/2024NLNot provided0%N/AN/ANot provided0%01/06/2025PL01/06/2015100%Not ProvidedNot Provided15/07/2015Not ProvidedNot ProvidedPTNot provided100%31/07/20230%30/11/20230%01/12/2023RO30/06/2024Not Provided31/03/2025Not Provided06/01//2025Not ProvidedNot ProvidedSEN/AN/ANot ProvidedNot Provided17/04/2021Not Provided17/04/2021SI31/12/20220%20/05/20250%01/06/20250%01/06/2025SK01/09/20230%01/05/20250%01/06/20250%Not ProvidedRespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)To be defined by MSTo be defined by MS as part of the national plan02/06/2025 
 
 
 
 
Regarding  National  GUM  -  Component  2,  additional  details  regarding  the  specific  percentage  of 
completion per milestone can be seen in the following figure.  

Figure 14: Percentage of Completion per Phase – GUM – Component 2 

59 

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

4.3 
4.1.5  Summary of Responses 

ICS2 – Release 2 

Summary from the Commission: 

ICS2  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. From this release onwards, and 
following a positive policy decision of the Commission and Member States in December 2020, the ICS2 
system will implement a Safety and Security Analytics capability. As part of Release 2, the Safety and 
Security Analytics capability will be integrated within the ICS2 common repository component and will 
implement the analytics platform accessible by MSs via CCN2 (and the Commission via UUM&DS) 
integrated  by  a  dedicated portal and a  data  factory  for  real  time  analytics  (enrichment  of  ENS  data) 
connected to a common repository.  

In  addition  to  the  ICS2  Safety  and  Security  Analytics  capabilities  project,  Release  2  poses  new 
challenges compared to Release 1, such as the addition of three new types of economic operators acting 
in the air transportation supply chains and thirteen different types of ENS filings, to bring into the system 
more and better quality trade data of goods moving towards the EU. Release 2 includes new business 
models  reflecting  the  business  needs,  rules  and  user  interfaces,  adding  an  increasing  complexity  of 
timers,  data  quality,  data  consistency  rules  and  linking  for  multiple  filings  and  arrival  notifications. 
Furthermore,  a  larger  volume  of  messages  and  complex  conformance  testing,  with  numerous 
stakeholders is expected. Lastly, the migration strategy between Release 1 and 2 will be  challenging 
with different transition windows. DG TAXUD has initiated coordination meetings to ensure the smooth 
development of the system. 

The work on the Operational guidance compendium for Release 2 has been completed as of Q1 2022. 
This work was supported by the ICS2 Project group with participants from Member States and trade 
representatives.  At  the  same  time,  the  Business  continuity  plan  was  updated  to  cover  Release  2 
operations.  

The development of the central components Common Repository, Share Trader Interface, Share Trader 
Portal was scheduled to be finished by the 1st of July 2022. The conformance environment was ready 
for Member States testing as of 1st July and for economic operators testing on 1st of September 2022. 

The  Common  Technical  System  Specification  (CTSS)  was  aligned  with  the  latest  version  of  the 
Functional System Specification. Two major CTSS version were produced: one in October 2021 and 
one in March 2022. The March 2022 version includes the specifications applicable for Release 3, in 
addition to the specifications related to Release 1 and Release 2 business process. 

A new version CTSS was published in September 2022. This version will integrate last changes raised 
by  business  for  Release  2  and  3  processes  as  well  as  additional  business  processes  necessary  for 
integration of the Common Repository and Safety and Security Analytics. 

The End-to-End organisation document was published for MS and EOs on 21 April 2022, having as 
further steps the elaboration of End-to-End scenarios. 

The planning of training, aimed to prepare Customs Administrations for the ICS2 Conformance Testing 
was finalised, with training campaigns taking place between May - June 2022.31  

ICS2 Release 2 Conformance Testing is planned to start in Q3 2022. By the end of 2022 it is expected 
that all NA will have started CT testing and that the majority will have finalised it. It is also expected 
that some EO start the CT testing as well. The EO Deployment windows ends by 1st October 2023. 

31 The first eLearning training module related to business process for National Administrations has been finalized end of June 
2022. An additional training module, Risk Management processes for ICS2 Release 2, has been included in the training strategy 
for Release 2 and agreed to be delivered in Q1 2023. 

60 

 
 
                                                      
By the end of 2022, Transitions strategy and Production checklist will be produced. Those will be used 
in February/March 2023 to start production of Release 2. 

Summary from the Member States: 

Member States are preparing the national functional and technical specifications based on the common 
EU specifications provided by DG TAXUD, participating in webinars and reviewing documentation. 
The Member States have indicated an increase in complexity compared with Release 1, citing the same 
potential  causes  of  delay  as  stated  before  for  ICS2  –  Release  1:  the  tight  timelines  between  related 
projects,  a  complex  data  migration,  resource  constraints,  impact  and  re-planning  due  to  the  VAT 
eCommerce  package    and  the  specific  working  circumstances  caused  by  the  COVID-19  pandemic, 
complex and lengthy service procurement procedures, and the numerous external stakeholders involved. 
A medium, respectively high-risk level on the on-time delivery of the project has been identified, while 
the complexity has been assessed as medium/high.  

Most of the Member States are progressing well. 

EE and CZ have reported delays in delivering the technical specifications due to the complexity and 
capacity of the IT contractor or the COVID-19 related financial challenges. At the same time, FI and SE 
will use the Central System, therefore will not develop technical specifications for the external domain. 

PT indicated that several modes of Conformance Testing will be executed while maintaining a high risk 
for the timely delivery of the system due to implementation of a completely new National ICS2 System. 

The other Member States that also reported to envisage timely implementation by 1/03/2023 are: BE, 
BG, CY, CZ, DE, ES, FI, HR, HU, IE, IT, LT, LU, LV, MT, PL, PT, SE, SI and SK (see table 27 below 
and adjusted to the latest developments).  

Important remark: 

Further to the planning and progress data collected from Member States and Commission services during 
Q1  and  Q2  2022,  new  information  has  been  communicated  to  the  Commission  which  has  not  been 
represented  in  this  accompanying  staff  working  as  it  was  not  part  of  the  methodological  approach 
established for this document. The key information will be taken on board and reflected in the main 
Report itself.  

Member States32 have submitted a written notification asking for derogation under Article 6(4) UCC to 
DG  TAXUD  considering  the  delay  for  ICS2  Release  2  beyond  the  legal  deadline.  The  derogation 
requests from the Member States were assessed by the Commission services in terms of the justifications 
provided by the specific situation of the Member States requesting it and in view of a set of common 
assessment criteria.  

In this light the Commission has proposed an Implementing Decision33 granting a derogation to Austria, 
Denmark, Estonia, France, Greece, Netherland and Romania for the Import Control System 2 to use 
means for the exchange and storage of information other than electronic data-processing techniques in 
relation to goods transported by air. The derogation is proposed to apply from 1 March 2023 until 30 
June 2023. 

Detailed Responses: 

Table 25 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

32 Member States that have indicated delays in implementation of ICS2 Release 2 beyond the deadline of 1/03/2023: AT, DK, 
EE, FR, GR, NL and RO. 
33 This reflects the state of play at the moment of the finalisation of the Report on 11 November 2022. 

61 

 
 
 
 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

BG 

5 

Low 

In  conjunction  with  the  development  of  the  national  components  of  ICS2 
Release  2,  BG  appreciates  as  necessary  the  upgrade  of  the  National  Import 
System and the National Risk Analysis System. 
Regarding the ICS2 Release 2 national components development, the Bulgarian 
customs administration uses agile and an iterative approach, combined with an 
adapted  and  combined  implementation  of  two  methodological  frameworks. 
ADM and RUP, each with its specific purpose. ADM aims implementation and 
maintenance of the overall BCA Architecture, while RUP is used to manage the 
software lifecycle of the software solution. According to RUP, ICS2 Release 2 
is expected to be in the middle of the Transition phase by the end of 2022. 
At  the  same  time,  it  was  indicated  that  the  implementation  of  Release  2  is 
expected to be deployed in time for the 01/03/2023 deadline, with Release 3 
following a similar trend. At the time of writing the tender procedure is ongoing 
for Release 3.  

Low  For Release 2, CY confirmed that they will be operational by 01/03/2023. 

CY 

CZ 

6 

6 

Med 

DE 

4 

Low 

DK 

5 

Med 

EE 

5 

High 

ES 

6 

Med 

FI 

6 

High 

CZ  appreciated  that  milestones  might  be  delayed  due  to  complexity  and  the 
capacity of the IT contractor. However, overall delivery is still foreseen within 
the  Deployment  deadline.  At  the  same  time,  the  deadline  of  publication  of 
Technical Specifications will be postponed.  
CZ  indicated  that  Release  2  technical  specifications  will  be  available  on 
30/06/2022,  with  Conformance  Testing  starting  in  December  2022  and 
deployment on time for 01/03/2023. 
According  to  DE  Release  2  will  be  implemented  as  part  of  the  national  IT-
System ATLAS (Release 10.1). All Milestones related to Economic Operators 
will be published by EU-COM and the Technical Specifications for the external 
commonication via STI-ICS2 will also be provided by EU-COM. Conformance 
Testing  between  Economic  Operator  and  EU-COM  will  be  scheduled 
individually  in  coordinaton  with  the  concerned  Member  State.  The  national 
elaboration Phase as well as the construction have started. 
DE  emphasized  the  increased  difficulty  in  identifying  all  of  the  relevant 
stakeholders affected by Release 2, a phenomenon easily observed when trying 
to have all traders compliant on the first day. 
DK  appreciates  that  a  need  to  clarify  the  business  value  chains  should  be 
prioritised at EU level, before technical development and testing begin.  
The  identified  cause  for  delay  by  DK  is  referring  to  the  complexity  level 
associated  with  the  system  development.  Technical  specifications  and 
refinement is ongoing, as is onboarding of Economic Operators and preparation 
for Conformance Testing. 
Due  to  COVID-19  related  financial  challenges,  the  ICS2  Release  2  project 
deadline had to be postponed, with a new deadline being set for 01/10/2023. All 
milestones are expected to be impacted by the change. At the same time, the 
Estonian Tax and the Customs Board have raised the question of financing with 
high priority in all relevant instances.  
ES mentioned that due to the complexity of specifications not fully detailed at 
the  beginning  of  the  project  and  the  complexity  of  functionalities  and 
Conformance  Testing  activities,  an  agile  approach  is  being  used  in  order  to 
minimise the impact on the delivery of the system. At the same time, the Release 
2 deployment date of 01/03/2023 was confirmed, however ES expressed some 
concerns about the readiness of the traders. 
Regarding  ICS2  Release  2  and  3  no  changes  to  the  timing  are  envisaged.  FI 
indicated that there will be some problems in relation to the readiness of traders. 
The work on Release 3 has not started yet as they are focused on Release 2. 

62 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

FR 

4 

Med 

GR 

HR 

HU 

6 

3 

High 

Med 

IE 

5 

Med 

5 

6 

Low 

Low 

IT 

LT 

LU 

LV 

6 

High 

MT 

6 

Med 

NL 

5 

High 

For  Release  2,  FR  indicated  a  delay  of  3  months  given  the  difficulties 
encountered in operation of Release 1 (e.g. in May 2021 20% of messages were 
lost, which led to delay in work on R2, utlimately affecting the CT planning, in 
particular  Mode  2.).  At  the  same  time,  changes  are  required  regarding 
interactions with postal services.  
For  ICS2  –  Release  2  GR  indicated  that  a  different  contractor  will  be  used, 
which could lead to possible issues for Release 2. The deployment deadline is 
still envisaged for 01/03/2023. 
It was confirmed by the HR colleagues that they are on track for the Release 2 
date of 01/03/2023. This will include AN for air mode of transport and the AN 
for maritime will come with Release 3 on 01/03/2024.  
At the time of writing a national component for economic operators is being 
created, following stricter and progressive plans. 
HU  expects  to  be  on  time  with  Release  2  for  01/03/2023,  however  they  are 
concerned about all traders being ready. 
The complexity of the system is considered to be high given the requirement to 
engage with Trade and their collective collaboration.  
A new format for messages is expected and the collaboration between economic 
operators and delivery of this is close to AES and NCTS Phase 5. 
For AN, it was mentioned that arrival information is already obtained for the 
airport  and  maritime  authorities  on  all  flights  and  ships  so  specific  arrival 
notification messages are not needed. IE is currently examining how this will 
integrate with the Shared Trader Interface for ICS2. 
Release 2 will be deployed on time, having shared specifications with traders 
with further engagement envisaged, however there are concerns about the trader 
readiness. IT stated that an iterative approach with continuous feedback is being 
used for the system development. 
LT  envisages  a  timely  deployment  by  March  2023  for  ICS2  Release  2.  The 
system will be developed using an agile approach. Some delay regarding the 
final Technical Specifications publication date is expected.  
The planning for ICS2 Release 2 follows the WP schedule.  
For  Release  2,  LV  is  planning  to  meet  the  original  deadline  of  01/03/2023, 
however  their  contractor  will  provide  software  only  in  mid-January  2023, 
therefore it will depend on the quality and readiness of Conformance Testing 
activities.  
At the same time, LV mentioned that an iterative approach is being used in the 
system development. 
DK  indicated  that  numerous  activities  concerning  various  systems  are 
happening all in the same period, which ultimately is causing the delay of the 
system  and  impacts  Conformance  Testing  activities.  At  the  same  time  MT 
mentioned  that  overall  the  delivery  is  still  foreseen  within  the  Deployment 
deadline. 
According  to  NL,  the  ICS2  –  Release  2  will  be  developed  using  an  agile 
approach,  with the  initiation  of  activities  yet  to  be  decided  considering  other 
priorities. This approach starts with describing a high level design of the features 
and of the IT-solution, in the so called “Epic” format. 
NL  has  associated  to  this  project  a  high  risk  on  the  on-time  delivery  of  the 
project given the intricacies of this project. To this it can be added  Brexit, e-
commerce, the labour market and the COVID-19 pandemic.  
At  the  same  time,  NL  has  indicated  that  in  order  to  reduce  the  impact  on 
milestones, the minimisation of the scope is under consideration. 

63 

 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

NL explained that the complexity of the project has increased considering that 
a  lot  of  external  stakeholders  (carriers,  freightforwarders  and  their  software 
providers) and internal stakeholders (e.g. policy makers, risk analists, control 
officers, etc) are being involved. In this light, between all of the parties has to 
to  be  maintained  a  strong  communication  in  order  to  be  able  to  define  the 
national requirements. 
Another  complexity  factor  reffers  to  NL’s  National  Entry  System  which  is 
composed  of  several  components  that  are  being  developed  by  10  internal 
development  teams,  with    most  of  them  not  been  dedicated  ICS2  teams.  NL 
emphasized that within the organisation, the priorities of these teams have to be 
aligned, together with the definition of their workpackages. On the same note, 
NL mentioned the context of MASP and the fact that a lot of projects are running 
in parallel, making use of the same development expertise. 
At  the  time  of  writing,  all  milestones  (Construction  phase,  Comformance 
Testing and Deployment) are expected to be delayed, with the deadline being 
pushed to Q4 2023. 
For  ICS2  Release 2,  PL  plans  deployment  on  01/03/2023. They  are  on  track 
with the development and testing.  
PT indicated that due to the implementation of a completely new National ICS2 
System  the  on-time  delivery  of  the  project  could  be  at  risk,  however  the 
deployment  is  still  foreseen  for  March  2023,  with  minor  concerns  regarding 
traders  readiness.  In  this  light,  an  agile  development  method  will  be  used  to 
reduce implementation timeframe.  
Same response as for AN. 
SE identified a risk pertaining to the economic operators, underlining that it is 
challenging to reach out an contact all the concerned parties. During 2022 parts 
of ICS2 will be ready and deployed, but will not be exposed to web service until 
start of Conformance Testing in January 2023.  
SE confirmed that for ICS2 Release 2 they are on track to deploy the system on 
01/03/2023,  with  migration  for  traders  until  01/10/2023.  However,  SE 
expressed some concern about the readiness of traders. On the same note, SE 
indicated that for Release 3 all milestones are on track. 
SI  explained  that  the  complexity  is  caused  by  relatively  new  processes  and 
functionalities,  sequences  of  electronic  messages,  R&C  and  the  practical 
identification of persons who will declare the data. 
At  the  same  time  an  increased  workload  of  external  contractors  with  other 
MASP  projects  (eg.  transit,  export  etc.)  are  increasing  the  complexity  of  the 
development of the system. 
However, Release 2 is planned to be deployed in the expected deadline. 
Communication  has  been  initiated  between  Financial  Directorate  and  the 
potential provider of the system regarding the development approach. Release 
2 is planned to be on-time, having minor concerns regarding trader readiness.  

5 

6 

Low 

High  

PL 

PT 

RO 

SE 

4 

Med 

SI 

5 

Med 

SK 

1 

Low 

Table 25: Detailed responses from Member States – ICS2 – Release 2 

64 

 
 
 
 
 
 
Figure 15 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase34. 

Figure 15: Summary of Survey Responses – ICS2 – Release 2 

ICS2 – Release 3 

Summary from the Commission: 

The aim of the trans-European project on UCC ICS2 Release 3 is to enhance the functional scope of 
ICS2 with support for further modes of transport and implement the complete UCC requirements for all 
“entry  of  goods”  use  cases  building  on  ICS2  Release  1  and  Release  2.  This  Release  will  cover  the 
implementation of new ENS obligations and related business and risk management processes for all 
goods entering the EU by maritime, inland waterways, road and rail traffic (including goods in postal 
consignments  transported  by  these  means  of  transport).  This  Release  3  will  also  include  further 
extension for Safety and Security Analytics. 

The  Release 3 Common Technical System Specfications were delivered by March 2022. The further 
updates are to implement additional business changes and messages related to integration with Safety 
and Security Analytics (Enrichments). By the end of 2022, the first iteration of software implementing 
the Release 3 scope is scheduled.  

The end of ICS2 release 3 deployment window is rescheduled from Q4 2024 to Q1 2025 in order to 
align it with NCTS - Phase 6. This change allows Member States and economic operators to have a 
sound legal and IT basis to smoothly transition from the ENS requirements covered by ICS/NCTS - 
Phase 5 into the new ENS requirements under ICS2/NCTS - Phase 6. 

Summary from the Member States: 

Considering  the  ICS2  specifications,  the  Member  States  are  not  required  to  implement  new 
functionalities  for  Release  3.  Conformance testing  is therefore  not  applicable  for  Member  States for 
Release 3, it will only apply for economic operators. 

Additional work is related only to providing support to economic operators, namely supporting them in 
the project implementation and testing of applications interfacing with ICS2 Release 3.  

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

65 

 
 
 
 
 
                                                      
The Member States have identified potential causes for delay: the intricacies of this project, with all the 
new  processes  and  the  new  software,  the  tight  labour  market,  the  impact  caused  by  the  COVID-19 
pandemic  and  lack  of  human  resources  caused  by  crossed  over  use  for  different  projects  and  the 
workload created by Release 2. 

Detailed Responses: 

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

66 

 
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

5 

Low 

6 

4 

4 

5 

3 

6 

6 

3 

6 

6 
3 

4 

5 
6 

CY 

CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HR 
HU 

IE 

IT 
LT 

LU 

BG explained that TAXUD's functional and technical specifications are being  
used  for  ICS2  -  Release  3,  upgraded  with  the  national  requirements  in  the 
procedure  for  selection  of  the  contractor  for  the  development  of  national 
components. At the same time, they expressed the need to upgrade the national 
import  system  and  the  national  risk  analysis  system  in  conjuntion  with  the 
development of national components.  
According  to  CY,  for  Release  3  the  technical  specifications  are  planned  for 
15/03/2023,  conformance  testing  for  February  2024  and  operations  on 
01/03/2024.  All  of  these  milestones  are  within  the  UCC  Work  Programme 
planning timelines. 
Release 3 has a minor impact on CZ because of the mode of transport, with 
the  impact  focusing  on  the  risk  analysis.  The  deployment  is  planned  for 
01/03/2024. CZ also mentioned that they have two development contractors, 
one for the import related systems and another for risk analysis systems. 
DE stated that ICS2 - Release 3 will be implemented as part of the national IT-
System ATLAS - Release 10.2, for which the preparation activities have not yet 
started. 
Technical Specifications related activities are ongoing with the onboarding of 
the economic operators. 
EE explained that in 2022 the ICS2 - Release 3 activities are not representing a 
main focus. At the same time, it is anticipated that due to existing and persistent 
financial risks there is a risk for delay for the timely delivery of the system. 

Low 

Med 

Low 

Med 

Med 

Med  Same response as for ICS2 – Release 2. 

Low 

High 

ICS2  -  Release  3  involves  all  other  modes  of  transport,  being  dependent  on 
NCTS  Phase  6  timetable,  therefore  is  is  expected  that  the  complexity  of  the 
system to increase. For more details please see ICS2 – Release 2. 
Given the transition from Release 2 to Release 3 and the already stated delay 
for the latest, a 3 months delay is envisaged for ICS2 R3. 
GR indicated that due to delay in call for tender procedures the Conformance 
Testing and Deployment activities will be impacted with a possible subsequent 
effect on the on-time delivery of the project. Internal discussions are ongoing in 
order to minimise these effects. 
High  Same response as for ICS2 – Release 2. 
Low  None. 

Med 

Med 

Contingent  on  successful moves  to  all  other  UCC  systems  by  the  end  of the 
transition period, both economic operators and Customs Authorities will still be 
under pressure. 

Low  None. 
Low  The system will be developed using an agile approach.   

LU expressed that for Release 3 they need a budget and the tender process to be 
finished, therefore the planning has not been properly assessed yet. 

67 

 
 
 
 
 
 
 
 
 
 
LV 

6 

High 

LV explained that their planning takes into consideration delays caused by the 
the phased approach used in the development of the system.  
LV understanding is that ICS2 – Release 2 Technical Specifications will be used 
for  ICS2  –  Release  3  as  well,  with  a  similar  time  frame  for  deployment. 
However, it is appreciated that the Trade will not be willing to develop and test 
right  now,  therefore  ICS2  R3  must  have  separate  Conformance  Testing 
activities in the end of 2023, beginning of 2024. 
A  high  risk  of  missing  the  deadline  was  underlined  based  on  late  start  of 
development due to late procurement. Considering this, Conformance Testing 
and Deployment activities will be impacted. 

MT 
NL 

PL 

PT 

RO 

SE 

SI 

SK 

6 
5 

4 

6 

4 

5 

1 

Low  None. 
High  Same response as for ICS2 – Release 2. 

PL  has  not  started the analysis  of  the  Release  3  requirements  yet,  given  that 
currently, the entire workload has been put on the implementation of the Release 
2. For this reason, the analytical work on the ICS2 R3 will start when it will be 
certain  that  the  deadline  for  the  ICS2  R2  implementation  can  be  met. 
Additionally,  there  is  a  risk  concerning  the  funding  for  the  development  of 
Release 3 as it has not been released yet. 
The update of National ICS2 System  will take place, with impact on ICS2  – 
Release 3 and to the connection to Central System. 
An  agile  approach  on  development  will  be  used  in  order  to  reduce 
implementation timeframe. 
Same response as for ICS2 – Release 2. 
SE identified a risk pertaining to the economic operators, underlining that it is 
challenging to reach out and contact all the concerned parties. 
An increased workload for external contractors with other MASP projects (eg. 
transit, export etc.) is impacting the timely delivery of the system. 

Low 

High 

Med 

Med 

Low  None. 

Table 26: Detailed responses from Member States – ICS2 – Release 3 

Figure 16 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase35.

Figure 16: Summary of Survey Responses – ICS2 – Release 3 

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

68 

 
 
 
 
 
                                                      
4.1.6 Overview of Project Progress 

Table 27 and Table 28 indicate the percentage of completion as of the end of 2022 in comparison to the 
target dates set forth in the UCC Work Programme.  

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

Table 27: Comparison of Planned and Actual Dates – ICS2 – Release 236 

36 Several dates provided may differ given the derogation process undergoing. 

69 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion European Commission12/11/2019100%N/AN/A01/03/2023Not ProvidedAT01/03/2022Not Provided28/02/2023Not Provided01/03/2023Not ProvidedBENot ProvidedNot ProvidedNot ProvidedNot Provided01/03/2023Not ProvidedBG31/03/2022100%15/12/2022100%01/03/20230%CY31/10/2022100%20/02/20230%01/03/20230%CZ31/10/2022100%14/02/202350%01/03/202350%DE01/06/202270%February 202320%01/03/202390%DK31/10/2022100%14/02/2023100%Delayed0%EE31/12/202240%N/AN/A03/10/20230%ES01/03/2022100%15/09/2022100%01/03/20230%FI31/03/2022N/A30/09/2022100%01/03/202395%FR31/12/2022100%15/04/202350%01/06/202380%GRNot ProvidedNot ProvidedNot ProvidedNot Provided01/03/2024Not ProvidedHR31/10/2022100%10/02/202320%01/03/202385%HU25/11/2020100%10/02/20230%01/03/202390%IE28/01/2022100%28/03/202340%01/03/20230%IT31/12/2021100%14/02/202350%01/03/20230%LT30/07/2022100%15/02/202350%01/03/20230%LU04/11/2021Not Provided28/02/2023Not Provided01/03/2023Not ProvidedLV10/01/2022100%01/03/202340%01/03/20230%MT31/08/2022100%31/01/202350%01/03/202390%NL31/12/2021100%15/09/202350%01/11/20230%PL30/06/2022100%18/11/20220%01/03/20230%PT01/09/2022100%01/02/20230%28/02/20230%RO30/11/2021Not Provided31/01/2023Not Provided01/10/2023Not ProvidedSEN/AN/A14/02/20230%01/03/20230%SI01/04/2022100%18/02/2023100%01/03/202390%SK30/10/202275%14/02/202350%01/03/202350%RespondeeTechnical SpecificationsConformance TestingDeployment30/06/201801/03/2023 
 
 
 
 
                                                      
In regards to the implementation of ICS2  – Release 3,  the following Member States have a planned 
deployment date that is later than the deadline in the UCC Work Programme: CY, FI, FR, GR and NL. 
AT and DK did not provide data. 

Table 28: Comparison of Planned and Actual Dates – ICS2 – Release 3 

70 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion European Commission30/03/2022100%N/AN/A01/03/2024Not ProvidedATNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedBENot ProvidedNot ProvidedNot ProvidedNot Provided01/03/2024Not ProvidedBG31/12/2022100%15/12/20230%01/03/20240%CY15/09/20230%22/02/20240%01/04/20240%CZ30/06/20230%14/02/20240%01/03/20240%DEN/AN/ANot ProvidedNot Provided01/03/2024Not providedDKNot Provided0%Not Provided0%Not provided0%EE01/06/20230%01/02/20240%01/03/20240%ES01/03/2022100%15/09/20230%01/03/20240%FI31/03/20240%31/12/20240%31/03/20250%FR31/03/2023100%15/04/202475%01/06/202480%GR30/04/20230%28/02/20240%31/03/20240%HR10/10/20230%01/02/20230%01/03/20230%HU31/08/20230%01/02/20240%01/03/20240%IE28/01/20220%28/03/20240%01/03/20240%ITNot Provided0%Not Provided0%01/03/20240%LT30/07/202380%15/12/20230%01/03/20240%LU01/07/2023Not Provided28/02/2024Not Provided01/03/2024Not ProvidedLV10/01/2022100%01/03/20230%01/03/202390%MT01/02/20240%31/05/20240%01/10/20240%NL01/10/2023100%15/09/20240%01/11/20240%PLNot Provided0%Not Provided0%01/03/20240%PT01/09/20230%01/02/20240%01/03/20240%RONot ProvidedNot Provided31/01/2024Not Provided29/02/2024Not ProvidedSENot ProvidedN/A15/02/20240%01/03/20240%SI01/10/20230%17/02/20240%01/03/20240%SKN/A0%14/02/20240%01/03/20240%Conformance TestingDeployment(Start of the deployment window)30/06/201801/03/2024RespondeeTechnical Specifications 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Regarding  ICS2  –  Release  2,  additional  details  regarding  the  specific  percentage  of  completion  per 
milestone can be seen in the following figure. 

Figure 17: Percentage of Completion per Phase – ICS2 – Release 2 

71 

 
 
 
 
Regarding  ICS2  –  Release  3,  additional  details  regarding  the  specific  percentage  of  completion  per 
milestone can be seen in the following figure.  

Figure 18: Percentage of Completion per Phase – ICS2 – Release 3 

72 

 
 
 
UCC PROOF OF UNION STATUS (POUS) 

4.4 
The  UCC  Proof  of  Union  Status  (PoUS)  is  a  trans-European  system  designed  to  allow  storage, 
management and retrieval of certain types of documents (e.g. T2L, T2L/F, customs goods manifest) that 
traders provide to prove the Union status of their goods. The system is meant to improve the uniformity 
of the procedures across the European Union and contribute to the establishment of a more consistent, 
harmonised and thus simplified process related to customs clearance for Union goods.  

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

The project is split into two phases: 

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

•  Implementing  the  electronic  Customs  Goods  Manifest  (CGM),  including  the  information 
exchange with the European Maritime Single Window environment (EMSWe)37. 

4.1.7 Summary of Responses 

PoUS – Phase 1 

Summary from the Commission: 

Technical and System Specifications were completed in Q1 2022. An agile-like development approach 
is being used for the project, progressing according to the planning set by the UCC Work Programme. 
According to the Work Programme the component is anticipated to enter into production on 01/03/2024. 

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 this year.  

Summary from the Member States: 

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

Detailed Responses: 

Table 29 provides the individual Member States’ responses to the survey: 

MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

AT 

BE 

BG 

CY 

CZ 

AT has decided to use the Central System for PoUS. They confirmed that it will 
be difficult to comply with the legal deadlines considering other priority projects 
(NCTS, etc.).  
BE  confirmed  that  they  will  not  be  able  to  comply  with  the  legal  deadlines 
considering other priority projects (NCTS, etc.). 
BG  is  implementing  IT  projects  using  the  TOGAF/ADM  and  RUP 
methodologies. BG will use the Central System, however the connection to risk 
analysis nationally needs to be analysed. 
CY  confirmed  that  they  will  not  be  ready  with  the  implementation  within 
MASP. They will start analysis in April/May 2023 and finalise by end 2023. 
The current offer indicates end of development by March 2023.  
CZ advised that for PoUS there are no delays expected and that the planning is 
set in accordance with the MASP. CZ is using the Central System. 

3 

6 

4 

Low 

Low 

Low 

37 The deployment is planned for 02/06/2025. 

73 

 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

DE  will  make  use  of  the  central  PoUS  provided  by  EU-COM,  therefore  a 
national development with specific interfaces to the economic operator will not 
be needed. This Project has a link to the project "UCC Presentation Notification"  
when  the  Proof is used  at Presentation  Customs  Office.  For  that  purpose  the 
"National  Entry  Systems"  will  be  updated  as  part  of  the  national  IT-System 
ATLAS. Technical specifications will be defined to the extent necessary for the 
integration of the central PoUS web services. 
A  first  preliminary  plan  was  submitted  in  February  2022,  containing  the 
following milestones: Development start: Q1 2023, Development end: Q3 2023, 
National testing start: beginning of Q4 2023, National testing end: end of Q4 
2023. 
DE  emphasized  that  business  discussions  are  ongoing  about  interfacing  with 
national risk analysis, when a proof should be endorsed/registered. The business 
value (especially the benefit for the Authorised Issuer) is being questioned and 
the  technical  constraints  that  national  RA  (risk  analysis)  systems  are  not 
designed to interface with central systems need to be considered. 
DK will use the Central System and confirmed that they will not be ready within 
MASP. They still require to assess if RA integration is to be developed, with 
the option to choose a fully manual input). 
EE is planning to use the Central System, however delays are being anticipated 
related  to  introducing  the  connection  to  the  risk  analysis,  without  being 
considered a blocking issue. EE plans to have this completed by 01/03/2024. 
A preliminary plan has been set: Development start: 01/11/2022, Development 
end:  30/09/2023,  National  testing  start:  01/10/2023,  National  testing  end: 
30/11/2023. At the current moment, EE is reporting as primary causes for delay: 
the focus being shifted on other priority projects and the financial issues. 
The reasoning behind the choice of developing a national solution for PoUS, 
rather than using the central one stands behind the need to  integrate with the 
suite of national applications that ES has. ES indicated that it is easier for them 
to develop within their environment than to integrate an external product, given 
that they already have a national PoUS system.  
A  preliminary  plan  has  been  set:  Development  start:  Q1  2023,  Development 
end:  Q4  2023,  National  testing  start:  early  September  2023,  National  testing 
end: Q1 2024. 
Other ongoing UCC projects are causing disruption in the initial plan for the 
system.  ES  is  trying  to  minimise  the  impact  on  the  on-time  delivery  of  the 
project by running several activities in parallel to mitigate the delay. In this light, 
Technical Specifications are expected to be completed as initially scheduled. 
An agile approach is being used for the development of the system.  
Technical Specifications and Conformance Testing will not be applicable,  FI 
will use the central system instead. FI confirmed that the system development 
is in accordance with the MASP.  
FR  will  be  using  te  central  system  solution.  It  was  mentioned  that  for  the 
moment their focus is shifted onto other projects, therefore the delivery of the 
system in a timely manner will be affected, in particular with great impact on 
Conformance Testing and Deployment activities. At the same time it was not 
yet  decided  if  the  Central  System  will  be  used  for  PoUS.  FR  provided  a 
provisional deployment date for  Q1 2024. 
GR  indicated  that  for  PoUS  they  encountered  delays  in  the  call  for  tender 
procedures and that they intend to use a Central System. 
HR indicated that they will use the Central System for PoUS, however they will 
have national development to do in order to link to the risk analysis, therefore 

74 

DE 

3 

Low 

DK 

EE 

2 

Low 

ES 

4 

Med 

3 

4 

3 

Low 

Med 

Low 

FI 

FR 

GR 

HR 

 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

will not be able to achieve this in 2022. A number of Member States face the 
same  situation  and  it  does  not  affect  the  central  system,  however  the  risk 
analysis  would  have  to  be  handled  nationally  without  the  connection.  This 
would  involve  manual  intervention,  but  it  does  not  delay  the  rollout  of  the 
central system, as long as it can be managed until they connect. 
HR added that current statistics showed that there is low usage of T2l/T2LF so 
the impact should be small. On this note it is preferred by the NA-HR to avoid 
manual work if possible, therefore they will have  to decide whether the auto 
exchange of risk analysis will be achieved in 2022 or 2023. 
HU intends to use the Central System for PoUS and plan to be ready including 
with  the  national  connection  to  risk  analysis.  HU  wishes  to  develop  a  web 
service  to  provide  risk  analysis  communication  between  the  national  risk 
analysis  system  and  PoUS  on  CCN2.  The  development  is  planned  to  be 
completed before the end of the year. 
At the same time, the planning schedule and the dates of most national tasks and 
milestones need to be revised. 
IE will be using the Central System for PoUS. 
Italy will use the Central System which they will then need to integrate with 
their  risk  analysis  system.  Due  to  this  project  being  further  in  the  future,  no 
detailed planning has yet been envisaged, however they intend to comply with 
the legal deadlines. 
According to the information provided by LT a central  PoUS system will be 
used.  
LT  will  not  develop  the  link  to  their  RA  system,  therefore  they  will  use  the 
central PoUS manually. 
Furthermore,  as  regards  the  integration  with  the  national  risk  management 
system, the integration contract could be used, however there are some risks for 
a timely integration. 
For PoUS it was mentioned that LU will probably use the central solution but a 
definite decision has not been made yet. LU indicated that it will be difficult for 
them  to  be  ready  with the system  within MASP.  At  the  current  stage,  LU  is 
analysing the decision as to whether or not to develop link to their RA system. 
LV will use the Central System. They will not be ready within MASP, unless 
they choose to not develop any link to their RA system. Delays have as primary 
causes: the current assessment regarding the need to integrate the RA system 
(currently not being used at national level) and other prority projects (NCTS, 
etc.). 
MT indicated that  they  will  be  using  the  Central  System.  However  there are 
concerns  that  they  will  not  be  able  to  develop  the  interface  to  national  risk 
analysis in time due to working on parallel systems with a small team. 
NL  opted  for  the  use  of  the  Central  System,  with  no  impact  on  the  national 
systems.  At  the  same  time,  it  was  emphasized  that  the  scope  of  Phase  1  is 
expected  to  be  broader  than  anticipated.  Therefore,  an  interface  between  the 
webservice and NL’s national risk analysis system might be needed. 
NL confirmed that they will not be ready within MASP. 
PL will use the national system and explained that due to some delay in signing 
of a contract which covers among others the deployment of the PoUS system, 
the implementation will be postponed for Q1 2024. The iterative development 
approach will be used for PoUS. 
PL expressed that one of their main causes for delay is having a lot of projects 
to  develop  in  parallel.  In  2018  PL  developed  the  e-Status  (applicants  submit 
T2L/T2LF only electronically and SAD is no longer accepted). E-Status is part 

75 

HU 

IE 

IT 

2 

3 

4 

Low 

Low 

Low 

LT 

3 

Low 

LU 

LV 

MT 

NL 

4 

3 

Low 

Med 

PL 

2 

Low 

 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

of their ECS export system (their AES). PL now works on the AES (in line with 
UCC). Only after the successful implementation of the AES will PL implement 
the PoUS, updating the e-Status to the PoUS requirements. 
PT indicated that they will use the Central System, using an agile development 
approach to reduce implementation timeframe. PT confirmed that they will be 
ready  with  the  implementation  according  to  the  MASP,  whether  or  not  they 
develop any link to their RA system. 
RO will use the Central System. Phase 2 is not yet planned and they expect to 
have delays. A primary cause for delay is represented by other priority projects 
(NCTS, etc.). 
SE  noted  that  the  Central  System  will  be  used  to  a  full  extent,  therefore 
Technical Specifications concerning the external domain will not be used.  
SE  thinks  it  is  unlikely  to  meet  the  development  date  of  the  end  of  2022, 
however they believe they can manage to proceed with conformance testing in 
2023, in order to be ready for the March 2024 deployment. At the current stage, 
for Phase 2 no analysis has started yet. 
SI is currently in the phase of analysis on how to use Central System for PoUS 
together with the national Risk Analysis System. 

Low 

Med 

PT 

5 

Low 

RO 

SE 

SI 

SK 

3 

5 

1 

High  Same response as for GUM – Component 2. 

Table 29: Detailed responses from Member States – PoUS – Phase 1 

76 

 
 
 
 
 
 
Figure 19 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase38. 

Figure 19: Project Status as per Survey – PoUS – Phase 1 

PoUS – Phase 2 

Summary from the Commission: 

It was highlighted that the deployment date of the PoUS Phase 2 CGM (02/06/2025) is not aligned to 
the EMSWe deployment date (15/08/2025), therefore, since the PoUS envisaged to receive considerable 
volume of the CGM through the EMSW, and the gap between the dates would create unnecessary burden 
for Trade, discussions are undergoing to ensure that the deployment dates in the UCC WP and MASP-
C of the PoUS Phase 2 CGM and the EMSWe are aligned.39 

Among the activities to be carried, the Technical & System Specifications are planned starting Q1 2023. 
As  a  result  of  the  work  on  the  technical  implementation  and recent legal  discussions,  a  Request for 
Change list was prepared to align the functional specifications of the T2L/T2LF. 

Summary from the Member States: 

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

Detailed Responses: 

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

MS 

AT 
BE 

BG 

CY 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

3 

6 

Low 

Low  

BG  is  implementing  IT  projects  using  the  TOGAF/ADM  and  RUP 
methodologies.  Currently,  the  work  on  preparing  the  tender  procedure  is 
ongoing, having no established planning at the moment. 
According to CY, no additional activities for PoUS Phase 2 are planned during 
2022. 

38 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the CT 
environment and coordination for Member States; 
39 Waves of external reviews are envisaged. 

77 

 
 
 
 
 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

CZ 

4 

Low 

DE 

4 

Low 

CZ is planning the same scope of Conformance Testing on national level which 
is  prepared  before  all  new  systems.  In  all  cases,  tests  are  running  regarding 
communication  with  Economic  Operators  and  national  Helpdesk,  while 
assessing if it is necessary with the central system and on national level with 
others components. 
CZ then advised that for PoUS there are no delays expected and the planning 
has been provided. 
According to DE, Phase 2 is linked to the implementation of the Customs Goods 
Manifest  of  the  European  Maritime  Single  Window  Initiative  for  which  the 
business  scope  and  the  IT-architecture  still  needs  to  be  elaborated.  Planning 
details will be provided when the Business Case and the Vision Document are 
available.  Considering  that  the  expected  date  of  deployment  should  be  June 
2025, preparation activities have not yet started. 

DK 
EE 

ES 

FI 
FR 
GR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 

NL 

PL 

PT 

RO 
SE 

SI 

SK 

3 

4 

4 
4 
3 

2 
3 
3 
3 

4 

3 

1 

5 

3 

5 

1 

Low  None. 

Med 

According to ES planning a full deployment of the system is expected in June 
2025. Technical Specifications are expected to be completed as planned. 
An agile approach is being used for the development of the system. 

Low  Same response as for PoUS - Phase 1. 
Low  None. 
Low  Same response as for PoUS - Phase 1. 
Same response as for PoUS - Phase 1. 

Low  None. 
Low  Same response as for PoUS - Phase 1. 
Low  None. 
Low  Same response as for PoUS - Phase 1. 

Low  Same response as for PoUS - Phase 1. 

Med 

According  to  NL  external  stakeholders  are  being  involved,  therefore  a 
communication campaign will be needed to inform them on the progress and 
the anticipated risk on the on-time delivery of the project. A primary identified 
cause  is  expected  to  be  the  context  outlined  by  MASP,  with  all  the  projects 
running in parallel and the need and use for the same development expertise. 
According to NL, PoUS – Phase 2 related activities will not be initiated in 2022. 

Low  An iterative approach is envisaged for the system development. 

Low 

An  agile  development  approach  will  be  used  to  reduce  implementation 
timeframe. 

Low  Same response as for PoUS - Phase 1. 

Low 

Among the current activities undertaken by SI are the review and study of the 
PoUS  specifications.  An  agile  approach  is  envisaged  for  the  system 
development. 

High  Same response as for PoUS - Phase 1. 

Table 30: Detailed responses from Member States – PoUS – Phase 2 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 20 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase40. 

Figure 20: Project Status as per Survey – PoUS – Phase 2 

4.1.8 Overview of Project Progress 

Table 31 and Table 32 highlight any known divergences in the planning compared to the dates set in the 
Work Programme.  

Table 31: Comparison of Planned and Actual Dates – PoUS – Phase 1 

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

79 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion European Commission31/03/2022100%31/03/20240%01/03/20210%AT01/08/2022Not Provided29/02/2024Not Provided01/12/2023Not ProvidedBENot ProvidedNot Provided01/03/2024Not Provided01/03/2024Not ProvidedBG12/12/2022100%29/02/20240%01/03/20240%CYN/A100%22/02/202430%01/03/20240%CZ01/02/2022Not Provided01/03/20240%01/03/20240%DE31/03/202350%31/12/20230%01/03/20240%DK15/03/20200%29/02/20240%01/03/20240%EEN/A10%N/A0%01/03/20240%ES01/03/202350%28/02/20240%01/02/20240%FIN/AN/A31/03/2024N/A01/03/20240%FR11/11/2022100%01/09/20230%01/03/20240%GR30/04/20230%31/01/20240%31/03/20240%HRN/ANot Provided29/02/2024Not Provided29/02/2024Not ProvidedHU01/12/2022100%31/03/2024Not Provided31/03/202425%IEN/AN/AN/AN/A01/01/2024N/AITNot Provided100%Not Provided0%01/03/20240%LT31/03/2022N/A28/02/2024N/A01/03/2024N/ALUNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot Provided31/02/2024LVNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedMT01/02/202350%31/05/2023N/A01/10/20230%NLN/AN/A01/03/20240%01/03/20240%PL01/12/202225%29/12/20230%15/01/20240%PT01/06/20230%01/12/20230%29/02/20240%RONot ProvidedNot ProvidedNot ProvidedNot Provided01/03/2024Not ProvidedSEN/AN/ANot Provided0%01/03/20240%SI01/01/2022100%20/02/20240%01/03/20240%SKNot Provided0%Not Provided0%Not Provided0%RespondeeTechnical SpecificationsConformance TestingDeployment30/06/202201/03/2024 
 
 
 
                                                      
Table 32: Comparison of Planned and Actual Dates – PoUS – Phase 2 

80 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion European Commission30/06/202330%30/06/20250%15/08/20250%ATN/ANot ProvidedN/ANot ProvidedN/ANot ProvidedBENot ProvidedNot Provided01/03/2025Not Provided01/03/2025Not ProvidedBG20/12/20230%30/05/20250%02/06/20250%CYN/A0%19/05/20250%02/06/20250%CZ01/04/20230%02/06/20250%02/06/20250%DEN/AN/AN/AN/AN/AN/ADK15/03/20200%30/06/20250%30/09/20240%EEN/A0%N/A0%02/06/20250%ES30/03/20240%02/06/20250%02/06/20250%FIN/ANot ProvidedNot ProvidedN/A30/06/20250%FR31/05/20240%28/02/20250%02/06/20250%GR31/08/20240%31/05/20250%30/06/20250%HRN/ANot Provided01/06/2025Not Provided31/05/2025Not ProvidedHU30/09/20240%01/06/20250%01/06/20250%IEN/ANot ProvidedN/AN/A01/01/2025N/AITNot Provided0%Not Provided0%02/06/20250%LT30/06/2023N/A31/05/2025N/A02/06/2025N/ALUNot ProvidedNot ProvidedNot ProvidedNot Provided31/03/2025Not ProvidedLVNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedMT01/01/20240%31/05/2024N/A01/10/20240%NL01/07/20230%01/06/20250%02/06/20250%PL01/12/20220%29/12/20230%15/01/20240%PT01/06/20240%01/03/20250%01/06/20250%RONot ProvidedNot ProvidedNot ProvidedNot Provided02/06/2025Not ProvidedSEN/ANot ProvidedNot Provided0%02/06/20250%SI01/03/20230%30/05/20250%02/06/20250%SKNot Provided0%Not Provided0%Not Provided0%RespondeeTechnical SpecificationsConformance TestingDeployment30/06/202202/06/2025 
 
 
 
 
Regarding  PoUS–Phase  1,  additional  details  regarding  the  specific  percentage  of  completion  per 
milestone can be seen in Figure 21. 

Figure 21: Percentage of Completion per Phase – PoUS – Phase 1 

81 

 
 
 
 
Regarding  PoUS–Phase  2,  additional  details  regarding  the  specific  percentage  of  completion  per 
milestone can be seen in Figure 22. 

Figure 22: Percentage of Completion per Phase – PoUS – Phase 2 

82 

 
 
 
UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) 

4.5 
The UCC Centralised Clearance for Import (CCI) project aims to allow for goods to be placed under a 
customs procedure using centralised clearance, enabling economic operators to centralise their business 
from a customs point of view. The processing of the customs declaration and the physical release of the 
goods will be coordinated between the related customs offices. 

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

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

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

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

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

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

4.1.9 Summary of Responses 

CCI – Phase 1 

Summary from the Commission: 

CCI is the first trans-European system using the new network architecture, CCN2ng. All of the other 
projects  supporting  conformance  testing  activities  need  to  be  aligned  with  the  new  architecture  and 
approach.  

“Forerunner”  Member  States  have  been  identified  to  work  closely  with  the  Commission  for  the 
development activities and with a view to start operations soon after the start of the deployment window 
planned for the project in the UCC Work Programme41.  

As of January 2022 pre-Conformance Testing activities have started with “forerunner” Member States42, 
having Conformance Testing planned for 13/10/2022 - 01/12/2022.  

The conformance environment was outlined on TAXUD’s side. It is envisaged that ES finishes their 
testing activities before December 2022. Their target is to execute tests in the summer and go live in 
October  2022.  Several  NAs  reported  risks  and  challenges  to  go  live  before  the  legal  deadline  of 

41 The deployment window set by the UCC WP is 01/03/2022 – 01/12/2023; 
42 In January 2022, ES as a forerunner started national pre – conformance test activities. A technical meeting with MSs was 
held on 16/12/2021 for presenting and discussing the MS CCI P1 NPPs. The communication between Member States and DG 
TAXUD will continue to follow up on their progress. 

83 

 
 
                                                      
1/12/2023.  In  this  light,  DG  TAXUD  support  for  the  conformance  testing  activities  will  need  to  be 
extended. 

It  needs  to  be  highlighted  that  CCI  messages  are  fully  aligned  to  the  new  Annex  B  and  the  ones 
applicable to the external domain with the Traders can be re-used by those MSs who decided to start 
updating their NIS in accordance with new Annex B, instead of Annex D to the UCC DA and Annex C 
to the UCC IA. 

Summary from the Member States: 

Most Member States are analysing the technical and functional specifications and some have cited that 
there  may  be  a  risk  in  meeting  the  CT  and  deployment  milestones.  Many  Member  States  have 
commented that the planning is tight in the context of import systems. In addition to the complexity of 
the project, other reasons for potential delay are human and financial resource constraints, impact and 
re-planning due to the VAT eCommerce package43 and also the specific working circumstances caused 
by the COVID-19 pandemic. 

In terms of assessing the level of completeness of the system, three quarters of the Member States that 
provided information reported that the system is on target. However there are several Member States 
that have indicated that at the current stage the system is delayed beyond the deployment deadline44. 

BG, EE, ES, HR, IE, IT, NL and PL mentioned that technical specifications have been completed. ES, 
HU and PL have initiated the Conformance Testing activities. Only ES has reported to have completed 
the development of CCI Phase 1. 

Regarding the associated risk level on the on-time delivery of the project the majority of the Member 
States have indicated mostly a medium to high level of risk, and also assessed the complexity as being 
medium to high.  

Detailed Responses: 

Table 33 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

6 

Low 

BG  is  implementing  IT  projects  using  the  TOGAF/ADM  and  RUP 
methodologies. According to BG planning for CCI – Phase 1, they intend 
to start development in 2022 and to go live in November 2023. 
CY mentioned that from their perspective it is unlikely that traders in CY 
will  be  involved  in  centralised  clearance  operations,  however  they  are 
making the necessary preparations to introduce it. 
The  Technical  Specifications  were  published  on  15/05/2022  with 
Conformance  Testing  planned  for  October/November  2023  and 
Operations  on  01/12/2023.  For  Phase  2  it  is  intended  for  Technical 
Specifications to be available on 30/11/2024, Conformance Testing taking 
place in May 2025 and Operations on 02/06/2025. 
CZ presented that for CCI Phase 1 there where some activities that have 
already started and that deployment would take place on 01/12/2023 while 
for Phase 2 it would deploy on 01/02/2025. 
DE explained that the project will be implemented as part of the major 
release of the national IT-System ATLAS (Release 10.2) as a new trans-
European system, therefore delays on delivery are expected. The creation 
of  a  new  national  PG  for  CCI  with  the  necessary  resources  and  the 

CY 

6 

Low  

CZ 

DE 

6 

5 

Med 

High 

43 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33); 
44 DE, GR, FI, FR, NL, SI and SK. 

84 

 
 
 
 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

application  of  an  agile  imlplementation  development  method  are 
considered to reduce the impact on planning.   
Internal analysis has already started with the aim to start operation in Q4 
2024.  Once  CCI  is  deployed,  it  will  be  upgraded  to  fully  integrate  the 
national import requirements and to replace the “old” system. 
DE explained that the Annex B (DA) requirements are being implemented 
in the existing national import systems so the deadline of 31/12/2022 can 
be achieved. However for CCI it will be necessary to develop a completely 
new system. 

High  DK informed that at the moment the system is undergoing planning. 

DK 

EE 

4 

5 

Med 

ES 

6 

High 

FI 

6 

High 

FR 

5 

High 

Currently the system is in analysis phase, development activities having 
not yet started. EE plans to deploy the system in December 2023. 
ES explained that the first implementation targets SCI functionality with 
no Simplified declaration, using an iterative development approach. The 
final delivery of the project will require planning coordination with at least 
another Member State. 
ES’s  plan  has  been  adapted  to  the  availability  of  the  Technical 
Specifications for the Trans-European Systems (TES), with the need of 
further adjustments on the system availability in the partner country. 
The  project  has  suffered  delays  in  relation  to  the  publication  of  the 
specifications due to the complexity of the system that has affected the 
national planning, considering the high interrelationship between national 
and European declaration systems. 
FI informed that the entire import system will be built from scratch and 
noted that given the many parallel projects, the COVID-19 pandemic, the 
limited  resources,  especially  on  suppliers  side  and  the  high  level  of 
workload the delivery of CCI - Phase 1 will be postponed by two quarters, 
therefore a derogation will be needed, possibly until Q2 2024. 
At the same time it was indicated that the supplier uses an agile method 
for  the  system  development  in  order  to  reduce  impact  on  milestones, 
however deliveries are to be tested in Finnish Customs and further sent in 
bigger entities. 
Regarding CCI, FR had to abandon the plan to be ‘forerunner’ as it was 
needed  to  prioritise  its  developments  to  be  ready  with  the  new  import 
system. Additional resources on business and IT side were mobilized in 
this regard. FR explained that from a technical point of view there is no 
added value in delivering the application in several batches, having links 
with internal repositories and internal processes that must be developed 
from start to finish. 
Delays have been recorded given the involvement of the technical team in  
Brexit  and  E-commerce,  with  a  strong  impact  on  human  and  financial 
resources, idea strenghtened by the COVID-19 pandemic. As regards the 
mitigating measures, FR outsourced some activities with a contractor and 
in parallel, they secured the import system to have a better base for CCI. 
At the same time AES developments have to be ensured, given France's 
position  as  an  "exit"  Member  State  for  the  other  Member  States. 
Therefore, it was expressed that many choices that require an increased 
level  of  resources  are  to  be  made  for  several  projects  that  have  to  be 
carried out simultaneously. In this light, FR has chosen to prioritize AES 
(core  functions)  over  CCI  given  the  importance  of  the  export  volumes. 
Ultimately, the calendar was shifted in order to secure other projects: the 

85 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

6 

6 

5 

6 

4 

High 

Med 

Med 

Med 

Med 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

6 

High 

MT 

6 

Med 

NL 

5 

High 

PL 

5 

Med 

CCI – Phase 1 system will deliver the functionalities by iterations, having 
an envisaged deployment date set for October 2024.  
Same response as for PoUS – Phase 2. 
Currently functionalities are developed, HR expressing that the system is 
expected to be highly complex. 
HR indicated that the deadline will be met, however they will be under 
some  pressure  given  that  the  centralised  clearance  is  linked  to  the 
timelines of AES and National Import systems. 
According to HU the connectivity to the data link developments will be 
completed  on  30/04/2023.  Full  functionality  will  be  finished  on 
01/12/2023. 
IE highlighted that communication with other MSs is new at Import, plus 
the move to the revised Annex B and the data chages to EUCDM V6.1 are 
challenges  for  EOs  and  Customs  Authorities,  therefore  the  effective 
delivery  of  the  project  could  be  impacted.  The  planning  for  go-live  in 
October 2023 was confirmed by IE and they hope to have all traders on 
board. 
In relation to CCI - Phase 1, IT has started development in June 2022 with 
conformance testing planned from May to October 2023 and deployment 
on 06/11/2023. Work on Phase 2 will start when Phase 1 is done. 
For CCI Phase 1, the testing is to be finished in September 2023 and the 
deployment is planned to be within the legal deadline, therefore no risks 
are foreseen for the moment for the CCI project. 
According to LU, CCI Phase 1 was also affected by the tendering process, 
however at the moment it is still possible to meet the 01/12/2023 deadline. 
If not, the new envisaged deadline will be 30/06/2024. 
LV  marked  the project as delayed,  however overall the  delivery is still 
foreseen within the Deployment deadline. A primary cause identified is 
the lack of readiness related to procurement procedure. 
At  the  same  time,  CCI  depends  on  the  new  import  system  being 
implemented in the last quarter of 2023. A possible rollout of changes in 
stages  with  the  national  import  and  then  CCI,  rather  than  both 
simultaneously is to be examined. Other risks associated with financing 
were identified.  
The CCI Phase 1 system will be developed and implemented under the 
National  Import  System,  which  will  be  deployed  around  Q1/Q2  2023, 
instead of Q4 2022. Trader involvement is not envisaged given the nature 
of it and their location. 
For CCI, NL is considering to merge Phase 1 and Phase 2 and they intend 
to combine them with CCE. The deadline would then be the deadline of 
CCI Phase 2. 
NL has associated to this project a high risk on the on-time delivery of the 
project  given  the  intricacies  of  this  project.  To  this  is  added  Brexit,  e-
commerce, the labour market and the COVID-19 pandemic.  
At the same time, NL has indicated that in order to reduce the impact on 
milestones, the minisation of the scope is under consideration. 
At the time of writing, all milestones (Construction phase, Conformance 
Testing and Deployment) are being delayed. 
PL noted that the CCI Phase 1 system will be developed and implemented 
under the National Import System, having the implementation planned for 
01/12/2023. Risks pertaining to the COVID-19 pandemic and its impact 
to  financial  and  human  resources  are  being  associated  with  a  possible 

86 

 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

delay  on  the  system  delivery.  The  specifications  for  Phase  1  will  be 
published in June 2022. No major risks for delay are being envisaged for 
both Phase 1 and 2. 

6 

Low  An agile development approach is being used. 

PT 

RO 

SE 

4 

Med 

SI 

6 

High 

SK 

1 

High 

For CCI Phase 1, RO mentioned that this is part of the same contract as 
national  import,  therefore  at  the  current  stage  they  are  still  waiting  on 
contractor planning. 
SE explained that due to serveral projects that should be developed at the 
same time, the deployment deadline of the CCI – Phase 1 system could be 
altered. At the time of writing, SE is placed in the analysis phase, having 
yet to consider the approach for the project development. 
The  deployment  is  planned  for  December  2023,  but  there  are  risks 
associated. For Phase 2, they currently plan for June 2025 as in the UCC 
WP. 
SI indicated that for the moment they cannot anticipate delays. The status 
of the project will be assessed once they receive the offer from the external 
IT contractor regarding the development of the CCI phase 1 project. 
Previously  SI  completed  the  national  import  declaration  system  in 
accordance  with  the  new  Annex  B  requirements,  which  had  to  be 
postponed  several  times  due  to  the  unpreparedness  of  the  external 
environment as a consequence of COVID-19. 
The deployment is being maintained for 01/12/2023. 
SK noted that due to lack of financial and human recources, all milestones 
related to the system development are impacted, leading to possible delays 
on  the on-time  delivery  of  the  project.  However,  the implementation  is 
planned  to  be  with  entry/import  system  in  the  same  contract,  therefore 
aiming to achieve CCI - Phase 1 date. 

Table 33: Detailed responses from Member States – CCI – Phase 1 

87 

 
 
 
 
 
 
Figure 23 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase45. 

Figure 23: Summary of Survey Responses – CCI – Phase 1 

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

88 

 
 
 
 
 
                                                      
CCI – Phase 2 

Summary from the Commission: 

Representatives of 10 Member States46 have been actively involved in the CCI Phase 2 project group, 
identifying and developing proposals for the processes and the new functionalities to be implemented. 
The business processes and functional specifications for Phase 2 were  approved during 2020 and the 
technical specification document was approved in June 2022 in view of the planned date for starting the 
deployment window for the initial Member States in October 2023. 

Summary from the Member States: 

Most Member States are analysing the technical and functional specifications and some have cited that 
there  may  be  a  risk  in  meeting  the  CT  and  deployment  milestones.  Many  Member  States  have 
commented that the planning is tight in the context of import systems. In addition to the complexity of 
the project, other reasons for potential delay are given such as human and financial resource constraints, 
impact  and  re-planning  due  to  the  VAT  eCommerce  package47  and  also  the  specific  working 
circumstances caused by the COVID-19 pandemic. 

In terms of assessing the level of completeness of the system, three quarters of the Member States that 
provided information reported that the system is on target. No Member States have yet completed the 
development of the system, however there are numerous Member States that have indicated that at the 
current stage the system is delayed beyond the Deployment deadline48. EE and FI explained that in their 
case, the system is delayed, beyond the Deployment deadline.  

Several  Member  States  have  indicated  that  activities  were  initiated  in  relation  to  Technical 
Specifications, with the exception of BG, ES, IT and NL. 

Regarding the associated risk level on the on-time delivery of the project the majority of the Member 
States  have  indicated  a  medium,  high  level  of  risk,  while  assessing  the  complexity  as  being 
medium/high.  

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

CY 

CZ 

5 

6 

6 

Med 

Low 

BG  is  implementing  IT  projects  using  the  TOGAF/ADM  and  RUP 
methodologies. 

Low   No activities are planned until the end of 2022 for CCI Phase 2. 

The system is developed under NIS, for further details please see section 
referring to NIS. 
Indicative  milestones in  national  project  plan  are  as  follows:  Technical 
Specifications = 01/06/2024, The period of CT with EOs = 01/10/2024-
31/01/2025, Deployment = 01/02/2025. 
In DE’s perspective, CCI – Phase 2 is considered a business upgrade only 
for which no complex and time-consuming migration strategy from CCI 
– Phase 1 is required. 
Implementation of CCI – Phase 2 highly depends on the finalisation of 
CCI  –  Phase  1  for  which  delays  have  been  identified,  but  mitigation 
measures are taken to ensure operation starts in Q4 2024. Following this 
it is appreciated to be possible to compensate the delay for CCI – Phase 2 
in order to meet the legal end-date of the deployment window 02/06/2025. 

DE 

3 

Med 

46  AT, BE, CZ, DE, DK, ES, FI, FR, NL and PT; 
47 Council Implementing Regulation (EU) 2017/2459 of 5 December 2017 (OJ L 348, 29.12.2017, p. 32–33); 
48 SI and SK. 

89 

 
 
 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

The creation of a new national PG for CCI with the necessary resources 
and the application of an agile implementation development method are 
considered to reduce the impact on planning.   

DK 

EE 

ES 

FI 

FR 

GR 
HR 
HU 

IE 

IT 
LT 

LU 

LV 

MT 

NL 

PL 

4 

5 

6 

6 

5 

5 
6 
4 

5 

4 

6 

5 

5 

5 

PT 

6 

Low 

Med 

Med 

High 

High 

Med 

The project is currently undergoing planning. 
No activities related to the project development have started. There is a 
high risk identified for the system outcome, considering the existing lack 
of human and financial resources. 
CCI – Phase 2 depends on the success of Phase 1, furthermore this may 
help reducing the complexity of the second phase. An iterative approach 
is envisaged for the system development. 
FI informed that the entire import system will be rebuilt.  
Same response as for CCI – Phase 1. 
FR added that currently their activities are focused on the applications for 
the  NIS  and  CCI  projects,  with  Conformance  Testing  activities  to  be 
completed after the NIS is finalised. At the same time, AES constraints 
are generating delays as well. Technical Specifications and Conformance 
Testing are expected to be impacted. 
Same response as for CCI – Phase 1. 
Same response as for CCI – Phase 1. 

Low 
Med 
Low  According to HU, Phase 2 planning is on target. 

Low 

Med 

Following  Phase  1,  Phase  2  incorporates  additional  procedures,  full 
engagement with Economic Operators being required.  
Same response as for CCI – Phase 1. 

According to LU, CCI Phase 2 should be ok by the UCC WP date as it is 
a separate deliverable. 
CCI – Phase 2 will be a part of totally new national import system, as the 
old system cannot be modified. This associates a medium risk of delay to 
the project. 

Med 

Low  None. 

Low 

Med 

According to NL a high level of risk is being associated to the  on-time 
delivery of the project given the new application and its interactions with 
many  other  (national)  applications.  Furthermore  many  MASP-projects 
developments  are  occuring  at  the  same  time,  influencing  each  other, 
creating interdependencies and ultimately increasing the complexity. 
To minimise the impact on delivery, NL is using an agile approach. 
Same response as for CCI – Phase 1. 
PT  emphasized  that  the  Conformance  Testing’s  purpose  is  for  the 
Economic Operators to be able to realize if their systems comply with the 
specifications and for PT to assess if the external domain was correctly 
developed.  The  Conformance  Testing  with  the  Member  States  will  be 
completed in order to evaluate if all the necessary connections/validations 
are correctly performed. 
This  Phase  2 is intended  to  treat  all  the  matters  which  were  omitted in 
Phase  1  due  their  complexity.  The  project  will  be  developed  and 
implemented as part of the National Import System. Therefore, since this 
project is highly complex, the integration of CCI – Phase 2 will also be 
complex.  To  this  adds  that  the  development  of  this  system  is  not  only 
related with the system itself, but it is also related to the development of 
all  national,  central  and  other  MS’s  systems/modules,  national  and  UE 

90 

 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

RO 
SE 

4 

Med 

SI 

6 

High 

SK 

1 

High 

entities  connections,  which  ultimately  increases  the  inter-dependencies 
and  the  complexity  of  the  “global  system”.  An  agile  development 
approach will be used to reduce implementation timeframe. 

Same response as for CCI – Phase 1. 
SI noted that the start of CCI - Phase 2, depends on the finalisation of the 
first phase.  CCI  is  appreciated as  a  complex  system  which includes  47 
electronic  messages  and  15  BPMs,  exchange  of  electronic  messages 
between  SCO  and  PCO,  specific  rules  and  conditions  (R&C)  for  CCI, 
specific code lists for CCI and demanding Conformance Testing.  
SI indicated that for the moment they cannot anticipate delays. The status 
of the project will be assessed once they receive the offer from the external 
IT  contractor  regarding  the  development  of  the  CCI  phase  2  project 
(dependant on completion of Phase 1).  
Previously  SI  completed  the  national  import  declaration  system  in 
accordance  with  the  new  Annex  B  requirements,  which  had  to  be 
postponed  several  times  due  to  the  unpreparedness  of  the  external 
environment as a consequence of COVID-19. 
Same response as for CCI – Phase 1. 

Table 34: Detailed responses from Member States – CCI – Phase 2 

Figure 24 provides the percentage of respondents (Member States plus the European Commission) in 
each development phase49. 

Figure 24: Summary of Survey Responses – CCI – Phase 2 

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

91 

 
 
 
 
 
 
 
 
                                                      
4.1.10  Overview of Project Progress 

Table 35 and Table 36 highlight any known divergences in the planning compared to the dates set in the 
Work  Programme.  As  this  project  has  a  deployment  window,  the  ‘Deployment’  and  ‘Operations’ 
columns are shown. If there is a difference in these two dates, this implies that a migration period is 
planned.  

Regarding CCI – Phase 1, the following Member States have a planned operations date that is later than 
the deadline in the UCC Work Programme: DE, FI, FR and GR. DK did not provide data. 

Table 35: Comparison of Planned and Actual Dates – CCI – Phase 1 

92 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateEuropean Commission09/10/2020100%Not Provided5%Not Provided5%Not ProvidedAT01/12/2021Not providedNot providedNot providedNot providedNot providedNot providedBE01/12/2021Not provided01/12/2023Not provided01/12/20230%01/12/2023BG27/08/2021100%15/10/20230%31/10/2023Not provided31/10/2023CY15/05/202280%15/11/20230%01/12/20230%01/12/2023CZ31/03/202325%30/11/20230%01/12/20230%01/12/2023DE31/03/20240%30/06/20250%31/12/20240%31/12/2024DKNot provided5%Not Provided0%Not Provided0%Not ProvidedEE01/12/2022100%30/10/20230%29/11/20230%29/11/2023ES14/03/2022100%Not provided100%30/09/2022100%Not providedFI31/12/202260%31/03/20240%30/06/202410%30/06/2024FR01/02/202230%05/20230%01/06/20220%01/11/2024GRNot provided30%30/09/20220%31/12/20220%01/12/2024HR30/06/2022100%30/11/20230%01/12/202320%01/12/2023HU15/03/202350%01/12/202310%01/12/20230%01/12/2023IE01/10/2022100%30/09/20230%01/10/20230%01/10/2023IT01/10/2020100%30/09/20230%01/03/20220%01/12/2023LT04/05/2023Not provided01/12/2023Not provided01/12/2023Not provided01/12/2023LU01/02/2023Not provided30/06/2024Not provided30/06/2024Not provided30/06/2024LV01/10/2022N/A29/10/20230%30/10/20230%30/10/2023MT31/08/202280%31/10/20230%15/11/202350%15/11/2023NL01/01/2022100%01/12/20230%01/12/20230%01/11/2025PL30/07/2022100%30/09/202310%01/12/202310%01/12/2023PT15/12/202275%15/10/20230%01/12/20230%01/12/2023RO30/06/2023Not provided31/12/2023Not provided01/12/2023Not providedNot providedSENot provided0%Not provided0%01/12/20230%Not providedSI01/03/20210%20/11/20230%01/12/20230%01/12/2023SK01/12/20220%01/11/20230%01/12/20230%Not provided30/09/202001/03/202201/12/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
For the implementation of CCI – Phase 2, FI’s planned deployment date is one month later than the 
target date set in the WP, considering that the entire import system will be rebuilt. EE reported a delay 
of one month as well. 

Table 36: Comparison of Planned and Actual Dates – CCI – Phase 2 

93 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateEuropean CommissionNot provided100%Not provided0%Not provided0%Not providedATNot providedNot providedNot providedNot providedNot providedNot providedNot providedBEN/ANot providedN/ANot providedN/ANot providedNot providedBG04/11/2024100%17/03/20250%31/03/20250%31/03/2025CY30/11/20240%19/05/20250%02/06/20250%02/06/2025CZ01/06/20230%31/01/20250%01/02/20250%01/02/2025DE31/03/20240%30/06/20250%31/12/20240%31/12/2024DKNot provided0%Not provided0%Not provided0%Not providedEE31/03/20240%31/12/20240%30/06/20250%30/06/2025ES30/09/202250%30/09/20240%01/10/20240%01/04/2025FI31/12/20240%30/06/20250%30/06/20250%30/06/2025FR31/03/20230%31/12/20230%30/06/20240%30/06/2024GR31/12/20220%31/12/20240%31/03/20250%31/03/2025HR30/06/20230%01/02/20250%01/03/20250%01/03/2025HU15/03/20230%01/05/20250%01/06/20250%01/06/2025IE01/10/20230%30/09/20240%01/10/20240%01/10/2024IT01/01/2023100%31/12/20240%01/03/20250%01/06/2025LT01/06/2024Not provided01/12/2024Not provided02/06/2025Not provided02/06/2025LU01/07/2023Not provided01/04/2025Not provided01/06/2025Not provided01/06/2025LV01/10/20240%23/02/20250%23/03/20250%23/03/2025MT31/01/20230%31/10/20230%15/11/20230%15/11/2023NLNot provided50%Not provided0%Not provided0%01/11/2025PL30/09/20230%01/01/20250%01/06/20250%01/06/2025PT01/06/20240%15/04/20250%01/06/20250%01/06/2025RO30/06/2024Not provided30/06/2025Not provided01/06/2025Not providedNot providedSENot provided0%Not provided0%01/06/20250%Not providedSI01/10/20230%20/05/20250%01/06/20250%01/06/2025SK01/06/20240%31/05/20250%02/06/20250%Not providedRespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)30/06/202202/10/202302/06/2025 
 
 
 
 
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
25. 

Figure 25: Percentage of Completion per Phase – CCI – Phase 1 

94 

 
 
 
 
 
Regarding  CCI  –  Phase  2,  additional  details  regarding  the  specific  percentage  of  completion  per 
milestone can be seen in Figure 26. 

Figure 26: Percentage of Completion per Phase – CCI – Phase 2 

95 

 
 
 
 
UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE 
4.6 
The  aim  of  this  project  is  to  align  the  existing  trans-European  New  Computerised  Transit  System 
(NCTS) to the UCC legal provisions. The scope of the project includes the alignment of information 
exchanges to UCC data requirements, the upgrade and development of interfaces with other systems 
such as AES in addition to new safety and security requirements. 

In terms of the planning approach, the project is divided into two components.  

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

NCTS – Phase 5 will meet the following objectives50: 

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

Model; 

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

Transit Convention (CTC) countries. 

Additionally, NCTS – Phase 5 will improve the following processes: 

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

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

  Strengthen the safety and security for entry/exit. 

Lastly, a number of new functionalities are being incorporated: 

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

Component  2,  the  “NCTS  -  Phase  6  (P6)”,  will  align  NCTS  to  the  new  provisions  set  by  the  UCC 
regarding  Advanced  Cargo  Information  for  Safety  and  Security,  while  continuing  the  practice  of 
Combined Declaration for the MS opting to offer this facilitation to their trade. It requires the set-up of 
an automated interface between NCTS and ICS2 to ensure that trade and MS can serve both the transit 
procedure and the Safety and Security formalities simultaneously with a single process for the benefit 
of  all.  The  time  line  of  NCTS  –  Phase  6  is  synchronised  with  the  one  of  ICS2  Release  3,  having  a 
transition window from 3 June 2024 till 1st March 2025 for the Member States to migrate from NCTS- 
Phase 5 to NCTS – Phase 6. 

It  is  important  to  highlight  that  the  NCTS  system  specifications  developed  by  the  Commission 
(Functional  System  Specifications  (FSS)  and  Technical  System  Specifications  (TSS))  cover  the 
information exchanges (IE) in the common, national, and external domains: 

  The  common  domain  communication  refers  to  the  information  exchanges  between  customs 

offices located in different Member States. 

  The  national  domain  includes  the  interface  between  national  NCTS  and  other  systems  at 

national level (e.g. AES-NCTS). 

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

96 

 
 
                                                      
  Finally, the external domain includes the communications between the customs offices and the 

declarant/trader at exit, at national level. 

Regarding  the  message  exchanges  on  the  common  domain,  the  NCTS  specifications  prepared  by 
DG TAXUD  are  mandatory  for  all  the  Member  States.  In  case  of  external  or  national  domain,  the 
common  NCTS  specifications  are  strongly  recommended,  aiming  to  harmonize  the  export  and  exit 
formalities as much as possible among the EU Member States. 

There are 36 National Administrations (NAs) currently in operation for NCTS: the 27 Member States, 
Northern Ireland under the terms of  the NIP, and the other 9 CTC Countries (Andorra, Switzerland, 
Republic  of  Serbia,  Republic  of  North  Macedonia,  Norway,  San  Marino,  Turkey,  Ukraine  (since 
1.10.2022), United Kingdom). There are also 3 acceding countries to the CTC Convention at various 
stage of preparation targeting a date of entry in operation: Montenegro for 01.06.2023, Georgia and 
Moldova targeting 2024. 

The following report addresses the progress and risks of the 27 Member States.  

On the basis of the information available at time of writing, Andorra, Switzerland, Republic of Serbia 
Norway and San Marino should be ready on time to enter the final provisions of NCTS by 01.12.2023. 
United Kingdom  (and  Northern  Ireland)  and Turkey  are  posing  a  risk  for  the  business continuity  of 
NCTS at this date because they opt for a “last day Big Bang” strategy while they are respectively #5 and 
#8 in the top countries in NCTS.  Republic of North Macedonia announced that they will not be ready 
in time and asked for a derogation. Montenegro will be ready on time but does not present a risk for the 
business continuity of NCTS. 

4.1.11  Summary of Responses 

NCTS – Component 1 

Summary from the Commission: 

For NCTS – Phase 5, the challenge is to ensure business continuity and a smooth transition for Member 
States  and  trade  while applying  significant changes  in  the  applicable  Data  and  Process  models. The 
Member  States  approved  a  new  set  of  specifications  which  will  rule  the  quality,  technical  support, 
business  continuity,  security  and  capacity  of  the  future  NCTS  –  Phase  5  operations  (Service 
Management,  Service  Level  Agreement,  Terms  of  Reference,  Crisis  management,  Capacity  Plan, 
Security Plan). So far,  no delays have materialised on the central components and the project is currently 
on track.  

The Commission and the Member States are engaged in an important transition for the trans-European 
customs systems for export and transit, starting with the successful deployment of the new UCC NCTS-
Phase 5 and UCC AES systems in DE in March 2021 and the successful entry in international operation 
of AES on 26 April 2022 by ES and DE. This opened the path to the next generation of interconnected 
trans-European systems for the trade community and the national customs authorities, demonstrating 
the  quality  of  the  Specifications  and  Legal  provisions  underpinning  these  two  systems  and  most 
importantly their business continuity. The new export and transit systems offer significant benefits and 
enable simplifications while ensuring the business continuity with the systems in operation so far. This 
important milestone has been achieved thanks to the close collaboration between the Commission and 
the national customs and trade associations.  

The NCTS - Phase 5 project pioneered a collaborative, iterative and agile working method that has been 
praised by all Member States and traders involved. The agile approach adopted since the start of the 
project pays off in terms of functional and technical quality and  of actual  progress of the MSs. The 
collective intelligence of the Member States is a critical asset for the success of the transition at stake. 

Increasing progress of the Member States in 2022 

97 

 
 
 
 
The  Member  States  have  booked  significant  progress  in  the  deployment  of  their  national  transit 
applications in 2022. 74% of the MSs are actively engaged in their implementation, while 70% of the 
Member  States  already  published  their  trader  specifications,  26%  of  the  Member  States  are  in  the 
procurement or inception stage, and almost ready to start - see Figure 28 below. 

The  Member  States  have  progressed  in  their  specifications  and  developments,  some  through  their 
Conformance Tests, other in their connectivity with the Central Services.  

The % of completion of the transition is at 48%, up by 18% since end 2021. 

Ramp up of the Conformance Tests in 2022 and entry in operation 

23% of the MS have already started their Conformance Tests.  

NCTS - Phase 5 is on track to start its international operation end 2022-early 2023 with DE, PL, IT, LU 
and SI.  

Shift of the national project plans to 2023 and beyond 
The plans of the Member States continue to drift closer to the deadline of the 01.12.2023 set by the UCC 
Work Programme.  

The transition faces a delay equivalent to 3 quarters as the % of completion of the transition should be 
at 72% according to the 2020 plan. 

All Member States but three re-confirm that they will be in operation before the 01.12.2023 deadline for 
the entry into the final provisions of the UCC as illustrated in  Figure 27.51 AT, LT and NL signalled 
their intention to enter in operation mid-2024. 

DE is the leading Member State, having entered national operation in March 2021, as planned. A group 
of  five  Member  States  (DE,  LU,  PL,  IT,  SI)  will  be  the  first  wave  of  Member  States  entering  into 
international operations end 2022 early 2023. The transition will spread over five quarters.  

Figure 27: NCTS – P5 National Administrations entry into operations as of 23 August 2022 

DG TAXUD assessed that 44% of the Member States’ plans pose challenges to the orderly and timely 
transition to the final provisions of the UCC by the 01.12.2023 and to the smooth transition of trade 
(Table 38 below). 

51 GR filed a request for derogation but has not modified its national project plan leading to entry in operation on the 01.12.2023. 

98 

 
 
 
 
                                                      
The main incentives for the Member States to keep the necessary focus on  NCTS – Phase 5 are the 
critical need for business continuity, the importance of Transit in a post Brexit EU, the early availability 
of  the  common  technical  specifications52  and  the  awareness  that  the  Return  on  Investment  of  each 
Member State and the value for Trade depend on the readiness of all other Member States. 

Recommendations to the Member States 

The  Commission  invited  the  Member  States  to  take  all  mitigation  actions  to  avoid  delaying  their 
readiness beyond the 01.12.2023 milestone set by the UCC Work programme. 

The  Member  States  at  risk  of  missing  the  deadline  or  already  signalling  an  entry  in  operation  after 
01.12.2023  should  take  advantage  of  the  remaining  5  quarters  before  the  deadline  to  speed  up  their 
implementation or to start working on their “plan-B” to secure their business continuity under the final 
provisions of the UCC.  

The Commission invited the Member States that have not yet done it, to publish their trade specifications 
without any delay and by the 3rd quarter 2022 at the latest.  

The Coordination programme 

Under the umbrella of the “National Administration coordination programme”, the Commission assists 
and monitors the development and deployment of the national components for NCTS – Phase 5 by the 
Members States. 90%+ of the Member States submit regular updates to their national project plans.  

The Trade community is kept regularly informed of the progress achieved and of the national project 
plans 

Summary from the Member States: 

NCTS  –  Phase  5  is  regarded  as  a  medium/high  complex  project due to the  dependencies  with  other 
systems,  high  availability  requirements  and  competing  priorities.  Despite  this,  the  vast  majority  of 
Member States have reported to remain on-track for 01.12.2023, the entry into the final provisions of 
the UCC set in the UCC Work Programme.  

Most Member States have reported a low/medium risk level on the on-time delivery of the project, with 
only a few of them rating it as high.  

The main risks reported relate to: 

  Delay in call for tender procedures, procurement and service providers; 
  Competing priorities and inter-dependencies within and outside the UCC Work programme i.e. 

eCommerce and ICS2; 

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

Many Member States have also informed that an agile development methodology was adopted in order 
to reduce the implementation timeframe. 

In terms of assessing the level of completeness of the system, half of the Member States that provided 
information  reported  that  the  system  is  on  target,  with  the  other  half  stating  that  currently  the 
development  of  the  system  is  being  delayed,  but  overall  the  deployment  is  still  planned  within  the 
deadline.  The  %  of  Completion  of  each  of  the  Member  States’  projects  according  their  respective 
national project plans is provided in Table 39 below. 

52 NCTS-P5 is the only project along with AES-P1 which has had its common technical specifications approved 4 years before 
the date of entry in operation. 

99 

 
 
                                                      
DE has been the first to deploy the system, having the end-date of the transition window for trader being 
shifted from end 2022 to June 2023 to allow maximum flexibility to migrate from NCTS-P4 to NCTS-
P5.  

A representative number of Member States have been either progressing or completing their Technical 
Specifications, with just a few Member States (BG, GR and SK) not yet initiating the activities. NL 
mentioned  that  according  to  their  planning,  the  project  is  currently  delayed  beyond  the  Deployment 
deadline, with all milestones being impacted. However mitigating measures are planned: minimisation 
of the scope, while using an agile approach on development.  

Detailed Responses: 

Table 37 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

4 

Low 

CY 

6 

Low 

CZ 

6 

Low 

DE 

6 

Low 

BG indicated that at the moment the Elaboration Phase is underway. By 
the end of the year it is expected that both the Elaboration Phase and the 
Construction  Phase  to  be  finished.  AES  and  NCTS  P5  are  expected  to 
have the implementation within the legal deadline. 
The analysis, the preparation of specifications, part of the implementation 
and part of the conformance testing of the system will take place in 2022. 
The public procurement process has been concluded and the contract has 
been signed with the contractor. The project initiation document has been 
agreed  and  the  relevant  project  plans  and  timelines  for  all  the  UCC 
systems have been updated and agreed.   
During  Q1  of  2022  CZ  has  been testing  the  new  system  internally  and 
correcting all the errors encountered. According to their National Project 
Plan a test environment for traders has been available since 01/03/2022 
and since this date they will be testing the commercial software. Mode 1 
of the Conformance Testing began in January 2022 and Mode 2 as of June 
2022. 
Partial deployment approach with limited functionality is not used for the 
system development, having in place a plan for a “big bang” method. 
The  Czech  Republic  will  start  operations  in  NCTS  –  Phase  5  on 
03/04/2023. The transitional period for traders will not be used. 
Regular meetings with the contractor are taking place on a weekly basis, 
where the progress in development is being evaluated. 
DE indicated that for NCTS – Phase 5 the Conformance Testing activities 
related  to  Mode  2  are  completed  and  ready  to  start  production.  The 
following  functionalities  will  be  deployed  until  the  end  of  2022:  (1) 
Update of the national interface Export followed by Transit; (2) Business 
Statistics (IE411C). 
DE is making use of an agile development approach in defined software 
release-cycles. The ongoing  activities concern the finalisation and fine-
tuning of NCTS – Phase 5, the monitoring of operations as well as the 
preparation  of  remaining  Conformance  Tests  for  new  functionalities 
(Export followed by Transit; IE411c) and the start of the Conformance 
Testing  (certification)  of  economic  operators.  As  soon  as 
the 
implementation of the UCC is completed, national work on the technical 
modernisation of the system is to be resumed (e.g. GUI modernisation; 
Change of Communications Protocols). 

100 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

The end-date of the transition window for trader has been shifted from end 
2022 to June 2023 to allow maximum flexibility to migrate from NCTS-
P4 to NCTS-P5. 

DK 

6 

Med 

EE 

ES 

FI 

6 

5 

6 

Med 

Med 

High 

FR 

4 

High 

DK  is  building  up  a  new  IT  Customs  Platform  for  Import,  Export  and 
Transit (incl. GMS) and a new portofolio of IT Supporting Systems ex. 
Control systems, Manifest, Taric etc.   
Conformance Testing with Economic Operators has not yet been decided, 
the  delay  being  related  to  the  connectivity  setup  and  to  the  fact  that 
releases of ERMIS have not yet been received. 
As a mitigating measure DK is developing a temporary CCN adapter in 
house,  however,  the  delivery  is  being  delayed  because  of  Contractor, 
ultimately increasing the level of risk on the delivery of the project. The 
degree of functionality for the ERMIS standard software is another cause 
for possible delays. 
The  above  mentioned  risks  will impact the  milestones  for  CT,  external 
and national domain. 
EE indicated that the procurement process is delayed with all milestones 
being impacted, in particular CT and Deployment. However, overall the 
delivery is still foreseen within the Deployment deadline. EE noted that 
all analysis is complete and mostly developed. At the time of writing the 
CT is ongoing. 
ES associated an increased risk level related to the delivery of the project, 
considering that it requires a high level of coordination between countries 
and a significant effort in transition management.  
According to ES the planning was updated, given that NCTS – Phase 5 
will be delivered after AES, with operations confirmed for 15/11/2023. 
The implementation of NCTS – Phase 5 is ongoing, with the Conformance 
Testing  activities  underway.  The  need  to  build  a  new  system  has  had 
impact  on  CT  and  Deployment,  therefore  delays  are  to  be  expected 
however the system is still foreseen to be delivered in a timely manner. 
FR  noted  that  there  will  be  an  anticipated  delay  of  Deployment  into 
production of 1 quarter regarding Phase 5. There are several causes: lack 
of human resources, delays on software on contractor’s side, changes in 
specifications  agreed  at  EU  level  and  lack  of  budget.  To  this  it  can  be 
added the fact that the current Transit application still needs an increased 
level  of  support  and  the  existing  competition  with  other  projects.  The 
milestones  related  to  Conformance  Testing  and  Deployment  will  be 
impacted.  Furthermore,  FR  stated  that  for  Phase  thare  are  5  iterations 
planned, implementing DTI mode from iteration 3 in order to avoid delay 
on Conformance Modes 1 and 2.  
It  was  emphasized  that  the  capability  for  completing  this  project  in  a 
timely manner, even before the expected deadline existed and still exists, 
however Phase 5 is not a priority for the French national administration. 
FR  concluded  by  saying  that  Export  followed  by  Transit  will  be 
implemented in 2023 with AES interface. 

101 

 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

GR 

6 

High 

HR 

5 

High 

HU 

IE 

5 

6 

Low 

Med 

IT 

5 

Med 

LT 

3 

Med 

LU 

LV 

MT 

3 

5 

Med 

Low 

GR noted that they are expecting an anticipated delay on finalisation of 
the  Technical  Specifications  of  2  quarters,  but  overall  the  system  is 
anticipated to be completed within the deployment deadline. A primary 
cause for delay is the actual delay in the call for tender procedures, with a 
particular  impact  on  Conformance  Testing  and  Deployment  activities. 
Internal discussions are underway in order to assess the situation. 
HR indicated that there will be an anticipated delay of Deployment into 
production of 1 quarter regarding Phase 5. 
The  system  is  considered  to  be  delayed,  but  overall  foreseen  to  be 
delivered within the Deployment deadline. A main cause identified was 
the  RFC's  that  have  been  introduced  to  be  implemented  late  in  the 
construction phase of NTA, which disrupted the testing process. 
HR explained that CT and Deployment in production are most impacted 
and that in order to meet the deadline of delivery they will have to first 
carry out the Conformance Testing campaign and afterwards to implement 
the large number of changes into NTA. This will create a clear view on 
the changes and if they are applied correctly. At the current stage, a new 
tender procedure is underway. 
HU  aspires  to  complete  the  development  phase  and  start  CT  Mode  1 
before  the  end  of  the  year.  Due  to  unforeseen  constraints,  the  2021 
planning schedule had to be revised and the dates of most national tasks 
and milestones have been delayed. 
IE mentioned that delays are possible given that the testing of AES and 
the Transition Handler (TH) will be complex and can create challenges, 
with  the TH  being  a  new  concept.  Internal  system  started  end  of  April 
2022 with Conformance Testing as of 13/06/2022. 
The project has a medium level of risk, given its success mainly depends 
on  the  development  and  conformance  testing  activities  performed  by 
economic operators to adapt their IT systems while respecting the planned 
deadline. 
The  major  change  made  to  the  2021  national  planning  concerns  the 
slippage  of  the  expected  date  of  deployment  of  the  system  from 
27/02/2023 to  08/05/2023. The delay is due to the greater effort requested 
for the implementation of the changes (RFCs) approved in 2021 and 2022. 
Both  AES  &  NCTS-P5,  were  planned  together,  with  the  national 
development completed and CT Mode 2 currently underway. 
According to LT, about 5 months were lost due to contractual difficulties 
related  to  an  unsuccessful  procurement.  The  national  plan  will  be 
amended  with  some  changes  to  the  dates  for  testing,  with  the  new 
deployment date set 01/10/2024. 
LU  expressed  that  for  NCTS-P5  they  expect  a  mid-December  delivery 
from their provider and a go-live date of 10/01/2023. 
A medium risk is associated with the delivery of the project, in particular 
concerning the deployment of the system. In order to prevent this from 
happening LV will deploy NCTS – Phase 5 with limited functionality.  
Both AES and NCTS – Phase 5 will be deployed in a “big bang” approach 
in October 2023. 
Regarding NCTS Phase 5 the migration window is towards the end of the 
deployment period, however the volume of transit declarations annually 
is  very  small,  therefore  issues  are  not  envisaged.  A  similar  situation 
applies for AES.  

102 

 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

NL 

5 

High 

PL 

5 

Med 

PT 

6 

High  

RO 

SE 

SI 

SK 

5 

5 

1 

High 

Low 

High 

For NCTS – Phase 5, NL announced a delay for deployment, with a new 
date  set  for  01/04/2024.  At  the  same  time,  NL  is  considering  using  a 
partial deployment approach.  
The Conformance Testing campaign is planned for the period 31/05/2022 
-01/09/2022. 
PL stated that the system is delayed, with the delivery foreseen within the 
Deployment  deadline  caused  by  prolonged  tendering  and  staff  related 
problems due to COVID-19 pandemic.  
In June 2022 PL will announce that is ready to start testing with economic 
operators  based  on  DDNTA  v5.14.  PL  will  also  inform  economic 
operators  that  a  decision  has  been  made  to  implement  the  production 
system  based  on  the  v5.15  specifications.  This  implementation  is 
envisaged for January 2023. The v5.15 specifications PL plans to publish 
in August/September 2022 with the list of changes to v5.14. 
Conformance  testing  will  be  performed  based  on  specifications  and 
scenarios (v.5.14), however additional CT testing will be needed for the 
changes resulting from specifications of v5.15. At the same time it was 
stated  that  integrations  with  other  national  systems  will  be  added 
gradually as those systems will be ready.  
The  Mode  1  of  CT  is  extended  due  to  preCT  and  internal  acceptance 
process. 
PT will perform national, external and common domain tests with Central 
Systems and Traders. PT indicated that there is a  risk related to delivery 
due to the need of an implementation of a completely new National Transit 
System.  An  agile  development  approach  will  be  used  to  reduce 
implementation timeframe. 
A “Big Bang” operation is scheduled for both AES Phase 1 and NCTS 
Phase 5 for 01/09/2023. The delay is mainly attributed due to delay of the 
tender. 
Conformance Testing will be based on ongoing connectivity tests. 
A  risk  for  delays  has  been  associated  with  the  timely  delivery  of  the 
project given that the hired contractor has implemented major changes to 
the  product  and  platform  at  a  very  late  stage,  causing  a  delay  of  three 
months compared to last years report. 
NCTS – Phase 5 will be deployed in February 2023 using a “big-bang” 
approach.  The  development  of  the  application  was  made  by  the 
combination of both the iterative and agile approaches. 
The system order is currently under discussions with an emphasis on the 
supplier. For both NCTS – Phase 5 and AES, SK is planning to deploy the 
systems by deadline in a “big bang” approach.  
It is expected to have the contract in place by the end of August, bearing 
a risk of delay considering the tight timeline.  

Table 37: Detailed responses from Member States – NCTS – P5 

103 

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

Table 38: Risk Assessment: NCTS – P5 

104 

 
 
 
 
 
Figure 28 provides the distribution of Member States in regards of the status of their interface with Trade 
and of their project implementation.  

Figure 28: Project Status as per latest national project plans – NCTS – P5 

105 

 
 
 
 
 
 
 
NCTS – Component 2 

Summary from the Commission: 

The aim of NCTS – Phase 6 is to complete the alignment of NCTS to the Safety & Security data specified 
in the latest releases of the UCC DA/IA Annex B. Phase 6 will also implement specific requirements in 
transit customs declarations of goods brought into the customs territory of the Union. The main goals 
are to secure the continuity of the long established practice of the combined declaration and to ensure a 
fully integrated management of the Safety and Security provisions of the UCC in NCTS to prevent a 
duplication of processes and systems for the trade and the MSs. NCTS - Phase 6 will interface with the 
ICS2 system to minimise the IT burden of the MS and trade. NCTS – Phase 6 will further harmonise 
the presentation process across all Customs Offices of the Member States, which is a major step forward. 
It  will  set  a  stepping  stone  for  future  Smart  Border  initiatives  between  Member  States  and  other 
neighbouring countries. 

An initiative was launched to perform a feasibility study on the interconnection between ICS2 and NCTS 
in April 2020, including an analysis of the Safety and Security (S&S) requirements and the possible 
implementation options. A survey was conducted to support the analysis of the current and the possible 
future  situation.  The  Feasibility  Study  proceeded  to  an  extended  analysis  of  the  potential  business 
processes  for  lodgment  and  processing,  as  well  as  amendment  and  invalidation  of  a  combined 
declaration,  incorporating  the  business  process  and  data  declaration  analysis  results.  The  outcome 
confirmed that the communication of ICS2 and NCTS - Phase 6 is feasible. The Feasibility Study was 
eventually translated into the Business Case by mid-2021. 

At the request of the Member States, the Business Case was suspended awaiting for the analysis of the 
technical  implications  of  the  proposals  made.  The  Member  States  requested  more  clarity  on  the 
implication for the Opt-in and Opt-out MSs regarding the option of the combined declaration facility 
that they might offer or not to their trade and regarding the interface between NCTS and ICS2 R3. 

A Technical Study conducted in the second half of 2021 with the Member States provided the expected 
clarifications and details. Via a technical survey, trade and Member States confirmed their support for 
the continuation of the Combined Declaration practice while emphasing the challenge to reconcile the 
expectations set by NCTS and the Safety and Security provisions of the UCC.  The deployment planning 
of ICS2 R3 and NCTS - Phase 6 were aligned to allow a progressive migration of the Member States 
from the current Safety & Security provisions of NCTS to the one set by the UCC Annex B from June 
2024 to March 2025. While considering the pressure growing on the milestone of NCTS - Phase 5, the 
use of the agile methodology should reduce the risks for all parties (parallel elaboration of the BPM and 
Technical Specifications). The Vision Document was produced on the basis of this Techncal Study end 
2021. 

The Business Case and Vision Document were approved in December 2021.  

Elaboration activities for the Technical System Specifications and the BPM are taking place in 2022, 
with functional and technical specifications being elaborated in parallel, in iterations. Preparatory steps 
are  taken  to  start  the  Conformance  Test  before  mid  2023.  However,  the  plans  for  the  Conformance 
Testing  and  Deployment  may  be  affected  by  some  Member  States  deploying  the  Phase  5  later  than 
planned. 

106 

 
 
 
 
4.1.12  Overview of Project Progress 

Table  39  highlights  any  known  divergences  in  the  planning  compared  to  the  dates  set  in  the  Work 
Programme53. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ columns 
are shown. If there is a difference in these two dates, this implies that a migration period is planned. 

Table 39: Comparison of Planned and Actual Dates – NCTS – P5 

The deployment of NCTS - Phase 5 shows a delay of 3 quarters in comparison with the initial national 
plans  filed  at  the  end  of  2020  (respectively  Earned  and  Planned  Value  in  the  figure  below54).  The 
deployment of NCTS - Phase 5 is currently at 48% (Earned Value) while it should be at 72% (Planned 
Value). The Member States will speed up their projects and contain their risks to reach the milestones 
of deployment by 1 December 2023. 

53 The percentage of deployment refers to DG TAXUD preparation and the aggregated progress of Member States based on 
their National Project Plans. 
54 The Planned and Earned Values are built on a basket of 12 key milestones across all the Member States 

107 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateEuropean CommissionNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedAT01/06/2021Not ProvidedN/ANot Provided30/06/202471%30/06/2024BE01/02/2020100%01/10/202250%01/06/202350%01/06/2023BG15/08/2022100%01/03/20230%28/08/202336%28/08/2023CY01/12/2022100%11/11/2022100%27/06/202333%17/07/2023CZ21/10/2021100%01/07/2022100%03/04/202358%03/04/2023DE26/10/2020100%18/01/2021100%01/10/202192%16/06/2023DK01/08/202275%10/09/202240%01/05/202350%30/08/2023EE31/05/2022100%01/12/202250%30/06/202350%30/06/2023ES30/06/2022100%01/05/202350%01/07/202345%15/11/2023FI07/12/2021100%03/10/202250%04/09/202325%29/09/2023FR30/11/2021100%15/01/202360%01/01/202350%01/12/2023GR31/10/2022100%02/05/20230%01/12/202325%01/12/2023HR31/12/2021100%01/09/2022100%01/04/202358%01/04/2023HU01/12/2022100%17/03/202310%30/08/202333%30/11/2023IE19/08/2022100%21/08/20230%21/08/202342%19/10/2023IT15/02/2021100%07/02/202290%14/09/202275%01/03/2023LT01/10/202390%26/02/202410%01/10/20240%01/10/2024LU01/06/2021Not Provided14/02/2022Not Provided01/10/202273%01/07/2023LV01/03/2021100%27/02/202350%02/10/202333%02/10/2023MTN/A100%07/03/202350%01/09/202344%01/12/2023NL01/10/2021100%01/04/20240%30/06/202473%01/06/2025PL31/05/2021100%08/06/2022100%16/01/202267%30/11/2023PT01/01/2023100%15/03/20230%01/12/202342%01/12/2023RO17/11/2022Not Provided30/05/2023Not Provided01/09/202325%01/09/2023SE01/12/2021100%23/02/20230%01/09/202329%01/09/2023SI15/02/2020100%10/01/2022100%01/02/202383%01/02/2023SK31/10/20220%15/09/20230%30/11/202311%30/11/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)31/12/201901/03/202101/12/2023 
 
  
 
 
 
 
                                                      
Figure 29: Conformance tests: Planned value versus earned value –KPI1- NCTS – P5 

Figure 30 below shows the percentage of Member States in Conformance Tests. The light grey curve 
(the planned Value) is the baseline set by the Member States’ plans end 2020 while the dark purple (the 
Earned, alias Actual, Value) is the one compiled from the latest NPP submitted before 23.08.2022. 

The figure below shows that the peak of Conformance Tests has shifted by 3 quarters from the baseline 
of  end  2020  and  raised  in  volume.  The  Conformance  Tests  bells  are  now  skewed  to  the  right  in 
comparison of the baseline, as late-runner MSs will complete their Conformance Tests campaigns during 
the last quarter of 2023. 

Figure 30: Conformance tests: Planned value versus earned value – KPI2-NCTS – P5 

108 

 
 
 
 
 
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
31.  

Figure 31: Percentage of Completion per Phase – NCTS – P5 

109 

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

Figure 32: NCTS – P5 Transitional Period 

110 

 
 
 
 
UCC AUTOMATED EXPORT SYSTEM (AES) 

4.7 
The AES project consists of an upgrade of both the existing trans-European Export Control System and 
the existing national export systems. It aims to implement the UCC requirements for export and exit of 
goods, including export and re-export declarations; EXS and centralised clearance for Export, re-export 
notifications  and  an  interface  with  EMCS  and  NCTS.  The  project  entails  implementing  the  UCC 
simplifications offered to trade to facilitate export of goods for European companies, such as centralised 
clearance for export, and the UCC obligations to better monitor what exits the customs territory of the 
Union to prevent fraud. The export declaration, and all linked message exchanges as well as the Arrival 
At Exit Notification and Exit Summary declaration are subject to considerable rework. The proposed 
message  structures  are  fully  convertible  from/to  “Legacy”/”To  Be”  ones,  guaranteeing  a  smooth 
transition and fostering business continuity from Q1 2021 until Q4 2023. 

The following processes will be implemented: 

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

In terms of planning, the system is comprised of two components.  

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

The  second  component  relates  to  the  “National  Export  Systems  upgrade”  and  aims  to  upgrade  the 
national systems used for the completion of certain formalities not impacting the common domain of 
the AES. 

It is important to highlight that the AES system specifications developed  at central level (Functional 
System  Specifications  (FSS)  and  Technical  System  Specifications  (TSS))  cover  the  information 
exchanges (IE) in the common, national, and external domains: 

  The  common  domain  communication  refers  to  the  information  exchanges  between  customs 

offices located in different Member States. 

  The national domain includes the interface between national AES and other systems at national 

level (e.g., AES-EMCS and AES-NCTS). 

  The  external  domain  includes  the  communications  between  the  customs  offices  and  the 

declarant/trader at exit, at national level. 

Regarding  the  message  exchanges  on  the  common  domain,  the  AES  specifications  prepared  by  DG 
TAXUD are mandatory for all the Member States. In case of external or national domain, the common 
AES specifications are strongly recommended, aiming to harmonize the export and exit formalities as 
much as possible among the Member States. 

The 27 Member States (and Northern Ireland under the NIP) are the parties in operation for the Export 
Control System (ECS). They all need to transition to the AES system by the 01.12.2023.  

111 

 
 
 
4.1.13  Summary of Responses 

AES – Component 1 

Summary from the Commission: 

For AES, the challenge is to ensure business continuity and smooth Member State and trade transition 
while  applying  significant  changes  in  the  applicable  Data  and  Process  models.  The  Member  States 
approved a new set of specifications which will rule 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).  So  far,    no  delays  have 
materialised on the central components and the project is currently on track.  

The Commission and the Member States are engaged in an important transition for the trans-European 
customs systems for export and transit, starting with the successful deployment of the new AES in DE 
in March 2021 and the successful entry in international operation of AES on the 26 April 2022 by ES 
and DE. This opened the path to the next generation of interconnected trans-European systems for the 
trade community and the national customs authorities, demonstrating the quality of the Specifications 
and legal provisions underpinning these two systems and most importantly their business continuity. 
The new export and transit systems offer significant benefits and enable simplifications while ensuring 
the business continuity with the systems in operation so far. This important milestone has been achieved 
thanks to the close collaboration between the Commission, the national customs administrations and the 
trade associations.  

The AES project pioneered a collaborative, iterative and agile working method that has been praised by 
all Member States and traders involved. The agile approach adopted since the start of the project pays 
off  in  terms  of  functional  and  technical  quality  and  of  actual  progress  of  the  Member  States.  The 
collective intelligence of the Member States is a critical asset for the success of the transition at stake. 

Start of AES operation 

The  highlight  of  2022  is  the  start  of  the  international  operation  for  AES  with  DE  and  ES  on  
26/04/2022. It happened without issue and the operation has been smooth since. The central Convertor 
ieCA  developed  and  operated  by  the  Commission  and  other  central  systems  deliver  according 
expectation. This major achievement is the result of 3+ years of the intense collaborative work between 
the Member States and the Commission. It opened the transition on the Common Domain. 

Increasing progress of the MS in 2022 

The  Member  States  have  booked  significant  progress  in  the  deployment  of  their  national  export 
applications in 2022. 74% of the Member States are actively engaged in their implementation, while 
52% of the Member States already published their trader specifications, 26% of the Member States are 
in the procurement or inception stage, and almost ready to start. Refer to Figure 33 below. 

The  Member  States  have  progressed  in  their  specifications  and  developments,  some  through  their 
Conformance Tests, other in their connectivity with the Central Services. The % of completion of the 
transition is at 48% up by 20% since end 2021.  

Ramp up of the Conformance Tests in 2022 and entry in operation 

33% of the MS have already started their Conformance Tests.  

PL, NL, IT, SI and HR will join the AES operation by end 2022 early 2023. 

Shift of the national project plans to 2023 and beyond 

The plans of the Member States continue to drift closer to the deadline of the 01.12.2023 set by the UCC 
Work Programme.  

The transition faces a delay of equivalent to 3 quarters as the % of completion of the transition should 
be at 71% according to the 2020 plan. Refer to Figure 33 below. 

112 

 
 
All Member States but three re-confirm that they will be in operation before the 01.12.2023 deadline for 
the entry into the final provisions of the UCC as illustrated in Figure 33. AT, FI and SE signalled their 
intention to enter in operation mid-2024 or in the second half of 2024. 

DE is the leading Member State, having entered national operation in March 2021, as planned.  

DE and ES started the international operation of AES-P1 on the 26/04/2022.  

A group of five Member States (NL, IT, PL, HR and SI) will be the first wave of Member States joining 
DE and ES into operations end 2022 - early 2023. The transition will spread over five quarters. 

Figure 33: AES – Component 1 National Administrations entry into operations as of 23 August 2022 

DG TAXUD assessed that 44% of the Member States’ plans pose challenges to the orderly and timely 
transition to the final provisions of the UCC by the 01.12.2023 and to the smooth transition of trade 
(Table 41: Risk Assessment: AES – Component 1). 

The main incentives for the Member States to prioritize AES are the critical need for business continuity, 
the  importance  of  Export  in  a  post  Brexit  EU,  the  early  availability  of  the  common  technical 
specifications55 and the awareness that the Return on Investment of each MS and the value for Trade 
depend from the readiness of  all other Member States. 

Recommendations to the Member States 

The  Commission  invites  the  Member  States  to  take  all  mitigation  actions  to  avoid  delaying  their 
readiness beyond the 01/12/2023 milestone set by the UCC Work programme. 

The  Member  States  at  risk  of  missing  the  deadline  or  already  signalling  an  entry  in  operation  after 
01.12.2023  should  take  advantage  of  the  5  quarters  remaining  before  the  deadline  to  spead  up  their 
implementation or to start working on their “plan-B” to secure their business continuity under the final 
provisions of the UCC.  

The Commission invited the Member States that have not yet done it, to publish their trade specifications 
without any delay and by the 3rd quarter 2022 at the latest.  

The Coordination programme 

55 NCTS-P5 is the only project along with AES-P1 which has had its common technical specifications approved 4 
years before the date of entry in operation. 

113 

 
 
 
 
                                                      
Under the umbrella of the “National Administration coordination programme” the Commission assists 
and monitors the development and deployment of the national  components for AES by the Member 
States.  90+%  of  Member  States  submit  regular  updates  to  their  national  project  plans.  The  Trade 
Community is kept regularly informed of the progress achieved and of the national project plans. 

Summary from the Member States: 

Regarding  AES  –  Component  1  most  Member  States  have  reported a  low/medium  risk  level  on  the 
on-time delivery of the project, with only a few of them rating it as high. The complexity of the system 
is being assessed as medium/high, given the many interdependences among systems. 

The main risks reported relate to: 

  Delay in call for tender procedures, procurement and service providers; 
  Competing priorities and inter-dependencies within and outside the UCC Work programme i.e. 

eCommerce and ICS2; 

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

Many Member States have also informed that an agile development methodology was adopted in order 
to reduce the implementation timeframe. 

In terms of assessing the level of completeness of the system,  more than half of the Member States 
reported  that  the  system  is  on  target,  with  the  others stating  that  currently  the  development  is  being 
delayed, but overall the Deployment is still foreseen within the provided deadline. The % of Completion 
of each of the Member States projects according their respective national project plans is provided in 
Table 43 below. 

DE completed the project development, with the following functionalities to be deployed until the end 
of  2022:  Centralised  Clearance,  Update  of  the  national  interface  Export  followed  by  Transit  and 
Business  Statistics  (IE411C).  FI  mentioned  that  according  to  their  planning,  the  project  is  currently 
delayed beyond the foreseen Deployment deadline, given several risks factors: the need to prioritize 
NCTS and other parallel projects, AES requiring many integrations, COVID-19 impact and shortage of 
resources especially on suppliers side.  

Detailed Responses: 

Table 40 provides the individual Member States’ responses to the survey: 

MS 

AT 
BE 
BG 
CY 
CZ 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

4 
6 
6 

Low  Same response as for NCTS – Phase 5. 
Low  Same response as for NCTS – Phase 5. 
Med  Same response as for NSP EXP. 

DE 

6 

Low 

DE indicated that for AES - Component 1 the Conformance Testing activities 
related to Mode 2 are completed and ready to start production. The following 
functionalities will be deployed until the end 2022: (1) Update of the national 
interface Export followed by Transit; (2) Business Statistics (IE411C). 
DE  is  making  use  of  an  agile  development  approach  in  defined  software 
release-cycles. The ongoing activities concern the finalisation and fine-tuning 
AES (e.g. adaptation of Surveillance), the monitoring of operations as well as 
the  preparation  of  remaining  Conformance  Tests  for  new  functionalities  of 
AES  (e.g.  centralised  clearance)  and  the  start  of  the  Conformance  Test 
(certification) of economic operators. 

114 

 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

DK 

EE 

ES 

FI 

FR 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

6 

5 

5 

6 

6 

6 

6 

6 

6 

5 

4 

4 

6 

NL 

4 

Low 

The end-date of the transition window for trader has been shifted from  end 
2022 to June 2023 to allow maximum flexibility to migrate from ECS-P2  to 
AES. 

Med  Same response as for NCTS – Phase 5. 

Med 

Low 

High 

Low 

EE mentioned that due to lack of financing for the development of the system, 
the delivery could be affected. 
For  AES  the  launch  for  common  domain  took  place  on  26/04/2022,  after 
finalising  testing  with  DE.  Testing  with  traders  on  the  external  domain  is 
underway.  ES  indicated  that  for  EXS  there  will  not  be  any  Office  of 
Lodgement available. 
At  the  same  time  an  iterative  approach  is  being  used  for  the  system 
development. 
According to FI national project plan, the AES system will be postponed, with 
a new feasible deadline set for 30/06/2024. The main causes identified are: the 
prioritisation  of  NCTS,  other  parallel  projects,  the  severe  impact  of  the 
COVID-19  pandemic  and  the  shortage  of  resources  especially  on  suppliers 
side. 
According to FR, AES will be split in 2 phases with one main release to ensure 
business  continuity,  and  subsequent  releases,  postponed  to  2024,  that  will 
cover the deployment of CCE, EXS and interfaces with EMCS and NCTS. 

High  Same response as for NCTS – Phase 5. 

Med 

HR  explained  that  the  RFC's  beeing  introduced  late  in  the  stage  of  the 
development  disrupted the testing process, ultimately impacting CT activities. 

Med  None. 

Med 

IE stated that Conformance Testing activities will be performed during 2022 
for AES – Component 1. Delays are possible given that the testing of AES and 
the  Transition  Handler  (TH)  can  create  challenges  due  to  their  complexity, 
considering that the TH is at the same time a new concept. Internal system 
started end of April 2022 with Conformance Testing as of 13/06/2022. 

Med   Same response as for NCTS – Phase 5. 

Med 

Med 

Med 

Due  to  complex  and  lenghty  service  procurement  procedures  the  system  is 
expected to be delayed, the impact being reflected on Conformance Testing 
and Deployment activities. However, the operation date of December 2023 is 
still feasible. 
For LU a go-live date of 15/10/2023 is being envisaged, while the pessimistic 
planning would be 01/10/2024. 
Same response as for NCTS – Phase 5.  
LV explained that Technical Specifications will not be provided considering 
the lack of the External Domain API. 

Numerous  activities  concerning  various  systems  happening  all  in  the  same 
period are affecting the delivery deadline, having Technical Specifications as 
the most impacted milestone. 
For  AES  they  split  the  work  for  export,  exit  and  centralised  clearance  for 
export (CCE). NL explained that the complexity level of the project is being 
influenced  by  the  fact  that  the  Export  and  the  Exit  are  being  supported  by 
different applications. In this light, Export is an upgrade of an existing system, 
while Exit is becoming a new application. Furthermore, many MASP-projects 
developments happening all at the same time and influencing each other are 
adding to the complexity of the system.  
The third part will be focused on the CCE, with a deployment date envisaged 
for  2025.  Conformance  Testing  and  Deployment  activities  for  CCE  are 

115 

 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

impacted. In this light, NL is considering combining CCE with CCI Phase 1 
and 2 in 2025. 
NL indicated that an agile approach is used for the system development, with  
current activities focused on finishing the features based on the current version 
of the DDNXA. 
PL  stated  that  the  key  factor  in  the  system  implementation  process  is  the 
necessity  of  connection  of  AES-P1  with  national  systems  developed 
simultaneously in customs administration. During the implementation of the 
new system, the project team registered several risks, such as the IT provider 
quality of service, the delay on software deliverables on contractor’s side or 
the lack of human resources on both sides. In this light, it is estimated that not 
all software providers  will manage to develop new client applications on time. 
At  the  same  time  the  COVID-19  pandemic  has  created  an  unstable 
environment, that has been impacted work progress across all systems. 
In 2021 PL has redefined their National Project Plan, having set Q4 2022 as a 
new date for implementation of AES-P1. The development of the project will 
consider both an agile and an iterative approach. 

PL 

5 

Med 

PT 
RO 

6 

SE 

4 

SI 

4 

SK 

3 

Low 

High  Same response as for NCTS – Phase 5. 
Same response as for NCTS – Phase 5. 
In the case of AES, SE had already advised a delay and this was confirmed 
with  deployment  now  planned  for  01/10/2024,  with  full  operations  by 
31/12/2024. 
The outlined national project plan for AES is being followed and according to 
SE comments the foundation for the system has been created with a plan to 
add the skeleton starting september 2022.  
Although  the  system  is  considered  to  be  complex  considering  all  the 
interdependencies  and  the  way  of  elaboration,  this  is  not  appreciated  as  a 
stopping activity. SE will avoid implementing a phased approach, given the 
possible cumbersome development and its impact on the timely delivery. 
The  first  version  of  SIAES2  (Slovenian  Automated  Export  System  -  2nd 
generation) was successfully installed in the test environment on 23/02/2022. 
The technical  documentation  is completed,  as  well  as  the  National  Domain 
Testing (Mode 0), the Conformance Testing activities for Mode 1 started May 
2022 and the development of the new export application is roughly complete. 
According to SI the deadline remains the same: 01/05/2023. 
SK explained that the system is considered to be delayed, however the delivery 
is still foreseen within the Deployment deadline. One of the primary causes is 
the lack of financial and human recources.  
At the current stage, the procurement on technical analysis is complete, with 
Conformance Testing activities planned for Q2 2023. 

High 

Low 

Table 40: Detailed responses from Member States – AES – Component 1 

The risk assessment of national project plans of the Member States by the Commission Services is shown 
and substantiated in the table below: 

116 

 
 
 
 
Table 41: Risk Assessment: AES – Component 1 

117 

 
 
 
 
 
Figure 34 provides the distribution of Member States in regards of the status of their interface with Trade 
and of their project implementation. 

Figure 34: Project status as per latest national project plans – AES – Component 1 

118 

 
 
 
 
 
 
AES – Component 2 

Summary from the Commission: 

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

Summary from the Member States: 

In relation to the on-time delivery of the project most Member States have reported a low/medium risk 
level, while only a few of them have rated it as high56. The complexity of the system is being assessed 
as medium/high, given the many interdependences among systems. 

Various reasons were provided as the cause, such as: 

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

eCommerce and ICS2; 

  Lack of resources (staff & budget); 
  The COVID-19 pandemic; 
  Transition; 
  Delay in call for tender procedures; 
  Delay from the traders. 

Some Member States have also informed that an agile development methodology is adopted in order to 
reduce the implementation timeframe, while a significant number prefer an iterative approach.  

In terms of assessing the level of completeness of the system,  more than half of the Member States 
reported  that  the  system  is  on  target,  with  the  others stating  that  currently  the  development  is  being 
delayed, but overall the Deployment is still foreseen within the deadline (CZ, DK, GR, LT and SK). FI 
mentioned  that  according  to  their  planning,  the  project  is  currently  delayed  beyond  the  foreseen 
Deployment deadline, given several risks factors: the need to prioritize NCTS and other parallel projects, 
with  AES  requiring  many  integrations,  COVID-19  impact  and  shortage  of  resources  especially  on 
suppliers side.  

A representative number of Member States have been either progressing or completed their Technical 
Specifications, while BG, GR, LT, MT and SK have not yet initiated the activities related to them. At 
the same time LV explained that they will not have External Domain API, therefore will not proceed in 
providing Technical Specifications for Trade. 

Detailed Responses: 

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

MS 

AT 
BE 
BG 
CY 
CZ 

DE 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

4 

6 

6 

Low  Same response as for AES – Component 1. 

Med  Same response as for AES – Component 1. 

Low 

According  to  DE  the  trans-European  AES  is  developed  together  with  the 
national export component and corresponds to the national release AES 3.0.1 
The  acceptance  test  AES  3.0.1  started  on  18/01/2021  and  was  carried  out 
without interruption until 05/03/2021. 

56 FI, HU, PT and SK. 

119 

 
 
 
 
 
 
 
 
 
 
 
                                                      
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

DK 
EE 

ES 

FI 

FR 
GR 

HR 

HU 
IE 

IT 

LT 
LU 
LV 
MT 

NL 

PL 
PT 
RO 
SE 
SI 
SK 

6 
5 

5 

6 

6 
6 

5 

6 
5 

3 

4 

4 
5 

5 
6 

4 
4 
3 

The information related to AES – Component 1 is relevant for this section as 
well. 

Med  Same response as for AES – Component 1. 
Med   Same response as for AES – Component 1. 

Low 

High 

ES  indicated  that  improvements  have  been  made  to  the  NPP.  An  iterative 
approach will be used for the system development. 
FI indicated that they are expecting a delay of 5 quarters on completion of the 
Conformance Testing activities and on Deployment into production. 
Additional  information  can  be  found  under  the  section  dedicated  to  AES  – 
Component 1. 

Low   Same response as for AES – Component 1. 
High  Same response as for AES – Component 1. 

Low 

HR explained that Component 2 will be developed in parallel with Component 
1. All the functionalities that have been defined at this current stage, are being 
developed, with the rest to be completed by the end of the year. 

High  None. 
Med  Same response as for AES – Component 1. 

Low 

According to Italy’s NPP for Component 2 national Conformance Testing will 
be  performed  and  the  deployment  has  been  updated  compliant  to  the  new 
deployment  date  of  AES  Component  1.  Therefore,  the  new  date  for  AES  -  
Component 2 has been postponed from 27/02/2023 to 08/05/2023. 

Med  Same response as for AES – Component 1. 

Med  Same response as for AES – Component 1.since  
Low  None. 

A partial deployment approach with limited functionality is envisaged, with the 
first part being focused on the adjustment to Annex B and a deployment date set 
for the end of 2022. Second part will be related to the new UCC-functionalities 
excluding  CCE  (deployment  date  set  for  2023).  NL  explained  that  the 
complexity level of the project is being influenced by the fact that the Export 
and the Exit are being supported by different applications. In this light, Export 
is an upgrade of an existing system, while Exit is becoming a new application. 
Furthermore,  many  MASP-projects  developments  happening  all  at  the  same 
time and influencing each other are adding to the complexity of the system. 

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

Low  Same response as for AES – Component 1. 
Low  Same response as for AES – Component 1. 
High  Same response as for AES – Component 1. 

Table 42: Detailed responses from Member States – AES – Component 2 

120 

 
 
 
 
 
 
 
 
 
 
 
 
Figure 34 provides the percentage of Member States in each development phase. 

Figure 34: Project Status as per Survey – AES – Component 2 

4.1.14  Overview of Project Progress 

Table  43  highlights  any  known  divergences  in  the  planning  compared  to  the  dates  set  in  the  Work 
Programme. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ columns are 
shown. If there is a difference in these two dates, this implies that a migration period is planned.  

Table 43: Comparison of Planned and Actual Dates – AES – Component 1 

121 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateEuropean CommissionNot providedNot providedNot providedNot providedNot providedNot providedNot providedATN/AN/AN/AN/A30/06/20240%30/06/2024BE01/02/2020Not provided01/02/2023Not provided01/09/202350%01/09/2023BG15/08/2022100%01/03/20230%28/08/202336%28/08/2023CY01/11/2022100%27/10/202230%04/07/202333%04/07/2023CZ21/10/2021100%03/10/202280%03/04/202358%03/04/2023DE26/10/2020100%18/01/2021100%01/10/202192%16/06/2023DK01/08/202275%10/09/202250%01/05/202350%30/08/2023EE31/05/202280%01/12/202220%30/06/202350%30/06/2023ES15/04/2021100%18/10/2021100%03/10/2022100%30/04/2023FI07/12/2021100%09/01/202330%25/05/202433%21/06/2024FRN/A100%14/08/20230%02/10/202327%01/12/2023GR31/10/202250%02/05/20230%01/12/202425%01/12/2023HR31/12/2021100%01/07/2022100%01/01/202367%01/01/2023HU31/01/202380%01/03/20230%30/08/202333%30/08/2023IE28/01/2022100%13/06/2022100%30/01/202367%30/03/2023IT15/02/2021100%07/02/202290%14/09/202275%01/03/2023LT04/05/202395%02/06/20230%01/12/202317%01/12/2023LU01/01/2023Not provided01/03/2023Not provided15/10/202317%15/11/2023LVN/AN/A27/02/202350%02/10/202318%02/10/2023MTN/A100%07/03/202350%01/09/202344%01/12/2023NL01/12/2021100%23/08/2023100%03/12/202275%30/08/2023PL31/05/2021100%02/08/2022100%16/01/202367%30/11/2023PT15/09/2022100%15/03/20230%01/12/202350%01/12/2023RO17/11/2022Not provided30/05/2023Not provided01/09/202325%01/09/2023SE01/09/20220%01/10/20230%01/10/202436%20/12/2024SI06/04/2021100%01/08/202290%01/05/202375%01/05/2023SK31/10/202295%15/09/20230%30/11/202333%30/11/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)31/12/201901/03/202101/12/2023 
 
 
 
  
The deployment of AES shows a delay of 3 quarters in comparison with the initial national plans filed 
at the end of 2020 (respectively Earned and Planned Value in the figure below57). The deployment of 
AES is currently at 48% (Earned Value) while it should be at 71% (Planned Value). The Member States 
will speed up their projects and contain their risks to reach the milestones of 1 December 2023. 

Figure 35: Key milestones: Planned value versus earned value – AES – Component 1 

The Figure 36 below shows the percentage of Member States in Conformance Tests. The light grey 
curve (the planned Value) is the baseline set by the MSs plans end 2020 while the dark purple (the 
Earned, alias Actual, Value) is the one compiled from the latest national project plans submitted before 
23.08.2022. 

The figure below shows that the peak of Conformance Tests has shifted by 3 quarters from the baseline 
of end 2020. The Conformance Tests bells are now skewed to the right in comparison of the baseline, 
as late-runner MSs will complete their Conformance Tests campaigns during the last quarter of 2023. 

Figure 36: Conformance Tests: Planned value versus earned value – AES – Component 1 

57 The Planned and Earned Values are built on a basket of 12 key milestones across all the Member States 

122 

 
 
 
 
                                                      
In regards to the implementation AES – Component 2, SE has a planned deployment date that is later 
than the deadline in the UCC Work Programme. 

Table 44: Comparison of Planned and Actual Dates – AES – Component 2 

123 

Target date from WP 2022 Planned/ Actual End Date2022 % of Completion2022 Planned/ Actual End Date2022 % of Completion Target date from WP 2022 Planned/ Actual Date2022 % of Completion Target date from WP2022 Planned/ Actual DateATNot ProvidedNot ProvidedNot ProvidedNot Provided30/06/2024Not Provided30/06/2024BE01/09/2021Not Provided01/09/2023Not Provided01/09/2023Not Provided01/09/2023BG14/11/2022100%18/08/20230%30/08/20230%30/08/2023CY01/11/2022100%02/06/202330%04/07/20230%04/07/2023CZ21/10/2021100%02/04/202380%03/04/202380%03/04/2023DE06/03/2021100%16/06/2023Not Provided06/03/2021100%16/06/2023DK01/08/202275%30/08/202350%01/05/20230%30/08/2023EE31/03/202280%01/06/202320%30/06/20230%30/06/2023ES15/04/2021100%30/04/2023100%22/01/2022100%30/04/2023FI30/06/2023100%30/06/202430%30/06/202445%30/06/2024FR13/01/2022100%30/09/20230%31/12/20230%01/12/2023GRDelayed50%Not Provided0%31/12/20220%31/12/2022HR31/12/2021Not Provided31/12/2022100%01/01/2023100%01/01/2023HU31/01/202380%31/08/20230%31/08/20230%01/12/2023IE28/01/2022100%30/03/2023100%31/01/20230%31/03/2023IT15/02/2021100%30/06/202290%05/09/20220%15/11/2023LT04/05/202395%01/12/20230%01/12/20230%01/12/2023LU01/02/2023Not Provided30/06/2024Not Provided30/06/2024Not Provided30/06/2024LVN/AN/A30/09/202350%02/10/202375%02/10/2023MT31/03/20230%31/10/20230%15/11/20230%15/11/2023NL22/06/2021100%30/08/2023100%03/12/202250%30/08/2023PL31/05/2021100%01/09/2022100%16/01/2023100%30/11/2023PT31/12/2022100%01/08/20230%01/12/20230%01/12/2023RONot ProvidedNot Provided31/08/2023Not Provided15/05/2023Not Provided31/08/2023SE01/12/20230%20/12/20240%01/10/20240%20/12/2024SI18/12/2020100%28/02/202390%01/05/20230%01/05/2023SK01/01/202395%30/11/20230%01/12/20230%Not ProvidedRespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)To be defined by MS01/03/202101/12/2023 
 
 
 
 
 
 
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
36.  

Figure 37: Percentage of Completion per Phase – AES – Component 1 

124 

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

Figure 38: AES – Component 1 Transitional Period 

125 

 
 
 
 
 
Regarding AES - Component 2, additional details regarding the specific percentage of completion per 
milestone can be seen in Figure 38. 

Figure 39: Percentage of Completion per Phase – AES – Component 2 

126 

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

Figure  39  provides  a  visual  overview  of  the  planning  of  the  UCC  Work  Programme  projects.  The 
overview  provides  the  timeline  of  the  development  of  the  projects.  The  “N”  symbol  identifies  the 
national projects. The other projects are related to trans-European systems, which might have a central 
or decentralised architecture. 

Figure 40: Planning Overview: UCC Work Programme Projects  

127 

 
 
 
 
 
6.  ANNEX 2 – ACRONYMS, ABBREVIATIONS & KEY TERMS 

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

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

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

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

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

128 

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

T2LF 

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

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

Table 45: Abbreviations and Acronyms 

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