COMMISSION STAFF WORKING DOCUMENT Accompanying the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278(a) of the Union Customs Code, on progress in developing the electronic systems provided for under the Code during 2023
Date: 2024-09-09
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, 9.9.2024  SWD(2024) 214 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278(a) of the Union Customs Code, on progress in developing the electronic systems provided for under the Code during 2023 {COM(2024) 395 final}  
 
 
TABLE OF CONTENTS 

1. 

Introduction ..................................................................................................................................... 4 

2.  Projects Completed before 2023 ..................................................................................................... 7 

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

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

2.3.  UCC DIRECT TRADER ACCESS TO THE EUROPEAN INFORMATION SYSTEMS 
(UUM&DS) ..................................................................................................................................... 9 

2.4.  UCC  ECONOMIC  OPERATOR  REGISTRATION  AND  IDENTIFICATION  SYSTEM 
UPGRADE (EORI2) ..................................................................................................................... 10 

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

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

2.7.  UCC AUTHORISED EOS (AEO) UPGRADE ................................................................ 13 

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

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

3.  Projects to be completed by the end of 2023 ................................................................................. 16 

3.1.  UCC  NOTIFICATION  OF  ARRIVAL  (AN),  PRESENTATION  NOTIFICATION  (PN) 
AND TEMPORARY STORAGE (TS) ......................................................................................... 16 

3.2.  UCC NATIONAL IMPORT SYSTEMS (NIS) UPGRADE ............................................ 39 

3.3.  UCC SPECIAL PROCEDURES – COMPONENT 1 (SP EXP) ...................................... 47 

3.4.  UCC SPECIAL PROCEDURES – COMPONENT 2 (SP IMP) ....................................... 54 

3.5.  UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 2 ....................................... 61 

3.6.  UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) – PHASE 1 ....................... 69 

(NCTS)  UPGRADE  – 
3.7.  UCC  NEW  COMPUTERISED  TRANSIT  SYSTEM 
COMPONENT 1 ........................................................................................................................... 78 

3.8.  UCC AUTOMATED EXPORT SYSTEM (AES) ............................................................ 94 

4.  Ongoing Projects: Detailed Planning and progress Information ................................................. 114 

4.1.  UCC GUARANTEE MANAGEMENT (GUM) ............................................................. 114 

4.2.  UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 3 ..................................... 121 

4.3.  UCC PROOF OF UNION STATUS (POUS) ................................................................. 128 

4.4.  UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) – PHASE 2 ..................... 137 

4.5.  UCC  NEW  COMPUTERISED  TRANSIT  SYSTEM 
(NCTS)  UPGRADE  – 
COMPONENT 2 ......................................................................................................................... 144 

Annex 1 – Planning Overview – UCC Work Programme Projects ..................................................... 147 

Annex 2 – Acronyms, Abbreviations & Key Terms ........................................................................... 148 

1 

 
 
 
 
 
 
Table of Figures 

Figure 1: Project Status as per Survey – AN ......................................................................................... 21 
Figure 2: Project Status as per Survey – PN .......................................................................................... 27 
Figure 3: Project Status as per Survey – TS .......................................................................................... 32 
Figure 4: Percentage of Completion per Phase – AN ............................................................................ 36 
Figure 5: Percentage of Completion per Phase – PN ............................................................................ 37 
Figure 6: Percentage of Completion per Phase – TS ............................................................................. 38 
Figure 7: Summary of Survey Responses – NIS ................................................................................... 44 
Figure 8: Percentage of Completion per Phase – NIS ........................................................................... 46 
Figure 9: Project Status as per Survey – SP EXP .................................................................................. 51 
Figure 10: Percentage of Completion per Phase – SP EXP .................................................................. 53 
Figure 11: Project Status as per Survey – SP IMP ................................................................................ 58 
Figure 12: Percentage of Completion per Phase – SP IMP ................................................................... 60 
Figure 13: Summary of Survey Responses – ICS2-R2 ......................................................................... 66 
Figure 14: Percentage of Completion per Phase – ICS2-R2 ................................................................. 68 
Figure 15: Summary of Survey Responses – CCI-P1 ........................................................................... 75 
Figure 16: Percentage of Completion per Phase – CCI-P1 ................................................................... 77 
Figure 17: NCTS-P5 timeline ................................................................................................................ 79 
Figure 18: NCTS-P5 National Administrations entry into Operation as of 17 September 2023 .......... 81 
Figure 19: Conformance tests: Planned value versus earned value – KPI1 – NCTS-P5....................... 91 
Figure 20: Conformance tests: Planned value versus earned value – KPI2 – NCTS-P5....................... 92 
Figure 21: Percentage of Completion per Phase – NCTS-P5 ................................................................ 93 
Figure 22: NCTS-P5 Transitional Period .............................................................................................. 94 
Figure 23: AES-C1 timeline .................................................................................................................. 96 
Figure 24: AES-C1 Member States entry into Operations as of 17 September 2023 ........................... 99 
Figure 25: Key milestones: Planned value versus earned value – KPI1 – AES-C1 ............................ 109 
Figure 26: Conformance Tests: Planned value versus earned value – KPI2 – AES-C1 ..................... 110 
Figure 27: Percentage of Completion per Phase – AES-C1 ................................................................ 112 
Figure 28: AES-C1 Transitional Period .............................................................................................. 113 
Figure 29: Percentage of Completion per Phase – AES-C2 ................................................................ 114 
Figure 30: Summary of Survey Responses – GUM-C2 ...................................................................... 119 
Figure 31: Percentage of Completion per Phase – GUM-C2 .............................................................. 121 
Figure 32: Summary of Survey Responses – ICS2-R3 ....................................................................... 126 
Figure 33: Percentage of Completion per Phase – ICS2-R3 ............................................................... 128 
Figure 34: Percentage of Completion per Phase – PoUS-P1 ............................................................... 136 
Figure 35: Percentage of Completion per Phase – PoUS-P2 ............................................................... 137 
Figure 36: Summary of Survey Responses – CCI-P2 ......................................................................... 142 
Figure 37: Percentage of Completion per Phase – CCI-P2 ................................................................. 144 
Figure 38: NCTS-P6 timeline .............................................................................................................. 145 
Figure 39: Planning Overview: UCC WP Projects ............................................................................. 148 

2 

 
 
Table of Tables  

Table 1: Comparison of Planned and Actual Dates – REX-R1 ............................................................... 7 
Table 2: Comparison of Planned and Actual Dates – CDS ..................................................................... 8 
Table 3: Comparison of Planned and Actual Dates – UUM&DS ........................................................... 9 
Table 4: Comparison of Planned and Actual Dates – EORI2 ............................................................... 10 
Table 5: Comparison of Planned and Actual Dates – SURV3 .............................................................. 11 
Table 6: Comparison of Planned and Actual Dates – BTI .................................................................... 12 
Table 7: Comparison of Planned and Actual Dates – AEO upgrade ..................................................... 13 
Table 8: Comparison of Planned and Actual Dates – INF .................................................................... 14 
Table 9: Comparison of Planned and Actual Dates – ICS2-R1 ............................................................ 15 
Table 10: Detailed responses from Member States – AN ..................................................................... 21 
Table 11: Detailed responses from Member States – PN ...................................................................... 27 
Table 12: Detailed responses from Member States – TS ...................................................................... 31 
Table 13: Comparison of Planned and Actual Dates – AN ................................................................... 33 
Table 14: Comparison of Planned and Actual Dates – PN .................................................................... 34 
Table 15: Comparison of Planned and Actual Dates – TS .................................................................... 35 
Table 16: Detailed responses from Member States – NIS..................................................................... 44 
Table 17: Comparison of Planned and Actual Dates – NIS .................................................................. 45 
Table 18: Detailed responses from Member States – SP EXP .............................................................. 50 
Table 19: Comparison of Planned and Actual Dates – SP EXP ............................................................ 52 
Table 20: Detailed responses from Member States – SP IMP .............................................................. 57 
Table 21: Comparison of Planned and Actual Dates – SP IMP ............................................................ 59 
Table 22: Detailed responses from Member States – ICS2-R2 ............................................................. 66 
Table 23: Comparison of Planned and Actual Dates – ICS2-R2........................................................... 67 
Table 24: Detailed responses from Member States – CCI-P1 ............................................................... 75 
Table 25: Comparison of Planned and Actual Dates – CCI-P1 ............................................................ 76 
Table 26: Detailed responses from Member States – NCTS-P5 ........................................................... 87 
Table 27: Risk Assessment by the Commission: NCTS-P5 .................................................................. 89 
Table 28: Comparison of Planned and Actual Dates – NCTS-P5 ......................................................... 90 
Table 29: Detailed responses from Member States – AES-C1 ........................................................... 104 
Table 30: Risk Assessment by the Commission: AES-C1 .................................................................. 105 
Table 31: Detailed responses from Member States – AES-C2 ........................................................... 107 
Table 32: Comparison of Planned and Actual Dates – AES-C1 ......................................................... 108 
Table 33: Comparison of Planned and Actual Dates – AES-C2 ......................................................... 111 
Table 34: Detailed responses from Member States – GUM-C2 .......................................................... 119 
Table 35: Comparison of Planned and Actual Dates – GUM-C1 ....................................................... 120 
Table 36: Comparison of Planned and Actual Dates – GUM-C2 ....................................................... 120 
Table 37: Detailed responses from Member States – ICS2-R3 ........................................................... 125 
Table 38: Comparison of Planned and Actual Dates – ICS2-R3......................................................... 127 
Table 39: Detailed responses from Member States – PoUS-P1 .......................................................... 132 
Table 40: Detailed responses from Member States – PoUS-P2 .......................................................... 134 
Table 41: Comparison of Planned and Actual Dates – PoUS-P1 ........................................................ 135 
Table 42: Comparison of Planned and Actual Dates – PoUS-P2 ........................................................ 135 
Table 43: Detailed responses from Member States – CCI-P2 ............................................................. 142 
Table 44: Comparison of Planned and Actual Dates – CCI-P2 .......................................................... 143 
Table 45: Comparison of Planned and Actual Dates – NCTS-P6 ....................................................... 147 
Table 46: Abbreviations and Acronyms .............................................................................................. 150 

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. Different completion deadlines were scheduled 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 the business case, business process modelling,  Vision Document (VIS) 
and Conformance Testing are defined in the Multi-Annual Strategic Plan for Customs (MASP-C).  

The  first,  second,  third  and  fourth  UCC  Annual  Progress  Report 4 were  published  on  13/12/2019, 
14/12/2020, 14/12/2021 and 10/02/2023, respectively. 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 2023, 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 Directorate General for Taxation and Customs Union (DG TAXUD). 

This annual report covers a reflection of the progress status achieved on 30 June 2023 with more 
recent updates in several cases including a view on the expected progress by 31 December 2023 in 
order to have a full picture of the progress made in 2023. 

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 
additional progress reporting information by means of an EU survey launched in March 20235, and the 
bilateral high-level meetings between DG TAXUD and the Member States Customs IT Directorates on 
the state of play of 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 

1 In the context of this report, ‘The Commission’ refers to the European Commission. 
2 External communication with the EOs. 
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/EN/ALL/?uri=CELEX:52021DC0791; 
2022: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52020DC0806. 
5 The information was collected between March 2023 and June 2023. 

4 

 
 
 
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.  

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 light of 
the upcoming deadlines for several projects. From this perspective, UCC Notification of Arrival (AN), 
UCC  Presentation  Notification  (PN),  UCC  Temporary  Storage  (TS),  UCC  National  Import  Systems 
(NIS)  Upgrade,  UCC  Special  Procedures  –  Component  1  (SP  EXP),  UCC  Special  Procedures  – 
Component  2  (SP  IMP),  UCC  Import  Control  System  2  –  Release  2  (ICS2-R2),  UCC  Centralised 
Clearance  for  Import  –  Phase  1  (CCI-P1),  UCC  New  Computerised  Transit  System  upgrade  – 
Component 1 (NCTS-P5) and UCC Automated Export System (AES) are planned to be in Operation by 
the end of 2023. 

In view of all this, it can be seen that constant communication has been maintained with the Member 
States  in  order  to  monitor  regularly  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 consider that the seventeen electronic systems listed in 
the UCC WP are divided into three categories:  

i) 

ii) 

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; 

iii)  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 they are 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 are entirely completed, an overview of the project 

progress, a summary of the survey responses and; 

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

provided, along with a summary of the responses from the survey. 

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 to medium complexity and 5 and 6 to 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; 

•  For those projects for which a derogation was granted (AN, PN, TS, NIS, SP IMP and ICS2-
R2) details regarding the progress towards meeting the new legal deadline provided for in the 
derogation and; 

•  Lessons learnt during the development of the project on what worked well and what did not 
with regards to the progress and potential delays to the project and what additional assistance 
or support would the Member States like to receive from the Commission for the period 2023-
2025. 

In the EU’s survey section devoted to lessons learnt and support and assistance from the Commission, 
Member States provided the Commission with findings in relation to the development of the project. 

5 

 
 
These remarks  provide useful guidance for improving the future performance of the systems for the 
period 2023-2025 and facilitating the development of the projects. This information has been collected 
and will be presented to the Member States and the EOs for more in-depth discussion.  

As  lessons  learnt  and  best  practices,  the  following  was  reported  by  the  Member  States.  Good 
teamwork  and  trustful  cooperation  both  at  the  EU  and  national  level  and  with  all  the  stakeholders 
involved (EOs, IT team, contractors, etc.) has been essential to ensure completion of the projects. The 
Member States pointed out the importance of the scoping phase, in the context of close collaboration 
among several of them. In regard to the involvement of the EOs, communication needs to be clear to get 
the message across and ensure that the information is effectively disseminated. With respect to tendering 
and  procurement  procedures,  relationships  with  contractors  have  proven  fundamental,  to  ensure  the 
smooth development of the system. Consequently, documentation has to be well-suited to facilitate good 
quality work and procedures should start to be implemented sufficiently in advance to avoid delays. 
Automation of processes is another key area in which Member States highlighted the need to have access 
to information, analyse the topic in-depth and carry out testing to establish the most accurate functional 
requirements. In this line, the automation of regression tests has been valuable. With respect to planning, 
Member States emphasised the importance of planning phases ahead and setting out realistic deadlines 
taking  into  account,  not  only  the  national  capacity  (i.e.,  resources  available),  but  also  that  of  other 
stakeholders involved (developers, EOs, etc.). Member States would appreciate longer Conformance 
Testing and transitional phases. Finally, Member States indicated the importance of financial planning 
to ensure the availability of resources throughout the development of the systems. 

Regarding the support and assistance received from the Commission, Member States indicated that the 
continued technical dialogue with DG TAXUD is useful and appreciated the support and information 
provided for by the Commission. Member States assessed webinars and information sharing activities 
as valuable and indicated that they would benefit from further support and timely information from the 
Commission, such as guidelines and extensive trainings covering all aspects related to the systems. In 
this  line,  Member  States  would  welcome  further  bilateral  meetings,  timely  updates  of  operational 
guidelines and IT and business assistance for EOs, customs administrations and other stakeholders from 
the Commission. As a closing remark, Member States indicated that a centralised initiative from the 
Commission to gather and disseminate lessons learnt, best practices and common errors of EOs and 
National Administrations would facilitate the development of the projects.  

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  2022, are  the main  outcomes  of the  progress  reporting 
exercise  for  2023  and  are  included  in  this  Commission  Staff  Working  Document.  Reporting 
information that summarises the current project status, key risks and mitigating actions is found in the 
Report from the Commission to the European Parliament and the Council pursuant to Article 278a 
of the UCC, 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 2023; 
•  Section 3: Projects to be completed by the end of 2023; 
•  Section 4: Projects ongoing during 2023.  

6 

 
 
 
 
2.  PROJECTS COMPLETED BEFORE 2023 

2.1. UCC REGISTERED EXPORTER SYSTEM (REX) 

The UCC Registered Exporter System (REX) is a trans-European system that contains information both 
on Registered Exporters established in Generalised Scheme of Preferences (GSP) countries6 and on EU 
EOs in partner countries Switzerland (CH), Norway (NO) and Türkiye (TR) 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.  REX – Release 1 (REX-R1) was the only release covered in the 
scope of the UCC WP. No risks were identified during the implementation of REX-R17 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 2023:  

•  The REX Trader Portal (TP), as part of the EU Customs Trader Portal (EU CTP) was 

launched on 25 January 2021; 

•  The REX Partner Country release to add a user-interface for Norway, San Marino and 

Andorra to use REX was launched on 2 February 2023; 

•  Development of the REX 4.0 technical major release is ongoing, aiming to migrate all the 

REX modules to the eUI technology; 

•  73,191 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; 

•  98,931 active REX registrations for Member States (REX MS) module (including 782 

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

•  7,797 applications submitted by the EU Traders in the REX Specific TP; 
•  759 T-REX Local Users are configured in T-REX module and able to use REX BC; 
•  415 T-REX Local Administrators are configured in T-REX module and can manage Local 

Users. 

2.1.1.  Overview of Project Progress 

Table 1 compares the actual dates to those set in the UCC WP. Despite there being a slight delay in the 
finalisation of the Technical Specifications, REX-R1 was deployed on time. 

Table 1: Comparison of Planned and Actual Dates – REX-R1 

6 Countries benefiting from the EU 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. 

7 

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

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 
CDS to manage their national customs decisions, if they wish to do so.  

The project was fully deployed on 2 October 2017.  

Some statistical information on the use of CDS – situation as of May 2023: 

•  Since the start of deployment on 2 October 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 Q2 2020, most likely due 
to the pandemic situation. The situation stabilised after the summer break to an increase of 28 
applications per working day; 

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

the current legislation; 

•  During 2022, 7,649 new applications were submitted, an average of 29 applications per 

working day, and 5,042 decisions were taken; 

•  From January to May 20238, 3,529 applications were submitted, an average of 37 applications 

per working day, and 2,580 decisions were taken. 

2.2.1.  Overview of Project Progress 

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

Table 2: Comparison of Planned and Actual Dates – CDS 

8 Both months included 

8 

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

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 CDS on 2 October 
2017, as agreed in the context of the UCC WP. The system was also incorporated into other electronic 
projects, such as the UCC Binding Tariff Information (BTI), the UCC Authorised Economic Operators 
(AEO)  and  the  Information  Sheets  (INF)  system  for  Special  Procedures  (SP).  The  project  further 
evolved to include system-to-system interfaces in view of the ICS2 deployment and it will also be used 
for future UCC and non-UCC projects, such as for the Proof of Union Status (PoUS) and for the projects 
on the Carbon Border Adjustment Mechanism (CBAM) and the Central Electronic System of Payment 
information (CESOP). 

The UUM&DS component is available for all Member States and the system-to-system connectivity has 
been almost reached by almost all of them, targeting to be completed by the remaining Member States 
by the end of 2023. 

2.3.1.  Overview of Project Progress 

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

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

9 

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

SYSTEM UPGRADE (EORI2) 

This  system  upgrade  provided  minor  changes  to  the  existing  trans-European  Economic  Operator 
Registration and Identification (EORI) system. These changes enabled the registration and identification 
of  EOs  of the  Union as  well  as third-country  operators  and  persons  apart from  EOs.  The  Economic 
Operator Registration and Identification upgrade (EORI2) system has been in Operation since 5 March 
2018. 

Some statistical information on the use of the EORI2 system – situation until April 2023: 

•  The total number of EOs registered with a valid EORI is 8,487,237; 
•  230,830 EORI numbers were created during the period of 1 January 2023 to 30 April 2023. 

2.4.1.  Overview of Project Progress 

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

Table 4: Comparison of Planned and Actual Dates – EORI2 

10 

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

The Surveillance 3 (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 1 October 2018, with all the data being gathered in different 
formats via Surveillance Recap. Additionally, all national systems needed to be fully aligned to the UCC 
by  31/12/2022  (legal  deadline  for  all  Member  States),  though  extended  until  31/12/2023  for  those 
Member  States  having  been  granted  a  derogation,  thereby  enabling  the  system  to  operate  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 NIS even beyond the derogation date, it 
will  have  a  direct  consequence  on  the  collection  of  the  data  via  Surveillance  Recap  and  on  the 
functioning of the reports of the SURV3 system. Therefore, the system will have to be prolonged in use 
until all Member States are on board. The collection of all the required data from all Member States is 
essential not only for SURV3 but also for other projects such as for CBAM. 

2.5.1.  Overview of Project Progress 

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

Table 5: Comparison of Planned and Actual Dates – SURV3 

11 

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

The  project for  a  UCC  Binding  Tariff  Information (BTI)  system aims  to  upgrade the  existing  trans-
European  Binding  Tariff  Information  (EBTI-3)  database  containing  all  BTI  issued  by  customs 
authorities  of  Member  States.  The  customs  authorities  concerned  are  responsible  for  recording  their 
decisions in the  BTI  database.  EOs  apply  for  binding  tariff  decisions  to  ensure legal  certainty  when 
classifying goods they import or export from the EU.  

Concerning the status of the project, the first phase was completed by October 2017. The second phase 
started Operations on 1 October 2019. The construction of the access for this system to the EU CTP was 
also completed on 1 October 2019. 

Some statistical information on the use of the EBTI system since the ‘go live’ of the TP on 1 October 
2019: 

•  The TP (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 151,000 BTI applications (27,000 via the EU TP and 124,000 via the national TP) 

have been accepted and more than 149,000 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. 

2.6.1.  Overview of Project Progress 

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

Table 6: Comparison of Planned and Actual Dates – BTI 

12 

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

Following the legal changes adopted in the UCC, the Authorised Economic Operators (AEO) upgrade 
aims to enhance the process of applications and authorisations for AEO status. The project consisted of 
two phases. In Phase 1, significant improvements were made to the existing AEO system, in light of the 
harmonisation  of  the  decision-taking  procedure  for  customs.  Phase  2  focused  on  implementing  an 
electronic form to provide a harmonised interface for EOs to submit their AEO applications and receive 
their AEO decisions electronically.  

The  upgraded  system  was  deployed  in  two  releases.  Part  1  encompassed  the  submission  of  AEO 
applications  and  the  decision-making  process  (Phase  2,  Part  1).  Part  2  encompassed  the  remaining 
processes (Phase 2, Part 2). 

Some statistical information on the use of the AEO system – situation until April 2023: 

Since the EU eAEO TP was deployed in October 2019: 

•  1,766 AEO applications were submitted via the EU eAEO TP; 
•  25 Member States are leveraging the EU eAEO TP and the remaining Member States are 

using their own National TP. 

On 30 April 2023, 18,241 valid AEO authorisations were granted to EOs in the Economic Operator 
System. 

2.7.1.  Overview of Project Progress 

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

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

13 

Target date from WPActual End Date% of CompletionActual End Date% of Completion Target date from WPActual Date% of Completion 31/03/201631/03/2016100%28/02/2018100%05/03/201805/03/2018100%31/12/201831/12/2018100%29/07/2019100%01/10/201901/10/2019100%31/12/201831/12/2018100%06/11/2019100%16/12/201916/12/2019100%DeploymentTechnical SpecificationsConformance Testing 
 
 
 
 
2.8. UCC INFORMATION SHEETS (INF) FOR SPECIAL PROCEDURES 

The aim of the Information Sheets (INF) for Special Procedures (SP) 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 SP. This harmonised 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 1 June 2020.  

The  INF  Specific  Trader  Portal  component  was  also  successfully  integrated  into  the  EU  CTP  and 
deployed on 1 June 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 and INF). 

The Commission maintains close communication with  the Member States, ensuring the provision of 
necessary  support,  assistance  and  supervision.  A  Project  Group  (PG)  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 – situation until June 2023: 

•  As from October 2020, all Member States are using the INF system; 
•  From the start of Operations on 1 June 2020 until June 2023, around 58,918 requests were 

created by EOs, and approximately 53,873 INFs were treated and processed;  

•  The average number of processed INFs per working day increased from 48 in 2020, to 86 

in 2021 and 2022, and 97 in Q1 2023. 

2.8.1.  Overview of Project Progress 

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

Table 8: Comparison of Planned and Actual Dates – INF 

14 

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

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

In  terms  of  planning,  the  programme  will  be  implemented  in  three  releases.  Release  1  covers  the 
obligation on the relevant  EOs  (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  (i.e.,  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 started. 
Release 3 will cover the very similar business process as Release 2, but for all goods in maritime and 
inland waterways, road and rail traffic (this also includes goods in postal consignments transported in 
these means of transport). Please refer to Section 3.5 for a detailed update on the status of Release 2 and 
Section 4.2 for Release 3. 

The  first  ICS2  release,  ICS2  –  Release  1  (ICS2-R1)  started  Operations  on  15  of  March  2021  with 
majority of National Entry Systems (NES) connected. Most of the EOs had connected to the ICS2-R1 
system  before  the  end  of  the  deployment  window  on  1  October  2021.  All  remaining  NES  and  EO 
systems  were  connected  by  December  2021,  with  exception  of  UK  (Northern  Ireland).  All  national 
customs  authorities  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 EO deployment window, it was observed that the quality and completeness of ENS data, 
as well as its coverage and the implementation of air cargo security referrals, posed challenges for the 
affected EOs, especially in the postal sector. These critical compliance issues had and will have to be 
continuously addressed to ensure compliance with the new UCC requirements. 

Since the end of December 2021, ICS2-R1 is operational in 30 National Customs Administrations: all 
EU Member States, CH, NO and UK9. All Postal operators, including the postal operators of CH and 
NO, are connected to ICS2, apart from the UK postal operator, that is not operational10. 

2.9.1.  Overview of Project Progress 

Table 9 compares the actual dates to those set in the UCC WP.  

Table 9: Comparison of Planned and Actual Dates – ICS2-R1 

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

15 

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 2023 

3.1. UCC 

NOTIFICATION  OF 

ARRIVAL 

(AN), 

PRESENTATION 

NOTIFICATION (PN) AND TEMPORARY STORAGE (TS) 

The goal of this project is to define the processes at the national level in respect of the AN, PN and TS 
notifications,  as  described  in  the  UCC.  The  project  aims  to  ensure  that  Safety  and  Security-related 
customs  formalities  for goods  entering  and  exiting  are  properly conducted,  and 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 the EU level. In this light, the systems 
were  planned  to  be  in  operation  by  31  December  2022,  as  defined  in  the  UCC  basic  Regulation. 
However, several Member States requested a derogation as stated in Article 6(4) of the UCC, addressing 
a formal request, of a temporary nature, stating a scope and clear justification. On 1 February 2023, the 
Commission adopted Implementing Decisions, granting derogations to certain Member States for AN, 
PN and TS, extending the previously stated deadlines to 31 December 2023. 

3.1.1.  Summary of Responses 

Notification of Arrival (AN) 

Summary from the Member States: 

The project is closely interlinked with other projects such as NIS and ICS2. This is often reported by the 
Member States as the reason for assessing the project as medium to highly complex.  

Recurrently identified causes of delay related to the project are the interdependencies between core and 
supporting systems, delays in public procurement procedure, dependencies from other stakeholders, the 
contractor’s capacity and unexpected delays caused by the intrinsic development of the system.   

Besides the complexity of the project per se, other reasons for potential delay were provided, such as 
resource constraints, both workforce and financially related, further adaptations to the UCC Annex B11 
and the specific working circumstances caused by the COVID-19 pandemic. At the same time, many 
Member States attributed the increased complexity level to the parallel development of the systems and 
to the many dependencies and stakeholders involved. 

Some Member States reported that measures are taken to keep the deployment within the deadline. Some 
examples  include  allocating  additional  resources  to  the  project  and/or  implementing  an  Agile 
development methodology to reduce the implementation timeframe. 

The above summary also applies to PN and TS. 

The following Member States reported to implement AN as part of ICS2-R2, in particular through the 
EU Shared Trader Interface: BG, CY, EE, ES, FI, FR, HR, HU, LT, LU, NL, SE, and SI. The following 
Member States developed or are developing a national solution (often in conjunction with NIS): CZ, IT, 
MT, PL, PT, and SK. Some Member States did not provide any information in this regard. 

AT12, BG, CZ13, EE, FI, FR14, IT, LT, LU15, LV16, NL17, SI, and SK18 indicated the project as completed. 
Other Member States reported to envisage AN implementation by the end of 2023: CY, ES, HU, PL, 

11 Annex B of the Commission Delegated Regulation (EU) 2015/2446 regarding common data requirements, as amended by 
Delegated Regulation (EU) 2021/234. 
12 Information provided from a bilateral meeting between AT and DG TAXUD held on 06/06/2023. 
13 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 
14 Information provided from FR on 18/10/2023 regarding the progress of the UCC project on AN/PN/TS. The AN system was 
Deployed for air transport on 01/07/2023. For maritime transport FR plans to deploy on 01/06/2024. 
15 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
16 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
17 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
18 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

16 

 
 
 
RO19,  and  SE  (see  Table  10  below  and  adjusted  to  the  latest  information  available).  DK  and  MT20 
indicated that the project will be delayed beyond the foreseen Deployment deadline. 

DE and IE marked the project as not applicable. 

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for derogation under 
Article  6(4)  of  the  UCC,  concerning  the  delay  for  AN,  beyond  the  deadline  of  31  December  2022, 
regardless of the option given to implement the system with ICS2-R2. The derogation requests from the 
Member States were assessed by the Commission services in terms of the justifications provided for the 
specific  situations  of  the  respective  Member  States  requesting  it  and  in  view  of  a  set  of  common 
assessment criteria.  

In this light, the Commission adopted an Implementing Decision (EU) 2023/23521 on 1 February 2023, 
granting a derogation to AT, BE, BG, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LU, MT, NL, PL, PT, 
RO, SE, SI, and SK for AN provided for in Article 133 of the  UCC. The derogation applies 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 ICS2-R2 and ICS2-R3, respectively, as the 
projects are closely linked.  

Detailed Responses22: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

5 

Low 

CY 

6 

High  

national 

In the case of BG, AN will be implemented as part of the ICS2-
R2  system  and  updated  according  to  its  planning  for  air 
transport.  Regarding 
components’ 
ICS2-R2 
development, the Bulgarian Customs Administration is using an 
Agile  and  iterative  approach.  BG  applies  an  integrated 
implementation  of  two  technological  frameworks  –  Adaptive 
Development  Methodology  (ADM)  and  Rational  Unified 
Process (RUP). 
In relation to the NA, PN and TS projects, CY indicated that 
these projects are within the new legal deadline provided for in 
the derogation that was granted. In 2022, CY progressed with 
the preparation of specifications and the implementation of the 
the 
system,  which 
interconnections between core and supporting systems, the high 
percentage of system availability required, limitations in human 
resources  and  the  COVID-19  pandemic  contributed  to  the 
complexity  of  the  AN,  PN  and  TS  projects.  CY  faces  a  high 
level of risk on the AN project, as all milestones were impacted. 
The system is expected to ‘go live’ on 07/11/2023, within the 
deadline provided for in the derogation. CY indicated two main 

completed.  However, 

almost 

is 

19 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
20 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
21 Commission Implementing Decision (EU) 2023/235 of 1 February 2023 granting a derogation requested by certain Member 
States  pursuant  to  Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of  the  Council  to  use  means  other  than 
electronic data-processing techniques for the exchange and storage of information for the notification of arrival of a sea-going 
vessel or of an aircraft (OJ L 32, 3.2.2023, p. 220-222). 
22 Fields marked in grey mean no information was provided on that specific topic. 

17 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

causes for the delay. The first is related to delays in the public 
procurement 
procedure.  The  Contracting  Authority 
(Department of Information Technology Services) launched a 
two-phase public procurement procedure in full alignment with 
the  national  legislation  for  the  development,  operation  and 
maintenance of all systems required for the full implementation 
of the UCC. The second phase, launched in October 2020, led 
to the signing of a contract with the successful EO in December 
2021.  The  second  reason  for  the  delay  is  the  policy-related 
decision of the Department of Customs and Excise to develop 
and operate the Import Declarations System and its interfaces 
using  the  latest  version  of  Annex  D  of  2446/2015  (European 
Union Customs Data Model [EUCDM] v6.1 instead of EUCDM 
v5.2), which is planned to become mandatory on 01/12/2023. 
This decision was made to avoid additional administrative costs 
for both the Department of Customs and Excise and the EOs, 
who would have to make changes to their systems twice (three 
times for express couriers) within a very short period of time. 
By using v6.1 and moving the production date from 01/01/2023 
to  April/May  2023,  the  EOs  will  gain  a  few  more  months  to 
adapt  their  systems,  as  the  Technical  Specifications  are 
scheduled to be published by the end of July 2023. Furthermore, 
proceeding with the latest data model v6.1 will allow CY to start 
working  on  the  Single  Window  project  and  be  able  to  apply 
quantity  management  for  the  main  Common  Health  Entry 
Document  for  consignments  of  food  and  feed  of  non-animal 
origin certificates (CHED-D) in due time. Mitigation measures, 
such as the allocation of extra human and other resources, are 
planned. 
CZ indicated that the AN system was deployed on 01/03/2023, 
with a transition period until 01/10/202323. 
DE communicated that AN will be implemented as part of the 
ICS2 system and it will be updated according to its planning. 
External  milestones  related  to  the  Technical  Specifications, 
Conformance Testing and Deployment that affect the EOs will 
be considered in line with the ICS2 planning for ICS2-R2 and 
R3, especially in relation to Shared Trader Interface. 
As the Danish implementation of AN for air follows the Danish 
implementation of ICS2-R2, DK aims to ‘go live’ with AN for 
air on 31/10/2023 and with AN for shipping on 01/03/2024. AN 
will be received via ICS2 Shared Trader Interface and stored in 
ICS2 Common Repository. DK is using an Agile and iterative 
approach for the development of the system. 
AN will be deployed on 01/10/2023 for air transport in line with 
ICS2-R2  planning.  For  other  transport  modes,  AN  will  be 
deployed  in  2024  in  line  with  the  ICS2-R3  planning 24 .  EE 
advised that due to the COVID-19 related financial challenges, 
the project deadline for ICS2-R2 and AN had to be postponed. 
EE is progressing towards the use of an Agile approach for the 
system development. 

CZ 

DE 

1 

3 

Low 

Low 

DK 

3 

Medium 

EE 

4 

Low 

23 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 
24 Information provided from a bilateral meeting between EE and DG TAXUD held on 01/06/2023. 

18 

 
 
 
MS 

ES 

FI 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

1 

3 

Low 

ES informed that AN will be developed in the ICS2-R2 system, 
using an Agile development approach. 

Medium  FI indicated the overall status of the project as completed. 

FR 

5 

Medium 

GR 

HR 

3 

Medium 

HU 

5 

Medium 

IE 

3 

Low 

IT 

LT 

LU 

LV 

MT 

4 

5 

5 

3 

Low 

Low 

Low 

Low 

FR will use the application developed by BE and will deploy 
AN concomitantly with ICS2-R2 (this applies to PN and TS as 
well). Considering that the AN project was delayed and ICS2-
R2  is linked  with it,  FR asked  for  a derogation for  ICS2.  FR 
shared  that  the  system  was  Deployed  for  air  transport  on 
01/07/2023, while for maritime transport it is envisaged to be 
Deployed  on  01/06/2024,  with  a  migration  window  for  EOs 
until 04/12/202425. 

HR indicated that AN will be deployed according to the ICS2 
deadlines for different modes of transport. In accordance with 
the national agreement, the economic side of economic entities 
will submit AN through Shared Trader Interface. There will be 
a big challenge in supporting the testing of the EOs in ICS-R2. 
Testing  activities  for  air  transport  will  be  carried  out  in 
accordance  with  the  timelines  for  ICS2-R2.  For  maritime 
traffic, AN will be submitted through Shared Trader Interface 
by including it in ICS2-R3. The registered arrival notification 
will be submitted to the  Common Repository via the IE4N07 
message. 
HU shared that the project development is progressing well and 
that the derogation deadline will be met26.  
IE explained that in accordance with Article 133 of the UCC, 
where  the  information  on  arrival  is  available  to  the  customs 
authorities, it may waive this notification. IE has already been 
providing this information from its port and airport authorities 
and  will  not,  therefore,  require  the  operators  to  submit 
notifications of arrival. However, for ICS-R2, the notifications 
of arrival will be submitted directly to Shared Trader Interface. 
IT completed this project in 2022. The Technical Specifications 
were  published  on  01/06/2022,  Conformance  Testing  with 
traders  took  place  between  05/09/2022  and  12/12/2022, 
followed by Deployment on 13/12/2022. 
LT shared that AN will be aligned with the ICS2 functionality 
(for  which  deadline  for  production  is  01/03/2023).  The  EOs 
requested to postpone the start of Operations until 01/10/2023. 
LT indicated that an Agile approach is being used for the system 
development. 
LU indicated that the system is deployed27. 
LV  reported  that  AN  is  received  from  port  and  airport 
authorities28. 
MT informed that the AN project is being delayed until June 
202429. 

25 Information provided from FR on 18/10/2023 regarding the progress of the UCC project on AN/PN/TS. 
26 Information provided from a bilateral meeting between HU and DG TAXUD held on 07/09/2023. 
27 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
28 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
29 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 

19 

 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

NL 

1 

Low 

PL 

3 

Low 

PT 

6 

High 

NL decided to use Shared Trader Interface (instead of National 
Trader  Interface)  for  EOs  to  submit  AN.  Shared  Trader 
Interface was developed and tested centrally by DG TAXUD. 
NL shared that the AN system for air transport was Deployed 
on 01/07/202330. Delays were caused due to COVID-19, Brexit 
and  the  amount  of  functionalities  to  be  developed  for  ICS2, 
while at the same time many functionalities being developed by 
the same team for other UCC and national projects. NL is using 
an Agile approach. 
PL  plans  to  update  the  AN  system  with  the  new  NIS/CCI 
systems by 01/07/202431. The implementation of NIS based on 
the  new  Annex  B  of  the  Commission  Delegated  Regulation 
(EU)  2021/234  is  scheduled  for  June  2024.  PL  indicated  that 
both an Agile and an iterative approach are going to be used for 
the system development. 
The implementation of the national AN system in PT is being 
delayed beyond the expected Deployment deadline. Operations 
are planned in the second half of 202432. The cause of the delay 
is  the  complexity  of  integrating  various  national  systems, 
including  ICS2,  NIS,  the  Risk  Management  System,  TS 
Facilities  systems,  Ports  Authorities,  and  Airport  Authorities. 
To  mitigate  the  delay,  PT  has  adopted  an  Agile  development 
approach to reduce the implementation timeframe and improved 
its  planning  to  meet  the  required  timeframe.  However,  PT  is 
currently  facing  procurement  and 
tendering  difficulties, 
particularly with the renewal of contracts with the companies 
developing the systems, which may lead to an implementation 
of  the  national  AN  system  beyond  the  Deployment  deadline 
established  in  the  granted  derogation.  A  partial  deployment 
approach is not feasible due to a high level of risk associated 
with implementing a completely new national AN system. PT 
explained that AN of the means of transport is waived for an 
EO,  under  the  provisions  of  Article  133  of  the  UCC.  The 
administration receives the information regarding AN from 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 and ICS2-R3 is also complex.  
To  facilitate  the  implementation,  a  test  environment  will  be 
made available to the EOs. Ongoing activities are being carried 
out  with  ports  and  airports’  authorities  to  ensure  smooth 
integration. Development is ongoing, but the milestones most 
impacted  are  Conformance  Testing  and  Deployment,  which 
were  postponed  to  2023  due  to  the  complexity  of  the 
developments with ports and airports and the need for a longer 
time period for Conformance Testing  activities. In July 2022, 
the Technical Specifications for the EOs were published. 

30 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
31 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
32 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 

20 

 
 
 
Complexity 
Rating 

Risk 
Level 

MS 

RO 

SE 

3 

Low 

SI 

SK 

3 

1 

Low 

High 

Additional Comments 

RO shared its plans to  deploy the AN system by 01/10/2023, 
within the derogation deadline33. 
SE confirmed that it will use the ICS2 functionality for AN and 
deploy the system within the time schedule provided for in the 
derogation decision. SE is using Shared Trader Interface within 
the  central  ICS2  system,  therefore,  developing  any  Technical 
Specifications regarding the external domain is not necessary. 
The Deployment for the traders to the Shared Trader Interface 
was  on  01/03/2023.  Nonetheless,  due  to  late  changes  in 
December  2022,  the  Deployment  planned  for  the  national 
integration on 01/03/2023 was delayed until 20/06/2023, within 
the time limit set out in the derogation decision. Some air traders 
have not yet submitted ENS, but it is envisaged that the majority 
will be submitted by 02/10/202334. 
SI  explained  that  AN  and PN  are  already  implemented  along 
with ICS2 for air cargo. For maritime, AN is expected to be in 
use in 2024. 
SK  confirmed  that  the  system  is  Deployed  with  the  common 
repository domain35. 

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 

33 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
34 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
35 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

21 

 
 
 
 
 
 
 
 
Presentation Notification (PN) 

Summary from the Member States: 

Please see also the summary from AN. 

Regarding the alignment of the system development with the data requirements the new Annex B of the 
Commission  Delegated  Regulation  (EU)  2021/234,  BG,  ES,  and  IE indicated  that they  have  not  yet 
adapted  to  the  new  requirements.  BG  plans  to  conform  with  them  as  of  24/06/2024.  All  the  other 
Member States that provided additional comments in Table 11 below, complied with the requirements 
of  the  new  Annex  B  of  the  Commission  Delegated  Regulation  (EU)  2021/234  to  the  common  data 
requirements for declarations, notifications and proof of the customs status of union goods provided for 
in Article 2(2) of the Commission Delegated Regulation (EU) 2021/234. 

At  the  moment  of  writing,  AT36,  BG,  DE,  EE,  IT,  LT,  LU37,  LV38,  and  SI  indicated  the  project  as 
complete, with the caveat that in the case of BG, which implemented PN as part of TS and their import 
declaration system, based on requirements from Annex D to the Delegated Regulation (EU) 2015/2446, 
the system will have to be updated by 31 October 2023.  

BE,  CY,  CZ,  HR39,  HU,  IE,  MT,  NL,  PL,  RO40,  SE,  and  SK41 reported  that  they  envisage  the  PN 
implementation by the end of 2023 (see Table 11 below, as adjusted to the latest information available). 
ES, FR42, MT43, and PT indicated that the project implementation will be delayed beyond the foreseen 
Deployment deadline. 

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for derogation under 
Article  6(4)  of  the  UCC,  considering  the  delay  of  PN  beyond  the  deadline  of  31  December  2022, 
regardless of the option given to implement the system with ICS2-R2. The derogation requests from the 
Member States were assessed by the Commission services in terms of the justifications provided for the 
specific  situations  of  the  respective  Member  States  requesting  it  and  in  view  of  a  set  of  common 
assessment criteria.  

In this light, the Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/23444 
granting a derogation to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LU, MT, NL, PL, PT, RO, 
SE, SI, and SK for the PN system provided for in Article 133 of the UCC. The derogation applies 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: 

Complexity 
Rating 

Risk 
Level 

MS 

AT 

Additional Comments 

36 Information provided from a bilateral meeting between AT and DG TAXUD held on 06/06/2023. 
37 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
38 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
39 Information provided from a bilateral meeting between HR and DG TAXUD held on 25/05/2023. 
40 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
41 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 
42 Information provided from FR on 18/10/2023 regarding the progress of the UCC project on AN/PN/TS. 
43 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
44 Commission Implementing Decision (EU) 2023/234 of 1 February 2023 granting a derogation requested by certain Member 
States  pursuant  to  Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of  the  Council  to  use  means  other  than 
electronic data-processing techniques for the exchange and storage of information for the Presentation Notification related to 
goods brought into the customs territory of the Union (OJ L 32, 3.2.2023, p. 217-219). 

22 

 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

BE 

3 

Low 

BG 

5 

Low 

CY 

6 

High 

CZ 

4 

Low 

DE 

4 

Low 

DK 

4 

Medium 

Framework 

(TOGAF)/ADM 

BE  indicated  that  the  project  is  experiencing  delays  due  to 
dependencies on other projects, each with different deadlines. 
PN  is  closely linked  to  ICS2  and  inter-trader  agreements  still 
need  to  be  worked  out  for  traders  for  the  air  sector 45.  This 
situation  complicates  the  process  of  conducting  thorough 
analysis and implementing necessary changes, especially when 
the  deadlines  for  these  projects  shift.  However,  the  project  is 
still expected to be completed within the designated deployment 
deadline.  Technical  Specifications  for 
the  project  were 
completed  on  20/04/2023  and  the  Conformance  Testing  and 
Deployment activities are currently underway. 
BE  informed  that  an  Agile  approach  is  being  employed  for 
system development. 
A  plan  to  update  NIS  according  to  the  new  Annex  B  of  the 
Commission Delegated Regulation (EU) 2021/234 is ongoing, 
with  a  deadline  set  for  31/10/2023.    The  Open  Group 
Architecture 
and  RUP 
methodologies  are  being  used  for  the  implementation  of  IT 
projects. 
Same response as for AN. 
Additionally,  CY  shared  that  it  is  analysing  the  development 
with  an  IT  contractor,  while  using  an  Agile  approach  for  its 
development.  Functional  and  Technical  Specifications  were 
completed  on  22/05/2023  with  both  System  to  System  (S2S) 
and  Graphical  User  Interface  (GUI)  connections  provided. 
However, CY informed that some traders will not be ready for 
S2S connection. The system itself is on course but, while the 
GUI will be available, it will not suit all users46. 
CZ indicated that following the derogation, the Deployment is 
planned  for  the  end  of  2023.  Functional  and  Technical 
Specifications were completed and the communication with the 
Common  Repository  is  in  production.  CZ  explained  that  a 
significant  reduction  in  the  financial  budget  for  the  Customs 
Administration of the Czech Republic has triggered a negative 
impact  at  the  level  of  personal  relationships  and  contractual 
relationships  with  external  software  providers.  Therefore,  the 
ability  to  maintain  a  high  level  of  digitisation  and  volume  of 
modernised systems has been reduced. 
DE indicated that the PN project was completed in 31/10/2022. 
PN was updated as part of the NES of the national IT-System 
Automated  Customs  Tariff  and  Local  Processing  Application 
System (ATLAS) Release 9.1 for which the EOs were allowed 
to carry out migration from 01/05/2021 until 14/10/2022. 
As the Danish implementation of PN for air follows the Danish 
implementation of ICS2-R2, DK indicated that aims to 'go live' 
with PN for air on 31/10/2023. The Danish implementation of 
PN  for  shipping,  rail  and  road  transport  follow  the  Danish 
implementation  of  ICS2-R3  and  is  planned  to  ‘go  live’  on 
01/03/2024. 

45 Information provided from a bilateral meeting between BE and DG TAXUD held on 14/06/2023. 
46 Information provided from a bilateral meeting between CY and DG TAXUD held on 20/07/2023. 

23 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

PN  will  be  deployed  in  line  with  the  ICS2-R2  planning  on 
01/10/2023 for air transport. For other transport modes, PN will 
be deployed in 2024 in line with  the  ICS2-R3 planning47. EE 
informed that due to the COVID-19 related financial challenges, 
the  ICS2-R2 and AN projects deadlines had to be postponed. 
EE draws attention to 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 
EOs should be 01/03/2024. EE is progressing towards the use 
of an Agile approach for the system development. 
ES reported that the PN system is already in place and integrated 
with ICS2, but it is not yet adapted to the requirements of the 
new Annex B of the Commission Delegated Regulation (EU) 
2021/234. ES indicated that the deployment of the update of the 
system  might  be  delayed  by  a  quarter,  preventing  ES  from 
meeting  the  legal  deadline,  due  to  dependencies  with  other 
subsystems  that  also  require  updates  by  the  Deployment 
deadline. Migration is planned until the end of 2025, but ES will 
try  to  end  before,  on  01/09/2025 48 .  Notwithstanding,  ES  is 
collaborating with the other subsystems to meet the Deployment 
deadline  and  a  Scrum  methodology  is  being  used  for  its 
development. ES noted that the TS system will not be impacted 
by the delay. 

FR will use the application developed by BE and will deploy 
PN concomitantly with ICS2-R2. FR informed of a medium risk 
level  due  to  an  ambitious  timeline  for  the  compliance  testing 
and  Deployment.  The  Conformance  Testing  for  the  central 
system  (Base  Common  Repository)  is  included  in  the  ICS2 
project.  Regarding  the  Deployment,  FR  shared  its  plans  to 
Deploy the PN system for air transport on 06/03/2024 and on 
01/06/2024 for maritime transport. The migration window for 
EOs  is  planned  until  01/06/2024  for  air  and  04/12/2024  for 
maritime49. 

HR  shared  that  PN  is  on  track  and  will  be  deployed  for  air 
transport together with ICS2-R2 by end June 202350. 

EE 

4 

Low 

ES 

6 

High 

FI 

FR 

5 

Medium 

GR 

HR 

HU 

5 

Medium  Same response as for AN. 

IE 

3 

Low 

Annex  B  to  the  UCC  for  PN  was  implemented  in  November 
2022. IE is now upgrading PN according to the new Annex B 
of  the  Commission  Delegated  Regulation  (EU)  2021/234  and 
stated that this upgrade does not seem to be as complex as the 
original  implementation.  IE  intends  to  issue  the  Technical 
Specifications  in  June  2023  and  deploy  the  system  on 
24/06/2024. Even though IE's original intention was to deploy 
in October 2023, the date was re-evaluated in line with the CCI 
Deployment and upgrade to all NES and import messages to the 
new Annex B of the Commission Delegated Regulation (EU) 

47 Information provided from a bilateral meeting between EE and DG TAXUD held on 01/06/2023. 
48 Information provided from a bilateral meeting between ES and DG TAXUD held on 23/11/2023. 
49 Information provided from FR on 18/10/2023 regarding the progress of the UCC project on AN/PN/TS. 
50 Information provided from a bilateral meeting between HR and DG TAXUD held on 25/05/2023. 

24 

 
 
 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

IT 

LT 

LU 

LV 

MT 

4 

6 

Low 

Low 

3 

Low 

NL 

2 

Medium 

PL 

3 

Low 

PT 

6 

High 

2021/234  at  the  same  time.  IE  expects  to  have  the  test 
environment for trade available in January 2024. 
Same response as for AN. 
The  implementation  of  the  PN  for  all  EOs  will  follow  a  ‘big 
bang’ approach. Conformance Testing was finished in 2022 and 
Deployment took place in February 2023. The EOs requested to 
postpone the start of Operations until 01/10/2023. LT indicated 
that  an  Agile  approach  is  being  used  for  the  system 
development. 
Same response as for AN. 
LV  informed that the  PN system  is  updated to the latest  data 
requirements51. 
Same response as for AN. 
NL  indicated  a  medium  risk  due  to  the  relatively  complex 
relationship between the PN and TS systems. It was found that 
TS  functionalities  needed 
to  be  developed  before  PN 
functionalities, which is why PN functionalities are expected to 
be  delivered  later,  latest  by  01/12/2023.  This  is  necessary  to 
meet  the  derogation  deadline  for  ICS2-R2,  which  is  on 
30/06/2023. To complete the ENS lifecycle, PN has to be shared 
with the Common Repository, which will be tested as part of 
the  ICS2-R2  Conformance  Testing  between  June  and 
November  2023.  NL  informed  that  the  Deployment  for  air 
transport is planned for 01/12/2023, while the Deployment for 
maritime transport is envisaged on 01/06/202452. The causes of 
the delay are Brexit, the effects of the COVID-19 pandemic, and 
the amount of functionalities required to be developed for ICS2 
using  the  same  human  resources  as  for  the  other  UCC  and 
national  projects.  Therefore,  NL  implemented  a  package  of 
mitigating measures to address this delay and is using an Agile 
approach for the development of this system. 
Same response as for AN. 
The implementation of the national PN system in PT has been 
delayed beyond the foreseen Deployment deadline. Operations 
are planned in the second half of 202453. The cause of the delay 
is due to the complexity of integrating various national systems, 
including  ICS2,  NIS,  the  Risk  Management  System  and  TS 
Facilities  systems.  To  mitigate  the  delay,  PT  has  adopted  an 
Agile  development  approach  to  reduce  the  implementation 
timeframe  and  improved  its  planning  to  meet  the  required 
timeframe.  However,  PT  is  currently  facing  procurement  and 
tendering  difficulties,  particularly  in  the  renewal  of  contracts 
with the companies developing the systems, which may lead to 
an  implementation  of  the  national  PN  system  beyond  the 
Deployment deadline established in the granted derogation. A 
partial deployment approach is not feasible due to a high level 
of risk associated with implementing a completely new national 
PN system. 

51 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
52 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
53 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 

25 

 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

To  facilitate  the  implementation,  a  test  environment  will  be 
made  available  to  the  EOs.  Ongoing activities  with  ports  and 
airports’  authorities  are  being  carried  out  to  ensure  a  smooth 
integration.  Development  is  ongoing,  but  the  most  impacted 
milestones  are  Conformance  Testing  and  Deployment,  which 
were  postponed  to  2023  due  to  the  complexity  of  the 
developments with ports and airports and the need for a longer 
time  period  for  the  Conformance  Testing  activities.  In  July 
2022, Technical Specifications for the EOs were published. 
Same response as for AN54. 
SE  explained  that  there  is  a  medium  risk  of  delay  in  testing 
activities  due 
to  ongoing  development  activities.  The 
development of the PN system is progressing and the target is 
to  meet  the  deadline  in  the  derogation  decision  regarding  air 
transport, which requires all the EOs to complete Conformance 
Testing and be in Operation by the end of 2023. For other modes 
of transport, the end of the Conformance Testing and Operation 
periods is set on 01/03/2024, in line with ICS2-R3. However, 
SE draws attention to the fact that if the interface with Maritime 
Single  Window  (MSW)/European  Maritime  Single  Window 
(EMSW)  is  implemented  for  maritime  traffic,  the  Operation 
date may be impacted. Currently, SE is assessing the possibility 
of  integrating  the  application  developed  by  BE  in  the  Expert 
Team on new approaches to develop and operate Customs IT 
systems 
IT 
infrastructure  and  investigating  the  feasibility  of  using  a 
national application to a certain extent as an alternative. 
SE shared that a derogation for sea freight has been requested 
due to the link with EMSWe. The data for the national MSW 
currently used is not in line with UCC, which will require the 
national MSW to be updated. SE will try to avoid that traders 
needing to submit twice (to customs and to national MSW) by 
adding 2-3 elements to the MSW and passing them on to close 
ICS255.  During  the  first  half  of  2021,  the  plan  for  the  UCC 
projects  to  be  implemented  was  reviewed  and  realistic  dates 
were  set.  Based  on  that,  SE  has  been  able  to  reprioritise  and 
increase  the  resources  for  this  project  in  terms  of  allocated 
human and economic resources. 
SE informed that it is going to use the application developed by 
BE in the ETCIT cooperation. At the moment of writing, SE is 
analysing  and  considering  the  most  efficient  way  to  integrate 
the application into the existing IT infrastructure,  considering 
the alternative of investigating the possibility of using a national 
application at least to a certain extent. 
Same response as for AN. 
SK shared that the PN system is system is already in place and 
integrated with ICS256. 

(ETCIT)  cooperation 

their  existing 

into 

RO 

SE 

4 

Medium 

SI 

SK 

3 

1 

Low 

High 

54 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
55 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
56 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

26 

 
 
 
 
 
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 

27 

 
 
 
 
 
 
 
Temporary Storage (TS) 

Summary from the Member States: 

Please see also the summary from PN. 

BG implemented PN and TS as part of its national import declaration system. As it was implemented 
based on requirements from Annex D to the Commission Delegated Regulation (EU) 2015/2446, it will 
be  updated by  31  October  2023.  All  the  other Member  States  that  provided  additional  comments in 
Table 12 below, complied with the requirements of the new Annex B of the Commission Delegated 
Regulation (EU) 2021/234. 

At the moment of writing, DE, EE, FI, IT, LT, LU57, NL58, and LV59 indicated the project as complete. 
Other Member States that envisaged the implementation of the TS system by the end of 2023 are BE, 
BG,  CY,  CZ,  HR,  HU,  IE,  RO60,  and  SI  (see  Table  12  below,  as  adjusted  to  the  latest  information 
available). AT61, DK, ES, FR62, MT63, PT64, SE, and SK informed that the project implementation will 
be delayed beyond the foreseen Deployment deadline. 

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for derogation under 
Article  6(4)  of  the  UCC,  considering  the  delay  for  TS  beyond  the  deadline  of  31  December  2022, 
regardless of the option given to implement the system with ICS2-R2. The derogation requests from the 
Member States were assessed by the Commission services in terms of the justifications provided for the 
specific  situations  of  the  respective  Member  States  requesting  it  and  in  view  of  a  set  of  common 
assessment criteria.  

In this light, the Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/23665 
granting a derogation to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LT, LU, MT, NL, PL, PT, 
RO, SE, SI, and SK for the TS system referred to in Article 145 of the UCC. The derogation applies 
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: 

Complexity 
Rating 

Risk 
Level 

MS 

AT 

BE 

6 

Medium 

Additional Comments 

BE  reported  a  delay  in  the  TS  project.  However,  despite  this 
delay,  the  overall  delivery  is  still  expected  to  meet  the 
Deployment  deadline.  The  delay  is  primarily  due  to  the 
complexity of the Conformance Testing activities and the need 
to coordinate with other systems that have different deadlines. 
BE  anticipates  a  delay  of  two  quarters  for  the  Conformance 

57 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
58 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
59 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
60 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
61 Information provided from a bilateral meeting between AT and DG TAXUD held on 06/06/2023. 
62 Information provided from FR on 18/10/2023 regarding the progress of the UCC project on AN/PN/TS. 
63 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
64 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 
65 Commission Implementing Decision (EU) 2023/236 of 1 February 2023 granting a derogation requested by certain Member 
States  pursuant  to  Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of  the  Council  to  use  means  other  than 
electronic data-processing techniques for the exchange and storage of information for the Temporary Storage declaration related 
to non-Union goods presented to customs (OJ L 32, 3.2.2023, p. 223-225). 

28 

 
 
 
 
 
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

BG 
CY 

CZ 

5 
6 

2 

DE 

4 

4 

4 
6 
6 
5 

3 

5 
3 
4 

4 

DK 

EE 
ES 
FI 
FR 
GR 

HR 

HU 
IE 
IT 

LT 

LU 

Low 

Low 
High 

Testing phase and four quarters for the Deployment phase. An 
Agile approach is being employed for the system development. 
Same response as for PN. 
Same response as for PN. 
CZ indicated that following the derogation, the Deployment is 
planned  for  the  end  of  2023.  Functional  and  Technical 
Specifications were completed and the communication with the 
Common  Repository  is  in  production.  CZ  explained  that  a 
significant  reduction  in  the  financial  budget  for  the  Customs 
Administration of the Czech Republic has triggered a negative 
impact  at  the  level  of  personal  relationships  and  contractual 
relationships  with  external  software  providers.  Therefore,  the 
ability  to  maintain  a  high  level  of  digitisation  and  volume  of 
modernised systems has been reduced. 
DE indicated that the TS project was completed on 31/10/2022. 
TS was updated as part of the NES of the national IT-System 
ATLAS (Release 9.1) for which the EOs were allowed to carry 
out migration from 01/05/2021 until 14/10/2022. 
DE drew attention to the fact that the data model is not in line 
with the EUCDM and will be updated following the approach 
of  CCI  and  NIS,  which  will  be  the  basis  for  the  new  and 
modernised import application. The project conforms to the data 
requirements of the new Annex B of the Commission Delegated 
Regulation  (EU)  2021/234.  However,  it  does  not  currently 
comply with the formats and codes set out in the Implementing 
Act (IA). 
DK reported that the TS system development is on schedule, but 
the release has been postponed due to the fact that DK focused 
on  ‘going  live’  with  AES,  NCTS  and  ICS2.  Therefore,  DK 
expects to ‘go live’ on 15/10/2024 and thus, indicates that it will 
not  reach  the  derogation  deadline.  DK  is  using  an  Agile  and 
iterative approach for the development of the system. 
Same response as for PN. 
Same response as for PN. 
Same response as for PN. 
Medium  Same response as for PN. 

Low 
High 
High 

Medium 

Low 

Low 

HR explained that the Deployment for TS is set for 17/04/2023 
and  the  overall  status  of  the  project  is  on  target.  Technical 
Specifications  are  already  completed  and  the  Conformance 
Testing activities took place in January 2023. 

Low 
Low 

Medium  Same response as for PN. 
Same response as for PN. 
Same response as for PN. 
The implementation of TS for all EOs by LT will follow a ‘big 
bang’ approach and the legacy system will be kept accessible, 
but  no  processing  of  new  declarations  will  occur 66 . 
Conformance Testing will be conducted until November 2023, 
with Deployment scheduled for the end of December 2023. 
Same response as for PN. 

Medium 

66 Information provided from a bilateral meeting between LT and DG TAXUD held on 01/06/2023. 

29 

 
 
 
 
 
 
 
 
MS 

LV 

MT 

Complexity 
Rating 

Risk 
Level 

3 

Low 

NL 

5 

Medium 

PL 

3 

Low 

PT 

6 

High 

Additional Comments 

LV  shared  that  the  TS  system  is  updated  to  the  latest 
requirements and is used also for postal consignments67. 
Same response as for PN. 
NL is uncertain whether the EOs and their IT service providers 
will be prepared in time, between 01/12/2023 and 29/02/2024, 
to  submit  the  TS  declaration  in  line  with  the  new  Technical 
Specifications. NL will provide the software developers of the 
EOs with a self-service testing facility that they can use to test 
whether their system meets the nationally-developed Functional 
and  Technical  System  Specifications  (TSS)  regarding  the  TS 
declaration.  NES  NL's  functionalities  to  process  the  TS 
declaration will ‘go live’ at the latest on 01/12/2023. Regarding 
the functionalities of the TS system, NL mentioned that (1) the 
TS declaration may be submitted, changed and invalidated by 
the  declarant,  (2)  the  TS  declaration  may  be  invalidated  by 
Customs if goods are not presented, and (3) it will be possible 
to take over data from a previously lodged ENS declaration into 
the TS declaration. Overall, NL indicated that delivery, while 
delayed, is still foreseen within the  Deployment deadline. NL 
plans to Deploy the TS system for air transport on 01/12/2023 
and for maritime transport on 01/06/202468. The causes of the 
delay are Brexit, COVID-19 and the number of functionalities 
required  to  be  developed  for  ICS2  using  the  same  human 
resources as for other UCC and national projects. Therefore, NL 
has implemented a package of mitigating measures to address 
this delay. NL is using an Agile approach for the development 
of this system. 
Same response as for PN. 
The implementation of the national TS system in PT has been 
delayed beyond the expected deadline due to the complexity of 
integrating  various  national  systems,  such  as  ICS2,  NIS,  the 
Risk  Management  System,  TS  Facilities  systems,  Ports 
Authorities, and Airport Authorities. Operations are planned in 
the second half of 202469. In order to mitigate the delay, PT has 
adopted  an  Agile  development  approach,  to  reduce  the 
implementation  timeframe  and  has  improved  its  planning  to 
meet  the  required  deadline.  However,  PT  is  currently  facing 
procurement and tendering difficulties, particularly in renewing 
contracts with companies developing the systems, which may 
lead to an implementation of the national TS system beyond the 
Deployment deadline established in the granted derogation.  
Implementing a partial deployment approach is not feasible due 
to the high risk associated with implementing a completely new 
national  TS  system.  The  national  system  that  will  cover  AN, 
PN, and TS projects integrates all the information regarding the 
entry and exit of means of transport (air and sea) as well as the 
entry and exit of goods (import/export manifest). This national 
system  will  also  include  the  control  of  Electronic  Transport 
Document, Regular Shipping Service, and African, Caribbean 

67 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
68 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
69 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 

30 

 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

and Pacific Countries (ACP) authorisations in the import/export 
manifest. Upon the entry of goods, the system will be integrated 
with ICS2, the Risk Management System and NIS. At the exit 
of goods, the system will be integrated with AES-C1 and AES-
C2  and  the  Risk  Management  System  to  control  the  exit  of 
goods with automatic exit certification for export.  
In maritime traffic, the customs system is interconnected with 
the  system  of  the  port  authorities  in  a  single-window 
environment similar to EMSW. This requires the port system to 
be  completely  redesigned  to  follow  the  developments  of  the 
UCC WP. To facilitate implementation, a test environment will 
be made available to the EOs. Ongoing activities with ports and 
airports  authorities  are  being  carried  out  to  ensure  a  smooth 
integration.  Development  is  ongoing,  but  the  most  impacted 
milestones  are  Conformance  Testing  and  Deployment,  which 
were postponed to 2023, due to the complexity of developments 
with ports and airports and the need for a longer time period for 
Conformance  Testing  activities.  In  July  2022,  Technical 
Specifications for the EOs were published. 
Same response as for PN70. 
SE  indicated  that  it  will  not  meet  the  deadline  set  in  the 
derogation Implementing Decision. SE plans to have the system 
developed by end 2024 and ready for sea freight by 202571. SE 
the  interface  with 
draws  attention  to 
the  fact  that  if 
MSW/EMSW 
the 
Operations date may be impacted (scheduled on 15/08/2025). 
During the first half of 2021, the plan for the UCC projects to 
be implemented was reviewed and new dates were set. Based 
on  that,  SE  has  been  able  to  reprioritise  and  increase  the 
resources  for  this  project  in  terms  of  allocated  human  and 
economic resources. Currently, SE is assessing the possibility 
of  integrating the  application  developed  by  BE  in  the  ETCIT 
cooperation into its existing IT infrastructure and investigating 
the feasibility of using a national application to some extent as 
an alternative. 
SI mentioned that the overall status of the project is on target 
and  will  be  completed  by  the  end  of  2023.  TS  is  part  of  the 
Slovenian Automated Import System (SIAIS2) declaration. The 
declaration for TS will be harmonised with column G4 of the 
new Annex B of the Commission Delegated Regulation (EU) 
2021/234. 
SK shared that the Deployment of the TS system is planned by 
the end of 2024, mainly due to a lack of human resources72. 

implemented  for  maritime 

traffic, 

is 

RO 

SE 

4 

Medium  

SI 

SK 

3 

1 

Low 

High 

Table 12: Detailed responses from Member States – TS 

70 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
71 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
72 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

31 

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

Figure 3: Project Status as per Survey – TS 

32 

 
 
 
3.1.2.  Overview of Project Progress 

Table 13, Table 14 and Table 1573 highlight any known divergences in the planning compared to the 
dates set in the UCC WP. As this project has a deployment window, the ‘Deployment’ and ‘Operations’ 
columns are shown. If there is a difference in these two dates, this implies that a migration period is 
planned. 

In  regards  to the implementation  of  Arrival  Notification  (AN), the following  Member  States  have a 
planned/actual  Operations  date  that  is  later  than  the  deadline  in  the  UCC  WP  and/or  the  granted 
derogation  deadline74:  DE,  FI,  FR,  GR,  LT,  MT,  and  SE.  HR  did  not  provide  information  on  the 
Operations date, while IE indicated the project as not applicable. 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 – AN 

73 The 2023 % of Completion is updated based on the survey replies. The Actual/Planned dates are updated based on the updates 
on the Project National Plans provided by the Member States and the information shared in bilateral meetings between the 
Member States and DG TAXUD. Some of the Deployment dates indicated refer to air traffic. For maritime traffic, other dates 
could be applicable. For more details, please refer to the ‘Detailed Responses’ section of each project. 
74 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/235, granting a derogation to AT, BE, 
BG, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LU, MT, NL, PL, PT, RO, SE, SI, and SK from 01/01/2023 until the deployment 
of the AN system, but not later than 31/12/2023, for air transport and 01/03/2024 for maritime transport or inland waterways, 
whichever date is sooner. 

33 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP74 2023 Planned/ Actual Date2023 % of Completion Target date from WP742023 Planned/ Actual DateAT01/11/2021Not ProvidedN/AN/AN/AN/A01/07/2023BENot ProvidedNot Provided30/06/2023Not Provided30/06/2023Not Provided01/03/2023BG28/03/2022100%15/12/2022100%01/03/2023Not Provided01/03/2023CY22/05/2023100%Not Provided100%07/11/2023100%07/11/2023CZN/AN/AN/AN/A01/03/2023N/A01/10/2023DEN/AN/AN/AN/A01/03/2023N/A02/10/2023DK01/09/2021100%30/06/2023100%31/10/2023100%31/10/2023EE02/10/2023100%31/08/2023100%01/10/2023Not Provided03/10/2023ESN/AN/AN/AN/AN/AN/A02/10/2023FI30/06/2022100%Not ProvidedNot Provided31/03/2023Not Provided31/03/2023FRN/A100%N/A100%01/07/2023100%01/06/2024GR31/12/2023N/ANot ProvidedNot Provided31/12/2024Not Provided31/12/2024HRNot ProvidedNot ProvidedNot Provided100%01/07/2023Not ProvidedNot ProvidedHU30/06/2023100%15/12/2023100%31/12/2023100%31/12/2023IEN/AN/AN/AN/AN/AN/AN/AIT01/06/2022100%12/12/2022100%13/12/2022100%13/12/2022LT01/06/2020100%01/03/2023Not Provided01/03/2023100%01/10/2023LU01/06/2022Not Provided28/02/2023Not Provided01/03/2023100%01/03/2023LVN/A100%N/A100%24/09/2017100%25/09/2017MT30/11/2023100%01/05/2024Not Provided01/06/2024100%01/06/2024NL16/03/2023100%14/06/2023100%01/07/2023Not Provided01/10/2023PL01/01/2023N/A30/09/2023N/A01/12/2023N/A30/09/2023PT31/12/2022100%30/09/2024100%28/10/2024100%29/10/2024RO30/11/2021Not provided31/01/2023Not Provided01/10/2023Not Provided30/09/2023SEN/AN/AN/A100%01/03/2023100%31/03/2025SI01/10/2022100%01/02/2023100%01/03/2023100%01/03/2023SK01/10/20220%14/02/20230%01/03/20230%01/03/2023To be defined by MS and for Notification of Arrival in line with ICS2 planningTo be defined by MS as part of the national plan31/12/2022Technical SpecificationsConformance TestingDeployment(Start of the deployment window)RespondeeOperations(End of the deployment window) 
 
 
 
 
 
 
 
 
 
 
In  regards  to  the  implementation  of  Presentation  Notification  (PN),  the  following  Member  States 
indicated a planned/actual Operations date for PN, which is later than the deadline set in the UCC WP 
and/or the granted derogation deadline75: BG, ES, GR, LT, MT, PT, and NL. FR, HR, and RO did not 
provide information on the Operations date. 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 – PN 

75 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/234, granting a derogation to AT, BE, 
CY, CZ, DK, EE, ES, FR, GR, HU, HR, LU, MT, NL, PL, PT, RO, SE, SI, and SK from 01/01/2023 until the deployment of 
the PN system, but not later than 31/12/2023, for air transport and 01/03/2024 for maritime transport, inland waterways, road 
or rail transport, whichever date is sooner. 

34 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP75 2023 Planned/ Actual Date2023 % of Completion Target date from WP752023 Planned/ Actual DateAT01/11/2021Not ProvidedN/AN/A21/06/2023Not Provided01/07/2023BE12/10/2021Not Provided30/06/2023Not Provided05/07/2023Not Provided01/10/2023BG04/08/2023100%16/10/2023100%23/10/2023100%23/10/2023CY22/05/2023100%Not Provided100%07/11/2023100%07/11/2023CZ01/03/2023100%30/09/2023100%01/03/2023100%01/10/2023DE09/10/2020100%14/10/2022100%06/03/2021100%31/10/2022DK01/09/2021100%30/06/2023100%31/10/2023100%31/10/2023EE02/10/2023100%31/08/2023100%01/10/2023100%03/10/2023ES30/06/2022100%15/09/202420%01/03/202480%02/10/2024FI31/03/2020100%Not Provided100%31/03/2021100%31/03/2021FR31/03/2023100%N/AN/A06/03/2024100%Not ProvidedGR31/12/2023Not ProvidedNot ProvidedNot Provided31/12/2024Not Provided31/12/2024HR01/04/2022100%31/12/2022Not Provided01/03/2023Not ProvidedNot ProvidedHU30/06/2023100%15/12/2023100%31/12/2023100%31/12/2023IE04/10/2019Not Provided04/10/2021Not Provided23/11/2020Not Provided05/10/2021IT01/06/2022100%12/12/2022100%13/12/2022100%13/12/2022LT01/07/2022100%01/03/2023100%28/02/2023100%01/10/2023LU14/12/2021Not Provided01/07/2023Not Provided10/01/2023Not Provided10/01/2023LV05/06/2017100%22/09/2017100%24/09/2017100%25/09/2017MT30/11/2023100%01/05/2024N/A01/06/2024100%01/06/2024NL01/04/2022100%01/12/2023100%01/12/2023100%01/03/2024PL01/01/2023N/A31/12/2023N/A31/12/2023N/A31/12/2023PT31/12/2022100%30/09/2024100%28/10/2024100%29/10/2024RO31/03/2023Not Provided31/12/2023Not Provided01/10/2023Not ProvidedNot ProvidedSE01/12/2022100%31/12/202375%27/09/202375%31/12/2023SI01/10/2022100%01/02/2023100%01/03/2023100%01/03/2023SK01/02/20230%31/08/20230%01/10/20230%01/10/2023To be defined by MS and for Notification of Arrival in line with ICS2 planningTo be defined by MS as part of the national plan31/12/2022RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In regards the implementation of  Temporary Storage (TS), the following Member States indicated a 
planned/actual Operations date for TS, which is later than the deadline in the UCC WP and/or the granted 
derogation deadline76: BG, CZ, DK, ES, GR, MT, NL, PT, SE, SI, and SK. AT, FR, HR, and RO did 
not provide information on the Operations date. 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 15. 

Table 15: Comparison of Planned and Actual Dates – TS  

76 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/236, granting a derogation to AT, BE, 
CY, CZ, DK, EE, ES, FR, GR, HU, HR, LT, LU, MT, NL, PL, PT, RO, SE, SI, and SK from 01/01/2023 until the deployment 
of the TS system, but not later than 31/12/2023, for air transport and 01/03/2024 for maritime transport, inland waterways, road 
or rail transport, whichever date is sooner. 

35 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP76 2023 Planned/ Actual Date2023 % of Completion Target date from WP762023 Planned/ Actual DateATNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedBE12/10/2021100%30/10/2023Not Provided29/11/2023Not Provided01/12/2023BG04/08/2023Not Provided16/10/2023100%23/10/2023100%23/10/2023CY02/05/2023100%Not Provided100%07/11/2023100%07/11/2023CZ01/09/2023100%31/12/2023100%31/12/2023100%01/01/2024DE09/10/2020100%14/10/2022100%06/03/2021100%31/10/2022DK01/11/2023100%15/10/20240%15/10/20240%15/10/2024EE02/10/2023100%31/08/2023100%01/10/2023100%01/07/2021ES30/06/202220%15/09/202380%01/03/2024Not Provided02/10/2024FI31/12/2020100%Not Provided100%31/12/2022100%31/12/2022FR31/03/2023100%N/A100%06/03/2024100%Not ProvidedGR31/12/2023Not ProvidedN/AN/A31/12/2024Not Provided31/12/2024HR25/02/2022100%28/02/2023100%01/12/2022100%Not providedHU30/06/2023100%15/12/2023100%31/12/2023100%31/12/2023IE04/10/2019100%04/10/20210%23/11/20200%05/10/2021IT01/06/2022100%12/12/2022100%13/12/2022100%13/12/2022LT04/05/2023100%31/10/2023100%31/10/2023100%31/10/2023LU14/12/2021Not Provided01/07/2023Not Provided10/01/2023Not Provided10/01/2023LV05/06/2017100%22/09/2017100%24/09/2017100%25/09/2017MT30/11/2023100%01/05/2024Not Provided01/06/2024100%01/06/2024NL01/09/2022Not Provided01/12/2023100%01/12/2023100%01/03/2024PL29/07/2022Not Provided31/12/2023Not Provided31/12/2023Not Provided31/12/2023PT31/07/2022Not Provided30/09/2024100%28/10/2024100%29/10/2024RO31/03/2023Not Provided31/12/2023Not Provided01/10/2023Not ProvidedNot providedSENot Provided0%Not Provided0%01/10/20240%31/12/2024SI28/04/2023Not Provided02/10/2023100%30/11/2023100%01/01/2024SK01/06/20240%31/05/20250%02/06/20250%02/06/2025To be defined by MS and for Notification of Arrival in line with ICS2 planningTo be defined by MS as part of the national plan31/12/2022RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
 
Regarding AN, additional details on the specific percentage of completion per milestone can be seen in 
Figure 477. 

Figure 4: Percentage of Completion per Phase – AN78 

77 The target operations date from Member States that have been granted a derogation refers to air transport. For other transport 
modes, Member States have until 01/03/2024. 
78 Technical  Specifications  (TS)  are  indicated  in  red,  Conformance  Testing  (CT)  in  yellow,  Deployment  (D)  in  green  and 
Operations (O) in blue. In the case where the Deployment and Operations dates are the same, both phases are merged (DO) 
and shown together in blue. The red line indicates the target dates from the UCC WP, while the red broken line represents the 
deadline  provided  in  the  derogation  granted  to  the  Member  States  mentioned  in  the  'Important  Remark'  section  of  the 
corresponding project. 

36 

 
 
 
 
Regarding PN, additional details on the specific percentage of completion per milestone can be seen in 
Figure 579. 

Figure 5: Percentage of Completion per Phase – PN 

79 The target operations date from Member States that have been granted a derogation refers to air transport. For other transport 
modes, Member States have until 01/03/2024. 

37 

 
 
 
 
Regarding TS, additional details on the specific percentage of completion per milestone can be seen in 
Figure 680. 

Figure 6: Percentage of Completion per Phase – TS 

80 The target operations date from Member States that have been granted a derogation refers to air transport. For other transport 
modes, Member States have until 01/03/2024. 

38 

 
 
 
 
3.2. UCC NATIONAL IMPORT SYSTEMS (NIS) UPGRADE 

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 NIS has to be upgraded in line with these new UCC 
requirements. 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 the EU level.  

The upgrade mainly relates to: 

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

b)  Changes for Centralised Clearance at the national level; 
c)  Changes to the exchange of information; 
d)  Adjustments of the respective messages with the datasets in Annex B to the UCC Delegated 

Act (DA) and UCC IA; 

e)  Impact of changes in other electronic systems at national level.  

3.2.1.  Summary of Responses 

Summary from the Member States: 

Most Member States 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.  

BG, IT, and LV upgraded their NIS in line with the UCC and the requirements of the Annex B of the 
Commission Delegated Regulation (EU) 2015/2446 that was in force at that moment. They implemented 
NIS  within  the  legal  deadline  of  31  December  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 new Annex 
B of the Commission Delegated Regulation (EU) 2021/234, by the date they deploy the  Centralised 
Clearance at Import (CCI) Phase 1 system81. 

Other  Member  States decided to concentrate  first on  the  development  of other systems and  wait for 
further progress on the specifications for the trans-European system related to import, being the CCI 
system. These are those Member States that decided not to upgrade their existing NIS, but to build a 
completely new one. 

If  not  already  done,  updates  to  align  their  systems  with  the  provisions  of  the  new  Annex  B  of  the 
Commission Delegated Regulation (EU) 2021/234 will happen by the end of 2023.   

Most Member States indicated a high level of complexity  of the project, mainly  associated with the 
many  interdependencies  with  other  systems  at  the  national  level.  Member  States  that  are  currently 
developing NIS using an Agile development approach to reduce the implementation timeframe and to 
minimise the impact on milestones. 

Several Member States progressed well, with Technical Specifications either completed or in progress 
for almost 78% of the Member States. The Member States that already completed the project are DE, 
EE, ES82, FI, HR, IE, IT, LU83, PL, and SI. The Member States that envisage the NIS implementation 
by the end of 2023 are BE84, BG, CY, ES, FR, HU, LT, NL, RO85, and SE (see Table 16 below, as 
adjusted to the latest developments). Some other Member States (AT86, CZ, DK, GR, MT, PT, and SK87) 
do not expect to reach implementation by the end of 2023. 

81 Article 2(4a) of Commission Delegated Regulation (EU) 2015/2446. 
82 Information provided from a bilateral meeting between ES and DG TAXUD held on 23/11/2023. 
83 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
84 Information provided from a bilateral meeting between BE and DG TAXUD held on 14/06/2023. 
85 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
86 Information provided from a bilateral meeting between AT and DG TAXUD held on 06/06/2023. 
87 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

39 

 
 
 
 
Important remark: 

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

In this light the Commission adopted an Implementing Decision (EU) 2023/23788 on 1 February 2023, 
granting a derogation to AT, BE, CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, RO, and SE for 
the  NIS  system  to  use  means  other  than  electronic  data-processing  techniques  for  the  exchange  and 
storage of information. The derogation applies from 1 January 2023 until the deployment of NIS, but 
not later than 31 December 2023. 

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

5 

Low 

CY 

6 

High 

CZ 

1 

High 

BG  is  planning  an  update  of  NIS  in  accordance  with  the 
requirements set out in the Commission Delegated Regulation 
(EU) 2021/234. According to internal plans, a test version of the 
updated import system is expected in the middle of 2023 and 
full Deployment is planned for 31/10/2023. The IT projects are 
implemented using the TOGAF/ADM and RUP methodologies. 
BG indicated that an Agile approach is being used. 
Same  response  as  for  TS.  In  addition,  CY  explained  that  all 
milestones  were  impacted  due  to  delays  in  the  public 
procurement procedure and given the decision to develop and 
operate  the  Import  Declarations  System  and  its  interfaces  by 
using  the  EUCDM  v6.1.  Mitigating  measures  such  as  the 
allocation of extra human and other resources, are planned. The 
specifications and the implementation of the system took place 
in  2022.  Throughout  2023,  informational  and  promotional 
campaigns and meetings with the EOs and other stakeholders 
will be organised. 
CZ indicated that the Technical Specifications are expected to 
be  published  in  April  2024  and  the  system  is  planned  to  be 
operational  in  December  2024.  Delays  in  the  system's 
development  occurred  during  the  contractor's  work  on  the 
functional  specifications,  prompting  intensive  communication 
between CZ and the contractor to address the situation. Despite 
the  allocation  of  additional  resources,  the  situation  has  not 
shown  significant  improvement.  While  assurances  have  been 
given regarding the operational date, there are lingering doubts 
due to the contractor's slow progress resulting from insufficient 
resources89.  

88 Commission Implementing Decision (EU) 2023/237 of 1 February 2023 granting a derogation requested by certain Member 
States to use means other than electronic data-processing techniques for the exchange and storage of information related to the 
customs declaration for goods brought into the customs territory of the Union laid down in Articles 158, 162, 163, 167, 170 to 
174, 201, 240, 250, 254 and 256 of the Regulation (EU) No 952/2013 of the European Parliament and the Council laying down 
the Union Customs Code (OJ L 32, 3.2.2023, p. 226-228). 
89 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 

40 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

CZ is using an Agile approach for its development. CZ clarifies 
that  a  significant  reduction  in  the  financial  budget  for  the 
Customs Administration of the Czech Republic has triggered a 
negative  impact  at  the  level  of  personal  and  contractual 
relationships. Therefore, the ability to maintain a high level of 
digitisation  and  volume  of  modernised  systems  has  been 
reduced. 
Same response as for TS. 
DK indicated a high complexity of activities for this project due 
to the high number of national requirements for import, which 
require  new  developments  to  the  standard  system.  After  a 
replanning and a new prioritisation of the MASP projects in the 
Danish  UCC  Programme,  DK  decided  to  prioritise  the 
implementation of the trans-European releases ICS2, AES and 
NCTS-P5,  in  order  not  to  compromise  the  work  in  other 
Member States. Due to the need to prioritise the implementation 
of those UCC projects, DK will not be able to implement NIS 
on  31/12/2023.  DK  reported  a  good  progression  in  the 
development of the Danish NIS and has implemented an Agile 
setup  (Scaled  Agile  Framework  [SAFe]).  DK  expects  to 
implement  NIS  on  15/10/2024  and,  thus,  does  not  expect  to 
meet the derogation deadline. 
New NIS was implemented by the Estonian Tax and Customs 
Board and has been in operation since 01/07/2021. 
While  ES  has  had  an  old  legacy  system  in  production  since 
September 2022, a new NIS system ensuring full compatibility 
on  ES’s  external  domain  with  Annex  B  was  Deployed  in 
September 2023. This system allows SURV3 requirements to 
be  fulfilled.  In  parallel,  ES  shared  that  there  is  a  fully  new 
system,  including  CCI,  undergoing  Conformance  Testing  and 
Deployment  is  scheduled  for  May  2024,  with  a  migration 
window  until  March  2025.  This  transition  is  supported  by  a 
national converter established for EOs that are still in the old 
system, translating the new messages into the current system. 
This internal converter will be updated in April 202490. 
ES has implemented an iterative development methodology. 
FI explained that the system has been in operation with customs 
warehousing since 2019 and has been in free circulation since 
2020,  with  several  additional  deployments  since 
then. 
Significant  changes  resulting  from  VAT  also  impacted  the 
infrastructure.  FI  shared  that  its  dealing  with  is  a  heavy 
workload and limited resources, including the management of 
outsourcing. Some functions were prioritised over others and, 
as a result, some manual processes are still to be automated. The 
migration to the new system was completed in April 2023 and 
traders have been using it ever since91.  
FR informed of a high complexity level of activities for NIS due 
to the need to implement new procedures, like the recapitulative 
supplementary  declaration  as  well  as  the  evolving  nature  of 
Annex A (application for authorisation on declaration). FR has 

DE 

4 

Low 

DK 

5 

High 

EE 

6 

Low 

ES 

4 

Low 

FI 

6  

High 

FR 

6 

Medium 

90 Information provided from a bilateral meeting between ES and DG TAXUD held on 23/11/2023. 
91 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 

41 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

implemented mitigating measures, such as adding more human 
resources  and  working  alongside  connected  projects. A  new 
planification of NIS will be available by September 2023. This 
delay  is  necessary  in  light  of  the  complexity  of  the  above-
mentioned features and to have a better change management for 
the  customs  offices.  FR  is  working  on  a  tight  schedule  and 
unexpected events could further delay the planning. 
GR indicated delays to the start call for tender procedures, with 
internal discussions  under way  to  assess the  situation  and the 
impact  on  all  milestones  and  estimates  the  signature  of  the 
contract to be in Q4 2023. GR plans to update the NIS system 
to  accommodate  the  new  data  requirements  necessary  for 
sending  the  full  Surveillance  dataset.  A  derogation  extension 
request has been submitted92. 
NIS  was  implemented  on  01/01/2023  and  has  been  in 
Operations ever since. 
HU is currently undergoing a redesign of the NIS system. The 
necessary  IT  programmes  were  completed  to  overcome 
previously  identified  barriers  and  professional  tests  are  in 
progress.  In  parallel,  development  work  is  underway.  The 
system upgrade is expected to be Deployed by 10/09/2023 and 
the old and new systems will run in parallel until the end of 2023 
to allow for a gradual and smooth transition of the EOs93. 
NIS  was  implemented  in  November  2020  with  the  dataset 
applicable at the time before changes were implemented to the 
dataset  of  the  new  Annex  B  of  the  Commission  Delegated 
Regulation  (EU)  2021/234.  IE's  NIS  will  be  aligned  with  the 
new Annex B. IE indicated that it is carrying out many parallel 
developments under way. 
IT  shared  that  the  new  NIS  was  implemented  by  the  Italian 
Customs and has been in operation as planned according to the 
deadlines of Annex B. 

Medium  Same response as for TS. 
Same response as for TS. 

MT  shared  that  while  the  development  of  the  system  is 
progressing, system and conformance testing still needs to be 
done. A one-year delay is expected for the Deployment of the 
system  due  to  testing  requirements,  integration  with  other 
systems and ongoing tendering processes94. 
The  overall  status  for  the  system  deployment  is  assessed  as 
being on target. Deployment took place incrementally between 
April 2022 and March 2023. NL shared that the system will be 
ready  in  2023,  but  there  is  still  uncertainty  about  traders’ 
readiness95. NL indicated that an Agile approach is being used 
for the system development. 
The  overall  status  for  the  system  Deployment  is  assessed  as 
being on target, as Deployment took place in 01/04/2023. The 

Low 

Medium 

GR 

HR 

HU 

6 

6 

6 

High 

Low 

High 

IE 

4 

Medium 

Low 

IT 

LT 
LU 
LV 

MT 

NL 

PL 

5 

4 

6 

3 

92 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
93 Information provided from a bilateral meeting between HU and DG TAXUD held on 07/09/2023. 
94 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
95 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 

42 

 
 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

entities 

increases 

connections,  which 

Conformance Testing phase for the EOs ended on 04/11/2022, 
while tests with the central systems ended on 02/01/2023.  PL 
shared that the system is already fully aligned to Annex B but 
will  be  further  updated  to  the  new  version96.  The  main  risks 
identified related to the organisational changes and fluctuation 
of  the  human  resources.  Additional  risks  may  come  from 
funding  shortages.  For  the  system  development,  PL  used  an 
Agile and an iterative approach. 
The  implementation  of  NIS  has  been  delayed  beyond  the 
expected Deployment deadline. Operations are planned in the 
second  half  of  202497.  The  cause  of  the  delay  is  due  to  the 
complexity  of  integrating  various  national  systems.  The  new 
NIS  not  only relates  with  the  existing system,  but  also  to the 
development of all national, central systems/modules, national 
the 
and  EU 
interdependencies and the complexity of the ‘global system’. To 
mitigate  the  delay,  PT  has  adopted  an  Agile  development 
approach  to  reduce  the  implementation  timeframe  and  has 
improved  its  planning  to  meet  the  required  timeframe. 
However,  PT  is  currently  facing  procurement  and  tendering 
difficulties,  particularly  in  the  renewal  of  contracts  with  the 
companies  developing  the  systems,  which  may  lead  to  an 
implementation  of  NIS  beyond  the  Deployment  deadline 
established in the granted derogation. According to PT, a partial 
deployment approach cannot be envisaged for the system, given 
the high probability of disrupting NIS. The test environment is 
available to the EOs even though they have not started testing 
yet. Development is ongoing on Webforms and Webservices. 
Same response as for TS98.  
SE is progressing to meet the deadline for the completion of NIS 
on  31/12/2023  and  reiterated  its  intention  of  performing  a 
phased  implementation.  The  information  provided  by  SE 
regarding  NIS 
the  standard  customs 
declaration.  The  standard  customs  declaration  (excluding  SP) 
was deployed on 15/03/2022, with a migration period for traders 
until  the  end  of  202399.  The  customs  declaration  for  special 
fiscal territories (H5) will follow the same plan as SP IMP. The 
simplified  declaration  will  be  implemented  during  2024  and 
Entry in  the  Declarant's  Records  during  2025.  The  low  value 
declaration  H7  was deployed  in  April  2023  and  its  Technical 
Specifications  are  available  since  October  2022.  The  test 
environment  for  the  traders  took  place  in  December  2022. 
Concerning 
for  Customs  warehousing 
procedure, SE will perform an update to include requirements 
set  out  in  the  new  Annex  B  of  the  Commission  Delegated 
Regulation (EU) 2021/234. The system will be Deployed during 
2025. 

is  applicable  for 

the  declaration 

PT 

6 

High 

RO 

6 

Low 

SE 

3 

Low 

96 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
97 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 
98 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
99 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 

43 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

SI explained that an increased level of complexity was allocated 
to  the  system  development,  considering  the  team  had  to 
harmonise  the  data  of  the  import  declaration  with  the  new 
Annex  B  of  the  Commission  Delegated  Regulation  (EU) 
2021/234.  This  required  the  reprogramming  of  about  1,000 
national  Rules  and  Conditions,  and  approximately  2,000  risk 
analysis instructions. At the same time, there was a significant 
impact on the system due to the changes in data from EUCDM 
v3.1 to EUCDM v6.1. This caused a delay in the development 
of NIS, as the external environment was not prepared and it was 
challenging  to  work  with.  Furthermore,  communication  was 
highly affected due to the situation created by the COVID-19 
pandemic, adding to the complexity of the system development. 
SI  shared 
to  EUCDM  v6.0  by 
to  update 
31/12/2023100. 
SK shared that the new Annex B is planned to be implemented 
in the system by 01/07/2024 with CCI-P1. A big bang approach 
will be followed for traders. Since the Deployment of the system 
is being delayed beyond the deployment deadline, SK has sent 
a  derogation  request.  SK  explained  that  the  capacity  of 
resources  is  stretched  since  the  same  team  work  on  all  the 
system101. 

that  plans 

SI 

6 

Low 

SK 

Table 16: Detailed responses from Member States – NIS 

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

Figure 7: Summary of Survey Responses – NIS 

100 Information provided from a bilateral meeting between SI and DG TAXUD held on 13/06/2023. 
101 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

44 

 
 
 
 
 
 
3.2.2.  Overview of Project Progress 

Table 17 highlights any divergences in the planning compared to the dates set in the UCC WP. 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 the implementation of  NIS upgrade, the following Member States have a planned/actual 
Operations date that is later than the deadline in the UCC WP and/or the granted derogation deadline102: 
BE, BG, CZ, DK, ES, GR, HR, IE, MT, PL, PT, and SK. AT, FR, and RO did not provide information 
on the Operations date. The specific dates can be found in Table 17 below. 

Table 17: Comparison of Planned and Actual Dates – NIS 

102 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/237, granting a derogation to AT, BE, 
CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, RO, and SE from 01/01/2023 until the deployment of the NIS system, 
but not later than 31/12/2023. Additionally, where Article 2(4a) of Commission Delegated Regulation (EU) 2015/2446 applies, 
Member States will have until 01/07/2024 to deploy the system. 

45 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP102 2023 Planned/ Actual Date2023 % of Completion Target date from WP1022023 Planned/ Actual DateATNot provided80%Not provided0%Not Provided0%Not ProvidedBE01/11/2021Not provided01/10/2023Not provided06/12/2023Not provided31/03/2024BG04/08/2023100%16/10/2023100%23/10/2023100%23/10/2023CY22/05/2023100%Not Provided100%07/11/2023100%07/11/2023CZ01/04/202425%30/11/20240%01/12/20240%01/12/2024DE09/10/2020100%14/10/2022100%06/03/2021100%31/10/2022DK01/11/2023100%15/10/2024Not provided15/10/202430%15/10/2024EE31/12/2020100%30/06/2021100%01/07/2021100%01/07/2021ES14/03/2022100%30/06/2024100%30/09/2023100%30/06/2024FI30/06/2019100%Not provided100%31/12/2019100%31/12/2022FR31/03/202390%N/A100%31/12/202490%Not ProvidedGR31/12/2023100%Not ProvidedNot Provided31/12/20220%01/01/2025HR31/12/2021100%31/12/2022100%01/01/2023100%01/01/2023HU31/07/2022100%17/09/2023100%12/10/2023100%01/11/2023IE23/06/2023100%23/06/2024100%24/06/2024100%24/06/2024IT02/12/2019100%30/06/2021100%01/07/2021100%08/06/2022LT15/07/2023100%01/12/2023100%31/12/2023100%31/12/2023LU03/01/2022Not Provided29/04/2023Not Provided02/05/2023Not Provided02/05/2023LV30/10/2017100%01/06/2018Not Provided03/06/2018Not Provided04/06/2018MTN/A100%N/ANot provided01/02/202560%01/02/2025NL01/01/2022100%01/01/2023100%01/04/2022100%29/09/2023PL29/07/2022100%31/12/2023100%31/12/2023100%31/12/2023PT01/07/2022100%30/09/202440%28/10/2024Not Provided29/10/2024RO31/03/20220%31/12/20220%01/10/20230%Not ProvidedSE15/09/2021100%31/12/2022100%15/03/2022100%31/12/2023SI01/07/2019100%01/10/2021100%01/01/2022100%01/01/2022SK17/02/2023100%31/12/2024Not Provided01/01/2025100%01/01/2025To be defined by MSTo be defined by MS as part of the national plan31/12/2022RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
 
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
8. 

Figure 8: Percentage of Completion per Phase – NIS 

46 

 
 
 
3.3. UCC SPECIAL PROCEDURES – COMPONENT 1 (SP EXP) 

This project aims to accelerate, facilitate and harmonise SP across the Union, by means of providing 
common Business Process Models (BPMs). The national systems will implement all the UCC changes 
required  for  all  the  SP  (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 AES. 

In terms of planning, this project will be implemented in two stages/phases. The first component is the 
national SP EXP with the view to providing the required national electronic solutions for the export-
related special procedure activities.  

The implementation of SP EXP will occur through the AES upgrade project. Therefore, the information 
provided for under this project also applies in this context. 

3.3.1.  Summary of Responses 

Summary from the Member States: 

The Member States mainly indicated a low to medium risk level on the on-time delivery of the project, 
while assessing the complexity as being medium to high.  

The 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. Many  Member  States  also  implemented  Agile  development methodologies to 
reduce the implementation timeframe. 

According to the data analysed, the following Member States indicated the project as complete: BG, 
DE, LT, and SI.  

In  terms  of  assessing the level  of  completeness  of the  system,  approximatively  60% of the  Member 
States that provided updated information reported that the system is on target. ES, FI, FR, SE, and SK103 
indicated that currently the development of the system is delayed beyond the Deployment deadline.  

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

CY 

CZ 

4 

6 

Low 

Low 

BG indicated that since the National SP EXP is part of the AES 
the activities are included in the AES project. 
CY explained that the analysis, preparation of specifications and 
implementation  of  the  SP  EXP  took  place  in  2022  and  the 
process is now almost completed. SP EXP is marked as highly 
complex,  due  to  the  interdependencies  between  core  and 
supporting systems, need for high percentage of availability of 
the systems, limitations in human resources and the COVID-19 
pandemic. The system is planned to ‘go live’ on 24/10/2023. 

DE shared that SP EXP is implemented in line with AES-C1. 
The IT Service Providers and the EOs have to ensure that the 
Conformance Test is planned in time to be connected to the new 
system  by  the  end  date  of  the  soft  migration  from  Export 
Control System – Phase 2 (ECS-P2) to AES, on 29/10/2023 at 
the latest. DE is making use of an Agile development approach 

DE 

4 

Low 

103 Information provided from the updated SK National Project Plan on 07/11/2023. 

47 

 
 
 
 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

in 

the  delivery  of 

in  defined  software  release-cycles.  The  ongoing  activities 
concern the finalisation and fine-tuning of AES, monitoring of 
Operations, preparation of remaining conformance tests for new 
functionalities of AES (e.g., centralised clearance) and ongoing 
Conformance Tests (certification) of the EOs. The end date of 
the  transition  window  for  traders  has  been  shifted  from  June 
2023 to 2029.  
SF  EXP  is  assessed  as  being  on  target.  DK  explained  that  a 
partial  Deployment  took  place  on  29/04/2023  for  the  N1 
certificate and  on 29/07/2023 for N2 and N3 certificates. DK 
implemented a customised SAFe Agile approach for SP EXP, 
which  is  marked  as  highly  complex  because  of  the  many 
stakeholders and the integrations to other national systems. 
SP EXP is being developed alongside AES-C1. EE indicated a 
delay 
the  Technical  Specifications, 
development and Conformance Testing (Mode 1 and Mode 2). 
EE  implemented  an  Agile  approach,  separating  the  analysis, 
development,  delivery  and  testing  activities  into  different 
phases.  
ES assessed the project as being delayed beyond the foreseen 
deadline because SP IMP has to be aligned with the new import 
and export systems, which are not yet ready.  
FI explained that SP EXP is being developed together with the 
national  AES-C1.  AES  will  be  built from scratch,  which  will 
have a significant impact on the on-time delivery of the project, 
given  its  many  integrations  with  several  parallel  projects.  FI 
prioritised NCTS over AES, which will be activated again in Q2 
2023.  The  final  version  of  the  Technical  Specifications  for 
traders  will  be  published  on  25/05/2023.  FI  requested  a 
derogation, as SP EXP is delayed beyond the foreseen deadline, 
due  to  the  existence  of  many  parallel  projects,  the  impact  of 
COVID-19 and limited resources, especially on the side of the 
suppliers.  
FR allocated a high risk and complexity level to SP EXP. The 
project  is  delayed  beyond  the  foreseen  Deployment  deadline, 
due to the need to launch a complete overhaul of FR's export 
and import systems, a process which is complex and requires 
many  of  resources.  As  a  mitigation  measure,  FR  has  divided 
AES into several parts. The first delivery (accounting for 80% 
of  SP  EXP)  will  be made  alongside  the  AES  delivery,  in  Q4 
2024. The other features will be delivered in a later batch with 
another version of SP EXP during 2025. 

DK 

6 

Low 

EE 

6 

Medium 

ES 

5 

Medium 

FI 

6 

High 

FR 

6 

High 

GR 
HR 

HU 

3 

3 

Low 

Low 

HR stated that SP EXP is being developed together with AES. 
HU  indicated  that  the  project  is  on  target.    In  addition,  it 
informed  that  in  parallel  to  the  professional  design  tasks,  the 
tasks related to the IT physical and logical planning phase are 
currently being carried out. Developments in SP EXP will be 
implemented within the context of AES. 

48 

 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

IE 

6 

Medium 

3 

4 

Low 

Medium 

IT 

LT 

LU 
LV 
MT 

NL 

3 

Low 

PL 

5 

Medium 

transition  handler,  as  well  as 

IE indicated that the status of the project is on target and that SP 
EXP is deployed as part of AES. EE reported that the project 
became  more  complex  due  to  the  Transition  Period  and  the 
requirements  for  a 
the 
implementation  of  the  information  exchange  Conversion 
Application  (ieCA)  and  TP  rules.  The  end  of  the  trader 
migration  window  on  22/05/2023  is  set  as  an  important 
milestone.  Business  continuity  processes  were  implemented, 
which  will  be  followed  by  Centralised  Clearance  for  Export 
(CCE), integration with NCTS-P5 and then Excise Movement 
and  Control  System (EMCS).  Conformance  Testing  activities 
for Mode 2 were completed for the existing business continuity 
and new features of AES, such as CCE, are now under testing. 
The initial ‘go live’ of the project was due on 30/01/23, but due 
to  the  complexities  outlined  above  it  was  pushed  back  to 
21/03/23. 
IT shared that SP EXP is being developed together with AES. 
LT indicated that the Deployment deadline is 01/12/2023 and it 
will  be  Deployed  in  a  ‘big  bang’  mode  for  all  the  EOs.  LT 
pointed  out  that  the  Export  followed  by  Transit  functionality 
could be excluded.  

NL  indicated  that  the  status  of  the  project  is  on  target. 
Conformance Testing is done for the transition phase and the 
post transition phase will be carried out in the coming months. 
An Agile system has been developed, so the transition of traders 
is going to be phased out. 
PL  informed  that  the  status  of  the  project  is  on  target.  The 
implementation of the SP IMP and SP EXP systems has been 
gradually carried out in stages. The system was made available 
to customs officers from 01/07/2021, to monitor the use of SP 
by the EO. The system was then made available on a voluntary 
basis to the interested EOs from 29/11/2021, to submit the Bill 
of Discharge and Inventory. However, from 31/01/2022, all the 
EOs  using  SP  were  required  to  use  some  of  the  indicated 
functions  of  the  system.  The  Regulatory  Procedure  with 
Scrutiny  (RPS)  system  was  implemented  for  all  currently 
available business functions and became mandatory for the EOs 
as  of  28/03/2022.  The  RPS  system  is  fully  operational  in  the 
production version as of one year. One of the important changes 
is an adjustment to the RPS system to collect and process a new 
dataset from  customs  declarations  provided  from the  national 
IMP  system  and  NCTS  system.  Moreover,  relevant  business 
functions concerning the SP were implemented into the national 
IMP and EXP systems. PL indicated that it supplemented the 
SP IMP and SP EXP systems deployed in 2021 with additional 
required UCC SP functions (in the planned dates of 2022 for 
IMP and 2023 for EXP). PL also started working under a new 
IT  contract for  the  second phase of the  SP  IMP and SP  EXP 

49 

 
 
 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

implementation projects – functional development of the AES, 
Automated Import System (AIS) and RPS systems. 
Additionally, developments based on the data requirements of 
the  new  Annex  B  of  the  Commission  Delegated  Regulation 
(EU) 2021/234, are in progress. The identified risk for delay is 
due to the creation of a new IT national RPS system, with new 
functionalities and integration with other IT national customs. 
PL shared that this new system is needed in order to achieve the 
complex  business  goal.  SP  depends  on  the  RPS  system  for 
managing  and  settling  SP  and  it  is  integrated  with  other  IT 
national customs systems, which are currently being expanded. 
The  complexity  of  SP  EXP  is  particularly  high,  due  to  the 
integration with the national IMP and EXP systems in the field 
of online transfer of data from customs declarations regarding 
SP  to  the  RPS  system,  so  the  milestones  might  be  impacted 
depending on the progress of other projects. 
The given dates of project stages concern the contracts currently 
being implemented and the selected key functionalities of UCC 
SP are entered into the SP IMP and SP EXP systems. 
PT  indicated  that  it  is  developing  the  SP  EXP  system  as  an 
integrated part of AES, which poses a high risk associated with 
the  on-time  delivery  of  the  project,  due  to  a  brand-new 
implementation  of  the  AES  system  and  the  integration  with 
different national and EU systems. 
PT  reported that  national, external  and  common  domain  tests 
with central systems and traders are being carried out and that 
an  Agile  development  approach  will  be  used  to  reduce 
implementation  timeframe.  However,  PT  is  currently  facing 
procurement  and  tendering  difficulties,  particularly  with  the 
renewal  of  contracts  with  the  companies  developing  the 
systems. 
RO assessed the project as being on target and implemented an 
iterative approach for its development. RO updated the National 
Planning and provided a 15-day delay for Conformance Testing 
Mode 1. 
SE informed that the deployment of SP EXP is experiencing a 
delay  beyond  the  originally  anticipated  deadline.  This  delay 
occurred because in the first half of 2021, SE revised its plan for 
all projects and subsequently adjusted the dates accordingly. SE 
will  deploy  all  parts  in  01/10/2024  except  for  entry  in  the 
declarants’ records, Exit Summary Declaration (EXS) and re- 
export  notification,  which  will  be  deployed  during  2025.  SE 
pointed  out  that  there  will  be  no  communications  over  the 
common domain in the old format after the end of 2024. 
SP EXP is reported to be completed as of 08/05/2023. 
SK reported that SP EXP is being developed as part of AES and 
assessed  the  project  as  being  delayed.  Planned  Conformance 
Testing will be carried out alongside AES. SK plans to have the 
system in operations by 31/03/2024104. 

PT 

6 

High 

RO 

6 

Medium 

SE 

SI 

SK 

4 

4 

3 

Low 

Low 

Medium 

Table 18: Detailed responses from Member States – SP EXP 

104 Information provided from the updated SK National Project Plan on 07/11/2023. 

50 

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

Figure 9: Project Status as per Survey – SP EXP 

51 

 
 
 
 
 
3.3.2.  Overview of Project Progress 

Table 19 highlights any known divergences in the planning of the SP EXP compared to the dates set in 
the UCC WP. 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  the  implementation  of  the  SP  EXP,  the  following  Member  States  have  a  planned/actual 
Operations date that is later than the deadline in the UCC WP: FI, FR, GR, HU, LU, MT, PT, SE, and 
SK. AT and HR did not provide information on the Operations date. The specific dates can be found in 
Table 19 below. 

Table 19: Comparison of Planned and Actual Dates – SP EXP 

52 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP 2023 Planned/ Actual Date2023 % of Completion Target date from WP2023 Planned/ Actual DateATNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedBE01/09/2021Not Provided01/09/2023Not Provided30/09/2023Not Provided30/09/2023BG31/08/2022100%15/08/2023100%28/08/2023100%28/08/2023CY30/06/2023100%Not Provided100%24/10/2023100%24/10/2023CZ21/10/2021Not Provided01/10/2023Not Provided02/10/2023Not Provided02/10/2023DE09/10/2020100%29/10/2023100%06/03/2021100%29/10/2023DK01/08/2022100%14/07/2023100%29/07/2023100%01/11/2023EE31/03/2022100%01/09/2023100%30/09/2023100%01/10/2023ES05/11/202180%01/11/202280%15/12/202250%15/12/2022FI30/06/2023100%31/12/202430%31/12/202445%31/12/2024FR31/03/2023100%N/AN/A30/09/20240%31/12/2024GR31/12/2023Not ProvidedNot ProvidedNot Provided31/12/2024Not Provided31/12/2024HR31/12/2021100%14/03/2023100%02/05/2023100%Not ProvidedHU31/01/2023100%30/08/2024100%30/08/2024100%30/08/2024IE28/01/2022100%30/03/2023100%21/03/2023Not Provided21/05/2023IT15/02/2021100%07/05/2023Not Provided01/03/2023Not Provided08/05/2023LT04/05/2023100%01/12/2023100%01/12/2023100%01/12/2023LU01/07/2023Not Provided30/03/2024Not Provided01/12/2023Not Provided30/03/2024LVN/AN/A30/09/2023Not Provided02/10/2023Not Provided02/10/2023MTN/A100%N/ANot Provided01/12/2024Not Provided01/12/2024NL01/01/2022100%31/12/2022100%01/04/2022100%29/09/2023PL23/10/2020100%04/05/2021100%01/07/2021100%28/03/2022PT22/02/2023100%31/10/2024100%30/11/2024100%02/12/2024RO06/01/2023100%30/11/2023100%15/05/2023100%01/12/2023SE15/12/202270%20/12/202430%01/10/20240%20/12/2024SI18/12/2020100%23/05/2023100%24/05/2023100%24/05/2023SK03/02/2023100%31/03/20240%01/04/20240%31/03/2024RespondeeTechnical 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 the 
following Figure 10.  

Figure 10: Percentage of Completion per Phase – SP EXP 

53 

 
 
 
3.4. UCC SPECIAL PROCEDURES – COMPONENT 2 (SP IMP) 

This  national  project  aims  to  accelerate,  facilitate  and  harmonise  SP  across  the  Union,  by  means  of 
providing common BPMs. The national systems will implement all the UCC changes required for all 
the SP (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 NIS. 

In terms of planning, this project will be implemented in two stages/phases. The second component is 
the national SP IMP with the view to providing the required national electronic solutions for the import-
related SP activities. 

The implementation of SP IMP will occur through the NIS upgrade project. Therefore, the information 
provided for under this project also applies in this context. 

3.4.1.  Summary of Responses 

Summary from the Member States: 

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

The potential causes for delay indicated by the Member States are the following: implementation of a 
new import system and/or dependencies with other systems, alignment with the new Annex B of the 
Commission Delegated Regulation (EU) 2021/234, lack of resources and procurement delays. Many 
Member States informed that an Agile development methodology has been adopted in order to reduce 
the implementation timeframe. 

According to the analysed data the following Member States indicated the project as completed: DE, 
EE, FI, HR, IT, LT, SI, and SK. 

CZ, ES, GR, MT, PT, and RO reported that currently the development of the system is being delayed 
beyond the Deployment deadline.  

Important remark: 

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

In  this  light  the  Commission  adopted  an  Implementing  Decision  (EU)  2023/237 105 ,    granting  a 
derogation to AT, BG, CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, RO, and SE for the SP 
IMP system to use means other than electronic data-processing techniques for the exchange and storage 
of information. The derogation applies from 1 January 2023 until the deployment of the SP IMP system, 
but not later than 31 December 2023. 

105 Commission Implementing Decision (EU) 2023/237 of 1 February 2023 granting a derogation requested by certain Member 
States to use means other than electronic data-processing techniques for the exchange and storage of information related to the 
customs declaration for goods brought into the customs territory of the Union laid down in Articles 158, 162, 163, 167, 170 to 
174, 201, 240, 250, 254 and 256 of the Regulation (EU) No 952/2013 of the European Parliament and the Council laying down 
the Union Customs Code (OJ L 32, 3.2.2023, p. 226-228). 

54 

 
 
 
 
 
 
 
Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

CY 
CZ 
DE 

4 

6 
1 
4 

Low 

High 
High 
Low 

DK 

6 

Medium 

EE 

ES 

FI 

6 

6 

6 

Low 

Medium 

High 

FR 

5 

Medium 

BG indicated that the National SP IMP is part of NIS. Thus, the 
activities are included in the project adjustments of the existing 
import applications under the UCC. 
Same response as for NIS. 
Same response as for NIS. 
Same response as for NIS. 
The  National  SP  IMP  project  builds  upon  the  same  standard 
solution  as  the  National  SP  EXP.  DK  has  prioritised  the 
implementation of export and transit since they are of a Trans-
European  nature.  The  organisation  and  approach  are  partly 
based on the SAFe with Agile team structures and Agile events 
such as iteration planning and programme increments planning. 
DK indicated its commitment to making the system operational 
by  October  2024.  However,  DK 
identified  risks  and 
complexities related to the many dependencies to other systems, 
parallel developments and the interaction of many stakeholders. 
To face these difficulties, DK has implemented the following 
mitigation  measures:  (1)  improved  the  organisational  project 
structure  in  cooperation  with  the  supplier  delivering  the 
solution, (2) improved the process for handling clarifications, to 
avoid  bottlenecks  and  enable  faster  decision-making  and  (3) 
added resources to ensure legal compliance. 
Same response as for NIS. 
ES assessed the project as being delayed beyond the foreseen 
deadline because SP IMP has to be aligned with the new import 
and export systems, which are not yet ready. ES implemented a 
Scrum methodology for the development of the project. 
Same response as for NIS. 
The delay for NIS has impacted the planning of SP IMP, as SP 
IMP is backed by the NIS application. FR informed of a high 
complexity  level  in  the  SP  IMP  activities  due  to  the 
implementation  of  new  procedures,  such  as  the  recapitulative 
supplementary  declaration,  as  well  as  the  evolving  nature  of 
Annex A (application for authorisation on declaration). FR will 
deliver the functionalities in iterations, and SP IMP is part of 
the  5th  iteration.  A  first  (partial)  version  of  SP  IMP  will  be 
deployed in September 2023, to allow the operators to get used 
to  the  application  before  the  release  of  the  final  version, 
expected  in  2024.  Conformance  Testing  will  be  done  on  the 
national  system.  This  delay  is  necessary  in  light  of  the 
complexity of the above-mentioned features and to have a better 
change management for the customs offices. FR is working on 
a tight schedule and unexpected events could further delay the 
planning.  FR  has  implemented  mitigating  measures,  such  as 
adding more human resources and working alongside connected 
projects. 

GR 

6 

Medium  Same response as for NIS. 

55 

 
 
 
 
 
 
 
 
MS 

HR 

HU 

IE 

IT 

LT 

LU 
LV 
MT 

NL 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

6 

4 

4 

4 

4 

Low 

Low 

Medium 

Medium 

Medium 

SP IMP was implemented alongside NIS on 01/01/2023 and is 
in Operations ever since. 
According  to  HU  the  developments  of  SP  IMP  will  be 
implemented  within the framework of  NIS.  The  necessary  IT 
programs were completed and professional tests are in progress. 
IE indicated that the Deployment date for the SP IMP project 
has shift to June 2024, similarly to the CCI deployment in light 
of  the  alignment  of  its  NIS  with  the  new  Annex  B  of  the 
Commission  Delegated  Regulation  (EU)  2021/234.  IE  is  still 
pending  the  agreement  with  the  external  contractor  on  the 
approach to be used for the system development.  
IT  reported  that  SP  IMP  was  implemented  and  the  necessary 
technical tests with EOs are in progress. 
The implementation of SP IMP for all the EOs will follow a ‘big 
bang’ approach. Conformance Testing will be conducted until 
December  2023  and  Deployment  is  scheduled  for  the  end  of 
December 2023 as well. 

3 

Low 

NL shared that the overall status for the system deployment is 
assessed as being on target. An Agile development approach is 
being used in the system development. 
PL indicated that the implementation of SP IMP and SP EXP 
has been gradually carried out in stages. The system was made 
available to customs officers from 01/07/2021, to monitor the 
use  of  SP  by  the  EOs.  The  system  was  then  made  available 
voluntarily to the interested EOs from 29/11/2021 to submit the 
Bill of Discharge and Inventory. However, from 31/01/2022, all 
the EOs using the SP are required to use some of the indicated 
functions of the system. The RPS system was implemented for 
all currently available business functions and is mandatory for 
the EOs as of 28/03/2022. The RPS System is fully operational 
in  the  production  version  for  one  year.  One  of  the  important 
changes  is  an  adjustment  to  the  RPS  System  to  collect  and 
process a new dataset from customs declarations provided from 
the national IMP system and NCTS system. Moreover, relevant 
business  functions  concerning  the  SP  were  implemented  into 
national  IMP  and  EXP  systems.  PL 
it 
supplemented the Components 1 and 2 deployed in 2021 with 
additional required UCC SP functions (in the planned dates of 
2022 for IMP and 2023 for EXP). PL also started working under 
a new IT contract for the second phase of the Components 1 and 
2 implementation projects (functional development of the AES, 
AIS and RPS systems). 
Additionally, developments based on the data requirements of 
the  new  Annex  B  of  the  Commission  Delegated  Regulation 
(EU) 2021/234. 
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 shared that this 
new system is needed in order to achieve the complex business 

indicated 

that 

56 

PL 

5 

Medium 

 
 
 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

goal. SP depends on the RPS System for managing and settling 
SP and it is integrated with other IT national customs systems, 
which are currently being expanded. The complexity of SP IMP 
is particularly high due to the integration with national IMP and 
EXP systems in the field of online transfer of data from customs 
declarations  regarding  SP  to  the  RPS  System,  so  milestones 
might be impacted depending on the progress of other projects. 
The given dates of project stages concern the contracts currently 
being implemented, and the selected key functionalities of UCC 
SP are entered into SP IMP and SP EXP. 
PT informed that the implementation of the SP IMP system has 
been delayed beyond the expected  Deployment deadline. The 
cause  of  the  delay  is  the  complexity  of  integrating  various 
national systems. The new NIS not only relates with the existing 
system,  but  also  to  the  development  of  all  national,  central 
systems/modules, national and EU entities connections, which 
increases  the  interdependencies  and  the  complexity  of  the 
‘global system’. To mitigate the delay, PT has adopted an Agile 
development approach to reduce the implementation timeframe 
and has improved its planning to meet the required timeframe. 
However,  PT  is  currently  facing  procurement  and  tendering 
difficulties, particularly with the renewal of contracts with the 
companies  developing  the  systems,  which  may  lead  to  an 
implementation of the SP IMP System beyond the Deployment 
deadline established in the granted derogation. According to PT, 
a  partial  deployment  approach  cannot  be  envisaged  for  the 
system, given the high probability of causing the disruption of 
the SP IMP system. 
Same response as for NIS. 
SE reported delays compared to the deadlines indicated in the 
UCC  WP.  The  indicated  Operations  date  for  SP  IMP  is 
30/06/2023.  Regarding  Customs  Warehousing,  the  system  is 
developed but has to be upgraded to the new Annex B of the 
Commission Delegated Regulation (EU) 2021/234. Preliminary 
operational stage is planned for 2024. 
For more detailed information please refer to the NIS section. 
SI shared that SPs are part of the SIAIS2, which has been in use 
since  01/01/2022.  SI  shared  that  a  high  risk  of  delay  was 
inevitable due to the need to harmonise the import declaration 
data with Annex B in the IA / DA H2 (Storage – Declaration for 
customs  warehousing),  H3  (Specific  Use  –  Declaration  for 
Temporary  Admission)  and  H4  (Processing  –  Declaration  for 
inward processing). 
SP IMP, as a part of NIS, was deployed but not in line with the 
new  requirements  introduced  in  the  new  Annex  B  of  the 
Commission Delegated Regulation (EU) 2021/234. SP IMP will 
be aligned with the new Annex B together with NIS by the end 
date of the deployment window for CCI-P1. SK indicated that 
Conformance Testing was carried out at the national level with 
the EOs only. 

PT 

6 

High 

RO 

SE 

6 

3 

Low 

Low 

SI 

6 

High 

SK 

4 

Low 

Table 20: Detailed responses from Member States – SP IMP 

57 

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

Figure 11: Project Status as per Survey – SP IMP 

58 

 
 
 
 
 
3.4.2.  Overview of Project Progress 

Table 21 highlights any known divergences in the planning of the SP IMP compared to the dates set in 
the UCC WP. 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  the  implementation  of  the  SP  IMP,  the  following  Member  States  have  a  planned/actual 
Operations date that is later than the deadline in the UCC WP and/or the granted derogation deadline106: 
AT, BE, CZ, DK, ES, GR, HR, MT, and PT. RO did not provide information on the Operations date. 
The specific dates can be found in Table 21 below. 

Table 21: Comparison of Planned and Actual Dates – SP IMP 

106 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/237, granting a derogation to AT, BG, 
CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, RO, and SE from 01/01/2023 until the deployment of the SP IMP system, 
but not later than 31/12/2023. Additionally, where Article 2(4a) of Commission Delegated Regulation (EU) 2015/2446 applies, 
Member States will have until 01/07/2024 to deploy the system. 

59 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP106 2023 Planned/ Actual Date2023 % of Completion Target date from WP1062023 Planned/ Actual DateATNot ProvidedNot ProvidedNot ProvidedNot Provided03/02/2025Not Provided01/04/2025BE01/11/2021Not Provided01/10/2023Not Provided06/12/2023Not Provided31/03/2024BG04/08/2023100%16/10/2023100%23/10/2023100%23/10/2023CY22/05/2023100%Not Provided100%07/11/2023100%07/11/2023CZ01/04/202425%30/11/20240%01/12/20240%01/12/2024DE09/10/2020100%14/10/2022100%06/03/2021100%31/10/2022DK01/11/2023100%15/10/202410%15/10/202475%15/10/2024EE30/09/2020100%30/06/2021100%01/07/2021100%01/07/2021ES01/04/202290%30/06/202450%30/09/202250%30/06/2024FI01/09/2021100%Not Provided100%30/12/2022100%31/12/2022FR31/03/202280%N/AN/A30/09/202380%15/12/2023GR31/12/2023100%N/AN/A31/12/20240%31/12/2024HR31/12/2021100%31/12/2022100%01/01/2023100%01/01/2023HU31/07/2022100%17/09/2023100%12/10/2023100%01/11/2023IE04/10/2019100%04/10/2021100%23/11/2020100%05/10/2021IT02/12/2019100%30/06/2021100%01/07/2021100%08/06/2022LT15/07/2023100%01/12/2023100%31/12/2023100%31/12/2023LU22/02/2022Not Provided29/04/2023Not Provided02/05/2023Not Provided02/05/2023LV30/10/2017100%01/06/2018100%03/06/2018100%04/06/2018MTN/A100%N/AN/A01/02/202560%01/02/2025NL01/01/2022100%01/01/2023100%01/04/2022100%29/09/2023PL16/11/2020100%04/05/2021100%01/07/2021100%28/03/2022PT31/12/2022100%30/09/2024100%28/10/2024100%29/10/2024RO31/03/2023100%31/12/2023100%31/12/2023100%Not ProvidedSE01/06/2022100%31/12/2023100%20/06/2023100%31/12/2023SI01/07/2019100%01/10/2021100%01/01/2022100%01/01/2022SK27/01/2016100%10/06/2016100%11/06/2016100%11/06/2016To be defined by MSTo be defined by MS as part of the national plan31/12/2022RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
 
Regarding SP IMP, additional details on the specific percentage of completion per milestone can be 
seen in the Figure 12 below. 

Figure 12: Percentage of Completion per Phase – SP IMP 

60 

 
 
 
3.5. UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 2 

3.5.1.  Summary of Responses 

Summary from the Commission: 

ICS2-R2  covers  the  implementation  of  new  ENS  obligations  and  related  business  as  well  as  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 implemented a Safety and Security Analytics (SSA) capability. As part of ICS2-R2, the Safety 
and Security Analytics capability  is integrated within the ICS2  Common  Repository component and 
implements the analytics platform accessible by Member States via Common Communication Network 
2 (CCN2), 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, ICS2-R2 poses new challenges 
compared to ICS2-R1. These challenges include the addition of three new types of EOs involved in air 
transportation supply chains and thirteen different types of ENS filings.  The aim is to bring into the 
system more and better-quality trade data for goods moving towards the EU. ICS2-R2 includes new 
business models that reflect the needs of the industry as well as new 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 a complex Conformance Testing, 
with  numerous  stakeholders  is  expected.  Lastly,  the  migration  strategy  from  ICS2-R1  to  ICS2-R2 
presents a challenge due to the different transition windows. In 2022 DG TAXUD initiated ICS2-R2 
TES (Trans-European system) coordination meetings to ensure the smooth development of the system. 

The conformance environment is ready for Member States testing since 1 July 2022 and for EOs testing 
since 1 September 2022. Most of the Member States completed the Conformance Testing activities as 
planned, while some of them have not completed their Conformance Testing yet. The EO deployment 
window concludes on 1 October 2023 and development is ongoing as planned. 

The ICS2-R2 system was deployed and became operational on 1 March 2023, as planned. Updates were 
made  to the  Common  Repository,  Shared  Trader  Interface  and  Monitoring  components.  The  Shared 
Trade Portal and Safety and Security Analytics started Operations, and the onboarding of end users is 
ongoing. By 22 June 2023, no ICS2-R2 messages were sent by Economic Operators and 19 National 
Administrations passed the ICS2-R2 Conformance Testing. 

Summary from the Member States: 

Most of the Member States indicated that the ICS2-R2 project is highly complex due to interconnections 
between core and supporting systems, high percentage of system availability required, limitations in 
human  resources,  impact  of  the  COVID-19  pandemic  and  Conformance  Testing  issues.  These 
complexities led to delays in Deployment, resulting in the Commission granting derogations to some 
Member States. To mitigate these delays, some Member States are allocating additional resources and 
using Agile system development increasing manual control and use of the Customs Risk Management 
System 2 (CRMS2). 

Overall, a low/medium risk level was identified for the on-time delivery of the project, as most Member 
States will be able to deploy the system within the Deployment deadline.  

The  national  functional  and  Technical  Specifications  based  on  the  Common  Technical  System 
Specifications (CTSS) provided by DG TAXUD were already completed by more than 60% of Member 
States and currently in progress by 14% of Member States. However, GR and RO reported delays in 
delivering Technical Specifications due to delays in the tendering process. DE, SE, and SK will use the 
Central System, so they will not develop Technical Specifications for the external domain. 

MT,  PL,  RO,  and  SE  also  indicated  delays  in  Conformance  Testing  mainly  due  to  delays  from  the 
contractors. 

The UCC WP allows Member States to gradually connect with EOs until the deployment window ends. 
Nevertheless, concerns raised by DE suggest challenges in reaching all affected traders, especially those 

61 

 
 
outside  the  EU,  making  recording  and  monitoring  of  their  plans  and  the  required  Transition  Period 
difficult. 

AT107, BG, CY, DE, FI, FR108, HU, IT, LT, LU109, LV110, NL111, PL112, PT, SI, and SK indicated that the 
project is completed. CZ, ES, MT, and SE are targeting to deploy within the deadline, while DK, EE, 
GR, HR, IE, and RO reported that the project is being delayed beyond the foreseen deployment deadline.  

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for derogation  under 
Article 6(4) of the UCC, concerning the delay for ICS2-R2, beyond the deadline of 1 March 2023. The 
derogation requests from the Member States were assessed by the Commission services in terms of the 
justifications provided for the specific situations of the respective Member States requesting it and in 
view of a set of common assessment criteria.  

In this light, the Commission adopted on 24 February 2023 an Implementing Decision (EU) 2023/438113 
granting a derogation to AT, BE, DK, EE, FR, GR, HR, LU, NL, PL, RO, and SE for the ICS2-R2 
system provided for in Article 133 of the UCC, 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 
applies from 1 March 2023 until 30 June 2023. 

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

6 

High 

CY 

5 

Low 

BG indicated that the ICS2-R2 project is completed. As stated 
in its National Planning, the system was deployed and has been 
in  Operations  since  01/03/2023.  The  Bulgarian  customs 
administration used an Agile and iterative approach, combined 
with an adapted and integrated implementation of the ADM and 
RUP frameworks, each designed for a specific purpose. ADM 
was aimed at implementing and maintaining the overall BCA 
architecture,  while  RUP  was  used  to  manage  the  software 
lifecycle of the solution. 
CY  reported  that  the  preparation  of  specifications  and 
implementation  of  the  ICS2-R2  system  occurred  in  2022. 
However, the project experienced delays beyond the intended 
Deployment  deadline  due  to  Conformance  Testing  scenario 
issues on the ITSM side that currently remain unresolved. As a 
result,  not  only  Conformance  Testing  was  impacted,  but 
Deployment  also.  To  mitigate  this  delay,  CY  allocated 
additional resources to the project. Nonetheless, the project was 
highly  complex  due  to  interconnections  between  core  and 
supporting systems, the high percentage of system availability 
required, limitations in human resources and the impact of the 

107 Information provided from a bilateral meeting between AT and DG TAXUD held on 06/06/2023. 
108 Information provided from a bilateral meeting between FR and DG TAXUD held on 05/09/2023. 
109 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
110 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
111 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
112 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
113 Commission  Implementing  Decision  (EU)  2023/438  of  24  February  2023  granting  a  derogation  requested  by  certain 
Member States pursuant to Regulation (EU) No 952/2013 of the European Parliament and of the Council to use means other 
than electronic data-processing techniques for the exchange and storage of information for Release 2 of the Import Control 
System 2 (OJ L 63, 28.2.2023, p. 56-58). 

62 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

CZ 

5 

Low 

DE 

4 

Low 

DK 

5 

Medium 

EE 

5 

Low 

ES 

6 

Low 

FI 

6 

High 

traders,  particularly 

in  accordance  with 

the  requirements  of 

COVID-19 pandemic. CY shared that the system was Deployed 
on 21/06/2023114. 
CZ  shared  that  the  Technical  Specifications,  Conformance 
Testing  and  Deployment  for  ICS2-R2  were  completed  on 
15/02/2023,  24/02/2023  and  16/03/2023 respectively.  Traders 
are now transitioning to the system115. 
According to DE, ICS2-R2 is in Operations since 01/03/2023 
and was implemented as part of the national IT-System ATLAS 
Release  10.1.  Shared  Trader  Interface  was  implemented  to 
facilitate  message  exchange  between  the  EOs  and  customs 
the 
authority, 
Commission.  However,  DE  indicated  that  connection  from 
Trade  (Air  Carrier)  was  suspended  due  to  a  change  in  the 
transition strategy decided by DG TAXUD on 28/02/2023.  
Under the UCC WP, Member States can allow EOs to connect 
gradually  until  the  end  of  the  deployment  window  for  each 
release.  Despite  this  provision,  DE  expressed  concerns  about 
those  with 
reaching  all  affected 
headquarters  outside  the  EU.  As  a  result,  recording  and 
monitoring  of  the  traders'  plans  in  the  National  Planning  for 
customs and the necessary Transition Period required under the 
UCC WP may not be feasible. 
According to DK, the Deployment of ICS2-R2 is being delayed 
due to technical complexities in the development of the system 
and  lack  of  human  resources,  but  still  expects  to  meet  the 
Deployment date set on 31/10/2023. To mitigate this delay, DK 
increased  manual  control  and  the  use  of  CRMS2  and  is  re-
evaluating and reprioritising its MASP-C releases. 
EE noted that, due to COVID-19 related financial challenges, it 
had  to  postpone  the  ICS2-R2  project  deadline  to  01/10/2023. 
The consequences of the initial delay, caused by funding issues 
and the COVID-19 outbreak, are still affecting its development 
process.  EE  indicated  that  the  grace  period  granted  will  not 
provide  enough  to  implement  the  various  systems  properly, 
ensuring  full  compliance  and  business  continuity  as  well  as 
including  proper  testing  and  necessary  training  activities.  EE 
informed  that  it  is  now  moving  to  use  Agile  system 
development. 
ES reported that the ICS2-R2 project is becoming increasingly 
technically  and  functionally  complex.  Significant  time  was 
invested in performing regression testing to ensure that previous 
functionality  remains  intact.  The  automation  of  these  tests 
enabled the project to be delivered on time and, therefore, the 
project is on track to be in Operations by 02/10/2023. ES also 
shared that Scrum is being used to develop the system. 
Regarding ICS2-R2, FI indicated that the project was completed 
as planned and has been in Operations since 31/03/2023. ICS2-
R2  includes  a  complete  air  mode  Safety  and  Security  risk 
analysis process (Safety and Security risk analysis). 

114 Information provided from a bilateral meeting between CY and DG TAXUD held on 20/07/2023. 
115 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 

63 

 
 
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

FR 

GR 

6 

High 

HR 

HU 

5 

4 

High 

Low 

IE 

6 

Low 

6 

6 

Low 

Low 

IT 

LT 

LU 

LV 

MT 

6 

Medium 

FR  reported  that  the  ICS2-R2  system  was  deployed  on 
30/06/2023, in line with the granted derogation116. 
GR reported that the development of the ICS2-R2 system was 
still  in  progress  and  had  exceeded  the  Deployment  deadline 
granted  by  the  derogation.  GR  indicated  that  a  further 
derogation will be requested and a delayed agreement with the 
contractor  was  achieved. Due  to  Conformance  Testing  taking 
longer than  expected, the system is planned to be operational 
around 20/10/2023117. 
HR reported that a derogation was granted on 24/02/2023 for 
ICS2-R2, extending the Deployment deadline until 30/06/2023. 
The system was partially Deployed on 23/03/2023 and the goal 
is to complete functional testing by mid-April with the aim of 
being in Operations by 15/05/2023. HR also informed that an 
activity plan has been shared with the EOs. 
HU  indicated that  the  ICS2-R2  project  is  in  Operations  since 
01/03/2023. 
IE reported that there were delays and the full Deployment is 
expected to take place by end of June 2023118. The connectivity 
for  the  EOs  for  Conformance  Testing  has  been  problematic 
since the scenarios need to be manually initiated and verified on 
the EU side and this requires that testing can only be performed 
during the EU workday hours. Moreover, Conformance Testing 
was  late  because  the  vendor  provided  the  package  late. 
Therefore,  IE  indicated  that  additional  resources  were  put  in 
place  to  manage  Conformance  Testing  and  connectivity.  The 
EOs requested the Deployment Window to mitigate the impact 
of the slight delay in entering Operations. 
IT shared that the ICS2-R2 project was completed and has been 
Deployed in production as planned. 
LT indicated that the ICS2-R2 project was partially Deployed 
on 01/03/2023, with eleven NES functionalities implemented in 
line with the common specifications. The implementation of the 
e-screening  timers  on the  responsible Member  State  side  was 
Deployed  on  06/03/2023.  According  to  LT,  the  delay  in 
receiving comments from the testing team resulted in the need 
to repeat some tests. An Agile approach is being used for system 
development, with the 'go live' date set for 01/10/2023. 
Same response as for AN. 
LV  shared 
in  production  for  postal 
is 
consignments  since  01/07/2021  and  for  air  cargos  since 
01/03/2023. The other modes of transport are planned to be in 
production by 01/03/2024119. 
MT  indicated  that  the  Deployment  of  ICS2-R2  is  scheduled 
within the derogation deadline. While Technical Specifications 
were completed on 31/03/2023, Conformance Testing activities 
are currently underway and Deployment has been delayed due 
to delays from the software provider. MT also shared that it is 

that  ICS2-R2 

116 Information provided from a bilateral meeting between FR and DG TAXUD held on 05/09/2023. 
117 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
118 Information provided from a bilateral meeting between IE and DG TAXUD held on 17/05/2023. 
119 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 

64 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

to 

that  needs 

traders  have 

the  connection 

to  be  developed.  Despite 

facing  complexity  with  the  EOs  implementation,  particularly 
with regards to Air Freight Forwarders. 
NL reported that despite delays caused by COVID-19, Brexit, 
and the significant amount of functionalities required for ICS2-
R2,  it  still  anticipates  to  meet  the  Deployment  deadline. 
However,  due  to  the  high  complexity  of  the  project  and  the 
limited resources, NL's planning is more incremental than last 
year. The PN and TS-related functionalities that are part of the 
AN/PN/TS project will be delivered in a second increment. This 
enabled  NL to  ‘go live’ earlier  (on 01/07/2023)  with the first 
increment  and  meet  the  derogation  deadline  for  ICS2-R2. 
Currently, 
the  system 
available120. The remaining functionalities related to PN and TS 
will  be  delivered  no  later  than  01/12/2023.  Additionally,  NL 
indicated  that  the  development  of  the  national  UUM&DS 
component  is  a  risk  due  to  the  significant  amount  of 
functionality 
the 
the  UUM&DS  Conformance 
component's  development, 
Testing has made little progress since December 2022. 
PL informed that ICS2-R2 was deployed on 01/07/2023 and the 
system  is  expected  to  be  fully  operational  by  end  October 
2023121. 
PT  indicated  that  the  ICS2-R2  project  has  been  in  operation 
since 01/03/2023. Several modes of Conformance Testing were 
executed during the system's development and Agile was used 
to  reduce  the  implementation  timeframe.  According  to  PT, 
updating ICS2-R2 and connecting it to the central system was 
highly complex. 
RO  shared  that  the  development  of  the  ICS2-R2  system  has 
been delayed beyond the anticipated Deployment deadline due 
to delays in the tendering process. The contract, including ICS2-
R2 and ICS2-R3, was published on 28/04/2023. RO indicated a 
need for an extended derogation even outside the deployment 
window for traders running until 01/10/1023122.  
According to SE, the Deployment of the system will meet the 
derogation deadline of 08/06/2023. However, SE acknowledged 
that  contacting  all  EOs  involved  in  the  project  has  been  a 
challenge. Therefore, the Deployment date refers to when SE 
will be ready, but not necessarily when all traders will be able 
to fully use the system. Some air traders have not yet submitted 
ENS, but it is envisaged that the majority will be submitted by 
02/10/2023123. SE is using the  Shared Trader Interface within 
the  central  ICS2  system  and,  therefore,  there  is  no  need  to 
develop Technical Specifications for the external domain. 
SI  informed  that  the  ICS2-R2  system  was  Deployed  on 
01/03/2023 and it is anticipated to 'go live' on 01/10/2023. 

NL 

6 

Medium 

PL 

PT 

6 

6 

Low 

High  

RO 

5 

Low 

SE 

3 

Low 

SI 

6 

Low 

120 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
121 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
122 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
123 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 

65 

 
 
 
MS 

SK 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

3 

Low 

SK indicated that for the development of the ICS2-R2 system 
the  CTSS  provided  by  the  Commission  were  used  and  the 
system was deployed on 01/03/2023. 

Table 22: Detailed responses from Member States – ICS2-R2 

Figure 13 provides the percentage of respondents (Member States plus the Commission) in each 
development phase124. 

Figure 13: Summary of Survey Responses – ICS2-R2 

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

66 

 
 
 
 
 
3.5.2.  Overview of Project Progress 

Table 23 indicates the percentage of completion as of the end of 2022 in comparison to the target dates 
set forth in the UCC WP.  

The  target  date  set  for  the  Technical  Specifications  is  in  reference  to  the  common  Technical 
Specifications.  Member  States  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 ICS2-R2 and ICS2-R3 as per the MASP-C.  

In  regards  to  the  implementation  of  ICS2-R2,  the  following  Member  States  have  a  planned/actual 
Deployment date that is later than the deadline in the UCC WP and/or the granted derogation deadline125: 
CY, DK, EE, FI, GR, IE, MT, PL, and RO. 

Table 23: Comparison of Planned and Actual Dates – ICS2-R2 

125 The Commission adopted on 24 February 2023 an Implementing Decision (EU) 2023/438, granting a derogation to AT, BE, 
DK, EE, FR, GR, HR, LU, NL, PL, RO, and SE from 01/03/2023 until the deployment of the ICS2-R2 system, but not later 
than 30/06/2023. 

67 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP125 2023 Planned/ Actual Date2023 % of Completion European Commission12/11/2019100%N/AN/A01/03/2023100%AT01/03/2022Not Provided24/02/2023Not Provided21/06/2023100%BENot ProvidedNot Provided30/06/2023Not Provided30/06/2023100%BG28/03/2022100%15/12/2022100%01/03/2023100%CYNot Provided100%Not Provided100%21/06/2023100%CZN/A100%N/A100%01/03/2023100%DEN/AN/ANot Provided100%01/03/2023100%DK01/09/2021100%30/06/2023100%31/10/2023100%EE31/12/2022100%30/08/2023100%01/10/2023100%ES01/09/2022100%20/01/2023100%01/03/2023100%FI31/03/2022N/A30/09/2022100%31/03/2023100%FR31/03/2022100%31/03/2023100%30/06/2023100%GR30/04/2023100%15/09/2023100%01/10/2023100%HR01/04/2022100%14/06/2023100%29/06/2023100%HU25/11/2020100%10/02/2023100%01/03/2023100%IE28/01/2022100%30/06/2023100%11/04/2023100%ITN/AN/A14/02/2023100%01/03/2023100%LT30/07/2022100%15/02/2023100%01/03/2023100%LU04/11/2021Not Provided28/02/2023Not Provided01/03/2023100%LV10/01/2022100%29/09/2023Not Provided01/03/2023100%MTN/A100%N/A100%01/10/2023100%NL31/12/2021100%26/06/2023100%30/06/2023100%PL30/06/2022100%Not Provided100%01/07/2023100%PT01/09/2022100%01/02/2023100%01/03/2023100%RO30/11/2021100%31/01/2023100%15/03/2024Not ProvidedSEN/AN/A23/05/2023100%08/06/2023100%SI01/04/2022100%18/02/2023100%01/03/2023100%SK01/10/2022N/A14/02/2023100%01/03/2023100%30/06/201801/03/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window) 
 
 
 
 
 
Regarding ICS2-R2, additional details on the specific percentage of completion per milestone can be 
seen in the following Figure 14. 

Figure 14: Percentage of Completion per Phase – ICS2-R2 

68 

 
 
 
3.6. UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) – PHASE 1 

The UCC CCI project aims to allow for goods to be placed under a customs procedure using centralised 
clearance, enabling the EOs 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 CCI through a new trans-European system will strengthen trade facilitation. It 
will enable EOs to centralise their import activities and reduce interactions with customs by only 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 Value Added Tax. 

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 phases126.  

Phase  1  (CCI-P1)  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. Regarding the types of goods involved, this phase will cover all types of goods except for 
excise goods and goods subject to Common Agricultural Policy (CAP) measures.  

Phase 2 (CCI-P2) will cover the components that are not part of 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 
declaration; 

•  Supplementary declarations regularising more than one simplified customs declaration; 
•  The placing of goods under the temporary admission procedure; 
•  Goods subject to CAP 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.  

3.6.1.  Summary of Responses 

Summary from the Commission: 

The  introduction  of  CCI,  the  first  Trans-European  System  for  import  formalities,  required  a  fresh 
approach by adopting the new network architecture Common Communications Network 2nd Generation 
(CCN2ng)  and  Common  Reference  Architecture  (CoRA).  This  involved  the  redefinition  of 
specifications  and  effective  communication  with  the  Member  States.  The  Commission  is  diligently 
monitoring  the  progress  of  other  key  projects  to  ensure  alignment  with  the  new  infrastructure.  The 
coordination of multiple project teams has proven crucial for synchronising all activities. 

A medium risk level has been noted due to the dependency of Conformance Testing and Deployment 
on the actions of the Member States. To mitigate risks efficiently, the Commission is closely monitoring 
and coordinating activities with a dedicated team managing the Conformance Testing environment. As 
per the current plan, the Conformance Test Application (CTA) system is accessible in the conformance 
environment,  facilitating  CCI-P2  Conformance  Testing  activities  through  the  CCN2ng  exchange 
platform. 

Furthermore, the Commission is implementing a new iterative approach (presented in 2023 within the 
UCC  WP  and  MASP-C  revision),  considering  the  difficulties  on the side  of Member  States  and  the 
transition  between  CCI-P1  and  CCI-P2.  This  approach  allows  for  the  prioritisation  of  CCI-P1  with 

126 The original plan for CCI-P1 and CCI-P2 can change depending on the acceptance of the proposal being made in the 2023 
revision of the UCC WP. 

69 

 
 
 
standard  declarations  and  the  freedom  to  choose  the  message  type  (CCI-P1  or  CCI-P2),  providing 
flexibility for other combinations of CCI-P1, such as CCI-P1 with simplified declaration and includes 
an extended deadline for CCI-P1. In view of this, several Member States will be able to meet the CCI-
P1 deployment milestone of 1 July 2024 and there is more reassurance that all Member States will meet 
the final deployment milestone of the overall CCI project by 2 June 2025. 

Overall, the CCI-P1 project is progressing on schedule, with Technical Specifications completed in 2020 
and Conformance Testing activities with Member States currently underway. 

Summary from the Member States: 

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

Several Member States are currently reviewing the Technical and Functional Specifications, and certain 
concerns were raised regarding the feasibility of meeting the milestones for Technical Specifications, 
Conformance Testing and Deployment. Various Member States specifically highlighted the tightness of 
the import systems' planning. In addition to the inherent complexity of the project, potential delays may 
arise due to limitations in human and financial resources, as well as the need to adapt and re-plan in 
response to the unique working conditions resulting from the COVID-19 pandemic. Furthermore, the 
impact  and  complexities  stemming  from  Brexit  and  the  current  state  of  the  e-commerce  market 
contribute further to the potential for delays. 

In terms of assessing the level of completeness of the system, more than two thirds of the Member States 
that provided information reported that the progress of the system is on target. However, there are several 
Member States that indicated that at the current stage, the system is delayed. GR, NL127, SE128, and SK129 
submitted a written notification asking DG TAXUD for a derogation under Article 6(4) of the UCC for 
the delay of CCI-P1 beyond the deadline and LT and PL130 plan the need to request a derogation.   

BG, ES, HR, MT, PL, and SK shared that Technical Specifications were completed. ES completed the 
Conformance Testing, whereas BG, EE, HR, LU131, and PL initiated the Conformance Testing activities 
and are currently in progress. EE, HR, and PL reported the Deployment status as in progress for CCI-
P1.  

Detailed Responses: 

Table 24 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

5 

Low 

BG reported the status of the project as on target, based on the 
planned  dates  for  the  milestones.  Deployment  and  start  of 
Operations  are  planned  for  end  November  and  Conformance 
Testing activities started in April 2023. BG indicated the use of 
messages from CCI-P1 and upgrade later to P2 messages, but it 
is not  clear  whether this transition to  P2 messages  will  occur 
before the release of Phase 2 system functionality132.  
Additionally, BG shared that the contractor is implementing a 
development approach based on different iterations. 

127 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
128 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
129 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 
130 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
131 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
132 Information provided from a bilateral meeting between BG and DG TAXUD held on 27/07/2023. 

70 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

CY 

6 

Low  

CZ 

1 

High 

DE 

5 

High 

DK 

EE 

4 

5 

High 

Low 

ES 

4 

Low 

FI 

6 

High 

CY indicated that the analysis and preparation of specifications 
for CCI are in progress. Additionally, information activities and 
campaigns to promote the aims and benefits of the Centralised 
Clearance for EOs are being organised. The full scope of CCI-
P1  will  be  included  with  P2  messages.  The  Technical 
Specifications  were  published  on  22/05/2023,  while 
Deployment is planned for 28/06/2024133. 
CZ informed that the Deployment of CCI-P1 and CCI-P2 will 
take  place  simultaneously.  Furthermore,  as  CCI  is  being 
developed as part of the NIS system, which has been delayed 
until 01/12/2024, CZ will not be able to deploy CCI-P1 before 
this date. 
DE indicated that an internal analysis has begun with the aim of 
starting Operations in Q4 2025. 
The project has been delayed beyond the foreseen Deployment 
deadline as it will be implemented as part of the major release 
of the national IT system ATLAS Release 10.2 as a new trans-
European system. CCI-P1 and CCI-P2 will be included in one 
development  and  DE  will  develop  one  message  for  the 
declaration  which  will  be  adapted  depending  on  normal  or 
simplified procedure in use. Once the new import system is in 
place, traders will be migrated gradually to the new system134. 
To mitigate the impact of this delay, DE plans to create a new 
national  PG  for  CCI  with  the  necessary  resources  and  the 
implementation of Agile methodologies. 
DK informed that the delay in NIS is impacting the Deployment 
deadline planned for 30/06/2025. DK continues to analyse CCI-
P1 due to its dependency on NIS. 
EE indicated that the project is being postponed to provide more 
capacity for AES, NCTS-P5 and ICS2-R2 to be completed. The 
CCI-P1  system  will  deliver  functionalities  through  iterations 
and will be developed with the P1 message formats. EE shared 
that the envisaged Deployment date is set for May 2024135. EE 
is implementing an iterative approach for the development of 
CCI, with three iterations planned during the project. 
ES informed that the overall status of the project is on target and 
it is partially Deployed in operation with a temporary solution. 
Conformance Testing is ongoing136. The Deployment is linked 
to  business  needs,  such  as  a  National  Centralised  Clearance 
(CCL)  authorisation  that  may  require  the  system  to  be 
Deployed. ES informed that it is using iterative methodologies 
to develop CCI-P1. 
FI shared that the entire import system will be built from scratch 
and noted that, given the many parallel projects, the effects of 
the COVID-19 pandemic and the limited resources, especially 
on  the suppliers’  side,  Deployment  is expected  to  be delayed 
beyond the deadline, until Q2 2025. In light of the situation, FI 
assumed a more significant role in preparing the specifications 

133 Information provided from a bilateral meeting between CY and DG TAXUD held on 20/07/2023. 
134 Information provided from a bilateral meeting between DE and DG TAXUD held on 14/06/2023. 
135 Information provided from a bilateral meeting between EE and DG TAXUD held on 01/06/2023. 
136 Information provided from a bilateral meeting between ES and DG TAXUD held on 23/11/2023. 

71 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

and  is  also  working  on  preparing  any  applications  for  CCI 
authorisation from traders137.  
FI prioritised the development of other systems such as NCTS 
and  AES  over  CCI.  At  the  same  time,  FI  indicated  that  the 
respective contractor uses an Agile methodology for the system 
development to minimise the impact on milestones. However, 
deliveries are to be tested in the Finnish Customs and further 
sent to bigger entities. 
FR  indicated  that  the  strong  interdependencies  of  the  various 
national systems increased complexity and caused delays in the 
development  of  NIS  as  a  whole.  In  this  regard,  additional 
resources  on  the  business  and  IT  sides  were  mobilised  as  a 
mitigation measure. 
Brexit and e-commerce have had a strong impact on human and 
financial  resources,  causing  delays  in  the  involvement  of  the 
technical teams. The COVID-19 pandemic has equally had an 
impact on these areas. As a mitigating measure, FR outsourced 
some  activities  to  a  contractor  and,  in  parallel,  secured  the 
import system to have a better base for CCI. 
At the same time, AES developments have to be ensured, given 
FR’s  position  as  an  ‘exit’  Member  State  for  other  Member 
States. Therefore, many choices requiring an increased level of 
resources  are  to  be  made  for  several  projects  that  need  to  be 
carried out simultaneously. In this light, FR chose to prioritise 
AES  (core  functions)  over  CCI,  given  the  importance  of  the 
export volumes. 
The deadlines for this project shifted to secure other projects. 
CCI-P1 will deliver functionalities through iterations, with an 
envisaged Deployment date set for Q4 2024. 
GR  informed that  all  milestones  in  the  National  Planning  are 
affected  and  delays  are  foreseen  beyond  the  Deployment 
deadline, as the call for the tender procedure has not yet been 
finalised. The contract is expected to be signed in Q4 2023. The 
Deployment date is planned for June 2025138 and a derogation 
request was submitted.  
HR informed that the system is expected to be highly complex 
and  that  the  functionalities  that  were  defined  are  being 
developed.  
Deployment  is  in  progress  and  the  end  date  is  planned  for 
30/06/2024. HR indicated the status of the project as on target. 
HU reported that the connectivity to the data link developments 
will  be  completed  on  30/04/2023.  Full  functionality  will  be 
available on 01/07/2024139. The project is assessed as being on 
target, with Technical Specifications in progress.  
IE indicated that communication with other Member States is 
new for imports. Additionally, implementing the requirements 
of  the  revised  new  Annex  B  of  the  Commission  Delegated 
Regulation  (EU)  2021/234  and  the  data  changes  to  EUCDM 
v6.1 represent challenges for the EOs and customs authorities. 

FR 

6 

High 

GR 

6 

High 

HR 

6 

Low 

HU 

5 

Medium 

IE 

6 

Medium 

137 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 
138 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
139 Information provided from a bilateral meeting between HU and DG TAXUD held on 07/09/2023. 

72 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

6 

Low 

IT 

LT 

LU 

LV 

MT 

5 

Low 

NL 

5 

High 

PL 

5 

Medium 

Consequently,  the  effective  delivery  of  the  project  could  be 
impacted. IE reported that CCI-P1 and CCI-P2 are intended to 
be deployed together since P1 will use P2 message formats140 
and the project is expected to 'go live' in June 2024. 
IT  plans  to  implement  CCI-P1  by  01/07/2024,  integrating 
messages from CCI-P2. IT indicated that it will need to switch 
its public accounting system completely to ensure compatibility 
with CCI-P1141.  
For CCI-P1, LT plans the need for a legal derogation request. 
Deployment and start of Operations are planned for December 
2023. 
LU shared that Conformance Testing Mode 1 is about to begin, 
as well as testing with a major LU-based company142. 
LV plans to deploy CCI-P1 in June 2024. The full scope of CCI-
P1  will  be  included  with  P2  messages  and  the  delivery  is 
expected  in  full  by  January  2024.  At  the  time  of  writing,  no 
traders  are  interested  yet.  However,  LV  indicated  that  the 
onboarding for traders is different from other Member States as 
most traders do not use the S2S interface but rather a GUI and 
upload a file in a specific format143. 
MT indicated that CCI-P1 is being delayed beyond the foreseen 
Deployment  deadline.  Both  CCI-P1  and  CCI-P2  will  be 
developed  together.  Conformance  Testing  is  expected  to  be 
completed  by  November  2024.  MT  shared  that  some  tenders 
were  awarded  and  awaiting  contracts  to  be  signed  out,  while 
others are still being assessed144.  
NL is considering merging CCI-P1 and CCI-P2 and combining 
them  with  CCE,  setting  the  deadline  for  the  current  CCI-P2 
deadline.  NL  reported  that  the  project  is  highly  complex  and 
poses a high risk of not being delivered on time. Furthermore, 
NL identified  Brexit, e-commerce, labour market, COVID-19 
pandemic and the prioritisation of other parallel projects as the 
potential causes of delays145. 
NL also indicated that it is considering reducing the scope of 
the  project  to  minimise  the  impact  of  these  events  on  the 
delivery of milestones. As of now, all milestones (Construction 
phase, Conformance Testing, and Deployment) are delayed. 
PL  shared  that  the  CCI-P1  system  will  be  developed  and 
implemented  under  NIS,  planned  for  01/07/2024.  The 
deployment  of  the  system  is  being  delayed  beyond  the 
derogation  deadline.  CCI-P2  message  specifications  are 
intended to be used for CCI-P1146. PL advised that risks related 
to  the  COVID-19  pandemic  and  its  impact  on  financial  and 
human resources could have an impact on the system delivery. 

140 Information provided from a bilateral meeting between IE and DG TAXUD held on 17/05/2023. 
141 Information provided from a bilateral meeting between IT and DG TAXUD held on 07/11/2023. 
142 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
143 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
144 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
145 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 
146 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 

73 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

PT 

6 

Low 

RO 

6 

Medium 

SE 

4 

High 

SI 

6 

Medium 

PT informed that the Conformance Testing’s purpose is for the 
EOs  to  be  able  to  realise  if  their  systems  comply  with  the 
specifications and for PT to realise if the external domain was 
correctly  developed.  Conformance  Testing  with  the  Member 
States will be done to assess if all the connections/validations 
necessary are correctly executed and is envisaged to take place 
in 2024. The project will be developed and implemented as part 
of the completely new NIS, which explains the complexity of 
CCI. Therefore, the plan is for the system to be Deployed before 
June 2025 and beyond the foreseen Deployment deadline147.  
PT indicated that an Agile development approach will be used 
to  reduce  the  implementation  timeframe.  However,  PT  is 
currently  facing  procurement  and 
tendering  difficulties, 
particularly with the renewal of contracts with the companies 
developing the systems, which may lead to an implementation 
of  the  CCI  system  in  PT  beyond  the  expected  Deployment 
deadline.  PT  will  need  assistance  and  support  concerning 
Conformance Testing on CCI. 
RO noted that the interdependencies among the NIS systems are 
becoming a risk that might impact all the CCI-P1 milestones. 
The project is on target with the Technical Specifications phase 
currently in progress and implementation scheduled by the end 
of 2023, including CCI-P2 messages148. 
SE informed of a high risk due to the complexity of developing 
several projects simultaneously. Moreover, SE reported that it 
is changing its IT platform, which can have an impact on the 
implementation  of  the  systems  under  development.  SE  noted 
that the project is delayed beyond the Deployment deadline and 
has requested a derogation for CCI-P1. The plan is to implement 
CCI-P1  and  CCI-P2  at  the  same  time  by  02/06/2025 149 . 
Potential mitigation measures are under analysis. 
SI indicated that, currently, there are no anticipated delays. The 
potential risks identified by SI relate to the high complexity of 
the system, which includes several new electronic messages and 
BPMs, 
the  exchange  of  electronic  messages  between 
Supervising Customs Office for CCI and Presentation Customs 
Office for CCI, specific Rules and Conditions for CCI, specific 
code  lists  for  CCI,  demanding  Conformance  Testing  and 
for  National  Applications 
complex  Design  Document 
(DDNCA)  documentation,  which  specifies 
the  design 
requirements  to  which  any  Customs  Movement  Application 
needs to conform. Previously, SI completed NIS according to 
the  new  Annex  B  of  the  Commission  Delegated  Regulation 
(EU)  2021/234  requirements,  which  needed  to  be  postponed 
several  times  due  to  the  lack  of  preparedness  of  the  external 
environment as a consequence of COVID-19. The Deployment 
date is planned for 30/06/2024150. 

147 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 
148 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
149 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
150 Information provided from a bilateral meeting between SI and DG TAXUD held on 13/06/2023. 

74 

 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

SK 

3 

Low 

SK reported the status of the project as being delayed beyond 
the  Deployment  Deadline.  Technical  Specifications  are 
completed  and  preparation  for  Conformance  Testing  is 
ongoing.  In  earlier  stages,  a  shortage  of  financial  and  human 
resources,  along  with  changes  in  government,  affected  all 
milestones  related 
to  system  development  and  delayed 
contractual commitments. SK shared that a derogation request 
has been sent and the system is envisaged to be in Operations 
on 01/01/2025151. 

Table 24: Detailed responses from Member States – CCI-P1 

Figure  15  provides  the  percentage  of  respondents  (Member  States  plus  the  Commission)  in  each 
development phase152. 

Figure 15: Summary of Survey Responses – CCI-P1 

151 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 
152 The figure related to Conformance Testing includes the work from the Commission in regards to the preparation of the 
Conformance Testing environment and coordination for Member States. 

75 

 
 
 
 
 
 
 
3.6.2.  Overview of Project Progress 

Table 25 highlights any known divergences in the planning compared to the dates set in the UCC WP. 
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-P1, the following Member States have a planned/actual  Operations date that is later 
than the deadline in the UCC WP153: BE, CZ, DE, DK, ES, FI, HR, HU, IE, LT, LU, LV, MT, NL, PT, 
SI and SK. AT, FR, GR, IT, PL, RO, and SE did not provide data regarding the Operations date. 

Table 25: Comparison of Planned and Actual Dates – CCI-P1 

153 In the 2023 UCC WP Revision the end of the deployment window is envisaged for 01/07/2024. 

76 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP 2023 Planned/ Actual Date2023 % of Completion Target date from WP1532023 Planned/ Actual DateEuropean Commission09/10/2020100%Not Provided5%Not Provided5%Not ProvidedATNot ProvidedNot providedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedBE01/12/2021Not provided31/12/2023Not Provided30/06/20240%30/06/2024BG26/06/2023100%16/10/2023100%23/10/2023100%23/10/2023CY22/05/202380%Not Provided0%28/06/20230%28/06/2023CZ01/04/202425%30/11/20240%01/12/20240%01/12/2024DE30/06/202430%30/10/20260%15/11/20250%15/11/2025DK01/03/2023Not provided31/03/20240%02/05/20240%02/05/2024EE01/03/2023100%30/10/202375%01/10/20230%29/11/2023ES14/03/2022100%19/12/2022100%30/09/2022100%31/12/2024FI31/12/202460%Not Provided0%30/06/202510%30/06/2025FR31/12/202350%30/09/20240%02/06/20250%Not ProvidedGR31/12/2023100%30/09/20240%30/06/20250%Not ProvidedHR31/12/2023100%20/06/202410%30/06/2024100%30/06/2024HU15/09/2023100%01/06/202430%30/06/2024100%30/06/2024IE23/06/2023100%23/06/202425%24/06/20240%24/06/2024IT31/01/2023100%03/11/202320%01/07/202415%Not ProvidedLT15/07/2023100%31/12/2023100%01/02/202450%01/02/2024LU01/10/2023Not Provided30/06/2024Not provided30/06/2024Not Provided30/06/2024LVN/AN/A30/06/2024Not Provided30/06/2024Not Provided01/07/2024MTN/A80%N/A25%02/06/20250%02/06/2025NLNot Provided50%Not Provided0%Not Provided0%01/11/2025PL30/07/2022100%30/09/2023100%01/07/2024100%Not ProvidedPT01/07/2022100%30/09/20240%28/10/20240%29/10/2024RO30/05/2023100%N/AN/A01/12/2023100%Not ProvidedSENot Provided0%Not Provided0%N/A0%Not ProvidedSI01/03/202130%30/04/20240%30/04/20240%30/04/2024SK17/02/2023Not Provided31/12/2024100%01/01/202570%01/01/202530/09/202001/03/202201/12/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
16. 

Figure 16: Percentage of Completion per Phase – CCI-P1 

77 

 
 
 
 
3.7. UCC  NEW  COMPUTERISED  TRANSIT  SYSTEM  (NCTS)  UPGRADE  – 

COMPONENT 1 

This project aims to align the existing 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. 

The transit system offers significant benefits and simplifies processes while ensuring continuity with 
existing systems. This achievement is the result of close collaboration between the Commission, national 
customs authorities and trade associations. 

In terms of the planning approach, the project is divided into two components154. 

Component 1, NCTS – Phase 5 (NCTS-P5), includes steps to upgrade and extend the current NCTS 
processes  in  alignment  with  the  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  Exchange  to  UCC  data  requirements  and  to  upgrade  and  update  the  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-P5 will meet the following objectives155: 

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

Data Model; 

•  Harmonisation of 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-P5 will improve the following processes: 

•  Transit guarantees monitoring; 
•  Enquiry process; 
•  Business statistics for transit: The current collection of business statistics will be optimised to 

ensure support of measurements of the Customs Union Performance system; 

•  Strengthening of the Safety and Security of entry/exit. 

Lastly, several 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. 

The  new  transit  system  will  bring  about  substantial  benefits  and  simplifications  while  ensuring 
continuity with the existing operational systems. 

According to the revision of the UCC WP156, NCTS-P5 will be deployed in two steps: the first related 
to  core  functionalities  (Business  Continuity  aligned  with  UCC)  and  the  second  to  non-core 
functionalities (Pre-Lodgment, Incident "en route" Management, Office of Exit and Export followed by 
Transit). The National Administrations have the possibility to deploy both steps in one or deploy in 
sequence. 

154 Information regarding Component 1 is provided within this section, whereas details concerning Component 2 can be found 
in section 4.5. 
155 The same objectives will also be met by AES-C1. 
156 The revised UCC WP will be adopted in December 2023. 

78 

 
 
 
NCTS-P5 will be deployed in line with the following calendar: 

Figure 17: NCTS-P5 timeline 

For this section on NCTS, the entries in operation of the National Administrations are focusing on the 
core  functionalities,  as  they  represent  the  main  scope  of  NCTS-P5  and  ensure  business  continuity. 
Despite,  most  National  Administrations  will  deploy  both  their  core  and  non-core  functionalities 
simultaneously. 

It  is  important  to  highlight  that  the  NCTS  system  specifications  developed  by  the  Commission 
(Functional  System  Specifications  [FSS]  and  TSS)  cover the  Information  Exchange in the common, 
national, and external domains: 

•  The  common  domain  communication  refers  to  the  Information  Exchange  between  customs 

offices located in different Member States; 

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

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

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

declarant/trader at exit, at the 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 the case of external or national domains, the 
common  NCTS  specifications  are  strongly  recommended,  aiming  to  harmonise  the  export  and  exit 
formalities as much as possible among the EU Member States. The UCC Data Annex B is the binding 
legal framework for Transit Declarations. 

There are 36 National Administrations currently in operation for NCTS: the 27 Member States, Northern 
Ireland  under  the  terms  of  the  Northern  Ireland  Protocol  (NIP),  Andorra,  San  Marino  and  the  CTC 
Countries (Switzerland, Republic of Serbia, Republic of North Macedonia, Norway, Türkiye, Ukraine 
[since  1  October 2022],  and  the  United  Kingdom).  Montenegro,  Georgia  and Moldova  are  acceding 
countries to the CTC Convention at various stages of preparation, targeting entry into operation in 2024. 

3.7.1.  Summary of Responses 

Summary from the Commission: 

The  challenge  for  NCTS-P5  is  to  ensure  operation  continuity  and  a  smooth  transition  for  National 
Administrations and trade, while implementing significant changes in the applicable data and process 
models.  The  Functional  and  Technical  Specifications 157 approved  by  the  National  Administrations 
govern the quality, technical support, operation continuity, security and capacity of the transition to full 
NCTS-P5 Operations. 

The  NCTS-P5  project  has  pioneered  a  collaborative,  iterative  and  Agile  working  method  that  has 
received  praise  by  all  the  National  Administrations  and  traders  involved.  The  adoption  of  an  Agile 
approach  since  the  project's  inception  has  yielded  functional  and  technical  quality  as  well  as  actual 

157 The Functional and Technical Specifications include Service Management, Service Level Agreements, Terms of Reference, 
Crisis Management, Capacity Plans and Security Plans. 

79 

 
 
 
 
the  National 
progress  among  the  National  Administrations.  The  collective  intelligence  of 
Administrations is crucial for the successful transition at hand. The Coordination Programme is also 
essential  in  enabling  collaboration  between  the  National  Administrations  and  the  Commission  and 
providing transparency on the status of the project. 

UCC Work Programme and Technical Specifications to address the shift of the National Administrations 
and the traders 

Considering the delays reported by the National Administrations and by the trade community for their 
transition to NCTS-P5 (see below), the Central Project Team, in close cooperation with the National 
Administrations  issued  a  proposal  for  the  UCC  WP  and  the  TSS  aiming  at  ensuring  the  operation 
continuity of NCTS until January 2025 while bringing them in alignment with the UCC Annex B. 

In the same package, the Central Project Team adjusted the planning for the Deployment of NCTS-P6 
to avoid any overlap between the transition from NCTS-P4 to NCTS-P5 and the one from NCTS-P5 to 
NCTS-P6. The analysis showed that it was the only to ensure operation continuity, considering technical 
and resource perspective of both the National Administrations and the Commission, as well as alignment 
with the roll-out of ICS2-R3158. 

The TSS have been improved based on past experiences and of anticipated legal arrangements that will 
frame the NCTS-P5 operations, as set in Article 278 of the UCC. 

Progress of the Central Project Team 

Overall, the activities of the Central Project Team are on track according to the planned schedule for the 
development of the central system and the quality of the central services according to the agreed Service 
Level Agreement. The Central Converter demonstrated its fitness for purpose and its resilience with the 
growing  volume  of  conversion.  Other  central  systems  have  been  continuously  improved  and  the 
preparation for NCTS-P6 is ongoing with the development of the interface between NCTS-P6 and the 
ICS2-R3 Common Repository, a key component offering the interoperability between the NCTS and 
ICS2 systems. 

The  Business  Continuity  Plan  for  NCTS  was  decided  to  be  maintained  as  described  in  the  Transit 
Manual, including any necessary updates. 

Start of NCTS-P5 

The  Commission  and  the  National  Administrations  are  actively  involved  in  transitioning  the  trans-
European customs systems for export and transit. This started with the successful Deployment of the 
new UCC NCTS-P5 system by DE on 6 March 2021 and the entry into international operation by ES 
and  DE  on  13  February  2023.  These  achievements  paved  the  way  for  the  next  generation  of 
interconnected  trans-European  systems  for  the  trade  community  and  national  customs  authorities, 
showcasing the quality of the specifications and legal provisions supporting these systems and, most 
importantly, their business continuity. 

Since February 2023, SI, LU, CH, HR, DK, and BG have joined Operation as of mid-September 2023, 
bringing up to eight the number of National Administrations operational in the NCTS-P5 system. 

Increasing progress of the National Administrations in 2023 (as of mid-September 2023) 

The National Administrations reported significant progress in the deployment of their National Transit 
Application in 2023. 89% of the National Administrations are actively engaged in implementing their 
applications, while 11% are in the procurement or inception stage and are almost ready to start. 

Moreover,  79%  of  the  National  Administrations  already  completed  or  currently  are  on  their 
Conformance Testing activities, while 16% are in Deployment and 21% are already in Operation. 

158 As regards to the UCC WP Revision, NCTS-P5 will be Deployed by February 2025. The transition period from NCTS-P5 
to NCTS-P6 is envisaged between 01/03/2025 and 01/09/2025, during the same period that ICS2-R2 will transition to ICS2-
R3, allowing for a synchronisation between both systems. 

80 

 
 
 
The completion percentage of the transition phase of the National Administrations collectively stands at 
73% in Q3 2023, which is an increase of 34% since Q3 2022. 

The  central  converter,  ieCA,  developed  and  operated  by  the  Commission  along  with  other  central 
systems, has performed as expected. This significant achievement is the outcome of over three years of 
intensive collaboration between the Member States and the Commission, marking the beginning of the 
transition in the Common Domain. 

Entry into Operation 

Figure 18 below presents the updated planning of the National Administrations entry in Operation. The 
figure  is  based  on  the  date  at  which  a  National  Administration  joins  the  ‘To  Be’  operation  on  the 
Common Domain with their core functionalities. 

All National Administrations but 13 re-confirm their timely readiness for entry into Operation with the 
core  functionalities  by  1  December  2023,  which  is  a  substantial  achievement.  Several  National 
Administrations confirmed that they will be in Operation for both core and non-core functionalities by 
1 December 2024. However, five National Administrations (FR, MT, PL, AD, PT, indicated in orange 
in  Figure  18  below)  are  reviewing  their  plans  and  have  not  yet  committed  on  a  date  to  enter  into 
Operation. 

DE,  ES,  and  SI  started  international  Operation  in  February  2023  and  were  joined  by  five  National 
Administrations  (CH,  HR,  LU,  BG,  DK)  during  Q2  and  Q3  2023.  Currently,  16  National 
Administrations are implementing their deployment plans to ensure their timely entry into Operation 
during Q4 2023. Thus far, all entries in Operation have occurred without causing any disruption to the 
continuity and quality of the operation, reflecting the effective efforts of the National Project Teams. 

Figure 18: NCTS-P5 National Administrations entry into Operation as of 17 September 2023 

At the moment of writing, IT secured its plan to enter into Operation in November 2023, which will 
boost  the  transition  of  NCTS-P5,  considering  the  importance  of  the  DE-CH-IT  axis  in  NCTS 
volumetrics.  NL  also  secured  its  plan  to  enter  into  Operation  in  July  2023,  which  is  welcomed, 
considering its top position in NCTS volumetrics. Nevertheless, FR and PL are currently reviewing its 
plans. PL's plan to enter into Operation will probably shift to 2024 due to delays on the traders' side. PT 
is also experiencing difficulties in delivering on time. 

81 

 
 
 
Overall, the National Administrations have collectively achieved significant progress. However, at least 
eight of them will enter into Operation in 2024, with some possibly joining in Q4 2024, if not on the last 
day. For more information, see Table 27 below. 

Recommendations to the Member States 

The  Commission  invited  the  Member  States,  particularly  those  that  announced  running  over  the  1 
December 2023 milestone for the core functionalities, to maintain a high level of compliance with all 
their national projects so that NCTS-P5 can be deployed in time or with the shortest delay possible. 

The  National  Administrations  at  risk  of  missing  the  deadline  for  the  core  functionalities  or  already 
indicating  an  entry  in  Operation  after  1  December  2023  should  use  the  remaining  time  before  the 
deadline to take all the required steps to minimise delays as much as possible.  

The National Administrations are also reminded to implement all requirements of the Design Document 
for  National  Transit  Application  (DDNTA),  including  transitional  Rules  and  Conditions,  to  ensure 
business  continuity.  The  National  Administrations are  invited  to  adjust their  NCTS-P5  set-up  to  the 
compatibility measures required to ensure the operation continuity beyond 1 December 2023. 

Additionally, the Commission invited the National Administrations that have not yet done so to publish 
their trade specifications in accordance with the latest DDNTA 5.15 and RfCs promptly.  

National Administrations that do not offer a transition window to their trade should communicate their 
transition strategy well in advance to the EOs, allowing adequate time for the development and testing 
of the trade system. Additionally, all National Administrations should launch their outreach and support 
programs for the EOs. 

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-P5 by the National 
Administrations.  The  programme  is  being  extended  to  monitor  the  transition  of  the  National 
Administrations and traders during their transition to NCTS-P5, to collect the National Project Plans of 
the National Administrations for their transition to NCTS-P6 and to monitor operation continuity during 
the transition from NCTS-P5 to NCTS-P6 as well as to foster closer collaboration with the National 
Administrations.  

The trade community is regularly updated on the progress achieved and the National Planning. 

Considering  that  most  of  the  National  Administrations  are  currently  engaged  in  the  implementation 
phase of NCTS-P5, the Coordination Programme will provide support in the deployment in Operation 
of the National Administrations to coordinate the entry of trade into Operation. 

In addition, bilateral communication between the National Administrations and the Commission will be 
enhanced to provide support throughout the implementation of the NCTS system. This includes support 
in various stages of the development, such as Conformance Testing activities, National Planning and 
addressing any business or technical issues raised. 

Summary from the Member States: 

NCTS-P5 is regarded as a project with a medium to high complexity due to the dependencies with other 
systems, high availability requirements the limitation of resources by the Member States to develop the 
system and the constraints created by the COVID-19 pandemic. Despite this, the majority of the Member 
States reported to remain on track to meet the Deployment deadline for the project. 

Most Member States reported a low to 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 are related to the delay in call for tender procedures, procurement and service 
providers,  the  competing  priorities  and  interdependencies  within  and  outside  the  UCC  WP,  i.e., 
eCommerce and ICS2, lack of resources (human and financial), the Russian invasion of Ukraine, delay 
from the traders and changes in the specifications of the system. 

82 

 
 
Many  Member  States  also  adopted  an  Agile  development  methodology  or  an  iterative  approach  to 
shorten the implementation time frame. 

In  terms  of  assessing  the  level  of  completeness  of  the  system,  four  Member  States  completed  the 
development of the system, DE, EE, and SI, and half of the Member States that provided information 
reported that the system is on target159. BE, FI, HR160, IE, and MT indicated delays in the development 
of the activities of the project but are still on target to meet the legal deadline, whereas AT161, HU162, 
MT163, LT, NL164, PL165, and PT166 reported delays beyond the Deployment deadline. The percentage of 
Completion of each of the Member States’ projects according to their respective National Planning is 
provided in Table 28 below. 

Most Member States completed the Technical Specifications phase and are now either working on the 
Conformance Testing activities or plan to start them soon.  

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 

BE 

6 

Medium 

BG 

5 

Low 

CY 

6 

Low 

functionalities  of 

BE assessed the project as complex and challenging due to its 
interdependencies  with  other  projects  and  the  tight  deadline. 
BE’s  development  team  changed  during  the  course  of  the 
project,  which  caused  a  delay.  The  project,  however,  is  still 
foreseen  within  the  Deployment  deadline.  To  mitigate  this 
delay, BE has implemented an Agile approach and informed it 
will ‘go live’ with a Minimal Viable Product (MVP) with all 
existing 
the  current  NCTS.  New 
functionalities  (customs  office  of  exit,  customs  office  of 
incident  registration  and  the  connection  with  AES)  will  be 
available after the MVP. 
BG  indicated  that  the  status  of  the  project  is  on  target,  with 
Technical  Specifications  completed.  Conformance  Testing 
Mode 2 activities are ongoing and planned to be completed by 
15/08/2023.  The  system  is  planned  to  be  Deployed  on 
28/08/2023. BG is working closely with the software companies 
that provide services to the traders167. 
CY  informed  that  the  status  of  the  project  is  on  target  with 
Technical Specifications currently in progress. CY indicated a 
high complexity caused by the interdependencies between core 
and  supporting  systems,  need  for  a  high  percentage  of 
availability of the systems, limitations in human resources and 
effects of the COVID-19 pandemic. 
The analysis, the preparation of specifications and part of the 
implementation  of  the  system  are  set  to  finish  soon.  The 
Deployment is planned for 21/11/2023168. 

159 BG, CY, DK, ES, FR, HR, IT, LV, PT, RO, SE, and SK. 
160 Information provided from a bilateral meeting between HR and DG TAXUD held on 25/05/2023. 
161 Information provided from a bilateral meeting between AT and DG TAXUD held on 06/06/2023. 
162 Information provided from a bilateral meeting between HU and DG TAXUD held on 07/09/2023. 
163 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
164 Information provided from a bilateral meeting between MT and DG TAXUD held on 28/09/2023. 
165 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
166 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 
167 Information provided from a bilateral meeting between BG and DG TAXUD held on 27/07/2023. 
168 Information provided from a bilateral meeting between CY and DG TAXUD held on 20/07/2023. 

83 

 
 
 
 
 
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

CZ  

CZ  confirmed  the  planned  Deployment  date  of  the  system  in 
October169. 
DE indicated that NCTS-P5 was completed with the update of 
the national interface Export followed by Transit scheduled for 
2023. 
An  Agile  development  approach  is  being  used  to  define  the 
software  release  cycles.  The  ongoing  activities  involve  the 
finalisation  and  fine-tuning  of  NCTS-P5,  monitoring  of 
Operations, preparation of remaining Conformance Testing for 
new  functionalities  (Export  followed  by  Transit)  and  the 
continuation  of  the  Conformance  Testing  certification  of  the 
EOs.  Once  the implementation  of  the  UCC is completed,  DE 
will resume work on the technical modernisation of the system, 
such  as  GUI  modernisation  and  change  of  communication 
protocols. 
To allow for maximum flexibility in migrating from ECS-P2 to 
AES, the end date of the transition window for traders has been 
shifted from June 2023 to 29/10/2023. DE emphasised that the 
IT  Service  Providers  and  the  EOs  need  to  ensure  that  the 
Conformance Testing is planned in time to be connected to the 
new system by the end date of the soft migration on 29/10/2023. 
DK completed Technical Specifications activities and finalised 
Conformance Testing for the N1, N2 and N3 certificates. 
According to DK, the main cause for the high complexity of the 
project is the large number of stakeholders and the integration 
with other national systems. 
DK is planning to implement RfC.37. The Export followed by 
Transit  functionality  will  not  be  implemented  in  DK  by  the 
scheduled  date  of  29/07/2023.  However,  it  is  expected  to  be 
implemented before 01/12/2023. 

EE indicated that all milestones of the project were completed, 
although  some  delays  occurred  throughout  the  completion  of 
Technical Specifications, Conformance Testing Mode 1 and 2 
and Deployment. At the time of writing, traders are testing the 
system and a ‘big bang’ implementation is planned170. 
ES reported that the Technical Specifications and Conformance 
Testing phases were completed and Deployment activities are 
in progress. The NCTS system is currently open in the Common 
Domain (TES). The EOs conformance environment opened in 
December 2022, while the migration of the external domain is 
planned by March 2024171. 
ES implemented an iterative approach for the development of 
the NCTS system. 
FI informed that Conformance Testing and Deployment are the 
phases  that  experienced  the  most  delays.  The  effects  of  the 
COVID-19  pandemic,  limited  resources,  especially  on  the 
supplier’s  side  and  having  to  develop  multiple  systems  in 
parallel are indicated as the main causes of delays. Building the 

DE 

6 

Low 

DK 

6 

Low 

EE 

6 

Low 

ES 

4 

Low 

FI 

6 

High 

169 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 
170 Information provided from a bilateral meeting between EE and DG TAXUD held on 01/06/2023. 
171 Information provided from a bilateral meeting between ES and DG TAXUD held on 23/11/2023. 

84 

 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

the 

NCTS  system  from  scratch  also  adds  complexity  and  has 
affected the overall progress of the project. 
FI indicated that replanning and rescoping has been done and 
some resources have been reallocated from AES to NCTS work 
to prioritise it. Core functionalities are expected to be deployed 
on  18/11/2023  and 
inclusion  of  some  non-core 
functionalities  will  depend  on  the  progress  of  testing.  The 
testing  environment 
is  currently  open  for  traders.  The 
deployment of non-core functionalities is envisaged for October 
2024172. 
FR informed that the overall status of the project is on target, 
with no major delays or risks expected. 
An  iterative  approach  is  being  followed  by  FR  with  nine 
instalments defined for the development of the system. 
GR  shared that  the migration  of  all the  traders is  expected  to 
follow  a  big  bang  approach.  GR  has  experience  with  this 
approach from previous years and is adept at managing it173. 
HR indicated that the Deployment phase was impacted due to a 
restriction of time for the implementation of the RfC List before 
production, which disrupted the testing process. 
Despite the delay, HR shared its intentions for NCTS-P5 to be 
in Operation on 01/06/2023 following a big bang approach with 
the traders174. 
HU reported that  there were some contractual issues with the 
external contractor that are now solved and is confident with the 
planning  provided  by  the  contractor.  However,  it  will  not  be 
possible to allow a step implementation for the system within 
the contract and, therefore, NCTS-P5 will not be implemented 
by the initial deadline defined in the UCC WP but is envisaged 
to stay within the end dates defined in the new UCC WP175. 
IE  reported  that  delays  occurred  due  to  the  testing  of  AES, 
which  required  a  significant  amount  of  resources  and  caused 
Conformance  Testing  activities to  start  later  than  planned.  IE 
identified  other  causes  of  delays,  such  as  the  need  for  the 
implementation  of  RfCs and  alignment  to  the latest DDNTA, 
which  required  an  update  to  published  trader  specifications. 
Deployment  planning  has  been  delayed  for  one  month  until 
25/09/2023. 
The  GMS  functionality  is  expected  to  be  delivered  in  a  later 
iteration. 
IT  informed  of  the  high  risk  of  the  project  since  it  mainly 
depends  on  the  development  and  Conformance  Testing 
activities performed by the EOs. At the moment of writing, EOs 
did not progress sufficiently. 
Overall, IT assessed the status of the project as on target, with 
Conformance  Testing  and  Deployment  activities  currently  in 
progress.  IT  implemented  a  waterfall  approach  for  the 
development of the NCTS-P5 system. 

FR 

4 

Low 

GR 

HR 

6 

High 

HU 

4 

Low 

IE 

6 

Medium 

IT 

6 

High 

172 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 
173 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
174 Information provided from a bilateral meeting between HR and DG TAXUD held on 25/05/2023. 
175 Information provided from a bilateral meeting between HU and DG TAXUD held on 07/09/2023. 

85 

 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

LT 

2 

High 

LU 

LV 

MT 

6 

Medium 

NL 

PL 

5 

Medium 

impacted 

LT  reported that the project  was  delayed  by  5 months  due  to 
contractual difficulties related to an unsuccessful procurement. 
the  project's  progress  and  LT 
The  delays 
acknowledged that the initial Deployment deadline will not be 
met. LT shared that the contract with the provider was signed in 
February 2023 and are currently in an early stage of planning 
with the contractor. The new Deployment date  is planned for 
September 2024. Moreover, LT confirmed its plan to go  with 
all functionalities in one release176.  
LU will need to continue using NCTS-P4 messages with some 
traders  until mid-2024,  as the largest trader  will  not be  ready 
sooner. LU shared that for NCTS there is a significant risk given 
the need to have all Member States in NCTS-P5 before NCTS-
P6 can be Deployed177. 
LV indicated to be in progress with the development and testing 
of  the  system  and  Deployment  is  planned  for  27/11/2023. 
However,  connection  to  AES  and  declaration  prior  to  arrival 
will be later, probably in Q1 2024178. 
MT assessed that the overall delivery of the project is delayed 
beyond the foreseen Deployment deadline due to the tendering 
process.  MT  will  send  a  derogation  and  plans  to  deploy  the 
system in Q4 2024179. 
NL shared that the project development has been prioritised and 
separate  timelines  have  been  established  for  NCTS-P5  and 
AES-C1 projects. NL plans to enter in Operation on 01/07/2024, 
with  a  trade  transition  until  01/10/2024  and  is  confident  of 
achieving  those  milestones.  NL  is  actively  working  with  the 
Central Project Team in the delivery of the system and indicates 
a low risk for further delays because (1) NL will benefit from 
the  experience  of  other  NAs  that  will  have  Deployed  the 
package and (2) a 2-months contingency time has been planned 
between  the  end  of  the  trade  deployment  and  01/12/2024. 
Considering the actual plan, NL indicated that a derogation until 
December 2024 has been requested180. 
PL identified the following risks that are causing delays in the 
overall development of the NCTS-P5 project: delays in software 
deliveries, effects of COVID-19, Russian invasion of Ukraine 
and  the  complexity  of  the  new  Technical  Specifications. 
Initially,  the  dates  for  the  Conformance  Testing  and  the 
Deployment  phases  were  postponed  by  one  year  due  to  the 
additional  DDNTA  specifications.  The  tendering  process  was 
extended beyond the planned date. 
PL  is  engaged  in  implementation  changes  for  RfC  37  which 
have an impact on testing with traders. Further adjustments are 
anticipated from RfC 38. PL’s exporting traders are not ready 
and  they  have  a  policy  refraining  from  making  substantial 
system changes in December due to the busy trading period and 

176 Information provided from a bilateral meeting between LT and DG TAXUD held on 01/06/2023. 
177 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
178 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
179 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
180 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 

86 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

the associated risks. PL identified May 2024 as the most suitable 
time for the implementation of the system. The NCTS-P5 full 
scope is planned for December 2024 and PL will need to request 
a derogation181. 
PT informed that the high complexity of implementing a new 
NCTS system and integrating it with the different national and 
EU systems makes this a high-risk project. 
Conformance Testing activities are planned to take place until 
31/10/2023  and  Deployment  is  set  for  December  2023.  PT 
clarified that the project is progressing according to the planning 
with  no  major  delays  expected  and  it  is  using  Agile 
methodologies  to  minimise  the  implementation  timeframe. 
However,  PT  is  currently  facing  procurement  and  tendering 
difficulties, particularly with the renewal of contracts with the 
companies  developing  the  systems,  which  may  lead  to  an 
implementation of the NCTS/AES Systems in PT beyond the 
expected Deployment deadline. Operations are planned in the 
second half of 2024182. 
RO assessed the project as being on target with no major risks 
impacting the progress. The Technical Specifications have been 
released and the completion of Conformance Testing stands at 
over 70%. RO shared its intentions to Deploy the system from 
01/09/2023 to 01/12/2023, following a big bang approach for 
traders183.  
An iterative approach is being followed for the development of 
the system. 
SE  reported  that  the  progress  of  the  project  is  on  target. 
However,  a  potential  delay  was  identified  due  to  some 
difficulties  to  start  Conformance  Testing  activities  in  the 
common domain. 
SE  informed  that  the  Deployment  of  the  system  will  occur 
following a big bang approach on 15/11/2023184. 
SI  informed  that  all  development  activities  for  the  NCTS-P5 
application were completed by 2022. 
The  Mode  3  testing  scenarios  as  well  as  the  Mode  4 
Conformance test campaign were considered highly complex. 
SI encountered several challenges when testing with traders due 
to the changes in the transitional period between systems.  
SK indicated that Technical Specifications were completed and 
Conformance Testing activities are being delayed due to a lack 
of human resources and some bugs in the system that are being 
fixed  by  the  contractor.  The  plan  is  to  Deploy  the  system  on 
01/04/2024, following a big bang approach to move all traders. 
SK shared that there is active communication with traders for 
the preparation and testing purposes185. 

PT 

6 

High  

RO 

6 

Medium 

SE 

5 

Medium 

SI 

5 

High 

SK 

4 

Low 

Table 26: Detailed responses from Member States – NCTS-P5 

181 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
182 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 
183 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
184 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
185 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

87 

 
 
 
The risk assessment of National Planning of the National Administrations by the Commission Services 
is shown and substantiated in the Table 27 Risk Assessment by the Commission: NCTS-P5 below: 

Table 27: Risk Assessment by the Commission: NCTS-P5 

88 

 
 
 
 
3.7.2.  Overview of Project Progress 

Table 28 highlights any known divergences in the planning compared to the dates set in the UCC WP186. 
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 NCTS-P5, the following Member States have a planned/actual Operations date that is later 
than the deadline in the UCC WP187: AT, ES, FI, GR, HU, IE, LT, LV, MT, NL, PT, SE, and SK. FR 
did not provide information on the Operations date. 

Table 28: Comparison of Planned and Actual Dates – NCTS-P5 

186 The percentage of deployment refers to DG TAXUD preparation and the aggregated progress of National Administrations 
based on their National Plannings. 
187 In the 2023 UCC WP Revision, the end of the deployment window for the core functionalities of the system is envisaged 
for 01/12/2023 and the remaining functionalities for 02/12/2024. By 02/12/2024, all Member States and traders should use the 
NCTS-P5 system. The end of the transition is envisaged for 21/01/2025. 

89 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual Date2023 % of Completion Target date from WP187 2023 Planned/ Actual Date2023 % of Completion Target date from WP1872023 Planned/ Actual DateEuropean CommissionNot ProvidedNot ProvidedNot ProvidedNot Provided01/03/202185%Not ProvidedAT01/10/2023Not ProvidedN/ANot Provided01/07/2024Not Provided31/08/2024BE01/02/2020100%30/10/2023Not Provided29/11/2023Not Provided29/11/2023BG31/08/2022100%11/08/2023Not Provided28/08/2023100%28/08/2023CY14/02/2023100%Not Provided100%21/11/2023100%21/11/2023CZ21/10/2021100%01/10/2023100%02/10/2023100%02/10/2023DE26/10/2020100%29/10/2023100%01/10/2021100%16/06/2023DK01/08/2022100%22/05/2023100%29/07/2023100%01/11/2023EE31/05/2022100%27/06/2023100%01/10/2023100%01/10/2023ES30/06/2022100%17/02/2023100%03/10/2023100%12/03/2024FI07/12/2021100%30/09/2023Not Provided18/11/2023100%18/12/2023FR30/11/2021100%31/07/2023Not Provided01/12/2024Not ProvidedNot ProvidedGR31/10/2023Not Provided31/12/2024Not Provided01/12/2024Not Provided01/12/2024HR31/12/2021100%31/05/2023100%01/06/2023100%01/06/2023HU01/01/2024100%30/11/2024Not Provided01/12/2024100%01/12/2024IE19/08/2022100%11/07/2023Not Provided06/11/2023100%05/02/2024IT15/02/2021100%07/05/2023100%08/06/202375%06/11/2023LT01/12/202340%31/08/202440%01/09/202430%01/09/2024LU01/06/2021Not Provided14/02/2022Not Provided23/05/2023Not Provided30/09/2023LV01/03/2021Not Provided10/11/2023Not Provided27/11/2023Not Provided30/06/2024MTN/A100%N/ANot Provided01/12/2024100%01/12/2024NL01/10/2023Not Provided01/04/2024Not Provided31/05/2023Not Provided02/12/2024PL31/05/2023100%15/09/2023100%02/10/2023100%30/11/2023PT10/01/2023100%31/10/2024Not Provided30/11/2024100%02/12/2024RO05/01/2023100%30/11/2023Not Provided01/12/2023100%01/12/2023SE01/12/2021100%28/01/2024100%28/01/2024100%28/01/2024SI15/02/2020100%20/01/2023100%22/02/2023100%22/02/2023SK19/12/2022100%31/03/2024Not Provided01/04/2024100%31/03/2024RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)31/12/201901/03/202101/12/2023 
 
 
 
 
 
Figure  19  below  illustrates  the  percentage  of  completion  of  the  transition  for  all  National 
Administrations as a group. The light blue curve represents the Planned Value, which is the baseline 
endorsed by the Electronic Customs Coordination Group (ECCG) in October 2020.  The dark blue curve 
represents  the  Earned  Value,  also  known  as  the  Actual  Value,  compiled  from  the  latest  National 
Planning  submitted  before  15  September  2023  and  other  information  collected  from  the  National 
Administrations during the technical meetings188. 

At the end of Q3 2023, the deployment of NCTS-P5 stands at 73% (Earned Value), while it should be 
at  98%  (Planned  Value).  The  National  Administrations  are  working  to  accelerate  their  projects  and 
mitigate risks to meet the deployment milestones for the core functionalities by 1 December 2023 and 
for the non-core functionalities by 1 December 2024189. 

Figure 19: Conformance tests: Planned value versus earned value – KPI1 – NCTS-P5 

188 The Planned and Earned Values are built on a basket of 12 key milestones across all the National Administrations involved 
in the transition to NCTS-P5.  
189 According to the revised UCC WP that will be adopted in December 2023. 

90 

 
 
 
 
 
 
Figure 20 below displays the percentage of National Administrations in the Conformance Testing phase. 
The  light  purple  curve  represents  the  Planned  Value,  which  was  established  based  on  the  National 
Administrations'  plans  at  the  end  of  2020.  The  dark  purple  curve  represents  the  Earned  Value,  also 
known as the Actual Value, compiled from the latest National Planning submitted before 15 September 
2023. 

The peak of Conformance Testing has shifted by 3 quarters from the baseline set at the end of 2020 and 
has increased in volume. The distribution of the Conformance Testing bells now skews to the right in 
comparison  to  the  baseline,  as  National  Administrations  that  are  running  late  will  complete  their 
Conformance Testing campaigns during 2023 and 2024. 

Figure 20: Conformance tests: Planned value versus earned value – KPI2 – NCTS-P5 

91 

 
 
 
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
21.  

Figure 21: Percentage of Completion per Phase – NCTS-P5 

92 

 
 
 
Figure 22 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  National  Administration  in  their  National 
Planning, 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 WP. 

Figure 22: NCTS-P5 Transitional Period 

93 

 
 
 
 
3.8. UCC AUTOMATED EXPORT SYSTEM (AES) 

The AES project consists of an upgrade of both the existing trans-European ECS and the existing NES. 
It aims to implement the UCC requirements for the export and exit of goods, including export and re-
export declarations; EXS and CCE, re-export notifications and an interface with EMCS and NCTS. The 
project entails implementing the UCC simplifications offered to trade to facilitate the export of goods 
for European companies, such as CCE, 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 the 
Arrival  at  Exit  Notification  and  EXS  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 the latest trader is migrated to AES-C1. 

The following processes will be implemented: 

•  Export declaration pre-lodgement; 
•  Handling of simplified/supplementary declarations; 
•  CCE; 
•  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. 

The new export system brings about substantial benefits and simplifications while ensuring continuity 
with the existing operational systems. 

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

The  first  component,  AES  –  Component  1  relates  to  the  trans-European  AES.  The  project  aims  to 
further develop the existing ECS 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 CCE. It will also cover the development of harmonised interfaces with 
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.  

According to the revision of the UCC WP190, AES-C1 will be deployed in three steps: the first related 
to  core  functionalities  (Business  Continuity  aligned  to  UCC),  the  second  to  interface  with  Excise 
(planned  for  February  2024)  and  the  third  to  non-core  functionalities  (Central  Clearance,  Export 
followed by Transit Pre-Lodgement, Simplified/Supplementary Declarations). The Member States have 
the possibility to deploy both steps in one or deploy in sequence. 

AES-C1 will be deployed in line with the following calendar: 

190 The revised UCC WP will be adopted in December 2023. 

94 

 
 
 
Figure 23: AES-C1 timeline 

For  this  section  on  AES-C1,  the  entries  in  Operation  of  the  Member  States  focus  on  the  core 
functionalities, as they represent the main scope of AES-C1 and ensure business continuity. Despite this, 
most Member States will deploy both their core and non-core functionalities and their interface with 
Excise simultaneously. As of 1 December 2024, all Member States and economic operators should be 
using AES, but there will be still some restrictions applied till the end of the transition period or “Big 
Bang  to  UCC”.  At  the  moment  of  the  Big  Bang  all  restrictive  business  and  technical  rules  will  be 
removed and all MS and Traders will be submitting in AES the data 100% aligned to the UCC. 

The  second  component,  AES  –  Component  2  relates  to  the  NES  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 the central level (FSS and 
TSS) cover the Information Exchange in the common, national, and external domains: 

•  The  common  domain  communication  refers  to  the  Information  Exchange  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  the  case  of  external  or  national  domains,  the 
common  AES  specifications  are  strongly  recommended,  aiming  to  harmonise  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 ECS. 
They all need to transition to the AES-C1 system by 1 December 2023 for the core functionalities, 13 
February 2024 for the interface with Excise and 1 December 2024 for the non-core functionalities.  

95 

 
 
 
 
 
 
 
 
3.8.1.  Summary of Responses 

AES – Component 1 (AES-C1) 

Summary from the Commission: 

For AES, the challenge lies in ensuring business continuity and a seamless transition for Member States 
and  trade,  while  implementing  substantial  changes  in  the  applicable  Data  and  Process  models.  The 
Functional and Technical Specifications191 approved by the Member States govern the quality, technical 
support, operation continuity, security and capacity of the transition to full AES-C1 Operations. 

The AES project pioneered a collaborative, iterative and Agile working method that has been praised 
by all the 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 the 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. 
The Coordination Programme is also essential in enabling collaboration between the Member States and 
the Commission and providing transparency on the status of the project. 

UCC Work Programme and Technical Specifications to address the shift of the National Administrations 
and the traders 

Considering the delays reported by the Member States and by the trade community for their transition 
to AES-C1 (see below), the Central Project Team, in close cooperation with the Member States issued 
a  proposal  for  the  UCC  WP  and  the  TSS  aiming  at  ensuring  the  operation  continuity  of  AES  until 
January 2025 while bringing then in alignment with the UCC Annex B. 

The Technical System Specifications (TSS) have been improved in the light of the experience and of 
the expected legal arrangements which will frame the AES-C1 operation, as set in Article 278 of the 
UCC. 

Progress of the Central Project Team 

Overall, the activities of the Central Project Team are on track according to the planned schedule for the 
development of the central system and the quality of the central services according to the agreed Service 
Level Agreement. The Central Converter demonstrated its fitness for purpose and its resilience with the 
growing volume of conversion. Other central systems have been continuously improved. 

A  new  business  scenario  for  the  recapitulative  declarations  will  be  incorporated  in  the  AES  system 
specifications and the first update of the AES Business Guidance which is scheduled to be published by 
the end of 2023. 

A draft of the Business Continuity Plan for AES containing the Commission proposal is currently under 
preparation, following the information gathered from the Member States. The proposal is expected to 
be agreed between the Member States and the Commission by the end of 2023. 

Start of AES-C1 

The  Commission  and  the  Member  States  are  actively  involved  in  transitioning  the  trans-European 
customs systems for export. This started with the successful Deployment of the new UCC AES system 
in DE in March 2021 and the entry into international operation by ES and DE on 26 April 2023. These 
achievements paved the way for the next generation of interconnected trans-European systems for the 
trade community and the national customs authorities, showcasing the quality of the specifications and 
legal provisions supporting these systems and, most importantly, their business continuity. 

Since, IE, NL, HR, SI, DK, and BG joined the AES operation as of mid-September 2023, bringing the 
number of Member States in AES-C1 to eight at this date. 

191 The Functional and Technical Specifications include Service Management, Service Level Agreements, Terms of Reference, 
Crisis Management, Capacity Plans and Security Plans. 

96 

 
 
 
 
 
Increasing progress of the Member States in 2023 (as of mid-September 2023) 

The Member States reported significant progress in deploying their national export applications in 2023. 
Currently, 96% of the Member States are actively engaged in their implementation, while one Member 
State is in the procurement or inception stage and almost ready to start. 

Moreover,  82%  of  the  Member  States  are  already  in  or  have  already  completed  their  Conformance 
Testing activities, 11% are in deployment and 28% are already in Operation. 

The completion percentage of the transition phase for the Member States as a group stands at 74% in 
Q3 2023, exhibiting a 31% increase since Q3 2022.  

The  central  converter,  ieCA,  developed  and  operated  by  the  Commission  along  with  other  central 
systems, has performed as expected. This significant achievement is the outcome of over three years of 
intensive collaboration between the Member States and the Commission, marking the beginning of the 
transition in the Common Domain. 

Entry into Operation  

Figure 24 below presents the updated planning of the Member States’ entry in Operation. This figure is 
based on the date at which a Member State joins the ‘To Be’ operation on the Common Domain with 
their core functionalities. 

All Member States but 12 reaffirmed their intention to be in Operation with the Core functionalities by 
1 December 2023. Several Member States confirmed their intention to be in Operation for both Core 
and Non-Core functionalities as well as for their Excise interface by 1 December 2024. Two Member 
States (PL and PT, indicated in orange in Figure 24 below) are reviewing their plans and have not yet 
committed  to  their  date  of  entry  in  Operation.  XI  plans  to  enter  into  Operation  at  the  end  of  2025, 
however, efforts are being made to expedite this date before 1 December 2024. 

As of mid-September 2023, HR, IE, NL, SI,  DK, and  BG joined DE and ES in AES-C1 Operation. 
Currently, eight Member States, along with the Commission, are implementing their deployment plans 
to ensure their timely entry into Operation of AES-C1. Thus far, all entries in Operations have occurred 
without causing any disruption to the continuity and quality of the operation, reflecting the effective 
efforts of the National Project Teams. 

97 

 
 
 
Figure 24: AES-C1 Member States entry into Operations as of 17 September 2023 

At the moment of writing, IT secured its plan to enter into Operation in November 2023, which will 
boost the transition of AES-C1, considering its weight in NCTS volumetrics.  BE and FR, two major 
actors in  the  AES-C1  system,  will  enter into  Operation  during  2024  and  it is essential to secure  the 
deployment of FR before December 2024. PL's plan to enter into Operation will probably shift to 2024 
due to delays on the traders' side. PT is also experiencing difficulties in delivering on time. 

Overall, the Member States have collectively achieved significant progress. However, at least ten of 
them will enter into Operation during 2024, with some possibly joining in Q4 2024, if not on the last 
day. For further details, please refer to Table 30 below. 

Recommendations to the Member States 

The  Commission  invited  the  Member  States,  particularly  those  that  announced  running  over  the  1 
December 2023 milestone for the core functionalities, to maintain a high level of compliance with all 
their national projects so that NCTS-P5 can be deployed in time or with the shortest delay possible. 

For Member States that are at risk of missing the deadline for the core functionalities or already indicated 
an entry in Operation after 1 December 2023 are advised to take advantage of the remaining time before 
the deadline to undertake all necessary steps to minimise delays as much as possible. 

Furthermore,  the  Member  States  are  reminded  that  they  have  to  implement  all  requirements  of  the 
Design  Document  for  National  Export  Application  (DDNXA),  including  the  transitional  Rules  and 
Conditions, to ensure business continuity. The Member States are invited to adjust their AES-C1 set-up 
to the compatibility measures required to ensure the operation continuity beyond 1 December 2023. 

Additionally, the Commission invited the Member States that have not yet done so to publish their trade 
specifications in accordance with the latest DDNA 5 and RfCs promptly. 

It is essential for Member States that do not offer a transition window to their trade to communicate their 
transition strategy well in advance to the EOs. This will allow sufficient time for the development and 
testing  of  the  trade  system.  Moreover,  all  Member  States  should  initiate  their  outreach  and  support 
program for the EOs. 

The Coordination Programme 

98 

 
 
 
Under the umbrella of the ‘National Administration Coordination Programme’ the Commission assists 
and monitors the development and deployment of the national components for AES-C1 by the Member 
States. The programme is being extended to monitor the transition of the Member States and traders 
during their transition to AES-C1. 

The trade community is regularly updated on the progress achieved and the National Planning. 

Considering that the majority of the Member States are currently engaged in the implementation phase 
of AES-C1, the Coordination Programme has to provide support in the deployment in Operation of the 
Member States to coordinate the entry of trade into Operation. 

In  addition,  the  bilateral  communication  between  the  Member  States  and  the  Commission  will  be 
strengthened to support the Member States during their implementation of the AES system, through the 
various stages such as the development of the Conformance Testing activities, the National Planning 
and to address any business or technical issues raised by Member States. 

Summary from the Member States: 

Most Member States reported a low or medium-risk level regarding the on-time delivery of the AES-C1 
project, with only a few of them rating it as high. 

The delay in call for tender procedures, procurement and service providers; the competing priorities and 
interdependencies within and outside the UCC WP (i.e., eCommerce and ICS2); the lack of resources 
(staff  &  budget);  the  COVID-19  pandemic;  the  delays  from  the  traders  and  the  changes  in  the 
specifications are indicated as the main risk-causing events impacting the progress of the project. 

The  overall  complexity  of  the  system  is  being  assessed  as  medium/high,  mainly  due  to  the  many 
interdependences among systems, the large number of stakeholders and the intrinsic complexity of the 
processes that AES incorporates. 

Most Member States also reported adopting an Agile development methodology or an iterative approach 
with the objective of reducing the implementation time frame. 

The above summary also applies to AES-C2. 

In terms of assessing the level of completeness of the system, some of the Member States reported that 
the system is on target192. AT193, FI, FR, HU, LU, MT194, PL195, PT196, and SE stated that currently the 
development is being delayed beyond the Deployment deadline. FI, HU, and LU197 submitted a written 
notification  asking  for  derogation  under  Article  6(4)  UCC  to  DG  TAXUD  concerning  the  delay  for 
AES-C1 beyond the deadline 01/12/2023. 

The Member States that reported the completion of the AES project are DE, ES, HR198, IE, NL199, and 
SI. DE clarified that two functionalities are being developed until December 2023: (1) CCE; (2) the 
update of the existing national interface Export followed by Transit.  

The  percentage  of  Completion  of  each  of  the  Member  States’  projects  according  to  their  respective 
National Planning is provided in Table 32 below. 

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 

192 BG, CY, DK, EE, HR, IE, IT, MT, NL, PL, PT, RO, and SK. 
193 Information provided from a bilateral meeting between AT and DG TAXUD held on 06/06/2023. 
194 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
195 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
196 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 
197 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
198 Information provided from a bilateral meeting between HR and DG TAXUD held on 25/05/2023. 
199 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 

99 

 
 
 
 
 
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

BE 
BG 

4 

Low 

CY 

6 

Low 

CZ 

DE 

6 

Low 

DK 

6 

Low 

EE 

6 

Medium 

ES 

FI 

4 

6 

Low 

High 

involve 

Same response as for NCTS-P5. 
CY  informed  that  the  status  of  the  project  is  on  target  with 
Technical Specifications currently in progress. CY indicated a 
high complexity caused by the interdependencies between core 
and  supporting  systems,  the  need  for  a  high  percentage  of 
availability of the systems, the limitations in human resources 
and the effects of the COVID-19 pandemic. 
CY clarified that the analysis for AES took place in 2022 and 
the  other  activities  will  finish  in  2023.  Conformance  Testing 
will  be completed  by  15/08/2023  and  Deployment is  planned 
for 24/10/2023200. 
CZ  confirmed  the  planned  Deployment  date  of  the  system  in 
October201. 
DE  indicated  that  all  activities  for  AES-C1  were  completed. 
CCE  and  the  update  of  the  existing  national  interface  Export 
followed  by  Transit  functionalities  will  be  Deployed  by 
December 2023. 
DE implemented an Agile development methodology in defined 
software  release  cycles.  Ongoing  activities 
the 
finalisation  and  fine-tuning  of  AES,  the  monitoring  of 
Operations  and  the  preparation  of  remaining  Conformance 
Testing  for  new  functionalities  of  AES  (e.g.,  centralised 
clearance)  as  well  as  the  ongoing  Conformance  Testing 
certification with the EOs. 
The end date of the transition window for traders shifted from 
June  2023  to  29/10/2023  to  allow  maximum  flexibility  to 
migrate from ECS-P2 to AES. 
DK assessed the project as being on target and  informed that 
Conformance  Testing  activities  for  Mode  2  are  finished.  DK 
expects to finalise Conformance Testing activities for Mode 3 
on  14/07/2023.  The  transition  window  for  traders  is  allowed 
until 01/11/2023.  
The  project  is  highly  complex  due  to  the  high  number  of 
stakeholders involved and system integrations. 
EE assessed the project as being on target with the Technical 
Specifications  phase  completed  and  Conformance  Testing 
currently  ongoing.  Traders  are  testing  the  system  and  a  ‘big 
bang’ implementation is planned202. 
EE  reported  that  the  phases  of  the  project  were  divided  into 
analysis,  development,  delivery  and  testing  to  reduce  the 
implementation timeframe. 
ES  completed  all  activities  relating  to  AES-C1.  An  iterative 
approach was used for the development of the system. 
FI  assessed  the  project  as  delayed  beyond  the  Deployment 
deadline.  The  causes  indicated  for  delay  are  the  COVID-19 
pandemic,  the  limited  resources,  especially  on  the  supplier’s 
side,  and  having  to  develop  multiple  systems  in  parallel.  FI 
prioritised the development of NCTS which stalled progress for 

200 Information provided from a bilateral meeting between CY and DG TAXUD held on 20/07/2023. 
201 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 
202 Information provided from a bilateral meeting between EE and DG TAXUD held on 01/06/2023. 

100 

 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

AES. Given the situation, FI sent a derogation request for AES-
C1. Core functionalities are scheduled for October 2024. Half 
of  the  test  scenarios  have  already  been  completed  in  the  pre-
Conformance Testing phase. The test environment is expected 
to  be  available  well  in  advance,  with  a  one-month  migration 
period envisaged. FI also shared that the current exit system will 
remain  connected  to  AES  until  AES’s  exit  functionality  is 
introduced in Q2 2025. The existing EMCS connection in the 
current export system and will transition to the new system in 
October 2024203. 
FR informed of delays caused by the lack of resources available 
to  complete  all  the  ongoing  projects  for  the  import-export 
system. To mitigate the impact of the delays, FR will deliver 
AES following 3 releases (V1, V2 and V3). V1 will include core 
flow, diversion, enquiry procedure, manifest and invalidation. 
This is defined as the MVP. V2 and V3 will include re-export 
notification, NCTS link, EMCS link, EXS, amendment of the 
declaration, partial release and CCE. 
Overall, the expected delay is of one year for the MVP. 
GR  shared that  the migration  of  all the  traders is  expected  to 
follow  a  big  bang  approach.  GR  has  experience  with  this 
approach from previous years and is adept at managing it204. 
HR shared that the RfCs being introduced late in the stage of 
development disrupted the testing process, ultimately impacting 
Conformance Testing activities. Furthermore, HR indicated that 
it  has  limited  human  resources  that  can  perform  such  test 
scenarios. 
Although  that,  HR  indicated  that  the  system  is  in  Operation 
(except for CCE) since 03/05/2023 and a big bang approach was 
followed with traders205. 
HU  reported  delays  for  the  project  beyond  the  Deployment 
deadline due to a lack of resources that can be allocated to the 
project. As a result, HU requested a one-year derogation. 
HU is currently working on developing the TS, while the rest of 
the  activities  did  not  start.  Resources  were  reallocated  to  this 
project after the completion of EMCS P4.  
IE  assessed  the  project  as  being  completed206.  The  initial  ‘go 
live’  took  place  on  21/03/2023,  almost  two  months  after  the 
original expected date, due to the complexities already indicated 
as well as having to implement a last-minute RfC.37. 
IE  informed  that  the  Transition  Period  and  the  related 
requirement  for  a  Transition  Handler,  ieCA  and  TP  rules 
increased the complexity of the project. 
IE is currently working on testing activities with Conformance 
Testing for Mode 2 completed for exiting business continuity. 
Some of the newer AES features, such as CCE are still pending 
testing.  

FR 

6 

High 

GR 

HR 

6 

Medium 

HU 

6 

High 

IE 

6 

Medium 

203 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 
204 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
205 Information provided from a bilateral meeting between HR and DG TAXUD held on 25/05/2023. 
206 Information provided from a bilateral meeting between IE and DG TAXUD held on 17/05/2023. 

101 

 
 
 
 
 
Complexity 
Rating 

6 

4 

Risk 
Level 

High 

Medium 

MS 

IT 

LT 

LU 

LV 

MT 

4 

Low 

NL 

6 

Low 

PL 

5 

Medium 

Additional Comments 

IT  shared that  AES-C1  is scheduled  for  15  November  with  a 
phased approach207. 
LT  indicated  that  the  Conformance  Testing  activities  were 
completed  with  the  Tax  Inspectorate  and  with  the  National 
Paying Agency. Conformance Testing for Mode 1 is completed 
and Conformance testing for Mode 2 started on 02/06/2023 and 
is underway. 
LU reported that the full AES system deployment is planned for 
30/06/2024.  While  LU  will  be  using  the  EMCS  system 
developed  by  AT,  there  is  a  delay  with  establishing  the 
connection with AES and it remains uncertain whether it will be 
ready by May/June 2024208. 
LV  shared  that  a  new  technology  and  architecture  will  be 
implemented. The plan is to deploy the system on 02/10/2023, 
covering core functionalities but not including the connection to 
NCTS or EMCS. LV indicated that it probably will not be able 
to  connect  to  NCTS  by  December  2023.  Integration  with 
EMCS, and probably with NCTS, is planned for Q1 2024209. 
MT  reported  that  Technical  Specifications  for  AES-C1  were 
completed  and  is  currently  performing  Conformance  Testing. 
The development of the system is being done internally in the 
Malta Information Technology Agency (MITA). The project is 
being delayed beyond the foreseen Deployment deadline due to 
other integration needs. The system is planned to be Deployed 
in Q4 2024. MT indicated that a derogation will be requested210. 
NL informed that the AES-C1 system entered in Operation on 
22/04/2023. NL shared that an agile and iterative approach for 
the implementation is being used. EMCS connection is planned 
on  13/02/2024  and  CCE  will  be  implemented  together  with 
CCI-P2 in 2025211. 
PL assessed the project as being on target with the  Technical 
Specifications and the Conformance Testing phases completed. 
PL identified the following risks: (1) the IT provider's quality of 
service,  (2)  the  delay  in  software  deliverables  on  the 
contractor’s  side,  (3)  the  limited  training  of  the  team  on  the 
development  of  AES  and  NCTS  and  (4)  the  lack  of  human 
resources.  The  integration  of  AES  with  NCTS  and  other 
national  systems  being  developed  simultaneously  in  customs 
administration  poses  an  additional  risk.  In  this  light,  not  all 
software  providers  are  expected  to  develop  new  client 
applications on time. 
At  the  same  time,  the  COVID-19  pandemic  has  created  an 
unstable environment, that has impacted work progress across 
all systems. 
The initial dates established for the Conformance Testing and 
the development phases suffered a delay of one year, due to the 

207 Information provided from a bilateral meeting between IT and DG TAXUD held on 07/11/2023. 
208 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
209 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
210 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
211 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 

102 

 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

additional  releases  of  Design  Document  for  National  Export 
Application (DDNEA) specifications. 
PL  indicated that  its exporting traders  are  not ready and  they 
have  a  policy  refraining  from  making  substantial  system 
changes  in  December  due  to  the  busy  trading  period  and  the 
associated risks. PL identified May 2024 as the most suitable 
time for the implementation of the system. Full functionality is 
planned for AES and PL will need to request a derogation212. 
PL  shared  that  is  using  an  iterative  approach  for  the  system 
development. 
Same  response  as  for  NCTS-P5.  However,  PT  is  currently 
facing procurement and tendering difficulties, particularly with 
the  renewal  of  contracts  with  the  companies  developing  the 
systems,  which  may  lead  to  an  implementation  of  the 
NCTS/AES  systems  in  PT  beyond  the  expected  Deployment 
deadline. AES full scope is planned to be deployed in one step 
in the second half of 2024. EMCS connection will be done with 
the existing export system in February 2024213. 

High 

Medium  Same response as for NCTS-P5214. 

PT 

RO 

6 

6 

SE reported a delay in the project, impacting its progress beyond 
the Deployment deadline. The date for Deployment is scheduled 
for  October  2024,  with  the  first  deployment  including  all 
components,  except  (1)  entry  in  the  declarant's  records,  (2) 
EXS, and  (3) re-export notification, which are expected to be 
deployed  by  the  end  of  2025 215 .  From  2025  onwards, 
communication over the common domain in the old format will 
no  longer  be  available.  The  Technical  Specifications phase  is 
currently in progress, and SE indicated that a phased approach 
will be implemented for the development of the system. 
SI  informed  that  the  AES-C1  project  is  complete,  with 
and 
Technical 
Deployment  activities  fulfilled.  The  system  entered 
in 
Operations on 24/05/2023. 
Same response as for NCTS-P5. 

Specifications,  Conformance  Testing 

SE 

4 

Low 

SI 

SK 

5 

4 

Low 

Low 

Table 29: Detailed responses from Member States – AES-C1 

212 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 
213 Information provided from a bilateral meeting between PT and DG TAXUD held on 27/10/2023. 
214 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
215 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 

103 

 
 
 
 
 
 
 
The risk assessment of National Planning of the Member States by the Commission Services is shown 
and substantiated in the Table 30 below: 

Table 30: Risk Assessment by the Commission: AES-C1 

104 

 
 
 
 
 
AES – Component 2 (AES-C2) 

Summary from the Member States: 

Please see also the summary from AES-C1. 

In terms of assessing the level of completeness of the system, some Member States reported that the 
system is on target216. FI, FR, HU, MT, and SE stated that currently the development is being delayed. 
Out of those, MT will be requesting a derogation217, due to the limitation in the resources to complete 
the project and FI and HU already submitted a written notification asking for derogation under Article 
6(4) UCC to DG TAXUD concerning the delay for AES-C1 beyond the deadline 01/12/2023. 

The  percentage  of  Completion  of  each  of  the  Member  States’  projects  according  to  their  respective 
National Planning is provided in Table 33 below. 

Detailed Responses: 

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

MS 

AT 
BE 
BG 
CY 
CZ 

DE 

DK 

EE 

ES 

FI 

FR 

GR 

HR 

HU 
IE 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

4 
6 

6 

6 

6 

4 

6 

6 

6 

6 
6 

Low 
Low 

Low 

Low 

Same response as for AES-C1. 
Same response as for AES-C1. 
Same response as for AES-C1. 
According to DE, the trans-European AES project is developed 
together with the national export component and corresponds to 
the national release AES 3.0.1 DE indicated that the acceptance 
test  AES  3.0.1  started  on  18/01/2021  and  was  carried  out 
without interruption until 05/03/2021. 
The information shared for AES-C1 is relevant for this section 
as well. 
DK assessed the project as being on  target and  informed that 
Conformance  Testing  activities  for  Mode  2  are  finished.  DK 
expects to finalise Conformance Testing activities for Mode 3 
on  14/07/2023.  The  transition  window  for  traders  is  allowed 
until 01/11/2023. 

Medium  Same response as for AES-C1. 

Low 

High 

High  

ES informed that the end of the Conformance Testing will be 
marked by the start of the migration window for traders. 
The information shared for AES-C1 is relevant for this section 
as well. 
Same response as for AES-C1. 
According to FR, AES-C2 is highly linked to AES-C1.  
The information shared for AES-C1 is relevant for this section 
as well. 

Low 

Although  HR  indicated  that  the  project  is  on  target,  the 
Deployment date was postponed to 02/05/2023. 
HR informed that the national component was developed on a 
smaller  scale  in  the  first  phase  due  to  the  complexity  of  the 
mandatory scope of the scenario. 
Same response as for AES-C1. 
Medium  Same response as for AES-C1. 

High 

216 BG, CY, DK, EE, HR, IE, IT, MT, NL, PL, PT, RO, and SK. 
217 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 

105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
MS 

IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Complexity 
Rating 
6 
4 

5 
6 
5 
6 
6 
4 
5 
4 

Risk 
Level 
High 

Additional Comments 

Same response as for AES-C1. 
Medium  Same response as for AES-C1. 

Medium  Same response as for AES-C1218. 

Low 

High  

Same response as for AES-C1. 
Medium  Same response as for AES-C1. 
Same response as for AES-C1. 
Medium  Same response as for AES-C1. 
Same response as for AES-C1. 
Same response as for AES-C1. 
Same response as for AES-C1. 

Low 
Low 
Low 

Table 31: Detailed responses from Member States – AES-C2 

218 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 

106 

 
 
 
 
 
 
 
 
 
 
3.8.2.  Overview of Project Progress 

Table 32 highlights any known divergences in the planning compared to the dates set in the UCC WP. 
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 AES-C1, the following Member States have a planned/actual Operations date that is later 
than the deadline in the UCC WP219: AT, BE, FI, FR, GR, HU, LU, MT, PT, SE and SK. 

Table 32: Comparison of Planned and Actual Dates – AES-C1 

219 In the 2023 UCC WP Revision, the end of the deployment window for the core functionalities of the system is envisaged 
for 01/12/2023, the development of a harmonised interface with the EMCS for 13/02/2024, and the remaining functionalities 
for 02/12/2024. By 02/12/2024, all Member States and traders should use the AES system. The end of the transition is envisaged 
for 11/02/2025. 

107 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP219 2023 Planned/ Actual Date2023 % of Completion Target date from WP2192023 Planned/ Actual DateEuropean CommissionNot providedNot ProvidedNot provided85%Not Provided80%Not ProvidedAT31/12/2020Not ProvidedNot providedNot Provided01/07/2024Not Provided30/09/2024BE30/06/2022Not Provided05/02/2024Not Provided13/02/2024Not Provided13/02/2024BG31/08/2022100%11/08/2023100%28/08/2023100%28/08/2023CY01/08/2023100%Not provided100%24/10/2023100%24/10/2023CZ21/10/2021100%01/10/2023Not Provided02/10/2023Not Provided02/10/2023DE26/10/2020100%29/10/2023100%01/10/2021100%16/06/2023DK01/08/2022100%17/07/2023100%29/07/2023100%01/11/2023EE31/05/2022100%01/06/2023100%01/10/2023100%01/10/2023ES15/04/2021100%08/04/2022100%18/10/2022100%09/05/2023FI07/12/2021100%31/12/202450%25/05/202480%21/06/2024FR01/03/2023100%30/09/202425%31/12/20250%01/04/2026GR31/10/2023Not Provided31/12/2024Not Provided01/12/2024Not Provided01/12/2024HR31/12/2021100%10/03/2023100%03/05/2023100%03/05/2023HU31/03/2023100%30/08/20245%30/08/20240%01/12/2024IE28/01/2022100%30/03/2023100%21/03/2023100%21/05/2023IT15/02/2021100%07/05/2023100%08/06/202385%15/11/2023LT04/05/2023100%01/12/2023100%01/12/2023100%01/12/2023LU01/07/2023Not Provided30/03/2024Not Provided30/06/2024Not Provided30/06/2024LVN/ANot Provided30/09/2023Not Provided02/10/2023Not Provided02/10/2023MTN/A100%N/A100%01/12/2024100%01/12/2024NL01/12/2021100%29/09/2023100%01/05/2023100%22/04/2023PL15/05/2023100%02/10/2023100%02/10/2023100%30/11/2023PT22/02/2023100%31/10/2024100%30/11/2024100%02/12/2024RO05/01/2023Not Provided30/11/2023100%01/12/2023100%01/12/2023SE15/12/202270%20/12/202430%01/10/20240%20/12/2024SI06/04/2021100%23/05/2023100%24/05/2023100%24/05/2023SK02/02/2023100%31/03/2024100%01/04/2024100%31/03/2024RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window)31/12/201901/03/202101/12/2023 
 
  
 
 
 
Figure 25 below illustrates the percentage of completion of the transition for the Member States as a 
group. The light blue curve represents the Planned Value, which is the baseline endorsed by the ECCG 
in October 2020. The dark blue curve represents the Earned Value, also known as the Actual Value, 
compiled from the latest National Planning submitted before 15 September 2023220. 

At the end of Q3 2023, the deployment of AES-C1 stands at 74% (Earned Value), while it should be at 
96% (Planned Value). The Member States are working to accelerate their projects and mitigate risks to 
meet the deployment milestones for the Core functionalities by 1 December 2023 for the interface with 
Excise on 13 February 2024 and for the non-core functionalities by 1 December 2024221. 

Figure 25: Key milestones: Planned value versus earned value – KPI1 – AES-C1 

220 The Planned and Earned Values are built on a basket of 12 key milestones across all the  Member States involved in the 
transition to AES-C1. 
221 According to the revised UCC WP that will be adopted in December 2023. 

108 

 
 
 
 
 
 
Figure 26 below displays the percentage of the Member States in the Conformance Testing phase. The 
light purple curve represents the Planned Value, which was established based on each Member States' 
plans at the end of 2020. The dark purple curve represents the Earned Value, also known as the Actual 
Value, compiled from the latest National Planning submitted before 15 September 2023. 

The peak of Conformance Testing has shifted by two quarters from the baseline set at the end of 2020 
and has increased in volume. The distribution of the Conformance Testing bells now skews to the right 
in comparison to the baseline, as Member States that are running late will complete their Conformance 
Testing campaigns during 2023 and 2024. 

Figure 26: Conformance Tests: Planned value versus earned value – KPI2 – AES-C1 

109 

 
 
 
 
 
Regarding AES-C2, the following Member States have a planned/actual Operations date that is later 
than the deadline in the UCC WP222: AT, BE, FI, FR, GR, HU, LU, MT, PT, SE, and SK. 

Table 33: Comparison of Planned and Actual Dates – AES-C2 

222 In the 2023 UCC WP Revision, the end date of the deployment window is envisaged for 02/12/2024. 

110 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP 2023 Planned/ Actual Date2023 % of Completion Target date from WP2222023 Planned/ Actual DateATNot ProvidedNot Provided15/06/2024Not Provided01/07/2024Not Provided01/10/2024BE01/09/2021Not Provided05/02/2024Not Provided13/02/2024Not Provided13/02/2024BG31/08/2022100%11/08/2023100%28/08/2023100%28/08/2023CY30/06/2023100%Not Provided100%24/10/2023100%24/10/2023CZ21/10/2021Not Provided01/10/2023Not Provided02/10/2023Not Provided02/10/2023DE09/10/2020100%29/10/2023100%06/03/2021100%29/10/2023DK01/08/2022100%14/07/2023100%29/07/2023100%01/11/2023EE31/03/2022100%01/06/2023100%01/10/2023100%01/07/2023ES15/04/2021100%18/10/2022100%18/10/2022100%09/05/2023FI30/06/2023100%30/12/202450%30/12/202480%31/12/2024FR31/03/2023100%N/A25%30/09/20240%31/12/2024GR31/12/2023Not ProvidedNot ProvidedNot Provided31/12/2024Not Provided31/12/2024HR31/12/2021100%10/03/2023100%02/05/2023100%02/05/2023HU31/03/2023100%30/08/20245%30/08/20240%30/08/2024IE28/01/2022100%30/03/2023100%21/03/2023Not Provided21/05/2023IT15/02/2021100%07/05/2023100%07/09/202385%02/10/2023LT04/05/2023100%01/12/2023100%01/12/2023100%01/12/2023LU01/07/2023Not Provided30/03/2024Not Provided01/12/2023Not Provided30/03/2024LVN/ANot Provided30/09/2023Not Provided02/10/2023Not Provided02/10/2023MTN/A100%N/A25%01/12/20240%01/12/2024NL01/01/2020100%29/09/2023100%08/05/2023100%29/09/2023PL15/05/2021100%02/10/2023100%02/10/2023100%30/11/2023PT22/02/2023100%31/10/2024100%30/11/2024100%02/12/2024RO06/01/2023100%30/11/2023100%15/05/2023100%01/12/2023SE15/12/202270%20/12/202430%01/10/20240%20/12/2024SI18/12/2020100%23/05/2023100%23/05/2023100%23/05/2023SK03/02/2023100%31/03/2024100%01/04/2024100%31/03/2024To be defined by MS01/03/202101/12/2023RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
 
 
Additional details regarding the specific percentage of completion per milestone can be seen in Figure 
27.  

Figure 27: Percentage of Completion per Phase – AES-C1 

111 

 
 
 
Figure 28 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 State223 in their National Planning, 
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 WP. 

Figure 28: AES-C1 Transitional Period 

223 The  Member  States  that  announce  to  be  on  time  for  the  01/12/2023  milestone,  the  running  over  Member  States  is  not 
presented included in the chart. 

112 

 
 
 
 
 
Regarding AES-C2, additional details on the specific percentage of completion per milestone can be 
seen in Figure 29. 

Figure 29: Percentage of Completion per Phase – AES-C2 

113 

 
 
 
4.  ONGOING 

PROJECTS:  DETAILED 

PLANNING  AND 

PROGRESS 

INFORMATION 

4.1. UCC GUARANTEE MANAGEMENT (GUM) 

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, used in 
more than one Member State, are made electronically accessible to the Member States 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  among  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.  

GUM – Component 1 (GUM-C1) will cover the management of the comprehensive guarantees that 
may be used in more than one Member State. It will be implemented in the UCC CDS and interface with 
a  national  component  (GUM-C2)  for  the  monitoring  of  the  reference  amount.  Transit  guarantees 
monitoring is an exception to the above and it is handled as part of the NCTS project.  

GUM  –  Component  2  (GUM-C2),  that  relates  to  the  ‘National  Guarantee  Management’,  will  be 
implemented through a national electronic system where comprehensive guarantees valid in more than 
one Member State will be registered and managed and its reference amount monitored. It will also be 
used for other guarantees. 

4.1.1.  Summary of Responses 

GUM – Component 1 (GUM-C1) 

Summary from the Commission: 

The UCC Customs Decisions system will be used to implement a decentralised system with minimal 
central IT support. Technical Specifications for GUM-C1 were completed on 19 September 2022 and 
the Conformance Testing activities have not yet begun. The system is expected to be in operations by 
March 2024. 

Between October 2023 and June 2025, the Member States  will need to carry out their Conformance 
Testing and, therefore, it is their responsibility to plan accordingly (see National GUM – Component 2) 

An iterative process will be employed by the Commission to validate the project scope with the Member 
States. 

GUM-C1 is a highly complex project due to the need to implement updated Business Processes and the 
required integration of the system with CDS as well as other Member States’ national GUM systems. 
Additionally, there is a moderate risk level associated with timely project delivery, given the requirement 
of Annex A data elements, changes in Business Processes and the deployment of the GUM-C2 systems 
in all Member States, to ensure full functionality of the GUM system. 

National GUM – Component 2 (GUM-C2) 

Summary from the Member States:  

GUM  Component  2  refers  to  the  development  of  the  national  GUM  systems  of  the  Member  States, 
which can largely be conducted in parallel with GUM-C1 development. The Member States emphasised 
the fact that project interdependency exists regarding the NIS system of each Member State, particularly 
in cases where multiple Member States' guarantees are involved. 

114 

 
 
CZ224, ES, GR225, IE, LT, LV226, and SE already implemented national GUM systems. Similarly, the 
GUM  systems  for  BG  and  PL  were  also  integrated into  their  NIS.  EE,  FI,  and  SE  reported that  the 
Technical  Specifications  will  not  be  applicable  in  their  case,  as  there  is  no  interface  in  the  external 
domain to the trader. The remaining Member States reported that activities associated with the Technical 
Specifications or Conformance Testing stages are either in progress or have not yet been initiated.   

Most  of  the  Member  States  assessed the project  as medium/high  complexity  due  to  the  inclusion  of 
complex functionalities and interfaces with other customs systems, which are the main potential causes 
of  delays,  along  with  a  lack  of  human  resources.  In  this  regard,  EE  indicated  that  the  development 
process has been delayed beyond the foreseen Deployment deadline. 

Detailed Responses: 

Table 34 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 

DE 

4 

Low 

DK 

5 

Medium 

through 

the  GUM-C2  project.  BG 

BG indicated that GUM-C2 is a part of NIS and will be revised 
in line with the NIS planning, which will be updated according 
to the new Annex B of the Commission Delegated Regulation 
(EU)  2021/234.  BG  stated  that  during  Conformance  Testing 
activities,  connectivity  between  GUM-C2  and  the  National 
Accounting System was tested. In Q4 2022, terms of reference 
were  prepared,  which  envisions  an  upgrade  of  the  national 
GUM  system 
is 
implementing  IT  projects  using  the  TOGAF/ADM  and  RUP 
methodologies. 
CY indicated that the national part of GUM-C2 is on target and 
intended to be  in Operations on 02/06/2025227. For GUM-C1, 
CY will be using the central system. Additionally, CY informed 
of the high complexity level of activities for the project, due to 
the interconnections between core and supporting systems, high 
percentage of system availability required, limitations in human 
resources and the COVID-19 pandemic. 
CZ shared that a national system is already in place and ongoing 
efforts are underway to integrate it with the central component 
by June 2025228. 
DE indicated that GUM-C2 will be implemented in the major 
release  of  the  national  IT  system  ATLAS  Release  10.3, 
however, preparatory activities have not yet started. As of the 
current planning, Conformance Testing activities have not yet 
been  initiated  or  scheduled  and  there  is  no  determined 
deployment approach. 
DK reported that the project is currently ongoing. Nonetheless, 
multiple  interdependencies  exist  among  the  various  project 
deployments within the UCC WP. Consequently, this situation 
may have an impact on the Conformance Testing activities as 
well as the Deployment of GUM-C2. DK further informed that 
the detailed plans for Conformance Testing have not yet been 

224 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 
225 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
226 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
227 Information provided from a bilateral meeting between CY and DG TAXUD held on 20/07/2023. 
228 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 

115 

 
 
 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

EE 

ES 

4 

4 

Med 

Low 

FI 

5 

Medium 

FR 

5 

Low 

GR 

HR 

5 

Medium 

HU 

5 

Medium 

IE 

3 

Low 

formalised and it is anticipated that they will be planned during 
2023. 
EE indicated that the development process for GUM-C2 started 
in 2022 but has been delayed beyond the foreseen Deployment 
deadline  due  to  lack  of  financial  resources.  Additionally,  the 
level  of  risk  has  been  set  as  medium  due  to  lack  of  human 
resources as well. As a mitigating measure, EE informed that a 
new deadline was set, envisaging the system to be deployed in 
line with CCI-P1 on May 2024229. An Agile approach is being 
used for the development of the system. 
ES reported that GUM-C2 was implemented on 01/05/2019. 
FI reported that a new national GUM-C2 is being developed and 
indicated  that,  given  that  there  is  no interface  with  customers 
from GUM, TS will not be needed. According to FI's National 
Planning,  GUM-C2  will  be  developed  iteratively  in  several 
phases, with the final phase expected to be in production in Q2 
2025, by when integration to Customs Reference System (CRS) 
will start. However, a medium level of risk has been indicated 
for  the  on-time  delivery  of  the  project,  considering  the  many 
integrations required for the project. 
FR shared that the Technical Specifications were delayed by 6 
months,  but  at  the  moment  of  writing,  they  are  in  progress. 
Overall, the project is on target against the initial date defined 
in the UCC WP. According to FR, the project has a high level 
of  complexity,  due  to  the  connection  to  Customer  Reference 
Services, which is a prerequisite, and it has to be initiated prior 
to implementing GUM-C2. 
GR indicated that a national system is already in place and will 
be upgraded230. 
HR  reported  that  the  implementation  of  the  National  GUM 
system is planned for Q2 2025231. The development of GUM-
C2 is reliant on the development of the national import customs 
clearance system and the budget. The project has been identified 
as having a high level of complexity, due to the need to expand 
the existing system's functionality. This expansion will require 
the definition of new processes and architecture, which renders 
the task particularly demanding. 
HU indicated that the overall status of the project is on target 
and expects to start the Technical Specifications phase during 
2023. 
IE reported that a national system for guarantees is already in 
place. In 2020, IE implemented an interface with its accounting 
system as part of the Deployment of NIS. This interface is used 
to check when the procedure for free circulation under deferred 
payment  is  released,  ensuring  that  there  is  enough  guarantee 
remaining  to  cover  liabilities  before  the  goods  are  released. 
Monitoring  of  guarantees  for  all  other  procedures  (other  than 
transit, which is outside the scope of GUM) is performed in a 
post-clearance  environment  by  the  IE  control  officers.  IE 

229 Information provided from a bilateral meeting between EE and DG TAXUD held on 01/06/2023. 
230 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
231 Information provided from a bilateral meeting between HR and DG TAXUD held on 25/05/2023. 

116 

 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

IT 

4 

Low 

LT 

6 

Low 

LU 

LV 

MT 

5 

Low 

NL 

PL 

4 

Low 

PT 

6 

High 

indicated that the national system in place will be reviewed to 
determine the necessary changes, but a detailed plan is not yet 
available232. 
IT indicated that the project has started with the definition of the 
Technical  Specifications. The  planning  analysis  for GUM-C2 
upgrades is scheduled for 2024233. The system will be deployed 
using  a  waterfall  approach.  IE  intends  to  deploy  both 
Component 1 and Component 2 of GUM within the specified 
deadlines,  with  the  national  component  to  be  updated  by  Q4 
2024.  
LT shared that, during the implementation phase, GUM-C2 will 
be adapted to work with GUM-C1. This adaptation will ensure 
the management of import guarantees used in LT and at least 
one  other  Member  State,  as  well  as  with  NCTS-P5  and  the 
national import and export declaration processing system. This 
will  enable  the  automatic  management  of  guarantees  in  the 
declaration process. 
Although  the  Deployment deadline  was  delayed,  LT reported 
that  the  system  was  deployed  on  16/11/2022.  LT  further 
indicated that for all EOs will follow the ‘big bang’ approach 
and the system is expected to be in Operations by 14/02/2023. 
However,  the  project  is  highly  complex  due  to  the  system's 
complex  functionalities  and  interfaces  with  other  customs 
systems as well as a lack of human resources. 
LU is starting to work on the national GUM system234. 
LV reported that the national GUM system is in operations since 
2018 and has been updated recently. LV will be ready to connect 
to the central system235. 
MT  indicated  that  the  development  of  GUM-C2  will  start  in 
2024.  As  EOs  have  a  small  volume  of  movements,  it  is  not 
practical  for  most  of  them  to  create  a  system-to-system 
mechanism. However, MT will offer such a facility later for the 
EOs interested in creating a system-to-system mechanism. 

According  to  PL,  the  national  system  has  already  been 
implemented.  PL  anticipates  the  need  for  an  update  once  the 
common  specifications  for  the  trans-European  aspects  are 
published but does not envisage any delay risks. 
PT  shared  that  there  will  be  no  Technical  Specifications  for 
external  communication.  Conformance  Testing  activities  will 
be conducted for national, external, and common domain tests, 
along with central systems and traders. A high level of risk is 
anticipated  due  to  the  implementation  of  a  completely  new 
national  GUM  system  and  the  integration  with  other  national 
and  EU  systems.  However,  PT  has  indicated  that  an  Agile 
the 
development  approach  will  be  used 
implementation timeframe. 

reduce 

to 

232 Information provided from a bilateral meeting between IE and DG TAXUD held on 17/05/2023. 
233 Information provided from a bilateral meeting between IT and DG TAXUD held on 07/11/2023. 
234 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
235 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 

117 

 
 
 
 
 
 
 
 
  
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

RO 

SE 

SI 

4 

1 

4 

Medium 

Low 

Low 

SK 

1 

Low 

RO reported that GUM already exists at the national level, but 
some updates are needed, and a tender procedure will start for 
those updates236. 
SE  indicated  that  GUM-C2  was  deployed  on  17/04/2021. 
Technical  Specifications  and  Conformance  Testing  are  not 
applicable for SE, since there will be no external domain for the 
EOs to access the system. Instead, a web service will be enabled 
for the EOs to check the reference amount of the guarantees.  
SI  has  already  implemented  a  national  system  to  manage 
guarantees. After the Deployment of GUM-C1, SI will update 
its  national  GMS  accordingly.  SI  further  indicated  that  the 
deadline  for  the  Technical  Specifications  of  GUM-C2  has 
shifted from 31/12/2022 to 31/12/2023. 
SK shared that the national CRS system needs to be adjusted to 
integrate it with the central GUM component. At the moment of 
writing,  an  impact  assessment  is  underway  for  the  national 
component and a contract will soon be established to make the 
necessary  adjustments  to  the  national  guarantee  system.  SK 
advised  that  any  delays  in  the  NIS  project  could  potentially 
affect  national  GUM  development  work  since  the  same 
contractor will be involved237. 

Figure 30 provides the percentage of Member States in each development phase. 

Table 34: Detailed responses from Member States – GUM-C2 

Figure 30: Summary of Survey Responses – GUM-C2 

236 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 
237 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

118 

 
 
 
 
 
 
4.1.2.  Overview of Project Progress 

Table 35 and Table 36 highlight any known divergences in the planning compared to the dates set in the 
UCC WP238.  

Table 35: Comparison of Planned and Actual Dates – GUM-C1 

As  GUM-C2  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.  

With regards to the implementation, FI and FR indicated a planned/actual Operations date that is later 
than  the  deadline  in  the  UCC  WP238.  BE,  DE,  DK,  GR  and  HR  did  not  provide  information  on  the 
Operations date. 

Table 36: Comparison of Planned and Actual Dates – GUM-C2 

238 In the 2023 UCC WP Revision, for GUM-C1, the deployment date is envisaged for 11/03/2024 and for GUM-C2, the start 
of the deployment window is to be defined by Member States, with the earliest possible deployment date being 11/03/2024. 

119 

Target date from WPActual/Planned End Date2023 % of CompletionActual/Planned End Date2023 % of Completion Target date from WP238Actual/Planned Date2023 % of Completion 30/09/202219/09/2022100%Not Provided0%02/06/202511/03/202480%Technical SpecificationsConformance TestingDeploymentTarget date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP238 2023 Planned/ Actual Date2023 % of Completion Target date from WP2023 Planned/ Actual DateATN/AN/A31/12/2024Not Provided01/03/2025Not Provided01/03/2025BEN/AN/AN/ANot ProvidedN/ANot ProvidedNot ProvidedBG04/08/2023100%16/10/2023100%23/10/2023100%23/10/2023CYN/A0%N/A0%02/06/20250%02/06/2025CZ01/01/2024Not Provided31/05/2025Not Provided01/06/2025Not Provided01/06/2025DENot Provided0%Not Provided0%15/11/20250%Not ProvidedDKNot Provided70%Not Provided0%Not Provided0%Not ProvidedEEN/A70%N/A0%02/05/20230%29/11/2023ES30/06/2016100%31/08/2016100%01/09/2016100%01/05/2019FIN/AN/ANot Provided0%30/06/202590%30/06/2025FRNot Provided50%Not provided0%30/06/20250%30/06/2025GRNot ProvidedNot Provided30/06/2025Not Provided31/03/2025Not ProvidedNot ProvidedHR31/12/20230%Not Provided0%Not Provided0%Not ProvidedHU30/11/202420%01/05/20250%01/06/20250%01/06/2025IE04/10/2019100%04/10/2021100%23/11/2020100%05/10/2021IT11/07/202390%30/09/202410%05/11/20240%05/11/2024LT01/11/2021100%31/08/2022100%16/11/2022100%20/03/2023LUNot ProvidedNot ProvidedNot ProvidedNot Provided01/06/2025Not Provided01/06/2025LVN/AN/AN/AN/A03/06/2018100%04/06/2018MTN/A0%N/A0%01/06/20250%01/06/2025NL30/09/2024Not ProvidedNot ProvidedNot Provided01/06/2025Not Provided01/06/2025PL31/12/2021100%02/06/2025100%01/01/2024100%02/06/2025PT31/12/2022100%Not Provided100%28/10/2024100%29/10/2024RONot Provided100%Not ProvidedNot Provided30/11/2023100%01/12/2023SEN/AN/AN/AN/A17/04/2021100%17/04/2021SI31/12/20230%20/05/20250%01/06/20250%01/06/2025SK01/09/2023100%01/05/20250%02/06/20250%02/06/2025To be defined by MSTo be defined by MS as part of the national plan02/06/2025RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
 
 
Regarding National GUM-C2, additional details on the specific percentage of completion per milestone 
can be seen in Figure 31.  

Figure 31: Percentage of Completion per Phase – GUM-C2 

120 

 
 
 
4.2. UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 3 

4.2.1.  Summary of Responses 

Summary from the Commission: 

The aim of the trans-European project on UCC ICS2-R3 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-R1 and ICS2-R2. 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).  ICS2-R3  will  also  include  further  extension  for  Safety  and  Security 
Analytics. 

The ICS2-R3 Common Technical System Specifications (CTSS) were delivered by February 2022 and 
updated in September 2022. The Conformance Testing activities for ICS2-R3 will be exclusively carried 
out by EOs. The connectivity Conformance Testing activities are in progress since 1 of July 2023 and 
the Conformance Testing itself is planned to start on 11 December 2023 for functional testing. For ICS2-
R3,  no  R3  Conformance  Testing  campaign  is  foreseen  for  the  National  Administrations.  National 
Administrations should have completed the implementation of all functionalities of ICS2-R2 and done 
the mandatory Conformance Testing. 

According to the revision of the UCC WP239, ICS2-R3 will be deployed in three steps: first maritime 
and inland waterways carriers will be phasing in (step 1), then the house level filers in the maritime and 
inland waterways traffic (step 2), and then the road and rail carriers (step 3). 

The development of the Common Repository and Shared Trader Interface central components started 
and is progressing as planned. However, any new business challenges affecting these components may 
impact the delivery planning. The ICS2-R3 functional scope will be delivered in two CR/Shared Trader 
Interface releases. 

The development of the ICS2-R3 Shared TP and Monitoring components also started and is ongoing 
according to the established plan. 

A training delivery aimed at preparing Customs Administrations started in Q2 2023 and is planned to 
be completed end of 2024. 

Summary from the Member States: 

Most Member States reported a medium/high level of complexity in the ICS2-R3 project due to various 
factors such as the interdependence between core and supporting systems, the need for a high percentage 
of availability of the systems, limitations in human resources, the impact of the Covid-19 pandemic, 
testing and development of additional functionalities and the workload created by ICS2-R2. Therefore, 
some Member States indicated that they adopted  Agile and Scrum methodologies to ensure efficient 
system development.  

Considering  the  ICS2  specifications,  the  Member  States  are  not  required  to  implement  new 
functionalities for ICS2-R3. Conformance Testing is, therefore, not mandatory for Member States and 
it will only apply to EOs. 

Additionally, some Member States indicated that additional work will be needed to be done to support 
the EOs in the project implementation and testing of applications interfacing with ICS2-R3.  

Most Member States indicated that the project is on target, except for DK, FR and IE. DK reported that 
the  project  is  being  delayed,  however,  it  is  still  expected  to  be  completed  within  the  Deployment 
deadline. FR, IE, and RO240 indicated that the project will be delayed beyond the foreseen Deployment 
deadline and a schedule for ICS2-R3. 

239 The revised UCC WP will be adopted in December 2023. 
240 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 

121 

 
 
 
 
Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

CY 

CZ 

5 

Low 

6 

1 

Low 

Low 

DE 

4 

Low 

DK 

5 

Medium 

EE 

ES 

4 

6 

Low 

Low 

BG indicated the status of the project as being on target and no 
delays  are  expected 241 .  BG  adopted  an  Agile  methodology 
consisting  of  BCA  applying  an  integrated  implementation  of 
ADM and RUP. 
CY assessed the project as being on target. Activities for this 
project are set to start at the end of May 2023 and it is expected 
to ‘go live’ on 01/03/2024242. The complexity of the project is 
due  to:  (1)  interdependencies  between  core  and  supporting 
systems, (2) the need for a high percentage of availability of the 
systems (3) limitations in human resources and (4) the impact 
of the Covid-19 pandemic. 
According  to  CZ,  the  Technical  Specifications  will  be 
completed by 01/12/2023, followed by Conformance Testing 
on 15/02/2024 and Operations on 01/03/2024. 
DE informed that ICS2-R3 will be implemented as part of the 
national  IT-System  ATLAS  Release  10.2,  for  which  the 
preparation activities started and are progressing as planned. DE 
indicated that it is using the Shared Trader Interface to facilitate 
the  exchange  of  messages  between  the  EOs  and  the  customs 
authority. The Shared Trader Interface has been implemented in 
requirements.  The 
the  Commission's 
compliance  with 
Conformance Testing phase is scheduled to occur in early 2024, 
with Deployment planned for 01/03/2024. 
DK assessed the status of the project as delayed because of the 
delay in ICS2-R2, however, it is still foreseen to be completed 
within the Deployment deadline. As a proactive measure, DK 
reported  to  have  either  completed  or  initiated  the  tendering 
process  for  all  systems  and  external  providers  as  a  means  of 
mitigating potential issues. Conformance Testing will be carried 
out at a national level. The project is ranked as highly complex 
due to the intricate nature of the releases, which involve both 
business and technology aspects. Moreover, the sheer quantity 
of  MASP-C  releases  in  and  of  itself  adds  to  the  overall 
complexity.  Moreover,  the  Danish  national  legacy  systems, 
which previously posed challenges, remain part of ICS2-R3. 
EE indicated the project is on target and the pre-analysis phase 
has started with the contractor243. An Agile methodology for the 
development of the system is being implemented. 
According to ES, the project is progressing as planned, and a 
Scrum  methodology  has  been  adopted.  The  Technical 
and 
completed 
Specifications  were 
Conformance Testing is not applicable for ICS2-R3. 

01/09/2022 

on 

241 Information provided from a bilateral meeting between BG and DG TAXUD held on 27/07/2023. 
242 Information provided from a bilateral meeting between CY and DG TAXUD held on 20/07/2023. 
243 Information provided from a bilateral meeting between EE and DG TAXUD held on 01/06/2023. 

122 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

FI indicated that ICS2 -R3 involves all other modes of transport 
except  for  air,  which  adds  complexity  to  the  system.  The 
Commission  will  provide  the  Technical  Specifications  to  the 
traders. Conformance Testing is not applicable. FI shared that 
the system is planned to be deployed in Q2 2024 and no risks 
are envisaged244. 
FR  assessed  the  project  as  delayed  beyond  the  originally 
planned Deployment deadline and indicated that a schedule for 
ICS2-R3 has not been defined yet. 
GR  indicated  that  the  project  is  currently  on  target,  although 
there  are  some  delays  in  the  call  for  tender  procedures.  The 
project  is  considered  of  high  complexity  due  to  the  need  for 
testing  support for  several EOs  and  the  large  Greek maritime 
sector245. 
HR  assessed  the  status  of  the  project  as  being  on  target. 
Technical Specifications were completed on 31/12/2022 and the 
Conformance Testing phase is currently ongoing and expected 
to end on 24/04/2023. HR informed that testing activities were 
carried  out  for  the  development  of  ICS2-R2,  but  no  specific 
testing  was  conducted  for  ICS2-R3.  The  project's  complexity 
stems  from  the  need  to  support  the  testing  of  several  EOs  in 
maritime and road transport. 
HU evaluated the project's status as on track and reported that 
the Technical Specifications are currently in progress. 
IE  reported  that  a  derogation  is  needed  for  ICS2-R3  due  to 
business  reasons.  A  significant  amount  of preparation  will be 
required for Conformance Testing given the high volume of the 
EOs and carriers which adds complexity to the project. There is 
a  significant  capacity  issue  on  the  trader’s  side  for  testing 
connectivity,  and  it  will  be  the  first  time  for  many  of  these 
traders  to  be  involved  in  this  type  of  testing  with  the  Shared 
Trader Interface. IE indicated the importance to learn from the 
ICS2-R2 testing process246. 
IT  indicated  the  project  as  being  on  target  and  Technical 
Specifications have already been analysed. 
LT  informed  that  the  project  is  on  target  and  an  Agile 
methodology was implemented. 
LU  assessed  the  project  as  being  on  target  and  plans  the 
software  delivery  by  the  end  of  2024.  LU  will  not  be 
significantly impacted as there is no land or sea border with non-
EU countries247. 

FI 

FR 

GR 

HR 

HU 

6 

4 

6 

4 

3 

High 

Medium 

Medium 

Low 

Low 

IE 

5 

Medium 

Medium 

Low 

IT 

LT 

LU 

LV 

MT 

NL 

5 

6 

6 

3 

Low 

Medium 

MT indicated the project as being on target. As of the time of 
writing, the Technical Specifications phase has not started yet. 
NL  assessed  the  status  of  the  project  as  being  on  target.  The 
majority  of  functionalities  required  for  ICS2-R3  are  already 
being  developed  as  part  of  ICS2-R2,  leaving  little  time  to 
for  R3.  NL 
develop  additional 

functionalities  needed 

244 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 
245 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
246 Information provided from a bilateral meeting between IE and DG TAXUD held on 17/05/2023. 
247 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 

123 

 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

PL 

PT 

RO 

4 

6 

5 

Low 

Low 

Low 

SE 

3 

Medium 

SI 

SK 

6 

3 

Low 

Low 

implemented an Agile approach to ensure that all functionalities 
are completed by the end of 2023 and that the project will be in 
Operations in Q1 2024. 
PL reported that the ICS2-R3 project is on target and Technical 
Specifications are in progress. 
PT  assessed  the  status  of  the  project  as  being  on  target.  The 
Technical  Specifications  are  currently  in  progress,  several 
modes  of  Conformance  Testing  will  be  implemented.  PT 
indicated  that  the  update  of  the  national  ICS2-R3  and  the 
connection  to  the  central  system  adds  complexity  to  R3.  An 
Agile approach has been adopted to reduce the implementation 
timeframe. 
RO shared that the development of the ICS2-R3 system is being 
delayed beyond the foreseen deployment deadline due to delays 
in tender procedures and requested a derogation248. 
SE  reported  that  the  project  is  on  target.  The  Shared  Trader 
Interface within the central ICS2 system will be used and, thus, 
there is no need to develop Technical Specifications related to 
the  external  domain.  SE  also  indicated  that  the  team  is  still 
analysing and planning the project and its phases, so it is not yet 
possible to predict all potential risks. To ensure efficient system 
development, SE plans to adopt an Agile approach. 
SI  informed  that  the  ICS2-R3  project  is  on  target.  Technical 
Specifications were completed on 01/08/2022 and the system's 
Deployment is underway. No further Conformance Testing is 
required for ICS2-R3. 
SK evaluated the project's status as on target and informed that 
no  national  Technical  Specifications  are  being  developed. 
Instead,  the  Technical  Specifications  provided  by  the  EC  are 
being used and updated. SK informed that a waterfall method 
has been adopted to ensure that the fully developed ICS2-R2 is 
considered ready for ICS2-R3. 

Table 37: Detailed responses from Member States – ICS2-R3 

248 Information provided from a bilateral meeting between RO and DG TAXUD held on 22/06/2023. 

124 

 
 
 
 
 
 
 
 
 
 
Figure  32  provides  the  percentage  of  respondents  (Member  States  plus  the  Commission)  in  each 
development phase249. 

Figure 32: Summary of Survey Responses – ICS2-R3   

249 The  figure  related  to  Conformance  Testing  includes  the  work  from  the  Commission  regarding  the  preparation  of  the 
Conformance Testing environment and coordination for Member States. 

125 

 
 
 
 
 
 
4.2.2.  Overview of Project Progress 

Table 38 indicate the percentage of completion as of the end of 2023 in comparison to the target dates 
set forth in the UCC WP.  

The  target  date  set  for  the  Technical  Specifications  is  in  reference  to  the  common  Technical 
Specifications.  Member  States  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 ICS2-R2 and ICS2-R3 as per the MASP-C.  

Regarding the implementation of  ICS2-R3, FI,  FR, HR, IE, MT, PT, and SK  have a planned/actual 
Deployment date that is later than the deadline in the UCC  WP250. AT, LU, and RO did not provide 
information on the Deployment date. 

Table 38: Comparison of Planned and Actual Dates – ICS2-R3 

250 In the 2023 UCC WP Revision, the deployment of the full ICS2-R3 by all Member States is envisaged for 03/06/2024. The 
rollout of the ICS2-R3 system is planned in three steps: Step 1 concerning maritime and inland waterways carriers (with a 
deployment window starting on 03/06/2024 and ending on 04/12/2024); Step 2 related to the house level filers in the maritime 
and  inland  waterways  traffic  (with  a  deployment  window  starting  on  04/12/2024  and  ending  on  01/04/2025);  and  Step  3 
regarding the road and rail carriers (with a deployment window starting on 01/04/2025 and ending on 01/09/2025). 

126 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP250 2023 Planned/ Actual Date2023 % of Completion European Commission30/03/2022100%N/AN/A01/03/2024100%ATNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedNot ProvidedBENot ProvidedNot ProvidedNot ProvidedNot Provided01/03/2024Not ProvidedBG28/03/2022100%15/12/2023N/A01/03/20240%CY15/09/2023100%28/02/202430%01/03/20240%CZ30/06/2023100%14/02/20240%01/03/20240%DENot ProvidedN/ANot Provided100%01/03/2024100%DK01/02/202225%N/AN/A01/03/20240%EE01/10/2023100%20/02/202420%01/03/202480%ES01/09/2022100%N/AN/A01/03/202480%FI31/03/2022N/AN/AN/A31/03/202495%FR31/03/202360%N/AN/A30/06/202450%GR30/04/2023100%31/03/202430%01/03/20240%HR31/12/2022100%24/04/2023100%30/06/2024100%HU25/11/2023100%10/02/20240%01/03/202490%IE28/01/2022100%28/02/202420%24/06/20240%IT01/03/2023100%14/02/20240%01/03/202440%LT30/07/2023100%15/12/2023100%01/03/202470%LU01/02/2024Not Provided28/02/2024Not ProvidedNot ProvidedNot ProvidedLV10/01/2022100%28/02/2025Not Provided01/03/2024Not ProvidedMTN/A0%N/A0%01/09/20250%NL01/09/2023100%01/03/202450%01/03/202490%PLNot Provided100%Not Provided100%01/03/20240%PT01/09/2023100%01/02/202450%02/06/20240%RONot ProvidedNot ProvidedNot Provided0%Not Provided30%SEN/AN/ANot ProvidedNot Provided01/03/20240%SI01/10/2023100%17/02/2024N/A01/03/202495%SK01/01/2023N/AN/AN/A30/06/2024100%30/06/201801/03/2024RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window) 
 
 
 
 
 
 
 
 
 
Regarding ICS2-R3, additional details on the specific percentage of completion per milestone can be 
seen in Figure 33251.  

Figure 33: Percentage of Completion per Phase – ICS2-R3 

251 The “Target deployment date from WP” refers to the deployment readiness for all Member States. The “Target operations 
date from WP” refers to the final end date of all traders migrated. 

127 

 
 
 
 
4.3. UCC PROOF OF UNION STATUS (POUS) 

The UCC 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 [CGM]) 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 of data and 
documents dealing with PoUS between the customs authorities across all the Member States. 

The project is divided into two phases: 

•  Implementing  the  electronic  T2L  (F)  document  with  all  the  necessary  functionalities 

(Deployment planned for 1 March 2024); 

•  Implementing  the  electronic  CGM,  including  the  information  exchange  with  the  European 

Maritime Single Window environment (EMSWe)252. 

4.3.1.  Summary of Responses 

PoUS – Phase 1 (PoUS-P1) 

Summary from the Commission: 

The Technical and System Specifications were completed in Q1 2022. Conformance Testing activities 
are expected to be completed by Q1 2024 and, according to the UCC WP, PoUS-P1 is scheduled to enter 
in Operations on 1 March 2024. 

The Commission assessed a low risk regarding the on-time delivery of the project. 

Currently,  all  Member  States,  except  for  ES  and  PL,  who  will  use  their  own  national  systems,  are 
engaging in testing the central PoUS system in collaboration with their EOs. Some of them are going to 
develop  connection  with  their  national  Risk  Analysis  (RA)  system 253 and/or  with  other  non-PoUS 
systems254. 

Summary from the Member States: 

As it was agreed during the design phase of the project, the Commission would develop a central system 
and allow the Member States who are having already a system available to connect theirs to the central 
system. 25 Member States will use the system developed by the Commission, while ES and PL will use 
a national system.  

Detailed Responses: 

Table 39 provides the individual Member States’ responses to the survey: 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

1 

Low 

BG  informed  that  actions  were  taken  on  the  assignment  and 
realisation  of  the  project  for  the  implementation  of  the 
connection between the PoUS central system and the national 
risk  analysis  component  with  a  deadline  for  execution  on 
01/12/2023. 

252 The deployment is planned for 15/08/2025. 
253 Member States that will develop connection with their RA system: AT, BE, BG, CY, CZ, DE, EE, FI, HR, HU, MT, and 
SI. 
254 Member States that will develop connection with other non-PoUS systems: BE, DE, FI, IT, and MT. 

128 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

CY 

6 

Low 

CZ 

DE 

3 

Low 

DK 

3 

Low 

EE 

2 

Low 

ES 

4 

Low 

FI 

3 

Low 

CY  assessed  the  project  as  being  on  target,  with  an 
implementation  date  set  for  2023.  CY  informed  of  the  high 
complexity of the project due to the following causes: (1) the 
interdependencies between core and supporting systems (2) the 
need for a high percentage of availability of the systems (3) the 
limitations  in  human  resources  and  (4)  the  impact  of  the 
COVID-19 pandemic. 
CZ indicated that the central system will be used and connected 
to the national risk analysis. CZ confirmed its readiness for the 
connection in March 2024255. 
DE informed that the central PoUS provided by the Commission 
will be used and, therefore, a national development with specific 
interfaces to the EO will not be needed. This project is linked to 
the PN project when the Proof is used at Presentation Customs 
Office.  For  that  purpose,  NES  will  be  updated  as  part  of  the 
national  IT-System  ATLAS.  Technical  Specifications  will  be 
defined, to the necessary extent, for integrating the central PoUS 
web services. 
DK  will  use  the  central  PoUS  system  provided  by  the 
Commission and assessed the status of the project as being on 
target. 
EE  plans  to  use  the  central  system  but  anticipates  delays  in 
connecting to the risk analysis. However, this is not expected to 
be a blocking issue. EE indicated that it intends to complete the 
connection  by  01/03/2024,  and  no  partial  Deployment  is 
envisaged.  EE  reported  that  the  following  preliminary  dates 
were  set:  development  starting  on  01/11/2022  and  ending  on 
30/09/2023  and  national  testing  starting  on  01/10/2023  and 
ending on 30/11/2023. 
ES indicated that the reasoning behind the choice of developing 
a national solution for PoUS, rather than using the central one, 
stands behind the need to integrate it with the suite of national 
applications that ES has. ES shared that it is easier to develop a 
solution  within  its  environment  than  to  integrate  an  external 
product, given that it already has a national PoUS system. 
ES’s PoUS system has a hybrid architecture that requires two 
different  Conformance  Testing  stages:  (1)  Conformance 
Testing of the national systems vs, the central system, planned 
for October 2023 and (2) Conformance Testing of the national 
system for the EOs, which has been open since April 2023. 
ES shared that the hybrid system is ready and the migration is 
expected between January and March 2024256. 
An Iterative approach is being used for the development of the 
system.  
FI  reported  that  the  central  PoUS  system  provided  by  the 
Commission  will  be  used  and  FI  implemented  an  Agile 
approach  to  start  the  project  before  Q3  2023.  FI  is  still 
considering the risk analysis aspect257. 

255 Information provided from a bilateral meeting between CZ and DG TAXUD held on 29/08/2023. 
256 Information provided from a bilateral meeting between ES and DG TAXUD held on 23/11/2023. 
257 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 

129 

 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

FR 

2 

Medium 

GR 
HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

2 

3 

4 

3 

3 

2 

Low 

Low 

Low 

Low 

Low 

Low 

PL 

3 

Medium 

FR  will  use  the  central  PoUS  system  provided  by  the 
Commission.  It  assessed  the  project  as  delayed,  but  overall 
delivery is still foreseen within the Deployment deadline. The 
main  risks  for  the  delay  relate  to  Conformance  Testing  and 
Deployment activities, as FR has prioritised the development of 
the import and export systems. FR informed that it still needs to 
adapt  its  risk  analysis  application,  to  perform  an  analysis  of 
messages coming from the CNN2. 
GR indicated that the central system will be used258. 

HU  reported  that  the  central  PoUS  system  provided  by  the 
Commission  will  be  used.  HU  informed  that  the  target  dates 
concerning  the  development  and  Conformance  Testing  were 
revised, due to the prioritisation of other development tasks and 
the lack of human resources at a national level. 
IE  shared  that  the  central  PoUS  system  provided  by  the 
Commission will be used. 
The central PoUS system provided by the Commission will be 
used and, due to anti-fraud concerns, IT will opt for manual risk 
analysis259. IT plans to end the analysis and the implementation 
phase  and  start  the  Conformance  Testing  activities  with  the 
central system by 29/02/2024. 
LT  informed  that  the  central  PoUS  system  provided  by  the 
Commission and assessed the implementation of the project as 
being on target. 
LU reported that it will use the central PoUS system provided 
by  the  Commission.  Since  LU  issues  a  very  low  number  of 
documents, the PoUS system will not be connected to the risk 
analysis system and manual processing will be used instead260. 
LV  shared  that the  central  PoUS  system  will  be  used.  At  the 
moment of writing, no automated connection to risk analysis is 
planned  as  no  business  case  exists.  LV  indicated  that  small 
number of cases will be handled manually261. 
MT  indicated  that  the  central  PoUS  system  provided  by  the 
Commission will be used and the implementation project is on 
target. Integration with the national risk system and PN will be 
required. 
NL reported that it will use the central PoUS system provided 
by the Commission and the implementation project is reported 
as being on target. 
PL  informed  that  a  national  system  connected  to  the  AES 
system  will  be  developed.  The  status  of  the  project  is  being 
delayed  for  2  quarters  at  most 262 ,  due  to  (1)  delays  in  the 
tendering process (2) staff problems related to COVID-19, and 
(3)  additional  changes  in  the  development  process.  However, 
the status of the project is still foreseen within the Deployment 
deadline. Initially planned dates were updated according to the 

258 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
259 Information provided from a bilateral meeting between IT and DG TAXUD held on 07/11/2023. 
260 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
261 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
262 Information provided from a bilateral meeting between PL and DG TAXUD held on 03/10/2023. 

130 

 
 
 
 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

PT 

RO 

SE 

SI 

SK 

6 

2 

2 

5 

3 

following schedule: Technical Specifications to be finalised by 
05/06/2023,  Conformance  Testing  by  29/12/2023  and 
Deployment by 01/03/2024.  
PT  reported  that  the  central  PoUS  system  provided  by  the 
Commission will be used. 
RO  will  use  the  central  PoUS  system  provided  by  the 
Commission,  as it  has  a  low  number  of  T2L  documents.  The 
project is assessed as being on target and activities related to the 
project application are ongoing. 
SE  indicated  that  the  central  PoUS  system  provided  by  the 
Commission will be used and informed that there is no need to 
develop  any  Technical  Specifications  concerning  the  external 
domain.  SE  will  connect  the  system  with  its  national  risk 
analysis system263. 
SI  shared  that  the  central  PoUS  system  provided  by  the 
Commission  will  be  used  and  has  adopted  an  Agile 
methodology.  SI  informed  that  is  developing  interface  with 
national  risk  analysis  system  and  preparing  for  Conformance 
Testing264. 
SK reported that it will use the central PoUS system provided 
by the Commission and it has adopted a waterfall development 
process. The system will not be connected to the national risk 
analysis and the work will be executed manually265. 

Low 

Low 

Low 

Low 

Low 

Table 39: Detailed responses from Member States – PoUS-P1 

263 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
264 Information provided from a bilateral meeting between SI and DG TAXUD held on 13/06/2023. 
265 Information provided from a bilateral meeting between SK and DG TAXUD held on 20/10/2023. 

131 

 
 
 
PoUS – Phase 2 (PoUS-P2) 

Summary from the Commission: 

The  TSS  were  completed  by  Q2  2023.  The  Conformance  Testing  activities  are  anticipated  to  be 
concluded by Q3 2025. Considering that the PoUS is intended to handle a significant volume of CGM 
through EMSW, it was acknowledged that the time gap between the dates could impose unnecessary 
burdens on Trade. As a result, discussions were held to align the Deployment dates in the UCC WP and 
MASP-C for PoUS-P2 CGM with the EMSWe, leading to a rescheduling of the entry into Operations 
date to 15 August 2025. 

The Commission assessed a medium risk regarding the on-time delivery of the project.  

Summary from the Member States: 

Please see the summary from PoUS-P1. 

Detailed Responses: 

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

Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 
BG 

According  to  CY,  no  additional  activities  for  PoUS-P2  were 
planned  during  2022.  The  public  procurement  process  was 
concluded and the contract was signed with the contractor. The 
project initiation document was agreed and the relevant project 
plans and timelines for all the UCC systems were updated and 
agreed  upon.    No  changes  were  made  to  the  2022  National 
Planning for PoUS-P2. The status of the project is reported as 
being on target. CY indicated that the high complexity of PoUS-
P2  is  due  to  the  following  causes:  (1)  the  interdependencies 
between  core  and  supporting  systems  (2)  the  need  for  a  high 
percentage of availability of the systems (3) the limitations in 
human resources and (4) the impact of COVID-19. 

PoUS-P2  is  linked  to  the  implementation  of  the  CGM  of  the 
EMSW  initiative  for  which  the  business  scope  and  the  IT 
architecture  still  need  to  be  elaborated.  DE  informed  that 
planning details will be provided when the Business Case and 
the VIS are available. Considering that the PoUS-P1 activities 
are  ongoing  and  that  the  expected  date  of  Deployment  for 
PoUS-P2 is August 2025, project activities have not yet started. 
DK indicated the status of the project as being on target. 
EE reported the status of the project as being on target. The end 
date for Deployment shifted from 02/06/2025 to 15/08/2025. 
ES  reported  PoUS-P2  is  currently  under  preparation  and  on 
target266. ES shared that an Agile approach is being used for the 
development of the system. 
FI  shared  that  it  will  use  the  Central  PoUS  provided  by  the 
Commission.  PoUS-P2  has  not  started  yet  but  it  will  be 
integrated with EMSW267. 

CY 

6 

Low  

CZ 

DE 

DK 

EE 

ES 

FI 

4 

3 

3 

4 

4 

Low 

Low 

Low 

Low 

Low 

266 Information provided from a bilateral meeting between ES and DG TAXUD held on 23/11/2023. 
267 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 

132 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MS 

FR 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Complexity 
Rating 

Risk 
Level 

3 

Low 

Additional Comments 

FR  indicated  that  the  central  PoUS  system  provided  by  the 
Commission will be used and that PoUS-P2 has not started yet. 
GR shared that for PoUS-P2 it will coordinate with the upgrade 
of TS since they are interconnected268. 

HU noted that it will use the central PoUS system provided by 
the Commission. It informed that PoUS-P2 has not started yet. 
IE  reported  that  the  central  PoUS  system  provided  by  the 
Commission  will  be  used  and  IE  will  assist  with  testing. 
However, the developments for PoUS-P2 have not started yet. 
IT  indicated  that  the  central  PoUS  system  provided  by  the 
Commission will be used and PoUS-P2 has not started yet. The 
date of Deployment shifted from 02/06/2025 to 15/08/2025 due 
to changes in the UCC WP. 
LT  reported that  it  plans to  use  the  central  PoUS  system  and 
noted that PoUS-P2 has yet to begin. 

LV shared that another authority will develop the MSW but it 
will have some impact on customs269. 
MT  indicated  that  the  central  PoUS  system  provided  by  the 
Commission will be used. However, as of now, the development 
of PoUS-P2 has not begun and MT informed that the planning 
for it will start only after the Deployment of PoUS-P1. 
NL has indicated that as of now it is unclear how PoUS-P2 will 
work out. 
PL reported that it will use a national system that is connected 
to  the  AES  system.  However,  the  planned  end  dates  for 
Technical  Specifications,  Conformance  Testing, 
and 
Deployment had to be changed initially due to incomplete P2 
documentation from the Commission. 
PT  will  use  the  central  PoUS  system  provided  by  the 
Commission and PoUS-P2 developments have not started yet. 

Low 

Low 

Low 

Low 

Low 

Low 

Low 

Low 

Medium 

Low 

Low 

SE shared that it will use the central PoUS system provided by 
the Commission. PoUS-P2 will be linked with the EMSWe, for 
which some development will be needed270. 
SI adopted an Agile methodology and plans to use the central 
PoUS  system  provided  by  the  Commission.  SI  will  start 
working on this project once PoUS-P1 is completed.  
SK indicated that it will use the central PoUS system provided 
by  the  Commission  and  it  is  currently  dealing  with  a  lack  of 
human resources and time constraints. A waterfall development 
process has been adopted271. 

Table 40: Detailed responses from Member States – PoUS-P2 

2 

3 

3 

3 

4 

1 

1 

6 

4 

4 

3 

268 Information provided from a bilateral meeting between GR and DG TAXUD held on 04/10/2023. 
269 Information provided from a bilateral meeting between LV and DG TAXUD held on 15/06/2023. 
270 Information provided from a bilateral meeting between SE and DG TAXUD held on 12/09/2023. 
271 Information provided from a bilateral meeting between SI and DG TAXUD held on 13/06/2023. 

133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.3.2.  Overview of Project Progress 

Table 41 and Table 42 highlight any known divergences in the planning compared to the dates set in the 
UCC WP.  

Regarding PoUS-P1, all Member States except ES and PL will use the central PoUS system. ES and PL 
indicated that they are on target to meet the Deployment date set in the UCC WP of 1 March 2024. The 
specific dates for the central system can be found in Table 41 below. 

Table 41: Comparison of Planned and Actual Dates – PoUS-P1 

Regarding  PoUS-P2,  the  Commission  and  all  the  Member  States  (except  ES)  have  a  planned 
Deployment date that is later than the deadline in the UCC WP272. The specific dates for the central 
system can be found in Table 42 below. 

Table 42: Comparison of Planned and Actual Dates – PoUS-P2 

272 In the 2023 UCC WP Revision, the deployment of PoUS-P2 is envisaged for 15/08/2025. 

134 

Target date from WPActual/Planned End Date2023 % of CompletionActual/Planned End Date2023 % of Completion Target date from WPActual/Planned Date2023 % of Completion 31/03/202231/03/2022100%01/03/202470%01/03/202401/03/20240%Technical SpecificationsConformance TestingDeploymentTarget date from WPActual/Planned End Date2023 % of CompletionActual/Planned End Date2023 % of Completion Target date from WP272Actual/Planned Date2023 % of Completion 31/03/202230/06/2023100%15/08/20250%02/06/202515/08/20250%Technical SpecificationsConformance TestingDeployment 
 
 
 
 
 
Regarding PoUS-P1, additional details on the specific percentage of completion per milestone can be 
seen in Figure 34. 

Figure 34: Percentage of Completion per Phase – PoUS-P1 

135 

 
 
 
 
Regarding PoUS-P2, additional details on the specific percentage of completion per milestone can be 
seen in Figure 35. 

Figure 35: Percentage of Completion per Phase – PoUS-P2 

136 

 
 
 
 
4.4. UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) – PHASE 2 

4.4.1.  Summary of Responses 

Summary from the Commission: 

Please see also the summary from CCI-P1. 

CCI-P2 broadens the scope of the complex matters tackled in CCI-P1, leading to a heightened intricacy 
across multiple project areas. Currently, the project is on track, with the completion of the Technical 
Specifications on 17 June 2022, while Conformance Testing and Deployment activities have not started 
yet.  

Member States have the flexibility to develop, implement, and deploy CCI-P2 functionalities in multiple 
iterations within the designated deployment window. 

Summary from the Member States: 

Many  Member  States  indicated  that  the  planning  is  tight  in  the  context  of  import  systems.  The 
interdependencies of CCI-P2 with other projects that are part of the NIS system require that the Member 
States prepare the functional and Technical Specifications  according to those of the broader system. 
This adds complexity to the overall development of CCI-P2, which results in potential delays by the 
Member States. 

DG TAXUD carries out a close monitoring on the Member States’ CCI (P1 and P2) national project 
planning, organisational, development, connectivity set-up, the conformance testing, deployment, and 
entry in operation of CCI-P2. Monitoring of Member States CCI activities, including integration with 
NIS  and  other  national  systems  takes  place,  while  assistance  is  provided  where  needed.  Regular 
meetings for the synchronisation of the planned CCI-related activities, weekly and bi-weekly technical 
meetings for the status progress, feedback sessions for the execution of the conformance testing are held. 
DG TAXUD will continue their close technical support to the Member  States, while monitoring the 
progress  according  to  the  deployment  plan  for  CCI.  In  this  context  DG  TAXUD  initiates  issuing  a 
quarterly report for monitoring of the UCC CCI system deployment, starting with Q1 2024. 

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

Aside  from  the  interdependencies  between  the  core  and  supporting  systems,  the  complexity  of  the 
development of the system is incremented by the human and financial resource constraints, the need for 
a  high  percentage  of  availability  of  the  systems  and  the  difficulties  added  by  the  supplementary 
recapitulative declaration and the extension for excise goods that are part of the system. Other aspects 
adding complexity to the project are the effects derived from the COVID-19 pandemic, Brexit and the 
current situation of the e-commerce market. 

To lessen the impact of the delays some of the measures cited by the Member States are the creation of 
a new national PG for CCI with the necessary resources and the adoption of Agile methodologies and 
iterative approaches. 

In  terms  of  assessing  the  level  of  completeness  of  the  system,  over  85%  of  the  Member  States  that 
responded  to  the  survey  reported  that  the  system  is  on  target.  No  Member  State  has  achieved  full 
completion of the system development. Some Member States indicated that the current progress  has 
fallen behind the scheduled Deployment deadline: DE, MT273, NL, and SE. 

Most Member States communicated Technical Specifications activities had not been initiated yet, except 
for DE, DK, IE, LT, and RO, in progress, and BG, which has already completed this phase. 

Detailed Responses: 

Table 43 provides the individual Member States’ responses to the survey: 

273 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 

137 

 
 
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

AT 
BE 

BG 

5 

Low 

CY 

6 

Low  

CZ 

1 

Low 

DE 

5 

High 

DK 

EE 

ES 

FI 

4 

5 

3 

6 

Low 

Medium 

Low 

High 

BG informed that the overall status of the project is on target, 
with  a  medium  level  of  risk  on  the  on-time  delivery  of  the 
project.  These  risks  could  have  an  imminent  impact  on  the 
Technical  Specifications  and 
the  Conformance  Testing 
activities. 
BG will implement an iterative approach using TOGAF/ADM 
and RUP methodologies. 
CY indicated the overall status of the project as on target, citing 
the interdependencies between the core and supportive systems, 
the need for a high percentage of availability of the systems, the 
limitation of human resources and the effects of the COVID-19 
pandemic as some of the reasons for the increase in complexity 
of  the  project.  No  further  CCI-P2  activities  are  planned  until 
2024. 
CZ  reported  that  the  project  status  is  on  target  and  its 
development  and  Deployment  were  planned  in  parallel  with 
CCI-P1 activities. The system is being developed under NIS and 
the development is under analysis from the IT contractor. 
DE informed that the implementation of the CCI-P2 project has 
been delayed because it will be integrated into the major release 
of the national IT system ATLAS (Release 10.2) as a new trans-
European system. CCI-P1 and CCI-P2 will be included in one 
development  and  DE  will  develop  one  message  for  the 
declaration  which  will  be  adapted  depending  on  normal  or 
simplified procedure in use. Once the new import system is in 
place, traders will be migrated gradually to the new system274. 
However,  DE  clarified  that  the  national  project  has  already 
started  with  Technical  Specifications  currently  under 
development and Operations scheduled to begin in Q4 2024. 
To address the delays, DE indicated that a new national PG for 
CCI  will  be  created  with  the  necessary  resources  and  Agile 
methodologies will be employed. 
DK indicated that the project is currently on target and no major 
potential  delays  were  identified.  The  Conformance  Testing 
scope is currently undergoing further analysis. 
EE assessed the overall project status as on track and the first 
milestone, related to the completion of Technical Specifications 
is planned  for  31/03/2024  according to its  National  Planning. 
EE  noted  that  a  lack  of  human  resources  could  impact  the 
outcome of the system. 
ES  reported  that the  overall  status  of  the  project  is  on  target. 
Technical Specifications are currently in progress with the date 
for publication set for 02/06/2024. The  National Planning has 
been  updated  according  to  the  CCI-P1  and  P2  specification 
strategy.  ES  is  using  iterative  methodologies  to  develop  the 
project. 
According to FI, the associated risk level for CCI-P2 relates to 
the fact that the import system is set to be built from scratch. 

274 Information provided from a bilateral meeting between DE and DG TAXUD held on 14/06/2023. 

138 

 
 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

While there are some doubts about all CCI-P2 functions being 
ready by the planned date275, the status of the project is on target 
and  an  iterative  approach  is  being  considered  for  the  system 
development.  
FR  indicated  that  the  strong  interdependencies  of  the  various 
national systems increased complexity and caused delays in the 
development  of  NIS  as  a  whole.  In  this  regard,  additional 
resources  on  the  business  and  IT  sides  were  mobilised  as  a 
mitigation measure. Brexit and e-commerce have had a strong 
impact on human and financial resources, causing delays in the 
involvement of the technical teams. The COVID-19 pandemic 
has  equally  had  an  impact  on  these  areas.  As  a  mitigating 
measure, FR outsourced some activities to a contractor and, in 
parallel, secured the import system to have a better base for CCI. 
At the same time, AES developments have to be ensured, given 
FR’s position as an exit Member State for other Member States. 
Therefore,  many  choices  requiring  an  increased  level  of 
resources  are  to  be  made  for  several  projects  that  have  to  be 
carried out simultaneously. In this light, FR chose to prioritise 
AES  (core  functions)  over  CCI,  given  the  importance  of  the 
export volumes. The deadlines for this project shifted to secure 
other  projects.  CCI-P2  will  deliver  functionalities  through 
iterations, with an envisaged Deployment date set for Q2 2025. 
GR indicated that the risk level affects all milestones. However, 
the overall status of the project has been determined as on target. 
GR shared that there is a delay in the tender procedure. 
HR assessed the CCI-P2 project as having a high risk due to the 
supplementary recapitulative declaration and the extension for 
excise goods that are included in the system. Additionally, the 
interconnectivity between the systems from different Member 
States adds complexity and increases the risk. Nevertheless, the 
status of the project is currently on track, with the completion 
date  for  the  Technical  Specifications  phase  planned  for 
30/09/2024. 
HU shared that the planning for CCI-P2 is on track, but there 
are  potential  risks  that  could  affect  the  deployment  of  the 
system.  To  mitigate  these  risks,  HU  will  be  implementing 
iterative methodologies throughout the project development. 
IE  identified  that  communicating  with  other  Member  States' 
systems is the main factor contributing to the complexity of the 
project.  Furthermore,  other  UCC  systems  with  earlier 
deployment  deadlines  were  prioritised  over  CCI-P2,  which 
poses a risk. Despite this, the overall status of the project is on 
track. IE implemented processes to ensure business continuity 
during the development of CCI-P2. 
IT reported the project as being on target. The development and 
Deployment were planned in parallel with CCI-P1 activities. 
LT informed that the overall status of the project is on target and 
plans the use of an Agile approach for developing the system. 

FR 

GR 

6 

Medium 

HR 

6 

Medium 

HU 

5 

Medium 

IE 

5 

Medium 

IT 

LT 

6 

Low 

275 Information provided from a bilateral meeting between FI and DG TAXUD held on 27/09/2023. 

139 

 
 
 
 
 
 
 
Complexity 
Rating 

Risk 
Level 

Additional Comments 

MS 

LU 
LV 
MT 

NL 

5 

5 

Low 

High 

LU shared that envisages deployment by early June 2025276. 

Same response as for CCI-P1277. 
NL  identified  a  high  level  of  risk  associated  with  the  timely 
delivery of the project, with all milestones being affected by the 
implementation  of  new  processes  and  software.  The  Brexit, 
eCommerce, tight labour markets, the COVID-19 pandemic and 
the prioritisation of other parallel projects negatively impacted 
the development of the CCI-P2 system. To mitigate these risks, 
reduction  of  the  scope  and  the  use  of  Agile  approaches  were 
identified as potential measures. NL plans to be ready to Deploy 
the system in Q4 2025278. 
PL reported a medium level of risk affecting all milestones and 
assessed the overall status of the project as being on target. 
PL will pursue an iterative approach to develop and implement 
CCI-P2 within the NIS system. 
PT informed that the Conformance Testing’s purpose is for the 
EOs to realise if their systems comply with the specifications 
and  for  PT  to  assess  if  the  external  domain  was  correctly 
developed. Conformance Testing with the Member States will 
be  completed  to  evaluate  if  all  the  necessary  connections/ 
validations are correctly performed. 
CCI-P2 is intended to treat all the matters which were omitted 
in P1 due to their complexity. The project will be developed and 
implemented  as  part  of  the  NIS  system,  which  explains  the 
complexity  of  CCI-P2.  To  this  adds  the  fact  that  the 
development of this system is related to the development of all 
national,  central  and  other  Member  States’  systems/modules, 
national  and  UE  entities’  connections,  which  ultimately 
increases  the  interdependencies  and  the  complexity  of  the 
‘global  system’.  PT  indicated  that  an  Agile  development 
approach will be used to reduce the implementation timeframe. 
RO  noted  that  the  interdependencies  among  the  NIS  systems 
create a risk that might impact all milestones. The project is on 
target  with  the  Technical  Specifications  phase  currently  in 
progress. 
SE identified delays in the development of the CCI-P2 project 
since  other  systems  are  also  being  developed  simultaneously. 
Moreover,  SE  is  in  the  process  of  changing  its  IT  platform, 
which can affect implementation. Complexity is affected by the 
need  for  the  development  of  the  goods  shipment  level  in  the 
context  of  the  recapitulative  supplementary  declaration.  An 
analysis is taking place to find solutions to prevent delays. 
SI noted the high complexity of the CCI-P2 system, caused by 
the  high  amount  of  new  electronic  messages  and  BPMs,  the 
exchanges  of  electronic  messages  between  the  Supervising 
Customs Office  for CCI and the Presentation Customs Office 
for CCI, the specific Rules and Conditions for CCI, the specific 
code  lists  for  CCI,  demanding  Conformance  Testing  and  the 

PL 

5 

Medium 

PT 

6 

Medium 

RO 

6 

Medium 

SE 

4 

Medium 

SI 

6 

Medium 

276 Information provided from a bilateral meeting between LU and DG TAXUD held on 24/10/2023. 
277 Information provided from a bilateral meeting between MT and DG TAXUD held on 30/08/2023. 
278 Information provided from a bilateral meeting between NL and DG TAXUD held on 28/09/2023. 

140 

 
 
 
 
 
 
 
 
MS 

Complexity 
Rating 

Risk 
Level 

Additional Comments 

complex  DDNCA  documentations,  among  others.  Moreover, 
SI’s  existing  import  declaration  system  is  harmonised  with 
EUCDM3.2. This creates a risk since SI previously completed 
the national import declaration system per the new Annex B of 
the Commission Delegated Regulation (EU) 2021/234 and CCI-
P1. 
Despite the high complexity and the potential risks, the project 
is on target to be Deployed on 01/06/2025279. 
SK  categorised  CCI-P2  as  on  target  with  no  major  risks 
identified. 

SK 

1 

Low 

Table 43: Detailed responses from Member States – CCI-P2 

Figure  36  provides  the  percentage  of  respondents  (Member  States  plus  the  Commission)  in  each 
development phase. 

Figure 36: Summary of Survey Responses – CCI-P2 

279 Information provided from a bilateral meeting between SI and DG TAXUD held on 13/06/2023. 

141 

 
 
 
 
4.4.2.  Overview of Project Progress 

Table 44 highlights any known divergences in the planning compared to the dates set in the UCC WP. 
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.  

For the implementation of CCI-P2, the following Member States have a planned/actual Operations date 
that is later than the deadline in the UCC WP: BE, DE, EE, ES, FI, GR, and NL. AT, FR, and RO did 
not provide data regarding the Operations date, while SE indicated the Operations as not applicable. 

Table 44: Comparison of Planned and Actual Dates – CCI-P2 

142 

Target date from WP 2023 Planned/ Actual End Date2023 % of Completion2023 Planned/ Actual End Date2023 % of Completion Target date from WP 2023 Planned/ Actual Date2023 % of Completion Target date from WP2023 Planned/ Actual DateEuropean Commission17/06/2022100%Not Provided0%Not Provided0%Not ProvidedATNot ProvidedNot provided17/10/2025Not Provided01/11/2025Not ProvidedNot ProvidedBEN/ANot providedN/ANot Provided02/06/2025Not Provided30/06/2025BG04/11/2024100%28/03/20250%31/03/20250%31/03/2025CY30/11/20240%19/05/20250%02/06/20250%02/06/2025CZ01/04/20240%30/11/20240%01/12/20240%01/12/2024DE31/06/202430%30/10/20250%15/11/20250%15/11/2025DK05/08/2023Not providedNot Provided0%31/12/20240%31/12/2024EE31/03/20240%31/12/20240%30/06/20250%30/06/2025ES02/06/202450%30/06/20250%30/06/20250%30/06/2025FI31/12/20240%30/06/20250%30/06/20250%30/06/2025FR31/03/20240%30/09/20240%31/12/20250%Not ProvidedGR31/12/2023100%30/06/20250%30/06/20250%30/06/2025HR30/09/202450%30/05/20250%02/06/20250%02/06/2025HU15/10/202475%01/05/20250%02/06/202560%02/06/2025IE23/06/2023100%23/06/202425%24/06/20240%24/06/2024ITNot Provided100%Not Provided0%02/06/20250%02/06/2025LT01/06/2024Not Provided01/12/2024Not Provided02/06/2025Not Provided02/06/2025LU01/04/2024Not Provided01/05/2025Not Provided01/06/2025Not Provided01/06/2025LV24/03/20240%24/03/20250%25/03/20250%25/03/2025MTN/A0%N/A0%02/06/20250%02/06/2025NLNot Provided50%Not Provided0%Not Provided0%01/11/2025PL30/05/20240%01/05/20250%01/06/20250%01/06/2025PT01/06/20240%15/04/20250%31/05/20250%02/06/2025RO30/05/2023100%N/AN/A01/12/2023100%Not ProvidedSENot Provided0%Not Provided0%02/06/20250%N/ASI01/10/20230%20/05/20250%01/06/20250%01/06/2025SK01/06/20240%31/05/20250%02/06/20250%02/06/202530/06/202202/10/202302/06/2025RespondeeTechnical SpecificationsConformance TestingDeployment(Start of the deployment window)Operations(End of the deployment window) 
 
 
 
 
Regarding CCI-P2, additional details on the specific percentage of completion per milestone can be 
seen in Figure 37. 

Figure 37: Percentage of Completion per Phase – CCI-P2 

143 

 
 
 
4.5. UCC  NEW  COMPUTERISED  TRANSIT  SYSTEM  (NCTS)  UPGRADE  – 

COMPONENT 2 

Component 2, NCTS – Phase 6 (NCTS-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 Member States 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 can serve both the 
transit procedure and the Safety and Security formalities simultaneously with a single process for the 
benefit of all. The timeline of NCTS-P6 is synchronised with that of the ICS2-R3, having a transition 
window from 3 February 2025 until 1 September 2025 for the National Administrations to migrate from 
NCTS-P5 to NCTS-P6.  

According to the  revision of  the  UCC WP280,  NCTS-P6  will  be  deployed in line with the  following 
calendar: 

Summary from the Commission: 

Figure 38: NCTS-P6 timeline 

The aim of NCTS-P6 is to complete the alignment of NCTS to the Safety and Security data specified in 
the  latest  releases  of  the  UCC  DA  and  UCC  IA  Annex  B.  NCTS-P6  will  also  implement  specific 
requirements in transit customs declarations of goods brought into the customs territory of the Union. 
The primary goals are to ensure continuity of the long-established combined declaration practice and 
achieve fully integrated management of the Safety and Security provisions of the UCC in NCTS. This 
integration  aims  to  avoid  duplication  of  the  processes  and  systems  for  the  trade  and  the  National 
Administrations.  NCTS-P6  will  interface  with  the  ICS2  system,  to  minimise  the  IT  burden  on  the 
National  Administrations  and  trade.  Another  significative  advancement  is  the  harmonisation  of  the 
presentation process across all the Customs Offices of the National Administrations, which will serve 
as  a  steppingstone  for  future  Smart  Border  initiatives  between  National  Administrations  and  other 
neighbouring countries. 

The  integration  of  the  system  with  ICS2-R3  requires  the  synchronisation  of  two  significant  and 
autonomous  Trans-European  Systems  in  terms  of  their  process  flow  and  information  exchange.  To 
achieve this synchronisation, a dedicated  message  converter will be deployed  by the Commission to 
facilitate  seamless  communication  and  data  transfer  between  the  systems.  Therefore,  the  level  of 
complexity associated with the development of NCTS-P6 is significant. 

In April 2020, an initiative was launched to conduct a feasibility study on the interconnection between 
ICS2  and  NCTS,  including  an  analysis  of  Safety  and  Security  requirements  and  the  possible 

280 The revised UCC WP will be adopted in December 2023. 

144 

 
 
 
 
implementation options. The outcome confirmed the feasibility of communication between ICS2 and 
NCTS-P6. By mid-2021, the feasibility study was translated into a Business Case. 

At the request of the National Administrations, the Business Case was temporarily suspended, awaiting 
analysis of the technical implications of the proposed measures. National Administrations sought more 
clarity regarding the combined declaration facility option they could offer or not offer to their trade as 
well as the interface between NCTS and ICS2-R3. 

In  the  second  half  of  2021,  a  Technical  Study  was  conducted  with  the  National  Administrations  to 
provide the expected clarifications and details. Based on this Technical Study, the VIS was produced by 
the end of 2021. 

In  December  2021, the  Business  Case  and  VIS  were approved.  The  VIS  for  NCTS-P6  establishes a 
Transition Period from June 2024 to February 2025, aligning with the transition window of ICS2-R3. 
This  assumes  that  NCTS-P5  will  be  completed  on  time,  ensuring  business  continuity  of  the  transit 
combined declaration as a trade facilitation instrument. 

During 2022, the Functional and TSS for NCTS-P6 were elaborated in collaboration with the National 
Administrations and subsequently accepted by the ECCG in December 2022. 

A  significant  risk  of  overlap  has  been  identified  between  the  delays  of  the  ‘running-over’  National 
Administrations that will join the NCTS-P5 Operation in 2024 and the Transitional Period of NCTS-P6. 
The new proposal for the revision of the UCC WP is addressing this risk by establishing a clear cut-off 
for the transition to NCTS-P5 as well as by postponing the start and end dates of the deployment window 
for NCTS-P6. The proposal aims to ensure business continuity. 

145 

 
 
 
 
4.5.1.  Overview of Project Progress 

Table 45: Comparison of Planned and Actual Dates – NCTS-P highlights any known divergences in the 
planning  compared  to  the  dates  set  in  the  UCC  WP.  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 NCTS-P6, the following Member States have a planned/actual Operations date that is later 
than the deadline in the UCC WP281: FI, NL, PL, PT, SE, and SK. AT, BE, DE, DK, FR, and LU did not 
provide data regarding the Operations date. 

Table 45: Comparison of Planned and Actual Dates – NCTS-P6 

281 In  the  2023  UCC  WP  Revision,  the  start  of  the  deployment  window  is  envisaged  for  03/03/2025  and  the  end  of  the 
deployment window for 01/09/2025. 

146 

Conformance TestingTarget date from WP 2023 Planned/ Actual End Date2023 Planned/ Actual DateTarget date from WP281 2023 Planned/ Actual DateTarget date from WP2812023 Planned/ Actual DateEuropean Commission31/12/202231/03/202503/03/202501/09/2025ATNot ProvidedNot ProvidedNot ProvidedNot ProvidedBEN/AN/AN/ANot ProvidedBG03/06/202429/11/202416/12/202416/12/2024CY30/11/202323/05/202403/06/202403/06/2024CZ01/01/202430/09/202401/10/202401/10/2024DENot ProvidedNot ProvidedNot ProvidedNot ProvidedDKNot ProvidedNot ProvidedNot ProvidedNot ProvidedEE30/06/202331/12/202431/12/202431/03/2025ES30/06/202211/03/202413/02/202312/03/2024FI31/12/202431/12/202531/12/202531/12/2025FR01/11/2023Not Provided01/09/2025Not ProvidedGR30/06/202431/03/202531/03/202431/03/2025HR30/06/202428/02/202501/03/202501/03/2025HU30/09/202401/05/202501/06/202501/06/2025IE18/08/202320/08/202421/08/202420/10/2024IT31/12/202330/11/202401/09/202401/12/2024LT01/03/202402/05/202502/06/202502/06/2025LU01/02/202401/12/202401/12/2024Not ProvidedLV01/03/202421/02/202524/02/202524/02/2025MTN/AN/A01/01/202501/02/2025NLNot ProvidedNot ProvidedNot Provided01/09/2025PL01/08/202515/01/202601/03/202601/06/2026PT01/09/202401/05/202531/08/202501/09/2025RO31/12/202231/12/202431/12/202402/06/2025SENot ProvidedNot Provided03/03/202501/09/2025SI01/10/202320/05/202501/06/202501/06/2025SK01/06/202431/05/202501/09/202501/09/2025RespondeeTechnical SpecificationsDeployment(Start of the deployment window)Operations(End of the deployment window)30/06/202203/06/202402/06/2025 
 
 
 
 
ANNEX 1 – PLANNING OVERVIEW – UCC WORK PROGRAMME PROJECTS  

Figure 39 provides a visual overview of the planning of the UCC WP 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 39: Planning Overview: UCC WP Projects  

147 

 
 
 
 
 
ANNEX 2 – ACRONYMS, ABBREVIATIONS & KEY TERMS 

Description 
Adaptive Development Methodology 
Authorised Economic Operator 
Automated Export System 
Automated Import System 
Notification of Arrival 
Automated Customs Tariff and Local Processing Application System 
Business Process Model 
Binding Tariff Information 
Common Agricultural Policy 
Centralised Clearance for Export 
Centralised Clearance for Import 
Common Communication Network 2 
Common Communications Network 2nd Generation 
Customs Decisions System 
Customs Goods Manifest 
Common Reference Architecture 
Customs Risk Management System 2 
Common Transit Convention 
Common Technical System Specifications 
Delegated Act 
Design Document for National Applications 
Design Document for National Transit Application 
Design Document for National Export Application 

Acronym 
ADM 
AEO 
AES 
AIS 
AN 
ATLAS 
BPM 
BTI 
CAP 
CCE 
CCI 
CCN2 
CCN2ng 
CDS 
CGM 
CoRA 
CRMS2 
CTC 
CTSS 
DA 
DDNCA 
DDNTA 
DDNXA 
DG TAXUD  Directorate General for Taxation and Customs Union 
Electronic Customs Coordination Group 
ECCG 
Export Control System 
ECS 
Export Control System – Phase 2 
ECS-P2 
Excise Movement and Control System 
EMCS 
European Maritime Single Window 
EMSW 
European Maritime Single Window environment 
EMSWe 
Entry Summary Declaration 
ENS 
Economic Operator 
EO 
Economic Operator Registration and Identification 
EORI 
Economic Operator Registration and Identification upgrade 
EORI2 
European Union Customs Data Model 
EUCDM 
EU Customs Trader Portal 
EU CTP 
Exit Summary Declaration 
EXS 
Functional System Specifications 
FSS 
Generalised Scheme of Preferences 
GSP 
Graphical User Interface 
GUI 
Guarantee Management 
GUM 
Implementing Act 
IA 
Import Control System 2 
ICS2 
Information Exchange Conversion Application 
ieCA 
Information Sheet 
INF 
Multi-Annual Strategic Plan for Customs 
MASP-C 
Maritime Single Window 
MSW 
Minimal Viable Product 
MVP 
New Computerised Transit System 
NCTS 
Northern Ireland Protocol 
NIP 

148 

 
 
Description 
National Import System 
National Export System 
Project Group 
Presentation Notification 
Proof of Union Status 
Quarter 1/2/3/4 
Registered Exporter System 
Request for Change 
Regulatory Procedure with Scrutiny 
Rational Unified Process 
Scaled Agile Framework 
Slovenian Automated Import System 
Special Procedures 
Special Procedures – Component 1 
Special Procedures – Component 2 
Surveillance 2 
Surveillance 3 
The Open Group Architecture Framework 
Trader Portal 
Technical System Specifications 
Union Customs Code 
Union Customs Code Work Programme 

Acronym 
NIS 
NES 
PG 
PN 
PoUS 
Q1/2/3/4 
REX 
RfC 
RPS 
RUP 
SAFe 
SIAIS2 
SP 
SP EXP 
SP IMP 
SURV2 
SURV3 
TOGAF 
TP 
TSS 
UCC 
UCC WP 
UUM&DS  Uniform User Management and Digital Signature 
VIS 

Vision Document 

Table 46: Abbreviations and Acronyms 

149