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  COM(2024) 395 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278(a) of the Union Customs Code, on progress in developing the electronic systems provided for under the Code during 2023 {SWD(2024) 214 final}  
 
 
Table of Contents 

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

2. CONTENT OF THE REPORT .................................................................................................... 2 

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

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

4.1 

Projects completed before 2023 ............................................................................................ 4 

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

4.2.1 Trans-European projects ......................................................................................................... 5 

4.2.2 National projects ....................................................................................................................... 8 

4.3 

Risks for delays to the UCC IT implementation ............................................................... 10 

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

4.5 

State of play for enlargement countries ............................................................................. 14 

5. MANAGEMENT SUMMARY AND CONCLUSIONS ........................................................... 15 

1 

 
 
 
 
 
 
 
 
 
 
1.  INTRODUCTION 

This is the fifth annual report on the deployment progress of the outstanding electronic systems, 
in accordance with Article 278(a) of the Union Customs Code (UCC)1 on the progress in developing 
the electronic systems provided for under the UCC2. This report elaborates on the continuing progress 
in  developing  electronic  systems  and  describes  the  developments  towards  a  fully  digital  customs 
environment since the UCC entered into force. For this purpose, it draws on the UCC Work Programme3 
(UCC WP), established in 2019, which is considered as the baseline for reporting progress. 

The UCC entered into force on 1 May 2016 and following its amendment in 20194, it established the 
deadlines of 2020, 2022 and 2025 for the progressive completion of the projects in terms of IT transition 
and implementation. The existing electronic and paper-based systems can continue to be used for the 
completion  of  customs  formalities  (the  so-called  ‘transitional  measures’)  until  the  new  or  upgraded 
electronic systems envisaged under the UCC are operational. This legal instrument is used to steer and 
support the gradual and  complex three-dimensional transition process towards a fully digital customs 
environment, taking into account interdependencies between the systems. .  

It  should  be  noted  that  during  the  drafting  of  this  report  the  UCC  WP  of  2019  had  been  subject  to 
revision,  amongst  others  based  on  the  progress  input  received  from  Member  States  as  part  of  the 
preparation of the report. The new UCC WP is the instrument to steer Member States towards a common 
and feasible implementation of the pending projects, leaving more flexibility to meet the final deadlines 
but  nevertheless  keeping  the  necessary  pressure  for  a  full  implementation  of  the  UCC  WP  by  31 
December 2025. For this reason the report includes a forward looking approach as regards the readiness 
against the dates in the new UCC WP5, which was adopted by the Commission on 15 December 2023.  

2.  CONTENT OF THE REPORT 

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

i) 

ii) 

iii) 

Central trans-European systems to be developed or upgraded by the Commission (often 
also requiring developments or upgrades of the national systems by the Member States); 
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; 
National systems that have to be developed or upgraded exclusively by the Member States.  

This report analyses the tangible progress made for all these systems, outlining the scope and planning 
of each project (section 3). It also highlights potential delays, where identified, as well as envisaged 
mitigating measures (section 4). The overall assessment of the progress of the implementation of the 
UCC WP is summarised in the conclusion of this report (section 5).  

1 Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union 
Customs Code, OJ L 269, 10.10.2013, p. 1–101. 
2 Report from the Commission to the European Parliament and the Council:  
2019: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52019SC0434; 
2020: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0339; 
2021: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52021SC0382; 
2022: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023SC0029. 
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 Regulation (EU) 2019/632 of the European Parliament and of the Council of 17 April 2019 amending Regulation (EU) No 
952/2013 to prolong the transitional use of means other than the electronic data-processing techniques provided for in the Union 
Customs Code (OJ L 111, 25.4.2019, p. 54–58). 
5 Commission Implementing Decision (EU) 2023/2879 of 15 December 2023 establishing the work programme relating to the 
development and deployment of the electronic systems provided for in the Union Customs Code, OJ L_202302879, 22.12.2023, 
p.1-17, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202302879. 

2 

 
 
 
 
More details of the planning and status of each project are provided in the Commission’s Staff Working 
Document6, published alongside this report. The report and Staff Working Document are constructed on 
the basis of of information collected through the following sources:  

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

(2) a survey circulated to the Member States and to the Commission own services to capture the actual 
progress against the plans. 

The  data  yielded  are  both  quantitative,  in  the  form  of  deadlines  and  milestones  met  or  missed  and 
qualitative, in the form of detailed descriptions regarding the estimated complexity of the projects, the 
challenges  faced,  the  risks  anticipated,  the  delays  and  reasons  for  any  such  delays  as  well  as  the 
mitigating measures planned and/or taken. 

In  this  year’s  exercise,  Member  States  were  also  asked  to  provide  information  on  the  lessons  learnt 
during the development of the projects and on the possible additional support needs. 

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

The outcome of the survey provided the Commission with a clear view of the status of each system. 
However, the Commission determined it important to acquire up-to-date knowledge to obtain a full and 
accurate  understanding  of the status  of  each  of the  UCC  projects  on  the side  of  the  Member  States, 
comprehend the issues they were encountering and generate ideas for improving problematic situations.  

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

This report also contains an analysis based on more detailed information reported by the Member States 
in the framework of the Coordination Programmes in place since 2020 for the trans-European systems.  

3.  PROJECT METHODOLOGY FOR THE UCC ELECTRONIC SYSTEMS 

Dependent on the system architecture agreed by the Member States and the Commission for each of the 
systems, there is a role sharing defined as regards the responsibilities for the development, deployment, 
operation  and  maintenance.  This  is  laid  down  in  the  Implementing  Reguation  on  the  Technical 
Arrangements  for  the  electronic  systems  (IRTA),  which  describes  what  components  those  systems 
should consist of, and what their nature is – national (developed at national level) or common (developed 
at EU level).  

In  accordance  with  Article  103  of  the  IRTA,  the  common  components  shall  be  developed,  tested, 
deployed and managed by the Commission, and may be tested by the Member States. The  national 
components shall be developed, tested, deployed and managed by the Member States. The Member 
States shall ensure that the national components are interoperable with the common components. The 
Commission shall design and maintain the common specifications for the decentralised systems in 
close  cooperation  with  the  Member  States.  The  Member  States  shall  develop,  operate  and  maintain 
interfaces  to  provide  the  functionality  for  the  decentralised  systems  necessary  for  the  exchange  of 
information with economic operators and other persons  through national components and interfaces, 
and with other Member States through common components. 

Since 2022, the project methodology for the development of the systems has been further optimised. 
On  the  side  of  the  Commission,  the  business  process  modelling,  data  modelling  and  technical 
specifications have been developed more in parallel and through close collaboration from the start with 
legal,  business and  IT  experts.  This  best  practise method  has also  been  incorporated by  most  of the 
Member  States. Moreover,  there  is an  evolution  towards  adopting more  agile  methodologies  for  the 
development  of  the  UCC  electronic  systems,  enabling  gradual  enhancements  to  user  functionality 
through swifter and more manageable software releases. The Commission has adapted its approach and 
documentation for the trans-European systems to enable this agility as a support to the Member States 

6 Commission Staff Working Document Accompanying the Report from the Commission to the European Parliament and the 
Council pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for 
under the Code, SWD(2024) XX final. 

3 

 
 
 
 
to speed up the progress. This is also reflected in the new UCC WP.  

The  Member  States  and  the  Commission  continued  to  meet  regularly  in  the  Electronic  Customs 
Coordination Group (ECCG) to define and agree upon the project documents for each trans-European 
system. The ECCG is also the forum to steer and coordinate the activities amongst the Member States 
and  the  Commission.  In  addition,  the  Commission  systematically  consulted  the  trade  community 
through the Trade Contact Group (TCG). The Member States have the responsibility to maintain direct 
contact with their Economic Operators regarding national plans and  documentation for traders. Once a 
system is ready, it is of utmost importance that the Member States ensure a smooth transition from the 
existing  systems  to  the  upgraded  ones.  This  is  vital  to  prevent  any  impact  on  trade  and  customs 
operations. 

4.  GLOBAL  OVERVIEW  OF  PROGRESS  WITH  THE  UCC  ELECTRONIC 

SYSTEMS 

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

4.1  Projects completed before 2023 

The Commission reports the successful deployment of the following nine new systems or upgrades:  

• 

• 

• 

• 

• 

• 

• 

• 

• 

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

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

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

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

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

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

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

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

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

4.2  Ongoing projects 

This report aims to highlight the accomplishments and challenges encountered in the implementation of 
the ongoing projects in 2023.  

Section  4.2.1  provides  an  overview  of  the  six  trans-European  projects  scheduled  for  deployment 
between 2023 and 2025. Four of these projects had deployment windows ending in 2023 as set in the 
UCC WP of 2019 but as some Member States reported difficulties, the UCC WP was revised in 2023. 

Section 4.2.2 outlines the implementation of the three national projects, namely Notification of Arrival, 
Presentation Notification and Temporary Storage, Special Procedures  and  National Import Systems. 
These projects were originally planned to be operational by 31 December 2022, as defined in the UCC. 
However,  due  to the  inability  to meet  this  deadline  and  as  previously  identified  in  the  UCC  Annual 
Progress Reports, several Member States requested a derogation under Article 6(4) of the UCC. On 1 
February  2023,  the  Commission  adopted  Implementing  Decisions  granting  derogations  to  certain 
Member States, extending the deadline to 31 December 2023.  

4 

 
 
 
4.2.1 Trans-European projects 

The trans-European projects follow a particular structure, which may involve a combination of central 
and  national  elements  as  well  as  multiple  phases.  As  stated  in  Article  278(3)  of  the  UCC,  they  are 
required to be completed no later than 31 December 2025. A concise description and progress for each 
project is presented below: 

1) 

UCC  Guarantee  Management  –  GUM  (new):  aims  to  ensure  real  time  allocation  and 
management  of  different  types  of  guarantees  across  the  EU,  focusing  on  improving 
processing speed, traceability and monitoring of guarantees between customs offices.  

Progress:  A  business  guidance  document,  an  eLearning  module  and  IT  training  sessions 
were made available in 2023. A low risk was associated to the timely deployment of GUM – 
Component 1 which is to implemented centrally by 11 March 2024.  

Concerning the GUM – Component 2, Member States are expected to establish operational  
connections with the central component between March 2024 and June 2025. Member States 
predominantly indicated a low-risk level for the timely delivery of the project. By Q2 2023, 
seven Member States reported  the deployment of their  national component as completed, 
while for others the work is ongoing. Two anticipated delays in achieving the milestone. 

2) 

UCC Import Control System 2 – ICS2 (upgrade): aims to strengthen the safety and security 
of the supply chain by improving data quality, filing, availability and sharing of advanced 
cargo information.  

Progress: ICS2 – Release 2 extends the scope of the system to all cargo (including express 
and postal consignments) entering the EU by air.  

The central ICS2 – Release 2 system was deployed by the Commission on 1 March 2023 in 
line with the legal deadline. 

As regards the Member States readiness for their part in the implementation, twelve Member 
States deployed  ICS2 – Release 2 by 1 March 2023. Derogations were granted to  twelve 
other Member States, extending the deployment deadline until 30 June 20237 due to high risk 
of delays. By end of 2023, twenty-six Member States were operational with Release 2. The 
remaining Member State envisaged to connect during the first half of 2024.  

Traders  transitioned  gradually  until  October  2023,  however,  by  the  year’s  end, 
approximately  40  air  carriers  were  still  pending.  Member  States  are  responsible  for  the 
economic operators` compliance with ICS2. The Commission monitors the phasing in of the 
economic operators together with the Member States and relevant trade associations. The 
Commission has reminded Member States to take all necessary actions (including possibly 
imposing penalties) against continued non-compliance of economic operators. 

The development of ICS2 – Release 3 has started as planned. Most Member States indicated 
that the project is with low risk and on target to have the system fully deployed by the date 
specified in the UCC WP. 

3) 

UCC Proof of Union Status – PoUS (new): aims to store, manage and retrieve all proofs to 
demonstrate that traders provide the Union status of their goods. Due to dependencies with 
the  UCC  Customs  Goods  Manifest  (CGM)  and  the  European  Maritime  Single  Window 
environment (EMSWe), the project will be completed in two different phases to minimize 
risks and  inconsistencies.  

Progress: PoUS – Phase 1 is set to be operational by 1 March 2024, with low risk of delay. 

7 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). 

5 

 
 
 
 
Regarding PoUS – Phase 2, Technical Specifications were completed by the Commission in 
Q2 2023, and Conformance Testing activities are  scheduled to conclude in Q3 2025. The 
Commission is on schedule for a timely delivery of the project. However, it should be noted 
that in view of the difference in the deployment date of PoUS – Phase 2 Customs Goods 
Manifest (CGM) (2 June 2025) and the deployment date of the European Maritime Single 
Window environment (EMSWe) (15 August 2025), an alignment has been sought for in the 
new  UCC  WP.  As  a  result,  the  deployment  was  rescheduled  in  the  new  UCC  WP  to  15 
August 20258. A medium risk has been identified on the project in view of progress issues 
on the implementation of the EMSWe. 

4) 

UCC Centralised Clearance for Import – CCI (new): aims to allow economic operators to 
place goods under a customs procedure by lodging at their place of establishment a customs 
declaration  for  goods  which  are  presented  in  another  Member  State.  Built  upon  the  new 
National Import Systems, CCI will automate centralised clearance at the European level. 

Progress: For CCI – Phase 1, the Commission is progressing according to schedule and with 
ongoing  Conformance  Testing  with  Member  States.  A  medium  to  high  risk  level  was 
assigned to the project due to dependencies on Member States’ readiness with the National 
Import System (NIS) upgrade, a prerequisite for deploying CCI.  

In view of reported delays in the deployment of CCI - Phase 1 beyond 1 December 2023, 
the Commission is implementing a new iterative approach, prioritising standard declarations 
and the freedom to choose the message type, while extending the deadline for CCI – Phase 
19, with the final deployment on the 1 July 2024, reflected in the new UCC WP.  

As regards CCI – Phase 2, the Commission finalised the Technical Specifications in 2022, 
well in advance of the deployment window scheduled for October 2023 to 2 June 2025.  

In terms of assessing the level of completeness of the full CCI system, most of the Member 
States reported that the developments are progressing, with a medium level of risk associated 
with the timely delivery of the project against the deadline for CCI – Phase 2.  

Some Member States expressed their intention to deploy CCI – Phase 1 and CCI – Phase 2 
together. 

5) 

UCC  New  Computerised  Transit  System –  NCTS (upgrade):  aims  to  align the  existing 
Union and common transit system to the new UCC legal provisions, including the new UCC 
data requirements and the interfaces with other systems.  

Progress: Overall, for NCTS – Phase 5, significant progress has been achieved. However, a 
high risk was allocated to the project as the deployment deadline of 1 December 2023 could 
not be achieved by a number of Member States. Therefore, a new approach was agreed and 
reflected in the new UCC WP. This entails that NCTS – Phase 5 can be implemented in two 
steps: core functionalities by 1 December 2023 with business continuity aligned with UCC, 
and non-core functionalities by 2 December 2024.  

As illustrated in Figure 1, three Member States started operations by February 2023, while 
four others joined them by September 2023. All but six Member States committed to being  
operational with the core functionalities by 1 December 2023 and most confirmed they will 
be fully operational, for both core and non-core functionalities by 1 December 2024.  

8 Date updated accordingly in the 2023 UCC WP Revision. 
9 Approach presented in 2023 in the context of the revision of the UCC WP and MASP-C. The end of the deployment window 
for CCI – Phase 1 is envisaged to run till the end of Q2 2024, with the final deployment deadline being 01/07/2024. 

6 

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

For NCTS – Phase 6 the timeline is synchronised with that of ICS2 – Release 310 in the new 
UCC WP and the new deployment window establishes a clear cut-off for NCTS-Phase 5. 
These  changes  should  address the  risk  of  delays  and allow  Member  States and  traders  to 
define their strategy and actions to be ready by the new dates. Therefore, the risk associated 
to this project in view of its finalisation by 1 September 2025 is reduced to low.  

6) 

UCC  Automated  Export  System  –  AES  (upgrade):  aims  to  implement  the  UCC 
requirements for export and exit of goods.  

Progress:  For  AES  the  Member  States  reported  significant  progress  in  deploying  their 
national export applications in 2023. However, as the deployment deadline of 1 December 
2023 could not be achieved by a number of Member States, leading to a revised plan in the 
UCC WP, a high risk is allocated to the project. AES may be implemented in three steps: 
first, core functionalities (1 December 2023), the second to interface with Excise (February 
2024) and lastly, non-core functionalities (2 December 2024). 

These  changes  should  address the  risk  of  delays  and allow  Member  States and  traders  to 
define the strategy to meet the new deadlines, as failing to do so would pose a medium to 
high risk for a timely delivery by end 2024. 

Figure  2  illustrates  that  eight  Member  States  started  international  operations  for  AES  by 
September 2023. Another eight Member States, along with the Commission, are currently 
executing  their  deployment  plans  to  ensure  their  timely  entry  into  operation. Most  of the 
Member States confirmed their commitment to be operational with the core functionalities 
by 1 December 2023, and for core and non-core functionalities by 2 December 2024.  

10 As envisaged in the new UCC WP, NCTS – Phase 5 will be fully deployed by 21 February 2025. The transition period from 
NCTS – Phase 5 to NCTS – Phase 6 is envisaged between 01/03/2025 and 01/09/2025, during the same period that  ICS2 – 
Release 2 will transition to ICS2 – Release 3, allowing for the synchronisation between both systems. 

7 

 
 
 
 
 
 
Figure 2 – AES Member States entry into operations 

To summarise the status of the remaining trans-European projects, the Commission remains on track 
to meet the legal deadlines agreed upon in the context of the UCC and UCC WP. As regards the Member 
States’ deployments of the national components of these trans-European systems, serious risks for delays 
have been identified, in particular for CCI – Phase 1, AES, and NCTS – Phase 5 but they have been 
partially addressed with the new UCC WP (see section 4.3).  

4.2.2 National projects 

The  Member  States  were  due  to  complete  the  upgrade  of  their  three  fully  national  projects  11  by 
December 31, 2022, in accordance with Article 278(2) of the UCC. However, twenty two Member States 
could  not  meet  this  deadline  and  following  their  request,  were  granted  a  derogation,  externding  the 
deployment deadline to 31 December 202312.  

The progress for each national project is presented below and illustrated in Figure 3: 

1) 

UCC Notification of Arrival, Presentation Notification and Temporary Storage (AN, PN and 
TS) (upgrade): aims to automate national entry processes.  

Progress: The timely delivery of national systems was identified as being at risk in previous UCC 
Annual Progress Reports. As illustrated, most Member States completed the implementation by 
the end of 2023. For more details, please refer to section 3.1.2 of the Commission Staff Working 
Document accompanying this report. 

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

12 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). 
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). 
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). 
Commission Implementing Decision (EU) 2023/237 of 1 February 2023 granting a derogation requested by certain Member 
States to use means other than electronic data-processing techniques for the exchange and storage of information related to the 
customs declaration for goods brought into the customs territory of the Union laid down in Articles 158, 162, 163, 166, 167, 
170 to 174, 201, 240, 250, 254 and 256 of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying 
down the Union Customs Code (OJ L 32, 3.2.2023, p. 226-228).   

8 

 
 
 
  
 
 
2) 

UCC  National  Import  Systems  –  NIS  (upgrade):  aims  to  implement  all  process  and  data 
requirements that relate to imports as outlined in the UCC.  

Progress: Several Member States reported risks in the timely delivery of the project since 2022, 
resulting in derogations granted. By the end of 2023, NIS is deployed by nineteen Member States. 
A few Member States require a further update to have the project fully completed; others are not 
ready with the implementation by the end of 2023 (derogation deadline). For more details, please 
refer to section 3.2.2 of the Commission Staff Working Document accompanying this report. 

3) 

UCC Special Procedures – SP (upgrade): aims to harmonise special procedures (i.e., customs 
warehousing, end-use, temporary admission and inward/outward processing).  

Progress:  Considering  the  interdependencies  with  the  National  Import  Systems,  twenty-one 
Member States completed SP IMP by the end of 2023. For more details, refer to sections 3.3.2 
and 3.4.2. of the Commission Staff Working Document accompanying this report. 

TS 

NIS 

SP IMP 

UCC WP 
Deadline 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
ES 
FI 
FR 
GR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

AN 

PN 
31/12/2022  
with extension to 31/12/2023 (1) 
21-06-2023 
05-07-2023 
23-10-2023 
07-11-2023 
01-03-2023 
06-03-2021 
31-10-2023 
01-10-2023 
01-03-2024 
31-03-2021 
06-03-2024 
31-12-2024 
01-03-2023 
31-12-2023 
23-11-2020 
13-12-2022 
28-02-2023 
10-01-2023 
24-09-2017 
01-06-2024 
01-12-2023 
31-12-2023 
28-10-2024 
01-10-2023 
27-09-2023 
01-03-2023 
01-10-2023 

Not Provided 
29-11-2023 
23-10-2023 
07-11-2023 
31-12-2023 
06-03-2021 
15-10-2024 
01-10-2023 
01-03-2024 
31-12-2022 
06-03-2024 
31-12-2024 
01-12-2022 
31-12-2023 
23-11-2020 
13-12-2022 
31-10-2023 
10-01-2023 
24-09-2017 
01-06-2024 
01-12-2023 
31-12-2023 
28-10-2024 
01-10-2023 
01-10-2024 
30-11-2023 
02-06-2025 

N/A 
30-06-2023 
01-03-2023 
07-11-2023 
01-03-2023 
01-03-2023 
31-10-2023 
01-10-2023 
N/A 
31-03-2023 
01-07-2023 
31-12-2024 
01-07-2023 
31-12-2023 
N/A 
13-12-2022 
01-03-2023 
01-03-2023 
24-09-2017 
01-06-2024 
01-07-2023 
01-12-2023 
28-10-2024 
01-10-2023 
01-03-2023 
01-03-2023 
01-03-2023 

31/12/2022  
with extension to 31/12/2023 (2) 
Not Provided 
06-12-2023 
23-10-2023 
07-11-2023 
01-12-2024 
06-03-2021 
15-10-2024 
01-07-2021 
30-09-2023 
31-12-2019 
31-12-2024 
31-12-2022 
01-01-2023 
12-10-2023 
24-06-2024 
01-07-2021 
31-12-2023 
02-05-2023 
03-06-2018 
01-02-2025 
01-04-2022 
31-12-2023 
28-10-2024 
01-10-2023 
15-03-2022 
01-01-2022 
01-01-2025 

03-02-2025 
06-12-2023 
23-10-2023 
07-11-2023 
01-12-2024 
06-03-2021 
15-10-2024 
01-07-2021 
30-09-2022 
30-12-2022 
30-09-2023 
31-12-2024 
01-01-2023 
12-10-2023 
23-11-2020 
01-07-2021 
31-12-2023 
02-05-2023 
03-06-2018 
01-02-2025 
01-04-2022 
01-07-2021 
28-10-2024 
31-12-2023 
20-06-2023 
01-01-2022 
11-06-2016 

Legend 

In line with the UCC WP, the further update by 1 July 2024, and/or the granted derogation 
Beyond the deadline in the UCC WP and/or the granted derogation 
Not provided 

(1) Until 31/12/2023 for the Member States that were granted a derogation. 

9 

 
 
 
 
 
 
 
 
 
 
  
  
  
 
  
 
 
 
 
(2) Until 31/12/2023 for the Member States that were granted a derogation or until 01/07/2024, where Article 
2(4a) of Commission Delegated Regulation (EU) 2015/2446 applies, which is the case for instance for Bulgaria, 
Ireland and Poland. 

Figure 3 – National entry/import systems deployment planning 

To summarise, Member States are in the process of completing the upgrade of their three fully national 
projects. Although most Member States anticipate deploying their systems by the end of 2023, in line 
with the granted derogation deadline, a significant number of Member States still reported further delays, 
mostly for TS and NIS, resulting in deployments that will extend beyond 2023 and that impact other 
domains.  

The  delays  in  the  deployment  of  the  national  entry  systems  (Arrival  Notification/Presentation 
Notification/Temporary  Storage)  are  disrupting  the  ICS2  end  to  end  cycle  and  support  processes, 
impacting supply chains and increasing costs for economic operators for setting up an interim solution.  

The delays of NIS upgrade also have a negative impact on the economic operators, postponing the use 
of all the functionalities at import, simplifications in formalities of which the economic operators could 
benefit such as Entry Into the Declarant’s Records (EIDR). Furthermore, it is an important prerequisite 
for the deployment of the electronic system related to CCI.   

More details on the delays are reflected in section 3.2 of the Staff Working Document. 

4.3  Risks for delays to the UCC IT implementation 

This report distinguishes the progress made on the Commission’s side from that of the Member States. 
The Commission’s developments are progressing as planned and no delays beyond the legal deadline 
and no risks that could result in a delayed deployment were identified. Delays experienced by Member 
States impact  the progress of the trans-European systems such as ICS2, CCI, NCTS and AES in their 
totality which, in turn, have an impact on the activities under the Commission’s scope of action. This 
results in greater investment resources devoted to Conformance Testing activities and coordination and 
support  activities  in  the  trans-European  projects.  Furthermore,  it  also  results  in  further  assistance  in 
alternative  national  development  and  deployment  schemes  and  monitoring,  and  having  to  maintain 
central components for a longer time during transition periods.  

Most  Member  States  are  gradually  progressing  in  the  developments  under  their  responsibility, 
although  some  of  them  are  advancing  at  a  slower  pace  than  originally  planned.  As  a  result,  delays 
beyond  the  legal  or  derogation  deadlines  were  reported  in  some  national  and  trans-European 
projects.  

The Member States provided several grounds for justification of the delays, most of which are recurring, 
leading to  delays in the  development  of  their systems.  These include  a lack  of financial  and  human 
resources,  competing  priorities  and  the  impact  of  the  Russian  invasion  of  Ukraine  on  customs. 
Additionally, Member States also reported the inability of national IT infrastructures to cope with the 
technical needs of the projects, capacity issues of contractors and dependencies with other stakeholders, 
transition  and  testing  with  the  Economic  Operators,  delayed  or  unsuccessful  calls  for  tenders  to 
outsource pieces of work, burdensome public procurement procedures, governance issues and complex 
system integrations of the UCC projects.  

Despite  the  Commission’s  timely  delivery  of  the  Functional  and  Technical  Specifications  for  trans-
European systems under the UCC WP, there are still a few Member States where tenders have not been 
awarded or where significant problems in national procurement processes remain, impacting the timely 
delivery of the systems. 

Bilateral meetings between the Member States and the Commission were held to discuss and address 
issues and to emphasise the importance of prioritising the UCC projects. In this regard, the Commission 
also  provided  advice  on  possible  follow-up  actions  and  measures.  Twenty-two  Member  States 
submitted  formal  requests  for  derogations  to  the  Commission  under  Article  6(4)  of  the  UCC 
concerning  delays  beyond legal  deadlines in their  national  projects.  The  Commission reviewed  the 

10 

 
 
 
 
requests  and  the  justifications  provided  therein  in  light  of  the  specific  circumstances  and  issued 
Implementing  Decisions  granting  derogations  to  the  requesting  Member  States.  Derogations  for 
Notification  of  Arrival,  Presentation  Notification,  Temporary  Storage,  National  Import  System,  and 
Special  Procedures  –  Component  2  extended  the  deadline  until  31  December  202313,  while  the 
derogation for ICS2 – Release 2 extended the deadline until 30 June 2023. 

An overview of the granted derogations to the Member States is provided below: 

•  For the implementation of Notification of Arrival, a derogation was granted to the following 
Member States: AT, BE, BG, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LU, MT, NL, PL, PT, 
RO, SE, SI, and SK. At the same time, BG, CY, DE, EE, ES, FI, FR, HR, HU, LT, LU, NL, SE, 
and SI reported that they would use the AN integrated in ICS2 – Release 2 (deployed as of 1 
March 2023 or 30 June 2023 for Member States that were granted a derogation). DE and IE 
indicated Notification of Arrival as not applicable. 

•  For the implementation of Presentation Notification, a derogation was granted to the following 
Member States: AT, BE, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LU, MT, NL, PL, PT, RO, 
SE, SI, and SK.   

•  For  the  implementation  of  Temporary  Storage,  a  derogation  was  granted  to  the  following 
Member States: AT, BE, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LT, LU, MT, NL, PL, PT, 
RO, SE, SI, and SK. Additionally, GR shared the need for an extended derogation. 

•  For the implementation of the National Import Systems upgrade, a derogation was granted to 
the following Member States: AT, BG, CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, 
RO, and SE. These delays will impact the trans-European CCI project and Special Procedures 
–  Component  2,  which  follows  the  same  timeline  as  the  National  Import  System  upgrade. 
Additionally, GR and SK shared the need for an extended derogation. 

•  For the implementation of Special Procedures – Component 2, a derogation was granted to the 
following Member States: AT, BG, CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, RO, 
and SE. 

•  For the implementation of ICS2 – Release 2, a derogation was granted to the following Member 
States: AT, BE, DK, EE, FR, GR, HR, LU, NL, PL, RO, and SE. GR and RO submitted a formal 
request for a subsequent derogation. Additionally, GR and RO shared the need for an extended 
derogation. By end 2023, RO will still facing issues with the deployment of this release. 

Based on the information received from the Member States, we can conclude that 71% of the total of 
extended 2023 deadlines granted under the derogations have been met. The other 29% is still facing 
issues with the deployment.   

As  reflected  in  the  accompanying  Staff  Working  Document,  several  Member  States  informed  the 
Commission about delays on the trans-European projects: 

•  For the implementation of Special Procedures – Component 1, the following Member States 
indicated a planned operations date that is later than the set deadline in the UCC WP: FI, FR, 
GR, HU, LU, MT, PT, SE, and SK. For more details, please refer to section 3.3 of the Staff 
Working Document accompanying this report. 

•  For the implementation of ICS2 – Release 3, the following Member States reported deployment 
dates exceeding the deadline defined in the UCC WP14: FI, FR, HR, IE, MT, PT, and SK. For 

13  For modes of transport other than air, the derogations for Arrival Notification, Presentation Notification and Temporary 
Storage last until 29/02/2024. 
14 In the 2023 UCC WP Revision, the deployment of the full ICS2 – Release 3 by all Member States is envisaged for 03/06/2024. 
The rollout of the ICS2 – Release 3 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). 

11 

 
 
 
 
more  details,  please  refer  to  section  4.2  of  the  Staff  Working  Document  accompanying  this 
report. 

•  For the implementation of CCI – Phase 1, the following Member States indicated a planned 
operations date that is later than the deadline set in the UCC WP15: BE, CZ, DE, DK, ES, FI, 
HR, HU, IE, LT, LU, LV, MT, NL, PT, SI and SK. For CCI – Phase 2, BE, DE, EE, ES, FI, 
GR, and NL indicated a planned operations date which is later than the deadline set in the UCC 
WP.  For  more  details,  please  refer  to  sections  3.6  and  4.4  of  the  Staff  Working  Document 
accompanying this report. 

•  For the implementation of NCTS – Phase 5, AT, ES, FI, GR, HU, IE, LT, LV, MT, NL, PT, 
SE, and SK indicated delays  compared to the operations deadline set in the UCC WP16. For 
more  details,  please  refer  to  section  3.7  of  the  Staff  Working  Document  accompanying  this 
report.  

•  For the implementation of AES – Component 1, AT, BE, FI, FR, GR, HU, LU, MT, PT, SE, 
and SK indicated a planned operations date later than the deadline set in the UCC WP17. For 
more details, please refer to section 3.8 of the document accompanying this report. 

•  For  the  implementation  of  GUM  –  Component  2,  the  following  Member  States  indicated  a 
planned operations date that is later than the deadline set in the UCC WP18: BE, DE, DK, GR, 
and  HR.  For  more  details,  please  refer  to  section  4.1  of  the  Staff  Working  Document 
accompanying this report. 

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

To conclude, most Member States are targeting to deploy the national projects within the new deadlines 
provided  for  in  the  derogations.  However,  some  Member  States  still  reported  delays  beyond  the 
derogation  deadlines.  These  delays  may  in  addition  negatively  impact  the  delivery  of  the  national 
components of the trans-European systems with the implementation date in 2023, as additional effort is 
condensed  in  a  shorter  timeframe.  As  for  the  delivery  of  the  national  components  of  the  trans-
European systems, some Member States reported delays in certain projects. 

4.4  Mitigation actions 

Most  of  the  Member  States  have  made  significant  advancements  in  the  development  of  the  trans-
European  systems  and  several  were  striving  to  have  their  systems  deployed  by  the  end  of  2023  in 
accordance with the initial deadlines and derogations provided. However, some are experiencing delays, 
pushing their deployment plans to the end or beyond the deployment window. The Commission has 
urged strict adherence to their National Project Plans for a timely deployment.  

The Member States outlined the various mitigating actions aimed at addressing (potential) delays and 
ensuring  compliance  with  the  legal  deadlines.  These  actions  include  allocating  additional  resources, 
adopting agile methodologies, breaking the projects into stages and reorganizing supplier relationships 
to  improve  the  efficiency  and  enhancing  collaboration.  Other  Member  States  plan  to  enhance 
organisational structures, streamline processes and refine planning to improve project management and 
decision-making. These measures were referred to for both national and trans-European projects. 

15 In the 2023 UCC WP Revision the end of the deployment window is envisaged for 01/07/2024. 
16 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 – Phase 5 system. The end of the transition is envisaged for 21/01/2025. 
17 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. 
18 In the 2023 UCC WP Revision, for GUM – Component 1, the deployment date is envisaged for 11/03/2024 and, for GUM – 
Component 2, the start of the deployment window is to be defined by the Member States, with the earliest possible deployment 
date being 11/03/2024. 

12 

 
 
 
 
In  view  of  the  delays  on  the  side  of  the  Member  States,  the  Commission  has  been  increasing  its 
support to Member States through several actions.  

Firstly,  the  Comission  has  enhanced  supervision  and  monitoring  at  UCC  IT  programme  by 
increasing the frequency of  progress reports and organising bilateral meetings at Director level with 
each Member State. The implementation of the UCC WP has consistently been addressed in missions 
conducted by the Director-General and in plenary meetings with the Directors-General of the Member 
States  (in  the  Customs  Policy  Group  (CPG)).  Member  States  were  encouraged  to  take  mitigating 
measures and  submit funding requests under the Technical Support Instrument by 31 October 2023 to 
support customs IT developments. 

The Commission continued using a Multi-Annual Strategic Plan – Customs (MASP-C) dashboard  based 
on the MASP-C Revision 2019 and the UCC WP 2019 to monitor the progress, main project milestones 
and identify delays at an early stage. The dashboard is presented on a quarterly basis to the Member 
States in the ECCG and to the trade community in the TCG. Moreover, the UCC WP and the MASP-C 
is concurrently revised in line with strategic objectives. 

Additionally, as indicated in the UCC WP and MASP-C Revision 2019, the Commission sets specific 
interim milestones to ensure a smooth deployment of the decentralised trans-European systems and to 
avoid additional costs .  

Secondly, the Commission has reinforced its assistance to the Member States for trans-European 
systems by adopting an agile and iterative approach to developing and deploying the UCC electronic 
systems. This method, which includes prototyping, swift issue resolution and a balanced workload for 
both the Commission and the Member States, enhances system quality and facilitates tangible progress.  
Successfully implemented in the AES, NCTS – Phase 5 and ICS2 projects, this approach has been wel-
received by the Member States and traders.  

Furthermore, the Commission has established a collaborative mechanism among stakeholders from the 
outset of the projects to enhance preparatory activities, prevent decision-making difficulties and ensure 
transparency through regular project updates.  

The  Commission  also  continued  coordinating  and  monitoring  programmes  for  each  of  the  trans-
European systems which require substantial work on the side of the Member States. 

Further details on these measures were provided in the previous report of 2022.    

•  For the trans-European system ICS2, the Commission provided support to the Member States 
and  Economic  Operators  in  their  development  activities  for  ICS2  –  Release  2  and  ICS2  – 
Release  3  through  various  means.  This  included  organising  dedicated  webinars,  offering 
assistance through FAQs and coordinating plenary meetings. Additional guidance was provided 
to prevent disruptions at external borders due to delays in ICS2 – Release 2 (section 4.3). Close 
monitoring  ensured  alignment  of  project  plans  with  Commission’s  IT  delivery  milestones. 
Lastly,  communication  campaigns,  online  training  sessions  and  tailored  factsheets  were 
provided along with documentation accessible in the public CIRCABC library.  

•  For the trans-European systems NCTS – Phase 5 and AES, the Commission continued with 
the  ‘National  Administration  Coordination  Programme’  to  support  the  Member  States  in 
developing and deploying their national components. In 2023, the Coordination Programme was 
extended to oversee trader entry into operation, in collaboration with the Member States: 
Activities  include  a  dedicated  helpdesk,  virtual  meetings  to  mitigate  Member  States’ 
development  delays,  updated  information  dissemination  to  the  trade  community  and  regular 
reporting  to  the  ECCG  and  CPG.  Since  Q1  of  2021,  the  Commission  issued  quarterly 
consolidated progress reports on the transition to the new systems, providing KPIs for early alert 
detection.  

•  For the trans-European system CCI, the Commission established a dedicated team to address 

Member State’s questions and coordinate Conformance Testing.  

Thirdly, the Commission sought Member States’s input on their constraints and the needed support to 
mitigate the risks. The Member States expressed via a survey that the bilateral meetings at director level 

13 

 
 
 
and technical dialogue with DG TAXUD had been highly beneficial. They assessed technical webinars 
and information-sharing activities provided by the Commission as useful. Some suggested additional  
operational guidelines, assistance to Economic Operators, and comprehensive trainings beyond current 
capabilities.  

Fourthly, based on the outcome of the survey and on bilateral discussions with the Member States, the 
lack of appropriate funding was often revealed as a reason for delays. To this end, the Commission has 
established  a  dedicated  TSI  2024  flagship  under  the  Technical  Support  Instrument  (TSI)  for  the 
digitalisation of customs and tax focusing on UCC IT implementation. This has resulted in six Member 
States having submitted proposals for support to customs IT systems. The assessments of the proposals 
are ongoing and will be finalised early 2024 with a view to have the support in place in Q2 2024.  

Fifthly, to address the specific needs that Member States have in their daily management of the UCC 
customs  IT  projects,  the  Commission  has  established  a  contract  with  a  consultancy  company  to 
provide  direct  support  depending  on  needs  and  issues  to  address  delays.  The  first  pilot,  covering  3 
Member States (FR, MT, GR) started in Q4 2023 and is running till Q2 2024.  Depending on the outcome 
further activities could be launched in 2024. 

Finally, the Commission also initiated an exercise to gather lessons learnt and best practices for the 
development of the IT projects. A survey was conducted in 2023 and the outcomes were added to the 
Staff Working Document. For more details, please refer to page 6 of the document accompanying this 
report. 

As we are gearing towards the end of 2025, the Member States have been requested to safeguard the 
deadlines  in  the  new  UCC  WP.  Only  two  more  years  are  left  for  the  full  UCC  IT  implementation. 
Exceptional efforts and inmediate action are necessary to avoid delays and to ensure their business 
continuity for the trans-European systems.  

While the Commission supports in many ways as shown above, such as by adjusting dates in the new 
UCC WP and enabling achievable deadlines, the responsibility for developing and deploying national 
components and systems lies with the Member States. Role sharing has been defined and agreed with 
all stakeholders from the outset and should be respected throughout the project lifecycles. 

4.5  State of play for enlargement countries 

Finally,  in  the  transition  towards  the  upgraded  electronic  systems  envisaged  by  the  UCC  and  also 
considering the new IT approaches set up by the reform proposal, the future EU Enlargement will need 
to be included in the picture.  

For the time being the Commission does not systematically monitor the progress towards full electronic 
systems of candidate countries and there is no reporting obligation imposed on them under Article 278a 
of the UCC. However, the development of their IT systems supporting their alignment with EU customs 
legislation is a key element in the regular assessments carried out by the EU measuring the progress of 
the candidate countries in the enlargement path and under the Association Agreements with the EU.  

There are two IT systems which some of these countries are already applying and others are preparing 
to do so: 

(1)  NCTS  as  the  IT  supporting  system  for  the  implementation  of  the  provisions  of  the  Common 

Transit Convention (CTC) 

(2)  Related IT systems for mutual recognition with the EU AEO programme. 

The state of play of the preparedness of the candidate countries in relation to these two IT systems varies 
from one to another: North Macedonia, Serbia, Türkiye and Ukraine are already contracting parties of 
the Common Transit Convention and therefore fully using NCTS at different phases. Only Moldova has 
developed AEO mutual recognition with the EU, though Ukraine, Georgia and Türkiye are preparing to 
do so and therefore developing their national IT systems for that.  

14 

 
 
 
 
The candidate countries will need to progressively connect to or put in place the UCC systems in the 
path towards joining the EU customs territory, and depending on the planned date of accession they may 
also  be required to meet the functionalities of the future customs data hub  proposed in the Customs 
Reform package of 17 May 2023 and join this comprehensive project.  

In the future, in the framework of the preparations of the candidate countries towards enlargement, a 
reporting from them, conformance testing to ensure interoperability between their national systems and 
those of the MS and of the Commission or the data hub, and assessment by the EU on their performance 
will need to take place regularly.  

5.  MANAGEMENT SUMMARY AND CONCLUSIONS 

The UCC IT implementation has been a common project with  joined interest. All stakeholders have 
strongly committed to it from the outset in 2014, when the first UCC WP was adopted.  

In  the  context  of  drafting  this  report,  the  Commission  carefully  assessed  the  data  provided  by  the 
stakeholders  in  the  first  half  of  2023.  It  revealed  a  mixed  picture  of  the  progress  in  the  UCC  IT 
implementation: whilst the Commission is well on track with all its activities, on the side of the Member 
States the overall progress is not so positive and the difference between the Member States became more 
apparent than in the year 2022.  

Member States Progress and Effect of Delays 

There were clear spill-over effects from the delays in the national systems on the delivery of the national 
components  for  the  trans-European  systems,  as  such  impacting  directly  other  Member  States  and 
Economic  Operators.  Some  of  these  delays  are  putting  at  risk  the  deadlines  established  in  the  UCC 
legislation and thereby potentially leading to: (a) infringement cases and (b) underdelivery of the full 
automation of customs procedures and facilitation and as such of the estimated benefits for the private 
sector  and  for  the  other  impacted  Member  States,  both  having  made  huge  investments  to  meet  the 
deadlines. 

To this end, these issues have been considered in the context of the revision of the UCC WP and a new 
approach has been agreed in the new UCC WP, prioritising core processes and providing more time for 
the  finalisation  of  the  full  project  implementation  and  of  the  complex  transition  with  all  economic 
operators, who had also highlighted in the TCG the delays encountered on their side.  

Whilst  the  majority  of  the  Commission’s  project  activities  are  not  dependent  on  national  progress, 
certain types of activities require close collaboration between the Commission and the Member States, 
such  as  the  Conformance  Testing  of  a  national  component  of  a  trans-European  system.  Due  to  this 
collateral  impact,  it  can  be  observed  that  delays  in  the  implementation  of  national  components  by 
specific Member States have an impact on the overall achievements in the delivery of the trans-European 
projects and on the delivery of the UCC in its entirety. 

In compliance with Article 6(4) of the UCC, derogations to certain Member States can only be granted 
if they don’t affect the exchange of information between the Member State to which it is addressed and 
other Member States nor the exchange and storage of information in other Member States for the purpose 
of the application of the customs legislation. The lateness of certain Member States to deploy some of 
the required systems has a negative effect on the level playing field for operators throughout the Union 
since these systems are meant to offer the same facilities to economic operators in all Member States. 
Moreover, due to the nature of the different systems, the changes necessary for the alignment to the 
UCC requirements have repercussions also on other related or dependant IT systems and some have 
significance in the protection of revenues and the fight against unfair and illicit trade. 

The Commission has evaluated the derogation requests from Member States and assessed the delays in 
the trans-European systems. This resulted in 5 derogation decisions and the revision of the UCC WP 
during 2023. In parallel, the Commission also initiated the revision of the MASP-C. The endorsement 
of the new MASP-C 2023 by the Directors-General in the Customs Policy Group and the adoption of 
the new UCC WP by the Commission on 15 December 2023 provides for a revised legal and operational 
framework and for a new baseline to measure the progress for the ongoing projects.  

15 

 
 
 
The  new  UCC  WP  is  the  instrument  to  steer  Member  States  towards  a  common  and  feasible 
implementation  of  the  pending  projects,  leaving  more  flexibility  to  meet  the  final  deadlines  but 
nevertheless keeping the necessary pressure for a full implementation of the UCC WP by 31 December 
2025. As illustrated hereafter in green, the progress in the implementation is continuing towards 2025. 

 Figure 4 – Planning Overview 

To summarise Member States’ progress, it can be observed that about 71% of Member States that 
were granted a derogation for the national entry/import systems and ICS2 Release 2 are expected to 
meet  the  31  December  2023  deadline.  It  should  be  noted  that  the  pending  deployments  are  mostly 
concerning Temporary Storage and the  National Import System (NIS) upgrade. These delays are not 
only impacting trans-European projects such as Centralised Clearance at Import but extend the transition 
period for economic operators, hindering process, data harmonization. 

Delays in the NIS additionally hinder data submission to the Surveillance 3 system. Given its critical 
role in monitoring transactions and trade flows, this has led to adverse effects in specific sectors, such 
as,  the  agricultural  market.  Additionally,  having  the  NIS  in  place  is  essential  to  ensure  a  uniform 
implementation  of  the  Union  Common  Customs  Tariff.  This  means  supporting  Member  States’  risk 
assessment  in  respect  of  customs  legislation  and  having  uniformity  of  customs  controls,  fight 
circumvention of measures and sanctions, protecting the Union from unfair and illegal trade (including 
the requirements related to the Carbon Border Adjustment Mechanism (CBAM)). 

When we look at the total picture against the new UCC WP, we identify three categories for the future 
development: 

Approximately 60% of the Member States have announced that they will be able to deploy  all 
their systems within the project deadlines scheduled in the new UCC WP for the coming two years. 
They have honoured their commitments and in case of a limited delay for only very few systems, they 
seem  to  have  the  appropriate  management  tools  in  place  to  navigate  effectively  around  potential 
setbacks. The deadine of 2025 is at low risk. 

About 25-30% of the Member States have indicated their situations worsened since 2022. It seems 
that the delays have been further accumulating. The revised UCC WP leaves them with more options to 

16 

 
 
 
 
 
 
reduce the degree of non-compliance with the deadlines, however, if they are not engaging into strong 
mitigating actions, they risk failing to meet the project deadlines for one or more systems. The deadline 
of 2025 is at medium risk.  

About  10-15%  of  the  Member  States  have  serious  delays  for  most  remaining  systems.  These 
Member States are struggling to overcome their delays and will most probably miss a number of the 
project deadlines, regardless of the interventions provided. This is due to procurement challenges, no 
agile  project  management,  lacking  a  stable  and  reliable  planning  to  deliver  and  the  persistance  of 
structural issues in the administrations hitting almost all UCC projects. Even with the new UCC WP, 
there remains a significant challenge to accomplish the full IT implementation of the UCC. The deadline 
of 2025 is high risk. 

All stakeholders are to concentrate their efforts and investmentst to the legal timelines set out in the new 
UCC Work Programme. The close monitoring of the Commission at programme as well as project level 
will continue over the next two years and be supported with bilateral and plenary meetings with the 
Member States. For some Member States the recently launched consultancy contract to support Member 
States UCC IT implemenaton could have some impact in facilitating the process, or partly helping in 
reducing  delays.  Member  States  could  also  benefit  from  the  support  provided  under  the  Technical 
Support Instrument 2024, at least for the approved projects. The Commission is moving forward with a 
number of Member States on both tracks. 

Within this context of cumulating delays in Member States’ implementation of the UCC, it is important 
for  the  Commission  to  explore  also  the  potential  use  of  other  instruments  available  to  address  the 
implications for Member States that are significantly behind on their deployment timelines.  

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