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
Date: 2025-10-02
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, 2.10.2025  SWD(2025) 281 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 {COM(2025) 579 final}  
 
 
Table of Contents 

1. Introduction ......................................................................................................................................... 5 

1.1 Background ............................................................................................................................... 6 

1.2 Lessons Learnt and Support from the Commission ................................................................... 7 

1.3 Structure of the document ......................................................................................................... 8 

2. Projects Completed before 2024 ......................................................................................................... 9 

2.1 UCC Registered Exporter System (REX) ............................................................................... 10 

2.2 UCC Customs Decisions ......................................................................................................... 11 

2.3 UCC Direct Trader Access to the European Information Systems (UUM&DS) .................... 12 

2.4 UCC Economic Operator Registration and Identification System Upgrade (EORI2) ............ 13 

2.5 UCC Surveillance 3 (SURV3) ................................................................................................. 14 

2.6 UCC Binding Tariff Information (BTI) .................................................................................. 15 

2.7 UCC Authorised EOs (AEO) Upgrade .................................................................................... 16 

2.8 UCC Information Sheets (INF) for Special Procedures .......................................................... 17 

2.9 UCC Import Control System 2 (ICS2) – Release 1 & 2 .......................................................... 18 

3. Projects to be completed by the end of 2024 ..................................................................................... 19 

3.1 UCC Notification of Arrival (AN), Presentation Notification (PN) and Temporary Storage (TS)

20 

3.2 UCC National Import System (NIS) Upgrade ......................................................................... 42 

3.3 UCC Special Procedures – Component 1 (SP EXP) ............................................................... 49 

3.4 UCC Special Procedures – Component 2 (SP IMP) ................................................................ 55 

3.5 UCC Centralised Clearance for Import (CCI) – Phase 1 ......................................................... 61 

3.6 UCC Guarantee Management (GUM) – Component 1 ........................................................... 69 

3.7 UCC New Computerised Transit System (NCTS) Upgrade – Component 1 .......................... 70 

3.8 UCC Automated Export System (AES) .................................................................................. 86 

3.9 UCC Proof of Union Status (PoUS) – Phase 1 ...................................................................... 107 

4. Ongoing Projects: Detailed Planning and progress Information ..................................................... 109 

4.1 UCC Guarantee Management (GUM) – Component 2 ......................................................... 110 

4.2 UCC Import Control System 2 (ICS2) – Release 3 ............................................................... 116 

4.3 UCC Proof of Union Status (PoUS) – Phase 2 ...................................................................... 124 

4.4 UCC Centralised Clearance for Import (CCI) – Phase 2 ....................................................... 126 

4.5 UCC New Computerised Transit System (NCTS) Upgrade – Component 2 ........................ 132 

5. Annex 1 – Planning Overview – UCC Work Programme Projects ................................................. 140 

6. Annex 2 – Acronyms, Abbreviations & Key Terms ....................................................................... 141 

1 

 
 
 
 
 
 
Table of Figures 

Figure 1: Overview of projects completed before 2024 .......................................................................... 9 
Figure 2: Statistical information – REX ................................................................................................ 10 
Figure 3: Statistical information – CDS ................................................................................................ 11 
Figure 4: Statistical information – EORI2 ............................................................................................. 13 
Figure 5: Statistical information – BTI ................................................................................................. 15 
Figure 6: Statistical information – AEO upgrade .................................................................................. 16 
Figure 7: Statistical information – INF for SP ...................................................................................... 17 
Figure 8: Statistical information – ICS2 – Release 1 and 2 ................................................................... 18 
Figure 9: Overview of projects to be completed by the end of 2024 .................................................... 19 
Figure 10: Project progress and status per milestone – AN .................................................................. 24 
Figure 11: Project progress and status per milestone – PN ................................................................... 28 
Figure 12: Project progress and status per milestone – TS .................................................................... 32 
Figure 13: Actual/Planned dates per milestone – AN – Air transport ................................................... 34 
Figure 14: Actual/Planned dates per milestone – AN – Other modes of transport ............................... 35 
Figure 15: Actual/Planned dates per milestone – PN – Air transport.................................................... 37 
Figure 16: Actual/Planned dates per milestone – PN – Other modes of transport ................................ 38 
Figure 17: Actual/Planned dates per milestone – TS – Air transport .................................................... 40 
Figure 18: Actual/Planned dates per milestone – TS – Other modes of transport ................................ 41 
Figure 19: Project progress and status per milestone – NIS Upgrade ................................................... 46 
Figure 20: Actual/Planned dates per milestone – NIS Upgrade ............................................................ 48 
Figure 21: Project progress and status per milestone – SP EXP ........................................................... 52 
Figure 22: Actual/Planned dates per milestone – SP EXP .................................................................... 54 
Figure 23: Project progress and status per milestone – SP IMP ............................................................ 58 
Figure 24: Actual/Planned dates per milestone – SP IMP ..................................................................... 60 
Figure 25: Project progress and status per milestone – CCI-P1 ............................................................ 66 
Figure 26: Actual/Planned dates per milestone – CCI-P1 ..................................................................... 68 
Figure 27: NCTS-P5 timeline ................................................................................................................ 71 
Figure 28: NCTS-P5 National Administrations entry into operation as of 25 October 2024 ............... 73 
Figure 29: Project progress and status per milestone – NCTS-P5 ........................................................ 78 
Figure 30: Actual/Planned dates per milestone – NCTS-P5 ................................................................. 82 
Figure 31: Conformance tests: Planned Value versus Earned Value – KPI1 – NCTS-P5 .................... 83 
Figure 32: Conformance tests: Planned Value versus Earned Value – KPI2 – NCTS-P5 .................... 84 
Figure 33: NCTS-P5 transitional period ................................................................................................ 85 
Figure 34: AES-C1 timeline .................................................................................................................. 86 
Figure 35: AES-C1 Member States entry into operations as of 19 September 2024 ............................ 89 
Figure 36: Project progress and status per milestone – AES-C1 ........................................................... 94 
Figure 37: Project progress and status per milestone – AES-C2 ........................................................... 98 
Figure 38: Actual/Planned dates per milestone – AES-C1 .................................................................. 101 
Figure 39: Key milestones: Planned Value versus Earned Value – KPI1 – AES-C1 ......................... 102 
Figure 40: Conformance Tests: Planned Value versus Earned Value – KPI2 – AES-C1 ................... 103 
Figure 41: AES-C1 transitional period ................................................................................................ 104 
Figure 42: Actual/Planned dates per milestone – AES-C2 .................................................................. 106 
Figure 43: Actual/Planned dates per milestone – PoUS-P1 ................................................................ 108 
Figure 44: Overview of ongoing projects ............................................................................................ 109 
Figure 45: Project progress and status per milestone – GUM-C2 ....................................................... 113 
Figure 46: Actual/Planned dates per milestone – GUM-C2 ................................................................ 115 
Figure 47: Project progress and status per milestone – ICS2-R3 ........................................................ 120 
Figure 48: Actual/Planned dates per milestone – ICS2-R3 ................................................................. 123 
Figure 49: Actual/Planned dates per milestone – PoUS-P2 ................................................................ 125 
Figure 50: Project progress and status per milestone – CCI-P2 .......................................................... 129 
Figure 51: Actual/Planned dates per milestone – CCI-P2 ................................................................... 131 
Figure 52: NCTS-P6 timeline .............................................................................................................. 132 
Figure 53: Project progress and status per milestone – NCTS-P6 ...................................................... 137 

2 

 
 
Figure 54: Actual/Planned dates per milestone – NCTS-P6 ............................................................... 139 
Figure 55: Planning Overview – UCC WP Projects  .......................................................................... 140 

3 

 
 
 
 
 
Table of Tables  

Table 1: Comparison of Planned and Actual Dates – REX-R1 ............................................................. 10 
Table 2: Comparison of Planned and Actual Dates – CDS ................................................................... 11 
Table 3: Comparison of Planned and Actual Dates – UUM&DS ......................................................... 12 
Table 4: Comparison of Planned and Actual Dates – EORI2 ............................................................... 13 
Table 5: Comparison of Planned and Actual Dates – SURV3 .............................................................. 14 
Table 6: Comparison of Planned and Actual Dates – BTI .................................................................... 15 
Table 7: Comparison of Planned and Actual Dates – AEO upgrade ..................................................... 16 
Table 8: Comparison of Planned and Actual Dates – INF for SP ......................................................... 17 
Table 9: Comparison of Planned and Actual Dates – ICS2 – Release 1 and 2 ..................................... 18 
Table 10: Detailed responses from Member States – AN ..................................................................... 24 
Table 11: Detailed responses from Member States – PN ...................................................................... 28 
Table 12: Detailed responses from Member States – TS ...................................................................... 32 
Table 13: Detailed responses from Member States – NIS Upgrade ...................................................... 46 
Table 14: Detailed responses from Member States – SP EXP .............................................................. 52 
Table 15: Detailed responses from Member States – SP IMP .............................................................. 57 
Table 16: Detailed responses from Member States – CCI-P1 ............................................................... 66 
Table 17: Comparison of Planned and Actual Dates – GUM-C1 ......................................................... 69 
Table 18: Detailed responses from Member States – NCTS-P5 ........................................................... 78 
Table 19: Risk Assessment by the Commission: NCTS-P5 .................................................................. 79 
Table 20: Detailed responses from Member States – AES-C1 ............................................................. 94 
Table 21: Risk Assessment by the Commission: AES-C1 .................................................................... 95 
Table 22: Detailed responses from Member States – AES-C2 ............................................................. 98 
Table 23: Detailed responses from Member States – PoUS-P1 .......................................................... 107 
Table 24: Detailed responses from Member States – GUM-C2 .......................................................... 113 
Table 25: Detailed responses from Member States – ICS2-R3 ........................................................... 120 
Table 26: Detailed responses from Member States – PoUS-P2 .......................................................... 124 
Table 27: Detailed responses from Member States – CCI-P2 ............................................................. 129 
Table 28: Detailed responses from Member States – NCTS-P6 ......................................................... 136 
Table 29: Abbreviations and Acronyms .............................................................................................. 142 

4 

 
 
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 (BC), business process modelling, Vision Document 
(VIS)/Project  Charter,  and  conformance  testing  are  defined  in  the  Multi-Annual  Strategic  Plan  for 
Customs (MASP-C)4. 

The first, second, third, fourth and fifth UCC Annual Progress Report5 were published on 13/12/2019, 
14/12/2020, 14/12/2021, 10/02/2023, and 09/09/2024, 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,  the  Commission  continued  with  the 
methodology used in previous years, gathering information on the UCC projects state of play from the 
Member States and the Project Managers in Directorate General for Taxation and Customs Union (DG 
TAXUD). 

This annual report covers a reflection of the progress status achieved until 30 June 2024, including 
a view on the expected progress by 31 December 2024 and with more recent updates in several 
cases  due  to  deployments  planned  for  December  2024  with  a  view  to  have  a  full  picture  of  the 
progress made in 2024. 

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) 2023/2879 of 15 December 2023 establishing the Work Programme 
relating to the development and deployment for the electronic systems provided for in the Union Customs Code, 
OJ L, 2023/8568, 22.12.2023, https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32023D2879.  
4 Electronic Customs Multi-Annual Strategic Plan for Customs 2023 Revision, Ref. Ares(2023)8102089, 
28.11.2023, https://taxation-customs.ec.europa.eu/system/files/2023-12/000.%20MASP-
C_Rev.%202023_Main%20Body_v1.0.pdf.  
5 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/TXT/?uri=CELEX:52023DC0068;  
2023: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52024DC0395.   

5 

 
 
 
 
The main outcomes of the progress reporting exercise for 2024 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.  

1.1 BACKGROUND 

To support the electronic transition process towards a fully digital customs environment, the UCC WP 
outlines seventeen electronic systems divided into three categories:  

i)  Eleven  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);  
ii)  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 UCC WP and MASP-C set the baseline milestones for each electronic system and this document 
provides progress updates regarding their advancement. For this purpose, the Commission oversaw the 
collection of additional reporting information through the following sources: 

(1) National Planning that the Member States are required to provide bi-annually (January and June): 

The information gathered by the Member States’ customs authorities consists of detailed national project 
plans that include concrete dates, status, and progress of the milestones set in the UCC WP.  

(2) EU survey launched in February 20246 amongst the Member States to capture the progress: 

The information gathered from the survey consists of qualitative comments regarding the assessment of 
risk, delays, and reasons for any such delays, as well as the mitigating measures planned and/or taken 
in relation to the projects listed in the UCC WP. Finally, the Member States also provided information 
on the lessons learnt during the development of the projects. 

(3) the projects’ state of play provided by the Project Managers in DG TAXUD. 

(4) bilateral high-level meetings between DG TAXUD and the Member States Customs IT Directorates 
on the state of play of the UCC IT Implementation:  

DG  TAXUD  conducted  bilateral  high-level  meetings  with  Member  States  Customs  IT  Directorates, 
focusing on having a conversation with each Member State 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.  

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

In the framework of the Coordination Programmes, specific information was gathered from the more 
detailed project reporting and monitoring programmes in place since 2020 for the core decentralised 
trans-European systems in the area of transit and export. 

The 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 refer to the Commission’s activities 
only when it is central, while for the systems that involve national input, and even in some cases 

6 The information was collected between February 2024 and May 2024. 

6 

 
 
 
 
national  components,  the  analysis  refers  to  both  the  Member  States’  and  Commission’s 
activities; 

•  For the national systems, only Member States’ activities are reported. 

From this perspective, UCC Notification of Arrival (AN), UCC Presentation Notification (PN), UCC 
Temporary  Storage  (TS),  UCC  National  Import  System  (NIS)  Upgrade,  UCC  Special  Procedures  – 
Component 1 (SP EXP), UCC Special Procedures – Component 2 (SP IMP), UCC Centralised Clearance 
for Import – Phase 1 (CCI-P1), UCC Guarantee Management – Component 1 (GUM-C1), UCC New 
Computerised  Transit  System  upgrade  –  Component 1  (NCTS-P5),  UCC  Automated  Export  System 
(AES) and UCC Proof of Union Status – Phase 1 (PoUS-P1) are scheduled to be completed by the end 
of 2024. 

In view of all this, close and continuous communication has been maintained with the Member States 
to regularly monitor the progress of the UCC projects and to provide the necessary support in order to 
meet the deadlines.  

1.2 LESSONS LEARNT AND SUPPORT FROM THE COMMISSION 

In the EU’s survey section devoted to lessons learnt and support and assistance from the Commission, 
the Member States provided the Commission with findings in relation to the development of the project. 
These remarks  provide useful guidance for improving the future performance of the systems for the 
2025 deadline 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.  

Concerning the best practices and challenges encountered at national level, the Member States assessed 
strong management and clear organisation, together with previous experience in other UCC projects as 
valuable to ensure an  effective systems administration. With respect to planning, the Member States 
pointed out the short timeframes and parallel development of multiple projects leading to risks of delay. 
To mitigate this, the Member States highlighted the importance of having a well-structured and realistic 
plan  considering  not  only  national  capacity  (i.e.,  resources  available),  but  also  other  stakeholders 
involved (i.e., customs officers, EOs, contractors) and external factors (i.e., changes in requirements, 
delays in integrated systems). In this line, good teamwork and trustful cooperation at EU and national 
level has proved essential to ensure the completion of the projects. Furthermore, a timely call for tender 
procedures  and  procurement  as  well  as  coordination  with  service  providers  were  proved  to  be 
fundamental. In addition, the main obstacles associated with the implementation of the systems included 
high  dependency  between  integrated  projects  resulting  in  high  complexity  and  delays,  changes  in 
supporting platforms, and the need to comply with the updated customs regulation and related technical 
documentation. The Member States reported the adoption of Agile and iterative methodologies during 
the  development  phase,  the  implementation  of  integrated  systems  solutions,  and  emphasised  the 
importance of testing with other Member States and EOs. Moreover, the Member States underlined the 
relevance  of  scheduling  a  migration  window,  while  transitioning  the  EOs  iteratively  or  using  a  ‘big 
bang’ approach to resolve issues promptly. Lastly, the Member States indicated the preparation of guides 
and e-learning materials, along with organising coordination meetings as useful tools to ensure that the 
information is effectively disseminated to the EOs and customs officials. 

Regarding the support and assistance from the Commission, the Member States assessed the continued 
coordination and technical dialogue with DG TAXUD as essential during testing and implementation 
periods, particularly when referring to EOs guidance. In this line, the Member States noted that it would 
benefit  from  a  timely  communication  for  queries  raised  through  Programme  Information  and 
Collaboration  Space  (PICS)  as  well  as  in  case  of  technical  issues.  Moreover,  the  Member  States 
indicated  that  stable  customs  legislation  and  related  technical  documents  would  assist  with  the 
implementation  of  the  UCC  projects.  The  Member  States  appreciated  the  support  provided  by  the 
Commission through bilateral and project group meetings and would welcome further information in 
terms of guidelines and trainings as well as the sharing of best practices from other Member States. As 

7 

 
 
a  closing  remark,  the  Member  States  shared  an  interest  in  receiving  additional  business  support  and 
expertise, together with project management assistance from the Commission.  

1.3 STRUCTURE OF THE DOCUMENT 

The report is structured as follows: 

•  Section 1: Introduction; 
•  Section 2: Projects completed before 2024; 
•  Section 3: Projects to be completed by the end of 2024; 
•  Section 4: Projects ongoing during 2024.  

8 

 
 
 
2. PROJECTS COMPLETED BEFORE 2024 

Figure 1 provides the overview of the UCC projects completed before 2024: 

Figure 1: Overview of projects completed before 2024 

9 

 
 
 
 
 
2.1  UCC REGISTERED EXPORTER SYSTEM (REX) 

Deployment 

1 January 2017 

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) countries7 and on EU 
EOs in partner countries CH, NO, and 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-R18 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 2024:  

Active REX registrations9 

79,196 

108,12610 

Non-EU countries11 (REX BC) module 

Member States (REX MS) module 

Applications submitted in the REX TP by EU Traders 

10,191 
Applications 

Figure 2: Statistical information – REX 

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 

7 Countries benefiting from the EU GSP that provides preferential access to the EU market. 
8 For the scope of EU GSP, in parallel with the GSP scheme for of CH, and NO as partner countries. 
9 Aggregated information from 01/01/2017 until May 2024. 
10 It includes 839 registrations from Partner Countries CH, NO, and TR, as well as AD and SM. 
11 Beneficiary countries of the EU, Overseas Countries and Territories, as well as CH GSPs, NO GSPs, TR GSPs. 

10 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date31/03/201530/06/201531/12/201601/01/201701/01/2017Technical SpecificationsDeployment 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.2 UCC CUSTOMS DECISIONS 

Deployment 

2 October 2017 

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. The Member States also 
have the right to use CDS to manage their national customs decisions if it wishes to do so. The project 
was fully deployed on 2 October 2017.  

Some statistical information on the use of CDS – situation as of May 2024: 

CDS Application and Decision Statistics  

Number of applications submitted  

Average number of applications per working day 

2023 
9,779 

44 

202412 
5,637 

61 

Number of decisions taken 

6,748 

4,076 

2.2.1 Overview of Project Progress 

Figure 3: Statistical information – CDS 

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 

12 Information from January to May 2024. 

11 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date31/12/201531/12/201530/09/201702/10/201702/10/2017Technical SpecificationsDeployment 
 
 
 
 
 
 
 
 
 
 
 
 
2.3 UCC DIRECT TRADER ACCESS TO THE EUROPEAN INFORMATION 

SYSTEMS (UUM&DS) 

Deployment 

2 October 2017 

The  Direct  Trader  Access  to  the  European  Information  Systems  system  comprises  of  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 to cover the needs 
of other UCC and non-UCC projects, such as for the PoUS, the Carbon Border Adjustment Mechanism 
(CBAM) and the Central Electronic System of Payment information (CESOP). 

2.3.1 Overview of Project Progress 

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

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

12 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date31/12/201530/09/201530/09/201702/10/201702/10/2017Technical SpecificationsDeployment 
 
 
 
 
2.4 UCC ECONOMIC OPERATOR REGISTRATION AND IDENTIFICATION 

SYSTEM UPGRADE (EORI2) 

Deployment 

5 March 2018 

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 31 March 2024: 

EORI2 Records 

Q4 2023 
8,786,95913 
161,941 
1,144 

Q1 2024 
8,907,18214 
158,394 
10,729 

Total Valid Records 
New Valid Records 
Deleted Records 

2.4.1 Overview of Project Progress 

Figure 4: Statistical information – EORI2 

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 

13 Aggregated information from October 2019 until December 2023. 
14 Aggregated information from October 2019 until 31 March 2024. 

13 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/06/201631/07/201628/02/201805/03/201805/03/2018Technical SpecificationsDeployment 
 
 
 
 
 
 
 
 
 
 
 
2.5 UCC SURVEILLANCE 3 (SURV3) 

Deployment 

1 October 2018 

The Surveillance 3 system (SURV3) introduces an upgrade to the standard exchange of information in 
the earlier Surveillance 2 system (SURV2) to align the system with UCC requirements. This database 
records and centralises all EU trade data (imports for free circulation 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 
potential15.  

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 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 

15 Please refer to section 3 for more detailed information. 

14 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/09/201630/09/201630/09/201801/10/201801/10/2018Technical SpecificationsDeployment 
 
 
 
 
 
2.6 UCC BINDING TARIFF INFORMATION (BTI) 

Deployment Phase 1 – Step 1  1 March 2017 
Deployment Phase 1 – Step 2  2 October 2017 
1 October 2019 
Deployment Phase 2 

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 that it imports or exports from the EU.  

Concerning the status of the project, the first phase was completed on 2 October 2017 and the second 
phase started on 1 October 2019. The integration of the system with the EU CTP was also completed on 
1 October 2019. Additionally, the TP (central EU or national) is used by all traders across all Member 
States, and all BTI applications and decisions are transmitted electronically. 

Some statistical information on the use of the BTI system – situation until 31 May 2024: 

BTI applications submitted by 
EOs16 

BTI decisions issued by 
custom authorities17 

Digitalisation Progress 

177,000 

30,000 
via the EU TP 

147,000 
via the national TP 

168,000 

8 processes digitalised  
(including 20 sub-processes) 

2.6.1 Overview of Project Progress 

Figure 5: Statistical information – BTI 

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 

16 Aggregated information from 1 October 2019 until 31 May 2024. 
17 Aggregated information from 1 October 2019 until 31 May 2024. 

15 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/06/201610/06/201621/01/201701/03/201701/03/201730/06/201602/09/201625/02/201702/10/201702/10/201730/06/201830/06/201801/07/201901/10/201901/10/2019Technical SpecificationsDeployment 
 
 
 
 
 
 
 
 
 
 
 
2.7 UCC AUTHORISED EOS (AEO) UPGRADE 

Deployment Phase 1 – Part 1 
Deployment Phase 1 – Part 2 
Deployment Phase 2 

5 March 2018 
1 October 2019 
16 December 2019 

Following  the  legal  changes  adopted in  the  UCC,  the  AEO  upgrade aims to  enhance the  process  of 
applications and authorisations for the 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. Phase 1 – Part 1 encompassed the submission of 
AEO applications and Phase 1 – Part 2 the decision-making process. Phase 2 encompassed the remaining 
processes. 

Some statistical information on the use of the AEO system – situation until 31 March 24: 

AEO performance indicators 

AEO Applications 

AEO Authorisations 

Submitted 
New 
New 
Revoked 

Q4 2023 
105 
155 
162 
109 

Q1 2024 
91 
163 
137 
126 

Figure 6: Statistical information – AEO upgrade 

2.7.1 Overview of Project Progress 

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

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

16 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date31/03/201631/03/201628/02/201805/03/201805/03/201831/12/201831/12/201829/07/201901/10/201901/10/201931/12/201831/12/201806/11/201916/12/201916/12/2019Technical SpecificationsDeployment 
 
 
 
 
 
 
 
 
2.8 UCC INFORMATION SHEETS (INF) FOR SPECIAL PROCEDURES 

Deployment 

1 June 2020 

The aim of the Information Sheets (INF) for 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 improved the monitoring and control amongst customs offices.  

The INF central system was successfully deployed on 1 June 2020, and by October 2020, all Member 
States were actively using the system.  

The INF Specific TP 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 holds regular meetings to address any remaining business issues. 

Some statistical information on the use of the INF for SP system – situation until June 2024: 

INF requests created 
by EOs18 

INFs treated and 
processed by authorities19 

Averaged number of processed INF 
per working day 

82,752 

76,092 

2020 
48 

202420 
80 

Figure 7: Statistical information – INF for SP 

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 for SP 

18 Aggregated information from June 2020 until June 2024. 
19 Aggregated information from June 2020 until June 2024. 
20 Information until May 2024. 

17 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/06/201830/06/201829/05/202001/06/202001/06/2020Technical SpecificationsDeployment 
 
 
 
 
 
 
 
 
 
 
2.9 UCC IMPORT CONTROL SYSTEM 2 (ICS2) – RELEASE 1 & 2 

Deployment ICS2-R1  15 March 2021 
Deployment ICS2-R2  1 March 2023 

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 coordinated 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 (ICS2-R1) 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). The cut-off date for ICS2-R1 
related operations in production was on 19 April 2024. 

Release 2 (ICS2-R2) covers the implementation of further ENS obligations and related business and 
risk management processes for all the goods in full air (postal, express, general cargo) traffic. The ICS2-
R2 system was deployed and became operational on 1 March 2023, as originally planned and is fully 
operational. 

For Release 3 (ICS2-R3), please refer to Section 4.2. 

Some statistical information on the use of the ICS2 Release 1 and 2 – situation until 17 May 2024: 

ENS filing messages 

Period 
01/03/21 – 31/12/21  
01/01/22 – 31/12/22  
01/01/23 – 31/12/23  
01/01/24 – 17/05/24  
Total  

Release 1 
98,369,662  
293,101,713  
214,849,041  
36,794  
606,357,210  

Release 2 
-  
-  
108,269,533  
142,648,761  
250,918,294  

Total 
98,369,662  
293,101,713  
323,118,574  
142,685,555  
857,275,504  

Figure 8: Statistical information – ICS2 – Release 1 and 2 

2.9.1 Overview of Project Progress 

Table 9 highlights that there were no divergences in the planning compared to the dates set in the UCC 
WP. 

Table 9: Comparison of Planned and Actual Dates – ICS2 – Release 1 and 2 

18 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/06/201801/09/202105/09/202115/03/202115/03/202130/06/201812/11/2019N/A01/03/202301/03/2023Technical SpecificationsDeployment 
 
 
 
 
 
3. PROJECTS TO BE COMPLETED BY THE END OF 2024 

Figure 921 provides an overview of the deployment windows of the UCC projects to be completed by 
the end of 2024: 

Figure 9: Overview of projects to be completed by the end of 2024 

21  For  NIS  upgrade  and  SP  IMP  projects,  where  Article  2(4a)  of  Commission  Delegated  Regulation  (EU) 
2015/2446 applies, Member States have until 01/07/2024 to deploy the system. 

19 

 
 
 
 
 
 
 
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 Notification of 
Arrival (AN), Presentation Notification (PN), and Temporary Storage (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 project also considers that customs authorities may accept port or airport systems or other available 
methods of information for the notification of the arrival of the means of transport, the presentation of 
goods  to  customs,  and/or  the  temporary  storage  declarations.  Therefore,  in  this  report,  a  distinction 
between  air  transport  and  other  modes  of  transport  is  provided.  The  other  modes  of  transport  cover 
maritime transport or inland waterways, road, and rail transport. 

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 for air transport and 29 
February 2024 for other modes of transport. 

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 or high risk.  

The  risk-causing  factors  of  delay  recurrently  identified  by  Member  States  encompass  the 
interdependencies  between  core  and  supporting  systems,  amplified  by  the  upgrades  of  supporting 
systems, delays in public procurement procedures, limitations  in the contractor’s capacity, and EOs’ 
readiness.  In  addition  to  the  inherent  complexity  of  the  project,  other  contributing  factors  include 
resource constraints, parallel development of other customs systems, and prioritisation of export and 
transit projects. 

The  Member  States  reported  the  implementation  of  measures  to  mitigate  deployment  delays.  Some 
examples  include  allocating  additional  resources  to  the  project,  strengthening  coordination  with 
contractors, reinforcing assistance to  EOs, and/or implementing an Agile methodology to reduce the 
development timeframe. 

The above summary also applies to PN and TS. 

At the time of writing, AT, BE, BG, CZ, DE, DK, EE, ES, FI, FR, HU, IE, LT, LU, LV, NL, PL, SE, 
SI,  and  SK  indicated  that  the  AN  system  was  deployed  for  all modes  of transport.  GR,  HR,  and  IT 
deployed air transport, while for maritime  transport: GR and HR aim to deploy within the deadline, 
while IT plans to deploy beyond the deadline. From the remaining Member States, CY, MT, PT, and 
RO  indicated  the  deployment  for  both  air  and  maritime  transport  as  delayed  beyond  the  deadline. 
Additionally, PT submitted a written notification asking for a derogation under Article 6(4) of the UCC 
to DG TAXUD concerning the delay of AN beyond the deadline. 

20 

 
 
 
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 of AN 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 Member States requesting it and in view of a set 
of common assessment criteria.  

In this light, the Commission adopted an Implementing Decision (EU) 2023/23522 on 1 February 2023, 
granting a derogation to AT, BE, BG, CY, CZ, DK, EE, ES, FR, GR, HR, HU, LU, MT, NL, PL, PT, 
RO, SE, SI, and SK for AN provided for in Article 133 of the  UCC. The derogation applied 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 29 February 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 aligned with ICS2-R2 and  the date specified in the 
UCC WP 2023 for ICS2-R3, respectively, as the projects are closely linked23.  

Detailed Responses24: 

Table 10 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

Risk 
Level 

N/A 

MS 

AT 

BE 

BG 

Low 

CY 

High 

Additional Comments 

AT reported that the AN system has been operational for air transport since 
01/07/2023.  
BE informed that the AN system was deployed on 30/06/2023 for air transport 
and on 03/06/2024 for maritime transport.  
BG shared that the AN system was deployed on 01/03/2023 for air transport 
and for maritime transport on 03/06/2024, in line with ICS2-R3. BG used an 
Agile  and  iterative  approach  for  the  development  of  the  system  by 
implementing two technological frameworks: The Open Group Architecture 
Framework (TOGAF) / Adaptive Development Methodology (ADM) and the 
Rational Unified Process (RUP). 
CY  assessed  a  high  risk  related  with  the  timely  delivery  of  the  project; 
therefore,  the  project  is  being  delayed  beyond  the  deployment  deadline  and 
planned  for  30/10/2024.  The  delays  are  attributed  primarily  to  procurement 
issues and the complex interdependencies among core and supporting systems, 
including replacement or upgrades to TARIFF, Quota Management (QUOTA), 
Manifest,  Accounting,  Customs  and  Tax  Warehouses  Systems,  and  the 
National  Registration  and  Representation  TP.  Additionally,  coordination 
between contractors and lack of EOs readiness has caused further delays. To 
mitigate  the  delays,  CY  shared  that  it  has  implemented  corrective  project 
management measures, added additional resources, and strengthened support 
for  EOs,  which  have  improved  the  project  progress.  CY  reported  that  the 
Graphical User Interface (GUI) has been in production since December 2023, 
but  due  to  the  EOs’  lack  of  readiness  and  limited  Business  to  Government 
(B2G) service availability, an onboarding window was established.  

22 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). 
23 Considering the link with ICS2-R3 for maritime transport, the Member States that were granted a derogation 
have the possibility to deploy the system until 03/06/2024. 
24 Fields marked in grey mean no information was provided. 

21 

 
 
 
 
 
MS 

Risk 
Level 

CZ 

N/A 

DE 

N/A 

DK 

Low 

EE 

N/A 

ES 

Low 

FI 

FR 

N/A 

N/A 

GR 

Low 

HR 

HU 

N/A 

IE 

Medium 

IT 

Medium 

N/A 

LT 

LU 

LV 

Additional Comments 

CZ  informed  that  the  AN  system  for  both  air  and  maritime  transport  was 
deployed on 05/12/2023. 
DE shared that the AN system was deployed and will be covered by the ICS2 
system. Therefore, the EOs will follow the ICS2-R2 and ICS2-R3 planning, 
especially in relation to the Shared Trader Interface.  
DK reported that the AN system, which will support the ICS2-R3 onboarding 
plan (maritime, road, and rail), was deployed on 06/11/2023 for air transport 
and on 25/05/2024 for maritime transport. Additionally, DK shared it has been 
using an Agile approach.  
AN  was  deployed  on  01/10/2023  for  air  transport  and  on  03/06/2024  for 
maritime transport. 
ES reported that the AN system for air transport was deployed on 01/03/2023 
and  for  maritime  transport  on  03/06/2024  using  an  Agile  development 
approach.  
FI shared that the AN system was deployed in Q1 2023 for air transport and in 
Q2 2024 for maritime transport. 
FR informed that the AN system for air transport was deployed on 30/06/2023 
and for maritime on 03/06/2024. 
GR reported that the AN system was deployed for air transport in Q4 2023 and 
the deployment for maritime transport is planned for Q2 2024. Additionally, 
GR informed that this project was included in the development of the national 
system for ICS2-R2 and that it is using and Agile approach.  
HR reported that the AN system was deployed on 01/07/2023 for air transport 
and plans to deploy the maritime transport on 03/06/2024. 
HU informed that the AN system for all modes of transport was deployed on 
02/04/2024.  
IE shared that the AN system was deployed on 01/07/2023 for air transport and 
on 03/06/2024 for maritime transport. Additionally, it plans to submit AN with 
ICS2 CR for Roll-on/Roll-off (RoRo) traffic by the end of 2024. Consequently, 
IE  indicated  a  medium  risk  level  for  the  project  delivery  since  effective 
communication  and  changes  to  national  requirements  for  RoRo  traffic  are 
needed to integrate the system with ICS2 CR. 
IT reported that the AN system was deployed on 13/12/2022 for air transport, 
and the deployment of maritime transport is scheduled for 03/06/2024, together 
with  the  release  of  ICS2-R3 25.  IT  assessed  a  medium  risk  for  the  timely 
completion of the project, attributing this to the need to tailor the IT system to 
the specific requirements of each mode of transport. IT shared it has updated 
its National Planning based on the revised UCC WP.  
LT shared that the AN system for air transport was deployed on 01/03/2023 
and for maritime transport on 03/06/2024. 

LU informed that the AN system was deployed on 01/03/2023 for air transport. 

N/A 

LV reported that the AN system was deployed on 24/09/2017 for air transport 
and on 01/03/2023 for maritime transport. 

25 The information shared by IT in the survey has been updated based on a bilateral meeting between IT and DG 
TAXUD held on 06/05/2024. 

22 

 
 
 
 
 
 
MS 

Risk 
Level 

MT 

Low 

NL 

Low 

PL 

High 

PT 

High 

RO 

SE 

Low 

Additional Comments 

MT  informed  that  the  deployment  of  the  AN  system  is  delayed  beyond  the 
UCC  WP  deadline  due  to  delays  in  recreating  the  environments  where  the 
system can be implemented. MT  has undertaken discussions with the Malta 
Information Technology Agency (MITA) and the supplier to resolve this issue 
and  mitigate  the  delay.  This  resulted  in  continuous  communication  with  all 
stakeholders and efforts to have the necessary environment in place soon. In 
addition, MT adopted an iterative approach encompassing configurations, User 
Acceptance  Testing  (UAT),  training,  and migration.  Overall,  MT  noted  that 
the supplier provided technical specifications, and it anticipates going live in 
January 2025 for all modes of transport26. 
NL shared that the AN system was deployed on 30/06/2023 for air transport 
and on 27/05/2024 for maritime transport. The AN data is received through the 
Shared Trader Interface and CR, while National Export System (NES) handles 
the  processing  of  this  information.  To  develop  NES,  NL  is  using  an  Agile 
approach  with  planned  three-month  increments  focused  on  developing  the 
features that provide the most business value. 
PL shared that the AN system was deployed on 01/07/2023 for air transport 
and  03/06/2024  for  maritime  transport.  PL  clarified  that  the  AN  system  is 
implemented in ICS2 and integrated in the import system. The delays in the 
import system consequently postponed the implementation of the project. PL's 
import  system  is  an  extensive  platform  that  manages  nearly  all  customs 
procedures,  including  the  AN  process.  The  lack  of  experienced  experts, 
primarily due to retirements, resulted in the delayed publication of technical 
and  functional  specifications.  PL  used  the  system  that  was  in  operations  to 
uphold  operational  continuity  and  ensure  compliance  with  the  data  scope 
outlined in the UCC requirements. 
PT assessed the project as being delayed beyond the UCC WP deadline. The 
primary  reasons  for  the  delay  were  detailed  in  PT’s  derogation  request  in 
accordance with Article 6(4) of the UCC, submitted on 04/12/2023. Besides, 
the project’s difficulty and risk increased due to (a) the implementation of a 
new national system requiring integration between airport and port authorities; 
(b) the intricate interdependencies of various national and EU systems; and (c) 
the development halt from mid-2023 to the end of 2023 due to procurement 
and  tendering  difficulties,  particularly  in  the  renewal  of  the  supplier’s 
contracts.  To  mitigate  the  abovementioned  delays,  an  Agile  development 
approach will be implemented to streamline the implementation timeframe. PT 
noted  that  despite  the  delay  in  the  implementation  of  the  project, 
interdependence with ICS2 is guaranteed as the arrival notification is processed 
electronically in the old system and is duly sent to the common repository. 
Furthermore,  the  National  Planning  was  revised  to  include  updates  to  the 
conformance testing period with the EOs, and adjustments to the deployment 
date for all modes of transport, now set on 28/10/2024.  
RO informed that the AN system plans to be deployed on 01/05/2024 for air 
transport and on 16/12/2024 for maritime transport.  
SE indicated the use of the central ICS2 system for AN and anticipates that all 
EOs will be operational as scheduled. SE conveyed via its National Planning 
that  the  AN  system  was  deployed  for  air  transport  on  01/03/2023  and  for 
maritime transport on 03/06/2024. 

26 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 

23 

 
 
 
 
 
MS 

Risk 
Level 

SI 

N/A 

SK 

N/A 

Additional Comments 

SI  shared  that  the  AN  system  for  air  transport  has  been  operational  since 
01/03/2023 and for the maritime transport since 02/06/2024.  
SK reported that the AN system was deployed on 01/03/2023 for air transport. 
For other modes of transport, SK will use the central ICS2 CR system.  

Table 10: Detailed responses from Member States – AN 

Figure 1027 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 10: Project progress and status per milestone – AN 

27  The  progress  shown  in  the  figure  considers  both  the  air  and  maritime  transport  or  inland  waterways. 
Additionally, ‘Deployment’ encompasses both deployment and operations milestones. 

24 

 
 
 
 
 
 
 
Presentation Notification (PN) 

Summary from the Member States: 

Please see also the summary from AN. 

For the PN system, Member States were requested to comply 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 time of writing, AT, BE, BG, CZ, DE, DK, EE, ES, FI, FR, HR, HU, IE, LT, LU, LV, NL, SE, 
and  SI  indicated  the  system  as  deployed  for  all  modes  of  transport.  GR,  IT,  and  SK  deployed  air 
transport, while for the other modes of transport: GR plans to deploy within the deadline, while IT and 
SK will extend beyond. From the remaining Member States, CY, MT, PL, PT, and RO indicated the 
project being delayed beyond the deployment deadline for all modes of transport. Additionally, PT and 
SK  submitted  a  written  notification  asking  for  a  derogation  under  Article  6(4)  of  the  UCC  to  DG 
TAXUD concerning the delay of PN beyond the 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. 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 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) 2023/23428 
granting a derogation to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HR, HU, LU, MT, NL, PL, PT, RO, 
SE, SI, and SK for the PN system provided for in Article 133 of the UCC. The derogation applied 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 29 February 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. This differentiation by transport mode aligned with ICS2-R2 and 
the date specified in the UCC WP 2023 for ICS2-R3, respectively, as the projects are closely linked29. 

Detailed Responses: 

Table 11 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

Additional Comments 

AT 

N/A 

AT informed that the PN system was deployed on 01/06/2023. 

BE 

Low 

BE shared that the PN system was deployed on 05/07/2023 for all modes of 
transport, and it is aiming the enter operations for other modes of transport on 
31/12/2024. The delay is primarily due to dependencies on other projects such 
as  ICS2-R3  and  PoUS,  compounded  by  a  shortage  of  critical  resources 
including business analysts and IT developers. To mitigate the delay, BE has 

28 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). 
29 Considering the link with ICS2-R3 for maritime transport, inland waterways, road and rail transport, the Member 
States that were granted a derogation have the possibility to deploy the system until 03/06/2024. 

25 

 
 
 
 
MS 

Risk 
Level 

Additional Comments 

redistributed  IT  resources  to  prioritise  critical  needs  in  the  short  term.  BE 
informed that the Minimum Viable Products (MVPs) with core functionalities 
for  PN  and  TS  are  currently  in  production  and  specific  functionalities  for 
maritime and other modes of transport are still being developed. In addition, 
BE is using an Agile framework for the system’s development.  
BG reported that the PN system was deployed on 10/11/2023 for all modes of 
transport, and that the system is part of the NIS upgrade. 

BG 

N/A 

CY 

High 

Same response as for AN. 

CZ 

N/A 

DE 

N/A 

DK 

Low 

EE 

N/A 

ES 

Low 

N/A 

FI 

FR 

GR 

Low 

CZ informed that the PN system for all modes of transport was deployed on 
05/12/2023.  
DE  shared  that  the  PN  system  was  deployed  on  06/03/2021  and  has  been 
integrated as part of NES of its national IT system ‘Automated Customs Tariff 
and Local Processing Application System’ (ATLAS) (Release 9.1).  
DK informed that the PN system was deployed on 06/11/2023 for air transport 
and on 25/05/2024 for the other modes of transport. DK is conducting meetings 
with the EOs, a measure intended to ensure that the import flow, as well as the 
Safety and Security risk analysis, remain fully operational throughout 2024. In 
addition, DK shared that used an Agile approach for the project development. 
EE shared that the PN system was deployed on 15/03/2021 for all modes of 
transport. 
ES reported that the PN system was deployed on 01/01/2024 for air transport 
and on 01/03/2024 for other modes of transport, with the EOs migrating to the 
new system. ES shared that it used an Agile development approach. 
FI shared that the PN system was deployed in Q1 2021 for air transport and for 
other modes of transport in Q2 2024. 
FR informed that the PN system was deployed on 06/03/2024 for air transport 
and on 03/06/2024 for other modes of transport.  
GR informed that the PN system for air transport was deployed in Q4 2023 and 
plans to deploy for other modes of transport in Q2 2024. The PN functionality 
was incorporated in the national implementation of ICS2-R2 and ICS2-R3. In 
addition, GR is using and Agile approach for the project development.  

HR 

HR reported that the PN system was deployed on 01/03/2023.  

HU 

N/A 

Same response as for AN.  

IE 

Medium 

IE  shared  that  the  project  was  deployed  on  23/11/2020  for  all  modes  of 
transport and plans to integrate the PN system with ICS2 CR for RoRo traffic 
by the end of 2024.  Consequently,  IE indicated a medium risk level for the 
delivery of the system since the integration with ICS2 CR requires changes to 
national systems. 

IT 

Medium  Same response as for AN. 

LT 

LU 

N/A 

LT shared that the PN system was deployed on 28/02/2023 for all modes of 
transport. 

LU reported that the PN system was deployed on 10/01/2023 for air transport.  

26 

 
 
 
 
 
MS 

Risk 
Level 

LV 

N/A 

Additional Comments 

LV informed that the PN system for all modes of transport was deployed on 
24/09/2017 and updated in 202230. 

MT 

Low 

Same response as for AN. 

NL 

Low 

PL 

High 

NL informed that the PN system was deployed on 01/12/2023 for air transport 
and on 27/05/2024 for other modes of transport. NL used an Agile approach, 
with three-month increments to develop features that offer the most business 
value. 
PL shared that the project is delayed beyond the defined deployment deadline 
and  aims  to  deploy  the  PN  system  on  20/10/2024.  PL  highlighted  the 
substantial number of connections and interfaces of the PN system with other 
customs systems. In addition, PL noted that delays in its import system have 
contributed to the postponement of the PN system implementation. PL's import 
system is an extensive platform that manages nearly all customs procedures, 
including the PN process. The lack of experienced experts, primarily due to 
retirements,  resulted  in  the  delayed  publication  of  technical  and  functional 
specifications.  PL  aims  to  promptly  deploy  and  incorporate  the  UCC 
requirements  into  its  system.  Meanwhile,  it  plans  to  use  the  currently 
operational PN system, a measure intended to uphold  operational continuity 
and ensure compliance with the data scope outlined in the UCC requirements. 

PT 

High 

Same response as for AN. 

RO 

SE 

Medium 

SI 

N/A 

RO informed that the PN system plans to be deployed on 30/09/2024 for all 
modes of transport.  
SE reported that the system was deployed on 27/09/2023 for air transport and 
on  01/03/2024 for other modes  of transports,  aiming to  enter  operations for 
other modes of transport on 15/08/2025. The delay concerns maritime traffic 
due to the dependency with the European Maritime Single Window (EMSW) 
deployment. SE shared its intention to use the current data filing system via the 
Maritime National Single Window (MNSW) until the EMSW is deployed in 
August 2025. As PN should pertain to the entry summary declaration, SE needs 
to add several data elements to the current data filing system in  the MNSW 
starting from 03/06/2024. This approach aims to minimise the burden on trade 
and  prevent  the  need  for  SE  to  change  procedures  and  filing  systems  twice 
within  a  short  timeframe.  To  address  the  delay,  SE  has  allocated  additional 
resources to the project and intensified dialogue with the EOs to ensure their 
timely migration. In addition, SE shared that is analysing the consequences for 
the customs formalities since the deployment of the MNSW will be delayed 
until after the 15/08/2025.  
SI shared that the PN system for air transport was deployed on 01/03/2024 and 
for other modes of transport on 29/02/2024. 

30 The information shared by LV in the survey has been updated based on a bilateral meeting between LV and DG 
TAXUD held on 18/04/2024. 

27 

 
 
 
 
 
MS 

Risk 
Level 

SK 

High 

Additional Comments 

SK informed that the project was deployed on 01/10/2023 for air transport and 
aims to deploy the other modes of transport on 02/06/2025. As a result, SK 
assessed a high risk of delay to the PN system estimating the other modes of 
transport deployment beyond the deployment deadline. The elevated risk is due 
to dependencies on the delays in NIS and CCI. In response, SK has submitted 
a derogation request. By the end of 2024, SK plans to finalise contractual tasks, 
develop updated specifications for EOs, and initiate the conformance testing 
activities. 

Table 11: Detailed responses from Member States – PN 

Figure 1131 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 11: Project progress and status per milestone – PN 

31 The progress shown in the figure considers both the air and other modes transport. Additionally, ‘Deployment’ 
encompasses both deployment and operations milestones. 

28 

 
 
 
 
 
 
Temporary Storage (TS) 

Summary from the Member States: 

Please see also the summary from AN. 

For the TS system, Member States were requested to comply with the requirements of the new Annex 
B of the Commission Delegated Regulation (EU) 2021/234. 

At the time of writing, BE, BG, CZ, DE, EE, ES, FI, FR, HR, HU, IE, LT, LU, LV, NL, and SI indicated 
the system as deployed for all modes of transport. IT deployed air transport, while for other modes of 
transport will extend beyond. From the remaining Member States, AT, CY, DK, GR, MT, PL, PT, RO, 
SE, and SK indicated the project delayed beyond the deployment deadline for all modes of transport. 
Additionally, PT and SK submitted a written notification asking for a derogation under Article 6(4) of 
the UCC to DG TAXUD concerning the delay of TS beyond the 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 TS 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 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) 2023/23632 
granting a derogation to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HR, HU, 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 applied 
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 29 February 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. This differentiation by transport mode aligned with ICS2-R2 
and  the  date  specified  in  the  UCC  WP  2023  for  ICS2-R3,  respectively,  as  the  projects  are  closely 
linked33. 

Detailed Responses: 

Table 12 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Medium 

BE 

Low 

Additional Comments 

AT  reported  a  delay  in  the  TS  system  beyond  the  UCC  WP  deadline  and 
attributed  a  medium  risk  to  the  timely  delivery  of  the  project.  The  primary 
cause of delay was the need to re-initiate the tender procedure, which has now 
been completed. AT informed that communications with the Commission are 
ongoing to address the risks. TS is planned to go into operations alongside CCI-
P1 & CCI-P2 on 02/06/2025. Additionally, AT shared that is using an Agile 
approach tailored by the software provider. 
BE shared that the TS system was deployed on 29/11/2023 for all modes of 
transport, aiming the enter operations on 26/07/2024 for air transport and on 
01/10/2024  for  other  modes  of  transport.  The  delay  is  primarily  due  to 

32 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). 
33 Considering the link with ICS2-R3 for maritime transport, inland waterways, road and rail transport, the Member 
States that were granted a derogation have the possibility to deploy the system until 03/06/2024. 

29 

 
 
 
 
MS 

Risk 
Level 

Additional Comments 

dependencies on other projects such as ICS2-R3 and PoUS, compounded by a 
shortage of critical resources including business analysts and IT developers. 
To mitigate the delay, BE has redistributed IT resources to prioritise critical 
needs in the short term. BE informed that the MVPs with core functionalities 
for  PN  and  TS  are  currently  in  production  and  specific  functionalities  for 
maritime and other modes of transport are still being developed. In addition, 
BE is using an Agile framework for the system’s development.  

BG 

N/A 

Same response as for PN. 

CY 

High 

Same response as for AN. 

CZ 

N/A 

Same response as for PN. 

Low 

Same response as for PN. 

DE 

N/A 

DK 

High 

EE 

ES 

FI 

FR 

N/A 

N/A 

N/A 

GR 

High 

HR 

N/A 

DE reported TS was deployed on 06/03/2021 and has been integrated as part 
of  NES  of  its  national  IT  system  ATLAS  (Release  9.1).  Additionally,  DE 
shared that the data model is not completely in line with the European Union 
Customs Data Model (EUCDM) (Functional Message Structure [FMS]) and 
will be updated following the approach of CCI and NIS, which are the basis 
for the new and modernised import application. 
DK indicated a delay beyond the anticipated deployment deadline and assessed 
a high level of risk to the timely delivery of the system due to its prioritisation 
of export and transit projects over the import systems. Mitigation efforts have 
been undertaken with the supplier, however, complexity in the development 
and testing phases have been a challenge. DK aims to deploy the TS system 
for  all  modes  of  transport  on  08/03/2025  and  has  adopted  Agile  concepts 
throughout its development. 
EE reported that the TS system was deployed on 01/07/2021 for air transport 
and on 01/10/2023 for other modes of transport. 

FI shared that the TS system was deployed in Q4 2022 for air transport and for 
other modes of transport in Q2 2024. 
FR informed that the TS system was deployed for all modes of transport on 
06/03/2024. 
GR reported a high risk  associated to the timely delivery of the project and 
noted that the deployment of the TS system will be in Q2 2025, thus beyond 
the legal deadline. This is due to delays in procurement contracts for all UCC 
and MASP projects as well as difficulties with the tendering procedure. GR 
indicated that it is prioritising other trans-European system projects over TS 
because  its  existing  national  system  adequately  meets  the  TS  declaration 
requirements, despite not being based on the EUCDM. Furthermore, GR aims 
to resolve the tender procedure and secure a contractor by the end of 2024 and 
is using an Agile approach for its system development.  
HR reported that the TS system for all modes of  transport was deployed on 
17/04/2023. Additionally, HR shared that it has implemented a set of G3 and 
G4 declarations in accordance with customs legislation. 

HU 

N/A 

Same response as for AN.  

IE 

N/A 

IE indicated that the TS system was deployed on 23/11/2020 for all modes of 
transport. 

30 

 
 
MS 

Risk 
Level 

Additional Comments 

IT 

Medium  Same response as for AN. 

LT 

LU 

LV 

N/A 

LT  reported that the  TS  system  was  deployed for  all modes  of transport  on 
31/10/2023.  
LU shared that the TS system has been deployed for all modes of transport 
since 10/01/2023.  

N/A 

Same response as for PN. 

MT 

Low 

Same response as for AN. 

NL 

Low 

Same response as for PN. 

PL 

High 

Same response as for PN. 

PT assessed the project as being delayed beyond the UCC WP deadline. The 
primary  reasons  for  the  delay  were  detailed  in  PT’s  derogation  request  in 
accordance with Article 6(4) of the UCC, submitted on 04/12/2023. Besides, 
the project’s difficulty and risk increased due to (a) the implementation of a 
new national system requiring integration between airport and port authorities; 
(b) the intricate interdependencies of various national and EU systems; and (c) 
the development halt from mid-2023 to the end of 2023 due to procurement 
and  tendering  difficulties,  particularly  in  the  renewal  of  the  supplier’s 
contracts.  To  mitigate  the  abovementioned  delays,  an  Agile  development 
approach will be implemented to streamline the implementation timeframe. PT 
noted  that  despite  the  delay  in  the  implementation  of  the  project, 
interdependence with ICS2 is guaranteed as the arrival notification is processed 
electronically in the old system and is duly sent to the common repository. 
Furthermore,  the  National  Planning  was  revised  to  include  updates  to  the 
conformance testing period with the EOs, and adjustments to the deployment 
date, now set on 28/10/2024. At the moment of writing, PT shared that it is 
expected that some functionalities may be implemented in phases after the start 
date  of  operations,  namely  the  authorisation  to  move  goods  in  temporary 
storage between different temporary storage facilities (column G5). 
RO informed that the TS system plans to be deployed on 31/12/2024 for all 
modes of transport.  
SE reported that the system aims to be deployed on 01/10/2024 for air transport 
and  on  15/08/2025  for  other  modes  of  transports.  The  delay  is  due  to  its 
dependency with the EMSW deployment. SE shared that several projects are 
being  developed  simultaneously,  alongside  the  necessity  to  change  its  IT 
platform, which may impact the project's development. SE shared its intention 
to  use  the  current  data  filing  system  via  the  MNSW  until  the  EMSW  is 
deployed in August 2025. This approach aims to minimise the burden on trade 
and  avoid  the  necessity  for  SE  to  alter  procedures  and  filing  systems  twice 
within  a  short  timeframe.  To  address  the  delay,  SE  has  allocated  additional 
resources to the project and intensified dialogue with the EOs to ensure their 
timely migration. The expected outcome of these measures is the delivery of 
the  project  according  to  the  national  plan  provided.  Overall,  SE  anticipates 
having all EOs operational except for maritime traffic by 31/12/2024 and the 

PT 

High 

RO 

SE 

Medium 

31 

 
 
 
 
MS 

Risk 
Level 

SI 

N/A 

SK 

High 

Additional Comments 

deployment for maritime transport by August 202534. In addition, SE shared 
that  it  is  analysing  the  consequences  for  the  customs  formalities  since  the 
deployment of the MNSW will be delayed until after the 15/08/2025. 
SI  shared  that  the  TS  system  for  all  modes  of  transport  was  deployed  on 
01/03/2024.  
SK  assessed  a  high  risk  of  delay  to the  TS  system  planning its  deployment 
beyond the deployment deadline on 02/06/2025. The elevated risk is due to 
dependencies on the delays in NIS and CCI. In response, SK has submitted a 
derogation request. By the end of 2024, SK plans to finalise contractual tasks, 
develop updated  specifications for  EOs  and  initiate  the  conformance  testing 
activities. 

Table 12: Detailed responses from Member States – TS 

Figure 1235 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 12: Project progress and status per milestone – TS 

34 The information shared by SE in the survey has been updated based on a bilateral meeting between SE and DG 
TAXUD held on 27/03/2024.  
35 The progress shown in the figure considers both the air and other modes transport. Additionally, ‘Deployment’ 
encompasses both deployment and operations milestones.  

32 

 
 
 
 
 
3.1.2 Overview of Project Progress 

Figure 13, Figure 15, and Figure 17 for the air transport and Figure 14, Figure 16, and Figure 18 for 
other modes of transport highlight any known divergences in the Member States’ National Planning 
compared to the dates set in the UCC and/or the granted derogation deadline36 37 38 as well as the specific 
dates for each milestone. The dates reflected in the figures below indicate the full implementation of the 
project. Some Member States decided to deliver the system in several iterations or releases, linked to 
the ICS2 Releases.  

Concerning the implementation of Notification of Arrival (AN) – Air transport, the following Member 
States have a planned/actual deployment date that is later than the deadline set by the UCC and/or the 
granted derogation39: CY, FI, HU, IE, LT, MT, PT, and RO. In addition, DE did not provide information 
through its National Planning on the deployment date.  

Regarding  the  implementation  of  Notification  of  Arrival  (AN)  –  Other  modes  of  transport,  the 
following Member States have a planned/actual deployment date that is later than the deadline set by 
the UCC and/or the granted derogation: CY, FI, IE, IT, LT, LV, MT, PT, and RO. In addition, DE and 
LU did not provide information through their National Planning on the deployment date. 

The specific dates of each milestone can be found in Figure 13 for air transport and Figure 14 for other 
modes of transport. 

36 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 29/02/2024 
for maritime transport or inland waterways, whichever date is sooner. Additionally, considering the link with ICS2-
R3 for maritime transport, the Member States that were granted a derogation have the possibility to deploy the 
system until 03/06/2024.  
37 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 29/02/2024 for maritime 
transport, inland waterways, road or rail transport, whichever date is sooner. Additionally, considering the link 
with ICS2-R3 for maritime transport, inland waterways, road or rail transport, the Member States that were granted 
a derogation have the possibility to deploy the system until 03/06/2024. 
38 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 29/02/2024 for maritime 
transport, inland waterways, road or rail transport, whichever date is sooner. Additionally, considering the link 
with ICS2-R3 for maritime transport, inland waterways, road or rail transport, the Member States that were granted 
a derogation have the possibility to deploy the system until 03/06/2024. 
39 In all projects, for the Member States that provided dates in quarters, the project is considered on target if the 
UCC WP deadline falls within the quarter. 

33 

 
 
 
 
 
 
Figure 13: Actual/Planned dates per milestone – AN – Air transport 

34 

 
 
 
Figure 14: Actual/Planned dates per milestone – AN – Other modes of transport 

35 

 
 
 
Regarding  the  implementation  of  Presentation  Notification  (PN)  –  Air  transport,  the  following 
Member States indicated a planned/actual deployment date that is later than the deadline set in the UCC 
and/or the granted derogation: BG, CY, FR, HU, LT, MT, PL, PT, and RO.  

Concerning the implementation  of  Presentation  Notification  (PN)  – Other  modes  of transport, the 
following Member States have a planned/actual deployment date that is later than the deadline set by 
the UCC and/or the granted derogation: BG, CY, FI, IT, LT, MT, PL, PT, RO, and SK. In addition, DE, 
HR, LV, and LU did not provide information on the deployment date. 

The specific dates of each milestone can be found in Figure 15 for air transport and Figure 16 for other 
modes of transport.  

36 

 
 
 
 
 
Figure 15: Actual/Planned dates per milestone – PN – Air transport 

37 

 
 
 
Figure 16: Actual/Planned dates per milestone – PN – Other modes of transport 

38 

 
 
 
Regarding  the  implementation  of  Temporary  Storage  (TS)  –  Air  transport,  the  following  Member 
States indicated a planned/actual deployment date that is later than the deadline in the UCC and/or the 
granted derogation: AT, BG, CY, DK, FR, GR, HU, MT, PL, PT, RO, SE, SI, and SK.  

Concerning the implementation of Temporary Storage (TS) – Other modes of transport, the following 
Member States have a planned/actual deployment date that is later than the deadline set by the UCC 
and/or the granted derogation: AT, BG, CY, DK, FI, GR, IT, MT, PL, PT, RO, SE, and SK. In addition, 
DE did not provide information through its National Planning on the deployment date. 

The specific dates of each milestone can be found in Figure 17 for air transport and Figure 18 for other 
modes of transport. 

39 

 
 
Figure 17: Actual/Planned dates per milestone – TS – Air transport 

40 

 
 
 
Figure 18: Actual/Planned dates per milestone – TS – Other modes of transport 

41 

 
 
 
 
3.2 UCC NATIONAL IMPORT SYSTEM (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 National Import System (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 (UCC DA) and UCC Implementing Act (UCC IA); 

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

3.2.1 Summary of Responses 

Summary from the Member States: 

For  the  NIS  upgrade,  Member  States  were  requested  to  align  their  systems  with  the  new  data 
requirements in Annex B of the Commission Delegated Regulation (EU) 2015/2446, as amended by 
Delegated Regulation (EU) 2021/234. 

Most Member States assessed the project with a low risk since it is either completed or anticipated its 
delivery within the UCC WP deadline. The other Member States indicated medium or high risk due to 
the implementation of a new import system and/or interdependencies with other systems at the national 
level, namely CCI.  

The  causes  for  delays  frequently  cited  by  the  Member  States  encompass  the  lack  of  resources, 
procurement delays, difficulties in the EOs transition, prioritisation of export and transit projects and 
interdependencies with other customs systems. In addition, other contributing factors include the lack 
of business knowledge, challenges in the coordination with contractors, and modifications in the project 
strategy. Several Member States adopted an Agile development approach and improved the coordination 
with EOs to reduce the implementation timeframe. 

At the moment of writing, the Member States that have already deployed the upgrade are BG, DE, EE, 
ES, FI, HR, HU, IE, IT, LT, LU, LV, NL, PL, SE, SI, and SK, with IE, PL, and SK having provided the 
planning for a further update of the system. The other Member States reported a delay beyond the UCC 
deadline: AT, BE, CY, CZ, DK, FR, GR, MT, PT, and RO. Additionally, PT and SK submitted a written 
notification asking for a derogation under Article 6(4) of the UCC to DG TAXUD concerning the delay 
in the upgrade of NIS beyond the 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 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 Member States requesting it and in view of a set 
of common assessment criteria.  

42 

 
 
In this light the Commission adopted an Implementing Decision (EU) 2023/23740 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 upgrade to use means other than electronic data-processing techniques for the exchange 
and storage of information. The derogation applied from 1 January 2023 until the deployment of NIS, 
but  not  later  than  31  December  2023.  Additionally,  where  Article  2(4a)  of  Commission  Delegated 
Regulation (EU) 2015/2446 applies, Member States have until 01/07/2024 to deploy the system upgrade. 

Detailed Responses: 

Table 13 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Medium 

Additional Comments 

AT reported a delay in the  NIS upgrade beyond the UCC WP deadline and 
attributed  a  medium  risk  to  the  timely  delivery  of  the  project.  The  primary 
cause of delay was the need to re-initiate the tender procedure, which has now 
been completed. AT informed that communications with the Commission are 
ongoing to address the risks. Deployment for NIS is planned on 01/04/2025. 
Additionally,  AT  shared  that  is  using  an  Agile  approach  tailored  by  the 
software provider. 

BE 

BE informed that the NIS upgrade is planned to be deployed on 28/08/2024. 

BG 

N/A 

BG  shared  that  the  NIS  upgrade  according  to  the  requirements  of  the  new 
Annex B was deployed on 10/11/2023. 

CY 

High 

Same response as for AN. 

CZ 

High 

CZ indicated a high risk of delay for the NIS upgrade, stating it will  extend 
beyond the legal deadline. The delay is primarily due to financial limitations. 
The  development  of  the  system  commenced  in  February  2024;  however, 
further advancements are subject to obtaining additional financial resources. 
CZ reported significant revisions to its national plan and, by the time of writing 
it  expects  to  deploy  the  system  on  15/12/2025.  Additionally,  CZ  is 
implementing an Agile framework for the development of the system. 

DE 

N/A 

DE informed that the NIS upgrade system started operations on 31/10/2022. 

DK 

High 

Same response as for TS. 

EE 

N/A 

ES 

Low 

EE reported that the NIS upgrade has been in operations since 01/07/2021 and 
the necessary amendments to Annex B have been completed41. 
On 05/09/2023, ES deployed a transitional solution in alignment with the UCC 
to meet the legal deadline of the project. ES indicated that the NIS upgrade is 
in production and undergoing the migration phase with EOs with an entry to 

40 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). 
41 The information shared by EE in the survey has been updated based on a bilateral meeting between EE and DG 
TAXUD held on 06/05/2024. 

43 

 
 
 
 
 
MS 

Risk 
Level 

FI 

N/A 

FR 

Low 

GR 

High 

Additional Comments 

operations planned for 14/10/2025. In addition, ES shared that is using an Agile 
approach for the project's development. 
FI  shared  that  the  NIS  upgrade  has  been  in  operations  since  Q4  2022. 
Additionally, FI informed that a full release for the NIS upgrade is planned for 
Q4 202542. 
Due to technical and regulatory adaptation issues between the old and the new 
IT system, FR reported a delay beyond the deployment deadline in the upgrade 
of  NIS.  To  address  this  delay,  FR  has  outsourced  certain  activities  and  has 
adopted a new project management and follow-up methodology, resulting in 
the  stabilisation  of  the  NIS  project  plan.  FR  aims  to  deploy  the  system  by 
30/11/2024, using an iterative approach for its development. 
GR  shared  that  the  NIS  upgrade  has  been  delayed  beyond  the  deployment 
deadline and it is planned for Q2 2025. GR assessed a high risk to the project's 
timely completion due to procurement contract issues across all the UCC and 
MASP projects, and tender procedure challenges. To mitigate the delay, GR 
plans  to  implement  the  new  UCC  (nUCC)  data  format  in  SURV3  on 
01/07/2024  which  will  enable  the  transmission  and  statistical  collection  of 
import data in UCC formats and support new procedure codes under the UCC 
framework. However, the completion of the full UCC implementation in the 
national system is uncertain, pending the resolution of some tender issues. GR 
also noted that NIS is closely linked with the implementation of CCI and is 
using an Agile framework for system development. 

HR 

N/A 

HR shared that the NIS upgrade was deployed on 01/01/2023.  

HU 

N/A 

HU reported that the NIS upgrade has been in operations since 01/11/2023.  

N/A 

N/A 

IE  shared  that  NIS  is  deployed  and  intends  to  upgrade  the  system  from  the 
original  Annex  B  (EUCDM  5)  to  the  revised  Annex  B  (EUCDM  6) 
concurrently with the introduction of CCI-P1 and CCI-P2 in January 2026. 
IT  shared  that  the  NIS  upgrade  has  been  operational  since  30/11/2022. 
Additionally, IT plans to upgrade the NIS to EUCDM 6.2. 

N/A 

LT informed that the NIS upgrade was deployed on 31/12/2023. 

N/A 

MT 

Medium 

LU shared that NIS is fully implemented and has been aligned with Annex B 
since 02/05/202343. 
LV reported that NIS has been in operations since 04/06/2018 and an upgrade 
to the UCC requirements was completed on 13/06/202344. 
MT assessed a medium level of risk associated  to the timely delivery of the 
project,  as  development  is  not  yet  completed,  and  the  system  integration 
remains  outstanding.  The  project  is  experiencing  delays  beyond  the 
deployment  deadline  due  to  insufficient  resources,  planning,  and  business 
knowledge.  To  expedite  the  development  process,  MT  informed  about  the 
adoption Scrum methodologies in collaboration with the Customs Computer 

IE 

IT 

LT 

LU 

LV 

42 Information provided from a bilateral meeting between FI and DG TAXUD held on 02/04/2024. 
43 Information provided from a bilateral meeting between LU and DG TAXUD held on 22/07/2024. 
44 The information shared by LV in the survey has been updated based on a bilateral meeting between LV and DG 
TAXUD held on 18/04/2024. 

44 

 
 
 
 
 
MS 

Risk 
Level 

NL 

Low 

PL 

High 

PT 

High 

Additional Comments 

Section to monitor and validate progress on a three-week basis. MT plans to 
‘go live’ by the end of January 202545. 
NL  deployed  the  NIS  upgrade  system  on  01/04/2022  and  informed  that  the 
transition  of  the  EOs  to  the  system  is  progressing  slower  than  anticipated. 
Nevertheless, NL expects that the EOs will migrate to the new system by mid-
April 202446. To expedite this process, the EOs will transfer to the new system 
iteratively. 
PL  shared  that  NIS  was  deployed  and  a  further  upgrade  of  the  system  is 
expected on 20/10/2024. PL emphasised the significant number of connections 
and interfaces between NIS and other customs systems. Additionally, PL noted 
that  delays  in  the  development  of  NCTS-P5  have  led  to  delays  in  the 
implementation  of  the  NIS  upgrade.  PL's  import  system  is  an  extensive 
platform that manages nearly all customs procedures. The lack of experienced 
experts, primarily due to retirements, has resulted in the delayed publication of 
technical and functional specifications. PL aims to swiftly deploy and integrate 
the UCC requirements into its system. Meanwhile, it intends to use the existing 
NIS  to  ensure  operational  continuity  and  compliance  with  the  data  scope 
specified in the UCC requirements. 
PT reported the project as being delayed beyond the  foreseen deadline. The 
primary  reasons  for  the  delay  were  detailed  in  PT’s  derogation  requests  in 
accordance  with  Article  6(4)  of  the  UCC,  submitted  on  07/06/2022  and 
04/12/2023.  PT  shared  that  the  project  was  further  delayed  due  to  (a)  the 
complexity  of  implementing  a  new  NIS;  (b)  the  intricate  interdependencies 
among various national and EU systems; (c) a halt in the development between 
mid-2023  to  the  end  of  2023  due  to  procurement  and  tendering  difficulties, 
particularly in renewing the developer’s contracts. To address these delays, an 
Agile development approach will be adopted to expedite the implementation 
process.  At  the  moment  of  writing,  PT  shared  that  it  is  expected  that  some 
functionalities may be phased into operations after the start date of operations, 
due the intricate interdependencies among various national and EU systems, 
namely excise goods. Additionally, the National Planning has been updated to 
include revisions to the conformance testing period with the Commission and 
the  EOs,  along  with  modifications  to  the  deployment  date  now  set  on 
28/10/2024. 

RO 

RO informed that the NIS upgrade plans to be deployed on 31/12/2024. 

SE 

N/A 

implementation 

SE reported that the NIS upgrade has been operational since 31/12/2023. SE 
shared  that  having  a  short  implementation  period  for  the  EOs  reduces 
dependencies  and  simplifies 
the  customs 
administration  and  traders.  For  that  reason,  SE  will  follow  a  phased 
implementation plan. First, the deployment for the simplified declaration will 
occur on 02/09/2024, with a migration period until 27/09/2024, during which 
all  EOs  should  be  operational.  Second,  the  deployment  date  will  be  on 
01/11/2024 for the Entry in the Declarant’s Records (EIDR), with a migration 
period until 31/12/2024, when all EOs should become operational. 

for  both 

45 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 
46 The information shared by NL in the survey has been updated based on a bilateral meeting between NL and DG 
TAXUD held on 27/03/2024.  

45 

 
 
 
 
 
Risk 
Level 

MS 

SI 

SK 

High 

Additional Comments 

SI  reported  that  the  upgrade  of  NIS  to  the  new  Annex  B  was  deployed  on 
01/01/202247. 
SK shared that the current NIS system in operations is aligned with Annex D 
and plans to upgrade it to the new Annex B as defined in the Regulation (EU) 
2015/2446. As a result, SK attributed a high risk to the timely delivery of the 
project  planned  by  01/07/2025.  This  is  primarily  due  to  (a)  the  decision  to 
develop the NIS upgrade and CCI as a single system to avoid parallel system 
operations, which resulted in contract delays; (b) resource constraints; and (c) 
delays  in  other  critical  projects.  To  address  these  delays,  SK  submitted  a 
derogation request.  
By the end of 2024, SK aims to finalise its contracts, update the specifications 
for the EOs, and initiate the conformance testing activities. 

Table 13: Detailed responses from Member States – NIS Upgrade 

Figure 1948 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 19: Project progress and status per milestone – NIS Upgrade 

47 Information provided from a bilateral meeting between SI and DG TAXUD held on 08/05/2024. 
48 The information shared by IE, PL, and SK corresponds to a further upgrade of NIS, but the system is already 
deployed. Additionally, ‘Deployment’ encompasses both deployment and operations milestones. 

46 

 
 
 
 
 
 
 
 
3.2.2 Overview of Project Progress 

Figure 20 highlights any divergences in the Member States’ National Planning compared to the dates 
set in the UCC and/or the granted derogation deadline49 as well as the specific dates of each milestone. 
As this project has a deployment window, the deployment and operations milestones are shown. Any 
difference between these two dates indicates that a migration period is planned. 

Regarding the implementation of the National Import System (NIS) upgrade, the following Member 
States have a planned/actual deployment date that is later than the deadline in the UCC and/or the granted 
derogation deadline: AT, BE, BG, CY, CZ, DK, FR, GR, MT, PT, and RO. In addition, IE, PL, and SK 
reported having deployed NIS but need a further update. 

49 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 have until 01/07/2024 to deploy the system. 

47 

 
 
 
 
Figure 20: Actual/Planned dates per milestone – NIS Upgrade  

48 

 
 
 
 
3.3 UCC SPECIAL PROCEDURES – COMPONENT 1 (SP EXP) 

This project aims to accelerate, facilitate, and harmonise Special Procedures (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  SP  (customs  warehousing,  end-use,  temporary  admission,  and 
inward/outward processing). It is noteworthy that, in many Member States, the implementation of this 
project occurs within the context of the upgrades to AES. 

In terms of planning, this project will be implemented in two stages/phases. 

Component  1  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. 

For Component 2 (SP IMP), please refer to Section 3.4. 

3.3.1 Summary of Responses 

Summary from the Member States: 

The SP EXP system is closely interlinked with AES, which is often reported by the Member States as 
the reason for assessing the project as medium or high risk. 

The causes for delays frequently identified include the implementation of a new export system and/or 
interdependencies between systems, insufficient human resources, delays in the procurement process as 
well as with challenges in the EOs transition. In addition, other contributing factors include prolonged 
conformance  testing  periods,  concurrent  development  of  multiple  projects,  and  lack  of  business 
expertise.  To  that  end,  many  Member  States  implemented  Agile  development  methodologies,  and 
increased project resources to reduce the implementation timeframe. 

From the information shared, the following Member States reported the system as deployed: BE, BG, 
CY, CZ, DE, DK, EE, ES, HR, IE, IT, LT, LU, LV, NL, PL, RO, and SI. Furthermore, AT, FI, FR, GR, 
HU, MT, PT, SE, and SK indicated that the development of the system is currently delayed, with AT, 
FR,  and  GR  reporting  a  delay  beyond  the  deadline. Amongst those,  PT  and  SK  submitted  a  written 
notification asking for a derogation under Article 6(4) of the UCC to DG TAXUD concerning the delay 
of SP EXP beyond the deadline. 

Detailed Responses: 

Table 14 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Medium 

Additional Comments 

AT reported a delay in the SP EXP system beyond the UCC WP deadline and 
attributed a medium risk to the timely delivery of the project. AT plans to be 
operational  on  05/02/2025.  The  primary  cause  of  delay  was  the  need  to  re-
initiate the tender procedure, which has now been completed. AT informed that 
communications  with  the  Commission  are  ongoing  to  address  the  risks. 
Additionally,  AT  shared  that  is  using  an  Agile  approach  tailored  by  the 
software provider.  

BE informed that the SP EXP system was deployed on 19/06/2024.  

N/A 

BG shared that the SP EXP system was deployed on 28/08/2023.  

Low 

CY indicated that the SP EXP system has been operational since 18/12/2023. 
It aims to complete the migration of the EOs by the end of 2024.  

49 

BE 

BG 

CY 

 
 
 
MS 

CZ 

DE 

Risk 
Level 

Additional Comments 

N/A 

CZ shared that the SP EXP system has been operational since 01/10/2023. 

DE indicated that SP EXP was deployed on 06/03/2021.  

DK 

N/A 

DK reported that the system was deployed on 29/07/2023. 

EE 

ES 

N/A 

EE informed that the SP EXP system was deployed on 30/09/2023. 

N/A 

ES shared that the SP EXP system was deployed on 18/10/2022. 

FI 

High 

FR 

High 

GR 

Medium 

FI reported the project as delayed because the supplier has limited resources 
which risks the timely delivery of SP EXP. To mitigate the delay, FI prioritised 
the  supplier's  export  resources  towards  AES,  which  is  being  developed 
alongside SP EXP, instead of NCTS. Additionally, FI opted to reduce the scope 
and engaged in negotiations with the supplier at a management level. Despite 
these efforts, some features have been postponed and FI intends to deploy the 
system in Q4 2024.  
FR shared that the project is being delayed  beyond the planned deployment 
deadline and attributed a high risk to the timely delivery of the project. These 
delays are due to the system’s dependency on AES and NIS, which FR reported 
are both delayed due to the need to  implement numerous national rules. FR 
informed that given the SP EXP system will not be deployed prior to the current 
transition  period  end  date  it  plans  to  request  an  extension  of  the  transition 
period.  To  mitigate  these  delays,  FR  has  strengthened  its  team  and  is 
collaborating with DG TAXUD. With these mitigations in place, FR intends to 
initiate  the  conformance  testing  activities  and  expects  to  deploy  a  partial 
system by 31/12/2025. Additionally, FR is using an Agile approach to manage 
this system's deployment. 
GR  informed  that  the  SP  EXP  system  is  delayed  beyond  the  deployment 
deadline  and  highlighted  a  medium  risk  level  for  the  timely  delivery  of  the 
project. GR aims to be operational on 16/12/2024. The main challenge has been 
procurement  difficulties,  particularly  with  securing  a  contract  that  can 
encompass all UCC and MASP projects with tight timelines to fulfil all UCC 
requirements.  GR  shared  that  these  tendering  issues  have  not  allowed  it  to 
progress with the implementation of the system. Given SP EXP is part of the 
AES  implementation,  GR  is  addressing  the  delays  by  exploring  ways  to 
upgrade  its  existing  national  export  system  to  support  all  UCC  provisions. 
Additionally, GR shared it is using an Agile framework to develop the system. 

HR 

N/A 

HR informed that the SP EXP system was deployed on 01/01/2023.  

HU 

Medium 

HU  shared  that  it  is  experiencing  a  delay  due  to  its  limited  resources  and 
multiple IT projects being developed simultaneously. To mitigate the delay and 
ensure efficiency, HU reported  having reallocated resources after going live 
with Excise Movement and Control System (EMCS) Phase 4.1 on 14/02/2024. 
Additionally, HU  aims to go into operations on 02/12/2024 according to its 
National Planning and shared that is using an Agile framework to develop the 
system. 

IE 

N/A 

IE reported that the SP EXP system was deployed on 21/03/2023. 

50 

 
 
 
MS 

Risk 
Level 

IT 

Low 

Additional Comments 

IT informed that the SP EXP system was deployed on 08/06/2023 and plans to 
be in operation by 02/12/2024. In addition, IT shared it has updated its National 
Planning based on the revised UCC WP. 

LT 

LU 

LV 

N/A 

LT shared that the SP EXP system has been operational since 03/12/2023.  

LU reported that the SP EXP system was deployed on 08/07/2024 and it will 
begin operations on 02/12/2024. 

N/A 

LV informed that the SP EXP system was deployed on 10/10/2023. 

MT 

High 

NL 

Low 

PL 

Low 

PT 

High 

MT reported the system as delayed, but it estimates that SP EXP together with 
AES-C1 will be in operations by 11/02/2025. The causes provided include a 
lack of business expertise and delays in systems integration which have caused 
the postponement of the development phase. Also, MT shared the adoption of 
an Agile and iterative approach for the development of the project.  
NL shared that SP EXP was deployed on 01/04/2022, and experienced delays 
due to the extended duration of the traders’ transition, thereby lengthening the 
initial planning. NL planned for the traders to be switched to AES before the 
end  of  the  deployment  window  deadline.  NL  is  employing  an  iterative 
methodology for the transfer of traders.  
PL noted that the UCC SP project consists of two systems: (a) SP EXP (AES 
and Regulatory Procedure with Scrutiny [RPS]) which is concerned with the 
relevant functionalities regarding the export issues connected with UCC SP, 
and is being implemented during the  Project of System AES and Project of 
System  RPS,  and  (b)  SP  IMP  (Automated  Import  System  [AIS]  and  RPS) 
which  includes  the  relevant  functionalities  regarding  the  import  issues 
connected  with  UCC  SP,  and  is  being  implemented  during  the  Project  of 
System AIS and Project of System RPS. 
The  start  of  operations  of  SP  EXP  and  SP  IMP  for  all  EOs  took  place  on 
28/03/2022.  Additional  UCC  SP  functions  for  operational  integration  into 
AES, AIS, and RPS were executed in 2023 and are planned to continue until 
the end of 2024. 
Moreover, PL shared the adoption of an iterative approach for most cases, with 
the occasional use of an Agile methodology. 
PT  assessed  the  project  as  being  delayed  but  aims  to  be  operational  on 
02/12/2024. The primary reasons for the delay were shared in PT’s derogation 
request in accordance with Article 6(4) of the UCC, submitted on 04/12/2023. 
Additionally, the complexity and risk associated with the project escalated due 
to  (a)  the  challenges  of  establishing  a  new  NES;  (b)  the  intricate 
interdependencies among various national and EU systems; (c) the suspension 
of development from mid-2023 to the end of 2023 caused by procurement and 
tendering challenges, especially in renewing contracts with the suppliers. To 
mitigate the delays, an Agile development approach will be  implemented to 
streamline  the  project  timeframe.  Furthermore,  the  National  Planning  was 
adjusted  to  reflect  changes  in  the  conformance  testing  schedule  with  the 
Commission and EOs as well as alterations to the deployment timeline. 

RO 

RO shared that the SP EXP system has been operational since 16/03/2024.  

SE 

Low 

SE reported the project as being delayed  but still plans to deploy within the 
foreseen deployment deadline. To address the delay, SE developed a plan in 
Autumn 2021 which was updated according to the 2023 UCC WP revision. 
The  EOs  expressed  a  preference  to  shorten  the  migration  period  due  to  the 

51 

 
 
 
 
MS 

Risk 
Level 

Additional Comments 

complexity associated with concurrently using both the old and new systems, 
and differing process obligations. As a result, the migration period was reduced 
by  one  month.  SE  aims  to  ensure  operational  readiness  of  all  EOs  by 
02/12/2024. 

SI 

N/A 

SI shared that the SP EXP system was deployed on 24/05/2023.  

SK 

Low 

SK reported a delay in the SP EXP project but anticipates it to be operational 
by  14/10/2024.  SP  EXP  is  being  developed  as  part  of  AES,  which  is  also 
delayed.  The  main  reasons  for  the  delay  include  a  postponed  start,  limited 
human  resources,  and  a  prolonged  conformance  testing  period.  Additional 
delays  arose  from  necessary  modifications  to  the  Nitrogen  Oxide  Emission 
Control  Area  (NECA)  system.  To  mitigate  these  delays,  SK  submitted  a 
derogation  request  and  shared  that  it  will  postpone  some  non-core 
functionalities of the system. This strategy is designed to ensure the project is 
ready for operation by the deployment deadline, however SK has indicated it 
may result in a temporarily less effective solution. By the end of 2024, SK aims 
to  complete  the  conformance  testing  and  UAT,  adjust  the  NECA  system, 
provide training to the users, communicate with EOs, and initiate operations. 

Table 14: Detailed responses from Member States – SP EXP 

Figure 21 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 21: Project progress and status per milestone – SP EXP 

52 

 
 
 
 
 
3.3.2 Overview of Project Progress 

Figure  22  highlights  any  known  divergences  in  the  Member  States’  National  Planning  of  SP  EXP 
compared to the dates set in the UCC WP, along with the specific dates of each milestone. As this project 
has  a  deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference 
between these two dates indicates that a migration period is planned.  

Regarding the implementation of UCC Special Procedures – Component 1 (SP EXP), the following 
Member States have a planned/actual operations date that is later than the deadline in the UCC WP: AT, 
FR, and GR. In addition, BE did not provide information on the operations date, and HR reported the 
date as yet to be defined. 

53 

 
 
Figure 22: Actual/Planned dates per milestone – SP EXP  

54 

 
 
 
 
3.4 UCC SPECIAL PROCEDURES – COMPONENT 2 (SP IMP) 

This national project aims to accelerate, facilitate, and harmonise Special Procedures (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 is noteworthy 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. 

For Component 1 (SP EXP), please refer to Section 3.3. 

Component 2 is the national SP IMP with the view to provide 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: 

Most Member States assessed the project with a low risk due to its completion or the anticipation of 
meeting  the  UCC  WP  deadline.  The  Member  States  that  indicated  a  medium  or  high  risk  cited  the 
implementation of a new import system and/or the dependencies with other systems, mainly the NIS 
upgrade, as the primary cause of delay. 

Other  causes  for  delays  encompass  the  shortage  of  resources,  procurement  delays,  lack  of  business 
expertise  difficulties  in  the  EOs  transition,  and  the  prioritisation  of  export  and  transit  projects.  To 
mitigate the delays, many Member States informed that an Agile development methodology has been 
adopted and additional support has been provided to the EOs. 

At the time of writing, the following Member States indicated the system as deployed: BG, DE, EE, ES, 
FI, HR, HU, IE, IT, LT, LU, LV, NL, PL, SE, SI, and SK. Meanwhile, AT, BE, CY, CZ, DK, FR, GR, 
MT, PT, and RO reported that the development of the system is delayed beyond the UCC WP deadline. 
Additionally, PT and SK informed about submitting a written notification asking for a derogation under 
Article 6(4) of the UCC to DG TAXUD concerning the delay of SP IMP beyond the 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 SP IMP 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 Member States requesting it and in view of 
a set of common assessment criteria. 

In this light the Commission adopted an Implementing Decision (EU) 2023/23750, 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 applied from 1 January 2023 until the deployment of the SP IMP system, 
but  not  later  than  31  December  2023.  Additionally,  where  Article  2(4a)  of  Commission  Delegated 
Regulation (EU) 2015/2446 applies, Member States have until 01/07/2024 to deploy the system. 

50 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). 

55 

 
 
 
 
 
Detailed Responses: 

Table 15 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

Additional Comments 

AT 

Medium  Same response as for NIS. 

BE 

BE informed that SP IMP is planned to be deployed on 28/08/2024. 

BG 

N/A 

BG reported that the SP IMP system was deployed on 10/11/2023. Since this 
system is part of the NIS upgrade, the project activities were included in the 
adjustments of the existing import applications under the UCC. 

CY 

High 

Same response as for AN. 

CZ 

DE 

High 

Same response as for NIS. 

DE informed that the SP IMP system was deployed on 06/03/2021.  

DK 

High 

Same response as for TS. 

EE 

ES 

FI 

FR 

N/A 

Same response as for NIS. 

Low 

Same response as for NIS. 

N/A 

Same response as for NIS. 

N/A 

GR 

High 

FR informed that SP IMP plans to be deployed on 30/11/2024 beyond the legal 
deployment deadline. 
GR reported that SP IMP has encountered delays, resulting in the project plans 
falling behind the deployment deadline. GR informed the project faces a high 
risk  of  not  meeting  its  timeline  due  to  ongoing  issues  with  procurement 
contracts affecting all UCC and MASP projects, coupled with challenges in the 
tender process. To address these delays, GR intends to implement the nUCC 
data format in SURV3 on 01/07/2024. This implementation will facilitate the 
transmission and statistical collection of import data for special procedures in 
UCC  formats,  while  also  accommodating  new  procedure  codes  introduced 
under the UCC framework. The full UCC implementation in NIS is planned 
for Q2 2025, waiting for the outcome of the tender process. Additionally, GR 
noted  that  it  is  using  an  Agile  development  framework  to  enhance  system 
development. 

HR 

N/A 

Same response as for NIS. 

HU 

N/A 

Same response as for NIS. 

IE 

N/A 

The  SP  IMP  system  was  deployed  on  23/11/2020.  However,  IE  intends  to 
upgrade NIS from the original Annex D (EUCDM 5) to the revised Annex B 
(EUCDM  6)  concurrently  with  the  introduction  of  CCI-P1  and  CCI-P2  in 
January 2026. 

IT 

N/A 

Same response as for NIS. 

56 

 
 
 
 
MS 

LT 

LU 

LV 

Risk 
Level 

Additional Comments 

N/A 

Same response as for NIS. 

LU shared that SP IMP was deployed on 02/05/2023.  

N/A 

Same response as for NIS. 

MT 

High 

MT assessed a high risk associated to the timely delivery of the project. The 
development  work  has  not  started,  thus  indicating  that  the  project  will  be 
delayed beyond the foreseen deployment deadline. MT attributed the delay to 
the lack of knowledge from the business side. Given that the SP IMP system is 
part of the NIS upgrade, MT is facing delays in both the development and the 
integration of systems. MT plans to be in operations on 01/02/2025. 

NL 

Low 

Same response as for NIS. 

PL 

PT 

RO 

Low 

Same response as for SP EXP. 

High 

Same response as for NIS. 

Same response as for NIS. 

SE 

N/A 

SE reported that the SP IMP system has been in operations since 31/12/2023. 
Regarding customs warehousing, SE informed that the system is being used by 
all EOs. However, it requires an update to the new version of Annex B, which 
SE intends to implement during 2025. 

SI 

N/A 

SI informed that the SP IMP system has been operational since 01/01/2022.  

SK 

N/A 

SK shared that the SP IMP system was deployed on 11/06/2016 as part of NIS 
and  CCI  to  avoid parallel system  operations.  SK  noted  that  the current  NIS 
system is aligned with Annex D and plans to upgrade it to the new Annex B as 
defined  in  the  Regulation  (EU)  2015/2446  by  the  time  it  deploys  CCI-P1. 
Additionally,  SK  reported  that  it  submitted  a  derogation  request  to  help 
mitigate delays related to the NIS upgrade. 

Table 15: Detailed responses from Member States – SP IMP 

57 

 
 
 
 
 
 
Figure 2351 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 23: Project progress and status per milestone – SP IMP 

51 ‘Deployment’ encompasses both deployment and operations milestones. 

58 

 
 
 
 
 
 
3.4.2 Overview of Project Progress 

Figure  24  highlights  any  known  divergences  in  the  Member  States’  National  Planning  of  SP  IMP 
compared to the dates set in the UCC and/or the granted derogation deadline52, along with the specific 
dates  of  each  milestone.  As  this  project  has  a  deployment  window,  the  deployment  and  operations 
milestones  are  shown.  Any  difference  between  these  two  dates  indicates  that  a  migration  period  is 
planned. 

Regarding the implementation of  UCC Special  Procedures – Component 2 (SP IMP), the following 
Member States have a planned/actual deployment date that is later than the deadline in the UCC and/or 
the granted derogation deadline: AT, BE, CY, CZ, DK, FR, GR, MT, PT, and RO.  

52 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 have until 01/07/2024 to deploy the system. 

59 

 
 
 
 
Figure 24: Actual/Planned dates per milestone – SP IMP  

60 

 
 
 
 
3.5 UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) – PHASE 1 

The UCC Centralised Clearance for Import (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 (VAT). 

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

Phase  1  (CCI-P1)  will  cover  the  combination  of  centralised  clearance  with  standard  customs 
declarations and may also cover 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.  

For Phase 2 (CCI-P2), please refer to Section 4.4.  

3.5.1 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-P1  conformance  testing  activities  through  the  CCN2ng  exchange 
platform.  

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 the 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 in Q1 2024. 

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 
standard  declarations  and  the  freedom  to  choose  the  message  type  (CCI-P1  or  CCI-P2),  providing 

61 

 
 
flexibility for other combinations of CCI-P1, such as CCI-P1 with simplified declaration and includes 
an extended deadline for CCI-P1. Additional facilitation is provided by enabling the implementation of 
CCI-P1 functionalities using CCI-P2 (Full) Scope Technical System Specifications (TSS) (i.e., the ones 
also supporting the functionalities of the CCI-P1 system), preventing the need for a transition from CCI-
P1 to CCI-P2. Furthermore, in the aim to facilitate the work to the Member States, DG TAXUD created 
CCI-P2 (Full) Scope TSS package that consolidates the specifications for both phases, offering a single 
package that covers all CCI scenarios and processes. Accompanying this package, the CCI-P2 (Full) 
Scope Technical Specifications Guide has been produced aimed at helping the Member States and the 
traders on how to use CCI-P2 (Full) Scope TSS for the correct implementation of both phases’ scope. 

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 CCI project, most of the Member States 
indicated a medium to high level of risk.  

Aside from the interdependencies between the core and supporting systems, the Member States shared 
that the risk of delay in the development of the system is increased by human and financial resource 
constraints,  lengthy  procurement  processes,  replacement,  or  upgrades  of  supporting  platforms,  and 
concurrent  development  of  multiple  projects.  Additional  factors  contributing  to  the  project  delays 
include  the  lack  of  business  knowledge,  adjustments  in  the  development  strategy  and  coordination 
challenges with contractors.  

The Member States  reported the implementation of  several measures to mitigate the delays, such as 
strengthening project management, improving coordination with the contractors, implementing CCI-P1 
and CCI-P2 simultaneously, performing impact analysis, optimising the allocation of resources and/or 
implementing an Agile methodology to reduce the development timeframe. 

The above summary also applies to CCI-P2. 

In terms of assessing the level of completeness of the system, BG, EE, ES, HR, LU, LV, PL, and RO 
reported the project as completed, while LT is on target. AT, CY, CZ, DE, DK, FI, FR, GR, HU, IE, IT, 
MT, NL, PT, SE, SI, and SK shared that the project is delayed beyond the deployment deadline. BE did 
not provide concrete dates, but informed that it will be delayed. In addition, FI53, PT, and SK submitted 
a written notification asking for a derogation under Article 6(4) of the UCC to DG TAXUD concerning 
the delay of CCI-P1 beyond the legal deadline. 

Detailed Responses: 

Table 16 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

Additional Comments 

AT 

Medium  Same response as for TS. 

BE 

High 

BE  informed  that  CCI-P1  will  be  delayed  and  attributed  a  high  risk  at  the 
project's timely delivery. The delays stem from a lack of capacity on both the 
business  and  IT  sides,  more  complex  integrations  than  anticipated,  slower 
development  than  expected,  and  strategic  changes  during  the  project.  To 

53 Information provided from a bilateral meeting between FI and DG TAXUD held on 02/04/2024. 

62 

 
 
 
 
MS 

Risk 
Level 

Additional Comments 

simplified/supplementary  declarations 

mitigate the delay, BE has revised its strategy and will be taking a more focused 
and linear approach to the project's development. By the end of 2024, BE aims 
to  deliver  the  Presentation  Customs  Office  (PCI)  and  Supervising  Customs 
Office  (SCI)  components  for  pre-lodged/standard  declarations,  which  will 
include 
for  both  components. 
Additionally, BE shared it is using an Agile approach to develop the system. 
BG  reported  that  the  CCI-P1  system  started  operations  on  15/01/2024.  In 
addition, BG indicated that CCI-P1 functionalities fall within the scope of NIS, 
which was upgraded according to the new Annex B requirements and CCI-P1 
business processes.  
CY assessed a high risk to the timely delivery of the project since it is delayed 
beyond the deployment deadline and plans to be in operations on 30/10/2024. 
The  delays  are  attributed  primarily  to  procurement  issues  and  complex 
interdependencies among core and supporting systems, including replacement 
or  upgrades  to  TARIFF,  QUOTA,  Manifest,  Accounting,  Customs  and  Tax 
Warehouses  Systems,  and  the  National  Registration  and  Representation  TP. 
Additionally,  coordination  need  between  subcontractors  has  caused  further 
delays.  CY  shared  that  it  has  implemented  corrective  project  management 
measures  and  added  additional  resources,  which  have  improved  the  project 
progress. Therefore, CY intends to complete the project by the end of 2024. 
CZ attributed a high risk to the timely completion of the CCI-P1 project and 
shared it will be delayed beyond the UCC WP deadline. Financial constraints 
are the main reason for the delay, which is hindering the development of NIS. 
Development  began  in  February  2024,  with  future  progress  dependent  on 
securing additional financial resources. CZ opted to develop and deploy CCI-
P1  and  CCI-P2  simultaneously  to  streamline  the  process  and  it  plans  to  be 
operational on 15/12/2025. Furthermore, CZ is using an Agile framework to 
develop the project. 
DE indicated that the deployment of CCI-P1 will be delayed and shared that it 
plans to implement CCI-P1 alongside CC1-P2 on 15/11/2025.  
DK indicated a high risk of delay beyond the UCC WP deadline, as CCI-P1 is 
pending the deployment of NIS. Delays stem from prioritising the export and 
transit projects over its import system. DK has been implementing mitigating 
measures  with  the  supplier;  however,  complexity  in  the  development  and 
testing  phases  have  been  a  challenge.  DK  aims  to  deploy  the  system  by 
02/06/2025 and is using an Agile approach for its development. 
EE shared that the CCI-P1 system has been in production since 09/06/2024. In 
addition, EE implemented an Agile approach for the development of CCI, with 
different iterations. 
ES  reported  that  the  project  was  completed  for  CCI-P1  specifications. 
However, as the system has been redefined with CCI-P2 specifications, ES is 
updating the project and envisages it completed by the end of the 2024. ES 
shared  that  an  iterative  development  approach  is  being  used  for  the 
development. 
FI reported the system being delayed beyond the deadline set in the UCC WP 
and  assessed  a  high  risk  to  the  development  of  the  system  due  to  limited 
resources on the supplier’s side. To mitigate the delay, FI negotiated with the 
supplier  at  management  level,  focusing  on  project  planning  and  progress 

BG 

N/A 

CY 

High 

CZ 

High 

DE 

N/A 

DK 

High 

EE 

Low 

ES 

Low 

FI 

High 

63 

 
 
MS 

Risk 
Level 

FR 

N/A 

GR 

High 

Additional Comments 

monitoring. However, FI requested a derogation to deploy the system by Q2 
202554. At the moment of writing, conformance testing Mode 2 is ongoing.  

FR  indicated  that  it  plans  for  the  CCI-P1  system  to  be  operational  on 
20/06/2026 beyond the legal deployment deadline.  
GR  shared  that  the  CCI-P1  system  is  delayed  beyond  the  legal  deployment 
deadline  and  aims  to  deploy  the  system  in  Q2  2025  alongside  CCI-P2.  GR 
assessed a high risk to the timely delivery of the project given delays caused 
by procurement issues impacting all UCC and MASP projects. GR reported 
that it is exploring alternative solutions  to fulfil its legal obligations, but no 
final decisions have been made. GR aims to start the development of the system 
by the end of 2024; however, it noted that the project's start depends on the 
resolution of procurement challenges. 

HR 

Low 

HR informed that the system became operational on 30/09/2024.  

HU  indicated  that  the  CCI-P1  system  is  facing  delays  beyond  the  legal 
deadline,  with  a  medium  risk  related  to  its  timely  completion.  The  primary 
cause  of  the  delay  is  human  resource  constraints.  In  response,  HU  has 
reorganised  task  sequences  and  allocated  additional  resources  to  key  areas, 
enhancing  efficiency  through  resource  optimisation.  technical  specifications 
for  the  project  are  planned  to  be  updated  on  15/10/2024,  and  connectivity 
testing  is  currently  underway.  HU  plans  to  deploy  the  system  by  on 
02/06/2025. Furthermore, CCI-P1 is being developed concurrently with CCI-
P2, using Jira to manage the project's Agile development. 
IE  assessed  the  project  as  being  delayed  beyond  the  foreseen  deployment 
deadline. IE initially scheduled CCI-P1 deployment for June 2024, however, it 
has  shifted to  20/01/2026 as  both  CCI-P1  and  CCI-P2  will  be implemented 
concurrently with the NIS upgrade55. By the end of 2024, the contractor will 
deliver the software and conformance testing will commence in January 2025. 
The  main  reasons  for  this  delay  include  technical  issues  with  IE’s  existing 
national  import  application  that  require  prioritisation  as  well  as  the 
development of multiple projects during the 2024-2025 period. These issues 
strained the limited internal and external resources.  
IT shared that the CCI-P1 project is delayed. IT indicated that the delay stems 
from the project's complexities, which involve integrating several components 
from NIS, including the risk engine and control component, customs decisions, 
and accounting functions. IT aims to complete conformance testing and deploy 
the system by 04/11/2024 with the standard declaration.  
LT  shared  that  CCI-P1 is  on  target  and  aims  to  deploy  the  system  by 
01/07/2024. Additionally, LT informed that its National Planning was aligned 
with the revised UCC WP.  
LU reported that CCI-P1 has been in production since 30/06/2024, with CCI-
P2 messages56. 
LV reported the development as completed on 01/07/2024, except for the latest 
Request  for  Change  (RfC).  Conformance  testing  Mode  1  has  started  and 
additional changes in its system are needed due to particular testing scenarios. 

HU 

Medium 

IE 

Medium 

IT 

Medium 

LT 

Low 

LU 

LV 

Medium 

54 Information provided from a bilateral meeting between FI and DG TAXUD held on 02/04/2024. 
55 The information shared by IE in the survey has been updated based on a bilateral meeting between IE and DG 
TAXUD held on 26/03/2024. 
56 Information provided from a bilateral meeting between LU and DG TAXUD held on 22/07/2024. 

64 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

MT 

Medium 

NL 

High 

PL 

Low 

PT 

High 

LV associated a medium risk level to the timely delivery of the system due to 
recurrent RfCs during the development process, lack of time for testing and 
insufficient resources from both the LV customs team and the IT developer 
side,  given  the  simultaneous  development  of  numerous  projects.  LV  shared 
that an Agile and iterative approach was used.  
MT assessed the project as being delayed beyond the UCC WP deadline as the 
deployment  of  CCI-P1  is  scheduled  for  April  2025 57 .  Currently,  the 
development and integration of systems is ongoing. Concerning the reasons of 
the delay, MT indicated insufficient resources and planning as well as a lack 
of  business  knowledge.  In  addition,  MT  shared  the  use  of  a  Scrum 
methodology to validate the progress every three weeks. 
NL  reported  the  system  as  being  delayed  beyond  the  foreseen  UCC  WP 
deadline, which results in a high risk to the timely delivery of the project. An 
impact analysis is being conducted to evaluate the effects of implementing the 
CCI  system.  As  a  result  of  it,  NL  plans  to  deploy  CCI-P1  and  CCI-P2 
concurrently by 01/05/2025. In addition, NL shared the adoption of an iterative 
methodology for the building and testing of this system. 
PL shared that the CCI-P1 system was deployed on 01/07/2024, using an Agile 
approach for its development.  
PT reported the project as being delayed. The primary causes of delay were 
outlined in PT’s derogation request under Article 6(4) of the UCC submitted 
on  07/06/2022,  and  in  the  subsequent  derogation  request  submitted  on 
04/12/2023.  Moreover,  the  complexity  and  risk  associated  with  the  project 
were heightened by (a) the implementation of a complex new NIS as a basis of 
the CCI system; (b) the intricate interdependencies among various national and 
EU systems; and (c) the halt in development from mid-2023 to the end of 2023 
due to challenges in procurement and tendering, particularly in renewing the 
provider’s contracts. To address the delays, an Agile development strategy will 
be  implemented  to  shorten  the  implementation  period.  Additionally,  PT’s 
National Planning has been updated to include revisions to the conformance 
testing period with the Commission and EOs, along with modifications to the 
deployment date, now planned for 29/10/2024. 

RO 

RO indicated that the CCI-P1 system went into operations on 01/07/2024. 

SE 

Medium 

SI 

Medium 

SE reported a delay in the project beyond the deployment deadline due to the 
simultaneous development of several systems and the potential impact of an IT 
platform change on its implementation. To mitigate the delay, SE has allocated 
more human and financial resources to the project, increasing the possibility to 
deliver it according to the National Planning provided. SE shared its plans to 
publish the technical specifications on 02/12/2024 and have the conformance 
testing environment available by 01/03/2025. The deployment of the system is 
planned for 02/06/2025.  
SI reported that the CCI-P1 system is delayed but assessed a medium risk to 
the  timely  delivery  of  the  project  and  the  subsequent  CCI-P2.  The  primary 
cause  of  the  delay  lies  with  the  external  IT  contractor  that  has  concurrent 
commitments  with  other  UCC  projects  and  has  had  to  extend  the  project 
deadlines. This caused SI to adjust its National Planning aiming to have CCI-
P1  operational  on  02/12/2024.  By  the  end  of  2024,  SI  plans  to  implement 

57 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 

65 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

SK 

High 

conformance  testing  Mode  1,  Mode  2,  and  Mode  3  and  is  using  an  Agile 
approach for the system development.  
SK reported a delay in the CCI system beyond the UCC WP deadline and aims 
to deliver the CCI-P1 and CCI-P2 systems by 01/01/2026. SK attributed a high 
risk to the timely delivery of the project, primarily due to (a) the decision to 
develop  the  NIS  upgrade  and  the  CCI  system  as  a  single  project  to  avoid 
parallel  system  operations,  which  resulted  in  contract  delays;  (b)  resource 
constraints; and (c) delays in other critical projects. To address these delays, 
SK submitted a derogation request. 

Table 16: Detailed responses from Member States – CCI-P1 

Figure 25 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 25: Project progress and status per milestone – CCI-P1 

66 

 
 
 
 
 
3.5.2 Overview of Project Progress 

Figure 26 highlights any known divergences in the Member States’ National Planning compared to the 
dates  set  in  the  UCC  WP,  along  with  the  specific  dates  of  each  milestone.  As  this  project  has  a 
deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference  between 
these two dates indicates that a migration period is planned.  

Regarding UCC Centralised Clearance for Import – Phase 1 (CCI-P1), the following Member States 
have a planned/actual operations date that is later than the deadline in the UCC WP: AT, CY, CZ, DE, 
DK, FI, FR, GR, HR, HU, IE, MT, NL, PT, SE, SI, and SK. In addition, BE and IT did not provide 
information through their National Planning on the operations date. 

67 

 
 
Figure 26: Actual/Planned dates per milestone – CCI-P1 

68 

 
 
 
 
3.6 UCC GUARANTEE MANAGEMENT (GUM) – COMPONENT 1 

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  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.  

Component 1 (GUM-C1) covers the management of the comprehensive guarantees that may be used in 
more than one Member State. It is be implemented in the UCC CDS and will 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.  

For Component 2 (GUM-C2), please refer to Section 4.1.  

3.6.1 Summary of Responses 

Summary from the Commission: 

The UCC Customs Decisions system is being used to implement a decentralised system with minimal 
central IT support. Technical specifications for GUM-C1 were completed on 19 September 2022 and 
the system became operational in March 2024. The conformance testing activities for GUM-C1 remain 
available  until  the  Member  States  have  implemented  their  GUM-C2  system  within  the  June  2025 
deadline, for which it is their responsibility to plan accordingly. 

An iterative process was carried out 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. 

3.6.2 Overview of Project Progress 

Table 17 highlights any known divergences in the planning compared to the dates set in the UCC WP.  

Table 17: Comparison of Planned and Actual Dates – GUM-C1 

69 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/09/202219/09/2022Not provided11/03/202411/03/2024Technical SpecificationsDeployment 
 
 
 
3.7 UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE – 

COMPONENT 1 

This project aims to align the existing  New Computerised Transit System (NCTS) to the UCC legal 
provisions.  The  scope  of  the  project  includes  the  alignment  of  Information  Exchanges  to  UCC  data 
requirements, the upgrade and development of interfaces with other systems such as AES, in addition 
to new Safety and Security requirements. 

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

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

Component  1  (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, to 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 objectives58: 

•  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; 
•  Operational 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 trans-European system 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. 

NCTS-P5 will be deployed in two steps: the first related to core functionalities (operational continuity 
aligned  with  UCC)  and  the  second  to  non-core  functionalities  (Pre-Lodgement,  Incident  ‘en  route’ 
Management, Office of Exit and Export followed by Transit). The National Administrations have the 
possibility to deploy both steps at once or to deploy them in sequence. 

58 The same objectives will also be met by AES-C1. 

70 

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

Figure 27: NCTS-P5 timeline 

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); 

•  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 CTC contracting parties. In the case of external or national domains, 
the common NCTS specifications are strongly recommended, aiming to harmonise the transit formalities 
as much as possible among the CTC contracting parties. The UCC Data Annex B and Annex A3a of the 
CTC Convention are the binding legal framework for Transit Declarations. 

There are 39 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  with  Liechtenstein  connected,  Republic  of  Serbia,  Republic  of  North 
Macedonia, Norway with Iceland connected, Türkiye, Ukraine, and the United Kingdom). Montenegro, 
Georgia, and Moldova are acceding countries to the CTC Convention at various stages of preparation. 
Georgia is targeting entry into operation on 1 December 2024, while Montenegro and Moldova in 2025. 

For Component 2 (NCTS-P6), please refer to Section 4.5.  

3.7.1 Summary of Responses 

Summary from the Commission: 

The challenge for NCTS-P5 is to ensure  operational 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 specifications59 approved by the National Administrations govern 
the  quality,  technical  support,  operational  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 
the  National 
progress  among  the  National  Administrations.  The  collective  intelligence  of 

59 The Functional and technical specifications include Service Management, Service Level Agreements, Terms of 
Reference, Crisis Management, Capacity Plans and Security Plans. 

71 

 
 
 
 
 
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. 

Considering the delays reported by the National Administrations and by the trade community for their 
transition to NCTS-P5 (see below), the deadlines for the NCTS-P5 transition window have been updated 
in the UCC WP and in the TSS. These updates aim to ensure the operational continuity of NCTS until 
21 January 2025 while bringing them in alignment with the UCC Annex B. 

In the same package, the Central Project Team revised the deployment schedule for NCTS-P6 to avoid 
any overlap between the transition from NCTS-P4 to NCTS-P5 and from NCTS-P5 to NCTS-P6. The 
analysis showed that it was the only way to ensure operational continuity, given the technical constraints 
and the available resources of both the National Administrations and the Commission, as well as the 
alignment with the roll-out of ICS2-R360. 

The TSS have been improved based on past experiences and 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 ICS2-
R3 CR, a key component offering the interoperability between the NCTS and ICS2 systems. 

The Business Continuity Plan (BCP) for NCTS was decided to be maintained as described in the Transit 
Manual, including any necessary updates. In Q1 2024, the BCP update was started and made available 
to the National Administrations in October 2024. 

Migration to NCTS-P5 

The  National  Administrations  and  the  Commission  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. The quality of the specifications, the legal provisions supporting these 
systems  and,  most  importantly,  their  operational  continuity  was  demonstrated  throughout  2023  and 
2024. 

By 1 December 2023 (deadline for core functionalities), 14 National Administrations (DE, ES, SI, LU, 
HR, CH, DK, BG, CZ, EE, FI, IT, LV, and IE) were operational in the NCTS-P5 system. As of October 
2024, ten additional National Administrations (RS, SE, NO+IS, UA, CY, RO, XI, GB, and SK) have 
joined operations. 

Increasing progress of the National Administrations in 2024 (as of October 2024) 

The National Administrations reported significant progress in the deployment of their National Transit 
Application (NTA) in 2024. All National Administrations are actively engaged in implementing their 
transit application. 

Moreover, by the end of Q3 2024, 95% of the National Administrations are already in or have already 
completed  their  conformance  testing  activities,  26%  are  in  deployment  and  63%  are  already  in 
operations. 

60 As regards to the UCC WP Revision, NCTS-P5 will be deployed on 21 January 2025. The transition period from 
NCTS-P5 to NCTS-P6 is envisaged between 03/03/2025 and 01/09/2025, during the same period that ICS2-R2 
will transition to ICS2-R3, allowing for a synchronisation between both systems. 

72 

 
 
 
 
The completion percentage of the transition phase for the National Administrations collectively stands 
at 95% in Q3 2024 (Earned Value). 

The central converter, Information Exchange Conversion Application (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 28 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. 

All61 National  Administrations  re-confirmed  their timely  readiness  for  entry into operations  with  the 
core and non-core functionalities by 2 December 2024, with the exceptions of GR (on 31 December 
2024) and SM (on 21 January 2025). Thus far, all 25 entries in operations have occurred without causing 
any  disruption  to  the  continuity  and  quality  of  the  operations,  reflecting  the  effective  efforts  of  the 
National Project Teams.  

Figure 28: NCTS-P5 National Administrations entry into operations 

At the moment of writing, NL and PL plan to start operations by the end of October 2024. Additionally, 
GE  is  targeting  1  December  2024  as  its  accession  date.  These  countries  will  boost  the  transition  of 
NCTS-P5 as key actors in terms of number of transit movements. 

Overall, the National Administrations have collectively achieved significant progress and, despite the 
frequent shift in planning, it remains expected that all of them will be able to enter operations before 21 
January 2025. 

61 Except for SM which has not yet provided a National Planning.  

73 

 
 
 
 
 
 
 
 
 
Recommendations to the Member States 

The Commission invited the Member States that are running over the 1 December 2023 milestone for 
the core functionalities, to maintain a high level of compliance with all their national projects and to 
strictly respect the important milestone of 2 December 2024 and the legal deadline of 21 January 2025. 

The National Administrations not yet operating in the NCTS-P5 system were invited to give the highest 
priority to the NCTS-P5 project. Entering operations with sufficient resources allocated and optimised 
organisational structure will help those Member States to keep the deadline. All the required steps must 
be taken to minimise as much as possible the delays after 2 December 2024. 

The National Administrations are also reminded to implement all requirements of the Design Document 
for National Transit Application (DDNTA-5.15.1-v1.00), including transitional Rules and Conditions, 
to ensure operational continuity. The National Administrations are invited to adjust their NCTS-P5 set-
up to the RFC-List.38 and RFC-List.39 to ensure operational continuity from 21 January 2025. 

Additionally, the Commission invited the National Administrations that have not yet done so to publish 
their trade specifications in accordance with the latest DDNTA-5.15.2-v2.00 and RFC-List promptly.  

National Administrations that do not offer a transition window to their trade should communicate their 
transition strategy well in advance to the EOs. This will allow adequate time for the development and 
testing of the trade system. Member States that offer a transitional window should track the progress of 
their  EOs  and  periodically  report  via  submission  of  the  updated  national  project  plan  template  or 
business statistics. 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,  to  monitor  the  operational  continuity 
during the transition and to foster closer collaboration with the National Administrations.  

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

Considering  that  the  majority  of  the  National  Administrations  are  currently  engaged  in  the 
implementation and deployment of NCTS-P5, the Coordination Programme must also provide support 
to the National Administrations to coordinate the entry of trade into operations.  

The national project plan template has been updated to include additional milestones pertaining to the 
upload of business statistics as well as the projected or actual data on progress of transition by traders 
and their software providers.  

In  2024,  DG  TAXUD  closely  monitored  the  deployment  progress  of  trade  via  the  Coordination 
Programme and report to each Electronic Customs Coordination Group (ECCG) meeting. On 25 October 
2024, the transition by traders at departure was completed in all countries already operating in NCTS-
P5, except for IE, IT, and LU.  

Summary from the Member States: 

Most Member States reported a low to medium risk level on the on-time delivery of NCTS-P5.  

The risk-causing factors of delay reported by the Member States are related to difficulties in the tender 
procedures,  procurement,  and  coordination  with  service  providers,  along  with  interdependencies 
between various national systems, simultaneous development of multiple projects, delays from traders, 
and a lack of human and financial resources. Many Member States adopted an Agile methodology or an 
iterative approach to shorten the implementation timeframe, while also allocating additional resources 
to the project and strengthening the project management. 

74 

 
 
In terms of assessing the level of completeness of the system in the moment of writing, BG, CZ, DE, 
EE, ES, HR, RO, SE, and SI reported the entry into operations of the full system. BE did not provide 
concrete date through its National Planning but reported the project as delayed. 

The rest of Member States reported it will be operational before the end of the deployment window 
deadline: AT, CY, DK, FI, FR, GR, HU, IE, IT, LT, LU, LV, MT, NL, PL, PT, and SK. While most of 
these Member States will implement the system in full, some are joining operations as follows: CY, FI, 
and LV have the core functionalities (Step 1) in operations and aim to have the non-core functionalities 
(Step 2) operational before the end of 2024, while IE plans to have all functionalities operational before 
the deadline. 

Additionally,  PT and  SK  submitted a  written  notification  asking  for  a  derogation  under  Article  6(4) 
UCC to DG TAXUD concerning the delay of NCTS-P5 beyond the deadline. 

Detailed Responses: 

Table 18 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Medium 

BE 

High 

Additional Comments 

AT  reported  a  delay  in  NCTS-P5  and  shared  that  the  system  will  be  in 
operations in full by 02/12/2024. AT attributed a medium risk to the timely 
delivery of the project and stated the primary cause of delay was the need to 
re-initiate the tender procedure, which has now been completed. AT informed 
that communications with the Commission are ongoing to address the risks. 
The  delay  indicated  refers  to  the  core  functionalities  (Step  1),  while  the 
remainder of the project stays on schedule. Additionally, AT shared that it is 
using an Agile approach tailored by the software provider.  
BE  reported  a  delay  in  NCTS-P5  and  attributed  a  high  risk  to  the  timely 
delivery of the project. The delays are due to technical issues, strategic changes 
during the project, development slower than expected, and loss of experienced 
team  members.  In  response,  BE  shared  that  it  has  adjusted  its  strategy  by 
redirecting the development teams' focus on the main flows and prioritising the 
completion of core functionalities (Step 1) by the end of 2024. In addition, BE 
is using an Agile approach to develop the project.  

BG 

N/A 

BG reported that the NCTS-P5 system started operations on 28/08/2023. 

CY informed about a delay in the project but still plans for a delivery within 
the  end  of  the  deployment  window  deadline.  CY  deployed  the  core 
functionalities  of the system (Step 1) on 24/04/2024 and aims to deploy the 
non-core  functionalities  (Step  2)  on  02/12/2024.  The  delays  are  attributed 
primarily to procurement issues and complex interdependencies among core 
and supporting systems that have been late, including replacement or upgrades 
to  TARIFF,  QUOTA,  Manifest,  Accounting,  Customs  and  Tax  Warehouses 
Systems, and the National Registration and Representation TP. Additionally, 
the  need  for  coordination  between  different  contractors  and  redesign 
procedures  has  caused  further  delays.  CY  shared  that  it  has  implemented 
corrective  project  management  measures  and  added  additional  resources, 
which improved the project progress. 
CZ informed that the NCTS-P5 system started operations on 01/10/2023, with 
all traders onboarded.  

CY 

Medium 

N/A 

CZ 

DE 

N/A 

DE shared that the NCTS-P5 system has been operational since 29/10/2023. 

DK 

Low 

DK plans for the NCTS-P5 system to be operational by 30/06/2024 and aims 
to  implement  RfC-List.37  ‘Export  followed  by  Transit’  functionality  by 

75 

 
 
MS 

Risk 
Level 

Additional Comments 

21/01/2025. The deployment and migration of the EOs is expected to be in line 
with the new UCC legal deadline62. 

N/A 

EE reported that the NCTS-P5 system started operations on 01/10/2023. 

EE 

ES 

N/A 

FI 

Low 

FR 

Low 

GR 

Medium 

ES  shared  that  the  system joined  operations  on  12/03/2024,  with  all  traders 
onboarded. 
FI informed that the NCTS-P5 project will be delivered following the multiple-
step  approach  introduced  in  the  2023  UCC  WP  revision.  The  core 
functionalities of the system (Step 1) were deployed in Q3 2023, while the non-
core functionalities (Step 2) are planned for Q4 2024. 
FR reported the NCTS-P5 project as delayed but still on track to meet the end 
of  the  deployment  window  deadline.  FR  shared  that  the  delays  are  due  to 
budgetary constraints that halted the project in 2023. Progress on the project 
resumed in early 2024 after the budget was re-evaluated to ensure deployment 
on 28/10/2024. FR shared that its objectives for the year include completing 
Human  Machine  Interface  (HMI)  developments  for  the  Direct  Trader  Input 
(DTI) before conducting a certification with Electronic Data Interchange (EDI) 
service  providers  as  well  as  proceeding  with  conformance  testing  Mode  2 
between  April  and  June  2024  and  Mode  3  between  August  and  September 
202463. FR indicated that the timeline to finalise the system is tight but deemed 
it achievable, as it has recalibrated its resources to meet upcoming milestones. 
FR has extended its transition period until 21/01/2025.  
GR reported that the NCTS-P5 system is delayed. The primary cause of delay 
are procurement issues, especially in securing a contract to cover all UCC and 
MASP projects given the short timeframes expected. To mitigate the delay, GR 
shared that it is exploring how to upgrade its current national system to support 
NCTS-P5 messages. Additionally, GR aims to be in operations by 16/12/2024 
and is developing the system using an Agile framework.  

HR 

N/A 

HR shared that the NCTS-P5 system has been operational since 01/06/2023.  

HU 

Medium 

IE 

Low 

IT 

Low 

HU assessed a medium risk to the timely delivery of NCTS-P5 but still expects 
to deliver within the end of the deployment window deadline. The delay stems 
from  internal  resource  shortages  and  significant  personnel  changes.  HU 
informed that there have been efforts to resolve the resource issues and that 
mitigation strategies are ongoing. Operations were originally planned for the 
end of 2023, but the project has been postponed and a new ‘go live’ date has 
been set on 02/12/2024.  
IE informed that the core functionalities of the system (Step 1) were deployed 
on 30/11/2023, as planned. However, since trader migration was delayed, IE 
expects the system to be fully operational by 02/12/2024. 
IT shared that the NCTS-P5 project is on target. The system was deployed on 
29/11/2023 and IT plans for it to be operational on 01/12/2024. In addition, IT 
informed  that  it  has  been  cooperating  with  the  EOs  and  has  extended  the 
projects migration period to help those still using the legacy messages to adapt 
to the new system.  

62 Information provided from a bilateral meeting between DK and DG TAXUD held on 01/02/2024. 
63 The information shared by FR in the survey has been updated based on a bilateral meeting between FR and DG 
TAXUD held on 13/03/2024. 

76 

 
 
 
 
MS 

Risk 
Level 

LT 

Low 

LU 

LV 

N/A 

MT 

Low 

NL 

Medium 

PL 

Medium 

PT 

High 

Additional Comments 

LT  reported  the  NCTS-P5  project  on  target  and  plans  to  deploy  it  on 
01/09/2024. Regarding the project progress, LT shared the following progress 
updates:  (1)  the  structures  of  electronic  messages  used  by  EUCDM  in 
information exchange processes underwent updates and testing in a dedicated 
environment; (2) the processes concerning new customs office roles and the 
integration  of  electronic messages specified  in  NCTS-P5  were implemented 
and tested within the same environment; (3) the ieCA converter used by the LT 
Entrepreneur  Portal  (NTKS)  during  the  transition  period  was  adopted  and 
tested and; (4) conformance testing Mode 1 was completed and Mode 2 has 
started64.  
LU reported that NCTS-P5 was deployed 10/05/2023. Additionally, LU shared 
that  most  EOs  have  transitioned  to  this  system,  and  it  is  working  with  the 
remaining EOs to ensure a full transition by 02/12/202465. 
LV entered operations with the core functionalities of the system (Step 1) on 
27/11/2023.  Regarding  the  non-core  functionalities  (Step  2),  deployment  is 
planned for 01/12/2024.  
MT  assessed  the  NCTS-P5  system  as  being  delayed  but  aims  to  have  all 
functionalities operational by 21/01/202566. Regarding the causes of the delay, 
MT noted the postponement of the tender, the installation of the solution and 
the risk engine procurement. In addition, MT shared the adoption of an Agile 
and iterative approach.  
NL  indicated  the  NCTS-P5  system  as  being  delayed,  but  the  delivery  is 
expected within the end of the deployment window deadline. The reason for 
the  delay  relates  to  the  fact  that  the  complexity  of  the  system  construction 
exceeded initial expectations. By the end of 2024, operation, and migration, 
along with multiple long lived legacy messages, are expected to be finalised. 
To  mitigate  the  delay,  NL  transitioned  from  an  inhouse  development  to  a 
contractor’s package in 2023 which expedited the production by nearly a year. 
In  addition,  NL  is  using  an  iterative  methodology  for  both  the  reception  of 
product and the trader’s migration to NCTS-P5. 
PL reported a project delay, but delivery is still anticipated within the end of 
the  deployment  window  deadline.  PL  noted  that  the  deployment  date  was 
postponed twice since Q1 2023, but it is currently expected on 31/10/2024. The 
main  sources  of  risk  identified  by  PL  are  unforeseen  problems  at  multiple 
national levels and areas. This, together with traders' lack of readiness, updates 
to trader specifications, and dependencies on other systems, contributed to the 
delay in the development of the system. To address these issues, the suppliers 
have accelerated programming and are working on implementing the changes 
to its commercial application. PL has also informed traders about the upcoming 
changes  to  minimise  its  impact.  In  addition,  PL  shared  it  is  using  an  Agile 
methodology  by  gradually  implementing  patches  and  functionalities  to  the 
system.  
PT assessed the project as being delayed,  but still expected to be completed 
within  the  deadline.  The  main  reasons  for  the  delay  were  detailed  in  PT's 
derogation  request,  submitted  in  line  with  Article  6(4)  of  the  UCC  on 
04/12/2023.  PT  shared  that  the  project  was  further  delayed  due  to  (a)  the 

64 The information shared by LT in the survey has been updated based on a bilateral meeting between LT and DG 
TAXUD held on 12/03/2024.  
65 Information provided from a bilateral meeting between LU and DG TAXUD held on 22/07/2024. 
66 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 

77 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

implementation  of  a complex  new  National  Transit  system;  (b) the  intricate 
interconnections between various national and EU systems; and (c) a halt in 
the development between mid-2023 to the end of 2023 due to procurement and 
tendering  difficulties,  particularly in  renewing  the  developer’s  contracts.  To 
mitigate  the  delay,  an  Agile  development  approach  will  be  adopted  to 
streamline the implementation timeframe. Furthermore, the National Planning 
was  revised  to  include  updates  to  the  conformance  testing  period  with  the 
Commission and EOs, and adjustments to the deployment date. PT plans to be 
in operations by 02/12/2024. 
In addition, PT shared that due to its geographical location, it is unlikely that it 
will assume the role of customs office of exit for transit. Therefore, PT will not 
implement this functionality immediately, that is, on 02/12/2024. In the event 
that PT decides to move forward with this implementation, it will only occur 
at the end of 2025. Although PT is evaluating whether there is any theoretical 
situation in which it could assume the role of customs office of exit for transit, 
a decision will be made only after this evaluation is completed. Consequently, 
PT will determine whether or not to implement this functionality based on the 
outcome of the evaluation. 

RO shared that the NCTS-P5 project has been operational since 15/05/2024.  

N/A 

SE reported that the NCTS-P5 system started operations on 28/01/2024. 

N/A 

SI informed that the NCTS-P5 system has been operational since 22/02/2023.  

RO 

SE 

SI 

SK 

Low 

SK reported a delay in the NCTS-P5 system due to unfinished contracts that 
have  affected  the  project's  schedule.  Additionally,  resource  constraints  and 
delays  in  other  critical  projects  have  led  to  a  further  postponement  of  the 
project timeline. To address these delays, SK submitted a derogation request. 
SK aims to develop the new NTA and have the NCTS-P5 system in operations 
on 14/07/2024.  

Table 18: Detailed responses from Member States – NCTS-P5 

Figure 2967 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 29: Project progress and status per milestone – NCTS-P5 

67 The progress shown in the figure considers the 2023 UCC WP approach. A project is considered delayed beyond 
the anticipated deployment deadline if it extends past the end of transition date (21/01/2025). 

78 

 
 
 
 
 
 
 
The risk assessment of National Planning of the National Administrations by the Commission services 
is shown and substantiated in the Table 19 below: 

Table 19: Risk Assessment by the Commission: NCTS-P5 

79 

 
 
 
 
3.7.2 Overview of Project Progress 

Figure 30 highlights any known divergences in the Member States’ National Planning compared to the 
dates  set  in  the  UCC  WP,  along  with  the  specific  dates  for  each  milestone.  As  this  project  has  a 
deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference  between 
these two dates indicates that a migration period is planned. 

Regarding UCC New Computerised Transit System Upgrade – Phase 5 (NCTS-P5): 

•  The Member States that plan to deliver the system in full and have a planned/actual operations 
date that is later than the single operations deadline in the UCC WP are AT, DK, ES, FR, GR, 
HU, IT, LT, LU, MT, NL, PL, PT, RO, SE, and SK; 

•  The  Member  States  that  plan  to  deliver  the  system  by  steps  and  have  a  planned/actual  step 
operations date for the core functionalities (Step 1) that is later than the deadline in the UCC 
WP are CY and IE; 

•  BE did not provide information on the operations date.  

80 

 
 
 
 
 
81 

 
 
 
 
Figure 30: Actual/Planned dates per milestone – NCTS-P5 

82 

 
 
 
 
 
Figure  31  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 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 12 July 2024 and other 
information collected from the National Administrations during the technical meetings68. 

At the end of Q2 2024, the deployment of NCTS-P5 stands at 89% (Earned Value), while it should be 
at 100% (Planned Value). The National Administrations are working to accelerate their projects and 
mitigate risks to meet the deployment milestones for the core functionalities as soon as possible and for 
the non-core functionalities by 2 December 2024. 

Figure 31: Conformance tests: Planned Value versus Earned Value – KPI1 – NCTS-P5 

68 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.  

83 

 
 
 
 
 
 
 
Figure 32 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 until 12 July 2024. 

The main peak of conformance tests during Q3 and Q4 2023 is now in the past. There might be some 
residual conformance tests activity in the background for the National Administrations that will deploy 
the  remaining  of  their  scopes  in  upcoming  iterations,  as  well  as  a  surge  of  deployments,  without 
WP. 
compromising 

compliance 

revised 

UCC 

their 

with 

the 

Figure 32: Conformance tests: Planned Value versus Earned Value – KPI2 – NCTS-P5 

84 

 
 
 
 
 
Figure 33 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  its  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 33: NCTS-P5 transitional period  

85 

 
 
 
 
3.8  UCC AUTOMATED EXPORT SYSTEM (AES) 

The Automated Export System (AES) project consists of an upgrade of both the existing trans-European 
Export Control System (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, Exit Summary Declaration (EXS) 
and Centralised Clearance for Export (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 operational continuity from Q1 2021 until the latest trader is migrated to AES.  

The following processes will be implemented: 

•  Export declaration pre-lodgement; 
•  Handling of simplified/supplementary declarations; 
•  CCE; 
•  Re-export notification; 
•  Export process followed by transit: interoperability with the NCTS trans-European system; 
•  Export handling of goods under excise duties suspension interoperability with EMCS; 
•  Exit Summary Declaration for Safety and Security at 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.  

Component 1 (AES-C1) relates to the trans-European AES system. 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.  

AES-C1 will be deployed in three steps: the first related to core functionalities (operational continuity 
aligned to UCC), the second to interface with Excise, and the third to non-core functionalities (Central 
Clearance,  Export  followed  by  Transit,  Pre-Lodgement,  and  simplified/supplementary  declarations). 
The Member States have the possibility to deploy all steps at once or to deploy them in sequence. 

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

Figure 34: AES-C1 timeline 

86 

 
 
 
Component 2 (AES-C2) 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 Member States. In 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 need to transition to the AES-C1 system by 
1 December 2023 for the core functionalities, by 13 February 2024 for the interface with Excise, and by 
2 December 2024 for the non-core functionalities.  

3.8.1 Summary of Responses 

AES – Component 1 (AES-C1) 

Summary from the Commission: 

For AES, the challenge lies in ensuring operational 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 specifications69 approved by the Member States govern the quality, technical 
support, operational 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 adoption of an Agile approach since the project's 
inception has yielded functional and technical quality as well as the actual progress among 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. 

Considering the delays reported during 2023 by the Member States and the trade community regarding 
their transition to AES-C1 (see below), the deadlines for AES deployment and the end date for transition 
were updated in the UCC WP revision and in AES TSS. These updates aimed to ensure the operational 
continuity of AES until 11 February 2025 and full compliance with the deadlines set in Article 278(3) 
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. 

69 The functional and technical specifications include Service Management, Service Level Agreements, Terms of 
Reference, Crisis Management, Capacity Plans and Security Plans. 

87 

 
 
 
 
A  new  business  scenario  for  the  recapitulative  supplementary  declaration  at  export  has  been 
incorporated  in  the  AES  system  specifications  to  promote  harmonised  implementations  of 
simplified/supplementary declarations functions in the national AES systems. 

Following the publication of the initial version of the AES Business Guidance in 2022 (versions for 
customs and for trade, available in English, German, and French), the first update was published at the 
end of 2023, accepted in ECCG97 in March 2024. This update was aligned with the Commission’s plan 
to provide regular updates of the Guidance to enhance the business understanding of AES functions. 

Additionally, at the end of 2023, a BCP for AES was established between the Member States and the 
Commission.  This  plan  outlines  the  measures  to  be  adopted  in  all  Member  States  in  the  event  of  a 
temporary failure of the AES system. In Q2 2024, an update of the BCP was launched, introducing slight 
changes in the BC-EAD-Form. The updated package was accepted by ECCG, by written procedure, in 
August 2024. 

Migration to AES-C1 

The  Member  States  and  the  Commission  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 2022. 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, the 
legal provisions supporting these systems and, most importantly, their operational continuity. 

By 1 December 2023 (deadline for the core functionalities), fourteen Member States (DE, ES, IE, NL, 
HR, SI, DK, BG, EE, CZ, CY, LV, LT and IT) were operational in the AES system. As of 2024, seven 
additional Member States (RO, BE, LU, SE, FI, PL and SK.) joined AES operations. 

Increasing progress of the Member States in 2024 (as of July 2024) 

The Member States reported significant progress in deploying their national export applications in 2024. 
Currently, all of the Member States are actively engaged in their implementation, amongst which three 
Member States are in development or in the connectivity stage and almost ready to start. 

Moreover,  18%  of  the  Member  States  are  currently  in  conformance  testing  activities,  7%  are  in 
deployment, and 75% are already in operation. 

The completion percentage of the transition phase for the Member States as a group stands at 87% in 
Q2 2024, exhibiting a 3% increase since Q1 2024.  

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 35 is based on the date at which a Member State joins the ‘To Be’ operation on the Common 
Domain with their core functionalities. 

Almost all Member States confirmed that they will be in operations with the core functionalities, the 
interface with Excise and the non-core functionalities by 2 December 2024. However, XI plans to enter 
into  operation  with  limited  business  core  functionalities  in  mid-December  2024,  GR  and  FR  are 
expected to delay beyond December 2024.  

As of mid-November 2024, DE, ES, IE, NL, HR, SI, DK, BG, EE, CZ, LV, IT, LT, CY, RO, BE, LU, 
SE, PL, FI and SK are active in AES-C1 operation. 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. 

88 

 
 
Figure 35: AES-C1 Member States entry into operations 

Meanwhile, FR, PT, HU, MT, and GR are experiencing difficulties to deliver on time. 

Overall, the  National  Administrations  have  collectively  achieved significant progress.  All  remaining 
National Administrations, except FR and GR, will enter into operations before 11 February 2025, with 
most joining before end of 2024. 

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 AES-C1 can be deployed in time or with the shortest delay possible. 

For Member States that are at risk of missing the deadline for the non-core functionalities or already 
indicated an entry in operation after 2 December 2024, the Member States 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 have been reminded about the implementation of all the requirements 
of the Design Document for National Export Application (DDNXA), including the transitional Rules 
and Conditions, to ensure operational continuity. The Member States are invited to adjust their AES-C1 
applications according to the approved RfCs to ensure business continuity beyond 2 December 2024. 

Additionally, the Commission invited the Member States that have not yet done so to publish their trade 
specifications in accordance with the latest DDNXA v5.15.1 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. Member States that offer a transitional window should track the progress of 
their traders and periodically report via submission of the updated National Project Plans template or 

89 

 
 
 
 
business statistics. Moreover, all Member States should initiate their outreach and support program 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 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. 

The National Project Plan template has been updated to include additional milestones pertaining to the 
upload of business statistics as well as the projected or actual data on progress of transition by traders 
and their software providers.  

DG TAXUD will monitor closely the deployment progress of trade via the Coordination Programme 
and report to each ECCG.  

Summary from the Member States: 

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

The  main  risk  factors  impacting  the  progress  of  the  project  include  delays  in  call  for  procurement 
procedures, interdependencies with other national systems, insufficient human and financial resources, 
delays on the traders’ side, and the implementation of national regulations. Additionally, most Member 
States reported the adoption of an Agile methodology or an iterative approach for the development of 
the  system  to  reduce  the  implementation  timeframe.  In  certain  instances,  this  measure  is  being 
complemented with the allocation of additional resources to the project and an increased support to the 
EOs. 

The above summary also applies to AES-C2. 

At the time of writing, BG, CZ, DE, DK, EE, ES, HR, RO, and SI reported the entry into operations of 
the full system.  

The rest of Member States shared their intentions to join operations for the core functionalities (Step 1) 
and, if applicable, the interface with Excise (Step 2) before the end of deployment window; except for 
FR and GR, which will be delayed beyond the legal deadline. Additionally, all Member States except 
for FI, FR, GR and HU aim to have the none-core functionalities (Step 3) operational by the deadline. 

Additionally, FI70 and PT submitted a written notification asking for a derogation under Article 6(4) of 
the UCC to DG TAXUD concerning the delay of AES-C1 beyond the deadline. 

Detailed Responses: 

Table 20 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Medium 

Additional Comments 

AT attributed a medium risk level to the timely delivery of the system. The 
primarily cause of the delay was a failed development cooperation, resulting 
in a re-initiation of the tender procedure. To mitigate the delays, AT has agreed 
to follow an implementation plan with the new developer and stated that the 
project's  delivery  is  anticipated  within  the  end  of  the  deployment  window 

70 Information provided from a bilateral meeting between FI and DG TAXUD held on 02/04/2024. 

90 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

deadline, with operations planned for 15/12/2024. AT informed of changes to 
its National Planning resulting from the implementation plan agreed with the 
new supplier, these include, a review of conformance testing dates and scope, 
conducting a fit-gap analysis, and finalising the project scope. In addition, AT 
has been using an Agile approach.  

BE 

BE shared that it plans to have AES-C1 in operations on 30/09/2024.  

BG 

N/A 

Same response as for SP EXP. 

CY 

Medium 

CY assessed a delay in the project but still plans for a delivery within the end 
of the deployment window deadline. CY reported that the core functionalities 
(Step  1)  went  into  production  on  18/12/2023,  and  it  aims  to  complete  the 
interface with Excise (Step 2) by 31/07/2024 and non-core functionalities (Step 
3) by 11/02/2025. The delays are attributed primarily to procurement issues 
and complex interdependencies among core and supporting systems that have 
been  delayed,  including  replacement  or  upgrades  to  TARIFF,  QUOTA, 
Manifest,  Accounting,  Customs  and  Tax  Warehouses  Systems,  and  the 
National  Registration  and  Representation  TP.  Additionally,  the  need  for 
coordination  between  different  contractors,  conformance  testing  delays,  and 
technical issues that required infrastructure transfer and recovery work have 
caused further delays. CY shared that it has implemented corrective measures, 
added additional resources, and strengthened support to the EOs, which have 
improved the project progress. 

CZ 

N/A 

CZ shared that the AES-C1 system has been operational since 01/10/2023.  

DE 

Low 

DK 

N/A 

DE reported that the AES-C1 project has been in operations since 29/10/2023 
with  all  EOs  migrated,  and  functionalities  for  Centralised  Clearance  and 
Interface  with  NCTS  incorporated  into  the  national  IT  systems  ATLAS 
(Release 9.1). DE has been using an Agile development approach to enhance 
the  project,  oversee  operations,  and  perform  conformance  testing  for  new 
functionalities of the system.  
DK reported the entry into operations of the AES-C1 system on 31/05/2024, 
with all EOs migrated. DK shared that it deployed the core functionalities (Step 
1)  on  27/07/2023  and  the  interface  with  Excise  (Step  2)  on  13/02/2024. 
Regarding the non-core functionalities (Step 3), DK aims to deploy them on 
21/01/2025. 

N/A 

EE indicated the entry in operations on 01/10/2023.  

EE 

ES 

N/A 

FI 

High 

ES reported that the AES-C1 system joined operations on 09/05/2023, with all 
EOs migrated. 
FI reported the project as delayed beyond the end of the deployment window 
deadline since the supplier has limited resources. Consequently, this poses a 
significant  risk  to  the  timely  delivery  of  AES.  To  mitigate  the  delay,  FI 
prioritised  the  supplier's  export  resources  towards  AES,  instead  of  NCTS. 
Additionally, FI opted to reduce the scope and engaged in negotiations with 
the supplier at a management level. Despite these efforts, some features had to 
be  postponed  deriving  into  a  delay  in  the  overall  project.  FI  requested  a 
derogation, planning to deploy the core functionalities of the system (Step 1) 

91 

 
 
 
MS 

Risk 
Level 

Additional Comments 

in  Q4  2024 and  the  non-core  functionalities (Step  3)  in  Q2  202571,  while  it 
indicated that the interface with Excise (Step 2) is not applicable.  
FR informed about a delay in the delivery of the project beyond the end of the 
deployment window deadline given the need to implement numerous national 
rules  as  well  as  AES  dependencies  on  NIS.  FR attributed  a  high  risk to the 
timely delivery of the system and consequently, plans to request an extension 
of the transition period. To mitigate these delays, FR has strengthened its team 
and is collaborating with TAXUD. With these mitigations in place, FR intends 
to  initiate  conformance  testing  activities  and  expects  to  deploy  the  core 
functionalities (Step 1) and the interface with Excise (Step 2) on 31/12/2025, 
and the non-core functionalities (Step 3) on 30/09/2027. Additionally, FR is 
using an Agile approach to manage this system's deployment. 
GR reported a delay in the AES-C1 system. The primary cause of the delay 
stems from challenges in securing a comprehensive contract for all UCC and 
MASP  projects.  GR  shared  that  the  short  timelines  given  to  implement  all 
requirements  and  the  systems  interoperability  with  EMCS  have  caused 
additional  challenges.  To  address  this,  GR  is  considering  an  upgrade  to  its 
existing national export system to support AES export messages. Moreover, 
GR is utilising an Agile framework to develop the system and aims to be in 
operations by 16/12/202472. 

FR 

High 

GR 

Medium 

HR 

N/A 

HR reported that AES-C1 has been operational since 03/05/2023.  

HU 

Medium  Same response as for SP EXP. 

IE 

Low 

IT 

Low 

LT 

N/A 

LU 

IE indicated employing the multiple-step approach outlined in the 2023 UCC 
WP  revision,  with  the  core  functionalities  (Step  1)  operational  since 
21/05/2023 and the interface with Excise (Step 2) deployed on 21/03/2024. IE 
specified that the deployment of the non-core functionalities (Step 3) with the 
Export Followed By Transit (EFBT) and CCE functionalities was moved to 
01/07/2024 to ensure compliance with the UCC WP. 
IT  shared  that  the  AES-C1  project  is  on  target  and  indicated  it  is  using  the 
multiple-step approach. IT reported the following information: The system’s 
core  functionalities  (Step  1)  have  been  in  operations  since  08/06/2023, 
interface  with  Excise  (Step  2)  was  deployed  on  13/02/2024,  and  non-core 
functionalities (Step 3) are scheduled for 01/12/2024. Additionally, IT reported 
that it is collaborating with the EOs and has extended the project's migration 
period to assist those still using legacy messages transition to the new system.  
LT  reported  that  AES-C1  core  functionalities  (Step  1)  and  interface  with 
Excise  (Step  2)  were  deployed  on  03/12/2023,  while  the  non-core 
functionalities (Step 3) are planned to be deployed on 01/09/2024.  
LU  informed that  AES  was  deployed  on 08/07/2024 and  despite challenges 
with some larger traders who are not yet prepared to switch to AES, LU aims 
to  be  operational  on  02/12/2024  with  all  EOs  migrated  into  the  system. 
Additionally, LU informed that the connection with EMCS is already live73. 

71 The information shared by FI in the survey has been updated based on a bilateral meeting between FI and DG 
TAXUD held on 02/04/2024. 
72 This  date  was  stated  in  Greece’s  National  Project  Plan,  this  is  now  outdated.  Updated  Figure  35  indicates 
deployment is expected beyond 2025. 
73 Information provided from a bilateral meeting between LU and DG TAXUD held on 22/07/2024. 

92 

 
 
 
 
 
MS 

Risk 
Level 

LV 

N/A 

MT 

Medium 

NL 

Low 

PL 

PT 

High 

Additional Comments 

LV indicated the use of the multiple-step approach introduced in the 2023 UCC 
WP revision. LV reported the following information: core functionalities (Step 
1)  entry  in  operations  on  10/10/2023,  interface  with  Excise  (Step  2) 
deployment on 13/02/2024  and non-core functionalities (Step 3) planned on 
01/12/2024.  
MT shared that AES has been developed and is currently in the testing phase, 
even with delays the deployment is planned for 11/02/202574.The project is at 
risk due to technical constraints in the import system operations date that has 
superseded  the  export  ‘go  live’  date75.  In  addition,  MT  shared  the  use  of  a 
Scrum methodology to validate the progress every three weeks.  
NL reported a project delay, but delivery is anticipated within the steps set in 
the  UCC  WP.  NL  shared  that  the  core  functionalities  (Step  1)  entered  into 
operations  on  01/1/2023,  interface  with  Excise  (Step  2)  on  13/02/2024  and 
non-core  functionalities  (Step  3)  are  planned  for  02/12/2024.  NL expects  to 
transition all traders to AES in 2024 before the end of the deployment window 
deadline.  However,  the  migration  is  proving  to  be  lengthier  than  initially 
estimated, impacting the overall system progress.  
In  addition,  NL  shared  it  is  employing  an  iterative  methodology  during  the 
transfer of traders to AES.  
PL  indicated  that  it  plans  to  have  the  AES-C1  system  in  operations  on 
31/10/2024.  
PT shared that the project is delayed. The primary reasons for the delay were 
shared in PT’s derogation request in accordance with Article 6(4) of the UCC, 
submitted  on  04/12/2023.  Additionally,  the  complexity  and  risk  associated 
with the project escalated due to (a) the challenges of establishing a new NES; 
(b) the intricate interdependencies among various national and EU systems; (c) 
the suspension of development from mid-2023 to the end of 2023 caused by 
procurement and tendering challenges, especially in renewing contracts with 
the suppliers. To mitigate the delays, an Agile development approach will be 
implemented to streamline the project timeframe. Furthermore, the National 
Planning was adjusted to reflect changes in the conformance testing schedule 
with the Commission and EOs as well as adjustments to the deployment date, 
now scheduled for 30/11/2024. At the moment of writing, PT shared that it is 
expected that a few functionalities may be phased into operations after the start 
date  of  operations,  due  to  the  intricate  interdependencies  among  various 
national and EU systems. 

RO 

RO informed that the AES-C1 system has been operational since 16/03/2024.  

SE 

Low 

SE reported the project as being delayed and aims to deploy the system in full 
on 01/10/2024. To address the delay, SE developed a plan in Autumn 2021 that 
was updated with the 2023 UCC WP revision. Concretely, the plan includes: 
(a) to perform a partial certification of Certificates A1 and A2 between April 
and May 2024, and Certificates A3 and A4 in August 2024; (b) to schedule the 
EIDR, EXD, and re-export notification to be deployed during 2025, without 
impacting other Member States or the Common Domain; and (c) to shorten the 
migration  period  compared  to  what  was  initially  anticipated.  The  traders 
expressed  a  preference  for  this  accelerated  migration  due  to  the  complexity 

74 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 
75 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 

93 

 
 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

associated  with  concurrently  using  both  the  old  and  new  systems,  owing  to 
differing process obligations.  

SI 

N/A 

SI shared that the AES-C1 system has been operational since 24/05/2023. 

SK 

Low 

SK assessed a delay in the AES-C1 project but anticipates it to be operational 
on 14/10/2024. SK attributed a low risk to the timely delivery of the project 
despite  delays  caused  by  a  postponed  start,  limited  human  resources,  and  a 
prolonged conformance testing period. Additional delays arose from necessary 
modifications to the NECA system. To mitigate these delays, SK shared it will 
postpone some of the non-core functionalities of the system. This strategy is 
designed  to  ensure  the  project  is  ready  for  operation  by  the  deployment 
deadline, however SK has indicated it may result in a temporarily less effective 
solution. By the end of 2024, SK aims to complete the conformance testing and 
UAT,  adjust  the  NECA  system,  provide  training  to  the  users,  communicate 
with the EOs, and initiate operations. 

Table 20: Detailed responses from Member States – AES-C1 

Figure 3676 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 36: Project progress and status per milestone – AES-C1 

76 The progress shown in the figure considers the 2023 UCC WP approach. A project is considered delayed beyond 
the anticipated deployment deadline if it extends past the end of transition date (11/02/2025). 

94 

 
 
 
 
 
 
 
 
 
 
The risk assessment of National Planning of the Member States by the Commission services is shown 
and substantiated in the Table 21 below: 

Table 21: Risk Assessment by the Commission: AES-C1 

95 

 
 
 
 
 
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 at the moment of writing, the following 
Member States reported the system as completed: BE, BG, CY, CZ, DE, DK, EE, ES, HR, IE, IT, LT, 
LU, LV, NL, RO, and SI. FI, HU, PL, PT, SE, and SK indicated delays but expect the delivery of the 
project within the deployment deadline, whereas AT, GR, and MT informed being delayed beyond the 
legal  deadline,  and  FR  did  not  provide  concrete  planning  on  AES-C2.  Additionally,  FI 77 and  PT 
submitted a written notification asking for a derogation under Article 6(4) of the UCC to DG TAXUD 
concerning the delay of AES-C2 beyond the deadline.  

Detailed Responses: 

Table 22 provides the individual updates from the Member States on their responses to the survey and 
the national plans provided: 

MS 

Risk 
Level 

Additional Comments 

AT 

Medium 

AT reported a delay beyond the UCC WP deadline in the AES-C2 system and 
attributed a medium risk to the timely delivery of the project. AT shared its 
plans to implement the system on 05/02/2025. The primary cause of delay was 
the need to re-initiate the tender procedure, which has now been completed. 
AT  informed  that  communications  with  the  Commission  are  ongoing  to 
address  the  risks.  Additionally,  AT  shared  that  is  using  an  Agile  approach 
tailored by the software provider.  
BE indicated that AES-C2 was deployed on 19/06/2024 and plans for it to be 
operational on 30/09/2024.  

N/A 

Same response as for SP EXP. 

N/A 

CY shared that the AES-C2 system started operations on 18/12/2023.  

N/A 

Same response as for AES-C1. 

N/A 

DK 

N/A 

DE  reported  the  completion  of  AES-C2,  the  system  has  been  in  operations 
since 29/10/2023.  
DK reported the entry into operations of the AES-C2 system on 31/05/2024, 
with all EOs migrated. 

EE 

ES 

N/A 

EE shared that the AES-C2 system joined operations on 01/10/2023.  

N/A 

ES informed that the AES-C2 system started operations on 09/05/2023. 

FI 

High 

FI  reported  the  project  as  delayed  since  the  supplier  has  limited  resources, 
consequently posing a risk to the timely delivery of AES. To mitigate the delay, 
FI prioritised the supplier's export resources towards AES, instead of NCTS. 
Additionally, FI opted to reduce the scope and engaged in negotiations with 
the supplier at a management level. Despite these efforts, some features had to 

77 The information shared by FI in the survey has been updated based on a bilateral meeting between FI and DG 
TAXUD held on 02/04/2024. 

96 

BE 

BG 

CY 

CZ 

DE 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

be  postponed  deriving  into  a  delay  in  the  overall  project.  FI  requested  a 
derogation78 for AES and is planning to deploy the system in Q4 2024.  

FR 

High 

FR indicated that the planning for AES-C2 is yet to be confirmed. 

GR 

Medium 

GR informed that it is experiencing a delay in the AES-C2 system beyond the 
UCC WP deadline. The main challenges have been procurement difficulties, 
particularly with securing a contract that can encompass all UCC and MASP 
projects with tight timelines to fulfil the export requirements. To address this, 
GR is considering an upgrade to its existing national export system to support 
into  operations  on 
UCC  provisions.  Additionally,  GR  plans 
16/12/2024and is utilising an Agile framework to develop the system79. 

to  go 

HR 

N/A 

HR reported that AES-C2 has been operational since 02/05/2023.  

HU 

Medium  Same response as for SP EXP. 

IE 

Low 

IT 

Low 

IE  shared  that  AES-C2  started  operations  on  21/05/2023.  Additionally,  IE 
reported that it expects to implement the RfC-List.39 by the end of 2024, with 
a focus on the development of the new declaration type IE515 and EIDR.  
IT  shared  that  the  AES-C2  has  been  in  operations  since  08/06/2023. 
Additionally, IT reported that it collaborated with the EOs and extended the 
project's migration period to assist those still using legacy messages transition 
to the new system. 

LT 

LU 

LV 

N/A 

LT indicated that AES-C2 was implemented on 03/12/2023.  

Same response as AES-C180. 

N/A 

LV reported that the AES-C2 system started operations on 10/10/2023.  

MT 

Medium  Same response as AES-C181. 

NL 

High 

NL  reported  the  AES-C2  system  has  been  in  operations  since  01/12/2023, 
however, it is experiencing  a delayed in the CCE component, thus posing a 
high  risk  to  the  timely  delivery  of  the  full  system.  An  impact  analysis  was 
conducted to evaluate the effects of implementing this feature, with the object 
of preventing further hindrance to the overall project progress. Following this 
analysis,  NL  announced  that  the  CCE  component  would  be  combined  with 
CCI-P1 and CCI-P2 and implement in Q4 202582. In addition, NL shared the 
adoption  of  an  iterative  methodology  for  the  building  and  testing  of  this 
functionality.  

78 The information shared by FI in the survey has been updated based on a bilateral meeting between FI and DG 
TAXUD held on 02/04/2024. 
79 This  date  was  stated  in  Greece’s  National  Project  Plan,  this  is  now  outdated.  Updated  Figure  35  indicates 
deployment is expected beyond 2025. 
80 Information provided from a bilateral meeting between LU and DG TAXUD held on 22/07/2024. 
81 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 
82 Information provided from an email communication between NL and DG TAXUD on 23/07/2024. 

97 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

PL 

Medium 

PT 

High 

PL assessed the project as being delayed, but overall, it is anticipated to remain 
within the projected UCC WP deadline. The implementation planning has been 
postponed twice since 2023, but PL aims to deploy the system on 31/10/2024. 
The  main  causes  of  the  postponement  include  the  delayed  publication  of 
messages for traders, especially in the export domain, as well as reports from 
traders indicating their lack of readiness, both from a business and technical 
standpoint, to transition to the new service rules and system. Moreover, PL is 
encountering  unforeseen  problems  at  various  national  levels  and  areas.  To 
address this situation, software providers have accelerated programming and 
continue  to  work  on  integrating  changes  into  its  commercial  applications. 
Efforts have also been made to increase trader awareness and familiarity with 
the upcoming changes. In addition, PL shared the use of an iterative and Agile 
methodology  depending  on  the  scale  of  changes  and  the  urgency  of  error 
elimination.  
PT reported the project as being delayed. The primary reasons for the delay 
were shared in PT’s derogation request submitted on 04/12/2023. These delays 
are due to (a) the intricate interdependencies among various national systems; 
and  (b)  the  suspension  of  development  from  mid-2023  to  the  end  of  2023 
caused  by  procurement  and  tendering  challenges,  especially  in  renewing 
contracts  with  the  supplier.  To  mitigate  the  delays,  an  Agile  development 
strategy will be implemented to shorten the implementation period.  
Additionally, the National Planning has been updated to include revisions to 
the conformance testing period with the Commission and the EOs, along with 
modifications to the deployment date, now set on 30/11/2024. 
At  the  moment  of  writing,  PT  shared  that  it  is  expected  that  a  few 
functionalities may be phased into operations after the start date of operations, 
due to the intricate interdependencies among various national and EU systems. 

RO shared that the AES-C2 system has been operational since 16/03/2024.  

RO 

SE 

SI 

Low 

Same response as for AES-C1. 

N/A 

Same response as for AES-C1. 

SK 

Low 

Same response as for AES-C1. 

Table 22: Detailed responses from Member States – AES-C2 

Figure 37 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 37: Project progress and status per milestone – AES-C2 

98 

 
 
 
 
 
3.8.2 Overview of Project Progress 

Figure  38  for  AES-C1  highlights  any  known  divergences  in  the  Member  States’  National  Planning 
compared to the dates set in the UCC WP, along with the specific dates of each milestone. As this project 
has  a  deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference 
between these dates, indicates that a migration period is planned. 

Regarding UCC Automated Export System – Component 1 (AES-C1): 

•  The Member States that plan to deliver the system in full and have a planned/actual operations 
date that is later than the single operations deadline in the UCC WP are AT, BE, DK, GR, LU, 
MT, PL, PT, RO, SE, and SK; 

•  The Member States that plan to deliver the system by steps and have a planned/actual operations 
date for the core functionalities (Step 1) and/or interface with Excise (Step 2) that is later than 
the steps deadline in the UCC WP are CY, FI, FR, and HU. Furthermore, FI, FR, and HU have 
a planned/actual operations date for the non-core functionalities (Step 3) that is later than the 
step deadline in the UCC WP. 

99 

 
 
 
 
 
100 

 
 
 
Figure 38: Actual/Planned dates per milestone – AES-C1 

101 

 
 
 
 
Figure 39 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 12 July 202483. 

At the end of Q2 2024, the deployment of AES-C1 stands at 87% (Earned Value), while it should be at 
100% (Planned Value). The Member States are working to accelerate their projects and mitigate risks 
due to running over the deployment milestones for the core functionalities on 1 December 2023 and for 
the interface with Excise on 13 February 2024 in order to meet the deployment milestone for the non-
core functionalities by 2 December 2024. 

Figure 39: Key milestones: Planned Value versus Earned Value – KPI1 – AES-C1 

83 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. 

102 

 
 
 
 
 
 
 
Figure 40 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 12 July 2024. 

The distribution of the conformance testing curve shifts to the right in comparison to the baseline, as 
Member States have completed or are completing their conformance testing campaigns during Q4 2023 
and over 2024.  

The main peak of conformance tests during Q3 and Q4 2023 is now in the past, however, another lower 
pick was also present in Q2 2024 with number of National Administrations performing the conformance 
tests. There might be some residual conformance tests activity in the background for those Member 
States  that  will  deploy  the  remaining  of  their  scopes  in  upcoming  iterations,  as  well  as  a  surge  of 
revised  UCC  WP. 
deployments,  without 

compliance  with 

compromising 

their 

the 

Figure 40: Conformance Tests: Planned Value versus Earned Value – KPI2 – AES-C1 

103 

 
 
 
 
 
Figure 41 below illustrates the four milestones set in Article 278(a) of the Regulation (EU) 2019/632 
amending Regulation (EU) 2013/952 as reported by each Member State in its 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 41: AES-C1 transitional period 

104 

 
 
 
 
 
Figure  42  for  AES-C2  highlights  any  known  divergences  in  the  Member  States’  National  Planning 
compared to the dates set in the UCC WP, along with the specific dates of each milestone. As this project 
has  a  deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference 
between these dates, indicates that a migration period is planned. 

Regarding UCC Automated Export System – Component 2 (AES-C2), the following Member States 
have  a  planned/actual  operations  date  that  is  later  than  the  deadline  in  the  UCC  WP:  AT  and  GR. 
Additionally, FR did not provide concrete information in its National Planning. 

105 

 
 
 
Figure 42: Actual/Planned dates per milestone – AES-C2 

106 

 
 
 
3.9 UCC PROOF OF UNION STATUS (PoUS) – PHASE 1 

The  UCC  Proof  of  Union  Status  (PoUS)  is  a  trans-European  system  designed  to  allow  storage, 
management, and retrieval of certain types of documents (e.g., T2L, T2L/F, Customs Goods Manifest 
[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. 

Phase 1 (PoUS-P1) covers the implementation of the electronic T2L (F) document with all the necessary 
functionalities. 

For Phase 2 (PoUS-P2), please refer to Section 4.3. 

3.9.1 Summary of Responses 

Summary from the Commission: 

The TSS were completed in Q1 2022. Conformance testing activities were completed by Q1 2024 and 
PoUS-P1 entered in operations on 1 March 2024 as planned. 

A few Member States might still have to finalise their development and testing to connect their national 
Risk Analysis (RA) system84 and/or a national non-PoUS systems85, usually a presentation system, to 
the central PoUS system. Until then, if the Member States decide to develop any of the abovementioned 
connections, it will be using the central PoUS system manually.  

Summary from the Member States: 

The Member States had the option of using the central PoUS system or developing their own national 
application. From all Member States, ES and PL developed a national system, which started operations 
on 1 March 2024, together with the central system.  

Detailed Responses: 

Table 23 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

ES 

PL 

Risk 
Level 

N/A 

N/A 

Additional Comments 

ES reported that the PoUS-P1 system was deployed on 15/01/2024 and joined 
operations on 01/03/2024. 
PL shared that PoUS-P1 has been deployed since 01/03/2024 and plans to join 
operations by 15/09/2024. 

Table 23: Detailed responses from Member States – PoUS-P1 

84 Member States that might develop connection with their RA system: BG, CY, CZ, HR, HU, and MT. 
85 Member States that might develop connection with other non-PoUS systems: BE, EE, FI, IT, and MT. 

107 

 
 
 
 
 
 
3.9.2 Overview of Project Progress 

Figure 43 highlights any known divergences in the Member States’ National Planning compared to the 
dates set in the UCC WP, along with the specific dates for the central and national system.  

Regarding UCC Proof of Union Status  – Phase 1 (PoUS-P1), all Member States will use the central 
PoUS system, except ES and PL. ES and PL along with the Commission reported the system deployed 
by 1 March 2024.  

Figure 43: Actual/Planned dates per milestone – PoUS-P1 

108 

 
 
 
 
 
4. ONGOING PROJECTS: DETAILED PLANNING AND PROGRESS 

INFORMATION 

Figure 44 provides an overview of the deployment windows of the ongoing UCC projects: 

Figure 44: Overview of ongoing projects  

109 

 
 
 
 
 
4.1 UCC GUARANTEE MANAGEMENT (GUM) – COMPONENT 2 

The UCC Guarantee Management (GUM) project aims to assure the effective and efficient management 
of the different types of guarantees. The main objective is to ensure that the data of guarantees, used in 
more  than  one  Member  State,  are  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.  

For Component 1 (GUM-C1), please refer to Section 3.6. 

Component  2  (GUM-C2)  which  relates  to  the  national  Guarantee  Management  system,  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 

Summary from the Member States:  

GUM-C2 refers to the development  of the  national  GUM systems of the Member States, which can 
largely be conducted in parallel with GUM-C1. 

Most Member States reported a low to medium risk level on the on-time delivery of GUM-C2, with few 
of them rating it as high. The project interdependency with other systems causing a lack of resources, 
along with procurement difficulties are indicated as the main risk-causing factors.  

Regarding the level of completeness, ES, IE, LT, LV, PL, and SE joined operations for the GUM-C2 
system, with PL planning an upgrade in 2025. Amongst the others, most Member States reported the 
delivery within the legal  deadline, except for DE, FR, and GR who plan to  extend beyond the legal 
deadline. Additionally, BE did not provide concrete planning information. 

Detailed Responses:  

Table 24 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Low 

BE 

BG 

Low 

Additional Comments 

AT  informed  that  the  GUM-C2  project  is  on  target  to  be  deployed  on 
02/06/2025 and assessed a low risk to the timely delivery of the project. By the 
end of 2024, AT aims to complete the planning and coordination stages with 
the software provider. Additionally, AT shared that is using an Agile approach 
tailored by the software provider.  

The  GUM-C2  project  entails  upgrading  the  existing  national  GUM  system. 
According  to  BG,  GUM-C2  is  on  target  with  minimal  risk  concerning  the 
timely completion of the project by 14/04/2025. In 2023, the tender process 
concluded, and the inception phase was completed, which led to the initiation 
of the elaboration phase. By the end of 2024, BG aims to have the construction 
phase  accepted.  BG  is  using  an  Agile  and  iterative  approach  for  the 
development of the system by implementing two technological frameworks, 
namely TOGAF/ADM and RUP. 

110 

 
 
 
 
MS 

Risk 
Level 

CY 

High 

CZ 

Low 

DE 

DK 

Medium 

EE 

Low 

Additional Comments 

requirements  and  specifications  and 

issues,  complex  interdependencies  between  systems, 

CY  reported  that  the  GUM-C2  project  is  on  target  to  be  deployed  on 
02/06/2025 but identified a high risk of delay concerning the timely delivery 
of the project. CY shared that the delays stem from several factors, including 
procurement 
the 
necessity  for  coordination  among  contractors,  ongoing  development  of 
requirements, and incomplete technical specifications. CY outlined its plans to 
initiate 
the  system 
complete 
implementation by the end of 2024.  
CZ shared that the GUM-C2 system is on target with a low risk of delay to be 
deployed on 01/06/2025. CZ reported that the system currently works at the 
national level but needs to be adapted for communication with GUM-C1 within 
CDS, which is planned for the end of 2024.  
DE informed that the GUM-C2 system plans to be deployed on 15/11/2025, 
beyond the UCC WP deadline.  
DK reported that the project is currently underway with a medium level of risk 
due  to  awaiting  the  delivery  of  standard  components  from  an  external  IT 
supplier. DK plans to have these standard components developed by the end of 
2024, along with the completion of additional internal changes. An iterative 
approach  is  being  used  by  some  of  the  development  teams  working  on  the 
project. In the National Planning, DK informed that the deployment is planned 
on 02/06/2025. 
According  to  EE,  GUM-C2  is  on  target  to  meet  the  UCC  WP  deployment 
deadline.  This  deadline  considers  that  the  connection  between  the  Customs 
Reference System (CRS) bridge and GUM-C2 is no longer part of GUM-C1. 
The functional specifications are completed, and the system was deployed on 
09/06/2024, while the operations are planned for 02/06/2025. EE also shared 
that an iterative approach is being used for the development of the system. 

N/A 

ES reported that GUM-C2 was implemented on 01/05/2019. 

ES 

FI 

FR 

Low 

GR 

Low 

HR 

Medium 

HU 

Low 

FI shared that GUM-C2 is currently in development. According to its National 
Planning, the system is expected to be deployed in Q2 2025. 
FR reported that GUM-C2 plans to be deployed on 30/03/2026, beyond the 
UCC WP deadline. 
GR informed that it is experiencing a delay in the GUM-C2 system and does 
not anticipate meeting the UCC WP deadline with a deployment date in Q1 
2026. The main challenge has been procurement difficulties, particularly with 
securing  a  contract  that  can  encompass  all  UCC  and  MASP  projects.  To 
address this, GR is exploring different  possibilities to ensure a contractor is 
acquired  and  the  tender  procedure  can  be  finalised  by  the  end  of  2024. 
Additionally,  GR  shared  it  is  utilising  an  Agile  framework  to  develop  the 
system. 
HR informed that GUM-C2 is on target to be deployed on 02/06/2025 but noted 
an increased level of risk related to the timely delivery of the project due to 
limited resources and potential dependencies with other projects. By the end of 
2024, HR plans to complete both the functional and technical specifications 
requirements.  
HU reported the GUM-C2 project as being delayed, yet it remains on track to 
meet  the  deployment  deadline  on  02/06/2025.  HU  attributed  the  delays  to 
ongoing  discussions  among  Member  States.  HU  stated  continuous 
consultations  as  a  mitigating  measure  to  ensure  compliance  with  the 

111 

 
 
 
 
MS 

Risk 
Level 

Additional Comments 

deadline. By the end of 2024, HU plans to prepare its IT customers and update 
the Comprehensive Guarantee (CGU) licenses.  
IE  indicated  that  the  GUM-C2  project  is  on  target,  with  a  low  level  of  risk 
associated  to  its  timely  delivery.  IE  noted  that  its  existing  NIS  that  was 
implemented on 23/11/2020 already encompass the electronic monitoring of 
guarantee,  eliminating  the  need  for  a  new  system.  Based  on  ECCG  and 
Customs Business Group (CBG) meetings discussions, the Member States will 
need  to  undertake  a  conformance  testing  campaign  for  GUM-C2,  which  IE 
aims to conduct and finalise by the end of 2024. 
IT  informed  that  the  GUM-C2  project  is  on  target  to  be  deployed  on 
02/06/2025.  By  the  end  of  2024,  IT  plans  to  complete  the  analysis  and 
development phases of the project, to start conformance testing on 13/01/2025. 
Additionally,  IT  shared  it  has  updated  its  National  Planning  based  on  the 
revised UCC WP. 

IE 

Low 

IT 

Low 

LT 

N/A 

LT shared that the GUM-C2 system was deployed on 16/11/2022.  

LU 

LV 

N/A 

MT 

Low 

NL 

Low 

PL 

N/A 

PT 

High 

LU shared it will begin developments for GUM-C2, which involves connecting 
the  CDS  to  LU's  fully  operational  national  guarantee  system86.  LU  plans  to 
have the system operational on 01/06/2025. 
LV reported that GUM-C2 has been in operations since 04/06/2018 and was 
updated along with NIS. 
MT shared that it is on target to deploy the system by 02/06/2025. By the end 
of  2024,  MT  intends  to  issue  the  requirements  request  and  envisages  that 
development  will  commence  accordingly.  MT  has  adopted  Scrum 
methodologies in collaboration with the Customs Computer Section to monitor 
and validate progress every three weeks. 
NL indicated that it is on schedule with the planning provided. Currently, NL 
is  engaged  in  the  development  of  GUM-C2  and  anticipates  completing  its 
development before June 2025, following an Agile and iterative approach. 
PL  confirmed  that  GUM-C2  was  deployed  on  01/01/2024.  However,  an 
upgrade is planned for 202587. 
PT assessed a high risk to the timely delivery of the project but plans to deploy 
the system on 28/10/2024, in line with its National Planning. The complexity 
of  implementing  a  new  national  GUM  system,  together  with  the  intricate 
interdependencies  among  various  national  and  EU  systems,  increased  the 
project’s  difficulty  and  risk.  PT  informed  that  its  National  Planning  was 
revised, which includes updates to the conformance testing period with the EOs 
and adjustments to the deployment date. Additionally, an Agile development 
method will be employed to expedite the implementation process. 

RO 

RO informed that GUM-C2 plans to be deployed on 06/01/2025. 

SE 

N/A 

SE reported that GUM-C2 was deployed on 17/04/2021. 

SI 

Low 

SI shared that GUM-C2 is on target to be deployed on 01/06/2025. SI plans to 
prepare  the  technical  specifications  for  upgrading  and  supplementing  its 
existing national Guarantee Management system (SIGMS) by the end of 2024.  

86 Information provided from a bilateral meeting between LU and DG TAXUD held on 22/07/2024. 
87 Information provided from an email communication between PL and DG TAXUD on 23/07/2024. 

112 

 
 
 
 
 
 
MS 

Risk 
Level 

SK 

Medium 

Additional Comments 

SK  assessed  the  project  as  delayed  but  expected  to  be  completed  by 
02/06/2025, the UCC WP deadline. SK attributed a medium risk to the timely 
delivery of the project and shared that the delays are due to unfinished contracts 
that have affected the project's schedule. Additionally, resource constraints and 
delays in other critical projects have led to a further rescheduling of the project 
timeline.  By  the  end  of  2024,  SK  aims  to  finalise  its  contracts,  update  EOs 
specifications, and initiate conformance testing.  

Table 24: Detailed responses from Member States – GUM-C2 

Figure 4588 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 45: Project progress and status per milestone – GUM-C2 

88 The information shared by PL corresponds to a further upgrade of GUM-C2, but the system is already deployed. 

113 

 
 
 
 
 
 
 
4.1.2 Overview of Project Progress 

Figure 46 highlights any known divergences in the Member States’ National Planning compared to the 
dates set in the UCC WP. As  this project has a deployment window, the deployment and operations 
milestones  are  shown.  Any  difference  between  these  two  dates  indicates  that  a  migration  period  is 
planned.  

With regards to the implementation of the national UCC Guarantee Management (GUM-C2), DE, FR 
and GR indicated a planned/actual operations date that is later than the deadline in the UCC WP. BE did 
not provide information through their National Planning on the deployment date. 

114 

 
 
Figure 46: Actual/Planned dates per milestone – GUM-C2 

115 

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

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 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 
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 is implemented in three releases.  

For Release 1 (ICS2-R1) and Release 2 (ICS2-R2), please refer to Section 2.9. 

Release 3 (ICS2-R3) aims to cover the implementation of new ENS obligations, related business, and 
risk management process for all goods in maritime and inland waterways, road, and rail traffic. 

The Member States need to deploy their national ICS2 component by 3 June 2024. Depending on the 
mode of transport, the EOs shall start using ICS2 within the following deployment windows: 

•  For maritime and inland waterways carriers, between 3 June 2024 and 4 December 2024; 
•  For house level filers in the maritime and inland waterways traffics, between 4 December 

2024 and 1 April 2025; 

•  For road and rail carriers, between 1 April 2025 and 1 September 2025. 

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’ uses cases including the existing ones from ICS2-R2.  

ICS2-R3 includes further extension for Safety and Security Analytics. 

The ICS2-R3 Common Technical System Specifications (CTSS) were initially delivered in February 
2022 and subsequently updated in September 2022. For ICS2-R3, the conformance testing activities are 
exclusively carried out by EOs. The connectivity conformance testing activities are in progress since 1 
of July 2023 and the conformance testing itself  for functional testing  started on 11 December 2023. 
Unlike previous releases, for ICS2-R3 there was no R3 conformance testing campaign for the National 
Administrations. The National Administrations have already implemented all functionalities of ICS2-
R2 and completed the mandatory conformance testing. 

The  development  of  the  CR  and  Shared  Trader  Interface  central  components  has  started  and  is 
progressing as planned. 

Summary from the Member States: 

Most Member States assessed the project with a low risk due to its completion or the anticipation of 
meeting the UCC WP deadline. The Member States that indicated a medium to high risk cited difficulties 
during conformance testing, lack of EOs readiness, and delays involving the IT service providers as the 
main causes.  

The  majority  of  Member  States  shared  the  adoption  of  Agile  or  iterative  approaches  to  develop  the 
system.  

Most Member States indicated the project  as on target, deploying the system before 03/06/2024 and 
planning to enter operations as defined in the UCC WP: maritime and inland waterways carriers (Step 
1) in 2024, and maritime and inland waterways traffics (Step 2) and road and rail carriers (Step 3) in 

116 

 
 
2025.  Most  of  the  Member  States  indicated  the  conformance  testing  phase  either  in  progress  or 
completed89 and are either in deployment or operations phase. 

Detailed Responses: 

Table 25 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Low 

BE 

Medium 

BG 

Low 

CY 

Low 

CZ 

Low 

DE 

N/A 

DK 

Low 

EE 

Low 

Additional Comments 

AT  informed  that  ICS2-R3  is  on  target  and  stated  a  low  risk  to  the  timely 
delivery  of  the  project.  By  the  end  of  2024,  AT  aims  to  complete  the 
coordination  activities  with  the  software  provider,  deploy  the  system  on 
06/03/2024 and enter operations through the multiple-step approach defined in 
the UCC WP. Additionally, AT shared that is using an Agile approach tailored 
by the software provider.  
BE shared that ICS2-R3 is delayed, with a medium risk level associated to the 
timely  delivery  of  the  project.  The  risk  arises  from  challenges  encountered 
during  conformance  testing,  which highlighted  discrepancies  in  the  values 
received from the Information Technology Service Management (ITSM). BE 
reported that addressing these discrepancies resulted in additional alignment 
efforts. The system was deployed on 03/06/2024 and operations are scheduled 
for 01/09/2025. Additionally, BE reported the adoption of an Agile approach.  
BG reported that the development of the ICS2-R3 system is on target with a 
low  risk  associated  with  the  timely  delivery  of  the  project.  BG  intends  to 
commence operations for the national component of ICS2-R3 on 03/06/2024. 
An  Agile  and  iterative  approach  is  being  used  in  the  system  development 
process, integrating two technological frameworks: TOGAF/ADM and RUP. 
CY noted that the ICS2-R3 project is on target and associated a low risk of 
delay to its timely delivery. CY deployed the project on 03/06/2024 and plans 
to  join  operations  following  the  multiple-step  approach  defined in  the  UCC 
WP. 
CZ shared that the ICS2-R3 system was deployed on 01/06/2024 and has been 
in operations since then. Additionally, CZ shared that it used an Agile approach 
for the system development.  
DE informed that the ICS2-R3 project was deployed on 03/06/2024 and plans 
to enter operations through the multiple-step approach. Since the requirements 
of ICS2-R3 are covered by its national IT system ATLAS (Release 10.2), no 
additional  changes  were  required  from  ICS2-R2.  DE  shared  that  the 
Commission  will  publish  all  milestones  related  to  the  EOs  and  provide  the 
technical specifications for the external communication via the ICS2 Shared 
Trader Interface. Conformance testing between the EOs, and the Commission 
will  be  scheduled  individually  in  coordination  with  the  Member  States 
concerned.  
DK reported that ICS2-R3 went live on 25/05/2024 and onboarding of the EOs 
is  progressing.  DK  used  its  own  variation  of  the  Scaled  Agile  Framework 
(SAFe) for the development of this project. 
EE shared that the ICS2-R3 system was deployed on 03/06/2024 and it plans 
to  implement  the  maritime  and  inland  waterways  carriers  (Step  1)  on 
04/12/2024, for which it has identified a more suitable financial solution. For 

89  Considering  the  ICS2  technical  specifications,  the  Member  States  are  not  required  to  implement  new 
functionalities for ICS2-R3. Therefore, conformance testing is not mandatory for Member States, and it will only 
apply to the EOs. 

117 

 
 
 
 
MS 

Risk 
Level 

Additional Comments 

the house level filers in the maritime and inland waterways traffics (Step 2) 
and road and rail carriers (Step 3), EE plans to enter into operations in line with 
the dates defined in the UCC WP (01/04/2025 and 01/09/2025 respectively). 
EE adopted an Agile methodology for the development of the system that has 
enhanced the collaboration with the Commission. 
ES deployed the system on 03/06/2024. By the end of 2024, ES expects to have 
the ICS2-R3 system in operations, with maritime and inland waterways carriers 
(Step 1) and house level filers in the maritime and inland waterways traffics 
(Step 2) migrated. Road and rail carriers (Step 3) are scheduled for 01/09/2025. 
ES indicated that it is using an Agile approach for the project's development. 
FI deployed the ICS2-R3 system in Q2 2024 and plans to enter operations for 
maritime and inland waterways carriers (Step 1) in Q4 2024, house level filers 
in the maritime and inland waterways traffics (Step 2) in Q1 2025 and road and 
rail carriers (Step 3) in Q3 2025. By 2025, FI also reported that it will focus on 
integrating ICS2-R3 with the European Maritime Single Window environment 
(EMSWe), NCTS-P6 and PoUS-P290. 
FR  shared  that  the  ICS2-R3  project  is  on  target,  although  it  highlighted  a 
medium  risk  level  associated  to  the  timely  delivery  of  the  project  due  to  a 
compressed timeframe for end-to-end testing within its IT ecosystem. The tight 
schedule  poses  a  challenge  for  addressing  critical  bugs  before  deployment. 
Moreover, FR aims to address some discrepancies from other Member States 
at the community level that could potentially impact its national ICS2 system. 
FR reported that the application for the maritime sector will be made available 
by 01/06/2024 and, for the road and rail sectors, it aims to prepare it by the end 
of 2024. Additionally, FR plans to conduct a security certification in 2024 and 
complete the migration of EOs from ICS to ICS2 by 04/12/2024, employing 
an Agile approach for the system’s development.  
GR  reported that the  ICS2-R3  system  was  deployed  on  14/06/2024  and  has 
been in operations since then. By the end of 2024, GR aims for all traders from 
the  maritime  sector  to  be  using  the  system.  Additionally,  GR  shared  it  has 
adopted and Agile approach for the project’s development.  
HR reported that ICS2-R3 has encountered delays but remains on track to meet 
the deployment deadline. HR assessed a high risk to the timely delivery of the 
project due to delays in involving the IT service providers in the development 
activities. HR shared it will be developing the system in a phased approach as 
per the Commission Implementing Decision (EU) 2023/2879. HR aims to have 
the  core  system  deployed  on  03/06/2024  and  operational  according  to  the 
following  schedule:  maritime  and  inland  waterways  carriers  (Step  1)  on 
04/12/2024, house level filers in the maritime and inland waterways traffics 
(Step  2)  on  01/04/2024  and  finally,  road  and  rail  carriers  (Step  3)  on 
01/09/2025, with the latest step being in line with the NCTS-P6 plan. 
HU  shared  that  ICS2-R3  was  deployed  on  01/03/2023.  Regarding  the  entry 
into operations, HU is on target with maritime and inland waterways carriers 
(Step 1) planned on 04/12/2024, house level filers in the maritime and inland 
waterways traffics (Step 2) on 01/04/2025 and, road and rail carriers (Step 3) 
on 01/09/2025.  
IE assessed the project as being on target, with a medium risk level associated 
with the timely delivery of the project due to potential unreadiness of traders 

ES 

Low 

FI 

Low 

FR 

Medium 

GR 

Low 

HR 

Low 

HU 

Low 

IE 

Medium 

90 The information shared by FI in the survey has been updated based on a bilateral meeting between FI and DG 
TAXUD held on 02/04/2024. 

118 

 
 
 
 
MS 

Risk 
Level 

Additional Comments 

to migrate to the system. The deployment is planned for 03/06/2024 and IE 
plans  to  have  the  maritime  filings  and  communication  with  IE4N10  to  CR 
completed by the end of 2024. IE confirmed alignment with the revised UCC 
WP and the adoption of a multiple-step approach. Additionally, IE intends to 
explore a separate deployment window for all RoRo traffic between January 
and September 2025. 
IT  informed  that  the  ICS2-R3  project  is  on  target  and  plans  to  deploy  the 
system on 03/06/2024 for the maritime and inland waterways carriers (Step 1) 
and the house level filers in the maritime and inland waterways traffics (Step 
2).  
LT reported that the ICS2-R3 project is on target, with a low risk of delay. LT 
aims to deploy the system on 01/06/2024 but will continue supporting the EOs 
throughout  the  deployment  window  (until  01/09/2025).  Additionally,  LT 
shared  that  its  National  Planning  dates  were  adjusted  given  the  UCC  WP 
revision.  

IT 

Low 

LT 

Low 

LU 

LU informed that the ICS2-R3 system has been in operations since 01/07/2024.  

LV 

N/A 

MT 

Low 

NL 

Low 

PL 

N/A 

PT 

Low 

RO 

SE 

Low 

LV  reported  that  ICS2-R3  was  deployed  on  01/03/2023  and  plans  to  enter 
operations  through  the  multiple-step  approach  defined  in  the  UCC  WP:  for 
maritime and inland waterways carriers (Step 1) on 04/12/2024, for house level 
filers in maritime and inland waterways traffic (Step 2) on 01/04/2025, and for 
road and rail carriers (Step 3) on 01/09/2025. 
MT is delayed and plans to deploy the ICS2-R3 system for maritime and inland 
waterways carriers (Step 1) by 04/12/2024, contingent upon the approval of a 
change request. MT has been using a phased iterative approach encompassing 
configurations, UAT, training, and migration. 
NL shared the ICS2-R3 was deployed on 27/05/2024. All essential features are 
developed within NES as it continues through its Life Cycle Management. For 
maritime  and  inland  waterway  mode  of  transport  (Step  1),  all  master  and 
fulfillers will be connected into the ICS2 system by 04/12/2024. Following the 
ICS2  ‘go live’  procedure  and  transition  strategy from  ICS2-R2  to  ICS2-R3, 
house  level  filers  in  maritime  and  inland  waterways  traffic  (Step  2)  will 
connect on 01/04/2025, and road and rail carriers (Step 3) on 01/09/2025. To 
develop  the  NES,  NL  is  employing  an  Agile  approach  with  three-month 
planned increments focused on developing the features that deliver the most 
business value. 
PL informed that the ICS2-R3 project is on target with the UCC WP deadline 
as  its  national  export  system  includes  the  functionalities  and  operations 
required  for  ICS2-R3.  Conformance  testing  started  in  Q4  2023,  and 
deployment is planned for 03/06/2024. PL aims to join operations for maritime 
and  inland  waterways  carriers  (Step  1)  on  04/12/2024,  house  level  filers  in 
maritime and inland waterways traffic (Step 2) on 01/04/2025, and road and 
rail carriers (Step 3) on 01/09/2025. 
PT reported that ICS2-R3 is on target, with a low risk level associated to the 
timely delivery of the project. PT deployed the system and started operations 
on 03/06/2024. Additionally, PT shared it has been using an Agile development 
to expedite the implementation process.  
RO informed that the ICS2-R3 system plans to be deployed on 16/12/2024 and 
in operations by 01/09/2025. 
SE  shared  it  plans  to  have  the  ICS2-R3  system  deployed  for  maritime  and 
inland  waterways  carriers  (Step  1)  on  03/06/2024,  house  level  filers  in 
maritime and inland waterways traffic (Step 2) on 04/12/2024, and road and 

119 

 
 
 
 
MS 

Risk 
Level 

SI 

N/A 

SK 

N/A 

Additional Comments 

rail carriers (Step 3) on 01/04/2025. However, SE emphasised that not all EOs 
will be operational by then but will be by 01/09/2025 as defined in the UCC 
WP. 
SI shared that the ICS2-R3 system is planned to be deployed on 02/06/2024 
and enter operations on 03/06/2024.  
SK  indicated  the  ICS2-R3  project  was  deployed  on  03/06/2024,  but 
emphasised  that  EOs  will  be  operational  iteratively,  that  is:  maritime  and 
inland  waterways  carriers  (Step  1)  on  04/12/2024,  house  level  filers  in 
maritime and inland waterways traffic (Step 2) on 01/04/2025, and road and 
rail carriers (Step 3) on 01/09/2025.  

Table 25: Detailed responses from Member States – ICS2-R3 

Figure 4791 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 47: Project progress and status per milestone – ICS2-R3 

91 The progress shown in the figure considers the 2023 UCC WP approach. 

120 

 
 
 
 
 
 
4.2.2 Overview of Project Progress 

Figure 48 highlights any known divergences in the Member States’ National Planning compared to the 
dates set in the UCC WP, along with the specific dates of each milestone.  

Regarding the implementation of UCC Import Control System 2 – Release 3 (ICS2-R3), the following 
Member States that plan to deliver the system in full have a planned/actual operations date that is later 
than the single operations deadline in the UCC WP: BE, DK, MT, and RO. Additionally, IT did not 
provide information through its National Planning on the operations date. 

121 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
122 

 
 
 
 
Figure 48: Actual/Planned dates per milestone – ICS2-R3 

123 

 
 
 
 
4.3 UCC PROOF OF UNION STATUS (PoUS) – PHASE 2 

The  UCC  Proof  of  Union  Status  (PoUS)  is  a  trans-European  system  designed  to  allow  storage, 
management, and retrieval of certain types of documents (e.g., T2L, T2L/F, 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.  

For Phase 1 (PoUS-P1), please refer to Section 3.9. 

Phase  2  (PoUS-P2)  covers  the  implementation  of  the  electronic  CGM,  including  the  information 
exchange with the EMSWe92. 

4.3.1 Summary of Responses 

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 the 
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: 

The Member States have the option of using the central PoUS system or developing their own national 
application. From all the Member States, only ES and PL conveyed the intention to develop their own 
national system, and both are on target to deploy the system within the legal deadline.  

Detailed Responses: 

Table 26 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

ES 

Medium 

PL 

Low 

Additional Comments 

ES assigned a medium risk level to the timely delivery of the project, owing to 
the dependency on EMSW, which requires greater coordination at both EU and 
national  levels.  ES  informed  that  there  have  been  no  significant  changes  in 
terms of development. It aims to have the technical specifications available for 
the  EOs  by  09/09/2024  to  be  able  to  deploy  the  system  on  16/05/2025.  An 
iterative approach is being used for the development of the system.  
PL outlined it plans to have the technical specifications of the national hybrid 
system ready by 15/05/2025. The project planning was aligned with the latest 
update of the UCC WP with a deployment planned for 15/08/2025. 

Table 26: Detailed responses from Member States – PoUS-P2 

92 The deployment is planned for 15/08/2025. 

124 

 
 
 
 
 
4.3.2 Overview of Project Progress 

Figure 49 highlights any known divergences in the Member States’ National Planning compared to the 
dates set in the UCC WP, along with the specific dates for the central and national system.  

Regarding UCC Proof of Union Status – Phase 2 (PoUS-P2), all Member States, except ES and PL, will 
use the central PoUS system. ES and PL along with the Commission indicated to be on target deploy 
the system on 15 August 2025. 

Figure 49: Actual/Planned dates per milestone – PoUS-P2 

125 

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

The UCC Centralised Clearance for Import (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 VAT. 

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

For Phase 1 (CCI-P1), please refer to Section 3.5.  

Phase 2 (CCI-P2) will cover the components that are not part of CCI-P1, 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.  

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 and the CTA system accessible in the conformance environment, 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: 

Please see also the summary from CCI-P1.  

In  terms  of  assessing  the  level  of  completeness  of  the  system,  the  following  Member  States  aim  to 
complete the project within the UCC WP deadline: AT, BE, BG, CY, DK, EE, ES, FI, GR, HR, HU, IT, 
LT, LU, LV, MT, PT, and SI. However, CZ, DE, FR, IE, NL, PL, and SK informed that the project is 
scheduled beyond deployment deadline. In addition, SE did not provide concrete dates. SK submitted a 
written notification asking for a derogation under Article 6(4) of the UCC to DG TAXUD concerning 
the delay of CCI-P2.  

Most Member States shared that technical specifications and conformance testing activities are either in 
progress or not yet initiated.  

126 

 
 
 
 
Detailed Responses: 

Table 27 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

MS 

Risk 
Level 

AT 

Medium 

BE 

Medium 

BG 

Low 

CY 

Low 

Additional Comments 

AT informed that CCI-P2 is on target but with a medium risk level associated 
with the timely  delivery  of  the project  due  to  dependencies  on  the  software 
provider.  Deployment  is  scheduled  for  02/06/2025. AT  aims to  develop the 
project using an Agile approach tailored by the software provider.  
BE shared that CCI-P2 is currently on target to be deployed on 02/06/2025, but 
indicated a medium risk associated to the timely delivery of the system. The 
potential delay is due to the development of CCI-P1 exceeding the anticipated 
timeframe and the need to implement more complex declaration types for CCI-
P2. BE plans to progress with the analysis of CCI-P2 by the end of 2024 and 
is using an Agile approach to develop the system. 
BG  stated  that  certain  national  requirements  will  be  specified  in  2024,  and 
conformance testing is expected for February 2025. In addition, BG shared the 
adoption  of  the  TOGAF/ADM  and  RUP  frameworks  during  the  IT  project 
implementation.  
CY reported that the CCI-P2 project is on target with a low risk of delay. By 
the  end  of  2024,  CY  aims  to  verify  the  requirements  and  start  the 
implementation phase.  

CZ 

High 

Same response as for CCI-P1. 

DE 

Medium 

DK 

Medium 

EE 

Low 

ES 

Medium 

FI 

High 

DE shared that the CCI-P2 project is delayed and noted an increased level of 
risk associated with the timely delivery of the project due to budget constraints. 
At  the  moment  of  writing,  DE  informed  that  the  system's  development  is 
progressing; the technical specifications are being drafted and expected to be 
completed  on  30/06/2024,  while  the  national  functional  specifications  are 
anticipated  by  the  end  of  2024.  Deployment  is  scheduled  for  15/11/2025. 
Additionally, DE is using an Agile approach for the development of the system.  
DK indicated the CCI-P2 project is on target and expected to be operational by 
02/06/2025. DK reported a medium risk level associated to the delivery within 
the  deployment  deadline  due  to  delays  in  the  NIS  deployment.  DK  shared 
that the development and testing phases will be underway by the end of 2024, 
following an Agile approach. DK reported that the timelines for the export and 
transit projects affected the import system's development. 
EE reported that the analysis phase was completed, and the development phase 
is  ongoing.  As  per  its  National  Planning,  EE  expects  the  technical 
specifications  to  be  completed  on  30/01/2025  and  deploy  the  system  on 
02/06/2025. EE informed that it is using an iterative approach to develop the 
CCI system. 
ES informed that progress is expected in the development of the system during 
2024  and  reported  the  publication  of  the  technical  specifications  on 
02/06/2024. Although ES noted an increased level of risk due to the need to 
have  CCI-P1  built  on  CCI-P2  specifications,  deployment  is  planned  for 
02/06/2025 in line with the UCC WP deadline. In addition, ES shared that an 
iterative development approach is being used. 
FI reported the system being delayed assessed a high risk to the development 
of the system due to limited resources on the supplier’s side. To mitigate the 
delay, FI negotiated with the supplier at management level, focusing on project 
planning and progress monitoring. FI aims to have the system in operations by 
Q2 2025.  

127 

 
 
MS 

Risk 
Level 

FR 

High 

Additional Comments 

FR informed the CCI-P2 system is delayed and highlighted the need to secure 
NIS to establish a more robust foundation for the CCI development. Moreover, 
the scarcity of the resources will result in the concurrent execution of multiple 
IT  projects,  increasing  the  associated  risks.  FR  aims  to  explore  the 
implementation of mitigating measures during 2024 and plans to have CCI-P2 
in operations on 31/12/2026.  

GR 

High 

Same response as for CCI-P1. 

HR 

Low 

HU 

Low 

IE 

Medium 

Low 

Low 

IT 

LT 

LU 

LV 

High 

MT 

Low 

HR shared that the CCI-P2 system is on target, aiming to be in operations on 
02/06/2025.  HR  plans  to  complete  the  technical  specifications  and  start 
conformance testing by the end of 2024.  
HU  reported  that  CCI-P1  is  on  target  but  noted  an  increased  level  of  risk 
associated with the timely delivery of the project due to resource constraints. 
HU  shared  that  it  plans  to  deploy  the  system  by  02/06/2025,  after  the 
completion  of  conformance  testing.  Additionally,  HU  is  using  Jira  for  the 
project management.  
IE assessed the project with a medium risk level due to the development of 
multiple  projects  throughout  2024  and  2025,  which  has  strained  the  limited 
internal and external resources. IE initially scheduled CCI-P1 deployment for 
June 2024, however, the deployment has shifted to 20/01/2026 as both CCI-P1 
and CCI-P2 will be implemented concurrently with the NIS upgrade93.  
IT  shared  that  the  CCI-P2  system  is  on  target,  and  it  plans  to  complete  the 
analysis phase by the end of 2024 and deploy the system on 02/06/2025.  
LT reported that the CCI-P2 project is on target with a low risk of delay. LT 
aims to deploy the system on 02/06/2025, in line with the UCC WP deadline.  

LU shared that it aims for CCI-P2 to be operational on 01/06/2025. 

LV assessed the CCI-P2 project as being delayed within the foreseen UCC WP 
deadline, due to a change in the IT development team and the new procurement 
procedure. LV highlighted a significant risk due to the absence of interest from 
any  EO  but  noted  that  CCI-P1  will  be  implemented  under  the  existing 
agreement.  To  mitigate  the  delay  and  risk,  LV  has  divided  the  project  into 
smaller increments, following an Agile methodology, with the aim to deploy 
the system for 25/03/2025. 
MT outlined that the progress expected during 2024 is the readiness of the CCI-
P2 system for the implementation on the test environment and its preparation 
for  conformance  testing.  The  system  is  scheduled  to  be  deployed  in 
June202594. In addition, MT shared the use of a Scrum methodology, working 
with three-week increments. 

NL 

High 

Same response as for CCI-P1. 

PL 

Low 

PL reported a delay beyond the foreseen UCC WP deadline in the development 
of  the  CCI-P2  system,  with  the  technical  specifications  scheduled  for 
01/03/2025 and deployment for 01/06/2026. The reasons for the delay include 
insufficient  financial  resources,  delays  in  selecting  a  contractor  and  a 

93 Information provided from a bilateral meeting between IE and DG TAXUD held on 26/03/2024. 
94 Information provided from a bilateral meeting between MT and DG TAXUD held on 11/10/2024. 

128 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

postponement in initiating the documentation for the development. Also, PL 
shared the adoption of an Agile approach for the system development. 
PT assessed the project as being delayed, but still expected to be completed 
within  the  UCC  WP  deadline.  The  main  reasons  for  the  delay  are  (a)  the 
implementation of a complex new NIS as a basis of the CCI system; (b) the 
intricate interdependencies among various national and EU systems; and (c) 
the development halt from mid-2023 to the end of 2023 due to challenges in 
procurement and tendering, particularly in renewing the supplier’s contracts. 
Consequently, since both NIS and CCI-P1 have experienced delays beyond the 
anticipated deployment deadline, which has resulted in a cascading effect on 
CCI-P2. To address the delays, an Agile development approach will be adopted 
to streamline the implementation timeframe.  
Additionally, the National Planning has been updated to include revisions to 
the  conformance  testing  period  with  the  Commission  and  EOs,  along  with 
modifications to the deployment date, now set on 31/05/2025. 
RO shared that is on target and aims for the CCI-P2 system to be in operations 
on 31/12/2024. 
SE reported a delay in the delivery of the project due to multiple systems being 
developed in parallel. In addition, SE shared that delays to the implementation 
of the project could be affected by the need to change its IT platform. 
In addition, SE highlighted that there is a need to develop the goods shipment 
level in the supplementary recapitulative declaration before deploying CCI-P2, 
which is estimated to require a substantial development effort. To address this, 
SE has allocated additional human and financial resources to the project. The 
analysis on how the changes can be implemented in the best way is ongoing, 
and the aim is to limit the delay as much as possible. For the time being, SE 
reported that there is no planning information available. 
SI shared that work for CCI-P2 has yet to commence, as it is contingent upon 
CCI-P1  implementation.  However,  SI  reported  that  the  project  is  on  target, 
expecting to meet the 02/06/2025 deadline.  
Same response as for CCI-P1. 

Table 27: Detailed responses from Member States – CCI-P2 

PT 

High 

RO 

SE 

High 

SI 

Low 

SK 

High 

Figure 50 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 50: Project progress and status per milestone – CCI-P2 

129 

 
 
 
 
 
 
4.4.2 Overview of Project Progress 

Figure 51 highlights any known divergences in the Member States’ National Planning compared to the 
dates  set  in  the  UCC  WP,  along  with  the  specific  dates  of  each  milestone.  As  this  project  has  a 
deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference  between 
these two dates indicates that a migration period is planned.  

For the implementation of UCC Centralised Clearance for Import – Phase 2 (CCI-P2), the following 
Member States have a planned/actual operations date that is later than the deadline in the UCC WP: CZ, 
DE, FR, IE, NL, PL, and SK. In addition, IT and SE did not provide data through its National Planning 
regarding the operations date.  

130 

 
 
Figure 51: Actual/Planned dates per milestone – CCI-P2 

131 

 
 
 
 
4.5 UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE – 

COMPONENT 2 

This project aims to align the existing  New Computerised Transit System (NCTS) to the UCC legal 
provisions.  The  scope  of  the  project  includes  the  alignment  of  Information  Exchanges  to  UCC  data 
requirements, the upgrade and development of interfaces with other systems such as AES, in addition 
to new Safety and Security requirements. 

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

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

For Component 1 (NCTS-P5), please refer to Section 3.7. 

Component 2 (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 ICS2-R3, having a transition window from 3 March 2025 until 
1 September 2025 for the National Administrations to migrate from NCTS-P5 to NCTS-P6.  

NCTS-P6 will be deployed in line with the following calendar: 

Figure 52: NCTS-P6 timeline 

4.5.1 Summary of Responses 

Summary from the Commission: 

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 Annex b in the UCC DA and UCC IA. 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 National Administrations and 
trade.  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. 

132 

 
 
 
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  converter  will  be  employed  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 
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 that could be offered or not offered to their 
trades 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 established 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 operational 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 NCTS-P5 operations in 2024 and the transitional period of NCTS-P6. The 
revision of the UCC WP addressed 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 revised 
UCC WP aims to ensure operational continuity. 

Summary from the Member States: 

Most Member States reported a low or medium-risk level regarding the on-time delivery of the NCTS-
P6 project, with only a few of them rating it as high. 

Aside from the dependency with NCTS-P5 development, the risk of delay in the system is potentially 
related  to  stringent  deadlines,  concurrent  development  of  multiple  projects,  prolonged  tendering 
procedures, and resource constraints. To mitigate this risk, most Member States shared the use of Agile 
and/or iterative approaches.  

At the moment of writing, AT, FI, LT, LV, NL, SE, and SI confirmed being opt-out countries for NCTS-
P6. 

The following Member States indicated the system joining operations is on target and within the legal 
deadline: AT, BG, CY, CZ, DK, EE, ES, FI, HU, IE, IT, LT, LU, LV, MT, SE, and SI. GR, HR, NL, 
PT,  and  PL  reported  delays,  however,  FR,  PL  and  RO  indicated  a  delay  beyond  the  legal  deadline. 
Additionally, BE, DE, and SK did not provide concrete dates. 

Most Member States have yet to initiate the technical specifications phase, with only a few reporting 
them as in progress. 

Detailed Responses: 

Table 28 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided: 

133 

 
 
Risk 
Level 

MS 

AT 

BE 

BG 

Low 

CY 

Low 

CZ 

Low 

DE 

Low 

DK 

Medium 

EE 

Medium 

ES 

Low 

FI 

N/A 

FR 

N/A 

Additional Comments 

AT indicated that it will be an opt-out country, targeting 31/05/2025 for NCTS-
P6 start of operations95. 

BG noted the acceptance of the construction phase as the progress expected by 
the  end  of  2024.  In  addition,  BG  shared  the  use  of  an  Agile  and  iterative 
approach  by  applying  two  technological  frameworks,  TOGAF/ADM,  and 
RUP. BG aims for the NCTS-P6 system to be in operations on 23/06/2025. 
CY reported that the NCTS-P6 project is on target with a low risk of delay. CY 
aims to initiate the project and its analysis by the end of 2024 and deploy the 
system on 01/09/2025.  
CZ shared that the NCTS-P6 project is on target and indicated a low risk for 
the  timely  delivery  of  the  system.  CZ  aims  to  complete  the  technical 
specifications on 01/09/2024 and finish the development of the system by the 
end of 2024. Additionally, CZ informed that it is using an Agile approach for 
the implementation for the project.  
DE reported that NCTS-P6 is on target and indicated a low risk to the timely 
delivery  of  the  project.  DE  informed  that  it  will  not  use  the  combined 
declaration  following  Article  130  of  the  UCC  (NCTS-P6)  but  assured  all 
measures will be taken to ensure the software is aligned with the deployment 
window of the project.  
DK indicated a medium risk to the timely delivery of the project given the tight 
deadlines. However, DK shared that it plans to be developing the system by 
the  end  of  2024,  and  aims  be  in  operations  by  01/09/2025,  using  an  Agile 
approach.  
EE shared that it will be an opt-in country for this project96 and aims for the 
system  to  be  operational  on  01/04/2024.  EE  plans  to  advance  with  the 
conformance testing Mode 1 and pre-conformance testing Mode 2 as well as 
starting with conformance testing Mode 2. However, EE raised the risk that the 
upcoming  changes  in  the  technical  documents  could  potentially  affect  the 
project,  leading  to  additional  costs.  In  addition,  EE  noted  that  an  iterative 
methodology is being used, dividing the development into smaller iterations 
with weekly deliveries. 
ES shared its plans to start with the development of the NCTS-P6 system in 
2024 and publish the technical specifications on 03/10/2024. ES noted that an 
iterative development approach is being used for this project. 
FI informed that it is currently aiming to deploy NCTS-P6 in Q2 2025 as an 
opt-out country, given the risk of delay. However, it is considering being an 
opt-in country. An analysis is currently undergoing to review the impact on its 
system and ICS2. FI aims to complete this review in May 2024 and provide an 
update of the project timeline. 
FR shared that given the postponement of NCTS-P5 to October 2024, it aims 
to join operations for NCTS-P6 on 31/01/2026 beyond the legal deadline. The 
framing phase of the project will start in June 2024. Additionally, FR informed 
that it is receptive to the opt-in option, contingent on prevailing trends among 
Member States. 

95 Information provided from a bilateral meeting between AT and DG TAXUD held on 11/03/2024. 
96 Information provided from a bilateral meeting between EE and DG TAXUD held on 06/05/2024. Additionally, 
the specifications for Common Transit are expected to be delivered by the end of June 2024. 

134 

 
 
 
 
 
 
 
MS 

Risk 
Level 

GR 

Medium 

HR 

High 

HU 

Low 

IE 

Medium 

IT 

Low 

LT 

Low 

LU 

LV 

Low 

MT 

Low 

NL 

High 

PL 

High 

Additional Comments 

GR reported a delay in the NCTS-P6 system. The primary cause of the delay 
stems from challenges in securing a comprehensive contract for all UCC and 
MASP projects. GR  also  shared that the short timeframe to implement both 
NCTS projects has caused a challenge. Moreover, by 16/12/2024 GR plans to 
implement NCTS-P5 and start the development of NCTS-P6 using an Agile 
approach. 
HR informed that the project is experiencing delays with a high risk associated 
with the timely delivery of the project, but it still anticipates the completion 
within  the  UCC  WP  deadline.  HR  attributed  the  delay  to  the  pending 
publication of the updated EU specifications, leading to the postponement of 
the deployment date by six months. HR aims for NCTS-P6 to be operational 
on 01/09/2025. 
HU shared that NCTS-P6 is on target and plans to complete the procurement 
process for this project and sign the contract with the supplier by the end of 
2024. Operations are scheduled for 01/09/2025. 
IE assessed the project as having medium risk due to multiple projects being 
developed in the 2024-2025 period, which has strained the limited internal and 
external  resources.  IE  initially  scheduled  the  NCTS-P6  implementation  in 
2024,  however,  it  has  been  revised  to  09/06/2025  because  of  competing 
priorities97. By the end of 2024, the contractor will deliver the software and the 
trader specifications will be published.  
IT informed that the NCTS-P6 system is on target, and it is working on the 
analysis, design, and development of the system upgrades 
LT reported that the NCTS-P6 project is on target and plans to complete the 
technical  specifications  on  30/01/2025.  LT  shared  that  it  will  be  an  opt-out 
country98. 
LU informed that it is considering being an opt-out country for NCTS-P6 and 
plans to deploy the system on 02/06/202599. 
LV  reported  that  it  will  currently  be  an  opt-out  country100.  LV  shared  the 
completion of the connectivity tests and reported the beginning of conformance 
testing Mode 1. In addition, LV indicated the use of an Agile methodology for 
the development of NCTS-P6. 
MT informed that it will issue a tender or a change request in 2024. Also, MT 
noted  the  adoption  of  an  Agile  methodology  by  implementing  a  phased 
approach, encompassing configurations, UAT, training and migration.  
NL  reported  a  delay  in  the  project  due  to  the  dependency  of  NCTS-P6 
beginning on the completion of NCTS-P5 but anticipates meeting the UCC WP 
deadline.  While  the  impact  is  limited  given  NL  opt-out  status,  mitigating 
measures  within  the  NCTS-P5  system  have  been  placed  to  prevent  further 
delays.  Currently,  NL  is  designing  the  system,  and  features  will  soon  be 
transmitted to the supplier. In addition, NL disclosed that the features will be 
delivered and tested using an Agile methodology. 
PL assessed the project as being delayed beyond the UCC WP deadline. The 
main  causes  identified  include  a  lack  of  funds  allocated  for  NCTS-P6 

97 The information shared by IE in the survey has been updated based on a bilateral meeting between IE and DG 
TAXUD held on 26/03/2024. 
98 Information provided from a bilateral meeting between LT and DG TAXUD held on 12/03/2024. 
99 Information provided from a bilateral meeting between LU and DG TAXUD held on 22/07/2024. 
100 Information provided from a bilateral meeting between LV and DG TAXUD held on 18/04/2024. 

135 

 
 
 
 
 
MS 

Risk 
Level 

Additional Comments 

development in the current contract and the constrain of having only one active 
contract for the same system. Consequently, this situation poses a high risk due 
to  the  prolonged  tendering  process  and  the  learning  curve  associated  with 
engaging a new contractor, which might increase the delay. However, PL plans 
to sign the new contract by the end of 2024 and will prioritise the analysis and 
implementation  tasks  for  NCTS-P6  in  order  to  deploy  the  system  on 
01/06/2026. 
To  mitigate  these  issues,  PL  has  expedited  the  preparation  of  the  tendering 
process  by  providing  detailed  requirements  and  adopting  an  iterative 
development  approach.  This  approach  ensures  the  proper  sequencing  of 
deliveries  in  the  contract,  facilitating  close  cooperation  with  the  contractor. 
Moreover, PL aims to have an early publication of the trader’s specification 
and the deployment test environment to mitigate delays. In addition, PL noted 
that the deployment deadline for NCTS-P6 could be moved forward to stabilise 
NCTS-P5 after all Member States join. 
PT indicated a delay in the project resulting in a high risk to the timely delivery 
of the project. However, it still plans to complete the project within the UCC 
WP deadline. PT shared that the delays in the development of NCTS-P5 have 
impacted the start of NCTS-P6 as work on this phase will not start until the 
previous  phase  is  finished.  To  mitigate  the  delay,  an  Agile  development 
approach  will  be  adopted  to  streamline  the  implementation  timeframe. 
Furthermore,  the  National  Planning  was  revised  to  achieve  the  required 
timeframes.  PT  indicated  that  development  on  NCTS-P6  will  commence 
promptly to ensure timely progress on the project.  

PT 

High 

RO 

RO reported it plans to join operations on 01/06/2025.  

SE 

Low 

SI 

Low 

SK 

Low 

SE shared that it will be an opt-out country101. SE reported that the progress 
planned  for  2024  includes  the  completion  of  the  analysis,  the  start  of 
conformance testing Modes 1 and 2, as well as the development of the external 
testing  environment.  SE  shared  that  the  system  developer  is  using  an  Agile 
approach.  
SI informed being an opt-out country, but it is considering to be an opt-in in 
the  future 102 .  It  informed  that  NCTS-P6  is  on  target  despite  a  delay  in 
completing  the  technical  specifications.  SI  plans  to  have  the  technical 
documentation for the external domain prepared by 01/09/2024 and start with 
the development and conformance testing activities on 01/11/2024.  
SK shared that the NCTS-P6 project is on target, however, no concrete dates 
have been shared yet. By the end of 2024, SK aims to finalise its contracts and 
start the implementation of the updated specifications.  

Table 28: Detailed responses from Member States – NCTS-P6 

101 Information provided from a bilateral meeting between SE and DG TAXUD held on 27/03/2024 
102 Information provided from a bilateral meeting between SI and DG TAXUD held on 08/05/2024. 

136 

 
 
 
 
 
 
 
Figure 53 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 53: Project progress and status per milestone – NCTS-P6 

137 

 
 
 
 
 
 
4.5.2 Overview of Project Progress 

Figure 54 highlights any known divergences in the Member State’s National Planning compared to the 
dates  set  in  the  UCC  WP,  along  with  the  specific  dates  of  each  milestone.  As  this  project  has  a 
deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference  between 
these two dates indicates that a migration period is planned. 

Regarding UCC New Computerised Transit System – Phase 6 (NCTS-P6), the following Member States 
have a planned/actual operations date that is later than the deadline in the UCC WP: FR, PL and RO. 
BE, DE, and SK did not provide data through their National Planning regarding the operations date.  

138 

 
 
 
Figure 54: Actual/Planned dates per milestone – NCTS-P6 

139 

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

Figure 55 provides a visual overview of the planning of the UCC projects, as per the 2023 UCC WP 
revision.  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 55: Planning Overview – UCC WP Projects  

140 

 
 
 
 
 
 
 
6. 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 Continuity Plan 
Binding Tariff Information 
Centralised Clearance for Export 
Centralised Clearance for Import 
Customs Decisions System 
Customs Goods Manifest 
Common Repository 
Common Transit Convention 

Acronym 
ADM 
AEO 
AES 
AIS 
AN 
ATLAS 
BCP 
BTI 
CCE 
CCI 
CDS 
CGM 
CR 
CTC 
DG TAXUD   Directorate General for Taxation and Customs Union 
EBTI/EBTI-3 
ECCG 
EIDR 
EMCS 
EMSW 
EMSWe 
ENS 
EO 
EORI2 
EUCDM 
EU CTP 
GSP 
GUM 
ICS2 
ieCA 
INF 
MASP-C 
MNSW 
NCTS 
NECA 
NES 
NIS 
PN 
PoUS 
Q1/2/3/4 
QUOTA 
REX 
RfC 
RoRo 
RPS 
RUP 
SP 
SP EXP 
SP IMP 

trans-European Binding Tariff Information 
Electronic Customs Coordination Group 
Entry In the Declarant’s Records 
Excise Movement and Control System 
European Maritime Single Window 
European Maritime Single Window environment 
Entry Summary Declaration 
Economic Operator 
Economic Operator Registration and Identification upgrade 
European Union Customs Data Model 
European Union Customs Trader Portal 
Generalised Scheme of Preferences 
Guarantee Management 
Import Control System 2 
Information Exchange Conversion Application 
Information Sheet 
Multi-Annual Strategic Plan for Customs 
Maritime National Single Window 
New Computerised Transit System 
Nitrogen Oxide Emission Control Area 
National Export System 
National Import System 
Presentation Notification 
Proof of Union Status 
Quarter 1/2/3/4 
Quota Management 
Registered Exporter System 
Request for Change 
Roll-on/Roll-off 
Regulatory Procedure with Scrutiny 
Rational Unified Process 
Special Procedures 
Special Procedures – Component 1 
Special Procedures – Component 2 

141 

 
 
 
 
Acronym 
SURV3 
TOGAF 
TP 
TS 
TSS 
UAT 
UCC 
UCC WP 
UUM&DS 
VIS 

Description 
Surveillance 3 
The Open Group Architecture Framework 
Trader Portal 
Temporary Storage 
Technical System Specifications 
User Acceptance Testing 
Union Customs Code 
Union Customs Code Work Programme 
Uniform User Management and Digital Signature 
Vision Document 

Table 29: Abbreviations and Acronyms 

142