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  COM(2025) 579 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278(a) of the Union Customs Code, on progress in developing the electronic systems provided for under the Code {SWD(2025) 281 final}  
 
 
Table of Contents 

1. Introduction ..................................................................................................................................... 2 

2. Content of the Report ...................................................................................................................... 3 

3. Responsibilities for the UCC electronic systems ............................................................................ 4 

4. Global overview of progress with the UCC electronic systems ...................................................... 4 

4.1  PROJECTS COMPLETED BEFORE 2024 .......................................................................... 4 
4.2  ONGOING AND COMPLETED PROJECTS IN 2024 ........................................................ 5 
4.3  RISKS FOR DELAYS TO THE UCC IT IMPLEMENTATION ....................................... 12 
4.4  MITIGATION ACTIONS ................................................................................................... 14 
4.5  STATE OF PLAY FOR ENLARGEMENT COUNTRIES................................................. 16 
5. Management summary and conclusions ........................................................................................ 16 

1 

 
 
 
 
 
 
 
 
 
1. 

INTRODUCTION 

This is the 2024 annual progress report on the digital implementation of the Union Customs Code1 
(UCC), the sixth one drafted by the Commission in accordance with Article 278(a) of the UCC on the 
progress  in  developing  the  electronic  systems2.  It  covers  the  progress  status  achieved  in  2024, 
including a view on the expected future progress.  

The UCC entered into force on 1 May 2016 and following its amendment in 20193, it establishes the 
deadlines  of  2020,  2022  and  2025  for the  progressive  completion  of  the  projects  in  terms  of  digital 
transition and implementation. The existing electronic and paper-based systems can continue to be used 
for  the  completion  of  customs  formalities  (the  so-called  ‘transitional  measures’)  until  the  new  or 
upgraded electronic systems envisaged under the UCC are operational. In this context, the UCC Work 
Programme4  (UCC  WP)  and  the  Implementing  Regulation  on  the  Technical  Arrangements  for  the 
electronic  systems5  (IRTA)  are  to  be  read  in  conjunction  with  the  UCC  and  its  delegated  and 
implementing acts 

The  UCC  WP  is  the  legal  instrument  to  steer  the  gradual  and  complex  three-dimensional  transition 
process towards a fully digital customs environment, taking into account interdependencies between the 
systems and the situation of the actual development. It is the instrument used to steer the stakeholders 
in  the  projects  (Member  States,  Commission,  economic  operators)  towards  a  common  and  feasible 
implementation of the projects by 31 December 2025 as the final end date of the digital transition.  

This report draws on the UCC WP,  adopted by the Commission on 15 December 2023, as the 
baseline for reporting progress. The programme and project governance aspects are defined in  the 
Multi-Annual Strategic Plan for Customs (MASP-C).   

In  parallel  to the ongoing implementation  of the  UCC,  the  Commission  adopted  on  17  May  2023 a 
proposal  for  a  comprehensive  reform  of  the  Customs  Union,  including  a  new  UCC,  which  marks  a 
significant transformation of the EU customs framework.6 This proposal is currently under examination 
by the European Parliament and the Council according to the ordinary legislative procedure. 

This reform is structured around three main pillars:  

1)  the creation of an EU Customs Authority that will develop and oversee the EU Customs Data 
Hub: this will be the engine of the new system that will replace the current decentralised IT 
architecture based on customs declarations with a centralised, data-driven environment;  

Report from the Commission to the European Parliament and the Council:  

Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the 

1 
Union Customs Code, OJ L 269, 10.10.2013, p. 1–101. 
2 
2019: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52019SC0434; 
2020: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0339; 
2021: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52021SC0382; 
2022: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023SC0029; 
2023: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2024:395:FIN. 
3 
Regulation (EU) 2019/632 of the European Parliament and of the Council of 17 April 2019 amending Regulation 
(EU) No 952/2013 to prolong the transitional use of means other than the electronic data-processing techniques provided for 
in the Union Customs Code, OJ L 111, 25.4.2019, p. 54–58. 
4 
Commission  Implementing  Decision  (EU)  2023/2879  of  15  December  2023  establishing  the  work  programme 
relating  to  the  development  and  deployment  of  the  electronic  systems  provided  for  in  the  Union  Customs  Code,  OJ 
L_202302879, 22.12.2023, p.1-17, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202302879. 
5 
Commission Implementing Regulation (EU) 2025/512 of 13 March 2025 on technical arrangements for developing, 
maintaining and employing electronic systems for the exchange and storage of information under Regulation (EU) No 952/2013 
of 
the  Council,  OJ  L  2025/512,  20.3.2025,  p.  1–45,  https://eur-
lex.europa.eu/eli/reg_impl/2025/512/oj/eng. 
6 
Proposal  for  a  REGULATION  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL 
establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) 
No 952/2013 (COM/2023/258 final). 

the  European  Parliament  and  of 

2 

 
 
 
 
2)  a new partnership with trade operators based on transparent processes that will allow compliant 
trade  flows  to  operate  without  formal  customs  interaction  and  will  alleviate  the  related 
administrative burden;  

3)  a tailor-made e-commerce customs regime, which will make online platforms the key actors in 
ensuring  that  goods  sold  online  directly  to  consumers  in  the  EU  comply  with  all  customs 
obligations. 

The timely completion of the UCC electronic systems is a strong priority in order to materialise the 
benefits introduced for traders in the UCC. This is crucial to support and feed into the Customs Reform 
and  the  development  of  the  future  EU  Customs  Data  Hub,  otherwise  the  significant  simplifications 
promised by the customs reform would not be built on a strong base.  

2.  CONTENT OF THE REPORT 

The  projects  listed  in  the  UCC  WP  can  be  divided  into  three  categories  of  systems  based  on  the 
definitions provided for in the IRTA7:  

i)  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)  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; 
iii)  National systems that have to be developed or upgraded exclusively by the Member States.  

This report starts with explaining the method for the creation of the report and the sources used (section 
2) and then shortly covers the responsibilites for the UCC electronic systems (section 3). Furthermore, 
it contains the global overview of the different projects and their progress and also highlights potential 
delays, where identified, as well as envisaged mitigating measures (section 4). The overall assessment 
of the progress of the implementation of the UCC WP is summarised in the conclusion of this report 
(section 5).  

This report is accompanied by a Commission’s Staff Working Document8, published alongside this 
report, which contains detailed information on the planning and progress of the different projects as 
reported by the Member States. This work was supported by an external contractor. 

The report and Staff Working Document are drawn up on the basis of information collected from the 
following sources:  

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

and June). 

The information gathered for each project includes specific dates, the status, and the progress for each 
of the milestones set in the UCC WP;  

(2) survey circulated to the Member States. 

The information captured 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.  Moreover,  continuing  with  the 
approach taken in 2023, the Member States also provided information on the lessons learnt during the 
development of the projects and on the possible additional support needed;  

the  European  Parliament  and  of 

7 
Commission Implementing Regulation (EU) 2025/512 of 13 March 2025 on technical arrangements for developing, 
maintaining and employing electronic systems for the exchange and storage of information under Regulation (EU) No 952/2013 
of 
the  Council,  OJ  L  2025/512,  20.3.2025,  p.  1–45,  https://eur-
lex.europa.eu/eli/reg_impl/2025/512/oj/eng 
8 
Commission Staff Working Document Accompanying the Report from the Commission to the European Parliament 
and the Council pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided 
for under the Code, SWD (2024) XX final. 

3 

 
 
 
 
 
 
(3) bilateral high-level meetings with the Member States Customs IT Directorates. 

During the bilateral meetings a full and accurate understanding of the status of each of the UCC projects 
is  obtained  from  the  Member  States,  including  the  issues  they  were  encountering,  and  ideas  are 
generated for improving problematic situations.  

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

This  report  also  contains  an  analysis  based  on  more  detailed  information  provided  by  the  Project 
Managers in the Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD) 
and reported by the Member States in the framework of the Coordination Programmes in place since 
2020 for the trans-European systems.  

3.  RESPONSIBILITIES FOR THE UCC ELECTRONIC SYSTEMS 

Dependent on the system architecture agreed by the Member States and the Commission for each of the 
systems  (centralised,  decentralised  or  national),  there  is  a  role  sharing  defined  as  regards  to  the 
responsibilities for the development, deployment, operation, and maintenance. This is laid down in the 
IRTA, which describes what components those systems consist of, and what their nature is – national 
(developed at national level) or common (developed at EU level). In terms of architecture, the central 
systems and decentralised systems are of a trans-European nature and contain common components by 
default, sometimes incombination with national components, whilst the national systems only consist of 
national components.  

In  accordance  with  Article  103  of  the  IRTA,    the  common components  shall be  developed,  tested, 
deployed, and managed by the Commission and may be tested by the Member States. The  national 
components shall be developed, tested, deployed, and managed by the Member States.  

The  Member  States  shall  ensure  that  the  national  components  are  interoperable  with  the  common 
components.  The  Commission  shall  design  and  maintain  the  common  specifications  for  the 
decentralised systems in close cooperation with the Member States. The Member States shall develop, 
operate, and maintain interfaces to provide the functionality for the decentralised systems necessary for 
the exchange of information with Economic Operators and other persons through national components 
and interfaces, along with other Member States through common components. 

4.  GLOBAL OVERVIEW OF PROGRESS WITH THE UCC ELECTRONIC 

SYSTEMS 

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

4.1  PROJECTS COMPLETED BEFORE 2024 

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

• 

• 

• 

• 

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

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

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

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

4 

 
 
 
 
 
• 

• 

• 

• 

• 

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

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

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

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

UCC Import Control System 2 – Release 1 & 2 – ICS2 - Release 1 & 2 (upgrade): 
Deployed in 2021 and 2023, respectively. 

4.2  ONGOING AND COMPLETED PROJECTS IN 2024 

This report aims to highlight the accomplishments and challenges encountered in the implementation of 
the ongoing projects in 2024 by the Commission and the Member States.  

Section  4.2.1  provides  an  overview  of  the  six  trans-European  projects  scheduled  for  deployment 
between 2024 and 2025. Five of these projects have deployment windows ending in 2024 as set in the 
legal framework of the UCC WP.  

Section  4.2.2  outlines  the  implementation  of  the  three  national  projects,  namely  Notification  of 
Arrival/Presentation Notification/Temporary Storage (the so-called national entry systems), National 
Import Systems, and Special Procedures. These projects were originally planned to be operational by 31 
December  2022,  as  defined  in  the  UCC.  However,  due  to  the  inability  to  meet  this  deadline  and  as 
previously  identified  in  the  UCC  Annual  Progress  Reports,  several  Member  States  requested  a 
derogation under Article 6(4) of the UCC. As a result, on 1 February 2023, the Commission adopted 
Implementing Decisions granting derogations to certain Member States, extending the deadline to 31 
December 2023 for  the National Import Systems and the import domain of Special Procedures, as well 
as  for the  national  entry  systems  for  air  transport,  whilst a  further  alignment  was  indicated  with  the 
different releases of ICS2 for other modes of transport.  

4.2.1 Trans-European projects 

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

1) 

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

Progress: GUM – Component 1 that centrally manages guarantees that can be used across 
multiple  Member  States,  became  operational  on  11  March  2024  within  the  Customs 
Decisions System. In view of the interconnection between the two components, conformance 
testing activities remain available until Member States implement their GUM – Component 
2 systems.  

Concerning the national component, GUM – Component 2, Member States are expected to 
establish operational connections with the central component between March 2024 and June 
2025.  A  few  Member  States  reported  the  deployment  of  their  national  component  as 
completed; however, most Member States reported a low to medium risk level for the timely 
delivery of the project by Q2 2025. 

For  more  details,  please  refer  to  section  3.6.2  and  section  4.1.2  of the  Commission  Staff 
Working Document accompanying this report. 

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2) 

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

Progress: The ICS2 – Release 3 extends the scope from air transport to maritime and inland 
waterways,  road,  and  rail  traffic.  As  it  concerns  a  central  system,  conformance  testing 
activities for this release are exclusively carried out by economic operators. 

Overall, the economic operators shall start using ICS2 – Release 3 in three steps: maritime 
and inland waterways carriers by 4 December 2024, maritime and inland waterways traffic 
by  1  April  2025  and  road  and  rail  carriers  by  1  September  2025.  Most  Member  States 
indicated the project on target for the maritime transport and with a low risk towards meeting 
the UCC WP deadline for the other transport modes. 

For more details, please refer to section 4.2.2 of the Commission Staff Working Document 
accompanying this report. 

3) 

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

Progress: PoUS – Phase 1 started operations on 1 March 2024 as planned. 

Regarding PoUS – Phase 2, the technical specifications were completed by the Commission 
in Q2 2023, and conformance testing activities are scheduled to conclude in Q3 2025.  

The Member States and the Commission are on target for a timely delivery of the project by 
the legal deadline on 15 August 2025. A medium to high risk has been identified  for the 
project in view of the dependency with EMSWe. 

For more details, please refer to section 3.9.2 and 4.3.2 of the Commission Staff Working 
Document accompanying this report. 

4) 

UCC Centralised Clearance for Import – The new Trans-European CCI system ensure the 
digitalisation of the centralised clearence process at European level as defined in the Union 
Customs  Code  (UCC).  It  allows  trusted  traders  to  submit  a  customs  declaration  at  the 
supervising customs office in the member state of their establishment, for goods physically 
presented  to  a  customs  office  in  any  other  member  state,  enabling  customs  declaration 
processing and  physical  release  of goods  in  digital,  efficient,  predictable and coordinated 
way among the customs offices located in different Member States. 

The CCI system is being implemented in two phases:  

CCI  –  Phase  1,  enables  an  automated  processing  of  standard  and  simplified  declaration 
including pre-lodged customs declaration, as well supplementary declaration with a periodic 
or general nature for placing goods under release for free circulation, customs warehousing, 
inward processing and end use. CCI – Phase 2, builds upon Phase 1 by extending the scope 
to all remaining CCI scenarios, including more complex declaration types and process 
flows. It aims to complete the digital integration and functionality of centralised clearance 
for imports across the EU. 

Both phases are interrelated: Phase 1 is a prerequisite for Phase 2, and some Member States 
have opted to implement both phases simultaneously to streamline national efforts. 

Progress:  For  CCI  –  Phase  1,  the  Commission  is  progressing  according to  schedule and 
conformance testing with Member States is currently underway. A medium to high risk level 
has been assigned to the project due to dependencies on Member States’ readiness with the 
National Import Systems upgrade, a prerequisite for deploying CCI. 

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The CCI system entered its first phase implementation on 1 July 2024 with the readiness 
of the common components and some of the national components. As illustrated in Figure 
1 below, CCI phase 1 is available for use by European businesses in 9 Members States (BG, 
EE, ES, LU, LT, LV, PL, RO, HR) in September 2024. By 2 June 2025 BE, CZ, DK, EL, 
CY, IT, MT, AT, HU, PT, FI, SE and SI are planning to join gradually. By 31 December 
2025 DE, SK, NL, and IEare planning to join gradually. FR plans to join after 2025. 

Each blue stack bar includes the number of Member States having deployed the CCI system, 
while the green line depicts the total number of Member States (expected to be) in operations 
and the red line reflects the legal milestone of 01 July 2024. 

Figure 1: CCI P1 Member States entry in operations 

As regards to CCI – Phase 2, the Commission finalised the technical specifications in 2022, 
and conformance testing has been made available.  

To assist the Member States and traders in implementing all CCI scenarios and processes, 
the  Commission  developed  a  CCI  –  Phase  2  full  scope  technical  specifications  package 
consolidating the specifications for both phases, along with a guide. 

In terms of assessing the level of completeness of the full CCI system, most Member States 
reported that the developments are progressing, with some reassurance that they will meet 
the final deployment milestone on 2 July 2025.  

For more details, please refer to section 3.5.2 and 4.4.2 of the Commission Staff Working 
Document accompanying this report. 

5) 

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

Progress:  According to the 2023 UCC WP, NCTS – Phase 5 can be implemented in two 
steps: core functionalities by 1 December 2023 with business continuity aligned with UCC, 
and non-core functionalities by 2 December 2024. Economic operators were informed that a 
transtional period can be provide by the Member States till 2 December 2024 for the full 
implementation.  

7 

 
 
 
 
 
 
 
 
Figure 2: NCTS – Phase 5 Member States  entry into operations 

Overall, for NCTS – Phase 5, significant progress has been achieved. As illustrated in Figure 
2, 14 Member States started operations with core functionalities by 1 December 2023 and by 
October  2024  eleven  additional  joined.  All  Member  States  re-confirmed  their  timely 
readiness for entry into operations with the core and non-core functionalities by 2 December 
2024, with the exceptions of a few Member States who would join shortly later, but no later 
than 21 January 2025, which is the cut-off date of the old NCTS-Phase 4.  

For NCTS – Phase 6, the timeline was synchronised with that of ICS2 – Release 39. Most 
Member States reported a low risk associated with the delivery of the system by 1 September 
2025, with some of them are already progressing with the technical specifications. However, 
three  Member  States  (FR,  PL,  and  RO)  indicated  they  plan  to  join  operations  after  the 
deadline. 

For more details, please refer to section 3.7.2 and 4.5.2 of the Commission Staff Working 
Document accompanying this report. 

6) 

UCC  Automated  Export  System  –  AES  (upgrade):  aims  to  implement  the  UCC 
requirements for export and exit of goods, as well as the UCC  Simplifications offered to 
trade. 

Progress: According to the 2023 UCC WP, Member States can deploy AES in three steps: 
core functionalities by 1 December 2023, interface with Excise by 13 February 2024, and 
non-core functionalities by 2 December 2024. 

The Member States reported significant progress.  As illustrated in Figure 3, twelve Member 
States started operations with core functionalities by 1 December 2023 and by mid-October 
2024 seven additional joined. All remaining Member States, except FR and GR, will enter 
into operation with at least core functionalities and the Excise interface before 11 February 
2025, with most joining before the end of 2024. 

Regarding the national system, AES – Component 2, most Member States have or will deploy 
the system before the 2 December 2024 deadline.  

9 
As envisaged in the 2023 UCC WP, NCTS – Phase 5 will be fully deployed by 21 February 2025. The transition 
period from NCTS – Phase 5 to NCTS – Phase 6 is envisaged between 1 March 2025 and 1 September 2025, during the same 
period that ICS2 – Release 2 will transition to ICS2 – Release 3, allowing for the synchronisation between both systems. 

8 

 
 
 
                
 
 
 
For more details, please refer to section 3.8.2 of the Commission Staff Working Document 
accompanying this report. 

Figure 3: AES Member States entry into operations  

To summarise the status of the trans-European projects listed above, the Commission remains on track 
to meet the legal deadlines agreed upon in the context of the UCC and UCC WP. As regards the Member 
States’  deployments  of  the  national  components  of  these  trans-European  systems,  serious  risks  for 
delays have been identified, particularly for CCI and AES (see section 4.3).  

4.2.2 National projects 

The  Member  States  were due  to  complete  the  upgrade  of their systems for  the  three  fully  national 
projects10 by 31 December 2022, in accordance with Article 278(2) of the UCC. However, twenty-two 
Member  States could  not meet this deadline and  following their  request,  were granted  a derogation, 
extending the deployment deadline to 31 December 202311. Last year’s report reflected some further 
delays mainly for the National Import System and the system for Temporary Storage. By the end of 
2024, most of the Member States have deployed these different entry and import systems, though it has 
to  be  noted  that  some  are  working  in  iterations  and  that  some  functionalities  or  upgrades  to  their 

This timeline excludes the Export Component of the national Special Procedures system, for which the activity and 

10 
planning is interlinked with the AES. 
11 
Commission Implementing Decision (EU) 2023/235 of 1 February 2023 granting a derogation requested by certain 
Member States pursuant to Regulation (EU) No 952/2013 of the European Parliament and of the Council to use means other 
than electronic data-processing techniques for the exchange and storage of information for the notification of arrival of a sea-
going vessel or of an aircraft (OJ L 32, 3.2.2023, p. 220-222). 
Commission Implementing Decision (EU) 2023/234 of 1 February 2023 granting a derogation requested by certain Member 
States  pursuant  to  Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of  the  Council  to  use  means  other  than 
electronic data-processing techniques for the exchange and storage of information for the Presentation Notification related to 
goods brought into the customs territory of the Union (OJ L 32, 3.2.2023, p. 217-219). 
Commission Implementing Decision (EU) 2023/236 of 1 February 2023 granting a derogation requested by certain Member 
States  pursuant  to  Regulation  (EU)  No  952/2013  of  the  European  Parliament  and  of  the  Council  to  use  means  other  than 
electronic  data-processing  techniques  for  the  exchange  and  storage  of  information  for  the  Temporary  Storage  declaration 
related to non-Union goods presented to customs (OJ L 32, 3.2.2023, p. 223-225). 
Commission Implementing Decision (EU) 2023/237 of 1 February 2023 granting a derogation requested by certain Member 
States to use means other than electronic data-processing techniques for the exchange and storage of information related to the 
customs declaration for goods brought into the customs territory of the Union laid down in Articles 158, 162, 163, 166, 167, 
170 to 174, 201, 240, 250, 254 and 256 of Regulation (EU) No 952/2013 of the European Parliament and of the Council laying 
down the Union Customs Code (OJ L 32, 3.2.2023, p. 226-228).   

9 

 
 
 
   
                
 
 
 
datamodel will be deployed with a later release of their systems. In this respect, the full implementation 
of these projects is still work in progress for a substantial number of Member States. 

The progress for each national project is presented below and illustrated in Figure 4: 

1)  UCC Notification of Arrival, Presentation Notification, and Temporary Storage (AN, PN, 
and TS) (upgrade): aims to automate the national entry processes and harmonise data exchange 
between trade and customs across the Member States. 

Progress: The timely delivery of national systems was identified as being at risk in previous UCC 
Annual Progress Reports. As illustrated in Figure 4, most Member States aim to complete the 
implementation by the end of 2024 considering the link with ICS2 – Release 3.  

For  more  details,  please  refer  to  section  3.1.2  of  the  Commission  Staff  Working  Document 
accompanying this report. 

2)  UCC  National  Import  Systems  –  NIS  (upgrade):  aims  to  implement  all  process  and  data 

requirements that relate to the imports of goods as outlined in the UCC. 

Progress: Several Member States reported risks in the timely delivery of the project since 2022, 
resulting in derogations granted.  As illustrated in Figure 4, the NIS upgrade was deployed by 15 
Member States. However, a few Member States have deployed but require a further update (IE, 
PL, and SK), while four do not anticipate achieving implementation by the end of 2024.  

For  more  details,  please  refer  to  section  3.2.2  of  the  Commission  Staff  Working  Document 
accompanying this report. 

3)  UCC Special Procedures – SP (upgrade): aims to harmonise Special Procedures (i.e., customs 

warehousing, end-use, temporary admission and inward/outward processing). 

Progress:    As  illustrated  in  Figure  4,  18  Member  States  completed  SP  –  Component  2.  The 
remaining  Member  States  are  delayed  beyond  the  deadline,  four  of  which  do  not  envisage 
deploying the system by the end of 2024.   

As for SP – Component 1, most Member States have or will deploy the system by 2 December 
2024 despite the interdependencies with the AES system.  

For more details, refer to sections 3.3.2 and 3.4.2. of the Commission Staff Working Document 
accompanying this report. 

10 

 
 
 
 
 
 
 
 
 
 
AN 

PN 
31/12/2022 
 with extension to 31/12/2023[1] 

TS 

NIS 

SP IMP 

31/12/2022  
with extension to 31/12/2023[2] 

01/07/2023 
30/06/2023 
01/03/2023 
30/10/2024 
05/12/2023 
 N/A 
06/11/2023 
01/10/2023 
01/03/2023 

01/06/2023 
05/07/2023 
10/11/2023 
30/10/2024 
05/12/2023 
06/03/2021 
06/11/2023 
15/03/2021 
01/01/2024 

02/06/2025 
29/11/2023 
10/11/2023 
30/10/2024 
05/12/2023 
06/03/2021 
08/03/2025 
01/07/2021 
01/01/2024 

31/03/2023 

31/03/2021 

31/12/2022 

30/06/2023 
31/12/2023 
01/07/2023 
02/04/2024 
01/07/2023 
13/12/2022 
01/03/2023 
01/03/2023 
24/09/2017 

04/11/2024 
30/06/2023 
01/07/2023 
28/10/2024 

01/05/2024 
01/03/2023 
01/03/2023 
01/03/2023 

06/03/2024 
31/12/2023 
01/03/2023 
02/04/2024 
23/11/2020 
13/12/2022 
28/02/2023 
10/01/2023 
24/09/2017 

04/11/2024 
01/12/2023 
20/10/2024 

28/10/2024 

30/09/2024 
27/09/2023 
01/03/2023 
01/10/2023 

06/03/2024 

30/06/2025 
17/04/2023 
02/04/2024 
23/11/2020 
13/12/2022 
31/10/2023 
10/01/2023 
24/09/2017 

04/11/2024 
01/12/2023 
20/10/2024* 

28/10/2024 

31/12/2024 
01/10/2024 
01/03/2024 
02/06/2025* 

01/04/2025 
28/08/2024 
10/11/2023 
30/10/2024 

15/12/2025 

31/10/2022 

08/03/2025 
01/07/2021 
05/09/2023 
31/12/ 
2022 
30/11/2024 

30/06/2025 
01/01/2023 
01/11/2023 

20/01/2026* 

30/11/2022 
31/12/2023 
02/05/2023 
04/06/2018 

31/01/2025 
01/04/2022 
20/10/2024* 

28/10/2024 

31/12/2024 

31/12/2023 
01/01/2022 
01/07/2025* 

01/04/2025 
28/08/2024 
10/11/2023 
30/10/2024 

15/12/2025 
06/03/2021 
08/03/2025 
01/07/2021 
05/09/2023 

31/12/2022 

30/11/2024 

30/06/2025 
01/01/2023 
01/11/2023 
23/11/2020 
30/11/2022 
31/12/2023 
02/05/2023 
04/06/2018 

31/01/2025 
01/04/2022 
28/03/2022 

28/10/2024 

31/12/2024 

31/12/2023 
01/01/2022 
11/06/2016 

UCC WP 
Deadline 
AT 
BE 
BG 
CY 
CZ 
DE 
DK 
EE 
ES 

FI 

FR 
GR 
HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
PL 
PT 
RO 
SE 
SI 
SK 

Legend 

Deployment completed by 31/12/2024 

System not deployed by 31/12/2024  
No dates provided in National Project Plans or deployment not applicable 
Figure 4: National entry/import systems deployment planning 

[1] Until 31/12/2023 for the Member States that were granted a derogation. Additionally, FI and GR provided dates in quarters, 
therefore, if the quarter falls within the UCC WP deadline it has been considered in line. 
[2]  Until  31/12/2023  for  the  Member  States  that  were  granted  a  derogation  or  until  01/07/2024,  where  Article  2(4a)  of 
Commission Delegated Regulation (EU) 2015/2446 applies. 
* The national system was upgraded on time but requires a further alignment to the UCC and EU Customs Data Model. 

To summarise, Member States are in the process of completing the upgrade of their three fully national 
projects. A significant number of Member States reported delays, mostly for Temporary Storage, NIS 
upgrade, and SP – Component 2, resulting in deployments that extend beyond the 2023 deadlines. In 
turn, other domains are affected, such as the CCI system as the NIS upgrade is an important prerequisite 
for the deployment of the electronic system. 

11 

 
 
 
 
 
 
 
 
 
 
  
  
  
 
 
4.3  RISKS FOR DELAYS TO THE UCC IT IMPLEMENTATION 

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

Most  Member  States  are  firmly  and  gradually  progressing  in  the  developments  under  their 
responsibility, although  some of them are advancing at a slower pace than originally planned and 
some did not make sufficient use of the extended periods provided with the UCC WP of 2023. As a 
result, delays beyond the legal or derogation deadlines were reported in some national and trans-
European projects.  

Most  of  the  Member  States  have  made  significant  advancements  in  the  development  of  the  trans-
European  systems  and  several  were  striving  to  have  their  systems  deployed  by  the  end  of  2023  in 
accordance with the initial deadlines and derogations provided. However, some are still experiencing 
delays in 2024, resulting in the push of their deployment plans to the end or beyond the deployment 
window.  The  Commission  has  urged  strict  adherence  to  their  National  Project  Plans  for  a  timely 
deployment.  

The Member States provided several grounds for justification of the delays, most of which are recurring. 
These  include  a  lack  of  financial  and  human  resources,  competing  priorities,  and  interdependencies 
between systems. Additionally, Member States reported the inability of national IT infrastructures to 
cope with the technical needs of the projects, capacity issues of contractors, and dependencies with other 
stakeholders. Furthermore, other contributing factors to delays include extended conformance testing 
periods, traders’ readiness, delayed or unsuccessful calls for tenders, burdensome public procurement 
procedures, governance issues, and complex system integrations.  

As regards  the national  entry  and import  projects,  it was  outlined in  the  previous reports  and in 
Section 4.2 that Member States submitted formal requests for derogations  concerning delays beyond 
legal deadlines in their national projects,extending the deadline until 31 December 202312.   

The information provided in Figure 4 demonstrates that the following Member States are late for one or 
more projects: AT, CZ, DK, GR, and with some Member States requiring a further upgrade to their 
system to have a full alignment to the UCC. 

As  for  the  trans-European  projects  detailed  in  Section  4.2,  and  as  reflected  in  the  accompanying 
Commission Staff Working Document, several Member States informed the Commission about the 
following delays: 

•  For the implementation of Special Procedures – Component 1, the following Member States 
have a planned/actual operation date that is later than the deadline in the UCC WP: AT, CY, 
DK, FI, FR, GR, HU, IT, LT, LU, MT, PT, RO, SE, and SK. For more details, please refer to 
section 3.3 of the Commission Staff Working Document accompanying this report. 

•  For the implementation of ICS2 – Release 3, the following Member States have a planned/actual 
operations date that is later than the deadline in the UCC WP13: DK, FI, LU, MT, and RO. For 

For  modes  of  transport  other  than  air,  the  derogations  for  Arrival  Notification,  Presentation  Notification,  and 

12 
Temporary Storage last until 29/02/2024. 
13 
In the 2023 UCC WP Revision, the deployment of the full ICS2 – Release 3 by all Member States is envisaged for 
03/06/2024.  The  rollout  of  the  ICS2  –  Release  3  system  is  planned  in  three  steps:  Step  1  concerning  maritime  and  inland 
waterways carriers (with a deployment window starting on 03/06/2024 and ending on 04/12/2024); Step 2 related to the house 
level filers in the maritime and inland waterways traffic (with a deployment window starting on 04/12/2024 and ending on 
01/04/2025); and Step 3 regarding the road and rail carriers (with a deployment window starting on 01/04/2025 and ending on 
01/09/2025). 

12 

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

•  For the implementation of CCI – Phase 1, the following Member States indicated a planned 
operations date that is later than the deadline set in the UCC WP14: AT, CY, CZ, DK, GR, FI, 
HU, IE, MT, NL, PT, SE, SI, and SK. In addition, FI, PT, and SK have requested a derogation. 
For CCI – Phase 2, BE, CZ, DE, FI, GR, NL, and PL indicated a planned/actual operations date 
that  is  later  than  the  deadline  in  the  UCC  WP.  Additionally,  PT  and  SK  have  requested  a 
derogation.  For  more  details,  please  refer  to  sections  3.5  and  4.4  of  the  Commission  Staff 
Working Document accompanying this report. 

•  For the implementation of NCTS – Phase 5, AT, BE, CY, DK, ES, FI, FR, GR, HU, LT, MT, 
NL, PL, PT, RO, SE,  and SK have a planned/actual operations date for the core functionalities 
that is later than the deadline defined for this step 1 in the UCC WP15. However, all Member 
States deployed the system by 21 January 2025, which marked the end of the transition period. 
. This is a very important achievement in the implementation of the UCC WP.  For the non-core 
functionalities, a few Member States have delays, though this is not impacting the functioning 
of the new NCTS – Phase 5 as there is no direct interconnection with other Member States’ 
systems.  

•  For NCTS – Phase 6, GR, PL, and RO reported a planned/actual operations date that is later 
than the deadline in the UCC WP. This project is to be seen in connection with ICS2 Release 3. 
For  more  details,  please  refer  to  sections  3.7  and  4.5  of  the  Commission  Staff  Working 
Document accompanying this report.  

•  For  the  implementation  of  AES  –  Component  1,  the  following  Member  States  have  a 
planned/actual operations date for the core functionalities that is later than the deadline for this 
step 1 in the UCC WP16: AT, BE, CY, GR, HU, LU, MT, PL, PT, RO, SE, FR and SK.  

However,  more  important is the  final  deployment  date  for  the  AES  on 2  December  2024 as 
defined in the UCC WP with transitional rules in place till 11 February 2025. A few Member 
States reported issues leading potentially to a very short delay (PT, MT, HU and AT). However, 
a more substantial problem was reported by two Member States (FR and GR) who could not 
deploy their component on time, despite all measures taken, and were facing serious delays. 
Hence, the full deployment of the new AES system is blocked and the other Member States and 
European business are forced to remain in a longer period of transition.  

In  the  light  of  the  delays  in  implementing  AES,  the Commission  was  asked  to maintain the 
central  message  convertor  running  till  end  of  2025  to  assure  business  continuity  and  avoid 
disruptions in trade flows. This meant the de facto extension of the transition period. To have 
legal  coverage  for  this extension,  the  Commission  proposed a  legal  amendment  to  the  UCC 
Implementing  Regulation  for  Technical  Arrangements  (IRTA)  concerning  the  electronic 
systems. This amendment was voted on 7 February 2025 and adopted in March 2025 and allows 
for the continuation of the transitional measures for export and exit for an extended period till 
14 December 2025, whilst the deadline for Member States will remain as defined in the UCC 
WP 

In the 2023 UCC WP Revision the end of the deployment window is envisaged for 01/07/2024. 
14 
15 
In  the  2023  UCC  WP  Revision,  the  end  of  the  deployment  window  for  the  core  functionalities  of  the  system  is 
envisaged  for 01/12/2023  and  the  remaining  functionalities  for  02/12/2024.  By  02/12/2024,  all  Member  States  and  traders 
should use the NCTS – Phase 5 system. The end of the transition is envisaged for 21/01/2025. 
16 
In  the  2023  UCC  WP  Revision,  the  end  of  the  deployment  window  for  the  core  functionalities  of  the  system  is 
envisaged  for  01/12/2023,  the  development  of  a  harmonised  interface  with  the  EMCS  for  13/02/2024,  and  the  remaining 
functionalities  for  02/12/2024.  By  02/12/2024,  all  Member  States  and  traders  should  use  the  AES  system.  The  end  of  the 
transition is envisaged for 11/02/2025. 

13 

 
 
 
 
 
 
 
 For AES – Component 2, GR, FI, MT and FR indicated a planned/actual operations date that 
is later than the deadline in the UCC WP. For more details, please refer to section 3.8 of the 
Commission Staff Working Document accompanying this report. 

•  For  the  implementation  of  GUM  –  Component  2,  the  following  Member  States  indicated  a 
planned operations date that is later than the deadline set in the UCC WP17: GR, FI, DE and FR. 
For  more  details,  please  refer  to  section  4.1  of  the  Commission  Staff  Working  Document 
accompanying this report. 

•  For  the  implementation  of  PoUS  –  Phase  2,  which  is  interconnected  with  the  EMSWe,  the 
project is on schedule from a customs perspective, however, there are possible delays in the 
availability of the National Maritime Single Windows by Member States’ maritime authorities.   

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

4.4  MITIGATION ACTIONS 

The Member States outlined the various mitigating actions aimed at addressing (potential) delays and 
ensuring  compliance  with  the  legal  deadlines.  These  actions  include  optimising  the  allocation  of 
resources, adopting agile methodologies, implementing integrated systems solutions, and strengthening 
coordination with contractors to improve the efficiency and enhancing collaboration. Other Member 
States plan to improve organisational structures, streamline processes, and refine planning to improve 
project management and decision-making. These measures were referred to for both national and trans-
European projects. 

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

Firstly,  the  Comission  has  enhanced  supervision  and  monitoring  of the  UCC  IT  programme  by 
increasing the frequency of progress reports and organising bilateral meetings and missions at Director 
level with each of the Member States. The implementation of the UCC WP has also been put consistently 
on the agenda of the meetings and missions conducted by the Director-General and in plenary high-level 
meetings with the Directors-General of the Member States as in the Customs Policy Group. The Member 
States were encouraged to take mitigating measures. 

The Commission continued using a Multi-Annual Strategic Plan – Customs (MASP-C) dashboard based 
on the MASP-C Revision 2023 and the UCC WP 2023 to monitor the progress, project milestones, and 
identify delays at an early stage. The dashboard is presented on a quarterly basis to the Member States 
in the ECCG which is meeting jointly with the trade community. 

Additionally, as indicated in the UCC WP and MASP-C Revision 2023, the Commission sets specific 
interim milestones to ensure a smooth deployment of the decentralised trans-European systems and to 
avoid additional costs.  

Secondly, the Commission has reinforced its assistance to the Member States for trans-European 
systems by adopting an agile and iterative approach to developing and deploying the UCC electronic 
systems. This method, which includes prototyping, swift issue resolution, and a balanced workload for 
both the Commission and the Member States, enhances system quality and facilitates tangible progress.  
This approach has been well-received by the Member States and traders.  

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

17 
In the 2023 UCC WP Revision, for GUM – Component 1, the deployment date is envisaged for 11/03/2024 and, for 
GUM – Component 2, the start of the deployment window is to be defined by the Member States, with the earliest possible 
deployment date being 11/03/2024. 

14 

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

Further details on the activities carried out for ICS2, NCTS - Phase 5 and AES:     

•  For the trans-European system ICS2, the Commission continued to provide support to the 
Member States and Economic Operators in their development activities for ICS2 – Release 3 
through  various  means.  This  included  organising  dedicated  webinars,  offering  assistance 
through FAQs, and coordinating plenary meetings to  ensure alignment of project plans with 
Commission’s  IT  delivery  milestones.  Lastly,  communication  campaigns,  online  training 
sessions, and documentation were provided accessible in the public CIRCABC library.  

•  For the trans-European systems NCTS – Phase 5 and AES, the Commission continued with 
the  ‘National  Administration  Coordination  Programme’  to  support  the  Member  States  in 
developing  and  deploying  their  national  components.  The  programme  has  been  extended  to 
oversee the transition of the Member States and traders to NCTS – Phase 5 and AES systems, 
monitor the operational continuity during the transition, and foster closer collaboration with the 
Member States. Activities include a dedicated helpdesk, virtual meetings to mitigate Member 
State’s  development  delays,  updated information  dissemination  to the  trade community, and 
regular  reporting  to  the  ECCG  and  CPG.  Additionally,  the  Commission  issues  quarterly 
consolidated progress reports on the transition to the new systems since Q1 2021, providing 
KPIs for early alert detection.  

Inspired  by  the  monitoring  and  coordination  programmes  for  the  other  trans-European  projects,  the 
Commission  increased  its  activities  to  closely  monitor  the  progress  of  the  national  components’ 
development  by  the  Member  States  for  the  CCI  project  and  established  a  quarterly  consolidated 
progress report as of Q1 2024. Furthermore, the Commission’s dedicated CCI business team continued 
its  efforts  to  address  Member  State’s  questions  on  import  and  the  simplifications  at  import  such  as 
centralised clearance. In addition, regular technical meetings on a weekly and bi-weekly basis as well 
as feedback sessions on conformance testing were held. 

Thirdly, the Commission sought Member States’s input on their constraints and the needed support to 
mitigate the risks. The Member States expressed via the survey that the bilateral meetings at Director 
level  and  technical  dialogue  with  DG  TAXUD  had  been  highly  beneficial.  They  assessed  technical 
webinars  and information-sharing  activities  provided  by  the  Commission  as  useful.  Some suggested 
additional  operational  guidelines  and  trainings,  guidance  to economic  operators,  and  assistance  with 
business support and expertise, which was then taken forward by the Commission during 2024. 

Fourthly, based on the outcome of the survey and on bilateral discussions with the Member States, the 
lack of appropriate funding was often revealed as a reason for delays. The Commission’s communication 
around the new call for funding under the Technical Support Instrument (TSI) 2025 aims to promote 
awareness to Member States for the possibility to get support for the UCC digital transformation.   

Fifthly, to address the specific needs of Member States in their daily management of the UCC digital 
programme, three Member States (FR, MT and GR) took part in a pilot that the Commission put in place 
with a consultancy company at the end of 2023. These Member States reported during 2024 that the 
insights and recommendations provided were very useful in having a better understanding of the issues 
and how to address these and as such avoid further delays.  

Finally, the Commission continued with the exercise to gather the lessons learnt and best practices for 
the  development  of  the  digital  projects.  To  that  end,  the  survey  conducted  in  2024  provided  this 
information and the outcomes were added to section 1.2 of the Commission Staff Working Document 
accompanying this report. 

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

15 

 
 
 
continuity for the trans-European systems. In accordance with EU law, the Commission has engaged in 
formal correspondence with the Member States facing delays in implementing IT systems. 

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

4.5  STATE OF PLAY FOR ENLARGEMENT COUNTRIES 

The future EU Enlargement countries and other contracting parties to the Common Transit Convention 
(CTC) will need to take into account the transition towards the upgraded electronic systems envisaged 
by the UCC and the new IT approaches set up by the reform proposal.  

The  Commission  does  not  systematically  monitor  the  progress  towards  full  electronic  systems  of 
candidate countries as part of the reporting obligation under Article 278a of the UCC. However, as part 
of the enlargement strategy including the Association Agreements with the EU, the development of their 
IT  systems  supporting  their  alignment  with  EU  customs  legislation  is  a  key  element  in  the  regular 
assessments carried out by the EU.  

The candidate countries will need to progressively connect to or put in place the UCC systems in the 
path towards joining the EU customs territory. Depending on the planned date of accession, they may 
also be required to meet the functionalities of the future EU Customs Data Hub proposed in the Customs 
Reform package.  

In the future, in preparation for the Enlargement involving candidate countries, several key activities 
will need to occur regularly. These include reporting on the digital implementation and taking part in 
conformance testing to ensure interoperability between their national systems and those of the Member 
States and of the EU. Additionally, the EU will need to regularly assess the performance of the systems.  

5.  MANAGEMENT SUMMARY AND CONCLUSIONS 

The implementation of the UCC has been a collaborative project marked by strong commitment from 
all stakeholders since the UCC Work Programme (UCC WP) was first adopted in 2014.  

In  drafting  this  report,  the  Commission  closely  analysed  the  progress  data  collected  in  2024  and 
witnessed significant strides made by Member States towards the 2025 target. This shared dedication 
led to significant advancements in the UCC digital implementation programme in 2024, with successful 
rollouts of the Guarantee Management System (GUM), ICS2 Release 3, PoUS Phase 1 and NCTS - 
Phase 5.  

However, despite these achievements, some Member States continue to struggle with certain project 
deadlines, particularly for those related to the import domain (NIS, TS, CCI) and export domain (AES). 
The  delays  encountered  by  some  Member  States  have  a  negative  impact  on  the  other  stakeholders, 
limiting the  benefits and causing  additional  costs  for  the  Commission, other Member  States  and  the 
European businesses. For Member States not yet deploying the upgraded NIS, the Commission does not 
receive yet all the data needed for performing its surveillance tasks. For CCI, there is impact on European 
business as the roll-out and benefits for companies will only be available if both involved Member States 
(where the company is established and where the company is presenting the goods) have deployed their 
national CCI component. For AES, there is an impact on other Member States as an indirect export 
started in one Member State requires the confirmation of the exit in another Member State so that the 
companies can have a proof of exit and recover VAT. Therefore, both Member States need to be able to 
communicate in the same system.  

It remains essential that all stakeholders sustain efforts and dedicate the necessary resources to meet the 
final 2025 deadline, as further delays will continue having its spill-over effects on other Member States 
and disrupt the consistent operational framework intended to benefit all economic operators uniformly. 

16 

 
 
 
 
It  implies  prolonged  and  intensified  demands  on  resources  for  additional  conformance  testing, 
coordination,  and  extended  system maintenance  on  the  side  of the  Commission,  Member  States and 
economic operators. Furthermore, the UCC digital implementation plays a key role in revenue protection 
and in combating unfair or illicit trade.  

Compared to 2023 Member State efforts and results are now more pronounced, revealing an increasingly 
diverse  range  of  progress  as  we  approach  the  final  year  for  UCC  implementation.  This  variation 
underscores the urgent need for unified and prompt action to ensure a complete digital transition across 
all Member States. Maintaining momentum, addressing setbacks, and meeting deadlines are essential 
for preserving business continuity and supporting economic operators as the Union moves toward a fully 
digital customs environment. As visually represented in the graph below, a lot of work is behind us and 
the final year of deployments is at sight. 

 Figure 5 – Planning Overview  

As of 2024, approximately 63% of Member States face delays in CCI Phase 1, while fewer delays have 
been reported in other components, such as ICS2 Release 3 and AES, each impacting no more than 11% 
of Member States. These differences reflect varied levels of readiness and signal that, without sustained 
effort, delays could affect the collective timeline for full UCC implementation by 2025. 

To reach this critical milestone, all stakeholders must now redouble their focus and commitment to the 
UCC  WP’s  legal  timelines.  Concurrently, the  Commission  has formally  corresponded  with  Member 
States experiencing delays, in line with EU law. The Commission will continue its close monitoring and 
support  through  both  programme-level  and  project-level  engagement,  supplemented  by  bilateral 
exchanges and plenary meetings with Member States.  

17