REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the interim evaluation of the Customs programme for cooperation in the field of customs for 2021-2027
Date: 2026-01-29
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU programme, customs, customs cooperation, customs formalities, customs inspection, customs union, exchange of information, information system, project evaluation, third country

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   EUROPEAN COMMISSION  Brussels, 29.1.2026  COM(2026) 40 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the interim evaluation of the Customs programme for cooperation in the field of customs for 2021-2027 {SWD(2026) 20 final}  
 
 
1.  Introduction 

The  EU  Customs  Union,  as  an  exclusive  European  Union  competence  underpinned  by  the 
Union Customs Code1 (UCC), is a key pillar of the single market. It guarantees free circulation 
of  goods  within  the  EU  customs  territory,  while  applying  a  single  customs  tariff  and 
harmonised  rules  at  the  external  border.  The  UCC,  adopted  in  2013  and  progressively 
implemented  since  2016,  set  the  framework  for  a  fully  electronic,  paperless  customs 
environment and uniform application of customs legislation across Member States. Delivering 
this vision requires not only national implementation but also substantial common investment 
in large-scale European Electronic Systems (EES), common working methods and training to 
ensure that customs administrations can operate seamlessly as one. The Customs programme 
is the dedicated tool for providing this support. It pools resources and expertise to keep the 
Customs  Union  functioning  in  a  context  of  growing  trade  volumes,  new  technologies  and 
shifting geopolitical pressures. 

The Customs programme for 2021-2027, governed by Regulation (EU) 2021/444, is the EU’s 
ongoing cooperation programme in the field of customs, running from 2021 to 2027. It aims to 
support the EU Customs Union and participating customs authorities to act as one to protect 
the financial and economic interests of the Union and its Member States, to ensure security and 
safety within the Union and to protect the Union from unfair and illegal trade, while facilitating 
legitimate  business  activity.  The  programme  supports  the  preparation  and  uniform 
implementation of customs legislation and policy across Europe; cooperation between customs 
authorities; administrative and IT capacity building, including human competency and training, 
as well as the development and operation of the EES; and innovation in the area of customs 
policy. 

The programme has a budget of EUR 950 million between 2021 and 2027, the period of the 
current Multiannual Financial Framework (MFF). Compared to its predecessor, the Customs 
2020  programme  (EUR 523  million),  the  current  programme’s  budget  nearly  doubled. This 
reflects the scale of digitalisation and the operational ambition under this MFF to implement 
for implementation of the UCC, with the full implementation of the UCC work programme to 
be  completed  no  later  than  31 December  2025.  This  funding  allows  advanced  electronic 
systems to be developed that streamline customs processes, strengthen the security of the EU’s 
Single  Market  and  better  equip  customs  authorities  to  respond  to  emerging  global  trade 
challenges. 

The lion’s share of the budget (over 90%) goes to developing and maintaining the common 
components of the EES, developed at Union level and available for all Member States. These 
components allow the Customs Union to be implemented efficiently and allow Member State 
customs  authorities  to  cooperate  effectively  with  each  other.  The  systems  are  designed  to 
produce a seamless and secure electronic environment for exchanging data between customs 
authorities and with economic operators, as well as to ensure sound risk management. 

1 Regulation (EU) No 952/2013 of the European Parliament and of the Council laying down the Union Customs 
Code. 

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The remainder of the budget supports collaborative and human competency activities. These 
strengthen the operational capability and performance of national customs administrations and 
help them to cooperate and share knowledge. Support is provided, in particular, for project-
based  collaboration,  training,  working  groups,  seminars  and  workshops,  working  visits  and 
expert teams, i.e. structured collaboration between a variable number of participating Member 
States with an interest in a certain subject. Training is offered through the Customs and Tax EU 
Learning Portal (also referred to as the Learning Management System (LMS)). 

2.  Findings of the interim evaluation 

This report presents the findings of the interim evaluation of the Customs programme for 2021-
2027, in line with Article 14 of Regulation (EU) 2021/444. It is underpinned by a staff working 
document,  which  examines  in  detail  the  implementation  and  performance  of  the  Customs 
programme to date (2021-2024). The interim evaluation applies the Better Regulation criteria 
to assess the programme’s effectiveness, efficiency, coherence, EU added value and relevance. 
There is a clear focus on the common components of the EES but the interim evaluation also 
updates the analysis of the collaborative activities performed in earlier studies. It focuses on 
new aspects under the current programme, such as activities related to capacity building and 
common training, and innovation activities. Expert teams are also part of the analysis as these 
activities  are  more  recent  compared  to  other  collaboration  activities,  introduced  under  the 
Customs 2020 programme. 

Methodologically,  the  interim  evaluation  combines  Monitoring  and  Evaluation  Framework 
(MEF)  indicators  at  portfolio  level  with  in-depth  insights  from  case  study  research  into  the 
common components of the EES. It is complemented by targeted and general research covering 
the  breadth  of  programme  support. This  approach  reflects  the  principle  of  proportionality, 
given that EES account for the largest share of expenditure, and addresses evidence gaps from 
prior evaluation cycles. Four stand-alone case studies were produced on specific EES as was a 
case study on the LMS: 

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the EU’s new Import Control System (ICS2), which supports efforts to ensure the safety 
and security of the Union through the early collection and analysis of information on goods 
entering the EU, to identify potentially high-risk consignments; 
the system developed for Proof of Union Status (PoUS), which aims to make procedures 
more  uniform  across  the  EU  and  contribute  to  the  establishment  of  a  more  consistent, 
harmonised and thus simplified process related to the customs status of Union goods; 
the EU’s new Centralised Clearance for Import system (EU CCI), which enables CCI-
authorised trusted traders to submit customs declarations in one EU Member State while 
the  goods  are  physically  presented  for  clearance  in  another. This  facilitates  trade,  while 
supporting  effective  risk  management  and  a  joint  mechanism  for  customs  controls 
mechanism, and ensures proper collection of duties and other charges; 
the digitalisation of new controls on the Import of Cultural Goods (ICG), including 
digital  cooperation  with  customs  authorities  via  the  EU  single  window  environment  for 

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• 

customs. Since this system (and the associated controls) were not due to be deployed until 
28 June 2025, this case study focused on the management approach to developing the ICG; 
the LMS case study was developed to provide a cost-benefit analysis of this new portal, 
drawing on a survey of users, a survey of the Training Support Group previously carried 
out by the Directorate-General for Taxation and Customs Union (DG TAXUD), interviews 
with DG TAXUD officials and Member State training officials, and desk research. 

The data collection efforts for the overall assessment of the programme were designed to be 
comprehensive  while  prioritising  primary  research  on  the  key  issues.  This  included  desk 
research  (covering,  but  not  limited  to,  data  from  the  MEF),  targeted  interviews  with 
stakeholders, including European Commission officials, customs administration officials and 
economic operators, and a survey of national customs authorities. 

2.1. Effectiveness 

The Customs programme’s support for the common components of the EES provides a key 
contribution towards implementing EU customs policy and advancing the UCC systems ahead 
of the 2025 deployment deadline. This is corroborated by the interim evaluation. Particularly 
noteworthy has been the progress in the ongoing roll-out of ICS2, which is significant from a 
budgetary  point  of  view  and  has  already  contributed  to  the  Union’s  security  and  safety  by 
seizing more risky goods. This complex, centrally developed project was highly technical and 
not  without  its  challenges,  but  its  success  bodes  well  for  future  initiatives  led  by  the 
Commission. The interim evaluation reaffirms the importance of programme support for EES, 
but also notes that, for some newer systems, such as PoUS and EU CCI, Member States are 
facing delays in developing national components and connecting them to the central system. 

Collaborative activities funded by the programme continue to deliver strong results. These 
activities are the human dimension of the programme. They support networking, ownership of 
challenges  and  learning  opportunities.  They  also  ensure  consistent  training  across  the  EU, 
facilitate the exchange of best  practices and promote common solutions. Expert teams have 
proven  effective  in  providing  opportunities  for  collaboration  between  the  Commission  and 
national  customs  authorities,  serving  as  platforms  for  pooling  expertise  to  perform  tasks  in 
specific domains or carry out operational activities. 

Launched in 2021, the new LMS has successfully replaced the fragmented approach followed 
previously  when  training  activities  were  spread  across  several  websites.  Users  appreciate 
finding all activities on one portal and the portal has features that are generally highly regarded. 
This has increased the likelihood of national officials taking the courses available. Sufficient 
data  on  trends  in  usage  is  now  available,  making  it  possible  to  consider  setting  targets  and 
consider  ways  of  developing  the  audience  further.  This  includes  addressing  the  challenges 
Member States face in increasing use of the functionality, by allowing them to link their own 
learning management systems directly to the LMS. 

The current iteration of the programme introduced innovation as a specific objective and action 
type, aiming to generate new activities in response to emerging challenges. Initial expectations 
have not yet been met. This has been attributed to the time taken to embed this new specific 

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objective and to define the concept of innovation and eligible activities. Dedicated leadership 
to drive forward activities in this area or to create synergies with other EU support in this field 
might have led to greater progress. 

2.2. Efficiency 

The interim evaluation employed a counterfactual approach to assess the cost-effectiveness of 
three of the EES considered: ICS2, PoUS and EU CCI. It was found that the approach taken to 
develop these systems was more cost-effective than potential alternatives, which would have 
demanded more financial and human resources at national level. The Commission’s leadership 
was well received by national customs administrations and industry stakeholders, with most 
inefficiencies arising from decentralised aspects of the EES. Industry feedback highlighted the 
importance of business-friendly communication to facilitate timely compliance, especially for 
complex  projects.  It  also  highlighted  a  need  for  clear  timeframes  for  systems  deployment, 
which  allow  for  phased  or  staggered  implementation  where  systems  are  complex. While 
controls on ICG had not yet been deployed, the development process was well received by the 
Member States  and  a good practice  involved re-using an existing  module developed by the 
Directorate-General for Health and Food Safety (DG SANTE).  

The  interim  evaluation  indicated  that  the  collaborative  activities  are  valued  and  beneficial 
overall. However, Member States are not as proactively engaged in expert teams as they could 
be. They have capacity challenges that hinder active participation, and administrative burdens 
are particularly pronounced for those in leadership roles. This leads to Member States being 
reluctant to take on these roles. 

The  interim  evaluation  drew  extensively  on  the  indicators  laid  down  in  Annex  II  to  the 
Programme  Regulation  (EU)  2021/444  and  in  the  supplementing  delegated  act2  and  related 
staff working document on the MEF3. The new framework applied since 2021 has significantly 
improved compared to its predecessor. Yet, it remains sub-optimal in terms of which data are 
collected  and  how  they  are  then  used.  In  part,  this  is  because  the  MEF  remains  somewhat 
cumbersome, with around 40 nuanced indicators, despite the last wave of streamlining. 

2.3. Coherence 

A novelty under the current programming period was the introduction (under a different legal 
basis) of the Customs Control Equipment Instrument (CCEI)4. The instrument supports the 
purchase of customs equipment to ensure customs authorities can perform more sophisticated 
and consistent customs controls. The Customs programme complements this new instrument 
by improving the knowledge of officials on available technologies and how best to use them. 
It does this by providing a forum for exchanging knowledge and sharing good practices. The 
increasing  number  of  tasks  performed  by  customs  authorities  in  the  course  of  the  customs 
control (mainly linked to prohibitions and restrictions on the movement of goods across the 

2 Commission Delegated Regulation (EU) 2022/2565 supplementing Regulation (EU) 2021/444 of the European 
Parliament and of the Council with provisions on the establishment of a monitoring and evaluation framework. 
3 SWD(2023) 24 final 
4 Regulation (EU) 2021/1077 of the European Parliament and of the Council establishing, as part of the 
Integrated Border Management Fund, the instrument for financial support for customs control equipment. 

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external border) make it ever more crucial for the programme support to be coherent with other 
instruments, including but not limited to the sister programme managed by DG TAXUD for 
delivering  tax  policy  (the  Fiscalis  programme5)  and  the  CCEI.  The  interim  evaluation 
provides evidence of the programme having clear synergies and complementarities with both 
the  Fiscalis  programme  and  the  CCEI.  One  example  is  the  LMS  portal,  for  which  there  is 
improved coherence with Fiscalis as a result of the new common portal. The LMS portal is also 
used  for  training  on  customs  control  equipment.  Formal  and  informal  mechanisms  ensure 
coherence between  the  Customs  and Fiscalis programmes  and support  cooperation between 
them. This  includes  aligned programme  management approaches/principles and procedures, 
e.g. harmonised operational guides, common templates, and joint meetings of the Customs and 
Fiscalis national programme coordinators. 

As  with  the  previous  programme,  the  current  programme’s  coherence  with  other  relevant 
instruments has been ensured, but this requires continuous proactive efforts and should not be 
taken for granted. In particular, given the specific objective of fostering innovation in the area 
of  customs  policy,  synergies  with  Horizon  Europe6  could  be  better  exploited. Possible 
synergies could also be exploited using the Technical Support Instrument7. 

2.4. EU added value 

The  counterfactual  analyses  used  in  the  interim  evaluation  allows  an  evidence-based 
demonstration  of  the  added  value  of  the  EU’s  role  in  helping  to  achieve  the  programme 
objectives more effectively and efficiently. For ICS2, the evidence shows that the centralised 
approach is two to four times more cost-effective than the alternative. Feedback collected for 
PoUS confirms that, under both counterfactual scenarios tested, the overall financial burden on 
national budgets would be significantly higher than under the hybrid system, i.e. a model with 
a central system, developed by the Commission, and optional connections (for phases 1 and 2) 
and a mandatory connection (for phase 2) to be implemented by the Member States. It involves 
notable  increases  in  both  investment  costs  and  costs  related  to  regular  operations.  The 
implementation of a new trans-European system such as the EU CCI system also allows cost 
savings  for  Member  States.  On  the  other  hand,  without  shared  specifications  and  central 
components, each Member State would incur considerable costs due to the need to maintain 
fragmented  national  procedures. This  means  reduced  overall  competitiveness  and  increased 
administrative burdens and costs for national customs authorities. Another contribution made 
by the EU CCI is that the system’s common specifications were widely used by Member States 
to  both  build  and  upgrade  national  import  systems,  resulting  in  cost  savings  and  efficiency 
gains, while ensuring regulatory compliance at EU level. 

The interim evaluation confirms that the Customs programme achieves efficiencies of scale in 
IT  capacity  building.  Collaborative  activities  provide  opportunities  for  cooperation, 
communication  and  networking  across  the  EU.  These  could  not  be  achieved  without  the 

5 Regulation (EU) 2021/847 of the European Parliament and of the Council establishing the ‘Fiscalis’ 
programme for cooperation in the field of taxation. 
6 Regulation (EU) 2021/695 of the European Parliament and of the Council establishing Horizon Europe. 
7 See: https://commission.europa.eu/funding-tenders/find-funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en. 

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involvement of the EU and are essential for ensuring the harmonised implementation of EU 
customs policy. 

The  stakeholders  consulted  found  it  difficult  to  imagine  alternative  ways  of  operating  and 
cooperating, especially as regards managing the EU-supported digital systems and the role they 
play in the Customs Union. Without the Customs programme, cooperation  and data sharing 
between participating countries would have to be based either on informal and unstructured 
relations  between  Member  States  and  with  the  Commission,  or  on  formal  channels  and 
reciprocity agreements. This would be significantly more complex and costly to implement. 

Implementing common components of digital systems at EU level  contributes to mitigating 
various challenges, namely unequal capacity of national customs administrations in terms of 
IT  infrastructure  and  equipment  availability;  human  resources  and  operational  processes; 
uneven interpretation and implementation of relevant legislation by customs administrations; 
and geographic, administrative, legal and strategic obstacles to cooperation. 

2.5. Relevance 

Successive evaluations have reaffirmed that EU support is relevant for customs cooperation. 
This finding remains broadly valid. The current programme was launched at the beginning of 
2021 during one crisis, namely the COVID-19 pandemic. Then came the escalation of another 
crisis, Russia’s war of aggression against Ukraine in February 2022. Since then, other external 
events  have  destabilised  the  geopolitical  situation,  impacting  the  work  of  EU  customs 
authorities. While much of the programme support is relatively fixed (since it is dedicated to 
EESs), it has also responded to unexpected emerging needs. Programme support was used to 
prepare guidelines for translating unprecedented restrictive measures (sanctions), imposed on 
Russia and Belarus, into processes which customs officials (who would not typically deal with 
sanctions  of  this  scale  or  scope)  can  effectively  implement  in  their  day-to-day  work.  The 
programme  also  rapidly  included  Ukraine  as  a  programme  beneficiary.  Furthermore,  the 
Customs  Eastern  and  South-Eastern  Land  Border  Expert Team  (CELBET),  financed  by  the 
Customs programme, and other programme actions, such as targeted working visits, provided 
assistance for Member States bordering Ukraine to keep Ukraine’s trade routes open under the 
‘Solidarity lanes’ initiative8. 

The challenges posed by e-commerce were identified before this programme’s launch and have 
continued  to  increase  since. These  are  considered  to  require  a  more  fundamental  change  in 
customs policy, as proposed under the EU Customs Reform9. As such, the continued relevance 
of the programme may need to be re-assessed following the adoption of the reform, potentially 
as part of the final evaluation of the programme. 

8 See: https://commission.europa.eu/topics/eu-solidarity-ukraine/eu-assistance-ukraine/eu-ukraine-solidarity-
lanes_en. 
9 COM(2023) 257 final 

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3. Lessons learned 

The  section  below  identifies  a  set  of  possible  lessons  learned  and  (where  relevant)  makes 
suggestions  for  improvements  in  the  coming  years  for  the  programme’s  ongoing 
implementation. 

Lesson 1 – on EU support for common components of digital systems 

The case studies  of  four  major EES  show  how  EU investment  in  common components  has 
delivered  tangible  benefits  for  the  functioning  of  the  Customs  Union. Achieving  the  UCC 
ambitions within the planned timeline would be unrealistic without EU assistance. The interim 
evaluation  showed  that  alternative  scenarios  for  the  systems  studied  would  have  been  less 
effective and efficient. While findings from the cases cannot be extrapolated mechanically to 
the more than 50 EES, the systems chosen were illustrative of different types of challenges. To 
that extent, the lessons learned may well be more widely applicable in similar circumstances. 
The  Commission  has  shown,  for  example,  that  it  can  successfully  deliver  large,  complex 
systems like ICS2. However, phased implementation, close cooperation with the private sector 
and timely communication with stakeholders emerged as important considerations. At the same 
time, the successful execution of the UCC work programme also depends on national projects, 
which are monitored by the Commission but remain under Member State control. Given the 
parallel demands on Member States and economic operators, which strain resources, there is a 
continuing  need  for  programme  support  in  this  area.  Furthermore,  the  interim  evaluation 
identifies  scope  to  further  improve  the  dialogue  with  traders  by  providing  more  business-
friendly technical and operational guidance to ease the burden of introducing or transitioning 
to new systems. 

Lesson 2 – on the collaborative actions 

Collaborative  actions  play  a  vital  role,  supporting  the  human  element  of  the  Customs 
programme.  While  many  actions  function  effectively,  those  with  limited  Commission 
involvement have sometimes faced challenges related to ownership and leadership by Member 
States. It would therefore be appropriate to revisit the current approach to the governance of 
these actions. 

In  particular,  this  could  be  supported  through  awareness-raising  so  that  senior  management 
within  national  administrations  better  understand  the  importance  of  these  activities,  their 
potential and the prestige that could be associated with leading them (which is where the main 
issue lies). If this model cannot be adopted within the current programming period, it could be 
considered within the proposed Customs Reform. 

Lesson 3 – on the Learning and Management System 

While the LMS undoubtedly improves on what came before, some functionalities of the LMS 
could  be  fine-tuned  and  links  to  Member  State  learning  management  systems  could  be 
improved. This could improve efficiency and maximise the return on investment in training 
resources,  optimising  the  benefits  of  the  system.  There  are  also  opportunities  for  setting 

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benchmarks and targets now that the system has reached maturity and for low-cost initiatives 
to broaden the private sector audience. 

Lesson 4 – on innovation 

The first few years of the programme were used to establish a clearer understanding of what is 
to be understood as innovation in the area of customs policy (as opposed to innovation within 
IT  development  in  particular). Appointing  a  dedicated  innovation  ‘champion’  could  lead  to 
faster progress going forward. The innovation champion would be responsible for promoting 
an  innovation-focused  culture,  leading  relevant  working  groups  and  collaborating  with 
colleagues across DG TAXUD, the Directorate-General for Migration and Home Affairs (DG 
HOME) – the service in charge of the policy aspects of the research and innovation activities 
for civil security, including border management and customs – as well as the Joint Research 
Centre (JRC) and the Directorate-General for Research and Innovation (DG RTD). They would 
also engage with external partners, including the TAXUD Trade Contact Group, relevant EU-
funded customs-related research projects under Horizon Europe and international organisations 
like  the  World  Customs  Organization  (WCO),  to  provide  strategic  direction  and  cohesive 
leadership for all stakeholders. 

Lesson 5 – on project management 

Given  the  recent  challenges  related  to  geopolitical  developments,  evolution  of  international 
trade and ongoing digitalisation, it is necessary to maintain the scope for flexible and coherent 
support. Since much of the programme budget is allocated to large-scale IT projects, looking 
further ahead, examples of using the most agile approaches to project management could be 
built upon to further strengthen the flexibility of support in the face of fast-changing needs. 

Lesson 6 – on the Monitoring and Evaluation Framework 

The interim  evaluation  confirms  that the  current  framework is  simpler than its predecessor. 
However,  it  still  prioritises  a  comprehensive  set  of  indicators  over  a  more  manageable 
streamlined  version.  To  make  the  MEF  more  effective  in  the  future,  further  reducing  the 
number of indicators and the frequency of reporting should be seriously considered. For EES-
related indicators, providing narratives that align with programme objectives would yield more 
meaningful insights than just numerical data. Some sub-indicators may have limited value and 
could  be  removed,  while  others  might  benefit  from  periodic  evaluations  instead  of  annual 
surveys. Additionally, indicators related to collaborative activities could be better aligned with 
the  programme’s  specific  objectives  and  the  types  of  activities  outlined  in  the  Customs 
programme Regulation or work programme. Innovation could be illustrated through specific 
case studies rather than survey opinions. 

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