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: 2026-07-13
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU customs procedure, activity report, customs formalities, digital transformation, digitisation, electronic commerce, electronic government, information system, innovation, technical specification

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.7.2026  COM(2026) 362 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(2026) 180 final}  
 
 
Table of Contents 

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

2. Executive summary ......................................................................................................................... 4 

3. Content of the Report ...................................................................................................................... 5 

4. Responsibilities for the UCC digital implementation ..................................................................... 6 

5. Global overview of progress with the UCC electronic systems ...................................................... 7 

5.1  PROJECTS COMPLETED BEFORE 2025 .......................................................................... 7 
5.2  PROJECTS PROGRESS IN 2025 ......................................................................................... 7 
5.3  RISKS AND MITIGATING MEASURES ......................................................................... 17 

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1. 

INTRODUCTION 

This  document  constitutes  the  annual  progress  report  on  the  digital  implementation  of  the  Union 
Customs  Code1  (UCC)  for  the  year  2025  and  is  the  seventh  and  last  report  established  by  the 
Commission in accordance with Article 278(a) of the UCC on the progress in developing the electronic 
systems2.  

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 the digital 
transition and implementation of the UCC. During the transitional period, the existing electronic and 
paper-based systems could 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. The 
IRTA  defines  the  technical  arrangements  for  each  of  the  systems  in  terms  of  components, 
responsibilities, data access and technical 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). The report covers the progress accomplished over the years 
to achieve a fully digital customs in the European Union in 2025, marking the last year of the 
implementation of the UCC.  

Whilst the UCC establishes the legal basis for a fully digital, harmonised customs framework across the 
European  Union  and  its  external  borders,  its  full  and  uniform  implementation  across  all  customs 
domains  and across  all Member  States  represents  a  pre-requisite  of  the well-functioning  Customs 
Union  and  provides  the  foundation  for  the  next  phase  of  the  Customs  Reform.  It  is  therefore 
essential that all Member States complete their share of the implementation of the current UCC to ensure 
that economic operators and traders get the full benefit before moving into the EU Customs Reform. 
The Commission adopted on 17 May 2023 a proposal for a comprehensive reform of the Customs Union, 

1 Regulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union 
Customs Code, OJ L 269, 10.10.2013, p. 1–101. 
2 Report from the Commission to the European Parliament and the Council:  
2019: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52019SC0434; 
2020: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0339; 
2021: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52021SC0382; 
2022: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023SC0029; 
2023: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2024:395:FIN; 
2024: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52025DC0579. 
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. 

the  European  Parliament  and  of 

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including a new UCC, which marks a significant transformation of the EU customs framework.6 On 26 
March 2026, the European Parliament and the Council reached a political agreement in trilogue on the 
Commission’s proposal for the most ambitious reform of EU customs rules since 1968. The draft text is 
now expected to be reviewed by legal and linguistic experts and then approved by the Council and the 
European Parliament for publication in the Official Journal of the European Union by November 2026  

The Customs Reform is structured around three main pillars:  

1)  smarter risk management and customs controls through the creation of an EU Customs 
Authority and EU Customs Data Hub: it will digitalise and simplify procedures, reduce costs 
and red tape, promote a more uniform approach at the external border, and better protect the 
Single Market through stronger, data-driven risk management and enforcement;  

2)  a  stronger  parthnership  with  business:  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 modern framework for e-commerce: 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. 

Customs  play  a  vital  role  in  maintaining  the  safety  of  the  Single  Market  and  its  citizens.  With  the 
Customs  Reform,  European customs will  be equipped  to adapt to the fast-changing  landscape  of 
international trade. In this context, the reform introduces several targeted measures to address the rapid 
growth in e-commerce. Meanwhile,  as  a  temporary  solution,  the  Commission  and  Member  States 
agreed in November 2025, to remove the duty exemption that had been in place so far for parcels valued 
below €150  and  to introduce  a €3 duty on  these parcels,  starting  1st July  2026. The  removal  of  the 
threshold  aims  to  level  the  playing  field  between  e-commerce  sales  and  traditional  retail,  restoring 
fairness  while maintaining choice  for  consumers.  Furthermore,  with  the  agreement  in  trilogue  of  26 
March, a handling fee on low value goods imported into the EU is being introduced, to compensate for 
the increasing costs for customs authorities. The fee will be introduced no later than 1 November 2026. 
Once the EU Customs Data Hub is fully operational, normal customs duties will apply.  

It should be noted that, at this stage with all the political focus on the Customs Reform and e-commerce, 
there is a risk that the delays in the digital implementation of the UCC are overlooked as simple 
technical  delays,  while  the  systemic  consequences  of  these  delays  could  be  serious  for  the  EU. 
Malfunctioning or only partially deployed export/import systems could lead to congestion at major exit 
or entry points, creating protests, supervision failures and supply chain delays. Moreover, misaligned 
data could lead to the release of high-risk goods (dual-use, sanctioned goods, undervalued imports) to 
circulate before full risk analysis, including by limiting the Commission’s capacity to detect issues, and 
devise a reaction strategy in time. 

The timely completion of the UCC digital programme is a strong priority in order to materialise 
the  benefits  introduced  for  traders  in  the  UCC,  for  instance  through  further  harmonisation  of 
processes, digalisation by design, underpinned by an internationally aligned and integrated EU Customs 
Data Model,  and far-reaching  simplifications for  trusted  traders.  The  completion  of the  UCC  digital 
implementation is in that sense crucial to support and feed into the Customs Reform and the development 
of the future EU Customs Data Hub, as to ensure that the significant simplifications promised by the 
Customs Reform would be built on a strong base of harmonisation and digitalisation.  

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). 

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2.  EXECUTIVE SUMMARY 

The implementation of the UCC has reached its final and decisive year. Since the adoption of the 
UCC Work Programme in 2014, the collective effort of the Commission, Member States and economic 
operators has been instrumental in progressing towards a fully digital customs environment.  By early 
2025, 70% of the digital work programme had been completed. Throughout 2025, the implementation 
process  has  been  marked  by  significant  progress  and  several  major  milestones  across  both  trans-
European and national systems have been achieved, reflected in a steady shift towards a largely “green” 
implementation  landscape  across  Member  States.  This  report  demonstrates  that  the  UCC  digital 
implementation has been almost completed by the end of 2025, as visually represented in Figure 1. 
The projects marked in green are finished; the projects marked in orange indicate the areas where less 
than 90% of the Member States are ready, and the ones marked in yellow indicate where between 90% 
and 99% of the Member States are ready.   

Figure 1 – Planning Overview  

To this day, the Union Customs Code (UCC) digital implementation has been mostly completed, 
with  the  substantial majority  of  UCC  systems  now  deployed  and  Member  States  working in  a  fully 
integrated UCC digital environment. 96% of all the national systems and 100% of all the centralised 
trans-European systems are deployed by the end of 2025. The remaining challenges are limited, 
and  country  and  project specific.  They no longer  concern the  overall  architecture  of the  UCC  but 
relate  to  residual  delays  or  transitional  issues  in  a  small  number  of  Member  States.  The  project  for 
Centralised Clearance at Import is the most critical one. Other projects requiring specific follow up in 
some Member States are: the deployment of the national system on Temporary Storage, and the National 
Import System, as well as the deployment of the national component for Guarantee management, the 
Automated Export System (non-core), the New Computerised Transit System – Phase 5 (non-core) and 
Phase 6 (under derogation till 31 May 2026) and the Proof of Union Status – Phase 2 (under derogation 
till 1 March 2027). 

4 

 
 
 
 
 
 
They  remaining  activities  concern  mainly  the  completion  of  final  upgrades  by  some  Member 
States, testing or pre-deployment system validations, transition of economic operators of recently 
deployed  systems,  and  interconnections  between  systems.  In  this  context,  the  Commission  has 
adopted three derogation decisions in 2025 to provide legal certainty and business continuity, primarily 
to support the transition of economic operators for the submission of EU border security requirements 
in  combination  with  transit  (ICS2  -  Release  3  and  NCTS  –  Phase  6)  and  for  the  submission  of  the 
customs goods manifest as a proof of union status (PoUS – Phase 2). They remain limited in scope and 
timeline extension, and detailed monitoring mechanisms have been put in place to closely follow up on 
progress until full completion. 

In  addition,  the  Commission  decided  in  2025  to  pursue  legal  actions  against  fourteen  Member 
States in total for failing to meet their obligations under the UCC and its implementing acts. These 
concern two main types of non-compliance: the first relates to the deployment of customs digital systems 
(i.e.  Temporary  Storage  for  Air  transport,  National  Import  System,    the  Automated  Export  System, 
including ensuring operational readiness and migration of economic operators’ systems, affecting ten 
Member  States  in  total  and  the  second  concerns  the  transmission  of  the  full  set  of  57  standardised 
customs  data  elements in  the  required  format  via  the Surveillance system,  which  is  essential  for the 
collection, monitoring, and risk management of EU customs data, affecting thirteen Member States in 
total.  

The Commission’s activities in view of a combination of planning, coordination, support to specific 
Member States, monitoring and enforcement has proven effective.  

By the end of 2025, most of the concerned Member States managed to address the delays appropriately. 
With a limited set of residual deployments extending into 2026 and, in a few specific cases, into 2027, 
the remaining gaps are clearly identified, time-bound and under close follow-up. They are either covered 
by  derogation  decisions  and/or  subject  to  reinforced  monitoring  and,  where  necessary,  subject  to 
enhanced enforcement measures. At the same time, however, the difficulties faced by Member States in 
implementing  critical  projects,  most  notably  national  systems  and  components  have  underlined  the 
fragility of a joint adventure of a complex digital transformation, engaging the Commission, the 
27 Member States and thousands of economic operators towards a commonly agreed scope and 
completion date.  It requires integration of new systems to existing ones and interoperability between 
different domains such as export followed by transit. The complexity becomes even more critical when 
requiring  interoperability  with  other  digital  non-customs  transformation  programmes  such  as  the 
European Maritime Single Window environment.   

Looking back at the overall experiences in the digital transformation and implementation of the 
UCC Work Programme over a period of 10 years, there was a clear pattern identified. Member 
States highlighted that the most significant difficulties they encountered for achieving a successful 
completion  were:  (1)  governance  structures  enabling  timely  decision-making,  (2)  sustaining  the 
engagement of stakeholders, and (3) defining and maintaining a clear scope.  

Overall, the  end-2025  deadline  marked  the  formal  closure  of  the  UCC  digital implementation. 
With  the  core  digital  framework  under  the  UCC  being  now  operational  at  EU  level,  a  major 
achievement has been reported which will reinforce the control of the EU external borders and of 
trade flows at a time of major geopolitical and geoeconomic turbulences. The Customs Union is 
now in a position to move from transition and delivery to consolidation and stabilisation, with the 
UCC providing a solid and credible foundation for the forthcoming Customs Reform. 

3.  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:  

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 

5 

 
 
 
 
 
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 4). Furthermore, 
it contains the global overview of the different projects and their progress (section 5) and also highlights 
the risks and the mitigating measures (section 6).  

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  by  the  end  of  June  2025.  This  work  was  supported  by  an  external 
contractor. The latest updates from the Member States were mainly covered in the report. 

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), and a further update was requested towards the end of 2025. 

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;  

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

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.  

4.  RESPONSIBILITIES FOR THE UCC DIGITAL IMPLEMENTATION 

Dependent on the 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 of the systems related to the UCC digital 
implementation. 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  in  combination  with  national  components, 
whilst the national systems only consist of national components.  

the  European  Parliament  and  of 

of 
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  278(a)  of  the  Union  Customs  Code,  on  progress  in  developing  the  electronic  systems 
provided for under the Code, SWD(2026) 180 final. 

the  Council,  OJ  L  2025/512,  20.3.2025,  p.  1–45,  https://eur-

6 

 
 
 
 
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. 

5.  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). 

5.1  PROJECTS COMPLETED BEFORE 2025 

The Commission has delivered all the digital projects under its responsibility. The Member States have 
further progressed on the systems and components. As defined in the previous reports, this has led to 
the successful deployment of the following twelve new systems or upgrades:  

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

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

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

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

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

UCC Surveillance 3 – SURV3 (upgrade): Deployed in 20189;  

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. 

UCC Guarantie Management – component 1 – GUM C1 deployed in 2024 

UCC Proof of Union Status phase 1– PoUS deployed in 2024 

UCC New Computerised Transit System phase 5– NCTS P5 deployed in 2024 

5.2  PROJECTS PROGRESS IN 2025 

This  report  aims  to  highlight  the  accomplishments,  progress  and  challenges  encountered  in  the 
implementation of the ongoing projects in 2025 by the Commission and the Member States.  

9 However, challenges remain concerning the data transmission by Member States. 

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5.2.1 Trans-European projects 

The  trans-European  projects  follow  a  particular  structure,  which  may  entail  a  central  system  or  a 
combination  of  central  and  national  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. For more details, please refer to section 3 and 4 of the Commission Staff 
Working Document accompanying this report. 

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.  Guarantee 
management  is  done  on  two  levels.  In  essence,  the  so-called  GUM  central  component 
(Component  1)  is  used  for  the  management  of  authorizations  for  comprehensive  guarantees 
(including the registration of the reference amount, split per customs procedure and per Member 
State concerned), whilst the registration and management of comprehensive guarantees and the 
monitoring  of  the  related  reference  amounts  is  done  on  national  level  in  a  UCC-compliant 
guarantee management component (Component 2) developed nationally, which also includes the 
registration and management of other types of guarantees.  

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  were  expected  to 
establish operational connections with the central component between 11 March 2024 and 2 June 
2025. Ten Member States ensured the timely deployment of their national component.  

By the end of 2025, 21 Member States deployed GUM – C2, meaning a completion rate of 78%. 
The remaining 6 Member States (DK, FR, GR, HR, CY and IT) plan to be ready early 2026.10 

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. Whilst Releases 1 and 2 are fully implemented as part of the 
ICS2 project, work continued for Release 3. Economic operators are to use the ICS2 – Release 3 
in  three  steps:  maritime  and  inland  waterways  carriers  by  4  December  2024  (step  1), 
maritime and inland waterways traffic by 1 April 2025 (step 2) and road and rail carriers, 
including  goods  in  postal  consignments  transported  by  these  means  of  transport,  by  1 
September 2025 (step 3).  

As it concerns a central system, conformance testing activities for this release are exclusively 
carried out by economic operators. Mid 2025, there were worrying signs by some Member States 
as regards the readiness of the economic operators for step 3 of the ICS2 - Release 3.  

The need to integrate ICS2 with the smart border systems, the large number of economic operators 
that  have  difficulties  obtaining  a  registration  from  a  Member  State  for  connection  to  the  IT 
systems, the complexity of the rollout of the ICS2 system and the  resources necessary for the 
interoperability  with  national  systems,  and  interfaces,  for  both  Member  States  and  economic 
operators, as well as the specific and complex nature of the transportation mechanisms affected 
by this rollout, which includes multi-modal forms, have been proven to disproportionately affect 
some Member States and economic operators more than others. To ensure legal certainty, business 
continuity and a smooth transition to fulfilling the requirements of ICS2 Release 3, step 3, the 
Commission granted a derogation requested by certain Member States and the United Kingdom 

10 Based on the latest National Project Planning-information, HR has deployed their national GUM components on 1 March 2026, others (IT, 
CY, DK, FR) would follow in the period till 1 July 2026, and GR would deploy in December 2026. 

8 

 
 
 
 
in  respect  of  Northern  Ireland  pursuant  to  Regulation  (EU)  No  952/2013  of  the  European 
Parliament and of the Council for Release 3 of the Import Control System 2 (IE, GR, ES, FR, IT, 
LT, HU, FI and the UK in respect of XI) until 31 December 2025.  

By the end of 2025, the ICS2 is used in all Members States by the given deadline, meaning a 
completion rate of 100%, marking another major milestone accomplished in 2025.  

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 
2023 and the conformance testing activities were concluded in 2025. The Commission ensured 
the central system was operational on 15 August 2025, in line with the deadline referred to in the 
UCC WP. A few Member States decided to  use their national system  and to connect it  to the 
central one (hybrid mode). The Commission’s and Member States’ customs departments ensured 
a timely delivery of the project by the legal deadline. Member States’ maritime departments were 
supposed to implement the interconnection between the PoUS and the European Maritime Single 
Window environment (EMSWe) to allow facilitation to traders and enable them to submit all data 
(including customs manifest data) through a new single maritime portal at national level. To this 
end, both deployment dates in the EU legislation were aligned.  

However, as a result of the late implementation of the EMSWe, the maritime transporters were to 
face important hurdles if they were to use the PoUS without having the national maritime single 
windows under EMSWe in place.  The Commission therefore granted a derogation pursuant to 
Regulation (EU)  No  952/2013  of the  European  Parliament  and  of the  Council for  the  PoUS  - 
Phase 2 to certain Member States (BE, BG, CY, DE, DK, EE, IE, FI, FR, HR, IT, LV, NL, PL, 
PT, SE and SI) until 1 March 2027.  

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  and some  Member  States  have  opted  to implement  both  phases simultaneously to 
streamline national efforts. 

Progress: For CCI – Phase 1, the system entered its first phase implementation on 1 July 2024 
with the readiness of the common components and some of the national components. By 2 June 
2025, the system was available for use by European businesses in 10 Members States (BG, EE, 
ES, LU, LT, LV, PL, RO, HR, and IT). By October 2025, 2 more MS joined the CCI system (BE 
and SE).  

As illustrated in Figure 2, by the end of 2025, a total of 17 Member States (BE, BG, HR, CY, EE, 
FI, IE, IT, LV, LT, LU, MT, PL, RO, SI, ES, SE) had deployed their CCI P1 system, meaning a 

9 

 
 
 
completion rate of 63%. The remaining 10 Member States (AT, CZ, DE, DK, FR, GR, HU, NL, 
PT, SK) are scheduled for deployment throughout 202611. 

Figure 2: CCI P1 Member States in operations (situation on 31 December 2025) 

As regards to CCI – Phase 2, the Commission finalised the technical specifications in 2022. To 
assist  the  Member  States  and  traders  in  implementing  all  CCI  scenarios  and  processes,  the 
Commission  developed  a  full  scope  technical  specifications  package  consolidating  the 
specifications for both phases, along with a guide. The assessment mid 2025 showed that whilst 
most Member States  were progressing in the developments, a substantial number of Members 
States did not meet the final deployment milestone on 2 June 2025.  

By the end of 2025, as illustrated in Figure 3, there was on overall level of full CCI completion 
of  44%  (12  MS).  Based  on  the  updated  NPPs,  the  majority  of  the  remaining  Member  States 
envisage completing their conformance test activities in the first quarters of 2026 and plan the 
deploy the CCI full scope subsequently, with DE, DK, SK, GR and CZ to come in the first half 
of 202612 and AT, FR, NL, PT and HU in the second half.  

The Commission will continue with its quarterly monitoring programme till CCI is completed. 

11 SK has deployed on 14/02/2026 and DK on 19 March 2026.  
12 SK has deployed the full CCI system (Phase 1 and 2) on 14 February 2026, DK on 19 March 2026 and CZ on 18 May 2026.  

10 

 
 
 
 
 
 
 
Figure 3: CCI P2 Member States in operations (situation on 31 December 2025). 

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:    The  NCTS  -  Phase  5  system  became  operational  on  2  December  2024  and  the 
transitional  measures  were  ended  on  21  January  2025.  All  Member  States  are  currently 
successfully operating in NCTS – Phase 5. Some Member States are still to finalise the non-core 
functionalities. 

The  New  Computerised  Transit  System  (NCTS)  continues  to  evolve  as  part  of  the  wider 
modernisation  of  customs  processes  across  the  EU  and  Common  Transit  Convention  (CTC) 
countries. While all Member States completed the rollout of NCTS Phase 5 on 21 January 2025 
and in total 41 countries apply Union/common transit and NCTS, the attention has now shifted 
to the next phase of NCTS.  

For NCTS – Phase 6 offers two options, and it is up to the Member States to decide which option 
they implement:  

•  Opt-out option means when ENS particulars are not included in the transit declaration, 

and ENS is lodged directly to ICS2; 

•  Opt-in option means when ENS particulars are included in the transit declaration and 
NCTS – Phase 6 is connected to the ICS2 to ensure that ICS2 requirements regarding 
ENS business processes (risk analysis, control recommendations, decisions etc.) are also 
fulfilled.  

The timeline of the NCTS – Phase 6 was synchronised with that of ICS213. In the first half of 
2025, the Member States indicated to be progressing well, though several reported a medium to 
high risk level for the timely deployment by 1 September 2025.  

13 As referred to in the 2023 UCC WP, the transition period from NCTS – Phase 5 to NCTS – Phase 6 needs to occur between 
1 March 2025 and 1 September 2025, during the same period that ICS2 – Release 2 transitions to ICS2 – Release 3, allowing 
for the synchronisation between both systems. 

11 

 
 
 
 
 
 
As  Member  States  did  not  manage  to  properly  address  the  risk  of  delays  throughout  2025,  it 
resulted in a situation of non-readiness of the NCTS – Phase 6 by 1 September 2025. For the 
Member States making use of the opt-out option, the minimal transitional changes were dealt 
with at technical level. For the opt-in option, the delays were having impact on other Member 
States and on the economic operators as they would not be able to benefit from streamlined filing 
of transit and safety and security data. To avoid extra burden on the economic operators (including 
those  of  neighbouring  countries  such  as  Ukraine  and  Türkiye),  the  Commission  granted  a 
derogation  to  six  Member  States  pursuant  to  Regulation  (EU)  No  952/2013  of  the  European 
Parliament and of the Council for the use of Phase 6 of the New Computerised Transit System 
until 1 June 2026. These derogations foresee that rail and road operators may connect to ICS2 
until the end of 2025, and that connection to the transit system (NCTS Phase 6) interfacing with 
ICS2  may  take  place  until  31  May  2026.  This  additional  time  extension  was  justified,  in 
recognition of the more complex development and testing required for this interconnection. The 
derogation entails legal requirements for the Member States to report progress to the Commission.  

By the end of 2025, six MS received a formal derogation (BG, HR, LV, PL, RO, SK) and a total 
of sixteen Member States (AT, BG, CY, CZ, DE, EE, ES, FI, IE, IT, LT, LU, LV, MT, PT, SI) 
deployed the NCTS – Phase 6. Taken into consideration the derogations granted, this means a 
compliance rate of 74%. DK, FR, HU, SE schedule deployment of their system before 1 March 
2026. The remaining seven Member States (BE, GR, HR, NL, PL, RO and SK) intend to deploy 
their system at the latest by 1 June 2026, in line with the derogation extension. 

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 transitional period for economic operators was extended 
till 14 December 2025. However, as stated in the previous report, the full development of the 
national components by Member States was not feasible, as some Member States were not able 
to meet the deadline of 2 December 2024 nor the end of the transitional period of 11 February 
2025 and requested an extension of the transitional measures. In this context, the legal amendment 
to the Implementing Regulation for Technical Arrangements (IRTA), voted on 7 February 2025 
in the Customs Code Committee and adopted on 13 March 2025, included the extension of the 
transitional period till 14 December 2025.   

As illustrated in Figure 4, twelve Member States started operations with core functionalities on 1 
December 2023 and during 2024 and 2025 other Member States joined. However, the situation 
became critical again in the second half of 2025 due to the late deployment of some Member 
States (HU, PT, MT, FR, GR) resulting in leaving a medium to very tight window to the economic 
operators for transitioning to the new AES. In some countries, such as France, this was entailing 
a big risk of long queues of trucks at the exit points of the EU. Through enhanced monitoring and 
support provided by the Commission and the engagement of the Member States and the economic 
operators, the AES went live across the EU on 15 December 2025. This achievement of 100% 
completion  rate  of  the  AES  deployment  with  its  core  functionalities  was  a  major  milestone 
contributing to digital implementation of the UCC. 

Some Member States face further delays with the deployment of the non-core functionalities. 

Regarding the AES – Component 2, most Member States have deployed the component in 2025.            

12 

 
 
 
 
Figure 4: AES Member States entry into operations  

To summarise the status of the trans-European projects listed above, the Commission remained 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 were identified during 2025, particularly for CCI , NCTS - Phase 6, ICS2 Step 3 rail and road, 
PoUS and AES (see section 5.3). By the end of 2025, the system related to the PoUS – Phase 2 project 
was deployed, AES entered into operations with the core functionalities in all Member States and ICS2 
was operational for all modes of transport. Beyond 2025, there is a situation of non-compliance for the 
pending deployments of CCI and AES non-core functionalities in certain Member States.  

5.2.2 National projects 

The  Member  States  were due  to  complete  the  upgrade  of their systems for  the  three  fully  national 
projects14 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 202315.  

14 This timeline excludes the Export Component of the national Special Procedures system, for which the activity and planning 
is interlinked with the AES. 
15 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).   

13 

 
 
 
                 
 
 
 
 
Last year’s report reflected some further delays mainly for the National Import System and the system 
for Temporary Storage. The progress for each national project in 2025 is presented below and illustrated 
in  Figure  5.  For  more  details,  refer  to  section  3  of  the  Commission  Staff  Working  Document 
accompanying this report. 

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 
reports, but substantial progress was made during 2025. During 2025, some Member States were 
still facing delays with deployment of the system for Temporary Storage and/or with the transition 
of their economic operators. As these cases went well beyond the legal deadline, the Commission 
launched an infringement procedure for failing to fully comply with the legal obligation to deploy 
Temporary Storage – Air transport against eight Member States (AT, BE, CY, DK, GR, PT, RO, 
SK). 

At the end of 2025, most of the late Member States did manage to deploy their system. This can 
be summarised as a completion rate of 98%16. As illustrated in Figure 5, for the Notification of 
Arrival and the Presentation Notification, all Member States completed the implementation. For 
the  Temporary  Storage,  three  Member  States  were  facing  further  delays  and  indicated  a 
deployment  date  beyond  2025.  In  the  case  of  AT,  full  implementation  is  envisaged  by  April 
202617, whilst GR and SK plan implementation in 2027. As the Commission cannot accept any 
lateness, the infringements proceedings are continuing. 

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, 
the initial deadline for Member States’ deployment of NIS.  In the first half of 2025, some Member 
States  were  still  facing  delays  with  the  deployment  of  NIS  and/or  with  the  transition  of  their 
economic operators. Therefore, the Commission initiated an infringement procedure in the first 
half  of  2025  for  failing  to  fully  comply  with  the  legal  obligation  to  deploy  NIS  against  eight 
Member States (AT, CZ, CY, DK, GR, FR, PT, RO). During 2025, most Member States (AT, 
CY, DK, MT, PL, SK) took action to address the delays and completed the project in 2025.   

By the end of 2025, all Member States except one deployed the system, meaning a completion 
rate of 96%. In the case of CZ, full deployment is envisaged in Q2 2026. In a few Member States 
certain upgrades are still pending to have a fully UCC and EUCDM compliant implementation. 

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 5, most Member States were due to have SP IMP – Component 
2, meaning a completion rate of 96% with AT and CZ, being the last Member States to deploy 
their system in Q2-3 202618. As for SP EXP – Component 1, most Member States had deployed 
the  system  by  2  December  2024  despite  the  interdependencies  with  the  AES  system.  The 
remaining Member States (AT, FR, GR,  HU, MT and PT) deployed the system by the end of 
2025, meaning a completion rate of 100%, whilst for some Member States the transition of the 
economic operators was still ongoing. 

To summarise, significant efforts were made by Member States in 2025, and the national systems are 
now  operational,  while  only  a  limited  number  of  critical  delays  persist  beyond  2025  bringing  few 
Member States in a situation of non-compliance.   

16 For the implementation of the Temporary Storage related to maritime transport, the completion it 96% and for other modes 
than air or maritime, the completion rate is 89%.   
17 AT deployed the system on 15 April 2026. 
18 CZ deployed the NIS, including SP IMP, on 18 May 2026.  

14 

 
 
 
 
TS 

AN 

PN 
31/12/2022 
 with extension to 31/12/2023[1] 
16/05/2023 
05/07/2023 
10/11/2023 

01/07/2023 

30/06/2023 

01/03/2023 

15/04/2026 
29/11/2023 
10/11/2023 

NIS 

SP IMP 

31/12/2022  
with extension to 31/12/2023[2] 
01/09/2026 
14/12/2025 
28/08/2024 
28/08/2024* 
10/11/2023 
10/11/2023 

30/10/2024 

05/12/2023 

 N/A 
06/11/2023 
01/10/2023 
01/03/2023 

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

30/10/2024 
05/12/2023 
06/03/2021 

07/06/2025 
01/07/2021 
01/01/2024 

19/05/2025 

18/05/2026 

06/03/2021 

07/06/2025* 
01/07/2021 
05/09/2023 

19/05/2025 

18/05/2026 
06/03/2021 

07/06/2025 
01/07/2021 
05/09/2023 

31/03/2023 

31/03/2021 

31/12/2022 

31/12/2022 

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 

24/03/2025 
30/06/2023 
01/07/2023 

30/09/2025 

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 

24/03/2025 
01/12/2023 

06/03/2024 

30/11/2024* 

30/11/2024 

31/12/2027 
17/04/2023 
02/04/2024 
23/11/2020 
13/12/2022 
31/10/2023 
10/01/2023 

24/09/2017 

24/03/2025 
01/12/2023 

06/08/2024* 
01/01/2023 

01/11/2023 

05/10/2021 

01/07/2021 

31/12//2023 
02/05/2023 

04/06/2018 

24/03/2025 
01/04/2022 

06/08/2024 
01/01/2023 

01/11/2023 
23/11/2020 

01/7/2021 
31/12/2023 
02/05/2023 

04/06/2018 

24/03/2025 
01/04/2022 

20/04/2025 

20/04/2025* 

20/04/2025* 

01/07/2021 

30/09/2025 

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

30/09/2025 

30/08/2025 

02/12/2025 
01/03/2024 

01/10/2025 

30/08/2025 

15/03/2022 
01/01/2022 

31/03/2027* 

30/09/2025* 

30/09/2025 

30/08/2025 

23/02/2023 
01/01/2022 
11/06/2016 

100% 

100% 

89% 

96% 

93% 

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 
Completion 
rate by 2025 

Legend 

Deployment completed by 31/12/2025 

System not deployed by 31/12/2025 
No dates provided in National Project Plans or deployment not applicable 

Figure 5: National entry/import systems deployment planning 

[1] Until 31/12/2023 for the Member States that were granted a derogation.  
[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 and/or 
the transition of the economic operators is still ongoing. 

15 

 
 
 
  
 
 
 
 
 
 
  
  
  
 
 
5.2.3 Surveillance Data  

In this year’s report, we would like to highlight the remaining challenges concerning the transmission 
of the required data to the Surveillance 3 system (SURV3). The Commission’s Surveillance System 
plays a crucial role in the current geo-economical and geo-political climate. Its primary goal is to create 
a  comprehensive  surveillance  framework  that  monitors  trade  flows,  protects  the  Union’s  financial 
interests,  and  shields its  internal market from  unfair or  irregular practices.  This  system  provides the 
analytical foundation for detecting trade anomalies, preventing fraud, and ensuring fair competition for 
EU industries. As regards the Surveillance 3 system, which serves as the technical backbone of the EU’s 
customs  data  monitoring  architecture  as  it  collects  and  processes  trade  data  from  the  customs 
declarations submitted to the Member States’ customs administrations, the quality and availability of 
data reported through NIS are vital.  

As a substantial number of Member States continued submitting most of their import data using old 
systems. This number decreases to two Member States (AT, FR) when considering export data.  

In the light of the above, the Commission launched in 2025 infringement procedures against thirteen 
Member States (AT, BE, CY, CZ, DK, FR, IE, IT, MT, PT, RO, SI, SK) for failing to fully comply with 
the  SURV3  data  transmission  obligations,  particularly  regarding  data  completeness  and  format 
conformity. 

Whilst 5 Member States (BE, IT, MT, RO, SI) managed to take appropriate action in the course of 2025, 
a total of eight Member States (AT, CY, CZ, DK, FR, IE, PT, SK) was still not submitting the full set 
of import data to SURV3 by the end of 202519. This can be summarised as a completion rate of 70%. 

5.2.4. State of play for enlargement countries 

The  EU  Enlargement  countries  and  other  countries  such  as  the  contracting  parties  to  the  Common 
Transit Convention (CTC) need to take into account of the transition towards the upgraded electronic 
systems of the UCC and the new digital approaches set up by the Customs Reform proposal.  

The Commission does not systematically monitor the progress towards full electronic systems of these 
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 a digital 
strategy and of the digital landscape 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.  

19 FR, DK, SK have been submitting the SURV3 data by end of Q1 2026 and AT, IE, PT and CZ planned to be compliant by Q2 2026. 

16 

 
 
 
 
5.3  RISKS AND MITIGATING MEASURES  

Role sharing has been defined and agreed with all stakeholders from the outset, and should be respected 
throughout the project lifecycles. With the Commission successfully achieving a 100% completion rate 
for the deployment of the  central systems  and components under its responsibility, and the Member 
States having reached a very important degree of implementation as well by the overall 2025 deadline 
for the digital transition, the risks and mitigating measures remain only relevant for a small part of 
the overall digital implementation.  

As explained also in the previous reports, the underlying reasons reported by the Member States for 
the delays are multifaceted and largely recurring. They include shortages of financial and human 
resources,  competing  national  IT  priorities  and  interdependencies  with  other  projects.  In  addition, 
Member  States  have  highlighted  the  inability  of  some  national  IT  infrastructures  to  cope  with  the 
technical  requirements,  capacity  issues  of  contractors,  and  dependencies  with  external  stakeholders. 
Other  contributing  factors  include  extended  conformance  testing,  readiness  levels  of  economic 
operators,  lengthy  public  procurement  procedures,  governance  challenges,  and  the  complexity  of 
integrating new systems into existing IT landscapes.  

The Member States outlined in the survey also the various mitigating actions identified and put in place 
to address the delays encountered. 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 set up actions 
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.  

As regards the national projects, an overall completion rate of 96% has been achieved at the end of 2025 
for the national deployments of the national entry and import systems. Besides the few late Member 
States,  some  other  Member  States  are  still  providing  the  old  and  the  new  system  to  their  economic 
operators and/or are still preparing for some minor  upgrades of their national systems to have 100% 
compliance with the UCC and the EU CDM. The full completion is vital in view of the impact on the 
trans-European systems such as CCI, and on the data submission to the Surveillance system. For the 
Surveillance System to work properly, it is imperative that all Member States transition to the new data 
formats as soon as possible. This will enhance data availability, improve data quality, and strengthen 
the system's ability to monitor trade flows and protect the EU's financial interests.  

The Commission has launched legal enforcement measures in 2025 to Member States facing delays with 
the deployment of their national entry/import systems and/or with the submission of the required data 
to Surveillance and will take further legal actions in 2026 in addition to the continuous support and 
monitoring actions. 

As regards the trans-European decentralised systems with national components, the situation is 
very positive for some projects but critical for some other, as described below.  

The risks reported in the 2024 Report have been well-addressed by the Member States as regards the 
NCTS – Phase 5 deployment, leading to a successful closure of the transition period on 21 January 
2025. Also for the Release 3 of ICS2, a successful closure of the transition of the economic operators 
in road and rail transport took place on 31 December 2025. This is thanks to the efforts of the Member 
States  and  economic  operators,  whilst  the  Commission  continued  as  well  providing  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, 
monitoring 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 and the Europa website.  

17 

 
 
 
Concerning the implementation of the AES, the previous report stated that a few Member States planned 
actual  operations  date  throughout  2025,  beyond  the  initial  deadlines  in  the  UCC  WP20.  Upon  their 
request and to avoid disruptions in trade flows, the Commission extended the period allowing for the 
continuation of the transitional measures for export and exit till 14 December 2025. The Commission 
also  continued  with  the  ‘National  Administration  Coordination  Programme’  to  support  the  Member 
States in developing and deploying their national components. 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. E-learning modules, guidance documents and other information material 
has been made available to the Member States and the economic operators. By 15 December 2025, all 
Member States managed to get their system deployed as regards the core functionalities, with PT, FR 
and GR as last Member States. This demonstrates that the mitigating measures agreed at the end of 2024 
with the change of the transition date and the enhanced monitoring of the progress have revealed to be 
the right way forward. What remains to be done for a few Member States is related to the implementation 
of  the  non-core  functionalities,  which  will  be  further  monitored  throughout  2026  as  to  ensure  the 
economic operators can profit from all the simplifications offered by the UCC, such as the Centralised 
Clearance at Export (CCE).  

For the PoUS – Phase 2 project, its central operation depends on national deployments. The project is 
on schedule from a central customs perspective, however, there are important delays in the availability 
of the National Maritime Single Windows by Member States’ maritime authorities  as set out in the 
communication from the Commission of 22.10.2024 presenting the 2024 update of the Multi-Annual 
Implementation  Plan  for  the  establishment  of  a  European  Maritime  Single  Window  environment 
(C/2024/6300). In line with the derogation decision granted, the Member States are required to report 
on  the  progress  in  providing  the interface  between the  PoUS  system  as referred  to  in  Implementing 
Decision (EU) 2023/2879 and the Maritime National Single Window as provided for in Regulation (EU) 
2019/1239, every four months from 15 August 2025, by the 15th day following the fourth month. The 
Commission has reached out to the customs administrations in the meetings of the Electronic Customs 
Coordination Group (ECCG) and Customs Business Group (CBG) to work in close collaboration with 
the maritime authorities to bring in their expertise for the implementation.  

Further deployments were expected in 2025 for NCTS - Phase 6 as rail and road transport operators 
were expected to comply with the new EU customs security requirements from 1 September 2025. As 
for the reasons explained in section 3.7.2, 4.2 and 4.5.2, this date has been extended to 1 June 2026 for 
NCTS – Phase 6. In line with the derogation decision granted for NCTS – Phase 6, the Member States 
are  required  to  report  monthly  to  the  European  Commission  on  progress  made  in  developing  the 
interconnection provided for in Commission Implementing Decision (EU) 2023/2879. NCTS – Phase 6 
is a major step toward a more harmonised, data-driven transit environment across Europe — but the 
transition  is  uneven.  Some  traders  will  benefit  quickly  from  streamlined  filings,  while  others  must 
continue handling separate transit and security declarations. During the transition, for multimodal or 
multi-country shipments, filing rules may vary between the country of departure, transit, and destination. 
Forward looking, it is expected that by mid 2026 the transition is finished and all Member States will be 
in  NCTS  –  Phase  6.  Meanwhile  the  Member  States  and  economic  operators  should  prepare  for  and 
ensure technical readiness for NCTS – Phase 6 to be well positioned to move goods smoothly through 
the evolving transit landscape. The Commission will monitor very closely the progress. 

As regards the situation of the CCI system, seventeen Member States missed the deployment date for 
CCI – Phase 1 of 1 July 2024 set in the UCC WP21 whilst for CCI – Phase 2,  nineteen Member States 
missed  the  deadline  of  2  June  2025.  The  delays  of  Member  States  combined  with  the  different 
approaches to the incremental system development and deployment for CCI (see Figure 6 below on the 

20  In  the  2023  UCC  WP,  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 with the transition ending on 11/02/2025. 
21 In the 2023 UCC WP, the end of the deployment window is envisaged for 01/07/2024. 

18 

 
 
 
 
Operational Planning) creates a disbalance between the CCI scope implementation in the Member States 
and the requirements from the economic operators from the CCI full implementation. 

Figure 6: Operational Planning per Member States’ National Administrations (NAs) 

The Commission continued 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  States’  questions  on  import  and  the  simplifications  at  import  such  as 
centralised clearance. In addition, CCI Customs Business Group meetings were organised to coordinate 
amongst  others  the  activities  related  to  the  applications  for  a  CCI  authorisation,  as  well  as  regular 
technical meetings on a weekly and bi-weekly basis, and feedback sessions on conformance testing.   
E-learning modules and communication materials were published on the Europa website to support the 
transition to and the implementation of the new systems. The Commission also issued administrative 
letters to the Member States facing delays in the implementation of the CCI project beyond the legal 
deadline. 

Delays experienced by the Member States impact the progress of the trans-European systems in their 
totality which, in turn, have an impact on the activities of the Commission. This requires continuous 
investment  in  resources  devoted  to  conformance  testing,  coordination,  and  support  activities  for  the 
trans-European  projects  as  well  as  extended  maintenance  of  central  components  during  transition 
periods. It also entails further assistance to Member States and and monitoring of progress. 

To sum up, throughout 2025 the Commission has also taken a number of measures, complementary to 
the ones identified and carried out at national level by the Member States.  

Firstly, the Comission has enhanced supervision and monitoring of the UCC digital 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 and with the 
CIO’s of the Member States in the CIO Network. The Member States were encouraged to follow up 
closely  the  progress  for  the  remaining  projects  and  to  take  mitigating  measures  with  a  view  of 
completing the UCC digital programme by the end of 2025. 

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. 

19 

 
 
 
 
 
 
Secondly, the Commission has continued its reinforced 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.  

The Commission also continued coordinating and monitoring programmes for each of the ongoing 
projects related to the trans-European systems ICS2, NCTS, CCI and AES.     

Thirdly,  the  Commission  sought  Member  States’s  input  through  surveys  and    other  means  on  their 
constraints and the needed support to mitigate the risks. The Member States expressed that the bilateral 
meetings at Director level and technical dialogue with DG TAXUD had been highly beneficial. 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 2025 provided this information 
and the outcomes were added to section 1 of the Commission Staff Working Document accompanying 
this report. Furthermore, several Member States shared their national experiences and practices in the 
UCC digital transformation during the high-level Customs Policy Group meeting in July and December 
2025 and the CIO Network meeting in November 2025.  

Fourthly, in accordance with EU’s enforcement strategy, the Commission has also engaged in formal 
correspondence  with  the  Member  States  facing  delays  in  implementing  digital  systems.  The 
Commission  decided  to  pursue  legal  action  against  Member  States  for  failing  to  comply  with  their 
obligations under UCC and the UCC WP. Infringement procedures against 14 Member States (AT, BE, 
CZ, CY, DK, FR, GR, IE, IT, MT, SK, SI, PT, RO)  were opened in May22, June23 and July24 of 2025 for 
failing to meet their obligations to deploy the system for Temporary Storage for Air transport (TS Air), 
the National Import System (NIS), the Automated Export System (AES) and for failing to meet their 
obligations on customs data transmission to the Surveillance system (SURV3). 

Looking back at the overall experiences of the digital transition and implementation of the UCC over a 
period  of  10 years,  the Member  States’ feedback  was  asked during  a dedicated CIO  meeting  on  the 
greatest challenges during the UCC digital implementation.  The responses showed a clear pattern: the 
three  most  significant  difficulties  were,  by  a  considerable  margin,  (1)  governance  structures 
enabling timely decision-making, (2) sustaining the engagement of stakeholders, and (3) defining 

22  Letters  of  formal  notice  (LFN)  were  sent  to  Czechia  (INFR(2025)2017),  Denmark  (INFR(2025)2018),  Greece 
(INFR(2025)2019), Austria (INFR(2025)2015), Romania (INFR(2025)2020), and Slovakia (INFR(2025)2021) for failing to 
deploy the electronic systems for Temporary Storage for air transport and, in some cases, the National Import System, by the 
(INFR(2025)2012),  Cyprus 
31  December  2023  deadline.  Additionally,  Denmark 
(INFR(2025)2010), Austria (INFR(2025)2007), Portugal (INFR(2025)2013), and Romania (INFR(2025)2014) were sent LFN 
for 
SURV3. 
to 
https://ec.europa.eu/commission/presscorner/detail/en/inf_25_982#_blank 

(INFR(2025)2011),  France 

Commission 

complete 

customs 

transmit 

through 

failing 

data 

the 

to 

23  Infringement  procedures  were  initiated  against  Portugal  (INFR(2025)2064)  and  Belgium  (INFR(2025)2016)  for  non-
deployment of the Temporary Storage system for air transport, and in Portugal's case, also for the National Import System. 
Additionally, Letter of formal notice (LFN) was sent to Belgium (INFR(2025)2009) for failing to transmit complete customs 
data to the Commission through the SURV3 system. https://ec.europa.eu/commission/presscorner/detail/en/inf_25_1241 

24 The Commission issued letters of formal notice (LFN) to France (INFR(2025)2060) and Cyprus (INFR(2025)2061) for non-
deployment of the Temporary Storage and National Import System, and in France's case, also for the Automated Export System. 
Furthermore,  Czechia  (INFR(2025)2054),  Ireland  (INFR(2025)2055),  Italy  (INFR(2025)2056),  Malta  (INFR(2025)2057), 
Slovenia (INFR(2025)2059), and Slovakia (INFR(2025)2058) were cited for failing to transmit complete customs data to the 
Commission through the SURV3 system https://ec.europa.eu/commission/presscorner/detail/en/inf_25_1628 

20 

 
 
 
 
 
and maintaining a clear scope. The complexity of national governance arrangements has, in certain 
cases, created a diffusion of responsibility. In large-scale digital transformation programmes such as the 
UCC,  diffuse  accountability  translates  directly  into  delivery  risk.  The  Commission’s  experience  has 
shown that delivery accelerates only when clear high-level ownership, steering and central coordination 
are established at national level, progress has been markedly faster and more predictable. 

21