COMMISSION STAFF WORKING DOCUMENT Accompanying the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for under the Code
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  SWD(2026) 180 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to Article 278a of the Union Customs Code, on progress in developing the electronic systems provided for under the Code {COM(2026) 362 final}  
 
 
Table of Contents 

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

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

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

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

2. Completed Projects ............................................................................................................................. 9 

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

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

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

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

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

2.6 UCC Binding Tariff Information (BTI) .................................................................................. 16 

2.7 UCC Authorised EOs (AEO) Upgrade .................................................................................... 17 

2.8 UCC Information Sheets (INF) for Special Procedures .......................................................... 18 

2.9 UCC Import Control System 2 (ICS2) – Release 1 & 2 .......................................................... 19 

2.10 UCC Guarantee Management (GUM) – Component 1 ......................................................... 20 

2.11 UCC Proof of Union Status (PoUS) – Phase 1 ...................................................................... 21 

2.12 UCC New Computerised Transit System (NCTS) Upgrade – Component 1 ........................ 23 

3. Ongoing Projects ............................................................................................................................... 24 

3.1 UCC Notification of Arrival (AN), Presentation Notification (PN) and Temporary Storage (TS)
 ........................................................................................................................................... 25 

3.2 UCC National Import System (NIS) Upgrade ......................................................................... 47 

3.3 UCC Special Procedures – Component 1 (SP EXP) ............................................................... 53 

3.4 UCC Special Procedures – Component 2 (SP IMP) ................................................................ 58 

3.5 UCC Guarantee Management (GUM) – Component 2 ........................................................... 63 

3.6 UCC Centralised Clearance for Import (CCI) ......................................................................... 68 

3.7 UCC New Computerised Transit System (NCTS) Upgrade – Component 2 .......................... 79 

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

3.9 UCC Import Control System 2 (ICS2) – Release 3 ............................................................... 101 

3.10 UCC Proof of Union Status (PoUS) – Phase 2 .................................................................... 109 

4. Annex 1 – Planning Overview – UCC Work Programme Projects ................................................. 111 

5. Annex 2 – Acronyms, Abbreviations & Key Terms ....................................................................... 112 

6. Annex 3 – Definition of formats, legal base and legal deadline for Surveillance3 ......................... 113 

1 

 
 
 
 
 
 
Table of Figures 
Figure 1: Overview of completed projects .............................................................................................. 9 

Figure 2: Statistical information – REX ................................................................................................ 10 

Figure 3: Statistical information – CDS ................................................................................................ 11 

Figure 4: Statistical information – UUM&DS ...................................................................................... 12 

Figure 5: Statistical information – EORI2 ............................................................................................. 13 

Figure 6 : Statistical information – SURV3 .......................................................................................... 15 

Figure 7: Statistical information – BTI ................................................................................................. 16 

Figure 8: Statistical information – AEO upgrade .................................................................................. 17 

Figure 9: Statistical information – INF for SP ...................................................................................... 18 

Figure 10: Statistical information – ICS2 – Release 1 and 2 ................................................................. 19 

Figure 11: Statistical information – PoUS – Phase 1 ............................................................................ 22 

Figure 12: Overview of projects to be completed by the end of 2025 .................................................. 24 

Figure 13: Project progress and status per milestone – AN .................................................................. 28 

Figure 14: Project progress and status per milestone – PN ................................................................... 31 

Figure 15: Project progress and status per milestone – TS .................................................................... 35 

Figure 16: Actual/Planned dates per milestone – AN – Air transport ................................................... 37 

Figure 17: Actual/Planned dates per milestone – AN – Maritime transport ......................................... 38 

Figure 18: Actual/Planned dates per milestone – PN – Air transport.................................................... 40 

Figure 19: Actual/Planned dates per milestone – PN – Maritime transport .......................................... 41 

Figure 20: Actual/Planned dates per milestone – PN – Other modes of transport ................................ 42 

Figure 21: Actual/Planned dates per milestone – TS – Air transport .................................................... 44 

Figure 22: Actual/Planned dates per milestone – TS – Maritimes transport ......................................... 45 

Figure 23: Actual/Planned dates per milestone – TS – Other modes of transport ................................ 46 

Figure 24: Project progress and status per milestone – NIS Upgrade ................................................... 50 

Figure 25: Actual/Planned dates per milestone – NIS Upgrade ............................................................ 52 

Figure 26: Project progress and status per milestone – SP EXP ........................................................... 55 

Figure 27: Actual/Planned dates per milestone – SP EXP .................................................................... 57 

Figure 28: Project progress and status per milestone – SP IMP ............................................................ 60 

Figure 29: Actual/Planned dates per milestone – SP IMP ..................................................................... 62 

Figure 30: Project progress and status per milestone – GUM-C2 ......................................................... 65 

Figure 31: Actual/Planned dates per milestone – GUM-C2 .................................................................. 67 

Figure 32: Project progress and status per milestone – CCI-P1 ............................................................ 72 

Figure 33: Project progress and status per milestone – CCI-P2 ............................................................ 75 

Figure 34: Actual/Planned dates per milestone – CCI-P1 ..................................................................... 77 

Figure 35: Actual/Planned dates per milestone – CCI-P2 ..................................................................... 78 

Figure 36: NCTS-P6 timeline ................................................................................................................ 79 

2 

 
 
Figure 37: Project progress and status per milestone – NCTS-P6 ........................................................ 83 

Figure 38: Actual/Planned dates per milestone – NCTS-P6 ................................................................. 85 

Figure 39: Updated AES-C1 timeline ................................................................................................... 87 

Figure 40: AES-C1 Member States entry into operations as of September 2025 ................................. 90 

Figure 41: Project progress and status per milestone – AES-C1 ........................................................... 93 

Figure 42: Project progress and status per milestone – AES-C2 ........................................................... 96 

Figure 43: Actual/Planned dates per milestone – AES-C1 .................................................................... 99 

Figure 44: Actual/Planned dates per milestone – AES-C2 .................................................................. 100 

Figure 45: Project progress and status per milestone – ICS2-R3 ........................................................ 105 

Figure 46: Actual/Planned dates per milestone – ICS2-R3 ................................................................. 108 

Figure 47: Actual/Planned dates per milestone – PoUS-P2 ................................................................ 110 

Figure 48: Planning Overview – UCC WP Projects ........................................................................... 111 

Table of Tables  

Table 1: Comparison of Planned and Actual Dates – REX-R1 ............................................................. 10 

Table 2: Comparison of Planned and Actual Dates – CDS ................................................................... 11 

Table 3: Comparison of Planned and Actual Dates – UUM&DS ......................................................... 12 

Table 4: Comparison of Planned and Actual Dates – EORI2 ............................................................... 13 

Table 5: Comparison of Planned and Actual Dates – SURV3 .............................................................. 15 

Table 6: Comparison of Planned and Actual Dates – BTI .................................................................... 16 

Table 7: Comparison of Planned and Actual Dates – AEO upgrade ..................................................... 17 

Table 8: Comparison of Planned and Actual Dates – INF for SP ......................................................... 18 

Table 9: Comparison of Planned and Actual Dates – ICS2 – Release 1 and 2 ..................................... 19 

Table 10: Comparison of Planned and Actual Dates – GUM-C1 ......................................................... 20 

Table 11: Comparison of Planned and Actual Dates – PoUS-P1 .......................................................... 22 

Table 12:Comparison of Planned and Actual Dates – NCTS-P5 .......................................................... 23 

Table 13: Detailed responses from Member States – AN ..................................................................... 28 

Table 14: Detailed responses from Member States – PN ...................................................................... 31 

Table 15: Detailed responses from Member States – TS ...................................................................... 34 

Table 16: Detailed responses from Member States – NIS Upgrade ...................................................... 50 

Table 17: Detailed responses from Member States – SP EXP .............................................................. 54 

Table 18: Detailed responses from Member States – SP IMP .............................................................. 60 

Table 19: Detailed responses from Member States – GUM-C2 ............................................................ 65 

Table 20: Detailed responses from Member States – CCI-P1 ............................................................... 72 

Table 21: Detailed responses from Member States – CCI-P2 ............................................................... 75 

Table 22: Detailed responses from Member States – NCTS-P6 ........................................................... 83 

Table 23: Detailed responses from Member States – AES-C1 ............................................................. 93 

3 

 
 
  
Table 24: Detailed responses from Member States – AES-C2 ............................................................. 95 

Table 25: Detailed responses from Member States – ICS2-R3 ........................................................... 104 

Table 26: Detailed responses from Member States – PoUS-P2 .......................................................... 110 

Table 27: Abbreviations and Acronyms .............................................................................................. 113 

Table 28: Definition of formats, legal base and legal deadline – SURV3 .......................................... 114 

4 

 
 
1. INTRODUCTION 

The Union Customs Code (UCC) requires the European Commission and the Member States to upgrade 
some existing electronic systems and introduce a number of new systems for the completion of a modern 
and digital environment of customs formalities. In total, the UCC requires the upgrading or creation of 
fourteen trans-European systems and three national systems.  

The UCC entered into force on 1 May 2016. Different completion deadlines were scheduled for the end 
of 2020, 2022, or 2025, depending on the system. 

In view of the reporting requirement established by Article 278(a) of the Regulation (EU) 2019/632 
amending Regulation (EU) 2013/952, the Commission1 is committed to provide an annual report to the 
European Parliament and the Council on the progress in developing the electronic systems of the UCC. 
The report assesses the progress of the Commission and the Member States in developing each of the 
electronic systems, taking particular note of the following milestones: 

(a)  The date of publication of the technical specifications for the external communication2 of the 

electronic systems; 

(b)  The period of conformance testing with Economic Operators (EOs); 

(c)  The expected and actual dates of deployment of the electronic systems.  

The legal deadlines for finalising the technical specifications and for deploying the electronic systems 
are laid down in the UCC Work Programme (UCC WP)3. The detailed planning per project, containing 
additional milestones such as the business case, business process modelling, Vision Document (VIS), 
and conformance testing are defined in the Multi-Annual Strategic Plan for Customs (MASP-C)4. 

The  first,  second,  third,  fourth,  fifth  and  sixth  UCC  Annual  Progress  Report 5  were  published  on 
13/12/2019, 14/12/2020, 14/12/2021, 10/02/2023, 09/09/2024, and 02/10/2025 respectively. Details of 
the completed projects are limited in this report; however, additional information can be found in the 
previous year’s reports. 

1 In the context of this report, ‘the Commission’ refers to the European Commission. 

2 External communication with the EOs. 

3 Commission Implementing Decision (EU) 2023/2879 of 15 December 2023 establishing the Work Programme 
relating to the development and deployment for the electronic systems provided for in the Union Customs Code, 
OJ L, 2023/8568, 22.12.2023, https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32023D2879.  

4 Electronic Customs Multi-Annual Strategic Plan for Customs 2023 Revision, Ref. Ares(2023)8102089, 
28.11.2023, https://taxation-customs.ec.europa.eu/system/files/2023-12/000.%20MASP-
C_Rev.%202023_Main%20Body_v1.0.pdf.  

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

2019:https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0629&qid=1747132035353;  

2020: https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:52020DC0806; 

2021: https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52021DC0791; 

2022: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023DC0068; 

2023: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52024DC0395;  

2024: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0579  

5 

 
 
 
 
In  preparation  for  this  year’s  UCC  Annual  Progress  Report,  the  Commission  continued  with  the 
methodology used in previous years, gathering information on the UCC projects state of play from the 
Member States and the Project Managers in Directorate-General for Taxation and Customs Union (DG 
TAXUD). 

This annual report reflects the progress status achieved at the time of writing, until 30 June 2025, 
with  more  recent  updates  included  in  several  cases.  More  detailed  elements  of  the  state  of  play, 
including progress by 31 December 2025, are presented in the Annual Progress Report 2025 and in 
Annex 1 to this Staff Working Document.  

The main outcomes of the progress reporting exercise for 2025 are included in this Commission Staff 
Working Document. Reporting information that summarises the current project status, key risks, and 
mitigating actions is found in the Report from the Commission to the European Parliament and the 
Council pursuant to Article 278a of the UCC, on progress in developing the electronic systems provided 
for under the Code.  

1.1 BACKGROUND 

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

i)  Eleven  central  trans-European  systems  to  be  developed  or  upgraded  by  the  Commission 
(often also requiring developments or upgrades of the national systems by the Member States);  

ii)  Three decentralised trans-European systems that have to be developed or upgraded by the 
Commission, but have a major national component to be implemented by the Member States, 
and; 

iii)  Three  national  systems  that  have  to  be  developed  or  upgraded  exclusively  by  the  Member 

States. 

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

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

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

(2) EU survey launched in February 20256 amongst the Member States to capture the progress: 

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

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

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

DG  TAXUD  conducted  bilateral  high-level  meetings  with  Member  States  Customs  IT  Directorates, 
focusing on having a conversation with each Member State to gain the full picture of their status and to 

6 The information was collected between February 2025 and May 2025. 

6 

 
 
 
 
see what can be done to support them in their work, especially in light of the upcoming deadlines for 
several projects.  

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

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

The progress information has been collected, analysed, and reported in this accompanying Commission 
Staff Working Document, which presents the detailed overview of the progress of the various individual 
projects as follows: 

•  For the trans-European systems, the analysis and reporting refer to the Commission’s activities 
only when it is central, while for the systems that involve national input, and even in some cases 
national  components,  the  analysis  refers  to  both  the  Member  States’  and  Commission’s 
activities; 

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

The UCC is scheduled to conclude at the end of 2025. As a result, all related projects must be completed 
and fully operational by the end of the year to ensure compliance with the established legal framework. 
In view of all this, close and continuous communication has been maintained with the Member States 
to regularly monitor the progress of the UCC projects and to provide the necessary support in order to 
meet the deadlines.  

1.2 LESSONS LEARNT AND SUPPORT FROM THE COMMISSION 

In the EU survey section focused on lessons learnt and support from the Commission, Member States 
shared key insights from the implementation of their projects. These reflections offer practical guidance 
for enhancing future system development and deployment under the UCC framework. 

A commonly cited best practice was the formation of dedicated national project teams with prior UCC 
experience, often supported by customs officials embedded in development teams to ensure operational 
relevance. Many  Member States reported success  with  Agile  and in-house  development  approaches, 
which provided flexibility to adjust timelines, particularly in projects facing evolving requirements or 
external  dependencies.  Phased  implementation  strategies  and  early  integration  testing  helped  reduce 
complexity  and manage  risks  during  rollouts.  Effective  stakeholder  engagement  emerged as  critical. 
Close cooperation with national IT teams, software vendors, and traders, along with clear and consistent 
communication (e.g. user guides, e-learning materials, and helpdesks), supported smooth transitions and 
minimised business disruption. 

Key  challenges  included  aligning  diverse  national  IT  systems  and  legacy  infrastructure,  managing 
interdependencies across parallel UCC projects, and adapting to changes in EU technical specifications. 
Additional issues involved tight procurement timelines, constrained budgets, and limited technical staff. 
Data-related  obstacles, such  as  real-time  volume  processing, incomplete  submissions  from  EOs,  and 
cybersecurity  concerns,  were  addressed  through  frequent  monitoring,  iterative  testing  cycles,  and 
transitional data management plans. 

Finally, Member States underlined the importance of the Commission’s support during development 
and testing. Regular coordination, including through bilateral exchanges, project group discussions, and 
the Electronic Customs Coordination Group (ECCG), was seen as essential to clarifying expectations 
and ensuring alignment throughout implementation. 

7 

 
 
 
 
 
1.3 STRUCTURE OF THE DOCUMENT 

The report is structured as follows: 

•  Section 1: Introduction. 
•  Section 2: Completed Projects. 
•  Section 3: Ongoing Projects.  

8 

 
 
   
 
2. COMPLETED PROJECTS 

Figure 1 provides the overview of the UCC projects that have been completed: 

Figure 1: Overview of completed projects 

9 

 
 
 
 
 
2.1  UCC REGISTERED EXPORTER SYSTEM (REX) 

Deployment 

1 January 2017 

The UCC Registered Exporter System (REX) is a trans-European system that contains information both 
on Registered Exporters established in Generalised Scheme of Preferences (GSP) countries7 and on EU 
EOs in partner countries CH, NO, and TR exporting to GSP countries and certain other countries. The 
main purpose of the system is to replace the paper-based certification process by an IT-supported self-
certification process. The system includes a central database that contains the registered exporters and 
provides the Member States with the opportunity to enhance their national systems with an automated 
verification of REX members. 

There  were  three releases planned.  REX – Release 1 (REX-R1) was the only release covered in the 
scope of the UCC WP. No risks were identified during the implementation of REX-R18 and the project 
was successfully completed on 1 January 2017.  

Some statistical information on the use of the REX system since operations – situation as of 1 May 2025:  

Active REX registrations9 

84,229 

117,30210 

Non-EU countries11 (REX BC) module 

Member States (REX MS) module 

Applications submitted in the REX TP by EU Traders 

12,911 

Applications 

Figure 2: Statistical information – REX 

2.1.1 Overview of Project Progress 

Table 1 compares the actual dates to those set in the UCC WP. Despite there being a slight delay in the 
finalisation of the technical specifications, REX-R1 was deployed on time. 

Table 1: Comparison of Planned and Actual Dates – REX-R1 

7 Countries benefiting from the EU GSP that provides preferential access to the EU market. 

8 For the scope of EU GSP, in parallel with the GSP scheme for of CH, and NO as partner countries. 

9 Aggregated information from 01/01/2017 until 01/05/2025. 

10 It includes 993 registrations from Partner Countries CH, NO, and TR, as well as AD and SM. 

11 Beneficiary countries of the EU, Overseas Countries and Territories, as well as CH GSPs, NO GSPs, TR GSPs. 

10 

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

Deployment 

2 October 2017 

The  UCC  Customs  Decisions  System  (CDS)  is  designed  to  achieve  harmonisation  of  the  processes 
relating to the application for a customs decision, the decision taking, and the decision management. 
This  harmonisation  is  put  into  practice  via  the  standardisation  and  electronic  management  of  the 
application and decision/authorisation data across the Union. The system covers all applications and 
decisions that may have an impact/are valid in more than one Member State. The Member States also 
have the right to use CDS to manage their national customs decisions if they wish to do so. The project 
was fully deployed on 2 October 2017.  

Some statistical information on the use of CDS – situation as of 15 May 2025: 

CDS Application and Decision Statistics  

Number of applications submitted  

Average number of applications per 
working day 

Number of decisions taken 

2023 

2024 

202512 

9,779 

12,728 

5,620 

44 

58 

69 

6,748 

9,345 

4,082 

2.2.1 Overview of Project Progress 

Figure 3: Statistical information – CDS 

Table 2 highlights that there were no divergences in the planning compared to the dates set in the UCC 
WP.  

Table 2: Comparison of Planned and Actual Dates – CDS 

12 Information from 01/01/2025 to 15/05/2025. 

11 

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

SYSTEMS (UUM&DS) 

Deployment 

2 October 2017 

The  Direct  Trader  Access  to  the  European  Information  Systems  comprises  of  Uniform  User 
Management and Digital Signature (UUM&DS) components. The system aims to provide a service for 
user-to-system interfaces targeted to the electronic customs systems provided for in the UCC. In essence, 
the UUM&DS system facilitates a direct and EU harmonised trader access to the customs systems as 
stipulated in the UCC.  

The first deployment of the project was completed and implemented together with CDS on 2 October 
2017, as agreed in the context of the UCC WP. The system was also incorporated into other electronic 
projects, such as the UCC Binding Tariff Information (BTI), the UCC Authorised Economic Operators 
(AEO)  and  the  Information  Sheets  (INF)  system  for  Special  Procedures  (SP).  The  project  further 
evolved  to  include  system-to-system  interfaces  in  view  of  the  Import  Control  System  2  (ICS2) 
deployment and to cover the needs of other UCC and non-UCC projects, such as for the Proof of Union 
Status (PoUS), the Carbon Border Adjustment Mechanism (CBAM) and the Central Electronic System 
of Payment information (CESOP). 

Some statistical information13 on the use of the UUM&DS system – situation until March 2025: 

Number of Successful requests 

Systems using UMM&DS 

1,882,931 

Average monthly availability 
of UUM&DS 

99.94% 

System 
ICS2 
EUCTP 
CBAM 
CD 
UUM&DS-ADM-EXT 
CESOP (Taxation) 

% of Requests 
35.40% 
35.02% 
16.70% 
9.18% 
2.74% 
0.96% 

Figure 4: Statistical information – UUM&DS 

2.3.1 Overview of Project Progress 

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

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

13 All information in the figure below is from May 2024 until March 2025. 

12 

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

SYSTEM UPGRADE (EORI2) 

Deployment 

5 March 2018 

This  system  upgrade  provided  minor  changes  to  the  existing  trans-European  Economic  Operator 
Registration and Identification (EORI) system. These changes enabled the registration and identification 
of  EOs  of the  Union as  well  as third-country  operators  and  persons  apart from  EOs.  The  Economic 
Operator Registration and Identification upgrade (EORI2) system has been in operation since 5 March 
2018. 

Some statistical information on the use of the EORI2 system – situation until 31 March 2025: 

EORI2 Records 

Total Valid Records 
New Valid Records 
Deleted Records 

Q4 2023 
8,786,959 
161,941 
1,144 

Q1 2024 
8,907,182 
158,394 
10,729 

Q3 2024 
Q2 2024 
8,896,229  8,835,083 
141,811 
149,655 
2,278 
1,909 

Q4 2024 
8,962,947 
155,366 
35,460 

Q1 2025 
9,069,791 
157,529 
49,571 

Figure 5: Statistical information – EORI2 

2.4.1 Overview of Project Progress 

Table 4 compares the actual dates to those set in the UCC WP. Despite there being a slight delay in the 
finalisation of the technical specifications, EORI2 was deployed on time. 

Table 4: Comparison of Planned and Actual Dates – EORI2 

13 

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

Deployment 

1 October 2018 

The Surveillance 3 system (SURV3) introduces an upgrade to the standard exchange of information in 
the earlier Surveillance 2 system (SURV2) to align the system with UCC requirements. This database 
records and centralises all EU trade data (imports for free circulation and exports) that national customs 
authorities provide on a daily basis. The upgrade implements electronic data-processing techniques and 
establishes adequate  functionalities needed for processing and analysing the full surveillance dataset 
obtained from Member States. The new system will improve the customs risk analysis, the fight against 
fraud, market analysis, post-clearance controls and statistical analysis. 

The system was successfully deployed on 1 October 2018, with all the data being gathered in different 
formats via Surveillance Recap. Additionally, all national systems needed to be fully aligned to the UCC 
by  31/12/2022  (legal  deadline  for  all  Member  States),  though  extended  until  31/12/2023  for  those 
Member  States  having  been  granted  a  derogation,  thereby  enabling  the  system  to  operate  at  its  full 
potential14.  

An emphasis should be made on the need to extend the use of the system, given that for those Member 
States  who  are  going  to  be  delayed  or  partially  delayed  for  the  National  Import  System  (NIS)  even 
beyond  the  derogation  date,  it  will  have  a  direct  consequence  on  the  collection  of  the  data  via 
Surveillance Recap and on the functioning of the reports of the SURV3 system. Therefore, the system 
will have to be prolonged in use until all Member States are on board. The collection of all the required 
data from all Member States is essential not only for SURV3 but  also for other projects such as for 
CBAM. 

Some statistical information on the use of Surveillance data records received from January 2025 until 
June 2025 by format and Member State1516: 

14 Please refer to section 3 for more detailed information. 

15 See Annexe 3 Definition of formats, legal base and legal deadline for a more detailed description. 

16 0.00% represent numbers bellow two decimal point but with reception of data 

14 

 
 
 
 
 
 
 
 
 
 
Use of Surveillance data records 

Import 

Export 

MS 

CCIP 

nUCC 

Postal 

UCC 
Full 

UCC 
reduced 

CCIP 

nUCC 

UCC 
Full 

UCC 
reduced 

AT  100.00% 
59.79% 
BE 
BG 

99.99% 

CY 
CZ 
DE 
DK  100.00% 
EE 
ES 
FI 
FR 
GR 

98.59% 

0.01% 

0.28% 

HR 
HU 
IE 
IT 
LT 
LU 
LV 
MT 
NL 
0.00% 
PL 
PT  100.00% 
RO  100.00% 
SE 
SI 
SK 
XI 

0.00% 

40.21% 
99.08% 
0.01% 

100.00% 
0.00% 
100.00% 
100.00% 
100.00% 
1.41% 
100.00% 
97.71% 
99.28% 

99.72% 
100.00% 
98.54% 

98.24% 
98.77% 

100.00% 

0.92% 

100.00% 

0.00% 

2.28% 

100.00% 
99.79% 

0.72% 

0.21% 

1.39% 

0.07% 
100.00% 

1.08% 

0.15% 

1.76% 

100.00% 
100.00% 

99.99% 
0.08% 

0.01% 

0.06% 

0.01% 
0.11% 
100.00% 

0.00% 

0.05% 
100.00% 
0.00% 
23.85% 
0.01% 

0.01% 
99.92% 
100.00% 
99.99% 
100.00% 
100.00% 
99.94% 
100.00% 
99.99% 
99.89% 

100.00% 
28.90% 
100.00% 
99.82% 
100.00% 
100.00% 
100.00% 

100.00% 
99.95% 

100.00% 
76.15% 
99.99% 
100.00% 

0.00% 

100.00% 

71.10% 

0.18% 

0.00% 
100.00% 

0.00% 

100.00% 

100.00% 

2.5.1 Overview of Project Progress 

Figure 6 : Statistical information – SURV3 

Table 5 highlights that there were no divergences in the planning compared to the dates set in the UCC 
WP.  

Table 5: Comparison of Planned and Actual Dates – SURV3 

15 

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

Deployment Phase 1 – Step 1  1 March 2017 

Deployment Phase 1 – Step 2  2 October 2017 

Deployment Phase 2 

1 October 2019 

The  project for  a  UCC  Binding  Tariff  Information (BTI)  system aims  to  upgrade the  existing  trans-
European  Binding  Tariff  Information  (EBTI-3)  database  containing  all  BTI  issued  by  customs 
authorities  of  Member  States.  The  customs  authorities  concerned  are  responsible  for  recording  their 
decisions in the  BTI  database.  EOs  apply  for  binding  tariff  decisions  to  ensure legal  certainty  when 
classifying goods that it imports or exports from the EU.  

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

Some statistical information on the use of the BTI system – situation until 19 May 2025: 

BTI applications submitted by 
EOs17 

BTI decisions issued by 
custom authorities18 

Digitalisation Progress 

242,893 

47,075 
via the EU TP 

195,818 
via the national TP 

226,998 

8 processes digitalised  
(including 20 sub-processes) 

2.6.1 Overview of Project Progress 

Figure 7: Statistical information – BTI 

Table 6 compares the actual dates to those set in the UCC WP. Despite there being a slight delay of the 
technical specifications for Step 2, all phases were deployed on time. 

Table 6: Comparison of Planned and Actual Dates – BTI 

17 Aggregated information from 01/10/2019 until 19/05/2025. 

18 Aggregated information from 01/10/2019 until 19/05/2025. 

16 

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

Deployment Phase 1 – Part 1 

5 March 2018 

Deployment Phase 1 – Part 2 

1 October 2019 

Deployment Phase 2 

16 December 2019 

Following  the  legal  changes  adopted in  the  UCC,  the  AEO  upgrade aims to  enhance the  process  of 
applications and authorisations for the AEO status. The project consisted of two phases.  In Phase 1, 
significant improvements were made to the existing AEO system, in light of the harmonisation of the 
decision-taking procedure for customs. Phase 2 focused on implementing an electronic form to provide 
a  harmonised  interface  for  EOs  to  submit  their  AEO  applications  and  receive  their  AEO  decisions 
electronically.  

Some statistical information on the use of the AEO system – situation until 31 March 2025: 

AEO performance indicators 

Q4 2024 

Q1 2025 

AEO 
Applications 

AEO 
Authorisations 

Submitted 
New 
New 
Revoked 

105 
158 
192 
134 

97 
121 
170 
146 

Figure 8: Statistical information – AEO upgrade 

2.7.1 Overview of Project Progress 

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

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

17 

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

Deployment 

1 June 2020 

The aim of the Information Sheets (INF) for the SP project is to develop a new trans-European system 
to  support  and  streamline  the  data  management  processes  and  the  electronic  handling  of  data in  the 
domain  of  SP.  This  harmonised  the  approach  for  the  efficient  management  of  inward  and  outward 
processing procedures and improved the monitoring and control amongst customs offices.  

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

The INF Specific TP component was also successfully integrated into the EU CTP and deployed on 1 
June 2020. The EU CTP is the single portal at Union level to provide traders unique access to a number 
of centralised trans-European systems (e.g. EBTI, AEO, and INF). 

Currently a system-to-system interface between the INF central system and national declaration systems 
is being developed to automate the input and facilitate the processing of INF relevant data. 

Some statistical information on the use of the INF for SP system – situation until 15 May 2025: 

INF requests created 
by EOs19 

INFs treated and 
processed by authorities20 

Averaged number of processed INF 
per working day 

104,190 

95,837 

2020 

48 

2024/202521 

96 

Figure 9: Statistical information – INF for SP 

2.8.1 Overview of Project Progress 

Table 8 highlights that there were no divergences in the planning compared to the dates set in the UCC 
WP.  

Table 8: Comparison of Planned and Actual Dates – INF for SP 

19 Aggregated information from June 2020 until May 2025. 

20 Aggregated information from June 2020 until May 2025. 

21 Information from 16/05/2024 until 15/05/2025. 

18 

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

Deployment ICS2-R1  15 March 2021 

Deployment ICS2-R2  1 March 2023 

The  goal  of  the  UCC  Import  Control  System  2  (ICS2)  programme  is  to  strengthen  the  Safety  and 
Security of the supply chain for goods moved via all modes of transport. The aim is to do so through 
better targeted risk-based controls of EU customs authorities on improved Entry Summary Declaration 
(ENS) data quality, data filing, data availability and data sharing, and through real-time collaborative 
risk analysis and coordinated Safety and Security controls at the EU entry points. The main purpose of 
the  system  is  to  implement  the  new  requirements  resulting  from  the  UCC  and  strategic  objectives 
endorsed by the Member States in the risk management strategy and action plan of 2014. In terms of 
planning, the programme will be implemented in three releases.  

Release 1 (ICS2-R1) covers the obligation on the relevant EOs (postal operators and express carriers in 
air transport) to provide the minimum data (i.e., ENS pre-loading dataset). The cut-off date for ICS2-R1 
related operations in production was on 19 April 2024. 

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

For Release 3 (ICS2-R3), please refer to Section 3.9. 

Some statistical information on the use of the ICS2 Release 1 and 2 – situation until 16 May 2025: 

ENS filing messages 

Period 

Release 1 

Release 2 

Total 

01/03/21 – 31/12/21 

98,369,662 

01/01/22 – 31/12/22 

293,101,713 

- 

- 

98,369,662 

293,101,713 

01/01/23 – 31/12/23 

214,849,041 

108,269,533 

323,118,574 

01/01/24 – 31/12/24 

01/01/25 – 16/05/25 

40,408 

- 

373,503,457 

373,543,865 

137,402,173 

137,402,173 

Total 

606,360,824 

619,175,163 

1,225,535,987 

Figure 10: Statistical information – ICS2 – Release 1 and 2 

2.9.1 Overview of Project Progress 

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

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

19 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/06/201801/09/202105/09/202115/03/202115/03/202130/06/201812/11/2019N/A01/03/202301/03/2023Technical SpecificationsDeployment 
 
 
 
 
2.10 UCC GUARANTEE MANAGEMENT (GUM) – COMPONENT 1 

Deployment 

11 March 2024 

The UCC Guarantee Management (GUM) project assures the effective and efficient management of the 
different types of guarantees. A guarantee is the financial cover for customs duties and other charges. 

The UCC GUM system is comprised of two components.  

Component  1  (GUM-C1)  enhances  the  granting  and  the  management  of  authorisations  for 
comprehensive guarantees that may be used in more than one Member State. It was implemented in the 
UCC CDS and will interface with a national component (GUM-C2) for the monitoring of the reference 
amount. Transit guarantees monitoring is an exception to the above and it is handled as part of the New 
Computerised Transit System (NCTS) project.  GUM C1 became operational in March 2024 and the 
Member States had until 2 June 2025 to deploy their GUM-C2 system. 

For Component 2 (GUM-C2), please refer to Section 3.5.  

2.10.1 Overview of Project Progress 

Table 10 highlights any known divergences in the planning compared to the dates set in the UCC WP.  

Table 10: Comparison of Planned and Actual Dates – GUM-C1 

20 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date30/09/202219/09/2022Not provided11/03/202411/03/2024Technical SpecificationsDeployment 
 
 
 
 
 
2.11 UCC PROOF OF UNION STATUS (POUS) – PHASE 1 

Deployment 

1 March 2024 

The  UCC  Proof  of  Union  Status  (PoUS)  is  a  trans-European  system  designed  to  allow  storage, 
management, and retrieval of certain types of documents (e.g., T2L, T2LF, Customs Goods Manifest 
[CGM]) that traders provide to prove the Union Status of their goods. To this effect, PoUS includes a 
central repository for the storage and exchange of data and documents dealing with PoUS between the 
customs authorities across all the Member States. The system is meant to improve the uniformity of the 
procedures  across  the  European  Union  and  contribute  to  the  establishment  of  a  more  consistent, 
harmonised and, thus, simplified process related to customs clearance for Union goods.  

The project is divided into two phases. For both Phase 1 and Phase 2, the Member States had the option 
of using the central PoUS system or developing their own national application. From all Member States, 
only ES and PL chose to develop their own national system. 

Phase  1  (PoUS-P1)  covers  the  implementation  of  the  electronic  T2L/F  data  with  all  the  necessary 
functionalities.  The  Technical  Systems  Specifications  (TSS)  were  completed  in  Q1  2022  and 
conformance  testing  activities  were  completed  by  Q1  2024.  ES  and  PL  along  with  the  Commission 
reported the PoUS-P1 system deployed on 1 March 2024.  

For Phase 2 (PoUS-P2), please refer to Section 3.10. 

21 

 
 
 
 
 
 
 
 
 
Some statistical information on the use of the PoUS-P1 system – situation until 31 July 2025: 

PoUS Registered and Presented Proofs by MS 

MS 
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 
XI 
Grand Total 

# Registered Proofs22 
2589 
56442 
11656 
17589 
2921 
56462 
10268 
8022 
136171 
10185 
19665 
65065 
1397 
4825 
4235 
113097 
10893 
256 
8168 
1782 
52223 
26974 
17424 
8996 
10390 
3342 
2970 
1114 
665121 

# Presented Proofs23 
2 
3580 
5251 
118581 
14 
7411 
2103 
5281 
16314 
3196 
14587 
77844 
1918 
3066 
3476 
13009 
2107 
0 
1288 
1151 
5106 
5681 
5730 
5550 
4144 
664 
8 
30 
307093 

Figure 11: Statistical information – PoUS – Phase 1 

2.11.1 Overview of Project Progress 

Table 11 highlights any known divergences in the planning compared to the dates set in the UCC WP.  

Table 11: Comparison of Planned and Actual Dates – PoUS-P1 

22 Total number of Registered Proofs per Member State from 01/03/2024 to 28/02/2025. 

23 Total number of Presented Proofs per Member State from 01/03/2024 to 28/02/2025. 

22 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date31/03/202231/03/202231/03/202401/03/202401/03/2024Technical SpecificationsDeployment 
 
 
 
 
 
 
 
 
2.12 UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE – 

COMPONENT 1 

Deployment 

21 January 2025 

This project aimed to align the existing New Computerised Transit System (NCTS) to the UCC legal 
provisions.  The scope  of the  project  included  the  alignment  of  Information  Exchanges  to  UCC  data 
requirements,  the  upgrade and  development  of interfaces  with  other  systems  such  as  the  Automated 
Export System (AES), in addition to new Safety and Security requirements. The transit system offers 
significant  benefits  and  simplifies  processes  while  ensuring  continuity  with  existing  systems.  This 
achievement is the result of close collaboration between national customs authorities, trade associations 
and the Commission. 

It is important to highlight that the NCTS system specifications developed by the Commission cover the 
Information  Exchange  in  the  common,  national,  and  external  domains.  Regarding  the  message 
exchanges on the Common Domain, the NCTS specifications prepared by DG TAXUD are mandatory 
for  all  Common  Transit  Convention  (CTC)  contracting  parties.  In  the  case  of  external  or  national 
domains, the common NCTS specifications are strongly recommended, aiming to harmonise the transit 
formalities as much as possible among the CTC contracting parties. The UCC Data Annex B and Annex 
A3a of the CTC Convention are the binding legal framework for Transit Declarations. 

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

Component  1  (NCTS-P5)  included  steps  to  upgrade  and  extend  the  current  NCTS  processes  in 
alignment  with  the  UCC  legal  provisions,  to  introduce  new  processes  such  as  the  pre-lodgement  of 
customs declarations, to provide for the registration of ‘en route’ events, to align Information Exchange 
to UCC data requirements and to upgrade and update the development of interfaces with other systems. 
The system included some components that were developed centrally, but the main components were 
developed  at  the  national  level.  NCTS-P5  was  deployed  in  two  steps:  the  first  related  to  core 
functionalities  (operational  continuity  aligned  with  UCC)  and  the  second  to  non-core  functionalities 
(Pre-Lodgement, Incident ‘en route’ Management, Office of Exit and Export followed by Transit). The 
National Administrations had the possibility to deploy both steps at once or to deploy them in sequence. 

There are 40 National Administrations currently in operation for NCTS: the 27 Member States, Northern 
Ireland under  the  terms  of  the  Northern  Ireland  Protocol (NIP),  Andorra,  San Marino, and  the  CTC 
Countries (Switzerland with Liechtenstein connected, Serbia, North Macedonia, Norway with Iceland 
connected, Türkiye, Ukraine, the United Kingdom and Georgia). Georgia acceded to Common Transit 
and entered NCTS-P5 operations on 1 February 2025. Montenegro, and Moldova are acceding countries 
to the Common Transit Convention at various stages of preparation and aim to go into operation by the 
end of 2025. 

NCTS-P5 was deployed in line with the following calendar: Core functionalities (Step 1) on 01/12/2023, 
none core-functionalities (Step 2) on 02/12/2024. It became fully operational on 21 January 2025, after 
the end of transition date. All 40 National Administrations are currently operating in NCTS-P5, while 
NCTS-P4 systems will be decommissioned in the coming months.  

For Component 2 (NCTS-P6), please refer to Section 3.7.  

2.12.1 Overview of Project Progress 
Table 12 highlights any known divergences in the planning compared to the dates set in the UCC WP. 

Table 12:Comparison of Planned and Actual Dates – NCTS-P5 

23 

Conformance TestingTarget date from WPActual End DateActual End DateTarget date from WPActual Date31/12/201931/12/2019Not finished21/01/202521/01/2025Technical SpecificationsOperations 
 
 
3. ONGOING PROJECTS 

Figure 1224 25 provides an overview of the deployment windows of the UCC projects that are currently 
ongoing: 

Figure 12: Overview of projects to be completed by the end of 2025 

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

25 The  end  of  the  deployment window  for  AES-C1  is  02/12/2024, however  the  end  of  transition  deadline  was 
changed from 11/02/2025 to 14/12/2025, under Article 56 of the revised IRTA.  

24 

 
 
 
 
 
 
 
3.1 UCC NOTIFICATION OF ARRIVAL (AN), PRESENTATION NOTIFICATION 

(PN) AND TEMPORARY STORAGE (TS) 

The goal of this project is to define the processes at the national level in respect of the Notification of 
Arrival (AN), Presentation Notification (PN), and Temporary Storage (TS) notifications, as described 
in the UCC. The project aims to ensure that Safety and Security-related customs formalities for goods 
entering and exiting are properly conducted, and customs supervision begins at the appropriate time and 
is duly performed. It also aims to support harmonisation across the Member States regarding the data 
exchange between trade and customs. Furthermore, the project covers the automation of processes at 
the national level.  

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

The  development  activities  related  to  this  project  are  a  national  matter,  with  processes  and  data 
requirements for the external domain to be defined and agreed at the EU level. In this light, the systems 
were  planned  to  be  in  operation  by  31  December  2022,  as  defined  in  the  UCC  basic  Regulation. 
However, several Member States requested a derogation as stated in Article 6(4) of the UCC, addressing 
a formal request, of a temporary nature, stating a scope and clear justification. On 1 February 2023, the 
Commission adopted Implementing Decisions granting derogations to certain Member States for AN, 
PN, and TS, extending the previously stated deadlines to 31 December 2023 for air transport and 29 
February 2024 for other modes of transport (maritime transport or inland waterways and road & rail 
transport). 

3.1.1 Summary of Responses 

Notification of Arrival (AN) 

Summary from the Member States: 

While most Member States have completed the AN/PN/TS projects, a few reported delays. These delays 
are often attributed to the project’s strong interlinkage with other major initiatives such as NIS, ICS2, 
and the European Maritime Single Window (EMSW), frequently cited by Member States as a key reason 
for assessing the project as high risk. 

Common  risk  factors  contributing  to  delays  include  procurement  issues,  interdependencies  between 
national systems, coordination challenges, limited human resources, and the varying readiness of EOs. 
Further delays were linked to internal development bottlenecks and the prioritisation of other national 
projects, notably NIS. 

To address these risks, Member States have reported the implementation of various mitigation measures. 
These include corrective actions in project management and staffing, enhanced support for EOs, parallel 
development and testing activities, interim reliance on existing systems such as the Maritime Single 
Window  (MSW)  to  prevent  procedural  disruptions,  and  the  joint  implementation  of  related  national 
projects to streamline timelines.  

The above summary also applies to PN and TS.   

As of the time of writing, the following Member States reported that the AN system has been deployed 
for both air and maritime transport: BE, BG, CY, CZ, DE, DK, EE, ES, FI, FR, GR, HR, HU, IE, IT, 
LT, LV, MT, NL, PL, RO, SE, and SI. AT, LU and SK indicated that the system is operational for air 
transport but noted that maritime transport is not applicable. PT shared that the AN system for both air 
and maritime transport is delayed but will be deployed before the end of 2025. 

25 

 
 
 
Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for a derogation under 
Article 6(4) of the UCC, concerning the delay of AN beyond the deadline of 31 December 2022. The 
derogation requests from the Member States were assessed by the Commission services in terms of the 
justifications provided for the specific situations of the Member States requesting it and in view of a set 
of common assessment criteria.  

In this light, the Commission adopted an Implementing Decision (EU) 2023/23526 on 1 February 2023, 
granting a derogation to AT, BE, BG, CY, CZ, DK, EE, ES, FR, GR, HR, HU, LU, MT, NL, PL, PT, 
RO, SE, SI, and SK for AN provided for in Article 133 of the  UCC. The derogation applied from 1 
January 2023 until the deployment of the AN system, but not later than 31 December 2023, in respect 
of goods entering the customs territory of the Union by air, and 29 February 2024, in respect of goods 
entering the customs territory of the Union by maritime transport or inland waterways, whichever date 
is sooner. This differentiation by transport mode aligned with ICS2-R2 and  the date specified in the 
UCC WP 2023 for ICS2-R3, respectively, as the projects are closely linked27.  

Detailed Responses28: 

Table 13 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

BE 

BG 

CY 

Additional Comments 

AT reported that the AN  system for air transport has been  deployed since 16/05/2023, 
with ICS2 functionalities being used for the implementation of the AN system.  

BE informed that the AN system was deployed on 30/06/2023 for air transport and on 
03/06/2024 for maritime transport.  

BG  shared  that  the  AN  system  was  deployed  on  01/03/2023  for  air  transport  and  on 
03/06/2024 for maritime transport.  

CY reported that the AN system was deployed on 19/05/2025 for both air and maritime 
transport.  CY  informed  that  it  experienced  delays  due  to  multiple  factors,  including 
procurement  issues,  interdependencies  between  core  and  supporting  systems,  parallel 
upgrades, coordination challenges between contractors, limited human resources, and the 
readiness of  its EOs. To address these issues, CY implemented corrective measures in 
project  management  and  resourcing,  and  strengthened  support  for  EOs,  which  helped 
reduce the delays. 

CZ 

CZ  informed  that  the  AN  system  for  both  air  transport  and  maritime  transport  was 
deployed on 05/12/2023.  

DE 

DE indicated that the AN system has been completed as it is covered by their ICS2 system.   

26 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). 

27 Considering the link with ICS2-R3 for maritime transport, the Member States that were granted a derogation 
had the possibility to deploy the system until 03/06/2024. 

28 Fields marked in grey mean no information was provided. 

26 

 
 
 
 
 
MS 

DK 

EE 

ES 

FI 

FR 

GR 

HR 

Additional Comments 

DK reported that the AN system for air transport was deployed on 06/11/2023 and for 
maritime transport on 25/05/2024.  

EE  shared  that  the  AN  system  was  deployed  on  01/10/2023  for  air  transport  and  on 
03/06/2024 for maritime transport.  

ES  informed  that  the  AN  system  was  deployed  on  01/03/2023  for  air  transport. 
Additionally, ES shared that the AN system for maritime transport is aligned with ICS2-
R3 and was deployed on 03/06/2024. 

FI reported that the AN system was deployed in Q1 2023 for air transport and in Q2 2024 
for maritime transport.  

FR indicated that the AN system for air transport was deployed on 30/06/2023 and for 
maritime  transport  on  03/06/2024.  Additionally,  FR  shared  that  AN  messages  are 
processed by their ICS2 system.  

GR shared that the AN system was deployed on 31/10/2023 for air and maritime transport. 
GR noted that the implementation was based on ICS2.  

HR reported that the AN system was deployed on 01/07/2023 for air transport and on 
04/12/2024 for maritime transport.  

HU 

HU indicated that the AN system was deployed for all modes of transport on 02/04/2024. 

IE 

IT 

LT 

LU 

LV 

IE  shared  that  the  AN  system  was  deployed  on  01/07/2023  for  air  transport  and  on 
03/06/2024 for maritime transport. Additionally, IE noted that developments have started 
in relation to include AN messages through the EMSW, but this will not be in production 
until late 2026 or early 2027.  

IT  informed that  the  AN  system  was  deployed  on  13/12/2022  for  air transport and  on 
03/06/2024 for maritime transport. 

LT  reported  that  the  AN  system  was  deployed  on  01/03/2023  for  air  transport  and  on 
03/06/2024  for  maritime  transport.  Additionally,  LT  informed  that  the  central  ICS2 
system is being used for the implementation of AN.  

LU  shared  that  the  AN  project  was  completed,  having  deployed  the  system  for  air 
transport on 01/03/2023.  

LV  reported  that  the  AN  system  was  deployed  on  24/09/2017 for  air transport and  on 
01/03/2023 for maritime transport. Additionally, the AN system part of the ICS2 system.  

MT 

MT indicated that the AN system was deployed on 24/03/2025 for all modes of transport. 

NL 

PL 

PT 

NL  shared  that  the  AN  system  was  deployed  on  30/06/2023  for  air  transport  and  on 
27/05/2024 for maritime transport. However, NL indicated that the project is still delayed, 
as EOs will be following the ICS2 implementation dates to join operations. NL aims to 
have AN fully implemented on 01/10/2025.   

PL  shared  that  the  AN  system  was  deployed  on  01/07/2023  for  air  transport,  on 
03/06/2024 for maritime transport.  Additionally, PL shared that the AN functionalities 
were developed within ICS2.  

PT  reported  that  the  AN  project  is  delayed  beyond  the  UCC  WP  deadline,  with 
deployment for both air and maritime transport planned for 30/09/2025. PT attributed a 
high-risk level to the timely delivery of the project, with delays attributed to the strong 
interdependencies among national systems, which complicated the overall development 

27 

 
 
MS 

Additional Comments 

of  the  AN  system.  PT  shared  that the  project  was  particularly  complex,  as  it  involved 
building an entirely new system for AN, PN, and TS, requiring integration with airport 
and port authorities. Additional delays were caused by the need to connect this system 
with  ICS2,  NIS,  the  Customs  Risk  Management  System  (CRMS),  and  the  Temporary 
Storage Facilities system. To address these challenges, PT adopted Agile development to 
shorten the implementation timeframe and improved its planning processes. 

RO  shared  that  the  AN  system  was  deployed  on  01/05/2024  for  air  transport  and  on 
16/12/2024 for maritime transport.  

SE informed that the AN system was deployed on  01/03/2023 for air transport and on 
03/06/2024 for maritime transport. Additionally, SE noted that it will be using the central 
functionalities within the ICS2 project for AN messages.  

SI reported that the AN system joined operations on 01/03/2023 for air transport and on 
02/06/2024 for maritime transport. In addition, SI shared that it will use ICS2 for the AN 
processes.  

SK shared that the central ICS2 system is being used for the AN functionalities, which 
were deployed for air transport on 01/03/2023. 

Table 13: Detailed responses from Member States – AN 

RO 

SE 

SI 

SK 

Figure 1329 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 13: Project progress and status per milestone – AN 

Presentation Notification (PN) 

Summary from the Member States: 

Please see also the summary from AN. 

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

29 The progress shown in the figure considers  all modes of transport. Additionally, ‘Deployment’ encompasses 
both deployment and operations milestones. 

28 

 
 
 
 
 
 
 
 
declarations, notifications, and proof of the customs status of union goods provided for in Article 2(2) 
of the Commission Delegated Regulation (EU) 2021/234. 

As of the time of writing, the following Member States reported that the PN system has been deployed 
for all modes of transport: BG, CZ, DE, DK, EE, ES, FI, FR, HR, HU, IE, LT, LV, MT, PL, RO, and 
SE. CY, IT, NL and SI, have deployed the PN system for air and maritime transport and indicated that 
road & rail transport is not applicable. BE has also deployed the PN system for air and maritime transport 
but did not provide information regarding road & rail transport. AT, LU and SK reported deployment 
for air transport only, noting that maritime and road & rail transport are not applicable. In addition, PT 
shared that the PN system for both air and maritime transport is delayed, but will be deployed before the 
end of 2025.  

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for a derogation under 
Article 6(4) of the UCC, considering the delay of PN beyond the deadline of 31 December 2022. The 
derogation requests from the Member States were assessed by the Commission services in terms of the 
justifications provided for the specific situations of the Member States requesting it and in view of a set 
of common assessment criteria. 

In this light, the Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/23430 
granting a derogation to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HR, HU, LU, MT, NL, PL, PT, RO, 
SE, SI, and SK for the PN system provided for in Article 133 of the UCC. The derogation applied from 
1 January 2023 until the deployment of the PN system, but not later than 31 December 2023, in respect 
of goods entering the customs territory of the Union by air and 29 February 2024, in respect of goods 
entering  the  customs  territory  of  the  Union  by  maritime  transport,  inland  waterways,  road  &  rail 
transport, whichever date is sooner. This differentiation by transport mode aligned with ICS2-R2 and 
the date specified in the UCC WP 2023 for ICS2-R3, respectively, as the projects are closely linked31. 

Detailed Responses: 

Table 14 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

BE 

Additional Comments 

AT shared that the PN project was completed within the ICS2 system and was deployed 
on 16/05/2023 for air transport.  

BE  informed  that  the  PN  system  was  deployed  on  05/07/2023  for  air  and  maritime 
transport.  

BG 

BG reported that the PN system for all modes of transport was deployed on 10/11/2023.  

CY 

Same response as for AN.  

30 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). 

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

29 

 
 
 
 
 
MS 

CZ 

DE 

DK 

Additional Comments 

CZ  informed  that  the  PN  system  for  both  air  transport  and  maritime  transport  was 
deployed on 05/12/2023 and for road & rail transport on 01/06/2024.  

DE shared that the PN system was deployed for air transport on 06/03/2021. Additionally, 
it indicated that PN was updated as part of ‘National Entry System’ of the national IT-
System Automated Customs Tariff and Local Processing Application System (ATLAS) 
(Release 9.1), which covers all modes of transport. 

DK  reported  that  the  PN  system  was  deployed  for  air  transport  on  06/11/2023,  for 
maritime transport on 25/05/2024 and for road & rail transport on 29/07/2023.  

EE 

EE informed that the PN system was deployed on 15/03/2021 for all modes of transport.  

ES 

FI 

FR 

ES  shared  that  the  PN  system  was  deployed  on  01/01/2024  for  air  transport  and  on 
01/03/2024 for both maritime transport and road & rail transport.  

FI informed that the PN system was deployed in Q1 2021 for air transport and in Q2 2024 
for both maritime transport and road & rail transport.  

FR  reported  that  the  PN  system  was  deployed  on  06/03/2024  for  air  transport,  on 
03/06/2024 for maritime transport and on 01/04/2025 for road & rail transport. 

GR 

GR indicated that the PN system was deployed on 31/10/2023 for all modes of transport. 

HR 

HR shared that the PN system was deployed for all modes of transport on 17/04/2023 and 
was implemented as part of ICS2.  

HU 

HU indicated that the PN system was deployed for all modes of transport on 02/04/2024.  

IE  shared  that  the  PN  system  was  deployed  for  all  modes  of  transport  on  23/11/2020. 
Additionally,  IE  noted  that  PN  messages  will  reflect  the  revised  Annex  B  format  in 
January 2026 and will be included in the European Maritime Single Window environment 
(EMSWe) in late 2026 or early 2027. 

IT  informed  that  the  PN  system  was  deployed  on  13/12/2022  for  air  transport  and  on 
03/06/2024 for maritime transport. 

IE 

IT 

LT 

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

LU 

LV 

LU shared that the PN project is complete, having deployed the system for air transport 
on 10/01/2023.  

LV  reported  that  the  PN  system  was  deployed  on  24/09/2017  for  air  transport  and 
01/03/2023  for  maritime  and  road  &  rail  transport.    Additionally,  LV  shared  that  PN 
messages will be implemented as part of ICS2-R3 when all EOs join the system.  

MT 

MT informed that the PN system was deployed on 24/03/2025 for all modes of transport. 

NL 

PL 

NL  reported  that  the  PN  system  was  deployed  on  01/12/2023  for  air  transport  and  on 
27/05/2024 for maritime transport. However, NL indicated that the project is delayed, as 
EOs will be following the ICS2 implementation dates to join operations. NL aims to have 
PN fully implemented on 01/09/2025.    

PL shared that the PN system was deployed on 20/04/2025 for all modes of transport. 
However,  due  to  the  parallel  implementation  of  the  NIS  upgrade,  full  functionality  is 

30 

 
 
MS 

Additional Comments 

delayed for road and rail transport and will become operational on 01/09/2025. In addition, 
PN functionalities were developed within the NIS and ICS2 systems.  

PT 

Same response as AN.   

RO 

RO indicated that the PN system was deployed on 14/11/2024 for both air and maritime 
transport and on 01/04/2025 for road & rail transport. Additionally, RO noted that the PN 
system is dependent on ICS2.  

SE  shared  that  the  PN  system  was  deployed  on  27/09/2023  for  air  transport  and  on 
01/03/2024 for both maritime transport and road & rail transport.  However, SE shared 
that it has faced delays concerning maritime traffic due to the dependency with the EMSW 
deployment. SE shared it intends to use the current data filing system via the MSW until 
the new Maritime National Single Window (MNSW) is deployed by the Swedish Martime 
Authority in Q3 2027. This approach aims to minimise the burden on trade and prevent 
the need for SE to change procedures and filing systems twice within a short timeframe. 
As PN should pertain to the entry summary declaration, SE added several data elements 
to the current data filing system in the MSW since 03/06/2024. In addition, SE is analysing 
the consequences of the delays for the customs formalities since the deployment of the 
MNSW will be delayed until Q3 2027. 

SI  informed  that  the  PN  system  was  deployed  on  01/03/2023  for  air  transport  and  on 
29/02/2024 for maritime transport.  

SK  reported  that  all  PN functionalities  were implemented in all impacted systems and 
deployed on 01/10/2023 for air transport.  

SE 

SI 

SK 

Table 14: Detailed responses from Member States – PN 

Figure 1432 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 14: Project progress and status per milestone – PN 

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

31 

 
 
 
 
 
 
Temporary Storage (TS) 

Summary from the Member States: 

Please see also the summary from AN. 

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

As of the time of writing, the following Member States reported that the TS system has been deployed 
for both all modes of transport: BG, CZ, DE, DK, EE, ES, FI, FR, HR, HU, IE, LV, MT, PL and SI.  
CY, IT, LT and NL have indicated that the TS system for air and maritime transport has been deployed 
and indicated that road & rail is not applicable. BE has also deployed the TS system for air and maritime 
transport but did not provide information regarding road & rail transport. LU has deployed the system 
for air and road and rail transport while indicating that maritime transport is not applicable. Moreover, 
SE has deployed the system for air transport but reported delays for maritime and indicated road and 
rail as not applicable. AT, GR, PT, RO and SK have reported delays beyond the legal deadline, with GR 
and SK expecting the delays to extend beyond 2025.  

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for a derogation under 
Article 6(4) of the UCC, considering the delay of TS beyond the deadline of 31 December 2022. The 
derogation requests from the Member States were assessed by the Commission services in terms of the 
justifications provided for the specific situations of the Member States requesting it and in view of a set 
of common assessment criteria.  

In this light, the Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/23633 
granting a derogation to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HR, HU, LT, LU, MT, NL, PL, PT, 
RO, SE, SI, and SK for the TS system referred to in Article 145 of the UCC. The derogation applied 
from 1 January 2023 until the deployment of the TS system, but not later than 31 December 2023, in 
respect of goods entering the customs territory of the Union by air, and 29 February 2024, in respect of 
goods entering the customs territory of the Union by maritime transport or inland waterways, road or 
rail transport, whichever date is sooner. This differentiation by transport mode aligned with ICS2-R2 
and  the  date  specified  in  the  UCC  WP  2023  for  ICS2-R3,  respectively,  as  the  projects  are  closely 
linked34. 

Detailed Responses: 

Table 15 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

Additional Comments 

AT  reported  that the  TS  project is  delayed  beyond the  UCC  WP  deadline  but  aims  to 
‘deploy on 01/11/2025 for air and road & rail transport. AT attributed a medium risk to 
the timely delivery of the project, due to delays with the internal developments and the 
finalisation of the public tender (pending the conclusion of negotiations with the software 
provider  and  the  Commission).  Additionally,  AT  plans  to  deploy  TS  alongside  the 

33 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). 

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

32 

 
 
 
 
MS 

Additional Comments 

upgrade of NIS, instead of with Centralised Clearance for Import (CCI-P2) in order to 
reduce delays and deploy before the end of 2025.  

BE 

BE shared that the TS system was deployed on 29/11/2023 for air and maritime transport.  

BG 

BG reported that the TS system for all modes of transport was deployed on 10/11/2023.  

CY 

Same response as for AN.    

CZ 

CZ informed that the TS system for all modes of transport was deployed on 05/12/2023.  

DE 

Same response as PN.  

DK reported that the TS system was deployed on 07/06/2025 for all modes of transport. 
However, some delays occurred due to its dependency on the import system, which was 
postponed as priority was given to export and transit systems. DK also delayed the go-
live to ensure quality and usability for its EOs. To support deployment, DK implemented 
parallel development and testing, increased project resources, and is actively working with 
its vendor to ensure timely delivery of other MASP-C initiatives scheduled for 2025. 

EE shared that the TS system was deployed on 01/07/2021 for air transport, on 01/10/2023 
for maritime transport and on 03/06/2024 for road & rail transport.  

ES  informed  that  the  TS  system  was  deployed  on  01/01/2024  for  air  transport  and  on 
01/03/2024 for both maritime transport and road & rail transport.  

FI shared that the TS system was deployed in Q1 2022 for air transport and in Q2 2024 
for both maritime transport and road & rail transport.  

FR indicated that the TS system was deployed on 06/03/2024 for both air and maritime 
transport and on 01/04/2025 for road & rail transport.  

GR informed that deployment of the TS system is expected in Q4 2027 for air and road 
and rail transport and in Q4 2026 for maritime transport. 

DK 

EE 

ES 

FI 

FR 

GR 

HR 

HR reported that the TS system was deployed on 17/04/2023 for all modes of transport.  

HU 

IE 

IT 

LT 

LU 

LV 

HU indicated that the TS project was completed, having deployed the system for all modes 
of transport on 02/04/2024.  

IE  shared  that  the  TS  system  was  deployed  for  all  modes  of  transport  on  23/11/2020. 
Additionally,  IE  noted  that  TS  messages  will  reflect  the  revised  Annex  B  format  in 
January 2026 and will be included in the EMSWe in late 2026 or early 2027. 

IT  informed  that  the  PN  system  was  deployed  on  13/12/2022  for  air  transport  and  on 
03/06/2024 for maritime transport. 

LT reported that the TS system was deployed for both air transport and maritime transport 
on 31/10/2023.  

LU shared that the TS project was completed, having deployed the system for air and road 
and rail transport on 10/01/2023.  

LV reported that the TS system was deployed on 24/09/2017 for all modes of transport. 
Additionally, LV reported that the TS system has been updated according to UCC data 

33 

 
 
MS 

Additional Comments 

elements, and has confirmed it is aligned with the latest European Union Customs Data 
Model (EUCDM) version since 15/02/2022.   

MT 

MT informed that the TS system was deployed on 24/03/2025 for all modes of transport. 

NL 

PL 

NL  reported  that  the  TS  system  was  deployed  on  01/12/2023  for  air  transport  and  on 
27/05/2024 for maritime transport.  However, NL indicated that the project is delayed, as 
EOs will be following the ICS2 implementation dates to join operations. NL aims to have 
TS fully implemented on 01/10/2025.    

PL  shared  that  the  TS system  was  deployed  on 20/04/2025  for  all modes  of transport. 
However, due to the parallel implementation of the NIS upgrade, full functionality was 
delayed and became operational only on 19/06/2025. During this period, the legacy NIS 
was used by incorporating the TS functionality in a transitional data model.  

PT 

Same response as AN. 

RO 

RO informed that deployment of the AN system is expected on 30/08/2025 for all modes 
of transport. 

SE 

 SE  reported  that  the  TS  system  was  deployed  for  air  transport  on  08/10/2024  but  is 
delayed  beyond  the  legal  deadline  for  maritime  transport,  which  it  plans  to  deploy  on 
02/12/2025. SE shared that it had planned to use the MNSW as the external domain source 
for the temporary storage declarations. However, since the deployment of the MNSW in 
Sweden will be delayed until Q3 2027, SE is considering the possibility of submitting the 
temporary storage declarations directly to their TS system. This approach is intended to 
minimise disruption for traders. 

SI 

SI shared that the TS system was deployed on 01/03/2024 for all modes of transport. 

SK 

SK reported that the TS  project is delayed beyond 2025, with a ‘go live’ date planned 
tentatively  for  Q1  2027.  SK  attributed  the  delay  due  to  other  UCC  projects  being 
prioritised, in particular NIS, as well as having a single contractor working on all systems. 
SK aims to complete the initiation phase by the end of the 2025.  

Table 15: Detailed responses from Member States – TS 

34 

 
 
 
 
Figure 1535 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 15: Project progress and status per milestone – TS 

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

35 

 
 
 
 
 
 
3.1.2 Overview of Project Progress 

Figure 16, Figure 18, and Figure 21 for the air transport; Figure 17, Figure 19, and Figure 22 for the 
maritime  transport,  and  Figure  20  and  Figure  23  for  other  modes  of  transport  highlight  any  known 
divergences in the Member States’ National Planning compared to the dates set in the UCC and/or the 
granted derogation deadline36 37 38 as well as the specific dates for each milestone. The dates reflected 
in the figures below indicate the full implementation of the project. Some Member States decided to 
deliver the system in several iterations or releases, linked to the ICS2 Releases.  

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

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

The  specific  dates  of  each  milestone  can  be  found  in  Figure  16  for  air  transport  and  Figure  17  for 
maritime transport. 

36 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/235, granting a derogation 
to  AT,  BE,  BG,  CY,  CZ,  DK,  EE,  ES,  FR,  GR,  HU,  HR,  LU,  MT,  NL,  PL,  PT,  RO,  SE,  SI,  and  SK  from 
01/01/2023 until the deployment of the AN system, but not later than 31/12/2023, for Air transport and 29/02/2024 
for maritime transport or inland waterways, whichever date is sooner. Additionally, considering the link with ICS2-
R3 for maritime transport,  the Member States that were  granted a derogation  had  the possibility to deploy the 
system until 03/06/2024.  

37 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/234, granting a derogation 
to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LU, MT, NL, PL, PT, RO, SE, SI, and SK from 01/01/2023 
until the deployment of the PN system, but not later than 31/12/2023, for Air transport and 29/02/2024 for maritime 
transport, inland waterways, road or rail transport, whichever date is sooner. Additionally, considering the link 
with ICS2-R3 for maritime transport, inland waterways, road or rail transport, the Member States that were granted 
a derogation had the possibility to deploy the system until 03/06/2024. 

38 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/236, granting a derogation 
to AT, BE, CY, CZ, DK, EE, ES, FR, GR, HU, HR, LT, LU, MT, NL, PL, PT, RO, SE, SI, and SK from 01/01/2023 
until the deployment of the TS system, but not later than 31/12/2023, for Air transport and 29/02/2024 for maritime 
transport, inland waterways, road or rail transport, whichever date is sooner. Additionally, considering the link 
with ICS2-R3 for maritime transport, inland waterways, road or rail transport, the Member States that were granted 
a derogation had the possibility to deploy the system until 03/06/2024. 

39 In all projects, for the Member States that provided dates in quarters or months, the project is considered on 
target if the UCC WP deadline falls within the quarter or month indicated. 

36 

 
 
 
 
Figure 16: Actual/Planned dates per milestone – AN – Air transport 

37 

 
 
 
Figure 17: Actual/Planned dates per milestone – AN – Maritime transport 

38 

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

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

Concerning the implementation  of  Presentation  Notification  (PN)  – Other  modes  of transport, the 
following Member States have a planned/actual deployment date that is later than the deadline set by 
the UCC and/or the granted derogation: BG, FI, FR, LT, LV, MT, PL, and RO. In addition, BE and DE 
did not provide information through their National Planning on the deployment date. Furthermore, AT, 
CY, IT, LU, NL, PT, SI and SK indicated the project as not applicable. 

The specific dates of each milestone can be found in Figure 18 for air transport, Figure 19 for maritime 
transport and Figure 20 for other modes of transport.  

39 

 
 
 
 
 
Figure 18: Actual/Planned dates per milestone – PN – Air transport 

40 

 
 
 
Figure 19: Actual/Planned dates per milestone – PN – Maritime transport 

41 

 
 
 
Figure 20: Actual/Planned dates per milestone – PN – Other modes of transport 

42 

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

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

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

The specific dates of each milestone can be found in Figure 21 for air transport, Figure 22 for maritime 
transport and Figure 23 for other modes of transport. 

43 

 
 
Figure 21: Actual/Planned dates per milestone – TS – Air transport 

44 

 
 
 
Figure 22: Actual/Planned dates per milestone – TS – Maritimes transport 

45 

 
 
 
Figure 23: Actual/Planned dates per milestone – TS – Other modes of transport 

46 

 
 
 
 
3.2  UCC NATIONAL IMPORT SYSTEM (NIS) UPGRADE 

The project will implement all processes and data requirements deriving from the UCC, which relate to 
the import of goods into the Union. The existing National Import System (NIS) has to be upgraded in 
line with these new UCC requirements. The development activities related to this project are a national 
matter, with processes and data requirements for the external domain to be defined and agreed at the EU 
level.  

The upgrade mainly relates to: 

a)  Changes to support the different possibilities for lodging a customs declaration (e.g., standard, 
simplified declaration, including pre-lodged one, made through entry in the declarant's records, 
supplementary declaration) and its processing in the customs systems; 

b)  Changes for Centralised Clearance at national level; 

c)  Changes to the exchange of information; 

d)  Adjustments of the respective messages with the datasets in Annex B to the UCC Delegated 

Act (UCC DA) and UCC Implementing Act (UCC IA); 

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

3.2.1 Summary of Responses 

Summary from the Member States: 

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

Most Member States have deployed the NIS upgrade; however, the remaining ones assessed the project 
as medium-to-high risk due to delays extending beyond the UCC WP deadline.  

The most commonly cited causes of delays include financial resource constraints, the prioritisation of 
other systems, such as export and transit over NIS, and the time needed to accommodate the transition 
for EOs. Further delays were attributed to the strong interdependencies between national systems and 
evolving technical specifications during the development phase. 

To mitigate these challenges, Member States have reported adopting various measures. These include 
Agile development approaches to shorten implementation timelines, parallel development and testing, 
and increased allocation of project resources. Other actions involve planning the phase-out of outdated 
applications to support the shift to new systems and ensuring timely access to technical specifications 
for EOs to minimise disruption. In several cases, designating the NIS upgrade as a high-priority project 
has also helped concentrate resources and maintain momentum despite delays in related areas. 

At the moment of writing, the Member States that have already deployed the NIS upgrade are BE, BG, 
CY, DE, DK, EE, ES, FI, FR, GR, HR, HU, IE, IT, LT, LU, LV, MT, NL, PL, SE, SI, and SK, with IE, 
PL, and SK reporting having deployed NIS but need to implement a further update. In addition, AT, CZ, 
PT, and RO have reported a delay beyond the UCC deadline, with all but CZ aiming to deploy the NIS 
upgrade before the end of 2025.  

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for a derogation under 
Article 6(4) of the UCC, considering the delay of NIS beyond the deadline of 31 December 2022. The 
derogation requests from the Member States were assessed by the Commission services in terms of the 
justifications provided for the specific situations of the Member States requesting it and in view of a set 
of common assessment criteria.  

47 

 
 
In this light the Commission adopted an Implementing Decision (EU) 2023/23740 on 1 February 2023, 
granting a derogation to AT, BE, CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, RO, and SE for 
the NIS system upgrade to use means other than electronic data-processing techniques for the exchange 
and storage of information. The derogation applied from 1 January 2023 until the deployment of NIS, 
but  not  later  than  31  December  2023.  Additionally,  where  Article  2(4a)  of  Commission  Delegated 
Regulation (EU) 2015/2446 applies, Member States had until 01/07/2024 to deploy the system upgrade. 

Detailed Responses: 

Table 16 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

Additional Comments 

AT 

Same response as for TS.  

BE 

BE reported that the NIS upgrade was deployed on 28/08/2024.  

BG 

BG shared that the NIS upgrade was deployed on 10/11/2023 and confirmed the system 
is aligned to the new Annex B.  

CY 

Same response as for AN.  

CZ 

DE 

DK 

CZ shared that the NIS project is delayed beyond the legal deadline but aims to deploy 
the upgrade on 18/05/2026. CZ attributed a high level of risk to the timely delivery of the 
project,  due  to  financial  resource  constraints.  No  mitigation  measures  have  been 
implemented, as timely deployment depends on securing additional funding. 

DE  informed  that  the  NIS  upgrade  was  deployed  on  06/03/2021.  Additionally,  DE 
indicated that the upgrade was implemented as part of major release of the national IT-
System  ATLAS  (Release 9.1),  which  ensures  all  data  requirements  from  Annex  B  are 
covered. 

DK  reported  that  the  NIS  upgrade  was  deployed  on  07/06/2025.  Delays  occurred  as 
priority was given to the export and transit systems. DK also delayed the go-live to ensure 
quality  and  usability  for  its  EOs.  To  decrease  delays,  DK  implemented  parallel 
development  and  testing,  increased  project  resources,  and  is  actively  working  with  its 
vendor to ensure timely delivery of other MASP-C initiatives scheduled for 2025. 

EE 

EE informed that the NIS upgrade was deployed on 01/07/2021.  

ES 

ES shared that the NIS upgrade was deployed on 05/09/2023. Additionally, ES noted that 
the system currently is in the migration window for EOs and plans to be fully operational 
on 14/10/2025.   

FI 

FI informed that the NIS upgrade was deployed in Q4 2019.  

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

48 

 
 
 
 
MS 

Additional Comments 

FR 

FR reported that the NIS upgrade was deployed on 26/11/2024. 

GR 

GR informed that the NIS upgrade was deployed on 06/08/2024. 

HR 

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

HU 

HU informed that the NIS upgrade was deployed on 12/10/2023.  

IE 

IE reported that the NIS upgrade was deployed on 23/11/2020 but noted that the system 
upgrade, from the original Annex B (EUCDM 5) to the revised Annex B (EUCDM 6), 
will  be  deployed  concurrently  with  the  full  CCI  system  (CCI-P1  and  CCI-P2)  on 
31/12/2025.   

IT 

IT shared that the NIS upgrade was deployed on 01/07/2021. 

LT 

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

LU 

LU informed that the NIS upgrade was deployed on 02/05/2023. 

LV 

LV shared that the NIS upgrade was deployed on 03/06/2018.  

MT 

MT reported that the NIS upgrade was deployed on 24/03/2025. 

NL 

PL 

PT 

NL informed that the NIS upgrade was deployed on 01/04/2022 but noted a delay, since 
the EOs have required more time to transition to the new system (Entry In the Declarant’s 
Records  [EIDR]).  NL  will  depreciate  and  remove  the  old  application,  but  anticipates 
minimal impact on EOs as they have all the specifications needed to transfer to the new 
system by Q2 2025. 

PL reported that the NIS upgrade was deployed on 20/04/2025, with full functionalities 
operational  on  19/06/2025.  Delays  were  attributed  to  staff  shortages  and  the  limited 
readiness of EOs. During the transition, the legacy NIS was used with a temporary data 
model incorporating import functionality. The delay also provided EOs with additional 
time to adapt to the upgrade. 

PT  reported  that  the  NIS  upgrade  is  delayed  beyond  the  UCC  WP  deadline,  with 
deployment expected on 30/09/2025. PT attributed a high-risk level to the timely delivery 
of the project, with delays stemming from the strong interdependencies among national 
systems, which complicated the development of the NIS. PT noted that the project was 
particularly  complex,  as  it  involved  creating  an  entirely  new  import  system  requiring 
integration  with  various  national  and  EU  systems.  To  address  these  challenges,  PT 
adopted  Agile  development  to  shorten the  implementation timeframe  and  enhanced its 
planning processes. 

RO 

RO informed that deployment of the NIS upgrade is expected on 30/08/2025. 

SE 

SE shared that the NIS upgrade was deployed on 15/03/2022.  

SI 

SI reported that the NIS upgrade was deployed on 01/01/2022. 

49 

 
 
MS 

SK 

Additional Comments 

SK reported that the deployment of the NIS project is delayed beyond the legal deadline, 
as SK plans to be fully aligned with Annex B by  30/09/2025. However, a NIS version 
aligned with Annex D is currently operational and was deployed in 2016. SK shared that 
the delay occurred due to issues with procurement, lack of human resources and the scale 
of the project. SK has assigned the highest priority to the NIS project, which will be done 
in  concert  with  CCI-P1  &  CCI-P2,  but  has  noted  that  other  projects  are  subsequently 
having delays as most of the human resources have been assigned to NIS. Additionally, 
SK informed that it switched from CCI-P1 to CCI-P2 technical specifications during 2024, 
which caused further delays on the NIS project.  

Table 16: Detailed responses from Member States – NIS Upgrade 

Figure 2441 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 24: Project progress and status per milestone – NIS Upgrade 

41 The information shared by IE, PL, and SK corresponds to a further upgrade of NIS, but the system is already 
deployed. Additionally, ‘Deployment’ encompasses both deployment and operations milestones. 

50 

 
 
 
 
 
 
 
 
3.2.2 Overview of Project Progress 

Figure 25 highlights any divergences in the Member States’ National Planning compared to the dates 
set in the UCC and/or the granted derogation deadline42 as well as the specific dates of each milestone. 
As this project has a deployment window, the deployment and operations milestones are shown. Any 
difference between these two dates indicates that a migration period is planned. 

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

The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/237, granting a 
derogation  to  AT,  BE,  CY,  CZ,  DK,  ES,  FR,  GR,  HU,  LT,  LU,  MT,  NL,  PT,  RO,  and  SE  from 
01/01/2023 until the deployment of the NIS system, but not later than 31/12/2023. Additionally, where 
Article 2(4a) of Commission Delegated Regulation (EU) 2015/2446 applies, Member States had until 
01/07/2024 to deploy the system. 

42 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/237, granting a derogation 
to  AT,  BE,  CY,  CZ,  DK,  ES,  FR,  GR,  HU,  LT,  LU,  MT,  NL,  PT,  RO,  and  SE  from  01/01/2023  until  the 
deployment of the NIS system, but not later than 31/12/2023. Additionally, where Article 2(4a) of Commission 
Delegated Regulation (EU) 2015/2446 applies, Member States had until 01/07/2024 to deploy the system. 

51 

 
 
 
 
 
Figure 25: Actual/Planned dates per milestone – NIS Upgrade  

52 

 
 
 
 
 
3.3 UCC SPECIAL PROCEDURES – COMPONENT 1 (SP EXP) 

This project aims to accelerate, facilitate, and harmonise Special Procedures (SP) across the Union, by 
means of providing common Business Process Models (BPMs). The national systems will implement 
all  the  UCC  changes  required  for  all  SP  (customs  warehousing,  end-use,  temporary  admission,  and 
inward/outward processing). It is noteworthy that, in many Member States, the implementation of this 
project occurs within the context of the upgrades to AES. 

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

Component  1  is  the  national  SP  EXP  with  the  view  to  providing  the  required  national  electronic 
solutions for the export-related special procedure activities. The implementation of SP EXP will occur 
through the AES upgrade project. Therefore, the information provided for under the AES project also 
applies in this context. 

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

3.3.1 Summary of Responses 

Summary from the Member States: 

Most Member States have successfully deployed the SP EXP system. A few reported that its close link 
with  AES  affected  the  timing  of  deployment  or  operations,  with  interdependencies  across  national 
systems  causing  cascading  delays  in  AES  development.  However,  the  implementation  of  Agile 
methodologies by Member States was noted to have reduced implementation delays.  

From the information shared, the following Member States reported the system as deployed: AT, BE, 
BG, CY, CZ, DE, DK, EE, ES, FI, HR, HU, IE, IT, LT, LU, LV, NL, PL, RO, SE, SI and SK. FR, GR, 
MT and PT have indicated that the project is delayed beyond the UCC WP deadline, but aim to deploy 
the system before the end of 2025.  

Detailed Responses: 

Table 17 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

Additional Comments 

AT 

AT informed that the SP EXP system was deployed on 26/01/2025. 

BE 

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

BG 

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

CY 

CY reported that the SP EXP system has been deployed since 18/12/2023.  

CZ 

CZ shared that the SP EXP system was deployed on 01/10/2023.  

DE 

DE  informed  that  the  SP  EXP  system  has  been  deployed  since  06/03/2021  and  was 
implemented in line with AES.  

DK 

DK reported that the SP EXP system has been deployed since 29/07/2023.  

EE 

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

ES 

ES shared that the SP EXP system has been deployed since 18/10/2022. 

53 

 
 
MS 

Additional Comments 

FI 

FI reported that the SP EXP system was deployed on 05/11/2024.  

FR 

FR informed that deployment of the SP EXP system is expected on 15/10/2025. 

GR 

GR shared that deployment of the SP EXP system is expected on 01/12/2025 and will be 
developed within the AES framework. 

HR 

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

HU shared that the SP EXP system was deployed on 06/05/2025. However, HU reported 
a  delay,  given  that  all  related  components  and  functionalities  are  part  of  the  HU-AES 
system, which is still under development and expected to be operational by the end of Q3 
2025. 

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

IT reported that the SP EXP system has been deployed since 08/06/2023. 

HU 

IE 

IT 

LT 

LT shared that the SP EXP system was deployed on 03/12/2023.   

LU 

LU reported that the SP EXP system has been deployed since 08/07/2024.  

LV 

LV shared that the SP EXP system has been deployed since 10/10/2023, alongside AES.  

MT 

MT informed that deployment of the SP EXP system is expected on 21/07/2025. 

NL 

NL reported that the SP EXP system has been deployed since 01/04/2022.  

PL 

PT 

PL reported that the SP EXP system was deployed on 01/07/2021. Following analytical 
work  on  the  UCC  SP  conducted  in  2024,  additional functionalities  were  identified  for 
integration into the Special Procedures Settlement (RPS) system. This implementation is 
ongoing between 2024 and 2025. 

PT  reported  that  the  SP  EXP  project  is  delayed  beyond  the  legal  deadline,  with 
deployment  planned  for  01/11/2025.  PT  attributed 
the  strong 
interdependencies among national systems, which complicated the development of AES. 
PT noted that the project was particularly complex, as it involved creating an entirely new 
export  system  requiring  integration  with  various  national  and  EU  systems.  To  address 
these  challenges,  PT  adopted  Agile  development  to  shorten  the  implementation 
timeframe, enhance its planning processes and adjust the scheduling of training activities.  

the  delays 

to 

RO 

RO informed that the SP EXP system was deployed on 16/03/2024. 

SE 

SE shared that the SP EXP system has been deployed since 01/10/2024.  

SI 

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

SK 

SK informed that the SP EXP system was deployed on 01/11/2024 and was developed as 
part of the AES system.   

Table 17: Detailed responses from Member States – SP EXP 

54 

 
 
Figure 26 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 26: Project progress and status per milestone – SP EXP 

55 

 
 
 
 
 
 
3.3.2 Overview of Project Progress 

Figure  27  highlights  any  known  divergences  in  the  Member  States’  National  Planning  of  SP  EXP 
compared to the dates set in the UCC WP, along with the specific dates of each milestone. As this project 
has  a  deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference 
between these two dates indicates that a migration period is planned.  

Regarding the implementation of UCC Special Procedures – Component 1 (SP EXP), the following 
Member States have a planned/actual operations date that is later than the deadline in the UCC WP: AT, 
FR, GR, HU, MT and PT. In addition, BE did not provide information on the operations date through 
its National Planning. 

56 

 
 
Figure 27: Actual/Planned dates per milestone – SP EXP  

57 

 
 
 
 
3.4 UCC SPECIAL PROCEDURES – COMPONENT 2 (SP IMP) 

This national project aims to accelerate, facilitate, and harmonise Special Procedures (SP) across the 
Union,  by  means  of  providing  common  BPMs.  The  national  systems  will  implement  all  the  UCC 
changes  required  for  all  the  SP  (customs  warehousing,  end-use,  temporary  admission,  and 
inward/outward processing). It is noteworthy that, in many Member States, the implementation of this 
project occurs within the context of the upgrades to NIS. 

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

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

Component 2 is the national SP IMP with the view to provide the required national electronic solutions 
for the import-related SP activities. The implementation of SP IMP will occur through the NIS upgrade 
project. Therefore, the information provided for under this project also applies in this context. 

3.4.1 Summary of Responses 

Summary from the Member States: 

Most  Member  States  have  successfully  deployed  the  SP  IMP  system.  However,  some  assessed  the 
system  as  medium-to-high  risk  due  to  deployment  delays  extending  beyond  the  UCC  WP  deadline. 
Reported causes include financial and procurement issues, complex interdependencies between core and 
supporting systems, and the parallel replacement of related systems. Additional delays stemmed from 
coordination challenges with contractors, limited human resources, EO readiness, integration with the 
NIS system, unresolved public tenders, and ongoing negotiations with software providers. 

To  address  these  delays,  Member  States  indicated  the  implementation  of  measures  such  as  Agile 
development, parallel development and testing, and joint deployment with NIS. Further actions included 
enhanced  project  management,  resource  reallocation,  and  increased  support  for  EOs  to  maintain 
deployment timelines. 

At the time of writing, the following Member States indicated the system as deployed: BE, BG, CY, 
DE, DK, EE, ES, FI, FR, GR, HR, HU, IE, IT, LT, LU, LV, MT, NL, PL, SE, SI and SK. Meanwhile, 
AT,  CZ,  PT  and  RO,  reported  that  the  development  of  the  system  is  delayed  beyond  the  UCC  WP 
deadline, with only CZ planning to deploy after 2025.  

Important remark: 

Several Member States submitted a written notification to DG TAXUD, asking for a derogation under 
Article 6(4) of the UCC, considering the delay of SP IMP beyond the deadline of 31 December 2022. 
The derogation requests from the Member States were assessed by the Commission services in terms of 
the justifications provided for the specific situations of the Member States requesting it and in view of 
a set of common assessment criteria. 

In this light the Commission adopted an Implementing Decision (EU) 2023/23743, granting a derogation 
to AT, BG, CY, CZ, DK, ES, FR, GR, HU, LT, LU, MT, NL, PT, RO, and SE for the SP IMP system 
to  use  means  other  than  electronic  data-processing  techniques  for  the  exchange  and  storage  of 
information. The derogation applied from 1 January 2023 until the deployment of the SP IMP system, 
but  not  later  than  31  December  2023.  Additionally,  where  Article  2(4a)  of  Commission  Delegated 
Regulation (EU) 2015/2446 applies, Member States had until 01/07/2024 to deploy the system. 

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

58 

 
 
 
 
Detailed Responses: 

Table 18 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

Additional Comments 

AT reported that the SP IMP project is delayed beyond the UCC WP deadline but aims to 
deploy the system on 01/11/2025. AT attributed a medium risk to the timely delivery of 
the project, due to delays with the internal developments and the finalisation of the public 
tender  (pending  the  conclusion  of  negotiations  with  the  software  provider  and  the 
Commission). Additionally, AT plans to deploy SP IMP alongside the upgrade of NIS, 
instead of with CCI-P2 in order to reduce delays and deploy before the end of 2025.    

BE 

BE reported that the SP IMP system was deployed on 28/08/2024. 

BG 

BG reported that the SP IMP system has been deployed as of 10/11/2023. 

CY 

Same response as for AN.  

CZ 

DE 

CZ reported that the SP IMP project is delayed beyond the legal deadline but plans for the 
system to be deployed on 18/05/2026. CZ attributed a high-risk level to the timely delivery 
of the project, citing financial resourcing issues as the main cause of delay.  

DE  informed  that  the  SP  IMP  system  was  deployed  on  06/03/2021  Additionally,  it 
indicated that upgrade was implemented as part of major release of the national IT-System 
ATLAS (Release 9.1). 

DK 

Same response as for TS.  

EE 

EE shared that the SP IMP system was deployed on 01/07/2021.  

ES 

ES shared that the SP IMP system was deployed on 05/09/2023. Additionally, ES noted 
that it currently is in the migration window for EOs and plans to be fully operational on 
14/10/2025.   

FI 

FI reported that the SP IMP system was deployed in Q4 2022.  

FR 

FR informed that the SP IMP system has been deployed since 26/11/2024.  

GR 

GR reported that the SP IMP system was deployed on 06/08/2024. 

HR 

HR shared that SP IMP was deployed on 01/01/2023, as part of the new import system.  

HU 

IE 

IT 

HU  reported  that  the  SP  IMP  system  was  deployed  on  12/10/2023.  Additionally,  HU 
shared that the developments were implemented within the NIS framework.  

IE informed that the SP IMP system was deployed on 23/11/2020 and will be updated to 
the revised Annex B in Q1 2026.  

IT reported that the SP IMP system has been deployed since 01/07/2021. 

LT 

LT reported that the SM IMP system was deployed on 31/12/2023. 

59 

 
 
 
MS 

Additional Comments 

LU 

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

LV 

LV reported that the SP IMP system was deployed on 03/06/2018.  

MT 

MT informed that the SP IMP system was deployed on 24/03/2025.  

NL 

NL reported that the SP IMP system was deployed on 01/04/2022.  

PL 

Same response as SP EXP. 

PT 

Same response as NIS.   

RO 

RO reported that deployment of the SP IMP system is expected on 30/08/2025. 

SE 

SE shared that the SP IMP system has been deployed since 23/02/2023. Additionally, SE 
noted that an update from the ‘current’ Annex B to the ‘new’ Annex B will be performed 
for the customs warehousing procedure.   

SI 

SI reported that the SP IMP system was deployed on 01/01/2022. 

SK 

SK  reported  that  the  SP  IMP  system  was  deployed  on  11/06/2016.  Additionally,  SK 
shared that the system is being remade within the NIS upgrade to be aligned with Annex 
B.  

Table 18: Detailed responses from Member States – SP IMP 

Figure 2844 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 28: Project progress and status per milestone – SP IMP 

44 ‘Deployment’ encompasses both deployment and operations milestones. 

60 

 
 
 
 
 
 
 
3.4.2 Overview of Project Progress 

Figure  29  highlights  any  known  divergences  in  the  Member  States’  National  Planning  of  SP  IMP 
compared to the dates set in the UCC and/or the granted derogation deadline45, along with the specific 
dates  of  each  milestone.  As  this  project  has  a  deployment  window,  the  deployment  and  operations 
milestones  are  shown.  Any  difference  between  these  two  dates  indicates  that  a  migration  period  is 
planned. 

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

45 The Commission adopted on 1 February 2023 an Implementing Decision (EU) 2023/237, granting a derogation 
to  AT,  BG,  CY,  CZ,  DK,  ES,  FR,  GR,  HU,  LT,  LU,  MT,  NL,  PT,  RO,  and  SE  from  01/01/2023  until  the 
deployment of the SP IMP system, but not later than 31/12/2023. Additionally, where Article 2(4a) of Commission 
Delegated Regulation (EU) 2015/2446 applies, Member States had until 01/07/2024 to deploy the system. 

61 

 
 
 
 
Figure 29: Actual/Planned dates per milestone – SP IMP  

62 

 
 
 
 
3.5 UCC GUARANTEE MANAGEMENT (GUM) – COMPONENT 2 

The UCC Guarantee Management (GUM) project assures the effective and efficient management of the 
different types of guarantees. A guarantee is the financial cover for customs duties and other charges. 

The UCC GUM system is comprised of two components.  

For Component 1 (GUM-C1), please refer to Section 2.10. 

Component 2 (GUM-C2) refers to the national Guarantee Management systems, meaning the guarantee 
management  system  that  each  Member  States  deploys  individually,  but  in  line  with  the  GUM 
requirements. These national guarantee management systems are e.g. used for the management of the 
guarantees and the monitoring of the reference amount. The deadline for the deployment of GUM 2 
systems was 2 June 2025. 

3.5.1 Summary of Responses 

Summary from the Member States:  

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

Some Member  States  have  already  implemented  GUM-C2,  though  several  Member  States  have  still 
reported a risk for on-time delivery. Key risk factors include the parallel deployment and, in some cases, 
prioritisation of other major systems such as NCTS, AES, CCI, and NIS;  limited personnel, and the 
simultaneous replacement or upgrade of support systems like the Customer Reference Services (CRS). 
Additional delays were linked to internal development timelines, procurement, and the finalisation of 
public tenders. 

To mitigate these risks, Member States applied corrective actions in project management and budgeting, 
improved  interdepartmental  coordination,  and  gave  GUM-C2  higher  prioritisation  than  in  previous 
years. In some cases, it was deployed in parallel with NIS and CCI-P2 to minimise further delays. 

At the time of writing, the following Member States have joined operations: BE, BG, CZ, EE, ES, FI, 
IE, LT, LU, LV, NL, PL, SE, SI and SK. Additionally, AT, CY, DE, DK, FR, GR, HR, HU, IT, MT, PT 
and  RO  have  reported  delays  beyond  the  UCC  WP  deadline,  with  FR,  GR  and  HR  expected  to  go 
operational after 2025.  

Detailed Responses:  

Table 19 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

Additional Comments 

AT reported that the GUM-C2 project is delayed beyond the UCC WP deadline but aims 
to have the system operational on 14/12/2025. AT attributed a medium risk of delay to the 
timely  delivery  of  the  project,  due  to  delays  with  the  internal  developments  and  the 
finalisation of the public tender (pending the conclusion of negotiations with the software 
provider and the Commission). AT noted that GUM-C2 will be implemented alongside 
the NIS update, in order to reduce delays and deploy before the end of 2025. 

BE 

BE shared that the GUM-C2 system joined operations on 15/06/2025. 

BG 

BG reported that the GUM-C2 system became operational on 23/04/2025.  

CY 

CY reported that the GUM-C2 is delayed beyond the UCC WP deadline, with the start of 
operations  expected  on  31/12/2025.  CY  attributed  a  high  level  of  risk  to  the  timely 
delivery  of  the  project,  noting  that  deployment  was  delayed  due  procurement  issues, 

63 

 
 
MS 

Additional Comments 

interdependencies  between  systems,  parallel  upgrades  of  supporting  systems,  limited 
human resources, and delays in other dependent systems. To address these challenges, CY 
implemented corrective measures in project management, resource allocation, and support 
for EOs. 

CZ 

CZ shared that the GUM-C2 system was deployed and became operational on 01/01/2025. 

DE 

DK 

EE 

ES 

FI 

FR 

DE  informed  that  the  start  of  operations  of  the  GUM-C2  system  is  expected  on 
15/11/2025. 

DK reported that the GUM-C2 project is delayed beyond the legal deadline, but aims for 
the system to become operational on 27/09/2025. DK attributed a high risk to the timely 
delivery  of  the  project,  noting  GUM-C2  has  been  delayed  so  as  to  prioritise  the 
deployment of its national import system.  

EE  informed  that  the  GUM-C2  system  was  deployed  on  09/06/2024  and  became 
operational on 09/06/2025. 

ES  indicated  that  the  GUM-C2  system  was  deployed  on  01/09/2016  and  has  been  in 
operations since 01/05/2019. 

FI shared that the GUM-C2 functionalities linked with NCTS were deployed in Q4 2024 
while the remaining functionalities became operational on 24/05/2025.  

FR  reported  that  the  GUM-C2  project  is  delayed  beyond  the  legal  deadline,  with 
deployment and operations planned for 30/03/2026. FR assessed a medium risk for timely 
implementation, citing the prioritisation of the CCI project in 2025 and reliance on third-
party suppliers as key causes of delay. To mitigate further setbacks and budget overruns, 
a detailed 2025–2026 timeline has been developed, new contractors have been engaged, 
and  project  milestones  have  been  adjusted  to  reflect  evolving  national  priorities  and 
stakeholder needs. 

GR 

GR informed that the start of operations of the GUM-C2 system is expected in Q2 2026.  

HR 

HU 

IE 

IT 

LT 

HR reported that the GUM-C2 project is delayed beyond the UC WPP deadline, with the 
start  of  operations  expected  on  31/03/2026.  HR  shared  that  the  implementation  was 
delayed  due  to  the  parallel  development  of  other  systems.  In  the  interim,  the  existing 
system is being used to maintain continuous monitoring of guarantees. 

HU informed that the GUM-C2 project is delayed beyond the UC WPP deadline, with the 
system expected to become operational on 17/11/2025. HU attributed a medium level of 
risk  to  the  timely  delivery  of  the  system,  sharing  the  delays  are  due  to  the  parallel 
deployment of multiple systems and constraints in available personnel. In order to mitigate 
the  delays,  HU  held  consultations  with  the  IT  department  to  prioritise  the  project  and 
enhance cooperation between technical and professional teams. 

IE informed that the GUM-C2 system has been operational since 05/10/2021.   

IT shared that the GUM-C2 system is expected to become operational on 17/11/2025. 

LT  reported  that  the  GUM-C2  system  was  deployed  on  16/11/2022  and  has  been 
operational since 20/03/2023. 

LU 

LU shared that the GUM-C2 system became operational on 02/06/2025.  

64 

 
 
MS 

Additional Comments 

LV 

LV informed that the GUM-C2 system started operations on 04/06/2018.  

MT 

MT reported that the GUM-C2 system is expected to start operations on 12/12/2025. 

NL 

NL shared that the GUM-C2 system became operational on 01/06/2025.  

PL 

PL reported that the GUM-C2 system joined operations on 02/06/2025. 

PT 

PT informed that the GUM-C2 system is expected to become operational on 01/10/2025. 

RO 

RO shared that the GUM-C2 system is expected to start operations on 30/08/2025. 

SE 

SE reported that the GUM-C2 system has been operational since 17/04/2021.  

SI 

SI shared that the GUM-C2 system joined operations on 01/06/2025.  

SK 

SK reported that the GUM-C2 system became operational on 02/06/2025. 

Table 19: Detailed responses from Member States – GUM-C2 

Figure 30 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 30: Project progress and status per milestone – GUM-C2 

65 

 
 
 
 
 
 
3.5.2 Overview of Project Progress 

Figure 31 highlights any known divergences in the Member States’ National Planning compared to the 
dates set in the UCC WP. As this project has a deployment window, the deployment and operations 
milestones  are  shown.  Any  difference  between  these  two  dates  indicates  that  a  migration  period  is 
planned.  

With regards to the implementation of the national UCC Guarantee Management (GUM-C2), AT, BE, 
CY, DE, DK, EE, FR, GR, HR, HU, IT, MT, PT and RO indicated a planned/actual operations date that 
is later than the deadline in the UCC WP.  

66 

 
 
Figure 31: Actual/Planned dates per milestone – GUM-C2 

67 

 
 
 
 
3.6 UCC CENTRALISED CLEARANCE FOR IMPORT (CCI) 

The UCC Centralised Clearance for Import (CCI) project aims to allow for goods to be placed under a 
customs  procedure  using  centralised  clearance,  enabling  the  EOs  to  centralise  their  business  from  a 
customs point of view.  The processing of the customs declaration and the physical release of the goods 
will be coordinated between the involved customs offices, both of which operate as part of one customs 
administration, although they are situated in different Member States. 

The implementation of CCI through a new trans-European system will strengthen trade facilitation. It 
will enable EOs to centralise their import activities and reduce interactions with customs by only using 
a  single  customs  office  (supervising  customs  office),  acting  as  a  one-stop  shop  in  the  EU.  The 
modernised  and  harmonised  UCC  CCI  customs  system  enables  customs  declaration  processing  and 
physical release of goods electronically and in a seamless, predictable and coordinated way among the 
customs  offices  located  in different Member  States.  In  addition,  the  new  CCI  system  will  introduce 
harmonisation and standardisation of processes and electronic exchange of information across the Union 
for  centralised  clearance  at  import.  It  is  also  expected  to  reduce  the  administrative  burden  for  the 
Customs Administration with automated processes and to allow tax authorities to have better supervision 
and control on the collection of import Value Added Tax (VAT). 

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

Phase 1 (CCI-P1) covers the combination of centralised clearance with standard customs declarations 
and  may  also  cover  simplified  customs  declarations  and  related  supplementary  declarations,  which 
regularise one simplified customs declaration. In addition, this phase covers the placing of goods under 
the following customs procedures: release for free circulation, customs warehousing, inward processing 
and end-use. Regarding the types of goods involved, this phase will cover all types of goods except for 
excise goods and goods subject to Common Agricultural Policy (CAP) measures.  

Phase 2 (CCI-P2) covers the functionalities that are not part of CCI-P1, namely: 

•  The combination of centralised clearance with customs declarations through an Entry in the 
Declarant's Records and related supplementary declarations, including the recapitulative 
declaration; 

•  Supplementary declarations regularising more than one simplified customs declaration; 

•  The placing of goods under the temporary admission procedure; 

•  Goods subject to CAP measures and excise goods; 

•  Goods in the context of trade with special fiscal territories; 

•  The communication of supporting/additional documents between the related customs offices.  

3.6.1 Summary of Responses 

CCI – Phase 1 (CCI-P1) 

Summary from the Commission: 

The introduction of the EU CCI system, the first trans-European system for import formalities, required 
a fresh approach by adopting the new network architecture Common Communications Network 2nd 
Generation (CCN2ng) and Common Reference Architecture (CoRA). This involved the redefinition of 
specifications  and  effective  communication  with  the  Member  States.  The  Commission  is  diligently 
monitoring  the  progress  of  other  key  projects  to  ensure  alignment  with  the  new  infrastructure.  The 
coordination of multiple project teams has proven crucial for synchronising all activities. 

68 

 
 
As regards the Commission, the technical system specifications (TSS) for CCI-P1 were completed in 
2020, and the conformance testing environment was assured for the Member States well in advance 
before the end date of the deployment window for the first phase of the system. 

The  Commission  is  adopting  a new iterative approach,  introduced in  2023  within the  UCC  WP and 
MASP-C revision, to address Member States' reported delays and ease the transition between CCI-P1 
and CCI-P2. This approach allows for the prioritisation of CCI-P1 with standard declarations and the 
freedom to choose the message type CCI-P1 or CCI-P2, providing flexibility for other combinations of 
CCI-P1 (such as simplified and supplementary declarations in the first phase) and ensures an extended 
deadline for CCI-P1 by seven months until 1 July 2024. To simplify the process, additional facilitation 
is  provided  by  enabling  the  implementation  of  CCI-P1  functionalities  using  CCI-P2  Full  Scope 
specifications (i.e., the ones also supporting the functionalities of the CCI-P1 system), removing the 
need for a transition from CCI-P1 to CCI P2. Furthermore, to facilitate the Member States, DG TAXUD 
developed a consolidated CCI-P2 (Full) Scope TSS package that consolidates the specifications for both 
phases, offering a single package that covers all CCI scenarios and processes. A corresponding guide 
has been provided to assist Member States and traders in effectively implementing both phases using 
this package. 

A medium risk level has been noted due to the dependency of conformance testing and deployment on 
the actions of the Member States. To mitigate risks efficiently, the Commission is closely monitoring 
and coordinating activities with a dedicated team managing the conformance testing environment. The 
Conformance Test Application (CTA) system is accessible in the conformance environment, facilitating 
CCI-P1 conformance testing activities through the CCN2ng exchange platform. DG TAXUD carries 
out a close monitoring on the Member States’ CCI (P1 and P2) national project planning, organisational, 
development, connectivity set-up, the conformance testing, deployment, and entry in operations of CCI-
P1 and CCI-P2. Monitoring of Member States’ CCI activities, including integration with NIS and other 
national systems, takes place, while assistance is provided where needed. Regular meetings are held for 
the synchronisation of the planned CCI-related activities, weekly and bi-weekly technical meetings for 
the status progress, feedback sessions for the execution of the conformance testing. DG TAXUD will 
continue the close technical support to the Member States, while monitoring the progress according to 
the deployment plan for CCI. In this context, DG TAXUD initiated issuing quarterly reports in Q1 2024 
for monitoring UCC CCI system deployment, releasing six reports in total by June 2025. 

By  the  1  July  2024  deadline,  eight  Member  States  (BG,  EE,  ES,  LU,  LV,  LT,  PL  and  RO)  had 
successfully deployed the CCI-P1 system, while HR and IT deployed later in 2024, on 30 September 
and  8  November  respectively.  An  additional  seven  Member  States  deployed  by  June  2025.  The 
remaining Member States have reported deployment dates ranging from the end of 2025 to Q3 2026.  

Overall, there is reassurance that most of them will meet the final deployment milestone of the CCI Full 
(P1 and P2) system by 31 December 2025, as required under Article 278(3) of the UCC. Some MSs 
(BE, FR, PL and PT) plan to deploy CCI-P1 by the end of 2025, with CCI-P2 scheduled for Q2 2026. 
FI and SE will  deploy the CCI  full system by the end of 2025 but will  delay certain functionalities, 
targeting Q2 2026 and Q3 2026 respectively. Finally, there are four Member States that plan to delay 
the CCI full system implementation until 2026: CZ and GR expect to deploy the full system by Q2 2026, 
while NL and HU aim for Q3 2026. 

Summary from the Member States: 

Less than half of the Member States have completed the CCI-P1 project. Among those still in progress, 
most reported a medium to high risk of delayed delivery. The main causes of delay included procurement 
and funding issues, limited supplier capacity, and the need to finalise public tenders. Further challenges 
were linked to the complexity of integrating national and EU systems, interdependencies between core 
and supporting systems, technical limitations of existing national applications. Delays in deploying the 
NIS upgrade and the parallel rollout of other major UCC projects in 2025, such as NCTS and AES, also 
strained human and technical resources. 

To  mitigate  these  delays,  Member  States  implemented  phased  rollouts,  adopted  Agile  development 
methods,  and  prioritised  the  project  nationally.  Additional  measures  included  reinforcing  project 

69 

 
 
management, reallocating resources, and engaging in high-level negotiations with suppliers to improve 
planning and oversight. 

The above summary also applies to CCI-P2. 

In terms of assessing the level of completeness of the system, BG, EE, ES, HR, IT, LT, LU, LV, PL, 
RO, and SE reported the project as completed. AT, BE, CY, CZ, DE, DK, FI, FR, GR, HU, IE, MT, NL, 
PT, SI and SK shared that the project is delayed beyond the UCC WP deployment deadline, with CZ, 
DE, GR, HU, NL and SK expected to go operational after 2025  

Detailed Responses: 

Table 20 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

Additional Comments 

AT  reported that  the  CCI-P1  project  is  delayed  beyond  the  legal deadline, however,  it 
aims to have the system operational on 14/12/2025. AT attributed a medium risk of delay 
to the timely delivery of the project, due to delays with the internal developments and the 
finalisation of the public tender (pending the conclusion of negotiations with the software 
provider and the Commission). AT noted that CCI-P1 will be implemented alongside CCI-
P2 in order to reduce delays and deploy before the end of 2025.  

BE 

BE plans to have the CCI-P1 system operational on 15/10/2025. 

BG 

CY 

CZ 

DE 

DK 

BG  shared  that  the  CCI-P1  system  began  operations  on  15/01/2024.  Additionally,  BG 
added that the system functionalities are aligned with NIS, which was upgraded according 
to the new Annex B requirements.  

CY aims to have the CCI-P1 system operational on 29/09/2025. CY reported the delays 
are due to several factors, including procurement challenges, interdependencies between 
core  and  supporting  systems,  parallel  upgrades,  contractor  coordination  issues,  limited 
human resources, and the readiness of their EOs. Additional delays stem from the late 
deployment  of  other  systems  critical  to  the  CCI  project.  To  mitigate  these  issues,  CY 
applied  corrective  measures  in  project  management  and  resourcing,  and  reinforced 
support for EOs, which will help reduce the overall delay. 

CZ reported that the CCI-P1 project is delayed beyond the legal deadline, with operations 
planned for 18/05/2026. A high level of risk was attributed to the timely delivery of the 
project, primarily due to financial resource constraints. CZ plans to develop and deploy 
CCI-P1 and CCI-P2 simultaneously. 

DE noted that the CCI-P1 project is delayed beyond the legal deadline, with operations 
planned for 28/02/2026. The delay was attributed to the need to implement the second 
stage of the VAT package for eCommerce and adjustments related to Brexit. To mitigate 
this, DE established a new expert group with additional staff and budget. Both Phase 1 
and Phase 2 are planned for joint deployment. 

DK reported that the CCI-P1 project is delayed beyond the legal deadline, but it plans for 
the system to join operations on 27/09/2025. DK attributed a medium risk to the timely 
delivery of the project, noting that the deployment of CCI is dependent on the rollout of 
the national import system.  

EE 

EE shared that the CCI-P1 system started operations on 09/06/2024.  

ES 

ES reported that the CCI-P1 system joined operations on 03/10/2022. Additionally, ES 
informed that the system was built and integrated with the NIS. 

70 

 
 
MS 

FI 

FR 

Additional Comments 

FI informed that the CCI-P1 project is delayed beyond the UCC WP deadline but aims to 
have the system operational on 22/11/2025. FI attributed the delays to a lack of supplier 
resources but shared that it held management level negotiations with the supplier and has 
focused on project planning and progress monitoring to mitigate the delay.  

FR reported that the CCI-P1 project is delayed beyond the legal deadline, with operations 
planned  for  15/12/2025.  The  delay  was  attributed  to  the  prioritisation  of  the  national 
import system. To mitigate the delay, FR has divided the implementation into two steps. 
Step 1, to be completed by the end of 2025, will cover customs declaration submission 
upon presentation, invalidation, and amendment in Presentation Customs Office (PCI) for 
procedures 40 00 and 42 00. Step 2 is planned to cover the remaining functionalities and 
go into operations on 30/06/2026. 

GR 

GR plans to start operations for both CCI-P1 and CCI-P2 on 30/06/2026. 

HR 

HR reported that the CCI-P1 system has been operational since 30/09/2024. 

HU 

IE 

HU reported that the CCI-P1 project is delayed beyond the legal deadline and aims to have 
the system operational on 30/09/2026. A medium level of risk was attributed to the timely 
delivery of the project, with delays primarily linked to the parallel deployment of multiple 
systems,  including  AES,  and  limited  human  resources.  Both  Phase  1  and  Phase  2  are 
planned for joint deployment. 

IE  informed  that  the  CCI-P1  project  is  delayed  beyond  the  UCC  WP  deadline,  with 
deployment  and  operations  planned  on  31/12/2025.  IE  attributed  a medium  risk  to  the 
timely delivery of the project, highlighting that technical issues with the existing national 
import applications are being prioritised.  IE reported that the number of UCC  projects 
running simultaneously in 2025 puts significant pressure on limited internal and external 
resources.  IE aims to implement CCI-P1 and CCI-P2 simultaneously. 

IT 

IT reported that the CCI-P1 system became operational on 04/11/2024.  

LT 

LT shared that the CCI-P1 system has been operational since 01/07/2024.  

LU 

LV 

LU indicated that the CCI-P1 system joined operations on 30/06/2024. Additionally, LU 
shared that CCI-P1 was integrated with its NIS and that no EOs are using the system yet.  

LV reported that the CCI-P1 system started operations on 01/07/2024 and that it is part of 
its new national import system.  

MT 

MT aims for the CCI-P1 system to join operations on 31/12/2025. 

NL 

NL informed that the CCI-P1 project is delayed beyond the UCC WP deadline and aims 
for the system to become operations on 01/09/2026. NL attributed a high risk to the timely 
delivery of the project, noting that CCI is a complicated process and that the increased 
integration  of  European  systems  over  the  common  domain  limits  solutions.  NL  also 
highlighted  the  challenges  of  integrating  national  processes  for  managing  the  control 
findings, noting that the supplementary declaration with recapitulative nature combined 
with the use of multiple goods shipment will require major adjustments to the national 
system.  To mitigate the risk, NL aims to implement its national system in multiple phases, 
starting with operations for EIDR, and implementing standard customs declarations and 
simplified declarations at a later date.  

71 

 
 
MS 

PL 

PT 

Additional Comments 

PL shared that the CCI-P1 system has been operational since 01/07/2024. Additionally, 
PL noted that CCI-P1 was implemented as a module of the NIS.  

PT reported that the CCI-P1 project is delayed beyond the legal deadline, with operations 
planned to start on 15/12/2025. A high level of risk was attributed to the timely delivery 
of the project, mainly due to the implementation of the NIS upgrade, which underpins the 
CCI system and requires integration with various national and EU systems. PT noted that 
strong interdependencies among national systems complicated the NIS development but 
stated  that  Agile  methodologies  and  a  revised  plan  were  used  to  shorten  the 
implementation timeframe. 

RO 

RO informed that the CCI-P1 system became operational on 01/07/2024.  

SE 

SE  reported that  the  CCI-P1  system  became  operational  on  02/06/2025,  although  EOs 
have yet to submit an authorisation. Delays were attributed to the prioritisation of other 
UCC IT systems, though SE noted that significant resources were allocated to support the 
implementation of all UCC-related projects. 

SI 

SI plans to have the CCI-P1 system operational on 10/11/2025.  

SK 

SK reported that the CCI-P1 project will be delayed beyond 2025, with operations now 
slated to begin on 01/01/2026, alongside CCI-P2. SK attributed the delay to the parallel 
development of NCTS-P5 and AES as well as the switch from CCI-P1 to CCI-P2 technical 
specifications. In addition, SK noted that this project is being prioritised46. 

Table 20: Detailed responses from Member States – CCI-P1 

Figure 32 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 32: Project progress and status per milestone – CCI-P1 

46 Information provided from a bilateral meeting between SK and DG TAXUD held on 06/03/2025. 

72 

 
 
 
 
 
 
 
 
 
CCI – Phase 2 (CCI-P2) 
Summary from the Commission: 

Please see also the summary from CCI-P1. 

CCI-P2 broadens the scope of the complex matters tackled in CCI-P1, leading to a heightened intricacy 
across multiple project areas. The technical specifications were finalized on 17 June 2022, and the CTA 
system  was  made  available  in  the  conformance  environment  for  Member  States  well  ahead  of  the 
deployment window deadline for the system’s second phase. 

Member States have the flexibility to develop, implement, and deploy CCI-P2 and thus the CCI Full 
system functionalities in multiple iterations using agile approach within the final deployment window 
by 31 December 2025. 

Summary from the Member States: 

Please see also the summary from CCI-P1.  

In  terms  of  assessing  the  level  of  completeness  of  the  system,  the  following  Member  States  have 
completed the CCI-P2 project: BG, EE, ES, HR, LU, LV and RO. AT, BE, CY, CZ, DE, DK, FI, FR, 
GR, HU, IE, IT, LT, MT, NL, PL, PT, SE, SI and SK informed that the project is scheduled to become 
operation  beyond  deployment  deadline,  with  AT,  CY,  DK,  FI,  IE,  LT,  MT  and  SI  aiming  to  go 
operational before the end of 2025.  

Detailed Responses: 

Table 21 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

Additional Comments 

AT reported that the CCI-P2 project is delayed beyond the UCC WP deadline and aims 
for the system to become operational on 14/12/2025. AT attributed a medium risk of delay 
to the timely delivery of the project, due to delays with the internal developments and the 
finalisation of the public tender (pending the conclusion of negotiations with the software 
provider  and  the  Commission).  Additionally,  AT  plans  to  minimise  the  extent  of  the 
delays by prioritising the deployment of CCI-P2 and deploy before the end of 2025. 

BE 

BE aims to have the CCI-P2 system operational on 30/06/2026. 

BG 

CY 

BG shared that the CCI-P2 system became operational on 23/04/2025. Additionally, BG 
added that the system functionalities are aligned with NIS, which was upgraded according 
to the new Annex B requirements. 

CY reported that the CCI-P2 system will begin operations on 29/09/2025 alongside CCI-
P1.  

CZ 

Same response as for CCI-P1.  

DE 

Same response as for CCI-P1.  

DK 

Same response as for CCI-P1.  

EE 

EE reported that the CCI-P2 system started operations on 09/06/2025.  

ES 

ES indicated that the CCI-P2 system became operational on 02/06/2025. Additionally, ES 
shared that the CCI system has been built and integrated with the NIS.   

FI 

FI aims for the CCI-P2 system to join operations on 22/11/2025.  

73 

 
 
MS 

FR 

Additional Comments 

FR reported that the CCI-P2 project is delayed beyond the legal deadline, with operations 
planned for  15/12/2026.  The  delay  was  due to  the  prioritisation  of  the  national import 
system.  To  mitigate  this,  FR  has  allocated  additional  resources  to  improve  planning. 
Technical Specifications are expected to begin by the end of 2025 and be finalised and 
shared by June 2026. 

GR 

GR plans to implement both CCI-P1 and CCI-P2 on 30/06/2026. 

HR 

HR shared that the CCI-P2 system joined operations on 02/06/2025. 

HU 

Same response as CCI-P1. 

IE 

IT 

LT 

LU 

Same response as CCI-P1.  

IT aims for the CCI-P2 systems to join operations on 13/10/2026. 

LT shared that the CCI-P2 project is delayed beyond the legal deadline but aims for the 
system  to  be  in  operation  on  31/12/2025.  LT  noted  that  there  have  been  delays  in  the 
public procurement process due to lack of timely funding and supplier issues. LT aims to 
finalise this process and complete the implementation of CCI-P2 by the end of 2025. In 
addition, LT confirmed that the delays will not affect other Member States as LT has not 
issued any CCI authorisations and isn’t involved in their use as a participating Member 
State.  

LU reported  that the CCI-P2 system  became operational on 02/06/2025, despite issues 
that  were  encountered  during  conformance  testing.  Both  Phase  1  and  Phase  2  were 
implemented together, however, as of yet, no EOs have requested an authorisation.  

LV 

LV informed that the CCI-P2 system joined operations on 02/06/2025.  

MT 

MT aims for the CCI-P2 system to join operations on 31/12/2025.  

NL informed that the CCI-P1 project is delayed beyond the UCC WP deadline and aims 
for the system to become operations on 01/07/2026. NL attributed a high risk to the timely 
delivery of the project, noting that CCI is a complicated process and that the increased 
integration  of  European  systems  over  the  common  domain  limits  solutions.  NL  also 
highlighted  the  challenges  of  integrating  national  processes  for  managing  the  control 
findings, noting that the supplementary declaration with recapitulative nature combined 
with the use of multiple goods shipment will require major adjustments to the national 
system. To mitigate the risk, NL aims to implement its national system in multiple phases, 
starting with operations for EIDR, and implementing standard customs declarations and 
simplified declarations at a later date.  

PL  indicated  that  the  CCI-P2  project  will  be  delayed  beyond  2025,  as  it  aims  for  the 
system to become operational on 01/06/2026. PL attributed a medium risk level to the 
timely  delivery  of  the  project  and  noted  that  the  delay  is  due  to  a  prolonged  public 
procurement procedure. Phase 2 will be developed under a new contract, with tendering 
in  the  preparation  phase.  PL  shared  that  no  mitigation  measures  have  been  taken  but 
assured that EOs can submit import declarations without using centralised clearance.  

NL 

PL 

PT 

PT reported that the CCI-P2 project is delayed beyond the legal deadline but plans for the 
start of operations to begin on 16/11/2026. PT attributed a high level of risk to the timely 

74 

 
 
MS 

Additional Comments 

delivery of the project, citing the challenge posed by the delayed implementation of Excise 
and EIR in the new NIS system forms the basis of the CCI systems and the integration 
with different national and EU systems. PT additionally remarked that the strong inter-
dependencies of various national systems produced some difficulties in the development 
of  the  NIS  as  a  whole  but  that  Agile  development  will  be  used  to  reduce  the 
implementation time-frame.  

RO 

RO shared that the CCI-P2 system became operational on 31/03/2025. 

SE 

SE  informed  that  the  CCI-P2  project  will  be  delayed  beyond  2025,  as  it  aims  for  the 
system to become operational on 01/09/2026. SE indicated that the delays stem from the 
prioritisation of other UCC projects and the complexities of establishing a goods shipment 
level, which is not currently in place. This new level will require extensive changes not 
only in the customs declaration system but also in several surrounding systems, to ensure 
the correct collection of duties and effective risk management. By the end of 2025, SE 
expects to have finalised the majority of the development that is needed for the essential 
functionalities of the goods shipment level.   

SI 

SI aims to have the CCI-P2 system operational on 10/11/2025.  

SK 

SK reported that the CCI-P2 project will be delayed beyond 2025, noting that the system 
will become operational on 01/01/2026, alongside CCI-P1 and the NIS system upgrade. 
SK attributed the delay to the parallel development of other systems, namely NCTS-P5 
and AES as well as the switch from CCI-P1 to CCI-P2 technical specifications.  

Table 21: Detailed responses from Member States – CCI-P2 

Figure 33 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 33: Project progress and status per milestone – CCI-P2 

75 

 
 
 
 
 
 
3.6.2 Overview of Project Progress 

Figure 34 highlights any known divergences in the Member States’ National Planning compared to the 
dates  set  in  the  UCC  WP,  along  with  the  specific  dates  of  each  milestone.  As  this  project  has  a 
deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference  between 
these two dates indicates that a migration period is planned.  

Regarding UCC Centralised Clearance for Import – Phase 1 (CCI-P1), the following Member States 
have a planned/actual operations date that is later than the deadline in the UCC WP: AT, BE, CY, CZ, 
DE, DK, FI, FR, GR, HR, HU, IE, IT, MT, NL, PT, SE, SI, and SK.  

Figure 35 highlights any known divergences in the Member States’ National Planning compared to the 
dates  set  in  the  UCC  WP,  along  with  the  specific  dates  of  each  milestone.  As  this  project  has  a 
deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference  between 
these two dates indicates that a migration period is planned.  

For the implementation of UCC Centralised Clearance for Import – Phase 2 (CCI-P2), the following 
Member States have a planned/actual operations date that is later than the deadline in the UCC WP: AT, 
BE, CY, CZ, DE, DK, EE, FI, FR, GR, HU, IE, IT, LT, MT, NL, PL, PT, SE, SI and SK. 

76 

 
 
 
Figure 34: Actual/Planned dates per milestone – CCI-P1 

77 

 
 
 
Figure 35: Actual/Planned dates per milestone – CCI-P2 

78 

 
 
 
 
3.7 UCC NEW COMPUTERISED TRANSIT SYSTEM (NCTS) UPGRADE – 

COMPONENT 2 

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

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

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

For Component 1 (NCTS-P5), please refer to Section 2.12. 

Component 2 (NCTS-P6) will align NCTS to the new provisions set by the UCC regarding Advanced 
Cargo Information for Safety and Security, while continuing the practice of combined declaration for 
the Member States opting to offer this facilitation to their trade. It requires the set-up of an automated 
interface  between  NCTS  and  ICS2  to  ensure that  trade  can  serve  both  the  transit  procedure  and  the 
Safety and Security formalities simultaneously with a single process for the benefit of all. The timeline 
of NCTS-P6 is synchronised with that of ICS2-R3, having a transition window from 3 March 2025 until 
1 September 2025 for the National Administrations to migrate from NCTS-P5 to NCTS-P6.  

NCTS-P6 has been deployed in line with the following calendar (Figure 36) that is aligned to the UCC 
WP. Deadlines linked to ICS2/NCTS-P6 derogations are not depicted since they are separate of the legal 
deadlines. 

Figure 36: NCTS-P6 timeline 

3.7.1 Summary of Responses 

Summary from the Commission: 

The aim of NCTS-P6 is to complete the alignment of NCTS to the Safety and Security data specified in 
the latest releases of the Annex B in the UCC DA and UCC IA. NCTS-P6 will also implement specific 
requirements in transit customs declarations of goods brought into the customs territory of the Union. 
The primary goals are to ensure continuity of the long-established combined declaration practice and 
achieve fully integrated management of the Safety and Security provisions of the UCC in NCTS. This 
integration aims to avoid duplication of the processes and systems for the National Administrations and 

79 

 
 
 
trade.  NCTS-P6  will  interface  with  the  ICS2  system,  to  minimise  the  IT  burden  on  the  National 
Administrations and trade. Another significative advancement is the harmonisation of the presentation 
process  across  all  the  Customs  Offices  of  the  National  Administrations,  which  will  serve  as  a 
steppingstone  for  future  Smart  Border  initiatives  between  National  Administrations  and  other 
neighbouring countries. 

The  integration  of  the  system  with  ICS2-R3  requires  the  synchronisation  of  two  significant  and 
autonomous  trans-European  systems  in  terms  of  their  process  flow  and  information  exchange.  To 
achieve  this  synchronisation,  a  dedicated  converter  will  be  employed  to  facilitate  seamless 
communication and data transfer between the systems. Therefore, the level of complexity associated 
with the development of NCTS-P6 is significant. 

In April 2020, an initiative was launched to conduct a feasibility study on the interconnection between 
ICS2  and  NCTS,  including  an  analysis  of  Safety  and  Security  requirements  and  the  possible 
implementation options. The outcome confirmed the feasibility of communication between ICS2 and 
NCTS-P6. By mid-2021, the feasibility study was translated into a Business Case. 

At the request of the National Administrations, the Business Case was temporarily suspended, awaiting 
analysis of the technical implications of the proposed measures. National Administrations sought more 
clarity regarding the combined declaration facility option that could be offered or not offered to their 
trades as well as the interface between NCTS and ICS2-R3. 

In  the  second  half  of  2021,  a  Technical  Study  was  conducted  with  the  National  Administrations  to 
provide the expected clarifications and details. Based on this Technical Study, the VIS was produced by 
the end of 2021. 

In December 2021, the Business Case and VIS were approved. The VIS for NCTS-P6 established a 
transition period from June 2024 to February 2025, aligning with the transition window of ICS2-R3. 
This assumed that NCTS-P5 would be completed on time, ensuring operational continuity of the transit 
combined declaration as a trade facilitation instrument. 

During 2022, the Functional and TSS for NCTS-P6 were elaborated in collaboration with the National 
Administrations and subsequently accepted by the ECCG in December 2022. 

A  significant  risk  of  overlap  was  identified  between  the  delays  of  the  ‘running-over’  National 
Administrations that joined NCTS-P5 operations in 2024 and the transitional period of NCTS-P6. The 
revision of the UCC WP addressed this risk by establishing a clear cut-off for the transition to NCTS-
P5 as well as by postponing the start and end dates of the deployment window for NCTS-P6. The revised 
UCC WP aims to ensure operational continuity. 

In  2024,  to  facilitate  the  upgrade  from  NCTS-P5  to  NCTS-P6,  considering  the  reduced  transition 
window,  the  technical  specifications  have  been  optimised by  eliminating the need  for  conversion  of 
Common Domain messages. 

At the beginning of 2025, early indications suggested that certain National Administrations might not 
be able to deploy (all) NCTS-P6 functionalities before the 1 September 2025 deadline. These concerns 
were  later  confirmed  through  official  communications  from  several  National  Administrations,  with 
revised deployment timelines. 

An analysis of the potential impact of these delays, along with an examination of all possible mitigation 
measures, was carried out. The aim was to support National Administrations in meeting the established 
deadlines  for  ENS  submissions  under  the  UCC,  while  minimising  disruptions  to  the  functioning  of 
NCTS. For each optimised functionality specified for NCTS-P6, a risk assessment and mitigation plan 
was  developed  to  ensure  operational  continuity  for  all  countries  (aligned  to  either  NCTS-P5  or  P6) 
beyond the formal deployment date, should this prove necessary. At the time of writing, the derogation 
decisions are being prepared for the National Administrations that have requested an extension. These 
derogations will allow rail and road operators to connect to ICS2-R3 until 31 December 2025, and to 
NCTS-P6 interfacing with ICS2 until 31 May 2026. They were introduced to ease the transition for EOs, 
particularly small enterprises, who will be permitted to continue using NCTS-P5 and/or ICS1 until the 
new deadlines. Further details are provided in the Important Remark section below. 

80 

 
 
Important remark: 

Member  States,  Common  Transit  Convention  Countries  and  Trade  Associations  expressed  some 
concerns in the ECCG/TCG meetings held in February and June 2025 about their readiness with the 
implementation of the new entry summary declaration requirements underpinned by the ICS2- R3 (Step 
3)  and  NCTS-P6  (opt-in)  implementation  as  of  1  September  2025.  The  Commission  found  that  the 
appropriate legal approach was to issue derogation decisions according to the articles 6(4) and 8(2) of 
the UCC. Seven Member States (ES, FI, FR, HU, IE, IT and LT) and the U.K. in respect of Northern 
Ireland requested derogation from the deployment date of ICS2-R3 until 31/12/2025. In addition, seven 
Member States (BG, HR, GR, LV, PL, RO and SK) requested derogation from the deployment date of 
ICS2-R3  and  NCTS-P6  opt-in  version  until  01/06/2026.  At  the  moment  of  writing,  the  derogation 
decisions are being prepared. For more information regarding the derogations, please consult the 2025 
APR Report from the Commission to the European Parliament and the Council.  

Summary from the Member States: 

More than half of the Member States shared that they are on track to meet the NCTS-P6 deployment 
deadline,  though  several  reported  a  medium  to  high  risk  level  for  on-time  delivery.  Key  challenges 
include  the  delayed  publication  of  technical  specifications,  the  parallel  development  of  other  UCC 
projects, ongoing procurement processes, and limited funding. Some Member States also cited delays 
to ensure system quality or due to contractor timelines. 

Where  mitigation  measures  have  been  taken,  they  focus  on  accelerating  development  through 
strengthened teams, improved coordination with contractors, and the finalisation of tenders. 

At the time of reporting, only FI has started operations. The following Member States reported being on 
track to join operations within the legal deadline: BE, BG, CY, CZ, EE, ES, IE, IT, LT, LV, MT, and 
SI. Meanwhile, AT, DK, FR, GR, HR, HU, LU, NL, PL, PT, RO, SE and SK indicated delays beyond 
the  legal  deadline,  with  FR,  GR,  NL,  PL,  RO,  and  SK  expected  to  become  operational  after  2025. 
Additionally, DE has not provided concrete implementation dates in its national project plan. 

Detailed Responses: 

Table 22 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

Additional Comments 

AT 

AT plans for the NCTS-P6 system to join operations on 04/09/2025. 

BE 

BE aims to have the NCTS-P6 system join operations on 01/09/2025. 

BG 

BG aims for the NCTS-P6 system to become operational on 21/07/2025.  

CY 

CY reported that the NCTS-P6 system is on track to become operational on 01/09/2025. 
Additionally, CY indicated it will be an opt-out country.  

CZ 

CZ shared that the NCTS-P6 system is on target to join operations on 01/09/2025.  

DE 

DK 

DE  reported  that  NCTS-P6  system  is  on  target  and  indicated  a  low  risk  to  the  timely 
delivery  of  the  project.  DE  informed  that  it  will  not  use  the  combined  declaration 
following Article 130 of the UCC (NCTS-P6) but assured all measures will be taken to 
ensure the software is aligned with the deployment window of the project. 

DK reported that the NCTS-P6 project is delayed beyond the UCC WP deadline, but it 
aims for the system to join operations on 27/09/2025. DK attributed a high level of risk to 
the timely delivery of the project, noting NCTS-P6 has been postponed so as to ensure the 
quality of the import system and its usability for the EOs. DK  plans to first deploy the 

81 

 
 
MS 

EE 

Additional Comments 

national import system and subsequently NCTS-P6. Additionally, DK shared it will be an 
opt-out country due to time constraints.  

EE informed that the NCTS-P6 project is delayed within the legal deadline and aims for 
the system to be in operations on 16/08/2025. EE attributed a medium level of risk to the 
timely  delivery  of  the  project,  primarily  due  to  delays  in  the  publication  of  technical 
specification  amendments.  These  delays  have  resulted  in  increased  efforts  and  costs. 
Nevertheless, EE plans to have the NCTS-P6 system operational as an opt-in country by 
the end of 2025.  

ES 

ES shared that the NCTS-P6 system is on target to become operational on 01/09/2025. 

FI 

FR 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

FI informed that the NCTS-P6 system became operational on 24/05/2025 as an opt-out 
country. Additionally, FI shared that it is analysing the possibility of adopting opt-in in 
Q2 2026.  

FR reported that the NCTS-P6 project is delayed beyond 2025, with operations planned 
for 31/01/2026. A medium risk level was attributed to the timely delivery of the project, 
with delays attributed to the completion of NCTS-P5 and ongoing resource constraints. 
To address this, development teams have been reinforced, and continuous system testing 
is planned. 

GR shared that the NCTS-P6 project is delayed beyond 2025 but aims for the system to 
become operational on 30/06/2026. 

HR  reported  that  the  NCTS-P6  project  is  delayed  beyond  the  legal  deadline,  with 
operations planned to start on 30/12/2025. The delay was attributed to the late publication 
of technical specifications and the subsequent need for multiple revisions. 

HU reported that the NCTS-P6 project is delayed beyond the legal deadline and plans to 
become  operational  on  15/12/2025.  The  main  cause  of  delay  is  the  ongoing  public 
procurement process to secure the necessary software provider. 

IE shared that the NCTS-P6 system is on target to become operational on 01/09/2025. 

IT plans for the NCTS-P6 system to join operations on 01/09/2025. 

LT reported that the NCTS-P6 system is on target and aims for it to become operational 
on 01/09/2025.  

LU shared that the NCTS-P6 project is delayed beyond the UCC WP deadline but aims 
for the system to become operational on 01/12/2025. LU attributed the delay to changing 
specifications  and  a  lack  of  information  concerning  the  planning  of  the  conformance 
testing activities. 

LV informed that it aims for the NCTS-P6 system to become operational on 01/09/2025. 
However, LV noted a medium risk of delay to the timely delivery of the project as it would 
like to adopt opt-in functionalities.  

MT 

MT reported that the NCTS-P6 system is on target to become operational on 01/09/2025.  

NL 

NL informed that the NCTS-P6 project is experiencing delays beyond 2025 and aims for 
the system to join operations on 01/04/2026. NL attributed a high level of risk to the timely 
delivery of the project given the accumulation of MASP-C projects.  

82 

 
 
MS 

PL 

Additional Comments 

PL reported that the NCTS-P6 project is delayed beyond 2025, with operations planned 
for 22/06/2026. A high level of risk was attributed to the timely delivery of the project 
due to funding shortages under the current contract and a lengthy procurement process. A 
new contract is under tender, but further delays may occur if a new provider requires time 
to become familiar with the system. PL aims to sign the new contract and complete at 
least half of the analysis phase by the end of 2025. 

PT 

PT plans for the NCTS-P6 system to become operational on 01/10/2025.  

RO 

RO reported that the NCTS-P6 project is delayed beyond 2025 but aims to have the system 
join operation on 01/06/2026.  

SE 

SI 

SK  

SE reported that the NCTS-P6 project is delayed beyond the legal deadline but aims to 
start operations on 16/11/2025. SE attributed a medium risk to the timely delivery of the 
project, stating contractor deliverables as a contributing factor to the delay. To mitigate 
this delay, SE has been in close contact with the contractor and aims to deploy the system 
as a big bang.     

SI informed that the NCTS-P6 system is on track to become operational on 01/09/2025 as 
an opt-out country. 

SK reported that the NCTS-P6 project is delayed beyond 2025 and plans to ‘go live’ on 
01/03/2026  as  an  opt-in  country  but  will  meet  the  01/09/2025  deadline  as  an  opt-out 
country. SK has attributed a medium risk to the timely delivery of the project, citing delays 
caused  by  prioritising  other  UCC  projects.  In  addition,  SK  shared  it  is  experiencing 
problems with the link between NCTS-P6 and the ENS requirements in ICS2-R3 (Step 
3), noting its traders will not be ready to lodge separate ENS declarations47. SK aims to 
complete all conformance testing campaign modes by the end of 2025.    

Table 22: Detailed responses from Member States – NCTS-P6 

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

Figure 37: Project progress and status per milestone – NCTS-P6 

47 Information provided from a bilateral meeting between SK and DG TAXUD held on 06/03/2025. 

83 

 
 
 
 
 
 
3.7.2  Overview of Project Progress 

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

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

84 

 
 
Figure 38: Actual/Planned dates per milestone – NCTS-P6 

85 

 
 
 
3.8  UCC AUTOMATED EXPORT SYSTEM (AES) 

The Automated Export System (AES) project consists of an upgrade of both the existing trans-European 
Export Control System (ECS) and the existing National Export System (NES). It aims to implement the 
UCC requirements for the export and exit of goods, including export and re-export declarations, Exit 
Summary Declaration (EXS), Centralised Clearance for Export (CCE), re-export notifications and an 
interface  with  Excise  Movement  and  Control  System  (EMCS)  and  NCTS.  The  project  entails 
implementing the UCC simplifications offered to trade to facilitate the export of goods for European 
companies, such as CCE, and the UCC obligations to better monitor what exits the customs territory of 
the Union to prevent fraud. The export declaration and all linked message exchanges, the Arrival at Exit 
Notification and EXS are subject to considerable rework. The proposed message structures are fully 
convertible from/to ‘Legacy’/‘To Be’ ones, guaranteeing a smooth transition and fostering operational 
continuity from Q1 2021 until the latest trader is migrated to AES.  

The following processes will be implemented: 

•  Export declaration pre-lodgement; 

•  Handling of simplified/supplementary declarations; 

•  CCE; 

•  Re-export notification; 

•  Export process followed by transit: interoperability with the NCTS trans-European system; 

•  Export handling of goods under excise duties suspension interoperability with EMCS; 

•  Exit Summary Declaration for Safety and Security at exit. 

The new export system brings about substantial benefits and simplifications while ensuring continuity 
with the existing operational systems. 

In terms of planning, the system is comprised of two components.  

Component 1 (AES-C1) relates to the trans-European AES system. The project further develops the 
existing  ECS  to implement  a  full  AES  that  covers  the  business  requirements  for  processes  and  data 
brought about by the UCC. These processes and data include the coverage of simplified procedures and 
CCE. It also covers the development of harmonised interfaces with EMCS and NCTS. As such, AES 
enables the full automation of export procedures and exit formalities. The system includes some parts 
that have been developed centrally, but the main components are being developed at the national level.  

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

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

86 

 
 
 
 
Figure 39: Updated AES-C1 timeline 

Component 2 (AES-C2) relates to the NES upgrade and upgrades the national systems used for the 
completion of certain formalities not impacting the Common Domain of the AES. 

It is important to highlight that the AES system specifications developed at the central level (FSS and 
TSS) cover the Information Exchange in the common, national, and external domains: 

•  The  Common  Domain  communication  refers  to the Information  Exchange  between  customs 

offices located in different Member States; 

•  The national domain includes the interface between national AES and other systems at national 

level (e.g., AES-EMCS and AES-NCTS); 

•  The  external  domain  includes  the  communications  between  the  customs  offices  and  the 

declarant/trader at exit, at national level. 

Regarding the message exchanges on the  Common Domain, the AES specifications prepared by DG 
TAXUD are mandatory for all Member States. In case of external or national domains, the common 
AES specifications are strongly recommended, aiming to harmonise the export and exit formalities as 
much as possible among the Member States. 

The 27 Member States and Northern Ireland under the NIP needed to transition to the AES-C1 system 
by 1 December 2023 for the core functionalities, by 13 February 2024 for the interface with Excise, and 
by 2 December 2024 for the non-core functionalities.   

After 2 Member States requested the extension of the transitional rules and the ieCA converter until 
December  2025,  the  UCC  Implementing  Regulation  for  Technical  Arrangements  (IRTA)  was  re-
activated to include a provision that allowed for the transitional measures to be prolonged. The IRTA 
revision package underwent interservice consultation between December 2024 and January 2025 and 
was  voted  in  the  Customs  Code  Committee  General  Legislation  (CCC-GEN)  of  7/02/2025,  with  all 
Member States in favour. The new IRTA was adopted on 13 March 2025 and published in the Official 
Journal48 on 20 March 2025. Article 56 of the IRTA extended the End of Transition deadline for AES-
C1 until 14/12/2025. 

48 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  European  Parliament  and  of  the  Council:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=OJ:L_202500512  

87 

 
 
 
 
 
 
 
 
3.8.1 Summary of Responses 

AES – Component 1 (AES-C1) 

Summary from the Commission: 

For AES, the challenge lies in ensuring operational continuity and a seamless transition for Member 
States and trade, while implementing substantial changes in the applicable data and process models. The 
functional and technical specifications49 approved by the Member States govern the quality, technical 
support, operational continuity, security, and capacity of the transition to full AES-C1 operations. 

The AES project pioneered a collaborative, iterative and Agile working method that has been praised 
by all the Member States and traders involved. The adoption of an Agile approach since the project's 
inception has yielded functional and technical quality as well as the actual progress among the Member 
States. The collective intelligence of the Member States is a critical asset for the success of the transition 
at stake. The Coordination Programme is also essential in enabling collaboration between the Member 
States and the Commission and providing transparency on the status of the project. 

Considering the delays reported during 2023 by the Member States and the trade community regarding 
their transition to AES-C1 (see below), the deadlines for AES deployment and the end date for transition 
were updated in the UCC WP revision and in AES TSS. These updates aimed to ensure the operational 
continuity of AES until 11 February 2025 and full compliance with the deadlines set in Article 278(3) 
of the UCC. Following the adoption of the new IRTA, Member States that didn’t manage to complete 
their  deployment  within  the  UCC  WP  deadlines  will  benefit  from  the  extension  of  the  Transitional 
measures for AES-C1 until 14 December 2025.   

Progress of the Central Project Team 

Overall, the activities of the Central Project Team are on track according to the planned schedule for the 
development of the central system and the quality of the central services according to the agreed Service 
Level Agreement. The central converter demonstrated its fitness for purpose and its resilience with the 
growing volume of conversion. Other central systems have been continuously improved. 

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

Following the publication of the initial version of the AES Business Guidance in 2022 (versions for 
customs and for trade, available in English, German, and French), the first update was published at the 
end of 2023, accepted in ECCG97 in March 2024. This update was aligned with the Commission’s plan 
to provide regular updates of the Guidance to enhance the business understanding of AES functions. No 
further updates have been made since then.  

Additionally, at the end of 2023, a Business Continuity Plan (BCP) for AES was established between 
the Member States and the Commission. This plan outlines the measures to be adopted in all Member 
States in the event of a temporary failure of the AES system. In Q2 2024, an update of the BCP was 
launched, introducing slight changes in the BC-EAD-Form. The updated package was accepted by the 
ECCG in August 2024, by written procedure. No further updates have been made since then.  

Migration to AES-C1 

The  Member  States  and  the  Commission  are  actively  involved  in  transitioning  the  trans-European 
customs systems for export. This started with the successful deployment of the new UCC AES system 

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

88 

 
 
 
 
 
 
in DE in March 2021 and the entry into international operation by ES and DE on 26 April 2022. These 
achievements paved the way for the next generation of interconnected trans-European systems for the 
trade community and the national customs authorities, showcasing the quality of the specifications, the 
legal provisions supporting these systems and, most importantly, their operational continuity. 

By 1 December 2023 (UCC WP deadline for the core functionalities), twelve Member States (DE, ES, 
IE, NL, HR, SI, DK, BG, CZ, EE, LV, and IT) were operating in the AES system. As of 1 September 
2025, twelve additional Member States (LT, CY, RO, BE, LU, SE, FI, PL, SK, AT, HU, and MT) have 
joined AES operations. 

Increasing progress of the Member States and the Commission in 2025 (as of 1 September 2025) 

The Member States reported significant progress in deploying their national export applications in 2025. 
Currently, the remaining Member States (FR, GR and PT) are actively engaged in their implementation, 
performing conformance testing and planning to operate the new system by December 2025. However, 
XI has announced that it will not be able to join the system before the end of the transition period. 

The  central  converter,  ieCA,  developed  and  operated  by  the  Commission  along  with  other  central 
systems, has performed as expected. This significant achievement is the outcome of over three years of 
intensive collaboration between the Member States and the Commission, marking the beginning of the 
transition in the Common Domain. 

Entry into operation  

Figure 40 is based on the date which a Member State joined or will join the ‘To Be’ operation on the 
Common  Domain  with  their  core  functionalities.  Thus  far,  all  entries  in  operations  have  occurred 
without causing any disruption to the continuity and quality of the operation, reflecting the effective 
efforts of the National Project Teams. 

Almost all Member States confirmed that they will be in operations  with the core functionalities, the 
interface with EMCS and the non-core functionalities by 14 December 2025. FR plans to go-live with 
only the core functionalities (Step 1) in Q4 2025, with the traders’ migration completed by 14 December 
2025. GR plans to be operational by 1 December 2025 without a migration period for the traders. PT is 
operating AES only in the common domain as a first step and intends to complete deployment with all 
functionalities before December 2025.  

However, a few Member States announced that certain non-core functionalities and/or the harmonised 
interface with EMCS will only be deployed after 2025. BE plans to deploy CCE and the interface with 
NCTS in 2026; FR will gradually deploy non-core functionalities and the EMCS interface during 2026 
and 2027; HU intends to  deploy non-core functionalities in 2026; and NL has not yet scheduled the 
deployment  of  CCE  and  the  interface  with  NCTS.  In  addition,  XI  faces  significant  challenges  in 
deploying the full scope of AES and is expected to be delayed beyond 14 December 2025. 

89 

 
 
 
 
Figure 40: AES-C1 Member States entry into operations as of September 2025 

Overall, the  National  Administrations  have  collectively  achieved significant progress.  All  remaining 
National Administrations, except XI, will enter into operation before 14 December 2025. 

Recommendations to the Member States 

The  Commission  invited  the  Member  States,  particularly  those  that  announced  running  over  the  1 
December 2023 milestone for the core functionalities, to maintain a high level of compliance with all 
their national projects so that AES-C1 can be deployed in time or with the shortest delay possible. 

Member States that are late are advised to take advantage of the remaining time before the end of the 
extended transition period to undertake all necessary steps to minimise delays as much as possible. 

Furthermore, the Member States have been reminded about the implementation of all the requirements 
of the Design Document for National Export Application (DDNXA), including the transitional Rules 
and Conditions, to ensure operational continuity. 

Additionally, the Commission invited the Member States that have not yet done so to publish their trade 
specifications in accordance with the latest DDNXA v5.15.2 and RfCs promptly. 

It is essential for Member States that do not offer a transition window to their trade to communicate their 
transition strategy well in advance to the EOs. This will allow sufficient time for the development and 
testing of the trade system. Member States that offer a transitional window should track the progress of 
their traders and periodically report via submission of the updated National Project Plans template or 
business statistics. Moreover, all Member States should initiate their outreach and support programme 
for the EOs. 

The Coordination Programme 

Under the umbrella of the ‘National Administration Coordination Programme,’ the Commission assists 
and monitors the development and deployment of the national components for AES-C1 by the Member 
States. The programme is being extended to monitor the transition of the Member States and traders 
during their transition to AES-C1. 

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

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

90 

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

Summary from the Member States: 

Most Member States have started operations for AES-C1, while the few facing delays reported varying 
levels of risk. Key challenges included internal development issues, complex system interdependencies, 
and the prioritisation of other national projects. To reduce implementation timeframes, Member States 
adopted Agile methodologies and reinforced project teams and resources.  

At the time of writing, the following Member States reported that they have entered operations, either 
through a single-step or multi-step approach: BE, BG, CY, CZ, DE, DK, EE, ES, FI, HR, IT, LT, LU, 
LV, NL, PL, RO, SE, SI, and SK. AT, GR, HU, IE, MT and PT are on track to begin operations before 
the end of the transition period. Some MS are, however, facing delays beyond the deployment deadline, 
with non-core functionalities (Step 3) expected to become operational after 2025. 

Detailed Responses: 

Table 23 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

Additional Comments 

AT  reported  that  the  AES-C1  system  was  deployed  on  26/01/2025  and  aims  for  it  to 
become fully operational on 30/09/2025, following the completion of the transition period 
with the EOs50. Additionally, AT shared that export declaration pre-lodgement, handling 
of simplified/supplementary declarations and re-export notification functionalities are not 
yet  in  operation.  CCE  functionality  is  planned  to  be  operational  by  17/07/2025  and 
interoperability with the NCTS trans-European system functionality is planned to be fully 
operational without the use of a workaround solution by 30/09/2025.  

BE  shared  that  AES-CI  system  was  deployed  on  19/06/2024  and  the  system  joined 
operations  with  core  functionalities (Step  1)  and  the  interface  with  Excise  (Step  2)  on 
18/12/2024. 

BG informed that the AES-C1 system has been operational, with all functionalities since 
29/08/2023.  

CY reported that the AES-C1 system entered operations with core functionalities (Step 1) 
on 18/12/2023, interface with Excise (Step 2) on 31/07/2024, and non-core functionalities 
(Step 3) on 20/01/2025. 

CZ  shared  that  the  AES-C1  system  started  operations  with  all  functionalities  on 
01/10/2023.  

DE reported that the AES-C1 system has been operational, with all functionalities since 
29/10/2023.  

DK  informed  that  the  AES-C1  system  joined  operations  with  all  functionalities  on 
31/05/2024.  

EE  shared that  the  AES-C1  system  has  been  operational,  with  all  functionalities  since 
01/10/2023.  

50 The information shared by AT in the survey has been updated based on a bilateral meeting between AT and DG 
TAXUD held on 24/04/2024. 

91 

 
 
 
 
 
 
MS 

ES 

FI 

FR 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

Additional Comments 

ES  reported  that  the  AES-C1  system  joined  operations  on  09/05/2023  with  all 
functionalities.   

FI informed that the AES-C1 system is completed, the core functionalities (Step 1) have 
been  operational  since  05/11/2024  and  the  non-core  functionalities  (Step  3)  since 
24/05/2025.  

FR reported that the AES-C1 project is delayed beyond the legal deadline, with operations 
planned  for  core  functionalities  (Step  1)  on  14/12/2025,  Excise  interface  (Step  2)  on 
31/12/2025,  and  non-core functionalities (Step  3)  on 30/03/2028.  A medium risk  level 
was  attributed  to  the  project  due  to  delays  in  finalising  the  Information  System  (IS) 
construction.  The  application  is  now  complete,  with  internal  testing  underway  in 
collaboration with EOs and the Commission. To prevent further delays, the project team 
has been reinforced with additional resources to meet key milestones and improve output 
quality. 

GR  reported  that  the  AES-C1  project  is  delayed  but  still  aims  to  be  operational  on 
01/12/2025. The delays were attributed to procurement issues and limited resources, with 
GR assessing a medium risk to timely delivery. To mitigate this, additional budget has 
been allocated to support on-time implementation. 

HR  shared  that  the  AES-C1  system  started  operations  with  all  functionalities  on 
03/05/2023.  

HU reported that the AES-C1 project is delayed beyond the legal deadline but is expected 
to be fully operational by the end of 2025. HU shared that the core functionalities (Step 
1) and the interface with excise (Step 2) have been operational since 06/05/2025. For the 
non-core functionalities (Step 3), it aims to have the AES-NCTS interface in operations 
on  07/07/2025,  while  CCE,  re-export  notification  and  the  EIDR  functionalities  are 
planned for 31/12/2025. 

IE  reported  the  AES-C1  project is  almost  completed. IE  shared  that the  system joined 
operations  with  core  functionalities  (Step  1)  on  21/05/2023,  the  interface  with  Excise 
(Step  2)  on13/02/2024  and  aims  for  the  non-core  functionalities  (Step  3)  to  become 
operational on 01/08/2025.  

IT shared that the AES-C1 system joined operations with the core functionalities (Step 1) 
and the non-core functionalities (Step 3) on 01/12/2024.  

LT informed that the AES-C1 system is completed. The core functionalities (Step 1) and 
the interface  with  Excise  (Step  2) joined  operations on  03/12/2023  while  the  non-core 
functionalities (Step 3) have been operational since 01/12/2024.  

LU  shared  that  the  AES-C1  system  joined  operations  on  02/12/2024  with  all 
functionalities.   

LV reported that the AES-C1 system is fully implemented. The system entered operations 
with the core functionalities (Step 1) on 10/10/2023, followed by the interface with Excise 
(Step 2) on 13/02/2024 and the remaining non-core functionalities (Step 3) on 01/12/2024.  

MT  aims  to  deploy  AES-C1  on  21/07/2025.  In  addition,  operations  for  the  core 
functionalities  (Step  1)  are  planned  for  21/07/2025,  the  Excise  interface  (Step  2)  on 
27/10/2025 and the non-core functionalities (Step 3) on 24/11/2025. 

NL reported that the AES-C1 system is operational, with core functionalities (Step 1) live 
since  01/12/2023,  the  Excise  interface  (Step  2)  since  13/02/2024,  and  non-core 

92 

 
 
 
 
MS 

Additional Comments 

functionalities (Step 3) since 02/12/2024. However, NL noted delays with some additional 
non-core functionalities. Exit followed by Transit is planned for delivery by the end of 
2025 while planning for CCE is still ongoing. 

PL 

PL informed that AES-C1 started operations with all functionalities on 31/10/2024. 

PT reported that the AES-C1 project is delayed beyond the legal deadline, with operations 
for core functionalities (Step 1) and the Excise interface (Step 2) planned for 04/11/2025, 
and the  non-core functionalities (Step  3)  on  17/11/2025.  The  delays  were attributed  to 
strong interdependencies among national systems, which complicated the development of 
AES.  PT  noted  that  the  project  was  especially  complex,  as  it  involved  creating  a  new 
export  system  requiring  integration  with  various  national  and  EU  systems.  To  address 
these challenges, PT adopted Agile development to accelerate implementation, improved 
its planning processes and adjusted the scheduling of training activities. 

RO  shared  that  the  AES-C1  system  joined  operations  on  16/03/2024  with  all 
functionalities.   

SE reported that the AES-C1 system has been fully operational with all functionalities 
since 02/12/2024.  

PT 

RO 

SE 

SI 

SI informed that AES-C1 system started operations with all functionalities on 24/05/2023. 

SK 

SK informed that the AES-C1 system has been operational with all functionalities since 
01/11/2024.  

Table 23: Detailed responses from Member States – AES-C1 

Figure 41 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 41: Project progress and status per milestone – AES-C1 

93 

 
 
 
 
 
 
 
 
 
 
AES – Component 2 (AES-C2) 

Summary from the Member States: 

Please see also the summary from AES-C1. 

At the moment of writing, the following Member States have joined operations for AES-C2: BE, BG, 
CY, CZ, DE, DK, EE, ES, FI, HR, HU, IE, IT, LT, LU, LV, NL, PL, RO, SE, SI and SK. AT, GR, MT 
and  PT  are  delayed  beyond  the  legal  deadline  but  plan  to  join  operations  before  the  end  of  2025. 
Additionally, FR reported the project as not applicable.  

Detailed Responses: 

Table 25 provides the individual updates from the Member States on their responses to the survey and 
the national plans provided in June 2025: 

MS 

Additional Comments 

AT 

AT plans for the AES-C2 system to join operations on 30/09/2025.  

BE 

BE informed that the AES-C2 system joined operations on 18/12/2024. 

BG 

BG shared that the AES-C2 system started operations on 29/08/2023.  

CY 

CY reported that the AES-C2 system has been operational since 18/12/2023.  

CZ 

CZ shared that the AES-C2 system started operations on 01/10/2023.  

DE 

DE informed that the AES-C2 system has been operational since 29/10/2023. 

DK 

DK shared that the AES-C2 system started operations on 31/05/2024.  

EE 

EE reported that the AES-C2 system has been operational since 01/10/2023.  

ES 

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

FI 

FI reported that the AES-C2 system joined operations on 05/11/2024.  

FR 

FR reported the system as not applicable.  

GR 

GR plans for the AES-C2 system to join operations on 01/12/2025. 

HR 

HR shared that the AES-C2 system has been operational since 02/05/2023.  

HU 

IE 

IT 

HU  reported  that  the  AES-C2  system  was  deployed  and  became  operational  on 
06/05/2025, but experienced delays due to dependencies on the delivery of the AES-C1 
system. 

IE reported that the AES-C2 system started operations on 21/05/2023.  

IT shared that the AES-C2 system joined operations on 01/12/2024.  

94 

 
 
 
 
MS 

Additional Comments 

LT 

LT informed that the AES-C2 system has been operational since 03/12/2023.  

LU 

LU reported that the AES-C2 system joined operations on 02/12/2024.   

LV 

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

MT 

MT plans for AES-C2 to become operational on 21/07/2025.  

NL 

NL reported that the AES-C2 system has been operational since 01/12/2023. However, 
NL  noted  that  CCE  and  the  interface  between  NCTS-P5  and  AES  have  not  yet  been 
completed.  

PL 

PL informed that the AES-C2 system has been operational since 31/10/2024.  

PT 

PT  reported  that  the  AES-C2  project  is  delayed  beyond  the  legal  deadline,  with 
deployment  planned  for  01/10/2025.  PT  attributed  a  high  level  of  risk  to  the  timely 
delivery of the project, with delays stemming from the strong interdependencies among 
national systems, which complicated the development of the AES system. PT noted that 
the  project  was  particularly  complex,  as  it  involved  creating  an  entirely  new  national 
export  system  requiring  integration  with  various  national  and  EU  systems.  To  address 
these challenges, PT adopted Agile development to shorten the implementation timeframe 
and enhanced its planning processes. 

RO 

RO shared that the AES-C2 system joined operations on 16/03/2024. 

SE 

SE reported that the AES-C2 system began operations on 02/12/2024 for all interfaces 
related to the common domain. Delays were noted for the deployment of EIDR, the Exit 
Summary Declaration, and the Re-Export Notification, due to the prioritisation of other 
UCC projects. SE stated that EIDR will be deployed on 01/02/2026, with all EOs expected 
to be operational by 28/02/2026, noting that it is currently used by only a few EOs, and 
only for exports to NO. The Exit Summary Declaration and Re-Export Notification are 
planned for deployment in the second half of 2026, though both involve a very limited 
number of transactions. 

SI 

SI informed that the AES-C2 system joined operations on 24/05/2023. 

SK 

SK reported that AES-C2 has been operational since 01/11/2024.  

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

95 

 
 
 
 
 
 
Figure 42 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 42: Project progress and status per milestone – AES-C2 

96 

 
 
 
 
 
3.8.2 Overview of Project Progress 

Figure  43  for  AES-C1  highlights  any  known  divergences  in  the  Member  States’  National  Planning 
compared to the dates set in the UCC WP, along with the specific dates of each milestone. As this project 
has  a  deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference 
between these dates, indicates that a migration period is planned. 

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

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

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

Figure  44  for  AES-C2  highlights  any  known  divergences  in  the  Member  States’  National  Planning 
compared to the dates set in the UCC WP, along with the specific dates of each milestone. As this project 
has  a  deployment  window,  the  deployment  and  operations  milestones  are  shown.  Any  difference 
between these dates, indicates that a migration period is planned. 

Regarding UCC Automated Export System – Component 2 (AES-C2), the following Member States 
have a planned/actual operations date that is later than the deadline in the UCC WP: AT, BE, GR, HU, 
MT and PT. Additionally, FR indicated the project as not applicable. 

97 

 
 
 
 
 
98 

 
 
 
 
 
Figure 43: Actual/Planned dates per milestone – AES-C1 

99 

 
 
 
 
 
Figure 44: Actual/Planned dates per milestone – AES-C2 

100 

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

The goal of the UCC ICS2 programme is to strengthen the Safety and Security of the supply chain for 
goods moved via all modes of transport. The aim is to do so through better targeted risk-based controls 
of EU customs authorities on improved ENS data quality, data filing, data availability and data sharing 
and through real-time collaborative risk analysis and co-ordinated Safety and Security controls at the 
EU entry points. The main purpose of the system is to implement the requirements resulting from the 
UCC and strategic objectives endorsed by the Member States in the risk management strategy and action 
plan of 2014. 

In terms of planning, the programme is implemented in three releases.  

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

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

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

•  For maritime and inland waterways carriers, between 3 June 2024 and 4 December 2024; 

•  For house level filers in the maritime and inland waterways traffics, between 4 December 

2024 and 1 April 2025; 

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

3.9.1 Summary of Responses 

Summary from the Commission: 

The trans-European project on UCC ICS2-R3 enhances the functional scope of ICS2 with support for 
further modes of transport and implements the complete UCC requirements for all ‘entry of goods’ use 
cases including the existing ones from ICS2-R2.  

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

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

The development of the central components, namely the Common Repository (CR) and Shared Trader 
Interface has started and is progressing as planned. 

Important remark: 

Member  States,  Common  Transit  Convention  Countries  and  Trade  Associations  expressed  some 
concerns in the ECCG/TCG meetings held in February and June 2025 about their readiness with the 
implementation of the new entry summary declaration requirements underpinned by the ICS2- R3 (Step 
3)  and  NCTS-P6  (opt-in)  implementation  as  of  1  September  2025.  The  Commission  found  that  the 
appropriate legal approach was to issue derogation decisions according to the articles 6(4) and 8(2) of 
the UCC. Seven Member States (ES, FI, FR, HU, IE, IT and LT) and the U.K. in respect of XI requested 
derogation from the deployment date of ICS2-R3 until 31/12/2025. In addition, seven Member States 
(BG, HR, GR, LV, PL, RO and SK) requested derogation from the deployment date of ICS2-R3 and 
NCTS-P6 opt-in version until 01/06/2026. At the moment of writing, the derogation decisions are being 

101 

 
 
 
 
prepared. For more information regarding the derogations, please consult the 2025 APR Report from 
the Commission to the European Parliament and the Council.  

Summary from the Member States: 

At the time of writing, all Member States have deployed the ICS2-R3 system. In terms of operations, 
BG, CZ, GR, LU, PT, and SI are fully operational across all modes of transport, having adopted a single-
step approach. DK, is also following a single-step approach and is on track to become operational by 
the UCC WP deadline. 

The following Member States have started operations for maritime and inland waterways carriers (Step 
1) and house-level filers in these traffic modes (Step 2), and are on target to reach operational status for 
road and rail carriers (Step 3) by the deadline: AT, BE, CY DE, EE, ES, FI, HR, HU, IE, LT, LV, MT, 
PL, RO SE, and SK. 

In addition, IT has yet to join operations, but is on track to do so with all functionalities before the final 
deadline. FR and NL joined operations for Step 1 but reported a delay in reaching Step 3 and Step 2 
respectively. 

Detailed Responses: 

Table 26 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

AT 

BE 

BG 

CY 

CZ 

DE 

DK 

EE 

Additional Comments 

AT  shared  that  the  ICS2-R3  system  was  deployed  on  03/06/2024,  with  operations  for 
maritime and inland waterways carriers (Step 1) and house level filers in the maritime and 
inland waterways traffics (Step 2) starting on 04/12/2024 and 01/04/2025 respectively. 
AT aims to have the system operational for road and rail carriers (Step 3) on 01/09/2025.  

BE  informed  that  ICS2-R3  was  deployed  on  03/06/2024,  with  maritime  and  inland 
waterways  carriers  (Step  1)  in  operations  since  04/12/2024  and  maritime  and  inland 
waterways traffics (Step 2) since 01/04/2025. Additionally, BE plans to have road and rail 
carriers (Step 3) operational on 01/09/2025. 

BG reported that the ICS2-R3 system has been operational for all modes of transport since 
03/06/2024.  

CY shared that the ICS2-R3 system was deployed on 03/06/2024 and is fully operational 
since 04/12/2024 for maritime and inland waterways carriers (Step 1) and 01/04/2025 for 
house level filers in the maritime and inland waterways traffics (Step 2).  

CZ shared that the ICS2-R3 system was deployed and started operations on 01/06/2024 
for all modes of transport. 

DE informed that the ICS2-R3 system was deployed on 03/06/2024, with maritime and 
inland waterways carriers (Step 1) in operations since 04/12/2024 and maritime and inland 
waterways traffics (Step 2) since 01/04/2025. Additionally, DE is on target to have road 
and rail carriers (Step 3) operational on 01/09/2025. 

DK reported that the ICS2-R3 system was deployed on 25/05/2024 and is on track to start 
operations  for  all  modes  of  transport  on  01/09/2025,  as  only  a  few  EOs  remain  to  be 
onboarded.  

EE informed that the ICS2-R3 system was deployed on 03/06/2024. Operations began 
with maritime and inland waterways carriers (Step 1) and house level filers in the maritime 
and inland waterways traffics (Step 2) on 01/04/2025. Road and rail carriers (Step 3) are 
scheduled to become operational on 01/09/2025. 

102 

 
 
 
 
MS 

ES 

FI 

FR 

GR 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

Additional Comments 

ES  shared  that  the  ICS2-R3  system  was  deployed  on  03/06/2024,  with  operations  for 
maritime and inland waterways carriers (Step 1) starting on 04/12/2024, house level filers 
in the maritime and inland waterways traffics (Step 2) on 01/04/2025 and road and rail 
carriers (Step 3) planned for 01/09/2025. 

FI  shared  that  the  ICS2-R3  system  was  deployed  during  Q2  2025,  with  operations  for 
maritime and inland waterways carriers (Step 1) and house level filers in the maritime and 
inland  waterways  traffics  (Step  2)  starting  on  01/04/2025.  FI  aims  to  have  the  system 
operational for road and rail carriers (Step 3) on 01/09/2025. 

FR  informed  that  ICS2-R3  was  deployed  on  03/06/2024,  with  maritime  and  inland 
waterways carriers (Step 1) in operations since 04/12/2024. FR aims to have road and rail 
carriers (Step 3) join operations on 31/12/2025. 

GR reported that the ICS2-R3 system was deployed and  has been in operations for all 
modes of transport since 14/06/2024. 

HR shared that ICS2-R3 was deployed on 03/06/2024. Operations began with maritime 
and inland waterways carriers (Step 1) and house level filers in the maritime and inland 
waterways traffics (Step 2) on 01/04/2025. Road and rail carriers (Step 3) are scheduled 
to become operational on 01/09/2025. 

HU  reported  that  the  ICS2-R3  system  was  deployed  on  01/03/2023.  Operations  were 
launched for maritime and inland waterways carriers (Step 1) on 04/12/2024, followed by 
house-level filers in the maritime and inland waterways traffics (Step 2) on 01/04/2025. 
Road and rail carriers (Step 3) are expected to follow on 01/09/2025. 

IE  informed  that  the  ICS2-R3  system  was  deployed  on  03/06/2024,  and  has  been 
operational for maritime and inland waterways carriers (Step 1) since 04/12/2024 and for 
house level filers in the maritime and inland waterways traffics (Step 2) since 01/04/2025. 
In addition, IE aims to have road and rail carriers (Step 3) operational on 01/09/2025, but 
noted that EOs may face challenges meeting the final deadline. 

IT shared that ICS2-R3 was deployed on 03/06/2024. IT aims for maritime and inland 
waterways carriers (Step 1) and house-level filers in the maritime and inland waterways 
traffics (Step 2) to join operations on 14/07/2025 and for road and rail carriers (Step 3) on 
01/09/2025. 

LT reported that the ICS2-R3 system was deployed on 01/06/2024. This was followed by 
operations  for  maritime  and  inland  waterways  carriers  (Step  1)  on  04/12/2024,  house-
level filers in the maritime and inland waterways traffics (Step 2) on 01/04/202. It aims 
for road and rail carriers (Step 3) to become operational on 01/09/2025.  

LU shared that the ICS2-R3 system  joined operations on 01/07/2024 for all applicable 
modes of transport. Additionally, LU noted that the impact of ICS2-R3 is limited as it has 
no land or sea borders with 3rd countries.  

LV  reported  that  the  ICS2-R3  system  was  deployed  on  01/03/2023.  Operations  for 
maritime and inland waterways carriers (Step 1) began on 04/12/2024, followed by house-
level filers in these traffic modes (Step 2) on 01/04/2025. LT plans to launch operations 
for road and rail carriers (Step 3) on 01/09/2025. 

MT  informed  that  ICS2-R3  was  deployed  on  03/12/2024,  with  maritime  and  inland 
waterways  carriers  (Step  1)  in  operations  since  04/12/2024  and  maritime  and  inland 

103 

 
 
 
 
MS 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Additional Comments 

waterways traffics (Step 2) since 01/04/2025. Additionally, MT plans to have road and 
rail carriers (Step 3) operational on 01/09/2025. 

NL shared that the ICS2-R3 system was deployed on 27/05/2024 and has been operational 
for maritime and inland waterways carriers (Step 1) since 04/12/2024. NL aims to have 
the system operational for house level filers in the maritime and inland waterways traffics 
(Step 2) on 01/09/2025.  

PL informed that the ICS2-R3 system was deployed on 03/06/20204, with maritime and 
inland waterways carriers (Step 1) in operations since 04/12/2024 and maritime and inland 
waterways traffics (Step 2) since 01/04/2025. Additionally, PL is on target to have road 
and rail carriers (Step 3) operational on 01/09/2025. 

PT  shared  that  the  ICS2-R3  system  joined  operations  on  03/06/2024  for  all  modes  of 
transport.  

RO  reported  that  ICS2-R3  was  deployed  on  16/12/2024.  Operations  for  maritime  and 
inland waterways carriers (Step 1) began on 01/05/2024, and house-level filers in these 
traffic  modes  (Step 2) on 01/04/2025.  RO  plans  to  launch  operations for  road and rail 
carriers (Step 3) on 01/09/2025. 

SE  informed  that  the  ICS2-R3  system  was  deployed on  03/06/2024.  Operations  began 
with maritime and inland waterways carriers (Step 1) on 04/12/2024, followed by house-
level filers in the maritime and inland waterways traffics (Step 2) on 01/04/2025. Road 
and rail carriers (Step 3) are scheduled to become operational on 01/09/2025. 

SI reported that ICS2-R3 was deployed on 02/06/2024 and has been operational for all 
modes of transport since 03/06/2024.  

SK  shared  that  the  ICS2-R3  system  is  on  target  to  meet  the  UCC  deadline  and  was 
deployed on 03/06/2024. Operations were launched for maritime and inland waterways 
carriers (Step 1) on 04/12/2024, followed by house-level filers in the maritime and inland 
waterways traffics (Step 2) on 01/04/2025. Road and rail carriers (Step 3) are planned to 
follow  on  01/09/2025.  In  regards  to  Step  3,  SK  noted  that  traders  might  have  issues 
meeting the deadline and has launched a campaign for the trade community to help in this 
regard51.  

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

51 Information provided from a bilateral meeting between SK and DG TAXUD held on 06/03/2025. 

104 

 
 
 
 
 
 
 
 
Figure 45 provides the progress reported by the Member States through their national project plans, 
along with the status of the project. 

Figure 45: Project progress and status per milestone – ICS2-R3 

105 

 
 
 
 
 
 
 
3.9.2 Overview of Project Progress 

Figure 46 highlights any known divergences in the Member States’ National Planning compared to the 
dates set in the UCC WP, along with the specific dates of each milestone.  

Regarding the implementation of UCC Import Control System 2 – Release 3 (ICS2-R3): 

•  The Member States that plan to deliver the system in full and have a planned/actual 

operations date that is later than the single operations deadline in the UCC WP: DK;  

•  The Member States that plan to deliver the system by steps and have a planned/actual 

operations date for the maritime and inland waterways carriers (Step 1) that is later than the 
Step 1 operations deadline are: EE, FI, FR and IT. In addition, FR also has a planned/actual 
operations date for road and rail carriers (Step 3) that is later than the Step 3 operations 
deadline, while IT does so for house-level filers in the maritime and inland waterways traffics 
(Step 2). 

106 

 
 
 
 
 
 
 
 
 
 
107 

 
 
 
 
 
Figure 46: Actual/Planned dates per milestone – ICS2-R3 

108 

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

The UCC PoUS is a trans-European system designed to allow storage, management, and retrieval of 
certain types of documents (e.g., T2L, T2L/F, CGM, CGMF) that traders provide to prove the Union 
Status  of  their  goods.  The  system  is  meant  to  improve  the  uniformity  of  the  procedures  across  the 
European  Union  and  contribute  to  the  establishment  of  a  more  consistent,  harmonised  and,  thus, 
simplified process related to customs clearance for Union goods.  

A system will be created that will include a central repository for the storage and exchange of data and 
documents dealing with PoUS between the customs authorities across all the Member States. 

The project is divided into two phases.  

For Phase 1 (PoUS-P1), please refer to Section 2.11 

Phase  2  (PoUS-P2)  covers  the  implementation  of  the  electronic  CGM,  including  the  information 
exchange with the EMSWe52. 

3.10.1 Summary of Responses 

Summary from the Commission: 

The  TSS  were  completed  by  Q2  2023.  The  conformance  testing  activities  of  the  PoUS  central 
components (PoUS STP, PoUS BO and web-services used for national PoUS systems (ES and PL)) are 
anticipated to be concluded by Q3 2025. The system-to-system (S2S) connection for traders is envisaged 
to occur via the MNSWs and was planned to be deployed at the same date as the central PoUS-P2, 
namely on 15 August 2025, in order to meet the requirements laid down by Article 26 of Regulation 
(EU) 2019/1239 establishing a EMSWe. For this S2S part, there is a delay for two different reasons: 

•  Over the past few months, Member States haves announced delays in the implementation of 
the MNSWs for up to 18 months following the planned deployment date, which will have a 
significant impact on the maritime sector. The Commission looked into a potential solution 
from the legal point-of-view (in order to allow to continue the shipping company’s manifest 
use until the MNSW is ready). 

• 

In May 2025, the Commission changed the technical strategy below to be used for the S2S in 
order to simplify the work from the MS side: SPEED2 should be used instead of CCN2. That 
has introduced yet another cause for a delay in the release into PROD of the S2S 
communication between the MNSW and the central PoUS system. 

Nevertheless, the Phase 2 is envisaged to be deployed according to the UCC WP on 15 August 2025, 
providing the service of submitting CGM requests without the S2S connection. 

Important remark: 

The Commission found that the appropriate legal approach to bridge the tie gap between the deployment 
of PoUS-P2 and the MNSW was to issue derogation decisions according to the articles 6(4) and 8(2) of 
the UCC. Seventeen Member States requested derogations from the connection between the PoUS and 
the MNSW, until the latter will be in place individually in each Member State. For more information 
regarding the derogations, please consult the 2025 APR Report from the Commission to the European 
Parliament and the Council. 

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

109 

 
 
 
 
 
 
 
 
Summary from the Member States: 

The Member States have the option of using the central PoUS system or developing their own national 
application. From all the Member States, only ES and PL conveyed the intention to develop their own 
national system. ES is on target to deploy the system within the legal deadline, however, PL has reported 
it will be delayed beyond 2025 and has requested a derogation as described above. 

Detailed Responses: 

Table 27 provides the individual updates from the Member States on their responses to the survey and 
the national project plans provided in June 2025: 

MS 

Additional Comments 

ES 

ES reported that the PoUS-P2 system is on track to join operations on 15/08/2025.  

PL 

PL shared that the PoUS-P2 project is delayed beyond 2025, with operations planned for 
30/06/2027. A high level of risk was attributed to the timely delivery of the project due to 
funding shortages under the current contract and a lengthy procurement process. A new 
contract is under tender, but further delays may occur if a new provider requires time to 
become familiar with the system. PL aims to sign the new contract and complete at least 
half of the analysis phase by the end of 2025. 

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

3.10.2 Overview of Project Progress 

Figure 47 highlights any known divergences in the Member States’ National Planning compared to the 
dates set in the UCC WP, along with the specific dates for the central and national system.  

Regarding UCC Proof of Union Status – Phase 2 (PoUS-P2), all Member States, except ES and PL, will 
use the central PoUS system. ES and the Commission indicated to be on target to deploy the system on 
15 August 2025, however PL indicated that it will go into operations after the UCC WP deadline. 

Figure 47: Actual/Planned dates per milestone – PoUS-P2 

110 

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

Figure 48 reflects the state of play at the end of 2025, corresponding to the legal deadline established in 
the revised 2023 UCC Work Programme. The projects marked in green are fully completed, while 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 48: Planning Overview – UCC WP Projects  

111 

 
 
 
 
 
 
 
 
5. ANNEX 2 – ACRONYMS, ABBREVIATIONS & KEY TERMS 

Acronym 

Description 

AEO 

AES 

AN 

Authorised Economic Operator 

Automated Export System 

Notification of Arrival 

ATLAS 

Automated Customs Tariff and Local Processing Application System 

BTI 

CCE 

CCI 

CDS 

CGM 

CRS 

CTC 

Binding Tariff Information 

Centralised Clearance for Export 

Centralised Clearance for Import 

Customs Decisions System 

Customs Goods Manifest 

Customer Reference Services  

Common Transit Convention 

DG TAXUD   Directorate-General for Taxation and Customs Union 

EBTI/EBTI-3 

trans-European Binding Tariff Information 

ECCG 

EIDR 

EMCS 

Electronic Customs Coordination Group 

Entry In the Declarant’s Records 

Excise Movement and Control System 

EMSW 

European Maritime Single Window 

EMSWe 

European Maritime Single Window environment 

ENS 

EO 

Entry Summary Declaration 

Economic Operator 

EORI2 

Economic Operator Registration and Identification upgrade 

EUCDM 

European Union Customs Data Model 

EU CTP 

European Union Customs Trader Portal 

GSP 

GUM 

ICS2 

ieCA 

INF 

IRTA 

Generalised Scheme of Preferences 

Guarantee Management 

Import Control System 2 

Information Exchange Conversion Application 

Information Sheet 

UCC Implementing Regulation on Technical Arrangements 

MASP-C 

Multi-Annual Strategic Plan for Customs 

MNSW 

Maritime National Single Window 

MSW 

NCTS 

Maritime Single Window 

New Computerised Transit System 

112 

 
 
 
 
 
Acronym 

Description 

NES 

NIS 

PN 

National Export System 

National Import System 

Presentation Notification 

PoUS 

Proof of Union Status 

Q1/2/3/4 

Quarter 1/2/3/4 

REX 

RfC 

SP 

SP EXP 

SP IMP 

SURV3 

TP 

TS 

TSS 

UCC 

Registered Exporter System 

Request for Change 

Special Procedures 

Special Procedures – Component 1 

Special Procedures – Component 2 

Surveillance 3 

Trader Portal 

Temporary Storage 

Technical System Specifications 

Union Customs Code 

UCC WP 

Union Customs Code Work Programme 

UUM&DS 

Uniform User Management and Digital Signature 

VIS 

Vision Document 

Table 27: Abbreviations and Acronyms 

6. ANNEX 3 – DEFINITION OF FORMATS, LEGAL BASE AND LEGAL 

DEADLINE FOR SURVEILLANCE3 

SDR Format 

Details 

CCIP 

Annex 21-02, of 
the UCC IA 

(16 data 
elements) 

Reduced UCC 

Annex 21-02,  
of the UCC IA 

(16 data 
elements) 

Format according to CCIP 
legislation, which is the format 
accepted before UCC entered 
into force with the addition of 
the Data Elements required for 
VAT legislation.  

This format is put in place to 
cover the case for those 
Member States who cannot 
provide the 41 data elements 
but want to align with the UCC 
format for the data elements 
available.  

Validity 

Import 

Export 

Will be discontinued 
for imports not later 
than 1st July 2025 
(legal date)  

Will be discontinued 
for exports as of 2nd 
December 2024 
(legal date)  

Will be discontinued 
for imports not later 
than 1st July 2025 
(legal date)  

Will be discontinued 
for exports as of 2nd 
December 2024 
(legal date)  

113 

 
 
 
 
 
  
  
Full UCC - 
current Annex B 

Annex 21-01, of 
the UCC IA 

(41 data 
elements) 

Full UCC – 
new Annex B 

Annex 21-03, of 
the UCC IA 

(57 data 
elements) 

This format supports national 
declaration systems complying 
with the UCC legislation and 
following the data formats as 
set out in the current Annex B 
UCC DA19  

The format will support 
national declaration systems 
complying with the UCC 
legislation and following the 
data formats as set out in in the 
NEW Annex B UCC DA20  

This queue will be 
discontinued for 
imports as of 1st July 
2025 (legal date)  

This queue will be 
discontinued for 
exports as of 2nd 
December 2024 
(legal date)  

MS may switch to the “Full UCC – new 
Annex B” format as of 1st March 2022  

MS must switch to 
“Full UCC – new 
Annex B” format for 
imports at the latest 
by 1st July 2025 
(legal date)  

MS must switch to 
“Full UCC – new 
Annex B” for 
exports at the latest 
by 2nd December 
2024 (legal date)  

Postal 

Annex 21-03, of 
the UCC IA 

The format will support postal 
declarations for national 
declaration systems complying 
with the UCC legislation  

MS may transmit 
data this format as of 
1st March 2022  

Not applicable  

Table 28: Definition of formats, legal base and legal deadline – SURV3 

114