Annexes to COM(2019)629 - Progress in developing the electronic systems provided for under the Customs Code - Main contents
Please note
This page contains a limited version of this dossier in the EU Monitor.
| dossier | COM(2019)629 - Progress in developing the electronic systems provided for under the Customs Code. |
|---|---|
| document | COM(2019)629  |
| date | December 13, 2019 |
It is envisaged that an agreement with Member States on the revised Annex B will be reached by the end of 2019 and the related legislation will then be adopted in 2020. However, Member States are concerned that this instability negatively impacts their national planning efforts. Specifically, they agree that the frequent addition of new obligations and deadlines via the updates to the UCC WP jeopardises their ability to reflect the common data requirements in their national systems. However, it should be noted that the current review of the UCC WP has become necessary in order to properly implement the amended Article 278 of the UCC. The amendment to Article 278 of the UCC is the result of the compromise found between the European Parliament, the Council and the Commission. The applicability of the different columns of Annex B to the UCC-DA is linked to the deployment dates of the electronic systems defined in the UCC WP.
5European Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No 952/2013 of the European Parliament and of the Council as regards detailed rules concerning certain provisions of the Union Customs Code (OJ L 343, 29.12.2015, p. 1).
Another concern that Member States have expressed is the instability created and the difficulties to plan due to the ongoing review cycles of business and IT documentation.
These review cycles (where documents go through iterative updates as a result of input from experts) are necessary to ensure a common understanding and implementation of the systems. Where Member States depend on the finalisation of the project documentation, they sometimes do not yet have any form of national planning for some projects. Though many Member States express their willingness to take mitigating actions to ensure that they respect the planning deadlines set out in the UCC WP, their impact assessment processes are long and complex and are slowing down their efforts.
Member States reported that they operate based on an “Agile”6 approach, which allows for flexibility. However, such an approach means that at the same time some projects are planned only six quarters in advance. Hence, these Member States do not yet have an accurate view on their ability to meet the target deployment dates for some systems.
Finally, new challenges will emerge, requiring new customs policy, legal and IT measures to be put in place, sometimes with urgency, and often endanger the already agreed planning schemes for the UCC WP implementation (e.g. e-commerce, etc.).
As a conclusion, there is for the moment no critical risk identified concerning the deadline for finishing the implementation of the UCC systems by the end of 2025. This said, the IT teams of the Commission and of the Member States Customs Administrations need to be provided with the appropriate resources to mitigate the existing high risks of missing deadlines for some of the systems, notably concerning national systems. There is a need to ensure appropriate statutory staff in the IT teams to lead the projects, and financial resources in the current Customs 2020 and future replacement programme to ensure the delivery by outsourcing partners. There is also a need to avoid scope creep and new legislation with an impact on Customs systems before the end of 2023. If these measures are in place, as per the recommendations of the European Court of Auditors report, the risk level should be reasonably under control.
Mitigation actions
A Multi-Annual Strategic Plan for Customs (MASP-C) dashboard is used as a progress tracking and information tool from the Commission side on its progress. The baseline for the dashboard milestones is the MASP-C 2019 and the UCC WP 2019. The dashboard is presented on a quarterly basis to the Member States (Electronic Customs Coordination Group) and the trade community (Trade Contact Group) for information and steering purposes.
The Commission is now not only monitoring progress against the main project milestones as in the UCC WP and MASP-C but is also setting specific interim milestones per project (e.g. milestones by which all Member States should have completed the conformance testing). Such closer monitoring is needed in order to make the deployment of the decentralised trans-European systems manageable and to avoid additional costs for operating old and new systems in case of an extended deployment window. As these core trans-European systems with their decentralised architecture will only be successful if all Member States have switched to the new environment, the Commission has urged Member States not to wait until the end of the deployment window to make the switch to the new
6A
method of project management, used especially for software development,that is characterised by the division of tasks into short phases of work and frequent reassessment and adaptation of plans.
systems. A “National Administration quarterly monitoring programme” for the trans-European systems AES and NCTS with Key Performance Indicators will run from 2020, in order to measure progress on a regular basis and raise flags well in advance where problems might occur.
As another accompanying measure, the Commission will establish a “National Administration coordination programme” in early 2020 to support Member States in the development and deployment of their national components for the trans-European systems. These systems are specifically targeted because, Member States agreed in 2016-2017 that the import, transit and export systems were the core systems and should be considered as the top priorities for deployment. As a number of Member States have pushed their transition work on the national systems and components related to import, transit and export procedures to the very end of the deployment windows, there is a risk that they haven't foreseen sufficient time for testing and finalising the deployments according to the common specifications and IT transition policy. As the trans-European systems will only function properly when all Member States have joined in, national deployment issues or delays will impact the trans-European system layer and endanger the timely completion.
In addition, based on feedback from the Member States the Commission already identified a risk of completion of the national systems due by 2022, in particular in relation to the entry of goods and import domain, which would negatively impact the completion of CCI.
These programmes will help to steer the IT transition process from 2020 with a dedicated helpdesk, webinars, bilateral visits, training, conformance testing follow up, quarterly progress reporting, service delivery management, etc. Member States and the Commission need to be well equipped to face the challenges ahead.
The output of these programmes is considered to bring valuable progress information and will be used for the future annual progress reports. It will provide for detailed progress information per project and per Member State.
4. CONCLUSION
In conclusion, it is evident that the Commission and Member States face challenges in ensuring the full deployment of the UCC electronic systems by the relevant deadlines. There are resource issues in Member States, the systems are complex and interconnected, and there must be a smooth transition from existing systems to upgraded ones, so that the impact on trade is minimised.
Nevertheless, it is also clear that tangible progress is being made. An important number of electronic systems have already been deployed and are now fully operational.
The remaining ones are mostly on track and planned to be completed in the period 2020-2025 in line with the planning of the projects defined in the UCC WP. A summarised overview of the planning and progress can be found in Fig 2 below.
Fig 2: Planning for UCC WP projects
With regard to these remaining systems, while a number of issues have been highlighted at Member States level, no critical risks have been identified at the time of writing of this report. The Commission and the Member States will continue their regular meetings to steer and monitor the projects via the MASP-C dashboards and via the reinforced planning and progress reporting requirements for the UCC WP implementation. The Commission and the Member States will also continue the elaboration and development work for the remaining trans-European systems in terms of business cases and vision documents, as well as to prepare the functional and technical specifications (including transitional technical specifications in some cases) as the basis for the systems rollouts and deployments.
The Commission is planning additional mitigating actions as of early 2020, in the form of a coordination programme to assist Member States in the deployment of their components of the AES and NCTS systems, in particular, and a monitoring programme to assess their progress in this area. With these managerial instruments, the Commission is confident that it has the appropriate mechanisms in hand to face the upcoming dynamic challenges. Many Member States, for their part, have expressed their willingness to take mitigating actions to ensure that they respect the planning deadlines set out in the UCC WP.
More details of the planning and status of each project are provided in a Commission staff working document published alongside this report.