Kiri

EN EN

EUROPEAN COMMISSION

Brussels, 16.10.2024

COM(2024) 458 final

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND

THE COUNCIL

pursuant to Article 14(3) of Regulation (EU) 2019/880 of the European Parliament and

of the Council of 17 April 2019 on the introduction and the import of cultural goods (28

June 2023 - 29 June 2024)

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Table of Contents

1. INTRODUCTION ............................................................................................................................... 3

2. OBJECTIVES TO BE MET ................................................................................................................... 4

3. PROJECT ARCHITECTURE AND PLANNING APPROACH .................................................................... 5

Phase 1 – Conceptualisation ............................................................................................................... 5

Phase 2 – System development .......................................................................................................... 5

Phase 3 – Deployment and Operation ................................................................................................ 5

4. PROGRESS OVERVIEW ..................................................................................................................... 6

Project development ........................................................................................................................... 6

Methodology: approach used for the implementation of the ICG System ......................................... 7

High-level planning .............................................................................................................................. 7

Request for Changes (RfCs) ................................................................................................................. 8

External synergies................................................................................................................................ 8

Internal Cooperation ........................................................................................................................... 8

Work with the Project Group on ‘Digitalisation of Cultural Goods’ .................................................... 8

5. RISKS FOR DELAYS ........................................................................................................................... 9

Risk 1 – Staff allocation ....................................................................................................................... 9

Mitigation actions .............................................................................................................................. 10

6. CONCLUSIONS ............................................................................................................................... 10

ANNEX I: MULTIANNUAL STRATEGIC PLANNING............................................................... 12

ANNEX II: MAIN PROJECT PHASES AND CRITICAL MILESTONES TIMELINE ............ 14

2

GLOSSARY

Business Case The document that provides the IT project justification

and defines its budgetary requirements.

Vision Document

The Vision Document elaborates on the assumptions

made in the Business Case Document. It records the

system owner/system supplier partnership and

understanding of the system at the time of writing.

Project Charter

The Project Charter replaces the Vision Document as per

the alignment with the Commission PM2/Agile

methodology. It records the system owner/system

supplier partnership and understanding of the system at

the time of writing.

ICG system Import of Cultural Goods system - the centralised

electronic system for the import of cultural goods.

TRACES

Trade Control and Expert System - the European

Commission's multilingual online platform for sanitary

and phytosanitary certification. It will also host the ICG

system.

EU CSW - CERTEX EU Customs Single Window - Certificates Exchange.

MFF Multiannual Financial Framework; the EU long-term

budget, running from 2021 to 2027.

BPM

Business Process Model - the application-level Business

Process Model describes the entirety of the business

process and flow of information for an application,

completing the System Business Process Model created

during the “System Specification” phase, to take into

account the application’s own needs.

BAC document The Business Acceptance Criteria document

PQTM Proximity Quoted Times and Means

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1. INTRODUCTION

Regulation (EU) 2019/880 of the European Parliament and of the Council of 17 April 20191

on the introduction and the import of cultural goods (hereafter “the Regulation”) aims to

prevent the illicit trade in cultural goods, in particular when it contributes to the financing of

terrorist activities, and to prohibit the import into the customs territory of the Union of

cultural goods exported illegally from third countries.

The Regulation subjects the import of certain cultural goods that are considered to be

particularly endangered (namely, archaeological objects and parts of monuments that have

been dismembered) to import licences and others, which are considered less endangered, to

importer statements and ensures that they undergo uniform controls when imported into the

Union. Certain imports of cultural goods that are intended for specific uses (educational,

scientific or research-related) are exempted from these documentary requirements.

The obligation for importers to obtain an import licence or draw up and submit an importer

statement to customs will only start to apply from the moment that a centralised electronic

system (the ICG system) will become operational.

The ICG system will not only serve as a means for the accomplishment of formalities by

operators, but also for the storage and the exchange of information between Member States

administrations in charge of implementing the Regulation (customs and cultural authorities).

The functioning of the ICG system depends on the EU Single Window Environment for

Customs established by Regulation (EU) 2022/23992, which provides a legal basis for the

functioning of the EU CSW-CERTEX.

The EU CSW-CERTEX represents the central component of the EU Single Window and is

developed by the Commission to link the national Single Window Environments for customs

to Union systems or databases managing non-customs requirements so that all relevant

authorities can access the relevant data and collaborate more easily on border checks.

Every 12 months from the entry into force of the Regulation and, until the ICG system

becomes operational, the Commission is to present a report to the European Parliament and to

the Council on the progress made with establishing this electronic system.

The first Commission annual progress report3 outlined the action taken by its services during

the first year after the Regulation entered into force, namely: (a) the preparatory work for

adopting the necessary implementing provisions, and (b) the consultations with the Member

States via the Expert Group for customs issues related to cultural goods and the Project Group

for the import of cultural goods.

The second Commission annual progress report4 presented the progress achieved with the

adoption of the Commission Implementing Regulation (EU) 2021/10795, as well as the roll-

1 OJ L 151, 7.6.2019, p. 1–14 2 Regulation (EU) 2022/2399 of the European Parliament and of the Council of 23 November 2022 establishing

the European Union Single Window Environment for Customs and amending Regulation (EU) No 952/2013 OJ

L 317, 9.12.2022, p. 1–23 3 COM(2020) 342 final 4 COM (2021) 358 final

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out of Phase 1 – ‘Conceptualisation’ of the ICG project, the work carried out by the Project

Group created for this purpose and the advancement of the Business Case and the Vision

Document for the ICG project.

The third Commission annual progress report6 covered the finalisation of the first version of

the package of Business Process Models for the ICG system; the finalisation of the Business

Acceptance Criteria (BAC) document; and the creation of user stories and their alignment

with the BAC, verifying the information needed for the developers to estimate and implement

the functionalities necessary to meet the requirements.

The fourth Commission annual progress report7 covered

(a) the start of developing the ICG system, i.e. the first internal releases, encompassing the

general functional infrastructure, as well as the core workflows.

(b) the extention of the core functionalities to the complete management capabilities and the

definition of new functional concepts such as the simplified procedure to obtain an import

licence for subsequent imports; applying for an import licence that covers multiple objects,

splitting a licence application; or the ICG third countries law compendium feature (the

Library).

(c) the launch of business activities for the EU CSW-CERTEX integration, so that import

licences or importer statements are accessible to customs via the EU CSW-CERTEX.

The present fifth annual progress report covers the period from July 2023 to June 2024. This

will be the last report before the ICG system becomes operational in the 2nd quarter of

2025. For the sake of completeness, the objectives to be met, the project architecture and the

planning approach, which are detailed in previous progress reports, are also briefly mentioned

here. The overall assessment of the progress made and the identified risks for delay are

summarised in the conclusions section of this report.

2. OBJECTIVES TO BE MET

The ICG system is to become operational by 28 June 2025 at the latest, as on that date, it will

become mandatory for all operators to obtain import licences or submit importer statements to

customs through that electronic system, in order for them to be able to import8 legally specific

categories of cultural goods into the Union.

The project is currently at its third phase, as most of the development has been completed and

the interconnection of the ICG system to the EU-CSW CERTEX is well underway. In

parallel, training sessions are organised to familiarise Member States administrations with the

ICG system’s operational functionalities.

5 Commission Implementing Regulation (EU) 2021/1079 of 24 June 2021 laying down detailed rules for

implementing certain provisions of Regulation (EU) 2019/880 of the European Parliament and of the Council on

the introduction and the import of cultural goods; OJEU L 234 of 2.7.2021, p. 67. 6 COM(2022) 580 final 7 COM(2023) 758 final 8 The Regulation defines as ‘import’ the placement of goods under the following customs procedures: release for

free circulation; storage in customs warehouses or free zones; temporary admission; and end-use, including

inward processing.

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The project on the import of cultural goods is also planned in detail through the Multi-Annual

Strategic Plan for electronic Customs revision 20239 (MASP-C Rev. 2023 v1.0). An excerpt

of the planning of the project on the import of cultural goods from MASP-C rev. 2023 is

provided in Annex I to this report (table 1 – Consolidated fiche 1.18 ‘Digitalisation of

Cultural Goods’), as well as an excerpt of the planning of EU CSW-CERTEX rev. 2023 from

MASP-C Consolidated Fiche 1.13 (table 2).

3. PROJECT ARCHITECTURE AND PLANNING APPROACH

As explained analytically in the first annual progress report, the Project Architecture is based

on the methodology provided for in MASP-C rev. 2023 and its Annexes, including the

Governance Scheme, the EU Customs Business Process Modelling Policy and the IT strategy.

A comprehensive roadmap, with the main project phases and the critical milestones is detailed

in Annex II.

Despite of the project progressing on several levels at the same time, it can be figuratively

divided into three main phases:

Phase 1 – Conceptualisation Initially, a Business Case is prepared, providing the project

justification and defining budgetary requirements. Further, the Level 3 (user requirements

BPMs) and Level 4 (functional requirements BPMs) are produced, followed by a Vision

Document, which provides more detailed information on the project definition in terms of

architecture, cost, time, and risk, as well as information such as milestones, deliverables and

project organisation.

Phase 2 – System development Based on the provisions of the implementing act, the user

requirements and the functional specifications for the system, technical specifications on how

the system will be constructed are developed.

Once the design of the system is ready from a conceptual perspective and the deliverables

listed in Table 1, Milestones 1 and 3 (see Annex I) are produced, a more in-depth work begins

and more technical aspects are taken into account in the Application & Service specifications

and Technical System Specification documents (concretisation of the Business Case and the

Vision Document). The ICG is to be integrated in the existing TRACES platform and

therefore it will reuse to some extend the existing specifications, architecture, messages and

interface.

Phase 3 – Deployment and Operation The actual IT development phase (Construction

Phase) begins, which is followed by a Transition phase where the early versions of the ICG

system will be gradually rolled out to the different groups of users and tests are performed to

ensure that, by 28 June 2025, operators and competent authorities are capable and well trained

in the use of the system. Then a 6 months after-care period will follow, during which the

system will be fine-tuned to match any operational needs that may become evident only after

the use of an IT system becomes mandatory, and to ensure that operations are running

smoothly.

As the ICG system will be interconnected with Member States’ customs systems via the EU

CSW-CERTEX, this activity will require Conformance Testing. While the date of

interconnection was originally foreseen for 3 March 2025, the Commission has prepared an

9 https://taxation-customs.ec.europa.eu/customs-4/electronic-customs_en and MASP-C Annex 2

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amendment to the EU SWE-C Regulation in order to align the applicability date with that of

Regulation (EU) 2019/880, i.e. by 28 June 2025 at the latest.

4. PROGRESS OVERVIEW

Project development

During the reporting period there has been substantial progress in the development of the ICG

system, as well as with regard to its integration with the EU CSW-CERTEX. Throughout the

reporting period, collaboration with Member States has been a top priority. To ensure that

their input and feedback would contribute to the system's continuous improvement and

successful implementation, several work meetings were organised. Those have taken place

both on a bilateral basis and within the Project Group on the Digitalisation of Cultural Goods.

Early feedback from Member States has been invaluable in refining the system, allowing the

Commission to address concerns and incorporate suggestions effectively. Four live

demonstrations of the ICG system have taken place throughout this reporting period, during

which Member States played a pivotal role in providing feedback and insights. Early

engagement with them facilitated the gathering of valuable feedback on prototypes and

functionalities, allowing for iterative improvements based on real-world usage scenarios. This

collaborative approach not only enhanced the usability of the system but also fostered

ownership.

Progress continued on both business and technical fronts for the ICG system and

specifications were adapted to meet the evolving needs. By keeping these specifications up-

to-date, the project ensured that it remained agile and responsive to changing requirements.

Strong focus was placed on testing the system in view of identifying and anticipating potential

problems while enhancing the user experience and reducing the chances of critical issues that

may occur post-deployment. Integration efforts with the EU CSW-CERTEX system

continued to be a priority to ensure that the customs control objective would be operational as

per the legal deadline of 28 June 2025.

During the reporting period the Commission has also been developing training modules on the

new import rules and the ICG system, as well as a user manual for the ICG system. The

design of the training materials and the development of the user manual underscore the

project's commitment to ensuring that end-users are equipped with the knowledge and

resources needed to leverage the system effectively. With regard to training materials, two

modules are being developed: one for competent authorities and importers and the second for

customs.

Notable progress was also made in the development of the ICG compendium comprising

succinct profiles of third countries’ legislation on export requirements. The so-called Library

feature of the ICG system aims to assist competent authorities, importers and customs in

informing themselves on the exact requirements for exporting cultural goods legally out of

third countries. To this end, extensive efforts were dedicated to refining and fine-tuning the

template to ensure that it accurately captures the relevant legal provisions and other key

details of the third countries in question and the first 12 profiles were drafted. The exercise

continues with the preparation of more country profiles, in close cooperation with the

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International Council of Museums (ICOM), in particular regarding countries for which a Red

List has been issued by that organisation.

In parallel, by embracing emerging technologies, the project aims to remain at the forefront of

innovation by exploring the potential integration of AI-driven functionalities for the

identification of cultural objects.

Methodology: approach used for the implementation of the ICG System

The methodological approach used for the implementation of the ICG represents a mix

between different Commission services’ methodologies and practices for conceptualisation,

quality assurance, development and deployment. In this context, the regular internal meetings

and demonstration sessions allow for discussing and implementing real functionalities,

avoiding too elaborate mock-up screens. The adaptive planning allows for responding faster

to expectations and changes in a flexible way.

To ensure effective feedback from future users and the successful implementation of the

system, Member States will be invited to participate on a voluntary basis as soon as a test

version is available. This collaborative approach aims to:

Engage stakeholders early: gathering diverse perspectives and insights that will be valuable

for refining the system. At the same time, an extensive demo was organised for the art market,

specifically tailored for them, highlighting the main workflows, while gathering relevant

feedback.

Foster collaboration: contributing to a more robust and user-friendly system.

Early familiarisation: Member States will have the opportunity to become familiar with the

system early in the development process, helping them understand its functionalities and

benefits before the date of the full deployment.

High-level planning

The ICG features are classified under different categories as presented below:

(a) “ICG core features with existing base in TRACES”: essential features where existing

functionality will be reused;

(b) “ICG core features without existing base in TRACES”: essential features to be built from

scratch;

(c) “ICG not core features”: important but not essential features;

(d) “External connections”: features that rely on external inputs;

(e) “Out of scope”: features not for the first ICG system version (e.g. Artificial Intelligence);

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Table 1: High-level overview of availability targets

Request for Changes (RfCs)

As per the Change Management Process, whenever a change is identified, this is registered in

a Request for Change (RfC) list. While the development activities are progressing and internal

discussions are ongoing, several changes are identified to be implemented at the Level 2-

Level 4 ICG BPMs. Therefore, the BPMs and BAC document are updated to reflect the latest

status considering the amendments. The Member States are informed about the changes,

however so far the modifications do not have any impact on them. As part of the external

review process, during the second quarter of 2024, Member States were asked to conduct a

formal review of all changes implemented up to that point and provide feedback or comments

as necessary. Member States approved the changes, having been informed in a timely manner

about the modifications, thanks to the close cooperation established through various forums.

External synergies

During the reporting period, the Commission has been liaising closely with international

organisations, such as UNESCO and ICOM in the context of populating the ICG Library with

quality third country law profiles, in particular for Red List countries10).

Internal Cooperation

An extensive cooperation exists between the Commission’s services responsible for customs

and for health, who are responsible for a number of policies that are deeply intertwined. The

operational framework of cooperation has been agreed between services and has been further

enhanced during the reporting period through continuous monitoring.

Work with the Project Group on ‘Digitalisation of Cultural Goods’

The Commission has created a Customs Project Group on the Digitalisation of Cultural

Goods11 which serves as a discussion forum for experts from Member States national customs

administrations and competent (cultural) authorities with experience in carrying out licencing

formalities in heritage matters, in particular digitally. The Group provided support in the

preparation of the implementing act, and is assisting the Commission services with defining

the parameters and elaborating the criteria for the functional specifications of the ICG system.

The Project Group12 currently consists of delegates from 15 Member States (AT, BE, BG,

DK, DE, EE, EL, ES, FR, HU, IT, LV, NL, PT and RO) and to-date it has met four times

(during the reporting period 29 June 2023 – 28 June 2024).

During this reporting period, the Project Group mainly examined and provided their expertise

and insight on the following subjects:

• Four demonstrations of the ICG system were conducted; during the last one (June 2024)

Member States had the opportunity to test the ICG system in a training environment, and

they were also informed about the pre-registration of operators (in order to avoid a large

influx of registration requests just before the date when the system is expected to go live).

10 https://icom.museum/en/resources/red-lists/ 11 The Project Group on Digitalisation of Cultural Goods serves as a discussion platform, where experts from

national customs administrations and competent (cultural) authorities with experience in carrying out licencing

formalities in heritage matters, in particular digitally, come together to provide support with the activities related

to the development of the ICG System. 12 For more details on the Project Group’s mandate and work, please see the Commission’s first Progress Report

COM(2020) 342 final.

9

• Establish the functionality of the ICG system supporting the temporary import of cultural

goods in exemption from licencing requirements in the context of commercial art fairs,

including a mechanism for follow up controls of the exempted imports by the competent

authorities and an alert mechanism in case the terms of the exemption were infringed.

• Define the template for the third countries law compendium, to help the ICG users

identify the export laws in third countries.

• Finalise the Administrative Cooperation module, allowing Member States competent

authorities to exchange information on documents managed in the ICG.

• Cooperation with the Member States regarding the services or departments they have

designated as competent authorities in their territory (for inclusion in the ICG).

• Progress on the training materials for the ICG system, including the ICG user manual, to

ensure users will be fully equipped with the necessary knowledge and skills to efficiently

operate the system.

• Incorporation of the feedback from Member States with regards to concrete workflows

such as : Split workflow, Partial rejection workflow, e-Seal, issuance of an importer

statement for the purpose of a commercial art fair and the related period of time for the

temporary admission, etc.

• Cooperation on the future translation activities for the ICG system, making it available in

all EU languages, ensureing inclusivity and accessibility for all users.

• Member States were consulted regarding the future extension of the ICG to include the

export domain13, ensuring an equal protection for European as well as for world cultural

heritage. Some examples of consultation with the Member States on the export topic

include : practice to issue open licences, the existence of digital solution to handle the

export certificates in the area of cultural goods, workflows at national level, etc.

Additionally, during the reporting period and as new functionalities were created and added to

the system, the ICG developers team made a demonstration to the Expert Group on customs

issues related to cultural goods14 and to the Expert Group ‘Dialogue with the Art Market’15 to

get feedback on the implementation of the new features. Three demonstrations were

performed in the context of the Project Group of Digitlisation of Cultural Goods, and a fourth

with the Customs Business Group (CBG), given the importance to familiarise all the Member

States with the ICG testing environment and not only the Project Group members.

5. RISKS FOR DELAYS

Risk 1 – Staff allocation

The initial proposal from the Commission did not provide for the creation of an IT system.

Thus, resources were not allocated accordingly. However, in the course of the negotiations

and at the request of the co-legislators, the creation of the ICG system was included in the

Regulation, which called for additional resources, unforeseen at that point. The needs for this

six-year project in terms of IT development personnel were estimated, at the time of the final

political trilogues in December 2018, to be two full time Administrator posts. To partly

mitigate this risk, an internal PQTM consultant was assigned from Q4 2023 to support the

13 Council Regulation (EC) 116/2009 on the export of cultural goods. 14 A Commission group composed by representatives of Member States customs and cultural authorities. 15A Commission group composed by representatives of art market associations, academia, international

organisations and other stakeholders.

10

Administrator in charge. This is intended to provide additional support, given that both the

AD and the PQTM consultant work only partially on the ICG project.

Despite the constraints, the Commission is committed to delivering the project within the

stipulated timeframe, ensuring compliance with the regulatory requirements. The legal

framework mandates that the system must be continuously maintained and operated once

established. Therefore, ongoing resource allocation is essential for proper aftercare.

Discontinuing support would negatively affect compliance with the legal requirements.

Sustaining a dedicated team will provide essential continuity, leveraging expertise for both

immediate support and future enhancements, thereby ensuring long-term reliability and

adaptability for the overall cultural goods domain, including import and, in the future, export.

Mitigation actions

The risk has been reported internally.

6. CONCLUSIONS

This progress report is the last one of the series as the ICG system will become

operational and Regulation (EU) 2019/880 fully applicable on 28 June 2025.

The main actions to develop the ICG system that were undertaken during the period covered

by the present 5th progress report can be summarised as follows:

• The reporting period saw significant advancements in the development of the ICG system

and its integration with the EU CSW-CERTEX. Collaboration with Member States

remained a priority, involving early participation for familiarisation with the ICG system

and feedback, which played a crucial role in refining its functionalities. Four live

demonstrations were conducted, allowing Member States to be actively involved in the

process and provide valuable insights and feedback, which led to iterative improvements

and enhanced usability.

• Several ICG functional concepts were agreed and completed, in close cooperation with

the Member States, to ensure the readiness of the system within the legal deadline.

• A strong focus was placed on testing to identify potential issues and improve the user

experience, reducing the likelihood of critical problems post-deployment.

• Additionally, progress was made on developing third country profiles for the ICG law

compendium (the Library), with extensive efforts to refine the template to accurately

capture export legal provisions and other key details for the targeted countries.

• The period also emphasised the development of comprehensive training materials,

including a user manual, to ensure end-users are well-equipped. Two training modules

are planned: one for competent authorities and importers, and another for customs.

• Planning the translations for the ICG system in close cooperation with the Member

States, to ensure the relevant linguistic skills and cultural knowledge necessary to

accurately translate technical terms.

• Integration with the EU CSW-CERTEX system remained a key priority in order to ensure

that customs will have all the necessary access to information for control purposes within

the legal deadline. Ongoing efforts are made to enhance system reliability and user

satisfaction through rigorous testing, focusing on identifying and addressing potential

issues pre-deployment.

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• Finalisation of the mechanism for the Administrative Cooperation, enabling Member

States’ competent authorities to exchange information on documents managed within the

ICG system.

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ANNEX I: MULTIANNUAL STRATEGIC PLANNING

The MASP-C ensures an effective and coherent management of IT projects by setting out both a

strategic framework and milestones within the legal deadlines established in legislation. It is ultimately

endorsed by the Member States in the Customs Policy Group (CPG) based on advice provided by the

Electronic Customs Coordination Group (ECCG) and consultations with trade at the Trade Contact

Group (TCG).

The planning for the electronic system has been discussed and approved by the Member States and is

described in detail in Fiche 1.18 of the MASP-C rev. 2023.

Table 1 below provides an excerpt of the planning of the project on the import of cultural goods from

MASP-C rev. 2023 Fiche 1.18.

Table 1 - Excerpt of MASP-C rev. 2023 Fiche 1.18

Milestones Estimated completion date

1 Business Analysis and Business Modelling

- Business Case Document Q4 2020

- Level 3 (User Requirements BPM) Q3 2021

- Level 4 (Functional Requirement detailed BPM) Q3 2021

2 Legal Provisions

- Current provisions adopted* Q2 2019

- Future provisions adopted** Q2 2021

3 Project Initiation Phase

- Vision Document Q2 2021

- GO decision Q2 2021

4 IT Project

- Application & Service Specifications Q2 2023

- Technical System Specifications Q2 2023

Construction Phase

- Central services implementation Q3 2024

- Service integration in National Systems N/A

- National implementation N/A

Transition Phase

- Deploy and rollout Q4 2024

- Conformance tests Q2 2025

5 Operation

- Commission, Member States administrations and

Traders

Q2 2025

- Non-EU Countries and non-EU traders (in case

required)

N/A

6 Implementation support (training and communication)

- Centrally developed training and communication Q4 2024

- National training and communication Q4 2024

*Current provisions refer to Regulation (EU) 2019/880

**Future provisions refer to the implementing provisions to be adopted according to Regulation (EU)

2019/880

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Table 2 provides an excerpt of the EU CSW-CERTEX project, with a focus on Component 2 of the

EU-CSW CERTEX project, interconnecting the ICG system.

Table 2 - Excerpt of MASP-C rev. 2023 Fiche 1.13 – Component 2 “EU CSW- CERTEX”

Milestones Estimated completion date

1 Business Analysis and Business Modelling

- Business Case Document Q1 2017

- Business Case Annex Q4 2023

- Level 3 (User Requirements BPM) Q1 2024

- Level 4 (Functional Requirement detailed BPM) Q1 2024

2 Legal Provisions

- Current provisions adopted* In force

- Future provisions adopted** 2022

3 Project Initiation Phase

- Vision Document Q3 2017

- Project Charter 16 Q4 2023

- GO decision Q4 2023

4 IT Project

- Application & Service Specifications Q2 2024

- Technical System Specifications Q2 2024

Construction Phase

- Central services implementation Q3 2024

- Service integration in National Systems From Q4 2024 onwards

- National implementation From Q4 2024 onwards

Transition Phase

- Deploy and rollout Q4 2024

- Conformance tests From Q4 2024 onwards

5 Operation

- Commission, Member States administrations and

Traders (NB: This is the Operations date for the

Commission, MS will conformance test from Q2 2020)

Q1 2025

- Non-EU Countries and non-EU traders (in case

required)

N/A

6 Implementation support (training and communication)

- Centrally developed training and communication N/A

- National training and communication N/A

*Current provisions refer to Regulation (EU) 2019/880

**Future provisions refer to the implementing provisions to be adopted according to Regulation (EU) 2019/880

16 To replace the Vision Document as per the alignment with the Commission PM2/Agile methodology.

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ANNEX II: MAIN PROJECT PHASES AND CRITICAL MILESTONES TIMELINE