Corporate report

Accounting Officer Assessment Summary: Customs Declaration Service Northern Ireland Programme

Published 1 November 2021

It is normal practice for Accounting Officers to scrutinise significant policy proposals or plans to start, or vary major projects, and assess whether they measure up to the standards set out in HM Treasury’s Managing Public Money guidelines. From April 2017, the government has committed to make a summary of the key points from these assessments available to Parliament when an Accounting Officer has agreed an assessment of a project within the Government Major Projects Portfolio (GMPP).

Background and context

The Customs Declaration Service (CDS) was built as a replacement to Customs Handling of Import Export Freight (CHIEF) that would be compliant with the Union Customs Code. CDS has been live since August 2018 with IT delivery completed in May 2020. At this point the service had been built to handle the existing rest of the world volume of declarations on CHIEF (55 to 60 million per annum).

The Northern Ireland Protocol (NIP) was designed as a practical solution to avoiding a hard border on the island of Ireland, whilst ensuring the UK, including NI, could leave the EU as a whole, and protect the integrity of the EU’s single market.

The CDS Northern Ireland Programme (CDS NI) was established to deliver the functional and non-functional changes necessary for CDS to comply with the NIP. CDS will be used primarily as the declaration channel for Northern Ireland declarations; CHIEF will be used for all other customs declarations, although running CDS as the single future customs platform remains HMRC’s strategy. HMRC customs platforms may need to deal with up to 400m declarations per year; therefore, both customs platforms are continuing to dual run whilst scaling of CDS is completed and declarants prepare to move to CDS.

An announcement has now been made on GOV.UK around the closure of CHIEF and the implementation of the CDS as the UK’s single customs platform, which will take place on 31 March 2023. From this date, all businesses will need to declare goods through CDS. Migration to CDS is planned to finish by March 2023. CDS is currently used for Northern Ireland and Rest of World declarations and has already processed more than one million declarations since it went live in 2018.

Ahead of the 31 March 2023 complete closure, services on CHIEF will be withdrawn in two stages:

1. 30 September 2022: import declarations close on CHIEF
2. 31 March 2023: export declarations close on CHIEF / National Exports System (NES)

CDS NI Programme had approval to spend £154.43m for 2020 to 2021.

The Programme adhered to HM Treasury’s Managing Public Money guidance. The Programme satisfied the criteria for GMPP status and completed Q4 reporting for 2020/21 in accordance with the GMPP timeframes.

Clear governance processes have been established between internal stakeholders and these will be used for programme management and funding within the new delivery construct. The programme met its quarterly GMPP reporting requirements and exited GMPP at the end of quarter 4 of 2020 to 2021. An assessment of the programme’s progress has been published in the GMPP annual report.

Following the successful delivery of Release 1, to deliver the functional and non-functional changes necessary to for CDS to comply with NIP at the end of the Transition Period, Borders & Trade Delivery Group considered lessons learned and revised their delivery model to one that gives greater focus to the end-to-end journeys and places an even greater emphasis on the role of the customer. Delivery Directorates were established that focus on imports, exports and transit end to end journeys; and customer strategies that sit across these for traders, hauliers, intermediaries, ports and the rest of the supply chain.

The programmes that were within the old Customs Transformation Directorate, including CDS NI closed at the end of March 2021 as a result of the restructuring and residual scope has transferred to new GB and NI Delivery Directorates within the new Borders & Trade Release 2 Programme business case.

Regularity

CDS Programme was part of HMRC’s work to implement the NIP, which became UK law under the EU Withdrawal Agreement Act 2020.

The programme did not require any additional legislation and complied with Parliamentary requirements for the control of expenditure, with programme funds being applied only to the extent and for the purposes authorised by Parliament.

Propriety

The programme complied with Parliamentary requirements for the control of expenditure, with funds being applied only to the extent and for the purposes authorised by Parliament.

Value for money

Value for money has been assessed in an options appraisal in the programme business case. The agreed preferred option enabled smooth operation of customs processes to regulate and manage the movement of freight following the UK’s exit from the EU.

The projects delivered by the programme lay the foundations for the future strategic reforms supporting HM Government’s border ambitions of stripping out complexity, reducing administrative burdens on business and releasing resources through improved and streamlined processes.

Supporting the continued flow of trade supports the UK economy and by facilitating trade within the internal UK market helps to preserve the Union of Great Britain and Northern Ireland. Therefore, based on the benefit to the wider economy and given this is a priority for government, I deem this expenditure to be value for money.

Feasibility

The programme leadership, supported by delivery partners, had the skills and experience needed to achieve the project deliverables within the required timeframe. The programme has delivered against plan and has been subject to independent assurance reviews conducted by the Infrastructure & Projects Authority (IPA). The last IPA led (Hybrid) Gateway 0 assurance review for CDS NI was conducted in May 2020 and the (Hybrid) Gateway 1 in June 2020. Following completion of the programme the IPA concluded that the programme was ready to close and exit GMPP.

Conclusion

As the Accounting Officer for HMRC I have considered my assessment of the Customs Declaration Service Northern Ireland Programme and on balance the proposal was value for money and deliverable, I approved it as of 14 October 2021. I have prepared this summary to set out the key points which informed my decision. This summary will be published on the government’s website (GOV.UK). Copies will be deposited in the Library of the House of Commons and sent to the Comptroller and Auditor General and Treasury Officer of Accounts.

Accounting Officer’s name: Jim Harra, Chief Executive HM Revenue and Customs.

Date of signing: 14 October 2021