Corporate report

Accounting Officer assessment summary: Northern Ireland Trader Support Service Programme

Published 29 January 2021

It is normal practice for Accounting Officers to scrutinise significant policy proposals or plans of major projects, and then assess whether they measure up to the standards set out in Managing Public Money. 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 projects within the Government Major Projects Portfolio (GMPP).

Background and context

The Protocol on Ireland/Northern Ireland (NIP) exists to ensure that the progress made by the people of Northern Ireland (NI) in the 22 years since the Belfast (Good Friday) Agreement is secured into the future. The Protocol was designed as a practical solution to avoid a hard border on the island of Ireland, whilst ensuring that the UK, including Northern Ireland, could leave the EU as a whole, and protecting the integrity of the EU’s single market.

The NI Trader Support Service (TSS) provides a free-to-use service to support traders to meet their administrative obligations under the NI Protocol. The TSS is designed to meet the NI Command Paper commitment for HMRC to provide extensive support to NI traders. A funding allocation of £270m has been confirmed by HM Treasury.

The Programme adheres to HM Treasury’s Managing Public Money guidance. The Programme has been awarded GMPP status and has completed Q3 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. As part of GMPP the Programme will report quarterly to the GMPP Portfolio Office on progress.

Regularity

The Programme is part of HMRC’s work to implement the NIP, which became UK law under the EU Withdrawal Agreement Act 2020. The Programme does not require any additional legislation and complies with Parliamentary requirements for the control of expenditure, with Programme funds being applied only to the extent and for the purposes authorised by Parliament. The Programme spend has received relevant HMT approvals.

Propriety

The Programme continues to comply 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 government has committed to providing extensive support to UK traders to assist them to comply with their new administrative obligations under the NIP.

In assessing the case for support, it was clear that a combination of:

• the low business readiness starting point in relation to NI (trade between NI and GB having been excluded from earlier ‘no-deal’ preparations)
• the lateness of clarity regarding the NIP requirements
• the lack of intermediary capacity on the GB-NI route, and of Community Service Providers and software connectivity with the new Customs Declaration Service (CDS), which is the only NIP-compliant customs declaration platform

all pointed to the need for a temporary State-supplied service in order to achieve an acceptable level of NIP compliance after 31 December 2020.

While there was a case for charging for the TSS on a cost-recovery basis, this had to be weighed against the need for State support for the additional costs of customs obligations on what is largely intra-UK trade, at least on a transitional basis.

Supporting the continued flow of trade will support the UK economy and by facilitating trade within the internal UK market will help 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.

To secure value for money, the TSS was procured under an open procurement exercise carried out in accordance with public procurement rules.

Feasibility

The Programme procured an external consortium led by Fujitsu to recruit, train and employ customs agents to provide advice and complete import declarations on behalf of traders. The TSS went live on 21 December 2020 and will have full end to end connectivity with CDS by mid-February.

The Programme is subject to the requirements of the GMPP and is subject to review by the Infrastructure and Projects Authority (IPA). The Programme was assessed in an IPA gateway review in December 2020, which provided an independent view regarding feasibility.

Conclusion

As the Accounting Officer for HMRC, I have considered the Programme and assessed the proposal as value for money and deliverable. Consequently, I have approved it as of 27 January 2021. I have prepared this summary to set out the key points which informed my decision. If any of these factors change materially during the lifetime of this Programme, I undertake to prepare a revised summary, setting out my assessment of them. 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.

Signature:

Date of signing: 27 January 2021