Corporate report

Northern Ireland Delivery Programme: Accounting Officer Assessment Summary

Published 19 August 2026

Applies to Northern Ireland

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 (HMT) Managing Public Money guidance. 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).

An initial Accounting Officer Assessment of the Northern Ireland Delivery Programme was undertaken and published in August 2023. At that point in the lifecycle, the programme was at the beginning of delivering several key economic and political imperatives for the UK. There was clear oversight on cost and scope, and an experienced leadership team. The programme was therefore assessed as value for money and deliverable.

In the 3 years since, the programme’s scope and delivery length has been extended. The changes to scope are material to the position assessed in 2023. They reflect the incorporation of additional Windsor Framework requirements, the extension of the delivery lifecycle from 3 to 5 years, and the funding required to complete delivery and enable programme closure.

Background and context

The Northern Ireland Delivery Programme, ‘the programme’, was established as part of HMRC’s 2021 Spending Review settlement to continue delivery of HMRC policy and legislative commitments for Northern Ireland (NI), following the United Kingdom’s (UK) exit from the European Union (EU). It includes delivery of the changes to HMRC systems and processes to enable HMRC and businesses to operate within the terms of the Windsor Framework.

The programme supports HMRC’s Vision to be a trusted, modern tax, customs and valuations department. It is specifically aligned to the department’s Strategic Objective to contribute to government economic aims, delivering changes to the UK’s customs regime by simplifying and streamlining customs processes and laying the foundations for further innovation in the customs system and international trade.

Assessment against the Accounting Officer Standards

Regularity

The programme was initiated to support the government’s commitment to implement the Northern Ireland Protocol and then the Windsor Framework. It 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’s scope remains within HMRC’s statutory functions.

Propriety

The programme adheres to HMRC’s Change Framework governance and undertakes the appropriate assessments and reporting. The business case for the programme was originally approved by HMRC’s Change Investment Design Committee and HMT in March 2022. The business case has been updated at key points since and was most recently re-approved in March 2026 within HMRC and by HMT. Clear governance processes are in place for effective programme management. A Programme Board is the main decision-making authority, and the Senior Responsible Officer (SRO) is accountable for delivery.

Procurement of suppliers follows HMRC’s established commercial governance process, ensuring appropriate scrutiny and challenge, and delivers value for money.

The programme became part of the GMPP in October 2022 and has since been subject to four National Infrastructure and Service Transformation Authority (NISTA) Gateway 0 Strategic Assessments. The programme was most recently reviewed in April 2025.

In April 2026, following reforms to the government’s spending and accountability framework under Project Reset, the programme was reclassified as a Departmental Major Programme (outside of GMPP).

Value for money

The programme has followed HMT’s Green Book methodology and 5-case model. Value for money has been assessed via an options appraisal which has been documented in the Programme Business Case. As the programme lifecycle has progressed the preferred delivery option has been revisited at each update of the business case. The value for money judgement is not based on a conventional financial return, rather it is based on whether the preferred option represents the lowest-cost and most deliverable means available to HMRC to meet obligations already committed under the Windsor Framework.

The benefits are understood as legal compliance and risk-avoidance rather than a conventional return-on-investment. Without this investment, HMRC would not meet statutory responsibilities, which would undermine delivery of the Windsor Framework, potentially leading to infraction proceedings and financial penalties. While these consequences cannot be monetised with precision, they are material to the value-for-money judgement because they represent risks that HMRC would otherwise incur by stopping short of compliance. There would be increased operational risk for UK businesses and disruption to GB to NI trade flows that are worth approximately £17 billion annually, illustrating the scale of trade supported by these arrangements. There would also be wider impacts on the economy and global confidence in the UK.

Feasibility

The programme leadership, supported by delivery partners, has the skills and experience needed to achieve the programme’s objectives within the required timeframe. The programme regularly monitors progress against delivery plans, risks and dependencies, with action being taken when it is appropriate to do so. Confidence in the programme’s continued feasibility is underpinned by its proven track record of achieving key milestones and successful delivery of systems that support the movement of goods under the Windsor Framework. This provides assurance that the programme can continue to deliver the remaining scope while managing delivery and operational risks effectively.

The most recent external NISTA review in April 2025 assessed the programme as Amber. The programme has continued to report Amber through formal quarterly GMPP reporting throughout 2025 to 2026, which represents the consistent delivery progress made while recognising the risks that have been managed.

The programme is in its fifth and final year, with the most complex system changes now being operational and it remains on course to complete the remaining planned outcomes. A Gate 5 assurance review organised by HMRC is expected later in 2026 to assess readiness for closure. The outcome of this review will inform subsequent governance decisions.

Conclusion

As the Accounting Officer for HMRC, I conclude that the Programme remains regular, proper, feasible and represents the most proportionate and cost-effective route available to HMRC to meet the government’s statutory and international commitments. I have therefore approved it as of 5 August 2026. 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 updated 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: JP Marks, Chief Executive HM Revenue and Customs

Signature:

Date: 5 August 2026