Transparency data

Northern Ireland Delivery Programme — summary business case

Published 19 August 2026

Applies to Northern Ireland

Overview

Following the United Kingdom’s (UK) exit from the European Union (EU), HMRC established the Northern Ireland Delivery Programme to complete delivery of the required changes to HMRC systems and processes for goods moving between Great Britain and Northern Ireland (NI), and other movements involving Northern Ireland, including those with the EU and the rest of the world. This was initially done under the terms of the Northern Ireland Protocol and subsequently the Windsor Framework.

The programme business case was first approved in March 2022 and has been iterated 4 times throughout the Programme lifecycle. The latest full revision (version 4.2) was approved by HMRC and HM Treasury in April 2025. In March 2026, an addendum to the Version 4.2 confirmed the final position on scope, costs and programme closure.

The programme is now in its fifth and final year, with the most complex system changes operational. The remaining period to April 2027 is focused on completing residual system changes, transitioning services to business as usual, embedding arrangement for future changes, and formally closing the programme.

This document provides a summary of the approved business case, reflecting the programme’s final scope, cost profile and delivery approach.

1. Strategic case

1.1. Case for Change

Following the UK exit from the EU, HMRC established the Northern Ireland Delivery Programme to complete the work required for HMRC to implement new customs, VAT and excise arrangements for goods moving between Great Britain and Northern Ireland, and other movements involving Northern Ireland, including those with the EU and the rest of the world. These arrangements initially under the Northern Ireland Protocol, then from February 2023, the Windsor Framework, introduced new legislative processes, that did not previously apply to goods moving within the UK.

For HMRC this has required changes to policy, IT systems and processes and how we support NI businesses. It has also introduced new customs authorisations and data sharing requirements, as agreed between the UK government and the EU under the terms of the Windsor Framework.

Under the Windsor Framework, Northern Ireland also remains aligned to relevant EU legislation, including the Union Customs Code (UCC), which provides the legal framework for customs rules and procedures across the EU. The UCC includes the Multi Annual Strategic Plan (MASP), a programme of system and process improvements that modernise border and customs operations, across EU Member States, and includes NI.

1.2. Objectives for the Programme

• to deliver the changes required to our systems and processes for HMRC and for businesses to operate under the terms of the Windsor Framework
• to meet HMRC’s legal obligations under the Windsor Framework and UCC for customs, VAT and excise

1.3. Strategic fit with HMRC and wider government strategies and priorities

The programme supports HMRC’s Vision, to be a trusted, modern tax customs and valuations department. It is specifically aligned to the departments Strategic Objective — contribute to government economic aims, including through delivering the UK’s customs regime by:

• simplifying and streamlining customs processes
• completing our programmes of major transformation
• increasing the resilience and stability of our systems and operations​
• laying the foundations for further innovation in the customs system and international trade

2. Economic case

2.1. Options appraisal

The requirement for change is fixed by international agreement, as set out in the Windsor Framework, and the need to ensure the continued flow of compliant GB to NI trade. The options appraisal undertaken at the outset of the programme in early 2022, therefore used social cost-effectiveness analysis, and considered the most efficient way to achieve the necessary outcomes.

2.2. The shortlist of options (from early 2022)

Option	Description	Outcome
1. Maintain pre-EU exit position	Retain existing arrangements without further investment or change.	Discounted — at an early stage as it would not support compliance with Windsor Framework or sustain the smooth flow of trade. It could lead to infraction proceedings and legal penalties.
2. Enhance Existing Service Model (TSS)	Continue to utilise existing service delivery arrangements to reduce the scale of internal transformation required.	Discounted — It would not materially reduce the need for wider system and operational changes. Delivery would still require significant investment and coordination, with limited evidence of a more efficient outcome.
3. Targeted Compliance Approach	Deliver a limited set of critical changes to support key requirements.	Discounted — It would not achieve full compliance with Windsor Framework and could affect the stability of established arrangements. It would not provide a sustainable long-term solution. It could lead to infraction proceedings and legal penalties.
4. Operationally Led Delivery Model	Deliver required changes while maximising the use of operational processes and resources to manage internal activities.	Discounted — Although it could meet technical requirements, it would increase operational complexity and reliance on manual processes. This could impact service quality and long-term value for money.
5. Full Compliance Delivery	Deliver the full scope of changes required to meet Windsor Framework and UCC requirements and support end-to-end compliance.	Preferred — enables full compliance with the Windsor Framework, supports the continued flow of trade, and maintains strong international relationships. It provides a sustainable, long-term solution aligned with programme objectives.
6. External Partnership Approach	Explore delivery of services through external platforms or partnerships.	Discounted — It would not align with the established framework and would not provide a viable or acceptable route to achieving compliance.

2.3. The rationale for the choice of preferred option

The preferred option taken forward delivers the full scope of required system changes, enabling compliant operations through stable digital services. It was selected because it provides the most effective and deliverable route to achieving full compliance while minimising operational, delivery and legal risks. It also provides a sustainable long-term solution for HMRC to operate the Windsor Framework. Alternative options would not fully deliver the required capability, would not provide effective support for UK businesses and would introduce greater delivery, operational and legal risks for HMRC.

2.4. Key programme scope and activities

The programme is now in the final year and throughout its lifecycle has delivered a series of enhancements to the Borders and Trade IT infrastructure. It has also introduced a range of digital systems, services and processes which together support the movement of goods and the management of associated customs regulatory requirements under the Windsor Framework and UCC.

Summary of key outcomes achieved:

• enhancements to the Customs Declaration Service and other HMRC systems, to enable Northern Ireland traders to submit declarations, calculate duties and for our systems to support the use of XI and EU EORI reference numbers and other policy requirements agreed with the EU. Including a Customs Duty Waiver Scheme allowing traders to manage and claim reliefs where goods remain within the UK or where duty liabilities are adjusted following movement
• the introduction of the UK Internal Market Scheme (UKIMS) and associated simplified declarations and Traders Goods Profile. Supporting simplified movements within the UK internal market by enabling UKIMS authorised traders to move goods using reduced data requirements
• the introduction of the UK Carrier Scheme allowing authorised carriers to move eligible consumer parcels without customs declarations or duties. This is supported by simplified declaration approaches, which enable a reduced dataset derived from core movement information to be submitted for high-volume consignments. Together, these arrangements support efficient parcel movements while embedding the necessary controls within a proportionate data requirement
• improved capabilities for sharing data with the EU providing near real time data for goods movements from GB to NI, sharing data from a number of HMRC systems to meet reporting, analytical and surveillance requirements. A key part of the Windsor Framework for ensuring goods move across the Irish sea in a controlled manner
• delivery of a new Import Control System (ICS2) to manage safety and security declarations across the EU and NI and support risk-based controls for goods movements
• delivery of a new Certificate Exchange System (CERTEX) enabling digital management and validation of licensed and controlled goods, replacing earlier processes and supporting more efficient goods clearance processes
• improved digital services for VAT by delivering eCommerce services — One Stop Shop (OSS) and Import One Stop Shop (IOSS), which enable NI businesses selling goods into the EU to account for VAT through a single registration and return, supported by an IOSS Intermediaries portal for agents acting on behalf of businesses
• improved digital services for Excise by re-platforming and modernising the Excise Movement Controls System (EMCS) to provide a fully digital service for managing the movement of excise goods

2.5. Focus for final year

Now in the final year, the focus is on completing the remaining delivery and decommissioning of obsolete services. Ensuring that the enduring systems and processes are supported and fully transitioned into steady state operation, with clear ownership and governance to maintain performance and manage future changes to maintain compliance with ongoing regulatory requirements.

2.6. Benefits

This investment in HMRC’s customs, VAT and excise systems is essential to support the effective and on-going implementation of the Windsor Framework and ensure continued compliance with the UK’s domestic and international obligations. The changes provide the digital capability required to support the arrangements, now in place, for the movement of goods between Great Britain and Northern Ireland, with benefits primarily arising from meeting policy, legislative and compliance requirements rather than direct financial returns.

The programme does not present a conventional return-on-investment case and does not lead to material cashable benefits. This reflects the nature of the requirement. Northern Ireland Delivery is primarily a compliance and legislative delivery programme. The value delivered by the programme is therefore best understood through non-cashable benefits and the counterfactual consequences of non-delivery.

The investment enables HMRC to continue delivering a modern, resilient and compliant customs service that facilitates trade while maintaining appropriate controls to protect the integrity of the UK internal market and the EU Single Market. It ensures that customs systems remain fit for purpose, supports future policy and legislative changes, and provides a sustainable digital platform to operate the Windsor Framework, enabling HMRC to deliver its strategic objectives.

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.

3. Commercial case

3.1. Commercial approach

The programme has adopted a commercial approach aligned to HMRC’s existing delivery model for digital and technology services. Delivery has been undertaken through a combination of internal capability and external suppliers operating under established HMRC and cross-government commercial arrangements.

The programme did not seek to establish separate, programme specific contracts. Instead, it has made use of:

• existing HMRC contracts for digital and technology services
• centrally managed supplier frameworks
• established delivery relationships aligned to HMRC systems

This approach has enabled the programme to access the capability required to deliver complex system changes while maintaining consistency with HMRC’s wider technology architecture. It has also reduced procurement lead times and supported the delivery of time critical changes.

Commercial delivery has focused on achieving value for money within the constraints of legislative timelines and technical complexity. The programme has balanced:

• the need for specialist technical capability
• the requirement to deliver at pace
• the need to control cost and commercial risk

In practice, delivery has involved a mix of suppliers providing development, infrastructure and support services, working alongside HMRC teams. Responsibility for contract management has remained within HMRC’s established commercial structures, rather than within the programme itself.

4. Financial case

4.1. Financial cost of the preferred option

The Programme has a forecast total lifecycle cost of £717.7 million, covering the 5-year period from 2022 to 2023 through to 2026 to 2027. This reflects the latest approved position in March 2026.

Programme expenditure was predominantly incurred between 2022 to 2023 and 2024 to 2025, reflecting the delivery of large-scale changes across the Border and Trade IT infrastructure. All expenditure has been approved in line with HM Treasury spending controls. Budget is in place to deliver the remaining scope and to support programme closure. The approved funding profile is therefore sufficient to complete the remaining programme scope and support closure, with no further approval being sought.

Cost profile of the preferred option by year

Financial Year	2022-23	2023-24	2024-25	2025-26	2026-27	2027-28 to 2030-31	Totals
£ million CDEL	128.7	166.4	163.4	76.3	44.8	3.0	582.5
£ million RDEL	21.2	36.6	32.3	19.7	12.3	13	135.1
Total Whole life public sector cost	149.9	203	195.7	96	57.1	16	717.7

The approved programme funding profile includes £16 million from 2027 to 2028 to 2030 to 2031, comprising £4 million in 2027 to 2028 to support programme closure and £12 million for the ongoing operation and support of services through to 2030 to 2031.

4.2. Financial risks

Throughout the lifecycle of the programme, financial risk has been driven by delivery complexity, evolving requirements and dependencies across HMRC systems. These risks have been managed through contingency, prioritisation and governance.

5. Management case

5.1. Overall governance arrangements

The Northern Ireland Delivery Programme has been managed through established HMRC governance and assurance structures. The Programme sits within the Borders and Trade Group portfolio, with the Director of Customs Change as Senior Responsible Owner (SRO).

A Programme Board is the SRO’s key decision-making forum, with escalation through Borders and Trade Director General to HMRC Executive Committee.

Senior leadership has remained largely consistent throughout the programme lifecycle, with formal SRO and Programme Director appointments in place. Delivery has been supported by established teams and stakeholders with the appropriate knowledge, capability and experience to manage complex system changes across customs, VAT and excise.

From April 2022 to March 2026, the programme was part of the Government Major Projects Portfolio (GMPP). Following reforms to the government ‘spending and accountability framework’, the programme was reclassified as a Department Major Programme in April 2026, to simplify oversight and strengthen departmental accountability.

As a former GMPP, the programme has been subject to external assurance throughout its lifecycle, including 4 NISTA Gate 0 reviews. The most recent review in April 2025 provided an Amber Delivery Confidence Assessment and concluded that the programme was well placed to deliver its agreed scope, while providing recommendations to support the transition towards closure and business-as-usual operations.

A Gate 5 review organised by HMRC is expected in November 2026 to assess readiness for closure. The outcome of this review will inform subsequent governance decisions relating to programme closure to include residual scope, accountable owner, funding and delivery route.

5.2. Key milestones

Throughout the lifecycle the programme has successfully managed delivery of large-scale change, working to constrained timelines. This delivery is now largely complete, and the programme is planned to close by April 2027.

Following programme closure, there will be an ongoing need for changes to HMRC systems and processes to maintain continued compliance with our obligations under the Windsor Framework and UCC. This work will continue under separate delivery and governance arrangements.

The following table represents key milestones that have been achieved and are planned.

Milestone	Achieved/forecast
Programme start up	April 2022
Customs duty reimbursement scheme and digital account introduced	June 2023
VAT eCommerce OSS/IOSS core systems delivered	March 2024
EMCS Re-platforming and legislative changes for duty paid movements	August 2024
Windsor Framework new facilitations for trade and hauliers	May 2025
Windsor Framework — EU Data sharing requirements	November 2025
CERTEX operational	September 2025
Onboarding to new Imports Control System completed	December 2025
Complete remaining scope and handover activities	March 2027
Programme Closure	March 2027

5.2. Risk management

Risk management has been integral throughout delivery, including management of delivery complexity, capacity constraints and transition risks. These are managed through established governance and oversight arrangements.

5.3. Evaluation plan

Lessons learned have been captured throughout the programme lifecycle and will inform closure and evaluation activity. Programme evaluation will focus on confirming delivery of required outcomes and the operational effectiveness of services once fully embedded.

Post Programme closure, the ongoing evaluation of the services and processes the programme has delivered, will be undertaken by the established Northern Ireland Customs Sub-Regime board.

Conclusion

During its lifecycle, the Northern Ireland Delivery Programme has delivered the system and process changes required for HMRC to support the operation of new trading arrangements under the Windsor Framework.

The programme is now in its final phase, focused on completing delivery, transitioning services to business as usual, and closing in a controlled manner. This summary of the latest approved business case sets out the programme’s strategic rationale, delivery approach and financial position at its final stage.