Does Ukraine have a chance to develop and implement all the Customs IT systems required for EU Accession by 2030?
There are just over four years left until 2030. Time flies relentlessly, which calls for the utmost responsibility – almost with a stopwatch in hand – when it comes to all the “homework” Ukraine must complete on its path to EU membership. Among the top priorities is the customs area. Since the EU Customs Code envisions a paperless, fully digital customs environment, the readiness of both the IT systems and the legislation underpinning their operation will be the key criteria by which Ukraine’s preparedness for EU accession will be assessed in 2030.
The European Commission is proposing approaches that could ensure success even under these challenging circumstances and is ready to provide support for their implementation. Thus, in the summer, the European Commission’s Directorate-General for Taxation and Customs Union (DG TAXUD) shared with Ukraine’s Ministry of Finance and the State Customs Service a Guidance on Developing the Digital Customs Systems Required for the Implementation of the EU Customs Legislation, along with a comprehensive list of the customs IT systems mandatory for Ukraine’s EU accession.
The uniqueness of this information lies in the fact that it provides not only the system names but also the official sources where detailed information on each system is published. Through these links, which are accessible to authorized officials, one can continuously obtain up-to-date information on system requirements and updates.
This Guidance should serve as Ukraine’s primary source for planning and managing the development of customs IT systems, as it was specifically prepared for Ukraine as an EU candidate country (while the Multi-Annual Strategic Plan for Customs – MASP-C – serves as a reference document for EU Member States).
What do Ukraine should do?
A matter of scale
Ukraine, as a candidate for EU accession, must implement 24 IT systems. At present, only one of them – NCTS – fully meets all EU requirements. Its successful implementation provides a good foundation for optimism regarding the others, but it remains only the first “European block” in Ukraine’s customs IT architecture.
Naturally, Ukraine already has a number of developed customs IT systems and reasonably aims to make maximum use of them in the future. To do so, it is necessary to analyze each system for compliance with EU requirements (through a so-called gap analysis) and make an optimal decision: whether to upgrade the existing systems or develop new ones – and, if new ones are to be developed, when and by whom and with what funding.
To be considered a “completed homework assignment” by the EU, almost every system must pass through seven classic development stages – all before 2030: Gap analysis and assessment of the necessary scope of work based on EU requirements; development of technical specifications according to EU standards; actual system development; internal (national-level) testing; conformance pre-testing and conformance testing (where applicable); training for customs officials, businesses, and IT specialists and reporting for readiness of the Customs IT systems for EU accession.
Ukraine, with EU4PFM assistance, implemented NCTS following this approach. It took three years – just for a single system. This example clearly illustrates the scale of the work required. And yet – despite all the challenges – the task remains achievable.
A few words about priorities
When there are many tasks and little time, setting clear priorities becomes essential.
Firstly, among the 24 systems mentioned, two are key: the Customs Clearance System and the Risk Management System. According to the Enlargement Report 2025, it was recommended to develop new customs declaration clearance and risk management systems, which are identified as key elements for aligning with EU customs standards.
The Customs Clearance System must be developed in line with the EU Customs Data Model (EUCDM) and the data requirements of the Annex to the Union Customs Code (UCC). It must also include additional functionalities such as the Automated Export System (AES), the National Import System (NIS) based on the specifications for Centralised Clearance for Import (CCI). The new Risk Management System must, in turn, be compatible with the EU’s new Import Control System – ICS2.
Secondly, resources should be concentrated on systems and projects that require substantial national-level development, while wherever possible, Ukraine should leverage the functionalities provided by systems developed directly by the European Commission.
A few words about timing
To put it plainly – there is no time to spare. Ukraine is already behind schedule. However, with the immediate mobilisation of joint efforts, the plan, though extremely challenging, can still be fulfilled.
The complexity lies in the fact that, to successfully complete the seven development stages listed earlier by 2030, the key and most complex systems – the new Risk Management System and the Customs Clearance System – must be aligned with the EU Customs Data Model (EUCDM) and undergo testing and pilot operation by the end of 2027.
Several organisational steps to be taken by the Ukrainian side are recommended and – if implemented by the end of 2025 – could create realistic chances for success: appointment of project managers and establishing working groups for each IT system; approvement of a detailed Roadmap for each IT system (national planning) and establishment of a Steering Committee to monitor and manage the progress of all IT systems.
It’s important that progress should be assessed continuously throughout implementation.
The new Customs Code and IT systems: parallel development
The new Customs Code of Ukraine, based on the Union Customs Code (UCC) and its secondary legislation, will provide the legal foundation for the development and implementation of IT systems compatible with EU requirements.
A draft of this new “customs constitution” for Ukraine has already been developed, the related secondary legislation should be developed in 2026, and the entire legal framework is expected to enter into force in 2027.
What makes Ukraine’s approach unique in its preparation for EU accession is that the new Customs Code based on the UCC is being developed in parallel with the IT systems that will operate under it.
It is worth noting that Ukraine is acting much more rationally than many other countries did when preparing for EU membership. For many of them, the time gap between the entry into force of their Customs Code and the implementation of key customs IT systems was up to ten years. For example, the Union Customs Code (UCC) was adopted in 2013, and the EU Member States had approximately a 10-year time-frame for the development and implementation process. Over that decade, the UCC itself underwent multiple amendments – which meant that systems developed in the meantime also had to be repeatedly adjusted.
Ukraine, however, has every chance to avoid such a protracted process and to minimise the number of subsequent modifications. The proper planning could clearly and realistically demonstrate how EU customs legislation (starting with the new Customs Code) and the corresponding customs IT systems can be developed in parallel – as a single package.
At the same time, it is important to consider that the EU itself is planning a reform of its Customs Code, which foresees a gradual transition to a new digital architecture based on the EU Customs Data Hub. Therefore, Ukraine must closely follow developments in this area to ensure readiness for that transition within its EU accession objectives.
Loss of time increases the risks
Back in July, the EU’s Guidance Letter provided the Ukrainian side with a comprehensive overview of the actions required for the development of customs IT systems. Ukraine already has a CMU-approved Medium-Term Customs Reform Plan until 2030, which includes the development of customs IT systems necessary for implementing the EU acquis in the customs sphere. However, to deliver on this plan and ensure readiness for EU accession in 2030, Ukraine must develop and approve an appropriate Roadmap at the responsible authority level.
Its approval will serve as the starting point that will allow the entire process to be monitored: whether tasks are carried out on time, who is responsible. This Roadmap must comply with all DG TAXUD requirements for organising the management of the process based on DG TAXUD recommendations.
EU4PFM, as an EU-funded Programme, stands ready to support both the preparation of the Roadmap and its implementation, including financing the development of key systems. EU4PFM have already officially submitted detailed proposals to the Ministry of Finance and the State Customs Service.
The two key systems, to recall, are the Customs Clearance System and the Risk Management System. It is important to underline that we are referring to the development of entirely new systems aligned with EU requirements, as building new solutions ensures significantly higher efficiency and fulfilment of EU requirements than upgrading the existing ones, which means that the new core systems must be developed, and other related services should be upgraded.
In other words, to meet the EU-integration requirement of developing and implementing a new Customs Code of Ukraine based on the EU Customs Code, it is not enough to adopt the Code and the secondary legislation: the two above-mentioned IT systems and additional services must also be developed and implemented, with process of pre-conformance and conformance testing successfully completed.
In essence, any delay in launching the development of the new Customs Clearance and Risk Management systems will jeopardise that the new Customs Code and related secondary legislation enters into force in 2027. Given the complexity of these systems and the absence of an approved development plan, such a delay is, unfortunately, a realistic risk.
There is an additional consideration: compressed implementation timelines inevitably increase project costs. Even if these expenses do not fall on Ukraine’s state budget or other technical support.
Decision-makers must understand the cost of every day of delay – yet it is equally important to emphasise that, with timely and forward-looking decisions, which we are confident Ukraine’s authorities will take, the country can rely on the EU’s continued support and expert advice to ensure that the required customs IT systems are delivered successfully and on time.
Vytenis Ališauskas,
Key International Customs Expert,
EU Public Finance Management Support Programme for Ukraine (EU4PFM)
Dragan Jeremic
Key International Expert on IT
EU Public Finance Management Support Programme for Ukraine (EU4PFM)