Policy & Compliance
The third and fi nal phase of ICS2 implementation is now under way ICS2 implementation – the fi nal straight
EU’s ICS2 share a common goal, ensuring safety and security of goods entering their respective customs territories, there are several important differences in how the two systems operate. S&S GB operates on a single-filer model, where one party (typically the carrier or freight forwarder) submits the complete Entry Summary Declaration (ENS) on behalf of all parties in the supply chain. Multiple fi ling ICS2 by contrast, introduces a multiple filing model. This means that different actors in the supply chain, including carriers, freight forwarders, and in some cases importers or express parcel operators, can each submit parts of the ENS data separately, contributing to a complete declaration. While this modular structure supports greater transparency and confidentiality of business data, it also introduces complexity and additional registration requirements. It requires clear coordination among supply chain partners to ensure that all required data elements are submitted accurately, on time and in the correct sequence. Misalignment or missing data from one party can lead to delays in crossing the border. While S&S GB onboarding is
T he Import Control System 2 (ICS2) is a major upgrade to how safety and security data is submitted and processed for goods entering the European Union. It also applies to movements into Northern Ireland under the terms of gradual replacement of the former ICS system, and the process has been completed in stages. The implementation of ICS2 began in March 2021, starting with postal and express carriers the Windsor Framework. The implementation has been a transporting goods by air. In March 2023, the second phase extended ICS2 requirements to all air freight operators. This brought general air cargo within its scope, requiring air carriers, freight forwarders and logistics providers to submit pre- arrival safety and security data for goods entering the EU by air. Phase 3 The third and final phase, currently under way, introduces ICS2 requirements for maritime, road,
and rail movements. Particularly important to UK traders is the inclusion of road freight into Northern Ireland, including accompanied and unaccompanied ro-ro movements from Great Britain. The deployment of this phase began in June 2024 when traders who required additional time to prepare could apply for a deployment window to slightly delay their onboarding. However, the current ICS-NI system will be fully retired on 1 September 2025. After this date, all Entry Summary Declarations (ENS) for goods arriving in Northern Ireland by air, sea, (road) must be submitted through ICS2. UK traders may recognise similarities between ICS2 and a system already implemented domestically. In order to comply with international obligations and maintain border security standards post-Brexit, the UK introduced its own Safety & Security (S&S GB) declaration requirements. While the UK’s S&S GB and the
“ Particularly important to UK traders is the inclusion of road freight into Northern Ireland, including accom - panied and unaccomp- anied ro-ro movements
18 | August 2025
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