Policy & Compliance
ICS2 implementation for road and rail: a progress overview
Early feedback on the latest Import Control System 2 requirements (ICS2) suggests that the accuracy of data submitted remains a key area of focus for authorities
T he year has commenced without any new customs implementations being introduced. However, since 1 January 2026 traders moving goods by road or rail to the European Union, including Northern Ireland, are required to submit a safety and security declaration using the Import Control System 2 (ICS2). At the time of writing this article, no serious concerns have been raised by Members in relation to the current phase of ICS2 implementation. However, this should not be interpreted as an indication that the system is without any complexities, and compliance challenges may yet emerge. BIFA will continue to monitor the situation closely and engage with Members when further developments arise. Nevertheless, government officials have indicated that much like the earlier implementation of Safety and Security (S&S GB) requirements in the UK, one of the principal challenges relates to the quality of information submitted within the entry summary declarations (ENS). Accuracy focus Early feedback suggests that the accuracy of data submitted remains a key focus area for authorities. There are indications from the relevant government officials that they will actively support traders by providing additional guidance aimed at improving compliance levels. In this context, the release of ‘stop words’ has already proven to be a practical step in assisting declarants. Two such releases have been issued to date, offering
clearer guidelines around acceptable data inputs. This support is particularly important as accuracy requirements under ICS2 are stringent and more complex compared with the S&S GB information requirements. Consequently, poor quality
ICS2 permits multiple consignments to be declared within a single ENS, but under certain conditions. This clarification is particularly important for operators handling consolidated or groupage movements, where misinterpretation could lead to unnecessary duplication of declarations and wastage of working hours. HMRC is currently working on printed guidance addressing this issue, which is expected to be published in due course. Phased introduction The introduction of ICS2 will be phased over the course of the current year, allowing both authorities and industry time to adapt and implement the new requirements in the operational processes. BIFA will continue to monitor all ICS2-related developments and will inform Members promptly as soon as new information, guidance, or clarifications become available.
submissions increase the risk of delays or declaration rejections. Ensuring high quality data at this stage is essential, especially ahead of the planned introduction of house-level filing scheduled for later this year. BIFA has also raised with authorities a significant challenge previously experienced by traders during the introduction of S&S GB submission requirements, specifically related to the declaration of multiple consignments in groupage shipments under a single ENS. Similar uncertainty was identified by the trade community in relation to ICS2 requirements, prompting requests for clarification. Based on current understanding,
“ One of the principal challenges relates to the quality of information submitted within the entry summary declarations
February 2026 | 29
www.bifa.org
Made with FlippingBook Annual report maker