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February 28, 2019

Border IT Systems Aren’t Ready for Brexit: Plan A Scratched, Plan B Troubled

"The government assesses readiness of traders as one of its most significant risks"

By CBR Staff Writer

Six of the eight IT systems deemed “most critical for day one” after Brexit are at serious risk of not being delivered on time or in an adequate condition.

That’s according to a National Audit Office review [pdf] of projects highlighted by the cross-government Border Delivery Group published today.

Worrying, it said that HMRC had decided last month that a flagship new Customs Declaration Service (CDS) to handle and risk-assess customs declarations, and account for payment of duties, would not be ready for a no-deal Brexit.

But the fall-back option, the existing Customs Handling of Import and Export Freight (CHIEF) system, is riddled with issues and also may not be ready in time.

“Software developers may be unable to deliver all functional changes required”

” HMRC must complete further work to ensure CHIEF is ready for 29 March 2019. This includes work to ensure that CHIEF connects with other critical systems, including the Department for Environment, Food & Rural Affairs’ (Defra’s) Import of Products, Animals, Food and Feed System (IPAFFS) through the Automatic Licence Verification System (ALVS).”

” There also remains a risk that key delivery partners will not be ready. HMRC is working with BT and Community System Providers (CSPs) to upgrade the network links into CHIEF. CSPs had also expressed concerns that they may not have capacity to handle all the changes required to their systems for a ‘no deal’ scenario while still maintaining their systems for existing activity.”

“In December 2018, HMRC reported that software developers may be unable to deliver all functional changes required on CHIEF by 29 March 2019”

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Customs Declaration Service Migration

HMRC was in the middle of migrating businesses and traders from the CHIEF system to CDS, but technical issues have meant that customs software developers and Community System Providers have been unable to carry out all of the required product testing.

The HMRC told the NAO that because of the risk of a no-deal Brexit they have focused all of their attention on work and testing to implementing changes required for ‘day one of no deal’.

In the trader migration HMRC had expected to migrate 25 high-volume traders over to the new CDS system by the end of 2018. However they have ‘missed this target’, only managing to move four of the high-volume traders onto the CDS, which as stated above will no longer be the primary system on March 29.

Concerns over HMRC’s engagement with traders in the lead up to Brexit has been an ongoing concern.

Public Accounts Committee Chair MP Meg Hillier said in a letter to [PDF] to Jon Thompson, the permanent secretary at HMRC that: “You gave us no assurance that HMRC has a plan to ensure that businesses are aware of what they will need to do. We are particularly concerned about the 100,000 small traders that HMRC can not engage directly with, as you do not know who they are.”

Customs Declaration Service

In the event of ‘no deal’, on ‘day one’ different departmental systems must be connected to support operation of the border Image Source: NAO

Six Out of Eight Critical IT Systems at Risk

Meg Hillier commented today that: “It is alarming that six of the eight critical IT systems needed are in danger of not being ready in time and that government assesses readiness of traders as one of its most significant risks.”

These include systems such as Import of Products, Animals, Food and Feed system’ (IPAFFS) and the Automatic Licence Verification System (ALVS).

The issue is aggravated by the fact that these systems cannot operate effectively alone and their successful delivery is dependent on them being able to interoperate.

For example in the case of a bio security risk detected by IPAFFS it must first record the results of the bio security checks. If an animal or product has been cleared IPAFFS must then communicate information through CHIEF to ALVS IT network so custom officers can facilitate customs clearances.

Needless to say any failure in these system could result in significant delays at UK border entry points.

See Also: Alarm Bells Ring Over Crucial Brexit Customs IT System Delays

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