ICS2 Update: HMRC Confirms Extra Time for GB > NI Road/Rail ENS — What Traders Must Do Now

HMRC has confirmed that businesses moving goods by road or rail from Great Britain (GB) to Northern Ireland (NI) can keep using the legacy Import Control System Northern Ireland (ICSNI) for Entry Summary Declarations (ENS) until 31 December 2025 if they need more time to migrate to ICS2. Traders that are already on ICS2 should stay the course, and those close to migrating should continue preparations. From 1 January 2026, ICS2 will be mandatory for these movements.

Why this matters (and what changed)

The EU’s Import Control System 2 (ICS2) is the bloc’s advanced cargo pre-arrival security regime. It’s already live for air and maritime, and the final phase (Release 3 for road/rail) is moving into place across Member States. The European Commission reported on 29 August 2025 that the transition to Release 3 is complete, albeit with limited, temporary derogations in some countries. The Commission also published fresh operational guidance for road/rail, including how ICS2 interacts with the new NCTS Phase 6 transit processes.

HMRC’s communication gives GB→NI road/rail traders breathing room to finish their switch without disrupting supply chains, while still steering everyone toward the ICS2 dataset by the end of 2025.

ICS2, NCTS P6 and “who files where”: the quick explainer

• ICS2 is the EU’s pre-arrival security system. Economic Operators submit an Entry Summary Declaration (ENS) either system-to-system via the Shared Trader Interface (STI) or through the Shared Trader Portal (STP) after registering in the EU’s UUM&DS framework (accessed via the EU Customs Trader Portal).
• Road/rail in the EU from 1 September 2025: Under the Commission’s new guidance, where a Member State opted in to NCTS P6 derogation, the ICS2 ENS can be waived if the safety & security dataset is lodged in the P6 transit declaration within ENS time limits. Where a state did not request that derogation (opt-out), ENS via ICS2 is mandatory from 01/09/2025. Always check the Member State’s position before you move.
• France’s ELO (Enveloppe Logistique Obligatoire): Using ELO for full trucks that are covered by an ENS is only possible for operators who have migrated to ICS2. If you plan to cross into France, factor this into your timeline.

GB→NI (road/rail): what you can do between now and 31 December 2025

1. If you use the Trader Support Service (TSS):
   You can keep filing via ICSNI or switch to the ICS2 dataset when ready. TSS will move all users to ICS2 by 31 December 2025—no separate ICS2 registration required for TSS users.
2. If you don’t use TSS:
   You must register for ICS2 to file ENS via the EU systems. Start with HMRC’s “Register to use the Import Control System 2” guidance, and follow the steps to get access to the EU Customs Trader Portal (STP/STI).
3. Know when ICS2 applies in the UK context:
   ICS2 is used only for goods entering NI (not GB). For GB safety & security, use the separate GB service; for GB→NI you’ll use ICSNI or ICS2 during the transition.
4. Parcels under the Windsor Framework:
   B2C parcel movements from GB to NI do not require a customs declaration or ENS, while B2B parcels have specific data rules—review the government’s Windsor Framework parcel guidance.

GB→EU by road/rail: check the Member State and the date

For GB→EU movements, ICS2 requirements vary by country and timing during this rollout. Always verify whether your first EU country of entry expects an ICS2 ENS for road/rail from 1 September 2025, or whether they use the NCTS P6 derogation (and under what conditions). The Commission’s ICS2 landing page and the road/rail derogation guidance are your primary references. If you’re entering via France, plan for ELO adoption (and thus ICS2 readiness).

Key dates to circle

• 1 September 2025 — EU Release 3 (road/rail) in effect; some Member State derogations apply. Check whether ICS2 ENS is mandatory for your first EU country of entry, or whether NCTS P6 may temporarily cover the ENS data.
• Up to 31 December 2025 — For GB→NI road/rail ENS, HMRC confirms continued ICSNI use if you’re not ready, but migrate to ICS2 by year-end.
• From 1 January 2026 — ICS2 dataset mandatory for GB→NI (including TSS users).

Bottom line

If you move goods GB→NI by road/rail, you now have until 31 December 2025 to complete your migration to ICS2, with ICSNI remaining available in the interim. Don’t lose momentum: map your lanes, check Member State rules, register your interest for ICS2 filing with the Customs Declarations UK platform, and align data and timelines.

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