Quick background: upgrading CHIEF (current system) to CDS predates Brexit. Introducing EU's new customs legislation in 2016 meant that new functionality required. CHIEF was also getting old and generally needed a revamp.
/2
So CDS was supposed to be ready in 2018. HMRC announced it will launch it in August 2018 and gradually move traders from CHIEF to CDS batch by batch.
What ended up happening was pretty normal for a large IT/gov project - delays. A lot of delays. Like really a lot. CDS delivery became a constantly moving target.
And that would have been fine if it hadn't been for Brexit
/4
Brexit meant a massive increase in customs declarations (estimated 500% increase).
CHIEF/CDS is the system that processes these declarations.
That was a problem as CDS wasn't ready and CHEIF wasn't good enough to cope with the projected numbers of post-Brexit declarations
/5
So after initially stating (repeatedly) that CDS will be ready on time, HMRC finally admitted it won't and decided to focus on increasing CHIEF's capacity.
/6
But CDS was still needed for the Irish Sea border due to that pesky NI Protocol and goods at risk issue. CDS can functionality that can handle that. CHIEF doesn't.
So NI traders and GB trader sending goods to NI were going to be moved to CDS before 1 Jan.
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And we were told that everything was going well with that.
There was still an issue with training and traders not being familiar with the new system. But there weren't any reasons to believe that something might be wrong.
/8
So issues with CDS migration are actually quite worrying. Here is why:
1⃣ CDS is an upgrade. Elaborate but still an upgrade. It's been in the works for over 4 years. If this system is delayed and we've run out of time how likely is it that other systems will be ready
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You know, the systems that don't exist and are being designed, built and tested in the last 3 months of this year: GVMS, TSS, IPAFFS etc.
If CDS isn't ready after 4 years we have 0 chance of getting the other ones on time
2⃣ No backup plan for NI
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If CDS isn't ready then we will need to revert to CHIEF and god only knows if CHIEF can actually handle all these declarations. I've heard that that hasn't actually been tested and HMRC is hoping for the best.
/11
3⃣ The Irish Sea border is of strategic importance and so politically sensitive (hello 🇪🇺 🇺🇸).
The evidence session points to a number of miscalculations when it comes to Gov's planning that can lead to catastrophic consequences
/12
If this is how well the Gov is prepared to handle such an important border, how well do you think it's prepared to handle everything else? How much thought has been given to everything else?
Don't they have a duty of care?
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CDS was the one system I thought we didn't need to worry about. The one area that has been prepped and tested.
I probably shouldn't be surprised but I actually am. This is really bad news
/ends
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that stood in the way of a compromise. Perhaps it was just the Brexit myth (sovereignty etc) or once again an example of this Gov talking itself into a corner.
I'll be very interested to see whether the UK will indeed "cave".
/2
As smn tweeted yesterday.
We've known for a while that there will need to be some movement on both sides for a deal to be reached - it's not possible for both sides to keep their current red lines.
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1⃣ Has no simplifications, full processes as of 1 Jan
2⃣ Is politically sensitive
3⃣ Border operating model hasn't been published
4⃣ Not given sufficient attention as considered "not a border" and politicised
One more thing to point out re EU vs UK border readiness is that HMRC used to be really good at this sort of thing (communicating with traders, providing guidance)
/1
A couple years back when the EU’s customs legislation was changing and MS needed to implement it HMRC was doing really well and provided clear info on time.
/2
Only a couple years back HMRC had a number of helplines and services helping traders and consultants like me to understand the official interpretation of the legislation (customs can be highly contextual).
It's not that preparing for Brexit was impossible, it's not even that trading under WTO terms is impossible (way more expensive and cumbersome but not impossible), it's just how insanely late we're with pretty much everything.
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