So this is a fascinating🧵
Why? Cause out of all the IT systems we need for 1 Jan I thought CDS was not the biggest issue.

Short one on why and a bit of background on CDS and what does that all mean in practice.
/1
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.

Spoiler alert - that didn't quite happen

/3


gov.uk/government/new…
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.

/7
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

/9
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

/10
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?

/13
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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More from @AnnaJerzewska

8 Nov
I'm still wondering whether we'll actually see signs of this newly found enthusiasm for compromising on the UK-EU deal.

Sure, the world has just become a somewhat lonelier place for the UK's PM but I'm just not sure that it was the promise of a UK-US deal

1/
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.

/3
Read 5 tweets
7 Nov
OMG
I have NEVER been this happy to lose a bet
Wow, CNN

"It's easier to be a parent this morning"
Read 4 tweets
6 Nov
The Irish Sea border:

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

/1
UK Gov's one initiative - TSS - was and is an area of risk as traders told it will submit declarations "on their behalf"

1⃣ Giving traders a false sense of security
2⃣ Insanely short deadline to develop a system of that complexity

👇
/2

None of this, as Peter reminds us, is new. Most of these issues could have been prevented.

There are a few points that were/are dependent on the deal with the EU/ Join Committee's work on NI Protocol.

But most wasn't.

/3


Read 5 tweets
30 Oct
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).

They had amazing experts.

/3
Read 5 tweets
29 Oct
An all-day webinar today with the Belgian, Dutch, French, and Irish customs authorities (as you might have noticed by my earlier tweets).

You know these traffic management systems we're trying to build in the last few months of this year? The have them ready.

/1
New customs officers, hired and trained.

New veterinary stuff needed for SPS checks? No problem, already hired.

Oh and Border Control Posts for SPS controls already built.

/2
Ports ready and processes in place.

Guidance for traders available for months. Direct comms sent to traders. Helplines! They have helplines!

Clear answers re forms and requirements.

/3
Read 7 tweets
27 Oct
Cause the last few years of CDS delays taught us nothing...

This will come as a shock to very few ppl but a couple of months is not enough time to build a new IT system, test it, train ppl and deploy it.

/1
"Haven't been given enough time and information" is the main problem everyone in the private sector faces.

It's the current mantra of companies and intermediaries

/2


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.

/3
Read 4 tweets

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