ICS2 in 2026: What to lock down before year end 2025.

ICS2 implementation timeline for EU and Northern Ireland imports

ICS2 replaces ICS1 and ICSNI for Entry Summary Declarations on goods entering the EU and Northern Ireland.

The system applies to goods moving:

• From Great Britain to Northern Ireland
• From non EU countries into Northern Ireland
• From Great Britain into the EU

While the legal obligation starts on 1 January 2026, the operational transition is happening now. As 2025 closes, carriers and hauliers are finalising migrations, testing data flows, and stabilising processes ahead of live enforcement.

For supply chains connected to the EU and Northern Ireland, this is the last opportunity to confirm readiness before the new system is fully in force.

What is ICS2 and how does it change EU import controls

ICS2 introduces a different approach to EU import security and risk assessment. Authorities assess consignments earlier, using detailed pre arrival data rather than relying on information provided close to or after arrival.

This shift allows customs authorities to identify potential risks sooner and intervene earlier in the movement of goods.

For businesses, the practical impact is clear. Data quality and timing matter more than ever. Errors that were previously corrected later in the process are now identified upfront, often before goods reach the border.

ICS2 data requirements for Entry Summary Declarations

ICS2 significantly expands the level of detail required for Entry Summary Declarations.

Key data elements include:

• Clear and accurate goods descriptions
• Correct HS codes provided at an early stage
• Full buyer and seller details
• Precise weights, packaging, and delivery locations
• Data suitable for pre arrival risk analysis

For certain movements, Arrival and Presentation of Goods notifications are also required.

As go live approaches, incomplete or inaccurate data is more likely to result in holds, interventions, or delays before goods are released.

Who is responsible for ICS2 filings across the supply chain

Under ICS2, the legal responsibility for submitting the Entry Summary Declaration remains with the carrier or haulier.

Operationally, the data used to complete that declaration originates across the supply chain. Shippers, traders, forwarders, and logistics partners all contribute information that feeds into the filing.

This shared dependency becomes most visible at this stage. If upstream data is missing, late, or inaccurate, the carrier still carries the obligation, but the disruption affects the entire flow.

ICS2 makes data ownership and accountability visible in a way previous systems did not.

Why the final weeks of 2025 matter for ICS2 readiness

As 2025 comes to a close, ICS2 preparation has moved fully into execution.

Carriers are confirming final migration dates. Systems are live or close to live. Data requirements are being tested against real shipments rather than theoretical scenarios.

This is the last window to verify:

• That carriers and logistics partners are fully migrated
• That required data can be provided on time and at the correct level of detail
• That roles and responsibilities are clear if issues arise
• That manual workarounds are identified and removed

Once January 2026 begins, any remaining gaps tend to show up as operational friction rather than planning items.

ICS2 impact on shippers, carriers, and logistics service providers

ICS2 affects different stakeholders in different ways.

For shippers, the focus is on data ownership, internal alignment, and commercial risk. Poor data quality can quickly translate into delivery delays, customer impact, and additional cost.

For logistics service providers and carriers, ICS2 increases liability exposure and reputational risk. Inaccurate or incomplete filings can disrupt service reliability and damage trust with customers.

For both groups, success under ICS2 depends on coordination, clarity, and consistent data standards across partners.

ICS2 as part of wider EU customs and data driven risk controls

ICS2 is not a standalone change. It forms part of a broader EU customs transformation focused on earlier intervention, centralised risk analysis, and increased reliance on structured data.

This reflects a long term shift in how customs compliance is managed. Control increasingly starts upstream, long before goods arrive at the border.

Businesses that treat ICS2 as a last mile compliance issue may face ongoing friction. Those that use it to strengthen data quality and accountability are better positioned for future reforms.

Practical steps to finalise ICS2 readiness before January 2026

In the final weeks before go live, practical actions include:

• Confirming carrier and partner migration status
• Validating product and shipment data against ICS2 requirements
• Testing live or near live scenarios to expose weak points
• Aligning escalation paths for issues once ICS2 is enforced

ICS2 will apply regardless of preparation level. At this stage, the difference lies in how predictable and controlled operations will be once enforcement begins.