Delays and uncertainty hamper post EU exit border ambitions, says NAO report

Government has repeatedly changed and deferred its plans for the introduction of full import controls following the UK's exit from the European Union (EU). This has caused uncertainty for businesses and extra costs for government and ports, according to a new National Audit Office (NAO) report.¹

The UK's exit from the EU resulted in changes to how goods and services are traded between the two territories.

Government is currently operating a partial import control regime after delaying the implementation of full controls five times since the end of the EU exit transition period on 31 December 2020.²

It estimates that it will have spent at least £4.7 billion to implement new arrangements and improve the management of the border, but has not yet specified when it intends to have a full regime in place.

The repeated delays in introducing import controls, and difficulties forecasting requirements, have resulted in government expenditure on infrastructure and staff that were ultimately not needed.³ Late announcements about policy and uncertainty about the implementation of controls have also reduced the ability of businesses and ports to prepare for changes.

Though post EU exit border processes (including the introduction of full customs controls) have operated relatively smoothly, businesses trading goods between the UK and the EU have faced additional costs and administrative burdens.

In 2022, traders made 39 million customs declarations on goods moving between Great Britain and the EU. Meanwhile, HM Revenue & Customs (HMRC) is yet to update its 2019 estimate that completing customs declarations would result in an additional annual burden to UK businesses of £7.5 billion.⁴

The government is introducing new controls in 2024 relating to sanitary and phytosanitary (SPS) goods and safety and security declarations (SSDs),⁵ focusing on higher-risk areas such as plant and animal products that are more likely to be carrying pests and disease. The latest phase came into force on 30 April 2024, with further controls to come later. When fully implemented, these controls will cost traders an estimated £469 million a year, although some costs would have existed before the UK left the EU.⁶

The loss of access to EU surveillance and alert systems reduces the UK's awareness of impending dangers like African Swine Fever, and the phased approach to introducing full controls has increased biosecurity risk.^{7, 8} Ongoing uncertainties and differences in port readiness also mean that new SPS controls may operate on an inconsistent and incomplete basis for a period after they are introduced.

Implementing a full import control regime is part of the UK government's ambition of having “the world's most effective border, one that creates prosperity and enhances security for a global United Kingdom”.⁹  

However, its 2025 UK Border Strategy lacks a clear timetable and an integrated cross-government delivery plan, with individual departments leading different aspects of implementation.

Without strong mechanisms to report on delivery and hold departments to account, there is a significant risk that delivery of the Strategy's underlying programmes will fall well into the future. When it published the Strategy in 2020, the government committed to publishing an annual report setting out progress, but this will not happen until 2025 at the earliest.

Improving the functioning of the border is dependent on the successful delivery of the Single Trade Window (STW) digital programme, but the programme fell behind its original schedule and has since been replanned.¹⁰

The NAO report identifies challenges to the delivery of the STW, including overly optimistic timescales and an underestimation of the programme's complexity. HMRC acknowledges the challenges facing the programme and considers delivery to be back on track.¹¹

The UK government is still finalising its plans for the movement of goods into and out of Northern Ireland¹² and is working with the Northern Ireland Civil Service to implement new arrangements.

The NAO recommends that full border controls operate at all ports as soon as possible, with government departments and devolved administrations collaborating where necessary.

Other recommendations include refreshing the STW delivery roadmap and clarifying cross-departmental coordination, monitoring and reporting on the 2025 UK Border Strategy.

Gareth Davies, head of the NAO, said:

“The UK leaving the EU created a large-scale change in arrangements for the movement of goods across the border. However, more than three years after the end of the transition period, it is still not clear when full controls will be in place.

“The border strategy has ambitious plans to use technology and data to facilitate trade while managing risks. To achieve its objectives, government requires strong delivery and accountability – including a more realistic approach to digital transformation – together with effective monitoring to enable future improvements.”

Notes to editors

1. The NAO has reported six times previously on the management of the UK border. This latest report brings together information on the impact and cost of new arrangements, and on future risks and opportunities, and examines whether the government is on course to implement an efficient and effective trade border. Most of the arrangements required to implement new border controls, and the specific arrangements relating to the movement of goods in and out of Northern Ireland, are the responsibility of the UK government. However, SPS controls are a devolved responsibility in Northern Ireland, Scotland and Wales. The report covers devolved responsibilities only where the UK government and the devolved administrations need to work together to implement new arrangements.
2. The government has introduced some import controls since the end of the transition period, including full customs controls.
3. For example, government procured or built sites at Dover White Cliffs and Dover Bastion Point at a combined cost of £62 million, but subsequently decided they were not required when it adopted the new risk-based import control regime for SPS goods, which reduced the volume of goods that required checking. HMRC also spent £258 million between 2020-21 and 2023-24 on building and running eight temporary border facilities to cope with additional demand that did not fully materialise. Port Health Authorities (PHAs) recruited around 520 staff to undertake SPS checks, 370 of which were subsequently not required.
4. HMRC estimated in 2019 that completing customs declarations would result in an additional annual burden to UK businesses of £7.5 billion. It is currently working on a revised estimate which is likely to be significantly smaller due to lower than anticipated declaration numbers. HMRC informed the NAO that the primary reasons for its over-estimate included changes in behaviour by traders and intermediaries, such as submission of fewer declarations for more items, and a lack of detailed information about levels of trade with the EU prior to EU exit and how this would translate into declarations.
5. SPS checks involve inspections of animals, plants and their products.
6. £469 million is the government's estimate of the annual cost to traders of the SPS controls and safety and security declaration (SSD) requirements it is putting in place under its new border target operating model, some of which existed before the UK left the EU because of long-standing controls applied to imports from countries in the rest of the world.
7. In September 2022, Defra reported to ministers that less than half of the required checks on plants and less than 10% of those on live animals were taking place. In March 2024, Defra informed the NAO that the situation remained similar to that in September 2022.
8. The Department for Environment, Food & Rural Affairs informed the NAO that there had not been any outbreaks of disease resulting from the phased approach, but that the lack of requirement for Export Health Certificates for goods arriving from the EU would have made it harder to track the source of an outbreak, if one had occurred.
9. 2025 UK Border Strategy – HM Government, December 2020, p.10.
10. The STW is a digital programme that aims to both reduce friction for traders, particularly small and medium-sized enterprises, who wish to move goods across the border and enhance the efficiency and effectiveness of government processes through improved data sharing and analysis.
11. HMRC is leading the delivery of the STW programme on behalf of government.
12. As per the February 2023 Windsor Framework and the January 2024 Safeguarding the Union Command Paper.