Getting ready for UKIMS - What you need to know

January 2025

The UK Internal Market Scheme (UKIMS) will be implemented on 31 March 2025.

We've put together a collection of answers to the most frequent questions we've been asked about getting ready for the introduction of the new arrangements.

What is the U.K. Internal Market Scheme Lane?

The U.K. Internal Market Scheme Lane is another name for the 'Green Lane' arrangements that were to be introduced under the U.K. Internal Market Scheme (UKIMS) on the 1 October 2024, but have now been delayed to 31 March 2025.

Under UKIMS, a trader moving 'Not At Risk' consignments from Great Britain to Northern Ireland can use the Simplified Process for Internal Market Movements (SPIMM) by submitting a reduced dataset of information via an Internal Market Movement Information (IMMI) rather than having to complete Supplementary Declarations or a pre-movement Full Frontier Declaration.

What is the reduced dataset?

This reduced dataset of information (H8) is data already typically held within ordinary commercial information and contains twenty four fields rather than the eighty plus fields that are required currently for all commercial GB to NI movements - and will continue to be required for 'At Risk' consignments following the full implementation of the Windsor Framework. This bespoke, significantly reduced dataset will be provided upfront to HMRC in most cases by means of the Trader Support Service (TSS) or via a trader’s chosen agent.

Traders moving goods under the U.K. Internal Market Scheme Lane will not be subject to customs checks, except where these are necessary as part of an intelligence-led, risk-based approach, and will not be required to complete a supplementary declaration.

The requirement to complete full import declarations will remain as per the current freight arrangements for 'At Risk' consignments.

Who is responsible for UKIMS declarations?

It is the responsibility of the UKIMS authorisation holder to use the U.K. Internal Market Scheme correctly. The authorisation holder must know in advance of declaring their goods if the movement is considered as 'At Risk' or 'Not At Risk'. If a consignment is declared as 'Not At Risk', you will need to be able to evidence this and hold supporting records of the movement for five years.

Further information is available from GOV.UK: Apply for authorisation for the UK Internal Market Scheme if you bring goods into Northern Ireland.

How do I know if the goods I receive from suppliers in GB / RoW are 'At Risk' or not?

If the compliance requirements of UKIMS are followed correctly, you should only be declaring goods received from either Great Britain or the Rest of World (outside of GB and the EU) as 'Not At Risk', if you know at the time of movement that the goods will not enter the EU, and that they will remain in the UK Internal Market.

If you cannot evidence, at the time of goods movement, that those goods are 'Not At Risk' then you cannot declare those goods as 'Not At Risk' under the U.K. Internal Market Scheme.

Traders should also note that the treatment of movements and the correct use of UKIMS applies to all movements to NI, whether:

• Moving on the TSS Simplified Procedure and completing a Supplementary Declaration,
• Or completing a pre-movement Full Frontier Declaration,
• Or post Windsor Framework full implementation and using the Simplified Process for Internal Market Movements (SPIMM) and submitting information via an Internal Market Movement Information (IMMI). 

I’ve been approved for the U.K. Internal Market Scheme (UKIMS). Does this mean that HMRC consider ALL my consignments as 'Not At Risk'?

Declaring items as 'Not At Risk' is a legal undertaking by the importer that for any consignments that they declare as 'Not At Risk' of entering the EU, they trade entirely, i.e. "wholly, purely" within the internal United Kingdom market.

As part of the application process for UKIMS, the applicant must accept the T&Cs on authorisation, which include nine declarations you must abide by. These declarations include the statement, "I will only use this authorisation to declare goods brought into Northern Ireland for release for free circulation which are solely for sale to, or final use by, end consumers in the U.K. This includes where those goods have been subject to non-commercial processing before their sale or final use".

If following application the trader is authorised, the letter of authorisation also states the conditions of authorisation as set out in the guidance and in Decision No 1/2023 of the Joint Committee established by the Withdrawal Agreement. The conditions include that the authorised trader must "not move any goods 'At Risk' of onward movement to the European Union (EU) under this authorisation" and that they "make the appropriate customs declaration for any 'At Risk' goods and pay any duties that are applicable".

I previously declared goods as 'Not At Risk' but I’ve now sold them to customers in Ireland (EU). What do I need to do now?

If the compliance requirements of UKIMS is followed, the above should not happen. In cases where this does happen, per GOV.UK advice you need to let HMRC know that the goods were declared incorrectly.

If you declared your goods 'not at risk' by mistake, you should apply for a voluntary clearance amendment (underpayment) from HMRC. You should not complete an additional declaration for the goods movement. If you submit another declaration for the goods movement, then you are declaring the goods more than once to HMRC, doing this does not amend the original goods movement information.

The liability for the accuracy of the movement information submitted remains with the UKIMS authorisation holder used to move the goods. If you are using a third party to complete your goods movements, you are still responsible as the UKIMS authorisation holder to ensure your authorisation is being used correctly. If you cannot evidence at the time of goods movement that those goods are 'Not At Risk' then you cannot declare those goods as 'Not At Risk' under UKIMS.

The treatment of movements and the correct use of UKIMS applies to all movements to NI, whether moving on the TSS Simplified Procedure and completing a Supplementary Declaration, or completing a pre-movement Full Frontier Declaration, or post Windsor Framework full implementation and using the Simplified Process for Internal Market Movements (SPIMM) and submitting information via an Internal Market Movement Information (IMMI).

Most of our deliveries from Great Britain come through Amazon or Fast Parcel Operators (FPOs). What will change with these deliveries after 31 March 2025?

From the 31 March 2025, full import customs declarations will be required to be completed for each movement in advance for 'At Risk' consignments moved via Fast Parcel Operators (FPO), i.e. 'At Risk' goods are goods that are either destined for or potentially could end up in the European Union either in their current form or following processing within Northern Ireland.

However, traders authorised under UKIMS moving 'Not At Risk' consignments from Great Britain to Northern Ireland can use the Simplified Process for Internal Market Movements (SPIMM) by submitting, prior to the movement, a reduced dataset of information via an Internal Market Movement Information (IMMI).

If you only trade internally within the U.K. market and can meet the eligibility criteria to declare your parcels as 'Not At Risk', you should consider applying for the U.K. Internal Market Scheme in preparation for these changes. 

If you still have questions about UKIMS and how to get ready for the new arrangements our team are on hand to offer fully funded advice. Select the link below to get in touch.