Impact assessment

Borders and Trade Release 2 Programme - screening equality impact assessment

Published 1 June 2023

Programme objectives

The Release 2 Programme ran from 1 April 2021 to 31 March 2022, and the assessment therefore only relates to this period.

The core objectives of the Borders and Trade Release 2 Programme (2021 to 2022) are:

• ending of staged customs controls and associated easements
• implementation of the Withdrawal Agreement, the Northern Ireland Protocol and the Trade and Cooperation Agreement
• stabilisation and resilience of the IT platform
• delivery of an effective, sustainable, and affordable operating model

Customer groups affected

The customer groups that will be impacted by the change are:

• VAT registered traders (Northern Ireland (NI)/Great Britain (GB)/Rest of World (RoW)/HV/ROI/EU)
• ports
• hauliers (UK and non-UK)
• airports (public, private and military)
• intermediaries (including Trader Support System (TSS))
• Community Software Providers (CSPs)
• software developers (SWDs)
• Express Operators (EOs) and Royal Mail Group (RMG)
• manufacturers and importers, economic operators
• carriers
• individuals
• gas, oil and electricity suppliers
• online market places

What customers will need to do

What customers need to do as a result of the change

The programme is making changes to existing UK IT systems, products and processes and introducing new systems/services to support government policy objectives at the UK Border supporting the implementation of the Withdrawal Agreement, the Trade and Cooperation Agreement, and in connection with meeting UK obligations in respect of implementing the Northern Ireland Protocol.

How customers will access this service

Access to the services will encompass various means dependent on what service or process the customer wishes to undertake. For example:

• the Goods Vehicle Movement Service (GVMS) will be in place for all imports, exports and transit movements at border locations which have chosen to introduce it and will be accessed via an HMRC portal, by subscribing to a service and accessing it via Government Gateway or by connecting to the service by way of an Application Platform Interface (API)
• applying for a Business Tax Account is achieved by accessing a web link on GOV.UK
• where necessary,third parties will gain access directly into EU systems, through an EU digital portal (itself accessed via GOV.UK) once access rights have been provided by HMRC
• SWDs, CSPs and Express Operators (EOs) will increase their functional integration and compatibility with Customs Declaration Service (CDS)
• we are keeping the Trader Support Service live in Northern Ireland to aid traders in their efforts to make timely declarations of goods movements
• building of new inland sites will enable customs and safety and security checks on goods travelling across the GB-EU border ensuring control at the border and preventing delays to flow of goods
• the New Computerised Transit System (NCTS) is a system of electronic declaration and processing that traders must use to submit Common Transit declarations. They can also use NCTS to submit Transports Internationaux Routiers (TIR) declarations electronically if they’re in Northern Ireland

When customers need to do this

The introduction of Staged Customs Controls (SCC) from 1 January 2021, means that customers will be required to be ready at different stages up to the date that full controls are in place. For transit movements, border locations will be able to use GVMS if they wish to automate the process of completing Office of Transit formalities, which is required from 1 January 2021.

Regarding UK obligations with respect to the Northern Ireland Protocol, we will expect customers to comply with Customs and S&S processes from 1 January 2021 for GB to NI movements.

For RoW to GB, Safety & Security (S&S) declarations are currently submitted into ICS. They will need to be submitted into the new S&S GB service from 1 January 2021.

For EU to GB, S&S declarations are not required to be submitted into S&S GB until 1 January 2022. This applies to all goods, even when moved under transit.

Assessing the impact

This screening equality impact assessment relates to the operational delivery of Release 2 rather than the provisions and requirements of the NI Protocol itself.

We assessed the equality impacts on all the protected characteristic groups in line with the Equality Act and Public Sector Equality Duty and section 75 of the Northern Ireland Act:

Racial groups

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

Disabled and not disabled

Impact on customers

Consideration should be given to those customers who use screen readers to access digital content.

Consideration should be given to potential accessibility issues for customers within this protected characteristic group who will not be able to defer responsibility to an agent.

Proposed mitigation

The proposed mitigation is:

• the services must be in line with HMRC, Home Office and GDS usability and accessibility guidelines
• HMRC already provides additional assistance for customers who are deaf or hearing impaired, blind or partially sighted
• all GOV.UK web content adheres to national and international standards such as W3C
• HMRC offers Extra Support Team services which can be accessed by those customers who cannot, for whatever reason, interact with HMRC digitally or who need additional support and reassurance
• clear guidance to help people via GOV.UK is provided and regularly updated; access to call centres, webchats, minicom, translation to provide direct support

Sex

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

Gender reassignment

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

Sexual orientation

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

Age

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group; although consideration must be given regarding impact on older generation customers, who may be more hesitant to engage digitally (although it is recognised this may not be the case for all those in the older generation population).

Proposed mitigation

HMRC offers Extra Support Team services which can be accessed by those customers who cannot, for whatever reason, interact with HMRC digitally or who need additional support and reassurance.

Religion or belief

Impact on customers

Some religious groups, follow rules related to computer use that may affect access to digital services.

Proposed mitigation

-An individual will be required to use an intermediary to submit a declaration on their behalf if their belief restricts them from doing so.

Carers

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

Pregnancy and maternity

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

Marriage and civil partnership

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

Political opinion (for Northern Ireland only)

Impact on customers

There is no evidence to suggest any specific impacts on those customers within this protected characteristic group.

People who use different languages (Including Welsh Language and British Sign Language)

Impact on customers

Some Welsh language speakers may be unable to use appropriate GOV.UK resources if not translated.

Proposed mitigation

Due to the relatively low numbers involved - and the fact that the proposed IT system changes are primarily operated by existing third parties/large operators - any need for alternative language versions of the services will need to be evidenced through external engagement and may be introduced at a later stage.

Opportunities to promote equalities

We have considered opportunities to promote equalities and good relations between people in each of the protected characteristic groups and those outside of that group. These are:

• looking at ways to improve communications
• notice boards in drivers’ lounges
• red/green indicators
• Registered Driver Scheme (RDS) app
• text message
• notification from logistics section
• access specific web page/portal to view outcomes
• digital provision will offer choice to individuals in this group to self-serve outside of traditional business hours to suit their needs

A full equality impact assessment is not recommended.