Impact assessment

Excise Movement and Control System: screening equality impact assessment

Published 19 August 2024

1. Project objectives

The EU wide Excise Movement and Control System (EMCS) is the legal mechanism to move excise goods under excise duty suspension arrangements.

EMCS is a UK and EU-wide computer system that’s used to record duty suspended movements of excise goods taking place within the UK and the EU. EMCS captures and processes information about the movements online, validates the data entered and allows real time notification of the dispatch and receipt of duty suspended excise goods. It allows the exchange of secure online messages containing specific consignment and movement information between UK and EU trading partners.

The scope of this project includes:

• fixes to specification defects
• service enhancements to align with Legislative change
• increase and change to service functionality, the most significant of these changes involves the introduction of Duty paid movements onto the EMCS service so movements are managed electronically rather than the using the existing manual/paper process
• delivery of a modernised solution for EMCS on a new platform
• redesign of the EMCS trader portal to enhance the user journey and meet modern accessibility standards
• redesign of the integration and files exchanging information between EMCS and its associated systems

2. Customer groups affected

EMCS will affect:

• exporters
• importers
• warehouse Keepers
• registered consignors/consignee

3. What customers will need to do

3.1 What customers need to do as a result of the change

Northern Ireland customers need to re-enrol for digital services with a new number. All other changes relate to applying new guidance for systems.

3.2 How customers will access this service

The customers will access this service through the Trader Front End or third-party software.

3.3 When customers need to do this

When customers dispatch or receive duty suspended excise goods using EMCS.

4. Assessing the impact

Before the scheme started 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

There is no evidence to suggest there will be impacts on customers with any of these protected characteristics:

• racial group
• sex
• sexual orientation
• gender re-assignment
• carers
• pregnancy/maternity
• marriage/civil partnership
• political opinion (Northern Ireland only)

4.1 Disabled

Impact on customers

The population will be made up of disabled/not disabled (customer groups). 

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 for applying for the grant to an agent.  

Proposed mitigation

The new digital service will be available for self-employed only (not for agents). HMRC will provide support via contact centres for the completion of applications where needed. Agents will also be informed of their inability to file application on client’s behalf which will allow them to prepare their clients accordingly. 

HMRC provides extra support and reasonable adjustments for all customers who need extra help, for example because of their personal circumstances, mental health difficulties or physical disabilities.

All GOV.UK web content, adheres to national and internationals standards.

HMRC offers Extra Support Team services that 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 will be provided and regularly updated; access to call centres, webchats, minicom, translation to provide direct support.  

4.2 Age

Impact on customers

The population consists of multiple age groups. There is no evidence to suggest any specific impacts on those customers within this protected characteristic group; although consideration has been given regarding impact on older generation customers maybe more hesitant to engage digitally although its recognised this may not be for all those in that 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. Channel shift strategies are considering the impact of age on digital capability so that access to alternative services is maintained for those customers who choose not to interact digitally. 

4.3 Religion or belief

Impact on customers

The population consists of customers with various religious beliefs. 

The intrinsic values of some religions, such as Judaism (the Sabbath) and Islam (Ramadan) limit the times of day or week when customers in this group can interact with HMRC services. 

Some religious groups, such as the Plymouth Brethren, follow rules related to computer use that may affect access to digital services. 

Proposed mitigation

UK tax law provides for the tax treatment of Islamic financial products.

Digital provision will offer choice to individuals in this group to self-serve outside of traditional business hours to suit their needs. 

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

Impact on customers

Population consist of diverse people who use different Languages, (including Welsh Language and British Sign Languages). 

Proposed mitigation

Due to EU not accepting Welsh language a waiver was agreed that Welsh language is not required

5. 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.

None have been identified.

A full equality impact assessment is not recommended.