Madrid, November 27, 2025. The European Union has completed the roll out of ICS2 Release 3 for all transport modes, including road and rail. Some Member States granted temporary derogations during 2025, yet the direction is clear. From February 3, 2026 only v3 ENS messages will be used. If you still lodge v2 and need to amend after that date, you will have to invalidate and re-lodge in v3. This article explains what changes, who is affected, how to migrate without disruption, and how we connect from Essentos so your transition is safe, measurable, and fast.
What is ICS2 and why does it matter now
ICS2 is the EU customs safety and security system for Entry Summary Declarations (ENS) before arrival at the EU customs territory. With Release 3, coverage extends to maritime, inland waterways, road, and rail. The goal is better risk analysis based on complete, standardised data and more predictable controls at the external border. On September 1, 2025 ICS2 became fully operational in all Member States for all modes, with limited temporary derogations where granted.
In practice, this means more granular data, stricter validations, and time windows for ENS in road and rail defined by each national authority. Traders, carriers and terminals that prepare early will face fewer rejections and fewer manual fixes.
The dates you cannot move
- September 1, 2025. Release 3 is in force EU wide. Some Member States allowed temporary derogations for road and rail during 2025.
- Through December 31, 2025. Example Spain. The Tax Agency confirmed a postponement for road and rail until year end. Other countries published similar notes in 2025.
- February 3, 2026. Hard cut. Only v3 ENS messages remain. ENS lodged in v2 before the cut cannot be amended after that date. They must be invalidated and re-lodged in v3.
For planning and training, several customs authorities published deployment windows and phase calendars. Revenue Ireland is a useful reference, with Phase 3 for road and rail between April 1 and September 1, 2025.
Who needs to move now
You are in scope if you are:
- A road or rail carrier entering or transiting the EU.
- A freight forwarder or logistics operator lodging ENS at master or house level.
- An intermodal or rail terminal orchestrating pre-arrival events.
- An IT or EDI/API provider maintaining customs flows.
The priority is to migrate to v3 well before the cut and to align processes with your partners.
What changed with v3 vs v2
- New ENS message structures and tighter validations to reduce ambiguity.
- Better traceability between master and house data.
- Clear rules for amendments and invalidations with known impacts.
- Closer alignment with pre-arrival operational events and national system behaviours.
The Commission’s official ICS2 page is explicit. From February 3, 2026 only v3 is used. Any amendment of a v2 filing after that date requires invalidation and re-lodgement in v3.
Derogations in 2025, and Spain as an example
Derogations gave operators time to finish developments. They were temporary and country specific. Spain publicly confirmed a postponement for road and rail until December 31, 2025. DG TAXUD also published guidance for road and rail, including how derogations interact with NCTS upgrades. If you enter through a Member State without derogation, ICS2 was already mandatory for road and rail from September 1, 2025. Always check the national note and the DG TAXUD guidance before planning.
Operational impact by mode
Road. Presentation times are close to the border crossing. Accuracy for the first point of entry and the time window is critical.
Rail. You rely on train planning and events. Alignment with the rail operation and consistency with house level filers is essential.
Multimodal with ports. If you combine sea, rail, and road, pre-arrival milestones and coherence across port systems and ENS are the difference between smooth and painful.
What to do now
- Identify your role in ENS. Road or rail carrier, house level filer, representative.
- Register or refresh your credentials with your national customs and test the ICS2 channel now.
- Map v2 to v3 and stop relying on v2 well before February 3, 2026.
- Map mandatory and optional data and prepare operational evidence for audits.
- Orchestrate pre-arrival processes to hit ENS windows in road and rail.
- Align customers and EDI/API providers under a single transition timeline.
- Measure rejections and response times and fix root causes at the data source.
DG TAXUD and several Member States explicitly advise not to wait until December to switch. Early testing lowers rejection rates and avoids January bottlenecks.
How we connect from Essentos
Our role is to make this transition practical in real operations, without forcing hardware changes.
- Essentos Connect. We expose and consume APIs and EDI to map and send v3 ENS and to integrate pre-arrival events with national systems. We also consolidate status returns so every team reads a single source of truth.
- Essentos Operations. We turn each job into clear tasks with prerequisites and evidence. Photos, reads and signatures are captured with user, device, date, time and location. This reduces v3 rejections by eliminating missing or inconsistent data.
- Essentos Analytics. We track data quality, validation rejections, presentation windows, and productivity, and we keep a full audit trail.
We are software first and hardware agnostic. We integrate your current stack and align your data semantics with ICS2 structures.
External access with Essentos Plus
Essentos Plus gives secure external access to operational and documentary information. Customers, forwarders and shippers can see shipment status, pre-arrival events and download authorised documents without flooding your team with calls and emails.
- What users see. Status, recent events, coded incidents and their resolution with evidence.
- How they access. Roles and permissions by customer, contract or shipment. Expiring links, access logs, optional SSO and two factor authentication.
- Why it helps. Fewer resends, fewer discrepancies, and the same data that goes to customs via ICS2.
If you also run port interfaces, we can align with PCS or DUEPORT. If your flow includes road legs that use eCMR, we keep that document aligned with what you file for ICS2.
A realistic day migrating to v3
First thing in the morning the team prepares the v3 ENS with complete data. Connect validates business rules and sends through the national channel. Operations checks prerequisites and attaches evidence to each milestone. A minor warning arrives from the customs system. The operator fixes it in minutes and resubmits. The customer logs into Essentos Plus and sees the same status that customs is using for risk analysis. Later that day a change that used to be done in v2 is not allowed anymore. Because you already moved to v3, the update is clean, auditable, and does not block a truck or a train.
Common mistakes to avoid
- Waiting until January to test v3. The learning curve becomes a rejection spike.
- Master and house out of sync. Lack of coordination multiplies amendments.
- Weak data for sensitive goods. Poor descriptions and codes trigger unnecessary controls.
- Ignoring the entry country. Rules and windows vary by administration. Check the national note and DG TAXUD guidance.
Test plan before the cut
Phase 1. Lab. Unit tests for v2 to v3 mapping. Syntactic and business validations with edge cases.
Phase 2. Integration. Full ENS v3 filings with status returns. Controlled amendments and invalidations.
Phase 3. Live pilot. Representative corridors by country. Monitor rejections and response times in production.
Exit criteria. Rejection rate under your threshold, time inside the presentation window, trained teams and signed procedures.
Project checklist to be ready on time
- Name an ICS2 program owner and a core team.
- Inventory corridors, entry countries and modes.
- Define presentation windows by flow.
- Complete the v2 to v3 mapping including optional fields that improve acceptance.
- Align contracts and SLA with EDI or API partners.
- Set up test environments and a pool of real cases.
- Run the three phase test plan and sign the exit criteria.
- Train traffic and documentation teams.
- Publish amendment and invalidation procedures.
- Turn on dashboards and alerts for rejections.
- Launch a live pilot in December to operate smoothly in January.
- Disable v2 before February 3 with clear operational safeguards.
KPIs to watch from day one
- Validation rejection rate for v3.
- Customs response time by corridor and country.
- Window compliance by mode.
- Share of shipments with complete evidence.
- Amendments and incidents before and after the v2 cut.
- Operational effort in minutes per file.
Myths you should drop now
- Migrating to v3 is only a format change.
- Derogations let me wait without risk.
- If the forwarder is ready, I am ready.
- Presentation windows are the same EU wide.
- Data quality does not influence controls.
- I can amend any v2 ENS after the cut.
- ICS2 does not touch my operations.
- An EDI provider equals a passed test.
- Two test filings equal a robust pilot.
- Audits can be solved with screenshots and emails.
90 day roadmap to the cut
- Days 1 to 30. Audit current v2 messages, map to v3, review data sources, register or refresh access to the national channel.
- Days 31 to 60. Pilot v3 ENS with real scenarios. Fix rejections. Tune rules in Operations.
- Days 61 to 90. Harden evidence and Analytics dashboards, train teams, and inform customers with Essentos Plus.
Request an ICS2 assessment
We review your v3 messages, orchestrate ENS with Essentos Connect, enforce prerequisites and evidence with Essentos Operations, measure rejections and time windows with Essentos Analytics, and activate Essentos Plus so your customers can view the same electronic truth you file to customs.