The EU's Import Control System 2 (ICS2) — advance safety-and-security filing before goods reach the EU border — has now closed its last gap. As covered when Release 3 rolled out, road and rail transport became subject to ICS2 from 1 April 2025, with the transition reported complete EU-wide on 29 August 2025. What that "complete" didn't mean, at the time, was everywhere: five member states kept running on the old system for road hauliers a while longer.
The five holdouts, and why
Croatia, Latvia, Poland, Romania and Slovakia were granted a temporary derogation allowing road carriers to keep filing safety-and-security data combined with the transit declaration in NCTS Phase 5 (NCTS-P5), instead of switching straight to a standalone ENS in ICS2. Until the derogation ran out, hauliers moving through these five countries could file either in ICS1/NCTS-P5 or in ICS2.
1 June 2026: the derogation ends
That grace period closed on 1 June 2026. From that date, ICS2 (or NCTS Phase 6 where a carrier is already on it) is mandatory for road and rail in all five countries too, and ICS1 has been fully decommissioned across every EU member state and every transport mode. The practical consequence is blunt: a road or rail movement into or through the EU without a valid ENS filed in ICS2 doesn't get a warning notice — it gets stopped at the border for a security risk check.
What it means for you
If your goods or your transit routes touch Croatia, Latvia, Poland, Romania or Slovakia, confirm with your carrier that ENS data now flows through ICS2 or NCTS-P6 rather than the old combined NCTS-P5 filing — the fallback option that existed until 1 June 2026 is simply gone. For everything else — what ICS2 is, its earlier release dates for air and sea, and how it fits alongside DMS 4.0, AES and NCTS: Customs IT systems.
Sources: European Commission — ICS2 Release 3 transition, temporary derogations · x7trade — ICS2 ENS and NCTS P6 for road & rail: the derogation period 2025–2026.