BTOM Phase 5 – UK Border Controls 2026: What Changes for Your Business

What is BTOM — the Border Target Operating Model?

The Border Target Operating Model (BTOM) is the UK government's comprehensive plan for reorganising border controls following the country's departure from the European Union. The document, first published in August 2023, replaced the earlier Border Operating Model and set out a phased roadmap for implementing new import control requirements.

Why was it needed? After Brexit (1 January 2021) the UK formally left the EU Single Market and Customs Union. This required the introduction of border controls on goods imported from the EU. For the first few years the UK government repeatedly deferred full implementation, concerned about supply chain disruption and cost increases. BTOM was designed to bring order to this process and give businesses a clear timetable for change.

BTOM's core philosophy rests on three pillars:

• Risk-based controls — not every consignment is physically inspected. The system categorises goods by risk level (low, medium, high) and directs only those that require it to checks.
• Digitalisation — replacing paper certificates and forms with a fully electronic document flow.
• Proportionality — the cost of controls should be proportionate to the risk the import presents.

BTOM phases — what came before Phase 5?

To understand Phase 5, it helps to know the context of earlier stages. Each phase introduced a further level of controls:

Phase 1 (31 January 2022) — health certificates

The first phase focused primarily on sanitary and phytosanitary (SPS) goods. From this date, importers of animal products, plants and food into the UK had to hold Export Health Certificates (EHC) issued by the relevant authority in the exporting country. For Polish food exporters this meant obtaining certificates from the Chief Veterinary Inspectorate or the State Inspectorate for Plant Protection and Seed Inspection.

Phase 2 (30 April 2024) — physical checks at BCPs

This was the pivotal moment. The UK launched physical inspections of SPS goods at Border Control Posts (BCPs). High- and medium-risk goods (meat, dairy, live plants) became subject to physical inspection at the border. This brought Common User Charges and potential delays at ports such as Dover and the Channel Tunnel.

Phases 3–4 (second half of 2024 – 2025) — expanded SPS controls

Phases three and four extended controls to further SPS categories, including processed foods, composite products and wood. Pre-notification was introduced — a requirement to declare imports in IPAFFS (Import of Products, Animals, Food and Feed System) before arrival in the UK. Carriers had to adapt their logistics processes to meet new timing requirements.

Phase 5 (2026) — full digitalisation and the Single Trade Window

Phase 5 is the culmination of the entire transformation. At its heart is the UK Single Trade Window (STW) — a single digital platform through which all border declarations, certificates and notifications will be submitted. This is the most ambitious element of BTOM and the one that will change the day-to-day work of customs brokers, freight forwarders and carriers most profoundly.

What exactly does BTOM Phase 5 change?

Phase 5 introduces several fundamental changes that will affect every participant in the UK-EU supply chain:

1. UK Single Trade Window (STW)

The Single Trade Window is the UK government's flagship digitalisation project. Instead of submitting documents across several separate systems (CDS for customs declarations, IPAFFS for SPS, PEACH for plants, GVMS for vehicle movements), businesses will be able to submit one integrated declaration through the STW. The system will automatically distribute data to the relevant government agencies.

What this means in practice:

• One form instead of many — logistics, customs, SPS and security data entered once.
• Automatic validation — the system instantly checks completeness and accuracy.
• Real-time feedback — consignment status, inspection decisions and release notifications visible in one dashboard.
• API integration — logistics companies can connect their TMS/WMS systems directly to the STW.

2. Automated risk controls

Phase 5 introduces advanced risk assessment algorithms based on historical data, importer profiles and predictive analysis. The system will automatically determine which consignments require:

• Document checks — online verification of certificates and declarations.
• Physical inspection — goods inspection at a BCP.
• Automatic release — low-risk consignments from trusted operators may be released without human intervention.

For businesses with a strong compliance track record this means faster clearances and lower costs. For those with a problematic history — more frequent checks.

3. New requirements for ENS and SSD declarations

Entry Summary Declarations (ENS) and Safety and Security Declarations (SSD) are moving to a new data format. Phase 5 requires:

• An expanded data set — more information on sender, recipient, route and consignment contents.
• Earlier submission deadlines — ENS/SSD declarations must be submitted further in advance of the goods' arrival.
• STW-compatible format — no more manually entering data into separate systems.

4. End of paper SPS certificates

Phase 5 sets the deadline after which paper health certificates will no longer be accepted at the UK border. All EHCs, phytosanitary certificates and accompanying documents must be in electronic format, integrated with IPAFFS or submitted via the STW.

5. Changes to GVMS

The Goods Vehicle Movement Service (GVMS) — the system managing the movement of goods vehicles — will be more deeply integrated with the STW. This means changes to the way GMR (Goods Movement Reference) numbers are generated and managed. Carriers must ensure their systems communicate with the new version of GVMS.

Who is affected?

Phase 5 affects a wide range of operators. If your business operates on EU-UK trade lanes, these changes apply to you:

Importers into the UK

Businesses importing goods into Great Britain from the EU must adapt their declaration processes to the STW. This applies to both SPS and non-SPS goods. Importers are responsible for the accuracy of data in customs declarations and for working with their customs broker who submits those declarations.

Exporters to the UK

Exporters shipping goods to the UK should pay particular attention to:

• Issuing health certificates (EHC) in electronic format within the required timescale.
• Accuracy of commercial invoices and transport documents.
• Communication with the UK importer regarding new STW requirements.

Carriers and freight forwarders

Transport companies are most operationally affected. They must:

• Update IT systems to integrate with the new GVMS and STW.
• Train drivers on new BCP procedures.
• Ensure all documents are in electronic format before entering the UK.

Customs brokers and agents

Customs brokers (such as Easy Clearance) must adapt their software to the new STW APIs and updated declaration formats. This is also an opportunity — firms that implement new systems early will be able to offer faster and more reliable services.

Timeline — when do the changes take effect?

The UK government has published the following Phase 5 implementation schedule:

What you need to do NOW — preparation checklist

Whether you are an exporter, importer or freight forwarder, here are the concrete steps to take today:

For exporters to the UK

1. Check whether your SPS certificates can be issued electronically — contact the relevant competent authority. Confirm that your inspection body is ready to issue EHCs in electronic format to IPAFFS.
2. Update commercial invoice data — the new STW format requires additional fields (including expanded goods descriptions, 8-digit HS codes, full sender and recipient contact details).
3. Designate a compliance owner — someone in the business should track BTOM changes and communicate them to the team.
4. Contact your UK customs broker — confirm that your broker is STW-ready and ask about their migration plan.

For importers into the UK

1. Register for the STW pilot — if you import regularly, early access to the STW gives you time to test before the mandatory deadline.
2. Review your broker agreement — ensure your customs broker is planning STW migration and has experience with the new declaration formats.
3. Update your IT systems — if you use your own import management software, plan an API integration with the STW.
4. Train your team — new procedures mean new knowledge. Invest in training for your logistics and compliance teams.

For carriers and freight forwarders

1. Update your TMS — your transport management system must communicate with the new version of GVMS.
2. Prepare drivers — BCP procedures at Dover, Eurotunnel and other ports will change. Drivers need to know what to expect.
3. Ensure GMR numbers are generated in the new format — the old format may stop being accepted after Q4 2026.
4. Test electronic connectivity — before October 2026, confirm that you can send and receive documents in electronic format.

Cost impact — what to expect

Phase 5 is not just a procedural change — it will also affect costs. Here is what will affect your budget:

New BCP charges

Since Phase 2, importers have paid a Common User Charge (CUC) for physical inspections at BCPs. Phase 5 modifies the charge structure:

• Document check fee — from £6 to £30 per consignment (depending on commodity category).
• Physical inspection fee — from £40 to £145 per consignment (higher rates for high-risk goods).
• Reduced rates for Trusted Traders — businesses with AEO (Authorised Economic Operator) status or a strong compliance history may qualify for lower rates.

IT system adaptation costs

Integration with the STW requires a technology investment. For large freight forwarders this could run to tens of thousands of pounds. For smaller operators, costs will depend on whether they use proprietary software or the customs broker's systems.

Inspection times and potential delays

Paradoxically, in the short term (Q3–Q4 2026) there may be transitional delays as businesses and government systems adjust to the new model. In the longer term (2027+), automated risk controls should reduce clearance times for low-risk goods. The early weeks after each BTOM change have historically caused queues at Dover and Folkestone — worth factoring into transport planning.

Long-term savings

The STW is designed to reduce administrative costs for businesses trading with the UK. One submission instead of many, automatic validation and faster releases should translate into real savings. The UK government estimates that the STW could save businesses a combined up to £1 billion per year after full rollout. How those savings are distributed in practice remains to be seen.

BTOM Phase 5 and ENS/SSD declarations — the technical changes

For customs brokers and agents, the most significant changes are technical, affecting safety and security declarations. Key details:

• New ICS2 data schema — the UK adopts an expanded Import Control System 2 schema, broadly aligned with the EU standard but with UK-specific modifications.
• Mandatory 6-digit HS code — until now, a 4-digit code was sufficient in ENS declarations. From Phase 5, a minimum 6-digit commodity code is required.
• Sender and producer data — new fields requiring full details of the sender (not just the importer) and the goods producer.
• Submission time windows — ENS declarations for maritime containerised cargo must be lodged 24 hours before loading. For road freight (ro-ro) — a minimum of 2 hours before arrival at a UK port.

If you use our ENS/SSD services, you do not need to worry — we update declaration formats automatically.

FAQ — frequently asked questions

What is BTOM Phase 5?

BTOM Phase 5 is the fifth and final phase of implementing the UK's new Border Target Operating Model. It introduces full digitalisation of border processes, including the UK Single Trade Window — a single platform for submitting all border declarations.

When does BTOM Phase 5 take effect?

The STW pilot begins in Q2 2026. Key dates are 1 July 2026 (new ENS/SSD format mandatory), 1 September 2026 (STW available to all), 1 October 2026 (end of paper SPS certificates) and 1 January 2027 (STW mandatory).

Does BTOM Phase 5 only apply to SPS goods?

No. Phase 5 applies to all goods imported into the UK — both SPS (food, animal products, plants) and non-SPS (electronics, textiles, machinery, etc.). The STW covers all UK trade.

Do I need to change my customs broker because of Phase 5?

Not necessarily, but confirm that your customs broker is STW-ready. Ask about their migration plan, integration with new systems and experience handling the new declaration formats. A well-prepared broker (like Easy Clearance) plans for these changes well in advance.

How much will the new border controls cost?

BCP charges range from £6 for a document check to £145 for a physical inspection. The exact amount depends on the commodity category and type of check. Businesses with AEO certification or Trusted Trader status may qualify for reduced rates.

Could Phase 5 be delayed?

Historically, every BTOM phase has been delayed. The UK government reserves the right to postpone dates. We recommend preparing in line with the current timetable, but with a flexible contingency plan.

What is the UK Single Trade Window?

The Single Trade Window (STW) is a government digital platform that will replace multiple separate systems (CDS, IPAFFS, PEACH, GVMS) with a single point of contact. Businesses submit one declaration and the system distributes the data to the relevant agencies.

How will BTOM Phase 5 affect EU-UK transit times?

In the short term (Q3–Q4 2026) there may be transitional delays. In the longer term, automated risk controls should reduce clearance times, particularly for low-risk goods and trusted importers.

Current regulatory status

The BTOM Phase 5 timetable may change. The UK government has postponed previous phases on multiple occasions. The information in this article reflects the position as of April 2026 — check the latest announcements on GOV.UK.

Official sources

• GOV.UK: Border Target Operating Model — Cabinet Office, 2026
• GOV.UK: Single Trade Window Programme — HMRC, 2026
• GOV.UK: Import controls from the EU to Great Britain — Defra/HMRC, 2026
• GOV.UK: GVMS — Get a Goods Movement Reference — HMRC, 2026