UKIMS — UK Internal Market Scheme: Who Must Register and How

Businesses trading goods between Great Britain and Northern Ireland — and indirectly also Polish exporters and importers working with partners in Northern Ireland — increasingly ask what exactly UKIMS is and whether it affects them. Below we explain the registration rules, the required documents and the most common mistakes in the application, relying solely on official gov.uk guidance.

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What is UKIMS — definition and legal basis

The UK Internal Market Scheme (UKIMS) is an authorisation issued by HMRC that gives access to simplified processes when moving goods within the United Kingdom's internal market — that is, from Great Britain (England, Scotland, Wales) to Northern Ireland. The mechanism was created under the Windsor Framework — the agreement between the United Kingdom and the European Union governing the status of Northern Ireland after Brexit. Since 9 June 2023 HMRC no longer accepts new applications for the UK Trader Scheme (UKTS); businesses register for UKIMS. The Windsor Framework arrangements for moves from GB to NI are described in shipping goods to Northern Ireland.

According to HMRC guidance, a UKIMS authorisation gives access to simplified processes for Internal Market Movements from Great Britain to Northern Ireland: you submit a simplified dataset (Internal Market Movement Information) based on commercial information instead of a full declaration. "At risk" goods are charged the applicable EU duty rate and go through the full customs process.

When goods are "not at risk" — significance for duty

The central concept of UKIMS is the classification of goods as "not at risk" of moving to the European Union. According to gov.uk guidance, goods meet this condition when they are intended for sale to, or final use by, end consumers located in the United Kingdom, the importer of record holds a UKIMS authorisation, and the goods are not subject to EU trade remedies. The authorisation only matters where the EU duty rate is above zero — if the EU rate is zero, goods from Great Britain are "not at risk" without it.

For goods undergoing commercial processing in Northern Ireland an additional threshold applies: according to HMRC guidance, a business may declare such goods as "not at risk" if it meets at least one condition: annual turnover below £2 million, imports of sheepmeat, poultry or beef under UK tariff rate quotas, or an approved purpose (food for sale to end consumers in the UK, construction, health and care services, not-for-profit activity, and animal feed used in Northern Ireland).

Who must register for UKIMS

UKIMS registration applies to businesses that physically move goods from Great Britain to Northern Ireland and want to use simplified declarations instead of the full customs declarations used for goods entering the EU market. In practice this covers both businesses registered in Northern Ireland and businesses from the rest of the United Kingdom.

The "established in the UK" requirement

According to HMRC guidance, the applicant must be "established in the UK". A business with its registered office or fixed place of business in Northern Ireland must have its human and technical resources permanently there, and its customs, commercial and transport records must be available in Northern Ireland. A business established elsewhere in the UK (England, Scotland, Wales) must carry out its customs operations in the UK, have an indirect customs representative in Northern Ireland — for example the free Trader Support Service — and keep its records available in the UK.

HMRC eligibility criteria

• Tax and customs record: the business must demonstrate a good record of tax and customs compliance over the last three years, with no serious or repeated breaches of tax and customs rules.
• No economic offences: HMRC checks the directors and employees responsible for moving the goods for serious offences connected with business activity.
• Financial solvency: the business must demonstrate its ability to meet its financial obligations over the last three years and must not be subject to insolvency proceedings.
• Operational competence: the applicant must show that it understands its obligations under the authorisation and can provide accurate information within the declaration system.

UKIMS registration — what documents and details are needed

According to gov.uk guidance, when preparing an application for UKIMS authorisation, a business should gather:

• An EORI number starting GB or XI (a business established in Northern Ireland applies with its XI number; others should use XI if they have one) — how to get a UK EORI number (GB and XI) is explained in a separate guide.
• Details of the business, its directors, the people in charge of it and the people responsible for moving the goods covered by the authorisation (date of birth, National Insurance number and address).
• The company number or Unique Taxpayer Reference (UTR).
• The date the business was incorporated or started trading, and a document of establishment or proof of a permanent business address.
• Annual turnover for the last full accounting period (a business without one gives anticipated turnover with supporting evidence such as a cash flow forecast).
• The estimated number of "not at risk" declarations planned per year.
• A description of the systems and controls used to keep records of the goods moved.
• Details of the customs representative, your VAT registration number and Trader Support Service number if you have them; for processed goods, the addresses where processing takes place.

How to register for UKIMS — step by step

1. Check eligibility against the HMRC criteria described above — failing any condition (e.g. established in the UK) disqualifies the application from the outset.
2. Gather the documents and details listed in the previous section, including the EORI number and the details of the people responsible for moving the goods.
3. Submit the application online on gov.uk after signing in to your HMRC account (Government Gateway). You can save your progress after each question and come back later.
4. Complete the application in full — HMRC expressly warns that incomplete forms or missing information delay the processing of the application.
5. Receive confirmation — after the application is submitted, HMRC sends an email confirmation with a unique case reference number.
6. Keep the required records once authorised: evidence that each consignment was "not at risk" (for example invoices, contracts and purchase orders, delivery receipts, consignment notes) must be kept for 5 years at a UK address HMRC can visit.

UKIMS and Northern Ireland — what it changes in practice for businesses

For businesses registered in Northern Ireland and moving goods from Great Britain, UKIMS means access to the Simplified Processes for Internal Market Movements instead of the full customs declaration required for goods "at risk" of moving to the EU. For Polish businesses trading with partners in Northern Ireland this matters indirectly: a counterparty on the British side that moves goods onward from GB to NI may need its own UKIMS authorisation (where the EU duty on the goods is above zero) to avoid EU duty on that leg of the supply chain. It is worth verifying this when planning delivery routes involving Northern Ireland, especially for financial and tax settlements between entities from different jurisdictions — more on this in our material on finance and tax for international businesses.

UKIMS does not replace other regulatory requirements applying to specific categories of goods — e.g. food products, for which separate sanitary and phytosanitary rules apply (see: the UK-EU SPS agreement and food exports). A UKIMS authorisation concerns the customs status of the move from GB to NI; it does not remove the formalities when exporting goods from Poland to the United Kingdom — we described the full list of documents and details to prepare before clearance in the 2026 UK export checklist.

The most common mistakes in a UKIMS application

• An incomplete form. HMRC expressly identifies incomplete answers as the main cause of delays in processing applications.
• No customs representative in Northern Ireland for businesses registered in the rest of the UK — without one, the application does not meet the "established in the UK" requirement.
• Incorrectly classifying goods as "not at risk" when in reality the goods will ultimately go outside the UK market (e.g. to Ireland) — such a declaration exposes the business to EU duty rates being charged retrospectively.
• Overlooking the turnover threshold for processed goods — businesses with turnover above £2 million that process goods in Northern Ireland must rely on another basis: a UK tariff rate quota or an approved purpose.

Sources

• GOV.UK — Apply for authorisation for the UK Internal Market Scheme if you bring goods into Northern Ireland
• GOV.UK — Internal Market Movements from Great Britain to Northern Ireland
• GOV.UK — Check if you can declare goods you bring into Northern Ireland 'not at risk' of moving to the EU

If your business moves goods to Northern Ireland or you need help with customs documentation on the British side, contact us.

Frequently asked questions