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National Audit Office says new Government border regime has created uncertainty and increased risk

23rd May 2024 / By Alistair Driver

The Government’s financial spending watchdog has issued some strong criticisms of the way the new border control regime has been implemented.

Dover portIn a report published earlier this week on ‘implementing an effective trade border’, the National Audit Office concluded that the Government’s Border Target Operating Model (BTOM) has created uncertainty and an increase in risk, while adding costs to the supply chain.

The government originally intended to introduce a full import control regime on January 1, 2021.

However, the NAO concluded: “More than three years after the end of the transition period, full import controls are still not in place. In addition, the model’s operation is still to be tested and the government may not be able to apply controls consistently as the controls are phased in.”

It concluded that the UK has faced increased biosecurity risk as a result of the phased approach to introducing full import controls.

“Departments have assessed that biosecurity risk to the UK has increased since the end of the transition period,” the report said. “The UK losing access to EU surveillance and alert systems also reduces its awareness of impending threats.”

The report discussed the government’s intention to apply new import controls ‘flexibly’ while Port Health Authorities s and local authorities recruit and train staff, and while traders adjust.

“While the government intends to scale up checks on a national basis, there is likely to be a period during which different levels of control and checking are operating at different ports. Stakeholders told us that they were concerned this could divert trade flows to the entry point of least resistance,” it warns.

Wasted spending

The report highlighted government estimates that it will spend at least £4.7 billion to implement new border arrangements. 

“The government’s new border target operating model should reduce costs to traders in comparison to its initial plans,” the NAO report says.

“However, repeated delays in implementing controls have meant ongoing uncertainty and an increase in risk, and the government and border stakeholders have also incurred unnecessary costs.

“This could have been avoided if the government had established a clearer vision of how the border should operate from the start, and had taken a more strategic and planned approach to implementation.”

The reported noted that changes in direction about the introduction of import controls have resulted in the government spending money on infrastructure and staff that were ultimately not needed.

For example, the government procured or built sites at Dover White Cliffs and Dover Bastion Point at a combined cost of £62 million, but subsequently decided they were not required when it adopted the new risk-based import control regime for SPS goods, which reduced the volume of goods which required checking.

HMRC also spent £258 million between 2020-21 and 2023-24 on building and running eight temporary border facilities to cope with additional demand which did not fully materialise.


The government’s 2025 UK Border Strategy included ambitious plans to use technology and data to facilitate the passage of legitimate trade, while still identifying people and goods at risk, an approach that most stakeholders supported.

“However, there is no timetable for achieving these ambitions, and the extended phasing of the introduction of full import controls has meant slower progress on other elements of the strategy,” the NAO report concluded.

The report will only reinforce industry concerns over the current state of border controls, particularly the decision to cut funding for illegal meat import checks at the Port of Dover to fund the new BTOM.