EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, 16.12.2021  
SWD(2021) 386 final  
 
COMMISSION STAFF WORKING DOCUMENT  
         
 
Accompanying the document  
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL  
Final evaluation of the Regulation (EU) No 250/2014 of the European Parliament and of 
the Council of 26 February 2014 establishing a programme to promote activities in the 
field of the protection of the financial interests of the European Union (Hercule II I 
programme) and repealing Decision No 804/2004/EC  
{COM(2021)  809 final}   
 
1 
 Table of contents  
1. INTRODUCTION  ................................ ................................ ................................ ................................  2 
2. BACKGROUND  ................................ ................................ ................................ ................................ .. 6 
3. IMPLEMENTATION / STA TE OF PLAY  ................................ ................................ ........................  19 
4. METHOD ................................ ................................ ................................ ................................ ............  26 
5. ANALYSIS AND ANSWERS  TO THE EVALUATION Q UESTIONS  ................................ ..........  29 
6. CONCLUSIONS AND RECO MMENDATIONS  ................................ ................................ ..............  60 
ANNEX 1 - PROCEDURAL  INFORMATION  ................................ ................................ ...........................  68 
ANNEX 2 - STAKEHOLDE R CONSULTATION – SYN OPSIS REPORT  ................................ ..............  71 
ANNEX 3 - METHODS AN D ANALYTICAL MODELS  ................................ ................................ .........  88 
ANNEX 4 - LIST OF AC RONYMS AND ABBREVIAT IONS  ................................ ................................ . 90 
ANNEX 5 - GLOSSARY  ................................ ................................ ................................ .............................  91 
ANNEX 6 - EXTERNAL E VALUATION SUPPORT ST UDY ................................ ................................ .. 92 
 
2 
 1. INTRODUCTION  
The Hercule III programme  was one of the operational programmes implemented by the 
Commission under the 2014-2020 multiannual budget . It was a key component  of the 
EU’s two-pronged action to protect its financial interests: at EU level, internal control 
practices, audits and the investigations from the European Anti -Fraud Office (OLAF)  
seek to ensure value for money and combat fraudulent practice  and irregularities . In 
parallel, the EU supports Member States in multiple  ways in their work  to protect the EU 
budget at national level, including with material support . The Hercule III programme was 
the vehicle to provide that support for anti -fraud work over the last financing period .  
The EU budget for the subsequent multiannual period  2021 -2027 has increased 
substantially . An evaluation of the Hercule III programme can feed in  important lessons 
to the successor  programme , the EU’s new anti-fraud programme  (UAFP) . It mirrors  the 
overall approach of Hercule III, but adapts it to the ever -changing fraud landscape.  
Article 13(2)(b) of Regulation  (EU) No  250/20141 mandates  the Commission ( with 
OLAF as lead department ) to evaluat e the Hercule III programme . This Comm ission staff 
working document  accompanies the Commission report  on the achievement of the 
objectives of the Hercule III programme.  
1.1. Purpose  and scope  of the evaluation  
The purpose of the final evaluation is to analyse  the performance of the now finalised 
Hercule III programme  through a retrospective, evidence -based qualitative and 
quantit ative assessment . The aim is  to establish to what  extent the programme and the 
projects  it funded can be considered successful , and what lessons can be learn t for the 
future implementation of its successor programmes . Article 34 of the 2018 Financial 
Regulation2 states  that programmes and activities that entail significant spending must  be 
subject to both prior  and post evaluations, which must  be proportionate to the objectives 
and expenditure.  
                                                           
1 Regulation (EU) No  250/2014 of the European Parliament and of the Council of 2 6 February 2014 
establishing a p rogramme to promote activities in the field of the protection of the financial interests of 
the European Union (Hercule III programme) and repealing Decision No  804/2004/EC, OJ L 84 of 
20.3.2014 . 
2     Regulation (EU, Euratom) 2018/104 6 of the European Parliament and of the Council of 18 July 2018 
on the financial rules applicable to the general budget of the Union, amending Regulations (EU) No 
1296/2013, (EU) No 1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) 
No 1316/2013, (EU) No 223/2014, (EU) No 283/2014, and Decision No 541/2014/EU and repealing 
Regulation (EU, Euratom) No 966/2012, OJ L 193, 30.7.2018, p. 1.  
 
3 The aim of th is evaluation is also to comply with internal control framework principle 12 
(previously internal control standard 143): ‘the organi sation  deploys control activities 
through policies that establish what is expected and in procedures that put policies into 
action.’  
The scope, as set out in the evaluation roadmap4, is to evaluat e the performance of the 
programme  and to what extent its results will sustain in the longer term . It looks at five 
evaluation criteria: relevance  of all the programme objectives; (internal and external) 
coherence  of the programme ; effectiveness  in attaining it s objectives and expected 
results , including the sustainability of certain types of actions ; the efficiency  of the use 
of resources; the programme 's added value  to the EU and to society .  
The evaluation takes into account the findings of the 2017 -2018 Hercule III mid -term 
evaluation5, and data from the annual overviews on implementation of the programme, 
annexed to the Commission annual reports on the protection of the EU’s financial 
interests  (PIF Reports)  based on Article 325 of the Treaty on the Functioning of the 
European Union ( TFEU ). The timeframe  for the evaluat ion is the seven -year period  
between  1 January  2014 and 31 December  2020 , including  preparatory legislative and 
implementing activities.  
The main stakeholders  for this evaluation are  the programme beneficiaries and 
applicants, in particular national and regional administrations in the Member States;  
participants to conferences, seminars and training events organised with financial support 
from the programme ; partners that could  have an overview of action taken under the 
programme : the Advisory Committee for the Coordination of Fraud Prevention 
(COCOLAF6), the Anti-Fraud Coordination Service ( AFCOS , a national service 
designated by each Member State to facilitate cooperation and information  exchange 
with OLAF , including exchange of information of an operational nature) , the Network of 
Associations of European criminal la w, academic institutions and relevant Commission 
departments . 
                                                           
3      https://ec.europa.eu/info/sites/info/files/about_the_european_commission/eu_budget/revision -internal -
control -framework -c-2017 -2373_2017_en.pdf ; SEC(2007) 1341, 16.10.2007 – Annex 1: Internal  
Control St andards for Effective Management.    
4 The roadmap for the final evaluation of Hercule III was open for stakeholder feedback for four weeks 
between 15 June 2020 and 13 July 2020, accessible on the following website: 
https://ec.europa.eu/info/law/better -regulation/have -your-say/initiatives/12435 -Fraud -prevention -final-
evaluation -of-the-Hercule -III-Programme -2014 -20-_en. 
5 Commission staff working document (SWD(2018)  3 final, 10.1.2018) and Report from the 
Commission  to the European Parliament and to the Council (COM(2018) 3 final, 10.1.2018).  
6 COCOLAF c oordinates how the European Commission and its Member States go about combatting 
fraud involving EU money.  OLAF  coordinates COCOLAF on behalf of the Commission.  The 
participants are representatives from Member State authorities and from Commission departme nts. 
 
 
4 Certain  projects that started in 2020 – when possible, given that the COVID -19 
pandemic prevent ed physical meetings at certain moments – are still ongoing. The 
Commission will r eport on g rant agreements and most procurement contracts signed in 
2020 and on their effects at a later stage (2021 and onwa rds). 
This evaluation cov ers all current and previous EU Member States , including  
unsuccessful applications submitted by potential beneficiaries.  
The Commission will draw on the  results of this evaluation  when preparin g future annual 
work  programmes , and when  monitoring the EU’s new anti-fraud programme . It adopted 
the first annual work programme  under the UAFP for 2021 by means of a Commission 
implementing decision on 23  July 20217. 
1.2. Policy context  
The protection of the EU’s financial interests (PIF) has to be seen in the broader political 
and policy context, which includ es the institutional architecture governing anti-fraud 
action  that is currently undergoing a significant change.  
The expansion  of the European Union in 2004 and 2007 led to a strengthen ed 
coordination  of national anti -fraud activities. The objective of the Hercule I programme 
was to ensure an equivalent  and efficient level of protection  of the EU’s financial 
interests and to support the exchange of best practice.8 In line with this objective, 
national  anti-fraud coordination services  (AFCOS) were  set up in all Member State s.  
In 2011, the Commission adopted the anti-fraud strategy9, which was revised in 2019. 
The strategy applies to all Commission departments  and executive agencies. It sets out 
the general objectives of policy action to combat fraud. Its main goals are to adapt anti -
fraud measures to address today’s  challenges; to increase the amount of recovered funds 
affected by fraudulent activities; and to  enhance cooperation between EU  bodies in the 
fight against fraud and corruption.  
Since 2012, the Commission encourages Member States to adopt national anti-fraud 
strategies , which should contain  anti-fraud measures and policies  and there by 
                                                           
7 Commission  Implementing  Decision on the financing of the union a nti-fraud programme  and the 
adoption of the work programme  for 2021  (C (2021) 5338 final , 23.07.2021 ). 
8 Communication from the Commission on the implementation of the Hercule programme  and its 
extension during the period 2007 -2013 , COM(2006) 339 final, 28.6.2006 . 
9 Communication from the Commission to the European Parliament, the Council, the European 
Economic  And Social Committee, the Committee of the Regions and the Court of Auditors from 
29.04.2019 on the Commission Anti -Fraud Strategy: enhanced action to protect the EU budget  
(SWD(2019) 170 – 171 final, 29.4.2019 ; COM(2019) 196 final, 29.4.2019 ). 
 
5 contribute to combating fraud both on national and EU levels .10 According to the 
latest  PIF report11 on anti -fraud measures taken by the Member States in 2020, the 
situation on national anti -fraud strategies  has improved since by the end of 2020, 14 
Member States12 had adopted national strategies . 
In Ju ne 2021, the European Public Prosecutor’s Office (EPPO) became operational. 
Based on  Council  Regulation  (EU) 2017/1939  (EPPO Regulation )13, the EPPO  was set up 
to conduct criminal investigations in respect of  crimes affecting  the EU’s financial 
interests. The crimes falling within the material competence of the EPPO are defined in 
the Directive on protection of the European Union ’s financial interests by means of 
criminal law14 (PIF Directive) . Not all Member States have decided to join the EPPO. 
Therefore, different forms of cooperation between the EPPO, OLAF, and national 
judicial and administrative authorities will have to be established . 
Although tangible progress has been achieved over the last two decades, the level of 
protection of the EU’s financial interests among Member States remains uneven. This is 
due to factor s such as differing  enforcement priorities, technical capacity, the level of PIF 
awareness, the geographical location (especially on the revenue side), the wealth of the 
Member State  and related resources they allocate to  police and justice administrations , as 
well as  differ ing level s of fraud and corruption.  
Hercule III, and now the EU’s anti-fraud programme (UAFP), support the transition 
towards the new institutional landscape by funding , for instance , training and 
conferences.  By integrating the main IT tools, the anti-fraud information system  (AFIS) 
and the irregularities management system (IMS) , into its scope , the UAFP is even better 
placed to support  the multiple  bodies involved in this work at national level.   
                                                           
10 Commission staff working document, implementation of Article 325 TFEU by the Member States in 
2019, accompanying the 31st Annual Report on the protecti on of the European Union's financial 
interests - Fight against fraud – 2019 (COM(2020) 159 final, SWD(2020) 159 final, 3.9.2020 ). 
11 Report from the Commission to the European Parliament and the Council - 32nd Annual Report on the 
protection of the European  Union's financial interests – Fight against fraud - 2020 (COM(2021) 578 
final, 20.9.2021).  
12 Austria, Bulgaria, Croatia, Czech  Republic , France, Greece, Hungary, Italy, Latvia, Lithuania, Malta, 
Portugal, Slovakia, Sweden.  
13 Council Regulation (EU) 2017/1 939 of 12 October 2017 implementing enhanced cooperation on the 
establishment of the European Public Prosecutor’s Office, OJ L 283, 31.10.2017, p. 1 –71. 
14 Directive (EU) 2017/1371 of the European Parliament and of the Council of 5 July 2017 on the fight 
against fraud to the Union's financial interests by means of criminal law , OJ L 198, 28.7.2017, p. 29.  
 
6 2. BACKGROUND  
2.1. Hercule III - description  and intervention logic  
The concept of protecti ng the EU’s financial interests covers prevention, detection and 
investigation of fraud against the EU’s budget and can extend  to measures to address  
other serious irregularities. Action to protect the financial interests cover s the whole of 
the expenditure side of the EU budget. On the revenue side, action mainly covers 
‘traditional own resources’15. 
The Hercule programme  was specifically de signe d to protect the EU’s financial in terests  
by providing financial support  to Member States and other relevant bodies  in combating 
irregularities, fraud and corruption that are a risk to the EU budget . It was administered 
by the European Anti -Fraud Office (OLAF ), part of  the European Commission. The first 
Hercule programme16 was established in 2004  by Decision No  804/2004/EC. The 
Hercule II programme  was established in 2007 by  Decision No  878/2007/EC17, which 
extended the scope to  cover cigarette smuggling and counterfeitin g. In 2014 , Regulation 
(EU) No  250/201418 establish ed the Hercule  III programme  for 2014 -2020.  
Following calls for proposal s, the eligible beneficiaries  for technical assistance  and 
training under the programme  were  national or regional a dministrations of Member 
States , educational institutes and non -profit -making entities established and operating in 
a Member State for at least one year . The participation of administrations from non -EU 
countries was subject to an agreement between the non-EU country concer ned and the 
European Union on participation in EU programmes. For the duration of the Hercule III 
programme, no such agreement specifically for this programme had yet come into force.  
                                                           
15 EU traditional own resources for the 2014 -2020 EU budget were mainly customs duties and sugar 
levies, defined in Article 2(1) (a) of the 2014 Own Resourc es Decision.   
16 Decision 804/2004/EC of the European Parliament and of the Council of 21 April 2004, establishing a 
Community action programme to promote activities in the field of the protection of the Community's 
financial interests (Hercule programme), OJ L 143 of 30.4.2004, p. 9 -14. 
17 Decision No 878/2007/EC of the European Parliament and the Council of 23 July 2007 amending and 
extending Decision No 804/2004/EC establishing a Community action programme to promote 
activities in the field of the protecti on of the Community's financial interests (Hercule II programme), 
OJ L 193, 25.7.2007, p. 18 -22. 
18 See footnote 1.  
 
7 2.2. The 2011 Hercule III impact assessment  – identified drivers  
The December 2011 impact assessment  accompanying the Commission proposal for a 
regulation establishing the Hercule III programme  identified five key drivers  to address. 
Linked to the five drivers,  the impact assessment identified nine specific problems19. 
- Key driver 1 : fraudsters adapt quickly to new circumstances at EU level, operate 
across borders and exploit the weakest points.  Linked with problems 1, 2, 3, 6 and 7 . 
- Key driver 2 : the Commission and Member States have committed themselves to 
stepping up the fight against cigarette smuggling.  Linked with problems 1, 2, 5 and 9 . 
- Key driver 3 : pressure on public finance s require increasingly cost -efficient ways to 
protect the EU’s financial interests through improved detection and prevention.  
Linked with problem s 1, 4 and 5 . 
- Key driver 4 : the vast majority of anti -fraud resources are at national level, in many 
and varied competent authorities.  Linked with p roblems 6, 7 and 8 . 
- Key driver 5 : differences in incentives and capacit y between Member States impede 
equivalence in the protection of financial interests.  Linked with problems 6 and 9 . 
 
- Problem  1: how to develop specialist knowledge and deploy state -of-the-art 
technical equipment to modernise prevention, detection and investigation work to 
protect the EU budget?  
- Problem  2: how to respond to the rapid development in organised crime in key 
sectors such as cigarette smuggling and counterfeiting?  
- Problem  3: how to maintain public confidence in the EU given the rise in challenges 
to good governance and public finance ethics from past and prospective expansions  
and the continued increase in EU expenditure in high -risk non-EU countries?  
- Problem  4: lack of sufficient  awareness and expertise to prevent and detect fraud on 
an EU scale . 
- Problem  5: insufficient and/or ineffective use of risk analysis and information 
sharing about fraud patterns at EU level . 
- Problem  6: shortcomings in the ability and/or willingness of competent authorities to 
cooperate among themselves and/or with OLAF . 
- Problem  7: difficulties in setting up  information exchange mechanisms and tools that 
enable  standardised, interconnected and efficient transnational anti -fraud cooperation.  
- Problem  8: lack of a uniform administrative and judicial environment to investigate 
and prosecute EU budget fraud . 
- Problem  9: gaps in the skills, experience and sharing of best practice among national 
competent authorities.  
                                                           
19 Commission staff working document – impact assessment accompanying the proposal for a regulation 
of the European Parliament and of the Council on the Hercule III programme to promote activities in 
the field of the protection of the EU financial interests (SEC(2011)1610 final, p. 10, 19.12.2011).  
 
8 Based on these identified problems, the gener al objective  of the Hercule III programme 
was ‘to protect the financial interests of the Union thus enhancing the competitiveness of 
the Union's economy and ensuring the protection of taxpayers' money’20. The 
programme ’s specific objective  was ‘to prevent and combat fraud, corruption and any 
other illegal activities affecting the financial interests of the Union, including cigarette 
smuggling and counterfeiting’21.  
In addition, to provide solutions to the problems  identified , the programme had five 
operational objectives  as listed in Article 5 of Regulation (EU) No 2 50/2014:   
a) to improve the prevention and investigation of fraud and other illegal activities 
beyond current levels by enhancing transnational and multi disciplinary  cooper ation;  
b) to increase the protection of the EU’s financial interests against fraud by facilitating 
exchange s of information, experiences and best practice, including staff exchanges;  
c) to step up the fight against fraud and other illegal activities by providing technical 
and operational support to national investigation s, in particular to customs and law 
enforcement authorities;  
d) to limit the currently known exposure of the EU’s financial interests  to fraud, 
corruption and other illegal activities with a view to reducing the development of an 
illegal economy in key risk areas such as organised fraud, including cigarette 
smuggling and counterfeiting;  
e) to step up  the development of specific legal and judicial protection of the EU’s 
financial interests against fraud by promoting comparative law analysis.  
Lastly, reporting by Member States on irregularities and suspected fraud cases  detected 
during the implementation of the budget, and reported on the ba sis of Article 325 TFEU, 
showed that the detrimental impact on the EU budget over the years remained at a 
level  that requir ed the EU to maintain this work  to protect the EU budget . Figure 1 
overleaf illustrates the programme’s overall  intervention logic, as described above  and 
with a breakdown by type of action , including the planned outputs, results and impacts . 
                                                           
20 Article 3 of Regulation (EU) No 250/2014.  
21 Article 4 of Regulation (EU) No 250/2014.  
 
9 
 Figure 1 – General intervention logic of the Hercule III programme  

 
10 
 2.3. Intervention logic  per type  of Hercule III action  
2.3.1.  Technical assistance  (see Figure 2  below)  
Financial support from  the programme under technical assistance enabled  the purchase 
of: 
- technical equipment, investigation tools and methods with training provided for staff 
to operate such tools; devices and animals to carry out inspections; training  courses ; 
automated systems for the recognition of vehicle number plates and container codes; 
training to operate such tools;  
- access to databases with information on trade  flows, ship -manifest data, container 
traffic and company information, as well as services to  support Member States in 
storing and destroy ing seized cigarettes and other counterfeit goods;  and the chemical 
analysis of samples from tobacco and cigarette seizures.  
2.3.2.  Training and conferences, seminars and digital forensics ( Fig. 3) 
The programme funded the organisation of  conferences, seminars, courses, workshops, 
ad hoc  training  and staff exchanges to exchange experience  and good practice between 
competent authorities. The aim was to disseminate knowledge on how to identif y risk 
factors and increase knowledge of the PIF Directive22.  
The programme provided support for d igital forensic s training courses , including  
launching a quality assurance process and certification procedure for digital forensics 
experts (‘DFAT’: digital forensic analysis training), and creatin g a network of experts.  
2.3.3.  Legal training and studies ( Figure 4 ) 
The programme funded the  organisation of regular high -profile research activities , such  
as conferences, seminars and workshops to improve cooperation between academics and 
practitioners; scientific publications and dissemination of knowledge among the judiciary 
(prosecutors, judges and court staff) and other legal professions (lawyers, barri sters, 
solicitors, notaries, bailiffs).  For example , it funded  an external study23 to identify  an 
approach to measure the illicit market for tobacco products  (April 2020) .
                                                           
22 See footnote 15 . 
23 Study to identify an approach to measure the illicit market for tobacco products – Final report, RAND  
Europe, April 2020, published by the European Commission (OLAF.B.1); https://op.europa.eu/s/sDt j 
 
11 
 Figure 2 – Intervention logic – Technical assistance: financial s upport to purchase equipment and services  needed by national authorities for 
investigations  
 

 
12 Figure 3 – Intervention logic  - Training for law enforcement staff  to boost  operational and investigative capacit y to run  PIF investigations  
 
 

 
13 Figure 4 – Intervention logic – Support for conferences  and legal studies to develop  academic research into PIF at EU and national levels  

 
14 
 2.4. Input of resources , expected results  and impact  
Over the period 2014 -2020, t he Commission managed a budget  of EUR 104.9 million for 
the Hercule III programme, with an annual average of commitments between EUR 14 
and 17 million, disbursed in the form of grants and procured services.  
The programme provided financial sup port to several types of activities that come under 
three  broader areas  of action24: 
1. Technical assistance  (at least 70% of the programme's budget – through grants), 
providing  national authorities with financial support to acquir e specific knowledge, 
equipment and information technology tools and to acquire  access to specific 
databases and IT tools that facilitat e data collection  and analysis .  
The aim of the technical assistance was to obtain the following  results : 
- successful seizures, confiscations  and recoveries following joint action  and cross -
border operations;  
- technical equipment used properly to generate sustainable added value (at least for 
the normal – variable – life span of the equipment);   
- information exchanged among  Member States on the results achieved with the 
technical material.  
2. Training  (maximum 25% of the programme's budget – through grants and 
procurement), to help fund the organisation of targeted specialised training, risk 
analysis workshops, conferences and legal studies . 
The expected results  of the training initiatives  were to increase awareness among  the 
judiciary (prosecutors, judges and court staf f) and the legal profession (lawyers, 
solicitors, barristers, bailiffs) about  the protection of the EU’s financial interests , to 
increase digital expertise and to train participants on evidence -based policies and 
legislat ion to protect the EU budget . 
The expected results of the legal training were also to create and increase knowledge 
about the fight against fraud and to continue  the exchange of good practice , as well as 
to improve  as far as possible the coordination of exchanges between practitioners and 
academics.  
                                                           
24 Article 8 of Regulation (EU) No 250/2014.  
 
15 3. Any other action  (maximum 5% of the budget): other types of action provided for in 
the annual work programmes, as necessary to achiev e the programme’s  general, 
specific and operational objectives.  
Under this catego ry, the programme funded action such as  a 2015 ‘Eurobarometer’ 
survey  (updated July 2019)25 on public opinions, attitudes and behaviour in the EU on 
cigarette smuggling and the consumption of smuggled cigarettes . It also funded the 
development of evidence -based policies and legislati on to contribut e to better policy -
making.  
The overall expected impact of the programme  is a significant and lasting contribution to:  
- an effective  protection of the EU’s financial interests;  
- ensuring the competitiveness  of the EU’s economy (for example by strengthening the 
competitiveness of European businesses by tackling and eradicating illegal economic  
circuits wherever possible) and protecting  public finances;  
- ensuring a continued and reliable protection  of taxpayers’ money, maintain ing public  
confidenc e that fraud and corruption are being tackled . 
2.5. External factors that affected the programme’s achievement  
2.5.1.  Positive external factors that affected the delivery of results and achievement 
of objectives  
Technical assistance projects  were found to have a number of positive external effects . 
The evaluation  showed that, based on the assessment of achievements, the acquisition of 
modern equipment produced  a number of positive effects that are not among the 
programme’s primary objectives , but nevertheless benefit the national authorities.   
One of the main positive external effects identified was that the equipment purchased to 
perform border checks had proven useful to detect , for example,  illegal drugs  or illegal 
weapons . Evidence from the case studies also indicates the usefulness of equipment in 
seizing illegal substances or artefacts that do not primarily jeopardise the EU’s  financial 
interest s but pose a more general security threat to EU Member States.  
Evidence from the assessment of achievements and from the 16 case studies suggest s that 
technical equipment increased the health and safety  of customs and police officers. The 
purchase of more modern scanners  minimised the risk to radiation exposure . Modern 
                                                           
25 Special Eurobarometer 443 – ‘Public perception of illicit tobacco trade’, survey conducted by TNS 
opinion & social at the request of the European Commission, European Anti -Fraud Office. 
Coordinated by the Eur opean Commission, Directorate -General for Communication (Strategy, 
Corporate Communication Actions and Eurobarometer Unit). Publication: July 2016; Fieldwork: 
November -December 2015. https://ec.europa.eu/anti -fraud/public -perception -illicit -tobacco -trade_en . 
Updated Eurobarometer survey, July 2019: https://europa.eu/eurobarometer/surveys/detail/2191  
 
16 communication and surveillance equipment helped officers monitor criminal activities 
while staying undetected and at a safe distance.  
Figure 5 – Unexpected  or unintended knock -on effects of the programme  - example  
 
2.5.2.   Negative external factors that affected the delivery of results and 
achievement of objective s 
The evaluation identified t wo possible negative effects that c ould have  affected the 
delivery of results and achievements .  
- Administrative capacity . The lack of national resources to manage the 
administrative burden can hinder the uptake of applications from Member States that 
may not have th e same organisational capacity.  
This can be linked to the lack of clarity regarding decisional responsibilities in the 
Member States . 
- Lack of legislative support . One EU -level interviewee noted that customs units 
uncovered  an increase in the illegal traffic of raw tobacco . But, as raw tobacco  is not 
covered by  the EU excise system, it was often not possible for the enforcement 
services to analyse collected or seized samples of illegal raw tobacco, which made 
(criminal) investigations into the origins o f seized raw tobacco difficult.  
This legal gap may relate to  issues that are being identified in the monitoring and 
control system applied to the raw tobacco supply chain . The Commission is currently 
carrying out an impact assessment related to excise duties legislation26.  
2.6. Baseline and points of comparison  
The baseline provides a point of comparison against which the Commission will evaluate 
the implementation of the Hercule III program me. It takes  account of the impact 
assessment of the Hercule III Regulation and the evaluation of Hercule II  (the pre ceding 
programme ). 
                                                           
26 Legislative initiative to review Council Directive 2011/64/EU of 21  June 2011 on the structure and 
rates of excise duty applied to manufactured tobacco . The inception impact assessment is available at: 
https://ec.europa.eu/info/law/better -regulation/have -your-say/initiatives/12645 -Tobacco -taxation -
excise -duties -for-manufactured -tobacco -products -updated -rules -_en  
The purchase and use of specialised equipment funded by the programme had 
unexpected or unintended knock -on effects  in terms of enhanc ing the health and 
safety of users. The new equipment  improved the overall working environment . 
Refurbish ing work stations also improved the comfort and functionality of work 
places for staff, increasing at the same time  the safety and quality of stored 
evidence and equipment . 
 
17 2.6.1.  The 2011 impact assessment o f the Hercule III  Regulation  
The 2011 Commission proposal for a regulation  establishing the Hercule III programme 
was based on an impact assessment .27 The assessment  found that the positive impact of 
the Hercule II programme  was not fully reached at the time (2011), in part because some 
Member States were unable to co -finance Hercule II projects, especially in terms of 
procur ing technical equipment.  
Notably on the eastern and southern fringes of the EU, the affected areas were those 
where there wa s the greatest common interest to strengthen  the control of the EU’s 
borders against smuggling or trans national  fraud.  In response , the Commission 
increase d the maximum funding  rate in co -financed activities from 50% to 80% in the 
Hercule III programme . 
The m aximum co -financ ing rate can be exceptionally raised from 80% to 90%  for very 
specific projects  that meet  at least two of the following criteria : i) they take place at an 
external EU border; ii) they take place at the most vulnerable locations; iii) they reflect  
the results of the Eurobarometer survey of public attitudes to counterfeited, smuggled 
cigarettes and ‘cheap whites ’; and iv) they reflect  the findings of the 2014 report on the 
protection of the EU’s financial interests.   
2.6.2.  Final evaluation of t he 2015 Hercule II programme  
The 2015 ex post  evaluation of Hercule II found that the support granted to Member 
States was largely positive and led to better transnational and multidisciplinary 
cooperation between authorities in their work  to protect the EU’s financial interests. The 
programme contributed to strengthening the operational and investigative capacity of its 
main beneficiaries, such as police forces, customs authorities and other law enforcement 
agencies.  
The evaluation also found that the effectiveness of the programme co uld be even 
greater by facilitating  more personal contact s between stakeholders, for example, 
through staff exchanges . It also highlighted t he need to strengthen the reporting on the 
programme’s activities, and monitoring of results . These findings were ec hoed in the 
mid-term evaluation of Hercule III.  
                                                           
27 COM staff working document , SEC(2011) 1610 final, 19.12.2011, p. 38.  
 
18 2.6.3.  The January 2018 Hercule III mid -term evaluation report  
In January 2018, the Commission published its  mid-term evaluation report  of Hercule 
III28 covering the period 2014 -2017. The evaluation identified similar problems to those 
listed in the 2011 impact assessment, in particular:  
- gaps in skills, expertise and the sharing of best practices among national competent 
authorities;  
- lack of standardised and interconnected information exchange mechanisms; 
cooperation among authorities as well as a lack of awareness and expertise to prevent 
and detect fraud;  
- gaps in developing specialist knowledge and technologies to fight fraud, in improving 
the use of ris k analysis and information sharing, and in responding to development s in 
organised crime;  
- differences among Member State systems to investigat e and prosecut e fraud.  
The mid-term evaluation also demonstrated that , at that stage (end 2017 ), the programme  
had fulfilled its mission. It had proven relevant , with mechanisms in place to ensure 
coherence , and it had been effective  and efficient . There was a clear added  value  in 
continu ing to  run a programme  at EU level, and its activities were  found to be broadly  
sustainable . The evaluation report also contained suggestions for improve ment s, in 
particular in terms of cross -border cooperation between Memb er States, cooperation 
with non -EU partners  and new technological developments .    
With regard  to training , the mid-term evaluation  concluded that only a few projects had  
involved staff exchanges between national administrations and few involved 
international participation . 
2.6.4.  The July 2018 UAFP inception impact assessment  
When comparing the  situation between 2011 (impact assessment  for the Hercule III 
programme ) and 2018 (the impact assessment29 for the EU’s new anti-fraud programme  
(UAFP )30), the main issues that  the initiative s aimed to tackle were  large ly similar.  Fraud  
undermining  the EU’s financial interests remained  a prevalent issue.  
In 2016, 19  080 fraudulent and non -fraudulent irregularities  were reported to the 
Commission, involving a total of approximately EUR 2.97 billion . 1 410 irregularities 
were reported as fraudulent, involving EUR 391 million , covering both expenditure and 
                                                           
28 Staff working document (2018) 3 final, 10.1.2018.  
29 See the impact assessment for Hercule III, accompanying the proposal for a regulation establishing the  
union anti-fraud programme:  SWD(2018) 294 final, 30.5.2018 . 
30 Regulation (EU) 2021/785 of the European Parliament and of the Council establishing the union anti-
fraud programme, OJ L 172/110, 17.5.2021, p. 110 -122. 
 
19 revenue . Although this was an improvement compared to 2015, the sheer volume of 
identified fraud and irregularities remained high.  
Most of the key drivers  of fraud identified in the inception phase of the Herc ule III 
programme  remain ed relevant when the impact assessment was carried out for the UAFP . 
In particular, the capacity of fraudsters to adapt quickly and operate across borders to 
exploit the weakest points had not noticeably diminished. Pressure  on public finance s is 
even higher today , requiring  the Commission and the Mem ber States to protect the EU’s 
financial interests by stepping up detection and prevention  work .  
Lastly, the differences in incentives and capacit y between Member States persist and 
result in an uneven protection  of the financial interests within the EU.  
3. IMPLEMENTATION / STATE OF PLAY 
3.1. Administrative implementation  
Following the final evaluation of the Hercule II programme, some changes were made . 
Hercule III integrated IT support into the scope for technical assistance and brought in 
stricter reporting requirements for beneficiaries . It also brought in an  annual overview 
with information on the results of the Hercule III programme, i.e. an annual  report by the 
Commission on actions and results of the Hercule III programme.  
Another  major change was the increase of the co -financing rate under technical assistance 
actions , from 50% (Hercule II) to 80% (Hercule III) of all eligible costs. Financial  
support was available in the form of grants, public procurement or reimbursement of the 
cost of participation in activities under the programme . 
The Commission financing decisions with the annexed annual work programme s ensured 
that the general, specific and operational objectives of th e Hercule III programme  were 
implemented in a consistent manner. They outlined the outputs and the expected results, 
the methods of implementation and total amount (input, available budget per sector, list  
of the calls for propo sals to be published and the contracts to be concluded).  
Once the Commission had adopted the financing decision and made available the 
financial resources, it published calls for proposals (e.g. for technical as sistance, 
conferences, legal training and studies).  The proposals submitted by Member State 
authorities or other eligible applicants were then evaluated according to the selection and 
award criteria.  
Every year, from 2014 to 2020, the Commission launched three  calls for proposals: one 
for technical assistance , one for legal training and studies  and one for training, 
conferences and staff exchange s. In 2020, following requests from applicants, in view of 
their organisational challenges during the COVID -19 crisis, the Commission extended the 
deadline for the three  calls for proposals by 3-4 weeks , depending on the type of call.  
 
20 The Commission implemented the Hercule III programme  by issuing grants following the 
calls for proposals . It entered into  public procurement contracts (for purchasing (access 
to) databases, organising conferences and (specialised) training, plus the development of 
specific IT  tools) following calls for tender and administrative arrangements concluded 
with the European Commis sion’s Joint Research Centre (JRC) for the development of 
specific tools.  
As of November  2021 , OLAF registered  280 finalised projects  out of 336 granted 
projects  (83.3%). For a project to be considered finalised, the technical and financial 
reports have  to be submitted and the final payment made , which is some time after the 
project ends. 
3.2. Monitoring implementation of the programme  
The programme  is monitored  through annual implementation reports that the European 
Commission submit s to Parliament and to the Council . The reports  present input and 
output indicators on the use of the budget, the number of action s carried out , the main 
results achieved, information on cooperation and coordination between the Commission 
and the Member States, and insights in terms of consistency and complementarity with 
other programme s. 
The annual implementation report is a Commission staff working document annexed to 
the annual PIF report . The European Parliament’s C ommittee on Budgetary Control 
(CONT Committee ) issues  its opinion on the PIF report by the end of each year . The 
Commission carefully takes account of the  observations  for the following years . 
Four key performance indicators  (KPI) are used to measure t he achievement  of the 
programme’s specific objective31, ‘to prevent and combat fraud, corruption and any other 
illegal activities affecting the financial interests of the Union ’: 
a) information on seizures carried out by joint actions and cross -border operations;  
b) added value of technical equipment funded under the programme ; 
c) (the number of) information exchanges among Member States; and,  
d) the number and type of (specialised) training.  
Beneficiaries of the actions must  report on the results achieved. The method for reporting 
differ s according to the type of action (techn ical assistance and training). For technical 
assistance  grants , the results are first reported in a ‘ final technical report ’ issued after  the 
request for final payment of the grant . Results are also reported in a ‘final implementation 
report ’ submitted one year after the final  date of the grant agreement. The reporting 
condition is set out in the annual work programme , specified in the calls for proposals 
and required by the grant agreement.  
                                                           
31 Article 4 of Regulation (EU) No 250/2014.  
 
21 Beneficiaries of training grants  must  submit a ‘ final technical report ’ with the main 
results o f surveys held among the participants to assess the relevance of the event and 
user satisfaction, as set out in the calls for proposals and required by the gran t agreement. 
As of 2017, grant beneficiaries  must  organise a ‘post-event survey ’ six months after the 
event took place to measure the mid -term impact , in particular in relation to the use of 
the skills acquired during the training course and the effect  of networking .  
For procurement -based activities, conferences a nd training  initiatives , the beneficiaries 
must  run user satisfaction surveys  following these events.  For contracts for the purchase 
of access to databases , monitoring the results of the actions takes a different form: the 
Commission receives detailed information on how the different users make use of the 
databases.  
The findings based on the beneficiaries' reports in both the technical assistance and the 
training reports  are included in the annual overviews on implementation  of the 
programme  and are used as input to estimat e the KPI32. The Commission also monitored 
the identified and reported impacts of the programme  through information contained in 
grant beneficiaries  or contractors’ final technical reports . These cover ed success stories, 
the results achieved with the activities funded and th e contribution they made to 
protectin g the EU’s financial interests . 
3.3. Implementation figures 2014 -2020  
The budget available f or Hercule III was only slightly  bigger than for the Hercule II 
programme (EUR 98.5 million for Hercule II for 2007 -2013, compared to approx imately  
EUR 104.9 million for Hercule III for 2014 -2020 ).  
Figure 6 - Annual commitments Hercule III - 2014 -202033 (actual figures)  
Year  Commitment appropriations (in euro)  Payment appropriations (in euro)  
2014  13 677 700  11 004 993  
2015  14 067 100  12 385 254  
2016  14 542 300  19 307 530  
2017  14 950 000  13 244 989  
2018  15 347 500  13 255 186  
2019  15 891 200  16 064 692 
2020  16 443 100  15 321 445  
Total  104 918 900  100 584 089  
                                                           
32 Article 4 of Regulation (EU) No 250/2014.  
33    Source : OLAF - Annual overview with information on the results of the Hercule III p rogramme as part 
of the annual reporting by the Commission to the European Parliament and to the Council on the 
protection of the European Union's financial interests - Fight agai nst fraud . 
 
22 Applications for Hercule III grants were consistently over the level of grants available to 
award  over the period 2014 –2019. In particular, applications for technical  assistance 
grants are very competitive, with a peak in 2014, whe n only 25% of all  applications were 
successful. The average success rate of applications for technical assistance is 33%, while 
on average 43% of all applications for anti -fraud training  are successful.  
On average 51% of applications for legal training and studies are  awarded a grant. Thus, 
in all three  areas, only half or fewer than half of all applicants can proceed  with their 
suggested projects , showing that the Hercule III programme  is successful and relevant  
for applicants , with the high co -financing rate of grants  being an incentive to apply . No 
more than 5% of the budget can be spent  on other types of action . They  include funding 
studies that are not directly related to anti -fraud or legal issues, or in some circum stances , 
support for nationals from non -EU countries to participate  in workshops or 
conferences. The special Eurobarometer survey from July 2016 (updated, July 201934) on 
public perception of illicit tobacco trade was also funded un der ‘other types of action ’. 
Figure s 7-8-9 - Number of grant applications and grants  award ed per type of action  
 
Source: OLAF own data on Hercule III applications.  
The number of applications received fluctuated over the programme’s lifespan. Hercule 
III, compared to the previous Hercule II programme, increased the maximum co -
financing rate in technical assistance (from 50% in the previous programme to up to 90% 
of the total cost). This  triggered  a high interest from Member  State  authorities in applying 
for funding in the first three years. The increased interest combined with the limited 
amount of funding available under the programme led to the Commission having to reject 
a high number of proposals due to  insufficient funds.  This is likely to have been the 
                                                           
34 https://europa.eu/eurobarometer/surveys/detail/2191  
8379
72
53
42 4347
211723 2220
1329
0102030405060708090
2014 2015 2016 2017 2018 2019 2020Technical Assistance Grants
Applications received
 Grants awarded
 
23 reason for a gradual  decrease in the applications received for the following years, 
stabilising at around 40 -50 technical assistance applications per year.  
 
 
For applications for funding  training , where the maximum co -financing rate remained as 
in the previous Hercule II programme (80%, with an exceptional rate of 90%), the 
number of applications varied between 17 and 42 for anti-fraud training and between 6 
and 22 for legal training , with no obvi ous explan ation for  these fluctuations.  
The Hercule III calls were publicised in a similar way each year, through existing 
networks and channels, on OLAF ’s website and through Official Journal announcements. 
Starting with 2017, the calls were also published on the Commission’s ‘Funding and 
tenders ’ portal, increasing visib ility for the targeted stakeholders.  
All Member States are eligible for funding under  Hercule III. The evaluation  found  – 
based on publicly available aggregated data under ‘ technical  assistance’ and ‘ anti-fraud 
2942
2833
171936
1213 1315
81013
051015202530354045
2014 2015 2016 2017 2018 2019 2020Anti -fraud Training Grants
Applications received
 Grants awarded
162022
18
13
621
8 8109
5 511
0510152025
2014 2015 2016 2017 2018 2019 2020Legal Training Grants
Applications received
 Grants awarded
 
24 training & legal studies’ during the past funding period of 2014 -2020 – that some 
Member States  obtained  relatively more funding under Hercule III than others .  
Technical assistance actions are (more) concentrated in Member States that have an 
external border to the east, as well as some coastal states such as Spain and Ireland.  
The cause  of this possible inequity  between the 28/27 Member States is likely to be due 
to multiple  reasons . In some cases it may be linked to the geographical location  of the 
Member State ; in others it is not immediately identifiable, such as for example the low 
participation rate of Denmark , Austria or the United Kingdom.  
In some circumstances, projects run in non-EU countries  may also receive funding from 
Hercule III. Costs incurred for persons from non-EU countries to participate in an event 
funded under the programme, such as conferences, seminars or training sessions, can be 
considered eligible for funding under certain conditions. In such instances, the funds are 
mainly used to organise conferences, workshops, or training  in order to strengthen 
cooperation w ith the EU and support capacity building of tax authorities in those non-
EU countries . This includes coordination of activities of participating countries and 
representatives of international organisations with the aim of exchanging experience and 
best pra ctice between authorities , developing high -profile research and conducting 
studies.  Figure 10 shows  all non -EU countries in which projects were run. 
Figure 10 - Non-EU countries in which (training and conferences) projects were run 
that received funding under Hercule III  
 
Source:  OLAF - Annual overviews with information on the results of the Hercule III programme  as part of the annual 
reporting by the Commission to the European Parliament and to the Council on the protection of the European Union's 
financial interests - Fight against fraud. 2014 -2019 (PI F Reports).  
 
3.4. Costs and benefits of the programme  for the  stakeholders  
The main  direct benefit of the programme  related to technical assistance actions was 
the purchase  of technical assistance equipment  and the provision of innovative tools . As a 

 
25 result, 14 out of the 80 respondents to the survey noted that the new equipment had led to 
increased detection rates and, by default, an increase in the number of seizures . This 
finding was similar to the finding under training , where the developmen t of research and 
knowledge building produced  the greatest benefit.  
The programme also  generated  indirect benefits in the form of  strengthening 
collaboration and cooperation between and within Member State authorities and 
stakeholders, and the exchange of  best practice . Considering the  costs and benefits 
incurred/accrued by stakeholders,  most applicants stated  in the survey that  the benefits 
of the programme  outweighed the costs. In addition, several stakeholders highlighted 
that, for technical assistance projects , the value of goods seized often exceeded the initial 
value of the contract awarded by the programme . This was also seen in the case studies in 
Poland , where the value of  a single seizure made possible through Hercule -funded tools 
covered the entire investment cost of the project.  
A few interviewees highlighted several  contextual factors that can affect the balance 
between costs and benefits. In particular, one partner organisation highlighted that the 
programme budget ha d not taken into account  the rise in staff costs over the funding 
period, thus in comparison with other funding opportunities, the programme  can appear 
relatively more restrictive.  
The next figure  shows the difference between the average maximum amounts to be 
awarded and the average amounts finally requested and received per type  of action .  
Figure 11 - Average amounts awarded and requested by type of action35 
Type of action  Average maximum amount 
to be awarded  in EUR  Average maximum  amount 
requested and received  (EUR)  
Technical assistance  492 589  484 215  
Anti-fraud training and 
Legal training & studies  70 550  55 221  
On average,  the beneficiaries of technical assistance actions request payment to a level of 
around  88% of the maximum awarded grant amounts . The b eneficiaries of training 
actions requested  on average  only 73% of the maximum amount  awarded. The reason 
for the difference  between the maximum amount awarded and the amounts requested are 
corrections or cost adjustments  that are proposed either by OLAF or by the 
beneficiaries when submitting the final financial reports.  
                                                           
35 The requested amounts are derived from the final financial reports submitted by the beneficiaries  at the 
end of the projects.  Source: Ramboll data, based on a sample of projects taken, Interim Report, May 
2021 , Table 5.22, p. 178 . 
 
26 4. METHOD  
4.1. Short description of methodology  
To compl ement its work, the European Commission commissioned a study to underpin 
this evaluation. The external study was carried out between October 2020 and October 
2021 by RAMBOLL Management  Consulting  S.A./N.V., in a consortium with London 
Economics (UK) and Università Cattolica ( Milano, IT). The conclusions of the study are 
set out in the final report36. 
An inter-service steering group  of Commission departments37 was set up to steer the 
evaluation process. The group  reviewed the roadmap38, the terms of reference for the 
external contract, and the inception , interim and final report s. 
In June 2020, the European Commission launched an online  public consultation  on the 
evaluation roadmap . It did not attract any response s, probably because the programme 
targets  a specific and specialised audience. The Commission did not run a n open public 
consultation on this stage of the evaluation as the primary beneficiaries are national 
administrations that were contacted via targeted surveys.  
The evaluation is based on information from a selection of 98 projects funded by the 
programme. The information was obtained through  desk research and targeted 
consultations of internal and external stakeholders through interviews and three  specific 
surveys (to beneficiaries and unsuccessful applicants of technical assistance; to 
participants of funded events; and to users of  the databases  procured ). Further detailed 
information on the external study methodology can be found in Annex 3 to this staff 
working document  and in Appendix 5 to the study’s final report ( the synopsis report).  
Data were collect ed through desk research and literature review, online interviews for 16 
case studies in  eight  selected Member States, and during online meetings with 
stakeholders from the EU institutions and external partners associated to the programme .  
The replies to the evaluation questions are based on t wo data sources : 
Primary data . This includes  data collected specifically for the evaluation via:  
- online interviews with Commission staff; national institutions active in fraud 
prevention and the protection of the EU's financial interests, as well as beneficiaries 
of actions funded under the programme ; 
                                                           
36 https://op.europa.eu/en/publication -detail/ -/publication/3d9c63bd -4da3 -11ec -91ac -01aa75ed71a1    
37 With officials from OLAF, the Commission’s Secretariat -General, DG TAXUD, DG JUST, DG 
BUDG and the Commission’s Legal Service . 
38 The evaluation roadmap was published  by the Commission’s Secretariat -General between 15 June 
2020 and 13 July 2020: no feedback  was received from the public.  
 
27 - targeted online surveys with beneficiaries of projects  funded during the programme ; 
unsuccessful applicants; participants in events ; and users of services procured under 
the programme , in particular database users.  
Secondary data . This includes  data collected by examining:  
- public sources, such as the text of the Regulation and supporting documents (the 
Commission proposal as adopted in 2011, together with the impact assessment); 
Hercule III annual work programme s; Hercule III annual implementation reports; 
Article 325 r eports; the final evaluation report and interim reports of the Hercule II 
programme , legal acts underpinning other EU programme s39; 
- documentary evidence on applications for grants (application forms ), contracts and 
grants awarded (final t echnical reports, final financial reports and final 
implementation reports) ; 
- quantitative information on implementation of the annual work programmes , such as 
the budget and the number of grants/contracts, broken down by type of action and 
Member State as collected from the annual implementation reports . 
4.2. Analysis of data and results  
The primary and secondary data gathered by RAMBOLL was analysed using several  
methods, including descriptive statistical analysis  (closed questions in the online 
surveys), quantitative data analysis techniques  (case studies , economic analysis), and 
qualitative data analysis  (desk research, interviews and open  questions in online 
surveys).  
The evaluation question matrix40 was a key tool for the analysis, which follows the 
structure of the evaluation questions and related indicators  to facilitate cross -checking  
and matching of results . Checked  and confirmed data were  used to respond to the 
evaluation questions as listed in the evaluation question matrix.  
The collected primary and secondary data were verified and confirmed at the level 
of the evaluation criteria , comparing and contrasting the results of different data 
sources . The data were used  to identify  and analyse the overall achievement of the 
programme ’s objectives, their continued relevance, programme  efficiency and the 
sustainability  (effect)  and added value of the programme  at EU level.  
In using  triangulation to provide answers to the evaluation questions and sub -questions 
put forward in the evaluation matrix, the principle is that a hypothesis set out in the 
intervention logic can only be confirmed if different types of stakeholder support it 
                                                           
39     Such as the Customs 2020  programme , the F iscalis 2020 programme or the ‘internal security f und’. 
40 See the Final Evaluation Report of the Hercule III programme, Appendix 1 - Evaluation Question 
Matrix : https://op.europa.eu/en/publication -detail/ -/publication/3d9c63bd -4da3 -11ec -91ac -
01aa75ed71a1    
 
28 and different data sources provide relevant evidence . The synthesis  was built on the 
findings  and fed into the development of robust conclusions and recommendations , and 
the final study report.  The results of this analysis are presented in the appendices41 to the 
final study report.  
4.3. Limitations to the methodology, mitigating measures and robustness of 
findings  
The lifecycle of a programme  like Hercule III is such that it takes some time, at the end of 
the programme , to identify  and obtain  results for the most recent projects . This limit s the 
input available for a final evaluation, considering that in 2020 many  (physical) activities 
had to be suspended due to the pandemic.  
Another limitation is that , although most data are fully available  for most projects , for 
other  (types of) projects,  the information has been difficult to collect  in practic e. Due to 
restricted physical access to offices in the OLAF premises during the COVID -19 
pandemic, t he final project reports were not available  for all 100 initially selected 
projects . The incomplete project files were replaced by other projects according to the 
selection criteria se t out in the inception report. The final sample totalled  98 instead of 
100 projects . This did not affect the findin gs of the study . 
The number of respondents to three targeted online survey consultations appeared 
unbalanced both in the number of addressees contacted (partly lacking private data such 
as email addresses) and in the number of (completed) surveys returned to the consultant . 
Lessons learnt  from past evaluations . The study on the mid -term evaluation in 2017 -
2018 found that beneficiaries had difficulties providing the data to measure the key 
performance indicators (‘KPI’) laid down in  Article 4 of the Regulation (information 
on seizures carried out by joint actions and cross -border operations; added value of 
technical equipment; and, information exchanges among Member States).  
The collection of data to measure these indicators is reportedly the most burdensome 
aspect of the reporting phase . The reports to feed the KPIs therefore provided only 
relatively limited input into the mid -term evaluation of the programme . 
Figure 12 – Alleviating the issue of data collection issue under the new UAFP  
 
                                                           
41 See footnote 40, Appendices 1 to 3.  
The EU’s a nti-fraud p rogramme (successor of Hercule III) addressed the monitoring 
limitation  by including a dedicated Annex II on monitoring indicators for the programme. 
The adopted annual work programme for 2021 contains detailed information on the expected 
results from technical assistance project s, together with indicators  that will enabl e the 
Commission to monitor these  results and the added value  and effective use of the co -financed 
technical equipment . 
 
29 5. ANALYSIS AND ANSWERS TO THE EVAL UATION QUESTIONS  
The analysis was conducted against the evaluation criteria of relevance, effectiveness 
(including sustainability), efficiency,  coherence (both internal and external ), and EU 
added value.  
5.1. Relevance of the programme  
The assessment of relevance explores the degree to which the programme proves relevant 
to protect the financial interests of the EU, and the extent to which it is able to tackle 
current and future problems and needs faced by stakeholders.  
In understanding the programme ’s overall relevance, it is important to examine the 
context42 in which it operates and the current and future challenges it aims to tackle. For 
the present purposes, that is notably the level of fraud to the detriment of the EU budget 
on both the expenditure and the revenue side.  
Every year, the Commission reports to the European Parliament on irregularities related 
to the EU’s financial interests reported by the Member States. The Commission prepares 
the Report on the Protection of the Union’s Financial Interests (the ‘PIF report’).  
Protectin g the EU’s financial interests is a shared responsibility of the European 
institutions and the Member States .  
Member States contribute to the largest share  of the EU budget, collect the traditional 
own resources on behalf of the EU, and also directly  manage about two thirds of its 
expenditure (mainly cohesion policy funding, agricultural and fisheries -related 
expenditure) . Under  Article 325 TFEU , Member States take the same measures to 
counter fraud affecting the EU’s financial interests as they take to counter fraud affecting 
their own financial interests.  
In 2020 , the number of reported cases in comparison with the five -year average 
decreased  for both fraudulent and non -fraudulent irregularities  related to EU 
revenue . The related amount increased for fraudulent irregularities  but decreased for 
non-fraudulent irregularities43. 
                                                           
42 See Appendix 3 of the final  evaluation report by RAMBOLL for details.  
43 Commission staff working document - Statistical evaluation of irregularities reported for 2019: own 
resources, agriculture, cohesion and fisheries policies, pre -accession and direct expenditure - 
accompanying th e 31st Annual Report on the protection of the European Union's financial interests - 
Fight against fraud – 2019 (SWD(2020) 160 final, 3.9.2020, Annex 2 ); and the Report  from the 
Commission to the European Parliament and the Council - 32nd Annual Report on the protection of the 
European Union's financial interests - Fight against fraud – 2020, COM(2021)  578 final, 20.09. 2021, 
Chapter 6.1.2, page 31 and Annex 1.  
 
30 Figure 13 - Revenue: irregularities detected by Member States - traditional own 
resources  (reported in 2020)  
Budget sector  Fraudulent 
irregularities  Non -fraudulent 
irregularities  FDR44 IDR45 
 N EUR 
(million)  N EUR (million)  % % 
Traditional own 
resources  451 108 4  003 382 0.43%  1.54%  
Figure 14 – Trends and variations in reported cases  
As concerns revenue, t he overall situation in 202046 appears 
to be less affected by the COVID -19 pandemic than could  
have been expected , with the number of cases reported as 
fraudulent or non -fraudulent and of the related amounts 
within the usual range of annual fluctuation s. However, the 
impact of COVID -19 on the Member States varies.  
Inspections by anti -fraud se rvices was the most successful 
method of detecting fraudulent cases and related amounts 
in 2020.  
Most cases reported in 2020 as fraudulent or non -fraudulent 
affecting EU revenue relate to undervaluation , incorrect classification  or wrong 
description of goods or smuggling.   
Footwear, textiles, vehicles, electrical machinery and equipment were the types of goods 
most affected by fraud and irregularities in terms of number of cases and monetary value . 
Compared to the number of cases detected and reported in previous years, the number of 
cases  of fraudulent irregularities reported in 2020  (451) is comparable to 2019 but the 
financial impact is higher, with EUR 107.8 million  involved, compared to EUR 80 
million in 2019 (+35% ). The number of detected cases has steadily decreased from 600+ 
in 2014 to 451 in 2020. These figures indicat e the need to maintain the programme . 
Between 2015 and 2020, the number of reported irregularities  (fraudulent and non -
fraudulent) related to EU expenditure  for the programming period 2007 -2013 
decreased . The  number of cases  linked to the next period  2014 -2020 have been 
                                                           
44 The FDR is the  fraud detection rate: the ratio of financial amounts related to fraudulent irregularities on 
the total payments made.  
45 The IDR is the  irregularity detection rate: the r atio of financial amounts related to non -fraudulent 
irregularities on the  total payments made.  
46 Report from the Commission to the  European Parliament and the  Council  - 32nd Annual Report on the 
protection of the European Union's financial interests - Fight against fraud – 2020, COM(2021)  578,  
final, 20.09. 2021, Chapter 6.1.2, page 31 and onwards.  

 
31 increasing, consistently with each implementation cycle. Reported irregularities  related 
to annual spending  (direct aid to farmers and market support measures) remained stable . 
The EU and its Member States share the responsibility for protecting the EU’s financial 
interests and for fighting fraud. Member State authorities manage three quarters  of EU 
expenditure  and collect the EU’s traditional own resources . The Commission oversees 
both of these areas, sets standards and verifies compliance.  
The European Commission’s annual reports  on the protection of the EU’s financial 
interests  detail the measures taken at European and national level to counter fraud 
affecting the EU budget. These reports are based on information from  the Member States, 
including data on detected irregularities and fraud.  
The number of irregularities reported a s fraudulent ( includ ing cases of suspected or 
established fraud) and the associated amounts are not a direct indicator  of the level of 
fraud affecting the EU budget. They primarily  indicat e the level of detection and 
reporting of potential fraud  by Member States and EU bodies. However, analysi ng this 
information helps to assess the overall level of fraud , identify the areas most at risk, and 
thereby help target action at both EU and national level.  
In 2019 , a total 939 irregularities  (514 on the expenditure side, 425 on the revenue side 
of the budget) were reported as fraudulent  (i.e. 8% of all irregularities detected  and 
reported), involving about EUR 461 million  (28%  of all reported financial amounts were 
affected by irregularities) and covering both expenditure and revenue .  
The number s reported in 2019 and their monetary value  decreased significantly 
compared to 2018 .  
Looking at a five-year period (2015 -2019), the number of reported fraudulent 
irregularities was 40% less than in 2015, and 25% below the five-year average. The 
financial impact fluctuates substantially , as it is skewed by individual cases involving 
large sums.  
In 2019 , the Commission was notified of 10 787 irregularities  (6 550 on the expenditure  
side, and, 4 237 on the revenue side  for t raditional own resources ) reported as non-
fraudulent ( similar to 2018) . The financial amounts  involved decreased by 8%  to 
approximately EUR 1.2 billion.  
In 2020 , the financial value  of detected fraud against the EU budget continued to fall 
according to the 2020 PIF report, adopted by the European Commission on 
20 September  2021. The 1 056 fraudulent irregularities  (451 on  traditional own 
resources and 605 on expenditure) reported in 2020 had a combined financial impact of 
EUR 37 4 million  (EUR 108 million – own resources ; EUR 266 million - 
expenditure) , around 20% fewer  than in 2019  and continuing the steady decrease seen 
 
32 over the last five years . The number of reported non-fraudulent irregularities remained 
stable, but fell in value by 6% , according to the report47. 
Over the last five years, the number of reported irregularities (fraudulent and non -
fraudulent) related to EU expenditure  for the programming period 2007 -2013 decreased, 
while those linked to the 2014 -2020 EU budget have increas ed, consistently with the 
implementation cycles . Reported irregularities related to annual spending (direct aid to 
farmers and market support measures) remained stable.  
Organised crime is a significant threat to the European public , to business and to state 
institutions, as well as to the economy as a whole. Organised crime groups operate across 
all EU Member States and use their large illegal profits to infiltrate the legal economy 
and public institutions, including via corruption . They  erode the rule of law and 
fundamental rights, and undermin e people’s right to safety as well as their trust in public 
authorities. Fraud is becoming increasingly appealing for organised crime.   
Combating the illicit tobacc o trade is an important component of the EU policy to protect 
the EU’s financial interests . Its effects go  beyond the finances though, since the illegal 
tobacco trade also affects the EU security and health . Throughout 2020 , the Commission 
continued implementing the second action plan to combat illegal tobacco trade48.  
The work to combat the illicit tobacco trade , which had featured prominently in activities 
supported by Hercule III , is also illustrative of the difficulties in measuring the 
prevalence of fraud , even in a sin gle sector.  Several studies have attempted to measure 
the true scale of illicit tobacco markets, including a 202 0 external s tudy financed by the 
Hercule III programme49. This study discussed the methodological difficulties in detail, 
and only with those caveats suggested  that counterfeit and contraband consumption could 
account for 8% of total consumption in 2018 and that there were approximately 43.6 
billion counterfeit and contraband cigarettes in Europe in 201 9, all of which evaded taxes 
and customs duties .  
The 2018 mid -term evaluation50 of the Hercule III programme  gives a similar picture in 
terms of the context . The evaluation demonstrated that the programme’s specific and 
                                                           
47    Report from th e Commission to the  European Parliament and the  Council,  32nd Annual Report on the 
protection of the European Union's financial interests - Fight against fraud – 2020, COM(2021)  578,  
final, 20.09.2021.  
48 Commission Communication, Second Action Plan to fig ht the illicit tobacco trade 2018 -2022  
(COM(2018) 846 final, 7.12.2018).  
49 Study to identify an approach to measure the illicit market for tobacco products – Final report, 
Chapters 3.1 -3.3, RAND Europe, April 2020, published by the European Commission (OLAF.B.1). 
https://op.europa.eu/s/ sDtj. 
50 CEPS et  al. (2017). Mid -term Evaluation of the Hercule III p rogramme, Final report:  
https://ec.europa.eu/anti -fraud/sites/antifraud/files/her culeiii_midterm_evaluation_en.pdf  
 
33 operational objectives and activities remained  relevant. It noted that the rationale 
underlying the programme  was still appropriate and no additional adjustments were 
required to account for current problems affecting the financial  interests of the EU.  
The findings of the current evaluation  are in line with the  2018 findings , with a large 
majority of stakeholders stating that both the specific objective and operational objectives 
were highly relevant in terms of protecting the EU’s  financial interests. The programme’s  
specific objective was found to be the most relevant by an average of 83% respondents 
across all three surveys.  
In particular, operational objective 3 on stepping up the fight against fraud by providing 
technical and operational support to national authorities, ranked the highest (80%)  in 
terms of relevance . Crucially, the interviews also confirmed that the operational 
objective s will remain relevant  in the future . Respondents found  operational  objective 
2 on the exchange of information and operational objective 3 on providing technical and 
operational support to national authorities to be particular ly relevan t. 
The programme  was viewed as highly relevant in addressing the main problems of 
stakeholders related to the protection of the EU’s financial interests. In the applicants’ 
survey, 101 out of 126 (80%) answered that the programme  was relevant to address the 
main problems they faced in combating fraud over the period 2014 -2020, and they noted 
that Hercule III  was the only programme  specifically designed to tackle fraud and illicit 
activity across the EU.  Respondents considered t he programme  relevant because it  
complemented the work carried out at Member State level to combat fraud.    
Figure 1 5 – Example of the Programme’s relevance from the case study findings  
 
Evidence from the case studies and interviews found  that, while most Member S tates 
have their own national strategy to fight fraud, the programme  provided  additional 
support that they could access quickly, allowing  national authorities to reach the ir 
Case -study example - Latvia*  
The programme’s relevance was underlined in the projects in this case study. 
Beneficiaries primarily highlighted  its ability to help tackle the high costs of 
purchasing equipment, limi ted available national budgets, and the need for 
improved data quality and analysis. By financing each of the projects, the 
programme had a strong re levance in tackling national and EU level fraud, by 
boosting capacity and evidence that national level institutions can use to effectively 
identify and limit the spread of fraud.  
*This case study included an analysis of two technical assistance projects f or two separate Latvian national 
authorities involving the strengthening of the technical capacity of investigative departments and capacity building 
for forensic examination.  
 
34 national objectives faste r. These findings correspond with the 2011 impact assessment 
and the 2018 mid -term evaluation. The following  needs  remain relevant since the 2011 
impact assessment:  
- the need to tackle the increased technological capacity of criminals  involved in 
illicit activities (outlined in pink in the overview chart overleaf , Figure 16);  
- the need for up -to-date technical support  (outlined in blue);  
- gaps in knowledge and the sharing of best practices  (outlined in green) ; and,  
- problems in creating a harmonised approach across all Member States  in the fight 
against fraud (outlined in yellow).  
 
Figure 16 - Overview of the main needs and drivers - areas of continued relevance  
           
The outline colours shown in the legend highlight for each evaluation where the theme was mentioned. Source: 
RAMBOLL Final Report on the evaluation of the Hercule III Programme.  
Each of the top five most salient needs identified by stakeholders (shown in green) can be 
linked to past issues uncovered in the 2011 impact assessment and previous evaluations, 
thus hig hlighting the recurrent needs and problems (2011 -2020).  

 
35 Data collection and analysis tools - example of good practice51 
Two projects for the analysis of ‘big data’ that were initiated under the Hercule II 
programme continued beyond 2014 under Hercule III .  
The autom ated monitoring tool (AMT)  and container traffic (CONTRAFFIC, 
financed by the Commission through AFIS)  are projects carried out by the European 
Commission’s Joint  Research Centre  under administrative arrangements with the 
Commission (OLAF). These two projects provide tools to support investigations that 
need data and analysis on container movements ( CONTRAFFIC: current and past 
vessel/container movements)  and EU import and export flows (AMT) , providing more 
realistic and effective scenarios for joi nt customs operations .52  
In 2020, the AMT tool was used to monitor and examin e imports of medical supplies 
needed for the COVID -19 pandemic. It was also used to assess the findings from joint 
customs operations carried out in previous years, such as the operation to identif y the 
issue  of undervaluation in imports of textiles and footwear goods.53 
In 2020, OLAF and the JRC also continued with the administrative arrangement for the 
data analysis for customs anti -fraud project (INTEL4CUSTAF) . Funded by the 
Hercule III programme, the administrative arrangement was initially set up at the end of 
201754 between OLAF and the JRC to provide scientific and technical support in 
advancing the EU’s customs anti -fraud data analytics capacity55. 
OLAF initiated the project following requests from Member State customs 
representatives, who recognised the potential of working together with  new datasets 
and analytical methods to address the ever -changing world of customs fraud . The 
project  scope is def ined by activities under Council Regulation (EC) No 515/9756 on 
mutual administrative assistance to ensure the correct application of customs legislation.  
                                                           
51 Source: Annual overview with information on the results of the Hercule III programme  accompanying 
the PIF -report , 2014 , p. 8.  
52 The automated monitoring tool monitors trade flows and identifies suspicious changes in volu me or the 
average price of products, enabling the detection of undervalued products and other types of customs 
fraud such as evasion of anti -dumping duties or misdeclaration of the commodity. Contraffic enables 
officers to detect cases of false declaration  of origin by cross -checking information on physical 
movements of containers with information in customs declarations.   
53 Commission staff working document, Hercule III programme - 2020 implementation, accompanying  
the Report from the Commission to the Eu ropean Parliament and the Council - 32nd Annual Report on 
the protection of the European Union's financial interests - Fight against fraud – 2020 (SWD(2021) 257 
final, p. 20 ). 
54 The first administrative arrangement was signed in late December 2017, coverin g work carried out in 
2018, meaning there is a one -year lag between the annual Hercule III financing decision and the 
associated INTEL4CUSTAF work (e.g. the 2017 Hercule III decision covered funding for 
INTEL4CUSTAF work in 2018).  
55 This support  falls under the activity defined in Article 8(a)(v) of Regulation (EU) No 250/2014 . 
56 Council Regulation (EC) No 515/97 of 13 March 1997 on mutual assistance between the 
administrative authorities of the Member States and cooperation between the latter an d the 
 
 
36 The project is part of a wider effort to provide knowledge and facilitate the work of 
customs authorit ies in Member States for the effective and efficient use of data and 
analytical approaches in the area of customs anti -fraud. In line with the objectives of the 
Hercule III programme, the main beneficiaries of this project are Member State  customs 
authorities. The aim is to improve the overall effectiveness and efficiency of customs 
anti-fraud data analysis across the EU.  
The stakeholders interviewed provided several examples of future needs where the (new) 
programme  could increase its relevance . 
Figure 17 – Specific needs voiced by the stakeholders  
 
The Regulation establishing  the EU’s anti-fraud programme  (UAFP) for the 2021 -2027 
period takes these needs  into account by stressing that ‘the protection of the financial 
interests of the Union should address all aspects of the Union budget, on both t he revenue 
and expenditure side’  (Regulation (EU) 2021/785 , Recital 11 ). Expenditure  fraud is also a 
special focus of the first implementing decision57 adopted in 2021 . 
The evaluation also found that the programme  should  be more reactive and responsive 
(on a yearly basis) to key risk areas as they develop . In particular, interviews with 
Member State AFCOS, applicants and beneficiaries (from the case studies) suggested that 
                                                                                                                                                                             
Commission to ensure the correct application of the law on customs and agricultural matters , OJ L 82, 
22.3.1997, p. 1 . 
57 Commission Implementing De cision on the financing of the union a nti-fraud programme and the  
adoption of the work programme  for 20 21 (C (2021) 5338 final , 23.07.2021 ). 
The AFCOS  and the ‘ PIF associations ’ pointed out that the programme  should  
place an increased focus on expenditure fraud . Although this is  partially 
covered in the scope of the programme , the stakeholders  mentioned  that it could 
be more actively developed as an area of focus in the annual work programme s. 
In many respects, the need to focus on expenditure fraud stems from  the 
overarching pro blem raised by all stakeholders of the need to heighten  
awareness and publicity  of available EU funding opportunities . 
Linked to the need for greater awareness was the need for the programme  to 
be more reactive and responsive to  key risk areas as they deve lop each year . In 
particular, interviews with Member State AFCOS, applicants and beneficiaries 
(from the case studies) suggested that the programme  could develop policy 
documents including action plans to tackle emerging threats such as food 
fraud, the (criminal or) unlawful use of drones and advances in cybercrime . 
 
37 the programme  could play a rule in implementing or potentially developing action plans , 
including on  emerging threats such as food fraud, (criminal  or) unlawful  use of drones 
and developments in cybercrime .  
The need to adjust to new technological developments and challenges is prominent  in the 
EU’s anti-fraud programme (Regulation (EU) 2021/785, Recital 20) , and in the 2021 
UAFP annual work programme . 
Figure 18 – Key findings in terms of relevance  
 
5.2. Effectiveness  
Assess ing the programme’s effectiveness looks at the progress made towards achiev ing 
the set objectives , whether the intended outcomes have been achieved  (or are likely to 
be achieved in the future)  and to what extent the achievements are sustainable . At a 
broader level, the analysis assessed the achievements  of the programme , in relation to the 
key activities of technical assistance, (legal) training , conferences , research activities  and 
studies . To that effect,  dividing  the criterion of effectiveness into technical assistance and 
training  facilitated the assessment .  
Article 8(a) of  Regulation (EU) No 250/2014  provides that  technical assistance consist s 
of the provision of specialised technical assistance for Member State  authorities . This 
includes provi ding specific knowledge, specialised and technically advanced equipment 
and ef fective information technology tools , providi ng the necessary support and 
facilitating investigations conducted by Member State authorities.  
The evidence collected during th e evaluation indicates that the programme  continues to 
be successful  in supporting national law enforcement agencies, in line with the results of 
Overall, the programme was found to be highly relevant in:  
- tackling the current challenges in the fight against fraud across Europe.  The 
needs of stakeholders have not drastically changed since the initial 2011 impact 
assessment of the programme;  
- addressing the financial and tec hnological gaps by m aking the prospect of 
purchasing technology more realistic and achievable  for national authorities .  
In turn, this meant that the p rogramme was also able to complement the work 
carried out at Member State level, and as one beneficiary noted – to “rationally 
and effectively achieve their overarching objectives”.  
The relevance of the p rogramme  could be further improved . Specifically, it c ould 
take better account of  emerging threats and it could also place a greater 
emphasis  on expenditure fraud and cybercrime . 
 
38 the final evaluation of the previous Hercule II programme  and the mid -term evaluation of 
the Hercule III programme . 
Overall, there was broad consensus among the different stakeholders that technical 
assistance actions contributed to providing support to the law enforcement authorities of 
the Member States in their work to combat  illegal cross -border activities.   
In the applicants’  survey, 52 ou t of 60 respondents agreed to a great or to a certain extent 
that the support provided by the programme  contributed to supporting law enforcement 
agencies in their work to combat illegal cross -border activities . Th e interviewees 
confirmed that the technical assistance was effective in supporting law enforcement 
agencies.  
The results of the desk -based assessment of achievements suggest that the programme  
helped increase both the operational and analytical capacity of law enforcement agencies.   
According to the analysis of the project reports, purchased equipment helped national law 
enforcement agencies carry out  more operations, for instance by increasing the number of 
checks at border crossing points through scanners or by enabling them to oper ate in 
difficult or dangerous situations due to better and safer communication equipment (such 
as surveillance equipment or IMSI -catchers58).  
The technical assistance  project reports also show that the projects enabled national law 
enforcement agencies to improve the quality of the evidence collected  using more 
modern technologies. IT systems and software enabled  law enforcement agencies to 
analyse a greater volume of data and thus reveal complex crimina l activities.   
On the programme’s contribution to stimulate more staff e xchanges for specific projects , 
the programme was perceived as making a limited  contribution , with only 38% of 
beneficiaries answering that the programme had contributed towards this aspect . In-depth 
interviews conducted at EU level confirmed this finding and  acknowledged that staff 
exchanges as part of technical assistance projects  were not an area of focus.  
However, respondents suggested that staff exchanges could have a greater impact as 
part of training  rather than technical assistance projects . This is in line with evidence 
from the Hercule III mid-term evaluation and the final evaluation of the Hercule II 
programme , which uncovered limited evidence showing that joint operations and staff 
exchanges had increased and/or were effective.  
Minimising the risks in the key areas of cigarette smuggling and counterfeiting  
Evidence collected from an assessment of the achievements and case studies show s that 
technical assistance projects were successful in reducing the risk of cigarette 
                                                           
58 An international mobile subscriber identity -catcher, or IMSI -catcher, is a telephone eavesdropping 
device used for intercepting mobile phone traffic and tracking location data of mobile phone users.  
 
39 smuggling and counterfeiting . The programme  thus continued to focus on the key risk 
areas of cigarette smuggling and counterfeiting.   
In total, 19 technical assistance projects out of the 98 selected projects  assessed were 
able to report on the quantities of seized  cigarettes with the purchased equipment.  
The project reports show  that the following factors helped nat ional law enforcemen t 
agencies reduce the risk of cigarette smuggling:  
- modern fixed scanners  enabled  operators  to scan more objects at border crossing 
points and produce  higher quality imagery ; 
- mobile scanners and sniffer dogs  enabled customs authorities to search vehicle 
parts that could not have been searche d without the equipment ; 
- surveillance equipment  helped law enforcement agencies collect evidence on 
large smuggling operations and illegal cigarette production facilities.  
Interviewees  from the JRC  also highlighted the importance of the TOBLAB project59 at 
the JRC in helping national law enforcement agencies collect additional evidence of 
cigarette smuggling patterns within Europe and worldwide.   
Overall, there is comparatively less evidence availab le on the effectiveness of 
technical assistance in reducing the risk of counterfeiting than of cigarette 
smuggling.   
Only four out of 19 projects60 reported on the quantities of counterfeited products  seized . 
One reason could be the nature of the technical equipment purchased. Interviewees for 
one of the case studies for example pointed out that scanners are not able to detect 
counterfeit products in containers per se, as this would require a manual in spection by 
customs officers.  
However, respondents agreed to a certain or great extent that technical assistance projects 
contributed both to reducing the risk of cigarette smuggling (45 out of 60) and reducing 
the risk of counterfeiting (40 out of 60).  Ultimately, law enforcement officials may also 
not always see the need to establish whether the smuggled product they have seized is 
genuine or counterfeit, unless there are specific reasons to do so.   
Technical assistance projects  helped national law enforcement agencies  cooperate better 
with other organisations and departments within their countries, but also with law 
enforcement agencies from other Member States.   
                                                           
59 JRC operates a dedicated tobacco laboratory (TOBLAB) to create chemical fingerprints of tobacco, 
which are processed by chemometric tools to identify similarities among tobacco products seized in 
different countries. This intelligence supports law enforcement actions at Member State as well as 
European Commission level.  
60 Out of the 60 technical assistance projects that were assessed in terms of the programme’s 
achievements,  19 projects reported on quantitative numbers of seizures that they achieved with the 
purchased equ ipment. Not all technical assistance projects are related to identifying illicit products.  
 
40 According to evidence  collected  from the assessment of achievements, the purchase of 
forensic IT systems and communication technologies enabled law enforcement 
authorities to exchange intelligence information and evidence with other organisations 
within their countri es and outside their  countries.  
Figure 19 – Case study example - Effectiveness of technical assistance projects in 
contributing to the programme’s specific and operational objectives  
 
Technical assistance projects were found to produce  a number of positive external effects. 
Based on the assessment of achievements, the purchase of modern equipment generated a 
number of positive effects that are not among the programme’s primary objectives, but 
nevertheless benefit the national law enforc ement agencies.  
Equipment purchased and used to  carry out  border checks has proven useful to 
detect illegal drugs or illegal weapons.  10 out of the 19 final implementation reports 
analysed as part of the assessment of achievements  reported  seizures of dru gs or illegal 
weapons.  
Evidence from the case studies also indicates the usefulness of equipment in seizing 
illegal substances or artefacts that do not primarily undermine  the EU’s financial interest s 
but pose a more general security threat to EU Member States.  
Evidence from the assessment of achievements and from case studies suggest that 
technical equipment  increased the health and safety of customs and police officers .  
The modernisation of scanners  minimised the risk to radiation exposure . Modern 
communication and surveillance equipment helped officers monitor criminal activities 
while staying undetected at a safe distance.  
 
 
Case -study example - Hungary  
The most important area of support  that the programme provided  was in increasing 
data exchange, developing and providing IT tools for investigations, and 
monitoring intelligence work . Thanks to  the surveillance technologies  acquired , 
both projects in Hungary generated benefits such as increased technological 
capacity, greater support provided to law enforcement agencies and increased 
transnational cooperation . 
*This case stu dy included an analysis of two t echnical  assistance projects for two separate Hungarian national authorities 
involving the provision of tools for digital evidence analysis as well as  technical capacity development.  
 
41 Figure 20 – Case study example - external factors affecting the delivery of results 
and achievements  
 
Figure 21 - Key findings regarding the effectiveness of technical assistance projects  
 
Contribution to improving preven tion and investigation of fraud  – Training  
Under Article 8(b) of Regulation (EU) No 250/2014, a training project is described as the 
organisation of targeted specialised training, risk  analysis  training workshops, and where 
appropriate, conferences. This includes coordinating activities of participating countries 
and representatives of international organisations with the aim of exchanging experience 
Case -study example - Lithuania  
Beneficiaries found that a scanner purchased through the p rogramme generated  
additional effects  other than increasing the detection o f smuggled goods. The scanner  
lowered the  risk of radiation  and therefore resulted in  a safe and healthier 
environment  in the workplace, creating a positive impact on the productivity  of staff 
working in customs controls. Thus, the project highlighted areas where the effects of the 
programme work indirectly by enabling more productive working procedures  and at 
the same time creating a safer and healthier w ork environment for the officers  
operating the purchased equipment.  
*This case study included an analysis of two technical assistance projects for two separate  national authorities involving the 
development of criminal intelligence tools and the installation of a high -power stationary x -ray scanner.  
The evidence collected through the study suggests that technical assistance project s 
were effective during the period under review (2014 -2020). In particular, the 
purchase of technical equipment and IT tools supported national law enforcement 
agencies and helped minimise risk  in the key areas of cigarette smuggling and 
counterfeiting.  
Overall, the study found slightly less evidence  of the effectiveness of technical 
assistance project s in the area of counterfeiting . Furthermore, technical assistance 
actions were found to have facilitated national and transnational cooperation 
between  benef iciaries .  
The analysis of evidence also unveiled some positive external effects  of technical 
assistance , specifically in the detection of illicit goods such as cigarettes and 
counterfeited products, as well as the increased health and safety  of customs an d 
police officers.  
 
42 and best practice between authorities and developing high -profile research activities and 
studies.  
This section provides an overview of the main results achieved by beneficiaries 
implementing awarded  grants for training purposes, throughout the programme 
duration, including projects ending in 202061, which may have started in 2018 or 2019 . 
Training activities finalised in 2020 concerned a wide range of disciplines and topics such 
as: fighting transit fraud in the EU; advanced X -ray image interpretation training; 
methodologies of detecting and investigating crimes detrimental to EU financial interests; 
and enhancing the cooperation and control models in the field of prevention of fraud 
affecting the EU’s own resources.  Between 2014 an d 2020, a bout 10 000 participants 
followed specialised training and conference activities, co -financed by the programme 
through grants. The received feedback upon the end of the event resulted in a 93% 
participants’ satisfaction rate. About 1 340 law enfor cement officials from all Member 
States participated in the specialised digital forensic and analyst training funded under the 
programme  (2014 -2020). A valuable network of forensic and analysis specialists was 
created in each Member State as an effect of such training possibilities.  
As for the procured events, 45 high -level events organised by OLAF focused on the 
protection of the EU’s fin ancial interests, including high -level meetings between customs 
and other regulatory or enforcement authorities, conferences with prosecutors dealing 
with fraud cases, meetings of the dedicated task group on combating illicit cigarette 
production and smugg ling, seminars with the AFCOS members, etc.  
The effects of training and conferences funded by the programme were largely 
found to be of a less tangible nature , as they rarely result in the reduction of fraud or 
increased seizures of illicit cigarettes, whi ch can be directly attributed to a training event. 
Respondents that had participated in events funded under the programme highlighted the 
importance of these events for networking and meeting colleagues from other countries.  
In the framework of the study supporting this evaluation, t he stakeholders consulted by 
the external contractor found that  training  and conferences were a mixed success in 
enhancing multidisciplinary cooperation and cooperation with practitioners.  
The majority of respondents to the survey of event  participants did not agree, or agreed 
only to a limited  extent, that the events improved cooperation between practitioners and 
academi a. This may to a certain extent be explained by the participation rates . The vast 
majority of participants in events came from law enforcement agencies  (inspection 
services, customs, police) , the judiciary  (prosecutors, judges and court staf f) and national 
authorities  (audit services, EU -related administrative services ). Only a minority of 
participants (5% on average) came from academia  (universities, study centres) . Note, 
                                                           
61 Source: Advisory Committee for the Coordination of Fraud Prevention (COCOLAF) – OLAF 
presentation, 17 June 2021 - Hercule III, 2020 implementation and financing op portunities for 2021.  
 
43 however , that events open only to the law enforcement community (sometimes due to the 
sensitivity of the matters discussed), cannot promote cooperation with  academia.   
Moreover, during the interviews  of the study , representatives of academic institutions 
highlighted the programme’s success in enhancing cooperation between practitioners and 
academics, while interviewees from the EU institutions or Member State  AFCOS were 
more critical of this aspect .  
There is evidence that projects under the programme  were  effective at producing 
high -level research.   
A majority of respondents to the applicants’ survey agreed to a great or to a certain extent 
that the event they participated in or the support they received contributed to the 
development of high -profile research. Interviewees  from academic institutions also 
reported that the programme funds were successful in creating a communit y of scholars 
that work in the field of EU criminal law and on protectin g the EU’s financial interests.  
One example  of the success of the programme  in developing high -profile research 
activities is the EUCRIM journal , which received a periodic grant durin g the funding 
period under review. For 2014 –2020, EUCRIM published 27 special issues  in total , each 
of which contained multiple academic articles and commentaries written by renowned 
scholars in the area of European criminal law.  
Figure 2 2 – Key findings on the effectiveness of anti -fraud training and conferences  
 
Sustainability of the programme’s interventions  
The criterion of sustainability examines the extent to which the effects or changes  caused 
by the programme could be permanent  and to what degree their effects would last after 
project completion . Thus, the evaluation looks at the extent to which the long -term 
effects of the projects are viable and the degree to which they (may) have triggered any 
additional initiatives  at national level.  
Overall, the anti-fraud training and conferences  financed or procured by the 
programme were found to be effective . Networking played an  important role in 
developing crossborder  cooperation between Member State authorities and 
stakeholders.  
Further evidence confirmed that training and conferences were successful in 
enhancing the exchange of best practice and experience among participants, and 
in contributing to the development of high -profile research .  
The survey found l ess evidence  on the effectiveness of training in enhancing 
cooperation  between practitioners and academics . Non etheless, the programme 
was successful in expanding a community of scholars that work in the field o f EU 
criminal law (studies) and on protectin g the EU’s financial interests . 
 
44 In the case of technical assistance , evidence from the stakeholder consultations suggests 
that the sustainability of the programme is highly dependen t on the nature and cost of the 
equipment purchased. Thus, as long as the equipment used in the fight against fraud is in 
use, effects can be prolonged. However, potential costs concerning software updates and 
general maintenance were raised in the intervi ews as factors, which hinder the 
sustainability  of the programme’s effects, as in most cases these costs are not covered as 
part of the funding provided for one particular project.  
Beneficiaries of technical assistance grants must mention the Hercule III programme 
support in their reporting and in any other document or press release that report s on the 
results. For example, p ress releases issued following seizures of counterfeit or smuggled 
cigarettes through funded equipment must mention the EU funding. He nce, the EU -
funded investment by the beneficiary maintains it s continued impact beyond the date of 
the end of the project, depending on the lifetime and use of the purchased material(s).  
Technical assistance grants are awarded for the purchase and installa tion of technical 
equipment that, at the time of final reporting, were operational only for a short period. 
The first tangible results of the equipment, such as seizures , arrests of suspected persons 
or estimates of prevented losses to the national or EU b udget, can only be reported 
months after the closing date of the action. For this reason, beneficiaries are required to 
submit a final implementation report one year after the closing date of the action to report 
on the results from the use of equipment.  
Figure 23 – Case study example - long-term  sustainability of projects  
 
In terms of the provision of technical assistance, evidence from the stakeholder 
consultations suggests that the sustainability of the programme is highly dependent on the 
nature and cost of the equipment pu rchased. If the equipment used to combat fraud is in 
use, the effects can be sustained . However, potential costs of software updates and 
general maintenance were raised in the interviews as factors that could make the effects 
 
       This case study included an analysis of two technical assistance projects  for 
two separate national authorities involving the purchase of a backscattering van 
and capacity building for the detection of illicit cigarettes. Across both projects, 
positive long -term effects from the programme were apparent .  
The programme was a key driver in the stakeholders’ ability to meet their 
department objectives  in the fight against fraud, thus setting a foundation for future 
objectives and raising their capacity to develop further in the future. In particular, 
the study  noted that the effect s of the programme were not limited to the lifespan of 
the technologies but, in some instances, were able to build capacity and knowledge 
among the users of the equipment, thereby ensuring a more lasting impact . 
Case -study example - Poland  
 
45 of the programme  less sustainable , as in most cases the costs are not covered as part of  
the funding provided for that particular project.  
The mid - to long -term effects of training and conferences funded by the programme 
were found to be largely of a less tangible nature , as they rarely result in reduction of 
fraud or increased seizures of illicit cigarettes, which can be directly attributed to such an 
event. Respondents, participating in events funded under the programme , highlighted the 
importance of such events as opport unities for networking and meeting colleagues from 
other countries.  
According to the respondents, the informality of the events enabled participants to build 
a trustworthy working relationship , which is key for successful transnational 
cooperation. Partic ipants of events echoed this in the event feedback forms, while the 
survey with participants of procured events provides further evidence that training and 
conferences have been successful in enabling participants to exchange experience and 
best practice.  
While anti -fraud events and conferences were found to contribute to the development of 
professional networks, evidence on the sustainability  of these effects over time is 
inconclusive . Evidence seems to suggest that in the aftermath of events, participants have 
gone on to share the acquired competences and knowledge with their peers at their 
workplace. This thus adds to the sustainability of the Programme through its ability to 
have an e ffect not just at the EU level but also at the national and regional levels.  
Beneficiaries of grants for training must mention the support received from the Hercule 
III programme in every publication (title page) or related material (studies, booklets, 
newsletters, leaflets, etc.), in online  information (websites, audio -visual material, videos, 
software, other), and at events (conferences, workshops and seminars ). The mentions 
must include  a link from their website to the Hercule III programme site.  
  In this way, the benefits and impact of the programme are  magnified via  communicati on 
channels, providing digital access to Hercule and enhancing recognition of the 
programme. The  study  found that  the long -term effects of the programme are sustainable 
to a certain extent, given the limited durability of technical assistance projects.  
  Although the survey of the study found that events and conferences on anti -fraud 
contribute d to the development of professional networks, evidenc e on how sustainab le 
these effects are over time is inconclusive.  Evidence seems to suggest that after  the 
events, participants have gone on to share the acquired competences and knowledge with 
their peers at their workplace. This makes the programme  more  sustainabl e by generating 
an effect not just at EU level but also at the national and regional levels.  
As for the e xtent to which the programme triggered additional in itiatives  at national 
level, the evidence is inconclusive  as to whether the programme triggered similar 
initiatives at national level. The number of respondents who do not know whether  the 
programme triggered initiatives at national level was significant in all three surveys.  The 
lack of awareness or knowledge of comparable nationa l initiatives was also reflected in 
 
46 the interviews where only one respondent mentioned a research project implemented at 
national level as a result of a discussion at a conference funded by the programme.  
The above findings may be due to a combination of several reasons, for example the 
doubt that a beneficiary would no longer receive financial support from the programme 
once a similar initiative is set up with national funding or other sources of funding.  
5.3. Efficiency  
The aim of assessing  efficiency is to measure the relationship between the results and the 
resources invested in attaining the results. The assessment focused on identifying the 
benefits (cost savings, fraud reduction, etc.) related to the application process and 
implementation of funding projects , as well as the programme  overall.  
Evidence from the stakeholder consultations suggests that the main direct cost in 
both the application and implementation phases is staffing costs.  Interestingly, the 
degree to which the costs were due to administrative costs and/or burden in both the 
application procedures and the reporting required to implement  the contracts differed. 
This is consistent with the finding from the mid -term evaluation, which found that, on 
average , beneficiaries spent more time completing applications  than on reporting results. 
To understand these  differences, the following sub sections will explore each part in turn.  
Figure 2 4 – Case study example – Efficiency and cost effectiveness of projects  
 
Evidence from the applicants’ survey found that, on average, applicants to the 
programme  spend 15.3 full -time person days preparing and submitting an application. 
This is on  average 2.7 days less than the time to prepare the mid -term evaluation, 
suggesting that  the programme  may have made some efficiency gains over 2014 -2020.   
Case -study example – Bulgaria and Latvia  
Bulgaria : Interviewees in both projects highlighted that in their opinion it was not 
possible to achieve any  cost savings. As both projects were procured via public 
procurement processes according to Bulgarian public procurement rules and 
procedures, the cheapest possible bids were awarded the contracts.  
Latvia : Interviewees focusing on both projects underlined how the benefits could not 
have been  generated  at a lower cost. This was primarily because the purchased 
equipment was carefully selected following a market  analysis of the most cost -
effective option available. The cost could not have been lower than the market value.  
*The case study in Bulgaria included an analysis of two technical assistance projects for two separate national authorities 
involving the purchase of  Х-Rays scanners and enhancing technical capacity while Latvia involved the purchase of IT forensic 
equipment and a Rama Spectrometer.  
 
47 This decrease could be explained by  the switch to the online platform ‘e‘-grants ’ in 2017. 
However, the respondents and sample sizes vary between the mid -term evaluation and the 
applicants’ survey conducted for the purpose of this evaluation . Therefore,  efficiency 
gains could purely reflect a different set of respondents.  
Although there may have been a reduction in the number of full -time person days needed 
to complete the application procedure, 43% (53 out of 123) of respondents to the 
applicants’ surv ey answered that the administrative costs had increased . This compare s 
to 30% (37 out of 123) who answered that the costs had not changed.  
Evidence from the interviews suggest s that a lack of dedicated staff in the given 
organisations that are knowledgeable of EU funds could in part explain the administrative 
costs incurred, with more time being spent understanding the application process and 
what was required for an application to be successful.  
Most  stakeholders were of the view that the application procedure could be further 
simplified. Across the interviews, survey and case studies, they suggested that the 
programme  could provide more support during  the application phase, particularly by 
fostering a better understanding of the award criteria and what constitutes best  practice in 
preparing proposals. Furthermore, clearer instructions on the application procedure could 
help minimise common  mistakes that are made in all applications, therefore helping to 
reduce delays and the overall time spent completing applications. Despite the costs 
incurred and scope to simplify the application procedure,  most  applicants were of the 
view that additional administrative and fina ncial burdens did not discourage them from 
applying to a call fo r proposals under the programme . 
There were mixed views , however , on the extent to which the procedures in the 
implementation phase could be simplified , with 42% of beneficiaries answering that it 
could be simplified, and 38% answer ing that it could not. The interviews also revealed 
these difference s of opinion , where only a few interviewees could provide examples of 
ways to simplif y the implementation pr ocedure. Suggestions included minimising the 
need for final reports  from beneficiaries and a specific example of using the multi annual  
administrative arrangements between OLAF and the JRC to better implement projects.  
The majority of the programme beneficiaries acknowledged that they experienced both 
direct and indirect benefits as a result of implement ing the projects.  
The main direct benefit highlighted  relating to technical assistance projects  was the 
simple benefit of acquiring technical assistance equipment and innovative tools and 
methods.  Respondents noted that the equipment had resulted in higher  detection rates 
and, by default, an increase in the n umber of seizures. This was similar to the findings 
under training , where the greatest benefit was in develop ing research and building 
knowledge among stakeholders.  
Concerning  the indirect benefits of the programme , the most salient answer was in 
strengthening collaboration and cooperation between and within Member State 
authorities, and stakeholders, and in exchang ing best practice. This was reiterated in 
 
48 the interviews where beneficiaries reported that the main indirect  benefits were in 
improv ing the daily work of law enforcement authorities through better knowledge and 
skills.  
Considering the costs and benefits incurred/accrued by stakeholders, most were of the 
view that the programme benefits outwe ighed the costs.  For example, e vidence  from the 
applicants’ survey highlighted that 92% of beneficiaries agreed that the benefits 
generated outweigh the cost s incurred during the contract.  
In addition, several stakeholders  highlighted that, for technical assistance  projects , the 
value of goods seized often exceeded the initial value of the contract awarded by the 
programme . The case studies in Poland confirmed that  the value of a single seizure 
covered the whole project investment cost.  A few interviewees  highlighted several 
contextual factors  that can affect the relationship between costs and benefits.  
A partner organisation highlighted that there can be differences in the use of funding 
under the programme  to organis e events and conferences between different stakeholders. 
For example, some organisations may not always have the experience of organising 
large -scale events compared to other organisations who may have more trained and 
experienced staff. Thus, in this situa tion it may not be fair to compare the use of budget 
between organisations in assessing the individual efficiency of each project.  
Figure 25 – Main findings under efficiency  
 
 
5.4. Coherence  
The assessment of internal and external coherence  examines the extent to which aspects 
of the Hercule III programme worked well together and with other EU programmes and 
areas of action . 
Considering the costs and benefits  incurred by stakeholders, a good majority were of the 
view that the programme’s benefits outweighed the costs .  
The overwhelming majority of beneficiaries also reported that they experienced both 
direct and indirect benefits as a result of implementing the projects, with the most salient 
benefit being the purchase of technical equipment. This was due to many national 
authorities experiencing budget restraints, limiting their ability to make significant 
investments. Overall, the main direct costs in both th e application and implementation 
phases were for staffing costs.  
On average, applicants to the programme spent 15.3 full -time person days preparing and 
applying for funding, compared to an average of 14.4 full -time person days to meet the 
programme’s repo rting requirements during the implementation. They identified scope to 
simplify some  procedures in the programme  (application and reporting), namely through 
avoiding redundancies in application forms as well as providing further guidance.  
 
49 The assessment of internal coherence examines whether the different projects funded 
under the programme  are complementary , whether  there are synergies between them or 
whether  they overlap. The f indings on internal coherence drew on three sources: desk 
research, feedback received in interviews and responses from the applicants’ survey.  
The activities eligible for funding under the programme  appe ar to be 
complementary . The evaluation did not identify any critical overlaps between the 
different activities funded by Hercule III.   
The review of the regulation  establishing the Hercule III programme  and its annual work 
programme s did not uncover any inconsistenc ies that would generate significant overlap s. 
Desk research was suppl emented by opinions provided by multiple  stakeholders  to assess 
how the programme was implemented in practice.  Although  interviewees from EU 
institutions did not mention any current overlaps between programme  activities, a quarter 
of participants to the applicants’ survey (27 out of 99) did. A few of the respondents who 
provided written feedback ( 6 out of 18) mentioned that conferences, seminars, and legal 
studies are somehow related. In fact, after a conference  is organised , stakeholders often 
work together to prepar e a study on the topics cover ed.  
Therefore, survey respondents found that  the distinction between these types of 
activities was not clear . However, it can be argue d that rather than overlapping, these 
activities appear  to be strongly complementary, in that one precedes and feeds into the 
other. Similarly, several respondents who provided written feedback highlighted that the 
purchase  of equipment often requires training. This may result in an overlap between 
technical a ssistance and training activities.  
The assessment did not reveal any significant contradictions between the type s of 
activities funded. The desk -based assessment of coherence and the feedback collected 
through interviews did not highlight any contradictio ns.  
Internal coherence between the types of activities of the Hercule III programme  
Figure 26 provides an overview of the activities eligible for funding under each pillar of 
the Hercule III programme . Activities listed in r ow (i) under technical assistance and 
under training appear similar  but they target different audiences  and have different 
goals .  
Training under the technical assistance pillar specifically focus es on providing specific 
information on the use of equipment funded under technical  assistance a s well as on  the 
use and sharing of data collected by the equipment in transnational cooperation or with 
the Commission. The aim of the ‘general’ training i s to raise awareness of the 
mechanisms available at national and EU level that help Mem ber States combat fraud.  
Overall, the activities eligible for funding under the Hercule III programme  appear 
to be strongly complementary . Activities  funded under training may help stakeholders 
implement technical assistance projects effectively  in future. In turn, projects eligible 
under the third pillar may help fill any specific gaps arising from the first two pillars.  
 
50 Figure 26 - Activities eligible for funding under the Hercule III programme  
 (a) Technical assistance  (b) Training  (c) Other  
(i) Providing specific 
knowledge , specialised and 
technically advanced 
equipment and effective 
information technology (IT) 
tools facilitating 
transnational cooperation 
and cooperation with the 
Commission .  Fostering better 
understanding of EU and 
national mechanisms .  Any other action not 
covered under point 
(a) or (b) of this  
Article, provided for 
in the annual work 
programme s 
referred to in Article 
11, which is 
necessary for 
attaining  
the general, the 
specific and the 
operational 
objectives  
provided for in 
Articles 3, 4 and 5 
respectively . (ii) Ensuring the necessary 
support and facilitating 
investigations, in particular 
the setting up of joint 
investigation teams and 
cross -border operations.   Exchanging experience 
and best practices between 
the relevant authorities in 
the participating countries, 
including specialised law 
enforcement services and 
representatives of interna -
tional organisations as 
referred to in Article 7(3 ). 
(iii) Supporting Member States’ 
capacity to store and 
destroy seized cigarettes, as 
well as independent 
analytical services for the 
analysis of seized cigarettes.  Coordinating the activities 
of participating countries, 
and representatives of 
international 
organ isations, as referred 
to in Article 7(3 ). 
(iv) Enhancing staff exchanges 
for specific projects, in 
particular in the field of the 
fight against cigarette 
smuggling and 
counterfeiting.  Disseminating knowledge, 
particularly on better 
identification of risk for 
investigative purposes.  
(v) Providing technical and 
operational support for the 
law enforcement authorities 
of the Member States in 
their fight against illegal 
cross -border activities and 
fraud affecting the EU’s 
financial interests, including 
in particular support for 
customs authorities.  Developing high -profile 
research activities, 
including studies.  
(vi) Building information 
technology capacity 
throughout participating 
countries by developing and 
providing specific databases 
and IT tools facilitating data 
access and analysis  Improving cooperation 
between practitioners and 
academics.  
 
51  (a) Technical assistance  (b) Training  (c) Other  
(vii) Increasing data exchange, 
developing and providing 
IT tools for investigations, 
and monitoring intelligence 
work.  Further raising the 
awareness of the  judiciary 
(prosecutors, judges and 
court staff)  and other 
branches of the legal 
profession (lawyers,  
barristers, solicitors,  
notaries, bailiffs) for the 
protection of the EU’s 
financial interests.  
The actions eligible for funding appear to be coherent with one another. They have been 
implemented in line with the allocation of funds provided in the Annex to the Hercule  III 
Regulation.  Whilst respecting the set financial values, the number of actions funded were 
also implemented in a well -balanced manner : approximately 50% of the actions were 
technical assistance opportunities  (about 80% financial value) , while 48% of them were 
training activities  (about 1 9% financial value) .  
Figure 27 – Finding on the coherence of eligible projects  and their implementation  
 
The assessment of external coherence  examines whether there are any compl ementarities, 
synergies or overlaps between the Hercule III programme  and other EU legislation or 
programme s. Findings on external  coherence are based on  two sources : desk research and 
feedback received in the interviews with the external contractor during the study.  
The desk -based assessment and EU interviews uncovered significant complementarities 
between Regulation (EU)  2017/1939 implementing enhanced cooperation on the 
establishment of the Euro pean Public Prosecutor’s Office 62 (‘EPPO Regulation ’) and the 
Hercule III  programme . The objective of the EPPO Regulation is to ‘enhance the fight 
against offences affecting the financial interests of the Union by setting up the EPPO’ 
(Recital 12 of Regulation (EU) No 2017/1939).  
                                                           
62 See footnote 13.  
Projects eligible for funding appear to be coherent with one another . They were  
implemented in line with the allocation of funds provided for in the Annex to the 
Hercule III Regulation. Whilst respecting the set financial values, the number of 
projects  funded were also implemented in a well -balanced manner : approximately 
50% were technical assistance and 48% were training projects.  
 
52 Regulation (EU) 2017/1939 specifie s that the EPPO  shall establish and maintain a close 
relationship  with OLAF based on mutual cooperation . They  act according to their 
respective mandates and avoid duplicatin g investigative activities . 
In relation to the above, four interviewees mentioned that , while the core activities of the 
EPPO are related to the inv estigations and prosecutions of crimes affecting the Union’s 
financial interests,  some specific  EPPO’s initiatives, such as  the training of national 
authorities on features and activities  of the EPPO , are complementary to other schemes  
funded by the programme. Conferences  funded by Hercule III were also organised to 
support the debate s on the establishment of the EPPO . The desk -based review of the 
EPPO and Hercule III legal texts also highlights aspects  of complementarity:  
- both pursue the objective t o protect the EU’s financial interests;  
- both promote , albeit in very different contexts,  collaboration between EU and non -EU 
bodies to facilitate and step up the fight  against fraudulent activities.  
There is a small potential risk that the training activities organised by the EPPO and the 
training activities funded by the programme (especially on legal training) may overlap , 
despite being seen as complementary. Since the EPPO started its operational activities on 
1 June 2021, this potential overlap is limited to training projects, funded through the 
Hercule Programme under the 2020 budget, and to those, which  would be implemented in 
2021 and 2022.  The training activities funded by the Hercule programme focus on 
protection of the EU’s financia l interests by means of administrative law whereas training 
organised by the EPPO is dedicated to criminal investigations within their remit. The 
EPPO Regulation and the Hercule III Regulation have similar objectives but they 
contribute to their achievemen t in different ways.  
The PIF Directive  sets minimum rules concerning the definition of criminal offences and 
sanctions in the area of  combat ing fraud and other illegal activities affecting the EU's 
financial interests. The PIF Directive seeks to strengthen  the fight  against criminal 
offences  that undermine  the EU’s financial interests.  
There appears to be some  complementarity between the PIF Directive and the Hercule  III 
Regulation. The aim of the PIF Directive is to strengthen the fight against fraud and 
protect the EU’s financial interests , in line with the general objectives of the Hercule  III 
programme. Both desk research and interviews with stakeholders from the EU 
institutions indicate that the two pieces of legislation differ  quite substantially in terms of 
how they envisage achiev ing their goals.  
The PIF Directive aims to harmonise the rules on the definitions and penalties  in the area 
of crimes affecting the Union ’s financial interests , which national authorities and the 
EPPO must  apply when investigating  and prosecuting such crimes . The PIF Directive 
also defines the EPPO ’s materia l competence . The Hercule III Regulation, by contrast , 
combats  fraud by provi ding funding for activities to conduct investigations on fraudulent 
activities , to seize a nd destroy fraudulent products and to learn about the modus operandi 
 
53 of criminal networks. To sum up, the PIF Directive , the EPPO  and the Hercule III 
programme activities have similar  objective s but pursue them in very different  ways. 
There is strong complementarity between action under the Hercule III programme  and 
AFIS .  
The anti-fraud information system (AFIS) is a web -based platform that was set up on the 
basis of Council Regulation 515/9763. AFIS  offer s several IT applications to users in 
organisations tasked with preventing, investigating, and prosecuting infringements of EU 
customs or agricultural legislation. OLAF operates the AFIS anti -fraud applications . 
The general objective of AFIS is to protect the EU’s financial interest  and taxpayers’ 
money. Its specific objective is to support mutual assistance in customs matters by 
provi ding secure information exchange tools for joint operations and specific customs 
anti-fraud information exchange modules and databases such as the Cust oms Information 
System. AFIS allows for a  safe and efficient exchange of information . The Hercule III 
Regulation encourages  such exchanges  between different competent bodies. Interviewed 
stakeholders confirm ed that AFIS is complementary to Hercule III, as it provides a useful 
IT tool to implement technical assistance projects  funded by Hercule III.  
One interviewee mentioned that AFIS (and Council Regulation (EC) No 515/97 ) are 
complementary to the Hercule III programme . Both legal bases have in the past allow ed 
for funding of similar conferences run under both programme s.  
The Commission decided to make better use of this complementarity and integrated in the 
EU’s new anti-fraud programme the Hercule component (spending part), the AFIS part 
and the Irregularity Management System (IMS); the latter two based on Regulation (EC) 
No 515/97. This will further increase complementarity and avoid any risk of overlap.  
Desk research also found complementarities between the Hercule III programme  and the 
Fiscalis 2020 programme . Under  Regulation 1286 /201364 establish ing the Fiscalis 2020 
programme , the general objective of Fiscalis 2020 is to improve the proper functioning of 
taxation systems in the internal market by stepping up cooperation between participating 
countries, their tax authorities and their officials .  
Several areas for action eligible for funding under the Fiscalis programme  are similar in 
nature to those eligible under the Hercule III programme . This may be a source of 
potential , though  limited , overlap. Two interviewees  mentioned that  training /workshops, 
                                                           
63 Council Regulation (EC) No 515/97 of 13 March 1997 on mutual assistance between the 
administrative authorities of the Member States and cooperation between the latter and the 
Commission to ensure the correct appli cation of the law on customs and agricultural matters , OJ L 82, 
22.3.1997, p. 1 . 
64 Regulation (EU) No 1286/2013 of the European Parliament and of the Council of 11 December 2013  
establishing an action programme to improve the operation of taxation systems in the European Union 
for the period 2014 -2020 (Fiscalis 2020) and repealing Decision No 1482/2007/EC, OJ L 347, 
20.12.2013, p. 25.  
 
54 working visits , administrative cooperation and expert skills development could have been 
funded under either the Hercule or the Fiscalis programme s.  
Nevertheless, an in -depth analysis and comparison of the Hercule III and Fiscalis’ work 
programme s established that there was no overlap . The Hercule III programme did not 
fund activities primarily  focusing on tax fraud, tax evasion, and aggressive tax planning. 
On the contrary, it can be argue d that Hercule III was complementary to Fiscalis in that 
action to combat fraud using Hercule -funded equipment also contribute d to combating 
tax fraud and evasion.  
Desk research and interviews also found an area of potential overlap between the Hercul e 
III programme  and the Customs 2020 programme  (2014 -2020, repealed and replaced by 
the new Customs programme65). However, both programmes are to be considered 
complementary to each other and their output should not mean duplication of the efforts 
and financial support. The participating Commission departments are preparing  a future 
coordination to improve cooperation  across the departments  with a view to regularly 
review joint implementation issues, likely supported by an arrangement to avoid any 
potential double funding.  
Under Regulation 1294 /201366, the general objective of the Customs 2020 Programme  is 
to support the functioning and the modernisation of the customs union in order to  
strengthen the internal market . One of its specific objectives is to support customs 
authorities in protecting the financial and economic interests of the EU and of the 
Member States. In that sense, the joint actions pillar of Customs 2020 set up a specific 
grant for the customs eastern and south -eastern land border expert team (CELBET III67), 
which supported the cooperation and sharing of expertise of the partner country c ustoms 
experts, the coordination of data analysis and risk assessment efforts to increase the 
quality and efficiency of customs controls at the borders.  
The technical assistance pillar of the Hercule III programme  provides for the purchase 
and upgrading of tools to carry out inspections of containers, trucks, railway wagons and 
vehicles at the EU’s external borders and within the EU to detect smuggled and 
counterfeit goods.  
Therefore,  Hercule III provided support to applicants for grants from the CELBET 
customs authorities concerned to purchase equipment to combat smuggling or other 
criminal cross -border activities .  
                                                           
65 Regulation (EU) 2021/444 of the European Parliament and of the Council  establishing the Customs 
programme for cooperation in the field of customs and repealing Regulation (EU) No 1294/2013, OJ L 
87, 15.3.2021, p. 1.  
66 Regulation (EU) No 1294/2013 of the European Parliament and of the Council of 11 December 2013 
establishing an action programme for customs in the European Unio n for the period 2014 -2020 
(Customs 2020) and repealing Decision No 624/2007/EC , OJ L 347, 20.12.2013, p. 209 . 
67     https://www.celbet.eu  
 
55 As such , there was  complementarity between the two programmes reinforcing each 
other’s impact  in the eastern and south-eastern EU Member States having  access to both 
sources of funding .  
The Hercule III programme  funded the purchase of customs control equipment whereas 
the Customs programme  did not.  To avoid any potential future risk of overlap between 
the two programmes, Recital 17 of the Regulation establishing the EU anti-fraud 
programme (UAFP) clarifi es that such potential overlapping of funding  should be 
avoided.   
In addition, t he UAFP’s 2021 annual work programme clarifies that  the UAFP will 
support the acquisition of types of equipment that do not fall under the scope of the new 
instrument for financial support for customs control equipment, as part of the Integrated 
Border Management Fund68.  
Finally, as specified in the UAFP annual work programme, the Commission will look at 
the potential overlap while evaluating the coherence and added value of a proposal for the 
protection of the EU’s financial interests.  
Figure 28 – Case study example (Malta) – External coherence  
 
                                                           
68 Regulation (EU) 2021/1077 of the European Parliament and of the Council of 24 June 2021 
establishing, as part of th e Integrated Border Management Fund, the instrument for financial support 
for customs control equipment, OJ L 234, 2.7.2021, p. 1 –17. 
This project concerned  the procurement of a ‘Z Backscatter van’, which is 
deployed flexibly at several  ports in Malta. It is used to scan containers and 
cargo ships  as well as  vehicles that arrive with ferries in Malta. Awarded grant 
amount: EUR 864 284.06  
The authorities sought to create synergies  with the customs 2020 programme  in 
the form of a working visit of Belgian c ustoms to Malta , which resulted in  
knowledge and skill t ransfer  and was highly appreciated by the authorities  
involved . Interviewees highlighted that they benefitted from the customs 2020 
programme, as th e fund was used to finance the visit of two representatives of the 
Belgian customs authority to Malta. Durin g this visit, the Maltese customs gained 
valuable knowledge and skills on how to operat e the backscatter van, which 
proved to be crucial when the equipment was deployed . Belgian customs had 
already acquired a backscatter van  so they could share operational  skills and 
experience  in using  this exact equipment.  
The interviewees welcomed the scope to finance these initiative s across funding 
programmes.  
 
56 The objectives of the Hercule III and the Justice programme  are inherently 
complementary. Under Article 3 of Regulation 1382 /201369 establish ing the Justice 
programme , the  general objective of the programme  is to contribute to the further 
development of a European area of justice based on mutual recognition and mutual trust, 
in particular by promoting judicial cooperation in civil and criminal matters. Article 12 of 
Regulation 1382/2013 states  that the Commission must  ensure overall consistency, 
complementarity and s ynergies with the work of EU bodies, offices and agencies 
operating in areas covered by the objectives of the programme.  The Hercule III 
programme  has the objective to prevent and combat fraud, corruption and any other 
illegal activities affecting the EU’s  financial interests . The achievement of Hercule 
objectives strongly depends  on a fully functioning EU judicial system.  
Four  stakeholders interviewed mentioned that training for the judiciar y (prosecutors, 
judges and court staf f) could be implemented and financed under either p rogramme . To 
avoid such overlaps,  the target groups of both programme s should be better defined . The 
Hercule III programme  should (mainly) target public authorities and law enforcement 
agencies (inspection services, customs, police) and the Justice programme  should 
(mainly) target training for  public prosecutors , magistrates and court staff . In any event, it 
should be mentioned that the same costs  should not be double or multiple funded, but 
training, conference or study activities  can be implemented and funded by two or more 
(complem entary) programme s. The Pericles programme and the structural reform support 
programme finance similar activities to the Hercule III programme. More synergies 
between both programmes could be achieved on counterfeiting.  
Figure 2 9 - Main findings under coherence (internal and external coherence)  
 
                                                           
69 Regulation (EU)  2021/693 of the European Parliament and of the Council of 28  April 2021 
establishing the Justice program me and repealing Regulation (EU) No  1382/2013 , OJ L 354, 
28.12.2013, p. 73.  
Internal coherence  
The projects eligible for funding under Hercule III appear to be complementary with one 
another. The assessment did not identify any critical overlaps between the different activities, 
although a few survey respondents indicated that conferences, training, and legal studies, as 
activities, could  overlap to a certain degree. Based on desk research and interviews, it 
appears that participants did not actively seek synergies across the range of projects funded 
by this programme.  
External coherence  
There are strong complementarities between the Hercule III p rogramme and the AFIS 
platform. The programme is also highly complementary with the Fiscalis and the Customs 
2020 programmes. Lastly, the objectives of the Justice p rogramme are complementary to 
those of the Hercule programme . However, there is potential for overlap too as both  
programmes fund certain similar training activities.  
 
57 5.5. Added value  
3.1.16.  EU added value as identified through the external study  
The evaluation looked at e vidence of EU added value  at national level and the extent to 
which similar results could be achieved without EU action.  
Figure 30 – Case study example – EU added value  
 
Stakeholders consider that EU action taken under the programme  provided  significant 
added value, compared to what could have been achieved at national and regional level.   
The evaluation of the Hercule II programme and the mid -term evaluation of Hercule III 
confirmed that the programme  did indeed provid e added value. This evaluation support s 
the same finding. The majority (70/99) of respondents to the applicants’ survey disagreed 
that the same results could have been achieved at national or regional level. In particular, 
the programme  was seen to provide two main aspects  of additional value . 
Firstly,  it acted as a key driver and enabler for stakeholders to counter and reduce 
the risks of fraud harming the EU’s financial interests.   
Across each of the stakeholder consultation activities, many stakeholders (particularly 
Member State authorities) mentioned the role the programme  had in providing the means 
to tackle the key areas of fraud in their countries. This was particularly the case for 
technical assistance where beneficiaries noted that it is often not feasible to make large 
investments in different types of technologies or  equipment due to limits in the national 
budget  available to them .  
Interviewees  from central and eastern European countries mainly cited a lack of available 
budget/ability for Member States to finance new equipment . This was also the case in the 
applicant s’ survey where a greater number of respondents who answered that the same 
results could not have been  achieved at national level were authorities in countries 
such as Poland, Bulgaria , Latvia, and also Italy .  
The grants funded by the programme  therefore made the prospects of such investments 
more probable, and in some cases, aided Member State authorities in making a case to 
Case study example – Latvia  
This case study included an analysis of two technical assistance projects for two 
separate Latvian national authorities involving the strengthening of the technical 
capacity  of investigative departments and capacity building for forensic 
examination . Both projects outlined the clear added value of EU action  under t he 
programme . This was primarily due to  the lack of available national funds, hence 
the Programme acted as a strong enabler for both departments concerned  to 
provide high quality information to their respective law enforcement agencies and, 
by extension, help reduc e the levels of fraud in Latvia .  
 
58 their ministries to make the investments. This increased probability was also linked in 
some of the interviews to the speed at which  the programme  can provide support, 
compared to national level funding opportunities.  
Several beneficiaries , as well as unsuccessful applicants , noted the additional 
cred ibility  and reliability  generated  by being associated with the programme . In 
particular, being connected to the programme , and by default to activities carried out with 
OLAF, added increased legitimacy to the work  carried out at national level.  
Secondly,  beneficiaries viewed the programme  as a facilitator for EU -level cooperation 
between Member States, specifically by funding training, conferences , databases 
and tools.  
More specifically, the main additional value found in terms of training (i.e. training 
activities, conferences and funded databases and tools) was the programme ’s ability to 
enable EU -level groups and events to be created and to function . In particular, anti -
fraud training and conferences were found to provide signifi cant value in bringing 
countries together that may not have worked together previously.  
For each of the three  annual calls (for projects on technical assistance , legal t raining  and 
training and conferences ) under the Hercule annual work programmes , the applications 
received are assessed by an evaluation committee on the basis of four criteria (eligibility, 
exclusion, selection and award) and ranked with a score and award criteria. The  latter 
include  (ex ante identifiable) added value  of the application in protectin g the EU’s  
financial interests;  conformity with the operational objectives of the programme ; quality 
of the project; and  value for money.  
Evidence from the 2020 Hercule III a nnual work programme  found that for technical 
assistance , the Commission encouraged projects  that are carried out jointly by the 
programme 's beneficiaries in multiple Member States in order to strengthen cross -border 
cooperation to combat activities that are detrimental to the EU's financial interests, such 
as smuggling tobacco, cigarettes, counterfeit goods or VAT -carousels.  
While the evaluation  found evidence that these joint operations took place, it is unclear 
whether there has been an increase since 2016. The EU’s new anti-fraud programme  
puts greater emphasis  on joint action between Member States  for technical assistance 
projects . Its 2021 annual work programme  reflects th at. 
3.1.18.   The programme’s contribution to the Commission’s priorities  
This evaluation also looked into the programme’s contribution to the Commission ’s 
overarching priorities, in particular to its ‘Europe 2020’ strategy. In March 2010, the 
European Commission adopted the  Europe 2020 strategy for smart, sustainable and 
 
59 inclusive growth70. Its objective was to enhance competitiveness  within the EU between 
businesses and to protect their competitiveness from external unlawful competition.  
Figure 31 – The Hercule III programme’s contribution to the Commission’s 
strategies  
 
Though  the Hercule III programme d id not make a direct contribution  to this strategy , it 
can be seen to  have  indirectly contribute d. For example, following the logic that 
preventi ng and combat ing fraud, corruption and other illegal activities against EU 
financial interests helps secure EU resources that can be invested into other EU initiatives 
to promote  smart, sustainable and inclusive growth, the programme can be seen as a 
crucial gatekeeper fo r action under the Europe 2020 strategy.  
Figure 3 2 - Summary of key findings in terms of EU added value  
 
 
                                                           
70 Communication from the Commission, EUROPE 2020 - A strategy for smart, sustainable and inclusive 
growth, COM(2010) 2020 . 
The overall view across consulted stakeholders is that the programme provides 
clear EU added value . Specifically, it acts as an enabler and driver for Member 
States to use a higher standard of equipment  to detect and reduce the risks of 
fraud than would have been possible without the programme.  
The programme was also seen to act as a facilitator for EU level cooperation 
between Member States , specif ically by funding training , conferences , databases 
and tools.  
 
60 6. CONCLUSIONS  AND RECOMMENDATIONS  
The following section provides a summary of the conclusions with a breakdown by 
evaluation criterion (relevance, effectiveness (including sustainability), efficiency, 
coherence and EU added value ). It also makes certain recommendations . 
This section f ocuses only on the Hercule III programme,  as it was set up for the previous 
multiannual budget period . It does not take into account further developments in EU 
policy, notably with the proposal and subsequent adoption in  2021 of the EU anti-fraud 
programme. Indeed, many of the conclusions and recommendations presented in this 
section  and similarly in the con sultant’s report are to a good extent already reflected in 
the UAFP. In that sense, this evaluation lends good support to the Commission’s current 
practice. That , however , is outside the scope of this technical evaluation of a past 
programme. It is to be d eveloped further in the Commission’s Report to the European 
Parliament and the Council, which the present evaluation is accompanying . 
Conclusion 1 – The programme is considered highly relevant, and must be 
continually adjusted to new developments in the fraud landscape, in anti -fraud tools 
and in the regulatory framework  
The programme remains highly relevant in meeting the needs of stakeholders working on 
the front line to protect  the EU’s financial interests. Evidence collected  by the contractor 
through consultations with stakeholders showed that their needs are highly aligned with 
the objectives of the programme. This is particularly the case for operational objective 3 
on strengthening the fight against fraud by providing technical and operational suppo rt to 
national authorities.  
However, new, more recent developments  in the field of expenditure fraud and 
cybercrime  affect the continued relevance of the programme, drafted in 2011. This 
applies in particular to new developments in expenditure fraud, cyber crime, and the need 
for the programme itself to be(come) more reactive to emerging threats.  
Stakeholders also highlighted the continuous need for greater awareness and publicity  
of EU funding opportunities under this and similar programmes.  
- Recommendation 1.1: To maintain the programme’s relevance, the Commission 
should regularly review and adjust the focus of the programme  where needed . 
 
For an anti -fraud programme to remain relevant, it must continuously adapt to a fast -
changing anti -fraud landscape. New trends in criminal activity arise, and fraudsters will 
always invent new techniques  and use the opportunities of operating seamlessly across 
border s, and in cyberspace.  
In seeking to address this ever -changing panorama, the Commission has drawn on 
multiple sources to develop an anti -fraud programme. Two  main  sources stand out: on the 
one hand , continuous dialogue with the stakeholders, notably those on the frontline of 
protecting the EU’s financial interests at European a nd national level. Several  of these 
 
61 groups are already consulted during the preparatory phase to draw up each new work 
programme.  
On the other hand, several Commission action plans ( in areas such as customs71, work to 
combat  tobacco smuggling72, or the Comm ission ’s anti-fraud strategy73 or the priorities 
agreed with the Member States in the framework of the European multidisc iplinary 
platform against criminal threats (EMPACT) and similar policy documents ), provide 
authoritative guidance on the evolving priorities of EU law enforcement. A continuous 
close alignment with these guidance documents will also increase the coherence of the 
anti-fraud programme with the EU’s wider action on the expenditure, revenue , home and 
justice domains.  
- Recommendation 1.2: the Commission should continuously strive to promote to 
stakeholder groups  the opportunities available under the programme, including 
its evolving focus.  
 
The Commission (OLAF), implementing the programme, has already made  good use of 
several channels to publicise opportunities for funding under the Hercule III programme. 
These range from the OLAF website via the AFCOS network to the Council and expert 
groups where all Member States are represented. In addit ion, all relevant information is 
always published on the Commission (OLAF) website and on the  web portal  that collects 
all Commission funding and tender opportunities.  
Conclusion 2 – stakeholders  perceive the programme’s effectiveness as very high , 
both in terms of technical assistance and training , though actual effectiveness  has 
proved difficult to assess.  
The stakeholders perceive d the programme as highly effective  across all three  sectors of 
action. The programme was influential in supporting national authorities in 
investigations, creating national and international networks and working towards a 
strengthened EU level approach to combating fraud.  
Technical assistance generated more direct impacts than training activities. This was 
particularly the case for the provision of technical and advanced equipment used by 
national authorities in the prevention and investigation of fraud or other illegal activities. 
Most notably,  technical assistance  grants generat ed specific knowledge facilitating 
transnational cooperation and cooperation with the Commission, as well as increasing 
both the operational and analytical capacity of law enforcement agencies across the EU.  
                                                           
71 Commission Communication Action Plan Taking the Customs  Union to the Next Level , COM (2020) 
581 final, 28.9.2020.  
72 Commission Communication Second Action Plan to fight the illicit tobacco trade 2018 -2022 , COM 
(2018) 846 final, 7.12.2018.  
73 Commission anti -fraud strategy: enhanced action to protect the EU budg et (SWD(2019) 170 final - 
SWD(2019) 171 final  - COM(2019) 196 final, 29.4.2019).  
 
62 Training activities were also perceived to be ef fective , but their effects were more 
indirect. The indirect effects were principally created through the development of 
networks facilitated through participation in training events and conferences.  
Member States made comparatively little use of the scope for staff exchanges. Any 
administrative bottlenecks in this area would warrant analys is in more detail. A low level 
of take -up of such initiatives may also be indicative of low demand for such initiatives. It 
is possible that such initiative s, as welcome as they are in principle, in practice have a 
suboptimal cost -benefit ratio for participating administrations.  
Notwithstanding these broadly positive finding s, assessing the programme’s effectiveness 
through other (documentary) sources of evidence proved to be challenging . In particular, 
data collection via final technical and implementation reports, especially for technical 
assistance , was found to produce disparate types of data that could not be analysed 
easily . This was underlined in the economic analysis carried out as part of the 16 case 
studies , where it was not possible to fully determine  the extent to which the programme 
had a measurable effect on reducing illicit trade and fraudulent activities. However , it is 
necessary to give a  caveat , which is , that assessing the impact on illicit trade through any 
EU initiative is fraught with challenges and complexities  due to the dynamic and 
unknown aspects  of illicit activities that operate across the EU.  
Conclusion 3 - the programme produces several positive external side effects.  
The programme generated  a number of positive external side  effects , which further 
enhanced its effectiveness in protecting the EU’s financial interests. First and foremost , 
the acquisition of modern equipment generated a number of positive effects including the 
detection of additional illegal activities that were not originally covered  under the 
programme. This included the detection of illegal drugs, weapons and artefacts . The 
detection of these substances or objects provides increased security to Member States and 
the EU, and has an impact that goes beyond the protection of financial interests (i.e. 
increased  public  safety, increased safety for users of the equipment and further hindering 
organised crime groups ).  
Conclusion 4 - the programme’s  benefits outweigh the costs incurred, but more 
guidance and simplified processes could improve  efficiency in the future, and help 
address challenges in terms of uneven administrative capacity in the Member States.  
The stakeholders found the programme’s  benefits  outweigh the costs  incurred. Though 
only indicative, the time taken to prepare applications was found to have decreased 
compared to the results of the 2018 mid -term evaluation, but the time taken to  fulfil the 
reporting requirements increased slightly. Despite these conclusions, stakeholders 
confirmed that they were not deterred from applying  to the programme, and did not 
face any significant administrative costs o r red tape  due to the reporting requirements. 
Thus, despite any costs incurred through the programme, the burden was largely found 
to be appropriate given the benefits  it generated .  
 
63 Overall, the main direct costs during  both the application and implementa tion phases are 
staffing  costs . On average, a pplicants to the programme spent 15.3 full -time person days 
preparing and applying, compared to an average of 14.4 full -time person days fulfilling 
the reporting requirements.  
The programme was found to generate both direct and indirect  benefits . Direct benefits 
included the possibility to acquire technical assistance equipment where Member States 
do not have available funding to invest in technologically advanced and expensive 
equip ment. It therefore  acts as an enabler for Member State authorities .  
By contrast, t raining projects  were found to generate more indirect benefits  for 
stakeholders. These benefits can be seen to contribute to an EU level network of 
stakeholders, collectivel y working together to combat fraud, though measuring the impact  
of these network effects is challenging.  
However, there are also indications that different levels of administrative capacit y in 
some entities at national or regional level in the Member States may hamper the 
programme’s ability to deliver results and achieve its objectives. As a result, the 
argument was made by the consultant in the study that not all Member States were able 
to benefit equally  from the programme due to national organisational circumstances . 
- Recommendation 4 : the a pplication and reporting procedures in the programme 
should take into account the administrative capacity of Member States, and to 
this effect,  the Commission should issue suitable guidance material.   
The Commission (OLAF) already makes available a number of documents to guide 
potential applicants on what is expected from them. This includes the annual work plan 
and the special calls for proposal s. In addition , OLAF conducts a wide range of 
awareness raising initiatives by presenting the funding opportunities to networks , 
stakeholder groups and forums such as the GAF74 meetings with the Council, the 
COCOLAF committee meetings, meetings among the AFCOS members, Customs 2020 
expert teams , and reaching out to  networks of lawyers and PIF  organisations. All relevant 
information is always published on the Commission websites and on the electronic portal 
that collects all Commission funding and tender opportunities, so that it also reach es 
NGOs. The call notices are published in all EU languages in the EU Official Journal .  
Lastly, and importantly , the Commission operates a dedicated email address (functional 
mailbox) at OLAF for questions or observations on the Hercule III programme, 24/7 
accessible. Applicants can also contact OLAF via its website.  
                                                           
74   Groupe Anti -Fraude: The W orking Party on Combating Fraud of the Council of the European Union 
deals with questions related to the protection of the financial interests of  the EU and the fight against 
fraud and other illegal activities affecting those interests. It also works on issues concerning the 
European Anti -Fraud Office (OLAF) and its supervisory committee.  
 
64 It appears  feasible to go a step further in maki ng more detailed guidance material 
available to all potential applicants. Making such information available upfront and to all 
potential applicants also level s the playing field to those who decide to apply.  
The Commission could issue th is guidance in various formats, including in the form of 
hypothetical question s and answer s (Q&A ). Another option would be to include several 
guidance questions directly in the corresponding  fields of the application. The questions 
could help applicants under stand the  type of information requested , thus simpl ifying the 
drafting process for applicants and increas ing the quality of the applications. The 
contractor provided suggestions for questions that could be included in the application for 
technical assistan ce. 
At the same time, any further initiative to disseminat e information about the programme 
and provide  guidance to applica nts should be proportionate to  the Commission’s 
available resources. The Hercule III programme , like its successor, the UAFP, are among 
the smallest programmes managed by the Commission, and thus do not offer an economy 
of scale comparable to other programmes.  
Conclusion 5 - the programme is both internally and externally coherent.  
The analysis of the programme’s  internal coherence  did not uncover any major overlaps  
between the different activities identified.  
With regard  to external coherence , the analysis of the programme against  other relevant 
EU policies and pieces of legislatio n (i.e. the PIF Directive, the EPPO Regulation, the 
Fiscalis and the Customs 2020 programme s, the AFIS  platform  and the Justice 
programme) uncovered no major overlaps or inconsistencies . 
- Recommendation 5: the programme should maintain alignment and coherence 
with other relevant pieces of legislation.   
The Commission already systematically runs a series of consultation s to ensure full 
alignment and coherence between the Hercule III programme (and likewise the EU’s new 
anti-fraud programme) and other EU instruments. This applies notably to links with other 
programmes in the customs or justice policy areas . These consultations should continue 
unabated, particularly since new programmes are currently being implemented at the 
beginning of a new financing p eriod.  
Conclusion 6 - the programme  was found to have strong short to medium -term 
effects; evidence of long -term impacts was less tangible.  
The sustainability of the programme’s effect  was mainly achieved through the short to 
medium -term impacts  generated by beneficiaries running projects or events funded by 
the programme. For technical assistance , whether the project produces long -term impacts  
is highly dependent on the nature and additional costs  linked to the equipment or tools  
purchased . Thus, as long a s the equipment is in use, the impact extends beyond the 
project lifetime . However, the potential costs of software updates and general 
 
65 maintenance were raised as factors  that could  hinder  the sustainability /durability  of the 
programme’s effects, as in most cases these costs are not covered by the project funding.  
Training , however,  provided greater indications of the programme achieving a long-term 
impact . Participants active ly sharing the competences and knowledge gained duri ng 
(training and other) events with their peers and colleagues in other Member States 
seemed to produce more long -term effects. However, measuring the exact extent of these 
effects over the longer term is difficult.  
- Recommendation 6: for technical assista nce, the programme could include 
specific costs under future calls for proposals for technical upgrades or software 
updates to secure the long -term impact of the investment .  
 
The Hercule III Regulation had no specific  provision to fund  equipment maintenance or 
updates of software, although in certain projects, the cost of maintenance in technical 
assistance  was accepted for the duration of the grant agreement, as included in the 
applicant’s bid for funding .  
Conclusion 7 – there is clear added  value in taking EU action under the programme.  
The programme is widely seen as providing EU added  value . It does so by acting as an 
enabler and a driver  for Member States to use a higher standard of equipment to detect 
and reduce the risk of fraud. It also acts as a facilitator for EU -level cooperation  
between Member States, specifically by funding training, conferences , databases and 
tools. The programme  was also seen to provide greater  legitimacy to the work carried 
out at national level through the additional credence  by being associated with the 
programme and by default, with OLAF.  
There is also a widespread belief that withdrawing the programme would  have a negative 
impact on the fight against fraud at EU level,  as it is likely to increase fragmentation in 
the action taken across the Member States.  
Conclusion 8 – It was challenging to fully assess  the true impact of the programme  
under t he current monitoring and evaluation  framework applicable to Hercule III . 
One of the main difficulties in evaluating the programme is accurately assessing the 
direct impacts (i.e. the magnitude of impacts on supressing illicit and fraudulent 
activities). It remains crucial to improve the current monitoring and evaluation 
framework for future evaluations of the programme. This was emphasised not only in this 
study but also in the mid -term evaluation , which highlighted that the outcomes of 
technical assistan ce projects  were limited and it was not possible to  measure the key 
performance indicators listed in Article 4(a) -(c) of the Hercule III Regulation.  
In the study, t he contractor found that there is scope for the programme to develop and 
implement other indicators that could monitor the programme more closely. As the 
current performance framework provides top -level indicators, it would benefit from 
having indicators and judgement criteria set at the level of eligible actions . This is 
particularly important given the subtle variations found in the performance of the 
 
66 programme between different eligible actions (i.e. the direct and indirect  effect 
differences between technical assistance and training) as part of this evaluation.  
It is important to outline , however , that even with better data collection and monitoring, it 
would still be a challenge to gauge  the true impact of the programme. Differences 
between national contexts and levels of illicit activity have a direct impact on the type of 
data that bene ficiaries can provide. In addition , variations in the type of projects  funded 
under the programme can create challenges in assessing the programme’s overall direct 
impact.  
- Recommendation 8: the programme should try to improve the current 
monitoring and evaluation  framework by developing more specific indicators 
set at the level of eligible actions.  
 
It should be noted that for the EU’s new anti-fraud programme , like for all EU 
programmes, the Commission is fine -tuning an enhanced monitoring and evaluation 
framework developed for programmes run under the multiannual budget . Similarly, 
Article 12(4) of the  UAFP Regulation (EU) 2021/785 provides a  performance reporting 
system to ensure that data for monitoring implementation and evalu ating the results of the 
programme are collected efficiently, effectively, and in a timely manner.  
Conclusion 9 – creating  a centralised database of projects implemented under the 
programme would provide a readily accessible evidence base for future evaluations . 
The analysis of qualitative and quantitative data enabl ed this evaluation study to assess 
(in part) the effectiveness of the programme both at the level of individual projects  and 
for the programme as a whole. The contractor did so by creating  their own Excel database 
of a sample of projects  and compiling data available in the consulted final technical, 
financial and implementation reports , as well as event feedback surveys and post -event 
surveys for training submitted by beneficiaries. The con sultant’s database contained 
information on both training and technical assistance projects  and actions . It enabled the 
contractor to formulat e statements on key indicators of the effectiveness of the different 
actions and to uncover trends and changes to the achievements of funded projects .  
However, given the scope of this study, only the data on a sample of 98 analysed  projects  
were included in the ir database. It would aid f uture monitoring and evaluation work to 
have readily accessib le key indicators on  implemented projects , and uniform data formats 
that enable users to compar e different projects .  
- Recommendation 9: OLAF should centralise  data  collection and storage on 
implemented projects in a single  database to facilitate access to project 
documents and overviews of results.  
 
The Commission will look at  appropriate and efficient ways to implement these 
recommendations.  
 
------  
 
67 ANNEX 1 - PROCEDURAL INFORMATIO N 
1. LEAD DG,  DECIDE PLANNING REFERENCE  
 Lead DG: OLAF, which has managed and implemented the Hercule III 
programme  
 DeCIDE Planning reference: PLAN/2020/8105  
2. ORGANISATION AND TIMI NG 
In line with Article 13(2) of Regulation (EU) No 250/2014, which mandates an 
independent final evaluation, the Euro pean Commission (OLAF) used a DG TAXUD 
framework contract to take out a specific contract75 with an external contractor to conduct  
a study to underpin this Commission evaluation. The external study was carried  out by 
the Belgian subsidiary RAMBOLL Management S.A./N.V.76 of the Danish mother 
company RAMBOLL Management Consulting A/S77, in a consortium with London 
Economics (UK) and Università Cattolica (IT)78. The study ran between October 2020 
and October 2021.  
 An inter -service steering group (ISG) of Commission departments79 was set up to 
steer  this evaluation process. The ISG reviewed the roadmap80, the terms of 
reference for the external contract, the inception phase of the study and the end -
of-fieldwork report (quality assessment ). 
 ISG m eetings were held  with the contractor Ramboll:  
- on the inception report  – 7 December  2020  
- on the interim evaluation report  – 18 June 2021  
- on the quality assessment of the draft final report  – 13 September  2021 . 
3. EXCEPTIONS TO THE BETTER REGULATION GU IDELINES  
The Commission ( OLAF ) obtained an exception that it did not have to run an open public 
consultation on the evaluation. Instead, it ran a n open public consultation on the roadmap 
in June 2020 and targeted consultations of stakeh olders in 2021 . 
4. CONSULTATION OF THE RSB  
Not applicable.  
                                                           
75 Specific contract of 21.10.2020, No SI2.835825 (reopening competition under Framework Contract 
reference TAXUD/2020/AO -20/OLAF), implementing framework contract  No TAXUD/2019/CC/148, 
the latter signed on 6 May 2019.  
76 Belgian registration number: 867596506; 35 Square de Meeûs, 1000 Brussels, +32 2 737 96 80 , 
https://ramboll.com ; https://ramboll.com  
77 Danish registration number: 60997918; Hannemans Allé 53, 2300 Copenhagen, PIC 932241102.  
78 An Italian private research university; Largo Agostino Gemelli, 1, 20123 Milano, Italy.  
79 With officials from OLAF, the Commission’s Secretariat -General, DG TAXUD, DG JUST, DG 
BUDG and the Commission’s Legal Service . 
80 The evaluation roadmap was publicly accessible for comments between 15 June 2020 and 13 July 
2020: no feedback was received fro m the public.  
 
68 5. EVIDENCE , SOURCES AND QUALITY  
The Commission (OLAF) made the following analysis of the assessment carried out by 
the contractor of the quality of the 49 sources of evidence consulted, for each evaluation 
(sub)questions to be answered per evaluation criterion:  
Table 1 – Overview of the number of sources consulted and their quality assessment  
Evaluation  
criterion  
(No of sources 
consulted)  Strong 
quality  More than 
satisfactory  Indicative 
but not 
conclusive 
evidence  Weak 
evidence  Null Related 
evaluation 
(sub) question 
(when only 1 
or 2 
indicative 
sources)  
RELEVANCE (8)  6 
sources  2 sources*     * R elevance 
of operational 
obj. 2 and 4  
INTERNAL 
COHERENCE (2)    2 sources *   * HIII mid -
term 
evaluation  
EXTERNAL 
COHERENCE (6)   4 source s 2 sources*    * Coherence 
with EU 
legislation  
EFFECTIVENESS 
(16)  5 sources  10 sources  1 source*   * Negat ive 
external 
factors  
EFFICIENCY (10)   4 sources  5 sources  1 source* 
(mid -term 
evaluation ) 0 
sources**  * Regulatory 
costs  
** 
Enforcement 
costs  
EU ADDED 
VALUE (5)   3 sources  2 source s*   * Results 
achieved at 
national level 
without the 
programme  
SUSTAINABILITY 
(2)   2 source s 
(Long -
term 
effects)   0 
sources*  * National 
level 
initiatives  
Total sources (49)  6 18 23 2 -  
 
Just under half of the sources consulted were noted as indicative  but not conclusive 
evidence  (23/49), followed by the more than satisfactory  evidence (18/49). The 
effectiveness of the programme was substantiated  by most sources (16). The consulted 
sources are previous evaluations and studies, key policy documents, legislative 
documents, annual reporting , academic literature  and (other) studies.  
However, both the  criteria on  internal coherence and sustainability (long -term effects of 
the programme) had only two source s of reference, presenting indicative but not 
conclusive evidence ( the 2018 Hercule III mid -term evaluation and the 2014 PIF  report 
for internal coherence; the Hercule II final evaluation and the Hercule III mid -term 
evaluation for the s ustainability criterion).   
 
69 The contractor RAMBOLL  carried out a detailed and systematic review of Hercule III 
legal texts and policy documents to screen for any potential  inconsistencies, overlaps, 
contradictions, or duplications across the programme’s action areas.  
The f indings on internal coherence were based  on three sources : desk research, 
feedback received during interviews and responses to the applicants’ survey.  
 
70 ANNEX 2 - STAKEHOLDER CONSULTAT ION – SYNOPSIS REPORT  
This synopsis report on consultations is structured as follows:  
1. Introduction (and exemption to the scope)  
2. Stakeholder consultation activities – methodology and limitations  
a. interviews  - exploratory and in-depth interviews  
b. case study interviews  
c. targeted online surveys  
3. Comparison of results from di fferent consultation activities  
4. Integration of consultation results in the answers to the evaluation questions  
 
1. Introduction (and exemption to the scope)  
This synopsis report presents the stakeholder co nsultation activities carried out as part of the 
final evaluation of the Hercule III programme. The purpose is to explain the stakeholder 
groups consulted as part of the study and the consultation methods, timings, questions asked, 
and the limitations  faced in the process .  
The aim of the  report i s to compare and contrast the results of the different consultation 
activities, including interdependencies, synergies and/or contradictions. This includes 
explaining how far the results were taken into consideration in the assessment of the 
evaluation questions provided in the final report.  
OLAF requested a n exemption to not conduct  an open public consultation  as part of this 
evaluat ion process , which was granted by the Commission’s Secretariat -General. Instead , it 
ran a  consultation on the roadmap in June 2020 and targeted consultations of stakeholders in 
2021 by the external contra ctor RAMBOLL in the course of the study. The motivation for that 
approach is that the p rimary beneficiaries of the Hercule III programme are national 
administrations and public servants. The programme’s main goal is to facilitate and enhance 
cooperation in  tackling financial irregularities, fraud, corruption or other offences detrimental 
to the EU budget between national authorities within the European Union and with 
participating countries. What defines this enhanced cooperation are aspects such as financi al 
support to facilitate and secure the exchange of information, training, exchange of staff, 
cooperation in the field, purchase of dedicated material and tools, availability of information, 
working visits, exchange of good practices, networking and many m ore. All of these affect 
almost exclusively the national administrations of the Member States. Consulting the national 
administrations and beneficiaries (participants to – training and other  – events) on a variety of 
issues through targeted consultations i s therefore the most important feature of the 
methodology of the current final evaluation.  
Through the external contractor, performing an in -depth final evaluation of Hercule III, OLAF 
is seeking targeted feedback from three  groups of stakeholders through dedicated online 
surveys to request and assess their opinion on the impact of the programme between 2014 and 
 
71 today (beneficiaries of grants, unsuccessful applicants, participants to procured events, users 
of procured service s and databases financed by the programme) . 
2. Stakeholder consultation activities – methodology and approach  
The stakeholder consultation process  for this study included  the following activities : 
- interviews  
o exploratory interviews and in -depth (semi -structured) interviews  
o case study interviews  
- three targeted online surveys . 
The following section summarises the approach taken at each stage  of the stakeholder 
consultation.  
a) Interviews - exploratory  interviews and in-depth interviews  
At the design phase of the study, four exploratory interviews with six stakeholders in OLAF 
were carried out , as displayed in Table 1. The aim of the exploratory interviews was to gather 
insights into the functioning of the Hercule III programme and gain a better understanding of 
the funded projects . The findings from these exploratory interviews fed directly into the 
revis ed evaluation questions matrix, the refine d intervention logic and into the development of 
the method for the remaini ng stages of the project.  
 
Table 1 - Stakeholders consulted in exploratory interviews  
Stakeholders  Subject  Number of interviews  
OLAF, Unit C3  Forensic training  1 
OLAF, unit B1  Databases  1 
OLAF, unit D1  Conferences  2 
Grants, JRC  
Total  4 
 
During  the evidence collection phase, targeted semi -structured interviews were conducted to 
collect more details on why stakeholders hold certain opinions, and to collect additional 
evidence on evaluation questions for which qualitative data were judged to be an  important 
source.  
 
Overall, 25 semi -structured interviews were conducted with stakeholders in EU institutions 
and bodies, with partner organisations and with the AFCOS in the Member State  authorities . 
Table 2  gives  a full overview of the stakeholders interviewed as part of this study.  
 
72  
Table 2 - Stakeholders consulted as part of the in -depth semi -structured interviews  
Stakeholder group  Stakeholder type  Number of conducted 
interviews  
EU institutions and bodies  OLAF  5 
DG TAXUD  1 
DG JUST  2 
DG BUDG  1 
JRC 2 
Subtotal EU institutions and bodies   11 
Partners  Member State AFCOS  4 (ES, HR, DK, AT)  
COCOLAF  2 (ES, EE)  
PIF associations  3 (DE, IT, NL)  
Subtotal partners   9 
Unsuccessful applicants   3 
Applicants that submitted both 
successful and unsuccessful 
applications   2 
Total   25 
The data collected  through the interviews were summarised in individual interview reports 
after each interview. These were clearly labelled, and their structure was based on a template 
following the same format. The data collected was then coded and analysed using the QDA 
software NVivo®. This meant t hat each response from  interviewees was assigned to the 
evaluation sub -questions and categorised by topic, provid ing insights into the questions.  
This enabled the study team to give detailed answers to each evaluation sub -question for 
which the interviews  provided evidence and report the results per stakeholder group. The 
following analysis provides answers to each evaluation sub -question. Where possible and 
relevant , the results are broken down  by stakeholder group. Throughout the course of the 
interviews , several challenges were encountered, as listed  in Table 3 overleaf . 
Table 3 - Problems and solutions for the interviews  
Problem/limitation  Solution/mitigation  
The duration  of the interview guides made it 
difficult (especially for national  authorities), 
to cover all relevant questions in the allotted 
time.   At the scheduling stage, interviewees were given an 
indication of the time needed for the interview.  
Where there was not enough time, the study team 
focused on a number of set key questions. These 
were adapted based on any gaps in evidence 
identified and the knowledge of the interviewee.  
Overall knowledge and awareness of the 
programm e and its specific actions was not 
widely known across each of the 
stakeholder groups.  As the level of knowledge and experience with the 
Hercule III programme was different for the 
interview respondents, not all interviewees were 
able to answer questions relating to all evaluation 
criteria. The flexible approach to the design of the 
interview guides enabled the contractor to collect 
 
73 information , taking into account the experience of 
the interviewee with the programme. For instance, 
unsuccessful applicants were not asked to give 
their opinion on the effectiveness of their projects. 
Where limited evidence was collected on specific 
funded actions and areas of Hercule III, the other 
stakeholder consultation activities, as well as desk 
research helped to fill an y gaps.  
b) Case study interviews  
Each case study included the collection of documentary evidence and interviews with 
stakeholder s involved in operating the purchased equipment.  
The case  study interviews were targeted at the staff of the organisation that received Hercule 
III funding for projects. The study team intended to conduct two to three  interviews per 
project in the organisations concerned. The study team was able in all cases to interview the 
project coordinator as the person in charge of managing the Hercule III -funded project, and 
they also conducted  interviews with staff responsible for managing and operating the 
equipment purchased and trained on using  it. Table 4 gives t he exact number of interviews 
conducted per case study.  
Table 4 - Stakeholders interviewed as part of the case studies  
Case 
Study 
No. Country  Title of technical assistance action selected  Number of 
persons 
interviewed  
1 Bulgaria  X-ray scanners  2 
Enhancing technical capacity  
2  
2 Hungary  Monitoring equipment, hardware  and software for the 
collection and analysis of different types of data.  3 
Technical capacity development  5 
3 Latvia  Strengthening the technical capacity of investigative 
departments of the State Revenue Service of the 
Republic of Latvia  3 
Operational capacity building of the forensic 
document examination  2 
4 Lithuania  Strengthening of operational and technical capacities 
of Lithuanian customs to detect smuggled goods in 
particular cigarettes  1 
Development of criminal intelligence technical tools 1 
5 Malta  Backscatter scanner  3 
 Enhancing technical capacity  3 
 
74 6 Poland  Backscatter scanner  2 
Fixed scanner  1 
7 Romania  Improved special investigation methods in tackling 
high-profile organised crime groups  smuggling at the 
EU’s eastern border (EASTEROS)  2 
Fraud investigation in Brasov County with digital 
forensic hardware  and software  3 
8 Spain  Sniffer dogs  2 
Sunrise Hawk (IM SI catcher81) 4 
Total  8 Member States  16 projects  38 interviews  
c) Online surveys  
The evidence collection phase included sending three targeted survey questionnaires to three 
core stakeholder groups:  
- applicants’ survey – to complement the assessment of the programme by gathering the 
views of representatives of authorities or department s who have applied to calls for 
proposals for technical assistance or training activities under the programme over the 
period 2014 -2020 and whose applications were either successful or unsuccessful. OLAF 
provided contact details of applicants , in compliance with GDPR requirements .   
- participants’ survey – to target beneficiaries/people who attended events funded by the 
Hercule III programme over the period 2014 -2020. This was used primarily to gather 
further insights on the programme, specifica lly on the training side; 
- users’ survey – to target users of services procured by the programme (i.e. databases, 
statistics and IT tools and services to carry out chemical analysis of samples from tobacco 
and/or cigarette seizures) during the same period.  
Both the applicants and the participants surveys were launched on 26  February  2021 and 
remained opened until 26  March  2021 . The user survey was also launched on 26  February  but 
remained open until 6  April  2021 . 
Table  5 provides an overview of the responses per survey type, as well as the number of 
respondents the different surveys aimed to reach.  
Table 5 - Overview of the status of responses per survey type  
                                                           
81 An international mobile subscriber identity -catcher, or IMSI -catcher, is a telephone eavesdropping device 
used to intercept mobile phone traffic and tracking location data of mobile phone users.  
 
75 Survey  
Initial no. of contacts  
Emails returned  
(Base) Population  
Completed  
Partially completed  Total 
(Completed+ 
Partially 
completed)  Response 
Rate  
Applicants ’ 
survey  512 52 460 129 15 144 31% 
Participants 
of events  
survey  432 82 350 74 34 108 Unknown82 
Users of 
services  
survey  2474  147 2327  143 42 185 Unknown  
Total  3418  281 3137  346 91 432  
The table below provides an overview of the number of responses per stakeholder type. It is 
important to note that the number of respondents is higher than that displayed in Table  5 as 
the design of the survey allowed respondents to select more than one option when ch oosing 
their organi sation  type.  
Table 6 - Online survey respondents  – Type of stakeholder  
Survey  Type of stakeholder  Number of 
respondents  
Applicants’ 
survey  National law enforcement authorities (NLEAs)  58 
Research institutes/ academia  33 
National tax administration  23 
Other83 13 
Non-profit organi sations  13 
Local/regional customs authority  10 
Local/regional law enforcement authority  9 
National ministry acting in the area of fight against fraud  7 
Local/ regional tax administration  5 
Participants 
of events 
survey  National law enforcement authorities (NLEAs)  36 
Local/regional customs authority  16 
Other  10 
National tax administration  7 
National ministry acting in the area of fight against fraud  5 
                                                           
82 As the surveys were sent using a snowballin g technique by asking contact points to distribute the surveys to 
their users/participants, an accurate response rate cannot be generated.  
83 Respondents report ing that they belong to the category ‘other ’ (13) included  are representatives from 
lawyers’ ass ociations, paying agencies and different departments within national public administrations.  
 
76 Local/regional law enforcement authority  3 
Legal practitioners: lawyers, solicitors, barristers  2 
Local/regional tax administration  1 
Users of 
services 
survey  National law enforcement: customs authority  132 
Local/regional customs authority  37 
EU institutions/agencies  11 
National ministry acting in the area of fight against fraud  7 
Other  4 
National law enforcement: police 4 
It was not possible to provide an accurate response rate for either the participants or the user 
survey as a snowball approach was used to distribut e the surveys. For the participants’ survey, 
OLAF initially provided the contact details of organisers of events who distributed the survey  
among participants. For the user survey, OLAF contact points distributed the survey among 
beneficiaries of Hercule III services. In this case, it was also directly distributed among actual 
users of databases whose contact details were initially provided b y OLAF. Table  7 notes  the 
type of limitations encountered and the corresponding strategies taken to mitigate these issues.  
Table  7 - Problems and limitations associated with the online surveys  
Problems encountered  Mitigation strategy  
The lack of direct contacts for 
users of databases and 
participants of events limited 
the ability to send the survey 
directly to the relevant 
respondents.  Due to COVID -19, OLAF were unable to access files in the office 
directly, the available contact info rmation consisted of the 
organisers of events, participants of events, national contact points 
and users of services.  
OLAF therefore took a hybrid approach. It sent o ne email for each 
survey where the organisers/national contact points were asked to 
forwa rd the survey to the participants/users.  
A number of respondents 
only partially completed the 
survey.  Follow -up emails sent specifically to respondents who had only 
partially completed the survey helped encourage more respondents 
to complete the survey.  
3. Comparison of results from different consultation activities  
The consultation activities targeted a wide range of stakeholders across multiple  governance 
levels and geographic coverage. Within these groups, OLAF consulted a wide range of 
stakeholders via the different consultation activities. The following table gives an overview of 
the stakeholders reached during the different consultation methods . 
Table 8 - Stakeholders reached through different consultation methods84 
Stakeholder category  Interviews  Surveys  Total85 
                                                           
84 N/A means the group was not targeted, i.e. not expected to take part in a specific consultation activity.  
85 In some cases, stakeholders took part in both the int erviews and the surveys. Therefore, total numbers here 
are an estimat e of the overall number of stakeholders consulted per category.  
 
77 National law enforcement authorities86  38 230 268 
EU institutions/agencies  11 11 22 
Partners  9 N/A 9 
Research institutes/ academia  N/A 33 33 
National tax administration  N/A 30 30 
Non-profit organi sations  N/A 13 13 
Local/regional customs authority  N/A 63 63 
Local/regional law enforcement authority  N/A 12 12 
National ministry acting in the area of fight against fraud  N/A 18 18 
Legal practitioners: lawyers, solicitors, barristers  N/A 2 2 
Local/regional tax administration  N/A 6 6 
Total  58 418 476 
Although  the number of stakeholders consulted differs significantly across the different levels 
of governance, a ll the stakeholder groups  identified at the design stage of the study  were 
consulted.  
The main stakeholder group targeted by the interviews was national law enforcement 
authorities,  as they remain the main beneficiaries and final users of the funded equipment 
(case study interviews ). It also included  representatives of EU institutions such a s OLAF and 
partner organisations who could provide insights into the functioning of Hercule III and its 
funded actions. For the surveys, the overview table shows a bias towards greater 
representation of national law enforcement authorities in the sample size compared to other 
groups. In terms of geographical coverage, overall, there is an even geographical distribution 
of respondents , although there was less representation from northern and central European 
countries in the applicants’ survey . 
While it is  impossible to consult a statistically representative sample of stakeholders for the 
EU as a whole, the study was designed to be as inclusive as possible. In addition, efforts were 
made to ensure geographical balance between interviewed stakeholders. To facilitate this, the 
study team conduct ed interviews in the language of the interviewees to  further encourage 
participation .  
To ensure the representativeness of all stakeholder groups, the stakeholder consultations were 
designed to be complimentary in terms  of the topic areas covered. The topics and questions 
were tailored to each of the main stakeholder groups while ensuring a sufficient degree of 
overlap in terms of the evaluation questions. In particular, for the interviews, interview  guides 
were developed per stakeholder group and the online surveys were sent to three different 
target groups (applicants, users and participants). Each of these areas included both sub -
evaluation questions and top -level questions  to give respondents the o pportunity to express 
more general views when they do not have full knowledge of the topic area .  
                                                           
86 For simplicity, national law enforcement authorities refer here to national police and national customs 
authorities . 
 
78 Triangulation of the data on the above activities revealed that the stakeholder views were 
largely consistent with similar trends emerging throughout and with in stakeholder types. 
While some differing views were found in each of the consultation activities, they were taken 
into account and adequat ely represented in the analysis , factoring in any po tential  bias.  
4. Integrati ng the  consultation results in the answers to evaluation questions  
Table 10 shows the sources of evidence for each evaluation sub -question. In most cases , the 
evidence was collected via at least two stakeholder consultation activities.  
Table 9 - Ranking  
Symbol  Description  
 The evidence provided, while not comprehensive, is of high quality and reliable 
to draw a conclusion (e.g.: strong quantitative evidence with adequate sample 
sizes and no major data quality or reliability issues; or a wide range of reliable 
qualitative sources, across which there is good triangulation ). 
 The evidence allows for good triangulation, and it covers all the indicators within 
each sub -question. However, the geographical coverage of the evidence is not 
complete and/or more detailed information might be required from other sources.  
 The evidence is of good quality, but the geographical coverage of the evidence 
is not complete and not all the indicators within the sub -question are covered .  
 This source of evidence is limited/weak and not suitable for triangulation on the 
sub-questio n. 
 Not applicable or pending data collection ( work in progress ). 
 

 
79 Table 10 - Coverage of evaluation (sub)questions by different stakeholder consultation activities  
Evaluation questions  Sub-questions  Interviews  Applicants’ 
survey  Participants 
survey  Users 
survey  
Relevance  
To what extent have the 
specific and operational 
objectives87 of the Hercule III 
programme as established by 
Regulation 250/2014 proven 
to be and remained relevant 
to achieve the general 
objective to protect the EU’s 
financial interests?88 To what extent is the specific objective of the programme, 
in preventing and combating fraud, corru ption and any 
other illegal activities, relevant to protecting the EU’s 
financial interests?      
To what extent is the operational objective of improving the 
prevention and investigation of fraud and other illegal 
activities (OP1) relevant to protect ing the EU’s financial 
interests?      
To what extent is the operational objective of increasing the 
protection of the EU’s financial interests against fraud by 
facilitating the exchange of information, experiences and 
best practice (OP2) relevant to protecting the EU’s financial 
interests?      
To what extent is the operational objective of strengthening 
the fight against  fraud and other illegal activities by 
providing technical and operational support to national 
authorities (OP3) relevant to protecting the EU’s financial 
interests?      
To what extent is the operational objective of limiting the 
currently known exposure of the EU’s financial interests to 
fraud, corruption and other illegal activities with a view to 
reducing the development of an illegal economy in key risk 
areas (OP4) rel evant to protecting the EU’s financial 
interests?      
                                                           
87 Legend: GO – general objective, SO – specific objective, OP – operational objective . 
88 This question has been reworded. In the terms of reference , it was originally ‘To what extent have the specific and operational objectives of the Hercule III 
programme  as established by Regulation 250/2014 proven to be and remain relevant for the general objective of the protection of the fina ncial interests of the EU? ’ 

 
80 To what extent is the operational objective of enhancing the 
degree of development of the specific legal and judicial 
protection of the EU’s financial interests against fraud by 
promoting comparat ive law analysis (OP5) relevant to 
protecting the financial interests of the EU?      
To what extent is the Hercule 
III programme relevant to 
address the problems and 
needs related to protecting 
the EU’s financial interests?  To what extent was the Hercule III programme relevant to 
address the then relevant problems and needs of 
stakeholders (national competent authorities, enforcement 
agencies etc.) related to protecting the EU’s financial 
interests?      
To what extent is the Hercule III programme still relevant to 
address the current and new problems and needs of 
stakeholders (national competent authorities, enforcement 
agencies etc.) related to protecting the EU’s  financial 
interests?      
To what extent have the 
activities of programme as 
established by Regulation 
250/2014 proven to be and 
remain relevant for achieving 
its operational and specific 
objectives?  To what extent have technical activities proven to be and 
remain relevant to achie ving its operational and specific 
objectives (OPs 1, 2 & 3)?       
To what extent have training activities proven to be and 
remain relevant to achieving its operation and specific 
objectives (OPs 1, 2 & 4)?      
To what extent have support for conferences and legal 
studies proven to be and remain relevant to achieving its 
operational and specific objectives (OPs 1, 2 & 5)?      
Coherence  
To what extent are the 
different interventions of the 
programme coherent among 
each other?  To what extent are there complementarities, synergies or 
overlaps between the different types of activities (such as 
between training and technical assistance, e.g. in the area 
of digital forensics)?      

 
81 To what extent is this 
intervention coherent with 
other measures or actions at 
EU level that have 
contributed to the protection 
of the EU’s financial 
interests?  To what extent are there complementarities, contradictions 
or overlaps between the programme an d other EU 
legislation and measures, such as:  
 Directive 2017/1371 on the protection of the EU’s financial 
interests  
 Regulation 2017/1939 setting the European Public 
Prosecutor’s Office  
 Anti-fraud Information systems (AFIS)      
To what extent are there synergies, complementarities, 
contradictions or overlaps between the programme and 
other EU programmes such as:  
 Fiscalis 2020  
 Customs 2020  
 The Justice programme      
Effectiveness  
Technical assistance  
To what extent have the 
technical assistance 
interventions contributed to 
preventing and combating 
fraud, corruption and any 
other illegal activities 
affecting the EU’s financial 
interests (SO1)89? To what extent has the implementation of the technical 
assistance activities contributed to reaching the 
programme’s specific objective of preventing and 
combating fraud, corruption and any other illegal activities?  
    
                                                           
89 The question was added from the terms of reference (p. 11) where it stated a need to understand the e xtent to which the programme  is delivering its specific and 
operational objectives . 

 
82 To what extent have the 
technical assistance 
interventions contributed to 
improving the prevention and 
investigation of fraud and 
other illegal activities through 
an enhanced transnational 
and multi disciplinary  
cooperation (OP1)?  To what extent have the te chnical assistance activities 
contributed to providing specific knowledge facilitating 
transnational cooperation and cooperation with the 
Commission ( Article 8(a)(i))?      
To what extent have the technical assistance activities 
contributed to specialised and technically advanced 
equipment and effective information technology (IT) tools 
facilitating transnational cooperation and cooperation with 
the Commission ( Article 8(a)(i))?      
To what extent have the technical assistance activities 
contributed to ensuring the necessary support and 
facilitating investigations? In particular, the setting up of 
joint investigation teams and cross -border operations?      
To what extent have technical 
and operational support 
activities given to nation al 
investigations, in particular 
customs and law 
enforcement authorities, 
contributed to the 
strengthening of the fight 
against fraud and other illegal 
activities (OP 2 and 3)?  To what extent have technical and operational support 
activities contributed to  enhancing staff exchanges for 
specific projects, in particular in the field of the fight against 
cigarette smuggling and counterfeiting ( Article 8(a)(iii))?      
To what extent have technical and operational support 
activities contributed to providing support for the law 
enforcement authorities of the Member States in their fight 
against illegal cross -border activities?      
To what extent have technical and operational support 
activities contributed to building information technology 
capacity throughout participating countries by developing 
and providing specific databases and IT tools facilitating 
data access and analysis?      
To what extent have technical and operational support 
activities contributed to increasing data exchang e, 
developing and providing IT tools for investigations, and 
monitoring intelligence work?      
How did technical assistance 
activities contribute to limiting 
the currently known exposure 
of the EU’s financial interests 
to fraud, corruption and other How did technical assistance activities contribute to limiting 
the currently known exposure of the EU’s financial interests 
to fraud in the key risk area of cigarette smuggling?  
    

 
83 illegal activities with a view to 
reducing the development of 
illegal economy in key risk 
areas?  How did technical assistance activities contribute to limiting 
the currently known exposure of the EU’s financial interests 
to fraud in the key risk area of counterfeiting?  
    
Training  
To what extent have training 
activities contributed to 
improving the prevention and 
investigation of fraud and 
other illegal activities through 
an enhanced transnational 
and multi disciplinary  
cooperation (SO1)?  Has the implementation of the training activi ties contributed 
to reaching the programme’s specific objective of 
preventing and combating fraud, corruption and any other 
illegal activities?      
To what extent have training activities contributed to 
improving the prevention of other illegal activities by 
enhancing transnational and multi disciplinary  cooperation?  
    
To what extent have training 
activities facilitated the 
exchange of information, 
experience and best practice 
with a view to strengthening 
the fight against fraud 
detrimental to the EU’s 
financial interests?  To what extent have training activities facilitated the 
exchange of experience and best practice between the 
relevan t authorities in the participating countries, including 
specialised law enforcement services, as well as 
representatives of international organisations?      
To what extent have training activities facilitated the 
coordination of activities of participating countries, and 
representatives of international organisations?      
To what extent have training activities facilitated the 
dissemination of knowledge, particularly on better 
identification of risk for investigative purposes?      
To what extent have training 
activities contributed to 
develop the legal and judicial 
protection of the EU’s To what extent have training activities contributed to 
developing high -profile research activities, including 
studies?      

 
84 financial interests?  To what extent have training activities contributed to 
improving cooperation between practitioners and 
academics?      
To what extent have training activities contributed to further 
raising the awareness of the judiciary and other branches of 
the legal profession for the protection of the EU’s financial 
interests?      
Overall effectiveness  
To what extent have external 
factors affected (positively or 
negatively) the delivery of 
results and achievement of 
objectives90? To what extent have positive external factors affected the 
delivery of results and achievement of objectives?  
    
To what extent have negative external factors affected the 
delivery of results and achievement of objectives?  
    
To what extent have both the 
technical assistance and 
training activities contributed 
to the EU’s priorities for 
smart, sustainable and 
inclusive growth?  To what extent have the technical assistance activities 
contributed to fostering a better understanding of EU and 
national mechanisms?      
To what extent have the training activities contributed to the 
EU’s priorities of smart, sustainable and inclusive growth?  
    
Efficiency  
To what extent have the 
desired effects been 
achieved at reasonable costs What regulatory costs (direct and enforcement costs) have 
been borne by the EU through the implementation and 
monitoring of the Hercule III programme?      
                                                           
90 This evaluation question has been added to take into account the requirement in the terms of reference to explore ‘the external factors affecting (positively or 
negativel y) the delivery of results and achievement of objectives of the programme (p .11). 

 
85 on the basis of a cost/benefits 
analysis (with quantification 
and qualitative analysis)?  What direct costs (administrative burden, application costs, 
compliance costs, hassle costs) have been borne by 
beneficiaries of technical activities, anti -fraud training, and 
legal training and studies?      
What enforcement costs (information and monitoring, 
inspections, adjudication/ litigations) have been borne by 
beneficiaries of technical activities, anti -fraud training, and 
legal training and studies?      
What direct regulatory benefits (increase in the number of 
number of illicit goods identified, faster detection rates) 
have been achieved for different stakeholders? (EU, 
beneficiaries, participants at events)      
What indirect regulatory benefits91 (reduction in fraud crime 
and improvements in safety at the EU/ national level) have 
been achieved for different stakeholders? (EU, 
beneficiaries, participants at events)      
Are the costs and benefits reasonable in order to achieve 
the desired effects of the programme?      
To what extent were the activities to achieve the objectives 
of the programme made available in due time for the 
beneficiaries?      
Are there any obstacles of an administrative or financial 
nature which have discouraged certain categories of 
potential beneficiaries to apply to calls for tenders or calls 
for proposals?      
Could the same degree of 
effects have been achieved 
with lower  costs with simpler 
procedures, involving less 
administrative burden and/or Could the same degree of effects have been achieved with 
lower costs?  
    
                                                           
91 The B etter Regulation Guidelines  (BRG) define ‘indirect benefits ’ as being the ‘spill-over effects from compliance by the regulated entity with the new obligation; 
wider ma croeconomic benefits (GDP, productivity, employment rates, etc.); and other non-moneti sable benefits such as fundamental rights, social cohesion, 
reduce gender discrimination, improved security/stability etc .’ (p.69 of the BRG toolbox) . 

 
86 with different implementation 
mechanisms?  Could the same degree of effects have been achieved with 
simpler procedures at the different decision -making and 
funding stages?  
    
Could the use of other implementation mechanisms have 
provided for better efficiency?  
    
EU added value  
Has the programme allowed 
delivering results that could 
not, or  to a lesser extent, be 
achieved by interventions 
undertaken at national or 
regional level?  Is there evidence of EU added value resulting from the 
programme at the national or regional levels?      
To what extent could the same results be achieved at 
national and regional levels without EU intervention?  
    
What would be a 
consequence of stopping or 
withdrawing the existing EU 
intervention?  n/a  
    
Sustainability  
To what extent are the 
(positive) effects of the 
intervention likely to last after 
the intervention has ended?  To what extent are the long -term effects of the interventions 
sustainable?  
    
To what extent have the interventions triggered additional 
initiatives at national level?  
    

 
87 
 ANNEX 3 - METHODS AND ANALYTICA L MODELS  
This annex provides a description of the methodological approach to the evaluation by 
summarising the methodological approach of the external evaluation study.  
Sampling methodology  
The external contractor carried out the sampling according to three selection criteria:  
1. A balanced yet weighted geographical sample:  the geographical distribution in the 
selection of project reports resembles as closely as possible the geographical distri bution 
of all finalised projects . Countries with only one or two finalised projects  were  slightly 
overrepresented, while countries with more than 10 finalised projects  were  
underrepresented to include at least one project for every beneficiary Member State  (see 
Appendix 5 of the study report – note that Austria, Cyprus, Denmark, Luxembourg 
and the United Kingdom did not run any technical assistance project s between 2014 
and 2020 ). 
2. Contractor RAMBOLL sought  to factor in  the relative weight of technical assistance 
and training projects run under the Hercule III budget  in its selection. For each 
country, it aimed to select more technical assistance projects  than training projects . 
Some  outliers  are countries such as Italy that had an exceptionally high number of 
training projects  whereas other countries did not run any training projects  during this 
funding period. In the final sample, training is somewhat overrepresented (35% of the 
reports in the sample vs 25% of the total budg et), since in total, the number of training 
projects  is relatively h igh with mostly smaller budgets ; 
3. For the final selection of projects , RAMBOLL aimed to achieve a balanced 
distribution over time . This was however difficult to achieve for two reasons. In 2017, 
the reporting requirements for grant beneficiaries changed, and as a result final technical 
and implementation reports are much more comprehensive for projects finalised after 
2017. For some  recently finalised projects, the fina l technical or implementation report s 
are not yet available . In addition, some projects that were planned to be finished in 2020 
were extended  due to delays caused by the COVID -19 pandemic. Therefore, the final 
samplin g focused on the data availab le while still aiming to achieve a balanced 
distribution of selected projects.  
The in -depth assessment of achievements  went through a selection of 98 projects  funded 
over the 2014 -2020 period92. In November 2021, OLAF had registered 280 finalised projects 
out of 336 applications (83.3%)  under the programme, meaning that the final technical 
reports had been submitted for these 280 projects .  
                                                           
92 See RAMBOLL, Final Evaluation Report of the Hercule III programme, Appendix 5 – Assessment of 
Achievements, https://op.europa.eu/s/uVYM . 
 
88 Among the  projects  selected, 60 were technical assistance grants, 35 were anti-fraud  
training & conferences grants or legal training & studies grants, and 3 were related to 
procure d databases . Of the 35 training grants, two legal training & studies grants were 
selected that have been renewed on an annual basis. The same applies to the 3 selected 
projects on procure d databases.  
The assessment methodology  
For each selected project, all available reports were included in the desk research. This 
included the final technical reports, final financial reports, final implementation reports, and 
post-event surveys of projects funded by the programme. The evidence  from the reports was 
compiled by RAMBOLL, using an Excel database to collect  both quantitative and 
qualitative data.  
Information  from these reports was used to create a typology of project implementation and 
achievements in the form of a database. This was  used to identify the main characteristics of 
the projects based on data from the final technical/implementation reports . The main results 
and impacts as set out in the final technical/implementation reports  were  categoris ed 
follow ing the evaluation questi on matrix . 
Where quantitative data were available, it was added to the database of finalised projects . 
For technical assistance, quantitative data consisted mainly of the number of operations the 
equipment was used in, the number and types of goods seized, and the number of suspects 
identified and detained. For training, quantitative data are firstly the number of participants 
in events and the level of satisfaction reported by participants, and secondly the results of 
the post -event surveys.  
Both the final reports for training and technical assistance and the implementation reports 
for technical assistance contain qualitative data  too. Though  the post -event survey reports 
only contain quantitative data, the final technical reports for training  and conference grants 
describe the project achievements, which required a qualitative analysis.  
Qualitative  data were used by categorising the results described in the project reports and 
adding the categories to the d atabase. Based on the evidence provided in the reports, the 
study team judged the degree to which the assistance proved effective in reaching its 
objective. The robustness of these assessments was judged on the basis of supporting 
evidence and/or examples  provided , using a 5 -point scale ( for details, see Table 5.6 in 
Appendix 5 to the study report).  
 
 
89 
 ANNEX 4 - LIST OF ACRONYMS AND ABBREVIATIONS  
AFT      Anti-fraud training  
AFCOS     Anti-Fraud Coordination Service  
Annual Implementation Report  Commission staff working document, annual overview 
with information on the results of the Hercule III 
programme, accompanying the document ‘Report from the 
Commission to the European Parliament and the Council 
on the Protection of the European Union's financial 
interests - Fight against Fraud Annual Report ’ (‘PIF  
report ’) 
AMT                                                            Automated  Monitoring Tool  
Annual work programme  Annual work programme (‘AWP’) for the implementation 
of the 2014 -2020 Hercule III programme, established by 
Regulation (EU) No 250/2014, annex to the Commission 
decision concerning the adoption of the annual work 
programme and the financing of the Hercule III 
programme  
COCOLAF  Advisory Committee for the Coordination of Fraud 
Prevention ( French acronym ) 
EPPO                                                          The European Publ ic Prosecutor’s Office  
EUIPO                                                        The European Union Intellectual Property Office  
GAF                                                             Groupe Anti -Fraude (European Council Working Party)  
IA Impact  assessment accompanying the proposal for a 
legislative act, such as a regulation  
IT   Information technology  
ISG   Inter -service steering group 
JRC   The Commission’s Joint Research Centre  
LTS   Legal training and studies  
MFF                                                            Multiannual  financial framework  (EU budget)  
MS   Member State(s) (of the European Union)  
OECD                                                         Organisation for Economic Co -operation and Development  
OLAF    The European Anti -Fraud Office ( French acronym ) 
PIF  Protection of the financial interests of the EU  
PIF Associations                                         Mainly universities or research institutes working on 
European criminal law and  protection of the financial 
interest  of the EU (and Hercule III beneficiaries)  
Annual PIF Report (or ‘PIF report’)  The Commission’s annual report under Article 325 TFEU 
on the protection of the EU’s financial interests  
The programme   The Hercule III programme  
The Regulation (basic act)  Regulation (EU) No 250/2014 of the European Parliament 
and of the Council of 26  February 2014 establishing a 
Programme to promote activities in the field of the 
protection of the financial interests of the European Union  
(Hercule III Programme) and repealing Decision No 
804/2004/EC  
TA   Technical assistance  
TFEU  Treaty on the Functioning of the European Union  
VAT   Value added tax 
 
90 ANNEX 5 - GLOSSARY  
General  objective  To protect the EU’s financial interests, thus enhancing the competitiveness of the 
EU’s economy and ensuring the protection of taxpayers’ money (Article 3 of 
Regulation (EU) No 250/2014).  
Specific  objective  To prevent and combat fraud, corruption and other illegal activiti es against the 
EU’s financial interests, including cigarette smuggling and counterfeiting (Article 
4 of the Hercule Regulation).  
Operational  objectives  1. improving the prevention and investigation of fraud and other illegal 
activities beyond current levels by enhancing transnational and 
multi disciplinary  cooperation;  
2. increasing the protection of the financial interests of the EU against fraud by 
facilitating  the exchange of information, experiences and best practices, 
including staff exchanges;  
3. strengthening the fight against fraud and other illegal activities by providing 
technical and operational support to national investigation, and in particular 
customs and law enforcement authorities;  
4. limiting the currently known exposure of the financial interests of the EU to 
fraud, corruption and other illegal activities with a view to reducing the 
development of an illegal economy in key risk areas such as organised fraud, 
including cigarette smuggling and counterfeiting;  
5. enhancing the degree of development of the specific legal and judicial 
protection of the financial interests of the EU against fraud by promoting 
comparative law analysis (Article 5).  
Bodies eligible for 
funding  1. national or regional administrations of a participating country, as referred to 
in Article 7(1) of the Hercule Regulation, which promote the strengthening of 
action at EU level to protect the EU’s financial interests;  
2. research and educ ational institutes and non -profit -making entities provided 
that they have been established and have been operating for at least one year, 
in a participating country (Article 7(1)), and promote the strengthening of 
action at EU level to protect the financia l interests of the EU (Article 6).  
Beneficiaries  Eligible bodies that have been awarded a grant (in the period: 2014 -2020).  
End beneficiaries  Staff that operates the equipment purchased through a technical assistance grant or 
which is a participant in training activities.  
Unsuccessful applicants  Entities that applied without success to the Hercule III calls for proposals . 
Participants in events  Individuals taking part in events (conferences, seminars, training, etc.) funded by 
Hercule III grants (2014 -2020).  
Users of services  Individuals accessing services purchased under procurement and made available to 
EU, national and regional institutions. Users of services comprise users of 
statistics and IT tools, users of databases, and users of services to ca rry out 
chemical analysis of samples from tobacco and/or cigarette seizures.  
Traditional ‘ own 
resources’  A small share  of tax revenue raised by Member States is transferred to the EU 
budget, which has three  streams of  traditional own resources: tariffs and duties 
(agricultural tariffs, sugar customs duties, general tariffs), VAT -based income and 
gross national income -based revenue.  
 
91 ANNEX 6 - EXTERNAL EVALUATION S UPPORT STUDY  
 
The external study carried out by RAMBOLL Management Consulting is available 
through the following link : https://op.europa.eu/en/publication -detail/ -
/publication/3d9c63bd -4da3 -11ec -91ac -01aa75ed71a1