COMMISSION STAFF WORKING DOCUMENT Action Plan Accompanying the document 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 Commission Anti-Fraud Strategy: enhanced action to protect the EU budget
Date: 2019-04-29
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU control, EU strategy, administrative check, administrative cooperation, exchange of information, financial control, fraud, fraud against the EU, general budget (EU)

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 29.4.2019 SWD(2019) 170 final  COMMISSION STAFF WORKING DOCUMENT Action Plan Accompanying the document 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 Commission Anti-Fraud Strategy: enhanced action to protect the EU budget {COM(2019) 196 final} - {SWD(2019) 171 final}  
 
 
COMMISSION STAFF WORKING DOCUMENT 

Action Plan 

Accompanying the document 
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 
Commission Anti-Fraud Strategy: enhanced action to protect the EU budget 

Table of Contents 
Key Abbreviations .................................................................................................................................. 2 

Introduction ............................................................................................................................................. 4 

A.  Prevention and Detection ................................................................................................................ 6 

A.I. Cross-cutting issues ................................................................................................................. 6 

A.I.1: Priority measures: data collection and analysis .................................................. 6 

A.I.2: Priority measures: coordination and cooperation .................................................  

                                         among Commission services and executive agencies .......... 8 

A.I.3. Professional ethics ............................................................................................ 10 

A.I.4. Training, awareness-raising and technical assistance ....................................... 11 

A.I.5. Transparency .................................................................................................... 12 

A.I.6: Fraud-proofing of the legal framework for the implementation of the budget . 13 

A.I.7. Miscellaneous ................................................................................................... 15 

A.II. 

Expenditure ................................................................................................................. 16 

A.II.1. Direct management.......................................................................................... 16 

A.II.2. Indirect management ....................................................................................... 17 

A.II.3. Shared management ........................................................................................ 18 

A.III. 

Revenue ...................................................................................................................... 19 

A.III.1. Revenue – traditional own resources (TOR) .................................................. 19 

A.III.2. Revenue – value added tax (VAT) ................................................................. 20 

B. 

Investigation .................................................................................................................................. 21 

B.I.  European Public Prosecutor’s Office (EPPO) and PIF Directive ......................................... 21 

B.II. European Anti-Fraud Office (OLAF) ................................................................................... 22 

C. Corrective Measures and Sanctions; Follow-up of OLAF Recommendations ................................ 23 

D. Reporting on the Implementation of the CAFS ............................................................................... 24 

1 

 
 
 
 
Key Abbreviations 

Abbreviation 

Meaning 

AAR 
ABAC 
AGRI 
AOD 
BUDG 
CAFS 
CFSP 
CMB 
CRMS 
DEVCO 

DIGIT 
ECFIN 
ECHO 
EDES 
EEAS 
EIB 
EMPL 

EPPO 
Europol 
FPDNet 
FPI 
FR 
GROW 

HOME 
HR 
IAS 
IMS 
ISO 
IT 
JRC 
MARE 
MFF 
NEAR 

OIB 
OIL 
OLAF 

OP 
PIF1 

Annual Activity Report 
Accrual Based Accounting 
Directorate-General Agriculture and Rural Development 
Authorising Officer by Delegation 
Directorate-General for Budget 
Commission Anti-Fraud Strategy 
Common Foreign and Security Policy 
Corporate Management Board 
Customs Risk Management System 
Directorate-General International Cooperation and 
Development 
Directorate-General Informatics 
Directorate-General Economic and Financial Affairs 
Directorate-General Humanitarian Aid and Civil Protection 
Early Detection and Exclusion System 
European External Action Service 
European Investment Bank 
Directorate-General Employment, Social Affairs and 
Inclusion 
European Public Prosecutor’s Office 
EU Agency for Law Enforcement Cooperation 
Fraud Prevention and Detection Network 
Service for Foreign Policy Instruments 
Financial Regulation 
Directorate-General Internal Market, Industry, 
Entrepreneurship and SMEs 
Directorate-General Migration and Home Affairs 
Directorate-General Human Resources and Security 
Internal Audit Service 
Irregularity Management System 
International Organization for Standardization 
Information Technology 
Joint Research Centre 
Directorate-General Maritime Affairs and Fisheries 
Multiannual Financial Framework 
Directorate-General Neighbourhood and Enlargement 
Negotiations 
Office for Infrastructures and Logistics in Brussels 
Office for Infrastructures and Logistics in Luxembourg 
European Anti-Fraud Office 

Publications Office 
Protection of the EU’s financial interests 

1   French acronym for "protection des intérêts financiers de l'Union européenne". 

2 

 
 
                                                           
PIF Directive 

REGIO 
SG 
SJ 
SRSS 
TAXUD 
TED 
TOR 
TRADE 
VAT 

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 
Directorate-General Regional and Urban Policy 
Secretariat-General 
Legal Service 
Structural Reform Support Service 
Directorate-General for Taxation and Customs Union 
Tenders Electronic Daily 
Traditional own resources 
Directorate-General Trade 
Value added tax 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Introduction 

On  24  June  2011,  the  Commission  adopted  its  current  anti-fraud  strategy.  This  comprised: 
(i) a Communication from the Commission to the other EU institutions2, describing strategic 
objectives  and  key  operational  steps  to  attain  them;  and  (ii)  a  more  detailed  Commission-
internal Action Plan3.  

In preparation of the Multiannual Financial Framework (MFF) 2021 – 2027, the Commission 
has  reviewed  its  anti-fraud  strategy  to  take  account  of  the  developments  in  the  (anti-)fraud 
landscape  and  in  the  design  of  EU  policies.  This  review  is  reflected  in  its  Communication 
‘Commission  Anti-Fraud  Strategy:  enhanced  action  to  protect  the  EU  budget’4,  which  this 
staff working document accompanies. For the strategy update, the Commission services have 
carried  out  a  fraud  risk  assessment,  involving  also  the  executive  agencies.  The  results  are 
presented in another staff working document accompanying the Communication5.  

The  two  main  vulnerabilities  identified  in  the  Fraud  Risk  Assessment  are:  (i) an 
underdeveloped central analytical capacity; and (ii) gaps in the corporate supervision of fraud 
risk  management  at  department  level.  The  priority  objectives  (Objectives  1  and  2)6  of  the 
review are therefore to equip the Commission with stronger analytical capabilities and more 
centralised  oversight  mechanisms  for  anti-fraud  action  by 
individual  Commission 
departments.  The  other  key  objectives  (Objectives  3  –  7)7,  based  on  the  guiding  principles 
and standards of the 2019 Commission Anti-Fraud Strategy (‘the 2019 CAFS’)8 and on the 
Fraud  Risk  Assessment,  are  to  maintain  the  highest  standards  of  professional  ethics  and 
competence,  to  optimise  the  legal  framework  for  and  transparency  of  EU  funding,  and  to 
improve the fight against revenue fraud. 

The  measures  listed  in  the  tables  below  aim  to  meet  one  or  more  of  these  objectives.  The 
measures  are  grouped  according  to  stages  of  the  anti-fraud  cycle  (prevention,  detection, 
investigation and correction/sanctioning of fraud). They are divided into two further groups: 
those  that  relate  to  revenue  and  those  that  relate  to  expenditure  and,  within  expenditure,  to 
different  management  modes.  Some  action  points  (e.g.  No  49,  50,  52,  55)  refer  to  ongoing 
projects or measures so as to provide a more complete picture of the Commission's activities 
in a specific area. 

The Action Plan is designed to implement the Communication on the 2019 CAFS. With its 
recurring  (‘continuous’)  actions,  it  will  run  until  the  next  update  of  the  CAFS,  planned  for 
around the mid-point of the coming MFF; in the meantime, the Action Plan will be reviewed 

2   Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee, and the Committee of the Regions and the Court of Auditors of 24 September 2011 on the 
Commission Anti-Fraud Strategy, COM (2011) 376 final. 

3   Communication  to  the  Commission,  Commission  Internal  Action  Plan  for  the  Implementation  of  the 

Commission Anti-Fraud Strategy, SEC (2011) 787/3. 

4  COM (2019) 196. 
5  SWD (2019) 171. 
6   See the Annex to Communication COM (2019) 196. 
7   See the Annex to Communication COM (2019) 196. 
8  See Section 4.1. of the Communication (reference in FN 4).  

4 

 
 
                                                           
and amended as appropriate. The Action Plan’s implementation will be monitored mainly by 
OLAF, the Fraud Prevention and Detection Network (Directors’ level) and by the Corporate 
Management Board. Commission services and executive agencies will in due course integrate 
their  action  points  into  their  (local)  anti-fraud  strategies  and,  as  soon  as  possible,  into  their 
planning and programming cycles by including relevant activities in their management plans 
and reporting on their implementation in their annual activity reports. The latter will be done 
using suitable output and, where appropriate, result indicators. 

For the priority objectives, preliminary corporate-level result indicators should be developed 
by  2020.  These  result  indicators  should  be  refined  and  complemented  throughout  the 
2019 CAFS’  implementation,  in  line  with  actual  experiences  and  the  results  of  further 
analysis. Similarly, result indicators for Objectives 3 – 7 should be defined after due analysis. 
To  measure  ethical  awareness  or  anti-fraud  know-how  as  result  indicators  for  Objectives  3 
and 4, for example, a sound methodology will need to be developed and a Commission-wide 
baseline established, in  close cooperation with  the Commission's internal control and ethics 
functions. 

It  should  be  noted  that  in  the  below  tables  the  term  ‘services’  means  the  Commission’s 
departments  and  administrative  offices  and  the  executive  agencies.  The  term  ‘(other)  EU 
bodies’  includes  regulatory/decentralised  agencies,  joint  undertakings/joint  technology 
initiatives and similar organisations. 

5 

 
 
A.  Prevention and Detection 

A.I. Cross-cutting issues 

A.I.1: Priority measures: data collection and analysis 
Number  Objective 

Action 

1 

2 

3 

4 

Data collection 
and analysis 

Data collection 
and analysis 

Data collection 
and analysis 

Provide  strategic  analyses  that  can  feed  into 
fraud  risk  assessments  and  fraud  prevention 
activities  of  the  Commission  services  and  the 
Member States. Data sources for these analyses 
would include: 

o  closed OLAF investigations; 
o  cases  reported  by  the  Member  States 
through  the  Irregularities  Management 
System (IMS). 

Promote the analytical use of IMS data (also by 
the  Member  States)  to  improve  methods  and 
deployment  of  resources  in  the  field  of  fraud 
prevention, 
and 
correction.  

investigation 

detection, 

This  action  should  be  supported  by  a  built-in 
analytical tool to be developed by OLAF. 

Closely  monitor  Member  States’  reporting  of 
irregularities  by  carrying  out  respective  checks 
and/or  external  evaluation,  with  a  view  to 
improving  and  harmonising  the  quality  and 
completeness of the data reported in the IMS. 

Data collection 
and analysis 

Exploring  possibilities  to  strengthen  IT-based 
fraud  prevention  and  detection  (as  regards  risk 
scoring  and  controls  for  double-funding,  (self-) 
plagiarism, etc.) by: 

o  establishing 

and 

a 
Commission-wide inventory of existing 
IT tools; 

disseminating 

o  examining  ways 

to  enhance 

the 
interoperability  of  these  tools,  where 
possible  across  management  modes, 
share  them  among  interested  services 
and/or  enrich  them  with  data  coming 
from several sources; 

Lead service 

Due date 

OLAF 

Support: JRC 

2020 and 
then 
continuous 

2020 and 
then 
continuous 

2021 

2021 and 
then 
continuous 

2020 and 
then 
continuous 

OLAF 

Support: 
REGIO, 
AGRI, EMPL, 
MARE, 
HOME, JRC 

OLAF 
(coordination), 
REGIO, 
EMPL, 
MARE, AGRI, 
HOME 
Coordination: 
OLAF / JRC 

Support:  
BUDG, 
DIGIT, SJ, 
Spending 
Services9 

o  analysing  needs  and  potential  for  new 
developments,  working 
the 
most  cost-effective  balance  between 
corporate and local tools. 

towards 

9   Each service that is business owner of an IT tool has the lead responsibility for the analysis and adaptation of 

that tool in line with the action point. 

6 

 
 
                                                           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
improve 

the  ARACHNE  risk 
Review  and 
scoring tool. Continue to promote its use among 
Member  State  authorities,  supported  by  an 
necessary. 
opinion 
external 

legal 

as 

Explore  possibilities  for  an  extended  use  of 
ARACHNE  and  other  risk  scoring  tools  in  all 
management modes. 

5 

Data collection 
and analysis 

Examine  possible  scope,  tools  and  working 
methods for the exchange of audit results among 
services  and  for  exploiting  audit  results  for 
analysis and early detection of risks. 

EMPL 
Support: 
REGIO, 
AGRI, 
OLAF, JRC, 
SJ 

Coordination: 
OLAF/EMPL 
Support: 
JRC; RTD, 
DIGIT, 
BUDG, SJ, 
Spending 
Services 
OLAF 
Support:  
RTD, DIGIT, 
BUDG, 
Spending 
services 

2020-2021 

Explore an extended use of specific applications 
of audit tools (MAPAR) on audit procedures and 
developing analysis of findings. 

REGIO 

Support: 

6 

7 

8 

Data collection 
and analysis 

Data collection 
and analysis 

Encourage  cooperation  with  academia  and 
practitioners 
organising/contracting/co-
financing  conferences  and  studies  on  selected 
topics. 

by 

Map and review channels for exchanging fraud-
related  information  between  services,  other  EU 
bodies,  Member  States  (including  exchanges 
and 
non-EU 
with  Eurofisc), 
international organisations.  

countries 

Data collection 
and analysis 

Develop  country  profiles  to  better  analyse  and 
assess Member States’ anti-fraud action. 

RTD, DIGIT, 
OLAF, 
BUDG, 
Spending 
Services 

OLAF 

OLAF 

Support: 
BUDG, SJ, 
JRC, Spending 
services 
OLAF 

2020 and 
then 
continuous 

2020 and 
then 
continuous 

2020 and 
then 
continuous 

7 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A.I.2: Priority measures:  

coordination and cooperation among Commission services and executive agencies 
Number  Objective 

Action 

Lead service  Due date 

9 

Coordination, 
Cooperation 
and processes 

Have the Corporate Management Board strategically 
monitor  and  review  the  Commission’s  anti-fraud 
policies  at  least  once  a  year.  This  monitoring 
exercise will include: 

o 

o 

o 

the  follow-up  to  OLAF’s  recommendations 
on services’ anti-fraud strategies; 
the  overall  progress  in  the  2019  CAFS 
Action Plan; and 
the 
investigation-based recommendations.  

to  OLAF’s 

follow-up 

systemic 

10 

Coordination, 
cooperation 
and processes 

line  with 

Preparatory  work  undertaken  mainly  by  OLAF,  the 
FPDNet and by the central services at working level, 
in 
the  Administrative  Arrangements 
between  the  Commission  and  OLAF.  See  also 
Action 10. 
Intensify 
the  work  of 
Prevention and Detection Network by: 

the  Commission  Fraud 

o  organising  an  annual  Directors’ 

level 
meeting  to  review  Commission  anti-fraud 
policies; 

existing 

o  setting up subgroups of services with similar 
profiles,  based  on  needs  to  be  analysed  and 
including 
anti-fraud  networks 
composed  of  ‘families’  of  services.  OLAF 
and  BUDG  should  participate  in  all  sub-
groups  and 
the  External  Aid  subgroup 
should be open to the EEAS; 

2019 and 
then 
continuous 

SG 
Support: 
OLAF, 
BUDG, HR, 
SJ 

OLAF 
Support: 
BUDG 

2019 and 
then 
continuous 

o  choosing  agenda 

that 

relate 

to 
items 
colleagues’  daily  work  experiences  for 
‘hands-on’  collaboration,  including  a  peer 
review  of  fraud  risks,  red  flags  and  control 
systems where appropriate; and 

11 

Coordination, 
cooperation 
and processes 

o  collaborating  more  effectively  with 

the 
Commission’s  Network  of  Internal  Control 
Coordinators. 

Further  improve  service-level  anti-fraud  strategies 
and their implementation in the following ways: 

All services 

o  Continue  to  update  anti-fraud  strategies, 
taking  into  account  the  2019  CAFS  and 
following  a  peer  review  in  the  relevant 
FPDNet subgroup at least every three years;  
o  OLAF  should  update  its  methodological 
guidance  for  anti-fraud  strategies  when 
necessary;  

o  Draft  anti-fraud  strategies  and  updates 
should  be  subject  to  mandatory  review  by 

Coordination: 
OLAF 

Support: 
SG, BUDG 

8 

2019 and 
then 
continuous 

 
 
 
 
 
A.I.2: Priority measures:  

coordination and cooperation among Commission services and executive agencies 
Number  Objective 

Action 

Lead service  Due date 

OLAF; 

o  Without prejudice to AODs’ responsibilities, 
the  implementation  of  services’  anti-fraud 
strategies  should  be  closely  monitored  by 
OLAF,  from  the  planning  to  the  reporting 
stage;  

the  design 

o  Based  on  drafts  and  concepts  developed  by 
the  services  concerned,  OLAF  should  issue 
recommendations  on 
and 
implementation  of  anti-fraud  strategies  as 
appropriate. AODs who decide not to follow 
a recommendation must justify their position 
to  OLAF  in  writing.  Any  issues that  cannot 
be  resolved  bilaterally  between  OLAF  and 
the  service  concerned  may  be  discussed, 
without  prejudice  to  the  AODs’  ultimate 
responsibility,  in  the  relevant  subgroup  of 
the FPDNet and/or in other suitable contexts, 
such  as  peer  review  meetings  on  critical 
risks  or  annual  activity  reports.  They  may 
also be brought to the attention of the CMB. 

9 

 
 
 
 
 
Lead service  Due date 

HR 

Continuous  

Support: 
SG, OLAF 

HR 

2020  

HR 

2020 

Continuous 

Partner DGs 
of other EU 
bodies 

Support: 
SG, HR, 
OLAF 

A.I.3. Professional ethics 
Number  Objective 

Action 

12 

Integrity and 
compliance 

and 

Continue,  and  reinforce  where  appropriate,  internal 
communication 
training  on  questions  of 
professional ethics with special emphasis on conflict of 
interest, relations with lobbyists, duty of discretion and 
whistleblowing.  The  aim  is  to  create  a  common 
understanding  of 
to 
encourage  ethical  practices  in  the  workplace,  taking 
into account that fraud prevention and detection is only 
one aspect of ethics and integrity. 

relevant  concepts  and 

the 

13 

14 

15 

Integrity and 
compliance 

Integrity and 
compliance 

Evaluate the use of declarations of interest / absence of 
conflict of interest in the Commission and in executive 
agencies. 

Evaluate  the  Commission’s  policy  on  whistleblowing 
in the context of the report required by Article 113 of 
the Staff Regulations. 

Integrity and 
Compliance 

Promote the highest ethical standards among other EU 
bodies through: 

o  membership in management boards; 
o  presentation of the Commission’s best 
practices in inter-agency networks; 

o  support for ethics training; 
o  advocating inter-agency task forces on 

particular issues as necessary. 

10 

 
 
 
 
 
 
A.I.4. Training, awareness-raising and technical assistance 
Number  Objective 

Action 

Lead service 

Due date 

16 

17 

18 

19 

20 

Know-how and 
equipment 

Maintain  and  refine a  corporate anti-fraud training 
cycle,  including  regular  refresher  courses  and 
e-learning modules, which should be mandatory for 
relevant groups of staff such as financial officers. 

OLAF 

Support: 
BUDG, HR 

2020 and then 
continuous 

Know-how and 
equipment 

Ensure specialised anti-fraud training, according to 
needs identified, for target groups such as:  

OLAF 

2020 and then 
continuous 

o  project managers; 
o  auditors; 
o  Heads of, and administrative staff in, 
Representations and Delegations; and 
o  Heads  of  Civilian  CFSP  Missions  and  EU 
Special  Representatives  and  the  staff  of 
their offices. 

Know-how and 
equipment 

Know-how and 
equipment 

Support  other  Commission  services  and  executive 
agencies,  decentralised 
agencies,  other  EU 
institutions and bodies and Member States in their 
anti-fraud training activities.  
Provide  technical  assistance  to  Member  States 
through  various  spending  programmes  (including 
the EU Anti-Fraud Programme). 

Know-how and 
equipment 

Analyse  fraud  patterns  and  fraud  risks  using  case 
compendiums of OLAF investigations according to 
needs identified. 

OLAF 

Continuous 

OLAF 
TAXUD 
SRSS 
REGIO 
OLAF 

Continuous 

2021 and then 
continuous 

11 

 
 
 
 
 
 
 
A.I.5. Transparency 
Number 

Objective 

Action 

Lead service  Due date 

21 

22 

Transparency  Refine the TED database to improve data quality. 

OP 

Closely  monitor  Member  States’  input  to  the  TED 
database. Consider the possibility of audits or external 
evaluation. 

Transparency  Explore  the  possibility  of  using  existing  IT  tools 
(Financial  Transparency  System,  Single  Electronic 
Data Interchange Area, etc.) to improve information on 
procurement contracts and grant agreements concluded 
by the services, having due regard to the requirements 
mentioned in Article 38(2) FR. 

Support: 
GROW 
BUDG, JRC, 
RTD 

Support: 
GROW, 
DIGIT, OP, 
SJ 

2020 and 
then 
continuous 

2020 - 2021 

12 

 
 
 
 
 
 
 
 
A.I.6: Fraud-proofing of the legal framework for the implementation of the budget 
Number  Objective 

Action 

Lead service 

Due date 

Continuous 

23 

Legal 
framework 

24 

25 

Legal 
framework 

Transparency 

Legal 
framework 

Spending 
services10 

Support: 
OLAF / 
BUDG 

It  also 

regulations. 

When  drafting  legal  instruments  for  the  MFF  after 
2020,  involve  OLAF  at  the  early  stages  to  ensure 
adequate  provisions  on  preventing,  detecting  and 
prosecuting fraud.  
This  includes  legislative  proposals,  delegated  and 
the 
implementing 
following  types  of  documents,  if  such  documents  are 
area: 
of 
systemic 
implementing 
and 
guarantee 
agreements, 
agreements,  calls  for  tenders/proposals/expressions  of 
interest, and policy guidelines.  
Permanent  guidance  of  that  type,  e.g.  DEVCO’s 
Practical  Guide,  should  be  regularly  reviewed  as 
necessary, involving OLAF.  

importance 
decisions,  model 

a  policy 
contracts 

agreements, 

delegation 

includes 

for 

Specify appropriate record-keeping requirements in the 
context of financing not linked to costs and simplified 
cost  options,  with  a  view  to  attaining  the  intended 
simplification  effect  while  minimising  any  negative 
impact  simplification  measures  may  have  on  the 
possibility  to  detect  and  deal  with  fraud  and  other 
irregularities.  

Continuous 

Continuous 

All services 
Coordination: 
SG 
Support: 
OLAF 
Spending 
services 

Coordination: 
BUDG 

Support:  
OLAF, SJ 

include 

relevant, 

risks 
impact 
Where 
fraud 
assessments  and  evaluations  of 
legal  acts  and 
Commission policies required under the Commission’s 
Better Regulation framework.  

in 

Funding instruments must give the EPPO and OLAF – 
within the limits of their respective competences and in 
line with the law applicable to these bodies – authority 
to  investigate  suspected  fraud  in  any  EU-financed 
programmes/projects,  obliging  persons  or  entities 
receiving  Union  funds  to  provide  access  to  their 
premises  and  staff  and  all  relevant  documents, 
information, etc., on request. 
Recipients  must  be  bound  to  oblige,  in  any  contracts 
they conclude with third parties for the implementation 
of the project or funding scheme, those third parties to 
provide  for  such  access  rights,  permitting  the  EPPO 
and  OLAF  also  to  check  on  all  subcontractors, 
subsidiary  companies  and  implementation  partners 
under any management mode. 
The  same  principles  apply,  mutatis  mutandis,  to 
transactions supported by budgetary guarantees. 

10  And  other  services  launching  instruments  with  a  potential  impact  on  the  protection  of  the  EU's  financial 

interests. 

13 

 
 
                                                           
 
 
 
 
26 

Legal 
framework 

in  how 

far  certification  against 

ISO 
Examine 
standards,  most  notably  ISO  37001  on  anti-bribery 
management  systems,  could  be  required  from  entities 
involved 
applying 
their 
funds  or 
for  EU 
indirect  or  shared 
implementation  under  direct, 
management with a view to reducing fraud risks. 

in 

OLAF 

2021 

Support: 
GROW, 
HOME, 
BUDG, SJ, 
Spending 
services 

14 

 
 
 
 
 
A.I.7. Miscellaneous 
Number  Objective 

Action 

27 

28 

29 

30 

Coordination, 
cooperation and 
processes 

For  lump  sums  and  financing  not  linked  to  costs, 
develop  –  across  the  different  management  modes  – 
control  strategies  for  deliverables  and for  the  analysis 
of non-/under delivery, in particular to detect fraud.  

Legal 
framework 

Coordination, 
cooperation and 
processes 

Integrity and 
compliance 
Coordination, 
cooperation and 
processes 

Ensure appropriate coverage of fraud-related aspects in 
the Commission guidelines on Article 61 FR. 

Evaluate fraud risks and vulnerabilities with regard to 
spending in emergency situations 

Coordination, 
cooperation and 
processes 

Regularly  revise  and  update  the  corporate  IT  security 
strategy and monitor its implementation. Optimise the 
systems of the Commission and the executive agencies 
for  secure  operation  of  e-procurement,  e-grants  and 
other channels of e-governance.  

Lead service 

Due date 

Spending 
services 

Support: 
OLAF, BUDG 

2020 and 
then 
continuous 

BUDG 
Support: 
OLAF, HR, 
SJ, SG 

Spending 
services, in 
particular 
ECHO, 
HOME, FPI 
Coordination: 
OLAF 
Support: 
BUDG 
DIGIT 

2020 

2021 

Continuous 

15 

 
 
 
 
 
 
 
 
 
 
 
 
31 

32 

33  

34 

A.II.  Expenditure 

A.II.1. Direct management 
Number 

Objective 

Action 

Coordination, 
cooperation and 
processes 

If  not  yet  done,  set-up  advisory  peer  groups  for 
clusters  of  services  to  review  riskier  (e.g.  larger, 
complex) projects, in the frame of internal control.  

Lead service 

Due date 

All services 

2020 

Coordination: 
BUDG 

Support: 
OLAF, GROW 
HR / BUDG 

Support: 
GROW, OLAF 

2019 and 
then 
continuous 

DEVCO, NEAR, 
ECFIN 

2020 and 
then 
continuous 

Support:  
OLAF, BUDG 

Maintain and reinforce the corporate procurement-
related training cycle, a procurement community 
of practice, and continuous support (e.g. templates, 
helpdesk), including training and support for staff 
who are exceptionally involved in a procurement 
process (e.g. policy officers). 

Where  appropriate,  include  specific  anti-fraud 
measures  among  the  ‘conditionalities’  for  budget 
support. 
For budget support and macro-financial assistance, 
where  appropriate,  improve  control strategies  and 
strengthen verification mechanisms. 

Know-how and 
equipment 

Coordination, 
cooperation and 
processes 

Coordination, 
cooperation and 
processes 

Transparency 

Having due regard to data protection legislation, 

OLAF 

2021 

o  examine  the  possibility  of  setting-up  a 
database of experts involved in EU-funded 
projects 
to  prevent  or  detect  double 
claims; and 

o  explore  the  possibility  of  making  such  a 
thereof 
database  or  certain  elements 
public, 
the  Financial 
Transparency  System  and  the  Register  of 
Commission Expert Groups.  

building 

on 

Support: 
Spending 
services, DIGIT, 
BUDG, SJ, SG 

35 

Coordination, 
cooperation and 
processes 

Optimise  internal  workflows  regarding  budgetary 
guarantees. 

BUDG 

2020 

Support:  
ECFIN, OLAF, 
DEVCO, NEAR 

16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A.II.2. Indirect management 
Number  Objective 

Action 

Lead service 

Due date 

Continuous 

Spending 
services 

Support: 
BUDG, 
ECFIN, 
DEVCO, 
OLAF 

36 

Coordination, 
cooperation and 
processes 

Obtain assurance about internal control of entrusted 
entities, 
fund 
(sub-) 
financial 
managers, etc., e.g., through: 

intermediaries, 

o  Positive  assessment  of  the  equivalence  of 
the  entities’  systems,  rules  and  procedures 
with those of the Commission regarding the 
pillar on internal control as provided for in 
Article  154(3)  and  (4)(a)  FR,  including 
controls 
error, 
irregularities  and  fraud,  which  must  allow 
to  properly  and  timely  prevent,  detect  and 
correct fraud and other irregularities; 

concerning 

risks 

of 

o  Encouraging  the  exchange  of  best  practice 
regarding  anti-fraud  policies,  including  in 
the  domain  of  financial  instruments  and 
budgetary guarantees.  

17 

 
 
 
 
 
 
A.II.3. Shared management 
Number  Objective 

Action 

Lead service 

Due date 

37 

38 

39 

40 

41 

42 

Coordination, 
cooperation and 
processes 

Encourage  Member  States  to  put  in  place  national 
anti-fraud strategies, and provide advice and support 
in this respect.  

Legal framework  Where  appropriate  and  possible,  reinforce  Member 
States’ obligations for the post-2020 MFF throughout 
the anti-fraud cycle. 

Coordination, 
cooperation and 
processes 

Explore  the  possibility  of  applying  the  underlying 
rationale of Action Point 36 to financial instruments 
under shared management. 

Continuous 

2019-2020 

2021 

REGIO, AGRI, 
EMPL, MARE, 
HOME 
Coordination 
and support: 
OLAF 

1) REGIO, 
EMPL, MARE, 
HOME 
Coordination: 
REGIO 

2) AGRI 

Support (ad 1 
and 2): 
BUDG, GROW, 
OLAF, SJ 

REGIO, EMPL, 
MARE, AGRI, 
HOME 
Coordination: 
REGIO 
Support: 
OLAF, JRC, 
BUDG, SJ 

Coordination, 
cooperation and 
processes 

Transparency 

Coordination, 
cooperation and 
processes 

Transparency 
Coordination, 
cooperation and 
processes 

Transparency 

European Semester:  

Analyse/monitor  Member  States’  general  anti-
corruption policies through the country reports.  

HOME 

Continuous 

Explore  the  possibility  and  merits  of  extending  the 
country reports to cover Member States’ policies for 
protecting the EU’s financial interests from fraud. 

SG 
Support: OLAF 

2021 

Promote  integrity  pacts  for  safeguarding  EU  funds 
against fraud and corruption. 

for 

the 

ex-ante 

voluntary 
the  compliance  of 

assessment 
Promote 
mechanism 
large-scale 
infrastructure  projects  with  EU  procurement  rules. 
Measures  would  include  a  helpdesk  function  and  an 
information exchange mechanism. 

REGIO 
Support: 
GROW 

GROW 
Support: 
REGIO 

Continuous 

Continuous 

18 

 
 
 
 
 
 
 
 
 
 
 
 
 
A.III.  Revenue 

A.III.1. Revenue – traditional own resources (TOR) 
Number  Objective 

Action 

43 

44 

45 

46 

47 

48 

Fighting revenue 
fraud 

Legal framework 
Fighting revenue 
fraud 

Coordination, 
cooperation and 
processes 

Fighting revenue 
fraud 

Data collection 
and analysis 

Fighting revenue 
fraud 

Coordination, 
cooperation and 
processes 
Fighting revenue 
fraud 

Legal framework 
Fighting revenue 
fraud 

Coordination, 
cooperation and 
processes 

Review Council Regulation (EC) No 515/9711 with a 
view  to  increasing  mutual  assistance  among  and 
cooperation with national customs authorities. 

Lead service 

Due date 

OLAF 

2020 

level 

Continue  to  ensure  effective  and  efficient  fraud 
prevention  and  detection  in  the  area  of  TOR  at 
through  a  strategic  steering 
Commission 
function,  meeting  regularly  at  Director  and  at 
technical  level,  composed  of  TAXUD,  BUDG  and 
OLAF  as  permanent  members  and  other  interested 
services (in particular TRADE, AGRI, MARE) on an 
ad-hoc basis. 

Coordination: 
rotates among 
TAXUD, 
BUDG and 
OLAF.  

Support: 
All TOR DGs 

Strengthen  the  Commission’s  and  the  Member 
States’ analytical capacities in the anti-fraud customs 
area  by  sharing  approaches  and  good  practices  and 
by increasing awareness and making best use of data 
sources.  Improve  the  exchange  of  risk  information 
and risk analysis through the common Customs Risk 
Management System (‘Reshape of CRMS2’). 

Strengthen  international  cooperation  on  customs 
matters,  with  Belarus,  China,  Georgia,  Moldova, 
Russia,  Ukraine  and  the  United  Arab  Emirates 
among others.  

OLAF 
JRC 
TAXUD 

Support: 
BUDG 

TAXUD 
OLAF 

Develop  anti-fraud  measures  in  preferential  tariff 
arrangements. 

OLAF 

Continuous 

Continuous 

Continuous 

2020 and 
then 
continuous 

Implement the 2nd Commission Action Plan to fight 
2018-202212,  
the 
with a view to: 
- deepening engagement with key source and transit 

tobacco 

illicit 

trade 

countries; 

- addressing the issue of non-branded ‘cheap whites’ 

cigarettes in particular. 

OLAF 

Continuous 

11  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 
application of the law on customs and agricultural matters, OJ L 82, 22.3.1997, p. 1, as amended. 

12  Communication from the Commission to the European Parliament, the Council and the European Economic 

and Social Committee of 7 December 2018, COM (2018) 846 final. 

19 

 
 
 
 
 
 
 
 
 
 
 
 
                                                           
A.III.2. Revenue – value added tax (VAT) 
Number 

Objective 

Action 

49 

50 

51 

Fighting revenue 
fraud 

Legal framework 

Support  the  adoption  and  phasing-in  of  a  revamped 
VAT  system13,  under  which  cross-border  intra-EU 
transactions  will  be  taxed  in  the  customer’s  country, 
while  reporting  and  payment  of  VAT  is  carried  out  in 
the Member State of the supplier. 

Fighting revenue 
fraud 

Coordination, 
cooperation and 
processes 

Support  the  implementation  of  the  amendments  to  the 
Council  Regulation  on  administrative  cooperation  and 
combating fraud in the field of VAT (2010/904/EU), in 
particular  with 
to  data  exchanges  and 
cooperation  among  tax  authorities  and  Eurofisc  and 
with OLAF, Europol and the EPPO. 

regard 

Reinforce Eurofisc’s role in tackling cross-border VAT 
fraud,  particularly  by  making  better  use  of 
the 
information available within the network. 

Strengthen  the  international  exchange  of  best  practice. 
Based  on  Council  mandates,  strengthen  administrative 
co-operation  and  mutual  assistance  in  the  recovery  of 
VAT claims with non-EU countries. 

Fighting revenue 
fraud 
Coordination, 
cooperation and 
processes 

Lead service 

Due date 

TAXUD 

Continuous 

TAXUD, 
OLAF 

Continuous 

TAXUD 

Continuous 

13  Commission Proposal of 4 October 2017 for a Council Directive amending Directive 2006/112/EC as regards 
harmonising and simplifying certain rules in the value added tax system and introducing the definitive system 
for the taxation of trade between Member States, COM (2017) 569 final. 

20 

 
 
 
 
                                                           
 
 
B. 

Investigation 

B.I. European Public Prosecutor’s Office (EPPO) and PIF Directive14 
Number  Objective 

Action 

52 

53 

Coordination, 
cooperation 
and processes 

Coordination, 
cooperation 
and processes 

Support  the  setting-up  of  the  EPPO  and  provide  it  with 
administrative assistance in the start-up phase. 

Cooperation with the EPPO: 

The  Commission,  like  all  EU  institutions  and  bodies,  and 
national  competent  authorities,  must  without  undue  delay 
report  to  the  EPPO  any  criminal  conduct  in  respect  of 
which  it  could  exercise  its  competence  (Article  24  of 
Regulation  2017/193915).  To  comply  with  this  obligation 
by the time the EPPO becomes operational, services should 
have efficient procedures in place to carry out a preliminary 
evaluation of allegations reported to them. 

The  EPPO  Regulation  provides  that  EU  institutions  and 
bodies  may  make  use  of  OLAF  for  this  preliminary 
evaluation (Recital 51). Commission services and executive 
agencies  should  systematically  make  use  of  OLAF's 
expertise  as  a  final  quality  control  for  the  preliminary 
evaluation  of  allegations  and  put  in  place  the  necessary 
procedures for that to happen. 

Lead service 

Due date 

JUST / OLAF 

2019-2020 

Support: HR, 
BUDG, OIL 
All services 

Support: OLAF 

2020 and 
continuous 

54 

Legal 
framework 

Support  Member  States’  transposition  and  implementation 
of the PIF-Directive. 

JUST / OLAF 

2019 and 
then 
continuous 

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. Transposition 
deadline: 4 July 2019. 

15  Council  Regulation  (EU)  2017/1939  of  12  October  2017  implementing  enhanced  cooperation  on  the 

establishment of the European Public Prosecutor’s Office (‘the EPPO’), OJ L 283, 31.10.2017, p. 1. 

21 

 
 
 
 
                                                           
 
 
 
 
B.II. European Anti-Fraud Office (OLAF) 
Number  Objective 

Action 

Lead service 

Due date 

55 

Legal 
framework 

Negotiate the Commission's proposal for the review of the 
OLAF Regulation16 in order to: 

OLAF 

2019-2020 

o  adapt  how  OLAF  operates 
establishment of the EPPO; 
improve the effectiveness of OLAF’s investigative 
role; and 

following 

the 

o 

o  clarify and simplify the OLAF-Regulation. 

56 

Coordination, 
cooperation 
and processes 

Optimise  cooperation  between  services/other  EU  bodies 
and OLAF by, among other actions: 

o  defining  the  role  and  responsibilities  of  OLAF 

contact points in the various services; 

o  making  the  reporting  of  information  of  potential 
investigative  interest  more  efficient  through  direct 
channels between the services and OLAF;  

o 

o 

o  clarifying 

as 

the 

respective 
necessary 
responsibilities  of  OLAF  and  the  services  at  an 
operational level; 
improving  OLAF’s 
dismissal of cases reported by the services; 
reinforcing  cooperation  between 
shared 
the 
management DGs and OLAF to obtain information 
of  potential  investigative  interest  from  Member 
State authorities; and 

communication  on 

its 

2019 and 
then 
continuous 

All services 

Coordination: 
OLAF 

Support: SG, 
BUDG, 
partner DGs of 
other EU bodies 

o  encouraging the EEAS and other EU bodies to join 

such initiatives for better cooperation. 

57 

Legal 
framework  

Following thorough legal analysis, develop criteria for the 
scope of possible investigations in cases of budget support. 

OLAF / SJ 

2020 

Support: 
DEVCO, NEAR, 
ECFIN 

16  Commission  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  amending  Regulation 
(EU, Euratom) No 883/2013 concerning investigations conducted by the European Anti-Fraud Office (OLAF) 
as  regards  cooperation  with  the  European  Public  Prosecutor's  Office  and  the  effectiveness  of  OLAF 
investigations of 23 May 2018, COM (2018) 338. 

22 

 
 
 
 
                                                           
 
 
 
 
 
 
C. Corrective Measures and Sanctions; Follow-up of OLAF Recommendations 

Number  Objective 

Action 

Coordination, 
cooperation 
and processes 
Know-how 
and 
equipment 
Coordination, 
cooperation 
and processes 

Coordination, 
cooperation 
and processes 

Evaluate  and  optimise  the EDES,  including  cooperation 
between OLAF and other actors, in the light of the recent 
IAS audit. 

Integrate  information  about  how  to  consult  and  operate 
the EDES into corporate anti-fraud training. 

Apply  OLAF’s  "Instructions  on  drafting  Financial 
Recommendations  and  related  sections  of  the  Final 
Report"  and  "Guidelines  on  Financial  Monitoring"  and 
provide training if needed. 

Closely  monitor  Member  States’  follow-up  of  OLAF’s 
financial recommendations. 

Lead Service 

Due Date 

BUDG / OLAF 

2019 

OLAF 

Continuous 

Support: BUDG 

REGIO, EMPL, 
MARE, AGRI, 
HOME 

Continuous 

58 

59 

60 

61 

Coordination  for  the  purposes  of  systemic  follow-up  in 
the FPDNet and by the Corporate Management Board. 

OLAF 

Coordination, 
cooperation 
and processes 

follow-up  of  OLAF’s 
Closely  monitor  services’ 
administrative recommendations, to feed into the general 
monitoring  under 
the  Administrative  Arrangements 
between  the  Commission  and  OLAF  (see  Action  Point 
9). 

OLAF 

Continuous 

23 

 
 
 
 
 
 
 
 
D. Reporting on the Implementation of the CAFS 

Number  Objective 

Action 

62 

Data 
collection and 
analysis 

63 

Coordination, 
cooperation 
and processes 

Refine:  

o 

o 

o 

reporting  about  service-level  anti-fraud  strategies 
through the annual activity reports; 
the  contents  of  the  Annual  Management  and 
Performance  Report  with  regard  to  anti-fraud 
action; 
the role of other reporting channels; 

while  keeping  in  mind  that  documents  intended  for  the 
institutions  and  the  general  public  need  to  be  of  a 
reasonable length and easy to read. 
In close cooperation with the Commission's internal control 
and  ethics  functions,  develop  or  refine  result  and  impact 
indicators  for  the  CAFS  objectives,  including  measuring 
anti-fraud  awareness  among  staff.  Provide  advice  on  the 
indicators to be used for service-level anti-fraud strategies. 

Lead Service 

Due Date 

SG / BUDG/ 
OLAF 

2019-2020 

OLAF 

Support: SG/ 
BUDG/HR/JRC 

Preliminary 
result 
indicators for 
priority 
objectives by 
2020 

24