COMMISSION STAFF WORKING DOCUMENT Statistical evaluation of irregularities reported for 2021: own resources, agriculture, cohesion and fisheries policies, pre-accession and direct expenditure Accompanying the document COMMISSION REPORT TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 33rd Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2021
Date: 2022-09-23
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU statistics, EU strategy, activity report, coronavirus disease, epidemic, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.9.2022  SWD(2022) 307 final  COMMISSION STAFF WORKING DOCUMENT Statistical evaluation of irregularities reported for 2021: own resources, agriculture, cohesion and fisheries policies, pre-accession and direct expenditure Accompanying the document COMMISSION REPORT TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 33rd Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2021 {COM(2022) 482 final} - {SWD(2022) 302 final} - {SWD(2022) 303 final} - {SWD(2022) 304 final} - {SWD(2022) 305 final} - {SWD(2022) 306 final}  
 
 
CONTENTS 

LIST OF ABBREVIATIONS ............................................................................................. 4 

1. 

INTRODUCTION ....................................................................................................... 5 

1.1.  Scope of the document ...................................................................................... 5 
1.1.  Structure of the document ................................................................................. 5 

2.  TRADITIONAL OWN RESOURCES ....................................................................... 6 

EXECUTIVE SUMMARY ................................................................................................. 6 

Introduction ....................................................................................................... 7 
2.1. 
2.2.  General analysis –Trend analysis ...................................................................... 7 
2.2.1.  Reporting years 2017-2021 ................................................................. 7 
2.2.2.  OWNRES data vs TOR collection .................................................... 10 
2.2.3.  Recovery ............................................................................................ 12 
2.3.  Specific analysis .............................................................................................. 13 
2.3.1.  Cases reported as fraudulent .............................................................. 13 
2.3.2.  Cases reported as non-fraudulent ...................................................... 16 
2.3.3.  Fraudulent and non-fraudulent cases and COVID-19 related goods  19 
2.4.  Member States’ activities ................................................................................ 20 

2.4.1.  Classification  of  cases  as  fraudulent  and  non-fraudulent  and 

related rates ........................................................................................ 20 
2.4.2.  Recovery rates ................................................................................... 21 
2.4.3.  Commission’s monitoring ................................................................. 22 

3.  COMMON AGRICULTURAL POLICY ................................................................. 24 

EXECUTIVE SUMMARY ............................................................................................... 24 

3.2.1. 
3.2.2. 
3.2.3. 

3.1. 
Introduction ..................................................................................................... 26 
3.2.  General analysis .............................................................................................. 28 
Irregularities reported in the years 2017-2021 .................................. 28 
Irregularities reported as fraudulent .................................................. 28 
Irregularities not reported as fraudulent ............................................ 32 
3.3.  Specific analysis .............................................................................................. 35 
3.3.1.  Modus operandi ................................................................................. 35 
3.3.2.  Fraud  and  Irregularity  Detection  Rates  (FDR  and  IDR)  by  CAP 

components ........................................................................................ 43 
3.3.3.  Market measures – fraudulent and non-fraudulent irregularities ...... 43 
3.3.4.  Risk analysis and spontaneous reporting ........................................... 46 
3.4.  Anti-fraud work carried out by the Member States ......................................... 48 
3.4.1.  Duration of irregularities ................................................................... 49 
3.4.2.  Detection of irregularities reported as fraudulent by Member State . 49 
3.4.3.  Fraud and Irregularity Detection by sector and Member State ......... 51 
3.4.4.  Follow-up to suspected fraud ............................................................ 64 
3.5.  Recovery cases ................................................................................................ 66 

 
 
 
MAIN FINDINGS ............................................................................................................. 66 

4.  COHESION, FISHERIES AND OTHER INTERNAL POLICIES ......................... 72 

EXECUTIVE SUMMARY ............................................................................................... 72 

4.3.1. 
4.3.2. 

4.2.1. 
4.2.2. 
4.2.3. 

Introduction ..................................................................................................... 74 
4.1. 
4.2.  General analysis .............................................................................................. 75 
Irregularities reported as fraudulent .................................................. 75 
Irregularities not reported as fraudulent ............................................ 80 
Irregularities reported in relation to the PP 2014-2020: comparison 
with PP 2007-2013 ............................................................................ 81 
4.3.  Specific analysis ............................................................................................ 102 
Irregularities by area of the cohesion policy ................................... 102 
Irregularities by type ....................................................................... 126 
4.4.  Risk analysis and spontaneous reporting....................................................... 127 
4.5.  Antifraud and control activities by Member States ....................................... 129 
4.5.1.  Duration of irregularities ................................................................. 130 
4.5.2.  Detection of irregularities reported as fraudulent by Member State 131 
4.5.3.  Fraud detection rate ......................................................................... 133 
4.5.4. 
Irregularity detection rate ................................................................ 134 
4.5.5.  Follow-up to suspected fraud (programming period 2007-2013) ... 135 
4.6.  Other internal policies ................................................................................... 137 

MAIN FINDINGS ........................................................................................................... 139 

5.  PRE-ACCESSION POLICY................................................................................... 145 

EXECUTIVE SUMMARY ............................................................................................. 145 

5.1. 
5.2. 

Introduction ................................................................................................... 146 
Instruments for Pre-accession Assistance ..................................................... 146 
5.2.1.  Before 2007: Pre-accession Assistance (PAA) ............................... 146 
2007-2013: The Instrument for Pre-accession Assistance (IPA I) .. 146 
5.2.2. 
2014 – 2020: The Instrument for Pre-accession Assistance (IPA II)147 
5.2.3. 
2021  –  2027:  The  Instrument  for  Pre-accession  Assistance  (IPA 
5.2.4. 
III) .................................................................................................... 148 
5.3.  General analysis ............................................................................................ 148 
5.4.  Pre-accession Assistance (PAA 2000-2006) ................................................. 149 
5.4.1.  Recent trends ................................................................................... 149 
5.4.2.  Recent trends by component ........................................................... 150 
5.4.3.  Recent trends by beneficiary country .............................................. 150 
5.4.4.  Trends  since  the  start  of  PAA,  by  beneficiary  country  and 

5.5. 

component ....................................................................................... 151 
Instrument for Pre-Accession Assistance (IPA I, 2007-2013) ...................... 153 
5.5.1.  Recent trends ................................................................................... 153 
5.5.2.  Recent trends by component ........................................................... 153 
5.5.3.  Recent trends by beneficiary country .............................................. 154 
5.5.4.  Trends  since  the  start  of  IPA  I,  by  beneficiary  country  and 

component ....................................................................................... 154 

 
 
5.6. 

Instrument for Pre-accession Assistance II (IPA II 2014-2020) ................... 156 
5.6.1.  Recent trends ................................................................................... 156 
5.6.2.  Recent trends by component ........................................................... 156 
5.6.3.  Recent trends by beneficiary country .............................................. 157 
5.6.4.  Trends  since  the  start  of  IPA  II,  by  beneficiary  country  and 

component ....................................................................................... 157 

6.  DIRECT MANAGEMENT ..................................................................................... 158 

Introduction ................................................................................................... 158 
6.1. 
6.2.  General analysis ............................................................................................ 158 
6.2.1.  Five year analysis 2017-2021 .......................................................... 159 
6.3.  Specific analysis ............................................................................................ 160 
6.3.1.  Recoveries according policy areas .................................................. 160 
6.3.2.  Recoveries according to legal entity residence ............................... 160 
6.3.3.  Method of detection ......................................................................... 161 
6.3.4.  Types of irregularity ........................................................................ 162 
6.3.5.  Recovery .......................................................................................... 162 

COUNTRY FACTSHEETS ............................................................................................ 163 

Belgium - Belgique/België ...................................................................................... 163 
Bulgaria – България ............................................................................................... 164 
Czech Republic - Česká republika .......................................................................... 165 
Denmark – Danmark ............................................................................................... 166 
Germany – Deutschland .......................................................................................... 167 
Estonia – Eesti ......................................................................................................... 168 
Ireland – Éire ........................................................................................................... 169 
Greece – Ελλάδα ..................................................................................................... 170 
Spain – España ........................................................................................................ 171 
France ...................................................................................................................... 172 
Croatia – Hrvatska ................................................................................................... 173 
Italy – Italia ............................................................................................................. 174 
Cyprus – Κύπρος ..................................................................................................... 175 
Latvia – Latvija ....................................................................................................... 176 
Lithuania – Lietuva ................................................................................................. 177 
Luxembourg ............................................................................................................ 178 
Hungary - Magyarország ......................................................................................... 179 
Malta 180 
Netherlands - Nederland .......................................................................................... 181 
Austria – Österreich ................................................................................................ 182 
Poland – Polska ....................................................................................................... 183 
Portugal ................................................................................................................... 184 
Romania – România ................................................................................................ 185 
Slovenia – Slovenija ................................................................................................ 186 
Slovakia – Slovensko .............................................................................................. 187 
Finland – Suomi-Finland ......................................................................................... 188 

 
 
Sweden – Sverige .................................................................................................... 189 

ANNEXES ...................................................................................................................... 190 

 
 
 
 
LIST OF ABBREVIATIONS 

AMIF 
CAP 
CARDS 
CBC 
CF 
DA 
EAFRD 
EAGF 
EAGGF 
EFF 
EGF 
EMFF 
ERDF 
ESF 
ESIF 
FAL 
FDR 
FEAD 
FFL 
GUID 
HRD 
IDR 
IMS 
IPA 
IPARD 
ISF 
ISPA 
MM 
PAA 
PHARE 
PP 
RD 
REGD 
SA 
SAPARD 
TAIB 
TIPAA 
TOR 
YEI 

Asylum, Migration and Integration Fund 
Common Agricultural Policy 
Community Assistance for Reconstruction, Development and Stabilisation 
Cross-Border Cooperation 
Cohesion Fund 
Direct payments to farmers 
European Agricultural Fund for Rural Development 
European Agricultural Guarantee Fund 
European Agricultural Guidance and Guarantee Fund 
European Fisheries Fund 
European Globalisation Adjustment Fund 
European Maritime and Fisheries Fund 
European Regional Development Fund 
European Social Fund 
European Structural and Investment Funds 
Fraud Amount Level 
Fraud Detection Rate 
Fund for European Aid to the Most Deprived 
Fraud Frequency Level 
European Agricultural Guarantee and Guidance Fund – Section Guidance 
Pre-accession, Human Resources Development component 
Irregularities Detection Rate 
Irregularity Management System 
Instrument for Pre-accession Assistance 
Instrument for Pre-Accession Assistance for Rural Development 
Internal Security Fund 
Instrument for Structural Policies for Pre-Accession 
Market Support Measures 
Pre-Accession Assistance 2000-2006 
Pre-accession assistance programme 
Programming period 
Rural Development 
Pre-accession, Regional Development component 
Direct Support to Agriculture 
Special Accession Programme for Agricultural and Rural Development 
Transition Assistance and Institution Building 
Turkey Instrument for Pre-accession Assistance 
Traditional Own Resources 
Youth Employment Initiative 

4 

 
 
INTRODUCTION 

1. 

INTRODUCTION 

Scope of the document 

1.1. 
This document1 presents a statistical evaluation of the irregularities and fraud detected by the 
Member States during 2021, in the context of past  years and relevant programming periods 
(PP).  It  covers  both  the  revenue  and  expenditure  sides  of  the  EU  budget.  This  analysis  is 
based  on  the  notifications  provided  by  national  authorities  of  cases  of  irregularities  and 
suspected or established fraud. Their reporting is performed in fulfilment of a legal obligation 
enshrined  in  sectoral  European  legislation.  The  document  accompanies  the  Annual  Report 
adopted on the basis of article 325(5) of the Treaty on the Functioning of the European Union 
(TFEU),  according  to  which  “The  Commission,  in  cooperation  with  Member  States,  shall 
each year submit to the European Parliament and to the Council a report on the measures 
taken for the implementation of this article”. Therefore, this document should be regarded as 
an analysis of the achievements of the Member States, in terms of detection and reporting. 

The methodology (including the definition of terms and indicators), the data sources and the 
data  capture  systems  are  explained  in  detail  in  the  Commission  Staff  Working  Document  – 
Methodology for the Statistical Evaluation of Irregularities accompanying the Annual Report 
on the Protection of the EU financial interests for the year 20152. 

1.1. 

Structure of the document 

The  present  document  includes  an  analysis  of  the  irregularities  reported  in  the  area  of 
traditional  own  resources  (revenue),  as  well  as  an  analysis  of  the  irregularities  reported  for 
expenditure  (Common  Agricultural  Policy,  cohesion  policy,  fisheries  and  other  internal 
policies; the pre-accession policy and direct management). 

The  document  is  completed  by  27  country  factsheets,  which  summarise,  for  each  Member 
State, the main indicators and information on the detection of irregularities and fraud. 

Several  annexes  complement  the  information  and  data,  providing  a  global  overview  of  the 
irregularities reported according to the relevant sector regulations. Annexes 1 to 11 concern 
Traditional Own Resources, Annexes 12 to 14 complement information on the methodology 
for the analysis of irregularities concerning expenditure, Annex 15 covers all the expenditure 
sectors  for  which  Member  States  and  beneficiary  countries  have  a  reporting  obligation.

1 This document does not represent an official position of the Commission. 
2 SWD(2016)237final 
 http://ec.europa.eu/anti-fraud/sites/antifraud/files/methodology_statistical_evaluation_2015_en.pdf 

5 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

2. 

TRADITIONAL OWN RESOURCES 

EXECUTIVE SUMMARY 

In 2021, the COVID-19 pandemic continued to affect the lives of all individuals and businesses 
in the EU. Looking back, in 2020 the pandemic was experienced as an emergency, while in 2021 
it became part and parcel of life. Import figures for 2021 are proof of this. After the sharp 11.6% 
decrease in EU-27 imports in 2020, they increased by 23% in 2021.  

In  2021,  the  number  of  fraudulent  and  non-fraudulent  irregularities  related  to  TOR  remained 
quite stable, the related amount of TOR increased and was the highest  amount detected during 
the  last  5  years.  For  both  fraudulent  and  non-fraudulent  irregularities,  the  amount  of  TOR 
detected increased compared to the five-year average, by 32% and 13% respectively. In total, the 
TOR amount increased by 18% in 2021 compared to the average for 2017-2021. 

In  comparison,  the  number  of  fraudulent  and  non-fraudulent  irregularities  related  to  TOR 
decreased  by  3%  compared  to  the  five-year  average.  The  number  of  fraudulent  irregularities 
increased by 1 % and non-fraudulent irregularities decreased by 4%.  

Of  all  fraudulent  and  non-fraudulent  irregularities  detected  in  2021,  12%  were  classified  as 
fraudulent.   

National  anti-fraud  services,  together  with  customs  release  controls,  played  a  key  role  in 
detecting fraudulent irregularities in 2021. Inspections by anti-fraud services, the most successful 
method  way  of  detecting  fraudulent  irregularities,  surpassed  post-release  controls  and  release 
controls in detecting fraudulent duty evasion.  

Non-fraudulent irregularities were primarily detected by means of post-release controls.  

Most cases reported in 2021 as fraudulent and non-fraudulent related to undervaluation, incorrect 
origin or classification/misdescription of goods. Smuggling remains one of the main fraudulent 
irregularities.  Textiles,  electrical  machinery  and  equipment  were  the  types  of  goods  most 
affected  by  fraud  and  irregularities  in  number  of  cases  and  in  monetary  terms,  followed  by 
miscellaneous chemical products, footwear and tobacco most affected in terms of amounts and 
by vehicles and plastics in terms of number of cases. In 2021 China remained the most important 
country of origin of goods affected by irregularities reported as fraudulent or non-fraudulent. 

For  COVID-19-related  goods,  in  2021,  a  notable  increase  in  the  amounts  reported  as  irregular 
was observed for goods such as disinfectants and sterilisation products, protective garments and 
medical  consumables.  However,  analysis  shows  that  the  impact  of  irregularities  affecting 
COVID-19-related  goods  remained  relatively  low  in  2021  (4%  of  the  total  number  of 
irregularities reported in 2021 and 6% of the related amounts). 

In 2021, the Commission continued, on-the-spot or remotely, its monitoring and control visits to 
ensure  the  correct  application  of  EU  customs  and  TOR  legislation.  Where  cooperation  and 
progress made in tackling outstanding issues are considered insufficient, corrective measures are 
being applied.  

As  the  2020  PIF  report  states,  such  corrective  measures  have  already  been  applied  by  the 
Commission against the UK for undervalued textiles and footwear from China (Snapshot 1). On 
8  March  2022,  the  CJEU  issued  its  ruling  in  related  Case  C-213/19  against  the  UK.  The 
Commission is in the process of analysing the implications of that CJEU ruling both for the UK 
(e.g. re-calculation of TOR losses) and for the Member States.  

The  Commission  also  quantified  potential  TOR  losses  with  regard  to  the  evasion  of  anti-
dumping duties for solar panels and informed the EU Member States concerned. 

6 

 
TRADITIONAL OWN RESOURCES 

2.1. 

Introduction 

The  technical  explanations  and  the  statistical  approach  are  explained  in  the  accompanying 
document ‘Methodology regarding the statistical evaluation of reported irregularities for 2015’3. 
In summary, the statistics for the 2021 PIF report were prepared based on the  total established 
and  estimated  amount  of  TOR  as  reported  in  OWNRES.  Recovery  figures  are  based  only  on 
established amounts.  

For comparability with previous years, the analysis for this report was carried out based on the 
figures obtained for the EU of 27 Member States4. The UK figures can nevertheless be found in 
the annexes.  

The following analysis, based on the data available on the cut-off date (15 March 2022), aims to 
provide an overview of the reported cases of fraud and irregularities reported for  2021 together 
with their financial impact. 

2.2. 

General analysis –Trend analysis 

2.2.1.  Reporting years 2017-2021 

The number of cases reported in OWNRES for 2021 (3 988) is about 3 % lower than the average 
number of cases of irregularities reported for the 2017-2021 period (4 131). 

The total estimated and established amount of TOR involved (EUR 524 million) is about 18 % 
higher  than  the  average  estimated  and  established  amount  for  the  years  2017-2021  (EUR  443 
million). 
In 2021, eight big5 cases for a total amount of about EUR 122 million6 were reported compared 
to  2020,  when  five  big  cases  for  a  total  amount  of  about  EUR  67  million  affected  the  total 
estimated and established amount. 

3   In September 2019, the reporting rules were clarified and updated.  
4   The UK left the EU on 31 January 2020 and is no longer a Member State. Also since 1 January 2021, the UK (except 
Northern  Ireland)  is  no  longer  part  of  the  internal  market  and  customs  union  as  agreed  in  the  UK–EU  Withdrawal 
Agreement. 

5  Cases involving an amount of TOR exceeding EUR 10 million. 
6   The  Netherlands  (4  cases  –  EUR  76  million),  Belgium  (2  cases  –  EUR  25  million),  Germany  (1  case  –  EUR  11 

million) and Spain (1 case – EUR 10 million). 

7 

 
                                                           
TRADITIONAL OWN RESOURCES 

CHART TOR1: Total number of OWNRES cases and the related estimated and established amount (2017-2021) 

Annex 1 of the summary tables shows the situation on the cut-off date (15 March 2022) for the 
years 2017-2021. 

2.2.1.1.  Irregularities reported as fraudulent 

The number of cases reported as fraudulent registered in OWNRES for 2021 (482) is currently 
1% higher than the average number of cases reported for the 2017-2021 period (478). 

The  total  estimated  and  established  amount  of  TOR  involved  (EUR 157 million)  represents  an 
increase  of  32%  of  the  average  estimated  and  established  amount  for  the  years  2017-2021- 
(EUR 119 million).  

For 2021, Luxemburg, Finland and Sweden did not communicate any fraudulent case exceeding 
an amount of EUR 10 000. 

CHART TOR2: OWNRES cases reported as fraudulent and the related estimated and established amount (2017-2021) 

8 

 
 
 
TRADITIONAL OWN RESOURCES 

On  the  cut-off  date  (15  March  2022),  12%  of  all  cases  detected  in  2021  were  classified  as 
fraudulent. The percentage had remained stable since 2020 (12%). 

Annex 2 of the summary tables shows the situation on the cut-off date for the years 2017-2021. 

2.2.1.2.   Irregularities not reported as fraudulent 

At the same time, the number of cases not reported as fraudulent communicated via OWNRES 
for 2021 (3 506) was 4% lower than the average number reported for 2017-2021 (3 653). 

The total estimated and established amount of TOR (EUR 367 million) was 13% higher than the 
average estimated and established amount for the years 2017-2021 (EUR 324 million). 

Cyprus did not report any case of irregularity exceeding an amount of EUR 10 000 for 2021. 

CHART TOR3: OWNRES cases not reported as fraudulent and the related estimated and established amount (2017-2021) 

Annex 3 of the summary tables shows the situation on the cut-off date for years 2017-2021. 

2.2.2.  OWNRES data vs TOR collection  

In 2021, the total established amount of TOR (gross) was EUR 25.2 billion and about 98% was 
duly recovered and made available to the Commission through the A-account7. According to the 
OWNRES  data,  around  EUR  524  million  has  been  established  or  estimated  by  the  Member 
States in connection with cases reported as fraudulent/non-fraudulent where the amount at stake 
exceeds EUR 10 000. 

The  total  estimated  and  established  amount  reported  in  OWNRES  represents  2.11%  of  total 
collected  TOR  (gross)  amount  in  20218.  This  detection  rate  has  increased  compared  to  2020, 
when  it  was  1.95%9.  A  percentage  of  2.11 %  indicates  that  of  every  EUR  100  of  TOR  (gross) 
established and collected, an amount of EUR 2.11 is registered as irregular (fraudulent or non-
fraudulent)  in  OWNRES.  There  are  differences  among  the  Member  States.  In  eight  Member 
States10, the percentage is above the average of 2.11 %. The highest percentages for 2021 can be 

7   These are provisional figures available as of 15 March 2022. They might be changed in the final financial accounts. 
8   See Annex 4. 
9   On the cut-off date for the 2020 PIF report. 
10   Belgium, Greece, Spain, Latvia, Lithuania, the Netherlands, Austria and Finland. 

9 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

seen  in  Finland,  Latvia,  Greece,  the  Netherlands  and  Belgium,  with  5.38 %,  4.88 %,  4.38 %, 
4.34 % and 3.8 % respectively.  
For  the  seven  Member  States11  that  established  and  made  available  most  TOR  amounts,  the 
average percentage of the estimated  and  established OWNRES amounts  of TOR for 2021 was 
equal  to  2.28%.  Compared  to  the  previous  year  (1.91%),  this  represents  an  increase  of  0.37%. 
For  the  Netherlands,  the  proportion  of  estimated  and  established  OWNRES  amounts  of  TOR 
increased in 2021 from 0.79% to 4.34% compared to 2020, while for Belgium, Spain and Italy, it 
increased  by  1.46%,  0.72%  and  0.28%  respectively.  For  the  other  three  Member  States12,  the 
average proportion of estimated and established OWNRES amounts of TOR decreased in 2021 
(1.27 %) compared to the previous year (2.64%). 

TOR MAP1: Showing the percentage of estimated and established amount in OWNRES of established TOR for 2021  

2.2.2.1.   Detection rates in the COVID year 2021 

Whereas  the  variation  in  the  total  number  of  cases  reported  as  fraudulent  or  non-fraudulent  in 
2021  was  within  the  usual  range  of  the  annual  fluctuation,  the  related  amounts  increased 
considerably in 2021, leading to a higher overall detection rate in 2021 than in 2020. 

11   Belgium, Germany, Spain, France, Italy, the Netherlands and Poland.  
12   Germany, France and Poland. 

10 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

Chart TOR4 shows the variation in the annual detection rate13 for each Member State in 2017-
2021. Bearing in mind that a number of variable factors can affect national detection rates and 
that customs controls had to be performed under pandemic conditions in many cases in 2021, the 
overall  detection  rate  was  still  the  second  highest  in  2021  during  the  last  5  years.  The  2021 
detection  rates14  for  Belgium,  Greece,  Spain,  Latvia,  Lithuania,  the  Netherlands,  Austria  and 
Finland were above the EU average. This makes it hard to say how much the detection rates are 
affected by the pandemic, changes in import volumes, fraud patterns or national customs control 
strategies. 

Chart TOR4: Detection rates 2017-2021 per Member State  

2.2.3.  Recovery 

The  cases  of  fraud  and  irregularities  detected  in  2021  correspond  to  an  established  amount  of 
EUR 479 million15. Nearly EUR 216 million of this was recovered in cases where there was an 
irregularity  and  EUR 24 million  in  fraudulent  cases16.  In  total  EUR 240 million  was  recovered 
by all Member States for all cases detected in 2021. In absolute figures, Germany recovered the 
highest  amount  in  2021  (EUR  74  million),  followed  by  Spain  (EUR  47  million)  and  the 
Netherlands (EUR 43 million). This is a starting point for recovery. Analysis shows that lengthy 
recovery  procedures  spread  over  several  years  are  usually  required  due  to  administrative  and 
judicial procedures in complex cases or cases with a huge financial impact.  

Member States also continued their recovery actions for the detected cases of previous years. 

13  Ratio of the total established and estimated amount in  OWNRES to the total gross TOR collected. Data  available on 

cut-off date of 15.3.2022. 

14   Individual bigger cases detected in a specific year may affect annual rates significantly. The detection rates can also be 
affected by the way a Member State’s customs control strategy is set up to target risky imports and detect TOR-related 
fraud and irregularities. 

15   See Annex 5. The estimated amounts are excluded. 
16   See Annex 10. 

11 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

2.2.3.1.   Recovery rates 

Over  the  past  5  years  the  annual  recovery  rate  has  varied  between  50%  and  77%  (CHART 
TOR5). The recovery rate for cases reported in 2021 is currently 50%17. In other words, out of 
every  amount  over  EUR  10 000  of  duties  established  and  reported  for  2021  in  OWNRES  as 
irregular/fraudulent, approximately EUR 5 000 has already been recovered. 

CHART TOR5: Annual recovery rates (2017-2021) 

The overall recovery rate is a correlation between the detection, the established amount and the 
current  recovery  stage  of  individual  cases  (high  additional  duty  claims  are  more  frequently 
associated with lengthy administrative and criminal procedures).  

Recovery rates vary among the Member States. In seven Member States, the entire established 
amount has already been recovered18 and in another four Member States the recovery rates are 
above  90%.  In  Czechia  the  recovery  rate  is  99%,  in  Denmark  99%,  in  Germany  96%  and  in 
Sweden 95%. Differences in  recovery rates may  be due to  factors such as the type of fraud or 
irregularity, or the type of debtor involved. Because recovery is ongoing, it can be expected that 
the recovery rate for 2021 will also go up in the future.  

On the cut-off date (15 March 2022), the overall recovery rate for all years 1989-2021 was 64%.   

2.3. 

Specific analysis 

2.3.1.  Cases reported as fraudulent 

2.3.1.1.   Modus operandi 

A  breakdown  by  type  of  fraud  shows  that  most  fraudulent  cases  in  2021  relate  to  incorrect 
declarations  (incorrect  classification,  value,  country  of  origin  or  use  of  preferential 
arrangements) and formal shortcomings (e.g. failure to observe customs procedures). Smuggling 
as a fraud mechanism ranked second place in 2021. 

In  2021,  the  customs  procedure  ‘release  for  free  circulation’  remained  the  procedure  most 
vulnerable  to  fraud  (71%  of  the  number  of  cases  and  81%  of  the  estimated  and  established 
amount)19.  A  total  of  10%  of  all  cases  reported  as  fraudulent  and  12%  of  all  estimated  and 
established amounts in OWNRES cases registered as fraudulent for 2021  fall into the category 
‘Other’20,  whereas  14%  of  all  cases  reported  as  fraudulent  and  4%  of  all  estimated  and 
established amounts involve the customs warehouse procedure.  

17   See Annex 5. 
18   Estonia, Croatia, Cyprus, Luxembourg, Malta, Slovakia and Finland. 
19   See Annexes 6 and 7. 
20   The  category  ‘Other’  combines,  among  others,  the  following  procedures  or  treatments:  processing  under  customs 
control,  temporary  admission,  outward  processing  and  the  standard  exchange  system,  exportation,  free  zone  or  free 
warehousing, re-exportation, destruction and abandonment to the Exchequer. 

12 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

Of all cases reported as fraudulent, about 76% concern goods such as tobacco, vehicles, textiles, 
footwear,  meat  and  meat  products,  articles  of  leather,  iron,  steel  and  aluminium.  In  monetary 
terms, these groups of goods represent about 93% of all amounts estimated and established for 
cases  reported  as  fraudulent.  China,  Brazil,  the  United  Arab  Emirates,  Belarus,  Turkey,  the 
United  States  and  Russia  are  the  main  –  in  monetary  terms  –  reported  countries  of  origin  of 
goods affected by fraud. 

2.3.1.2.   Method of detection of fraudulent cases 
In 202121, inspections by anti-fraud services (38%) and customs controls carried out at the time 
of  the  release  of  goods  (37%)  were  the  most  successful  way  of  detecting  fraudulent  cases, 
followed by post-release controls (19%). 

CHART TOR6: Method of detection 2021 – Cases reported as fraudulent – by number of cases 

In  monetary  terms,  of  the  fraudulent  cases  registered  for  2021,  involving  EUR  157  million  in 
estimated or established amounts, around 60% were detected during an inspection by anti-fraud 
services, 24% during a post-release control and 13 % during a control at the time of the release of 
the goods.  

21   See Annexes 8 and 9. 

13 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

CHART TOR6: Method of detection 2021 – Cases reported as fraudulent – by estimated and established amount 

In  six  Member  States,  more  than  50%  of  all  estimated  and  established  amounts  in  fraudulent 
cases  were  detected  by  anti-fraud  services22.  As  regards  amounts,  controls  at  the  time  of  the 
release  of  goods  were  the  method  most  used  to  detect  fraud  in  Czechia,  Denmark,  Estonia, 
Greece,  Croatia,  Latvia,  Austria,  Poland,  Slovenia  and  Slovakia,  whereas  post-release  controls 
were the method most used in Bulgaria, Spain, Cyprus, Hungary, the Netherlands and Portugal. 

In  Denmark,  48%  of  all  estimated  and  established  amounts  in  fraudulent  cases  were  declared 
voluntarily. 

2.3.1.3.   Smuggled cigarettes 
In  2021,  there  were  115  cases  of  smuggled  cigarettes  registered  (CN  code23  24  02  20  90) 
involving estimated TOR of around EUR 30 million. In 2020, the number of cases of smuggled 
cigarettes was 124, totalling around EUR 21 million of TOR. 

The  highest  number  of  cases  was  reported  by  Lithuania  (46),  Poland  (18)  Belgium  (11),  and 
France  (10).  The  highest  amount  was  reported  by  Greece  (EUR 9  million)  and  Italy 
(EUR 8 million), followed by Belgium (EUR 5  million). No cases were reported by 14 Member 
States24. 

22   Belgium, Germany, Ireland, Italy, Lithuania and Romania. 
23   Combined nomenclature or CN – nomenclature of the Common Customs Tariff. 
24   Czechia, Ireland, Spain, Croatia, Cyprus, Luxembourg, Hungary, Malta, the Netherlands, Austria, Portugal, Slovenia, 

Finland and Sweden. 

14 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

Table TOR1: Cases of smuggled cigarettes in 2021 

2.3.1.4.   Textiles 

In 2021, textiles were the goods most vulnerable to fraudulent irregularities in monetary terms. 
In total 65 cases were reported, amounting to EUR 42 million. Undervaluation was the main type 
of irregularity. France, Bulgaria and Belgium were particularly affected by fraud, with five other 
Member States only marginally affected. Anti-fraud services detected most of the cases. 

2.3.1.5.   Cases reported as fraudulent by amount  

In 2021, the estimated and established amount was below EUR 100 000 in 345 cases reported as 
fraudulent (72% of all fraud cases), whereas it was above EUR 100 000 in 137 cases (28%). 

The total estimated and established amount in cases reported as fraudulent, where the amount at 
stake was above EUR 100 000, was EUR 147 million (94% of the total estimated and established 
amount for cases reported as fraudulent). 

Table TOR2: Cases reported as fraudulent by amount category in 2021 

2.3.2.  Cases reported as non-fraudulent 

2.3.2.1.  Working method 

to 
A  breakdown  of 
classification/misdescription.  Incorrect  value,  incorrect  use  of  preferential  arrangements,  and 
irregularities related to the transit procedure are also frequently mentioned.  

that  most  cases  of 

fraud  by 

shows 

relate 

fraud 

type 

15 

 
 
 
TRADITIONAL OWN RESOURCES 

Not  all  customs  procedures  are  equally  vulnerable  to  irregularities;  their  vulnerability  may 
change  over  time  as  certain  economic  sectors  are  briefly  targeted.  The  customs  procedure 
‘release  for  free  circulation’  is  the  customs  procedure  most  affected  by  irregularities.  This  is 
because  at  the  time  of  release  for  free  circulation,  non-compliance  in  the  customs  declaration 
may relate to a large number of irregularities, e.g. the tariff, the CN code, (preferential) origin, 
incorrect value, etc. On the other hand, in customs suspension procedures (such as warehousing, 
transit, inward processing, etc. – where the payment of duties is suspended) the sole irregularity 
that  might  occur  is  the  subtraction  of  the  goods  in  question  from  customs  supervision.  It  is 
therefore  normal,  and  to  be  expected,  that  most  fraud  and  irregularities  are  reported  in 
connection with the procedure ‘release for free circulation’. 

In 2021 most of the estimated and established amounts in OWNRES for cases reported as non-
fraudulent related to the customs procedure ‘release for free circulation’ (84%)25. A total of 6% 
of all estimated and established amounts in OWNRES registered as non-fraudulent for 2021 fall 
into the category ‘Other’26.  

Of  all  cases  reported  as  non-fraudulent,  about  60%  concern  textiles,  electrical  machinery  and 
equipment, vehicles, plastics, textiles, mechanical machinery and appliances, articles of iron and 
steel,  footwear,  organic  chemicals  and  chemical  products.  In  monetary  terms  these  groups  of 
goods  represent  about  73%  of  all  amounts  estimated  or  established  for  cases  reported  as  non-
fraudulent. China, the United States, Japan, India, Russia, Turkey and Taiwan are – in monetary 
terms – the main reported countries of origin of goods affected by irregularities. 

2.3.2.2.   Method of detection of non-fraudulent cases 

In  2021,  most  non-fraudulent  cases  (55%)  were  detected  during  post-release  customs  controls. 
Other frequently used methods of detection of non-fraudulent cases were release controls (20%), 
voluntary admission (13%), inspections by anti-fraud services (5%) and tax audits (5%).27 

25   See Annexes 6 and 7. 
26   The  category  ‘Other’  combines,  among  others,  the  following  procedures  or  treatments:  processing  under  customs 
control, temporary admission, outward processing and  the standard exchange system, exportation, a free zone or free 
warehousing, re-exportation, destruction and abandonment to the Exchequer. 

27   See Annexes 8 and 9. 

16 

 
                                                           
TRADITIONAL OWN RESOURCES 

CHART TOR8: Method of detection 2021 – Cases not reported as fraudulent – by number of cases 

As regards the estimated or established amounts, around 55% of all irregularities not reported as 
fraudulent registered for 2021 were detected during a post-release control, 19% during a control 
at the time of the release of the goods, 12% by voluntary admission, 9% during a tax audit and 
5% during an inspection by anti-fraud services. 

CHART TOR9: Method of detection 2021 – Cases not reported as fraudulent – by estimated and established amounts 

17 

 
 
 
TRADITIONAL OWN RESOURCES 

In 13 Member States, more than 50% of all non-fraudulent cases — in amounts — were detected 
during  post-release  controls28,  whereas  in  Belgium,  Denmark,  Luxembourg  and  Slovakia  they 
were detected during release controls.  In Greece, Portugal  and Romania more than 50% of the 
amounts relating to non-fraudulent cases were detected by anti-fraud services. In Finland, 69% 
of all amounts reported in non-fraudulent cases were reported as voluntary admission. 

In thirteen Member States voluntary admission was mentioned as a method of detection of cases 
reported as non-fraudulent29, with the highest amounts reported by Germany (EUR 15 million), 
Finland (EUR 8 million) and Spain (EUR 7 million). 

2.3.2.3.   Electrical machinery and equipment vulnerable to irregularities  

In 2021, electrical machinery and equipment (mostly solar panels) were more vulnerable to non-
fraudulent  reported  irregularities  in  monetary  terms  than  other  goods.  About  18%  (EUR  66 
million)  of  the  total  amount  established  in  non-fraudulent  irregularities  concerned  this  type  of 
good. Of 18 Member States, the Netherlands reported the highest figure (63 cases totalling EUR 
45 million). Incorrect classification/misdescription and incorrect value were the prevailing types 
of  irregularity.  Post-release  controls  were  the  most  frequent  type  of  check  leading  to  the 
detection of irregularities in declarations of imported goods. 

2.3.2.4.   Cases not reported as fraudulent by amount 

In 2021, the estimated and established amount was below EUR 100 000 in 3 088 non-fraudulent 
cases (88%), whereas it was above EUR 100 000 in 418 cases (12%). 

The  total  estimated  and  established  amount  in  non-fraudulent  cases  where  the  amount  at  stake 
was  above  EUR  100 000  amounted  to  EUR  286  million  (78%  of  the  total  estimated  and 
established amount for non-fraudulent cases). 

Table TOR3: Cases not reported as fraudulent by amount category in 2021 

2.3.3.  Fraudulent and non-fraudulent cases and COVID-19 related goods 

In 2021, imports of COVID-19-related goods continued to increase compared to 2019, but more 
slowly than in 2020.  

Analysis of the fraudulent and non-fraudulent irregularities detected in connection with COVID-
19  related-goods30  over  the  2017-2021  period  shows  that  the  total  number  of  cases  (191) 
detected in 2021 was only 6% higher than the average for the last 5 years (181). However, the 
related TOR amount (EUR 31 million) doubled in 2021 compared to the average for the  years 
2017-2021 (EUR 15 million).  

28   Bulgaria,  Czechia,  Estonia,  Ireland,  Croatia,  Lithuania,  Hungary,  Malta,  the  Netherlands,  Austria,  Poland,  Slovenia 

and Sweden. 

29   Belgium, Czechia, Denmark, Germany, Ireland, Spain, France, Latvia, the Netherlands, Austria, Slovakia, Finland and 

Sweden. 

30   Not all imports of COVID-19-related goods are within the scope of Commission Decision (EU) 2021/491 of 3 April 

2021. 

18 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

The  impact  of  irregularities  affecting  COVID-19-related  goods,  typically  low,  remained 
relatively low in 2021 (5% of the total number of irregularities reported in 2021 and 6% of the 
related amounts). 

CHART TOR10: Cases related to COVID-19 goods reported as irregular and the related estimated and established amount 
(2017-2021) 

Germany  reported  the  highest  number  of  cases  (77).  Belgium  and  Finland  reported  related 
amounts of EUR 9.5 million and EUR 8 million respectively. Thirteen other Member States were 
concerned to a lesser extent. The predominant types of working method were incorrect value and 
classification/misdescription. Errors in estimating customs duties were also found.  

A notable increase in the amounts reported as irregular was observed in  2021, in particular for 
goods  such  as  protective  garments  (gloves,  boot  covers,  overshoes  etc.),  disinfectants  and 
sterilisation products and medical consumables. 

CHART TOR11: Cases related to COVID-19 goods reported as irregular and the related estimated and established amount 
(2019-2021) 

19 

 
 
 
TRADITIONAL OWN RESOURCES 

2.4. 

Member States’ activities 

2.4.1.  Classification of cases as fraudulent and non-fraudulent and related rates 

For 2021, Member States reported 482 cases as fraudulent out of a total of3 988 cases reported in 
OWNRES, indicating a fraud frequency level (FFL) of 12%. The differences between Member 
States are relatively large. In 2021, 11 Member States categorised between 10% and 50% of all 
cases  reported  as  fraudulent.  However,  Luxembourg,  Malta,  Finland  and  Sweden  did  not 
categorise any cases reported as fraudulent. Eight Member States categorised less than 10% of 
cases as fraudulent31. Four Member States registered more than 50%32 of cases as fraudulent. 

In  2021,  the  total  estimated  and  established  amount  affected  by  fraud  in  the  EU  was 
EUR 157 million  and  the  overall  incidence  of  fraud33  was  0.63%.  For  2021,  the  highest 
percentages are in Greece (3.5%), Belgium (3.3%) and Lithuania (2.34%)34.  

The  total  estimated  and  established  amount  affected  by  cases  not  reported  as  fraudulent  was 
nearly  EUR  367  million,  indicating  a  non-fraudulent  irregularity  incidence35  of  1.48%.  The 
highest percentages are in Finland (5.85%), the Netherlands (3.98%), Latvia (3.56%) and Spain 
(2.15%)36. 

There  are  large  differences  between  Member  States’  classifications,  partly  due  to  their 
classification practices. This can affect the comparison of the amounts involved in cases reported 
as  fraudulent  and  as  non-fraudulent  by  Member  States.  Moreover,  individual  bigger  cases 
detected  in  a  specific  year  may  significantly  affect  annual  rates.  Factors  such  as  the  type  of 
traffic,  type  of  trade,  economic  operators’  level  of  compliance,  and  a  Member  State’s  location 
can significantly affect the rates. Bearing these in mind these, the rates of incidence can also be 
affected by how a Member State’s customs control strategy is set up to target risky imports and 
detect TOR-related fraud and irregularities. 

2.4.2.  Recovery rates 

2.4.2.1.   Cases reported as fraudulent 

Over the 1989-2021 period, OWNRES shows that, on average, 22% of the initially established 
amount was corrected (cancelled). The recovery rate for all years (1989-2021) is 40%37. The rate 
for  cases  reported  as  fraudulent  and  detected  in  2021  is  20%38.  The  rate  for  cases  reported  as 
fraudulent is in general much lower than for cases not reported as fraudulent. 

2.4.2.2.   Cases not reported as fraudulent 

OWNRES  shows  that  on  the  cut-off  date,  on  average  27%  (1989-2021)  of  the  initially 
established amount in relation to cases not reported as fraudulent has been corrected (cancelled) 
since 1989. The recovery rate for non-fraudulent cases reported for 2021 is 60%39. On the cut-off 

31   Czechia (2%), Denmark (6 %), Germany (4 %), Ireland (4%), Spain (6%), Hungary (4 %), the Netherlands (1 %) and 

Austria (7 %). 

32   Bulgaria (93 %), Estonia (89 %), Cyprus (100%) and Lithuania (68 %).  
33   The percentage that the total established and estimated amounts related to fraudulent cases represent of the total TOR 

collected by Member States. 

34   See Annex 4. 
35   The percentage that the total established and estimated amounts related to non-fraudulent cases represent of the total 

TOR collected by Member States. 

36  See Annex 4. 
37   This  calculation  is  based  on  19 313  cases  reported  by  the  EU-27,  an  established  amount  of  EUR  2  89  billion  (after 

corrections already processed) and a recovered amount of EUR 1.16 billion. 

38  See Annex 10. 
39   See Annex 10. 

20 

 
                                                           
TRADITIONAL OWN RESOURCES 

date, the annual recovery rate for the last 5 years had varied between 60% and 88%. The overall 
recovery rate for all years (1989-2021) for all cases not reported as fraudulent is 76%40. 

2.4.2.3.   Historical recovery rate (HRR) 
The HRR41 confirms that in the long term, recovery in cases reported as fraudulent is generally 
much less successful than in cases not reported as fraudulent (Table TOR4). Classification of a 
case  as  fraudulent  is  therefore  a  strong  indicator  for  forecasting  short-  and  long-term  recovery 
rates. 

Table TOR4: Historical recovery rate (HRR) 

2.4.3.  Commission’s monitoring 

2.4.3.1.   Examination of the write-off reports 

In 2021, 26 new write-off reports were submitted to the Commission by 9 Member States. The 
Commission  assessed  103  cases  totalling  EUR  54.8  million  in  2021.  In  65  of  these  cases, 
amounting  to  EUR  22.5 million42,  the  Commission's  view  was  that  the  Member  States  did  not 
demonstrate satisfactorily that the TOR were lost for reasons not imputable to them, so they were 
considered financially responsible for the loss. Late payment interest totalling EUR 46 million is 
also due. 

Examination of Member States’ diligence in write-off cases is a very effective way of gauging 
their recovery activity. It encourages national administrations to step up the regularity, efficiency 
and  effectiveness  of  their  recovery  activity,  since  any  lack  of  diligence  leading  to  failure  to 
recover results in individual Member States having to foot the bill. 

2.4.3.2.   Commission’s inspections 

In its TOR inspections, the Commission focused on Member States’ customs control strategies. 
The  Commission  also  closely  monitors  Member  States’  actions  and  their  follow-up  on 
observations made during its inspections. 

In  2021,  Commission  services  performed  TOR  inspections  (on  the  spot  in  Member  States  or 
remotely) on: (i) the reliability of the TOR accounts and related statements; (ii) the follow-up on 
inspections of the customs value control strategy; (iii) the control strategy for anti-dumping and 
countervailing  duties;  (iv)  the  management  of  the  separate  account  and  the  corrections  of  the 
normal account (refunds of customs duties). 

During  the  inspections  carried  out  in  2021,  the  Commission  identified  certain  shortcomings  in 
national customs systems. These shortcomings, some of which have a potential financial impact, 

40   This  calculation  is  based  on  82 668  cases  reported  by  the  EU-27,  an  established  amount  of  EUR  5.7  billion  (after 

corrections already processed) and a recovered amount of EUR 4.32 billion. 

41   The  HRR  expresses  the  recovery  rate  in  both  complex  and  easy  cases.  Established  and  closed  cases  from  2019 
onwards are therefore excluded, because they are predominantly easy cases (complex cases can generally not be closed 
within 3 years). 
42   See Annex 11. 

21 

 
 
                                                           
TRADITIONAL OWN RESOURCES 

are  being  followed  up  and  where  the  Commission  considers  that  cooperation  and  progress  in 
tackling outstanding issues are insufficient, it is applying corrective measures. 

As  the  2020  PIF  report  states,  such  corrective  measures  have  already  been  applied  by  the 
Commission against the UK for undervalued textiles and footwear from China (Snapshot 1). On 
8  March  2022,  the  CJEU  issued  its  ruling  in  related  Case  C-213/19  against  the  UK.  The 
Commission is in the process of analysing the implications of that CJEU ruling both for the UK 
(e.g. re-calculation of TOR losses) and for the Member States.  

The  Commission  also  quantified  potential  TOR  losses  with  regard  to  the  evasion  of  anti-
dumping duties for solar panels and informed the EU Member States concerned. 

One  general  conclusion  the  Commission  has  drawn  from  its  inspections  in  Member  States  in 
recent  years  is  that  a  timely  and  proactive  approach  to  assessing  and  monitoring  fraud  risks  is 
indispensable to effectively protect the EU’s financial interests. This includes using all available 
sources of information, exchanging information among the services involved and giving prompt 
feedback on actions taken. Such permanent assessment, exchange of information and monitoring 
of fraud risks and trends, as well as feedback, is required to fine-tune the measures to be taken 
and in this way to better protect the EU’s financial interests. 

2.4.3.3.   Particular cases of Member State failure to recover TOR 

If TOR are not established or recovered because of an administrative error by a Member State, 
the  Commission  applies  the  principle  of  financial  liability43,  making  individual  Member  States 
responsible for the error. Member States were held  financially liable in  2021 for over EUR 86 
million44, and new cases are being followed up by the Commission. 

43   Case  C-392/02  of  15.11.2005.  These  cases  are  typically  identified:  (i)  on  the  basis  of  Articles  119  and  120 
(administrative  errors  that  could  not  reasonably  have  been  detected  by  the  person  liable  for  payment)  and  103(1) 
(time-barring resulting from the inactivity of the customs administration) of the Union Customs Code; or (iii) on the 
basis of non-observance by the customs administration of articles of the Union Customs Code giving rise to legitimate 
expectations on the part of an operator. 

44   It includes customs duties (EUR 71 million) and interest (EUR 15 million), excluded payments made under reservation 

for solar panels, textiles and shoes originating from the People’s Republic of China. 

22 

 
 
                                                           
COMMON AGRICULTURAL POLICY 

3. 

COMMON AGRICULTURAL POLICY  

EXECUTIVE SUMMARY 

Section 3 analyses fraudulent and non-fraudulent irregularities reported by the Member States 
to  the  Commission  through  the  Irregularity  Management  System.  It  focuses  on  the 
irregularities  related  to  the  Common  Agricultural  Policy,  covering  support  to  agriculture 
(including  direct  payments  to  farmers  and  market  measures)  and  rural  development,  during 
the period 2017-2021.   

Over the period 2017-2021, the reporting of  fraudulent irregularities in relation to rural 
development  increased  by  23%.  It  decreased  for  the  programming  period  2007-2013,  as 
expected,  and  had  a  slow  start  for  the  programming  period  2014-2020,  which  might 
indicate  insufficient  detection  work  in  the  Member  States.  The  level  of  fraud  detected  for 
support  to  agriculture  was  rather  stable,  even  if  in  2021  the  number  of  fraudulent 
iregularities decreased by 17% with respect to 2020. 

Over the period 2017-2021, the rural development part of the budget was more affected by 
fraud  than  support  to  agriculture,  as  a  proportion  of  the  payments  received  by  the  Member 
States. However, the incidence of fraud for market measures was even higher than for rural 
development. Direct aid to farmers accounted for most payments, but the incidence of fraud 
was  low,  as  it  is  entitlement-based  and  there  are  systems  in  place  to  support  prevention. 
Similar patterns applied to non-fraudulent irregularities.  

Over the past years, the detection of fraud was concentrated in a few Member States and 
this was not substantiated by a similar level of concentration in related payments. Differences 
in  the  quality  of  prevention  or  detection  work  carried  out  or  different  approaches  taken  to 
criminal investigation may contribute to this. 

Over  the  period  2017-2021,  fraud  in  support  to  agriculture  most  often  concerned  the 
documentary proof. Fraudulent irregularities concerning the request were also recurrent. In 
most  cases,  these  irregularities  concerning  documentary  proof  or  request  were  due  to 
falsification. In the case of direct payments, most of these violations were concentrated in two 
Member States.  A wide range of documents  and information  can be falsified, such as lease 
agreements,  property  documents,  compliance  with 
the  conditionality  requirements. 
Concerning  fraud  about  ‘product,  species  or  land’,  over  or  fictitious  declarations  were 
frequently detected. When fraud in support to agriculture concerned the implementation of 
the action, it was related to market measures, often in combination with other violations. 
High financial amounts were recorded in several cases investigated by OLAF where conflict 
of  interest  was  combined  with  other  violations,  in  relation  to  the  market  measure 
‘Promotion’.  The  creation  of  artificial  conditions  for  the  purpose  of  receiving  financial 
support  is  a  potential  risk.  For  example,  beneficiaries  may  artificially  split  agricultural 
holdings and request aid via several linked companies, to avoid degressive aid rates or limits 
in terms of area or animals.  

In  terms  of  rural  development  fraud,  fraudsters  mainly  used  the  practice  of  falsifying 
documents. For example, this may involve falsifying invoices, declarations of equipment as 
new while it is second-hand, bids in procurement procedures, or false information provided 
on compliance with the conditions for receiving the aid. A significant number of fraudulent 
irregularities  concerned  failure  to  fully  implement  the  action.  The  creation  of  artificial 
conditions is a potential risk also for rural development funding.  

Concerning  market  measures,  the  highest  number  of  fraudulent  irregularities  concerned 
national support programmes for the wine sector, in particular investment measures and 

23 

 
COMMON AGRICULTURAL POLICY 

producer 

the restructuring and conversion of vineyards. The highest total financial amounts involved in 
fraud were related to the fruits and vegetables sector, where fraud most often concerned aid 
to 
concerning 
formation/administrative operation and measures concerning investment, sometimes together 
in  the  same  case.  The  financial  amounts  involved  were  high  also  for  the  market  measure 
specifically related to the promotion of agricultural products. 

for  preliminary 

both  measures 

recognition, 

groups 

With  reference  to  rural  development  and  direct  payments  to  farmers,  risk  analysis  and 
spontaneous  information  from  civil  society,  including  from  the  media,  have  a  marginal 
contribution  in  detecting  fraudulent  and non-fraudulent irregularities.  In relation  to  market 
measures, risk analysis has a stronger role in  detection, including because  of the risk-based 
scrutiny of commercial documents of those entities receiving payments.  

After about 10 years from initial reporting, the share of cases of suspected fraud that have 
not  led  to  conviction  remains  very  high,  while  the  share  of  cases  in  which  fraud  is 
established is low. This may signal the need to invest further in reporting suspected fraud and 
in the investigation/prosecution phase.  

24 

 
 
 
 
COMMON AGRICULTURAL POLICY 

3.1. 

Introduction 

Section 3 presents a statistical evaluation of irregularities and fraud detected by the Member 
States  in  2021  in  expenditure  under  the  common  agricultural  policy  (CAP).  It  provides 
context to these detections by looking at past years and relevant programming periods (PP). 
The  Member  States  reported  these  irregularities  and  cases  of  fraud  to  the  Commission 
through the Irregularity Management System (IMS). 

Over  the  period  2017-2021,  the  CAP’s  overarching  objectives  were  (i)  viable  food 
production;  (ii)  sustainable  management  of  natural  resources  and  climate  action;  (iii) 
balanced territorial development. Over 99% of expenditure was disbursed by Member States 
under shared management.  

For the purpose of this analysis, the CAP is split into two main parts: 

o  Support to agriculture (SA), by providing direct aid to farmers (DA) and measures to 
respond to market disturbances (MM), such as private or public storage and export 
refunds. The European Agricultural Guarantee Fund (EAGF) finances these actions. 

o  Rural  development  (RD)  programmes  run  by  the  Member  States.  The  European 

Agricultural Fund for Rural Development (EAFRD) finances these programmes. 

The European Maritime and Fisheries Fund (EMFF) provides funding and technical support 
to make the fishery industry more sustainable. However, EMFF is analysed together with the 
other structural funds, as it belongs to the ESIF (European Structural and Investment Funds) 
family of funding (see Section 4).  

Table NR1 below shows the 2021 budget for the CAP, which represents about 33% of the EU 
budget.  

Graph  NR1  below  shows  the  relative  weight  of  different  components  of  the  CAP  on 
payments and on the financial amounts involved in all CAP irregularities. 

In  2021,  rural  development  represented  26%  of  CAP  payments,  but  48%  of  the  financial 
amounts  involved  in  CAP  irregularities.  This  difference  in  the  percentage  of  payments  and 
the percentage of irregular amounts was even more pronounced for market measures, which 
accounted for just 5% of payments and 42% of irregularities in terms of financial amounts. 
Instead,  direct  aid  absorbed  most  of  the  CAP  payments  (70%),  but  accounted  for  less  than 
10% of the irregularities in terms of the financial amounts involved.  

25 

Payments (2)% of total EU budgetEUR million%DA: Direct aidShared37,88522.8%MM: Intervention in agricultural marketsShared2,5051.5%RD: Rural developmentShared13,9988.4%TOTAL166,140100.0%(2) Payments related to MM, DA and RD include only payments to EU27. The Total cover the whole EU budget.Table NR1: Financial year 2021 - EU27(1)  'Intervention in agricultural markets' includes budget chapter 05.02. 'Direct aid' includes Budget chapter 05.03. 'Rural development' includes budget chapter 05.04 Type of expenditure (1)Management modeYear 2021 
 
   
COMMON AGRICULTURAL POLICY 

The  European  Commission  is  responsible  for  managing  the  EAGF  and  the  EAFRD. 
However,  the  Commission  does  not  pay  the  beneficiaries  itself.  Under  the  principle  of 
shared management, this task is delegated to the Member States, who make the payments via 
national  or  regional  paying  agencies.  Before  these  paying  agencies  can  claim  any 
expenditure from the EU budget, they must be accredited on the basis of a set of criteria laid 
down by the Commission. 

Before  making  payments,  these  paying  agencies  must  also,  either  directly  or  via  delegated 
bodies, ensure that the aid applications are eligible. The checks they must carry out are laid 
down in the CAP sectorial regulations and vary from one sector to another. Specific national 
authorities are competent for rural development operations. 

The  Commission  reimburses  the  Member  States  the  expenditure  made  by  the  paying 
agencies.  EAGF  reimbursements  are  made  on  a  monthly  basis  and  EAFRD  on  a  quarterly 
basis. Though entitlements and measures supported under the EAGF follow a yearly flow, 
those  under  the  EAFRD  are  implemented  through  multiannual  programmes,  as  action 
financed  by  other  ESI  Funds.  In  general,  reimbursements  are  subject  to  possible  financial 
corrections by the Commission, under the clearance of accounts procedures.  

This report is structured as follows. Section 3.2 elaborates on general trends, broken down by 
fraudulent and non-fraudulent irregularities. Section 3.3 details more specific analyses (i) on 
the  types  of  irregularities;  (ii)  on  the  detection  rates  by  CAP  component;  (iii)  on  the 
irregularities  affecting  market  measures;  (iv)  on  risk  analysis  and  spontaneous  reporting. 
Section  3.4  focuses  on  the  anti-fraud  activities  carried  out  and  results  obtained  by  the 
Member  States,  including  analysing  the  fraud  and  irregularity  detection  rates  (the  ratio 
between  the  amounts  involved  in  cases  reported  as  fraudulent  (FDR)  or  not  reported  as 
fraudulent (IDR) and the payments made during the same period of time). 

26 

(1) For the methodology for the classification of the CAP irregularities in the different CAP components, see Annex 12. To simplify the graph, the financial amounts involved in irregularities do not include EUR 1 million (less than 1% of CAP irregular financial amounts) involved in SA irregularites that were not classified either MM or DA for lack of information (see Annex 12). Furthermore, 1 irregularity classified as mixed (SA/RD) and 5 irregularities classified as 'blank' are not considered in this graph (they account for less than EUR 0.1 million) 4.6%41.9%69.7%9.3%1.0%25.7%47.8%0.0%10.0%20.0%30.0%40.0%50.0%60.0%70.0%80.0%90.0%100.0%PaymentsFinancial amounts involved in irregularitiesGraph NR1: Weight (%) of the different components of CAP in payments and in financial amounts involved in irregularities (EU27 -year 2021) (1)MMDARD+DARD 
 
COMMON AGRICULTURAL POLICY 

3.2. 

General analysis 

3.2.1. 

Irregularities reported in the years 2017-2021 

The analysis in Section 3 refers to the EU-27, unless specified otherwise. UK data is added in the 
tables, as specified, to give a complete picture. However, the accompanying analysis focuses on 
the current Member States and EU-27 in aggregate. In the whole section, when reference is made 
to ‘fraudulent’ or ‘fraud’, this includes both ‘suspected fraud’ and ‘established fraud’.45  

Member States are requested to communicate: 

  non-fraudulent irregularities only when they  are  detected  after the expenditure has been 
introduced in a statement submitted to the Commission. This derogation does not apply to 
fraudulent irregularities: Member States must always report them.  

 

fraudulent  and  non-fraudulent  irregularities  involving  financial  amounts  above  EUR 
10 000.46  From  2017-2021,  several  Member  States  also  reported  several  irregularities 
under  this  threshold.  However,  these  cases  represented  only  about  1%  and  3%  of  the 
number  of  irregularities  reported  as  non-fraudulent  and  fraudulent,  respectively.  To  use 
all information reported by the Member States, they are included in the analysis for this 
section.47 

3.2.2. 

Irregularities reported as fraudulent 

Table NR2 below provides an overview of the number of irregularities reported as fraudulent 
by the Member States, broken down by the type of support, from 2017-2021.48 The number 
of  irregularities found in rural  development  spending decreased during  2018 and 2019 (by 
25%) and then bounced back during 2020 and 2021. As a result, during the overall period 
2017-2021,  fraudulent  irregularities  detected  and  reported  for  rural  development 
increased by 23%.  The irregularities found under support to  agriculture were  rather stable 
during 2018-2020. In 2021, there was a decrease of about 17% with respect to the previous 
year. This pattern resulted in an overall decrease of about 30% for irregularities detected 
and reported for support to agriculture, during the 5-year period.  

45  ‘Suspected  fraud’  means  an  irregularity  that  gives  rise  to  the  initiation  of  administrative  or  judicial 
proceedings at national level in order to establish the presence of intentional behaviour, in particular  fraud, as 
referred to in Article 1(1)(a) of the Convention drawn up on the basis of Article K.3 of the Treaty on European 
Union, on the protection of the European Communities’ financial interests. Regardless of the approach adopted 
by  each  Member  State,  ratification  of  the  1995  Convention  has  equipped  every  country  with  a  basis  for 
prosecuting and possibly imposing penalties for specific conducts. If this happens, i.e. a guilty verdict is issued 
and  is  not  appealed  against,  the  case  can  be  considered  ‘established  fraud’.  See  ‘Handbook  on  ‘Reporting 
irregularities in shared management’ (2017). 
46 The reporting of irregularities below this threshold between 2015-2019 was analysed in the framework of the 
2019 PIF Report (see Section 3.2.1. of ‘Statistical evaluation of irregularities reported for 2019: own resources, 
agriculture, cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2020)160 final (part 
1/3)). 
47 Data for this  section  was downloaded from the Irregularity  Management System (IMS) on 7/3/2022. When 
entering  a  case  into  IMS,  the  contributor  is  requested  to  specify  the  currency  in  which  the  amounts  are 
expressed. If the value of this field is left blank, no transformation is applied. If this field is filled with another 
currency, the financial amounts involved in the irregularity are transformed on the basis of the exchange rates 
published by the ECB at the beginning of 2022. 
48 The  category  'unclear' is used where  the  information is considered  insufficient to classify the irregularity in 
any other category. Annex 12 provides a detailed explanation of the classification of irregularities in SA, RD, 
SA/RD, ‘unclear’.  

27 

 
                                                           
COMMON AGRICULTURAL POLICY 

The  irregularities  in  rural  development  expenditure  reported  for  2017-2021  concerned  both 
PP 2007-2013 and PP 2014-2020. The number of rural development cases related to PP 
2007-2013 fell sharply in 2017, which was to be expected, given that the PP closed in 2015. 
Since then, the number of PP 2007-2013 cases has been rather stable, but still higher than the 
number  of  PP  2014-2020  cases.  The  start  of  detections  related  to  PP  2014-2020  has  been 
rather slow.  

For PP 2014-2020, the slow start of reporting should be closely monitored to ensure it is 
not  due  to less  of  a focus  on  fraud  detection. Graph  NR2  below  compares  the  first  eight 
years of PP 2007-2013 (2007-2014) with the first eight years of PP 2014-2020 (2014-2021), 
in  terms  of  number  of  non-fraudulent  irregularities  detected  and  reported  by  the  Member 
States. Graph NR3 below extends the comparison to the financial amounts involved. The gap 
between  the  two  programming  periods  is  clear  since  the  beginning  and  is  significantly 
increasing.     

28 

20172018201920202021NNNNNNSupport to agriculture (SA)14112612411898607Rural development (RD)11710688121144576SA/RD101399849Unclear100001TOTAL EU272692452212482501,233UK48952685REPORTING YEARTOTAL PERIODType of supportTable NR2 Number of irregularities reported as fraudulent by type of support - 2017-21 for the CAP05010015020020172018201920202021Irregularities reported as fraudulent 2017-21 by type of support (EU27)Support to agriculture (SA)Rural development (RD)SA/RD39%58%3%Irregularities reported as fraudulent in 2021by type of support (EU27)SARDSA/RD49%47%4%Irregularities reported as fraudulent  2017-2021 by type of support (EU27) SARDSA/RD 
 
 
 
 
COMMON AGRICULTURAL POLICY 

As  shown  in  Table  NR2  above,  several  irregularities  were  classified  SA/RD,  meaning  that 
they  were  related  to  both  components  of  the  CAP.  Basically,  in  all  of  these  irregularities, 
irregularities  in  rural  development  expenditure  were  found  in  combination  with 
irregularities in direct aid to farmers. 

The  detection  of  fraudulent  irregularities  was  concentrated  in  a  few  Member  States. 
From 2017-2021, the irregularities notified by the top five Member States in terms of cases 
reported represented about 70% of all irregularities reported as fraudulent (85% of financial 
amounts). In 2021, this rose to 85%, in terms of number of irregularities and more than 95%, 
in terms of financial amounts involved.  

29 

31132555051109293604042929282849672340100200300400500600700123456781-8Year from the start of the programming periodGraph NR2: No. fraudulent irregularities -Rural developmentComparison between the first 8 years of PP 2007-2013 and PP 2014-2020PP 2007-2013PP 2014-2020010,000,00020,000,00030,000,00040,000,00050,000,00060,000,000123456781-8Year from the start of the programming periodGraph NR3: Fin. amounts in fraudulent irregularities -Rural developmentComparison between the first 8 years of PP 2007-2013 and PP 2014-2020PP 2007-2013PP 2014-2020 
 
 
COMMON AGRICULTURAL POLICY 

A  deeper  analysis  of  concentration  was  included  in  the  2018  PIF  Report.49  That  analysis 
found that the concentration of detections went beyond what could be expected given the 
level of concentration of payments. This could be due to many different factors, including 
different  underlying  levels  of  irregularities  and  fraud,  differences  in  the  quality  of  the 
prevention  or  detection  work  or  different  practices  concerning  the  stage  of  the  procedure 
when potentially fraudulent irregularities are reported. The concentration of detections was 
more  accentuated  for  fraudulent  rather  than  for  non-fraudulent  irregularities.  This 
suggests that different approaches to criminal investigation and prosecution could be an 
additional  and  significant  factor  giving  rise  to  these  different  levels  of  detection  across  the 
Member States. 

The graph attached to Table NR3 below shows the trend of financial amounts involved in 
irregularities  reported  as  fraudulent.50  For  rural  development  irregularities,  similar  to  the 
trend  in  terms  of  number  of  detections,  the  financial  amounts  involved  fell  in  2017.  Since 
then, these financial amounts have been fluctuating around a 5-year average of about EUR 
17 million. The trend in the financial amounts involved in support to agriculture was heavily 
influenced  by  two  cases  concerning  market  measures,  worth  between  EUR  20  and  30 
million  each,  which  Poland  detected  in  2017  and  2018.  This  is  the  reason  for  the  much 
higher financial amounts found over these two years. Excluding these two irregularities, the 
irregular  financial  amounts  detected  in  relation  to  support  to  agriculture  were  rather 
stable, reaching a record low in 2020, but bouncing back to the 5-year average (about 
EUR 13 million) in 2021.  

Over the period 2017-2021, 55% of the irregular financial amounts involved were in support 
to  agriculture  irregularities,  and  42%  were  for  rural  development  irregularities.  However, 
over the same period, rural development payments represented just 26% of the CAP budget. 
Therefore,  rural  development  expenditure was  more affected by fraud than support to 
agriculture  expenditure.  This  is  analysed  further  in  Section  3.3.2.,  through  the  fraud 
detection rate, distinguishing between direct aid to farmers and market measures. 

49  Section  3.4.3  of  ‘Statistical  evaluation  of  irregularities  reported  for  2018:  own  resources,  agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2019)365 final. 
50 Fluctuations in the financial amounts involved in irregularities should not be misinterpreted. It must be kept in 
mind that a significant portion of financial amounts is linked to a relatively low number of cases. In this context, 
fluctuations are more likely and should not be overemphasised. 

30 

 
 
                                                           
COMMON AGRICULTURAL POLICY 

An analysis covering the period 2015-2019, included in the 2019 PIF Report51, shows that in 
most fraudulent irregularities, the ‘persons involved’52 were legal entities. Most of them were 
private  companies,  followed  by  non-profit  organisations,  in  particular  associations.  For  a 
significant  one  third  of  cases,  the  ‘persons  involved’  were  natural  persons.  Most  of  the 
fraudulent irregularities involved a single entity. 

3.2.3. 

 Irregularities not reported as fraudulent 

Table  NR4  below  provides  an  overview  of  the  number  of  irregularities  not  reported  as 
fraudulent by the Member States, broken down by the type of support, from 2017-2021. The 
number  of  rural  development  irregularities  not  reported  as  fraudulent  increased  constantly 
until 2015, in line with implementation of the programmes, while the number of irregularities 
related to support to agriculture remained stable. Since then, non-fraudulent irregularites in 
rural development fell sharply until 2017, were rather stable in 2018-2019, and started 
increasing  again  in  2020-2021,  in  line  with  progress  in  the  implemention  of 
PP 2014-2020.  

Table  NR5  below  focuses  on  the  financial  amounts  involved  in  these  irregularities.  The 
irregular  financial  amounts  in  rural  development  also  peaked  in  2015,  then  started  to 
fall. This trend reversed in 2020, in line with the increase in the number of detected and 
reported irregularities during 2020-2021. The irregular financial amounts in support to 
agriculture  fluctuated  strongly  around  an  annual  average  of  about  EUR  77  million.  This 

51 See  Section 3.3.5. of ‘Statistical evaluation of irregularities reported for 2019: own resources, agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2020)160 final.  
52  A  person  involved  is  anyone  who  had  or  has  a  substantial  role  in  the  irregularity.  This  could  be  the 
beneficiary,  the  person  who  initiated  the  irregularity  (such  as  the  manager,  consultant  or  adviser),  the  person 
who committed the irregularity, etc. 

31 

20172018201920202021EUREUREUREUREUREURSupport to agriculture (SA)40,837,94342,851,87211,961,8106,498,15113,026,048115,175,824Rural development (RD)16,219,03524,072,46311,596,64918,373,55316,488,46086,750,160SA/RD504,2711,903,5801,012,3022,452,587491,2996,364,039Unclear12,492000012,492TOTAL EU2757,573,74168,827,91524,570,76127,324,29130,005,807208,302,515UK067,213147,531407,66787,900710,311Type of supportTable NR3: Financial amounts involved in irregularities reported as fraudulent by type of support - 2017-21 for the CAPREPORTING YEARTOTAL PERIOD0102030405020172018201920202021MillionsAmounts of irregularities reported as fraudulent 2017-21 by type of support (EU27) Support to agriculture (SA)Rural development (RD)SA/RD43%55%2%Amounts of irregularities reported as fraudulent in 2021by type of support (EU27)SARDSA/RD55%42%3%Amounts of irregularities reported as fraudulent 2017-21 by type of support (EU27)SARDSA/RD 
 
                                                           
COMMON AGRICULTURAL POLICY 

was mainly due to the fact that cases involving over EUR 15 million each were reported in  
2017  (one  case  in  Romania),  2019  (two  cases  in  Poland)  and  2021  (one  case  in  Poland, 
accounting for nearly EUR 40 million) but none were detected in 2018 and 2020. All of these 
irregularities were related to interventions in the agricultural markets. 

The number of non-fraudulent irregularities in spending on rural development regularly and 
significantly  exceeded  the  number  on  support  to  agriculture,  over  the  entire  2017-2021 
period. As a result, the number of irregularities in rural development were over double 
the  number  affecting  support  to  agriculture.  Non-fradulent  irregularities  in  rural 
development also exceeded those in support to agriculture in terms of the financial amounts 
involved, but only by 16%. 

32 

20172018201920202021NNNNNNSupport to agriculture (SA)1,0218379108801,0154,663Rural development (RD)1,7121,7151,5742,0202,4009,421SA/RD5455532735224Unclear200158TOTAL EU272,7892,6072,5372,9283,45514,316UK5877138135995072,544Table NR4: Number of irregularities not reported as fraudulent by type of support - 2017-21 for the CAPREPORTING YEARType of supportTOTAL PERIOD05001,0001,5002,0002,5003,00020172018201920202021Irregularities not reported as fraudulent 2017-21 by type of support (EU27)Support to agriculture (SA)Rural development (RD)SA/RD29%70%1%Irregularities not reported as fraudulent in 2021by type of support (EU27)SARDSA/RD33%66%1%Irregularities not reported as fraudulent 2017-21by type of support (EU27)SARDSA/RD 
 
 
COMMON AGRICULTURAL POLICY 

Irregularities in rural development spending were found in both PP 2007-2013 and PP 2014-
2020. On the one hand, the number of rural development cases related to PP 2007-2013 
fell  sharply  during  2017-2019,  which  was  to  be  expected,  considering  that  this 
programming period closed in 2015. Since then, there were still detections of PP 2007-2013 
cases  and  they  have  been  following  a  stable  trend.  On  the  other  hand,  the  Member  States 
started  reporting  detections  related  to  PP  2014-2020,  following  an  accelerating  trend, 
reflecting progress in the implementation under this programming period.  

For PP 2014-2020, the reporting dynamics are broadly in line with those at the start of 
the  previous  programming  period.  Graph  NR4  below  compares  the  first  eight  years  of 
PP 2007-2013 (2007-2014) with the first eight years of PP 2014-2020 (2014-2021), in terms 
of  number  of  non-fraudulent  irregularities  detected  and  reported  by  the  Member  States. 
Graph NR5 below extends the comparison to the financial amounts involved. There is a gap 
between the two programming periods, but it is much narrower than that related to fraudulent 
irregularities.  

33 

20172018201920202021EUREUREUREUREUREURSupport to agriculture (SA)80,596,25542,672,04694,304,47062,394,925107,475,232387,442,928Rural development (RD)105,214,23594,306,04859,874,35994,132,35994,702,175448,229,176SA/RD6,905,2715,112,3606,071,2573,396,0701,768,51423,253,472unclear36,0220030,07373,731139,826TOTAL EU27192,751,783142,090,454160,250,086159,953,427204,019,652859,065,402UK1,549,3191,858,3503,175,6973,136,7982,137,91811,858,082Table NR5: Financial amounts involved in irregularities not reported as fraudulent by type of support - 2017-21 for the CAPREPORTING YEARType of supportTOTAL PERIOD02040608010012020172018201920202021MillionsAmounts of irregularities not reported as fraudulent 2017-21 by type of support (EU27) Support to agriculture (SA)Rural development (RD)SA/RD53%46%1%Amounts of irregularities not reported as fraudulent in 2021by type of support (EU27)SARDSA/RD45%52%3%Amounts of irregularities not reported as fraudulent 2017-2021 by type of support (EU27)SARDSA/RD 
 
 
COMMON AGRICULTURAL POLICY 

As shown in Table NR4 above, several irregularities were classified as SA/RD, meaning that 
they were related to both components of the CAP. Basically, in all these cases, irregularities 
in rural development spending were combined with infringements concerning direct aid 
to farmers. 

3.3. 

Specific analysis 

3.3.1.  Modus operandi 

3.3.1.1.   Support to agriculture 

Table NR6 below provides an overview of the most frequent categories (or combinations of 
categories) of irregularities linked to cases reported as fraudulent in relation to support to 
agriculture  in  2021  and  the  financial  amounts  involved.  It  also  gives  the  figures  over  the 

34 

35701442865541005149317815368531674732554837391132161049120100020003000400050006000123456781-8Year from the start of the programming periodGraph NR4: No. non-fraudulent irregularities -Rural developmentComparison between the first 8 years of PP 2007-2013 and PP 2014-2020PP 2007-2013PP 2014-2020050,000,000100,000,000150,000,000200,000,000250,000,000300,000,000123456781-8Year from the start of the programming periodGraph NR5: Fin. amounts in non-fraudulent irregularities -Rural developmentComparison between the first 8 years of PP 2007-2013 and PP 2014-2020PP 2007-2013PP 2014-2020 
 
 
COMMON AGRICULTURAL POLICY 

period 2017-2021.53 In the following paragraphs, the adjective ‘pure’ is used to refer to cases 
where a specific category of irregularity is not combined with other categories.  

The irregularities reported in 2021 mainly concerned the documentary proof.  Over the 
whole  period  2017-2021,  irregularities  concerning  the  request  were  also  recurrent.  Both  in 
relation  to  direct  payments  to  farmers  and  market  measures,  most  of  these  violations 
concerned  falsification.  In  the  case  of  direct  payments,  most  of  these  violations  were 
concentrated  in  two  Member  States  (Romania,  for  violations  concerning  the  documentary 
proof,  and  Italy,  for  violations  concerning  the  request).  A  wide  range  of  documents  and 
information can be falsified, such as lease agreements, property documents, compliance with 
the conditionality requirements. 

Over the period 2017-2021, the Member States detected few fraudulent cases of ‘pure’ ‘(non) 
action’. These cases accounted for the second highest financial amount involved, but this 
was influenced by one irregularity related to market measures that accounted for more than 
EUR 20 million (out of EUR 26 million). Nearly all of these ‘pure’  ‘non-action’ violations 
concerned  market  measures.  In  addition,  ‘(non-)action’  had  a  tendency  to  take  place  in 
combination  with  other  violations,  concerning  for  example  the  documentary  proof,  the 
request, ethics and integrity. Also all of these irregularities concerned market measures.  

Examples of fraudulent irregularities reported as ‘(non-action)’ in relation to market measures 

Example 1: The beneficiary submitted an application for support concerning the withdrawal from the market 
of  a  specified  quantity  of  a  specific  agricultural  product.  These  agricultural  products  should  have  been 
transferred to a charitable organisation, but this never took place. 

Example  2:  The  beneficiary  received  aid  for  the  reduction  of  milk  production,  following  false  declarations 
about  the  leasing/sale  of  part  of  the  cows  to  other  farmers.  Actually,  there  was  no  reduction  in  the  milk 
deliveries by the beneficiary. In another case, despite the declaration of reduction of milk production, the milk 
was still produced on the beneficiary’s farm and delivered to the first purchaser through another person linked 

53  For  the  full  description  of  the  categories  of  irregularities  and  the  related  types  of  violations,  please  see 
Annex 13. 

35 

NEURNEURT14Documentary proof645,920,30333718,715,377T15Product, species and/or land10122,645583,526,675T11Request7365,159955,379,755T19Ethics & Integrity53,807,5602232,375,493T12 | T14Beneficiary/Documentary proof4856,6374856,637T90Other4494,366181,522,857T12Beneficiary2891,890104,813,191T14 | T16Documentary proof/(Non-)action1554,1404642,610T11 | T14Request/Document proof113,3486557,938T16(Non-)action002226,316,619T13Accounts & records007209,242T12 | T16 | T19Beneficiary/(Non-)action/ Ethics & Integrity0059,374,623T11 | T16Request/(Non-)action005490,170T16 | T40 | T19(Non-)action/Public procurement/Ethics & Integrity0023,953,696T14 | T11 | T13Documentary proof/Request/Accounts & records002249,795T11 | T14 | T16Request/Document proof/(Non-)action00256,963T14 | T15Documentary proof/Product, species and/or land00226,502T19 | T16Ethics & Integrity/(Non-)action0012,662,694T19 | T12Ethics & Integrity/Beneficiary0012,287,276T13 | T12 | T19Accounts & records/Beneficiary/Ethics & Integrity001997,582T14 | T16 | T13Documentary proof/(Non-)action/Accounts & records001122,116T15 | T11 | T13Product, species and/or land/Request/Accounts & records00123,208T11 | T13Request/Accounts & records00114,805TOTAL EU279813,026,048607115,175,824Table NR6: Categories of irregularities reported as fraudulent in relation to support to agricultureCodeCategory of irregularityirregularities reported as fraudulent in 2021Irregularities reported as fraudulent 2017-21 
 
 
                                                           
COMMON AGRICULTURAL POLICY 

to  the  beneficiary.  In  another  case,  there  was  only  a  formal  relocation  of  part  of  the  production  among 
members of the same producer group. 

Irregularities  in  the  category  ‘pure’  'product,  species  and/or  land'  were  more  frequently 
detected,  mostly  in  relation  to  direct  aid  to  farmers.  The  majority  of  these  violations 
concerned 'overdeclaration and/or declaration of fictitious product, species and/or land'. 

Examples  of  fraudulent  irregularities  reported  as  ‘overdeclaration  and/or  declaration  of  fictitious 
product, species and/or land’ in relation to direct aid to farmers 

Example 1: The beneficiary declared ownership of a plot of land. However, this plot was owned by a public 
agency. 

Example  2:  The  beneficiary  requested  direct  payments  in  relation  to  the  use  of  a  number  of  plots  of  land. 
Cross-checks revealed that these plots were declared for payment also by other beneficiaries. In another case, 
the  beneficiary  requested  aid  for  plots  of  land  that  he  had  leased  to  another  person.  In  another  case,  the 
beneficiary  requested  aid  in  relation  to  land  he  was  not  using.  The  lease  agreement  submitted  with  the 
application  did  not  match  with  the  contract  submitted  by  the  lessor  at  the  request  of  the  paying  agency.  In 
another  case,  the  leasee  did  not  carry  out  the  agricultural  activities  he  was  supposed  to  carry  out  on  the 
declared land. The application had been made just to obtain the subsidies, which were transferred to the lessor, 
who was the legal representative of the leasee. 

Over  the  whole  period  2017-2021,  22 irregularities  were  reported  in  the  category  ‘pure’ 
'ethics and integrity'. All of these irregularities were communicated by Poland and were not 
reported  under  the  types  'conflict  of  interest',  'bribery'  or  'corruption',  but  as  'other 
irregularities  concerning  ethics  and  integrity'.  Most  concerned  the  creation  of  artificial 
conditions  for  receiving  financial  support  and  direct  aid  to  farmers.  For  example, 
beneficiaries may artificially split agricultural holdings and request aid through several linked 
companies, to avoid degressive aid rates or limits in terms of area or animals. Other Member 
States may have reported this type of infringement under other categories. Two irregularities 
concerned instead market measures and they involved the highest financial amounts. One of 
these  irregularities  included  overstating  costs  for  assets  transferred  among  members  of  the 
same group of producers. 

Examples of fraudulent irregularities related to the creation of artificial conditions 

Example 1: The beneficiary submitted several applications as a natural person and as manager of a number of 
companies.  There  were  personal  and  family  links  between  the  beneficiary  and  the  other  entities  applying  for 
payments. This was meant to circumvent rules about degressive rates of support.  

Example 2: The beneficiary established legal entities with personal, capital, family and business links, to obtain 
direct payments exceeding the maximum ceilings per beneficiary. 

High average financial amounts (about EUR 1.8 million) were recorded in several cases 
of conflict of interests combined with other violations (8 irregularities). In 2019, Czechia 
reported  two irregularities  related  to  corruption,  in  combination  with  public  procurement 
infringements (conflict of interests) and failure to implement the action. In five irregularities 
reported by Bulgaria in 2018, conflict of interests was combined with violations concerning 
the ‘beneficiary’ (mostly not  having the required quality) and  ‘(non) action’ (infringements 
relating  to  the  cofinancing  system).  In  another  case  detected  in  Bulgaria,  a  conflict  of 
interests was combined with violations concerning the ‘beneficiary’ (not having the required 
quality) and ‘accounts & records’ (revenues not declared). All of these eight irregularities 
were related to the market measure ‘promotion’ (see Section 3.3.3) and were investigated 
by OLAF. The investigations uncovered complex fraudulent schemes, mainly based on price 
inflation,  kickback  payments  and  money  laundering.  The  public  procurement  procedures 
were  breached  through  a  solid  network  of  companies  based  in  different  countries.  In  some 
cases, the manipulation was possible also due to the collusion of the beneficiaries. 

36 

 
COMMON AGRICULTURAL POLICY 

Table NR7 below provides an overview of the most frequent categories (or combinations of 
categories)  of  irregularities  linked  to  cases  not  reported  as  fraudulent  in  support  to 
agriculture expenditure in 2021 and the financial amounts involved. It also gives the total 
for these categories (or combinations of categories) for the period 2017-2021. 

Irregularities due only  to the  'request' (pure)  were by far the  most recurrent category 
during  2017-2021,  most  of  the  times  related  to  direct  payments  to  farmes.  However, 
during  the  last  year,  violations  concerning  the  category  'documentary  proof'  were  the 
most frequent, with a significant increase compared with the previous four years.  

Concerning the category ‘request’ in relation to direct payments to farmers, during 2017-
2021,  the  most  recurrent  type  of  violation  by  far  was  'false  or  falsified  request  for  aid', 
followed  by  'incorrect  or  incomplete  request  for  aid'.  This  rate  of  irregularities  related  to 
falsification would not be expected for non-fraudulent irregularities. During 2021, about 
one  third  of  the  violations  concernig  the  request  in  support  to  agriculture  were  related  to 
market  measures,  which  was  much  more  than  before.  In  general,  when  violations 
concerning  the  request  concerned  market  measure,  the  specific  infringement  was  about 
'product, species, project and/or activity not eligible for aid'. 

Concerning  the  category  ‘documentary  proof’,  more  than  half  of  this  type  of  violations 
reported  during  the  past  five  years  have  been  detected  in  2021,  with  a  three-fold  increase 
compared to 2020, which had already doubled the detections from 2019. The vast majority of 
these infrigements reported in 2021 were detected in Greece in relation to direct payments 
to farmers and concerned documents that were incomplete or incorrect. During 2017-2021, 
the  violations  related  to  direct  payments  to  farmers  were  still  the  majority,  but  the 
infringement related to market measures were more recurrent than during 2021. In general, 
during  2017-2021,  there  were  a  few  cases  related  to  false  or  falsified  documents,  which 
would not be expected for non-fraudulent irregularities. 

37 

 
COMMON AGRICULTURAL POLICY 

During  2017-2021,  the  highest  irregular  financial  amounts  were  due  to  infringements 
concerning ‘(non) action’. The vast majority of these irregularities were related to  market 
measures. About 27% of the irregular financial amounts reported over the past five years for 
‘(non) action’ were due to two irregularities related to market measures, totalling about EUR 
36 million. Focusing on the irregularities related to market measures, the highest financial 
amounts were involved in cases where the action was not implemented and in cases where 
the beneficiary carried out an operation that was prohibited during the measure. The most 
reported violations were about actions not implemented or not completed. Focusing on the 
irregularities  related  to  direct  payments  to  farmers,  the  financial  amounts  involved  were 
low and most of the violation concerned the action not implemented or not completed.  

During the last year, the financial amounts related to violations concerning the category 
'beneficiary'  were  the  highest,  with  a  significant  increase  compared  with  the  previous 
four years. The high financial amounts concerned irregularities related to market measures. 
The vast majority of violations were instead related to direct payments to farmers and were 
about  'operator/beneficiary  not  having  the  required  quality'.  However,  this  prevalence  in 
terms of numbers is less significant if also irregularities are considered where these violations 
were combined with other infringements, especially concerning ‘(non-)action’, which were 
basically  always  related  to  market  measures.  Concerning  irregularities  related  to  market 
measures, half of the ‘pure’ ‘beneficiary’ cases and basically all of the cases where there is a 
combination of other types of infringements concerned 'operator/beneficiary not having the 
required quality'.   

38 

NEURNEURT14Documentary proof3878,575,26970823,890,201T11Request1445,499,6031,26652,442,069T16(Non-)action13817,749,770775132,951,446T90Other1134,535,46438617,864,852T15Product/species and/or land1074,071,29663419,731,625T12Beneficiary6049,921,11935795,801,823T19Ethics & Integrity2113,835,59116817,799,834T13Accounts & records10254,503472,410,898T11 | T14Request/Documentary proof7622,542502,966,696T16 |T12(Non-)action/Beneficiary71,424,051563,601,514T11 | T13Request/Accounts & records6275,003132,016,074T11 | T16Request/(Non-)action362,320261,132,227T15 | T16Product/species and/or land/(Non-)action2112,5095310,503T14 | T16Documentary proof/(Non-)action248,136181,473,502T14 | T11 | T16Documentary proof/Request/(Non-)action1161,3159743,330T15 | T16 | T14Product/species and/or land/(Non-)action/Documentary proof1121,4241121,424T11 | T15Request/Product/species and/or land1111,79116493,777T11 | T12Request/Beneficiary110,5446643,046T18Bankruptcy132,016283,979T90 | T11Other/Request118,3973119,992T15 | T11 | T14Product/species and/or land/Request/Documentary proof115,70620896,936NullNull116,862141,741,807T17 | T13 | T14Movement/Accounts and records/Documentary proof0012790,078T14 | T12 | T16Documentary proof/Beneficiary/(Non-)action00102,614,352T11 | T13 | T14Request/Accounts & records/Documentary proof0010892,615T17Movement006532,680T12 | T14Beneficiary/Documentary proof005205,079T13 | T16Accounts & records/(Non-)action004188,871T13 | T14Accounts & records/Documentary proof 004129,822T13 | T15 | T11 | T14Accounts & records/Prod./species and/or land/Request/Docum. proof00443,780ALL OTHER00282,808,096TOTAL EU271,015107,475,2324,663387,442,927Table NR7: Categories of irregularities not reported as fraudulent in relation to support to agricultureCodeCategory of irregularityirregularities not reported as fraudulent in 2021Irregularities not reported as fraudulent 2017-21 
 
COMMON AGRICULTURAL POLICY 

Other recurrent categories of irregularities in support to agriculture expenditure not reported 
as  fraudulent  were  related  to  'product,  species  and/or  land',  or  'ethics  and  integrity'  (not 
combined  with  other  categories  of  irregularity).  The  majority  of  the  violations  concerning 
'product, species and/or land' were related to direct payments to farmers. In this case, the 
most  reported  violation  was  'overdeclaration  and/or  declaration  of  fictitious  product, 
species  and/or  land'  When  these  irregularities  concerned  market  measures,  the  most 
reported  violation  was  ‘inexact  quantity’.  Concerning  'ethics  and  integrity',  apart  from  one 
case  of  conflict  of  interest54,  all  of  these  violations  were  reported  as  'other  irregularities 
concerning ethics and integrity'. 

3.3.1.2.   Rural development 

Table  NR8  below  provides  an  overview  of  the  most  frequent  categories  of  irregularities 
reported  as  fraudulent  in  rural  development  expenditure  in  2021  and  the  corresponding 
financial amounts. It also gives the total for these categories over the period 2017-2021. 

Similar  to  the  findings  for  support  to  agriculture,  there  were  mainly  cases  of  ‘pure’ 
falsification  of  the  documentary  proof  or,  to  a  lesser  extent,  of  requests  for  aid. 
Falsification may concern, for example, invoices, declarations of equipment as new while it is 
second-hand,  bids  in  the  context  of  procurement,  and  information  on  compliance  with 
conditions for receiving the aid. The pure category 'documentary proof' was by far the most 
reported, most often because of false or falsified documents. The category pure 'request' was 
another frequent category, most often in relation to false or falsified requests of aid. 

Examples of fraudulent irregularities related to the documentary proof 

Example  1:  The  beneficiary  simulated  a  procurement  procedure  in  relation  to  the  purchase  of  agricultural 
equipment.  In  reality,  the  beneficiary  directly  bought  the  equipment  and  the  company  selected  through  the 
simulated procurement procedure issued a false invoice for the same equipment. In addition, the equipment was 
supposed  to  be  new,  while  it  was  second-hand.  To  hide  this,  false  manufacturer  labels  were  attached  to  the 
equipment. 

Example 2: To get the reimbursement of expenditure under the EU funded project, the beneficiary had to attach 
two offers for the same item, to evidence that the price  was reasonable. For many items, offers were received 
from company A and company B, always in competition among each other. However, company A did not exist; 
business information and employees from company B were used in the false offers of the inexistent company A.  

Example  3:  To  receive  an  advanced  payment,  the  beneficiary  had  to  attach  a  guarantee  from  a  financial 
institution.  Checks  with the financial institution ascertained that the  financial institution  had never issued that 
guarantee, which was therefore false. 

Example  4:  The  beneficiary  declared  that  a  building  funded  by  the  EU  was  used  for  the  sale  of  agricultural 
products, while it was used as home by the beneficiary. 

A significant number of detections and irregular financial amounts were related to pure '(non) 
action'. Under this category, from 2017-2021, the most reported type of violation was about 
actions not implemented.  

Examples of fraudulent irregularities related to the implementation of the action 

Example 1: The beneficiary did not fully implement the construction works envisaged in the business plan and 
did not increase to number of jobs. 

Example 2: The beneficiary did not use the accomodation built with the support of the EU fund for renting to 
the public. The beneficiary used it for private purposes, without advertising the availability of the accomodation. 

54 There was one additional case of conflict of interest in combination with other categories of violation. Both 
cases where conflict of interest was involved were related to market measures. 

39 

 
                                                           
COMMON AGRICULTURAL POLICY 

Example  3:  The  beneficiary  re-sold  the  agricultural  vehicle  bought  with  the  support  of  EU  funds,  instead  of 
using it during the operating period. 

The  category  pure  ‘ethics  and  integrity’  accounted  for  34  irregularities  found  during  2017-
2021. Similar to support to agriculture cases, Poland communicated most of these violations 
and they were not reported under the types 'conflict of interest', 'bribery' or 'corruption', but 
as  'other  irregularities  concerning  ethics  and  integrity'.  Most  of  these  violations  concerned 
the creation of artificial conditions for receiving financial support. Other Member States 
may have reported this type of infringement under other categories of irregularity, such as the 
one  referring 
type  of  violation 
'operator/beneficiary not having the required quality' or ‘other’). 

the  beneficiary  (for  example,  using 

the 

the 

to 

Example of fraudulent irregularities related to the creation of artificial conditions 

The beneficiary created false information about having had revenue from the sale of self-produced agricultural 
products or products resulting from their processing in the  period prior to the application. This was needed to 
qualify for the support.  

Two irregularities were reported as corruption and a few as conflict of interest. One case 
of conflict of interest was reported under ‘ethics and integrity’, together with other violations 
concerning the documentary proof. Eight cases of conflict of interest in public procurement 
were  reported55,  always  combined  with  false  or  falsified  requests  for  aid.  In  two  of  these 
cases, conflict of interest was also combined with false or falsified documents and, in another 
case, with non-implementation of the action. 

55 Under the category ‘public procurement’ and not ‘ethics and integrity’. 

40 

NEURNEURT14Documentary proof808,408,28127926,028,589T16(Non-)action16373,590483,625,247T11 | T14Request/Documentary proof111,730,118193,169,745T90Other63,451,0554932,361,341T14 | T16Documentary proof/(Non-)action6691,444141,649,998T13Accounts & records679,97115358,991T19Ethics & integrity5161,664342,534,869T14 | T15Documentary proof/Product/species and/or land3260,3864419,506T11Request358,799444,802,074T11 | T14 | T16Request/Documentary proof/(Non-)action2127,6669873,530T15Product/species and/or land256,25713295,804T14 | T18Documentary proof/Bankruptcy1496,1441496,144T11 | T13 | T19 | T14Request/Accounts & records/Ethics & integrity/ Documentary proof1357,8141357,814T11 | T16Request/(Non-)action1122,3401122,340T12Beneficiary1112,932121,345,644T40 | T11Public procurement/Request005233,911T40Public procurement004340,925T12 | T14Beneficiary/Documentary proof004248,641T14 | T19Documentary proof/Ethics & integrity002463,844T11 | T40Request/Public procurement002215,923T13 | T14Accounts & records/Documentary proof002141,719T12 | T19Beneficiary/Ethics & integrity00296,145T11 | T40 | T14Request/Public procurement/Documentary proof00272,983T13 | T17Accounts and records/Movement0013,783,746ALL OTHER0081,150,850Null0011,559,839TOTAL EU2714416,488,46057686,750,161Table NR8: Categories of irregularities reported as fraudulent in relation to rural developmentCodeCategory of irregularityirregularities reported as fraudulent in 2021Irregularities reported as fraudulent 2017-21 
 
                                                           
COMMON AGRICULTURAL POLICY 

Table NR9 below provides an overview of the most frequent categories of irregularities not 
reported  as  fraudulent  in  rural  development  expenditure  in  2021  and  the  corresponding 
financial amounts. It also gives the total for these categories over the period 2017-2021. 

The highest number of detections and irregular financial amounts were related to pure '(non) 
action', in particular action not completed, action not implemented, or failure to respect 
deadlines. Violations concerning 'documentary proof' alone (pure) or the ‘beneficiary’ were 
also recurrent. They were also often combined with the category ‘(non) action’ and with each 
other.  

Over  the  period  2017-2021,  the  number  of  infringements  related  to  'documentary  proof' 
followed  that  of  infringements  concerning  ‘(non)  action',  most  often  because  of  missing 
documents. However, during 2017-2021, false and/or falsified documents were reported in a 
number  of  cases  (about  50,  including  where  combined  with  other  violations),  which  would 
not be expected for non-fraudulent irregularities. The same applies to the category 'request', 
with a number of cases of falsification (about 20).  

The  category  pure  ‘beneficiary’  was  the  third  most  frequent  during  2017-2021  and  the 
second in 2021, most often because of the beneficiary not having the required quality.  

Most of the violations concerning product, species and/or land were due to over or fictitious 
declarations. 

There  were  just  a  few  reported  cases  of  conflict  of  interest.  There  was  one  pure  case  of 
conflict  of  interest.  In  addition,  there  were  eight  other  cases  of  conflict  of  interest  in 
procurement.  In  2020,  one  Member  State  reported  a  multi-million  irregularity  in  rural 

41 

Table NR9: Categories of irregularities non reported as fraudulent in relation to rural developmentNEURNEURT16(Non-)action110039,948,6314,531194,055,424T12Beneficiary2667,457,93097742,004,098T14Documentary proof2187,649,0391,00046,178,754T12 | T16Beneficiary/(Non-)action2096,949,88348314,658,420T11Request1565,271,57754627,149,502T14 | T16Documentary proof/(Non-)action1162,879,7572738,585,192T15Product, species and/or land1154,137,56256519,550,292T90Other805,216,53523830,489,578T19Ethics & integrity434,591,87821511,652,727T40Public procurement263,070,1901159,519,444T12 | T14Beneficiary/Documentary proof14236,108502,270,547T13Accounts & records7613,732694,254,284T12 | T14 | T16Beneficiary/Documentary proof/(Non-)action6130,410943,310,392T18Bankruptcy51,031,844598,568,189T16 | T18(Non-)action/Bankruptcy5601,290324,936,493T16 | T11(Non-)action/Request5125,64420683,843T17Movement33,337,453133,665,558T12 | T15Beneficiary/Product, species and/or land287,76711330,772T14 | T11Documentary proof/Request232,4548821,582T11 | T15Request/Product, species and/or land226,451599,817T15 | T17 | T16 | T14Prod., species, land/Movement/(Non-)act./Doc. proof1501,1071501,107T13 | T14Accounts & records/Documentary proof1156,3529303,136T11 | T13 | T12Request/Accounts & records/Beneficiary196,890196,890T16 | T11 | T15(Non-)action/Request/Product, species and/or land130,796130,796T90 | T13Other/Accounts & records128,198128,198T11 | T13Request/Accounts & records115,7335117,384T19 | T16 | T11Ethics & integrity/(Non-)action/Request114,637114,637T13 | T14 | T16Accounts & records/Documentary proof/(Non-)action113,35012316,673T15 | T14Product, species and/or land/Documentary proof112,0586139,400ALL OTHER005413,169,128Null11436,91826726,920TOTAL EU272,40094,702,1759,421448,229,177Category of irregularityirregularities not reported as fraudulent in 2021Irregularities not reported as fraudulent 2017-21Code 
 
COMMON AGRICULTURAL POLICY 

development  expenditure  related  to  conflict  of  interest,  corruption,  use  of  false  documents 
and accounts. Reporting as non-fraudulent would not be expected, but the Member State also 
communicated  that  penal  proceedings  were  ongoing.  Apart  from  these  cases,  infringements 
related to 'ethics and integrity' were reported as 'other'.  

3.3.2.  Fraud and Irregularity Detection Rates (FDR and IDR) by CAP components 
Table NR10 below shows the FDR and IDR per type of policy measure.56  

Detection rates for support to agriculture were much lower than for rural development. 
However, one part of support to agriculture, interventions in agricultural markets (market 
measures),  accounted  for  the  highest  FDR  and  IDR.  It  could  be  argued  that  this 
comparison  is  biased by a few cases   related to  market  measures  (two fraudulent and three 
non-fraudulent) involving exceptionally high financial amounts (more than EUR 10 million 
each). However, even excluding these irregularities from  the calculation, the FDR and  IDR 
for market measures were the highest, at 0.34% and 1.46%, respectively.  

The detection rates for direct payments to farmers were much lower. 

3.3.3.  Market measures – fraudulent and non-fraudulent irregularities 

As shown in Table NR10 above, the FDR and IDR of market measures are high. Table NR11 
below  shows  the  number  and  financial  amounts  of  irregularities  reported  as  fraudulent  in 
relation  to  market  measures  for  the  period  2017-2021,  while  Table  NR12  below  shows  the 
same data on irregularities that were not reported as fraudulent. 

Fraudulent  and  non-fraudulent  irregularities  involving  the  highest  financial  amounts 
are  often  related  to  market  measures.  From  2017-2021,  Poland  reported  two  fraudulent 
irregularities related to aid to producer groups for preliminary recognition in the  ‘fruits and 
vegetables’  sector,  accounting  for  over  EUR  20  million  each.  This  type  of  aid  was  also 
subject  to  three  non-fraudulent  irregularities,  accounting  together  for  over  EUR  75  million 
(all reported by Poland). Another non-fraudulent irregularity involving about EUR 19 million 
affected a food programme for deprived persons. 

56  Some  of  the  irregularities  used  for  these  calculations  do  not  refer  exclusively  to  a  specific  policy  measure, 
because the same case may cover several budget posts referring to different measures. The ‘SA/RD’ cases are 
only included in the total CAP FDR/IDR. So the SA and RD FDR/IDR are slightly underestimated. Most of the 
SA/RD cases had an impact both on DA and RD. No SA/RD case impacted both on MM and RD. There is only 
one cases that impacted both on MM and DA. These 'mixed' cases are included with their full financial amount 
in  DA  or  MM.  So  the  DA  and  MM  FDR/IDR  are  slightly  overestimated.  See  ‘Statistical  evaluation  of 
irregularities reported for 2019: own resources, agriculture, cohesion and fisheries policies, pre-accession and 
direct expenditure’, SWD(2020)160 final (Annex 14) for a methodology to assess the impact on FDR and IDR 
of these ‘mixed’ cases. This methodology applied to the period 2017-2021 suggests that FDR and IDR are not 
significantly sensitive to these ‘mixed’ cases issues. 

42 

FDR IDRDirect payments0.01%0.06%Intervention in agricultural markets0.72%2.19%Support to agriculture0.06%0.19%Rural development0.14%0.71%Total CAP0.08%0.32%0.40%0.85%0.08%0.25%Table NR10: FDR and IDR by type of CAP expenditure - EU27Type of expenditureIrregularities detected and reported 2017-2021 / Payments 2017-2021Total2.91% 
  
 
                                                           
COMMON AGRICULTURAL POLICY 

The highest number of irregularities reported as fraudulent were related to national support 
programmes  for  the  wine  sector.  Irregularities  affected  in  particular  investment  measures 
and  the  restructuring  and  conversion  of  vineyards.  However,  fraud  hit  also  promotion 
measures, including in non-EU markets.    

The highest financial amounts were involved in fraudulent irregularities related to ‘fruits and 
vegetables’. In this domain, the two above-mentioned cases reported by Poland contributed to 
the high financial amounts related to aid for producer groups for preliminary recognition. One 
of these  cases  concerned expenditure for investment,  but  also  the budget  for formation and 
administrative  operation  was  affected.  In  general,  fraud  touched  both  measures  concerning 
formation/administrative operation and measures concerning investment, sometimes together 
in the same case.  

The  financial  amounts  involved  were  high  also  for  the  market  measure  specifically 
related  to  the  promotion  of  agricultural  products.  Fraud  affected  both  promotion  in  the 
EU  markets  and  in  third  countries,  with  higher  irregular  financial  amounts  involved  in  the 
latter. 

Fraud affected also the school schemes and market measures related to milk and milk 
products.  

For irregularities not reported as fraudulent, the category 'products of the wine-growing 
sector'  was the  most frequently reported. Most of the times, non-fraudulent irregularities 
concerned  the  restructuring  and  conversion  of  vineyards.  Also  irregularities  related  to 
investments  were  frequently  reported.  When  promotion  measures  were  concerned,  the 
majority of cases were related to promotion in third countries. 

43 

NEURNEURNEUR446,434,576Investment192,570,912Restructuring and conversion of vineyards112,301,013Promotion61,020,880Promotion - third countries3221,492By product distillation161,543Green harvesting138,088Null3220,6482759,482,706Aid to producer groups for preliminary recognition2158,667,549Formation, administrative operation92,122,403Investment6817,021mix425,102,051Null230,626,074Operational funds for producer organisations3595,748Other measures for fruit and vegetables233,051Compensation to encourage processing of citrus fruits1186,3581421,843,722Within the EU43,369,365Third countries59,374,125Null59,100,231101,574,607Fruit and vegetables - products2108,722Fruit and vegetables - publicity1127,010Supply and distribution of products245,212Null51,293,6638351,44311,765,8331135,15310591,588,039Market measureThe market measure 'School schemes' include also relevant irregularities related to the market measure 'Fruit and vegetables'Table NR11: Number of irregularities reported as fraudulent in relation to market measuresIrregularities reported as fraudulent 2017-21TOTAL EU27Products of the wine-growing sectorFruit and vegetablesPromotionSchool schemesMilk and milk productsSugar restructuring fundPigmeat, eggs and poultry, bee-keeping and other  
 
 
COMMON AGRICULTURAL POLICY 

Promotion  of  agricultural  products  was  affected  by  non-fraudulent  irregularities  also 
when  not  related  to  the  wine  sector.  In  this  case,  the  majority  of  irregularities  concerned 
promotion within the EU. 

The highest financial amounts were involved in non-fraudultent irregularities related to 
'fruit and vegetables'. In particular, this was due to irregularities related to aid to producer 
and 
groups 
formation/administrative operation, sometimes together in  the same irregularity. Even more 
frequent  than  irregularities  related  to  aid  for  preliminary  recognition  were  irregularities 
concerning operational funds for producers organisations.  

recognition.  They 

investments 

preliminary 

concerned 

both 

for 

Programmes  of  Option  Specifically  Relating  to  Remoteness  and  Insularity  (POSEI) 
were often affected by non-fraudulent irregularities. Most of the times, this was linked to 
supply arrangement or other measures. 

The  school  schemes  were  also  not  free  from  non-fraudulent  irregularities,  in  particular 
concerning the supply and distribution of the products. The majority of cases were related to 
fruit and vegetables. 

The category 'Food programmes' was impacted by few irregularities, but high financial 
amounts.  As  mentioned,  one  single  non-fraudulent  irregularity  accounted  for  EUR  19 
million. 

44 

NEURNEURNEURProducts of the wine-growing sector99055,545,727Restructuring and conversion of vineyards55824,630,027Investment19814,845,165Promotion on third country markets1026,433,925Promotion694,574,397Promotion EU4109,744Other or null594,952,468Fruit and vegetables349181,688,598Aid to producer groups for preliminary recognition99161,843,281Formation, administrative operation232,101,271Investment4541,873,937mix26116,719,084Not specified51,148,989Operational funds for producers organisations23218,899,009Mix172,464Other17873,844Other plant products and measures683,881,385POSEI - import and supply of live animals7203,115POSEI - Supply arrangements251,455,166POSEI - Technical assistance124,250POSEI - Other measures352,198,854Beef and veal53817,599Promotion381,187,662Promotion EU29851,886Promotion third countries7247,340Not specified288,436School schemes542,771,331Fruit and vegetables392,092,526Milk15678,804Pigmeat, eggs and poultry, bee-keeping and other animal products14321,469Olive oil - quality improvement measures9276,339Sugar restructuring fund82,504,255Milk and milk products8239,206Food programmes631,168,386POSEI and smaller Aegean islands (excluding direct 4177,372TOTAL EU271,601280,579,327Table NR12: Number of irregularities not reported as fraudulent in relation to market measuresIrregularities reported as fraudulent 2017-21Market measureThe market measure 'School schemes' include also relevant irregularities related to the market measures 'Fruit and vegetables' and 'Milk and milk products'POSEI stands for Programmes of Options Specifically Relating to Remoteness and Insularity 
 
 
COMMON AGRICULTURAL POLICY 

3.3.4.  Risk analysis and spontaneous reporting 

Detection  capability  is  a  key  feature  of  the  anti-fraud  cycle,  which  contributes  to  the 
effectiveness  and  efficiency of the system for the protection of the EU budget.  In the 2017 
PIF Report, to boost the capability to detect irregularities, the Commission recommended to 
the  Member  States  to  improve  risk  analysis  and  the  use  of  spontaneous  reporting  of 
potential  irregularities  and  strengthening  the  protection  of  whistle  blowers  that  are  also  a 
crucial source for investigative journalism.57 With a focus on checks that led to discovering 
reported  irregularities,  Tables  NR13-NR18  below  provide  information  on  the  number  of 
checks that were carried out due to reasons that can be linked to these recommendations. 58 

So far, there has been little improvement on the ground (see Tables NR13-NR18 below). 
It  may  take  time  to  evolve  effectively  from  reactive  to  proactive  detections  based  on  risk 
analyses. It should also be considered that non-fraudulent irregularities that are detected and 
corrected at the national level before including the expenditure in a statement submitted to the 
Commission for reimbursement do not have to be reported. Therefore, if risk analyses have a 
higher impact in terms of ‘early’ detection of these irregularities, it would not be captured by 
Tables  NR13-NR18  below.  By  contrast,  this  exception  does  not  apply  to  fraudulent 
irregularities,  which  should  always  be  reported,  even  when  detected  before  expenditure  is 
submitted to the Commission. 

3.3.4.1.  Irregularities in relation to rural development 

With reference to rural development, risk analysis has still a marginal contribution to 
detecting  fraud.  In  addition,  during  the  past  five  years,  just  5%  of  the  fraudulent 
irregularities  were  detected  following  tips  (e.g.  from  whistle  blowers)  or  information 
published in the media (see Table NR13 below).  

Table NR14 below focuses on irregularities not reported as fraudulent in rural development. 
Risk  analysis  contribute  to  a  higher  share  of  detections  than  for  fraudulent 
irregularities, but this share is still very low. Also the share of non-fraudulent irregularities 
detected following tips or information published in the media is negligible.  

57 Section 9.2 of ‘29th Annual Report on the Protection of the EU’s financial interests  – Fight against fraud – 
2017’,  COM(2018)553  final  and  ‘Statistical  evaluation  of  irregularities  reported  for  2017:  own  resources, 
agriculture, cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2018)386 final.  
58 Tables NR13-NR18 include reasons that may indicate the use of some forms of risk analysis (comparison of 
data, probability checks and statistical analysis). 

45 

Table NR13 - EU27N.%EURRisk analysis30.5170,898Comparison of data30.5867,386Probability checks00.00Statistical analysis00.00Tip from informant, whistle-blower etc.284.92,296,235Information published in the media20.388,228Total (1)57686,750,161Reason for performing controlIrregularities reported as fraudulent - Rural development2017-2021(1) Total number of irregularities classified as RD (rural development) and reported as fraudulent  
 
 
                                                           
COMMON AGRICULTURAL POLICY 

3.3.4.2.   Irregularities in relation to market measures 

In relation to market measures, risk analysis has a stronger role in detecting fraudulent 
irregularities  than  in  other  CAP  sectors.  This  is  influenced  the  overall  low  number  of 
cases.  However,  about  11%  of  fraudulent  irregularities  were  detected  because  of  risk 
analysis. In addition, the categories 'scrutiny 4045', ‘scrutiny 485' and ‘scrutiny 1306’ refer to 
Regulation  No  4045/1989,  Regulation No  485/2008  and  Regulation  No  1306/2013, 
respectively.  These  deal  with  the  scrutiny  of  commercial  documents  of  those  entities 
receiving payments from the Guarantee section of the EAGGF (Reg. No 4045/1989) or from 
the  EAGF  (Reg.  No  485/2008  and  Reg.  No  1306/2013)59.  These  regulations  provide  for 
checks based on the assessment of the risks. Regulation No 4045/1989 already required the 
Member States to consider risk factors and concentrate on sectors or undertakings where the 
risk  of  fraud  is  high.  Taken  together,  these  scrutinies  accounted  for  more  than  25%  of 
detections. 

About  7%  of  the  fraudulent  irregularities  were  detected  following  tips,  which  is  similar  to 
other CAP sectors. The contribution of information published in the media was nil. 

Also for non-fraudulent irregularities, risk analysis seem to play a more important role 
in detection than in other CAP sectors. Risk analysis and risk-based scrutiny accounted for 
about  25%  of  cases.  The  share  of  irregularities  detected  following  tips  or  information 
published in the media was negligible, as in other CAP sectors. 

59 Reg. 485/2008 repealed Reg. 4045/1989 and Reg. 1306/2013 repealed Reg. 485/2008. 

46 

Table NR14 - EU27N.%EURRisk analysis1781.98,101,677Comparison of data941.03,160,916Probability checks690.72,736,613Statistical analysis20.021,017Tip from informant, whistle-blower etc.1291.49,847,855Information published in the media150.27,207,253Total (1)9,421448,229,177Reason for performing controlIrregularities not reported as fraudulent - Rural development2017-2021(1) Total number of irregularities classified as RD (rural development) and not reported as fraudulent Table NR15 - EU27N.%EURRisk analysis1211.41,439,373Comparison of data11.017,303Probability checks00.00Statistical analysis00.00Scrutiny 404587.62,506,861Scrutiny 4851817.11,902,026Scrutiny 130621.9120,773Tip from informant, whistle-blower etc.76.734,495,304Information published in the media00.00Total (1)10591,588,039Reason for performing controlIrregularities reported as fraudulent - Market measures2017-2021(1) Total number of irregularities classified as MM (market measures) and reported as fraudulent  
 
 
 
 
                                                           
COMMON AGRICULTURAL POLICY 

3.3.4.3.   Irregularities in relation to direct payments 

With  reference  to  direct  payments  to  farmers,  risk  analysis  has  still  a  marginal 
contribution in detecting fraud and non-fraudulent irregularities. In addition, during the 
past  five  years,  just  2-3%  of  the  fraudulent  and  non-fraudulent  irregularities  were  detected 
following  tips  (e.g.  from  whistle  blowers)  (see  Tables  NR17  and  NR18  below)  and  never 
following information from media. 

3.4. 

Anti-fraud work carried out by the Member States 

Previous  sections  have  examined  the  trend  and  main  features  and  characteristics  of  the 
irregularities reported as fraudulent. 

This  section  focuses  on  some  aspects  linked  to  the  anti-fraud  work  carried  out  and  results 
obtained by the Member States in particular. It analyses four aspects: 

47 

Table NR16 - EU27N.%EURRisk analysis472.92,350,914Comparison of data40.260,857Probability checks150.9403,453Statistical analysis00.00Scrutiny 404519912.414,650,091Scrutiny 485986.110,053,954Scrutiny 1306704.42,938,436Tip from informant, whistle-blower etc.181.169,768,106Information published in the media20.143,958Total (1)1,601280,579,327Reason for performing controlIrregularities not reported as fraudulent - Market measures2017-2021(1) Total number of irregularities classified as MM (market measures) and not reported as fraudulent Table NR17 - EU27N.%EURRisk analysis30.6360,039Comparison of data00.00Probability checks00.00Statistical analysis00.00Scrutiny 404500.00Scrutiny 48500.00Tip from informant, whistle-blower etc.122.2549,252Information published in the media00.00Total (1)54527,968,702Reason for performing controlIrregularities reported as fraudulent - Direct payments2017-2021(1) Total number of irregularities classified as DA (direct payments) and reported as fraudulent Table NR18 - EU27N.%EURRisk analysis331.0768,345Comparison of data792.51,674,359Probability checks130.4286,250Statistical analysis00.00Scrutiny 404520.11,085,326Scrutiny 48500.00Tip from informant, whistle-blower etc.1033.22,554,890Information published in the media00.00Total (1)3,213120,933,285Reason for performing controlIrregularities not reported as fraudulent - Direct payments2017-2021(1) Total number of irregularities classified as DA (direct payments) and not reported as fraudulent  
 
 
 
 
COMMON AGRICULTURAL POLICY 

(1)  Duration of irregularities (fraudulent and non-fraudulent). No analysis by Member State 

is presented in this section. 

(2)  The number of irregularities reported as fraudulent by each Member State (in 2021 and 

over the past five years). 

(3)  the FDR (the ratio between the amounts involved in cases reported as fraudulent and the 
payments  made  over  the  same  period)  and  the  IDR  (the  ratio  between  the  amounts 
involved in  cases  not  reported as fraudulent and the payments made over same period) 
over the past five years60; 

(4)  the follow-up to suspected fraud. 

3.4.1.  Duration of irregularities 

The  Member  States  are  requested  to  indicate  the  date  or  period  when  the  irregularity  was 
committed. Of the 15 549 irregularities (fraudulent and non-fraudulent) reported by Member 
States in  2017-2021 in  relation  to  the CAP,  9 057 (58% of the total) involved irregularities 
that were protracted over a span of time. For the 1 233 irregularities reported as fraudulent, 
this rises to 76%. About 41% of the irregularities consisted of a single act identifiable on a 
precise  date  (about  and  24%  of  the  fraudulent  irregularities)61.  The  average  duration  of  the 
irregularities that were protracted over time was 26 months (two years and two months). For 
the irregularities reported as fraudulent, the average was one month less: 25 months.   

3.4.2.  Detection of irregularities reported as fraudulent by Member State 

3.4.2.1.   Reported over the period 2017-2021 

Table  NR19  below  gives  an  overview  of  the  irregularities  reported  as  fraudulent  by  the 
Member  States  over  the  period  2017-2021.  It  also  shows  the  related  amounts,  overall 
payments under the agricultural policy62 and the FDR.  

Belgium,  Cyprus  and  Malta  have  notified  no  irregularities  as  fraudulent.  15  other  Member 
States reported fewer than 30 potentially fraudulent irregularities; six Member States reported 
between 30 and 60; and three Member States reported over 60. 

The FDRs exceeded 0.5% in Estonia and 0.30% in Romania and Bulgaria. Romania was the 
Member State that accounted for the highest number of irregularities, and Poland reported the 
highest financial amounts involved.  

60 The Member States have an obligation to report only irregularities for which payment and certification to the 
Commission was made. As a consequence, the IDR focuses on the 'repression' side of the anti-fraud cycle and 
does not include the results of prevention. This does not apply to the FDR, as fraudulent cases must be reported 
regardless. 
61 For a few irregularities, information was not enough to allocate them in one of the two categories (start date 
and final date not available, only final date available). The irregularities where only the start date was available 
have been considered as consisting of a single act identifiable on a precise date. 
62  Payments  are  taken  from  the  Annual  Activity  Reports  (AAR)  of  the  Commission’s  Directorate-General  for 
Agriculture and Rural Development from 2017 to 2021. In particular, reference is made to the tables on pages 
74-76 of the AAR 2017, pages 90-92 of the AAR 2018, pages 74-76 of the AAR 2019, pages 52-54 of the AAR 
2020, pages 57-59 of the AAR 2021.  

48 

 
 
                                                           
COMMON AGRICULTURAL POLICY 

3.4.2.2.  Reported in 2021 

Table  NR20  below  gives  an  overview  of  the  irregularities  reported  as  fraudulent  in  2021, 
broken down by Member State. It also shows the related amounts, overall payments for the 
common agricultural policy and the FDR.  

Nine  Member  States  reported  no  irregularities  as  fraudulent.  Most  Member  States  reported 
fewer  than  30  fraudulent  irregularities;  only  Romania  reported  over  30  fraudulent 
irregularities. 

The  highest  FDR  was  recorded  in  Estonia.  Romania  reported  the  highest  number  of 
irregularities and related financial amounts.  

49 

Payments in 2017-2021FDR 2017-2021NEURN%AT81,507,5906,259,558,4980.02%BG3117,742,3375,468,391,0730.32%CZ245,763,8836,069,455,5520.09%DE323,359,65130,596,563,2440.01%DK436,380,3864,672,344,4830.14%EE418,446,2891,254,889,9480.67%ES183,452,72733,427,576,1960.01%FI141,2974,409,356,2790.00%FR332,501,50347,445,521,3260.01%GR42,580,08413,193,746,4750.02%HR5387,4152,835,188,7200.01%HU282,058,9418,790,892,2940.02%IE215,2427,679,738,0580.00%IT16320,715,86027,835,391,4090.07%LT162,024,0023,437,231,9760.06%LU115,857239,186,3350.01%LV13611,2312,122,550,8450.03%NL311,260,5514,207,456,9080.03%PL13666,752,26922,337,292,2700.30%PT291,701,4496,489,500,9710.03%RO54758,548,48815,457,693,6370.38%SE112,9474,664,164,2100.00%SI5239,7431,264,973,1720.02%SK212,182,7753,115,274,5480.07%TOTAL EU271,233208,302,517266,932,108,5180.08%UK (1)26710,311Table NR19: Irregularities reported as fraudulent by Member State in 2017-2021Irregularities reported as fraudulent 2017-21(1) As of 1 February 2020, the UK is no longer part of the EU  
  
 
 
   
COMMON AGRICULTURAL POLICY 

3.4.3.  Fraud and Irregularity Detection by sector and Member State 

3.4.3.1.   Rural development 

Table  NR21  and  Map  NR1  below  provide  an  overview  of  the  irregularities  reported  as 
fraudulent  by  the  Member  States  over  the  period  2017-2021  for  rural  development 
expenditure. It also shows the total payments made for rural development and the FDR. As 
mentioned, the irregularities refer exclusively to the rural development component. 

50 

Payments in 2021FDR 2021NEURN%AT51,183,0971,288,012,0460.09%BG250,2311,222,168,3850.00%CZ111,5881,226,526,1900.00%DE3571,3736,094,225,4330.01%DK273,181,542924,954,1110.34%EE173,933,496272,860,9911.44%ES4856,6376,817,077,9720.01%FR667,2349,266,229,6540.00%GR12,543,0172,677,180,6710.09%HU15349,3191,887,106,1010.02%IT183,949,5225,710,441,4160.07%LT499,100703,641,6410.01%LV4182,290421,219,1460.04%NL728,819866,221,4500.00%PL195,272,4234,770,282,3400.11%RO1127,612,1293,162,138,4600.24%SI113,350258,422,6820.01%SK4100,640535,865,4850.02%TOTAL EU2725030,005,80754,388,576,8450.06%UK (1)587,900(1) As of 1 February 2020, the UK is no longer part of the EU Irregularities reported as fraudulent in 2021Table NR20: Irregularities reported as fraudulent by Member State in 2021 
 
 
 
 
COMMON AGRICULTURAL POLICY 

Estonia, Denmark and Romania recorded the highest FDR. The FDR was higher than the EU 
average also in Lithuania and Italy. 23 Member States reported fraudulent cases concerning 
rural  development  spending  over  the  period  2017-2021.  Romania  and  Poland  reported  the 
highest number of cases, and Romania reported the highest financial amounts involved. 

51 

Payments 2017-2021FDR 2017-2021NEURN%AT164,3902,683,298,6550.00BG181,386,6131,368,159,7430.10CZ221,810,1871,739,063,9480.10DE191,653,7046,052,778,4860.03DK406,277,050503,177,2121.25EE418,446,289559,585,0331.51ES1120,0005,138,906,3210.00FI141,2971,755,306,0590.00FR11835,0769,372,194,0660.01GR226,6282,868,329,9000.00HR2229,4171,397,341,4110.02HU251,794,3412,235,950,6990.08IE12,7501,575,791,2230.00IT319,247,6896,282,135,2010.15LT151,981,7031,032,795,2250.19LV13611,231835,699,1660.07NL6229,604519,398,2390.04PL594,059,8835,235,620,9790.08PT211,166,7812,530,746,9620.05RO23445,636,1586,084,588,9380.75SE112,9471,172,064,5600.00SI3145,337556,138,1530.03SK9971,087910,088,6600.11TOTAL EU2757686,750,16262,993,867,5970.14UK (1)18401,016Table NR21: Rural development: number of irregularities reported as fraudulent 2017-2021, amounts involved and fraud detection rate by Member StateMember StateIrregularities reported as fraudulent 2017-21(1) As of 1 February 2020, the UK is no longer part of the EU  
  
 
 
 
COMMON AGRICULTURAL POLICY 

In this map, the FDR ‘0.00’ indicates low financial amounts involved in the irregularities, in proportion to the payments received.  
If no relevant irregularities were reported, no FDR is mentioned in the map for the relevant Member State. See Table NR21. 
UK is not included.  

Table NR22 and Map NR2 below provide an overview of the irregularities not reported as fraudulent 
by the Member States over the period 2017-2021 concerning rural development expenditure. Table 
NR22 below also shows the total payments for rural development and the IDR.  

52 

 
 
COMMON AGRICULTURAL POLICY 

Bulgaria, Portugal and and Malta recorded the highest IDR. The IDR was higher than the EU 
average  also  in  Romania,  Lithuania,  Estonia,  Slovakia,  Italy  and  Hungary.  Portugal  and 
Romania  reported  the  highest  number  of  cases,  and  Romania,  Portugal,  Italy  and  Bulgaria 
reported the highest financial amounts involved. 

53 

Payments in 2017-21IDR 2017-21NEURN%AT231,059,7972,683,298,6550.04BE581,465,155356,883,9390.41BG90658,374,4631,368,159,7434.27CZ2015,198,2161,739,063,9480.30DE1939,788,0286,052,778,4860.16DK19466,862503,177,2120.09EE1616,734,636559,585,0331.20ES87931,362,6375,138,906,3210.61FI461,276,1191,755,306,0590.07FR51710,072,2729,372,194,0660.11GR6719,941,8702,868,329,9000.35HR1374,295,0901,397,341,4110.31HU59621,080,3442,235,950,6990.94IE21904,7961,575,791,2230.06IT54160,908,5486,282,135,2010.97LT38914,418,5591,032,795,2251.40LU139,26669,462,6110.06LV692,119,497835,699,1660.25MT171,458,86564,010,2442.28NL451,491,851519,398,2390.29PL88527,855,5475,235,620,9790.53PT1,46970,942,8202,530,746,9622.80RO1,38494,521,2486,084,588,9381.55SE191,136,8251,172,064,5600.10SI561,492,274556,138,1530.27SK1189,823,592910,088,6601.08TOTAL EU279,421448,229,17762,993,867,5970.71UK (1)3657,796,262Table NR22: Rural development: number of irregularities not reported as fraudulent 2017-2021, amounts involved and irregularity  detection rate by Member StateMember StateIrregularities not reported as fraudulent in 2017-21(1) As of 1 February 2020, the UK is no longer part of the EU  
   
 
 
 
COMMON AGRICULTURAL POLICY 

If  no  relevant  irregularities  were  reported,  no  IDR  is  mentioned  in  the  map  for  the  relevant  Member  State.  See  Table  NR22.  UK  is  not 
included.  

Tables NR21 and NR22 above indicate that the reporting of irregularities was concentrated in 
a few Member States. The top two Member States in terms of number of detections (Romania 
and Poland) reported 51% of all fraudulent irregularities related to rural development (57% in 
terms  of  the  financial  amounts  involved),  while  they  received  about  18%  of  payments.  For 
non-fraudulent  irregularities,  the  top  two  Member  States  (Romania  and  Portugal)  reported 
30%  of  cases  and  37%  of  the  financial  amounts  involved,  but  received  about  14%  of 
payments. 

The concentration of detections was analysed in detail in the 2018 PIF Report for the period 
2014-2018.63  The  analysis  suggests  that  the  concentration  of  detections  went  beyond  what 
could  be  expected  from  the  concentration  of  payments  related  to  rural  development  among 
Member States.  This  could  be due to  many different  factors, including  different underlying 

63  Section  3.4.3.1  of  ‘Statistical  evaluation  of  irregularities  reported  for  2018:  own  resources,  agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2019)365 final. 

54 

 
 
                                                           
COMMON AGRICULTURAL POLICY 

levels of irregularities and fraud, differences in the quality of prevention or detection work or 
different  practices  concerning  the  stage  of  the  procedure  when  potentially  fraudulent 
irregularities  were  reported.  This  difference  in  concentration  between  detections  and 
payments was less pronounced for non-fraudulent irregularities, which could be taken as an 
indication of more uniform  approaches  to  management and administrative checks, although 
data on individual Member States highlighted significant discrepancies. The concentration of 
detections was instead more accentuated for fraudulent irregularities, suggesting that different 
approaches  to  criminal  investigation  and  prosecution  could  be  an  additional  and  significant 
factor explaining the different levels of detection among Member States.  

3.4.3.2.   Market measures 

Table  NR23  and  Map  NR3  below  provide  an  overview  of  the  irregularities  reported  as 
fraudulent  by  the  Member  States  over  the  period  2017-2021  for  market  measures 
expenditure. The table also gives the total payments for market measures and the FDR.64  

FDR was the highest in Poland and Bulgaria, but significantly higher than the EU average also in 
Czechia. Sixteen Member States reported fraudulent cases in this area. Poland and France 
reported the highest number of cases and Poland and Bulgaria reported the highest financial 
amounts involved.  

64 Some of these irregularities do not refer exclusively to market measures, but the reporting authority may have 
also included budget lines/posts referring to other measures (i.e. direct aid, rural development or other payments 
related  to  budget  years  before  2006).  The  full  financial  amounts  of  these  irregularities  are  included  in  these 
tables. 

55 

Payments 2017-2021FDR 2017-2021NEURN%AT71,443,201126,262,3171.14BG1316,355,724131,949,70612.40CZ23,953,69696,233,0054.11DE3855,194704,456,7380.12DK195,21762,573,5650.15ES31,267,3792,860,031,7280.04FR221,666,4272,859,561,5950.06GR12,543,017301,359,3670.84HR1135,15354,500,8090.25HU3264,600206,868,5260.13IT3281,5813,281,110,0120.01LT142,29945,172,3720.09PL3160,910,910273,009,66022.31PT6517,298530,551,5720.10RO61,161,938248,715,8790.47SI294,40637,110,9720.25TOTAL EU2710591,588,04012,788,727,8100.72UK (1)00Table NR23: Market measures: number of irregularities reported as fraudulent 2017-2021, amounts involved and fraud detection rate by Member StateMember StateIrregularities reported as fraudulent 2017-21(1) As of 1 February 2020, the UK is no longer part of the EU  
   
 
 
                                                           
COMMON AGRICULTURAL POLICY 

If  no  relevant irregularities  were  reported,  no  FDR is  mentioned in the map for the  relevant Member State. See  Table  NR23.  UK is not 
included in the map.  

Table  NR24  and  Map  NR4  below  provide  an  overview  of  the  irregularities  not  reported  as 
fraudulent by the Member States over the period 2017-2021 in relation to market measures. It 
also gives the total payments for expenditure under market measures and the IDR. 

56 

 
 
 
COMMON AGRICULTURAL POLICY 

The IDR exceeded 58% in Poland, 21% in Malta and 16% in Romania. It was higher than the 
EU average also in Hungary, Sweden, Croatia and Bulgaria. The huge IDR in Poland is due 
to three cases, accounting together EUR 75 million, which refer to multiple budget years. The 
IDR of Malta is due to the low overall expenditure in this CAP sector. The IDR of Romania 
is influenced by one irregularity accounting for EUR 20 million. 22 Member States reported 
non-fraudulent  cases  concerning  market  measures.  Spain,  France  and  Italy  reported  the 
highest  number  of  cases  and  Poland,  Romania,  Spain  and  France  reported  the  highest 
financial amounts involved.  

57 

Payments in 2017-21IDR 2017-21NEURN%AT11905,166126,262,3170.72BE7321,725360,618,3040.09BG193,248,585131,949,7062.46CZ5151,25296,233,0050.16DE12219,793704,456,7380.03DK2145,36562,573,5650.23ES43223,509,3252,860,031,7280.82FI236,79843,426,2490.08FR31919,827,3382,859,561,5950.69GR17693,697301,359,3670.23HR61,471,28154,500,8092.70HU898,614,275206,868,5264.16IT28911,590,3263,281,110,0120.35LT7380,77345,172,3720.84MT3372,4541,714,05321.73NL301,311,916236,016,5680.56PL143160,386,482273,009,66058.75PT1123,740,780530,551,5720.71RO8741,400,308248,715,87916.65SE12,006,59071,041,8752.82SI5126,32637,110,9720.34SK3118,77255,844,8850.21TOTAL EU271,601280,579,32712,788,727,8102.19UK (1)6607,058(1) As of 1 February 2020, the UK is no longer part of the EU Table NR24: Market measures: number of irregularities not reported as fraudulent 2017-2021, amounts involved and irregularity  detection rate by Member StateMember StateIrregularities not reported as fraudulent in 2017-21 
 
 
 
 
COMMON AGRICULTURAL POLICY 

If  no  relevant  irregularities  were  reported,  no  IDR  is  mentioned  in  the  map  for  the  relevant  Member  State.  See  Table  NR24.  UK  is  not 
included in the map.  

Tables NR23 and NR24 above indicate that the reporting of irregularities was concentrated in 
a few Member States. The top two Member States in terms of number of detections (France 
and  Poland)  reported  about  50%  of  all  fraudulent  irregularities  (68%  of  irregular  financial 
amounts) related to market measures, while they received about 24% of payments. For non-
fraudulent irregularities, the top two Member States in terms of number of detections (Spain 
and France) did not overlap with the highest ranking Member States in terms of the financial 
amounts  involved  (Poland  and  Romania).  Poland  and  Romania  reported  about  72%  of  the 
irregular financial amounts and received about 4% of payments.  

As mentioned in Section 3.4.3.1, the concentration of detections was analysed in detail in the 
2018  PIF  Report,  covering  the  period  2014-2018.65  The  analysis  suggests  that  the  level  of 
concentration of detections went beyond what could be expected given the concentration of 

65  Section  3.4.3.2  of  ‘Statistical  evaluation  of  irregularities  reported  for  2018:  own  resources,  agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2019)365 final. 

58 

 
 
                                                           
COMMON AGRICULTURAL POLICY 

payments  related  to  market  measures  among  Member  States,  especially  for  fraudulent 
irregularities. This suggests the need for more uniform practice in criminal investigation and 
prosecution to protect the EU budget.  

3.4.3.3.   Direct payments to farmers 

Table  NR25  and  Map  NR5  below  provide  an  overview  of  the  irregularities  reported  as 
fraudulent by the Member States over the period 2017-2021 in relation to direct payments to 
farmers. It also shows the total payments for direct payments and the FDR.66 

Romania recorded the highest FDR, at 0.12%. Twelve Member States have reported fraudulent 
cases  in  this  area.  Romania  and  Italy  reported  the  highest  number  of  cases  and  financial 
amounts involved.  

66 Some of these irregularities  do not refer exclusively to direct aid, but the reporting authority may have also 
included  budget  lines/posts  referring  to  other  measures  (i.e.  market  measures,  rural  development  or  other 
payments related to budget years before 2006). The full financial amounts of these irregularities are included in 
these tables. 

59 

Payments 2017-2021FDR 2017-2021NEURN%DE10850,75223,839,328,0200.00DK28,1194,106,593,7060.00ES13966,99225,428,638,1470.00GR110,44010,024,057,2080.00HR222,8451,383,346,5000.00IT12911,186,58918,272,146,1960.06LU115,857166,369,5660.01NL251,030,9463,452,042,1010.03PL431,636,31116,828,661,6310.01PT217,3703,428,202,4370.00RO30511,010,7929,124,388,8200.12SK121,211,6882,149,341,0030.06TOTAL EU2754527,968,701191,149,513,1110.01UK (1)8309,295Table NR25: Direct payments: number of irregularities reported as fraudulent 2017-2021, amounts involved and fraud detection rate by Member StateMember StateIrregularities reported as fraudulent 2017-21(1) As of 1 February 2020, the UK is no longer part of the EU  
 
 
 
                                                           
COMMON AGRICULTURAL POLICY 

In this map, FDR ‘0.00’ indicates low financial amounts involved in the irregularities, in proportion to the payments received. If no relevant 
irregularities were reported, no FDR is mentioned in the map for the relevant Member State.See Table NR25. UK is not included in the map.  

Table  NR26  and  Map  NR6  below  provide  an  overview  of  the  irregularities  not  reported  as 
fraudulent by the Member States over the period 2017-2021 in relation to direct payments. It 
also shows the total payments for direct aid and the IDR. 

60 

 
 
COMMON AGRICULTURAL POLICY 

The IDR was the highest in Italy, more than double the rate for Romania, which ranked second. 
22 Member States have reported non-fraudulent cases in direct aid.  

61 

Payments in 2017-21IDR 2017-21NEURN%AT788,1963,449,997,5260.00BE32625,6102,479,028,8250.03BG13237,9723,968,281,6240.01CZ32568,6984,234,158,5990.01DE1503,801,93123,839,328,0200.02DK21470,7654,106,593,7060.01ES3789,324,09025,428,638,1470.04FI10313,2322,610,623,9710.01FR8230,72635,213,765,6650.00GR4908,258,99910,024,057,2080.08HR611,457,7671,383,346,5000.11HU24774,7516,348,073,0690.01IT1,25270,169,90918,272,146,1960.38LT1332,760,6772,359,264,3790.12LV7155,9991,256,471,0660.01NL36511,3893,452,042,1010.01PL803,494,50516,828,661,6310.02PT38957,4423,428,202,4370.03RO38513,811,4839,124,388,8200.15SE698,6583,421,057,7750.00SI580,385671,724,0470.01SK452,740,1022,149,341,0030.13TOTAL EU273,213120,933,286191,149,513,1110.06UK (1)1323,016,030Table NR26: Direct payments: number of irregularities not reported as fraudulent 2017-2021, amounts involved and irregularity  detection rate by Member StateMember StateIrregularities not reported as fraudulent in 2017-21(1) As of 1 February 2020, the UK is no longer part of the EU  
 
 
 
COMMON AGRICULTURAL POLICY 

In this map, IDR ‘0.00’ indicates low financial amounts involved in the irregularities, in proportion to the payments received. If no relevant 
irregularities were reported, no IDR is mentioned in the map for the relevant Member State. See Table NR26. UK is not included in the map. 

Tables NR25 and NR26 above suggest that the reporting of irregularities was concentrated in 
a few Member States. The top two Member States in terms of number of detections (Romania 
and  Italy)  reported  80%  of  all  fraudulent  irregularities  (and  79%  of  irregular  financial 
amounts) related to direct aid, while they received about 14% of payments. With reference to 
non-fraudulent  irregularities,  the  top  two  Member  States  in  terms  of  number  of  detections 
(Italy and Romania) reported about 51% of such irregularities (and 69% of irregular financial 
amounts), while they received about 14% of payments.   

The  concentration  of  detections  in  relation  to  direct  payments  to  farmers  was  analysed  in 
detail in the 2018 PIF Report, covering the period 2014-2018.67 The analysis suggests that the 
concentration  of  detections  went  beyond  what  could  be  expected  given  the  level  of 
concentration of payments related to direct aid to farmers among Member States.  This may 

67  Section  3.4.3.3  of  ‘Statistical  evaluation  of  irregularities  reported  for  2018:  own  resources,  agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2019)365 final 

62 

 
 
                                                           
COMMON AGRICULTURAL POLICY 

be  due  to  different  factors,  including  no  uniform  management  and  control  systems  and,  for 
the fraudulent irregularities, different approaches to criminal investigation and prosecution to 
protect the EU financial interests.  

3.4.4.  Follow-up to suspected fraud 

In  the  2019  PIF  Report,  a  new  analysis  of  the  follow-up  Member  States  give  to  suspected 
fraud has been introduced. This analysis considers the irregularities that have been reported 
as  suspected  fraud  from  2007  to  2013  and  look  at  whether  these  irregularities  have  been 
dismissed  (meaning  whether  they  have  been  de-classified  to  administrative  irregularities), 
they  are  still  pending  as  suspected  fraud  or  they  have  been  confirmed  as  established  fraud 
(following a final verdict). The details about the methodology for this analysis can be found 
in the 2019 PIF. 68 

Table NR27 includes the update of the  dismissal ratio, established fraud ratio and pending 
ratio.  The  dismissal  ratio  gives  the  percentage  of  fraudulent  irregularites  that  have  been 
reclassified as non-fraudulent during their lifetime, until end of 2021.69 The established fraud 
ratio gives the percentage of fraudulent irregularites that were classified as established fraud 
by the end of 2021.70 The pending ratio gives the percentage of fraudulent irregularities that 
were still classified as suspected fraud at the end of 2021. 71 These three percentages sum to 
100%. 

68 See  Section 3.4.4. of ‘Statistical evaluation of irregularities reported for 2019: own resources, agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2020)160 final (part 1/3) 
69 IRQ2 stands for non-fraudulent irregularities, IRQ3 stands for suspected fraud, IRQ5 stands for established 
fraud.  The  following  paths  are  considered  for 
the  dismissal  ratio:  IRQ3IRQ2,  IRQ2IRQ3IRQ2, 
IRQ5IRQ3IRQ2, IRQ3IRQ2IRQ5IRQ3IRQ2, IRQ3IRQ5IRQ3IRQ2, IRQ5IRQ2.  
70 The following paths are considered for the established fraud ratio: IRQ3IRQ5, IRQ2IRQ3IRQ5, IRQ2IRQ5, 
IRQ5, IRQ5IRQ3IRQ5, IRQ3IRQ2IRQ5.  
71  The  following  paths  are  considered  for  the  pending  ratio:  IRQ3,  IRQ2IRQ3,  IRQ5IRQ3,  IRQ3IRQ2IRQ3, 
IRQ3IRQ5IRQ3. 

63 

 
                                                           
COMMON AGRICULTURAL POLICY 

Similar  to  the  situation  up  to  2019,  about  23%  of  the  irregularities  reported  as 
fraudulent  were  dismissed  and  reclassified  as  non-fraudulent  by  the  end  of  2021. 
Another  62%  of  these  irregularities  were  still  pending.  This  may  point  to  a  significant 
underestimation of the dismissal ratio, because part of these cases that are still classified as 
suspected fraud are already closed. In any case, between 8 and 15 years have already passed 
since the detection of the irregularity and the more time passes the less it can be expected that 
fraud will actually be established. 

The  dismissal  ratio  varied  across  the  Member  States.  High  dismissal  ratios,  especially 
when associated with high pending ratios, may be due either to the detection phase or to 
the investigation/prosecution phase. Low dismissal ratios may be positive, but they may 
also be the result of many irregularities still pending. After eight years following the end 
of the period under consideration, the dismissal ratio was zero or very low in many Member 
States. This indicator must be read in combination with the pending ratio. The latter points to 
the  possibility  that  the  dismissal  ratio  increases  in  the  future  (depending  on  the  number  of 
cases  that  are  still  open)  or  to  an  underestimation  of  the  dismissal  ratio  (depending  on  the 
number  of  cases  that  are  already  closed).  High  dismissal  ratios,  especially  when  associated 
with a high number of still pending cases, may be due to (i) a detection phase that leads to 
report to the judicial authority cases that were not fraudulent; (ii) an investigation/prosecution 
phase that gives low priority or does not have enough resources to properly address the case; 
(iii) the stage of the procedure when an irregularity is classified as suspected fraud.72      

72 The dismissal ratio also depends on the stage of the procedure when an irregularity is classified as suspected 
fraud. For example, if such classification takes place  when the administrative authority forwards a case to the 

64 

RatioRatioRatio%%%AT00114686BE00113788BG2410612714563CY00001100CZ148821300DE10424171042DK13115410085EE157331362ES136500735FR1050001050GR730141565HU5778681014IE00004100IT4045894146LT00001100LU00001100LV222444333MT00005100NL00001100PL322225178760PT00001100RO32191312285SE00006100SI00431969SK00150150EU27226231491560662Table NR27 - CAP - Programming Period 2007-2013, irregularities reported during the period 2007-2013Member StateDismissalEstablished fraudPending N.N.N. 
 
                                                           
COMMON AGRICULTURAL POLICY 

The cases of established fraud were few. This may point to the need to invest further in 
the  investigation/prosecution  phase.  At  EU-27  level,  established  fraud  ratio  was  15%.  It 
was zero or very low in  many Member States. In general, the  established fraud ratio is not 
likely  to  increase  significantly  because,  while  62%  of  cases  are  still  classified  as  suspected 
fraud  (pending  ratio),  part  of  them  are  already  closed  and,  in  any  case,  between  8  and  15 
years  have  already  passed  since  the  detection  of  the  irregularity.  Similarly  to  the  dismissal 
ratio,  also  the  established  fraud  ratio  depends  on  the  stage  of  the  procedure  when  an 
irregularity is classified as suspected fraud (see above). 

3.5. 

Recovery cases 

For  an  in-depth  analysis  of  recovery  and  financial  corrections  in  the  CAP,  see  the  DG 
AGRI’s  2021  Annual  Activity  Report  and  the  2021  Annual  Management  and  Performance 
Report for the EU Budget73. 

MAIN FINDINGS 

Fraudulent irregularities 

Over the period 2017-2020, the number of fraudulent irregularities in support to agriculture 
expenditure  and  the  financial  amounts  involved  were  rather  stable,  apart  from  a  significant 
increase  of  the  financial  amounts  in  2017-2018, caused  by  just  two  cases  related  to  market 
measures. In 2021, the number of fraudulent irregularities decreased by 17% with respect to 
2020 and the financial amounts moved in the opposite direction, bouncing back to the 5-year 
average, after a record low in 2020. 

Over the period 2017-2021, fraudulent irregularities for rural development increased by 23%. 
They  were  related  to  both  PP  2007-2013  and  PP  2014-2020.  The  number  of  irregularities 
related to PP 2007-2013 fell sharply as from 2017. This is in line with the multiannual nature 
of  the  programming  period,  which  closed  in  2015.  The  number  of  reported  irregularities 
related  to  PP  2014-2020  have  been  increasing,  but  slowly.  During  the  first  eight  years  of 
implementation, the management and control systems for PP 2014-2020 detected much fewer 
fraudulent irregularities than the systems for PP 2007-2013, during the first eight years of that 
programming  period  (during  2007-2014).  This  slow  start  should  be  closely  monitored  to 
ensure it is not due to a reduced focus on combatting fraud.  

There were a number of fraudulent irregularities concerning both rural development spending 
and direct aid to farmers. 

During  2017-2021,  more  fraud  was  detected  in  rural  development  than  in  support  to 
agriculture  expenditure,  in  proportion  to  the  payments  received  by  the  Member  States.  The 
weight  of  the  financial  amounts  involved  in  fraudulent  irregularities  on  payments  (fraud 
detection  rate  -  FDR)  for  rural  development  was  more  than  double  that  for  support  to 
agriculture  (0.14%  versus  0.06%).  The  FDR  was  0.08%  for  the  overall  CAP  expenditure. 
Reimbursement-based expenditure, such as rural  development,  is more prone to  errors than 
entitlement-based expenditure and provides more opportunities for fraudsters.  Most support 
to  agriculture  payments  concern  direct  aid  to  farmers,  which  recorded  the  lowest  FDR,  at 
0.01%.  In  this  area  the  integrated  administration  and  control  system and  the  parcel 
identification system  support cross-checks, which enhances prevention. However, the other 

prosecution  service,  dismissal  is  more  likely.  If  an  irregularity  is  classified  as  suspected  fraud  only  when  a 
prosecutor requests the indictment, dismissal is less likely. 
73  COM  (2022)  401/2 on  7/6/2022.  See  also  the  Communication  from  the  Commission  to  the  Parliament,  the 
Council and the Court of Auditors on the Protection of the EU budget – COM(2016)486 on 18/7/2016. 

65 

 
 
                                                                                                                                                                                     
COMMON AGRICULTURAL POLICY 

component  of  support  to  agriculture,  market  measures,  accounted  for  the  highest  FDR,  at 
0.72%. Excluding a few irregularities involving exceptional financial amounts, the FDR was 
still 0.34%, more than double that for rural development.  

The detection of fraudulent irregularities was concentrated in few Member States. The level 
of  concentration  goes  beyond  what  could  be  expected  given  the  level  of  concentration  of  
corresponding  payments.  This  could  be  due  to  many  different  factors,  including  different 
underlying  levels  of  irregularities  and  fraud,  differences  in  the  quality  of  prevention  or 
detection work or different practices concerning the stage of the procedure when potentially 
fraudulent irregularities are reported. The concentration of detections was more accentuated 
for  fraudulent  rather  than  for  non-fraudulent  irregularities.  This  suggests  that  different 
approaches  to  criminal  investigation  and  prosecution  could  be  an  additional  and  significant 
factor explaining the different levels of detection among Member States. 

In  most  fraudulent  irregularities,  the  ‘persons  involved’  tend  to  be  legal  entities.  Most  are 
private  companies,  followed  by  non-profit  organisations,  in  particular  associations.  Most 
fraudulent irregularities involve a single entity. 

Non-fraudulent irregularities 

Over the period 2017-2021, non-fraudulent irregularities in support to agriculture expenditure 
continued to be rather stable. The irregular financial amounts linked to this part of the budget 
fluctuated strongly, mainly due to four cases related to market measures involving over EUR 
15 million each reported in  2017, 2019 and 2021, and none detected in 2018 and 2020. 

Non-fraudulent irregularities in rural development expenditure concerned both PP 2007-2013 
and PP 2014-2020. The number of irregularities related to PP 2007-2013 fell sharply during 
2017-2019,  which  was  to  be  expected,  considering  that  this  programming  period  closed  in 
2015.  Since  then,  there  were  still  detections  of  PP  2007-2013  cases  and  they  have  been 
following a stable trend. On the other hand, the  Member States started reporting detections 
related  to  PP  2014-2020,  following  an  accelerating  trend,  reflecting  progress  in  the 
implementation under this programming period.  

The  number  of  non-fraudulent  irregularities  in  rural  development  expenditure  has  regularly 
and  significantly  exceeded  those  in  support  to  agriculture  throughout  the  entire  2017-2021 
period,  with  over  double  the  number  of  irregularities.  The  ratio  of  the  financial  amounts 
involved in  non-fraudulent  irregularities on payments  (the irregularity detection rate  -  IDR) 
was  very  different  between  the  two  types  of  support,  as  it  was  0.19%  for  support  to 
agriculture and 0.71% for rural development (0.32% for the overall CAP expenditure). Most 
of  support  to  agriculture  payments  concern  direct  payments  to  farmers,  which  recorded  the 
lowest  IDR,  at  0.06%.  This  is  consistent  with  the    the  findings  of  the  European  Court  of 
Auditors,  according  to  which  payments  made  on  an  entitlement  basis  (such  as  direct 
payments  to  farmers, which represent  most of CAP  expenditure) is  less  prone to  error than 
reimbursement-based  expenditure  (such  as  rural  development).  However,  another  part  of 
support to agriculture, market measures, accounted for the highest IDR, at 2.19%. Excluding 
a few irregularities involving exceptional financial amounts, the IDR was 1.46%, still double 
than that for rural development.  

There  were  a  number  of  non-fraudulent  irregularities  concerning  both  rural  development 
spending and direct aid to farmers. 

66 

 
 
 
COMMON AGRICULTURAL POLICY 

Types of violation – support to agriculture 

Fraudulent irregularities 

Over the period 2017-2021, fraudulent irregularities in support to agriculture mainly concerned the 
documentary proof. Fraudulent irregularities concerning the request were also recurrent. In most 
cases, these irregularities concerning documentary proof or request were due to falsification. In the 
case of direct payments, most of these violations were concentrated in two Member States.  A wide 
range of documents and information can be falsified, such as lease agreements, property documents, 
compliance with the conditionality requirements. 

The Member States detected few fraudulent cases related to the implementation of the action, 
but there were also several cases in combination with other violations, such as documentary 
proof, the request, ethics and integrity. These cases accounted for the second highest financial 
amounts involved and were related to market measures.  

Irregularities concerning product, species and/or land were more frequently detected, mostly 
in  relation  to  direct  aid  to  farmers.  The  majority  of  these  violations  concerned  over  or 
fictitious declarations.  

High  average financial  amounts (about  EUR 1.8  million) were  recorded in several  cases of 
conflict  of  interest  combined  with  other  violations.  These  irregularities  were  related  to  the 
market  measure  ‘promotion’  and  were  investigated  by  OLAF,  which  uncovered  complex 
fraudulent  schemes,  mainly  based  on  price  inflation,  kickback  payments  and  money 
laundering.  The  public  procurement  procedures  were  also  breached  via  a  solid  network  of 
companies  based  in  different  countries.  In  some  cases,  the  manipulation  was  possible  also 
due to the collusion of the beneficiaries. 

One Member State reported a significant number of fraudulent cases of beneficiaries creating  
artificial  conditions  to  receive  financial  support,  under  the  category  ‘ethics  and  integrity’. 
Most  of  these  cases  concerned  direct  aid  to  farmers.  For  example,  beneficiaries  may 
artificially split agricultural holdings and request  aid via several linked companies, to avoid 
degressive  aid  rates  or  limits  in  terms  of  area  or  animals.  Either  the  other  Member  States 
failed to detect similar irregularities or they reported them under other categories. 

Non-fraudulent irregularities 

Non-fraudulent  violations  mostly  concerned  requests  for  aid,  most  of  the  times  because  of 
falsification of documents (which would not be expected for non-fraudulent irregularities) or 
incomplete/incorrect  requests,  in  relation  to  direct  payments  to  farmers.  When  these 
violations  concerned  market  measures,  they  were  about  products  or  species  not  eligible  for 
aid.  

Non-fraudulent violations concerning the documentary proof increased significantly in 2021, 
mainly because of detections in one Member State in relation to direct payments to farmers 
(incomplete/incorrect documents). 

Concerning  violations  related  to  the  implementation  of  the  action,  the  infringements 
concerning market  measures were prevalent, with (i) the highest  financial  amounts in cases 
where  the  action  was  not  implemented  and  in  cases  where  the  beneficiary  carried  out  an 
operation that was prohibited during the measure;  (ii) the highest  frequency of cases where 
the action was not implemented or not completed.   

The vast majority of violations concerning the beneficiary were related to direct payments to 
farmers and were about the beneficiary not having the required quality. This is the cases also 
for  the  market  measures,  where  higher  financial  amounts  were  involved  and  which  more 

67 

 
COMMON AGRICULTURAL POLICY 

frequently were combined with other types of infringements, especially in the implementation 
of the action.  

Another  recurrent  type  of  irregularities  not  reported  as  fraudulent  concerned  the  products, 
species  or  land,  in  particular  in  relation  to  direct  payments  to  farmers  (mostly  over  or 
fictitious declarations), but also market measures (mostly, inexact quantities). 

Concerning  'ethics  and  integrity',  apart  from  two  cases  of  conflict  of  interest  in  relation  to 
market measures, all of these violations were reported as 'other’. 

Types of violations – rural development 

Fraudulent irregularities 

Similar to irregularities in support to agriculture, over the period 2017-2021, irregularities in 
rural development mainly involved cases of falsified documentary proof or, to a lesser extent, 
falsified  requests  for  aid.  This  may  include  falsified  invoices,  declarations  of  equipment  as 
new  while  it  is  second-hand,  bids  in  the  context  of  procurement  and  information  on 
compliance with conditions for receiving the aid. A significant number of rural development 
fraudulent irregularities were related to the action, which was often not implemented.  

One  Member  State  reported  a  high  number  of  rural  development  fraudulent  cases  of 
beneficiaries  creating  artificial  conditions  to  receive  financial  support,  under  the  category 
‘ethics and integrity’ (see also support to agriculture). Only two irregularities were reported 
as corruption and a few as conflict of interest, especially in procurement and in combination 
with other violations such as false documents or requests, non-implentation of the action. 

Non-fraudulent irregularities 

The highest number of non-fraudulent irregularities in rural development were related to the 
action,  most  often  not  completed,  not  implemented  or  delayed.  Violations  concerning  the 
documentary  proof  (most  often  missing)  or  the  beneficiary  (most  often  not  having  the 
required  quality)  were  also  recurrent.  They  were  also  often  combined  with  the  violations 
concerning the action and with each other. Several cases of falsified documents or requests of 
aid were reported, which would not be expected for non-fraudulent irregularities. Most of the 
violations  concerning  product,  species  or 
fictitious 
declarations.There were just a few reported cases of conflict of interest, mostly in relation to 
procurement.  

land  were  due 

to  over  or 

Zooming in on market measures 

Individual  fraudulent  and  non-fraudulent  irregularities  involving  the  highest  financial 
amounts  are  often  related  to  market  measures.  From  2017-2021,  a  few,  but  high-impact 
irregularities were related to aid to producer groups for preliminary recognition in the ‘fruits 
and vegetables’ sector and a food programme for deprived persons. 

The  highest  number  of  irregularities  reported  as  fraudulent  concerned  national  support 
programmes for the wine sector. Irregularities affected in particular investment measures and 
the restructuring and conversion of vineyards. However, fraud hit also promotion measures, 
including in non-EU markets.    

The  highest  total  financial  amounts  were  related  to  market  measures  concerning  fruits  and 
vegetables, which most often concerned aid to producer groups for preliminary recognition. 
In  general,  fraud  touched  both  measures  concerning  formation/administrative  operation  and 
measures concerning investment, sometimes together in the same case. The financial amounts 
involved  were  high  also  for  the  market  measure  specifically  related  to  the  promotion  of 

68 

 
COMMON AGRICULTURAL POLICY 

agricultural products. Fraud affected both promotion in the EU markets and in third countries, 
with higher irregular financial amounts involved in the latter. 

The majority of the irregularities not  reported as fraudulent concerned market  measures  for 
products of the wine-growing sector, most of the times related to restructuring and conversion 
of  vineyards.  In  the  context  of  products  for  the  wine  sector,  also  irregularities  related  to 
investments  were  frequently  reported.  When  promotion  measures  were  concerned,  the 
majority of cases were related to promotion in third countries. 

Promotion  of  agricultural  products  was  affected  by  non-fraudulent  irregularities  also  when 
not related to the wine sector. In this case, the majority of irregularities concerned promotion 
within the EU. 

The highest financial amounts were involved in non-fraudulent irregularities related to 'fruit 
and vegetables'. In particular, this was due to irregularities related to aid to producer groups 
for  preliminary  recognition.  They  concerned  both  investments  and  formation/administrative 
operation, sometimes together in the same irregularity. Even more frequent than irregularities 
related to aid for preliminary recognition were irregularities concerning operational funds for 
producers organisations.  

Programmes  of  Option  Specifically  Relating  to  Remoteness  and  Insularity  (POSEI)  were 
often affected by non-fraudulent irregularities. Most of the times, this  was linked to supply 
arrangement or other measures. 

The  school  schemes  were  also  not  free  from  non-fraudulent  irregularities,  in  particular 
concerning the supply and distribution of the products. The majority of cases were related to 
fruit and vegetables. 

Risk analysis and spontaneous reporting 

With  reference  to  rural  development  and  direct  payments  to  farmers,  risk  analysis  and 
spontaneous  information  from  civil  society,  including  from  the  media,  have  a  marginal 
contribution in detecting fraudulent and non-fraudulent irregularities.  

In  relation  to  market  measures,  risk  analysis  has  a  stronger  role  in  detection,  including 
because  the  risk-based  scrutiny  of  commercial  documents  of  those  entities  receiving 
payments.  About  7%  of  the  fraudulent  irregularities  were  detected  following  tips,  which  is 
similar to other CAP sectors. 

Anti-fraud work carried out by the Member States 

The  Member  States  are  requested  to  indicate  the  date  or  period  when  the  irregularity  was 
committed.  Most  irregularities  covered  extended  spans  of  time,  particularly  in  cases  of 
fraudulent  irregularities,  consistent  with  their  intentional  nature.  The  average  duration  of 
these  protracted  irregularities  is  about  two  years,  both  for  fraudulent  and  non-fraudulent 
cases.  

Detection rates are the outcome of the checks carried out by the Member States and they can 
vary across Member States due to different underlying levels of irregularities and fraud, but 
also  due to  differences  in the quality of prevention or detection work or  different reporting 
practices.  Over  the  period  2017-2021,  the  FDRs  exceeded  0.5%  in  Estonia  and  0.30%  in 
Romania and Bulgaria. However, the picture changes depending on the CAP sector. For rural 
development,  Estonia,  Denmark  and  Romania  recorded  the  highest  FDRs,  while  Bulgaria, 
Portugal  and  and  Malta  scored  the  highest  IDRs.  For  market  measures,  the  FDR  was  the 
highest in Poland and Bulgaria, but also significantly higher than the EU average in Czechia. 

69 

 
COMMON AGRICULTURAL POLICY 

The IDR was the highest in Poland, but it was high also in Malta and Romania. For direct aid, 
Romania recorded the highest FDR and Italy the highest IDR. 

Therefore, detection levels were different across the Member States. In all CAP sectors (rural 
development, market measures and direct aid) the level of detection of irregularities and fraud 
across the different Member States was uneven. The level of concentration among Member 
States was analysed in detail in the 2018 PIF Report, covering the period 2014-2018. 

For  rural  development,  this  analysis  suggested  that  the  difference  in  level  of  concentration 
between detections and payments was less pronounced for non-fraudulent irregularities, even 
though  the  examination  of  data  on  individual  Member  States  highlighted  significant 
discrepancies.  The  concentration  of  detections  was  instead  more  accentuated  for  fraudulent 
irregularities, suggesting that different  approaches to  criminal  investigation and prosecution 
could  be  an  additional  and  significant  factor  explaining  the  different  levels  of  detection 
among Member States. Also in the specific case of market measures, this analysis found that 
the  level  of  concentration  of  detections  went  beyond  what  could  be  expected  given  the 
distribution of corresponding payments, especially for fraudulent irregularities.  

According  to  the  same  analysis,  direct  aid  was  the  CAP  sector  with  the  highest  level  of  
concentration. This may be due to different factors, including not uniform management and 
control  systems  and,  for  the  fraudulent  irregularities,  different  approaches  to  criminal 
investigation and prosecution. Specific problems may occur at the local level that need to be 
correctly and promptly addressed by the competent national authorities. 

About  one  fourth  of  the  irregularities  reported  as  fraudulent  were  dismissed.  The  dismissal 
ratio varied across the Member States. High dismissal ratios, especially when associated with 
a high number of still pending cases, may be due to (i) a detection phase that leads to report 
to the judicial authority cases that were not fraudulent; (ii) an investigation/prosecution phase 
that gives low priority or does not have enough resources to properly address the case; (iii) 
the stage of the procedure when an irregularity is classified as suspected fraud.    

Analysis suggests that the dismissal ratio is significantly underestimated. About 62% of the 
irregularities reported as fraudulent were still pending. However, for part of them no changes 
of  status  are  to  be  expected,  because  they  are  closed  cases.  In  any  case,  between  8  and  15 
years  have  already  passed  since  the  detection  of  the  irregularity.  There  were  few  cases  of 
established fraud. This may indicate the need to invest further in the investigation/prosecution 
phase.  

70 

 
 
COHESION AND FISHERIES 

4. 

COHESION, FISHERIES AND OTHER INTERNAL POLICIES 

EXECUTIVE SUMMARY 

Section 4 analyses fraudulent and non-fraudulent irregularities reported by the Member States 
to  the  Commission  through  the  Irregularity  Management  System.  It  mainly  focuses  on  the 
irregularities related to the Cohesion and Fisheries policies, financed by the Cohesion Fund, 
the  European  Regional  Development  Fund,  the  European  Social  Fund  and  the  Fisheries 
Funds (the European Structural and Investment Funds - ESIF).   

Between 2017 and 2021, the number of fraudulent and non-fraudulent irregularities related to 
the  programming  period  2007-2013  decreased  for  the  ESIF.  The  number  of  irregularities 
reported for the programming period 2014-2020 increased. These dynamics are in line with 
known trends and patterns in the detection and reporting of irregularities and are linked to the 
implementation cycle of multiannual programmes.  

The  number  of  irregularities  reported  as  fraudulent  for  the  programming  period  2014-2020 
were  in  line  with  those  detected  for  the  programming  period  2007-2013  after  the  same 
number  of  years  from  the  start  of  the  period.  This  is  not  the  case  for  non-fradulent 
irregularities. For them, the fall in the number and financial amounts reported after eight 
years from  the start  of the programming period  is  striking. Analysis identifies a number of 
potential explanations that may cover a significant part of this strong decline, such as delay in 
implementation of operational programmes, changes in reporting practices, increased use of 
simplified  cost  options,  the  introduction  of  the  annual  accounts,  increased  capability  of 
implementing bodies and beneficiaries. 

Risks  of  irregularities  seem  to  be  higher  in  the  areas  of  the  cohesion  policy  related  to 
transport,  environment  protection,  research,  technological  development  and  innovation 
(RTD&I), social inclusion and promotion of employment and labour mobility. 

Analysis points to risks related to the green transition, including for investments in energy 
efficiency,  in  the  provision  of  drinking  water,  in  waste  management,  in  renewable  energy 
(solar) and in risk prevention. Risks to the digital transition seem to be pointing at services 
and applications for SMEs, in terms of number of irregularities and services and applications 
for e-Government, in terms of financial amounts involved. Irregularities were reported also in 
relation to investments in the infrastructure for the digital transition. 

Concerning RTD&I, analysis suggests higher risks for investments to provide  assistance to 
these  activities  in  firms.  Measures  to  stimulate  research,  innovation  and  entrepreneuship  in 
SMEs were particularly affected.  

Risks  are  high  in  relation  to  investments  in  the  transport  infrastructure,  because  of  the 
frequency of irregularities in generic road projects, which reach the regional and local level, 
and because of the high financial amounts involved in irregularities concerning railways and 
Trans-European  Network  (TEN)  roads.  Also  investments  in  TEN  multimodal  infrastructure 
and in the electricity networks seem to be quite risky.   

Risks  in  relation  to  social  inclusion,  poverty  and  discrimination  seem  to  be  higher  for 
investments  in  (i)  active  inclusion;  (ii)  health  infrastructure;  (iii)  improved  access  to 
healthcare and social services;  (iv) social infrastructure and regeneration  of rural  and urban 
areas;  (v) 
in  favour  of  marginalised  communities  and  (vi)  childcare 
infrastructure.  

investments 

In relation to the promotion of employment and labour mobility, risks seem to be higher for 
investments  for  (i)  the  adaptation  to  change  of  workers  and  enterprises,  in  particular 

71 

 
 
COHESION AND FISHERIES 

operations  for  the  design  and  dissemination  of  innovative  and  more  productive  ways  of 
working;  (ii)  access  to  employment,  in  particular  operations  for  job-seekers  and  inactive 
people, including the long-term unemployed and people far from the labour market, and (iii)  
support for self-employment and business start-up. 

The most frequent fraudulent violations were about the use of false or falsified documents.  
High  financial  amounts  were  involved  where  fraudulent  infringements  of  contract 
provisions/rules  took  place.  This  type  of  fraud  often  consisted  in  incomplete  or  non-
implementation of the funded action. Most of fraudulent violations concerning ethics and 
integrity were about conflict of interests. Infringements of public procurement rules were 
the most reported among non-fraudulent violation, but only in 4% of  these cases fraud was 
detected.  

Risk  analysis  has  still  a  marginal  contribution  in  detecting  fraud,  while  information  from 
civil  society  (including  information  published  in  the  media)  has  a  significant  and  growing 
role. This is not the case for non-fraudulent irregularities. Detection of fraud and irregularities 
could  improve  through  ex-post  thematic  risk  analysis  projects  focusing  on  groups  of  past 
transactions.       

Two thirds of the irregularities have been occurring over a period of time, averaging nearly 
one  year  and  a  half.  The  rest  of  the  irregularities  consisted  of  a  single  act  identifiable  on  a 
precise date. On average, it took more than one year to come to a suspicion that a fraudulent  
irregularity  had  been  committed  and  one  year  and  a  half  to  close  the  case  after  reporting. 
These  average  times  are  expected  to  increase  as  the  implementation  of  the  operational 
programme progresses.   

With  reference  to  the  programming  period  2014-2020,  the  Fraud  Detection  Rates  (FDR) 
recorded  by  Romania  and  Slovakia  were  very  high,  but  due  to  single  irregularities  that 
involved  huge financial amounts. These irregularities also had a strong impact on the EU-27 
FDR,  which  was  about  1%  and  higher  than  in  the  programming  period  2007-2013.  In  line 
with  the  general  deep  decrease  in  non-fraudulent  irregularities  reported,  the  Irregularity 
Detection Rate (IDR) was above 1% only in Slovakia, Romania, Bulgaria, Greece. At EU-27 
level,  IDR  was  about  0.7%,  much  lower  that  in  the  programming  period  2007-2013.  These 
FDRs and IDRs for the programming period 2014-2020 are likely to change significantly in 
the coming years, with progress in the implementation of the operational programmes.  

After about 10 years from initial reporting, the share of cases of suspected fraud that have not 
led to conviction remains very high, while the share of cases in which fraud is established is 
low.  This  may  signal  the  need  to  invest  further  in  reporting  suspected  fraud  and  in  the 
investigation/prosecution phase.  

Concerning shared management  Funds for other  internal policies, the FEAD was the  Fund 
most affected by fraud. More than 90% of the detections of non-fraudulent irregularities were 
related to the following Funds: AMIF, the FEAD and the YEI.  

72 

 
 
 
 
 
COHESION AND FISHERIES 

4.1. 

Introduction 

Section 4 presents a statistical evaluation of irregularities and fraud detected by the Member 
States  during  2021,  with  reference  to  the  cohesion  and  fishery  policies.  It  places  these 
detections in the context of past years and relevant programming periods. The Member States 
reported  these  irregularities  and  cases  of  fraud  to  the  Commission  through  the  Irregularity 
Management System (IMS). 

Over half of EU funding is channelled through the five European Structural and Investment 
Funds (ESIF): 

  The  European  Regional  Development  Fund  (ERDF),  which  promotes  balanced 

development in the different regions of the EU; 

  The European Social Fund (ESF), which supports employment-related projects throughout 
Europe  and  invests  in  Europe’s  human  capital,  i.e.  its  workers,  its  young  people  and  all 
those seeking a job; 

  The  Cohesion  Fund  (CF),  which  funds  transport  and  environment  projects  in  countries 
where the gross national income (GNI) per inhabitant is less than 90% of the EU average. 
In 2014-2020, these countries were  Bulgaria, Croatia, Cyprus, Czechia,  Estonia, Greece, 
Hungary, Latvia, Lithuania, Malta, Poland, Portugal, Romania, Slovakia and Slovenia; 

  The  European  Agricultural  Fund  for  Rural  Development  (EAFRD)74,  which  focuses  on 

resolving the particular challenges facing the EU's rural areas; 

  The  European  Maritime  and  Fisheries  fund  (EMFF),  which  helps  fishers  to  adopt 
sustainable  fishing  practices  and  coastal  communities  to  diversify  their  economies, 
improving quality of life along European coasts. Due to the operating rules of the EMFF 
and  the  European  Fisheries  Fund  (EFF),  which  are  very  similar  to  those  of  the  other 
Structural Funds, irregularities reported by Member States in relation to fisheries policies 
are treated in this section, jointly with the Funds for cohesion and economic convergence. 

The  purpose  of  all  these  funds  is  to  invest  in  job  creation  and  a  sustainable  and  healthy 
European  economy  and  environment.  They  mainly  focus  on  five  areas:  (i)  research  and 
innovation; (ii) digital technologies; (iii) supporting the low-carbon economy; (iv) sustainable 
management of natural resources; and (v) small businesses.  

The European Commission and the EU Member States jointly manage ESIF. Each Member 
State prepared a partnership agreement, in collaboration with the Commission.  

After  this  introduction,  Section  4.2.  focuses  on  general  trends  for  fraudulent  and  non-
fraudulent  irregularities.  It  compares  detection  in  the  programming  period  (PP)  2014-2020 
with  detection  in  PP  2007-2013,  to  better  assess  current  trends  in  detecting  irregularities. 
Section 4.3. analyses more specifically fraud and irregularities to get a better undestanding on 
how different areas of the cohesion policy were impacted, including research and innovation 
and the green and digital  transitions,  which are central  also  to  the Recovery  and Resilience 
Facility.  The  same  section  includes  an  analysis  of  the  types  of  violations  reported  for  the 
cohesion  policy.  Section  4.4.  focuses  on  the  reasons  for  carrying  out  checks  that  led  to  the 
detection of irregularities. Section 4.5. takes  a  closer look  at the Member States’ anti-fraud 
activities and the results obtained, analysing fraud and irregularity detection rates (the  ratio 
between  the  amounts  involved  in  cases  reported  as  fraudulent  (FDR)  or  not  reported  as 

74  EAFRD  expenditure  is  considered  in  Section  3  'Common  agricultural  policy',  when  focusing  on  rural 
development. 

73 

 
 
                                                           
COHESION AND FISHERIES 

fraudulent  (IDR)  and  the  relevant  payments).  Section  4.6.  provides  figures  on  other  shared 
management Funds. 

4.2. 

General analysis 

The  analysis  in  this  section  refers  to  the  EU-27,  unless  specified  otherwise.  UK  data  is 
added in the tables, as specified, to give a complete picture. However, the accompanying 
analysis is focused on the current Member States and the EU-27 aggregate. In the whole 
section, when reference is made to ‘fraudulent’ or ‘fraud’, it includes ‘suspected fraud’ and 
‘established fraud’.75 

Member States are requested to communicate: 

  non-fraudulent irregularities only when they are  detected  after the expenditure has been 
introduced in a statement submitted to the Commission. This derogation does not apply to 
fraudulent irregularities: Member States must always report them.  

 

fraudulent  and  non-fraudulent  irregularities  with  financial  amounts  above  EUR 10 000. 
During 2017-2021, several Member States reported also a number of irregularities below 
this  threshold.  However,  these  irregularities  represented  about  1%  of  all  irregularities 
reported  (EU-27).  They  are  included  in  the  analysis  for  this  section,  to  make  use  of  all 
available information. 76 

Analysis  of  the  EU  cohesion  policy  is  more  complex  than  other  budget  sectors,  as 
information refers to different programming periods, which are regulated by different rules. 

4.2.1. 

Irregularities reported as fraudulent 

4.2.1.1.   Trend by programming period 

Table  CP1  below  provides  an  overview  by  programming  period  and  by  Fund  of  the 
irregularities reported as fraudulent in the past 5 years (2017-2021)77. 

Fraudulent irregularities related to PP 2007-2013 peaked in 2015, gradually decreased in 
the following years and in 2018 they were overtaken by those related to PP 2014-2020. These 
dynamics  are  in  line  with  known  trends  and  patterns  in  the  detection  and  reporting  of 
irregularities and are linked to the PP 2007-2013 implementation cycle78.  

75  ‘Suspected  fraud’  means  an  irregularity  that  gives  rise  to  the  initiation  of  administrative  or  judicial 
proceedings at national level in order to establish the presence of intentional behaviour, in particular fraud, as 
referred to in Article 1(1)(a) of the Convention drawn up on the basis of Article K.3 of the Treaty on European 
Union, on the protection of the European Communities’ financial interests’. Regardless of the approach adopted 
by  each  Member  State,  ratification  of  the  1995  Convention  has  equipped  every  country  with  a  basis  for 
prosecuting and possibly imposing penalties for specific conducts. If this occurs, i.e. a guilty verdict is  issued 
and  is  not  appealed  against,  the  case  can  be  considered  ‘established  fraud’.  See  ‘Handbook  on  ‘Reporting 
irregularities in shared management’ (2017). 
76  Data  for  this  section  was  downloaded  from  the  irregularity  management  system  (IMS)  on  7  March  2022. 
When entering a case, the contributor is requested to specify the currency in which the amounts are expressed. 
Where the value of this field is 'EUR' or the field was left blank, no transformation is applied. Where this field 
was  filled  with  another  currency,  the  financial  amounts  involved  in  the  irregularity  have  been  transformed, 
based on the exchange rates published by the European Central Bank (ECB) at the beginning of 2022. 
77 In some cases, the Member States reported irregularities as non- fraudulent, while a penal procedure had been 
started.  This  may  be  due  to  the  need  to  wait  for  some  procedural  steps  before  classifying  an  irregularity  as 
fraudulent. These cases are not included as fraudulent in the analysis for this  report; considering them as such 
would  increase  the  number  of  fraudulent  irregularities  by  about  11%  (1%  in  terms  of  financial  amounts 
involved). 
78 When support is based on multiannual programmes, the number of irregularities can be expected  to increase 
around  the  end  of  the  eligibility  period  and  decrease  afterwards,  when  routine  controls  are  less  intense.  In 

74 

 
 
                                                           
COHESION AND FISHERIES 

Reporting related to PP 2014-2020 basically started in 2017. It has been fluctuating around 
an  increasing  trend,  with  ups  in  2018  and  2020  and  downs  in  2019  and  2021.  These 
fluctuations are typical of detection of fraudulent cases, which is less linked to routine checks 
than detection of non-fraudulent irregularities. The current fraud frequency level (FFL)79 for 
PP 2014-2020 is high, at 10%: one irregularites out of ten is reported as fraudulent. To put 
this  into  context,  during  the  whole  period  between  2007  and  2021,  FFL  for  PP  2007-2013 
was  half  of  it,  just  5%.  This  higher  tendency  to  detect  fraud  is  influenced  by  a  strong 
decrease in non-fraudulent irregularities during PP 2014-2020. This is analysed further in 
the next sections.  

Table CP2 below provides an overview by programming period and by Fund of the financial 
amounts involved in cases reported as fraudulent. The financial amounts tend to fluctuate 
more due to the possibility of individual cases involving high amounts.  

For PP 2007-2013, while the number of irregularities peaked in 2015, the financial amounts 
remained around the highest level until 2016. Then, the amounts significantly decreased in 
2017 and further dropped in 2019. In 2020, there was a limited rebound mainly due to  one 
ERDF irregularities reported by Italy, totalling about EUR 18 million.  

general, increases in the number of reported irregularities can be influenced by Member States’ building up their 
capacity to detect fraudulent irregularities. 
79 FFL is the ratio between the number of fraudulent irregularities reported during a certain period and the total 
number of irregularities (fraudulent and non-fraudulent) reported during the same period.  

75 

20172018201920202021NNNNNNProgramming period 2014-2019176102230158685CF023124856ERDF610671148111442ESF1336255435163EMFF01154424Programming period 2007-13222119714957518CF13264631ERDF17396404030379ESF31201941589EFF5161619Programming period 2000-06330006ERDF030003ESF300003TOTAL EU272442981732792151,209UK1334314Table CP1: Number of irregularities reported as fraudulent between 2017 and 2021 by programming period - Cohesion and fisheries policiesFUND / PROGRAMMING PERIODREPORTING YEARTOTAL PERIOD05010015020025020172018201920202021Number of irregularities by Programming period -2017-2021 (EU27)Programming period 2007-13Programming period 2014-20Programming period 2000-06 
 
 
                                                                                                                                                                                     
COHESION AND FISHERIES 

For  PP  2014-2020,  the  financial  amounts  skyrocketed  at  EUR 650  million,  in  2018,  and  at 
EUR 1 600 million, in 2021. In 2018, this was due to two ERDF irregularities reported by 
Slovakia, accounting together for EUR 590 million. In 2021, the peak was mainly due to 
one  ERDF  irregularity  reported  by  Romania,  accounting  for  EUR  1 270  million.  In 
addition,  two CF irregularities reported by Slovakia  and Romania,  accounted together 
for EUR 190 million. The acceleration in 2020 was supported by five CF cases reported by 
Romania, totalling EUR 85 million. 

Those involved in fraudulent irregularities were most often legal entities. In most Member States, 
private companies represent the majority of those involved. The only exception with a large sample 
is Spain, where most of the reported entities were sub-national governmental bodies80. 

4.2.1.2.   Trend by Fund 

Tables CP3 and CP4 below focus on the distribution by Fund of the irregularities reported as 
fraudulent:   

(1)  Also because of the higher share of EU financing channelled through it, ERDF was the 
Fund most affected, because it had the highest number of cases reported as fraudulent, 
and the related financial amounts were the highest. Of the irregularities detected between 

80  This  is  based  on  the  analysis  included  in  the  2019  PIF  Report,  covering  2015-2019  (see  Section  4.2.3.  of 
‘Statistical  evaluation  of  irregularities  reported  for  2019:  own  resources,  agriculture,  cohesion  and  fisheries 
policies, pre-accession and direct expenditure’, SWD(2020)160 final (part 2/3)). A person involved is anyone 
who had or has a substantial role in the irregularity. This could be the beneficiary, the person who initiated the 
irregularity (such as the manager, consultant or adviser), the person who committed the irregularity, etc. 

76 

20172018201920202021EUREUREUREUREUREURProgramming period 2014-208,560,619664,986,58726,905,197160,595,5591,587,616,2152,448,664,177CF017,184,3671,041,151115,022,891223,124,824356,373,233ERDF5,764,229640,092,62223,762,66037,961,5911,355,081,0482,062,662,150ESF2,796,3906,648,1931,798,3314,896,2998,920,74925,059,962EMFF01,061,405303,0552,714,778489,5944,568,832Programming period 2007-13130,318,433149,702,90023,377,10146,451,87936,432,833386,283,146CF6,231,299326,6962,580,0641,902,89211,390,26222,431,213ERDF116,052,965111,913,29419,776,66240,283,82115,928,548303,955,290ESF4,103,72537,426,779361,3954,212,3887,816,44653,920,733EFF3,930,44436,131658,98052,7781,297,5775,975,910Programming period 2000-06298,5362,691,7060002,990,242ERDF02,691,7060002,691,706ESF298,5360000298,536TOTAL EU27139,177,588817,381,19350,282,298207,047,4381,624,049,0482,837,937,565UK40,118999,0241,193,812250,894349,7852,833,633Table CP2: Financial amounts related to the irregularities reported as fraudulent between 2017-2021 by programming period - Cohesion and fisheries policiesFUND / PROGRAMMING PERIODREPORTING YEARTOTAL PERIOD0200,000,000400,000,000600,000,000800,000,0001,000,000,0001,200,000,0001,400,000,0001,600,000,0001,800,000,00020172018201920202021Financial amounts involved in irregularities reported as fraudulent, by Programming period -2017-2021 (EU27)Programming period 2007-13Programming period 2014-20Programming period 2000-06 
 
 
                                                           
COHESION AND FISHERIES 

2017  and  2021  for  PP  2007-2013,  73%  (79%  of  financial  amounts)  concerned  ERDF. 
For PP 2014-2020, 65% (84% of the financial amounts) concerned ERDF. 

The  number  of  irregularities  reported  as  fraudulent  jumped  in  2015.  Then,  it  has 
fluctuated around the new, higher level, until 2018. In 2019, there was a significant 
drop in the reporting of fraudulent irregularities, due to a decrease in detections both 
for  PP  2007-2013  and  2014-2020.  Since  then,  the  number  of  fraudulent  irregularities 
related to PP 2007-2013 was rather low and stable, while the number of those related 
to PP 2014-2020 fluctuated around an increasing trend.  

Instead of peaking in 2015, the ERDF financial amounts continued to increase in 2016, 
and  in  2018  and  2021  they  litterally  skyrocketed.  As  mentioned,  these  extreme  rises 
were due to the two irregularities reported by Slovakia (totalling EUR 590 million) 
and the irregularity reported by Romania (accounting for about EUR  1 270) for PP 
2014-2020. 

(2)  After  a  decrease  in  2017,  the  number  of  ESF  fraudulent  irregularities  was  rather 
stable.  The  financial  amounts  recorded  an  extraordinary  increase  in  2018,  due  to  an 
irregularity  reported  by  Portugal,  accounting  for  more  than  EUR  30  million, 
related to PP 2007-2013. 

(3)  Since 2010, potential fraud affecting the CF is regularly reported. In 2018, the majority 
of detections  took  place in  Slovakia, while in 2020 it was  Romania reporting most 
cases. The amounts can fluctuate quite significantly, because of the low number of cases 
and  high  amounts  involved  in  the  projects  financed  by  the  CF.  In  2020,  the  financial 
amounts jumped to nearly EUR 120 million, mainly due to five irregularities reported 
by  Romania,  totalling  EUR  85  million.  In  2021,  the  financial  amounts  climbed  even 
further  to  more  than  EU  230  million,  mainly  due  to  one  irregularity  reported  by 
Slovakia  (accounting  for  EUR  118  million)  and  two  irregularities  reported  by 
Romania (totalling together EUR 105 million).  

These  trends  in  financial  amounts  are  also  due  to  different  reporting  patterns  in  the 
Member States. This is examined in the 2019 PIF Report, with reference to the 2015-2019 
period81. For example, for the ERDF, Slovakia had a tendency to detect and report fraudulent 
cases  with  large  financial  amounts,  supported  by  the  propensity  to  identify  irregularities 
covering most of the expenditure of the related projects/operations.  

81 See Section 4.1.1.2. of ‘Statistical evaluation of irregularities reported for 2019: own resources, agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2020)160 final (part 2/3) 

77 

 
 
                                                           
COHESION AND FISHERIES 

78 

20172018201920202021EUREUREUREUREUREURCF13257281487ERDF179205111188141824ESF4756445850255EFF5161619EMFF01154424TOTAL EU272442981732792151,209UK1334314REPORTING YEARTOTAL PERIODFUNDTable CP3: Number of irregularities reported as fraudulent between 2017-2021 by Fund - Cohesion and fisheries policies7%68%21%2%2%Irregularities reported as fraudulent 2017-2021 by Fund (EU27)CFERDFESFEFFEMFF6%66%23%3%2%Irregularities reported as fraudulent in 2021by Fund (EU27)CFERDFESFEFFEMFF05010015020025020172018201920202021Irregularities reported as fraudulent 2017-2021 by Fund (CF, ERDF, ESF) (EU27)CFERDFESF20172018201920202021EUREUREUREUREUREURCF6,231,29917,511,0623,621,215116,925,783234,515,085378,804,444ERDF121,817,194754,697,62243,539,32278,245,4121,371,009,5962,369,309,146ESF7,198,65244,074,9722,159,7269,108,68716,737,19579,279,232EFF3,930,44436,131658,98052,7781,297,5775,975,910EMFF01,061,405303,0552,714,778489,5944,568,832TOTAL EU27139,177,589817,381,19250,282,298207,047,4381,624,049,0472,837,937,564UK40,118999,0241,193,812250,894349,7852,833,633Table CP4: Financial amounts related to irregularities reported as fraudulent between 2017-2021 by Fund - Cohesion and fisheries policiesREPORTING YEARTOTAL PERIODFUND13%84%3%0%Irregularities reported as fraudulent 2017-2021by Fund (EU27)CFERDFESFEFFEMFF15%84%1%Irregularities reported as fraudulent in 2021by Fund (EU27)CFERDFESFEFFEMFF02004006008001,0001,2001,4001,60020172018201920202021MillionsFinancial amounts involved in irregularities reported as fraudulent 2017-2021 by Fund (CF, ERDF, ESF) (EU27)CFERDFESF 
 
 
 
 
COHESION AND FISHERIES 

4.2.2. 

Irregularities not reported as fraudulent 

Table  CP5  below  provides  an  overview  by  programming  period  and  by  Fund  of  the 
irregularities not reported as fraudulent in the past five years (2017-2021). Table CP6 below 
shows the financial amounts involved in these irregularities. As mentioned, fluctuations in the 
financial amounts  are broader and more frequent than in the number of detections and they 
can be linked to individual irregularities or groups of irregularities of huge value.  

The decrease in the number of irregularities and financial amounts related to PP 2007-
2013 was significant. This is in line with the multiannual nature of structural programmes, 
which were closed already in 2015. This trend was common to all Funds. Also the financial 
amounts  dropped  in  2018  and  2019,  then  started  increasing  again.  In  2020,  the  financial 
amounts increased for all Funds, except for the EFF, while in 2021, the financial amounts 
increased  only  for  the  CF.  This  was  influenced  by  single  cases  with  very  high  financial 
amounts  involved.  In  2020,  Slovakia  reported  two  CF  non-fraudulent  irregularities, 
totalling more than EUR 40 million, and Romania and Slovakia reported two ERDF cases, 
accounting  together  for  EUR  30  million.  In  2021,  Hungary  reported  a  CF  irregularity, 
accounting for EUR 66 million. 

Basically, reporting related to PP 2014-2020 began in 2016. Since then, these detections and 
irregular  financial  amounts  have  been  increasing  for  all  Funds,  but  less  than  expected 

79 

20172018201920202021NNNNNNProgramming period 2014-201928281,3031,9922,0816,396CF3896146124120524ERDF94470768132113423,995ESF572513495125591,728EMFF311403560149Programming period 2007-134,5679243853101856,371CF39383343225567ERDF33256093042261374,601ESF676213293713968EFF17319181510235Programming period 2000-0686127538CF100001ERDF55112326ESF110125GUID101406TOTAL EU274,7671,7581,7002,3092,27112,805UK4091421933043421,390Table CP5: Number of irregularities not reported as fraudulent between 2017 and 2021 by Programming period - Cohesion and fisheries policiesFUND / PROGRAMMING PERIODREPORTING YEARTOTAL PERIOD05001,0001,5002,0002,5003,0003,5004,0004,5005,00020172018201920202021Irregularities by Programming period -2017-2021 (EU27)Programming period 2007-13Programming period 2000-06Programming period 2014-20 
 
 
COHESION AND FISHERIES 

when compared to the previous programming period. In 2021, despite a slight increase in 
the number of reported irregularities, the financial amounts involved jumped to more 
than  EUR  650  million.  The  following  irregularities  contributed  to  this  large  increase:  one 
ESF reported by  Greece (accounting for EUR 108 million), one ERDF irregularity  reported 
by  Romania  (accounting  for  EUR 67 million),  one  CF  irregularity  reported  by  Slovakia 
(accounting for EUR 41 million).     

As for the fraudulent irregularities, these trends in financial amounts are also due to different 
reporting patterns in the Member States. This was examined in the 2019 PIF Report, with reference 
to the 2015-2019 period82. For example, concerning the CF, Slovakia had a tendency to detect and 
report non-fraudulent irregularities with large financial amounts involved, also because on average 
the irregularities covered a significant share of the related expenditure.   

4.2.3. 

Irregularities reported in relation to the PP 2014-2020: comparison with PP 2007-
2013 

The  current  programming  period  started  in  2014,  about  8  years  ago.  Reporting  of 
irregularities basically began in 2016 and increased in the following years. To put this trend 

82 See  Section 4.1.2. of ‘Statistical evaluation of irregularities reported for 2019: own resources, agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2020)160 final (part 2/3) 

80 

20172018201920202021EUREUREIREUREUREURProgramming period 2014-2065,166,160212,985,746385,581,658349,396,126651,284,8481,664,414,538CF9,434,50057,131,449214,405,71698,818,249122,621,507502,411,421ERDF51,267,559113,792,962123,122,303206,574,467310,196,661804,953,952ESF4,186,21841,318,25144,240,66841,034,862212,431,438343,211,437EMFF277,883743,0843,812,9712,968,5486,035,24213,837,728Programming period 2007-131,326,900,438167,311,32183,755,712136,892,903160,433,2081,875,293,582CF263,793,82724,981,26713,797,87244,181,28692,412,743439,166,995ERDF956,020,857122,455,69160,439,61978,843,34163,050,2091,280,809,717ESF85,253,95618,903,0284,587,79810,922,7764,161,141123,828,699EFF21,831,798971,3354,930,4232,945,500809,11531,488,171Programming period 2000-063,878,8061,124,36315,828,702424,1691,209,53122,465,571CF1,915,59700001,915,597ERDF1,005,3231,097,72315,443,614199,069178,59617,924,325ESF930,27026,640065,8221,030,9352,053,667GUID27,6160385,088159,2780571,982TOTAL EU271,395,945,404381,421,430485,166,072486,713,198812,927,5873,562,173,691UK9,859,053954,0202,000,26519,071,54210,007,32241,892,202Table CP6: Financial amounts related to irregularities not reported as fraudulent between 2017 and 2021 by Programming period - Cohesion and fisheries policiesREPORTING YEARTOTAL PERIODFUND / PROGRAMMING PERIOD02004006008001,0001,2001,40020172018201920202021MillionsFinancial amounts involved in irregularities by Programming period -2017-21 (EU27)Programming period 2000-06Programming period 2007-13Programming period 2014-20 
 
 
                                                           
COHESION AND FISHERIES 

into  perspective,  it  can  be  compared  with  the  number  and  financial  amounts  of  the 
irregularities  that  were  recorded  during  the  first  8  years  of  PP  2007-2013.  Tables  CP7  and 
CP8 below provide this information83. 

The  following  graphs  provide  a  more  precise  comparison,  based  also  on  the  actual  date  of 
reporting84.  This  comparison  is  affected  by  the  fact  that  the  irregularities  related  to  PP 
2007-2013 are more 'mature' than irregularities related to PP 2014-2020, which have only just 
recently been reported. The number of irregularities related to PP 2007-2013 and the financial 
amounts  involved  are  the  result  of  several  years  of  investigation  (after  detection).  This 
brought into the picture additional information to: (i) confirm or refute the hypothesis that an 
irregularity  had  been  perpetrated85;  (ii)  classify  the  irregularity  (as  fraudulent  or  non-
fraudulent); (iii) to quantify the financial amounts actually involved, etc. 

83 Tables CP7 and CP8 include irregularities corresponding to the year with which the irregularity is associated, 
regardless  of  when  it  was  reported.  Typically,  the  irregularities  reported  during  the  first  months  of  year  x+1 
refer to the year x. However, there can be cases where an irregularity reported later during the year x+1 is still 
associated with year x. In order to take this factor into consideration, all subsequent comparisons are based on 
irregularities  associated  with  the  first  8  years  of  implementation  (2007-2014  –  for  PP  2007-2013  -  or  2014-
2021–  for  PP  2014-2020)  AND  reported  before  8  March  2015  (for  PP  2007-2013)  or  8  March  2022  (for  PP 
2014-2020). See also next footnote.  Differences between  figures reported in Tables CP7 and CP8 and figures 
reported later in this section may depend also on whether or not the fisheries policy is included. 
84 For PP 2014-2020, irregularities are considered if they were reported before 8 March 2022, which is the date 
when  data  was  extracted  from  the  irregularities  management  system  (IMS)  for  this  analysis.  This  does  not 
include irregularities referring to the year 2022. For PP 2007-2013, irregularities reported before 8 March 2015 
are considered, in order to improve comparability. This does not include irregularities referring to the year 2015 
or later. 
85 For example, it is possible that data related to PP 2014-2020 now includes a number of irregularities that in 
the  following  years  will  be  cancelled  (as  investigations  may  ascertain  that  no  irregularity  was  committed). 
Irregularities related to PP 2007-2013 have already undergone this process, as 11-15 years have passed from the 
initial reporting. The same applies to the classification as fraudulent or non-fraudulent, etc. 

81 

PP 2007-201320072008200920102011201220132014TotalN00463490121215180686EUR00126,874,08916,806,458116,783,562163,628,06496,887,400103,522,706624,502,279PP 2014-202020142015201620172018201920202021TotalN01119176102230158687EUR0150,672368,0398,560,619664,986,58726,905,197160,595,5591,587,616,2142,449,182,887REPORTING YEARTable CP7: Irregularities reported as fraudulent: number and financial amounts involved - Cohesion and fisheries policies (EU27)PP 2007-201320072008200920102011201220132014TotalN071059341,8372,7333,6754,05013,341EUR096,61529,486,215111,699,745339,141,5531,039,633,004779,077,8381,222,570,9593,521,705,929PP 2014-202020142015201620172018201920202021TotalN01141928281,3031,9922,0816,411EUR015,8724,354,39465,166,161212,985,746385,581,658349,396,126651,284,8471,668,784,804Table CP8: Irregularities not reported as fraudulent: number and financial amounts involved - Cohesion and fisheries policies (EU27)REPORTING YEAR 
 
 
 
 
                                                           
COHESION AND FISHERIES 

As  shown  by  Graphs  CP1  and  CP2  above,  the  number  of  irregularities  reported  as 
fraudulent  was  similar  for  PP  2014-2020  and  PP  2007-2013,  after  a  comparable  period 
from  the  start  of  the  programming  periods.  There  was  a  slower  start  of  reporting  for  the 
current programming period, but, during the fifth year of implementation, there was a strong 
acceleration that filled the gap. The comparison  is more difficult for financial amounts (see 
Graphs CP3 and CP4 below). The financial amounts reported for PP 2014-2020 were much 
higher than for the previous programming period, because there were two noticeable jumps 
during  the  fifth  and  eighth  years  of  implementation.  The  first  upswing  was  due  to  the  two 

82 

 
 
 
 
 
COHESION AND FISHERIES 

cases  Slovakia  reported  for  the  ERDF,  which  totalled  about  EUR 590  million.  The 
second  jump  was  due  to  the  case  Romania  reported  for  the  ERDF,  accounting  for 
EUR 1 270  million,  and  two  CF  irregularities  reported  by  Slovakia  and  Romania, 
accounting  together  for  EUR  190  million  (see  Section  4.2.1.1).  However,  PP  2007-2013 
experienced  similar  –  but  much  smaller  -  shifts,  during  the  fourth  and  sixth  years  of 
implementation, due to two cases, accounting about EUR 120 million each (see Graph CP3 
below).  Taking  these  outliers  out  of  the  analysis,  the  financial  amounts  involved  in  the 
fraudulent irregularities reported for PP 2014-2020 were still higher than PP 2007-2013, 
but more aligned. 

83 

 
 
 
COHESION AND FISHERIES 

This was the outcome of different patterns followed by different Funds.  

The  irregularities  reported  as  fraudulent  for  the  CF  and  the  ERDF  significantly  increased 
from PP 2007-2013 to PP 2014-2020 (see Graphs CP5 and CP6 below). The increase in CF 
fraudulent irregularities was mainly due to detections in Slovakia and Romania, while 
detections in Hungary and Romania were the main contributors to the surge concerning 
the ERDF.  

For  the  ESF  and  the  Fisheries  Funds,  the  detection  and  reporting  of  fraudulent 
irregularities  was  lower  than  before  (see  Graphs  CP7  and  CP8  below).  ESF-related 
irregularities were lagging behind by a rather stable number of cases until the end of the sixth 
year. Then the gap widened due to an increase in irregularities for PP 2007-2013. This gap 
was  mainly  due  to  the  decrease  recorded  in  Germany,  which  was  influenced  by  reporting 
practices86,  and  Romania.  Also,  the  cumulated  financial  amounts  associated  with  the 
ESF-related  fraudulent  irregularities  for  PP 2014-2020  were  considerably  lower  than  the 
amounts  for  PP  2007-2013,  due  to  a  strong  increase  during  the  seventh  year  of 
implementation of PP 2007-2013.  

86 The high number of detections Germany reported towards the end of the third year of implementation of PP 
2007-2013 (year 2009) was largely due to the separate reporting of many interlinked cases, each involving less 
than  EUR 10 000.  This  increased  the  number  of  cases  for  PP  2007-2013  and  consequently  the  drop  between 
PP 2007-2013 and 2014-2020.   

84 

 
 
 
                                                           
COHESION AND FISHERIES 

85 

 
 
 
 
 
COHESION AND FISHERIES 

Focusing instead on the non-fraudulent irregularities, the fall in the number of cases and 
the financial amounts reported after 8 years from the start of the programming period 
is  striking  (see  Graphs  CP9-CP12  below).  This  significant  difference  between  these  two 
programming periods warrants further analysis.  

86 

 
 
 
 
COHESION AND FISHERIES 

87 

 
 
 
 
 
 
 
COHESION AND FISHERIES 

The  number  of  irregularities  not  reported  as  fraudulent  (and  the  related  amounts)  can  be 
influenced by the state of implementation of the programming period. An indicator to gauge 
this state of implementation may be the interim payments that have been made to the Member 
States,  as  these  payments  should  reflect  the  progression  of  eligible  expenditure87.  Graph 
CP13  below  shows  the  situation  concerning  CF,  ERDF  and  ESF.  During  the  first  8  years 
from the start of PP 2014-2020 (from 2014 to 2021), the Member States have received fewer 
interim payments than during the first 8 years from the start of PP 2007-2013 (from 2007 to 
2014). At the end of 2021, this (cumulative) gap still amounted to about -8% and it had been 
higher before (see Graph CP13 below). However, at least part of this gap could simply be due 
to the fact that interim payments are limited to 90% of eligible expenditure and the remaining 
10 % is released after the yearly examination and acceptance of the accounts. As such, this 
would  not  reflect  delayed  implementation88.  Overall,  these  findings  suggest  that  the 
dynamics  of  the  gap  in  interim  payments  might  explain  some  of  the  difference  in  the 
number of non-fraudulent irregularities, but certainly not all of it (as the total difference 
in detection is about -50% - see Table CP8 and Graph CP10 above).  

87 It should be noted that PP 2014-2020 brought in an ‘annual accounts’ system. The accounting year starts on 1 
July and ends on 30 June (except for the first accounting period). This might have changed the time gap between 
the actual occurrence of expenses and interim payments by the Commission. If the gap increased, at least part of 
the difference in trends in interim payments for the two programming periods may be due to the difference in 
the reimbursement mechanisms rather than actual delays in implementation. 
88 As mentioned, PP 2014-2020 brought in an ‘annual accounts’ system. In this new framework, reimbursement 
of interim payments is limited to 90 % of the amount resulting from applying the relevant co-financing rate to 
the  expenditure  declared  in  the  payment  request.  However,  the  remaining  10  %  is  released  after  the  yearly 
examination and acceptance of the accounts. If this 10% is not attributed to the same year of the declaration of 
expenditure, it generates a slower pace of interim payments, which is not the result of a slower implementation 
of the programme. 

88 

 
 
 
                                                           
COHESION AND FISHERIES 

89 

010,00020,00030,00040,00050,00060,00012345678Cumulative interim paymentsMillionsYears in the programming periodEuropean Social FundPP 2007-2013PP 2014-2020-38%-21%-15%-1%020,00040,00060,00080,000100,000120,000140,00012345678Cumulative interim paymentsMillionsYears in the programming periodEuropean Regional Development FundPP 2007-2013PP 2014-2020-49%-51%-36%-27%-22%-8%010,00020,00030,00040,00050,00012345678Cumulative interim paymentsMillionsYears in the programming periodCohesion FundPP 2007-2013PP 2014-2020+ 43%+ 10%+ 18%-7%-14%050,000100,000150,000200,000250,00012345678Cumulative interim paymentsMillionsYears in the programming periodCF, ERDF, ESFPP 2007-2013PP 2014-2020-20%-17%-8%Graph CP13: Cumulativeinterimpayments to the Member States during the first 8 years of the programming periods (EU27)(1)(1) For PP 2014-2020, the net iterim payments (net of recovery of ineligible expenses) are considered. -42%-38%-24%0%-61%-13% 
 
 
COHESION AND FISHERIES 

In  Graphs  CP14-CP17  below,  the  irregularities  not  reported  as  fraudulent  are  presented  by 
Fund.  The  widest  gap  is  recorded  for  the  ERDF  (-54%).  Also  for  the  CF  and  the  ESF, 
there were significant gaps with respect to PP 2007-2013, even if they were not as wide as for 
the ERDF (-39% for the CF, -48% for the ESF). For the CF, the financial amounts reported in 
relation  to  PP  2014-2020  were  not  far  from  those  related  to  PP  2007-2013.  Then,  during 
2021,  the  gap  suddenly  rose.  For  the  ESF,  the  negative  gap  steadly  widened,  in  terms  of 
number  of  irregularities.  The  gap  in  terms  of  financial  amounts  was  closed  by  one  ESF 
irregularity reported by Greece, accounting for EUR 108 million. For the Fisheries Funds, the 
gap in terms of numbers was in line with the other Funds (-47%), but this was based on far 
fewer  cases.  The  curves  of  the  financial  amounts  overlap  until  the  end  of  the  sixth  year, 
before diverging due to a sudden upswing of the financial amounts related to PP 2007-2013. 

90 

 
 
 
 
 
COHESION AND FISHERIES 

Given that ERDF showed the widest gap between PP 2007-2013 and PP 2014-2020, Graph 
CP18 below shows the comparison, Member State by Member State, in terms of number of 
irregularities  not  reported  as  fraudulent,  with  specific  reference  to  this  Fund.  Graph  CP19 
below focuses on the irregular financial amounts.  

For the majority of Member States, the numbers of non-fraudulent irregularities related to the 
two programming periods have been on persistently diverging paths (see Graph CP18 below). 
There are a few exceptions, such as Bulgaria, France, Croatia, Lithuania and Slovakia.  

91 

 
 
 
 
COHESION AND FISHERIES 

92 

 
 
 
 
 
COHESION AND FISHERIES 

93 

 
 
 
 
 
 
COHESION AND FISHERIES 

94 

 
 
 
 
COHESION AND FISHERIES 

With  general  reference  to  the  cohesion  and  fisheries  policies,  a  specific  analysis  has  been 
carried out, based on the non-fraudulent irregularities reported by the Member States, until 
2020 included. This analysis identifies a number of potential explanations that may cover a 
significant  part  of  this  strong  decline.  The  hypotheses  reported  below  are  based  on  the 
findings of this analysis. 

95 

 
 
 
 
COHESION AND FISHERIES 

For  all  the  Funds,  the  competent  national  authorities  should  build  on  this  analysis,  to 
assess  the  extent  to  which  these  potential  explanations  and  other  possible  explanations 
actually  apply  to  their  operational  programmes,  with  the  aim  of  implementing  corrective 
measures in case the decline may be due to less effective detection and reporting.  

Delays in the implementation of the operational programmes 

As  mentioned,  delays  in  the  implementation  of  the  relevant  operational  programmes 
may explain part of the current gap. At the end of 2020, the cumulative amount of interim 
payments received by the Member States during PP 2014-2020 was 17% lower than during 
the first seven years of PP 2017-2013 and it had been higher before. At the end of 2021, this 
difference decreased to -8% (see Graph CP13 above). 

Changes in the reporting practices for irregularities under EUR 10 000 

In  general,  Member  States  are  requested  to  communicate  irregularities  involving 
financial  amounts  above  EUR  10 000.  However,  several  Member  States  reported  a 
number of irregularities involving financial amounts below this threshold.  Apart from 
typographical  errors  or  mis-interpretation  of  the  reporting  rules,  there  may  be  different 
reasons  why  some  Member  States  reported  many  more  ‘below-the-threshold’  irregularities 
than others did: 

  An irregularity may consist of irregular operations which are interlinked and whose total 
financial  impact  exceeds  EUR  10 000,  even  though  each  operation  remains  below  the 
threshold.89  Some  reporting  authorities  may  have  chosen  to  report  these  irregularities 
separately, while other Member States may have combined them into a single irregularity.  

  The  competent  national  authority  reported  the  case  because  the  initial  estimation  of  the 
irregular financial amounts exceeded EUR 10 000, but subsequent updates lowered these 
financial amounts below the threshold.  

  The  competent  national  authority  reported  the  irregularity  with  a  provisional  estimation 
under  EUR  10 000,  pending  the  exact  quantification  of  the  financial  amount  involved. 
However,  at  the  end  of  the  assessment,  the  financial  amounts  involved  did  not  increase 
above the threshold.  

Part  of  the  decrease  in  non-fraudulent  irregularities  may  be  explained  by  a  possible 
change  in  the  reporting  practices  of  some  authorities  for  irregularities  with  less  than 
EUR  10 000  involved.  At  the  end  of  2020,  there  was  a  clear  difference  between 
PP 2007-2013  and  PP  2014-2020,  in  terms  of  non-fraudulent  irregularities  with  financial 
amount below the EUR 10 000 threshold. During PP 2007-2013, some reporting authorities 
may have been communicating irregularities also when the financial amounts involved were 
below EUR 10 000, despite the derogation. Then, they may have changed this practice during 
PP 2014-2020 or other reporting authorities may have stepped in. Already during the meeting 
of  May  2019  of  the  Advisory  Committee  for  the  Coordination  of  Fraud  Prevention 
(COCOLAF),  OLAF  attracted  the  attention  of  all  Member  States  on  the  practice  of  the 
reporting  of  ‘below-threshold’  irregularities  and  on  how  this  varied  across  the  Member 
States.  A  change  in  the  frequency  or  in  the  reporting  practices  (from  separate  to  aggregate 
reporting)  concerning  ‘small’  interlinked  irregularities  could  be  an  additional  contributing 
factor.  

89 See Sections 8.1 and 9.3 of the 'Handbook on Reporting of Irregularities in shared management'.  

96 

 
                                                           
COHESION AND FISHERIES 

Increase in the use of Simplified Cost Options (SCO) 

For PP 2014-2020, the possibility to use SCO has been extended, but the impact depends 
on  the  extent  to  which  implementing  partners  used  this  possibility.  For  PP  2007-2013, 
about  7%  of  the  declared  ESF  expenditure  was  under  SCOs,  differing  widely  from  one 
Member State to another. According to estimates made in 2016 and 2018, for PP 2014-2020, 
this  percentage  is  expected  to  rise  to  33-35%  for  the  ESF  by  the  end  of  the  programming 
period. However, the expectation concerning the percentage of the ERDF-CF budget covered 
by SCOs is much lower, at 4%.90 Strong differences between Member States are expected91.  

Consequently,  for  the  ESF,  the  increase  in  the  percentage  of  expenditure  covered  by 
SCOs  (from  7%  to  33%)  may  be  a  significant  factor  contributing  to  the  drop  in  non-
fraudulent irregularities. However, it also depends on (i) whether the estimated increase in 
the  use  of  SCOs  is  actually  materialising;  (ii)  to  what  extent  the  wrong  implementation  of 
SCOs  methdologies  brought  to  errors;  (iii)  to  what  extent  the  increased  use  of  SCOs  will 
concern projects that are more relevant for irregularity reporting92; and (iv) when, during the 
programming  period,  adopting  more  SCOs  can  have  a  greater  impact  on  patterns  of 
irregularities. 

The violations concerning the eligibility of the expenditure/action are experiencing the 
biggest  drop.  This  may  support  the  hypothesis  that  the  increase  in  the  use  of  SCOs  is 
contributing  to  the  drop  in  non-fraudulent  irregularities.  With  reference  to  non-
fraudulent  irregularities  concerning  ESF,  at  the  end  of  2020,  eligibility  violations  dropped 
from about 1 300 for the first seven years of PP 2007-2013 to about 100 for PP 2014-2020. 
Simplification due to the use of financing not linked to costs and SCOs may be contributing 
to  this  trend.  However,  the  adoption  of  SCOs  should  be  accompanied  by  more  stringent 
controls on the implementation of the action, which could be expected to lead to the detection 
of more infringements of the contract provisions/rules. Consistently, at the end of 2020, this 
type of violations declined to a much lesser extent than eligibility infringements (from about 
500 to about 350).    

Delayed adaptation to the change in a derogation to reporting non-fraudulent irregularities 

In  2009,  there  was  a  significant  change  in  the  reporting  Regulation.  Commission 
Regulation  n.  846  of  1 September  2009  changed  the  derogation  related  to  the  reporting  for 
non-fraudulent  irregularities  detected  and  corrected  by  the  managing  authority,  before 
expenditure being declared to the Commission.  

Before  the  change,  for  the  derogation  to  apply,  detection  and  correction  should  have  taken 
place ‘before any payment to the beneficiary of the public contribution and before inclusion 
of  the  expenditure  concerned  in  a  statement  of  expenditure  submitted  to  the  Commission’. 
After the change, the derogation has been broadened, as it became enough that detection and 

90  The  estimated  amount  to  expenditure  covered  by  SCOs  increased  to  4.4%  after  the  introduction  of  the 
Omnibus Regulation in August 2018. 
91  ‘Simplified  Cost  Options  in  the  European  Social  Fund  -  Promoting  simplification  and  result-orientation’: 
working document prepared by the European Commission Services, December 2016 
Use  and  intended  use  of  simplified  cost  options  in  European  Social  Fund  (ESF),  European  Regional 
Development  Fund  (ERDF),  Cohesion  Fund  (CF)  and  European  Agricultural  Fund  for  Rural  Development 
(EAFRD):  study  commissioned  by  Directorate  General  for  Regional  and  Urban  Policy  of  the  European 
Commission, June 2018 
92  As  mentioned,  the  Member  States  are  only  obliged  to  report  irregularities  with  a  financial  amount  over 
EUR 10 000. If SCOs tend to be used more for smaller projects, this would undermine the argument that SCOs 
were responsible for the drop of reported irregularities. 

97 

 
                                                           
COHESION AND FISHERIES 

correction  took  place  ‘before  inclusion  of  the  expenditure  concerned  in  a  statement  of 
expenditure submitted to the Commission’.93  

However, for most of the irregularities reported during the two programming periods, 
the derogation was the same. It could be argued that the change in the derogation helped to 
lower  the  number  of  reported  non-fraudulent  irregularities  during  PP  2014-2020  (more 
irregularities covered by the derogation). However, this should not be the case, because most 
of  the  irregularities  related  to  PP  2007-2013  were  reported  when  the  ‘new’  derogation  was 
already in place (after September 2009).  

It cannot be excluded that some authorities did not immediately adapt their reporting 
practices to the ‘new’ derogation and kept on applying the previous version during PP 
2007-2013.  In  any  case,  the  effect  would  be  limited  to  irregularities  detected  between  any 
payment to the beneficiary and the inclusion of the expenditure in a statement of expenditure 
to the Commission.  

Introduction of the annual accounts and the exclusion of ongoing assessments 

As  from  PP  2014-2020,  the  Member  States  can  exclude  from  the  annual  accounts 
expenditure  where  there  is  an  ongoing  assessment  about  the  legality  and  regularity. 
Through this exclusion, the Member States avoid a reduction in the contribution from a 
given  Fund,  even  in  case  of  irregularities.  The  Member  States  are  actually  using  this 
possibility.  As  from  PP  2014-2020,  each  year,  the  Member  State  prepares  the  accounts, 
which are examined and accepted by the Commission.94 In the framework of the preparation 
of  the  annual  accounts,  article  137(2)  of  the  Common  Provision  Regulation95  provides  the 
Member State with the possibility to exclude from the annual accounts expenditure that has 
already  been  declared  to  the  Commission  during  the  accounting  year  under  closure,  where 
there  is  an  ongoing  assessment  about  the  legality  and  regularity  of  this  expenditure.  This 
expenditure is  automatically recovered by the Commission  during the current  year, without 
this constituting a financial correction and without it reducing support from the Fund to the 
relevant  operational  programme.  In  case  the  assessment  concludes  that  this  expenditure  is 
legal  and  regular,  the  Member  State  can  re-introduce  the  expenditure  in  an  application  for 
interim payment  in subsequent  accounting  years. Also where the assessment concludes that 
the expenditure was irregular, there is no financial correction and reduction in support from 
the Fund.  

The  number  of  irregularities  labelled  as  ‘decertified’  in  IMS  dropped  from  PP 
2007-2013  to  PP  2014-2020.  This  could  be  linked  to  the  introduction  of  the  annual 
accounts  and  the  new  possibility  provided  by  article  137(2).  According  to  the  IMS 

93 For the programming period 2007-2013, Commission Regulation 1828 of 8/12/2006 (article 28, paragraph 2., 
letter  (c)),  provided  for  the  following  derogation  ‘cases  which  are  detected  and  corrected  by  the  managing 
authority  or  certifying  authority  before  any  payment  to  the  beneficiary  of  the  public  contribution  and  before 
inclusion of the expenditure concerned in a statement of expenditure submitted to the Commission’. 
Then, article 1(7)(b) of the Commission Regulation n. 846 of 1/9/2009 amended this derogation as ‘cases which 
are detected and corrected by the managing authority or certifying authority before inclusion of the expenditure 
concerned  in  a  statement  of  expenditure  submitted  to  the  Commission’.  This  formulation  has  been  kept  in 
Regulation 1303 of 17/12/2013 (article 122, paragraph 2., letter (c)) for the programming period 2014-2020 
94  The  accounting  year  starts  on  1  July  and  ends  on  30  June  (except  for  the  first  accounting  period).  The 
certifying  authority  prepares  the  annual  accounts  for  the  operational  programme.  These  accounts  are  then 
submitted to the Commission together  with the  management declaration of assurance, the annual summary of 
controls prepared by the managing authority, and the accompanying control report and audit opinion prepared 
by  the  audit  authority.  The  Commission  examines  these  documents,  before  issuing  a  yearly  declaration  of 
assurance.  
95 Regulation (EU) 1303/2013 of 17/12/2013 

98 

 
                                                           
COHESION AND FISHERIES 

guidance,  an  irregularity  should  be  labelled  as  ‘decertified’  in  case  the  Member  State 
excludes  the  related  project  from  EU  support.96  Actually,  during  PP  2007-2013,  many 
irregularities have been labelled as ‘decertified’ also when the Member State simply applied 
the  financial  correction,  cancelling  the  amount  involved  in  the  irregularity  from  the 
operational  programme  (before  reusing  the  same  amount  in  the  same  operational 
programme). Comparing the first seven years of implementation of the programming periods, 
there was a significant decrease in the number of irregularities labelled as ‘decertified’, which 
may point to a decrease in the practice of withdrawing whole projects from EU funding or to 
unreported irregularities in relation to these projects (see below).   

The possibility offered by article 137(2) might explain part of the declined in the non-
fraudulent irregularities reported by the Member States. A number of hypotheses may be 
formulated: 

1.  Some reporting authorities may have not communicated irregularities in IMS when 
the assessment of the excluded expenditure concluded that the expenditure was not 
legal and regular. At the moment of the exclusion from the annual accounts, the Member 
State  may  not  be  in  a  position  to  report  any  irregularity  in  IMS,  as  the  assessment  is 
ongoing.  However,  at  a  later  stage,  the  competent  authority  could  conclude  that  an 
irregularity has taken place. Even if the expenditure had been excluded from the annual 
accounts,  this  irregularity  should  be  reported,  because  it  was  detected  after  previous 
inclusion of the expenditure concerned in a payment application to the Commission (i.e. 
the original application for interim payment).  

2.  Similarly,  in  the  case  of  withdrawal  of  a  whole  project  after  exclusion  of  related 
expenditure  following  article  137(2),  some  reporting  authorities  might  have  assessed 
that  the  reporting  of  any  irregularity  (ascertained  at  the  end  of  the  assessment)  was  not 
necessary, because the project was not funded by the EU budget any longer. This would 
not be correct. 

3.  The  annual  accounts  (and  article  137(2))  may  have  introduced  a  more  orderly 
treatment of irregular expenditure. During PP 2007-2013, when there was no ‘annual 
accounts’  procedure,  in  a  number  of  instances,  in  case  of  doubt  about  legality  or 
regularity of the expenditure, the Member States could have resorted to cancelling part of 
or all EU support to certain projects, just to avoid pending issues with the Commission - 
which  could  lead  to  a  ‘net  financial  correction’  -  and  to  timely  free  resources  for  other 
projects. In IMS, the already reported irregularity would then be labelled as ‘decertified’. 
If  this  was  the  case,  at  least  a  subset  of  the  ‘decertified’  irregularities  in  PP  2007-2013 
could  be  related  to  regular  expenditure,  for  which  the  final  assessment  would  have 
resulted in the cancellation of the reported irregularity.  

During PP 2014-2020, the exclusion provided by article 137(2) can instead be used, 
at least in some cases. The presentation of the annual account represents a moment when 
the Member State has to certify that the declared expenditure is free from irregularities. In 
the presence of a piece of expenditure whose legality and regularity is dubious, possibly 
because of ongoing audit work, the national competent authority has now the possibility 
of avoiding the start of any correction procedure - that could lead to a financial correction 
by  the  Commission  -  by  simply  putting  the  expenditure  under  assessment  and 
withdrawing it from the accounts. This can be done only for expenditure declared during 
the accounting  year whose accounts have not been presented yet. However, the window 
between  the  payment  application  and  the  presentation  of  the  annual  accounts  can  reach 

96 ‘IMS User Manual 5: Create a case’ (2018), page 81 

99 

 
                                                           
COHESION AND FISHERIES 

more  than  one  year.  Then,  the  decision  about  cancelling  or  not  the  EU  support  can  be 
delayed until there is clarity about legality and regularity. Often, the excluded expenditure 
is eventually assessed as legal and regular.  

4.  By  putting  expenditure  under  assessment  (while  excluding  it  from  the  annual 
accounts), the Member State may delay the communication of the irregularity. If and 
when  the  assessments  will  be  finalised  with  the  first  conclusion  that  expenditure  is 
irregular, the communication in IMS will take place.97 This can contribute to the current 
decline of non-fraudulent irregularities for PP 2014-2020, at least temporarily. 

Improved practices may also be contributing to the decrease 

Under  certain  premises,  after  seven  years  of  implementation  (end  of  2020),  the 
combined effect of the above mentioned potential explanations would cover about two 
thirds  of  the  EU-wide  decline  in  reporting  of  non-fraudulent  irregularities.  Of  course, 
this is a rough estimation. However, this gives an idea of the possible contribution of these 
potential explanations.  

The  influence  of  increased  administrative  capacity  could  also  be  considered.  There  are 
no  indicators  to  gauge  the  increase  in  the  capability  of  the  implementing  bodies  and  of  the 
beneficiaries  and  the  impact  that  this  could  have  had  in  terms  of  decrease  of  unintentional 
irregularities. However, also these could be contributing factors.   

First of all, the legal framework for PP 2014-2020 requires the managing authorities to adopt 
effective  and  proportionate  anti-fraud  measures  that  take  into  account  the  risks 
identified98. This  is  more  relevant  for the detection of fraudulent irregularities,  which have 
actually  increased,  despite  the  decrease  of  non-fraudulent  irregularities.  However,  the  risk 
assessments carried out by the relevant authorities and the ensuing mitigating measures may 
have also contributed to preventing non-fraudulent irregularities or to detecting them before 
expenditure is submitted to the Commission. The actual impact of these anti-fraud measures 
depends on the timeliness and quality of the underlying risk assessments and ensuing actions. 

At  the  end  of  2020,  the  analysis  of  the  fraudulent  irregularities  suggested  that 
management  and  control  systems  detected  irregulaties  at  an  earlier  stage  during  PP 
2014-2020. As shown in Graphs CP1 and CP2 above, the number of irregularities reported as 
fraudulent  was  stable.  At  the  end  of  2020,  the  analysis  of  the  time  gap  between  the 
perpetration  of  the  fraudulent  irregularities  and  their  detection  suggested  that  this  gap  was 
shorter during PP 2014-2020 than during PP 2007-2013. 99 

If  this  improvement  applied  also  to  non-fraudulent  irregularities,  a  higher  share  of 
detected  irregularities  might  have  fallen  under  a  derogation  to  reporting,  because 
detected  before  inclusion  of  the  expenditure  in  any  statement  to  the  Commission. 
Fraudulent irregularities must be reported regardless of when they are detected. This allows a 

97 However, the possibility to delay the  communication of these irregularities  is  limited, because irregularities 
must be reported at the moment of the ‘first written assessment by a competent authority […] concluding on the 
basis  of  specific  facts  that  an  irregularity  has  been  committed,  without  prejudice  to  the  possibility  that  this 
conclusion may subsequently have to be revised or withdrawn as a result of developments in the course of the 
administrative or judicial procedure’. 
98 Article 125(c) of the Common Provisions Regulation 1303/2013.  
99 This analysis was based on the comparison of the date when the irregularity was committed (or started) and 
the  date  when  the  irregularity  was  discovered  (meaning  when  the  first  written  assessment  of  a  competent 
authority concludes that an irregularity has been committed, the so-called PACA). The irregularities where one 
of the two dates were missing (or where date of discovery precedes the data of perpetration) have been excluded 
from the analysis. 

100 

 
                                                           
COHESION AND FISHERIES 

comprehensive analysis of the time gap. Consequently, the finding that Member States have 
become  faster  in  detecting  fraudulent  irregularities  may  lead  to  the  hypothesis  that  the 
Member  States  have  been  detecting  more  fraudulent  irregularities  before  inclusion  of  the 
expenditure in a statement to the Commission. If this is true, another hypothesis can be made: 
this  improvement  may  be  having  an  influence  also  on  the  detection  of  non-fraudulent 
irregularities. This would support the potential explanation that at least part of the decrease in 
reported  non-fraudulent  irregularities  may  be  due  to  improved  capacity  of  the  management 
and  control  systems:  if  the  same  non-fraudulent  irregularity  is  detected  after  inclusion  in  a 
statement  to  the  Commission,  it  must  be  reported  in  IMS,  while  if  it  is  detected  before 
inclusion, it must not be reported. 

Besides  anti-fraud  measures,  other  factors  might  have  contributed  to  increase  the 
administrative  capacity.  The  2007-2013  national  strategic  reference  frameworks  (NSRF) 
have been replaced by the 2014-2020 partnership agreements. These agreements must present 
an  assessment  of  the  administrative  capacities  of  the  authorities 
in 
implementating  the ESI  Funds  together  with  – where  relevant –  a summary  of  actions to 
improve these  capacities.  In some Member States, the quality and experience of relevant 
authorities  may  have  improved  over  the  years,  especially  if  these  authorities  did  not 
change from one programming period to the other. During time, methodologies may have 
been  defined  by  the  competent  authorities  to  decrease  the  amount  of  unintentional 
irregularities,  shortcomings  may  have  been  identified  and  corrected  following  national  and 
EU  audit  work,  administrative  capacity  may  have  been  built,  etc.  The  Commission  has 
contributed with general capacity building actions and targeted remedial actions.  

involved 

Another  factor  could  be  that  the  beneficiaries  that  participate  in  the  implementation  of 
the  projects  during  PP  2014-2020  might  have  participated  to  the  projects  also  during 
PP 2007-2013. This experience may make easier to avoid unintentional irregularities.  

On the other side, the COVID-19 outbreak could have brought in additional stress on the 
administrative capacity of the relavant players of the management and control systems. 
This could contribute to the detection of more irregularities in the years to come. 

4.3. 

Specific analysis 

With reference to the cohesion policy, this section covers the following aspects: 

 How irregularities impacted on the different areas of this policy; 

 What was the contribution of different types of irregularity. 

4.3.1. 

Irregularities by area of the cohesion policy 

The operational  programmes financed under the EU cohesion policy  are implemented 
along  identified  intervention  fields.  These  intervention  fields  change  depending  on  the 
programming  period.  Annex  14  shows the  86  intervention  fields  for  PP  2007-2013  and  the 
123  fields  for  PP  2014-2020.  For  the  purpose  of  this  analysis,  Annex  14  introduces  a 
grouping of these intervention fields in areas and sub-areas. The following sections analyse 
the reported irregularities along these areas and sub-areas, taking into consideration also the 
share of expenditure declared for the operations in the relevant intervention fields (see below 
for further explanations).  

Table  CP9  below  shows  the  fourteen  areas  in  which  the  intervention  fields  have  been 
grouped. Figures CP1 and CP2 below show how irregularities impacted on these areas, 
focusing  on  fraudulent  and  non-fraudulent  cases,  respectively.  Annex  14  shows  which 
intervention  field  is  associated  to  which  area.  The  following  analysis  concerns  the 

101 

 
COHESION AND FISHERIES 

irregularities  under  PP  2014-2020  only100.  For  the  purpose  of  this  analysis  the  area  of 
information  and communication technology  is  associated to  the digital  transition. The areas 
related  to  the  protection  of  the  environment,  resource  efficiency,  the  shift  towards  a  low-
carbon  economy,  climate  change  are  associated  to  the  green  transition  (see  Table  CP9 
below)101.  In  Figures  CP1  and  CP2  below,  the  size  of  the  squares  is  proportional  to  the 
number of fraudulent irregularities reported by the Member States. The darker the colour of 
the squares, the higher the financial amounts involved.102   

100  However,  it  was  necessary  to  consider  also  the PP  2007-2013  intervention  fields,  because  they  have  often 
been  unduly  used  by  the  Member  States  to  report  irregularities  under  PP  2014-2020.  The  priorities  for  the 
PP 2014-2020  are  listed  in  the  Commission  Implementing  Regulations  (EU)  184/2014  and  215/2014  and  are 
different from the priorities for PP 2007-2013. Contrary to these Regulations, the Member States continued to 
encode  irregularities  in  IMS  using  the  (different)  priorities  that  were  valid  for  PP  2007-2013.  This  made 
necessary  to  formulate  hypotheses  about  which  PP  2014-2020  intervention  fields  the  reporting  authorities 
should  have  used  instead  of  the  PP  2007-2013  fields  they  actually  used.  Annex  14.4  clearly  shows  these 
hypotheses. Considering that the total expenditure declared is directly associated to the PP 2014-2020 fields, this 
could weaken the findings of the following analysis, especially when drilling down at the level of sub-areas. 
101 In these ‘green transition’ areas also the investments in risk prevention and management have been included, 
even  if  they  are  not  necessarily  linked  to  the  adaptation  to  the  climate  change.  However,  risk  prevention  and 
management  can  be  seen  at  least  indirectly  related  to  the  preservation  of  the  environment,  also  in  case  it 
concerns technological accidents or even earthquakes. 
102 The analysis is based on the intervention field codes reported in IMS. For some Member States, in IMS, the 
descriptions associated to two PP 2007-2013 field codes (COH-TH58 and COH-TH59) pertaining to the area of 
Culture,  made  wrongly  reference  to  technical  assistance.  The  hypothesis  has  been  made  that  the  operators 
correctly chose the codes to be associated to the irregularities, without being misled by the wrong descriptions. 
If  the  hypothesis  is  not  correct  for  all  related  irregularities,  this  would  lead  to  an  overestimation  of  the  area 
CultTour  and  an  underestimation  of  the  area  TechAss  (see  Table  CP9).  However,  there  were  no  such 
irregularities reported as fraudulent. Concerning non-fraudulent irregularities, there were 9 cases (EUR 472 000) 
reported  under  COH-TH58  and  2  cases  (EUR  3 447 000) reported  under  COH-TH59. This  would  not  change 
significantly Graph CP21 below and the main findings of the analysis. 

102 

Table CP9AreasShort descriptionStrengthening research, technological development and innovationRTD&IDigital transitionEnhancing accessibility to and use and quality of information and communication technologiesInfo&CommSupporting the shift towards a low-carbon economy in all sectorsLowCarbonPromoting climate change adaptation, risk prevention and managementClimate&RiskPreserving and protecting the environment and promoting resource efficiencyEnvironmentPromoting sustainable transport and removing bottlenecks in key network infrastructuresTransportPromoting sustainable and quality employment and supporting labour mobilityEmployPromoting social inclusion, combating poverty and any discriminationInclusionInvestment in education, training and vocational training for skills and lifelong learningEducationEnhancing competitiveness of small and medium sized enterprisesCompSMECulture and tourismCultTourEnhancing institutional capacity of public authorities and stakeholders and an efficient public administrationPubbAmmTechnical AssistanceTechAssOutermost RegionsOutermostGreen transition 
 
  
                                                           
COHESION AND FISHERIES 

Fraudulent irregularities 

103 

 
COHESION AND FISHERIES 

Few  fraudulent  irregularities  concerned  trasport,  but  the  financial  amounts  involved 
were  huge.  Financial  amounts  involved  in  research  and  innovation  were  the  second 
highest  and  this  was  based  on  a  broader  base  of  cases.  Concerning  transport,  this  was 
influenced  by  one  irregularity  where  EUR  1 270  million  were  involved.  Similarly,  for 
research  and  innovation,  the  high  financial  amounts  were  influenced  by  two  fraudulent 
irregularities, accounting together for about EUR 590 million.  

Fraudulent  irregularities  were  most  frequent  in  the  areas  related  to  employment,  to 
research and innovation and to the green transition. Concerning the green transition, they 
were most frequent in relation to the transition to a low-carbon economy and the protection of 
the  environment.  Excluding  the  above  mentioned  outliers  (related  to  transport  and 
research/innovation)  the  protection  of  the  environment  was  the  area  with  the  highest 
financial amounts involved, similar to transport but based on more cases. 

Non-fradulent irregularities 

inclusion  were  two  areas  with  many  non-fraudulent 
Research/innovation  and 
irregularities  and  high  financial  amounts  involved.  The  area  concerning  research  and 
innovation  is  the  one  affected  by  the  highest  number  of  non-fraudulent  irregularities.  The 
high  financial  amounts  involved  in  inclusion  were  influenced  by  an  irregularity  accounting 
for nearly EUR 110 million.  

Taken together, also the areas related to the green transition accounted for more than 
1 000  non-fraudulent  irregularities  and  about  EUR  250  million.  This  is  mainly  due  to 
non-fraudulent irregularities related to the protection of the environment and the shift towards 
a low-carbon economy. 

Concerning non-fraudulent irregularities, the highest financial amounts were related to 
transport. This was based on a lower number of cases than in other areas. 

Considering the share of cohesion funding devoted to the different areas 

The  share  of  total  expenditure  declared  (EU  share)  for  the  different  areas  of  the 
cohesion  policy  may  influence  the  frequency  of  irregularities  and  the  total  financial 
amounts involved in these irregularities. To take this factor into consideration, Graph CP20 
below proposes a comparison among areas of the cohesion policy based on: 

  The  percentage  of  irregularities  related  to  a  specific  area  over  the  total  number  of 

irregularities related to the cohesion policy103; 

  The percentage of the financial amounts involved in the irregularities related to a specific 
area over the total financial amounts involved in all irregularities related to the cohesion 
policy; 

  The  percentage  of  expenditure  declared  (EU  share)  for  the  operations  belonging  to  a 
specific  area  over  the  expenditure  declared  (EU  share)  for  all  operation  under  the 
cohesion policy (all intervention fields).104 

103 The totals of the cohesion policy (number of irregularities and financial amounts involved) do not include 23 
fraudulent irregularities (accounting for EUR 42 788 595) for which the reporting authority did not specify the 
intervention field. 

104  This  is  based  on  the  field  ‘Tot_Expend_EU_Declared’  from  the  file  ‘ESIF_2014__2020_ERDF-CF-
ESF_raw_  categorisation),  updated  at  2021,  published  on:  https://cohesiondata.ec.europa.eu/2014-2020-
Categorisation/ESIF-2014-2020-ERDF-CF-ESF-raw-categorisation/xe4p-7b9q 

104 

 
                                                           
 
COHESION AND FISHERIES 

Concerning fraudulent irregularities, this analysis confirms that the financial amounts 
involved in the areas transport and environment protection were very high. Graph CP20 
below focuses on fraudulent irregularities. The three outliers related to transport and research 
and innovation (see above) are not included in Graph CP20.  

Research/innovation  and  employment  are  the  two  areas  where  the  frequency  of 
fraudulent  irregularities  was  much  higher  than  what  could  be  expected  based  on  the 
weight of the expenditure declared (see Graph CP20 below). 

that 
Concerning  non-fraudulent 
research/innovation and inclusion were areas with a very high number of cases and/or 
financial  amounts  involved.  Graph  CP21  focuses  on  non-fraudulent  irregularities.  The 
outlier related to inclusion (see above) is not included in Graph CP21.  

irregularities,  Graph  CP21  below  confirms 

As  for  fraudulent  irregularities,  also  for  non-fraudulent  irregularities,  the  irregular 
financial  amounts  involved  in  transport  were  disproportionately  high,  also  when  the 
expenditure declared is taken into consideration.  

105 

0.05.010.015.020.025.030.035.040.0Climate&RiskCompSMECultTourEducationEnvironmentInfo&CommPubbAmmEmployInclusionRTD&ITransportLowCarbonGraph CP20: Comparison among areas based on their weight on totals (outliers excluded)Irregularities reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
    
 
COHESION AND FISHERIES 

Based on this preliminary analysis by area of the cohesion policy: 

  Trasport  is  a  risky  area  because  both  fraudulent  and  non-fraudulent  irregularities 

involved very high financial amounts; 

  Research,  technological  development  and  innovation  is  a  risky  area  because  of  the 

frequency of irregularities and the high financial amounts involved; 

  The  green  transition  seems  to  be  at  risk  of  fraud,  especially  considering  the  financial 
amounts  involved  in  the  area  of  environment  protection.  Also  non-fraudulent 
irregularities  were  frequent  and  costly  -  especially  for  environment  protection  and 
transition  to  low-carbon  economy  –  but  this  seems  to  be  due  also  to  the  level  of 
expenditure declared in these sectors.   

 

 

Irregularities concerning employment were quite frequent, especially fraudulent ones. 

Irregularities  concerning  social  inclusion,  poverty  and  discrimination  were  quite 
frequent, especially non-fraudulent ones.   

These  areas  are  further  analysed  in  the  following  sections.  Also  the  area  of  information, 
communication and technology is further analysed, because of its relevance for the digital 
transition, which is a key objective also of the Recovery and Resilience Facility. 

4.3.1.1.   The green transition 

In  Figures  CP3  and  CP4  below,  the  analysis  drills  down  to  the  level  of  the  sub-areas 
relevant  to  the  green  transition  (see  Annex  14).  Figure  CP3  is  based  on  the  fraudulent 
irregularities concerning the three areas that feed into the green transition (protection of the 

106 

0.05.010.015.020.025.030.035.0Climate&RiskCompSMECultTourEducationEnvironmentInfo&CommPubbAmmOutermost RegionsEmployInclusionRTD&ITransportTechnical AssistanceLowCarbonFigure CP21: Comparison among areas based on their weight on totals (outlier excluded)Irregularities not reported as fraudulent -PP 2014-2020Number of irregularitiesFinancial amounts involvedExp EU declared 
 
COHESION AND FISHERIES 

environment, the shift towards a low-carbon economy, climate change – see Table CP9 above 
and Annex 14). Figure CP4 focuses on non-fraudulent irregularities. 

Fraudulent irregularities 

The  majority  of  these  fraudulent  irregularities  concerned  energy  efficiency.  This  is 
confirmed  by  the  comparison  based  also  on  the  expenditure  declared  (see  Graph  CP22 
below).  Most  of  these  irregularities  have  been  classified  in  the  generic  intervention  field 
‘Energy efficiency, co-generation, energy management’, which was valid for PP 2007-2013 
(see footnote 101). In the few cases where the classification was more precise (based on the 
PP 2014-2020  fields),  fraudulent 
irregularities  mostly  concerned  ‘energy  efficiency 
renovation of existing housing stock, demostration projects  and supporting measures’ and 
were about conflict of interests in procurement or incorrect documents.  

The  highest  financial  amounts  were  involved  in  the  management  and  distribution  of 
drinking water. The prevalence of water management in term of financial amounts was also 
due to one fraudulent irregularity accounting for more than EUR 70 million, concerning the 
management  and  distribution  of  drinking  water  (generic  code  under  PP  2007-2013). 
However, the prevalence of this sub-area in terms of irregular financial amounts is confirmed 
by  Graph  CP22  below,  where  this  outlier  is  excluded  and  the  expenditure  declared  is 
considered. Most of the fraudulent irregularities concerning water management were related 
to  the  provision  of  water  for  human  consumption  (which  may  include  extraction, 
treatment,  storage  and  distribution  infrastructure).  Besides  water  management,  another  sub-
area  concerning  water,  water  treatment,  was  affected  by  few  but  costly  fraudulent 
irregularities. However,  this may be due also  to  the high expenditure declared for this field 
(see Graph CP22 below). 

Significant is also the contribution of waste management, both in terms of number and 
financial  amounts.  The  majority  of  these  fraudulent  irregularities  concerned  household 
waste  management  (including  minimisation,  sorting,  recycling  measures)  and  public 
procurement. The high financial amounts were mainly associated to fraudulent irregularities 
in  the  management  of  household  and  industrial  waste  (more  generic  code  under 
PP 2007-2013). 

107 

 
  
COHESION AND FISHERIES 

108 

0.010.020.030.040.050.060.0Biodiversity/NatureClimate changeEnergy efficiencyRisk preventionTracksWasteWaterWater treatmentGraph CP22: Comparison among sub-areas based on their weight on totals (outlier excluded)Green transition -Irregularities reported as fraudulent -PP 2014-2020Number of irregularitiesFinancial amounts involvedExp EU declared 
 
 
 
 
COHESION AND FISHERIES 

Non-fraudulent irregularities 

Also  for  non-fraudulent  irregularities,  the  majority  of  cases  concerned  energy 
efficiency.  This  sub-area  was  followed  by  water  and  waste  treatment  (see  Figure  CP4 
below). Concerning energy efficiency, the generic intervention field ‘Energy efficiency, co-
generation,  energy  management’  -  which  was  valid  for  PP  2007-2013  (see  footnote  101)  - 
was  the  most  frequently  reported.  However,  differently  from  fraudulent  irregularities,  this 
was  closely  followed  by  the  more  specific  field  about  ‘energy  efficiency  renovation  of 
public  infrastructure,  demostration  projects  and  supporting  measures’.  Energy  efficiency 
renovation  of  existing  housing  stock  was  instead  not  prevalent  among  non-fradulent 
irregularities.  Water  treatment  was  impacted  by  more  cases  than  waste  treatment,  but 
considering  the  share  of  expenditue  declared,  waste  treatment  seems  to  be  more  at  risk,  in 
terms of number of non-fraudulent irregularities (see Graph CP23 below).  

The highest financial amounts were involved in water management. This was mainly due 
to interventions related to the provision of water for human consumption, also because of 
one non-fraudulent irregularity accounting for more than EUR 41 million. A similar number 
of non-fradulent irregularities and even higher financial amounts (net of the aforementioned 
outlier)  concerned  water  management  and  drinking  water  conservation  (including  river 
basin management, water supply, climate change adaptation, metering, charging systems and 
leak  reduction).  The  remaining  non-fradulent  irregularities  made  generic  reference  to 
management and distribution of drinking water (PP 2007-2013 field).  

Non-fraudulent  irregularities  related  to  renewable  energy  (solar)  and  risk  prevention 
were  also  particularly  frequent,  considering  weights  in  terms  of  expenditure  declared 
for these types of investment. Risk prevention was particularly affected also in terms of 
irregular  financial  amounts.  This  is  suggested  by  Graph  CP23  below,  where  the 
comparison  takes  into  consideration  the  share  of  expenditure  declared  for  the  different 
intervention fields. 

The  high  financial  amounts  associated  to  climate  change  are  mainly  due  to  an 
irregularity  accounting  for  more  than  EUR  18  million,  out  of  the  EUR  25  million 
involved. These financial amounts are noticeable in Graph CP23 below and they would stick 
out  even  more  if  the  above  mentioned  outlier  accounting  for  EUR  41  million  in  water 
management  woud  be  excluded  from  Graph  CP23.  However,  also  the  financial  amounts 
involved  in  the  adaptation  to  climate  change  and  prevention  and  management  of  climate 
change  risks  are  influence  by  a  large  non-fraudulent  irregularity,  accounting  for  more  than 
EUR 18 million. 

109 

 
 
COHESION AND FISHERIES 

110 

0.05.010.015.020.025.030.035.0Air qualityAssistance for envi-friendlyprodBiodiversity/NatureClimate changeEnergy efficiencyNatural assetsOther renewablePollutionRehabilitationRenewable energy: biomassRenewable energy: solarRisk preventionSupport to low carboneconomyTracksUrban transportWasteWaterWater treatmentGraph CP23: Comparison among sub-areas based on their weight on totalsGreen transition -Irregularities not reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
 
COHESION AND FISHERIES 

4.3.1.2.   Research, technological development and innovation 

In Figures CP5 and CP6 below, the analysis drills down to the level of the sub-areas of 
research, technological development and innovation (see Annex 14). Figure CP5 focuses 
on fraudulent irregularities. Figure CP6 is based on non-fraudulent irregularities. 

Fraudulent irregularities 

to 

this  sub-area  were  strongly 

The prevalence of assistance to RTD and innovation activities in firms is clear, both in 
terms  of  number  of  fraudulent  irregularities  and  financial  amounts  involved.  The 
financial  amounts  related 
two 
aforementioned  irregularities,  accounting  together  for  EUR  590  million.  More  specifically, 
these  outliers  concerned  investment  in  infrastructure,  capacities  and  equipment  in  SMEs 
directly linked to research and innovation activities. However, the most reported intervention 
field in this sub-area was the generic (PP 2007-2013) ‘Other measures to stimulate research 
and innovation and entrepreneurship in SMEs’. The most recurrent violations concerned the 
documentary  proof,  in  particular  false  or  falsified  documents.  There  were  a  significant 
number of cases of conflict of interests. 

influenced  by 

the 

Non-fraudulent irregularities 

RTD and innovation activities in firms was clearly prevalent also with reference to non-
fraudulent irregularities (see Figure CP6 below). The most reported intervention field was 
again the generic (PP 2007-2013) ‘Other measures to stimulate research and innovation and 
entrepreneurship  in  SMEs’,  followed  by  research  and  innovation  processes  in  SMEs 
(including  voucher  schemes,  process,  design,  service  and  social  innovation).  The  highest 
financial  amounts  and  a  high  number  of  cases  were  related  to  investment  in  infrastructure, 
capacities  and  equipment  in  SMEs  directly  linked  to  research  and  innovation  activities 

111 

 
 
COHESION AND FISHERIES 

(including innovative technologies, establishment of new firms by universities, existing RTD 
centres and firms, etc.). 

Also the intervention fields  concerning  activities in  reasearch centres and the technology 
transfer  made a noticeable contribution  to  the total  number of non-fraudulent irregularities 
affecting research and innovation. However, this seems to be more in line with the share of 
expenditure declared for these intervention fields. 

4.3.1.3.   Transport and networks 

In  Figures  CP7-CP9  below,  the  analysis  drills  down  to  the  level  of  the  sub-areas  of 
sustainable  transport  and  other  networks  infrastructures  (see  Annex  14).  Figure  CP7  
and  CP8  focus  on  fraudulent  irregularities.  Figure  CP9  is  based  on  non-fraudulent 
irregularities. 

Fraudulent irregularities 

Most  of  the  fraudulent  irregularities  reported  under  PP  2014-2020  concerned 
motorways  or  roads,  with  most  of  the  irregular  financial  amounts  involved  in  the 
Trans-European  Network  (TEN)  infrastructure.  Two  irregularities  reported  by  Slovakia 
and Romania, accounting for EUR 118 million and EUR 36 million, contributed to the high 
financial  amounts  involved  in  TEN  motorways  and  roads.  The  low  number  of  fraudulent 
irregularities reported so far may be  due to  the long implementation  periods of this type of 
projects. For a better understanding of potential trends, reference to the situation concerning 
PP 2007-2013 may be useful. This is shown in Figure CP8 below105. 

105 As shown in detail in Annex 14, the sub-area ‘TEN-T motorways and roads’ has been created to collect all 
intervention fields related to this type of projects (the PP 2007-2013 field referred only to motorways, while the 
PP 2014-2020 fields expanded the scope to include both motorways and road). For the non-TEN-T projects, the 

112 

 
                                                           
COHESION AND FISHERIES 

infrastructure, 

During  PP  2007-2013,  most  of  the  fraudulent  irregularities  were  related  to  roads  that 
were  not  part  of  the  TEN  network.  However,  the  few  irregularities  related  to  TEN 
motorways  and  roads  were  enough  to  match  the  total  financial  amounts  involved  in 
non-TEN  projects.  Concerning  non-TEN 
to 
regional/local roads were most frequent, but the financial amounts involved in national roads 
were  much  higher.  The  financial  amounts  involved  in  one  irregularity  related  to  a  national 
road may be worth tens of millions. In the case of a TEN project the financial amounts can 
skyrocket. During PP 2007-2013, the three irregularities with the highest financial amounts in 
national  roads  averaged  EUR  25  million,  but  one  irregularity  related  to  a  TEN  motorway 
accounted  for  EUR  120  million.  The  most  frequent  violations  concerned  the  documentary 
proof, in particular false or falsified documents. There were several cases concerning ethics 
and integrity, including conflict of interests and corruption, and several cases related to public 
procurement. 

irregularities 

related 

distinction  has  been  maintained.  The  broader  sub-area  ‘Motorways  and  roads  no  TEN-T’  is  linked  to  the 
PP 2014-2020  field  (where  both  types  of  infrastructure  are  included)  while  the  more  specific  sub-areas  are 
linked to PP 2007-2013 fields (where the two types of infrastructure were kept separate).   

113 

 
 
                                                                                                                                                                                     
COHESION AND FISHERIES 

Fraudulent  irregularities  in  investments  for  railways  were  less  frequent,  but  financial 
amounts  involved  can  be  huge.  So  far,  during  PP  2014-2020,  there  was  just  one  such 
involved  exceeded 
irregularity 
EUR 1 270 million.  During  PP 2007-2013,  two  irregularities  related  to  railways  were 
reported. One of them accounted for nearly EUR 30 million, despite it was not related to a 
TEN project. 

reported  by  Romania,  but 

the  amounts 

(TEN) 

Non-fraudulent irregularities 

Also  for  non-fraudulent  irregularities,  most  of  cases  concerned  motorways  and  roads, 
with  higher  financial  amounts  involved  in  TEN  investments  (see  Figure  CP9  below). 
Graph CP24 below, where number and financial amounts are compared with the expenditure 
declared, confirms that the number of irregularities related to motorways and roads and the 
financial amounts involved in TEN infrastructure were disproportionately high. 

The  share  of  irregularities  concerning  railways  tend  to  be  larger  in  non-fraudulent 
irregularities than in fraudulent ones. The number of irregularities related to TEN and no 
TEN  projects  was  similar,  but  the  financial  amounts  related  to  TEN  projects  was  much 
higher, also because of two irregularities accounting together for about EUR 100 million. 

low 

level  of  expenditure,  non-fraudulent 

Despite  the 
irregularities  concerning 
multimodal trasport in connection with the TEN network occurred. As shown by Graph 
CP24  below,  considering  the  share  of  expenditure  declared  for  this  type  of  projects,  the 
number of non-fradulent irregularities and the financial amounts involved were high.  

Several  non-fraudulent  irregularities  affected  investments  in  the  electricity  network, 
with  low  financial  amounts  involved.  When  compared  with  the  share  of  expenditure 
declared  for  this  type  of  projects,  the  frequency  of  these  non-fraudulent  irregularities  was 
noticeable.  

114 

 
 
COHESION AND FISHERIES 

115 

0.010.020.030.040.050.060.0AirportsPortsElectricity no TEN-EInland waterways and ports no TEN-TIntelligence transportMobile rail assetsMotorways and roads no TEN-TMultimodal no TEN-TNatural gas no TEN-TRailways no TEN-TTEN-E ElectricityTEN-E Natural gasTEN-T Inland waterways and portsTEN-T motorways and roadsTEN-T MultimodalTEN-T RailwaysGraph CP24: Comparison among sub-areas based on their weight on totalsTransport & Networks-Irregularities not reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
 
 
 
COHESION AND FISHERIES 

4.3.1.4.  Digital transition 

In Figures CP10 and CP11 below, the analysis drills down to the level of the sub-areas 
of the information and communication technologies (see Annex 14). Figure CP10 focuses 
on fraudulent irregularities. Figure CP11 in based on non-fraudulent irregularities. 

Fraudulent irregularities 

Fraudulent  irregularities  related  to  the  digital  transition  were  not  frequent  and  they 
concerned services and applications. The finding about the low frequency comes out of the 
analysis in Section 4.3.1., also taking into consideration the share of expenditure declared for 
this area. Figure CP10 below shows that these irregularities affected investments concerning 
services  and  applications  both  for  SMEs  and  for  e-Government.  The  financial  amounts 
involved in the irregularities related to e-Government were much higher, also because of an 
irregularity  accounting  for  EUR  15  million,  related  to  discriminatory  selection  criteria  in 
public procurement.  

Non-fraudulent irregularities 

Member  States  more  often  reported  non-fraudulent  irregularities,  also  in  relation  to 
investments  for  the  digital  transition.  This  higher  frequency  is  suggested  also  by  the 
analysis  that  considers  the  share  of  expenditure  declared  in  this  area  (see  section  4.3.1  and 
Graph CP21 above).  

involved 

in  non-fraudulent 

financial  amounts 

The 
to 
e-Government were prevalent, but the number of irregularities related to services and 
applications  for  SMEs  was  also  noticeable  (Figure  CP11  below).  The  financial  amounts 
related  to  e-Government  were  very  high  also  considering  the  share  of  expenditure  declared 
for these investments (see Graph CP25 below). This is influenced by an irregularity in public 
procurement,  accounting  for  EUR  20 million.  The  number  of  non-fraudulent  irregularities 

irregularities  related 

116 

 
 
COHESION AND FISHERIES 

related to services and applications for SMEs was lower than that related to e-Government, 
but it was more significant, when considering that far less expenditure has been declared for 
this type of investments (see Graph CP25 below).  

117 

 
 
COHESION AND FISHERIES 

4.3.1.5.   Social inclusion 

In Figures CP12 and CP13 below, the analysis drills down to the level of the sub-areas 
of  social  inclusion,  poverty  and  discrimination  (see  Annex  14).  Figure  CP12  focuses  on 
fraudulent irregularities. Figure CP13 is based on non-fraudulent irregularities. 

Fraudulent irregularities 

Most  fraudulent  irregularities  concerned  active  inclusion,  but  the  highest  irregular 
financial  amounts  were  involved  in  investments  to  improve  the  health  infrastructure. 
Active  inclusion  means  equal  opportunities,  active  participation,  improving  employability, 
employment  for  disadvantage  people,  etc.  The  most  recurrent  violations  in  active  inclusion 
were  about  the  implementation  of  the  action  or  the  documentary  proof  (in  particular  false 
documents).  The  high  impact  of  fraudulent  irregularities  on  active  inclusion  and  health 
infrastructure is confirmed by the comparison with the share of expenditure declared for these 
intervention  fields  (see  Graph  CP26  below).  The  second  highest  number  of  fraudulent 
irregularities concerned  access  to services,  which includes healthcare and social services 
of general interests. Most of the times, the violations related to access to services were about 
the non or partial implementation of the action. 

118 

0.010.020.030.040.050.060.070.080.0InfrastructureInvestment for cooperationServices to citizensServices to SMEsGraph CP25: Comparison among sub-areas based on their weight on totalsDigital transition-Irregularities not reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
COHESION AND FISHERIES 

119 

 
 
 
 
COHESION AND FISHERIES 

Non-fraudulent irregularities 

The financial amounts involved  in  non-fraudulent  irregularities related to investments 
for  active  inclusion  were  very  high,  but  this  is  due  to  one  irregularity  accounting  for 
EUR  108  million  (Figure  CP13  below).  In  Graph  CP27  below,  the  comparison  is  not 
influenced  by  this  outlier.  Graph  CP27  below  suggests  that  the  detection  of  non-fraudulent 
irregularities  related  to  active  inclusion  is  influenced  by  the  larger  share  of  expenditure 
declared in this intervention field. 

When comparing also on the basis of the share of expenditure declared, non-fraudulent 
irregularities related to social infrastructure and the development/regeneration of rural 
and urban areas come to the attention. This is shown by Graph CP27 below. The finding 
concerning  regeneration/development  may  be  overemphasized  by  the  wrong  use  of 
intervention field codes by the Member States106. In terms of financial amounts involved in 
non-fraudulent irregularities, also the investments to improve access to services  (including 
healthcare and social services of general interest) and investments in favour of marginalised 

106 The prevalence of development/regeneration with respect to the share of expenditure declared for this area 
may  be  overemphasized  in  Graph  CP27,  because  most  of  the  irregularities  and  financial  amounts  have  been 
wrongly  reported  under  a  PP  2007-2013  intervention  field  (‘Integration  projects  for  urban  and  rural 
regeneration’).  Such  an  intervention  field  does  not  exist  under  PP  2014-2020.  These  irregularities  have  been 
grouped  together  with  the  following  PP  2014-2020  codes:  ‘Community-led  local  development  initiatives  in 
urban  and  rural  areas’  and  ‘Community-led  local  development  strategies’,  making  the  hypothesis  that  the 
operation  actually  pertained  to  one  of  them.  Consequently,  these  irregularities  are  compared  with  expenditure 
declared for these two PP 2014-2020 intervention fields.  

120 

0.05.010.015.020.025.030.035.040.045.0Access to servicesActive inclusionChildcare infrastructureDevelopment/regenerationHealth infrastructureHousing infrastructureSocial enterprisesSocial infrastructureFigure CP26: Comparison among areas based on their weight on totalsSocial inclusion -Irregularities reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
                                                           
COHESION AND FISHERIES 

communities  come  to  notice.  In  terms  of  number  of  irregularities,  this  is  the  case  for  the 
funding of child infrastructure (see Graph CP27).     

121 

0.05.010.015.020.025.030.035.040.0Access to servicesActive inclusionChildcare infrastructureDevelopment/regenerationDiscriminationHealth infrastructureHousing infrastructureMarginalised communitiesOtherSocial enterprisesSocial infrastructureGraph CP27: Comparison among sub-areas based on their weight on totals (outlier excluded)Social inclusion-Irregularities not reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
 
 
COHESION AND FISHERIES 

4.3.1.6.   Employment 

In Figures CP14 and CP15 below, the analysis drills down to the level of the sub-areas 
of promoting sustainable and quality employment and supporting labour mobility (see 
Annex 14). Figure CP14 focuses on fraudulent irregularities. Figure CP15 is based on non-
fraudulent irregularities. 

Fraudulent irregularities 

Most of fraudulent irregulaties and financial amounts involved concerned adaptation to 
change  of  workers  and  enterprises.  The  disproportionate  weight  of  these  irregularities  is 
confirmed by Graph CP28 below, where also the share of expenditure declared for this type 
of  projects  is  considered.  Within  this  sub-area,  the  majority  of  fraudulet  irregularities  were 
related  to  operations  for  the  design  and  dissemination  of  innovative  and  more  productive 
ways  of  working.107  For  these  operations,  the  majority  of  violations  concerned  the 
non-implementation  of  the  action  or  conflict  of  interests,  including  combined  in  the  same 
irregularity.  In  a  number  of  cases,  conflict  interests  was  combined  with  multiple  financing. 
Infringements related to the documentary proof were also recurrent, often because of false or 
falsified documents.  

The  high  irregular  financial  amounts  related  to  investments  for  the  modernisation  of 
the  labour  market  (see  Graph  CP28  below)  are  due  to  one  fraudulent  irregularity, 
accounting for about EUR 4.5 million.   

107 This intervention field belongs to PP 2007-2013, so it is not specifically financed by PP 2014-2020. 

122 

 
 
 
 
                                                           
COHESION AND FISHERIES 

Non-fraudulent irregularities 

Most of non-fraudulent irregulaties and financial amounts involved concerned access to 
employment (Figure CP15 below). However, this prevalence can be partly explained through 
the high share of expenditure declared for this type of operations, at least in terms of number 
of irregularities. Most of these irregularities and financial amounts were related to operations 
for  access  to  employment  for  job-seekers  and  inactive  people,  including  the  long-term 
unemployed and people far from the labour market. 

A  disproportionate  high  number  of  non-fraudulent  irregularities  were  reported  with 
reference  to  support  for  self-employment  and  business  start-up.  In  particular,  this  is 
suggested  by  Graph  CP29  below,  where  the  share  of  expenditure  declared  for  this  type  of 
operations is considered. 

123 

0.010.020.030.040.050.060.070.080.0Access to employmentAdaptation to changeAgeingLabour marketSelf-employmentGraph CP28: Comparison among areas based on their weight on totalsEmployment-Irregularities reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
 
 
COHESION AND FISHERIES 

124 

0.010.020.030.040.050.060.070.080.090.0Access to employmentAdaptation to changeAgeingLabour marketSelf-employmentGraph CP29: Comparison among areas based on their weight on totalsEmployment-Irregularities not reported as fraudulent -PP 2014-2020 Number of irregularitiesFinancial amounts involvedExp EU declared 
 
 
COHESION AND FISHERIES 

4.3.2. 

Irregularities by type 

Table  CP10  below  provides  an  overview  of  the  categories  of  irregularities  reported  in 
connection with the Cohesion policy (CF, ERDF, ESF).108 

The same irregularity  may  be  associated to  several  categories of infringement. That  is  why 
the row of totals  does not  result from  summing up the figures in  the respective columns  of 
Table  CP10  below:  it  would  result  in  multiple  counting  of  the  same  notification  of 
irregularity. 

Concerning  fraudulent 
irregularities,  the  most  frequent  violations  were  about 
supporting documents. One out of four infringements and one out of two Euro concerning 
supporting documents  was  fraudulent (see FFL and FAL109 in  Table CP10 above). Most of 
the times, false or falsified documents were used.  

Examples of fraudulent irregularities related to the documentary proof 

Example 1: Cross-checks allowed detecting that the same persons were declared as attending at the same time, 
different training activities, delivered by different trainers, in the framework of different projects. 

Example 2: In a procurement procedure, two of the three bids were fictitious. These two offers had been made 
by bidders who had been told in advance by the beneficiary the prices to be used in the offers. 

Example 3: With reference to the construction of ventilation systems in schools, payments to the beneficiary 
had  been  made,  based  on  documentation  evidencing  the  completion  of  the  systems  and  their  acceptance. 
However, these systems had not been completed. 

Example 4: In the framework of an application for a grant, to evidence its financial capability, the applicant 
presented a false promise to grant a loan apparently issued by a leasing company. In reality, the promise had 
not been issued by that company and it was signed by a person with no authority for that.  

High financial amounts were involved in fraudulent irregularities were infringements of 
contract  provisions/rules  took  place.  Fraud  often  consisted  in  incomplete  or  non-
implementation of the funded action. The frequency of fraud was rather low (see  FFL in 
Table CP10 above), also because violations concerning contract provisions were the second 
most  reported  among  the  non-fraudulent  irregularities.  The  average  financial  amount 

108 For details about the content of the categories listed in Table CP10, please see Annex 13. 

109 FFL (Fraud Frequency Level) is the ratio between the number of fraudulent irregularities reported during a 
certain  period  and  the  total  number  of  irregularities  (fraudulent  and  non-fraudulent)  reported  during  the  same 
period. FAL (Fraud Amount Level) is a similar indicator, but based on the financial amounts involved. 

125 

NEUREUR/avgFFLFALNEUREUR/avgIncorrect, missing, false or falsified supporting documents303139,424,410460,1472752814126,151,590154,977Infringement of contract provisions/rules120680,535,6055,671,1307721,711265,004,767154,883Ethics and integrity8953,219,642597,9745890645,802,24590,660Infringement of public procurement rules88183,410,9222,084,2154182,359814,838,127345,417Eligibility / Legitimacy of expenditure/measure6941,191,722596,9811329472102,182,604216,489Violations/breaches by the operator3713,700,129370,274192715936,344,080228,579Incorrect, absent, falsified accounts317,274,739234,669101327549,125,471178,638Product, species and/or land285,437,835194,208222710114,541,608143,976Infringements concerning the request25127,340,9755,093,639167013053,374,849410,576Multiple financing102,625,578262,5583766171,369,96680,586State aid3736,771245,59059557,722,101140,402Bankruptcy2327,059163,53055426,348,415151,153MovementNA0012774,80964,567Other6234,266,438552,684810686296,906,998432,809blank261,347,702,93751,834,728139618052,593,419292,186Total number of irregularities EU 27 (1)6632,444,614,0553,687,20110606,2611,654,816,369264,305(1) This is not the sum of the figures above, because one irregularity can refer to more than one categoryIrregularities not reported as fraudulentTable CP10: Categories of irregularity - Cohesion policy (PP 2014-2020) Categories of irregularitiesIrregularities reported as fraudulent 
 
                                                           
COHESION AND FISHERIES 

involved in these fraudulent irregularities was high at more than EUR 5.5 million. However, 
this  was  influenced  by  two  irregularities,  accounting  together  for  EUR  590  million.  Net  of 
these outliers, one out of four Euro involved in irregularities related to violations of contract 
provisions  were  fraudulent  and  the  average  financial  amount  involved  in  these  fraudulent 
irregularities was still more than EUR 750 000.  

Examples of fraudulent irregularities related to infringement of contract provisions/rules 

Example 1: The beneficiary did not implement  the  project in line  with the schedule  specified in the project 
application, the output and the result indicators were not achieved. The funds granted to the project were used 
for another objective. The funds allocated to the implementation of the project were used for unreasonable and 
inefficient spending, which resulted in lack of liquidity. Significant amounts were transferred from the project 
bank account to the bank account of the beneficiary, without being covered by direct costs incurred and settled 
for the project. 

Example 2: The beneficiary had not adapted the building in line  with the project purpose (nursery) and had 
not obtained the authorisation that was necessary to put in place the activities for which the building should 
have been used. 

Most  of  fradulent  violations  concerning  ethics  and  integrity  were  about  conflict  of 
interests. Ethichs and integrity is the category of infringement with the highest frequency of 
fraud, also in terms of financial amounts involved. Six out of ten infringements and nine out 
of ten Euro concerning ethics and integrity were fraudulent (see FFL and FAL in Table CP10 
above). Corruption was rarely reported. 

Examples of fraudulent irregularities related to ethics and integrity 

Example  1:  A  numer  of  companies  were  linked  through  shareholders  or  managers.  These  companies  issued 
invoices between each other, submitted them for co-financing and then they cancelled these invoices. 

Example 2: On the basis of an operational agreement with a development bank, a financial institution was in 
charge  of  granting  loan  supported  with  EU  funding.  There  was  a  suspicion  that  the  financial  institution 
granted several loans to entities to which it was linked, in a situation of conflict of interest, which translated 
also in unequal treatment of potential loan-takers.  

Infringements  of  public  procurement  rules  were  the  most  reported  among  non-
fraudulent violation, but only in 4% of these cases fraud was detected. Despite this, one 
out of five Euro involved in irregularities related to public procurement were fraudulent. The 
low  frequency  of  fraudulent  cases  suggests  that  either  fraud  detection,  investigation  and 
prosecution  concerning  public  procurement  or  the  administrative  capability  of  contracting 
authorities should be improved.  

4.4. 

Risk analysis and spontaneous reporting 

In the antifraud cycle, the capability of detecting fraud and irregularities is a key feature that 
helps making the system effective and efficient in protecting the EU budget. In the 2017 PIF 
Report, to boost the capability to detect irregularities, the Commission recommended to the 
Member  States  to  improve  risk  analysis  and  the  use  of  spontaneous  reporting  of 
potential  irregularities  and  strengthening  the  protection  of  whistle  blowers  that  are  also  a 
crucial source for investigative journalism110. 

110 Section 4.3 of the ‘29th Annual Report on the Protection of the EU’s financial interests – Fight against fraud 
–  2017’,  COM(2018)553  final  and  ‘Statistical  evaluation  of  irregularities  reported  for  2017:  own  resources, 
agriculture, cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2018)386 final.  

126 

 
                                                           
COHESION AND FISHERIES 

So far, there has been little improvement on the ground in the use of risk analysis (see 
Tables CP11, CP12 below111). Effectively shifting from reactive to proactive detections based 
on risk analysis can take time. In addition, non-fraudulent irregularities that are detected and 
corrected at the national level before the expenditure is included in a statement submitted to 
the Commission for reimbursement do not have to be reported. Therefore, if risk analysis has 
a higher impact in detecting these irregularities ‘earlier’, Tables CP11-CP12 below would not 
capture  this.  On  the  other  hand,  this  exception  does  not  apply  to  fraudulent  irregularities, 
which Member States should always report, even if they detect the irregularities before they 
submit the expenditure to the Commission. 

Risk  analysis  has  still  a  marginal  contribution  in  detecting  fraud,  while  information 
from civil society has a significant and growing role. During the past five years, about one 
out  of  four  irregularities  has  been  detected  following  tips  from  informant,  whistle-blowers, 
etc. and information published in the media (see Table CP11 below). During the previous five 
years  (2012-2016)  just  one  out  of  ten  fraudulent  irregularities  were  detected  because  of 
information from civil society.  

In relation to non-fraudulent irregularities, neither risk analysis nor information from 
civil  society  had  a  noticeable  role  in  detection  (see  Table  CP12  below).  There  was  no 
significant improvement with respect to the previous five years. 

The  low  share  of  irregularities  detected  following  risk  analysis  suggests  room  for 
improvement in this domain.  

It is true that risk analysis might have a more important role in detecting irregularities before 
expenditure  is  introduced  in  a  request  for  reimbursement  to  the  Commission.  These 
detections do not have to be reported in IMS and Tables CP11 and CP12 above are based on 
information from IMS only. However, this is valid only for non-fraudulent irregularities. As 

111 Besides risk analysis, other reasons that might indicate the use of some forms of risk analysis have also been 
added to the table (comparison of data, probability checks and statistical analysis). 

127 

Table CP11N.%EURRisk analysis141.22,738,280Comparison of data201.710,823,171Probability checks70.620,358,972Statistical analysis0.0Tip from informant, whistle-blower etc.22019.0133,530,055Information published in the media494.2627,410,780Total EU271,1602,824,402,579Reason for performing controlIrregularities reported as fraudulent - Cohesion policy - Programming periods 2007-2013 and 2014-20202017-2021N.%EURRisk analysis4443.649,682,109Comparison of data1110.914,367,374Probability checks720.612,063,954Statistical analysis10.045,833Tip from informant, whistle-blower etc.2081.745,051,611Information published in the media740.665,099,592Total EU2712,3833,494,382,222Reason for performing controlIrregularities not reported as fraudulent - Cohesion policy - Programming periods 2007-2013 and 2014-20202017-2021Table CP12 
 
 
 
                                                           
COHESION AND FISHERIES 

already mentioned, fraudulent irregularities must always be reported in IMS, so for fraudulent 
irregularities the contribution of risk analysis to detections was certainly low.  

In  addition,  analyses  suggest  that  the  total  error  rate  (as  an  indicator  of  the  amount  of 
expenditure at risk and a proxy of the unknown value of the irregularities committed) tend to 
be  higher  than  the  detection  rate  (as  a  measure  of  the  irregularities  actually  detected)  in 
several Member States. The difference between total error rate and detection may be due to 
several reasons,  including the functioning  of the  detection function of the management  and 
control systems. This includes the possibility that, in some cases, there is no adequate follow 
up with reference to past operations on the risks identified during audit work.  

Detection  may  improve  by  strengthening  ex-post  risk  analysis,  in  view  of  performing 
tailored checks.  

Checks before payment: 

  may focus on single items of expenditure or single operations, in view of accepting them 

for reimbursement; 

  may be carried out in a rather standard way and under time pressure, in view of respecting 

mandatory deadlines and facilitate legitimate business.  

A significant part of the irregularities reported in IMS may be the outcome of the work of the 
national audit authorities, after payment. In the framework of the assurance package, the audit 
authorities  target  a  number  of  operations  selected  on  the  basis  of  sampling  methods  where 
representativeness is the main leading principle, in view of projecting findings to the whole 
population  of reference.  Risk  analysis can only have a limited role.  In  addition,  audit work 
does not aim at detecting fraud. 

Detection  of  fraud  and  irregularities  could  improve  by  adding  to  the  above  mentioned 
preventive  checks  and  audits  of  operations  also  ex-post  thematic  risk  analysis  projects 
focusing  on  groups  of  past  transactions.  The  choice  of  the  groups  of  transactions  could  be 
based  also  (but  not  only)  on  the  finding  of  previous  audit  work,  including  system  audits. 
These risk analyses should consider these transactions in the wider context, including linking 
them 
through  beneficiaries,  contractors, 
subcontractors, beneficial owners. They would result in selecting a number of transactions for 
tailored ex-post checks.  

transactions,  considering 

to  other 

links 

These  risk  analyses  should  be  carried  out  by  bodies  that  are  external  to  the  management 
authorities,  to  maximise  positive  incentives  to  detection.  The  involvement  of  the  national 
Anti-fraud  Coordination  Services  (AFCOS)  could  be  considered,  in  line  with  the 
recommendation of the European Court of Auditors to expand the functions of these bodies to 
improve  coordination112.  In  case  the  AFCOS  has  no  powers  for  administrative  checks 
following  risk  analysis,  arrangements  with  national  bodies  with  such  powers  would  be 
needed. In case the analysis or the following administrative checks would lead to suspicion of 
fraud,  this  should  be  reported  with  no  delay  to  the  competent  national  bodies,  in  line  with 
relevant national rules, to be further investigated.       

4.5. 

Antifraud and control activities by Member States  

The  present  section  aims  to  examine  some  aspects  linked  to  the  anti-fraud  and  control 
activities and results of Member States. Four elements are taken into account: 

112  European Court of Auditors, Special Report 6/2019 

128 

 
                                                           
COHESION AND FISHERIES 

 duration of irregularities (fraudulent and non-fraudulent). No analysis by Member State is 

presented in this section; 

 the number of irregularities reported as fraudulent by each Member State; 

 the  ratio  between  the  amounts  involved  in  cases  reported  as  fraudulent  and  the  payments 
that occurred in relation to PP 2014-20 (FDR) and the ratio between the amounts involved 
in cases not reported as fraudulent and the payments that occurred in relation to PP 2014-20 
(IDR);113 

 the follow-up given to suspected fraud. 

4.5.1.  Duration of irregularities  

Two third of the irregularities have been occurring over a period of time, averaging one 
year  and  a  half.  With  reference  to  the  cohesion  and  fisheries  policies,  of  the  6 411 
non-fradulent  irregularities    reported  by  the  Member  States  in  relation  to  PP  2014-2020, 
4 074 (64% of the total) have been occuring over a period of time. For the 687 irregularities 
reported  as  fraudulent,  this  percentage  was  similar,  at  68%.  The  remaining  irregularities 
consisted  of  a  single  act  identifiable  on  a  precise  date  (33%  of  the  non-fraudulent 
irregularities  and  29%  of  the  fraudulent  irregularities)  or  irregularities  for  which  Member 
States have not provided the necessary information. The average duration of the irregularities 
that occurred over a period of time was about 16 months. 

On  average,  it  took  more  than  one  year  to  come  to  a  suspicion  that  a  fraudulent  
irregularity  had  been  committed  and  one  year  and  a  half  to  close  the  case  after 
reporting.  The  average  duration  of  the  different  phases  a  case  can  go  through,  from 
perpetration to case closure, is visualised in Figures CP16 and CP17 below.114 For fraudulent 
irregularities, on average, it took  15 months  to  suspect  that an irregularity  had been or was 
being  perpetrated.  Once  the  suspicion  arose,  the  Member  States  detected  the  fraudulent 
irregularity in three months. Then the fraudulent irregularity was reported to the Commission 
only eight months after detection. The average time from the reporting to the Commission to 
the case closure was one year and a half. For the non-fraudulent irregularities this took less 
than one year. This delay in closing fraudulent cases is consistent with the longer duration of 
criminal proceedings.  

These average times are expected to increase as  the implementation of the operational 
programmes progresses. Irregularities that are more craftily hidden or that are more difficult 
to investigate (and to close) will probably add as time passes, pushing these averages up. The 
average  durations  for  the  PP  2007-2013,  which  closed  already  in  2015,  could  be  an 
interesting reference.  They have been  analysed  in  detail  in  the framework of the  2018 PIF 
Report115.  Both  for  fraudulent  and  non-fraudulent  irregularities,  on  average,  it  took  nearly 

113 The Member States only have the obligation to report irregularities for which payment and  inclusion of the 
expenditure  concerned  in  a  statement  of  expenditure  submitted  to  the  European  Commission  occurred.  As  a 
consequence, the IDR focuses on the 'repressive' side of the anti-fraud cycle and does not include the results of 
'prevention' activities. This does not apply to the FDR, as fraudulent cases must be reported regardless. 
114 For the purpose of the analysis, (i) the date of the irregularity is the field 6.7.1 ‘From’ in IMS, (ii) the date of 
the suspicion is the field 6.1 ‘Date’ in IMS (when the information was received that led to the suspicion that an 
had been committed); (iii) the date of detection is the field 7.1 ‘Date of discovery (PACA) in IMS; (iv) the date 
of reporting is the field ‘registration date’ in IMS, (v) the date of closure is the field 12.1 ‘case closure date’ in 
IMS. Irregularities are taken into consideration for the calculation of the average durations only if the date of the 
next  step  is  not  before  the  date  of  the  previous  step.  For  example,  an  irregularity  for  which  the  date  of  the 
suspicion is before the date of the start of the irregularity is not taken into consideration. 
115  ‘Report  from  the  Commission  to  the  European  Parliament  and  the  Council  –  30th  Annual  Report  on  the 
Protection of the European Union's Financial Interests – Fight against Fraud – 2018', COM(2019)444 

129 

 
                                                           
COHESION AND FISHERIES 

two and a half years to suspect that an irregularity had been or was being perpetrated. This is 
much higher than the current averages for PP 2014-2020, so they can be expected to increase. 
Once the suspicion arose, the Member State detected the irregularity in less than half a year. 
Then  the  irregularity  was  reported  to  the  Commission  eight  months  after  detection.  This  is 
similar to PP 2014-2020. The average time from the reporting to the Commission to the case 
closure  was  nearly  three  years  and  21  months,  for  fraudulent  and  non-fraudulent 
irregularities, respectively. This is much longer than the current averages for PP 2014-2020, 
so they can be expected to increase. 

4.5.2.  Detection of irregularities reported as fraudulent by Member State  

Map  CP1  shows  the  number  of  irregularities  each  Member  State  reported  as  fraudulent  for 
PP 2014-2020.  In  Map  CP1,  the  darker  the  Member  State,  the  higher  the  number  of 
detections.  

130 

05101520253035404550Reporting to case closureDetection to reportingSuspicion to detectionIrregularity to suspicionFigure CP16: Average times from  irregularity to case closure PP 2014-2020; irregularities reported as fraudulentAvg. duration in months15 months3 months8 monthsNumber of irregularities at the basis of these averagetimes From irregularityto suspicion: 651From suspicionto detection: 672From detection to reporting: 671From reporting to case closure: 32051015202530354045Reporting to case closureDetection to reportingSuspicion to detectionIrregularity to suspicionFigure CP17: Average times from  irregularity to case closure PP 2014-2020; irregularities not reported as fraudulentAvg. duration in months11 months20 months3 months6 monthsNumber of irregularities at the basis of these averagetimes From irregularityto suspicion: 6 063From suspicionto detection: 6 073From detection to reporting: 6 204From reporting to case closure:1 61318 months 
  
 
 
COHESION AND FISHERIES 

Past analysis based on PP 2007-2013 suggested that the concentration of detections is not 
fully  explained  by  the  concentration  of  payments116.  This  analysis  was  quite  solid,  as  it 
was based on operational programmes closed several years before. This finding seems to be 
confirmed by the emerging differences in the fraud detection rates related to PP 2014-2020, 
even  if  implementation  is  still  ongoing  and  data  can  change.  The  outcome  of  that  analysis 
based on PP 2007-2013 could be due to many different factors, including different underlying 
levels of irregularities and fraud, differences in the quality of prevention or detection work or 
different  practices  concerning  the  stage  of  the  procedure  when  potentially  fraudulent 
irregularities were reported. This analysis found that the divergence between the distribution 
of  detections  and  the  distribution  of  payments  among  Member  States  was  smaller  for  the 
cohesion  and  fisheries  policies  than  for  CAP,  especially  in  the  case  of  fraudulent 
irregularities.  This  could  suggest  that  when  it  come  to  cohesion  and  fisheries  policies 
Member  States  take  a  more  similar  approach  to  criminal  investigation  and  prosecution  to 
protect the EU budget or to report suspected fraud than when it comes to agriculture. 

116  Section  4.4.2  of  ‘Statistical  evaluation  of  irregularities  reported  for  2018:  own  resources,  agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2019)365 final 

131 

 
 
                                                           
COHESION AND FISHERIES 

4.5.3.  Fraud detection rate 

The fraud detection rate (FDR) compares the results obtained by Member States in the fight 
against  fraud  with  the  payments  they  received.  Given  the  multi-annual  nature  of  cohesion 
programmes, focus is on the whole PP 2014-2020.  

Table  CP13  below  shows  data  on  fraud  detection  in  the  Member  States  for  PP  2014-2020. 
For reference purposes, the FDR for PP 2007-2013 is also included in the table. These two 
FDRs cannot be directly compared. While PP 2007-2013 has already gone through the whole 
implementation cycle, data for PP 2014-2020 are expected to change as implementation 
progresses.  Many  fraudulent  irregularities  are  still  to  be  detected.  The  increase  in  the 
financial  amounts  involved  in  irregularities  will  be  at  least  partly  counterbalanced  by  the 
increase in the payments made to the Member States.117  

The  huge  FDR  recorded  by  Romania  (12%)  and  Slovakia  (nearly  10%)  are  due  to  single 
irregularities that involved huge financial amounts.118 These irregularities also have a strong 
impact on the EU-27 FDR, which is higher than in PP 2007-2013. Excluding these outliers 
the FDR of Romania and Slovakia would be about 2% and the EU-27 FDR would be 0.24%. 
The FDR exceeded 0.1% only in  Latvia, Portugal, Sweden, Hungary, Denmark, Estonia. In 
the  other  Member  States,  the  FDR  was  still  close  to  zero.  Comparison  with  the  values 
consolidated for PP 2007-2013 suggests that the FDRs for PP 2014-2020 are likely to change 
significantly in the coming years.  

117  The  FDR  in  Table  CP13  and  the  IDR  in  Table  CP14  are  based  on  net  payments.  These  include  the  pre-
financing, which is frontloaded at the beginning of the programming period.   
118 Romania, one irregularity, accounting for EUR 1 270 million; Slovakia, 2 irregularities, accounting for EUR 
300 million and 290 million, respectively. 

132 

 
 
                                                           
COHESION AND FISHERIES 

4.5.4. 

Irregularity detection rate 

This  section  focuses  on  the  irregularity  detection  rate  (IDR),  which  compares  the  results 
obtained  by  Member  States  in  detecting  non-fraudulent  irregularities  with  the  related 
payments.  

Slovakia  recorded  the  highest  IDR,  at  more  than  6.5%.  In  line  with  the  general  deep 
decrease in non-fraudulent irregularities reported, the IDR is above 1% only in Romania, 
Bulgaria,  Greece.  It  is  between  0.5%  and  1%  in  Estonia,  Austria,  Croatia,  Latvia,  Czechia 
and Lithuania. In all other Member States, IDR is below 0.5%.  

133 

ReportedAmounts involvedNEUREUR%%AT588,632683,655,2790.010.13BE6133,0181,226,924,6260.010.02BG12544,0984,685,365,2780.010.02CY1126,260611,402,9430.020.18CZ376,002,29315,691,219,4900.041.01DE303,769,98212,189,461,5400.030.12DK12870,189443,006,8240.200.04EE204,054,7462,841,720,9140.140.31ES146,45519,604,659,3310.000.06FI1425,5251,115,365,1260.040.00FR1510,015,9079,631,467,5490.100.02GR56,550,88114,138,543,2970.050.11HR41,570,5414,393,398,6130.040.28HU14134,794,02716,446,375,4080.210.05IE00949,693,2850.000.00IT0022,366,820,7360.000.43LT7465,4125,228,515,5520.010.08LU00110,034,7950.000.00LV3215,650,7042,971,688,5450.530.71MT00464,474,0070.000.04NL4160,025809,000,2770.020.26PL9946,585,89958,842,053,7900.080.63PT3039,301,55217,356,974,1430.230.78RO1401,519,306,01812,783,035,09011.890.94SE42,588,9161,176,300,5370.220.00SI5818,0852,272,818,8290.040.62SK76755,313,7207,837,203,1919.640.95TOTAL EU276872,449,182,885242,773,660,6771.010.42UK (2)122,160,8136,398,255,7250.030.13(2) As of 1 February 2020, the UK is no longer part of the EUFraud detection rate 2007-2013(1) Net payments until 2021 from CF, ERDF, ESF, EMFF. Total includes payments related to cross border cooperationTable CP13: Number of irregularities reported as fraudulent, amounts involved and fraud detection rate by Member State - Programming period 2014-20Member StateIrregularities reported as fraudulent PP 2014-20Payments PP 2014-2020 (1)Fraud detection rate 2014-2020 
 
 
COHESION AND FISHERIES 

4.5.5.  Follow-up to suspected fraud (programming period 2007-2013) 

In  the  2019  PIF  Report,  a  new  analysis  of  the  follow-up  Member  States  give  to  suspected 
fraud has been introduced. This analysis considers the irregularities that have been  reported 
as  suspected  fraud  from  2007  to  2013  and  look  at  whether  these  irregularities  have  been 
dismissed  (meaning  whether  they  have  been  de-classified  to  administrative  irregularities), 
they  are  still  pending  as  suspected  fraud  or  they  have  been  confirmed  as  established  fraud 
(following a final verdict). The details about the methodology for this analysis can be found 
in the 2019 PIF.119 

Table  CP15  includes  the  update  of  the  dismissal  ratio,  established  fraud ratio  and  pending 
ratio.  The  dismissal  ratio  gives  the  percentage  of  fraudulent  irregularites  that  have  been 
reclassified  as  non-fraudulent  during  their  lifetime,  until  end  of  2021.120  The  established 
fraud ratio gives the percentage of fraudulent irregularites that were classified as established 

119 See Section 4.4.5. of ‘Statistical evaluation of irregularities reported for 2019: own resources, agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2020)160 final (part 2/3) 
120 IRQ2 stands for non-fraudulent irregularities, IRQ3 stands for suspected fraud, IRQ5 stands for established 
fraud.  The  following  paths  are  considered  for 
the  dismissal  ratio:  IRQ3IRQ2,  IRQ2IRQ3IRQ2, 
IRQ3IRQ5IRQ3IRQ2, IRQ3IRQ5IRQ2, IRQ5IRQ2.  

134 

ReportedAmounts involvedNEUREUR%%AT503,869,912683,655,2790.572.19BE543,356,5491,226,924,6260.271.22BG24859,777,9844,685,365,2781.282.46CY12765,039611,402,9430.130.70CZ52680,477,50715,691,219,4900.514.88DE23622,528,67512,189,461,5400.180.53DK12787,194443,006,8240.180.40EE23225,502,0342,841,720,9140.900.90ES23942,631,56519,604,659,3310.224.74FI341,185,6571,115,365,1260.110.25FR30835,816,0499,631,467,5490.370.45GR111173,255,68114,138,543,2971.234.07HR10925,238,5924,393,398,6130.571.23HU44677,744,18916,446,375,4080.471.55IE361,893,855949,693,2850.202.05IT29152,990,97922,366,820,7360.241.34LT28526,103,1555,228,515,5520.501.51LU114,259110,034,7950.010.42LV8516,781,7702,971,688,5450.562.44MT121,208,432464,474,0070.261.86NL22765,251809,000,2770.092.19PL1,898291,200,66558,842,053,7900.492.01PT19221,511,08817,356,974,1430.120.86RO480165,983,30812,783,035,0901.303.33SE483,093,3421,176,300,5370.260.49SI292,480,9972,272,818,8290.111.33SK415531,821,0757,837,203,1916.799.06TOTAL EU276,4111,668,784,803242,773,660,6770.692.52UK (2)1,31832,418,0306,398,255,7250.512.22(2) As of 1 February 2020, the UK is no longer part of the EUIrregularity detection rate2007-2013Table CP14: Number of irregularities not reported as fraudulent, amounts involved and irregularity detection rate by Member State - Programming period 2014-20  (1) Net payments until 2021 from CF, ERDF, ESF, EMFF. Total includes payments related to cross border cooperation.Member StateIrregularities not reported as fraudulent PP 2014-20Payments PP 2014-2020Irregularity detection rate2014-2020 (1) 
 
 
                                                           
COHESION AND FISHERIES 

fraud  by  the  end  of  2021.121  The  pending  ratio  gives  the  percentage  of  fraudulent 
irregularities that were still classified as suspected fraud at  the end of 2021.  122 These three 
percentages sum to 100%. 

Similar  to  the  situation  up  to  2019,  27%  of  the  irregularities  reported  as  fraudulent 
were dismissed and reclassified as non-fraudulent by the end of 2021. Another 56% of 
these irregularities were still pending.  This  may  point to a significant  underestimation  of 
the dismissal ratio, because part of these cases that are still classified as suspected fraud are 
already closed. In any case, between 8 and 15 years have already passed since the detection 
of the irregularity and the more time passes the less it can be expected that fraud will actually 
be established.  

The  dismissal  ratio  varied  across  the  Member  States.  High  dismissal  ratios,  especially 
when associated with high pending ratios, may be due either to the detection phase or to 
the investigation/prosecution phase. Low dismissal ratios may be positive, but they may 
also be the result of many irregularities still pending. After eight years following the end 
of the period under consideration, the dismissal ratio was zero or very low in many Member 
States. This indicator must be read in combination with the pending ratio. The latter points to 
the  possibility  that  the  dismissal  ratio  increases  in  the  future  (depending  on  the  number  of 
pending cases that are still open) or to an underestimation of the dismissal ratio (depending 
on the number of pending cases that are already closed). The dismissal ratio also depends on 

121 The following paths are considered for the established fraud ratio: IRQ3IRQ5, IRQ2IRQ3IRQ5, IRQ2IRQ5, 
IRQ5, IRQ2IRQ3IRQ2IRQ3IRQ5  
122 The following paths are considered for the  pending ratio: IRQ3, IRQ2IRQ3, IRQ5IRQ3, IRQ3IRQ2IRQ3, 
IRQ2IRQ3IRQ2IRQ3, IRQ3IRQ5IRQ3 

135 

RatioRatioRatio%%%AT00117583BE00002100BG1139141657CY00117583CZ31607131427DE161550454440EE117233350ES37500125FI31000000FR00001100GR003141886HU00006100IE00002100IT3247113551LT00009100LV6188242059MT000014100PL383016137357PT19001091RO12245295SE26700133SI75418538SK116953100EU2716327981633656Table CP15 - Programming period 2007-2013, irregularities reported during the period 2007-2013Member StateDismissalEstablished fraudPendingN.N.N. 
 
                                                           
COHESION AND FISHERIES 

the stage of the procedure when an irregularity is classified as suspected fraud. For example, 
if  such  classification  takes  place  when  the  administrative  authority  forwards  a  case  to  the 
prosecution service, dismissal is more likely. If an irregularity is classified as suspected fraud 
only when a prosecutor requests the indictment, dismissal is less likely.     

The cases of established fraud were few. This may point to the need to further invest in 
the investigation/prosecution phase. At EU-27 level, the established fraud ratio was about 
16%.  It  ranged  from  zero  or  about  zero,  in  nearly  half  of  the  Member  States,  to  45%,  in 
Germany.  The  established  fraud  ratio  is  not  likely  to  increase  significantly  because,  while 
56% of cases are still classified as suspected fraud (pending ratio), part of them are already 
closed and, in any case, between 8 and 15 years have already passed since the detection of the 
irregularity. Similarly to the dismissal ratio, also the established fraud ratio depends on the 
stage of the procedure when an irregularity is classified as suspected fraud (see above).  

4.6. 

Other internal policies 

Other  Funds  are  used  under  shared  management  to  finance  other  internal  policies.  Tables 
CP16  and  CP17  below  provide  an  overview  of  all  the  irregularities  and  related  financial 
amounts reported by the Member States up to 2021 with reference to the: 

 Asylum,  Migration  and  Integration  Fund  (AMIF):  This  Fund  was  set  up  for  the  period 
2014-2020,  with  a  total  envelope  of  EUR  7.7  billion.  It  is  meant  to  promote  the  efficient 
management of migration flows and the implementation, strengthening and development of 
a  common  EU  approach  to  asylum  and  immigration.  The  largest  proportion  of  the  AMIF 
(approximately 62%) is channelled through shared management. Member States implement 
their multiannual national programmes, which the responsible national authorities prepare, 
implement, monitor and evaluate, in partnership with the relevant stakeholders in the field, 
including  the  civil  society.  All  Member  States  except  Denmark  participate  in  the  Fund’s 
implementation.  Beneficiaries  of  the  programmes  implemented  under  the  AMIF  include 
state  and  federal  authorities,  local  public  bodies,  non-governmental  organisations, 
humanitarian  organisations,  international  organisations  and  public  law  companies  and 
education and research organisations. 

 Fund for European Aid to the Most Deprived (FEAD): Over EUR 3.8 billion are earmarked 
for  this  Fund  for  the  period  2014-2020.  The  FEAD  supports  Member  States  in  providing 
material assistance to the most deprived, including food, clothing and other essential items 
for personal use. Material assistance has to go hand in hand with social inclusion measures, 
such as guidance and support to help people out of poverty. National authorities may also 
support  non-material  assistance  to  the  most  deprived  people  to  help  them  integrate  better 
into  society.  Following  the  Commission's  approval  of  national  programmes,  national 
authorities  decide  on  the  delivery  of  the  assistance  through  partner  organisations  (public 
bodies or often non-governmental organisations).  

  European  Globalisation  Adjustment  Fund  (EGF):  This  Fund  provides  support  to  people 
who  lose  their  jobs  as  a  result  of  major  structural  changes  in  world  trade  patterns  due  to 
globalisation  or  as  a  result  of  the  global  economic  and  financial  crisis.  The  EGF  has  a 
maximum  annual  budget of EUR 150 million  for the period 2014-2020.  It can fund up to 
60% of the cost of projects designed to help workers made redundant find another job or set 
up  their  own  business.  EGF  cases  are  managed  and  implemented  by  national  or  regional 
authorities. Each project runs for 2 years. 

 Internal Security Fund (ISF): This Fund was set up for the period 2014-2020, with a total 
envelope of EUR 4.2 billion. The Fund promotes the implementation of the internal security 
strategy,  law  enforcement  cooperation  and  the  management  of  the  EU's  external  borders. 

136 

 
COHESION AND FISHERIES 

The 2014-2020 ISF is composed of two instruments, ISF Borders and Visa (B&V) and ISF 
Police. For the 2014-2020 period: 

o  EUR 3 billion is available to fund actions under the ISF B&V instrument, of which EUR 
2.4 billion are to be channelled through shared management. All Member States except 
Ireland participate in the implementation. The United Kingdom also does not participate; 

o  about  EUR  1.2  billion  is  available  to  fund  actions  under  the  ISF  Police  instrument,  of 
which EUR 754 million are to be channelled through shared management. All Member 
States except Denmark participate in the implementation. The United Kingdom also does 
not participate. 

 Youth  Employment  Initiative  (YEI):  While  supporting  the  Youth  Guarantee,  the  YEI  is 
aimed  at  young  people  who  are  not  in  education,  employment  or  training  (NEETs), 
including the long-term unemployed or those not registered as job-seekers. It ensures that in 
parts  of  Europe  where  the  challenges  are  most  acute,  young  people  can  receive  targeted 
support. The YEI’s total  budget  is  EUR 8.8 billion for the period 2014-2020. Of the total 
budget  of  EUR 8.8  billion,  EUR  4.4  billion  comes  from  a  dedicated  youth  employment 
budget  line,  which  is  complemented  by  another  EUR  4.4  billion  more  from  ESF  national 
allocations.  

The  FEAD  was  the  Fund  most  affected  by  fraud.  Financial  amounts  involved  in  these 
irregularities tend to be high. More than half of the irregularities reported as fraudulent were 
related  to  the  FEAD  and  they  represented  98%  of  the  irregular  financial  amounts.  The 
average financial amounts of these cases was nearly EUR 1 million and this was not due just 
to one case; 6 out of 8 cases ranged between about EUR 850 000 and EUR 1.8 million. 

More than 90% of the detections of non-fraudulent irregularities were related to the following 
Funds: AMIF,  the FEAD and the YEI. After a slight decrease in 2019, the number of AMIF 
irregularities increased in 2020, exceeding also the level reached in 2018, and dropped in 
2021. The reporting of FEAD irregularities has been increasing since 2020, with higher 
financial amounts  involved than with  the  AMIF.  However,  half of the irregular financial 
amounts were associated with the YEI.  

137 

NEURNEURNEURNEURNEURAMIF000000142,455142,455FEAD0034,701,01933,166,046248,16087,915,225YEI143,55800472,771005116,329TOTAL EU27143,55834,701,01973,238,817390,615148,074,009Table CP16: Number of irregularities and financial amounts reported as fraudulent by the Member States -  AMIF, FEAD, EGF, ISF and YEIFUNDREPORTING YEARTOTAL2017201820192020NEURNEURNEURNEURNEURNEURNEURAMIF00111,951221,676,99019536,449321,069,7196183,761803,478,870EGF00000000147,12400147,124FEAD3463,9215813,205101,097,3934873,764141,269,110241,900,290606,417,683ISF1178,812003419,0001223,018381,1828462,535161,364,547YEI0031,045,22493,559,27883,153,2286395,47871,748,415339,901,622TOTAL EU274642,73391,870,380446,752,661324,786,459562,862,613454,295,00119021,209,8462021REPORTING YEARTable CP17: Number of irregularities and financial amounts not reported as fraudulent by the Member States -  AMIF, FEAD, EGF, ISF and YEITOTAL2019FUND2016201720182020 
 
 
 
 
 
COHESION AND FISHERIES 

MAIN FINDINGS 

Fraudulent irregularities 

Fraudulent irregularities related to PP 2007-2013 peaked in 2015, gradually decreased in the 
following  years  and  in  2018  they  were  overtaken  by  those  related  to  PP  2014-2020. 
Reporting related to PP 2014-2020 basically started in 2017. It has been fluctuating around an 
increasing trend, with ups in 2018 and 2020 and downs in 2019 and 2021. These dynamics 
are in line with known trends and patterns in the detection and reporting of irregularities and 
are  linked  to  the  implementation  cycle  of  multiannual  programmes.  For  PP  2014-2020,  the 
financial amounts skyrocketed in 2018 and 2021, but just because of single cases with huge 
amounts involved.  

Also because of the higher share of EU financing channelled through it, ERDF was the Fund 
most affected by fraud, as it had the highest number of cases reported as fraudulent, and the 
related  financial  amounts  were  the  highest.  Since  2019,  the  number  of  ERDF  fraudulent 
irregularities  related  to  PP  2007-2013  has  been  rather  low  and  stable,  while  the  number  of 
those  related  to  PP  2014-2020  has  been  fluctuating  around  an  increasing  trend.  After  a 
decrease  in  2017,  the  number  of  ESF  fraudulent  irregularities  has  been  rather  stable.  Since 
2010,  potential  fraud  affecting  the  CF  is  regularly  reported.  In  2020,  the  majority  of 
detections took place in Romania, while in 2018 it was Slovakia reporting most cases. 

Non-fraudulent irregularities 

The decrease in the number of non-fraudulent irregularities and financial amounts related to 
PP 2007-2013 was significant. This is in line with the multiannual nature of these structural 
programmes, which were closed already in 2015. 

Basically, reporting related to PP 2014-2020 began in 2016. Since then, these detections and 
irregular financial amounts have been increasing for all Funds, but less than expected when 
compared  to  the  previous  programming  period.  In  2021,  despite  a  slight  increase  in  the 
number of reported irregularities, the financial amounts involved significantly rose, because 
of single cases with huge amounts involved.  

As  for  the  fraudulent  irregularities,  trends  in  financial  amounts  are  also  due  to  different 
reporting patterns in the Member States, in terms of the tendency to detect irregularities with 
high or low financial amounts involved and the tendency to detect irregularities that covered 
a significant or marginal share of the whole expenditure in the relevant project.  

Is reporting for PP 2014-2020 in line with past trends? 

Apart  from  outliers,  the  number  and  financial  amounts  reported  as  fraudulent  for  PP  2014-
2020 were in line with those detected for PP 2007-2013 after a comparable period from the 
start of the programming period.  

Focusing  instead  on  the  non-fraudulent  irregularities,  the  fall  in  the  number  and  financial 
amounts reported after 8 years from the start of the programming period is striking. The gap 
is significant for all Funds.  

Analysis suggests the following potential causes covering a significant part of the decline: 

  The  implementation  of  the  operational  programmes  under  PP  2014-2020  has  been 
delayed  when  compared  with  what  the  progress  of  implementation  was  under  PP 
2007-2013.  

138 

 
COHESION AND FISHERIES 

  These  was  a  noticeable  change  in  the  reporting  of  irregularities  below  the  threshold  of 
EUR 10 000. This may be due a change in the reporting practices or to less instances of 
small interlinked cases reported separately.  

  For  PP  2014-2020,  the  possibility  to  use  simplified  cost  options  (SCOs)  has  been 
extended.  For  the  ESF,  the  increase  in  the  percentage  of  expenditure  covered  by  SCOs  
may be a significant factor contributing to the drop in non-fraudulent irregularities.  

  For PP 2014-2020, the annual accounts have been introduced, with the new possibility of 
excluding expenditure under assessment of legality and regularity without a reduction in 
the support by the Fund. This may have brought a more orderly treatment of irregularities. 

Also  changes in  the derogations to  reporting, which entered into force in 2009, might  have 
played a role, in case Member State were slow in adapting their reporting practices. 

There are no indicators to gauge the increase in the capability of the implementing bodies and 
of  the  beneficiaries  and  the  impact  that  this  could  have  had  in  terms  of  decrease  of 
unintentional irregularities. However, this can be an additional factor contributing to the trend 
in  non-fraudulent  irregularities.  Capacity  building  actions  may  have  been  put  in  place  in 
recent  years  and  this  is  relevant,  especially  in  case  implementing  bodies  and  beneficiaries 
during PP 2014-2014 are the same as during PP 2007-2013.  

Member  States  should  assess  the  extent  to  which  these  potential  explanations  and  other 
possible  explanations  actually  apply  to  their  operational  programmes,  with  the  aim  of 
implementing corrective measures in case the decline may be due to less effective detection 
and reporting.  

Irregularities by area of the cohesion policy 

Concerning fraud, risks seem to be higher in the areas of the cohesion policy related to: 

 

 

transport and environment protection, because of the high financial amounts involved in 
fraudulent irregularities; 

research, technological development and innovation (RTD&I) and employment, because 
of the frequency of fraudulent irregularities. 

Concerning  non-fraudulent  irregularities,  RTD&I  and  inclusion  were  areas  with  very  high 
number of cases and/or financial amounts involved. As for fraudulent irregularities, also for 
non-fraudulent  irregularities,  the  irregular  financial  amounts  involved  in  transport  were 
disproportionately high.  

Green transition 

Concerning  fraud  in  relation  to  the  green  transition,  analysis  suggests  higher  risks  for 
investments in: 

  energy efficiency (contributing to the transition to low-carbon economy), because of the 
number of fraudulent irregularities. When specified, they mostly concerned renovation of 
existing  housing  stock  and  were  about  conflict  of  interests  in  procurement  or  incorrect 
documents; 

  provision  of  drinking  water  (contributing  to  environment  protection),  because  of  the 

financial amounts involved; 

  waste management (contributing to environment protection), both in terms of number of 
fraudulent  irregularities  and  financial  amounts.  Most  of  these  fraudulent  irregularities 
concerned household waste management and public procurement. 

139 

 
COHESION AND FISHERIES 

Concerning non-fraudulent irregularities in relation to the green transition, analysis suggests 
higher risks for investments in: 

  water management, because of the financial amounts involved on the irregularities; 

  energy  efficiency,  including  the  renovation  of  public  infrastructure,  and  waste 

management, because of the number of irregularities.  

 

renewable energy (solar) and risk prevention, because of the number of irregularities and,  
for risk prevention, because of the financial amounts involved in the irregularities. 

Reseach, technological development and innovation 

Research,  technological  development  and  innovation  was  an  area  at  risk,  with  frequent 
irregularities  and  the  high  financial  amounts  involved,  in  particular  with  reference  to 
assistance to these activities in SMEs. For the latter, the most recurrent fraudulent violations 
concerned the documentary proof, in particular false or falsified documents. There were also 
a significant number of fraudulent cases of conflict of interests.  

Activities in reasearch centres and the technology transfer contributed to the total number of 
non-fraudulent  irregularities  affecting  research  and  innovation.  However,  this  seems  to  be 
more in line with the share of expenditure declared for these intervention fields. 

Transport and networks 

Concerning  fraud  in  relation  to  trasport  and  networks,  analysis  suggests  higher  risks  for 
investments in: 

 

roads that are not part of TEN, because of the number of fraudulent irregularities, which 
is  probably  linked  to  the  higher  number  of  projects,  which  reach  the  regional  or  local 
level. The most frequent violations concerned the documentary proof, in particular false 
or  falsified  documents.  There  were  several  cases  concerning  ethics  and  integrity, 
including  conflict  of  interests  and  corruption,  and  several  cases  related  to  public 
procurement; 

 

railways  and  TEN  roads,  because  of  the  high  financial  amounts  involved  in  fraudulent 
irregularities; 

Concerning  non-fraudulent  irregularities  in  relation  to  trasport  and  networks,  analysis 
suggests higher risks for investments in: 

 

roads, with higher financial amounts involved in TEN investments; 

  no TEN railways, because of the number of irregularities and TEN railways, because of 

the financial amounts involved; 

  TEN multimodal transport investments;  

 

investments in the electricity networks, because of the number of irregularities despite the 
low amount of expenditure declared so far in this area.  

Digital transition 

Fraudulent irregularities related to the digital transition were not frequent and they concerned 
services  and  applications  both  for  SMEs  and  for  e-Government,  with  higher  financial 
amounts involved in the latter. 

Non-fraudulent  irregularities  were  more  frequent.  The  number  of  irregularities  related  to 
services and applications for SMEs was more significant than that related to e-Government, 
when considering the lower amount of expenditure declared in services and applications for 

140 

 
COHESION AND FISHERIES 

SMEs.  However,  the  financial  amounts  involved  in  irregularities  related  to  services  and 
applications for e-Government were higher. Non-fraudulent irregularities were reported also 
in relation to investments in the infrastructure for the digital transition. 

Social inclusion, poverty and discrimination 

Concerning fraud in relation to social inclusion, poverty and discrimination, analysis suggests 
higher risks for investments in: 

  active  inclusion,  because  of  the  number  of  fraudulent  irregularities.  The  most  recurrent 
violations  were  about  the  implementation  of  the  action  or  the  documentary  proof  (in 
particular false documents); 

  health 

infrastructure,  because  of 

in  fraudulent 
irregularities.  In  addition,  fraudulent  irregularities  impacted  also  on  the  funding  for  the 
improvement of access to services, which include healthcare, and most of the times, these 
violations were about the non or partial implementation of the action. 

the  financial  amounts 

involved 

Concerning non-fraudulent irregularities, analysis suggests higher risks for investments in: 

  social infrastructure and projects for urban and rural regeneration; 

 

improved  access  to  health  care  and  social  services  and  investments  in  favour  of 
marginalised  communities,  because  of  the  financial  amounts  involved  in  irregularities, 
and child infrastructure, because of the number of cases despite low expenditure declared. 

Promoting sustainable and quality employment and supporting labour mobility 

Concerning fraud in relation to the promotion of employement and labour mobility, analysis 
suggests higher risks for investments in the adaptation to change of workers and enterprises, 
in particular operations for the design and dissemination of innovative and more productive 
ways  of  working.  For  these  operations,  the  majority  of  violations  concerned  the 
non-implementation  of  the  action  or  conflict  of  interests,  including  combined  in  the  same 
irregularity. In a number of cases, conflict of interests was combined with multiple financing. 
Infringements related to the documentary proof were also recurrent, often because of false or 
falsified documents.  

Concerning non-fraudulent irregularities, analysis suggests higher risks for investments in: 

  access  to  employment,  in  particular  operations  for  job-seekers  and  inactive  people, 

including the long-term unemployed and people far from the labour market; 

  support for self-employment and business  start-up, because of the number of fraudulent 

irregularities. 

Irregularities by type 

Concerning  fraudulent  irregularities,  the  most  frequent  violations  were  about  supporting 
documents, in particular the use of false or falsified documents.  

High  financial  amounts  were  involved  in  fraudulent  irregularities  were  infringements  of 
contract  provisions/rules  took  place.  Fraud  often  consisted  in  incomplete  or  non-
implementation of the funded action.  

Most of fraudulent violations concerning ethics and integrity were about conflict of interests. 
Ethichs and integrity is the category of infringement with the highest frequency of fraud. 

Infringements  of  public  procurement  rules  were  the  most  reported  among  non-fraudulent 
violation, but only in 4% of these cases fraud was detected. The low frequency of fraudulent 

141 

 
COHESION AND FISHERIES 

cases  suggests  that  either  fraud  detection,  investigation  and  prosecution  concerning  public 
procurement or the administrative capability of contracting authorities should be improved.  

Risk analysis and spontaneous reporting 

Risk analysis has still a marginal contribution in detecting fraud, while information from civil 
society has a significant and growing role. During the past five years, about one out of four 
irregularities  has  been  detected  following  tips  from  informant,  whistle-blowers,  etc.  and 
information published in the media.  

In  relation  to  non-fraudulent  irregularities,  neither  risk  analysis  nor  information  from  civil 
society had a noticeable role in detection. There was no significant improvement with respect 
to the previous five years. 

Detection  of  fraud  and  irregularities  could  improve  by  adding  to  preventive  checks  before 
payments  and  audits  of  operations  also  ex-post  thematic  risk  analysis  projects  focusing  on 
groups of past transactions. The choice of the groups of transactions could be based also (but 
not only) on the finding of previous audit work, including system audits. These risk analyses 
should  consider  these  transactions  in  the  wider  context,  including  linking  them  to  other 
transactions,  considering  links  through  beneficiaries,  contractors,  subcontractors,  beneficial 
owners. These risk analysis projects should be carried out by bodies that are external to the 
management  authorities  and  would  result  in  selecting  a  number  of  transactions  for  tailored 
ex-post checks. The involvement of the national Anti-fraud Coordination Services (AFCOS) 
could be considered.       

Antifraud and control activities by the Member States 

Two third of the irregularities have been occurring over a period of time, averaging one year 
and a half. The rest of the irregularities consisted of a single act identifiable on a precise date. 
On average, it took more than one year to come to a suspicion that a fraudulent irregularity 
had been committed and one year and a half to close the case after reporting. These average 
times are expected to increase as the implementation of the operational programe progresses.   

With reference to PP 2014-2020, the Fraud Detection Rates recorded by Romania (12%) and 
Slovakia  (nearly  10%)  were  huge,  but  due  to  single  irregularities  that  involved    enormous 
financial  amounts.  These  irregularities  also  had  a  strong  impact  on  the  EU-27  FDR,  which 
was  about  1%  and  higher  than  in  PP  2007-2013.  The  FDR  exceeded  0.1%  only  in  Latvia, 
Portugal, Sweden, Hungary, Denmark, Estonia.  

With reference to PP 2014-2020, Slovakia recorded the highest Irregularity Detection Rate, at 
more  than  6.5%.  In  line  with  the  general  deep  decrease  in  non-fraudulent  irregularities 
reported,  the  IDR  was  above  1%  only  in  Romania,  Bulgaria,  Greece.  At  EU-27  level,  IDR 
was about 0.7%, much lower that in PP 2007-2013.  

These  FDRs  and  IDRs  for  PP  2014-2020  are  likely  to  change  significantly  in  the  coming 
years, with progress in the implementation of the operational programmes.  

About  one  fourth  of  the  irregularities  reported  as  fraudulent  were  dismissed.  The  dismissal 
ratio varied across the Member States. High dismissal ratios, especially when associated with 
a high number of still pending cases, may be due to (i) a detection phase that leads to report 
to the judicial authority cases that were not fraudulent; (ii) an investigation/prosecution phase 
that gives low priority or does not have enough resources to properly address the case; (iii) 
the stage of the procedure when an irregularity is classified as suspected fraud.    

Analysis suggests that the dismissal ratio is significantly underestimated. About  56% of the 
irregularities reported as fraudulent were still pending. However, for part of them no changes 

142 

 
COHESION AND FISHERIES 

of  status  are  to  be  expected,  because  they  are  closed  cases.  In  any  case,  between  8  and  15 
years  have  already  passed  since  the  detection  of  the  irregularity.  There  were  few  cases  of 
established fraud. This may indicate the need to invest further in the investigation/prosecution 
phase.  

Other shared management funds 

Concerning shared management Funds to finance other internal policies, the FEAD was the 
Fund  most  affected  by  fraud.  Financial  amounts  involved  in  these  irregularities  tend  to  be 
high, as the average financial amounts of these cases was nearly EUR 1 million. 

More than 90% of the detections of non-fraudulent irregularities were related to the following 
Funds: AMIF, the FEAD and the YEI. After a slight decrease in 2019, the number of AMIF 
irregularities  increased  in  2020,  exceeding  also  the  level  reached  in  2018,  and  dropped  in 
2021.  The  reporting  of  FEAD  irregularities  has  been  fluctuating  during  the  period,  with 
higher financial amounts involved than for the AMIF. Half of the irregular financial amounts 
were associated with the YEI. 

143 

 
PRE-ACCESSION 

5. 

PRE-ACCESSION POLICY 

EXECUTIVE SUMMARY 

Irregularities  reported  during  the  period  2017-2021  in  relation  to  pre-accession  occurred  in 
connection  with  funds  distributed  under  Pre-accession  Assistance  (2000-2006,  PAA),  the 
Instrument  for  Pre-accession  Assistance  I  2007-2013  (IPA  I)  and  the  Instrument  for  Pre-
accession Assistance II 2014-2020 (IPA II). About 19% of these irregularities were reported 
as fraudulent. This percentage (fraud frequency level – FFL) changed over time, increasing in 
2019 and peaking in 2021 at 25%. In 2021, nearly 60% of cases and more than 70% of the 
related financial amounts were reported by Turkey.   

reported  3 269 

There  was  just  one  non-fraudulent  irregularity  related  to  PAA  reported  in  2021,  while  the 
latest fraudulent irregularities were detected in 2018. This is in line with the implementation 
cycle  of  the  PAA  programmes,  which  covered  the  period  2000-2006.  Since  2000,  14 
for  around 
beneficiary  countries  have 
EUR 416 million).  The  three  most  affected  funds  were  SAPARD  (rural  development), 
PHARE  (institution  building,  cohesion  and  cross  border  cooperation)  and  ISPA  (large 
infrastructure).  In  terms  of  financial  amounts,  ISPA  was  more  affected  than  PHARE,  even 
though  ISPA  accounted  for  fewer  irregularities.  This  is  in  line  with  the  larger  size  of  the 
projects  funded  by  ISPA.  Most  of  the  irregularities  related  to  SAPARD  were  reported  by 
Romania, followed by Bulgaria and Poland. Most of the irregularities related to PHARE were 
evenly split between Romania and Bulgaria. Reporting from Romania accounted for the bulk 
of irregularities related to the ISPA programme. 

irregularities 

(accounting 

About 65% of the irregularities reported during the past  5  years  were still related to  IPA  I, 
although  the  number  of  such  irregularities  fell  markedly  in  the  last  two  years.  The  fraud 
frequency level was 18% over the past five years, although in 2019 it exceeded 30%. Since 
2007,  10  beneficiary  countries  have 
for 
EUR 76 million).  The  highest  number  of  irregularities  concerned  IPARD  (the  successor  of 
SAPARD  for  rural  development),  with  over  87%  of  the  irregularities  detected  by  Turkey. 
Only two other countries, Croatia  and North Macedonia,  reported  IPARD cases. A broader 
range  of  countries  reported  irregularities  concerning  cross  border  cooperation  (CBC);  this 
was the second most affected component of IPA I. The majority of these irregularities were 
reported  by  Bulgaria.  Turkey  reported  76%  of  the  irregularities  related  to  human  resources 
development (HRD) programmes, the third most affected component of IPA I. 

reported  860 

irregularities 

(accounting 

2017 saw the start of irregularities reporting for IPA II. The number of irregularities reported 
fell markedly in 2020, to bounce back in 2021. During the past 5 years, the fraud frequency 
level  was  19%,  close  to  the  FFL  for  IPA  I.    The  two  main  contributors  to  detection  were 
Turkey and North Macedonia, which together reported about 77% of irregularities and 82% 
of  the  related  financial  amounts.  More  than  76%  of  the  227  irregularities  related  to  IPA  II 
(accounting for EUR 5 million) concerned IPARD. The only other component with more than 
20 irregularities was cross border cooperation. Most of these irregularities were detected by 
Serbia and Bulgaria. 

144 

 
 
 
 
PRE-ACCESSION 

5.1. 

Introduction 

Section  5  presents  a  statistical  evaluation  of  irregularities  and  fraud  detected  by  the 
beneficiary countries during 2021 with reference to the pre-accession policy. It places these 
detections in the context of past years and relevant programming periods. 

The EU provides pre-accession assistance to candidate countries and potential candidates for 
EU  membership  to  support  them  in  meeting  the  accession  criteria  and  to  bring  their 
institutions and standards in line with the EU  acquis123. The current candidate countries are 
Albania, Montenegro, North Macedonia, Serbia and Turkey; potential candidates are Bosnia 
and Herzegovina and Kosovo124. 

In the whole section, when reference is made to ‘fraudulent’ or ‘fraud’, it includes ‘suspected 
fraud’ and ‘established fraud’. 

5.2. 

Instruments for Pre-accession Assistance  

5.2.1.  Before 2007: Pre-accession Assistance (PAA)  

Before  2007,  the  EU  provided  pre-accession  assistance  to  candidate  countries  through  a 
number  of  separate  instruments.  The  PHARE  programme  provided  support  for  institution-
building  measures  and  associated  investment,  as  well  as  funding  measures  to  promote 
economic and social cohesion and cross border cooperation. The ISPA programme dealt with 
large-scale  environmental  and  transport  infrastructure  projects,  while  the  SAPARD 
programme  supported  agricultural  and  rural  development.  For  the  programme  years 
2002-2006, Turkey received assistance under the specific pre-accession-oriented framework 
of the Pre-accession Financial Assistance for Turkey (TIPAA). The CARDS programme was 
the main financial instrument to  promote stability  in  the Western Balkans and facilitate the 
region’s closer association with the EU. The countries that joined the EU in 2004125 received 
a  Transition  Facility  (TF)  in  2004-2006,  as  did  Bulgaria  and  Romania  in  2007-2010.  All 
pre-2007 programmes and projects have been completed. 

5.2.2. 

2007-2013: The Instrument for Pre-accession Assistance (IPA I) 

For the period 2007-2013, the EU supported reforms in the ‘enlargement countries’ (i.e., the 
candidate  countries  Albania,  Montenegro,  North  Macedonia,  Serbia,  and  Turkey  and 
potential candidates Bosnia and Herzegovina and Kosovo), providing financial and technical 
help  via  the  Instrument  for  Pre-accession  Assistance  (IPA  I)126.  IPA  I  funds  built  up  the 
capacities of these countries throughout the accession process.  IPA I had a budget of about 
EUR 11.5 billion and consisted of five components127.  

The five components of IPA I were: (i) transition assistance and institution building (TAIB); 
(ii)  cross  border  cooperation  (CBC);  (iii) regional  development  (transport,  environment  and 
economic  development)  (REGD);  (iv)  human  resource  development  (strengthening  human 
capital  and  combatting  exclusion)  (HRD);  and  (v)  rural  development  (IPARD).  Candidate 
countries were eligible for all five components; potential candidates were eligible only for the 
first two128. 

123 Source: https://ec.europa.eu/neighbourhood-enlargement/policy/glossary/terms/preaccession-assistance_en 
124 This designation is without prejudice to positions on status, and is in line with UNSCR 1244/1999 and the 
ICJ Opinion on the Kosovo declaration of independence.  
125 Cyprus, Czechia, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Slovakia, and Slovenia. 
126 See Council Regulation (EC) 1085/2006 of 17 July 2006, OJ L 210, 31.7.2006, p. 82-93. 
127 Source: https://ec.europa.eu/neighbourhood-enlargement/instruments/overview_en. 
128 Source: https://ec.europa.eu/regional_policy/en/funding/ipa/. 

145 

 
                                                           
PRE-ACCESSION 

The  policy  and  programming  of  IPA  I  consisted  of  (i)  multiannual  indicative  financial 
framework  on  a  three-year  basis,  established  by  country,  component  and  theme;  and  (ii) 
multiannual indicative planning documents per country or per groups of countries (regional 
and horizontal programmes). The candidate countries also had to submit strategic coherence 
frameworks  and  multiannual  operational  programmes  for  the  third  and  fourth  component. 
Their principal aim was to prepare beneficiary countries for the future use of cohesion policy 
instruments  by  closely  imitating  its  strategic  documents,  national  strategic  reference 
framework and operational programmes, and management modes. 

5.2.3. 

2014 – 2020: The Instrument for Pre-accession Assistance (IPA II)  

For  the  period  2014-2020,  IPA  II  built  on  the  results  achieved  under  IPA  I  and  set  a  new 
framework  for  providing  pre-accession  assistance.  The  primary  innovation  of  IPA  II  is  its 
strategic  focus  on  specific  objectives.  The  multiannual  financial  framework  for  2014-2020 
allocated EUR 12.8 billion for the instrument129.  

Financial  assistance  under  IPA  II  pursues  four  specific  objectives:  (i)  support  for  political 
reforms; (ii) support for economic, social and territorial development; (iii) strengthening the 
beneficiaries’  ability  to  fulfil  (future)  obligations  stemming  from  EU  membership  by 
supporting  progressive  alignment  with  the  EU  acquis;  and  (iv)  strengthening  regional 
integration  and  territorial  cooperation.  The  IPA  II  Regulation  limits  financial  assistance  to 
five  policy  areas:  (i)  reforms  in  preparation  for  EU  membership  and  related  institution-and 
capacity-building;  (ii)  socio-economic  and  regional  development;  (iii)  employment,  social 
policies,  education,  promotion  of  gender  equality,  and  human  resources  development; 
(iv) agriculture and rural development; and (v) regional and territorial cooperation. 

To  provide  an  individual  implementation  framework  for  each  beneficiary,  country  strategy 
papers  were  drafted,  identifying  sectors  where  improvements  were  necessary  to  advance 
membership  goals.  The  priorities  outlined  in  these  papers  were  translated  into  detailed 
actions, included in annual or multiannual action programmes that take the form of financing 
decisions adopted by the European Commission. 

The bulk of IPA II assistance is channelled through the country action programmes; these are 
the main vehicles for addressing country-specific needs in priority sectors as identified in the 
indicative  strategy  papers.  Additionally,  IPA  II  funded  multi-country  action  programmes  to 
enhance regional cooperation, particularly in the Western Balkans. Financial assistance was 
also  provided via cross  border cooperation  programmes to  encourage territorial  cooperation 
between  IPA  II  beneficiaries  and  via  rural  development  programmes  to  encourage  the 
development of rural areas. 

In  accordance  with  the  Financial  Regulation,  IPA  II-funded  activities  are  managed  either 
directly (meaning that the Commission implements them directly until the relevant national 
authorities are accredited to  manage the funds) or indirectly (meaning that the Commission 
delegates the management of certain actions to external entities, while still retaining overall 
final responsibility for the general budget execution). Cross border cooperation programmes 
with Member States are administered via shared management, meaning that implementation 
tasks are delegated to the Member States. 

129 See Regulation (EU) 231/2014 of the European Parliament and of the Council of 11 March 2014 establishing 
an Instrument for Pre-accession Assistance (IPA II), OJ L 77, 15.3.2014, p. 11–26 and  
https://ec.europa.eu/neighbourhood-enlargement/instruments/overview_en.  

146 

 
                                                           
PRE-ACCESSION 

5.2.4. 

2021 – 2027: The Instrument for Pre-accession Assistance (IPA III)  

The general objective of the new IPA III instrument is to support the beneficiaries in adopting 
and  implementing  the  political,  institutional,  legal,  administrative,  social  and  economic 
reforms  required  by  those  beneficiaries  to  comply  with  Union  values  and  to  progressively 
align to Union rules, standards, policies and practices with a view to Union membership. 

IPA  III  will  leverage  support  to  reforms  fostering  sustainable  socio-economic  development 
and bringing the partners closer to the Union’s values and standards. 

The new programming  framework 2021-2027  reflects  the specific objectives  of the  IPA  III 
Regulation  and  focuses  on  the  priorities  of  the  enlargement  process  according  to  five 
thematic  windows,  which  mirror  the  clusters  of  negotiating  chapters  as  per  the  revised 
enlargement methodology. 

For the new multiannual financial framework period 2021-27, the IPA III budgetary envelope 
is EUR 14.2 billion130. 

5.3. 

General analysis 

This  section  focuses  on  the  700  irregularities  reported  during  the  period  2017-2021,  in 
relation  to  pre-accession  funds.131  These  irregularities  occurred  in  connection  with  funds 
distributed  under  the  2000-2006  PAA132  and  under  IPA  I  and  IPA  II133.  This  is  further 
explored in Sections 5.4, 5.5 and 5.6134. There were no irregularities reported under IPA III 
yet. 

Table PA1 (and the related graph) shows all the fraudulent and non-fraudulent irregularities 
detected  by  the  beneficiary  countries  during  the  past  5  years  under  pre-accession 
programmes. About 19% of these irregularities were reported as fraudulent. This percentage 
(the  fraud  frequency  level  –  FFL)  changed  over  time,  increasing  significantly  in  2019  and 
peaking in 2021 at 25%. 

130 https://ec.europa.eu/neighbourhood-enlargement/instruments/overview_en. 
131 Data for this analysis has been download from the Irregularity Management System (IMS) on 7/3/2022.   
132 SAPARD, PHARE, ISPA, CARDS, TIPAA, TF. 
133 CBC, HRD, IPARD, REGD and TAIB. 
134  To  provide  the  complete  picture,  three  additional  irregularities  must  be  mentioned.  These  irregularities, 
reported as fraudulent by Romania in 2020 and 2021, and as non-fraudulent by Estonia in 2021, relate to cross 
border cooperation under the European Neighbourhood Instrument. These irregularities are not included in the 
following  analysis,  as  they  do  not  relate  to pre-accession.  As  part  of  EU  policy  towards  its  neighbours,  cross 
border cooperation supports sustainable development along the EU’s external borders, helps reduce differences 
in living standards and addresses common challenges across these borders.  

147 

NEURNEURNEUR2017182,924,96510614,724,61912417,649,5842018171,721,26213110,350,22814812,071,4902019443,768,2771679,925,41221113,693,6892020223,895,603805,346,6921029,242,2952021291,862,348864,185,1481156,047,496TOTAL13014,172,45557044,532,09970058,704,554YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTALTable PA1 - Reported irregularities, 2017-2021 
 
                                                           
PRE-ACCESSION 

For 2021, irregularities were reported by eight beneficiary countries (see Table PA2). Nearly 
60%  of  these  cases  and  more  than  70%  of  the  related  financial  amounts  were  reported  by 
Turkey. As mentioned, the global fraud frequency level in 2021 was 25%, ranging from 54% 
in  Serbia  to  0  in  Albania,  Bulgaria,  Croatia  and  Romania.  When  focus  is  on  the  financial 
amounts,  the  differences  were  even  greater.  Here,  comparison  is  based  on  the  share  of 
financial  amounts  reported  as  fraudulent  (fraud  amount  level  –  FAL).  Serbia  recorded  the 
highest  FAL,  at  72%,  while  Turkey  accounted  for  the  lowest,  at  32%  (apart  from  Albania, 
Bulgaria, Croatia and Romania, which reported no fraudulent cases and Montenegro, which 
reported one case but without specifying of the financial amounts involved).  

5.4. 

Pre-accession Assistance (PAA 2000-2006) 

5.4.1.  Recent trends 

There  was  just  one  non-fraudulent  irregularity  related  to  PAA  reported  in  2021,  while  the 
latest fraudulent irregularities were detected in 2018. During the past 5 years, the beneficiary 
countries reported just 15 irregularities, where about EUR 3 million were involved (see Table 
PA3 and related graph). 

148 

FraudulentNon-fraudFFLiFraudulentNon-fraudFALiAL050%07,0430%BG030%088,7840%HR010%063,1960%ME1517%0324,5480%MK1185%57,05247,84454%RO020%0474,2570%RS7654%380,194148,12372%TR204630%1,425,1013,031,35332%TOTAL298625%1,862,3474,185,14831%i For details on the calculation of the FFL and FAL, see SWD(2016)237 final. http://ec.europa.eu/anti- fraud/sites/antifraud/files/methodology_statistical_evaluation_2015_en.pdfNumber of irregularitiesAmount of irregularities (EUR)Table PA2 - Reported irregularities, 2021 
 
 
PRE-ACCESSION 

5.4.2.  Recent trends by component  

The  15  irregularities  related  to  PAA  reported  during  the  past  5  years  concerned  four 
components.  TIPAA  accounted  for  the  highest  number  of  irregularities  and  ISPA  for  the 
highest financial amounts (see Table PA4). 

5.4.3.  Recent trends by beneficiary country 

The 15 irregularities related to PAA reported during the past 5 years were evenly split among 
three countries: Bulgaria, Romania and Turkey. The highest financial amounts were reported 
by Bulgaria (see Table PA5). 

149 

NEURNEURNEUR2017104121,7495121,74920183569,58818,7444578,33220190051,639,81351,639,81320200000002021001456,9011456,901TOTAL4569,588112,227,207152,796,795YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTALTable PA3 - Reported irregularities (PAA), 2017-2021NEURNEURNEURNEUR20170010004121,749201800123,52818,7442546,060201951,639,8130000002020000000002021001456,9010000TOTAL51,639,8133480,42918,7446667,809Table PA4 - Reported irregularities (PAA) by component, 2017-2021TIPAAYearISPAPHARESAPARD 
 
 
 
PRE-ACCESSION 

5.4.4.  Trends since the start of PAA, by beneficiary country and component 

Table PA6 and related graph show the number of irregularities and related financial amounts 
concerning PAA since 2000, by beneficiary country and component. 

Since  2000,  14  beneficiary  countries  have  reported  3 269  irregularities  related  to  six 
components.  The  three  most  affected  components  were  SAPARD,  PHARE  and  ISPA.  In 
terms  of  financial  amounts,  ISPA  was  more  affected  than  PHARE,  even  though  ISPA 
accounted for fewer irregularities. The PHARE  programme provided support for institution 
building,  as  well  as  for  promoting  economic  and  social  cohesion  and  cross  border 
cooperation.  The  ISPA  programme  dealt  with  large-scale  environmental  and  transport 
infrastructure  projects.  This  contributed  to  the  higher  financial  amounts  involved  in  the 
irregularities related to ISPA. 

Most of the irregularities related to SAPARD (rural development) were reported by Romania, 
followed by  Bulgaria and Poland.  Most of the irregularities related to  PHARE were  evenly 
split  between  Romania  and  Bulgaria.  Reporting  from  Romania  accounted  for  the  bulk  of 
irregularities related to the ISPA programme (see Table PA6 and related graph). 

150 

NEURNEURNEUR201700104121,749201800232,2722546,060201941,587,412152,4010020200000002021001456,90100TOTAL41,587,4125541,5746667,809Table PA5 - Reported irregularities (PAA) by country, 2017-2021YearBGROTR 
 
 
PRE-ACCESSION 

151 

NEURNEURNEURNEURNEURNEURBG006023,002,75927822,987,08331859,448,0811240,00000CY0000523,807000000CZ001830,283331,315,470178,320,1420000EE005208,04915897,592213,266,1790000HR22838,96655,388,432245,031,60651,282,8040000HU0000472,200,681623,960,3080000LT0072,33222690,871174,711,72641,021,91600LV0000191,796,91020859,979144,87400MT00008112,620000000PL001283,073853,227,2992795,859,413245,80000RO0038982,559,15233044,412,075944117,908,2070000SI00005189,006331,347,222160,00000SK00149,054613,161,935152,144,6070000TR0000000000956,115,344TOTAL22838,966480112,123,13493286,046,9551,731209,108,66891,412,590956,115,344Table PA6 - Total  irregularities reported under PAA componentsCARDSISPAPHARESAPARDTFTIPAA 
 
 
 
 
 
PRE-ACCESSION 

5.5. 

Instrument for Pre-Accession Assistance (IPA I, 2007-2013) 

5.5.1.  Recent trends 

Most of the irregularities reported during 2017-2021 were still related to  IPA  I (458 out  of 
700), although the number of these irregularities fell markedly in the last two years. The FFL 
was  18%  during  the  past  5  years,  although  in  2019  it  exceeded  30%.  The  number  of 
detections  of  fraudulent  irregularities  was  particularly  high  in  2019  (see  Table  PA7  and 
related graph).  

5.5.2.  Recent trends by component  

The 458 irregularities related to IPA I during the past 5 years concerned five components. By 
far,  the  highest  number  of  cases  and  the  highest  financial  amounts  concerned  IPARD,  the 
successor of SAPARD supporting agriculture and rural development.  

152 

NEURNEURNEUR2017162,924,96510214,602,87111817,527,8352018121,151,6751159,842,97912710,994,6542019383,417,733897,498,55012710,916,2822020123,387,514413,893,127537,280,64120214356,655292,260,888332,617,544TOTAL8211,238,54237638,098,41545849,336,956YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTALTable PA7 - Reported irregularities (IPA I), 2017-2021NEURNEURNEURNEURNEUR201722738,777171,744,9735612,528,2431114,450122,501,393201815181,994421,219,279577,413,172134,000122,146,20920190026205,119819,253,2191047,194101,410,751202000151,346434,515,0600092,714,23520210000181,778,8400015838,704TOTAL37920,771863,220,71725535,488,5342295,644589,611,292Table PA8 - Reported irregularities (IPA I) by component, 2017-2021YearCBC-IPAHRDIPARDREGDTAIB 
 
 
 
PRE-ACCESSION 

5.5.3.  Recent trends by beneficiary country 

During the past 5  years, irregularities related to  IPA I were reported by nine countries. The 
leading contributor to detection was Turkey, which reported about 74% of irregularities and 
87% of the financial amounts. 

5.5.4.  Trends since the start of IPA I, by beneficiary country and component 

Table  PA10  and  related  graph  show  the  number  of  irregularities  and  related  financial 
amounts concerning IPA I since 2007, by beneficiary country and component. 

Since 2007, 10 beneficiary  countries reported 860 irregularities related to five  components. 
The  highest  number  of  irregularities  concerned  IPARD.  About  87%  of  the  irregularities 
related  to  IPARD  were  detected  by  Turkey.  Only  two  other  countries,  Croatia  and  North 
Macedonia,  reported  IPARD  cases.  A  broader  range  of  countries  reported  irregularities 
concerning  cross  border  cooperation  programmes  (CBC-IPA),  the  second  most  affected 
component  of  IPA  I.  The  majority  of  irregularities  were  reported  by  Bulgaria.  The  only 
non-Member  State  that  reported  irregularities  relating  to  CBC  was  Serbia  (apart  from  one 
irregularity reported by Turkey). Besides reporting most of the IPARD irregularities, Turkey 
also  reported  76%  of  the  irregularities  related  to  the  human  resources  development  (HRD) 
programmes, the third most affected component of IPA I (see Table PA10 and related graph). 

153 

NEURNEURNEURNEURNEURNEURNEURNEURNEUR2017001520,932141,681101,368,04790127,9501649,636122,3888015,397,202201800923,4052148,3647103,600536,64710002010110,682,638201910000029,0812770,418126,1830081,153,297889,657,30320201871,4920000000061,848,26000345,829434,515,0602021000000163,19600666,42900117,276252,470,644TOTAL2871,4922444,3373190,045201,543,92441107,065151,968,8221649,636151,238,79033742,722,847Table PA9 - Reported irregularities (IPA I) by country, 2017-2021YearALBGGRHRMEMKRORSTR 
 
 
PRE-ACCESSION 

154 

NEURNEURNEURNEURNEURAL000000003871,492BG114426,49200000000GR3190,04500000000HR51228,97211423,444311,872,5035503,09391,061,787IT3553,93500000000ME002125,871002081,19400MK003267,13915215,05500151,891,292RO4720,83200000000RS21168,206000000141,216,402TR112,5331115,618,81431543,640,918185,968,4247210,409,533TOTAL1972,301,0151466,335,26836145,728,476436,552,71111315,450,506Table PA10 - Total  irregularities reported under IPA I componentsCBC-IPAHRDIPARDREGDTAIB 
 
 
 
 
 
 
PRE-ACCESSION 

5.6. 

Instrument for Pre-accession Assistance II (IPA II 2014-2020) 

5.6.1.  Recent trends 

The reporting of irregularities relating to IPA II started in 2017. The number of irregularities 
reported  fell  markedly  in  2020,  to  bounce  back  in  2021.  During  the  past  5  years,  the  fraud 
frequency level was 19%, close to the FFL for IPA I (see Table PA11 and related graph).  

5.6.2.  Recent trends by component  

The 227 irregularities related to  IPA  II during the past  5  years concerned five components. 
By far, the highest number of cases and the highest financial amounts concerned IPARD. The 
only other component with more than 20 irregularities was cross border cooperation. Most of 
these irregularities were detected by Serbia, closely followed by Bulgaria. 

155 

NEURNEURNEUR201710001020182015498,50417498,50420196350,54473787,049791,137,593202010508,090391,453,565491,961,6552021251,505,692561,467,359812,973,051TOTAL442,364,3261834,206,4772276,570,803YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTALTable PA11 - Reported irregularities (IPA II), 2017-2021NEURNEURNEURNEURNEUR201700001000002018851,409008447,09500102019266,18600721,071,407302020200020391,245,561206716,094202113317,44100542,393,98968,9988252,623TOTAL23435,036201745,158,052118,99817968,717Table PA12 - Reported irregularities (IPA II) by component, 2017-2021TAIBYearCBC-IPAHRDIPARDREGD 
 
 
 
PRE-ACCESSION 

5.6.3.  Recent trends by beneficiary country 

During the past 5 years, irregularities related to IPA II were reported by seven countries. The 
two  main  contributors  to  detection  were  Turkey  and  North  Macedonia,  which  together 
reported about 77% of irregularities and 82% of the related financial amounts. 

5.6.4.  Trends since the start of IPA II, by beneficiary country and component 

Table  PA14  and  the  related  graph  show  the  number  of  irregularities  and  related  financial 
amounts concerning IPA II, by beneficiary country and component. As reporting for IPA II 
started in  2017, data  for the past  5  years and data from  the start  of the programmes  (2014) 
coincide. 

156 

NEURNEURNEURNEURNEURNEURNEUR201700000000000010201800551,409101000307447,095201920266,1860049323,459001025747,9482020353,57900650,98410112,06800126,242291,718,782202157,043388,7846324,5481338,468117,35612511,042411,985,810TOTAL1060,62210206,37913375,53273473,995117,35617537,2841034,899,635Table PA13 - Reported irregularities (IPA II) by country, 2017-2021RSTRYearALBGMEMKRONEURNEURNEURNEURNEURAL000015,46400955,158BG10206,37900000000ME101010375,5330010MK000065469,59061,09323,312RO117,35600000000RS11211,301005150,415001175,567TR0010934,157,05157,9054734,680TOTAL23435,036201745,158,053118,99817968,717Table PA14 - Total  irregularities reported under IPA II componentsTAIBCBC-IPAHRDIPARDREGD 
 
 
 
DIRECT MANAGEMENT 

6. 

DIRECT MANAGEMENT 

6.1. 

Introduction 

Section  6  contains  a  descriptive  analysis  of  the  data  on  recovery  orders  issued  by 
Commission services in relation to expenditures managed under ‘direct management’ mode, 
which is  one of the three implementation  modes the Commission  can use to  implement the 
budget. 

According  to  the  Financial  Regulation,  the  Commission  implements  the  budget  directly 
(‘direct management’) as set out in Articles 125 to 153, through its departments, including its 
staff in the Union delegations under the authority of their respective Head of delegation, in 
accordance with Article 60(2), or through executive agencies as referred to in Article 69135. 
For the financial year 2021, a total of EUR 21 711 million136 has been disbursed under ‘direct 
management’ mode. Table DM1 presents the actual payments by policy areas. Compared to 
previous years, actual payments are lower. 

Table DM1 – Payments made in financial year 2021 by policy area 

General analysis 

6.2. 
For  the  financial  year  2021,  the  Commission  services  registered  879  recovery  items137  in 
ABAC  that  were  qualified  as  irregularities,  for  a  total  financial  value  EUR  42.89  million 

135 Regulation (EU, Euratom) 2018/1046 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 
966/2012PE/13/2018/REV/1, OJ L 193, 30.7.2018, p. 1–222 
136 In 2021, RRF accounted for EUR million 47 228, which is more than twice as big as the rest of the Direct 
Management (EUR million 21 711). As not a single irregularity was reported in 2021 in relation to RRF and its 
presence  in  the  analysis  would  distort  drastically  the  percentages,  it  has  been  excluded  from  the  presented 
analysis. 
Own calculation based on ABAC data. 
137 Recovery items mean ‘recovery context’ elements in ABAC. There can be more recovery context  elements 
associated to one recovery order issued. 

157 

Policy area Payments 2021 EUR million % Agriculture and Maritime Policy 336 1.55% Border Management 62 0.29% Defence 98 0.45% Environment and Climate Action 432 1.99% European Schools and Pensions 210 0.97% European Strategic Investments 3,727 17.17% External Action 4,122 18.99% Investing in People, Social Cohesion and Values 788 3.63% Migration 338 1.56% Pre-accession Assistance 678 3.12% Regional Development and Cohesion 1,123 5.17% Research and innovation 7,609 35.05% Security 133 0.61% Single Market 563 2.60% Space 34 0.16% Other Policies 1458 6.71% Total without RRF 21,711 100.00%   
 
                                                           
DIRECT MANAGEMENT 

irregular  amounts138.  Among  these  recovery  items,  54  have  been  reported  as  fraudulent, 
involving EUR 7.04 million irregular amounts. 

However,  qualifications  attributed  to  recovery  items  may  change  over  the  years:  it  may 
happen that cases of irregularities are turned into suspicions of fraud or the other way round, 
suspicions  of  fraud  are  reclassified  as  non-fraudulent  irregularities  upon  the  closure  of  the 
OLAF investigation. 

6.2.1.  Five year analysis 2017-2021 

The following analysis gives an overview of recovery data recorded in the ABAC system in 
the last five years. Between 2017 and 2021, on average, for one year, there were 50 recovery 
items  qualified  as  ‘irregularities  reported  as  fraudulent’139.  The  ratio  between  the  financial 
amounts  related  to  these  irregularities  and  expenditure  during  2017-2021  is  very  small,  it 
remains  close  to  zero  (0.041%).  This  ratio  is  quite  stable  throughout  the  years.  Figures  are 
presented in Table DM2 below. 

Table DM2 – Irregularities reported as fraudulent and related amounts, financial years 2017-2021 

With regard to ‘irregularities not reported as fraudulent’, between 2017 and 2021, on average, 
for one  year, 1 420 recovery items  are registered. Since 2020, there is a noticeable decline, 
both in the number of cases and in the percentage of irregular amount per payments. Figures 
are presented in Table DM3 below. 

Table DM3 – Irregularities not reported as fraudulent and related amounts, financial years 2017-2021 

Between  2017  and  2021,  in  total,  there  were  7 102  registered  recovery  items  qualified  as 
‘irregularities  not  reported  as  fraudulent’,  with  an  aggregate  recovery  amount  of 
EUR 271.72 million.  The  ratio  between  these  aggregate  irregular  amounts  corresponding  to 
the recovery items and expenditure during 2017-2021 is less than 0.25% (see Total in Table 
DM3). This ratio has been steadily declining for many years now from the zone of 0,5-0,6% 
(six years ago). 

138 Table DM4: sum of the Totals 
139 ‘Irregularities reported as fraudulent’ are cases of recovery items qualified in the ABAC system as ‘OLAF 
notified’. 

158 

EUR millionEUR millionN%201720,12412.37720.061201820,8166.17440.030201920,63010.57370.051202026,5799.15410.034202121,7117.04540.032TOTAL109,86045.302480.041YearPaymentsIrregularities  reported as fraudulentIrregular amounts/ PaymentsEUR millionEUR millionN%201720,12460.3316350.300201820,81666.9715790.322201920,63055.3517780.268202026,57953.2212850.200202121,71135.858250.165TOTAL109,860271.7271020.247YearPaymentsIrregularities not reported as fraudulentIrregular amounts/ Payments 
 
 
                                                           
DIRECT MANAGEMENT 

These figures  show  the  efficiency of the irregularity detection and recovery mechanisms in 
place. 

6.3. 

Specific analysis 

6.3.1.  Recoveries according policy areas 

Table DM4 provides an overview of irregularity statistics by policy area for 2021. 

Table DM4 – Irregularities reported by policy areas and related amounts, 2021 

In the financial  year 2021, the highest numbers of recovery items qualified as 'irregularities 
not reported as fraudulent' was recorded in the budget area ‘Research and innovation’ (126). 
It  was the ‘Single Market’ policy field  where the highest  irregular  amounts  were registered 
(EUR 11.54 million).  

During  the  same  year,  54  recovery  items  were  registered  as  ‘irregularities  reported  as 
fraudulent’. The three policy  areas  with   the  highest   number  of  irregularities  reported  
were ‘Environment and Climate Action’ (12 items), ‘Security, Defence, Border Management’ 
(11 items)  and ‘European Strategic Investments’ (10 items). EUR 7.04 million were involved 
in these irregularities, out of which 31% (EUR 2.16 million) were related to the policy area 
‘Research and Innovation’. 

6.3.2.  Recoveries according to legal entity residence 

During 2017-2021, with regard to ‘irregularities not reported as fraudulent’, 74% of the total 
number of recovery items and 70% of the related recovery amounts concerned legal entities 
that are  resident  of the  EU-27140.  For ‘irregularities  reported  as fraudulent’, these ratios are 
higher: 76% of the total number of recovery items and 75% of the related recovery amounts 
concerned a legal entity residing in the EU-27.  

140 The residence of the legal entity and the residence of the beneficiary are not necessarily the same. 

159 

Policy area Payments 2021 Irregularities not reported as fraudulent Irregularities reported as fraudulent EUR million EUR million N EUR million N Agriculture and Maritime Policy 336 0.03 2 0.00 0 Environment and Climate Action 432 0.37 19 0.28 12 European Schools and Pensions 210 0.00 0 0.00 0 European Strategic Investments 3727 3.31 107 1.54 10 External Action 4122 3.04 103 0.72 2 Investing in People, Social Cohesion and Values 788 2.09 91 0.00 2 Migration 338 0.88 29 0.00 0 Pre-accession Assistance 678 1.62 55 0.01 3 Regional Development and Cohesion 1123 5.66 43 0.00 0 Research and innovation 7609 3.65 126 2.16 9 Security, Defence, Border Management 133 3.08 109 1.67 11 Single Market 563 11.54 113 0.47 4 Space 34 0.00 0 0.00 0 Other Policies 1458 0.57 28 0.18 1 Total without RRF 21711 35.85 825 7.04 54   
 
                                                           
DIRECT MANAGEMENT 

Table DM5 – Recoveries per country of residence of the legal entity, 2017-2021 

Table DM5 above summarises the total recoveries made during the past five years according 
to the country of residence of the legal entity to which the payment was unduly made. 

6.3.3.  Method of detection 

For  each  recovery  item,  the  Commission  service  issuing  the  recovery  order  has  to  indicate 
how  the  irregularity  has  been  detected.  Six  different  categories  are  pre-defined  for  this 
purpose, two of which fall under the direct responsibility of the European Commission: ‘Ex-
ante controls’ and ‘Ex-post controls’. Table DM6 provides a breakdown of the recoveries by 
source of detection and by qualification. 

Table DM6 – Irregularities reported by source of detection and by qualification, 2017-2021 

With reference to the ‘irregularities reported as fraudulent’, ‘OLAF’ has been  mentioned as 
the source of detection in relation to 86% of recovery items, corresponding to 91% of total 
recovery amounts. Meanwhile ‘Ex-post controls’ were the source of detection of another 10% 
of this type of recovery items, corresponding to another 7% of the recovery amounts. 

160 

LE Country name Irregularities not reported as fraudulent Irregularities reported as fraudulent EUR million N EUR million N Austria 7.32 168 0.00 0 Belgium 11.69 382 6.30 7 Bulgaria 1.00 35 0.00 0 Croatia 1.85 36 0.00 0 Cyprus 0.49 49 0.20 7 Czech Republic 5.64 42 0.99 12 Denmark 11.25 207 0.00 0 Estonia 1.04 22 0.58 6 Finland 3.90 88 0.92 4 France 15.30 620 4.46 48 Germany 27.86 591 6.92 11 Greece 4.86 146 0.25 4 Hungary 2.28 62 0.00 0 Ireland 2.73 109 0.09 1 Italy 19.57 509 6.93 36 Latvia 0.22 17 0.00 0 Lithuania 0.14 19 0.11 1 Luxembourg 0.42 21 0.00 0 Malta 0.67 45 0.00 0 Netherlands 20.51 602 2.01 9 Poland 1.85 96 0.03 2 Portugal 3.00 81 3.26 22 Romania 4.79 69 0.13 4 Slovakia 4.43 16 0.00 0 Slovenia 2.12 117 0.00 0 Spain 27.31 915 1.01 15 Sweden 6.74 175 0.00 0 Total EU 27 189.00 5239 34.18 189 United Kingdom 36.42 859 5.95 24 Total other countries 46.30 1004 5.17 35 Grand Total 271.72 7102 45.30 248  Source of detection  2017-2021 Irregularities not reported as fraudulent Irregularities reported as fraudulent EUR million N EUR million N Ex-ante controls  47.35 542 0.46 6 Ex-post controls  203.95 6320 3.32 26 Other controls (ECA) 8.62 60 0.09 1 Other controls (Member States) 3.03 15 0.12 2 Other controls (OLAF) 3.78 29 41.30 213 Other controls (To identify) and n.a. 5.00 136 0.00 0 TOTAL 271.72 7102 45.30 248   
 
 
 
DIRECT MANAGEMENT 

About 97% of ‘irregularities not reported as fraudulent’ were detected through Commission 
controls  (ex-ante  and  ex-post  controls).  The  share  of  ex-ante  controls  has  been  steadily 
declining from 30% (six years ago) to 8% (value of the indicator now).  

6.3.4.  Types of irregularity 

The  Commission  services  also  have  to  specify,  in  the  recovery  context,  the  type  of 
irregularity in relation to each recovery item. Several types can be attributed to one recovery 
item.  For  ‘irregularities  reported  as  fraudulent’,  ‘Amount  ineligible’  was  the  most  frequent 
type  during  the  past  five  years.  In  relation  to  ‘irregularities  not  reported  as  fraudulent’, 
‘Amount  ineligible’  remains  the  most  frequent  irregularity  type,  followed  by  ‘Under-
performance/non-performance’ and then by ‘Documents missing’.  

Table DM7 provides the full picture regarding the frequency of each type during the past five 
years. The figures are stable and have been following the same pattern for many years. 

Table DM7 – Types of irregularity, 2017-2021 

6.3.5.  Recovery 

Once a recovery order is issued, the beneficiary is requested to pay back the amount unduly 
received or the amount is offset from remaining payments for the same beneficiary. 

For  the  recovery  orders  issued  between  2017  and  2021,  55%  of  the total  irregular  amounts 
have  already  been  recovered.  The  recovery  rate  for  ‘irregularities  reported  as  fraudulent’ 
(30%)  remains  well  below  the  one  calculated  for  ‘irregularities  not  reported  as  fraudulent’ 
(59%) 

161 

Type of irregularity 2017-2021 Irregularities not reported as fraudulent (frequency %) Irregularities reported as fraudulent (frequency %) Amount Number Amount Number Amount ineligible 77.1 84.2 67.7 73.2 Beneficiary 1.4 1.5 15.5 6.2 Calculation Error 2.6 3.0 0.0 0.0 Documents missing 2.9 3.2 5.2 2.7 Double funding 0.3 0.8 0.4 4.1 Profit 0.4 0.4 0.5 4.1 Public procurement rules not respected 0.1 0.4 4.2 3.2 Under-performance / non-performance 14.1 6.2 1.1 4.0 Ethics and Integrity 1.1 0.2 5.4 2.5 (blank) 0.0 0.1 0.0 0.0 TOTAL 100 100 100 100   
 
COUNTRY FACTSHEETS 

COUNTRY FACTSHEETS 

Belgium - Belgique/België 

162 

OWNRES / gross TORNEURNEUR%Established and estimated16175,935,74728111,311,3663.80%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)007233,1080.000.04Rural Development (RD)0019462,9530.000.56TOTAL0026696,0610.000.11FDRIDRNEURNEUR%%Support to agriculture (SA)0037908,4900.000.03Rural Development (RD)00581,465,1550.000.41SA/RD00238,845TOTAL00972,412,4900.000.08Irregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentFundIrregularities reported as fraudulentIrregularities reported in 20212. Natural ResourcesIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative6437,72539225,371,9230.021.22ERDF31,93613711,895,9930.001.21ESF3435,78925513,475,9300.041.26Programming Period 2014-20 - reporting year 2021137,5589366,986ERDF137,5585322,404ESF00444,583Programming Period 2014-20 - cumulative6133,018543,356,5490.010.27ERDF239,111361,810,2330.010.33ESF493,907181,546,3160.010.243. Cohesion and Fisheries PolicyIrregularities not reported as fraudulentIrregularities reported as fraudulentRatioRatioRatio%%%0011378800002100Natural resourcesCohesion and Fisheries PolicyFor the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudPendingN.N.N. 
 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Bulgaria – България 

163 

OWNRES / gross TORNEURNEUR%Established and estimated272,754,1852141,5971.36%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)117,30315292,2460.000.03Rural Development (RD)132,92818114,801,1130.014.17TOTAL250,23119615,093,3590.001.23FDRIDRNEURNEUR%%Support to agriculture (SA)1316,355,724323,486,5570.400.09Rural Development (RD)181,386,61390658,374,4630.104.27TOTAL3117,742,33793861,861,0200.321.13Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDR1NEURNEUR%%Programming Period 2007-13 - reporting year 2021001214,058,885CF0038,057,019ERDF0055,897,729EFF004104,137Programming Period 2007-13 - cumulative221,164,156694159,294,5360.022.46CF0017288,683,3410.004.01ERDF6260,23037359,232,1140.011.97ESF12546,0111039,355,6230.050.79EFF4357,915462,023,4590.603.39Programming Period 2014-20 - reporting year 20219309,4999014,230,989CF00103,535,154ERDF00588,184,453ESF9309,499141,093,657EMFF0081,417,725Programming Period 2014-20 - cumulative12544,09824859,777,9840.011.28CF002024,463,6080.002.40ERDF0017830,388,6800.001.25ESF12544,098392,914,0720.050.24EMFF00112,011,6240.005.723. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%24106127145631139141657For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Czech Republic - Česká republika 

164 

OWNRES / gross TORNEURNEUR%Established and estimated116,336643,034,7250.77%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)009263,5550.000.03Rural Development (RD)111,58851791,0730.000.22TOTAL111,588601,054,6280.000.09FDRIDRNEURNEUR%%Support to agriculture (SA)23,953,69637719,9500.090.02Rural Development (RD)221,810,1872015,198,2160.100.30TOTAL245,763,8832385,918,1660.090.10Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 2021145,630,646303,312,370CF52,510,6694257,056ERDF83,094,635242,799,918ESF125,3422255,396Programming Period 2007-13 - cumulative208256,387,0323,7911,243,012,1491.014.88CF3119,727,889371125,716,8520.231.45ERDF133234,190,4882,0621,017,337,6211.787.71ESF392,069,9261,32998,428,5190.062.74EFF5398,730291,529,1561.656.32Programming Period 2014-20 - reporting year 20216887,16125825,414,385CF00143,609,173ERDF2673,43020620,152,867ESF4213,732381,652,344Programming Period 2014-20 - cumulative376,002,29352680,477,5070.040.51CF1515,6799246,185,7340.010.98ERDF205,047,31330829,316,4820.060.35ESF16439,3021134,182,0950.020.16EMFF0013793,1950.004.103. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%14882130031607131427For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Denmark – Danmark 

165 

OWNRES / gross TORNEURNEUR%Established and estimated6351,143953,997,1690.90%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)00570,8160.000.01Rural Development (RD)273,181,542129,9632.730.03TOTAL273,181,5426100,7790.340.01FDRIDRNEURNEUR%%Support to agriculture (SA)3103,33623616,1300.000.01Rural Development (RD)406,277,05019466,8621.250.09TOTAL436,380,386421,082,9920.140.02FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-20212. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative2234,251512,554,8660.040.40ERDF2234,25119773,0080.090.30ESF0015523,1010.000.21EFF00171,258,7570.001.03Programming Period 2014-20 - reporting year 2021002136,080ERDF002136,080Programming Period 2014-20 - cumulative12870,18912787,1940.200.18ERDF2165,3166314,7060.110.20ESF003347,5190.000.22EMFF10704,8733124,9690.550.103. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%13115410085For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Germany – Deutschland 

166 

OWNRES / gross TORNEURNEUR%Established and estimated524,110,0391,25672,954,8901.51%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)2564,38323389,5060.010.01Rural Development (RD)16,99042818,6170.000.06TOTAL3571,373651,208,1230.010.02FDRIDRNEURNEUR%%Support to agriculture (SA)101,045,6601433,388,7510.000.01Rural Development (RD)191,653,7041939,788,0280.030.16SA/RD3660,28619632,973TOTAL323,359,65035513,809,7520.010.05FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-20212. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 2021009981,496ERDF009981,496Programming Period 2007-13 - cumulative20430,032,0921,401132,729,8070.120.53ERDF3712,606,797941102,545,3870.080.65ESF16617,411,17445329,376,4910.190.32EFF114,1207807,9290.010.74Programming Period 2014-20 - reporting year 20217873,036856,237,503ERDF4198,181665,263,233ESF3674,85518947,179EMFF00127,091Programming Period 2014-20 - cumulative303,769,98223622,528,6750.030.18ERDF161,571,28515818,210,5860.020.27ESF142,198,698754,205,5320.040.08EMFF003112,5570.000.083. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%10424171042161550454440For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Estonia – Eesti 

167 

OWNRES / gross TORNEURNEUR%Established and estimated81,033,810119,7141.85%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Rural Development (RD)173,933,49613254,4723.720.24TOTAL173,933,49613254,4721.440.09FDRIDRNEURNEUR%%Rural Development (RD)418,446,2891616,734,6361.511.20TOTAL418,446,2891616,734,6360.670.54Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative2310,754,92432931,285,6330.310.90CF52,691,616182,677,6790.230.23ERDF147,634,70425026,379,3650.411.42ESF3252,912451,279,9800.060.33EFF1175,69116948,6080.221.19Programming Period 2014-20 - reporting year 202172,825,416787,291,381CF007655,755ERDF62,485,424656,281,680ESF006353,945EMFF1339,99200Programming Period 2014-20 - cumulative204,054,74623225,502,0340.140.90CF00459,238,1180.001.01ERDF173,639,78416113,758,0530.260.97ESF274,970222,445,6250.020.56EMFF1339,992460,2370.490.093. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%157331362117233350For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Ireland – Éire 

168 

OWNRES / gross TORNEURNEUR%Established and estimated1100,366261,346,6240.28%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Rural Development (RD)12,75021904,7960.000.06Blank112,492236,022TOTAL215,24223940,8180.000.01Irregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative215,67227016,257,0850.002.05ERDF00954,107,2300.001.09ESF215,67216512,013,3950.003.20EFF0010136,4600.000.32Programming Period 2014-20 - reporting year 202100120,082ESF00120,082Programming Period 2014-20 - cumulative00361,893,8550.000.20ERDF0015394,5430.000.09ESF00211,499,3120.000.363. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%0000410000002100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Greece – Ελλάδα 

169 

OWNRES / gross TORNEURNEUR%Established and estimated99,995,058222,507,8624.38%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)12,543,0173505,956,6440.120.29Rural Development (RD)002052,911,9000.000.46TOTAL12,543,0175558,868,5440.090.33FDRIDRNEURNEUR%%Support to agriculture (SA)22,553,4575078,952,6970.020.09Rural Development (RD)226,6286719,941,8700.000.35TOTAL42,580,0851,17818,894,5670.020.14FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-20212. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 20211229,73600ERDF1229735.5900Programming Period 2007-13 - cumulative6622,863,4362,084830,214,1750.114.07CF00179158,819,8070.004.30ERDF5522,552,2981,516601,610,8050.194.95ESF11311,13836965,205,7260.011.49EFF00204,577,8370.002.79Programming Period 2014-20 - reporting year 20211262,82731141,862,261CF0055,376,223ERDF1262,827115,925,015ESF0014130,361,167EMFF001199,856Programming Period 2014-20 - cumulative56,550,881111173,255,6810.051.23CF36,117,7031312,323,6990.390.78ERDF2433,1794320,774,6710.000.23ESF0054139,957,4550.004.23EMFF001199,8560.000.123. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%730141565003141886For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Spain – España 

170 

OWNRES / gross TORNEURNEUR%Established and estimated2518,044,07142243,732,5953.03%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)4856,6371656,541,2600.020.12Rural Development (RD)0028110,972,6290.000.95TOTAL4856,63744617,513,8890.010.26FDRIDRNEURNEUR%%Support to agriculture (SA)173,332,72781132,883,3900.010.12Rural Development (RD)1120,00087931,362,6370.000.61SA/RD00111,111TOTAL183,452,7271,69164,257,1380.010.19Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative14421,846,0439,7811,668,646,1460.064.74CF295,63934295,396,8780.002.70ERDF13819,681,4538,6631,495,057,2970.096.53ESF3333,84458356,457,5570.000.71EFF11,735,10719321,734,4140.202.46Programming Period 2014-20 - reporting year 2021003313,243,669ERDF00165,007,024ESF00158,178,969EMFF00257,676Programming Period 2014-20 - cumulative146,45523942,631,5650.000.22ERDF0013528,711,5890.000.21ESF146,45510013,509,0410.000.25EMFF004410,9350.000.093. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%13650073537500125For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

France 

171 

OWNRES / gross TORNEURNEUR%Established and estimated716,540,50623617,698,3761.03%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)113,348613,047,7380.000.04Rural Development (RD)553,8861062,093,6590.000.11TOTAL667,2341675,141,3970.000.06FDRIDRNEURNEUR%%Support to agriculture (SA)221,666,42732821,619,1740.000.06Rural Development (RD)11835,07651710,072,2720.010.11TOTAL332,501,50384531,691,4460.010.07FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-20212. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative62,886,40941761,984,9790.020.45ERDF1197,68125942,888,9350.000.53ESF42,688,72814918,104,4100.050.33EFF109991,6340.000.56Programming Period 2014-20 - reporting year 20212454,866837,816,222ERDF1398,616626,636,282ESF0016695,762EMFF156,2505484,178Programming Period 2014-20 - cumulative1510,015,90730835,816,0490.100.37ERDF129,761,45819925,955,2940.180.48ESF2198,199938,265,0060.010.21EMFF156,250161,595,7490.020.503. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%105000105000001100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Croatia – Hrvatska 

172 

OWNRES / gross TORNEURNEUR%Established and estimated228,4426913,5461.68%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)0071,497,7380.000.42Rural Development (RD)00441,328,2880.000.35TOTAL00512,826,0260.000.38FDRIDRNEURNEUR%%Support to agriculture (SA)3157,998672,929,0480.010.20Rural Development (RD)2229,4171374,295,0900.020.31TOTAL5387,4152047,224,1380.010.25Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative42,184,460509,554,2450.281.23CF00182,368,1210.000.85ERDF22,138,592277,076,2630.632.07ESF245,868488,2620.030.06EFF00121,5990.000.28Programming Period 2014-20 - reporting year 202100156,504,326CF0014,277,746ERDF003360,107ESF001241,275EMFF00101,625,198Programming Period 2014-20 - cumulative41,570,54110925,238,5920.040.57CF00227,739,5830.000.93ERDF41,570,5415613,530,8230.050.47ESF00101,864,6960.000.33EMFF00212,103,4910.001.763. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Italy – Italia 

173 

OWNRES / gross TORNEURNEUR%Established and estimated1511,429,409684,905,7750.66%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)7781,9811656,933,2940.020.16Rural Development (RD)62,759,1551138,767,6060.190.60SA/RD5408,387151,320,924TOTAL183,949,52329317,021,8240.070.30FDRIDRNEURNEUR%%Support to agriculture (SA)967,655,8641,38666,343,5570.040.31Rural Development (RD)319,247,68954160,908,5480.150.97SA/RD363,812,30716319,972,181TOTAL16320,715,8602,090147,224,2860.070.53FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-20212. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 2021221,9285824,968ERDF004802,116EFF221,928122,852Programming Period 2007-13 - cumulative77115,592,1911,841360,336,3670.431.34ERDF43104,764,6171,562336,000,6890.531.69ESF81,914,63726122,844,9830.030.34EFF268,912,937181,490,6962.770.46Programming Period 2014-20 - reporting year 2021008016,911,054ERDF006014,707,986ESF00192,203,068EMFF0010Programming Period 2014-20 - cumulative0029152,990,9790.000.24ERDF0022244,401,6470.000.31ESF00688,589,3330.000.11EMFF00100.000.003. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%40458941463247113551For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Cyprus – Κύπρος 

174 

OWNRES / gross TORNEURNEUR%Established and estimated113,590000.03%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative111,156,899554,436,5740.180.70CF0091,583,6830.000.74ERDF5871,328281,390,1560.310.50ESF482,121131,312,2280.071.10EFF2203,4505150,5081.030.76Programming Period 2014-20 - reporting year 202100230,838ERDF001503ESF00130,335Programming Period 2014-20 - cumulative1126,26012765,0390.020.13CF003342,1560.000.19ERDF1126,260483,5910.050.03ESF005339,2920.000.223. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%0000110000117583For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Latvia – Latvija 

175 

OWNRES / gross TORNEURNEUR%Established and estimated91,043,536352,815,1174.88%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)00386,9610.000.03Rural Development (RD)4182,29020742,3060.150.60TOTAL4182,29023829,2670.040.20FDRIDRNEURNEUR%%Support to agriculture (SA)007155,9990.000.01Rural Development (RD)13611,231692,119,4970.070.25TOTAL13611,231762,275,4960.030.11Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-2021Period / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 20210021,490,097CF0011,471,720ERDF00118,377Programming Period 2007-13 - cumulative5932,979,731503113,557,8780.712.44CF15047124,356,8000.001.58ERDF4932,667,41138278,043,4711.363.24ESF8127,497335,868,0070.021.01EFF1184,318175,289,6000.154.24Programming Period 2014-20 - reporting year 202184,142,3083513,676,805CF003167,058ERDF74,083,5192913,385,566ESF003124,182EMFF158,78900Programming Period 2014-20 - cumulative3215,650,7048516,781,7700.530.56CF11,041,151111,205,2570.140.16ERDF2213,683,1386115,179,6410.790.88ESF5311,3728297,8870.070.07EMFF4615,043598,9860.800.133. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%2224443336188242059For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Lithuania – Lietuva 

176 

OWNRES / gross TORNEURNEUR%Established and estimated463,837,216221,345,5903.16%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)0013225,5580.000.04Rural Development (RD)499,100671,371,5760.050.73Blank00336,264TOTAL499,100831,633,3980.010.23FDRIDRNEURNEUR%%Support to agriculture (SA)142,2991533,409,6980.000.14Rural Development (RD)151,981,70338914,418,5590.191.40Bank00336,264TOTAL162,024,00254517,864,5210.060.52Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 202113,832,76700ERDF13,832,76700Programming Period 2007-13 - cumulative155,582,189540103,245,5540.081.51CF5773,52418466,605,0960.032.89ERDF54,248,55730133,471,0430.120.97ESF5560,108281,263,3000.050.12EFF00271,906,1150.003.59Programming Period 2014-20 - reporting year 2021134,563422,875,660CF0011335,525ERDF00262,308,835ESF005231,300EMFF134,56300Programming Period 2014-20 - cumulative7465,41228526,103,1550.010.50CF00595,235,4720.000.31ERDF0021120,283,1480.000.78ESF6430,84915584,5350.050.06EMFF134,563000.110.003. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%0000110000009100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Luxembourg 

177 

OWNRES / gross TORNEURNEUR%Established and estimated00143,1710.20%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Rural Development (RD)00139,2660.000.06SA/RD115,85700TOTAL115,857139,2660.010.02Irregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative008210,7880.000.42ESF008210,7880.000.84Programming Period 2014-20 - reporting year 202100114,259ERDF00114,259Programming Period 2014-20 - cumulative00114,2590.000.01ERDF00114,2590.000.063. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%00001100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Hungary - Magyarország 

178 

OWNRES / gross TORNEURNEUR%Established and estimated1135,545272,744,2571.08%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)0091,467,6240.000.11Rural Development (RD)15349,3192267,216,5450.061.25TOTAL15349,3192358,684,1690.020.46FDRIDRNEURNEUR%%Support to agriculture (SA)3264,6001139,389,0260.000.14Rural Development (RD)251,794,34159621,080,3440.080.94TOTAL282,058,94170930,469,3700.020.35Irregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 202141,169,6093379,500,279CF00468,468,141ERDF2190,7622911,032,138EFF2978,84700Programming Period 2007-13 - cumulative12112,187,4182,030383,922,0470.051.55CF2126,056131110,836,2430.001.30ERDF1049,944,5971,618236,680,4110.081.88ESF131,137,91827035,817,3020.031.00EFF2978,84711588,0902.921.76Programming Period 2014-20 - reporting year 2021203,484,32218323,058,322CF0071,000,540ERDF162,513,96411819,121,378ESF4970,357542,668,451EMFF004267,954Programming Period 2014-20 - cumulative14134,794,02744677,744,1890.210.47CF002310,749,0630.000.23ERDF13633,730,02030845,961,3330.400.55ESF51,064,00811020,750,1420.030.61EMFF005283,6510.001.40Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries PolicyRatioRatioRatio%%%577868101400006100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Malta 

179 

OWNRES / gross TORNEURNEUR%Established and estimated002328,5250.34%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Rural Development (RD)004687,2780.004.59TOTAL004687,2780.003.42FDRIDRNEURNEUR%%Support to agriculture (SA)003372,4540.001.37Rural Development (RD)00171,458,8650.002.28TOTAL00201,831,3190.002.01Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-2021Period / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative16305,5108015,802,0470.041.86CF001211,016,8960.003.88ERDF16305,510484,216,2670.070.95ESF0020568,8840.000.51Programming Period 2014-20 - reporting year 2021003590,454CF002520,976ESF00169,478Programming Period 2014-20 - cumulative00121,208,4320.000.26CF002520,9760.000.41ERDF005144,0590.000.07ESF003500,2350.000.48EMFF00243,1620.000.313. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%00005100000014100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Netherlands - Nederland 

180 

OWNRES / gross TORNEURNEUR%Established and estimated514,406,943490156,872,9774.34%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)728,819981,9170.000.01Rural Development (RD)003250,1240.000.15TOTAL728,81912332,0410.000.04FDRIDRNEURNEUR%%Support to agriculture (SA)251,030,946661,823,3050.030.05Rural Development (RD)6229,604451,491,8510.040.29TOTAL311,260,5501113,315,1560.030.08Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-2021Period / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative154,324,98442936,913,6110.262.19ERDF2209,94324220,301,4580.032.45ESF134,115,0415610,534,1630.501.28EFF001316,077,9900.0018.98Programming Period 2014-20 - reporting year 20212151,0257128,242ERDF007128,242ESF2151,02500Programming Period 2014-20 - cumulative4160,02522765,2510.020.09ERDF0020569,2420.000.16ESF3151,0251177,3900.040.04EMFF19,000118,6190.020.033. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%00001100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Austria – Österreich 

181 

OWNRES / gross TORNEURNEUR%Established and estimated44,203,383562,183,1102.22%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)51,183,097000.170.00Rural Development (RD)00161,3950.000.01TOTAL51,183,097161,3950.090.00FDRIDRNEURNEUR%%Support to agriculture (SA)71,443,201191,013,0690.040.03Rural Development (RD)164,390231,059,7970.000.04TOTAL81,507,591422,072,8660.020.03Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-2021Period / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 202100123,431ERDF00123,431Programming Period 2007-13 - cumulative81,542,06031825,124,7420.132.19ERDF71,531,14926021,842,8890.243.48ESF110,911573,264,2080.000.63EFF00117,6450.000.34Programming Period 2014-20 - reporting year 20210012470,415ERDF009401,068ESF00369,347Programming Period 2014-20 - cumulative588,632503,869,9120.010.57ERDF00393,624,2230.000.99ESF588,63210163,7450.030.05EMFF00181,9430.001.463. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%0011468600117583For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Poland – Polska 

182 

OWNRES / gross TORNEURNEUR%Established and estimated211,194,1049610,969,9580.81%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)145,076,2266873,357,8270.152.19Rural Development (RD)5196,1972928,901,2210.010.63TOTAL195,272,42336082,259,0480.111.72FDRIDRNEURNEUR%%Support to agriculture (SA)7662,646,783225164,251,7260.370.96Rural Development (RD)594,059,88388527,855,5470.080.53SA/RD145,60300TOTAL13666,752,2691,110192,107,2730.300.862. Natural ResourcesIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 202142,451,722318,537,696ERDF42,451,722288,418,639EFF003119,057Programming Period 2007-13 - cumulative315426,032,6875,6171,367,346,4390.632.01CF8169,309,554202261,659,0320.761.17ERDF245243,042,1464,8171,054,401,9410.703.03ESF548,065,15749544,009,9680.080.44EFF85,615,8291037,275,4980.791.02Programming Period 2014-20 - reporting year 2021132,156,79962789,939,727CF4114,232214,293,410ERDF41,191,83241266,640,914ESF5850,73519118,847,226EMFF003158,177Programming Period 2014-20 - cumulative9946,585,8991,898291,200,6650.080.49CF53,585,6239718,205,9430.020.10ERDF4732,679,4991,196224,138,4780.100.71ESF459,904,82159948,370,8260.110.54EMFF2415,9566485,4180.140.173. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%322225178760383016137357For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Portugal 

183 

OWNRES / gross TORNEURNEUR%Established and estimated3698,43191,132,8250.80%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)00251,794,2490.000.21Rural Development (RD)003848,946,6110.002.23Blank00237,466TOTAL0041110,778,3260.000.86FDRIDRNEURNEUR%%Support to agriculture (SA)8534,6681816,761,6410.010.17Rural Development (RD)211,166,7811,46970,942,8200.052.80Blank00367,539TOTAL291,701,449165377,772,0000.031.20FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-2021Period / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 202151,505,74700ESF5.01,505,747.00.00.0Programming Period 2007-13 - cumulative67168,214,6041,255185,423,3610.780.86CF191,452757,249,5850.000.24ERDF23104,876,946693145,628,5630.911.27ESF2962,311,34336116,364,9480.910.24EFF14934,86412616,180,2640.437.47Programming Period 2014-20 - reporting year 20211333,777,617666,188,477CF005906,864ERDF1032,993,557141,402,567ESF3784,060282,436,788EMFF00191,442,258Programming Period 2014-20 - cumulative3039,301,55219221,511,0880.230.12CF00112,024,4090.000.11ERDF1135,925,6758511,139,6790.360.11ESF173,246,429624,687,7890.060.09EMFF2129,448343,659,2120.051.473. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%0000110019001091For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Romania – România 

184 

OWNRES / gross TORNEURNEUR%Established and estimated10608,828352,223,1770.98%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)551,943,508715,055,6150.100.26Rural Development (RD)575,668,62130820,523,7870.471.69TOTAL1127,612,12937925,579,4020.240.81FDRIDRNEURNEUR%%Support to agriculture (SA)31212,216,28847655,347,9830.130.59Rural Development (RD)23445,636,1581,38494,521,2480.751.55SA/RD1696,04300TOTAL54758,548,4891860149,869,2310.380.97Irregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 2021129,915,203208,972,611CF001163,683ERDF104,010,61484,397,252ESF25,904,590103,876,632EFF001535,044Programming Period 2007-13 - cumulative255161,626,5132,449572,213,5150.943.33CF214,919,464356188,092,6450.263.22ERDF166126,406,4601,176284,441,4071.553.49ESF8318,799,40082377,431,6200.632.58EFF41,501,1899422,247,8440.8913.14Programming Period 2014-20 - reporting year 2021491,390,408,271181104,093,098CF2104,736,9111817,807,375ERDF451,285,570,5597182,427,767ESF2100,802883,538,950EMFF004319,006Programming Period 2014-20 - cumulative1401,519,306,018480165,983,30811.891.30CF18213,354,3703821,725,5815.500.56ERDF1191,305,796,027247131,751,99721.512.17ESF3155,62118512,024,3930.010.44EMFF0010481,3370.000.56Irregularities reported as fraudulentIrregularities not reported as 3. Cohesion and Fisheries PolicyRatioRatioRatio%%%3219131228512245295For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Slovenia – Slovenija 

185 

OWNRES / gross TORNEURNEUR%Established and estimated1565,8219274,6650.50%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)00344,7860.000.03Rural Development (RD)113,35010200,2320.010.17TOTAL113,35013245,0180.010.09FDRIDRNEURNEUR%%Support to agriculture (SA)294,40610206,7110.010.03Rural Development (RD)3145,337561,492,2740.030.27TOTAL5239,743661,698,9850.020.13Irregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative2325,507,43826354,745,6980.621.33CF002211,240,7020.000.80ERDF1425,243,62718239,342,5531.312.03ESF9263,811573,750,4570.030.50EFF002411,9860.002.06Programming Period 2014-20 - reporting year 202100131,278,174ERDF0010987,863ESF003290,311Programming Period 2014-20 - cumulative5818,085292,480,9970.040.11CF003622,0540.000.10ERDF1118,130161,380,2920.010.12ESF4699,95510478,6510.140.09Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries PolicyRatioRatioRatio%%%0043196975418538For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Slovakia – Slovensko 

186 

OWNRES / gross TORNEURNEUR%Established and estimated337,1314833,1880.18%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)117,728146,7990.000.01Rural Development (RD)00151,821,5930.001.31SA/RD382,91218413,449TOTAL4100,640342,281,8410.020.43FDRIDRNEURNEUR%%Support to agriculture (SA)577,74611294,6520.000.01Rural Development (RD)9971,0871189,823,5920.111.08SA/RD71,133,942372,564,221TOTAL212,182,77516612,682,4650.070.41Irregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2017-2021Period / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - reporting year 20211411,675,4754242,731,373CF18,879,5931213,995,123ERDF42,118,3122828,679,113ESF7380,767129,113EFF2296,802128,024Programming Period 2007-13 - cumulative166104,012,4811,472996,277,7390.959.06CF1540,275,184141373,922,1711.069.88ERDF9257,814,852907543,100,6021.009.37ESF555,522,61941378,367,2580.395.56EFF4399,82711887,7073.888.60Programming Period 2014-20 - reporting year 202119147,810,946128168,455,580CF2118,273,6811680,135,707ERDF1424,671,5818150,109,361ESF34,865,6843038,199,740EMFF00110,773Programming Period 2014-20 - cumulative76755,313,720415531,821,0759.646.79CF28131,758,70687342,500,8215.0513.14ERDF28617,928,231254124,373,29918.903.80ESF205,626,7837164,785,5660.293.31EMFF003161,3900.009.443. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%00150150116953100For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Finland – Suomi-Finland 

187 

OWNRES / gross TORNEURNEUR%Established and estimated004712,180,8225.83%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)00111,5380.000.00Rural Development (RD)008349,4350.000.08SA/RD00111,938TOTAL0010372,9110.000.04FDRIDRNEURNEUR%%Support to agriculture (SA)0022485,8730.000.02Rural Development (RD)141,297461,276,1190.000.07SA/RD00111,938TOTAL141,297691,773,9300.000.04Irregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative366,629814,113,0810.000.25ERDF239,843522,369,5040.000.24ESF00201,187,1240.000.19EFF126,7869556,4530.071.47Programming Period 2014-20 - reporting year 2021007143,786ERDF00354,578ESF00363,858EMFF00125,350Programming Period 2014-20 - cumulative1425,525341,185,6570.040.11ERDF1425,52519757,8580.070.12ESF0010183,1990.000.04EMFF005244,6010.000.40Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries PolicyRatioRatioRatio%%%31000000For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
 
 
COUNTRY FACTSHEETS 

Sweden – Sverige 

188 

OWNRES / gross TORNEURNEUR%Established and estimated0019410,241,2751.47%1. Traditional Own ResourcesReporting Year 2021Irregularities reported as fraudulentIrregularities not reported as fraudulentFDRIDRNEURNEUR%%Support to agriculture (SA)00576,4550.000.01Rural Development (RD)006397,7990.000.12SA/RD00122,203TOTAL0012496,4570.000.05FDRIDRNEURNEUR%%Support to agriculture (SA)0062,083,0450.000.06Rural Development (RD)112,947191,136,8250.000.10SA/RD00122,203TOTAL112,947263,242,0730.000.07Irregularities not reported as fraudulentIrregularities reported 2017-2021FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2021FundIrregularities reported as fraudulentPeriod / FundFDRIDRNEURNEUR%%Programming Period 2007-13 - cumulative466,7971478,105,8950.000.49ERDF229,027855,086,5510.000.56ESF237,770482,562,3900.010.37EFF0014456,9540.000.95Programming Period 2014-20 - reporting year 2021009306,071ERDF006236,629ESF00369,442Programming Period 2014-20 - cumulative42,588,916483,093,3420.220.26ERDF121,65918806,3090.000.12ESF1303,550291,289,5320.070.29EMFF22,263,7071997,5013.581.583. Cohesion and Fisheries PolicyIrregularities reported as fraudulentIrregularities not reported as fraudulentRatioRatioRatio%%%0000610026700133For the explanation of the indicators used in this table see the Statistical Evaluation in annex to the 2021 PIF4. Follow-up to suspected fraud - Irregularities reported from 2007 to 2013 (programming period 2007-2013)DismissalEstablished fraudN.Natural resourcesPendingN.N.Cohesion and Fisheries Policy 
 
 
 
 
 
 
ANNEXES 

189 

 
 
 
Annex 1 

190 

NEURNEURNEURNEURNEURBE223          23 726 124       261          22 283 583            385          47 469 948             394                   58 981 792       442                         87 247 113       BG20            1 256 344          16            3 464 979              2              653 686                  7                        4 033 595          29                           2 895 782          CZ89            8 694 889          94            4 867 003              51            4 429 408               60                      5 040 428          65                           3 051 061          DK58            2 420 367          54            7 321 780              66            3 395 257               68                      5 417 046          101                         4 348 312          DE2 002      106 540 344     1 744      126 395 355         1 794      139 989 508           1 695                167 522 042     1 308                      77 064 929       EE5              322 079             9              642 408                 7              605 861                  8                        1 120 169          9                             1 053 524          IE35            3 189 457          36            3 514 983              22            1 459 809               20                      2 917 657          27                           1 446 990          EL48            15 154 453       42            7 953 756              61            4 453 577               86                      7 808 656          31                           12 502 920       ES265          49 717 527       335          36 398 063            319          26 305 200             376                   49 986 510       447                         61 776 666       FR299          23 916 706       297          95 748 314            308          26 511 502             247                   42 426 057       307                         24 238 882       HR15            1 076 494          16            1 084 592              8              514 819                  23                      1 693 806          8                             941 988             IT145          19 031 678       104          10 377 350            163          14 591 931             98                      8 241 619          83                           16 335 184       CY5              128 966             4              70 088                   1              10 463                     1                             13 590               LV12            555 952             20            1 396 206              25            1 018 410               28                      1 494 637          44                           3 858 653          LT57            2 238 382          45            4 907 983              27            3 426 512               66                      5 145 936          68                           5 182 806          LU5              162 959             1              111 376                  1                        15 690               1                             43 171               HU26            1 467 961          11            1 072 471              56            3 221 298               71                      11 758 061       28                           2 879 802          MT2              366 319             1                        27 024               2                             328 525             NL450          75 544 010       503          129 423 739         408          75 820 261             432                   31 081 109       495                         171 279 920     AT56            7 337 055          48            2 199 340              47            4 943 359               47                      1 958 839          60                           6 386 492          PL99            2 998 406          156          6 857 085              144          10 146 884             124                   11 203 879       117                         12 164 061       PT38            5 457 304          37            9 398 614              33            1 913 721               14                      469 667             12                           1 831 256          RO32            1 666 170          25            1 143 202              57            3 573 862               45                      3 044 141          45                           2 832 005          SI13            425 419             15            1 019 068              10            428 418                  23                      5 642 854          10                           840 486             SK11            756 807             11            544 606                 7              423 202                  9                        165 408             7                             870 319             FI31            1 894 518          32            2 945 510              56            7 308 607               43                      3 756 471          47                           12 180 822       SE169          10 696 185       155          7 585 436              176          11 126 890             169                   11 580 849       194                         10 241 275       EU-274 210366 742 8754 070488 615 5144 234393 853 7684 155442 533 9423 988523 836 534UK81292 462 810       822132 149 553         906101 554 880           70394 587 939       37540 507 793       Total5 022459 205 6854 892620 765 0675 140495 408 6474 858537 121 8814 363564 344 327* Cut-off date 15/03/2022TOR: Total number of fraudulent and non-fraudulent cases with the related estimated and established amount2017 - 2021                                                                      MS20172018201920202021 
  
 
 
Annex 2 

191 

NEURNEURNEURNEURNEURBE2813 990 0004116 062 28711933 742 158       10847 286 81416175 935 747BG191 190 756153 405 7592653 686             74 033 595272 754 185CZ116 336DK188 0162167 7182146 535             4179 6276351 143DE606 471 43511520 558 4538432 093 868       1019 880 892524 110 039EE4310 9304568 1025505 284             61 032 34681 033 810IE133 992101 497 1546333 031             5360 3281100 366EL3714 834 859326 662 449142 346 258          293 670 49099 995 058ES353 252 144486 059 817302 561 607          3714 234 3712518 044 071FR989 202 7466280 351 669536 431 521          4426 168 230716 540 506HR8818 154121 011 2802388 465             131 213 666228 442IT232 243 030385 763 881312 387 954          172 507 3291511 429 409CY4118 402112 878113 590LV8359 10991 103 97215735 101             12773 63591 043 536LT381 275 220201 683 684172 458 400          414 275 529463 837 216LUHU4281 3181668 039124 550               6170 9381135 545MT2366 319NL103 358 199182 365 80172 500 608          91 333 377514 406 943AT75 625 4704147 35661 049 233          3120 16544 203 383PL521 729 020412 083 734272 532 711          332 203 630211 194 104PT7908 21441 643 05461 065 765          3120 5023698 431RO9286 427348 2565310 176             9234 52010608 828SI489 4008405 956264 994               71 358 8071565 821SK5115 016115 500               340 680337 131FI468 2545267 5714226 260             3153 380SE44 311 884133 834176 845               2105 540EU-2746771 213 299499152 687 72144092 650 510502121 458 391482157 083 641UK9492 867             28            979 857             29            992 995             7              16 327 115          2                       4 634 349          Total47671 706 166527153 667 57846993 643 505509137 785 506484161 717 990* Cut-off date 15/03/2022TOR: Total number of fraudulent cases with the related estimated and established amount2017 - 2021                                                                      2021MS2017201820192020 
 
 
 
Annex 3 

192 

NEURNEURNEURNEURNEURBE1959 736 1242206 221 29626613 727 79028611 694 97828111 311 366BG165 587159 2202141 597CZ898 694 889944 867 003514 429 408605 040 428643 034 725DK572 332 351527 154 062643 248 722645 237 419953 997 169DE1 942100 068 9091 629105 836 9021 710107 895 6401 594157 641 1491 25672 954 890EE111 149574 3062100 577287 823119 714IE343 155 465262 017 829161 126 778152 557 329261 346 624EL11319 594101 291 307472 107 319574 138 166222 507 862ES23046 465 38328730 338 24628923 743 59333935 752 13942243 732 595FR20114 713 96023515 396 64525520 079 98120316 257 82723617 698 376HR7258 340473 3126126 35410480 1406913 546IT12216 788 648664 613 46913212 203 977815 734 290684 905 775CY110 564357 210110 463LV4196 84311292 23510283 30916721 002352 815 117LT19963 162253 224 29910968 11225870 407221 345 590LU5162 9591111 376115 690143 171HU221 186 64310404 431553 196 7486511 587 123272 744 257MT127 0242328 525NL44072 185 811485127 057 93840173 319 65342329 747 732490156 872 977AT491 711 585442 051 983413 894 126441 838 674562 183 110PL471 269 3861154 773 3521177 614 173919 000 2499610 969 958PT314 549 090337 755 56027847 95611349 16591 132 825RO231 379 743221 094 946523 263 686362 809 620352 223 177SI9336 0197613 1128363 424164 284 0479274 665SK11756 8076429 5906407 7026124 7294833 188FI271 826 264272 677 938527 082 348403 603 0914712 180 822SE1656 384 3011547 551 60217511 050 04516711 475 30919410 241 275EU-273 743295 529 5763 571335 927 7923 794301 203 2583 653321 075 5513 506366 752 893UK80391 969 943       794131 169 697     877100 561 885     69678 260 824       37335 873 444           Total4 546387 499 5194 365467 097 4894 671401 765 1424 349399 336 3753 879402 626 337* Cut-off date 15/03/2022TOR: Total number of non-fraudulent cases with the related estimated and established amount2017 - 2021                                                2021MS2017201820192020 
 
 
 
 
Annex 4 

193 

OWNRES established and estimated amountOWNRES established and estimated amount as a % in amount gross TOR collectedOWNRES established and estimated amountOWNRES established and estimated amount as a % in amount gross TOR collectedOWNRES established and estimated amountOWNRES established and estimated amount as a % in amount gross TOR collectedEUREUR%EUR%EUR%123=2/145=4/167=6/1BE2 298 846 46587 247 1133,80%75 935 7473,30%11 311 3660,49%BG213 401 8682 895 7821,36%2 754 1851,29%141 5970,07%CZ397 242 6313 051 0610,77%16 3360,00%3 034 7250,76%DK481 405 8384 348 3120,90%351 1430,07%3 997 1690,83%DE5 093 429 52777 064 9291,51%4 110 0390,08%72 954 8901,43%EE56 927 4261 053 5241,85%1 033 8101,82%19 7140,03%IE520 025 5581 446 9900,28%100 3660,02%1 346 6240,26%EL285 526 55312 502 9204,38%9 995 0583,50%2 507 8620,88%ES2 037 380 79461 776 6663,03%18 044 0710,89%43 732 5952,15%FR2 354 923 76124 238 8821,03%6 540 5060,28%17 698 3760,75%HR56 007 666941 9881,68%28 4420,05%913 5461,63%IT2 490 547 03716 335 1840,66%11 429 4090,46%4 905 7750,20%CY41 148 35913 5900,03%13 5900,03%00,00%LV79 094 2973 858 6534,88%1 043 5361,32%2 815 1173,56%LT164 257 9055 182 8063,16%3 837 2162,34%1 345 5900,82%LU21 819 21943 1710,20%00,00%43 1710,20%HU265 882 1642 879 8021,08%135 5450,05%2 744 2571,03%MT97 819 881328 5250,34%00,00%328 5250,34%NL3 943 194 481171 279 9204,34%14 406 9430,37%156 872 9773,98%AT287 881 8306 386 4922,22%4 203 3831,46%2 183 1100,76%PL1 495 986 15112 164 0610,81%1 194 1040,08%10 969 9580,73%PT227 647 4141 831 2560,80%698 4310,31%1 132 8250,50%RO289 798 0892 832 0050,98%608 8280,21%2 223 1770,77%SI168 557 690840 4860,50%565 8210,34%274 6650,16%SK495 413 670870 3190,18%37 1310,01%833 1880,17%FI209 018 62112 180 8225,83%00,00%12 180 8225,83%SE697 152 29110 241 2751,47%00,00%10 241 2751,47%EU-2724 770 337 187523 836 5342,11%157 083 6410,63%366 752 8931,48%UK613 244 024                  40 507 793                   6,61%4 634 349                   0,76%35 873 444                 5,85%Total25 383 581 211564 344 3272,22%161 717 9900,64%402 626 3371,59%** The figure in colums 1 might slightly differ from the final ones published in the financial accounts. The term 'gross amount of TOR' used in this table means the collected amount of TOR which was thereafter made available to the EU budget adter deduction of the applicable retention rate concerning collection costs.* Cut-off date 15/03/2022    TOR: Percentage of the financial impact of OWNRES cases to the collected and made avialable TOR (gross) in 2021 per Member State*MSGross amount  TOR collected (A account)**AllFraudulentNon-fraudulent 
Annex 5 

194 

Established amountRecovered amountRREstablished amountRecovered amountRREUREUR%EUREUR%123=2/1123=2/1BE47 875 95030 114 06463%76 981 36216 618 59022%BG4 033 59518 5300%2 884 18734 4361%CZ4 996 8183 140 97463%3 051 0613 035 28399%DK5 417 0465 285 99798%4 348 3124 307 06199%DE167 522 042163 146 92097%77 051 47473 595 61396%EE87 82387 823100%19 71419 714100%IE2 557 3292 475 86997%1 346 624943 66170%EL5 246 899904 99317%3 547 504641 66218%ES44 981 39138 863 09686%61 776 66646 622 00575%FR42 200 79114 639 98735%22 480 50014 097 36363%HR635 652635 652100%941 988941 988100%IT8 213 0903 016 76737%8 061 4851 380 28317%CY0%13 59013 590100%LV735 734583 31479%3 018 2032 150 99971%LT839 837778 65993%1 345 590787 81459%LU15 69015 690100%43 17143 171100%HU11 758 0611 007 9829%2 879 803492 76417%MT27 02427 024100%328 525328 525100%NL30 869 10625 741 37683%170 829 23442 617 27925%AT1 958 8391 943 52199%6 373 2923 347 93553%PL5 027 8553 171 04663%3 093 7312 146 40669%PT469 667469 667100%1 831 256660 11036%RO2 958 4221 681 04357%2 832 0051 846 76565%SI5 642 8541 815 35132%840 486231 66828%SK165 408165 408100%833 188833 188100%FI3 632 5763 577 98098%12 180 82212 140 609100%SE11 423 03310 541 54892%10 241 2759 711 55795%EU-27409 292 534     313 850 282    77%479 175 047      239 590 039              50%UK94 551 30273 997 74678%40 507 79326 232 75365%Total503 843 836     387 848 027    77%519 682 840      265 822 792              51%* Cut-off date 15/03/2022TOR: Recovery rates (RR) per cut-off date MS20202021 
Annex 6 

195 

Release for free circulationTransitCustoms warehousingInward processingOtherRelease for free circulationTransitCustoms warehousingInward processingOtherBE73 248 4971 513 9001 153 37219 978             8 726 4691 265 433      11 409328 037980 018BG2 742 59011 595141 597CZ16 3363 034 725DK351 1433 789 89560 365146 909DE3 962 289133 48214 26966 742 820697 498         3 779 4211 635 088100 063EE1 033 810        19 714IE100 366           1 149 842196 782EL486 147185 71016 9829 306 220        2 507 862ES18 044 07136 171 80849 795           190 3067 243 39577 291FR4 627 1561 746 40013 877153 073           15 140 88125 218           764 2081 401 647366 422HR28 442913 546IT3 204 76415 7468 208 900        4 854 58751 188CY13 590LV552 450203 086288 000           2 772 31814 760           28 039LT3 837 2161 096 412249 178         LU43 171HU135 5452 567 911159 31417 032MT328 525NL13 643 496763 447128 687 4521 407 614      1 990 1116 237 16618 550 634AT4 203 3832 045 15994 060           17 07726 814PL224 827348 093621 18410 932 89237 066           PT698 4311 132 825RO608 8282 176 70522 12824 344SI565 821274 665SK37 131833 188FI4 047 3788 007 72487 70238 017SE7 974 150441 392         76 1261 198 837550 771EU-27127 329 364      4 004 752      6 639 177       -                19 110 347      308 106 496       4 282 013      14 819 305      18 666 764     20 878 315    UK4 634 349          28 694 445         7 178 999Total   131 963 713      4 004 752      6 639 177       -                19 110 347      336 800 941       4 282 013      14 819 305      25 845 763     20 878 315    * Cut-off date 15/03/2022Non-fraudulentMSFraudulentTOR: Estimated and established amount per customs procedure per Member State 2021 
 
Annex 7 

196 

Release for free circulationTransitCustoms warehousingInward processingOtherRelease for free circulationTransitCustoms warehousingInward processingOtherBE14747318193133                BG2432CZ164DK69131                DE50111 1703722216                EE81IE1179EL311422ES2538723291                FR36512922022102                HR26IT1311662CY1LV7113311LT46211LU1HU12511                MT2NL4130487374715              AT450312                PL579933PT39RO103311                SI19SK34FI40322                SE17710214                EU-2734126680473 0282397013138UK231558Total34326680473 3432397018938* Cut-off date 15/03/2022TOR: Customs procedure by number of cases per Member State 2021MSFraudulentNon-fraudulent 
 
Annex 8 

197 

AllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherAllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherBE1619510501232811421159114BG27124222CZ1164343171DK6519535211353DE522123441 25694865117018729EE85311IE11261624103EL9321322319ES254911142211912420104505FR7136211423668815631HR22651IT1517768222719CY110LV9813522148LT464622121LU011HU11272241MT022NL51449014628559AT4135644561PL211225296107610PT3219243RO10103535SI11927SK334121FI04727416SE01949151331048217793183127103 5066911 93519018245256UK2237328588048417795183127103 8796912 22019018254056* Cut-off date 15/03/2022TOR: Method of detection by number of cases per Member State 2021MSFraudulentNon-fraudulent 
 
Annex 9 

198 

AllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherAllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherBE87 247 11375 935 7473 654 801        1 331 499        69 815 074     120 000           450 378      563 994   11 311 3667 454 6112 160 813          170 283943 090582 568BG2 895 7822 754 18511 595             2 742 590        -                 141 597141 597             CZ3 051 06116 33616 336             3 034 72588 1162 303 072          618 73824 798DK4 348 312351 143181 784           169 359      3 997 1692 039 448699 013             146 710969 074142 924DE77 064 9294 110 03968 376             1 249 584        2 594 621       197 457      72 954 8903 309 63835 971 547        795 32216 483 91614 933 0331 461 434EE1 053 5241 033 810924 026           109 784          19 71419 714               IE1 446 990100 366100 366          1 346 62413 825740 986             94 69451 043360 12185 955EL12 502 9209 995 0588 764 217        557 101           450 462          223 279   2 507 86256 143               2 451 719ES61 776 66618 044 07114 327 324      2 794 772       875 346           46 629     43 732 5956 769 90711 261 109        2 357 51716 179 9627 074 62589 475FR24 238 8826 540 5062 332 771        950 507           3 257 228       17 698 3766 425 3163 813 389          6 142 2351 317 436HR941 98828 44228 442             913 546899 555             13 991IT16 335 18411 429 40974 089             438 348           10 916 972     4 905 775783 5281 872 573          2 249 673CY13 59013 59013 590             0LV3 858 6531 043 5361 023 125        20 411     2 815 117141 7631 063 477          868 631741 246LT5 182 8063 837 2163 837 216       1 345 59010 9641 334 626          LU43 171043 17143 171HU2 879 802135 545135 545           2 744 257196 1492 537 597          10 511MT328 5250328 525328 525             NL171 279 92014 406 94310 535             14 396 408      156 872 97736 629 094114 304 397      5 939 486AT6 386 4924 203 3832 745 447        1 457 936        2 183 110135 6521 785 613          259 3862 459PL12 164 0611 194 104714 137           52 941             359 948          67 078     10 969 958225 5449 608 911          1 135 503PT1 831 256698 431658 716           39 715            1 132 825137 563415 071             580 191RO2 832 005608 828608 828          2 223 1772 223 177SI840 486565 821565 821           274 66527 255247 410             SK870 31937 13137 131             833 188706 36065 282               61 545FI12 180 822012 180 8223 697 09974 838               8 408 885SE10 241 275010 241 275227 8748 818 718          70 0711 124 611EU-27523 836 534157 083 64121 152 63338 312 09094 884 987995 346817 194921 391366 752 89369 062 878200 523 97818 441 59833 583 55142 751 2762 389 613UK40 507 793 4 634 349       4 634 349        35 873 444     26 568 136        9 305 308        Total564 344 327161 717 99021 152 63342 946 43994 884 987995 346817 194921 391402 626 33769 062 878227 092 11418 441 59833 583 55152 056 5842 389 613* Cut-off date 15/03/2022TOR: Method of detection by established and estimated amounts per Member state 2021MSTotalFraudulentNon-fraudulent 
Annex 10 

199 

Established amount, EURRecovered amount, EURRR, %Established amount, EURRecovered amount, EURRR, %123=2/1456=5/4BE66 763 30410 145 81715%10 218 0586 472 77363%BG2 742 59010 4240%141 59724 01117%CZ16 3365583%3 034 7253 034 725100%DK351 143351 143100%3 997 1693 955 91799%DE4 096 5842 519 03661%72 954 89071 076 57797%EE000%19 71419 714100%IE000%1 346 624943 66170%EL1 039 642557 10154%2 507 86284 5613%ES18 044 0715 182 57729%43 732 59541 439 42895%FR4 782 1242 064 73043%17 698 37612 032 63368%HR28 44228 442100%913 546913 546100%IT3 220 509206 9566%4 840 9761 173 32724%CY13 59013 590100%000%LV203 086203 086100%2 815 1171 947 91369%LT000%1 345 590787 81459%LU000%43 17143 171100%HU135 54500%2 744 257492 76418%MT000%328 525328 525100%NL14 395 192804 7316%156 434 04241 812 54827%AT4 203 3831 457 93635%2 169 9101 890 00087%PL114 326114 326100%2 979 4042 032 07968%PT698 43139 7156%1 132 825620 39555%RO608 828393 28065%2 223 1771 453 48665%SI565 8213 8431%274 665227 82583%SK000%833 188833 188100%FI000%12 180 82212 140 609100%SE000%10 241 2759 711 55795%EU-27122 022 94924 097 29220%357 152 098215 492 74760%UK4 634 349         1 560 465          34%35 873 44424 672 28869%Total126 657 29825 657 75620%393 025 542240 165 03561%* Cut-off date 15/03/2022TOR: Recovery rates (RR) per Member State 2021FraudulentNon-fraudulentMS 
Annex 11 

200 

Total cases* Cases assessed twice (AI)  Total (amounts not counted twice) NEURNEURNEURNEURNNEURDK-     -                 4          752 659           -          -                   -    -             4                    3                                752 659                 DE1        122 291          23        3 751 256        4              1 202 830        -    -             28                  -                             5 076 376              EL-     -                 4          1 333 752        -          -                   -    -             4                    -                             1 333 752              ES-     -                 1          398 424           1              266 788           -    -             2                    -                             665 213                 FR1        74 288            1          103 599           -          -                   -    290            2                    -                             178 177                 HR-     -                 -       -                   1              203 428           -    -             1                    -                             203 428                 IT5        1 323 472       6          2 167 957        4              3 497 161        -    26 340       15                  1                                7 014 929              LT1        1 178 576       -       -                   1              1 172 149        -    -             2                    1                                2 350 725              NL7        4 061 570       7          6 051 438        -          -                   -    -             14                  -                             10 113 008            AT1        92 966            3          2 712 184        3              9 161 523        -    7 883         7                    1                                11 974 557            PL-     -                 3          443 373           -          -                   -    -             3                    -                             443 373                 PT-     -                 2          629 984           -          -                   -    -             2                    -                             629 984                 RO1        855 750          3          1 909 300        -          -                   1       102 303     5                    1                                2 867 353              SI-     -                 4          964 757           -          -                   -    -             4                    -                             964 757                 SK-     -                 1          676 551           -          -                   -    -             1                    -                             676 551                 SE-     -                 1          103 724           -          -                   -    -             1                    1                                103 724                 EU-27       17        7 708 912          63        21 998 958             14        15 503 879         1       136 816                    95                                  8              45 348 565 UK-     -                 2          480 461           6              8 928 881        -    -             8                    1                                9 409 342              TOTAL       17        7 708 912          65        22 479 419             20        24 432 760         1       136 816                  103                                  9              54 757 907 * Cases assessed twice are not includedTOR: Examination of write-off cases in 2021MS Acceptance  Reference to Article 13.2 rejected  Additional information request (AI)  Not appropriate  
 
 
 
 
 
ANNEX 12 

Classification of cases in relation to common agricultural policy 
expenditure 

This  Annex describes  the methodology  adopted  for  classifying irregularities concerning the 
common agricultural policy (CAP) in the components ‘rural development’ (RD) and ‘support 
to agriculture’ (SA). The methodology also covers the classification of the SA irregularities 
in the two sub-components ‘market measures’ (MM) and ‘direct aid to farmers’ (DA). 

For  each  irregularity  related  to  the  common  agricultural  policy,  the  competent  national 
authorities should provide the following information in the irregularities management system 
(IMS): 

Fund 

The  options  are 
EAGF,  EARDF, 
EAGF/EARDF 

Budget 
year 

Budget line 

Budget post 

Budget article 

Budget measure 

e.g. 
B050209/08/0000007 

e.g.         
B050209 

e.g.        
B050209/08 

e.g. 
B050209/08/0000007 

This methodology is based on the information included in the fields ‘Fund’, ‘Budget line’ and 
‘Budget post’. Budget line and budget post are IMS terminology. In the current EU budget, 
reference is made to chapters (corresponding to the first part of the IMS budget post above) 
and articles (corresponding to the IMS budget post).  

Cases are classified as RD, SA, SA/RD, Blank. 

Irregularities classified as RD 

Irregularities are classified as RD, where they concern only expenditure on IMS budget lines/posts 
that contain the codes ‘B0803', B0504', 'B01-4' or 'B01-50141. In addition, it has been considered that 
there are irregularities where the field 'Fund' refers to the EARDF (European Agriculture Rural 
Development Fund), even if the budget line/post is not specified. 

This  choice  has  been  made  because,  since  2004,  in  the  EU  budget,  expenditure  on  rural 
development has been grouped under the budget chapter 0504. Under this, the budget articles 
B050405 (as from  2007) and B050460 (as from  2014) refer to  European  Agricultural  Fund 
for  Rural  Development  (EAFRD)  funding142.  In  the  2021  budget,  the  EAFRD  is  under  the 
chapter B0803. 

Between 2000 and 2003, rural development was instead financed under budget chapter B01-
40 (EAGGF Guarantee Section). The appropriations included in this chapter were intended to 
cover expenditure on two types of rural development measures: (1) accompanying measures 
introduced in 1992 supplemented by the less-favoured-areas scheme; and (2) modernisation 
and diversification schemes. 

141 Most of these cases have the field 'Fund' filled in as 'EAFRD/EAGF', but the Budget line or the Budget post 
that are  explicitly  mentioned  lead to classify the case in this category  RD. In the  category  RD, also cases are 
included where the field 'Fund' is filled in as 'EAGF' and the budget line/post includes only RD budget codes. 
142  Budget  chapter  B504  is  split  in  the  following  budget  titles:  B050401  'rural  development  in  the  EAGGF  – 
Guarantee  section'  (later  with  the  addition  'Completion  of  earlier  programme  2000-2006'),  B050402  'rural 
development  in  the  EAGGF  –  Guidance  section'  (later  with  the  addition  'Completion  of  earlier  programme'), 
B050403  'Other  measures',  B050404  'Transitional  instrument  for  the  financing  of  rural  development  by  the 
EAGGF – Guarantee section for the new MS' (later with the addition 'Completion of earlier programmes 2004-
2006),  B050405  'rural development  financed by EAFRD (2007-2013)' (from 2007. As from 2014, it becomes 
'completion of …'), B050460 'EAFRD (2014-2020)' (from 2014). 

201 

 
                                                           
Before  2000,  the  EU  budget  had  no  explicit  reference  to  rural  development,  but  budget 
chapter  B01-50  (EAGGF  Guarantee  Section)  covered  expenditure  on  accompanying 
measures, similar to chapter B01-40 in 2000-2003. 

Irregularities classified as SA 

Irregularities  are  classified  as  SA,  where  the  IMS  budget  line/post  does  not  contain  RD 
budget codes143. In addition, it has been considered that there are irregularities where the field 
'Fund' refers to the European Agriculture Guarantee Fund (EAGF) and the budget line/post is 
not  specified.  For  these  cases,  it  is  not  clear  whether  this  expenditure  financed  rural 
development  (from  the  EAGGF  –  Guarantee  Section)  or  SA.  To  find  the  best  possible 
classification for these cases, the following assumption has been made. In 2007, the EARDF 
was  created  to  finance  all  measures  concerning  rural  development.  Consequently,  if  the 
budget years associated to an irregularity are from 2007 onwards, it seems to be unlikely that 
this irregularity is related to rural development, so it is considered SA. If also the budget year 
is not mentioned, but the programming period mentioned in the relevant field is 2007-2013 or 
2014-2020, the irregularity is considered SA. The other irregularities are classified as in the 
category ‘Blank’ (see below). 

SA includes expenditure relating to intervention in agricultural markets and direct payments 
to farmers. 

Irregularities classified as SA/RD 

Irregularities  are  classified  as  'SA/RD',  where  they  concern  both  types  of  expenditure  (RD 
and SA budget codes)144. In addition, it has been considered that there are irregularities where 
the field 'Fund' refers to 'EAGF/EARDF', but the budget line/post is not specified. For these 
cases, it is not clear whether this expenditure financed only rural development (before from 
the  EAGGF  –  Guarantee  Section  and  then  from  EARDF)  or  both  rural  development 
(EARDF)  and  SA  (EAGF).  To  find  the  best  possible  classification  for  these  cases,  the 
following  assumption  has  been  made.  In  2007,  the  EARDF  was  created  to  finance  all 
measures  concerning  rural  development.  Consequently,  if  the  budget  years  associate  to  an 
irregularity are from 2007 onwards only, it seems likely that there is also an SA component in 
the  expenditure  related  to  the  irregularity  (because  EAGF  is  more  likely  to  point  to  an  SA 
item of expenditure) so the irregularity is considered ‘SA/RD’. If also the budget year is not 
mentioned, but  the programming period is  2007-2013 or 2014-2020, the  irregularity is  also 
considered ‘SA/RD’. Other irregularities are classified as ‘Blank’. 

Irregularities classified as ‘Blank’ 

Irregularities are classified as 'Blank', where information has not been considered enough to 
assign the case to RD, SA or SA/RD145.  

Classification as ‘market measures’ or ‘direct payments’ 

Some  parts  of  the  analysis  in  Section  3  'Common  agricultural  policy'  separately  focus  on 
'interventions in agricultural markets' (or 'market measures') and 'direct payments' (or ‘direct 
aid’). 

143 Most of these cases have the field 'Fund' filled in as 'EAFRD/EAGF', but the budget line/post includes only 
SA budget codes. 
144 Most of these cases have the field 'Fund' filled in as 'EAFRD/EAGF' and the budget line/post includes both 
SA and RD budget codes. 
145 See above.  

202 

 
                                                           
In fact, since 2006, the EU budget provides for support to agriculture to be structured along two 
main budget chapters:146 

 Budget chapter B0502 'interventions in agricultural markets' (B080201, B080202, B080203, 

for budget 2021); 

 Budget chapter B0503 'direct aids' (B080204, B080205, for budget 2021). 

For the purpose of the analysis in Section 3 'Common agricultural policy', cases are classified 
as: 

 'Market measures', where they concern expenditure on IMS budget lines/posts  that contain 
the  code  '502',  as  from  the  2006  EU  budget  (B080201,  B080202,  B080203,  for  budget 
2021)  (NB,  the  same  case  may  also  concern  other  areas,  including  rural  development  or 
direct payments); 

 'Direct payments', where they concern expenditure on IMS budget lines/posts which contain 
the code '503', as from the 2006 EU Budget (B080204, B080205, for budget 2021) (NB, the 
same case may also concern other areas, including RD or market measures). 

Cases concerning only expenditure in 2005 (budget year) or before are not considered 'market 
measures' or 'direct payments'. Before 2006, the EU budget had a different structure: 

 In  2004  and  2005,  the  budget  chapters  0502  and  0503  referred  respectively  to  'Plant 

products' and 'Animal products';  

 Before 2004, budget subsection B01 covered the Guarantee Section of the EAGG fund and 

was split, among others147, in: 

o  B01-1 'Plant products'; 

o  B01-2 'Animal products'. 

146  The  other  chapters  of  Title  05  'Agriculture  and  rural  development'  are:  0501  'Administrative  expenditure', 
0504  'Rural  development',  0505  'SAPARD'  (later  'Instrument  for  pre-accession  assistance'),  0506  'External 
relations' (later 'International aspects'), 0507 'Audit', 0508 'Policy strategy and coordination', 0549 'Expenditure 
on administrative management' (until 2013), 0509 'Horizon 2020 – Research and innovation' (from 2014).  
147 B01-3 covered "Ancillary expenditure", B01-6 "Monetary reserve". 

203 

 
 
 
 
                                                           
ANNEX 13 

Categories of irregularities and related types 

This Annex shows the types of violations in the IMS and how they are grouped in categories. 
These categories are used in used in Tables NR6-NR9. 

In Table CP10 the following grouping is used: 

 Infringements concerning the request: T11/00, T11/01, T11/99 

 Eligibility / Legitimacy of expenditure/measure: T11/02 

 Multiple financing: T11/03, T11/04 

 Violations/breaches by the operator: T12 

 Incorrect, absent, falsified accounts: T13 

 Incorrect, missing, false or falsified supporting documents: T14 

 Product, species and/or land: T15 

 Infringement of contract provisions/rules: T16/00, T16/01, T16/02, T16/03, T16/04, T16/05, T16/06, 

T16/07, T16/09, T16/10, T16/99   

 Movement: T17 

 Bankruptcy: T18 

 Ethics and integrity: T19 

 Infringement of public procurement rules: T40, T41, T16/08 

 State aid: T50 

Code 

Category 

Type 

T11/00: Incorrect or incomplete request for aid 

T11/01: False or falsified request for aid 

T11 

Request 

T11/03: Incompatible cumulation of aid 

T11/02:Product, species, project and/or activity not eligible for aid 

T11/04: Several requests for the same product, species, project and/or activity 

T11/99: Other 

T12/00: Incorrect identity operator/beneficiary 

T12/01: Non-existent operator/beneficiary 

T12 

Beneficiary 

T12/02: Misdescription of the holding 

T12/03: Operator/beneficiary not having the required quality 

T13 

Accounts and records 

T12/99: Other 

T13/00: Incomplete accounts 

T13/01: Incorrect accounts 

204 

 
 
T14 

Documentary proof 

T13/02: Falsified accounts 

T13/03: Accounts not presented 

T13/04: Absence of accounts 

T13/05: Calculation errors 

T13/06: Revenues not declared 

T13/99: Other 

T14/00: Documents missing and/or not provided 

T14/01: Documents incomplete 

T14/02: Documents incorrect 

T14/03: Documents provided too late 

T14/04: Documents false and/or falsified 

T14/99: Other 

T15/00: Over or under production 

T15/01: Inexact composition 

T15/02: Inexact origin 

T15/03: Inaccurate value 

T15/04: Inexact quantity 

T15/05: Variation in quality or content 

T15/06: Quantities outside permitted limits, quotas, thresholds 

T15 

Product, species 
and/or land 

T15/07: Unauthorised substitution or exchange 

T15/08: Unauthorised addition or mixture 

T15/09: Unauthorised use 

T15/10: Falsification of the product 

T15/11: Incorrect storage or handling 

T15/12: Fictitious use or processing 

T15/13: Incorrect classification (incl. incorrect tariff heading) 

T15/14: Overdeclaration and/or declaration of fictitious product, species and/or 
land 

T15/99: Other 

T16/00: Action not implemented 

T16/01: Action not completed 

T16 

(Non-)action 

T16/02: Operation prohibited during the measure 

T16/03: Failure to respect deadlines 

T16/04: Irregular termination, sale or reduction 

205 

 
T16/05: Absence of identification, marking, etc. 

T16/06: Refusal of control, audit, scrutiny etc. 

T16/07: Control, audit, scrutiny etc. not carried out in accordance with 
regulations, rules, plan etc. 

T16/08: Infringement of rules concerned with public procurement 

T16/09: Infringements with regard to the cofinancing system 

T16/10: Refusal to repay not spent or unduly paid amount 

T16/99: Other 

T17/00: Irregularities in connection with final destination (change of, non arrival 
at, etc.) 

T17 

Movement 

T17/01: Fictitious movement 

T17/99: Other 

T18/00: Legal persons - liquidation 

T18/01: Legal persons - reorganisation to structure debt 

T18 

Bankruptcy 

T18/02: Natural persons - repayment plan 

T18/03: Natural persons - repayment plan not possible 

T18/99: Other 

T19/00: Conflict of interest 

T19/01: Bribery - passive 

T19/02: Bribery - active 

T19 

Ethics and integrity 

T19/03: Corruption 

T19/04: Corruption - passive 

T19/05: Corruption - active 

T19/99: Other irregularities concerning integrity and ethics 

T40/01: Lack of publication of contract notice 

T40/02: Artificial splitting of works/services/supplies contracts 

T40/03: Non-compliance with - time limits for receipt of tenders; or - time limits 
for receipt of requests to participate 

     T40/03A: Non-compliance with time limits for receipt of tenders 

T40 and 
T41 

Public procurement  

     T40/03B: Non-compliance with time limits for receipt of requests to participate 

T40/04: Insufficient time for potential tenderers/candidates to obtain tender 
documentation 

T40/05: Lack of publication of -extended time limits for receipt of tenders; or - 
extended time limits for receipt of requests to participate 

     T40/05A: Lack of publication of extended time limits for receipt of tenders 

     T40/05B: Lack of publication of extended time limits for receipt of request to     

206 

 
participate 

T40/06: Cases not justifying the use of the negotiated procedure with prior 
publication of a contract notice 

T40/07: For the award of contracts in the field of defence and security falling 
under directive 2009/81/EC specifically, inadequate justification for the lack of 
publication of a contract notice 

T40/08: Failure to state: - the selection criteria in the contract notice; and/or - the 
award criteria (and their weighting) in the contract notice or in the tender 
specifications 

     T40/08A: Failure to state the selection criteria in the contract notice 

     T40/08B: Failure to state the award criteria ( and their weighting) in the 
contract notice or in the tender specifications 

T40/09: Unlawful and/or discriminatory selection and/or award criteria laid down 
in the contract notice or tender documents 

     T40/09A: Unlawful and/or discriminatory selections criteria laid down in the 
contract notice or tender documents 

     T40/09B: Unlawful and/or discriminatory award criteria laid down in the 
contract notice or tender documents 

T40/10: Selection criteria not related and proportionate to the subject-matter of 
the contract 

T40/11: Discriminatory technical specifications 

T40/12: Insufficient definition of the subject-matter of the contract 

T40/13: Modification of selection criteria after opening of tenders, resulting in 
incorrect acceptance of tenderers 

T40/14: Modification of selection criteria after opening of tenders, resulting in 
incorrect rejection of tenderers 

T40/15: Evaluation of tenderers/candidates using unlawful selection or award 
criteria 

T40/16: Lack of transparency and/or equal treatment during evaluation 

T40/17: Modification of a tender during evaluation 

T40/18: Negotiation during the award procedure 

T40/19: Negotiated procedure with prior publication of a contract notice with 
substantial modification of the conditions 

T40/20: Rejection of abnormally low tenders 

T40/21: Conflict of interest 

T40/22: Substantial modification of the contract elements set out in the contract 
notice or tender specifications 

T40/23: Reduction in the scope of the contract 

T40/24: Award of additional works/services/supplies contracts without 
competition 

     T40/24A: Award of additional works/services/supplies contracts (if such award 

207 

 
constitutes a substantial modification of the original terms of the contract) 
without competition in the absence of extreme urgency brought about by 
unforeseeable events 

     T4024B: Award of additional works/services/supplies contracts (if such award 
constitutes a substantial modification of the original terms of the contract) 
without competition in the absence of an unforeseen circumstance for 
complementary works, services, supplies 

T40/25: Additional works or services exceeding the limit laid down in the relevant 
provisions 

T40/50: Unjustified direct award (i.e. unlawful negotiated procedure without prior 
publication of a contract notice) 

T40/51: Lack of justification for not subdividing contract into lots 

T40/52: Failure to extend time limits for receipt of tenders where significant 
changes are made to the procurement documents 

T40/53: Restrictions to obtain tender documentation 

T40/54: Failure to extend time limits for receipt of tenders where, for whatever 
reason, additional information, although requested by the economic operator in 
good time, is not supplied at the latest six days before the time limit fixed for the 
receipt of tenders. 

T40/55: Non-compliance with the procedure established in the Directive for 
electronic and aggregated procurement 

T40/56: Failure to describe in sufficient detail the award criteria and their 
weighting. 

T40/57: Failure to communicate/publish clarifications/additional information (in 
relation to selection/award criteria or conditions for performance of contracts or 
technical specifications). 

T40/58: Unjustified limitation of sub-contracting 

T40/59: Selection criteria (or technical specifications) were incorrectly applied. 

T40/60: Evaluation of tenders using award criteria that are different from the 
ones stated in the contract notice or tender specifications 

T40/61: Evaluation using additional award criteria that were not published 

T40/62: Insufficient audit trail for the award of the contract 

T40/63: Irregular prior involvement of candidates/tenderers towards the 
contracting authority 

T40/64: Bid-rigging 

T40/99: Other 

T41/01A: Lack of publication of contract notice 

T41/01B: Unjustified direct award (i.e. unlawful negotiated procedure without 
prior publication of a contract notice) 

T41/02: Artificial splitting of works/services/supplies contracts 

T41/03: Lack of justification for not subdividing contract into lots 

208 

 
T41/04A: Non-compliance with time limits for receipt of tenders 

T41/04B: Non-compliance with time limits for receipt of requests to participate 

T41/04C: Failure to extend time limits for receipt of tenders where significant 
changes are made to the procurement documents 

T41/05A: Insufficient time for potential tenderers/candidates to obtain tender 
documentation 

T41/05B: Restrictions to obtain tender documentation 

T41/06A: Lack of publication of extended time limits for receipt of tenders 

T41/06B: Failure to extend time limits for receipt of tenders 

T41/07A: Cases not justifying the use of a competitive procedure with negotiation 

T41/07B: Cases not justifying the use of a competitive dialogue 

T41/08: Non-compliance with the procedure established in the Directive for 
electronic and aggregated procurement 

T41/09A : Failure to publish in the contract notice the selection and/or award 
criteria (and their weighting) 

T41/09B : Failure to publish in the contract notice the conditions for performance 
of contracts or technical specifications. 

T41/09C : Failure to describe in sufficient detail the award criteria and their 
weighting 

T41/09D : Failure to communicate/publish clarifications/additional information. 

T41/10A : Use of criteria for exclusion, selection, award that are discriminatory on 
the basis of unjustified national, regional or local preferences 

T41/10B : Use of conditions for performance of contracts that are discriminatory 
on the basis of unjustified national, regional or local preferences 

T41/10C : Use of technical specifications that are discriminatory on the basis of 
unjustified national, regional or local preferences 

T41/11A : Use of criteria for exclusion, selection, award that are not 
discriminatory in the sense of the previous type of irregularity but still restrict 
access for economic operators 

T41/11B : Use of conditions for performance of contracts that are not 
discriminatory in the sense of the previous type of irregularity but still restrict 
access for economic operators 

T41/11C : Use of technical specifications that are not discriminatory in the sense 
of the previous type of irregularity but still restrict access for economic operators 

T41/12 : Insufficient or imprecise definition of the subject-matter of the contract 

T41/13 : Unjustified limitation of subcontracting 

T41/14A: Selection criteria (or technical specifications) were modified after 
opening of tenders. 

T41/14B: Selection criteria (or technical specifications) were incorrectly applied. 

T41/15A: Evaluation of tenders using award criteria that are different from the 
ones stated in the contract notice or tender specifications 

209 

 
T41/15B: Evaluation using additional award criteria that were not published 

T41/16: Insufficient audit trail for the award of the contract 

T41/17A: Negotiation during award procedure 

T41/17B: Modification of the winning tender during evaluation 

T41/18: Irregular prior involvement of candidates/tenderers towards the 
contracting authority 

T41/19: Competitive procedure with negotiation, with substantial modification of 
the conditions set out in the contract notice or tender specifications 

T41/20: Unjustified rejection of abnormally low tenders 

T41/21: Conflict of interest 

T41/22: Bid-rigging 

T41/23A: Modification of the contract elements set out in the contract notice, not 
in compliance with the directives 

T41/23B: Modification of the contract elements set out in the tender 
specifications, not in compliance with the directives 

T41/70: For the award of contracts in the field of defence and security falling 
under directive 2009/81/EC specifically, inadequate justification for the lack of 
publication of a contract notice 

T41/71: Lack of transparency and/or equal treatment during evaluation 

T41/72: Award of additional works/services/supplies contracts (if such award 
constitutes a substantial modification of the original terms of the contract) 
without competition in the absence of the applicable conditions (extreme urgency 
brought about by unforeseeable events; an unforeseen circumstance for 
complementary works, services, supplies) 

T41/73: Additional works or services exceeding the limit laid down in the relevant 
provisions 

T41/99: Other 

T50/01: Failure to notify State Aid 

T50/02:Wrong aid scheme applied 

T50/03:Misapplication of the aid scheme 

T50/04:Monitoring requirements not fulfilled 

T50 

State aid 

T50/05:Reference investment not taken into account in the applicable aid scheme 

T50/06:No consideration of revenue in the applicable aid scheme 

T50/07:No respect of the incentive effect of the aid 

T50/08:Aid intensity not respected 

T50/09:De Minimis threshold exceeded 

T50/99:Other State aid 

T90 

Other 

T90/99: Other irregularities 

210 

 
 
 
ANNEX 14 

On the analysis by intervention fields 

EU  expenditure  is  targeted  to  specific  intervention  fields,  which  change  depending  on  the 
programming  period.  In  IMS,  the  reporting  authorities  are  requested  to  specify  the 
intervention fields affected by the irregularities they communicate. 

For the cohesion policy, Annex 14.1 shows the intervention fields related to the programming 
period  2007-2013.  Annex  14.2  shows  the  intervention  fields  related  to  the  programming 
period 2014-2020.148 

For the purpose of this analysis, the intervention fields have been grouped along these areas: 

  Strengthening research, technological development and innovation; 

  Enhancing  accessibility  to  and  use  and  quality  of  information  and  communication 

technologies (digital transition); 

  Supporting the shift towards a low-carbon economy in all sectors (green transition); 

  Promoting climate change adaptation, risk prevention and management (green transition); 

  Preserving  and  protection  the  environment  and  promoting  resource  efficiency  (green 

transition); 

  Promoting sustainable transport and removing bottlenecks in key network infrastructures; 

  Promoting sustainable and quality employment and supporting labour mobility; 

  Promoting social inclusion, combating poverty and any discrimination; 

 

Investment in education, training and vocational training for skills and lifelong learning; 

  Enhancing competitiveness of  enterprises 

  Culture and tourism; 

  Technical assistance; 

  Outermost regions. 

For most of these areas, a number of sub-areas have been defined. They are shown in Annex 
14.3. 

Annex 14.4 shows the association of these intervention fields to each area and sub-area, both 
for the intervention fields of PP 2014-2020 and those of PP 2007-2013. 

148 The intervention fields for the PP 2007-2013 are listed in the Commission Regulation (EC) 1828/2006. The 
intevention fields for the PP 2014-2020 are listed in the Commission Implementing Regulations (EU) 184/2014. 

211 

 
 
 
 
 
                                                           
Annex 14.1 

212 

CodeDescriptionCOH-TH01R&TD activities in research centresCOH-TH02R&TD infrastructure (including physical plant, instrumentation and high-speed computer networks linking research centres) and centres of competence in a specific technologyCOH-TH03Technology transfer and improvement of cooperation networks between small businesses (SMEs), between these and other businesses and universities, postsecondary education establishments of all kinds, regional authorities, research centres and scientific and technological poles (scientific and technological parks, technopoles, etc.)COH-TH04Assistance to R&TD, particularly in SMEs (including access to R&TD services in research centres)COH-TH05Advanced support services for firms and groups of firmsCOH-TH06Assistance to SMEs for the promotion of environmentally-friendly products and production processes (introduction of effective environment managing system, adoption and use of pollution prevention technologies, integration of clean technologies into firm production)COH-TH07Investment in firms directly linked to research and innovation (innovative technologies, establishment of new firms by universities, existing R&TD centres and firms, etc.)COH-TH08Other investment in firmsCOH-TH09Other measures to stimulate research and innovation and entrepreneurship in SMEsCOH-TH10Telephone infrastructures (including broadband networks)COH-TH11Information and communication technologies (access, security, interoperability, risk-prevention,COH-TH12Information and communication technologies (TEN-ICT)COH-TH13Services and applications for the citizen (e-health, e-government, e-learning, e-inclusion, etc.)COH-TH14Services and applications for SMEs (e-commerce, education and training, networking, etc.)COH-TH15Other measures for improving access to and efficient use of ICT by SMEsCOH-TH16RailwaysCOH-TH17Railways (TEN-T)COH-TH18Mobile rail assetsCOH-TH19Mobile rail assets (TEN-T)COH-TH20MotorwaysCOH-TH21Motorways (TEN-T)COH-TH22National roadsCOH-TH23Regional/local roadsCOH-TH24Cycle tracksCOH-TH25Urban transportCOH-TH26Multimodal transportCOH-TH27Multimodal transport (TEN-T)COH-TH28Intelligent transport systemsCOH-TH29AirportsCOH-TH30PortsCOH-TH31Inland waterways (regional and local)COH-TH32Inland waterways (TEN-T)COH-TH33ElectricityCOH-TH34Electricity (TEN-E)COH-TH35Natural gasCOH-TH36Natural gas (TEN-E)COH-TH37Petroleum productsCOH-TH38Petroleum products (TEN-E)COH-TH39Renewable energy: windCOH-TH40Renewable energy: solarCOH-TH41Renewable energy: biomassCOH-TH42Renewable energy: hydroelectric, geothermal and otherCOH-TH43Energy efficiency, co-generation, energy managementCOH-TH44Management of household and industrial wasteCOH-TH45Management and distribution of water (drinking water)COH-TH46Water treatment (waste water) 
 
 
 
 
 
213 

COH-TH47Air qualityCOH-TH48Integrated prevention and pollution controlCOH-TH49Mitigation and adaptation to climate changeCOH-TH50Rehabilitation of industrial sites and contaminated landCOH-TH51Promotion of biodiversity and nature protection (including Natura 2000)COH-TH52Promotion of clean urban transportCOH-TH53Risk prevention (including the drafting and implementation of plans and measures to prevent and manage natural and technological risks)COH-TH54Other measures to preserve the environment and prevent risksCOH-TH55Promotion of natural assetsCOH-TH56Protection and development of natural heritageCOH-TH57Other assistance to improve tourist servicesCOH-TH58Protection and preservation of the cultural heritageCOH-TH59Development of cultural infrastructureCOH-TH60Other assistance to improve cultural servicesCOH-TH61Integrated projects for urban and rural regenerationCOH-TH62Development of life-long learning systems and strategies in firms; training and services for employees to step up their adaptability to change; promoting entrepreneurship and innovationCOH-TH63Design and dissemination of innovative and more productive ways of organising workCOH-TH64Development of specific services for employment, training and support in connection with restructuring of sectors and firms, and development of systems for anticipating economic changes and future requirements in terms of jobs and skillsCOH-TH65Modernisation and strengthening labour market institutionsCOH-TH66Implementing active and preventive measures on the labour marketCOH-TH67Measures encouraging active ageing and prolonging working livesCOH-TH68Support for self-employment and business start-upCOH-TH69Measures to improve access to employment and increase sustainable participation and progress of women in employment to reduce gender-based segregation in the labour market, and to reconcile work and private life, such as facilitating access to childcare and care for dependent personsCOH-TH70Specific action to increase migrants’ participation in employment and thereby strengthen their social integrationCOH-TH71Pathways to integration and re-entry into employment for disadvantaged people; combating discrimination in accessing and progressing in the labour market and promoting acceptance of diversity at the workplaceCOH-TH72Design, introduction and implementation of reforms in education and training systems in order to develop employability, improving the labour market relevance of initial and vocational education and training, updating skills of training personnel with a view to innovation and a knowledge based economyCOH-TH73Measures to increase participation in education and training throughout the lifecycle, including through action to achieve a reduction in early school leaving, gender-based segregation of subjects and increased access to and quality of initial vocational and tertiary education and trainingCOH-TH74Developing human potential in the field of research and innovation, in particular through post-graduate studies and training of researchers, and networking activities between universities, research centres and businessesCOH-TH75Education infrastructureCOH-TH76Health infrastructureCOH-TH77Childcare infrastructureCOH-TH78Housing infrastructureCOH-TH79Other social infrastructureCOH-TH80Promoting partnerships, pacts and initiatives through the networking of relevant stakeholdersCOH-TH81Mechanisms for improving good policy and programme design, monitoring and evaluation at national, regional and local level, capacity building in the delivery of policies and programmes.COH-TH82Compensation of any additional costs due to accessibility deficit and territorial fragmentationCOH-TH83Specific action addressed to compensate additional costs due to size market factorsCOH-TH84Support to compensate additional costs due to climate conditions and relief difficultiesCOH-TH85Preparation, implementation, monitoring and inspectionCOH-TH86Evaluation and studies; information and communication 
 
 
 
 
 
 
 
 
 
Annex 14.2 

214 

CodeDescriptionI.001Generic productive investment in small and medium – sized enterprises (‘SMEs’)I.002Research and innovation processes in large enterprisesI.003Productive investment in large enterprises linked to the low-carbon economyI.004Productive investment linked to the cooperation between large enterprises and SMEs for developing information and communication technology (‘ICT’) products and services, e-commerce and enhancing demand for ICTII.005Electricity (storage and transmission)II.006Electricity (TEN-E storage and transmission)II.007Natural gasII.008Natural gas (TEN-E)II.009Renewable energy: windII.010Renewable energy: solarII.011Renewable energy: biomassII.012Other renewable energy (including hydroelectric, geothermal and marine energy) and renewable energy integration (including storage, power to gas and renewable hydrogen infrastructure)II.013Energy efficiency renovation of public infrastructure, demonstration projects and supporting measuresII.014Energy efficiency renovation of existing housing stock, demonstration projects and supporting measuresII.015Intelligent Energy Distribution Systems at medium and low voltage levels (including smart grids and ICT systems)II.016High efficiency co-generation and district heatingII.017Household waste management, (including minimisation, sorting, recycling measures)II.018Household waste management, (including mechanical biological treatment, thermal treatment, incineration and landfill measures)II.019Commercial, industrial or hazardous waste managementII.020Provision of water for human consumption (extraction, treatment, storage and distribution infrastructure)II.021Water management and drinking water conservation (including river basin management, water supply, specific climate change adaptation measures, district and consumer metering, charging systems and leak reduction)II.022Waste water treatmentII.023Environmental measures aimed at reducing and/or avoiding greenhouse gas emissions (including treatment and storage of methane gas and composting)II.024Railways (TEN-T Core)II.025Railways (TEN-T comprehensive)II.026Other RailwaysII.027Mobile rail assetsII.028TEN-T motorways and roads — core network (new build)II.029TEN-T motorways and roads — comprehensive network (new build)II.030Secondary road links to TEN-T road network and nodes (new build)II.031Other national and regional roads (new build)II.032Local access roads (new build)II.033TEN-T reconstructed or improved roadII.034Other reconstructed or improved road (motorway, national, regional or local)II.035Multimodal transport (TEN-T)II.036Multimodal transportII.037Airports (TEN-T) (1)II.038Other airports (1)II.039Seaports (TEN-T)II.040Other seaportsII.041Inland waterways and ports (TEN-T)II.042Inland waterways and ports (regional and local)II.043Clean urban transport infrastructure and promotion (including equipment and rolling stock)II.044Intelligent transport systems (including the introduction of demand management, tolling systems, IT monitoring, control and information systems)II.045ICT: Backbone/backhaul networkII.046ICT: High-speed broadband network (access/local loop; >/= 30 Mbps)II.047ICT: Very high-speed broadband network (access/local loop; >/= 100 Mbps)II.048ICT: Other types of ICT infrastructure/large-scale computer resources/equipment (including e-infrastructure, data centres and sensors; also where embedded in other infrastructure such as research facilities, environmental and social infrastructure)III.049Education infrastructure for tertiary educationIII.050Education infrastructure for vocational education and training and adult learningIII.051Education infrastructure for school education (primary and general secondary education)III.052Infrastructure for early childhood education and careIII.053Health infrastructureIII.054Housing infrastructureIII.055Other social infrastructure contributing to regional and local developmentIV.056Investment in infrastructure, capacities and equipment in SMEs directly linked to research and innovation activitiesIV.057Investment in infrastructure, capacities and equipment in large companies directly linked to research and innovation activitiesIV.058Research and innovation infrastructure (public)IV.059Research and innovation infrastructure (private, including science parks)IV.060Research and innovation activities in public research centres and centres of competence including networkingIV.061Research and innovation activities in private research centres including networkingIV.062Technology transfer and university-enterprise cooperation primarily benefiting SMEs 
 
215 

IV.063Cluster support and business networks primarily benefiting SMEsIV.064Research and innovation processes in SMEs (including voucher schemes, process, design, service and social innovation)IV.065Research and innovation infrastructure, processes, technology transfer and cooperation in enterprises focusing on the low carbon economy and on resilience to climate changeIV.066Advanced support services for SMEs and groups of SMEs (including management, marketing and design services)IV.067SME business development, support to entrepreneurship and incubation (including support to spin offs and spin outs)IV.068Energy efficiency and demonstration projects in SMEs and supporting measuresIV.069Support to environmentally-friendly production processes and resource efficiency in SMEsIV.070Promotion of energy efficiency in large enterprisesIV.071Development and promotion of enterprises specialised in providing services contributing to the low carbon economy and to resilience to climate change (including support to such services)IV.072Business infrastructure for SMEs (including industrial parks and sites)IV.073Support to social enterprises (SMEs)IV.074Development and promotion of tourism assets in SMEsIV.075Development and promotion of tourism services in or for SMEsIV.076Development and promotion of cultural and creative assets in SMEsIV.077Development and promotion of cultural and creative services in or for SMEsIV.078e-Government services and applications (including e-Procurement, ICT measures supporting the reform of public administration, cyber-security, trust and privacy measures, e-Justice and e-Democracy)IV.079Access to public sector information (including open data e-Culture, digital libraries, e-Content and e-Tourism)IV.080e-Inclusion, e-Accessibility, e-Learning and e-Education services and applications, digital literacyIV.081ICT solutions addressing the healthy active ageing challenge and e-Health services and applications (including e-Care and ambient assisted living)IV.082ICT Services and applications for SMEs (including e-Commerce, e-Business and networked business processes), living labs, web entrepreneurs and ICT start-ups)IV.083Air quality measuresIV.084Integrated pollution prevention and control (IPPC)IV.085Protection and enhancement of biodiversity, nature protection and green infrastructureIV.086Protection, restoration and sustainable use of Natura 2000 sitesIV.087Adaptation to climate change measures and prevention and management of climate related risks e.g. erosion, fires, flooding, storms and drought, including awareness raising, civil protection and disaster management systems and infrastructuresIV.088Risk prevention and management of non-climate related natural risks (i.e. earthquakes) and risks linked to human activities (e.g. technological accidents), including awareness raising, civil protection and disaster management systems and infrastructuresIV.089Rehabilitation of industrial sites and contaminated landIV.090Cycle tracks and footpathsIV.091Development and promotion of the tourism potential of natural areasIV.092Protection, development and promotion of public tourism assetsIV.093Development and promotion of public tourism servicesIV.094Protection, development and promotion of public cultural and heritage assetsIV.095Development and promotion of public cultural and heritage servicesIV.096Institutional capacity of public administrations and public services related to implementation of the ERDF or actions supporting ESF institutional capacity initiativesIV.097Community-led local development initiatives in urban and rural areasIV.098Outermost regions: compensation of any additional costs due to accessibility deficit and territorial fragmentationIV.099Outermost regions: specific action to compensate additional costs due to size market factorsIV.100Outermost regions: support to compensate additional costs due to climate conditions and relief difficultiesIV.101Cross-financing under the ERDF (support to ESF-type actions necessary for the satisfactory implementation of the ERDF part of the operation and directly linked to it)V.102Access to employment for job-seekers and inactive people, including the long-term unemployed and people far from the labour market, also through local employment initiatives and support for labour mobilityV.103Sustainable integration into the labour market of young people, in particular those not in employment, education or training, including young people at risk of social exclusion and young people from marginalised communities, including through the implementation of the Youth GuaranteeV.104Self-employment, entrepreneurship and business creation including innovative micro, small and medium sized enterprisesV.105Equality between men and women in all areas, including in access to employment, career progression, reconciliation of work and private life and promotion of equal pay for equal workV.106Adaptation of workers, enterprises and entrepreneurs to changeV.107Active and healthy ageingV.108Modernisation of labour market institutions, such as public and private employment services, and improving the matching of labour market needs, including throughactions that enhance transnational labour mobility as well as through mobility schemes and better cooperation between institutions and relevant stakeholdersVI.109Active inclusion, including with a view to promoting equal opportunities and active participation, and improving employabilityVI.110Socio-economic integration of marginalised communities such as the RomaVI.111Combating all forms of discrimination and promoting equal opportunitiesVI.112Enhancing access to affordable, sustainable and high-quality services, including health care and social services of general interestVI.113Promoting social entrepreneurship and vocational integration in social enterprises and the social and solidarity economy in order to facilitate access to employmentVI.114Community-led local development strategiesVII.115Reducing and preventing early school-leaving and promoting equal access to good quality early-childhood, primary and secondary education including formal, non-formal and informal learning pathways for reintegrating into education and trainingVII.116Improving the quality and efficiency of, and access to, tertiary and equivalent education with a view to increasing participation and attainment levels, especially for disadvantaged groupsVII.117Enhancing equal access to lifelong learning for all age groups in formal, non-formal and informal settings, upgrading the knowledge, skills and competences of the workforce, and promoting flexible learning pathways including through career guidance and validation of acquired competencesVII.118Improving the labour market relevance of education and training systems, facilitating the transition from education to work, and strengthening vocational education and training systems and their quality, including through mechanisms for skills anticipation, adaptation of curricula and the establishment and development of work-based learning systems, including dual learning systems and apprenticeship schemesVIII.119Investment in institutional capacity and in the efficiency of public administrations and public services at the national, regional and local levels with a view to reforms, better regulation and good governanceVIII.120Capacity building for all stakeholders delivering education, lifelong learning, training and employment and social policies, including through sectoral and territorial pacts to mobilise for reform at the national, regional and local levelsIX.121Preparation, implementation, monitoring and inspectionIX.122Evaluation and studiesIX.123Information and communication 
 
Annex 14.3 

216 

AreaSub-areasActivities in research centresRTDI infrastructureAssistance to RTDI activities in firmsTechno transferHuman potentialStrengthening research, technological development and innovationAreaSub-areasInfrastructureServices for citizensServices to SMEsInvestment for cooperationEnhancing accessibility to and use and quality of information and communication technologiesAreaSub-areasRenewable energy: windRenewable energy: solarRenewable energy: biomassOther renewableEnergy efficiencyUrban transportTracksSupport low carbon economyAssistance for envi-friendly prodGreenhouse emissionsAir qualityPollutionWasteWaterWater treatmentRehabilitationBiodiversity/NatureNatural assetsClimate changeRisk preventionSupporting the shift towards a low-carbon economy in all sectorsPreserving and protectiong the environment and promoting resource efficiencyPromoting climate change adaptation, risk prevention and managementAreaSub-areasRailwaysRailways TEN-TMobile rail assetsRoadsMotorwaysTEN-T motorways and roadsMultimodalMultimodal TEN-TAirportsAirports TEN-TSeaportsSeaports TEN-TInland waterways and portsInland waterways and ports TEN-TIntelligence transportElectricityElectricity TEN-ENatural gasNatural gas TEN-EPetroleumPetroleum TEN-EPromoting sustainable transport and removing bottlenecks in key network infrastructuresAreaSub-areasAdaptation to changeLabour marketAccess to employmentSelf-employmentAgeingPromoting sustainable and quality employment and supporting labour mobility 
 
 
 
 
 
217 

AreaSub-areasDiscriminationActive inclusionMarginalised communitiesHealth infrastructureChildcare infrastructureHousing infrastructureOthe social infrastructureAccess to servicesSocial enterprisesDevelopment/regenerationOtherPromoting social inclusion, combating poverty and any discriminationAreaSub-areasServices to firmsEnhancing competitiveness of  enterprisesInvestment in firmsAreaSub-areasCultureTourismCulture and tourism 
 
 
 
 
 
 
 
Annex 14.4 

218 

AreaIntervention fieldSub-areasIntervention fieldIV.060Research and innovation activities in public research centres and centres of competence including networkingActivities in research centresIV.061Research and innovation activities in private research centres including networkingActivities in research centresIV.058Research and innovation infrastructure (public)RTDI infrastructureIV.059Research and innovation infrastructure (private, including science parks)RTDI infrastructureIV.062Technology transfer and university-enterprise cooperation primarily benefiting SMEsTechno transferIV.063Cluster support and business networks primarily benefiting SMEsTechno transferAssistance to RTDI activities in firmsCOH-TH04Assistance to R&TD, particularly in SMEs (including access to R&TD services in research centres)Assistance to RTDI activities in firmsCOH-TH09Other measures to stimulate research and innovation and entrepreneurship in SMEsIV.056Investment in infrastructure, capacities and equipment in SMEs directly linked to research and innovation activitiesAssistance to RTDI activities in firmsIV.057Investment in infrastructure, capacities and equipment in large companies directly linked to research and innovation activitiesAssistance to RTDI activities in firmsI.002Research and innovation processes in large enterprisesAssistance to RTDI activities in firmsHuman potentialCOH-TH74Developing human potential in the field of research and innovation, in particular through post-graduate studies and training of researchers, and networking activities between universities, research centres and businessesII.045ICT: Backbone/backhaul networkInfrastructureII.046ICT: High-speed broadband network (access/local loop; >/= 30 Mbps)InfrastructureII.047ICT: Very high-speed broadband network (access/local loop; >/= 100 Mbps)InfrastructureInfrastructureCOH-TH11Information and communication technologies (access, security, interoperability, risk-prevention, research, innovation, e-content, etc.)InfrastructureCOH-TH12Information and communication technologies (TEN-ICT)IV.078e-Government services and applications (including e-Procurement, ICT measures supporting the reform of public administration, cyber-security, trust and privacy measures, e-Justice and e-Democracy)Services for citizensIV.079Access to public sector information (including  open data e-Culture, digital libraries, e-Content and e-Tourism)Services for citizensIV.080e-Inclusion, e-Accessibility, e-Learning and e-Education services and applications, digital literacyServices for citizensIV.081ICT solutions addressing the healthy active ageing challenge and e-Health services and applications (including e-Care and ambient assisted living)Services for citizensServices to SMEsCOH-TH14Services and applications for SMEs (e-commerce, education and training, networking, etc.)Services to SMEsCOH-TH15Other measures for improving access to and efficient use of ICT by SMEsI.004Productive investment linked to the cooperation between large enterprises and SMEs for developing information and communication technology(‘ICT’) products and services, e-commerce and enhancing demand for ICTInvestment for cooperationResearch and innovation processes in SMEs (including voucher schemes, process, design, service and social innovation)IV.064COH-TH07II.048ICT: Other types of ICT infrastructure/large-scale computer resources/equipment (including e-infrastructure, data centres and sensors; also where embedded in other infrastructure such as research facilities, environmental and social infrastructure)COH-TH10COH-TH13R&TD activities in research centresR&TD infrastructure and centres of competence in a specific technologyTechnology transfer and improvement of cooperation networks ...Strengthening research, technological development and innovationInvestment in firms directly linked to research and innovation (...)COH-TH01COH-TH02COH-TH03Telephone infrastructures (including broadband networks)Services and applications for citizens (e-health, e-government, e-learning, e-inclusion, etc.)Enhancing accessibility to and use and quality of information and communication technologiesICT Services and applications for SMEs (including e-Commerce, e-Business and networked business processes), living labs, web entrepreneurs and ICT start-upsIV.082 
 
 
 
219 

II.009Renewable energy: windRenewable energy: windCOH-TH39Renewable energy: windII.010Renewable energy: solarRenewable energy: solarCOH-TH40Renewable energy: solarII.011Renewable energy: biomassRenewable energy: biomassCOH-TH41Renewable energy: biomassII.012Other renewable energy (including hydroelectric, geothermal and marine energy) and renewable energy integration (including storage, power to gas and renewable hydrogen infrastructure)Other renewableCOH-TH42Renewable energy: hydroelectric, geothermal and otherII.013Energy efficiency renovation of public infrastructure, demonstration projects and supporting measuresEnergy efficiencyII.014Energy efficiency renovation of existing housing stock, demonstration projects and supporting measuresEnergy efficiencyII.015Intelligent Energy Distribution Systems at medium and low voltage levels (including smart grids and ICT systems)Energy efficiencyII.016High efficiency co-generation and district heatingEnergy efficiencyIV.068Energy efficiency and demonstration projects in SMEs and supporting measuresEnergy efficiencyIV.070Promotion of energy efficiency in large enterprisesEnergy efficiencyUrban transportCOH-TH52Promotion of clean urban transportUrban transportCOH-TH25Urban transportIV.090Cycle tracks and footpathsTracksCOH-TH24Cycle tracksIV.065Research and innovation processes, technology transfer and cooperation in enterprises focusing on the low carbon economy and to resilience to climate changeSupport low carbon economyIV.071Development and promotion of enterprises specialised in providing services contributing to the low carbon economy and to resilience to climate change (including support to such services)Support low carbon economyI.003Productive investment in large enterprises linked to the low-carbon economySupport low carbon economyIV.087Adaptation to climate change measures and prevention and management of climate related risks e.g. erosion, fires, flooding, storms and drought, including awareness raising, civil protection and disaster management systems and infrastructuresClimate changeCOH-TH49Mitigation and adaptation to climate changeCOH-TH54Other measures to preserve the environment and prevent risksII.023Environmental measures aimed at reducing and / or avoiding greenhouse gas emissions (including treatment and storage of methane gas and composting)Greenhouse gasIV.069Support to environmentally-friendly production processes and resource efficiency in SMEsAssistance for envi-friendly prodCOH-TH06Assistance to SMEs for the promotion of environmentally-friendly products and production processes (...)IV.083Air quality measuresAir qualityCOH-TH47Air qualityIV.084Integrated pollution prevention and control (IPPC)PollutionCOH-TH48Integrated prevention and pollution controlII.017Household waste management,  (including minimisation, sorting, recycling measures)WasteII.018Household waste management, (including mechanical biological treatment, thermal treatment, incineration and landfill measures)WasteII.019Commercial, industrial or hazardous waste managementWasteII.020Provision of water for human consumption (extraction, treatment, storage and distribution infrastructure)WaterCOH-TH45Management and distribution of water (drink water)II.021Water management and drinking water conservation (including river basin management, water supply, specific climate change adaptation measures, district and consumer metering, charging systems and leak reduction)WaterII.022Waste water treatmentWater treatmentCOH-TH46Water treatment (waste water)IV.089Rehabilitation of industrial sites and contaminated landRehabilitationCOH-TH50Rehabilitation of industrial sites and contaminated landIV.085Protection and enhancement of biodiversity, nature protection and green infrastructureBiodiversity/NatureIV.086Protection, restoration and sustainable use of Natura 2000 sitesBiodiversity/NatureIV.091Development and promotion of the tourism potential of natural areasNatural assetsCOH-TH55Promotion of natural assetsNatural assetsCOH-TH56Protection and development of natural heritageClean urban transport infrastructure and promotion (including equipment and rolling stock)II.043Management of household and industrial wastePreserving and protectiong the environment and promoting resource efficiencyIV.088Promoting climate change adaptation, risk prevention and managementSupporting the shift towards a low-carbon economy in all sectorsEnergy efficiency, co-generation, energy managementRisk prevention (including the drafting and implementation of plans and measures to prevent and manage natural and technological risks)Promotion of biodiversity and nature protection (including Natura 2000)COH-TH44COH-TH51COH-TH43COH-TH53Risk prevention and management of non-climate related natural risks (i.e. earthquakes) and risks linked to human activities (e.g. technological accidents), including awareness raising, civil protection and disaster management systems and infrastructuresRisk prevention 
 
 
 
220 

II.026Other RailwaysRailways no TENCOH-TH16RailwaysII.024Railways (TEN-T Core)Railways TEN-TII.025Railways (TEN-T comprehensive)Railways TEN-TMobile rail assets? / Mobile rail assets no TENCOH-TH18Mobile rail assetsMobile rail assets?/Mobile rail assets TEN-TCOH-TH19Mobile rail assets (TEN-T)Roads no TEN/Motorways no TENCOH-TH20MotorwaysRoads no TENCOH-TH22National roadsII.028TEN-T motorways and roads — core network (new build)TEN-T motorways and roadsII.029TEN-T motorways and roads — comprehensive network (new build)TEN-T motorways and roadsII.033TEN-T reconstructed or improved roadTEN-T motorways and roadsII.030Secondary road links to TEN-T road network and nodes (new build)Roads no TENCOH-TH22National roadsII.032Local access roads (new build)Roads no TENII.034Other reconstructed or improved road (motorway, national, regional or local)Motorways and road no TEN/Roads no TENII.036Multimodal transportMultimodal no TENCOH-TH26Multimodal transportII.035Multimodal transport (TEN-T)Multimodal TEN-TCOH-TH27Multimodal transport (TEN-T)II.037Airports (TEN-T)Airports TEN-T/Airports?II.038Other airports1Airports no TEN / Airports?II.039Seaports (TEN-T)Seaports TEN-T/Seaports?II.040Other seaportsSeaports no TEN / Seaports?II.042Inland waterways and ports (regional and local)Inland waterways and ports no TENCOH-TH31Inland waterways (regional and local)II.041Inland waterways and ports (TEN-T)Inland waterways and ports TEN-TCOH-TH32Inland waterways (TEN-T)II.044Intelligent transport systems (including the introduction of demand management, tolling systems, IT monitoring control and information systems)Intelligence transportCOH-TH28Intelligent transport systemsII.005Electricity (storage and transmission)Electricity no TENCOH-TH33ElectricityII.006Electricity (TEN-E storage and transmission)Electricity TEN-ECOH-TH34Electricity (TEN-E)II.007Natural gasNatural gas no TENCOH-TH35Natural gasII.008Natural gas (TEN-E)Natural gas TEN-ECOH-TH36Natural gas (TEN-E)PetroleumCOH-TH37Petroleum productsPetroleumCOH-TH38Petroleum products (TEN-E)Mobile rail assetsOther national and regional roads (new build)Railways (TEN-T)Motorways (TEN-T)Regional/local roadsAirportsPortsCOH-TH30Promoting sustainable transport and removing bottlenecks in key network infrastructuresII.027COH-TH29COH-TH17II.031COH-TH21COH-TH23 
 
 
221 

Adaptation to changeCOH-TH63Design and dissemination of innovative and more productive ways of organising workAdaptation to changeCOH-TH64Development of specific services for employment, training and support in connection with restructuring of sectors and firms, and development of systems for anticipating economic changes and future requirements in terms of jobs and skillsAdaptation to changeCOH-TH62Development of special services for employment, training and support in connection with restructuring of sectors ...IV.117Enhancing equal access to lifelong learning for all age groups in formal, non-formal and informal settings, upgrading the knowledge, skills and competences of the workforce, and promoting flexible learning pathways including through career guidance and validation of acquired competencesAdaptation to changeIV.108Modernisation of labour market institutions,  such as public and private employment services, and improving the matching of labour market needs, including throughactions that enhance transnational labour mobility as well as through mobility schemes and better cooperation between institutions and relevant stakeholdersLabour marketCOH-TH65Modernisation and strengthening labour market institutionsIV.102Access to employment for job-seekers and inactive people, including the long-term unemployed and people far from the labour market, also through local employment initiatives and support for labour mobilityAccess to employmentIV.103Sustainable integration into the labour market of young people, in particular those not in employment, education or training, including young people at risk of social exclusion and young people from marginalised communities, including through the implementation of the Youth GuaranteeAccess to employmentIV.118Improving the labour market relevance of education and training systems, facilitating the transition from education to work, and strengthening vocational education and training systems and their quality, including through mechanisms for skills anticipation, adaptation of curricula and the establishment and development of work-based learning systems, including dual learning systems and apprenticeship schemesAccess to employmentCOH-TH72Design, introduction and implementing of reforms in education and training systems ...IV.105Equality between men and women in all areas, including in access to employment, career progression,  reconciliation of work and private life and  promotion of equal pay for equal workAccess to employmentCOH-TH69Measures to improve access to employment and increase sustainable participation and progress of women ...IV.107Active and healthy ageingAgeingCOH-TH67Measures encouraging active ageing and prolonging working livesIV.104Self-employment, entrepreneurship and business creation including innovative micro, small and medium sized enterprisesSelf-employmentCOH-TH68Support for self-employment and business start-upPromoting sustainable and quality employment and supporting labour mobilityCOH-TH66Implementing active and preventive measures on the labour marketIV.106Adaptation of workers, enterprises and entrepreneurs to change 
 
222 

IV.111Combating all forms of discrimination and promoting equal opportunitiesDiscriminationCOH-TH70Specific action to increase migrants' participation in employment ...IV.109Active inclusion, including with a view to promoting equal opportunities and active participation, and improving employabilityActive inclusionCOH-TH71Pathways to integration and re-entry into employment for disadvantaged people ...III.053Health infrastructureHealth infrastructureCOH-TH76Health infrastructureIII.052Infrastructure for early childhood education and careChildcare infrastructureCOH-TH77Childcare infrastructureIII.054Housing infrastructureHousing infrastructureCOH-TH78Housing infrastructureIII.055Other social infrastructure contributing to regional and local developmentSocial infrastructureCOH-TH79Other social infrastructureIV.073Support to social enterprises (SMEs)Social enterprisesIV.113Promoting social entrepreneurship and vocational integration in social enterprises and the social and solidarity economy in order to facilitate access to employmentSocial enterprisesIV.110Socio-economic integration of marginalised communities such as the RomaMarginalised communitiesIV.112Enhancing access to affordable, sustainable and high-quality services, including health care and social services of general interestAccess to servicesIV.097Community-led local development initiatives in urban and rural areasDevelopment/regenerationDevelopment/regenerationCOH-TH61Integrated projects for urban and rural regenerationIV.114Community-led local development strategiesDevelopment/regenerationIV.101Cross-financing under the ERDF (support to ESF-type actions necessary for the satisfactory implementation of the ERDF part of the operation and directly linked to it)OtherIV.115Reducing and preventing early school-leaving and promoting equal access to good quality early-childhood, primary and secondary education including formal, non-formal and informal learning pathways for reintegrating into education and trainingEducationIV.116Improving the quality and efficiency of, and access to, tertiary and equivalent education with a view to increasing participation and attainment levels, especially for disadvantaged groupsEducationIII.049Education infrastructure for tertiary educationEducationIII.050Education infrastructure for vocational education and training and adult learningEducationIII.051Education infrastructure for school education (primary and general secondary education)EducationPromoting social inclusion, combating poverty and any discriminationInvestment in education, training and vocational training for skills and lifelong learningCOH-TH73Measures to increase participation in education and training throughut the life-cycle ...COH-TH75Education infrastructure 
 
223 

IV.120Capacity building for all stakeholders delivering education, lifelong learning, training and employment and social policies, including through sectoral and territorial pacts to mobilise for reform at the national, regional and local levelsInstitutional capacityCOH-TH80Promoting the partnerships, pacts and initiatives through the networking of relevant stakeholdersIV.119Investment in institutional capacity and in the efficiency of public administrations and public services at the national, regional and local levels with a view to reforms, better regulation and good governanceInstitutional capacityCOH-TH81Mechanisms for improving good policy and programme design, monitoring and evaluation ...IV.096Institutional capacity of public administrations and public services related to implementation of the ERDF or actions supporting ESF institutional capacity initiativesInstitutional capacityIV.121Preparation, implementation, monitoring and inspectionTechnical assistanceCOH-TH85Preparation, implementation, monitoring and inspectionIV.122Evaluation and studiesTechnical assistanceCOH-TH85Preparation, implementation, monitoring and inspectionIV.123Information and communicationTechnical assistanceCOH-TH86Evaluation and studies; information and communicationIV.098Outermost regions: compensation of any additional costs due to accessibility deficit and territorial fragmentationOutermost regionsCOH-TH82Compensation of any additional costs due to accessibility deficit and territorial fragmentationIV.099Outermost regions: specific action to compensate additional costs due to size market factorsOutermost regionsCOH-TH83Specific action addressed to compensate additional costs due to size market factorsIV.100Outermost regions: support to compensate additional costs due to climate conditions and relief difficultiesOutermost regionsCOH-TH84Support to compensate additional costs due to climate conditions and relief difficultiesIV.066Advanced support services for SMEs and groups of SMEs (including management, marketing and design services)Services to firmsIV.067SME business development, support to entrepreneurship and incubation (including support to spin offs and spin outs)Services to firmsI.001Generic productive investment in small and medium –sized enterprises (‘SMEs’)Investment in firmsIV.072Business infrastructure for SMEs (including industrial parks and sites)Investment in firmsCultureCOH-TH59Development of cultural infrastructureCultureIV.076Development and promotion of cultural and creative assets in SMEsCultureIV.095Development and promotion of public cultural and heritage servicesCultureIV.077Development and promotion of cultural and creative services in or for SMEsCultureIV.093Development and promotion of public tourism servicesTourismIV.075Development and promotion of tourism services in or for SMEsTourismIV.074Development and promotion of tourism assets in SMEsTourismIV.092Protection, development and promotion of public tourism assetsTourismOther investment in firmsTechnical AssistanceOutermost RegionsCulture and tourismEnhancing competitiveness of  enterprisesCOH-TH57IV.094Protection, development and promotion of public cultural and heritage assetsCOH-TH58Protection and preservation of the cultural heritageCOH-TH60Other assistance to improve cultural servicesOther assistance to improve tourist servicesEnhancing institutional capacity of public authorities and stakeholders and an efficient public administrationCOH-TH05Advanced support services for firms and groups of firmsCOH-TH08 
 
 
ANNEX 15 

Abbrevations 

SA: Support to agriculture 

RD: Rural development 

SA/RD: Support to agriculture/ rural development 

GUID: European Agricultural Guarantee and Guidance Fund – Section Guidance 

EFF: European Fisheries Fund 

EMFF: European Maritime and Fisheries Fund 

CF: Cohesion Fund 

ERDF: European Regional Development Fund 

ESF: European Social Fund 

AMIF: Asylum, Migration and Integration Fund 

YEI: Youth Employment Initiative 

HRD: pre-accession, Human Resources Development component 

IPARD: Instrument for Pre-Accession Assistance in Rural Development 

PHARE: Pre-accession assistance programme 

REGD: pre-accession, Regional Development component 

TAIB: Transition Assistance and Institution Building 

TIPAA: Turkey Instrument for Pre-accession Assistance 

CBC: pre-accession, Cross-Border Cooperation component 

224 

 
 
 
 
225 

COUNTRIESSARDSA/RD or unclear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nnex to the Statistical Evaluation -Irregularities reported by Member States and Beneficiary Countries in 2021The number of irregularities reported measures the results of Member States’ work to counter fraud and other illegal activities affecting the EU’s financial interests. Therefore, the figures should not be interpreted as indicating the level of fraud in the Countries’ territories.FUNDS/TYPE OF EXPENDITURE 
 
 
226 

COUNTRIESSARDSA/RD or unclearEFFEMFFCFERDFESFAMIFFEADISFYEICBC-IPAIPARDREGDTAIBCBC-ENIPHAREAT1,183,09761,3950000424,49969,3470000000000BE233,108462,9530000359,96244,58300025,220000000BG309,54914,834,0410104,1371,417,72511,592,17314,082,1821,403,156039,7460088,78400000CY00000050330,3350000000000CZ263,555802,6610006,376,89826,720,8502,146,8140019,0500000000DE953,889825,6070027,09106,621,5051,622,03436,769351,77800000000DK70,8163,211,5040000136,08000000000000EE04,187,96900339,992655,7558,767,104353,94500172,8600000035,5270ES7,397,89710,972,6290057,67605,007,0248,178,96937,84800811,004000000FI11,538349,43511,938025,350054,57863,8580000000000FR3,061,0862,147,54500540,42807,034,8981,726,6970599,398082,582000000GR8,499,6612,911,90000199,8565,376,2236,417,578130,361,1670118,8830554,941000000HR1,497,7381,328,288001,625,1984,277,746360,107241,2750000063,1960000HU1,467,6247,565,8640978,847267,95469,468,68132,858,2433,638,8080000000000IE000000020,0820000000000IT7,715,27511,526,7601,729,31144,7800015,510,1022,203,0680000000000LT225,5581,470,67736,264034,563335,5256,141,602231,300000274,668000000LU00000014,25900000000000LV86,961924,5950058,7891,638,77817,487,462124,1820000000000MT0687,278000520,976069,47884,7200225,0000000000NL110,737250,1240000128,242151,0250000000000PL78,434,0539,097,4180119,057158,1774,407,64278,703,10719,697,9610656,51500000000PT1,794,2498,946,61137,46601,442,258906,86434,396,1244,726,5950000000000RO6,999,12326,192,4090535,044319,006122,707,9691,376,406,19113,420,9740133,9700017,35600014,220456,901SE76,455397,79922,203000236,62969,44224,424045,6250000000SI44,786213,5820000987,863290,3110000000000SK64,5271,821,593496,361324,82610,773221,284,104105,578,36743,475,3030000000000UK377,5571,848,26100009,061,9491,295,1580000000000AL00000000000005,46401,57900ME0000000000000324,5480000MK000000000000034,0621,09369,74100RS000000000000211,301124,1730192,84300TR00000000000003,621,3857,905827,16400TOTAL120,878,839113,038,8982,333,5432,106,6916,524,836449,549,3341,753,497,010235,655,867183,7611,900,290462,5351,748,415317,4414,172,8288,9981,091,32749,747456,901FUNDS/TYPE OF EXPENDITUREAnnex to the Statistical Evaluation - Irregular amounts related to irregularities reported by Member States and Beneficiary Countries in 2021