COMMISSION STAFF WORKING DOCUMENT Action Plan - 2023 revision Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE, THE COMMITTEE OF THE REGIONS AND THE COURT OF AUDITORS Commission Anti-Fraud Strategy Action Plan - 2023 revision
Date: 2023-07-11
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU budget, EU control, EU strategy, administrative check, digitisation, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 11.7.2023  SWD(2023) 245 final  COMMISSION STAFF WORKING DOCUMENT Action Plan - 2023 revision Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE, THE COMMITTEE OF THE REGIONS AND THE COURT OF AUDITORS Commission Anti-Fraud Strategy Action Plan - 2023 revision {COM(2023) 405 final}  
 
 
Commission Anti-Fraud Strategy Action Plan (revised July 2023) 

2 

3 

1.  Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
1 

Further develop, promote and increase the use of the current Arachne system in the Commission and in Member States 
notably  by  increasing  user-friendliness  and  exploring  possibilities  for  interoperability  and  synergies  with  other 
corporate IT tools as well as national databases. 

Continue developing the envisaged single integrated IT system (corporate Arachne) for data mining and risk scoring, 
in line with the Interinstitutional Agreement and the RRF Regulation1, with a view to extend its use to all Member 
States and to all management modes. 

Due date 
2023 and 
continuous 

2023 and 
continuous 

Lead service 
DAC, EMPL: lead 
Shared management 
DGs, JRC: support 

BUDG, DAC, 
EMPL: lead 
Spending DGs, 
OLAF, DIGIT, JRC: 
support 

Further develop and increase use of EDES in the Commission and in Member States based on user feedback, in view 
of its possible extension to shared management, notably by: 

BUDG 

2023 and 
continuous 

a. 

increasing the user-friendliness of the database; 

b.  exploring  possibilities  for  interoperability  and  synergies  with  other  corporate  IT  tools  as  well  as  national 

databases;  

c.  enhancing dialogue on EDES among Commission departments and Executive agencies, other EU institutions, 

Member States and implementing partners. 

4 

Explore the possibility to strengthen the anti-fraud functionalities in SUMMA, notably by: 

a.  considering the creation of a dashboard on unusual patterns in transactions to detect potential irregularities 

and provide analysis to DGs; 

BUDG: lead 
OLAF, spending 
DGs: support 

2025 

1 Regulation (EU) 2021/241. 

1 

 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Nr  Action 

b.  considering,  after  the  SUMMA  go-live,  a  screening  of  other  databases  such  as  Arachne  and  commercial 
databases via the SUMMA Business Partner Integrity Screening, similar to the envisaged screening of EDES 
and the Financial Sanctions Database, and exploring if and how these anti-fraud functionalities could be used 
in the Commission and beyond; 

c.  considering additional controls of business partners (legal entities). 

Increase  the  user-friendliness  of  the  Irregularity  Management  System  (IMS)  for  Member  States  authorities  and 
relevant Commission staff, the use of the system and therefore the completeness and accuracy of the data in the system, 
notably by: 

a.  upgrading the system technically; 
b.  exploring  the  possibilities  for  interoperability  with  other  Commission  and  national  systems  dedicated  to 

protecting the EU’s financial interests. 

Lead service 
BUDG: lead 
DAC, EMPL: 
support 

BUDG 

OLAF 

Due date 
2025 

2025 

2023 and 
continuous 

Explore options to improve the efficiency and accuracy of financial and administrative monitoring of follow-up of 
OLAF cases, notably by increasing data interaction possibilities between OLAF and Commission  departments and 
where appropriate monitoring of the follow-up of EPPO cases based on information received from the EPPO.  

OLAF, SG, BUDG 

2024 

Explore options to improve internal communication on cases of fraud and irregularities by: 

a.  exploring  the  possibilities  of  developing  IT  solutions  for  communication  between  OLAF,  Commission 
departments and Executive agencies along the full life cycle of a case - from communicating suspicions of 
fraud to OLAF, through selection and investigation, to follow-up and monitoring (including on information 
received from the EPPO, where appropriate) - to make such communication more regular and efficient, while 
respecting the confidentiality of investigations; 

OLAF: lead 
SG: support 

b.  updating  Commission  departments  and  Executive  agencies  bilaterally,  as  well  as  the  Secretariat-General 

OLAF 

where appropriate, on the status of OLAF cases every six months in the meantime 

Set  up  a  working  group  to  explore  available  and  possible  future  options  for  strengthening  digital  control  against 
plagiarism, also for 'external' plagiarism comparing not only documents prepared for the Commission but also other 
documents. 

OLAF: lead 
All DGs: support 

Develop a matrix of risk indicators in GETI (Get Intelligence system) to contribute to fraud prevention and to pro-
actively identify high risk projects and entities, targeting aspects such as unusual behaviour, financial information and 
contractual patterns. 

OLAF 

10  Set up a working group to explore available and possible future options for strengthening digital control of external 
service providers and experts, notably checking that they do not claim reimbursement for the same hours from several 
sources. 

OLAF: lead 
All DGs: support 

5 

6 

7 

8 

9 

2025 

2024 

2024 

2026 

2024 

2 

 
 
 
 
 
 
 
 
 
 
 
Nr  Action 
11  Further strengthen the Commission's IT and information security to respond quickly and effectively to evolving cyber-

security threats, including the threat of cyber-fraud, and minimise potential impacts, notably by:  

a.  regularly revising the IT security strategy and, as applicable, the IT security plans based on comprehensive 

risk assessments that take the possibility of cyber-fraud into account; 

b.  ensuring  close  cooperation  on  information  security  between  EU  institutions  and  bodies,  notably  on 

investigations of leaks of information, on common rules and tools to securely exchange information. 

12  Encourage Member States, notably through available funding programmes, to digitalise as appropriate fraud 

prevention, detection and investigation by supporting the development and use of IT tools for data collection and 
analysis using advanced data mining, machine learning technologies and forensics, as well as the exploration of 
emerging technologies such as artificial intelligence, block chain technology and biometrics.  

Lead service 

Due date 

DIGIT: lead strategy 
All DGs: lead plans 
OLAF: support 
HR: lead 
OLAF: support 

All DGs providing 
such funding 

2023 and 
continuous 

2023 and 
continuous 

2023 and 
continuous 

3 

 
 
 
 
 
 
 
 
 
2.  Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds  

Nr  Action 
13 

Further improve the prevention and detection of fraud to the RRF, notably by: 

a.  developing risk indicators on fraud, corruption, conflict of interest and double funding, for the purposes of 
auditing and identifying potential cases to be transmitted to OLAF for possible investigation or transmission 
to the EPPO; 

b.  carrying  out  system  audits  on  the  protection  of  the  EU's  financial  interests  focusing  on  high-risk  areas 

identified in risk assessments; 

c.  continuing anti-fraud awareness raising and training; 

d.  encouraging Member States to make use of IMS to report irregularities related to the RRF in line with an ECA 

recommendation. 

Encourage  Member  States  to  put  in  place  effective  and  proportionate  anti-fraud  measures,  such  as  strategies  at 
national, plan, programme or authority level and, as applicable, provide guidance and support in this respect. 

Lead service 
ECFIN: lead 
OLAF: support 

Due date 
2023 and 
continuous 

ECFIN, shared 
management DGs 
and OLAF  

Provide, as relevant, regular training, awareness raising and exchanges of best practice examples with Member State 
authorities, either dedicated to or including as an important element anti-fraud matters, such as prevention, detection 
and handling of irregularities, as well as reporting in the IMS. 

ECFIN, shared 
management DGs 
and OLAF 

Promote  sharing  of  best  practice  and  provide  guidance  for  Member  States  on  preventing,  detecting,  handling  and 
reporting conflict of interest situations. 

BUDG: lead 
ECFIN, shared 
management DGs: 
support 

17 

Promote and support the use of IMS by Commission auditors for fraud risk assessment purposes, notably by providing 
training. 

OLAF 

18  Verify, as relevant, that the work done by audit authorities and certification bodies includes checking on the existence 
of  adequate  procedures  for  timely  and  accurate  reporting  of  detected  irregularities,  their  handling,  follow-up  and 
transmission  of  information  to  the  competent  investigative  bodies.  This  might  include  cases  where  the  irregular 
expenditure  is  withdrawn  from  EU  funding  or,  in  the  case  of  the  RRF,  corrected  and  recovered  from  the  final 
recipients.  

ECFIN, shared 
management DGs 

14 

15 

16 

2023 and 
continuous 

2023 and 
continuous 

2024 and 
continuous 

2023 and 
continuous 

2023 and 
continuous 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Nr  Action 
19 

Support Member State authorities to improve the quantity and quality of irregularity reporting to the Commission via 
the IMS, notably by: 

a. 

 developing and updating guidance on reporting, for example, the IMS handbook, including on issues related 
to conflicts of interest; 

b.  reminding  Member  State  authorities  in  the  communication  on  the  outcome  of  a  Commission  audit  or  an 
investigation on the obligation to report in IMS irregularities above the threshold, also when identified during 
a Commission audit or an investigation, and to confirm explicitly their reporting of those irregularities to allow 
for their exact identification. 

Lead service 

Due date 

OLAF: lead 
Shared management 
DGs: support 
Shared management 
DGs: lead 
OLAF: support 

2024 

2023 and 
continuous 

5 

 
 
 
 
 
 
 
 
 
 
3.  Reinforce the protection of funds under indirect management and in the external relations area 

Nr  Action 
20  Develop a joint ethics and anti-fraud training plan with the EEAS, to ensure that specialised training is delivered 

consistently for targeted groups of staff notably in the Representations, Delegations and Missions. 

21  Raise awareness of pillar-assessed partners in the field of external action on their obligation to notify the Commission 

of cases of detected irregularities, fraud and exclusion situations, notably by: 

a.  providing the partners with guidance on the information to be shared with the Commission when notifying 

cases; 

b. 

 inviting OLAF to participate in relevant meetings with major recipients of EU funding. 

22  Develop common lines of action with the EEAS to reduce the risks associated with local agents who remain in the 

same post for a long period of time in the Delegations. 

Lead service 
External action DGs: 
lead 
OLAF, HR: support 

Due date 
2024 

INTPA: lead 
External action DGs, 
OLAF, BUDG: 
support 

External action DGs: 
lead 
OLAF: support 

2024 

2023 and 
continuous 

External action DGs: 
lead 
OLAF, HR: support 

2024 

23 

Improve the use of IMS in candidate countries, notably by: 

a.  developing guidance on irregularity reporting in IMS; 

b.  providing training to relevant national authorities; 

OLAF: lead 
NEAR: support 

OLAF: lead 
NEAR: support 

c.  raising awareness among relevant authorities on the need to report irregularities in IMS in a complete and 

NEAR, OLAF 

correct manner. 

24  Develop guidance and exchange of best practice on addressing the risks to spending in emergency situations (follow-

up to 2019 CAFS action 29), focusing on conflict of interest. 

ECHO, FPI, HOME: 
lead 
OLAF, BUDG: 
support 

2024 

2023 and 
continuous 

2024 and 
continuous  

2024 

6 

 
 
 
 
 
 
 
 
 
 
 
 
Nr  Action 
25  Cooperate with Ukraine authorities, international donors and their anti-fraud services to protect EU funding from 

Lead service 
OLAF  

fraud and corruption, notably by: 

Due date 
2023 and 
continuous  

a.  strengthening national anti-fraud structures through capacity building, in particular by: 

i. 

ii. 

providing targeted anti-fraud support to national authorities, e.g. through training and exchange of 
expertise; 
supporting accession to the Union Anti-Fraud Programme; 

b.  collaborating on possible cases affecting the EU’s financial interests, including through exchange of 

information. 

7 

 
 
 
 
 
 
 
4.  Reinforce the EU's capacity to fight customs fraud and protect EU revenues 

Nr  Action 
26 

Strengthen the Commission’s and Member States’ analytical capacities in the customs anti-fraud area by developing 
data analysis tools and increasing exchange of and access to relevant data for anti-fraud purposes, to improve the 
prevention and detection of customs fraud. 

27 

Ensure effective complementarity between customs risk management and anti-fraud activities, notably by: 

a.  strengthening data sharing in the Customs Risk Management System; 

Lead service 
OLAF, JRC, 
TAXUD, BUDG: 
lead 

TAXUD: lead 
OLAF, BUDG: 
support 

Due date 
2023 and 
continuous 

2024 

b.  developing and better defining risk indicators related to anti-dumping and undervaluation in the new 

Financial Risk Criteria Decision; 

c.  developing new common risk criteria for intellectual property rights at import. 

28   Define an anti-fraud strategy for new own resources and identify and implement mitigating measures on fraud risks 
concerning  the  Carbon  Border  Adjustment  Mechanism,  the  EU  Emissions  Trading  System  and  other  new  own 
resources. 

OLAF, BUDG, 
TAXUD, CLIMA 

29  Minimise the potential fraud risks associated with the EU Emissions Trading System (ETS), notably by: 

a. 

implementing and enhancing security measures; 

b.  exploring alternative operating models for the ETS Union Registry, and  conducting an in-depth feasibility 

assessment and cost–benefit analysis to inform the decision on a potentially new operating model. 

CLIMA 

CLIMA: lead 
SG, BUDG, DIGIT,  
TAXUD: support 

Within two 
years of 
adoption 

2023 and 
continuous 
2024 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.  Reinforce the EU anti-fraud architecture 

Nr  Action 
30 

Ensure effective cooperation between the Commission and the European Public Prosecutor’s Office (EPPO), notably 
by: 

a.  providing guidance to Commission departments and Executive agencies; 

Lead service 

Due date 

Central services as 
appropriate  

b.  establishing Commission wide cooperation on EDES and on the application of the Conditionality Regulation;  BUDG 

c.  assessing potential compliance issues with the Member States’ transposition and implementation of the PIF 

Directive. 

31 

Strengthen  the  support  to Decentralised  agencies  and  Joint  Undertakings2  in  their  effort  to  fight  fraud,  notably  in 
establishing a coherent anti-fraud framework across agencies by: 
a.  providing training on ethics and anti-fraud matters; 

b.  providing methodology and advice on anti-fraud strategies; 

JUST: lead 
OLAF: support 

OLAF: lead 
HR: support 
OLAF 

c.  sharing knowledge, allowing the agencies to publish relevant information on the inter-agency website; 

OLAF 

d.  regularly participating in relevant meetings of the EU Agencies Network to inform on anti-fraud matters. 

OLAF 

32 

Protect and empower investigative journalists as an important source of information on suspected fraud, notably by 
ensuring that appropriate EU legislation is in place including on SLAPP (strategic lawsuit against public participation) 
and on media freedom (European Media Freedom Act), and that Member States take appropriate measures to put in 
practice the Commission Recommendation on SLAPP and that on the safety of journalists, while funding projects in 
support of investigative journalism. 

CNECT, JUST 

2024 and 
continuous 
2023 and 
continuous 
2023 and 
continuous 

2023 and 
continuous 
2023 and 
continuous 
2023 and 
continuous 
2023 and 
continuous 
2023 and 
continuous 

33 

Enhance the involvement of civil society in the Commission’s anti-fraud efforts, notably by exploring the possibility 
to work with civil society organisations to increase whistleblowing and reporting of suspicions of fraud. 

OLAF, DGs as 
appropriate 

2024 

2 Bodies set up under the Treaty on the Functioning of the European Union and Euratom Treaty and referred to in Articles 70 and 71 of Regulation (EU, Euratom) 2018/1046. 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
6.  Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission 

departments and Executive agencies  

Nr  Action 
34  Maintain a high level of coordination and cooperation on anti-fraud matters between Commission departments and 

Lead service 
OLAF 

Executive agencies through the Fraud Prevention and Detection Network (FPDNet) and its subgroups.  

35  Regularly include aspects of the Commission’s anti-fraud policy on the agenda of the Corporate Management Board 

meetings, for example: 

SG, OLAF: lead 
All DGs: support 

a. 

the follow-up to OLAF's recommendations and – where applicable – information received from the EPPO; 

b.  overall progress in the implementation of the Commission's anti-fraud strategy and its accompanying action 

Due date 
2023 and 
continuous 

2023 and 
continuous 

plan. 

36 

Improve continuously service-level anti-fraud strategies and their implementation, notably by: 
a.  updating such strategies and fraud risk assessments in principle every three years3; 
b.  seeking OLAF's advice at an early stage in the development of such a strategy or update, submitting the drafts 
for OLAF's mandatory review and to peer review, and justifying in writing when OLAF’s recommendations 
on the anti-fraud strategy have not been followed. Any issues that cannot be resolved between OLAF and the 
Commission department concerned may be discussed in suitable fora or be brought to the attention of the 
Corporate Management Board. 

All DGs and executive 
agencies 
OLAF: support 

2023 and 
continuous 

37  Make use of OLAF’s investigative experience in the Commission’s work with individual Member States, notably in 

OLAF 

the European Semester and in the Rule of Law processes where appropriate. 

38 

In  implementing  the  EU’s  anti-corruption  policy4,  exploit  the  synergies  between  anti-fraud  and  anti-corruption 
policies, notably by identifying common areas of high risk and measures to address such risks. 

HOME, OLAF 

39  Exploit the synergies between policies against organised crime, fraud and corruption, notably by identifying sectors 
at risk of fraud and corruption by organised crime, and of its infiltration in the legal economy, and measures to address 
such risks. 

HOME, OLAF 

2024 and 
continuous 

2023 and 
continuous 

2023 and 
continuous 

3 In line with the 2019 CAFS and the anti-fraud strategy methodology of June 2021, ref. Ares(2021)4589215. 
4 See the Anti-corruption package adopted by the Commission on 3 May 2023. 

10 

 
 
 
 
                                                           
 
 
 
 
 
7.  Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
40  Map, enhance and promote existing ethics and anti-fraud training and awareness raising for staff at all levels across 
the Commission, and reinforce the existing financial learning activities with additional messages on ethics and anti-
fraud matters. 

Lead service 
OLAF, HR, SG, 
BUDG: lead 
All DG’s: support 

Due date 
2024 

41 

42 

Promote awareness on Members’ ethical obligations among Members of the Commission and Cabinets through the 
Network of Ethics and Transparency Contact Points and through targeted information for Members at the beginning 
and end of their mandates. 

SG: lead 
OLAF, HR: support 

2023 and 
continuous 

Provide corporate training and guidance on grants and procurement, including on simplified forms of reimbursement 
for grants, while ensuring that the training and guidance contain relevant anti-fraud elements.  

BUDG 

43  Based on identified needs and priorities of Commission departments and Member States, perform and disseminate 

strategic analysis and guidance, notably to: 

OLAF: lead 
All DGs: support 

a.  feed into training and awareness raising, fraud risk assessments, and other prevention and detection activities 

b. 

of Commission departments, agencies, Member States and other anti-fraud partners; 
translate audit results and experience from investigations into concrete advice on fraud risks, fraud patterns 
and red flags, for example, in the form of case compendia. 

2024 and 
continuous 

2023 and 
continuous 

44  Consider  anti-fraud  aspects  when  reviewing  the  recruitment  process  in  the  context  of  the  implementation  of  the 
Commission's new HR strategy, notably in the behavioural assessments and in the training of selection panels, and 
reinforce the checks of originals of qualifications and certificates of candidates. 

HR: lead 
OLAF: support 

2023 

11