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  COM(2023) 405 final  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  {SWD(2023) 245 final}  
 
 
1. 

INTRODUCTION 

The EU is facing great challenges, including inflation, post-pandemic recovery, climate change 
and  the  war  of  aggression  on  Ukraine.  Such  challenges  put  an  enormous  strain  on  the  EU 
budget. It is therefore more important than ever that the budget is well protected and that EU 
funds reach their intended recipients. Any failure to do so erodes trust in the EU institutions 
and the EU as a whole.  

Against this background, now is an appropriate time to take stock of the Commission’s efforts 
to fight fraud and irregularities, and to provide fresh impetus to such efforts.  

While  protecting  the  EU  budget  is  a  shared  responsibility  between  the  EU  and  its  Member 
States,1 the European Commission plays a leading role in setting the standards and creating the 
framework  for  this  shared  responsibility.  A  key  instrument  to  implement  this  role  is  the 
Commission’s Anti-Fraud Strategy (CAFS) and its accompanying action plan, the latest dating 
back to April 20192. 

The 2019 CAFS specified that the action plan would be reviewed and amended as appropriate. 
Today, the new realities facing the Commission in its efforts to protect the EU budget call for 
such a revision. The aim is to have a targeted and impactful action plan addressing the increased 
challenges facing the EU in the area of anti-fraud while building on the work done under the 
2019 action plan.  

Like its predecessor, the revised action plan seeks to strengthen all parts of the anti-fraud cycle: 
prevention, detection, investigation and correction. It complements a number of other recent or 
ongoing policy initiatives, such as the proposal for an interinstitutional Ethics Body3, the Anti-
corruption  package4,  the  ongoing  recast  of  the  Financial  Regulation5,  the  Rule  of  Law 
mechanism6 and the Conditionality mechanism7. 

It also complements the independent investigations conducted by European Anti-Fraud Office 
(OLAF) and the European Public Prosecutor’s Office (EPPO). 

This Communication is accompanied by the revised action plan. 

2. 

PREPARATION OF THE REVISED ACTION PLAN  

The revised action plan is the result of an extensive Commission internal consultation process, 
notably  through  the  Fraud  Prevention  and  Detection  Network  (FPDNet)  in  which  all 
Commission  departments  and  Executive  agencies  are  represented.  The  process  was  led  by 
OLAF, as the Commission’s lead department in anti-fraud and the chair of the FPDNet. The 
main conclusion of this consultation process is that while the 2019 CAFS remains valid, the 
accompanying action plan needs updating for a number of reasons. 

1 Article 325(1) TFEU. 
2 COM/2019/196 final and SWD(2019) 170 final. 
3 COM(2023) 311 final 
4 JOIN(2023) 12 final, COM(2023) 234 final / 2023/0135(COD). 
5 COM(2022) 223 final. 
6 COM(2019) 163 final, COM(2019) 343 final. 
7 Regulation (EU, Euratom) 2020/2092.  

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First, the implementation of the 2019 action plan is to a large extent complete. To date, 60 out 
of the 63 actions have either been finalised or, in the case of repetitive or continuous actions 
such as training, are ongoing8. New actions are needed to ensure sustained progress on anti-
fraud matters. 

Second, a number of important developments have taken place since 2019, including the start 
of  a  new  2021-2027  multiannual  financial  framework  (MFF),  the  launch  of  the 
NextGenerationEU and the Recovery and Resilience Facility (RRF), and the start of EPPO's 
operations. 

To prepare for the action plan revision, OLAF carried out an evaluation of the implementation 
of  the  2019  action  plan  through  a  survey  among  Commission  departments  and  Executive 
agencies. According to the survey, the most useful measures of the 2019 action plan relate to 
training and awareness raising on fraud-related matters, the strengthening of IT-based fraud 
prevention tools, the work of the FPDNet and the improvement of anti-fraud strategies. 

The evaluation also provided numerous ideas for new actions to be included in the revised plan, 
notably on the use of data mining and other IT tools, cooperation with the EPPO and with the 
decentralised agencies. 

OLAF has furthermore collected and analysed the main fraud risks identified by Commission 
departments and Executive agencies, to identify the most common and significant fraud risks. 
The following main fraud risks were identified: 

 

falsification of declarations and documents in procurement, grants and administrative 
expenditure; 
  double funding; 
  conflict of interest, corruption, favouritism or collusion; 
  misuse of insider information; 
  plagiarism; 
  undue influence; 
  unreliable counterparts; 
  undue access to IT devices, systems, bank accounts and hacking. 

Important sources of material for the revised action plan are also the European Parliament’s 
annual resolutions on the protection of the financial interests of the EU9, the European Court 
of Auditors' special reports as well as OLAF’s investigations. 

Through  bilateral  and  multilateral  meetings,  and  a  written  consultation  of  Commission 
department and Executive agencies, OLAF collected more than 200 ideas on what new actions 
to include and what actions to continue from the 2019 action plan.  

The  final  selection  and  formulation  of  actions  has  been  guided  by  the  ambition  to  have  a 
targeted and impactful action plan. Moreover, the need for continuity has been weighed against 
the need for renewal and innovation. Priority has been given to actions that are linked to new 
developments and to actions that address important fraud risks. 

8 The few remaining actions required an update. 
9 Notably European Parliament resolutions of 19 January 2023 (P9_TA(2023)0018) and of 7 July 2022 (P9_TA(2022)0300). 

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3.  THE SEVEN THEMES OF THE REVISED ACTION PLAN 

The 44 actions are grouped under seven themes that reflect the Commission’s priorities in the 
fight against fraud. 

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

The consultation process concluded that digitalisation should be an important priority for the 
Commission in moving forward its anti-fraud agenda. In particular, there is a need for more 
corporate  IT  solutions  to  make  the  fight  against  fraud  more  effective  and  efficient.  The 
Commission  will  therefore  continue  to  explore  possibilities  to  increase  digitalisation  and 
interoperability. There is also a need to further strengthen and broaden the use of existing IT 
tools  such  as  Arachne10,  EDES11,  SUMMA12  and  IMS13  to  prevent,  detect  and  investigate 
fraud.  The  future  corporate  Arachne  will  be  developed  for  risk  scoring  and  data  mining 
purposes  across  all  management  modes,  while  OLAF  will  explore  digital  options  to 
communicate better on its investigations with other Commission departments and Executive 
agencies. 

2.  Support Member States to  reinforce the protection of the Recovery and Resilience 

Facility, cohesion, agricultural and fisheries funds 

The RRF is a new instrument, with specific control and anti-fraud mechanisms. It therefore 
requires  particular  attention  to  ensure  that  no  loopholes  or  vulnerabilities  to  fraud  go 
undetected. The Commission will therefore continue its efforts to prevent and detect RFF fraud, 
notably  through  careful  analysis  of  risks  related  to  fraud,  corruption,  double  funding  and 
conflict  of  interest  and  through  audits  focused  on  protecting  the  EU's  financial  interests.  In 
shared management, the Commission plays an important role notably by providing support and 
guidance to the Member States on a range of topics, such as on the development of anti-fraud 
strategies  and  on  the  reporting  of  irregularities  and  fraud  in  the  Irregularities  Management 
System (IMS). The action plan provides that the Commission departments concerned by shared 
management and OLAF will enhance their targeted support to Member State authorities.  

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

relations area  

The  protection  of  funds  under  indirect  management  is  entrusted  to  partner  organisations. 
However, the Commission remains accountable and must guarantee a high level of protection 
of such funds. Therefore, implementing partners must report detected fraud systematically to 
the  Commission.  For  this  purpose,  the  Commission  will  provide  increased  support  and 
awareness  raising  targeted  at  such  partners  while  insisting  on  their  legal  obligations  to 
cooperate.   

10  Arachne  is  an  integrated  IT  tool  for risk  scoring,  data  mining and data  enrichment,  developed  to  support  managing 
authorities in their administrative controls and management checks in the area of Structural Funds. Arachne can be used to 
score risks, notably, related to double funding and conflict of interest. 

11 EDES is the Early Detection and Exclusion System, developed to prevent unreliable persons and entities from receiving EU 

funds in direct and indirect management. 

12 SUMMA is the Central Financial System of the European Commission, developed to replace the current system, ABAC. 
13 IMS, the Irregularity Management System, developed to enable EU Member States and candidate countries fulfil their legal 
obligation to report irregularities related to expenditure to the Commission. Based on data in IMS, the Commission performs 
operational and strategic analysis and publishes the annual Report on the Protection of the European Union’s Financial 
Interests. 

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

To boost the EU's capacity to effectively tackle customs fraud, analytical tools and data sharing 
play an important role. The Commission will further develop such analytical tools and increase 
the sharing of data. To protect revenues stemming from the Green Deal, the Commission will 
put in place measures to minimise fraud risks associated with the Carbon Border Adjustment 
Mechanism, the EU Emissions Trading System and other new own resources. 

5.  Reinforce the EU anti-fraud architecture 

The EU anti-fraud architecture consists of a great number of players who need to work together 
in  a  coordinated  manner  to  protect  as  far  as  possible  the  EU's  financial  interests.  The 
increasingly  complex  anti-fraud  landscape  and  the  sophistication  of  fraudsters  make 
cooperation and coordination across organisational boundaries more important than ever. The 
Commission will continue to develop cooperation with key partners such as Member States 
authorities  and  the  EPPO  to  combat  fraud.  It  will  also  boost  its  support  to  decentralised 
agencies  and  joint  undertakings,  protect  investigative  journalists  as  an  important  source  of 
information, and explore the possibility of increasing the involvement of civil society in the 
fight against fraud. 

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

While considerable progress has been made in terms of strengthening anti-fraud governance 
and improving coordination, cooperation and processes in the Commission, such efforts need 
to be sustained and strengthened in targeted areas to remain effective and efficient in the longer 
term. OLAF will continue to support Commission departments and Executive agencies through 
the FPDNet and through its advice on anti-fraud strategies. Moreover, anti-fraud policy must 
be  considered  in  its  wider  EU  policy  context.  Anti-fraud  considerations  need  to  be  further 
integrated into other policy areas that are intrinsically linked to anti-fraud, for example anti-
corruption and rule of law, and synergies further exploited.  

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

There is a continued need to strengthen the knowledge and maintain a high level of awareness 
among  Commission  staff  regarding  ethics  and  anti-fraud  matters.  Anti-fraud  and  ethical 
considerations should be a natural reflex for all Commission staff, in particular those whose 
tasks involve managing or controlling EU funds, as well as for Commission Members. The 
Commission will gradually strengthen training and awareness raising on ethics and anti-fraud 
in a holistic manner, as the two topics go hand in hand. The Commission will also strengthen 
the  anti-fraud  knowledge  base  and  integrate  anti-fraud  considerations  into  its  recruitment 
process.  

4. 

IMPLEMENTING AND MONITORING THE REVISED ACTION PLAN 

OLAF  will  coordinate  and  monitor  the  implementation  of  the  revised  action  plan  and  will 
regularly update the Commission’s Corporate Management Board on its progress. To ensure 
sustained  efforts  to  reduce  fraud  to  the  EU  budget,  OLAF  will  work  with  Commission 
departments and  Executive agencies to  ensure that relevant  actions are reflected in  service-
level anti-fraud strategies, management plans and annual activity reports. 

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Each  year,  the  Commission  will  report  to  the  other  EU  institutions  and  the  public  on  the 
measures taken at EU level and in the Member States to protect the EU's financial interests, 
including on the implementation of the action plan. Indicators will be developed internally to 
keep track of progress. 

The  Commission  will  therefore  ensure  that  the  results  of  actions  to  tackle  fraud  are  made 
available to the public. This should contribute to building people's trust in the EU institutions 
and to ensuring that the fight against fraud remains high on the EU's political agenda. 

The revised action plan will be implemented in 2023-2026 and may be amended, if required. 

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