COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of article 325 TFEU Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 34th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2022
Date: 2023-07-27
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU strategy, activity report, digitisation, fight against crime, financial control, fraud, fraud against the EU, innovation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.7.2023  SWD(2023) 274 final  COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of article 325 TFEU Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 34th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2022 {COM(2023) 464 final} - {SWD(2023) 272 final} - {SWD(2023) 273 final} - {SWD(2023) 275 final} - {SWD(2023) 276 final}  
 
 
TABLE OF CONTENTS 
1. 

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

2.  Overview of Measures Taken by Member States ....................................................................... 4 

2.1.  National Anti-Fraud Strategies ............................................................................................ 4 

2.2.  Anti-Fraud Measures ............................................................................................................ 5 

3.  Anti-Fraud Measures Taken by Member States ........................................................................ 8 

3.1.  Austria .................................................................................................................................... 8 

3.2.  Belgium .................................................................................................................................. 9 

3.3.  Bulgaria ................................................................................................................................ 10 

3.4.  Croatia ................................................................................................................................. 12 

3.5.  Cyprus .................................................................................................................................. 13 

3.6.  Czechia ................................................................................................................................. 15 

3.7.  Denmark .............................................................................................................................. 16 

3.8.  Estonia .................................................................................................................................. 17 

3.9. 

Finland ................................................................................................................................. 19 

3.10. 

3.11. 

3.12. 

3.13. 

3.14. 

3.15. 

3.16. 

3.17. 

3.18. 

France ............................................................................................................................... 20 

Germany .......................................................................................................................... 22 

Greece ............................................................................................................................... 23 

Hungary ........................................................................................................................... 24 

Ireland .............................................................................................................................. 27 

Italy ................................................................................................................................... 27 

Latvia ............................................................................................................................... 29 

Lithuania .......................................................................................................................... 30 

Luxembourg .................................................................................................................... 31 

3.19.  Malta ................................................................................................................................ 32 

3.20. 

3.21. 

3.22. 

3.23. 

3.24. 

3.25. 

3.26. 

3.27. 

Netherlands ...................................................................................................................... 32 

Poland ............................................................................................................................... 34 

Portugal ............................................................................................................................ 35 

Romania ........................................................................................................................... 37 

Slovakia ............................................................................................................................ 39 

Slovenia ............................................................................................................................ 40 

Spain ................................................................................................................................. 42 

Sweden ............................................................................................................................. 44 

4.  Additional Measures ................................................................................................................... 46 

4.1.  Belgium ................................................................................................................................ 46 

4.2.  Estonia .................................................................................................................................. 46 

4.3.  Germany .............................................................................................................................. 46 

 
 
4.5. 

Italy....................................................................................................................................... 47 

4.6.  Latvia ................................................................................................................................... 47 

4.7.  Romania ............................................................................................................................... 48 

4.8. 

4.9. 

Slovenia ................................................................................................................................ 48 

Spain ..................................................................................................................................... 49 

2 

 
 
 
 
LIST OF ABBREVIATIONS 

AFCOS 

Anti-Fraud Coordination Service 

AFS 

Anti-Fraud Strategy  

AMIF   

Asylum, Migration and Integration Fund  

CAP 

CDM 

EGF 

Common Agricultural Policy 

Centralised Direct Management  

European Globalisation Fund 

EPPO   

European Public Prosecutors’ Office 

ERDF   

European Regional Development Fund 

ESF 

EU 

European Social Fund 

European Union  

FEAD   

Fund for European Aid to the Most Deprived  

GEO 

IT 

Emergency Ordinance  

Information Technology 

MICAF 

Interministerial Anti-Fraud Coordination Office  

NAFS   

National Anti-Fraud Strategy 

NRA 

National Risk Assessment 

OLAF   

European Anti-Fraud Office 

PIF 

RRF 

RRP 

SEFI 

VAT  

Protection of the EU’s Financial Interests 

Recovery and Resilience Facility  

Recovery and Resilience Plan 

Council on the Protection of the EU’s Financial Interests  

Value Added Tax  

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.  Introduction 

Article 325(2) of the Treaty on the Functioning of the European Union obliges Member States to take 
the same measures to counter fraud that affects the EU’s financial interest as those used to protect their 
own financial interests.  

Paragraph 5 adds that the Commission, in cooperation with Member States, should submit every to the 
European Parliament and the Council a report on the measures taken to implement this article.  

To compile this document, the Commission has requested Member States to report up to three measures, 
which they considered most important for the protection the EU’s financial interests. Their responses 
were collected through a survey (also known as the PIF Questionnaire).  

Member States also had the opportunity to briefly describe additional measures, if deemed necessary 
and report case studies.  

2.  Overview of Measures Taken by Member States 
2.1. National Anti-Fraud Strategies  

Following the Commission’s sustained encouragement of Member States to adopt national anti-fraud 
strategies (NAFS), in 2022, only three Member States indicated not to rely on any strategy for protecting 
the EU’s financial interests. . For the other 24 Member States the approach taken varied widely.  

15 Member States have a NAFS in place. Five reported that they were in the process of drafting, or 
close  to  adopting  one,  while  four  additional  Member  States  indicated  that  they  have  an  alternative 
strategy in place. Germany’s approach, based on regional and sectoral strategies, covers cohesion, the 
recovery  and resilience facility  (RRF), and  other fields.  Cyprus  and  Sweden  rely  an  anti-corruption 
strategy also covering the EU’s financial interests, while Slovenia has drawn up a specific strategy for 
RRF. 

Table 1: Overview of the type of strategy pursued by Member States in their fight-against fraud and 
the fields they cover.  

Nine out of 15 NAFS were cross-cutting, covering the EU’s financial interests fully. The other national 
strategies  present  different  approaches,  targeting  specific  or  multiple  sectors,  such  as  expenditure 
(shared management and RRF), customs or value added tax (VAT). 

4 

AT BEBG CYCZDEDKEEESFIFRGRHRHUIEITLTLULVMTNLPLPTROSESISKNational AFS Regional AFSSectoral nationalSectoral regionalAnti-corruption Other Cohesion AgricultureFisheries CustomsVAT RRFOther Type Member StateFieldYES, NAFSYES YES, other AFSNONO, but developingNO, no plan 
 
 
 
All five Member States where the process of establishing a NAFS was ongoing indicated that their 
strategies would be cross-cutting and cover the EU’s financial interests throughout their territory.   

2.2. Anti-Fraud Measures  

In  2022,  Member  States  reported  72  single  and  packaged  measures1  intended  to  protect  the  EU’s 
financial interest. Through the PIF Questionnaire, they had been invited to report at most three critical 
anti-fraud measures. This staff working document offers a comprehensive, yet non-exhaustive overview 
of priorities and trends across the anti-fraud action taken across the Union.  

Table  2:  Overview  of  the number  of  single  and  packaged  anti-fraud  measures adopted by  Member 
States in 2022. 

Amongst the 72 measures adopted, 52  were single measure and 20 comprehensive  packages, which 
consisted of 39 individual actions. These 91 measures taken by Member States encompassed 52 new 
actions and 42 updates. Five measures were described as both.  

Anti-fraud actions targeted specific revenue and expenditure streams. Out of 91 individual measures 
only 32 were horizontal, as opposed to 59 sectoral policies. Sectoral measures took most frequently aim 
at fraud against cohesion funds, followed by fisheries, the RRF, and agriculture, in line with the last 
report on the protection of the EU’s financial interests’ (PIF Report) recommendation to protect the 
EU’s unparalleled recovery package. 

Table 3: Overview of the sectors targeted by individual anti-fraud measures adopted by Member States 
in 2022. 

y
c
n
e
u
q
e
r
F

Customs 

Tax Fraud 

Agriculture  

Fisheries  

Cohesion  

CDM  

FEAD 

EGF 

AMIF 

RRF 

7 

8 

12 

14 

15 

2 

4 

2 

5 

13 

Sector  

Member States’ measures were defined by their type. They may fall into one of four categories. Firstly, 
a legislative measure denotes an act  that either has legal force or has been adopted by a legislative. 
Secondly,  an  administrative  measure  is  an  act  adopted  by  an  administrative  body  to  realise  actions 
provided for in legislative acts. Thirdly, a decision or any other non-legislative act taken to change the 
organisational setting of an administration or body whose tasks and activities relate to the protection of 
the  EU’s  financial  interests,  may  be  classified  as  an  organisational  measure.  Lastly,  any  action 
undertaken  by  such  an  administration  or  body  and  with  a  direct  impact  on  its  operations  would  be 
considered an operational measure.  

Single measures were predominantly legislative and least often administrative, while Member States 
reported operational measures most frequently in context of packages.  

Table  4:  Overview  of  single and  packaged  anti-fraud  measures  adopted  by  Member  States  in 2022 
sorted according to type.  

1   Measures  based  on  a  single  ‘act’  are  referred  to  as  ‘single  measures’  to  distinguish  them  from  those 
implemented on the basis of a package of different acts (legal or administrative) or policy initiatives. 

5 

 
 
 
 
 
                                                           
y
c
n
e
u
q
e
r
F

Amount  

Single  

Package  

Type 

Legislative 

Administrative 

Organisational  

Operational  

20 

11 

9 

8 

11 

7 

12 

13 

Regardless, fraud against the EU budget can only be effectively fought if it is approached holistically, 
covering all stages of the anti-fraud cycle and drawing on a multitude of stakeholders, processes, and 
steps, all of which are deeply interconnected and influence each other. This cycle may be divided into 
four stages, including prevention, detection, investigation and prosecution, and recovery and sanction. 
Prevention can involve risks analyses, self-assessments, quantifying fraud, and its impact. Detection is 
marked  by  fraud  reporting  processes  and  identification  of  fraud  signals  by  audits,  the  information 
technology (IT) tools that support them, their comparability and interoperability, Law enforcement, the 
European Anti-Fraud Office (OLAF), the European Public Prosecutor’s Office (EPPO) and national 
judicial authorities’ investigations characterise the investigation and prosecution stage. Member States 
close this process by recovering compromised funds and sanctioning fraud.  

The pie charts 1-8 below show the attention that these phases received by the four types of single and 
packaged  measures.  Evidently,  Member  States  predominantly  took  action  to  strengthen  fraud 
prevention and detection. Investigation, prosecution, recovery and sanctioning have been targeted to a 
lesser extent. 

Recurring themes across reported single and packaged measures aim toward better fraud prevention 
and detection, including the transposition of the Directive (EU) 2019/1937 on the protection of persons 
who report breaches of Union law (Whistleblower Directive), the RRF, and cooperation with the EPPO.  

Pie  chart  1:  Frequency  with  which  single 
legislative  measures  targeted  each  anti-fraud 
cycle stage  

Pie  chart  2:  Frequency  with  which  single 
administrative  measures  targeted  each  anti-
fraud cycle stage  

Fraud Prevention

Fraud Prevention

10

15

Fraud Detection

13

17

Investigation and
Procecution

Recovery and
Sanction

2

2

8

9

Fraud Detection

Investigation and
Procecution

Recovery and
Sanction

6 

 
 
 
 
 
 
 
 
        
 
 
 
 
 
 
 
Pie  chart  3:  Frequency  with  which  single 
organisational  measures  targeted  each  anti-
fraud cycle stage  

Pie  chart  4:  Frequency  with  which  single 
operational measures targeted each anti-fraud 
cycle stage  

Fraud Prevention

Fraud Prevention

8

3

3

7

Fraud Detection

Investigation and
Procecution

Recovery and
Sanction

2

3

6

9

Fraud Detection

Investigation and
Procecution

Recovery and
Sanction

Pie chart 5: Frequency with which packaged 
legislative  measures  targeted  each  anti-fraud 
cycle stage  

Pie chart 6: Frequency with which packaged 
administrative  measures  targeted  each  anti-
fraud cycle stage  

4

6

10

10

Fraud
Prevention

Fraud
Detection

Investigation
and
Procecution

Recovery and
Sanction

8

4

4

7

Fraud Prevention

Fraud Detection

Investigation and
Procecution

Recovery and
Sanction

Pie chart 7: Frequency with which packaged 
organisational  measures  targeted  each  anti-
fraud cycle stage  

Pie chart 8: Frequency with which packaged 
operational measures targeted each anti-fraud 
cycle stage  

Fraud Prevention

Fraud Prevention

7

3

2

6

Fraud Detection

Investigation and
Procecution

Recovery and
Sanction

13

4

4

12

Fraud Detection

Investigation and
Procecution

Recovery and
Sanction

7 

 
 
 
 
 
  
 
  
 
 
 
 
3.  Anti-Fraud Measures Taken by Member States 
3.1. 
3.1.1.  NAFS 

Austria  

On June 30, 2022, Austria adopted a sectoral national anti-fraud strategy, covering its whole territory. 
It focuses on EU cohesion policy, agricultural, and fisheries funds. Expanding this NAFS’s sectoral 
coverage is, however, not foreseen.  

3.1.2.  Measures 

In 2022, Austria continued to update its administrative anti-fraud measures, focusing on the prevention 
and detection of fraud against European cohesion policy and agricultural funds. Jointly, the single and 
packaged measures comprehensively strengthened all but one stage of the anti-fraud cycle. 

3.1.2.1. Administrative Package for more Comprehensive Expenditure Audits   

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #1 Taken by Austria in 2022 

Package   Administrative 

Update  

Fraud 
prevention 

Fraud 
Detection 

Recovery and 
Sanction 

Sectoral: 
Cohesion 
Policy 

Public procurement; 
Conflict of interest; 
Shared management 
and control of EU 
funds; Anti-fraud or 
anticorruption strategy. 

Eligibility criteria; 
Management of 
funds; On the spot 
checks; 
Irregularities 
reporting; 
Recovery. 

Cross-cutting measure, 
multi-agency measure/ 
measure with impact on 
various bodies for 
monitoring the proper use 
of funds and the 
notification of identified 
irregularities. 

The  first  of  the  two  administrative  measures  reported,  is  a  package  that,  similarly  to  2021,  aims  to 
decrease irregularities thorough expense checks. Targeting exclusively EU cohesion policy funds, the 
initiative seeks to improve prevention, detection, recovery, and sanctioning of fraud by controlling and 
safeguarding the use of funds and reported irregularities. To this end, the administrative update foresees 
that relevant administrative bodies audit all expenses that beneficiaries submit fully.  

3.1.2.2. Administrative Measure for more Complete Transaction Records  

Anti-Fraud Measure #2 Taken by Austria in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Single  

Administrative 

Update  

Fraud 
Prevention 

Fraud 
Detection 

Sectoral: 
Agriculture 

Shared management 
and control of EU 
funds. 

Eligibility criteria; 
Monitoring/desk 
checks.  

To clarify or 
consolidate 
existing rules. 

Austria’s second administrative update is a single measure that clarifies and consolidates an existing 
rule to better prevent and detect fraud against EU agricultural funds. The alteration concerns the Special 
Directive  for  Austria’s  rural  development  program  between  2014  and  2020.  It,  more  specifically, 
introduces the obligation to either maintain records of all transactions associated with a project, or to 
use an alternative but equivalent accounting code.  

8 

 
 
 
 
3.2. 
3.2.1.  NAFS  

Belgium  

Belgium  does  not  currently  have  a  national  anti-fraud  strategy.  Nevertheless,  it  reported  that 
preparations for establishing such a wholesome strategy was ongoing. The Belgian national anti-fraud 
strategy has already been discussed at the latest 2022 Belgian AFCOS meeting. It has been agreed that 
statutory changes will form its basis, while special attention will be paid to Recovery and Resilience 
Facility associated risks. The latter could be adequately accounted for by integrating the Early Detection 
and Exclusion System data base into the ongoing fraud prevention culture.  

3.2.2.  Measures 

In 2022, Belgium put three anti-fraud measures into place, mostly packages of new legislation or acts. 
While the sectoral legislative measure focused on fraud detection, investigation and prosecution, the 
reported legislative package cut across sectors, fostering fraud prevention and detection. The only non-
legislative measure reported by Belgium was an organisational update to RRF funds management in 
Wallonia, strengthening the investigation and prosecution of fraud against them.   

3.2.2.1. Legislative Package for more Comprehensive VAT Records and Effective Penalties 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #1 Taken by Belgium in 2022 

Package  

Legislative  

New 

Fraud Detection 

Investigation and  
Prosecution 

Sectoral: 
Tax Fraud 

Antifraud or 
anticorruption 
strategy. 

Competences; 
Powers. 

To clarify or consolidate 
existing rules; To remedy 
flaws. 

The first of two new legislative  packages aims to improve tax fraud detection, its investigation and 
prosecution by clarifying the relevant existing rules and correcting flaws. Dating 20 November, 2022, 
the  law  on  various  fiscal  and  financial  provisions,  in  Articles  91,  103,  and  104,  introduces  a  VAT 
penalty  payment  mechanism.  It  further  alters  the  time  constraints  for  investigations  as  well  as  the 
conservation of books and books in the value added tax code.   

3.2.2.2. Legislative Package for a Higher Level of Protection for Whistleblowers 

Anti-Fraud Measure #2 Taken by Belgium in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Package  

Legislative  

New 

Fraud 
Prevention 

Fraud 
Detection 

Horizontal 

Whistle-
blowers 

Competences; Powers; Other 
administrative penalties; 
Criminal sanctions; Other. 

To enforce the rules in 
line with developments in 
EU law 

The  second  of  two  new  legislative  packages  is  horizontal  rather  than  sector  oriented,  generally 
endorsing  whistleblowers’  protection  for  a  stronger  bottom-up  approach  to  fraud  prevention  and 
detection. It encompasses two laws that became effective on January 1, 2023.  

The  first  measure,  of  28  November,  2022,  transposes  the  European  Whistleblowing  Directive, 
establishing shared minimum standards that guarantee a high level of protection to those who report 
breaches of Union and national law.  

9 

 
 
 
 
The second measure, the Law of 8 December, 2022, regulates reporting channels and the protection of 
whistle blowers in the public sector. Beyond the federal public administration and police, the law applies 
to strategic bodies, too, implementing a recent Group of States against Corruption recommendation to 
Belgium2.  

3.2.2.3. Organisational Measure for Improved Interagency Information Flows  

Anti-Fraud Measure #3 Taken by Belgium in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Single 

Organisational   Update  

Investigation and 
Prosecution 

Sectoral: 
Recovery and 
Resilience 
Facility  

Public procurement; 
Conflict of interest; Fraud 
definition; Shared 
management and control 
of EU funds. 

Reorganisation of 
existing bodies; 
Inter- agency 
cooperation. 

Reason / 
Expected 
Result  

Increased 
resources 

Belgium’s third and final measure during the 2022 reporting year was a single organisational update 
that integrated Wallonian bodies in charge of RRF funds into an existing  ‘OLAF working group’ to 
facilitate interagency cooperation through improved information flows. More specifically, the working 
group  comprises  all  functional  administrations  relevant  to  European  Regional  Development  Fund 
(ERDF)  and  RRF  expenditure  in  Wallonia,  intermediary  bodies,  the  European  Social  Fund  (ESF) 
agency,  audit  authorities,  and  experts.  Quarterly,  each  entity  notifies  irregularities  and  suspected 
irregularities/fraud.  These  instances  are  then  thoroughly  discussed  when  the  working  group  meets, 
ensuring  that  this  and  any  other  information  on  the  fight  against  fraud,  corruption,  and  conflict  of 
interest is disseminated amongst relevant stakeholders.  

3.3. 
3.3.1.  NAFS 

Bulgaria  

Since November 12, 2020, Bulgaria has had a cross-cutting national anti-fraud strategy, covering the 
EU’s financial interest and the whole national territory.  

3.3.2.  Measures 

In 2022, anti-fraud action in Bulgaria was predominantly legislative, revolving around fraud detection 
and prevention as well as its investigation and prosecution, but covering the whole anti-fraud cycle. 
Two  single  legislative  measures,  updated  existing  acts,  the  first  focusing  on  agricultural,  fisheries, 
cohesion, Fund for European Aid to the Most Deprived (FEAD), and Asylum, Migration and Integration 
(AMIF)  funds,  and  the  second  cross-cutting.  The  third  legislative  measure  was  accompanied  by 
administrative changes toward comprehensively protecting EU RRF funds.  

3.3.2.1. Legislative Measure for an Improved EU Fund Management Capacity at all Levels 

Anti-Fraud Measure #1 Taken by Bulgaria in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Fraud Prevention 

Single 

Legislative   Update  

Fraud Detection 

Investigation and 
Prosecution 

Sectoral: 
Agriculture, 
Fisheries; Cohesion 
policy; Fund for the 
most deprived; 
Migration and 
asylum.  

Shared 
management 
and control of 
EU funds.  

Competences; 
Powers; 
Recovery.  

To enforce the rules in 
line with 
developments in EU 
law. 

2  

see GrecoEvalRep (2019)3 Report, p.29, §128 

10 

 
 
 
                                                           
For 2022, the first of three legislative measures reported by Bulgaria amends and aligns the domestic 
(Act No. 51/2022) with EU legislation on EU funds under shared management for the 2021  – 2027 
programming period, protecting to a higher standard the EU’s financial interests. This aim is split into 
four  objectives.  First,  the  changes  intend  to  make  Bulgaria’s  system  for  managing  EU  funds  more 
transparent, easier to comprehend, and effective. Second, they intend to bulk up administrative capacity 
at management and all control levels. Third, the act  diminishes the administrative burden associated 
with  managing  EU  funds  by  codifying  the  corresponding  framework,  streamline  and  simplify 
procedures  tied  to  clear  deadlines,  forms  and  rules.  And,  lastly,  it  seeks  to  grant  effective  judicial 
protection to beneficiaries. On all accounts, this legislative measure thus strengthens fraud prevention, 
detection, investigation, and prosecution.  

3.3.2.2. Legislative Measure for Greater Information Accessibility for OLAF  

Anti-Fraud Measure #2 Taken by Bulgaria in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Fraud Prevention 

Single 

Legislative  

Update  

Fraud Detection  

Horizontal 

Investigation and 
Prosecution 

Public procurement; Financial 
crime (including money 
laundering); Organised crime; 
Corruption; Conflict of 
interest; Fraud definition; 
AFCOS; Customs/TOR/illicit 
trade; Shared management and 
control of EU funds. 

Competences; 
Powers. 

To enforce the rules 
in line with 
developments in EU 
law. 

The second single legislative measure adopted by Bulgaria in 2022 amends the Credit Institutions Act 
(SG No. 25/2022), giving OLAF access even if information is strictly protected by bank secrecy when 
it  is  strictly  necessary  for  the  office’s  investigation  to  improve  fraud  prevention  and  detection 
throughout. The changes to Articles 56(3)(2a), 56a(3)(2a), and 62(6)(7a) designate Bulgaria’s AFCOS 
Directorate as the competent authority for this information exchange.  

3.3.2.3. Mixed Package on Bulgaria’s Recovery and Resilience Plan 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Anti-Fraud Measure #3 Taken by Bulgaria in 2022 

Legislative  

Package 

New 

Administrative 

Fraud Prevention 

Fraud Detection 

Investigation and   
Prosecution 

Recovery and 
Sanction 

Horizontal 

Shared 
management and 
control of EU 
funds.  

Competences; Powers. 

Management of funds; 
Monitoring/desk checks; On 
the spot checks; 
Irregularities reporting; 
Recovery. 

Reason / Expected 
Result  

To enforce the 
rules in line with 
developments in 
EU law. 

To enhance 
existing measure.  

Covering the entire fraud cycle, the third legislative measure reported by Bulgaria comes integrated into 
administrative  action,  which  designates  the  authorities  and  bodies  responsible  for  implementing  the 
Member State’s Recovery and Resilience Plan (RRP). Decree No. 157 by the Bulgarian Council of 
Ministers, approved through Order No. 526 from July 1, 2022, specifies these bodies’ functions and the 
national management and control system for the RRP.  Thereby, the package aligns domestic with EU 
law, specifically with Regulation (EU) 2021/241, which establishes the RRF.  

11 

 
 
 
 
3.4. 
3.4.1.  NAFS 

Croatia 

To date, Croatia has adopted two NAFS, covering the years 2010-2012 and 2014-2016, which have 
been fully implemented. The Ministry of Justice and Public Administration has drafted and monitored 
the implementation of national strategic documents in the field of the fight against corruption as well 
as the Strategy for the Prevention of Corruption, covering 2021-2030, which was adopted in October 
2021 (Official Gazette 120/21) and is the fifth strategic document in this area since 2001.  

3.4.2.  Measures 

Croatia, for 2022, reported exclusively individual updates, two horizontal measures, one legislative, 
securing the confiscation of criminal proceeds, and the other operational, enhancing cooperation with 
the EPPO, as well operational changes to the management of cohesion funds using Arachne. Together, 
they  cover  the  entire  anti-fraud  cycle,  strengthening  the  protection  of  the  EU’s  financial  interests 
throughout although from different angles.  

3.4.2.1. Legislative Measure for a More Effective Confiscation of Criminal Proceeds 

Anti-Fraud Measure #1 Taken by Croatia in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Single 

Legislation 

Update  

Investigation, 
Prosecution 

Recovery and 
Sanction 

Horizontal 

Financial crime (including money 
laundering); Organised crime; 
Corruption; Customs/ToR/illicit trade. 

Recovery 

To clarify or 
consolidate existing 
rules; To remedy 
flaws. 

In  2022,  Croatia  amended  its  horizontally  applicable  Criminal  Procedure  Act  (Official  Gazette,  No 
80/2022) with the aim to secure better and more efficient confiscation of criminal proceeds. Concretely, 
the amendment prevents that relevant provisional measures are lifted during criminal proceedings by 
altering the reference point for their duration. Rather than lasting up to two years before an indictment 
is confirmed, provisional measures that secure the confiscation of criminal proceeds may now last for 
up to two years before an indictment is issued, as the former practice had proven ineffective. 

Extending these measures’ maximum duration intends to strengthen the recovery of funds, including 
those  originating  in  the  EU  budget, by  ensuring that  the  confiscation  of  criminal proceeds  becomes 
definitive and permanent. The change became effective on 19 July, 2022.  

3.4.2.2. Operational Measure for More Efficient Project Management  

Anti-Fraud Measure #2 Taken by Croatia in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Single 

Operational 

Update  

Fraud 
Prevention 

Fraud Detection  

Sectoral: 
Cohesion 
Policy 

ARACHNE 

IT tools ("IT data 
feeding", "Other 
IT").  

Enhanced cooperation; 
Enhanced information flow; 
Targeting of checks. 

The  first  of  two  operational  measures  reported  by  Croatia  for  2022  is  a  training  on  the  use  of  the 
ARACHNE IT tool for data mining and enrichment in cohesion policy. As part of the Croatian Human 
Resources  2014  –  2020  Operational  Programme,  the  training  was  conducted  by  the  European 
Commission on 28 June, 2022 with authorities involved in the ESF management and control system. 
Focusing  on  in-depth  analysis  and  data  enrichment,  it  intended  to  make  project  selection  and 
management checks more efficient as well as fraud identification, prevention, and detection stronger.  

12 

 
 
 
 
3.4.2.3. Operational Measure for Heightened Interinstitutional Cooperation 

Anti-Fraud Measure #3 Taken by Croatia in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Single 

Operational 

Update  

Fraud Detection  

Investigation, 
Prosecution 

Horizontal  

Financial crime (including 
money laundering); Shared 
management and control of 
EU funds. 

Structured 
cooperation with 
judicial 
authorities. 

Enhanced 
cooperation; 
Targeting of 
investigations.  

The  final  of  Croatia’s  two  reported  operational  measures  intends  to  enhance  inter-institutional 
cooperation  in  the  detection,  investigation,  and  prosecution  of  offences  against  the  EU’s  financial 
interests  at  large.  It  targets  specifically  the  Independent  Financial  Investigation  Sector  of  the  Tax 
Administration’s Central Office, the EPPO, and the delegated prosecutors in the Member State.  

First results of this measure have, according to Croatian authorities, already surfaced. The Independent 
Investigation Sector opened 18 cases in 2022 in response to EPPO requests, doubling the number of 
cases reported in the previous year.  

3.5. 
3.5.1.  NAFS 

Cyprus  

Cyprus has not yet reported a national anti-fraud strategy, neither having a procedure for establishing 
such  a  strategy  currently  ongoing.  The  Member  State  has,  nevertheless,  pursued  a  national  anti-
corruption strategy since 28 June, 2017.  

3.5.2.  Measures 

For 2022, Cyprus described two legislative single measures and one package, comprising a legislative, 
administrative,  organisation,  and  operational  action.  The  first  single  measure  aims  to  better  protect 
whistleblowers, transposing the Whistleblowing Directive into domestic law, boosting thereby fraud 
prevention, detection, investigation and prosecution. The second single legislative measure is equally 
horizontal,  but  focused  instead  on  fostering  integrity  and  transparency  in  public  decision  making 
processes, covering all anti-fraud cycle stages. The RRF and various stakeholders are targeted by the 
mixed method package adopted by Cyprus, which intends to prevent fraud.  

3.5.2.1. Legislative Measure for a Higher Level of Protection for Whistleblowers 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #1 Taken by Cyprus in 2022 

Fraud 
Prevention 

Single 

Legislative  

New 

Fraud Detection 

Horizontal  

Investigation, 
Prosecution 

Corruption; 
Conflict of 
interest; Whistle-
blower.  

Competences; Powers; 
Definition of a specific topic; 
Financial penalties; Criminal 
sanctions. 

To enforce the rules in 
line with 
developments in EU 
law. 

The first legislative action that Cyprus has reported strengthens EU laws and policies in the Member 
State  by  improving  protection  of  persons  who  report  breaches  thereof.  With  the  adoption  of  Law 
6(I)/2022,  Cyprus  has  transposed  the  EU  Whistleblowing  Directive  (Directive  (EU)  2019/1937) 
including provisions on whistleblowers, employers, and competent authorities.  

For whistleblowers, the legislation specifies who can report what, where reports need to be submitted, 
as  well  as  when  and  how  protection  is  given.  Provisions  for  employers  sketch  out  internal 
whistleblowing  channels,  defining  which  employers  are  obliged  to  have  them,  who  and  what  may 

13 

 
 
qualify as such a channel, how they should work and be secured. Competent authorities’ obligations, 
too, are laid out by the law.  

Overall,  these  rules  encourage  and  facilitate  the  confidential  and  secure  reporting  of  possible 
infringements  by  employees  who  have  acquired  relevant  information  while  performing  their  duties, 
shields them from relation by superiors and colleagues, and provides robust support measures.  

3.5.2.2. Legislative Measure for Curbing Corruption  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected 
Result  

Anti-Fraud Measure #2 Taken by Cyprus in 2022 

Single 

Legislative  

New 

Fraud 
Prevention 

Fraud 
Detection 

Investigation, 
Prosecution 

Recovery and 
Sanction 

Horizontal 

Public procurement; Financial crime 
(including money laundering); Organised 
crime; Corruption; Conflict of interest; 
Whistle-blower; Antifraud or anticorruption 
strategy; Other, anti-corruption strategy / 
integrity and transparency measures.  

Competences; 
Powers. 

To remedy 
flaws 

Cyprus’  second  legislative  measure is  threefold,  creating  an  Independent  Anti-Corruption  Authority 
and a framework for integrity and transparency in public decision making processes.  

Law 19(I)/2022 and Regulatory Administrative Act (RAA) 483/2022 establish and govern the authority. 
In the future, this authority will take action to prevent and combat corruption in the public. To this end, 
it has been mandated to supervise and assess public and private sector service providers, compile reports 
with recommendations, guide private sector actors in adopting internationally recognised best practices, 
conduct risk assessments, and produce and disseminate information. In addition, the authority will be 
in  charge  of  implementing,  enacting  managing  and  evaluating  Cyprus’  National  Anti-Corruption 
Strategy.  

Law  20  (I)/2022,  on  the  other  hand,  establishes  the  framework  for  guaranteeing  integrity  and 
transparency throughout the public decision-making process.  

3.5.2.3. Mixed Package for the Cypriot Recovery and Resilience Plan  

Single / 
Package  

Type  

New / 
Update 

Stage in 
Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #3 Taken by Cyprus in 2022 

Legislative 

Administrative 

Package  

New 

Fraud 
Prevention 

Organisational 

Operational 

Competences; 
Definition of a specific 
topic. 

To enforce the rules in line 
with developments in EU 
law. 

Monitoring/desk 
checks; Irregularities 
reporting. 

Inter-agency 
cooperation; General 
trainings; Fraud 
awareness trainings. 

IT tools ("IT data 
feeding", "Other IT"); 
Flagging practice; Risk 
indicators; Increased 
number of checks. 

To enhance existing 
measure; Cross-cutting 
measure, multi-agency 
measure / measure with 
impact on various bodies. 

Increased resources. 

Targeting of checks; 
Enhanced ex-ante controls; 
Enhanced ex-post controls. 

Sectoral: 
Recovery and 
Resilience 
Facility  

Public 
procurement; 
Corruption; 
Conflict of 
interest; Shared 
management.  

14 

 
 
For  2022,  the  most  complex  measure  reported  by  Cyprus  is  a  package  that  combines  legislative, 
administrative, organisational, and operational action in an effort to prevent fraud against RRF funds, 
affecting relevant stakeholders including economic operators and authorities.  

The legislative measure included in the package denotes the alignment of the Cypriot RRP and related 
grant schemes with the Council decision on guidelines for preventing, detecting, corruption and conflict 
of interest. The administrative measure translates this alignment into domestic guidelines, while the 
remaining  actions facilitate  their  implementation,  targeting  specifically  beneficial  ownership  data  in 
public procurement and in grant award decisions. They cover the procedure for submitting this data 
before projects are awarded and public contracts awarded as well as its checking with the ARACHNE 
tool. Cyprus reported that after successfully curbing corruption in the RRF’s context, this package could 
be extended to all other cohesion policy funds.  

3.6. 
3.6.1.  NAFS 

Czechia  

Czechia adopted its national anti-fraud strategy on 1 May, 2020. The strategy is cross-cutting, covering 
the EU’s financial interests and the entire national territory. The Member State has reported that an 
updated version will be adopted in 2023.  

3.6.2.  Measures 

For 2022, Czechia reported exclusively new sectoral operational measures, targeting all stages fraud 
but detection. The first measure described operationalises the enforcement of EU sanctions against the 
Russian  Federation,  enhancing  coordination,  cooperation,  and  information  flows  amongst  Czech 
authorities. A second operational measure interconnects, but this time the beneficial owners register 
with information systems used in managing fisheries and cohesion funds. The third measure pursues 
the same goal by completing all methodological documents relevant to the current programming period.  

3.6.2.1. Operational Measure for Enforcing EU Sanctions against the Russian Federation 

Anti-Fraud Measure #1 Taken by Czechia in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Single 

Operational 

New 

Investigation and 
Prosecution 

Recovery and 
Sanction 

Sectoral: 
Customs, 
Tax fraud  

Financial crime (including 
money laundering); 
Organised crime; 
Customs/ToR/illicit trade.  

Risk indicators; 
Structured cooperation 
with law enforcement; 
Structured cooperation 
with judicial 
authorities. 

Reason / Expected 
Result  

Enhanced 
coordination; 
Enhanced 
cooperation; 
Enhanced 
information flow.  

The  first  of  three  operational  measures  facilitates  the  enforcement  of  EU  sanctions  against  Russia 
through  enhanced  action  coordination,  cooperation,  and  information  flow  amongst  relevant  Czech 
public authorities. This step, covering the police, public prosecution service, financial intelligence unit, 
and national bank, was reportedly taken in response to the sanctions’ complexity. For instance, while 
tackling fraud against EU revenue streams including VAT and customs, they equally touch upon money 
laundering,  demanding  authorities  that  usually  do  not  work  together  to  cooperate  in  investigating, 
prosecuting, recovering, and sanctioning fraud.  

3.6.2.2. Operational Measure for More Fluid Information Exchanges on Beneficial Owners   

Anti-Fraud Measure #2 Taken by Czechia in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Single 

Operational 

New 

Fraud 
Prevention 

Sectoral: 
Fisheries, 
Cohesion policy 

Public procurement; 
Conflict of interest.  

IT tools ("IT 
data feeding", 
"Other IT") 

Simplification of 
procedures for identification 
of beneficial owners.  

15 

 
 
The second of three operational measures newly interconnects the beneficial owners register with the 
MS2014+ and MS2021+ information systems to improve fraud prevention in fisheries and cohesion 
policy fund distribution. On this path, beneficial owners will, in the future, be identified faster and more 
effectively.  

3.6.2.3. Operational Measure for Enhanced Collaboration on Implementing EU Funds  

Anti-Fraud Measure #3 Taken by Czechia in 2022 

Single / 
Package  

Type  

New / 
Update 

Single 

Operational 

New 

Stage in 
Anti-Fraud 
Cycle  

Fraud 
Prevention 

Horizontal / 
Sectoral  

Sectoral: 
Fisheries, 
Cohesion 
policy 

Area  

Scope  

Reason / Expected Result  

Public procurement; 
AFCOS; Shared 
management and 
control of EU funds.  

Methodological 
documents for the 
2021+ programming 
period 

Enhanced coordination; 
Enhanced cooperation; 
Enhanced information 
flow; Targeting of 
checks.  

Thirdly,  Czechia  enhanced  cooperation,  coordination,  and  information  flow  for  fraud  prevention  in 
fisheries and cohesion policy spending by completing all methodological documents associated with 
the  2021  –  2027  period.  These  documents  form  the  basic  framework  for  implementing  EU  funds, 
including elements that prevent fraud and foster procedural transparency.  

3.7. 
3.7.1.  NAFS 

Denmark  

On 31 December, 2022, Denmark adopted its sectoral national anti-fraud strategy, focusing on cohesion 
policy,  agricultural,  and fisheries  funds.  For the  RRF,  the  Danish  Ministry  of  Finance  is  reportedly 
drafting a separate section to be incorporated into other ministries’ own anti-fraud strategies.  

3.7.2.  Measures 

For  the  2022  reporting  period,  Denmark  listed  predominantly  administrative  anti-fraud  action,  two 
measures being new single measures, the third being integrated into a mixed type package. The first of 
two  standalone  measures  seeks  to  better  prevent  and  detect  fraud  against  cohesion  policy  funds  by 
improving  the  data  used  by  the  Danish  Business  Authority.  A  second  measure  reinforces  these 
objectives by safeguarding the correct application of remuneration rules. The package highlighted by 
Denmark seeks to grow the country’s agricultural agency’s anti-fraud and anti-evasion capacity.  

3.7.2.1. Administrative Measure for Preventing Double Funding 

Anti-Fraud Measure #1 Taken by Denmark in 2022 

Single / 
Package  

Type  

New / 
Update 

Single 

Administrative 

New 

Stage in 
Anti-Fraud 
Cycle  

Fraud 
Prevention 

Fraud 
Detection  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Sectoral: 
Cohesion 
Policy 

Conflict of 
interest; Shared 
management and 
control of EU 
funds.  

Eligibility criteria; 
Management of funds; 
Monitoring/desk checks; 
Administrative controls.  

To clarify or consolidate 
existing rules; Cross-cutting 
measure, multi-agency 
measure/measure with 
impact on various bodies. 

Denmark reportedly put in place a new administrative anti-fraud measure that aims to prevent double 
funding  from  EU  and  domestic  sources,  especially  in  cohesion  policy.  Said  action  integrates  and 
controls ex-post data from compensation schemes with those from the Danish Business Authority. In 
2022, the records of grants paid out from March to August in that year were already processed by the 
Business Authority’s caseworkers. This control has been supplemented with check-lists to ensure that 
participating  companies  do  not  receive  double  funding  by  enabling  project  operators  to  reach  out 
directly and validating this information, too.  

16 

 
 
3.7.2.2. Mixed Package for Building Anti-Fraud and Anti-Evasion Capacity  

Single / 
Package  

Type  

New / 
Update 

Stage in 
Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #2 Taken by Denmark in 2022 

Administrative 

New 

Package  

Organisational  

New 

Operational  

Update 

Fraud 
Prevention 

Fraud 
Detection  

Management of funds; 
Monitoring/desk checks; 
on the spot checks.  

To clarify or consolidate 
existing rules; To 
enhance existing 
measure.  

Sectoral: 
Agriculture 

Shared 
management and 
control of EU 
funds.  

Reorganisation of 
existing bodies; 
Competence.  

Increased resources.  

IT tools ("IT data 
feeding", "Other IT"); 
Risk indicators, 

Targeting of checks; 
Targeting of 
investigations.  

The  second  measure  that  Denmark  submitted  is  a  package  of  administrative,  organisation,  and 
operational measures intended to grow the country’s agricultural agency’s anti-fraud and anti-evasion 
capacity. To  this end, a  specialised  division  has  been  formed  within the agency.  It  will,  concretely, 
ensure correct, consistent, and timely follow-up on red flags. According to the Danish survey response, 
this action received considerable resources and priority.  

3.7.2.3. Administrative Measure for Safeguarding Remuneration Rules 

Anti-Fraud Measure #3 Taken by Denmark in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Single 

Administrative 

New 

Fraud 
Prevention 

Fraud 
Detection  

Sectoral: 
Cohesion 
Policy 

Shared management 
and control of EU 
funds 

Eligibility criteria; 
Management of funds; 
Monitoring/desk checks.  

To clarify or 
consolidate 
existing rules. 

The final measure reported by Denmark sets out to safeguard the correct application of remuneration 
rules, which the Member State has identified to have caused an array of problems in the past. The action 
explicitly integrates income register data and project reporting data, facilitating the correct application 
of  standard  salary  rates  and  data  use.  While  adopted  in  2022,  the  measure  will  likely  only  become 
effective in 2023.  

3.8. 
3.8.1.  NAFS  

Estonia 

On 18 January, 2022, Estonia adopted an anti-corruption strategy that also defends the EU’s financial 
interests. It applies to public and municipal authorities and the environmental, health care, welfare, and 
sports sectors.  

3.8.2.  Measures 

Estonia’s most crucial anti-fraud action was varied in terms of type but focused exclusively on fraud 
prevention and  detection, with two  of them  being  horizontal and  one focusing on  customs.    On the 
revenue  side,  Estonia  realised  a  single  operational  measure,  an  IT  tool  that  compares  declared  and 
Theseus prices. The second measure reported by the country is a package of a legislative update and its 
operational  demands,  which  automatically  link  public  procurement  procedures  to  the  invoices  paid, 
boosting controlling. At the organisational level, Estonia updated its training catalogue.  

3.8.2.1. Operational Measure for Combatting Undervaluation  

17 

 
 
Anti-Fraud Measure #1 Taken by Estonia in 2022 

Single / 
Package  

Type  

New / 
Update 

Single 

Operational 

New 

Stage in 
Anti-Fraud 
Cycle  

Fraud 
Prevention 

Fraud 
Detection  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Sectoral: 
Customs 

Customs/TOR/illicit 
trade 

IT tools ("IT data 
feeding", "Other 
IT"); Risk indicators; 
Increased number of 
checks.  

Enhanced coordination; 
Enhanced information flow; 
Targeting of checks; Targeting 
of investigations; Enhanced ex-
post controls.  

For 2022, Estonia further reported that its customs authority had created an operational IT tool that 
more  broadly  prevents  and  detects  undervaluation.  Said  tool  automatically  checks  declared  prices 
against those enlisted in the Theseus EU database. Customs have, simultaneously, expanded their use 
of this database from textiles and footwear to commodities at large. In effect, detecting and identifying 
undervaluation in customs declarations has become easier.  

3.8.2.2. Mixed Package for Improved Controls and Audit Effectiveness 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #2 Taken by Estonia in 2022 

Legislative 

Update  

Fraud 
Prevention 

Competences 

Reason / Expected 
Result  

To clarify or 
consolidate existing 
rules. 

Package 

Horizontal 

Public 
procurement 

Operational  

New 

Fraud 
Detection  

IT tools ("IT data feeding", 
"Other IT"); Risk 
indicators.  

Enhanced information 
flow; Targeting of 
checks.  

The  package  reported  by  Estonia  encompasses  amendments  to  its  Public  Procurement  Act  and  an 
operational IT tool that help prevent and detect fraud in this area. On the one hand, the legislative update 
(§ 83(71), § 83(32), § 124 (1) (21)), effective since 1 June, 2022, focuses on the exclusion of economic 
operators.  Potential  exclusion  grounds  are  made  easier  to  detect  as  are  irregularities  by  connecting 
public  procurement  procedures  to  invoices  paid,  ensuring  that  economic  operators  that  should  be 
excluded do not get their hands on EU funds. The IT, on the other hand, back this framework up by 
creating a direct link between the procurement register and the national unified economic accounting 
software. Public procurement procedures are thereby automatically linked to invoices paid, improving 
control and audit effectiveness.  

3.8.2.3. Organisational Measure for Enhanced Cooperation among Authorities 

Anti-Fraud Measure #3 Taken by Estonia in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Single 

Organisational 

Update 

Fraud 
Prevention 

Fraud 
Detection  

Horizontal 

Financial crime (Including money 
laundering); Conflict of interest; Fraud 
definition; AFCOS; Shared 
management and control of EU funds.  

General 
trainings; Fraud 
awareness 
trainings.  

Reason / 
Expected 
Result  

Neutral on 
resources. 

The final action highlighted by Estonia, is a series of organisational trainings on the protection of the 
EU’s financial interests meant to enhance cooperation. This series kicked off in spring 2022 with 30 
persons from 15 interconnected authorities attending, followed by an OLAF introductory training for 
more  than  150  professionals  in  autumn.  By  bringing  staff  from  various  executive  and  investigative 
bodies together, these meetings intend to pave the way for cooperation. 

18 

 
 
 
 
3.9. 
3.9.1.  NAFS 

Finland  

Currently, Finland neither has a national anti-fraud strategy in place, nor does the Member State plan 
to establish such a strategy. 

3.9.2.  Measures 

For  2022,  Finland  only  reported  two  new  measures,  both  primarily  aiming  to  strengthen  fraud 
prevention, horizontally and around RRF funds. The administrative measure comprises guidelines to 
curbing corruption in the central state administration, which runs and supervises EU funds management. 
The organisational measure denotes training sessions on fraud prevention in administering RRF funds.  

3.9.2.1. Administrative Measure for Curbing Corruption in the Central Administration  

Anti-Fraud Measure #2 Taken by Finland in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Single 

Administrative 

New 

Fraud Prevention 

Fraud Detection  

Horizontal 

Corruption  

Fighting corruption in 
public administration 

To enhance 
existing measure 

The first anti-fraud action listed by Finland for 2022 is a set of administrative guidelines that aims to 
curb corruption in the central state administration, which is responsible for running and supervising EU 
funded programmes. The Ministry of Finance issued  these guidelines to state administrators to help 
them detect and identify corruption and act accordingly. To managerial staff the measure further gives 
guidance on applying procedures properly and controlling corruption risks.  

3.9.2.2. Organisational Measure for Finland’s Recovery and Resilience Plan  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 Taken by Finland in 2022 

Single 

Organisational 

New  

Fraud Prevention 

Sectoral: Recovery and 
Resilience Facility  

AFCOS 

General trainings; Fraud 
awareness trainings.  

Neutral on 
resources 

For  2022,  Finland  reported  that  it  held  training  sessions  on  fraud  prevention  in  administering  and 
supervising  RRF  funds.  These  trainings  were  jointly  organised  by  the  State  Treasury,  Ministry  of 
Employment and Economic Affairs, and Finland’s AFCOS for the responsible authorities, who have 
little prior experience with running EU programmes. Therefore, the trainings focused on operational 
procedures as well as fraud risks associated with RRF funding. In some of these training sessions, OLAF 
and  the  EPPO  participated,  too,  for  the  Finnish  authorities  to  be  fully  conscious  of  the  regulatory 
environment around fraud.  

19 

 
 
 
 
 
3.10. 
3.10.1.  NAFS  

France  

On 4 February, 2022, France adopted its national anti-fraud strategy, cross-cutting and covering the 
EU’s financial interests. The Member State additionally runs an anti-corruption strategy, which protects 
the EU’s financial interests, too.  

3.10.2.  Measures  

For  2022,  France  adopted three  single  measures, one  legislative  update  and two  new  organisational 
actions, all of which cover fraud detection. The legislative update is horizontal, aligning French law 
with  EU  law  on  whistleblowers  and their  protection  across  the  board. The  second  action  is  equally 
horizontal but organisational in nature, concerning a training agreement and special training courses 
with the EPPO. The second organisational measure targets specifically the RRF and has created a task 
force to monitor and anticipate fraud risks.  

3.10.2.1.  Legislative Measure for a Higher Level of Protection for Whistleblowers  

Anti-Fraud Measure #1 Taken by France in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Single 

Legislative  

Update 

Fraud Detection  

Investigation and 
Prosecution  

Horizontal 

Whistle-
blowers;  

Definition of a 
specific topic 

To enforce the rules in line 
with developments in EU law 

The legislative measure reported by France concerns an update and the alignment of domestic with EU 
law on the protection of whistleblowers. Law No. 2022-401 from 21 March, 2022, concretely clarifies 
the definition of whistleblower and the scope of information covered by whistleblowing, the scope of 
protection,  supplementing  also  the  list  of  information  covered  by  professional  secrecy.  Should 
whistleblowers wish to benefit from protection, the channels available to them for reporting the facts 
have been simplified, and their non-liability for reporting extended.  

In more clearly defining a whistleblower, France has loosened several requirements, therefore granting 
protection  more  easily  and  increasing  the  chance  of  fraud  detection,  investigation,  and  prosecution. 
Before the update, a whistleblower had to act “in a disinterest” manner to receive protection. In the Spin 
2 Law, this concept has been replaced with the absence of financial compensation. A whistleblower 
further had to have personal knowledge of the facts on which they reported. This condition has been 
removed  from  the  definition,  recognising  that  protection  should  be  granted  even  if  the  information 
reported on has been relayed to the whistleblower. And, finally, the breach of the rule, no longer has to 
be “serious and manifest”.  

In short, now any natural person who reports or discloses, without financial compensation and in good 
faith, information pertaining to a crime, offence, threat, harm to the public interest, breach, or attempt 
to conceal a breach of international or EU law, is recognised as a whistleblower.  

Besides the definition, other important changes have been made to the Spin 2 Law to enhance fraud 
detection,  investigation,  and  prosecution  by  better  protecting  whistleblowers.  Following  the 
Whistleblowing Directive, the amended Spin 2 Law extends the protection afforded to whistleblowers, 
especially  against  retaliation,  as  well  as  natural  persons  and  non-profit  legal  entities  liked  to  them. 
Further, the law now gives whistleblowers the choice between internal and external reporting to the 
competent authority, the Defender of Rights, the courts, or a European body. The protection of sources 
has been strengthened, too, and the law newly reinforces confidentiality guarantees surrounding a report 
and extends the list of prohibited retaliation. The non-liability of whistleblowers for reporting has been 

20 

 
 
 
extended. The whistleblower may not be attacked in the civil courts for any harm which their report in 
good faith may have caused, or in the criminal courts for having intercepted and carried off confidential 
documents linked to their report containing information to which they had lawful access. The Law also 
aims to limit the financial cost of any proceedings which whistleblowers may have to initiate. At the 
start of a trial, the judge may grant a provision for legal costs to a whistleblower contesting a retaliatory 
measure or a gagging measure taken against them. The civil fine incurred in the event of a gagging 
measure against a whistleblower has been increased to EUR 60 000. Lastly, whistleblowers may benefit 
from psychological and financial support measures by the external authorities.  

In addition to these amendments, Decree No 2022-1284 from October 3, 2022, which implements Law 
No. 2022-401, has appointed the Anti-Fraud Agency alongside the EPPO as the authority responsible 
for  receiving  external  reports  on  breaches  of  integrity  in  particular  where  they  concern  breaches 
affecting the financial interests of the Union. 

3.10.2.2.  Organisational Measure for Effective and Efficient Fund Controls  

Anti-Fraud Measure #2 Taken by France in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Single 

Organisational 

New 

Fraud 
Prevention 
Fraud 
Detection  

Horizontal 

Fraud definition; AFCOS; 
Anti-fraud or anti-corruption 
strategy; Technical training.  

General trainings; 
Fraud awareness 
trainings.  

Reason / 
Expected 
Result  

A second organisational measure reported by France for 2022 concerns a training agreement and special 
training courses on fraud that affects the EU’s financial interests that aim to raise awareness amongst 
relevant  stakeholders  and  delegated  authorities.  Under  Action  1.2.1  of  France’s  NAFS,  the 
Interministerial Anti-Fraud Coordination Office (MICAF) organises these.  

Together with the EPPO, it offers two training modules, one on key concepts concerning fraud, the 
other entitled “Working with the EPPO”, which focuses on reporting fraud the public prosecutor. 

In  addition,  MICAF  alone  an  annual  catalogue  of  cross-cutting  training  courses  intended  for 
stakeholders  responsible  for  tackling  fraud  against  public  finances.  A  network  of  interinstitutional 
trainers design and provide these trainings, which revolve around document fraud, internal control and 
risk management, and the fight against corruption. 

To  facilitate  access  to  these  courses,  the  MICAF  has  proposed  an  agreement  that  sets  out  the 
conditions  for  their  delivery.  Its  signing  by  all  parties  is  currently  ongoing.  Once  running,  the 
courses  will  help  relevant  stakeholders  acquire  the  technical  expertise  needed  to  exercise  fund 
controls effectively and efficiently.  

3.10.2.3.  Organisational Measure for France’s Recovery and Resilience Plan  

Anti-Fraud Measure #3 Taken by France in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected 
Result  

Single 

Organisational 

New 

Fraud 
Prevention 

Fraud 
Detection  

Sectoral: Recovery 
and Resilience 
Facility  

AFCOS; Anti-fraud or anti-
corruption strategy; 
Oversight working group.  

Inter-agency 
cooperation  

Neutral on 
resources 

In 2022, France, amongst other organisational anti-fraud action, created a task force to detect and better 
prevent new types of fraud against RRF funds. Set up under Action 3.2.1 of the Member State’s NAFS 
by the MICAF, the task force brings together relevant domestic stakeholders for exchanges on fraud 
risks, their definition, and, thus, detection. These exchanges could potentially be used to outline a risk 

21 

 
 
  
map for use by systems to detect and investigate such fraud. The task force meets regularly, for the first 
time  on  October  27,  2022,  then  on  February  7,  2023.  Amongst  the  stakeholders  involved  are  the 
National  Recovery  and  Resilience  Plan  Coordination  unit  at  France’s  Treasury,  the  Interministerial 
Committee  for  the  Coordination  of  Inspections,  the  Secretariat-General  for  European  Affairs, 
investigative services, including the Criminal Police’s Central Directorate, the National Gendarmerie’s 
Directorate-General, the Criminal Financial Investigations Service, and the EPPO. 

3.11. 
3.11.1.  NAFS 

Germany 

Germany, due to being a federation, does not have a national anti-fraud strategy. Besides its sectoral 
national strategy, Germany’s states therefore run regional anti-fraud strategies, some targeting specific 
sectors.  

Framing its anti-corruption activities, the Member State has an overall anti-corruption strategy, which 
equally protects the EU’s financial interests at large.  

3.11.2.  Measures 

For  2022,  Germany  reported  three  standalone  administrative  measures  that  predominantly  aim  to 
prevent fraud against EU funds, including agricultural, fisheries and cohesion funds, but also targeted 
the remaining three fraud cycle stages. They range from a new strategy paper to a strategic update and 
an updated self-assessment tool respectively.  

3.11.2.1.  Administrative Measure against Conflicts of Interest in the EU Paying Agency  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected 
Result  

Anti-Fraud Measure #1 Taken by Germany in 2022 

Single 

Administrative  

New 

Fraud 
Prevention 

Sectoral: 
Agriculture, 
Fisheries 

Conflict of 
interest 

Monitoring/desk checks; 
Irregularities reporting; Strategy 
paper.  

To enhance 
existing 
measure 

The first of three administrative single measures adopted by Germany in 2022 is a strategy paper that 
seeks  to  resolve  conflicts  of  interest  in  the  EU  paying  agency  procedure.  Targeting  agriculture  and 
fisheries, the paper lays the groundwork for a more uniform procedure for dealing with conflicts of 
interest in the German paying agencies and administrative authorities throughout the German federal 
system.  

3.11.2.2.  Administrative Measure against Fraud and Corruption  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected 
Result  

Anti-Fraud Measure #2 Taken by Germany in 2022 

Single 

Administrative  

Update 

Fraud Prevention 

Fraud Detection 

Investigation, 
Prosecution  

Recovery and 
Sanction  

Sectoral: 
Cohesion 
policy 

Anti-fraud or Anti-
corruption Strategy  

Management of funds; 
Irregularities reporting.  

Annual update 

22 

 
 
 
For 2022, Germany finally reported an annually foreseen update of the anti-fraud and anti-corruption 
strategy  embedded  in  the  Thuringian  ERDF  operational  programme,  covering  the  entire  anti-fraud 
cycle.  

3.11.2.3.  Administrative Measure for Sounder Fraud Risk Analyses and Action 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #3 Taken by Germany in 2022 

Single 

Administrative  

Update 

Fraud 
Prevention 

Sectoral: 
Cohesion 
Policy 

Conflict of interest; Anti-
fraud or Anti-corruption 
Strategy.  

Monitoring/desk 
checks  

Reason / 
Expected 
Result  

To enhance 
existing 
measure 

The second of three administrative actions taken encompasses self-assessment tools, following up on 
Article 125(4)(c) of Regulation (EU) No 1303/2013 on the European Structural and Investment Funds 
for  the  2014  –  2020  programming  period  as  well  as  well  as  Annex  I  to  the  Guide  to  Fraud  Risk 
Assessment and Effective and Proportionate Anti-Fraud Measures. Employed by the ERDF Managing 
Authority, this measure was meant to ensure that fraud risk assessments were sound, and anti-fraud 
measures effective and appropriate.  

3.12. 
3.12.1.  NAFS 

Greece  

On 10 March, 2017, Greece last updated its national anti-fraud strategy, which, to date, focuses on the 
use of cohesion policy funds across the country.  

3.12.2.  Measures 

For 2022, Greece submitted three exclusively legislative single measures that mostly target the early 
stages of the anti-fraud cycle. One legislative measure is horizontal while the other two focus on RRF, 
agricultural, and fisheries funds. The horizontal measure transposes the Whistleblowing Directive into 
Greek law. To the Greek RRF Coordination Agency, an amendment adds a dedicated fraud prevention, 
detection, recovery, and sanctions unit. A third measure follows an EU recommendation, separating 
administrative from on-the-spot checks under agriculture and fisheries fund management. 

3.12.2.1.  Legislative Measure for a Higher Level of Protection for Whistleblowers 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #1 Taken by Greece in 2022 

Single 

Legislative 

New 

Fraud 
Detection 

Horizontal 

Whistle-
blowers 

Competences; Definition of a 
specific topic; Other administrative 
penalties; Criminal sanctions.  

To enforce the rules in 
line with developments 
in EU law 

The  first  legislative  measure  transposes  the  Whistleblowing  Directive  and  other  emergency 
arrangements that protect persons who report breaches of Union law into Greek law. Law 4990/2022 
establishes  a  system  for  reporting  said  breaches,  protect  the  persons  who  report  them,  secures  a 
corresponding submission procedure, sets up a channel for receiving and following up on reports, as 
well as a scheme for infringement penalties.  

23 

 
 
 
 
3.12.2.2.  Legislative Measure for Greece’s Recovery and Resilience Plan  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #2 Taken by Greece in 2022 

Fraud 
Prevention  

Single 

Legislative 

Update  

Fraud Detection  

Recovery and 
Sanction  

Sectoral: 
Recovery 
and 
Resilience 
Facility 

Public procurement; 
Corruption; Conflict of 
interest; Fraud definition; 
Shared management and 
control of EU funds; Anti-
fraud or anti-corruption 
strategy.  

Competences 

To clarify or consolidate 
existing rules; To remedy 
flaws; To enforce the 
rules in line with 
developments in EU law.  

Greece has further reported a legislative update, which adds to its RRF  Coordination Agency a unit 
dedicated to fraud prevention, detection, recovery, and sanction in this sector. Its Planning Procedures 
and Assessing Audits directorate has been formed under Article 62 of Law 4916/2022 and Article 273 
of Law 4738/2020, which form its statue. Accordingly, the directorate will draw up, monitor, and review 
actions that implement Greece’s RRF Anti-Fraud Strategy, assess fraud risks, and adopt measures to 
combat fraud.  

3.12.2.3.  Legislative Measure against Conflict of Interests Risks  

Single / 
Package  

Type  

New / 
Update 

Stage in 
Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #3 Taken by Greece in 2022 

Single 

Legislative 

Update  

Fraud 
Prevention  

Sectoral: 
Agriculture, 
Fisheries 

Public procurement; 
Corruption; Conflict of interest; 
Fraud definition; Shared 
management and control of EU 
funds; Anti-fraud or anti-
corruption strategy.  

Competences 

To clarify or consolidate 
existing rules; To remedy 
flaws; To enforce the rules 
in line with developments 
in EU law.  

The  third  legislative  anti-fraud  action  described  by  Greece  follows  a  European  Commission 
recommendation (No PAYR/2020/004/GR/LF), separating administrative from on-the-spot checks of 
agriculture  and  fisheries  funds  to  mitigate  conflict  of  interest  risks.  Said  risks,  the  recommendation 
reads, stem from the responsible Secretary General covering the relevant audit bodies and overseeing 
an EAFRD non-ICAS action beneficiary. On December 29, 2022, and by a ministerial decision (No 
3658(392485/2022), the duties for administrative and on-the-spot checks have now been allocated to 
the agency heads concerned with the common agricultural policy (CAP).  

3.13. 
3.13.1.  NAFS 

Hungary  

On 15 November, 2022, Hungary updated its cross-cutting national anti-fraud strategy, covering the 
EU’s financial interests and the whole national territory. With government decision No 1540/2020, not 
only operations under the 2021 – 2027 programming period and RRF, but equally those under the 2014 
– 2020 program, the Brexit Fund, cross-border interregional schemes, and common agricultural policy 
will be integrated into the Member State’s NAFS.  

Beyond anti-fraud measures, the Hungarian strategy covered anti-corruption tools until 2022.  

24 

 
 
 
 
3.13.2.  Measures 

For 2022, Hungary reported the adoption of three mixed packages, two of which are horizontal, while 
a third covers a wide array of EU funds, focusing primarily on fraud prevention and detection. The first 
of two horizontal measures implements the Commission notification submitted to Hungary under the 
conditionality  mechanism,  which  relates  to  the  country’s  public  procurement  system,  through  new 
legislation and an operational update. The second of two horizontal measures is instead composed of a 
legislative update and a new operational measure, which strengthen cooperation between the Member 
State and OLAF on investigations. The final package targets multiple funds and entails new legislative, 
organisational, and operational steps, laying the groundwork for two bodies that will control EU funds.  

3.13.2.1.  Mixed Package for More Competition and Transparency in Public Procurement 

Anti-Fraud Measure #1 Taken by Hungary in 2022 

Single / 
Package  

Type  

New / 
Update 

Legislative 

New 

Package  

Horizontal / 
Sectoral  

Stage in 
Anti-Fraud 
Cycle  

Fraud 
Prevention  

Operational   Update  

Fraud 
Detection  

Horizontal 

Public procurement; 
Corruption; Conflict 
of interest.  

Area  

Scope  

Reason / Expected Result  

Competences; 
Powers.  

To remedy flaws; To enforce 
the rules in line with 
developments in EU law. 

IT tools ("IT data 
feeding", "Other 
IT") 

Enhanced information flow; 
Enhanced ex-ante controls; 
Enhanced ex-post controls; 
Greater transparency.  

The  first  package  is  made  up  of  a  legislative  and  an  operational  measure,  focusing  on  public 
procurement as advised by the Commission notification submitted to Hungary on 27 April, 2022, under 
the conditionality mechanism. The latter objected specifically to the large share of single-bid procedures 
and  low  degree  of  competition  marking  Hungary’s  system  and  attesting  to  poor  prevention  and 
detection.  

In an attempt to even out these flaws, Government Decree No 63/2022 and Government Decision No 
1425/2022  describe  specific  measures,  the  actors  involved,  as  well  as  their  responsibilities  and 
deadlines.  An  example  of  such  a  measure  is  a  novel  framework  for  reviewing  public  procurement 
procedures’ merit in terms of efficiency and cost-effectiveness.  

In context of bidding specifically, the operational measure prioritises transparency, thus foreseeing a 
monitoring system and review of Hungary’s current Electronic Procurement System.  

3.13.2.2.  Mixed Package for a Stronger Cooperation with OLAF  

Anti-Fraud Measure #2 Taken by Hungary in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Legislative 

Update  

Fraud Prevention  

Competences; Powers; 
Other administrative 
penalties.  

To enforce the rules in 
line with developments in 
EU law 

Package  

Fraud Detection  

Horizontal 

OLAF on-site 
inspections 

Operational  

New 

Investigation and 
Prosecution 

Support for OLAF 
investigations 

Enhanced cooperation; 
Smoother cooperation.  

25 

 
 
The  second  package  is  composed  of  a  legislative  update  and  a  new  organisational  measure,  which, 
together, aim to strengthen cooperation between Hungary and OLAF in instances when an economic 
operator under investigation fails to do so. In other words, Act XXIX 2022 aligns Hungarian with EU 
law by enabling OLAF to request the assistance of the national tax and customs administration and 
fining its failure to cooperate. At the operational level, Hungary has, in turn, enabled customs officers 
to assist OLAF with on-the-spot checks in the event of resistance by the investigated economic operator. 
Ultimately, these measures thereby effect most phases of the anti-fraud cycle.  

3.13.2.3.  Mixed Package for a More Effective Control of EU Funds 

Single / 
Package  

Type  

New / 
Update 

Stage in 
Anti-Fraud 
Cycle  

Horizontal / Sectoral  

Area  

Scope  

Anti-Fraud Measure #3 Taken by Hungary in 2022 

Legislative 

Fraud 
Prevention  

Package  

Organisational  

New 

Fraud 
Detection  

Operational  

Sectoral: Agriculture, 
Fisheries, Cohesion 
Policy, Centralised 
Direct Management, 
Fund for the Most 
Deprived, Globalisation 
Fund, Migration and 
Asylum, Recovery and 
Resilience Facility  

Public 
procurement; 
corruption; 
conflict of 
interest; 
shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy.  

Reason / Expected 
Result  

To remedy flaws; To 
enforce the rules in 
line with 
developments in EU 
law. 

Competences; Powers; 
Definition of a specific 
topic.  

Reorganisation of existing 
bodies; New body. 

Increased resources 

IT tools ("IT data feeding", 
"Other IT"); Risk 
indicators; Increased 
number of checks; 
Structured cooperation 
with law enforcement; 
Structured cooperation 
with judicial authorities.  

Enhance 
cooperation; 
Targeting of checks; 
Targeting of 
investigations; 
Enhanced ex-ante 
controls; Enhanced 
ex-post controls.  

The third action reported by Hungary for 2022 is threefold, composed of a legislative, an organisational, 
and an operational measure, laying the groundwork for two bodies and with them, a  more effective 
control of EU funds and compliance with the conditionality procedure invoked against the Member 
State.  

Legislative  Act  XXVII  2022  establishes  an  Integrity  Authority  and  Anti-Corruption  Task  Force, 
specifying the processes underlying them, their legal status, responsibilities, powers, guidance and rules 
for their operations, organisational structure, as well as their staff’s rights and obligations. 

Markedly, both bodies will bring objectivity to anti-fraud action in Hungary. The Integrity Authority 
will be independent and autonomous. Half of the task force will be composed of non-state actors that 
combat corruption without the government, authorities, political parties, and business interests.  

Whilst  equally  independent,  the  bodies  will  approach  anti-fraud  action  differently.  The  Integrity 
Authority, on the one hand, will strengthen prevention, detection, conflicts of interest, corruption, as 
well as other infringements and irregularities linked to EU funds spending. It may further control public 
contracts financed fully or partly through EU funds, impose related information obligations, and register 
legal persons that are to be excluded from public procurement. The Anti-Corruption Task Force, on the 
other hand, will examine anti-corruption measures and propose improvements as well as wholly new 
measures, which will be reflected in an annual report.  

The remaining two actions, an organisational and an operational initiative, make adjustments to existing 
structures and tools to accommodate these new bodies.  

26 

 
 
 
 
3.14. 
3.14.1.  NAFS 

Ireland 

Ireland reported that it neither had a NAFS in place nor planned to set up one up.  

3.14.2.  Measures  

The  Member  State,  however,  pointed  toward  two  single  organisational  measures  that  thoroughly 
fostered anti-fraud action at all cycle stages in the management of agricultural and fisheries funds. The 
first measure enhanced the fraud register, while the second measure entails an IT solution for conflict 
of interest declarations.  

3.14.2.1.  Organisational Measure for Simpler Anti-Fraud Action 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected 
Result  

Anti-Fraud Measure #1 Taken by Ireland in 2022 

Single  

Organisational 

New 

Fraud Prevention 

Fraud Detection 

Investigation and 
Prosecution  

Recovery and 
Sanction  

Sectoral: 
Agriculture, 
Fisheries 

Public procurement; Financial 
crime (including money 
laundering); Conflict of interest; 
Fraud definition; Whistleblowers; 
Control of EU funds; Anti-Fraud 
or Anti-Corruption Strategy.  

Fraud awareness 
trainings; 
Simplification of 
procedures.  

Increased 
resources 

Touching  on  all  stages  of  the  anti-fraud  cycle,  the  first  of  two  organisational  measures  reported  by 
Ireland  for  2022  encompasses  a  review  of  its  fraud  and  financial  crime  policy  around  managing 
agricultural and fisheries funds. It more specifically enhanced the fraud register, detailing of anti-fraud 
measures across the managing authorities and specific reporting pathways in relation to suspected fraud. 
In this context, Ireland also planned training to all relevant staff.  

3.14.2.1.1.  Organisational  Measure  for  Managing  Conflict  of  Interest  Declarations  More 

Effectively  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 Taken by Ireland in 2022 

Single 

Organisational 

New 

Fraud Prevention  

Sectoral: 
Agriculture, 
Fisheries 

Conflict of 
interest 

Scope; Simplification of 
procedures.  

The  second  organisational  measure  reported  by  Ireland  constitutes  a  new  electronic  system  for 
managing conflict of interest declarations, therefore boosting mainly fraud prevention in agriculture and 
fisheries funds. Especially the overwhelming complexity of managing these declarations manually due 
to staff mobility, for example, pushed Ireland toward adopting this measure.  

3.15. 
3.15.1.  NAFS 

Italy  

Italy adopted its national anti-fraud strategy on 1 January, 2022. Its NAFS is cross-cutting, protecting 
the EU’s financial interests across its entire territory. 

27 

 
 
 
  
 
 
3.15.2.  Measures 

For  2022,  Italy  reported  a  customs  focused  mixed  method  updating  package,  a  new  horizontal 
legislative measure, and a standalone operational update, which jointly cover all stages of the anti-fraud 
cycle.  The  package  intended  to  curb  tax  evasion  and  money  launder  associated  with  the  entry  of 
underdeclared  Chinese  goods  into  EU  territory.  The operational  update  concerns  a  plan  that  targets 
customs  and  VAT  fraud,  and,  finally,  the  legislative  measure  aligned  Italian  with  EU  law  on  asset 
confiscation. 

3.15.2.1.  Mixed Package against the Undervaluation of Goods Entering the EU 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #1 Taken by Italy in 2022 

Administrative 

Fraud 
Prevention  

On the spot checks; 
Investigation; Irregularities.  

Reason / Expected 
Result  

Cross-cutting 
measure, multi-
agency measure/ 
measure with 
impact on various 
bodies 

Package  

Organisational 

Update 

Fraud 
Detection  

Sectoral: 
Customs  

Organised crime; 
Customs/TOR/illicit 
trade. 

Inter-agency cooperation; 
Fraud awareness trainings. 

Increased resources 

Operational  

Investigation 
and 
Prosecution  

Risk indicators; Increased 
number of checks; 
Structured cooperation with 
law enforcement; 
Structured cooperation with 
judicial authorities.  

Targeting of 
checks; Targeting 
of investigations.  

Italy, firstly, reported a mixed-measure package for 2022, which, joining administrative, organisational, 
and  operational,  aimed  at  the  improved  prevention,  detection,  investigation,  and  prosecution  of  tax 
evasion and associated money launder linked to customs. Specifically Chinese underdeclared goods 
entering EU territory were at the package’s core. The administrative action encompassed a report on 
the inspected undertakings’ tax residence, which was produced cooperatively by the Revenue Agency 
and competent judicial authorities. In the organisational and operational domains, the Customs and State 
Monopolies  Agency’s  Anti-Fraud  Directorate  updated  its  local  offices  on  the  forms  of  tax  evasion 
linked to undervalued Chinese products’ entry into the EU. Included in this update were the financial 
intelligence unit’s report and the Prime Minister’s Office’s annual report on information security policy, 
which highlighted the impact of underinvoicing by and dangers of Chinese criminal organisations.  

13.15.2.2. Operational Measure for Building Anti-VAT Fraud Capacity  

Anti-Fraud Measure #2 Taken by Italy in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Single 

Operational  Update 

Fraud Prevention  

Fraud Detection  

Investigation and  
Prosecution  

Recovery and 
Sanction  

Sectoral: 
Customs, 
Tax Fraud 

Fraud definition; 
Customs/ToR/Illicit 
trade; Anti-fraud or 
anti-corruption 
strategy.  

Risk indicators; 
Structured 
cooperation with law 
enforcement; 
Structured 
cooperation with 
judicial authorities.  

Enhanced cooperation; 
Targeting of checks; 
Targeting of 
investigations; 
Enhanced ex-ante 
controls; Enhanced ex-
post controls.  

Italy, for 2022, further reported an operational plan that targets all stages of VAT and customs fraud. In 
drawing up said plan, the Guardia di Finanza participated in four projects. Firstly, it took part in the 
EMPACT  international  cooperation  circuit,  leading  on  the  missing  trader  intra  community  fraud 
priority,  and  heading  an  operation  against  carousel  fraud  in  the  retail  sector.  The  law  enforcement 

28 

 
 
agency  was,  secondly,  involved  in  the  EMPACT  project,  which  focused  on  excise  duty  fraud  and 
countered illegal activities around processed tobacco. Thirdly, the Guardia di Finanza participated on 
the Joint Action Days and Joint Customs operations of the Law Enforcement Working Party. Finally, it 
performed customs checks that revolved around the international trade in endangered species of wild 
fauna and flora.  

13.15.2.3. Legislative Measure for an Enhanced Anti-Fraud Capacity  

Anti-Fraud Measure #3 Taken by Italy in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Investigation, 
Prosecution 

Package 

Legislative 

New 

Horizontal 

Recovery and 
Sanction  

Public procurement; Fraud 
definition; Customs/ToR/illicit trade; 
Shared management and control of 
EU funds; Anti-fraud or anti-
corruption strategy  

Definition of a 
specific topic; 
Recovery; 
Criminal 
sanctions.  

To enforce the 
rules in line with 
developments in 
EU law 

Across sectors, the packaged legislative measures reported by Italy for 2022 align domestic with EU 
law in defining asset confiscation to improve the competent authorities’ capacity for fraud investigation, 
prosecution, sanctioning, and funds recovery. Law No. 25 of 28 March, 2022, and Legislative Decree 
No. 156 of 4 October, 2022, increase the scope of confiscation in circumstances specified in Article 240 
bis of the Italian Criminal Code and amend said circumstances in Articles 316 bis, 316 ter, and 640 bis. 
Effectively, all fraud types that damage the EU’s financial interest are now covered by confiscation for 
disproportionality and smuggling.  

3.16. 
3.16.1.  NAFS 

Latvia  

Latvia has had a national anti-fraud strategy since 29 May, 2020, cutting across sectors and protecting 
the EU’s financial interests across its entire territory. Its update is due in 2023.  

3.16.2.  Measures 

For 2022, Latvia reported three new standalone anti-fraud measures, which were exclusively intended 
to improve fraud detection, horizontally and in taxes. The operational measure is an IT tool used to 
search for red flags in revenue and expenditure controls and checks. The first of two organisational 
measures,  concerns  an  e-learning  course  on  the  protection  of  the  EU’s  financial  interests,  available 
country wide, the second refers to capacity building trainings for revenue and control staff.  

3.16.2.1.  Operational Measure for a Broad Access to Fraud Risk Data   

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #1 Taken by Latvia in 2022 

Single 

Operational  

New 

Fraud 
Detection 

Horizontal 

AFCOS  

IT tools ("IT data 
feeding", "Other 
IT")  

Targeting of checks; Targeting of 
investigations; Enhanced ex-post 
controls.  

The first of three anti-fraud actions described by Latvia is an operational IT tool for fraud detection as 
regards  EU  revenues  and  expenditures.  It  was  designed  by  AFCOS  based  on  the  “Methodology  on 
Typologies of Crimes that Can Cause Damage to the EU’s Financial Interests”. Accordingly, the tool 

29 

 
 
allows users countrywide to search for red flags and typologies of fraud with filters, aiming to improve 
data analysis during controls and checks within fraud detection.  

3.16.2.2.  Organisational Measure for an Improved Awareness of the AFCOS’s Duties 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #2 Taken by Latvia in 2022 

Single 

Organisational 

New 

Fraud Detection 

Horizontal 

AFCOS  

General 
trainings  

Neutral on resources 

For 2022, the first of two organisational measures reported by Latvia concerns an e-learning course on 
the protection of the EU’s financial interests that is available country wide. Developed by AFCOS, the 
course encompasses four chapters that give its user an insight to the history of EU anti-fraud, regulatory 
acts, and definitions, the institutions involved and their tasks, anti-fraud actions, and fraud reporting. 
The course will be available to the AFCOS network’s employees, familiarise new employees with their 
job duties, and upkeep this awareness.  

3.16.2.2.1.  Organisational Measure for Greater Fraud Detection Capacity Among Revenue 

Control Staff 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 Taken by Latvia in 2022 

Single 

Organisational 

New 

Fraud Detection  

Sectoral: Tax 
Fraud  

Fraud 
Definition  

Competence   Decreased resources 

Latvia  thirdly  reported  another  organisational  measure  aimed  at  building  fraud  detection  capacity 
amongst revenue control staff through trainings. These sessions were provided under OLAF’s Hercule 
III programme and correspondingly sought to better integrate technical means and software for fraud 
detection into the State Revenue Service’s daily control activities. They more specifically taught staff 
how to retrieve data through programmes from carriers, and cloud storage during these activities in a 
consistent  format.  Detecting  incomplete  declarations  should  therefore  become  easier,  as  should  the 
continuation of control measures, from audits to the initiation of criminal proceedings.  

3.17. 
3.17.1.  NAFS  

Lithuania  

Lithuania follows a NAFS, more specifically, an Anti-Corruption Strategy that also covers the EU’s 
financial  interests.  But,  the  development  of  an  anti-fraud  strategy  and  methodology  for  assessing 
criminal threats to the financial system, including EU funds is ongoing.  

30 

 
 
 
 
3.18. 
3.18.1.  NAFS  

Luxembourg  

Luxembourg does not have a NAFS in place, however, the procedure for establishing such a strategy is 
ongoing. In said process, Luxembourg relies on the 2021 – 2027 funding programme and RRF results. 

The Member State will until then follow a sectoral national strategy that targets specifically cohesion 
policy, agricultural, and recovery and resilience facility funds.  

3.18.2.  Measures  

Luxembourg  reported  two  measures  for  2022,  including  a  single  legislative  update  that  cuts  across 
sectors and a new operational package that is dedicated to the RRF, which cover all stages of the anti-
fraud  cycle.  The  legislative  measure  aligns  Luxembourgish  law  on  mutual  assistance  and  the  fight 
against  money  laundering  and  the  financing  of  terrorism  with  international  standards,  while  the 
operational measure broadly relates to the framework underpinning the country’s RRP.  

3.18.2.1.  Legislative Measure for Improved International Mutual Assistance  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #1 Taken by Luxembourg in 2022 

Fraud Prevention 

Fraud Detection 

Single  

Legislative 

Update  

Horizontal  

Investigation and 
Prosecution  

Recovery and 
Sanction  

Financial crime 
(including money 
laundering)  

Powers; Definition 
of a specific topic. 

To clarify or 
consolidate existing 
rules 

For 2022, Luxembourg reported a single legislative measure that aligns key legal texts governing the 
international  mutual  assistance  on  criminal  matters  and  the  fight  against  money  laundering  and  the 
financing of terrorism, and ensures that they comply with international standards. On 12 August, 2022, 
the  law  from  29  July,  2022,  entered  into  force,  updating  the  criminal  procedure  code,  the  law  of  8 
August, 2000, on international judicial assistance in criminal matters, the law of 12 November, 2004, 
on the fight against money laundering and terrorist financing, as well as the law from 10 July, 2020, on 
the central fiduciary and trusts register.  

3.18.2.2.  Operational Package for Luxembourg’s Recovery and Resilience Plan  

Single / 
Package  

Type  

New / 
Update 

Package   Operational 

New 

Anti-Fraud Measure #2 Taken by Luxembourg in 2022 

Stage in 
Anti-Fraud 
Cycle  

Fraud 
Prevention 

Fraud 
Detection  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Sectoral: 
Recovery and 
Resilience 
Facility  

Shared 
management 
and control of 
EU funds 

IT tools ("IT data 
feeding", "Other IT"); 
Flagging practice; 
Increased number of 
checks; Structured 
cooperation with judicial 
authorities.  

Enhanced coordination; 
Enhanced cooperation; 
Enhanced information flow; 
Targeting of checks; 
Enhanced ex-ante controls; 
Enhanced ex-post controls.  

The operational anti-fraud action reported by Luxembourg for 2022, is sectorally restricted to the RRF, 
aiming  to  provide  a  framework  to  prevent  and  detect  fraud,  corruption,  double  funding,  and  avoid 
conflicts  of  interest.  This  management  and  control  system  has  been  laid  out  in  alignment  with 

31 

 
 
 
 
Regulation  (EU)  2021/241,  which  established  the  RRF.    It,  correspondingly,  aims  to  implement  an 
effective and efficient control process throughout the execution of the Recovery and Resilience Plan 
and to respond to the various requests of the European Commission or any other authority. 

3.19. 
3.19.1.  NAFS  

Malta 

Malta adopted its updated national anti-fraud and corruption strategy on 31 May, 2021. It now stretches 
across sectors and protects the EU’s financial interests and international public funds throughout the 
Member State.  

3.19.2.  Measures  

Malta reported only one new standalone administrative action, which transverses sectors and targets 
fraud  prevention  and  detection.  It,  more  specifically,  refers  to  the  country’s  first  National  Risk 
Assessment of fraud and corruption in Malta.  

3.19.2.1.  Administrative Measure for Continuously Effective Risk Based Anti-Fraud 

Action 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #1 Taken by Malta in 2022 

Fraud 
Prevention  

Single 

Administrative 

New 

Horizontal 

Fraud and Corruption 
Risk Assessment and 
Management  

Risk 
management 
cycle 

High-level results of the 
first NRA on Fraud and 
Corruption  

Fraud 
Detection  

In 2022, the Internal Audit and Investigations Department, for the first time, undertook a National Risk 
Assessment (NRA) on fraud and corruption in Malta linked to public funds. This also includes funds 
that Malta is required to manage under its international obligations. To protect these effectively, the 
NRA sets out to maintain an effective Maltese risk based regime, prioritise and allocate public resources 
accordingly, assists national authorities in fine tuning their controls, and raise awareness among  the 
general public.  

3.20. 
3.20.1.  NAFS  

Netherlands  

The Netherlands do not have a national anti-fraud strategy in place. The procedure for establishing such 
a  strategy  is,  nevertheless,  currently  ongoing.  Second  only  to  the  centralisation  of  processes  that 
counteract  fraud  against  EU  funds.  The  Dutch  AFCOS  is  key  in  in  the  latter  step,  clarifying  and 
expanding its tasks and responsibilities in coordinating anti-fraud actions.  

In parallel, the Member State still runs a cross-cutting anti-fraud strategy that protects the EU’s financial 
interests across its territory.  

3.20.2.  Measures  

For 2022, the Netherlands reported three measures, including a single but horizontal operational update, 
a customs focused single organisational update, and a standalone operational update on fisheries funds, 
which target primarily fraud prevention but touch upon detection and recovery, too. The first measure 

32 

 
 
 
will ensure that future legislation will be enforceable and verifiable before it becomes effective. The 
second action improved the Netherlands’ reporting on traditional own resources, and, finally the third 
step taken is toward an update fraud risk assessment framework for fisheries funds. 

3.20.2.1.  Operational Measure for More Easily Enforceable and Verifiable Regulation 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #1 Taken by the Netherlands in 2022 

Single 

Operational  

Update  

Fraud 
Prevention  

Horizontal 

Shared management 
and control of EU 
funds 

Risk 
indicators 

Enhanced coordination; 
Targeting of checks; Enhanced 
ex-ante controls.  

In the future, the first of two updated operational measures described by the Netherlands will test new 
regulation  across  the  board.  Targeting  its  enforceability  and  verifiability  before  regulation  becomes 
effective, this testing will enhance coordination, checks, and ex-ante controls throughout the shared 
management of EU funds. As the measure allows any identified flaws to be adjusted, it will strengthen 
help prevent fraud against these funds.   

3.20.2.2.  Organisational Measure for Improved Reporting  

Anti-Fraud Measure #2 Taken by the Netherlands in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Single 

Organisational  

Update  

Fraud Detection  

Recovery and 
Sanction  

Sectoral: 
Customs 

Shared management and 
control of EU funds 

Leading times; 
Mission reports. 

Increased 
resources 

In 2022, the Netherlands further realised an organisational update that ease the shared management and 
control of EU funds by improving the reporting on traditional own resources. This update concerns, 
amongst others, the mutual assistance reports, whose information value has been heightened through 
content adjustments and changes to their handling including leading times. In the long-run, better shared 
management  should  strengthen  fraud  detection  as  well  as  the  fund  recovery  and  fraud  sanctioning, 
freeing up more resources.  

3.20.2.3.  Operational Measure for Comprehensive Fraud Risk Assessments  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 Taken by the Netherlands in 2022 

Single 

Operational   Update  

Fraud 
Prevention  

Sectoral: 
Fisheries 

Shared management 
and control of EU 
funds 

Preventative screening for the 
establishment of good clear 
and enforceable regulations 

Targeting of 
checks; Enhanced 
ex-ante controls. 

33 

 
 
The  second  operational  measure  reported  by  the  Netherlands  points  to  an  update  of  the  fraud  risk 
assessment framework that is obligatory for new legislation governing EU fisheries funding. Aiming to 
strengthen fraud prevention, the measure is to identify possible complications and fraud opportunities 
ahead of them occurring and affecting funds. It maps out these risks, weights and links them to control 
measures,  such  as  specific  checks,  stakeholder  communication,  and  sanctions.  In  this  process,  the 
analysis covers every step, from application to settlement, the type of regulation, its target group, and 
the level of compensation considered.  

3.21. 
3.21.1.  NAFS 

Poland  

Presently, Poland neither runs nor intends to deploy a national anti-fraud strategy.  

3.21.2.  Measures 

For 2022, Poland, nevertheless, reported three all new measures, composed of a mixed type package, 
an operational, and legislative standalone action, which focus on fraud prevention and detection in tax 
revenues,  cohesion  and  agricultural  funds  respectively.  The  package  creates  a  national  e-invoicing 
system, while the single operational measure set up an IT tool used for EU project controls. Finally, the 
legislative  action  lays  out  practices  to  prevent  conflicts  of  interest  amongst  staff  in  the  Ministry  of 
Agriculture and Rural Development.  

3.21.2.1.  Mixed Package for Strengthened VAT Checks 

Anti-Fraud Measure #1 Taken by Poland in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected Result  

Legislative 

New 

Fraud 
Prevention 

Fraud 
Detection  

Competences; 
Powers; 
Definition of a 
specific topic; 
Recovery.  

Package  

Organisational  

New 

Investigation, 
Prosecution  

Sectoral: 
Tax fraud 

Financial crime 
(including 
money 
laundering); 
VAT.  

Simplification of 
procedures 

To remedy flaws; To enforce the 
rules in line with developments in 
EU law. 

Reduced costs of invoicing for 
entrepreneurs; Digitalisation of 
paper and electronic documents; 
Faster, electronic, automated 
circulation of invoices; No need to 
manually register invoices; 
Facilitated and automated posting of 
invoices in financial and accounting 
systems.  

Operational  

New 

Recovery and 
Sanction  

IT tools ("IT data 
feeding", "Other 
IT") 

Enhanced coordination; Enhanced 
information flow.  

In 2022, Poland, firstly, created a national e-invoicing system, which aims to tighten the tax system, 
reduce irregularities in VAT accounting, improve business operating conditions with easier document 
access, and discourage dishonest behaviour on part of taxpayers as a whole. The system, mandated by 
Act  2076, from  October  2021,  and  Regulation  2481 from  27  December,  2021, is  underpinned  by  a 
central, continuously reinforced and updated database of business-to-business and business-to-customer 
transaction invoices, which will also serve as an archive. With a standardised electronic invoice model, 
analyses will be automated and centralised under the National Revenue Administration. Matching this 
new model, the invoicing process has also been simplified and made less bureaucratic. These changes 
then,  intend  to  aid  VAT  checks,  affecting  all  stages  of  the  anti-fraud  cycle  by  modernising  the 
accounting system.  

34 

 
 
3.21.2.2.  Operational Measure for Improved and More Transparent Project Planning 

and Monitoring 

Single / 
Package  

Type  

New / 
Update 

Stage in 
Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #2 Taken by Poland in 2022 

Single 

Operational 

New 

Fraud 
Prevention  

Fraud 
Detection  

Sectoral: 
Cohesion 
Policy 

Shared 
management 
and control of 
EU funds 

IT tools ("IT data feeding", 
"Other IT"); Digitalisation 
of control of EU funded 
projects; simplification of 
control procedures; 
enhancements of control 
related information flow. 

Enhanced coordination; 
Enhanced cooperation; 
Enhanced information flow; 
Targeting of checks; Enhanced 
ex-post controls; Improved 
project controls; Improved risk 
monitoring and fraud trends; 
Better protection of EU financial 
interests.  

For 2022, Poland reported the introduction of a new IT tool used in project controls to better protect EU 
cohesion  policy  as  well  as  recovery  and  resilience  plan  funds  from  being  compromised.  It  more 
specifically  computerises  these  controls,  including  their  underlying  processes  like  the  setting  up  of 
questions and checklists and their implementation, from filling in check lists to compiling the audit trail. 
The application thereby enables inspectors to plan, implement, and record key project control processes 
in one location, enhancing their transparency. Inspectors can, further, more easily monitor projects post 
control, potentially gaining new insights into risk and irregularity trends. And, finally, with this IT tool, 
observers gain access to the controls of implemented and registered projects, speeding up risk responses. 
By improving the control process on full scale, the e-Controls application should correspondingly boost 
fraud prevention and detection. 

3.21.2.3.  Legislative Measure against Conflicts of Interest in the Government  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 Taken by Poland in 2022 

Single 

Legislative 

New 

Fraud Prevention  

Fraud Detection  

Sectoral: 
Agriculture 

Corruption; Conflict 
of interest.  

Definition of a 
specific topic 

To clarify or 
consolidate existing 
rules 

Poland additionally introduced a legislative measure that lays down practices to prevent conflicts of 
interest amongst staff in the Ministry of Agriculture and Rural Development. As part of this ministry’s 
anti-corruption strategy, Order No 21 from 27 September, 2022, specifies the conduct in the case that 
honesty,  objectivity,  or  impartiality  standards  are  being  violated.  It  further  outlines  how  corruption 
threats should be reported, compiled, recorded, and handled, as well as how  corruption, conflicts of 
interest, and anti-corruption actions should be implemented. 

3.22. 
3.22.1.  NAFS 

Portugal  

Since  April  23,  2015,  Portugal  has  had  a  national  anti-fraud  strategy  in  place,  which  is  soon  to  be 
updated. While it is currently limited to cohesion policy funds, this nationwide strategy will then target 
RRF, agricultural, and fisheries funds, too.  

35 

 
 
 
 
3.22.2.  Measures  

For 2022, Portugal reported that it had adopted three operational packages, which made updates to anti-
fraud action across customs, taxes, a variety of funds, and agricultural and fisheries funds respectively 
touching repeatedly upon various stages of the anti-fraud cycle. Firstly, the Member State updated its 
strategic plan for combatting tax and customs duty fraud. Secondly, it updated its national anti-fraud 
strategy,  and,  thirdly,  Portugal  updated  its  strategy  for  ex-ante  quality  controls  of  agricultural  and 
fisheries funding.  

3.22.2.1.  Operational Package for Enhanced Data Quality and Risk Analyses 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #1 Taken by Portugal in 2022 

Fraud Prevention  

Package   Operational 

Update 

Fraud Detection  

Sectoral: 
Customs, 
Tax Fraud  

Plan to combat 
tax and customs 
revenue fraud 
and evasion  

IT tools ("IT data 
feeding", "Other IT"); 
Flagging practice; Risk 
indicators; Increased 
number of checks.  

Enhanced coordination; 
Enhanced information flow; 
Targeting of checks; 
Enhanced ex-ante controls.  

Recovery and 
Sanction 

The  Member  State  adopted  a  package  of  operational  measures  that  implement  the  2021-2022 
Addendum to Portugal’s 2018-2020 Strategic Plan for Combatting Tax and Customs Duty Fraud and 
Evasion. These  measures mostly  digitise existing  means to combat these  malpractices.  Portugal  has 
reported that information quality and quantity have increased since then, allowing tax returns to be pre 
filled and cases of evasion and fraud identified early on. Additionally, the system for declaring low-
value assignments has been complemented with risk assessment tools.  

3.22.2.2.  Administrative Package for an Updated NAFS 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / Sectoral  

Area  

Scope  

Reason / 
Expected 
Result  

Anti-Fraud Measure #2 Taken by Portugal in 2022 

Package 

Administrative   Update 

Fraud 
Prevention 

Fraud 
Detection 

Investigation, 
Prosecution  

Recovery and 
Sanction  

Sectoral: Agriculture, Fisheries, 
Cohesion Policy, Centralised Direct 
Management, Fund for the Most 
Deprived, Globalisation Fund, 
Migration and Asylum, Recovery and 
Resilience Facility  

Anti-fraud or 
Anti-
corruption 
Strategy  

Management of 
funds; 
Irregularities 
reporting.  

Annual 
update 

In  2022,  Portugal  updated  its  national  anti-fraud  strategy  from  cohesion  policy  to  all  EU  funding 
programmes to more wholly protect its financial interests. Close coordination amongst the Inspectorate-
General  for  Finance  Audit  Authority,  the  Development  and  Cohesion  Agency,  and  the  Institute  for 
Agriculture and Fisheries Financing produced a packaged 5-year action plan that covers all stages of 
the anti-fraud cycle. It will involve all bodies that manage and control EU funds in Portugal.  

36 

 
 
 
 
 
3.22.2.3.  Operational Package for More Thorough Oversight  

Anti-Fraud Measure #3 Taken by Portugal in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Fraud 
Prevention  

Package   Operational 

Update 

Fraud 
Detection  

Sectoral: 
Agriculture, 
Fisheries 

Shared 
management and 
control of EU 
funds  

Flagging practice; 
Increased number of 
checks; Parcel and land 
areas management.  

Enhanced coordination; 
Enhanced information flow; 
Enhanced ex-ante controls; 
Enhanced ex-post controls.  

Recovery and 
Sanction 

A second package of operational actions taken by Portugal in 2022 denotes an update of the country’s 
strategy for ex-ante quality controls  to defend payments and contracting in agriculture and fisheries 
against fraud. Said strategy targets particularly young farmers in these domains, tightening up controls 
and  oversight  procedures  for  handling  irregularities  and  recovering  any  unduly  paid  out  aid,  and 
thoroughly monitoring operations in the long-run. Beyond these practical improvements, the strategy 
facilitates liaison amongst the managing authorities.  

3.23. 
3.23.1.  NAFS 

Romania  

Romania does not follow a NAFS, but has initiated its establishment. The decisions made to produce 
the  draft  NAFS  are  currently  being  evaluated  in  terms  of  transparency,  while  the  draft  itself  is 
undergoing  an  inter-professional  consultation.  The  process  will  be  concluded  with  the  government 
endorsing and approving the strategy, which is projected to the first half of 2023.   

In parallel, Romania relies on several domestic strategies that will connect to its future NAFS, such as 
its  national  anti-corruption  strategy  for  2021  –  2025  and  its  medium-term  strategy  for  the  National 
Agency for Fiscal Administration for 2021 – 2024.  

3.23.2.  Measures 

In 2022, Romania took, amongst others, two new and one updating single legislative measures, which 
touched upon all stages of the anti-fraud cycle, concentration on prevention and detection, horizontally, 
the  RRF,  and  various  funds.  The  horizontal  action,  once  again,  concerned  the  transposition  of  the 
Whistleblower  Directive  into  domestic law.  The  RRF  action  regulates the  dispersion  of  funds,  and, 
finally the multiple fund measure proceeded similarly.  

3.23.2.1.  Legislative Measure for a Higher Level of Protection for Whistleblowers  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #1 Taken by Romania in 2022 

Single 

Legislative  

New 

Horizontal  Whistleblowers  

Fraud Detection 

Investigation and 
Prosecution  

Definition of a specific 
topic; Protection of 
whistleblowers.  

To enforce the rules in 
line with developments 
in EU law.  

37 

 
 
 
The first legislative anti-fraud action reported by Romania for 2022 transposes the EU Whistleblower 
Directive,  reinforcing  fraud  detection,  its  investigation,  and  prosecution  by  better  protecting 
whistleblowers  who  act  in  the  public  interest.  Law  361/2022  from  16  December,  2022,  lays  the 
groundwork for this protection of persons who, more specifically, report breaches of the law within 
authorities, public institutions, other legal persons subject to public law, and legal persons governed by 
private  law.  It  sets  out  the  procedures  for  receiving,  examining,  and  acting  on  such  reports, 
whistleblowers’ rights, measures to protect them, authorities’’ obligations, and data subjects’ rights.  

3.23.2.2.  Legislative Measure for Romania’s Recovery and Resilience Plan 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #2 Taken by Romania in 2022 

Single  

Legislative  

New 

Fraud 
Prevention 
Fraud 
Detection 
Investigation, 
Prosecution  
Recovery and 
Sanction  

Sectoral: 
Recovery and 
Resilience 
Facility  

Public procurement; 
Conflict of interest; Shared 
management and control of 
EU funds.  

Competences; 
Powers; 
Recovery.  

To enforce the rules 
in line with 
developments in EU 
law 

The second of three legislative measures reported by Romania is an emergency order that regulates 
funds dispersed under the RRF and/or related national public funds. Emergency Ordinance (GEO) No 
70/2022  from  26  May,  2022,  aims  to  more  effectively  prevent,  verify,  detect,  and  recover  double 
funding and irregularities in public procurement, state aid, and de minimis schemes.  

3.23.2.3.  Legislative Measure for Aligning Romanian with EU Law on Fund Management 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 Taken by Romania in 2022 

Fraud 
Prevention  

Single  

Legislative   Update 

Fraud Detection  

Recovery and 
Sanction 

Sectoral: 
Agriculture, 
Fisheries, 
Cohesion 
Policy, Fund 
for the Most 
Deprived, 
Migration 

Conflict of interest; 
Shared management 
and control of EU 
funds; Recovery of 
state aid.  

Competences; 
Definition of a 
specific topic; 
Recovery; Financial 
penalties.  

To clarify or 
consolidate existing 
rules; To enforce the 
rules in line with 
developments in EU 
law.  

The last of three legislative measures, too, is a government emergency order, which amends the existing 
rules that govern the prevention, detection, and sanctioning of irregularities in the dispersion of EU 
funds in Romania as well as related national funds. On the one hand, Government Emergency Ordinance 
No 97 from 29 June, 2022, aligns Romania’s legal framework under GEO No 66/2021 with relevant 
EU  rules  on  three  accounts.  First,  provisions  on  recovering  and  calculating  interest  on  state  and  de 
minimis aid have been adjusted to reflect EU rules on fund management. Second, Romanian legislation 
regulating conflicts of interests now follows Article 61 of Financial Regulation No 1046/2018. And, 
third, provisions on the annual accounts’ clearance have been amended to mirror EU law. On the other 
hand,  GEO  No  97  adapts  existing  domestic  rules  to  the  new  management  framework  for  regional 
operational  programmes  for  the  2021  –  2027  programming  period.  In  brief,  the  legislative  measure 
closes the gap between Romanian and EU law on fraud prevention, detection, recovery, and sanction 
and future proofs it.  

38 

 
 
3.24. 
3.24.1.  NAFS 

Slovakia  

Since 4 June, 2019, Slovakia has had an updated version of its cross cutting anti-fraud strategy in place, 
which protects the EU’s financial interests throughout its entire territory.  

3.24.2.  Measures  

Slovakia  reported three  measures,  including  two  standalone  novelty  actions,  one  legislative  and  the 
other operational, as well as an updating legislative package. Jointly, these steps touch on all stages of 
the  anti-fraud  cycle  on  multiple  accounts.  The  single  legislative  measure  concerns  amended  rules 
governing  the  distribution  of  fisheries,  cohesion,  and  migration  and  asylum  funds.  The  operational 
measure is a cooperation agreement that defines relevant authorities’ future contribution toward more 
effectively auditing funds, and, finally, the legislative package updated the distribution of RRF funds.  

3.24.2.1.  Legislative  Measure  on  the  Dispersion  of  EU  Funds  and  Treatment  of 

Irregularities 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #1 Taken by Slovakia in 2022 

Single  

Legislative  

New 

Fraud 
Prevention 

Fraud 
Detection 

Investigation, 
Prosecution  

Recovery and 
Sanction  

Sectoral: 
Fisheries, 
Cohesion Policy, 
Migration and 
Asylum  

Conflict of interest; 
AFCOS; Shared 
management and control 
of EU funds; 
Irregularities; 
Transparency.  

Competences; Powers; 
Definition of a specific 
topic; Recovery; 
Financial penalties.  

To enforce the 
rules in line with 
developments in 
EU law 

The first of two legislative measures reported by Slovakia for 2022 concerns new rules governing the 
distribution of fisheries, cohesion policy, and migration and asylum funds in the Member State. Act No. 
121/2022 from March 16, 2022 more concretely contains rules on relations, procedures, and conditions 
for accessing these funds, the competences of the relevant authorities in managing and controlling said 
funds,  as  well  as  liabilities  in  the case  that these  conditions  are breached.  Along  these  considerable 
novelties, the act also outlines the handling of irregularities through, for example, close cooperation 
between MAs and law enforcement bodies.  

3.24.2.2.  Operational Measure for Boosting Cooperation among Managing Authorities 

Single / 
Package  

Type  

New / 
Update 

Stage in 
Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #2 Taken by Slovakia in 2022 

Single 

Operational  

New 

Fraud 
Prevention  

Sectoral: 
Cohesion 
Policy 

Public procurement; 
Conflict of interest; 
Shared management 
and control of EU 
funds.  

Methodical support; 
Education; Mutual 
exchange of 
information; 
Institutional 
cooperation.  

Enhanced coordination; 
Enhanced cooperation; 
Enhanced information 
flow; Targeting of 
checks.  

Slovakia additionally described an operational measure, a cooperation agreement that defines relevant 
authorities’ future contribution towards more effective EU cohesion policy fund audits. The agreement 
amongst the Slovak Ministry of Investments, Regional Development and Digitalisation, the Supreme 
Audit  Office,  and  the  Public  Procurement  Office  targets  specific  audit  areas,  where  cooperation 
promises outstanding benefits for fraud prevention. Building on existing competences in auditing the 

39 

 
 
eligibility  of  expenditure,  mutual  methodological  support,  education,  and  information  exchange  in 
public procurement, for example, should deliver superior results.  

3.24.2.3.  Legislative Package for the Slovakian Recovery and Resilience Plan  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #3 Taken by Slovakia in 2022 

Fraud Prevention  

Package  

Legislative   Update 

Fraud Detection  

Sectoral: 
Recovery 
and 
Resilience 
Facility  

Conflict of 
interest; Recovery 
and Resilience 
Plan.  

Powers; 
Definition of a 
specific topic.  

To clarify or consolidate existing 
rules; To remedy flaws; To 
enforce the rules in line with 
developments in EU law.  

Recovery and 
Sanction 

In 2022, Slovakia took a second legislative measure amends Act No. 368/2021 that governs RRF funds 
to better prevent, detect, recover, and sanction fraud against them. Improvements made range from more 
powers for the National Implementation and Coordination Authority, such as requesting information 
from the Public Procurement Office, police, law enforcement and courts for resolving irregularities, 
over the exclusion of applicants, to alignments of legal definitions, such as of conflict of interests, with 
EU law. 

3.25. 
3.25.1.  NAFS 

Slovenia 

Slovenia neither follows a national anti-fraud strategy nor plans to establish one. However, the Member 
State runs an anti-fraud strategy to guide the domestic coordination body overseeing the RRF.  

3.25.2.  Measures 

For 2022, Slovenia reported two single legislative updates that focus on tax fraud, alongside customs 
and fisheries funds, and a third mixed type package underpinning RRF funds, boosting, amongst others, 
fraud  prevention  and  detection.  The  second  legislative  measure  amends  control  and  monitoring 
procedures.  The  mixed  measure  package,  by  contrast,  revolved  around  setting  up  a  manual  for 
implementing the RRF on part of its coordinating body.  

3.25.2.1.  Legislative Measure for Aligning Slovenian Law with the PIF Directive  

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 Taken by Slovenia in 2022 

Fraud Prevention  

Single  

Legislative  

Update 

Fraud Detection  

Sectoral: Customs, 
Tax Fraud  

VAT fraud by 
officials 

Power in criminal 
proceedings 

To remedy flaws 

Investigation and 
Prosecution 

40 

 
 
The first legislative measure reported by Slovenia more closely monitors losses from missing trader 
VAT  fraud  and  transposes  the  PIF  Directive  into  domestic  law,  strengthening  fraud  prevention, 
detection,  investigation  and  prosecution  on  the  revenue  side.  With  regards  to  the  PIF  Directive’s 
transposition,  the  Law  on  Amendments  and  Additions  to  the  Criminal  Code  (KZ-1J),  which  was 
published in the Slovenian Official Gazette No. 16/23, adjusts the definition of “EU official” to match 
the Staff Regulations of Officials and the Conditions of Employment of Other Civil Servants of the 
European  Union  under  EU  law.  Thereby,  it  expanded  the  jurisdiction  of  Slovenian  authorities  in 
criminal proceedings where the suspect of any criminal offence is an EU official.  

3.25.2.2.  Legislative Measure for More Expansive Controls and Reinforced Monitoring 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #2 Taken by Slovenia in 2022 

Fraud Prevention  

Single 

Legislative   Update 

Fraud Detection  

Sectoral: Tax 
Fraud, 
Fisheries 

Implementation 
monitoring  

Competences; Powers; 
Financial penalties; 
Other administrative 
penalties.  

To clarify or consolidate 
existing rules; To remedy 
flaws; To enforce the rules 
in line with developments in 
EU law.  

Investigation and 
Prosecution  

In  2022,  Slovenia  adopted  a  twofold  legislative  measure  focusing,  on  the  one  hand,  on  control 
procedures for detecting fraud against fisheries funds and, on the other hand, on the prevention of money 
laundering.  

Act No. 48/22 expands the control procedures used by the Agency for Agricultural Markets and Rural 
Development to detect fraud and artificially created conditions under said body’s operating programme 
for implementing the European Maritime and Fisheries Fund in the Member State from 2014 - 2020.  

Act No. 145/22 aims to more effectively monitor measures that are meant to prevent money laundering 
and the financing of terrorism and are deployed by the Slovenian Office for the Prevention of Money 
Laundering.  In  fact,  this  act  transposes  Directive  (EU)  2019/1153  and  Directive  (EU)  2019/217, 
detailing,  too,  the  implementation  of  Regulation  (EU)  2018/1672.  Finally,  it  corrects,  occasionally 
loosens existing rules on money laundering and terrorist financing, and introduces new tools that may 
be used by liable entities for implementation or by supervising entities for monitoring, enabling money 
laundering and terrorist financing risks to be managed more effectively.  

41 

 
 
 
 
3.25.2.3.  Mixed Package for the Slovenian Recovery and Resilience Facility  

Single / 
Package  

Type  

New / 
Update 

Stage in 
Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 Taken by Slovenia in 2022 

Administrative 

Package  

Organisational 

 New 

Operational  

Fraud 
Prevention  

Fraud 
Detection  

Sectoral: 
Recovery and 
Resilience 
Facility  

Public 
procurements; 
Financial crime; 
Organised crime; 
Corruption; 
Conflict of interest; 
Fraud definition; 
AFCOS; 
Whistleblowers; 
Shared 
management and 
control of EU 
funds; Anti-fraud 
or anti-corruption 
strategy; RRF anti-
fraud strategy.  

Monitoring/desk 
checks; On the spot 
checks; Irregularities 
reporting; Manual; 
Integrity plan.  

To clarify or consolidate 
existing rules; To 
enhance existing 
measures; More effective 
risk management.  

Simplification of 
procedures; Risk 
management.  

Neutral on resources 

IT tools ("IT data 
feeding", "Other IT"); 
Flagging practice; Risk 
indicators.  

Targeting of checks; 
Enhanced ex-ante 
controls; Enhanced ex-
post controls; More 
effective risk 
management.  

Slovenia  reported  a  third,  mixed  measure,  which  it  adopted  in  2022.  The  new  package  combines 
administrative, organisational, and operational steps towards a manual for implementing the Recovery 
and Resilience Facility (Version 1.1. – August 2022) on part of its coordinating body.  

More concretely, the administrative measure encompasses the manual and the integrity plan, while the 
organisational measure concerns risk management and its operational counterpart a corresponding IT 
tool.  

3.26. 
3.26.1.  NAFS  

Spain 

As of 2022, Spain does not have a national anti-fraud strategy, but is establishing one. In the future, it 
will  extend  to  the  State  Administration,  Spain’s  autonomous  communities,  and  local  authorities, 
protecting the EU’s financial interests in full. On the State Administration’s part, the will additionally 
include measures that protect national budget expenditure against fraud and corruption. That is, due to 
the commitment made by the Secretary of State for Public Administration and compliance with the IV 
Open Government Plan regarding the Integrity System of the General State Administration. In 2023, 
the strategy will most likely be completed.  

3.26.2.  Measures 

Spain described a single horizontal legislative and administrative measure, as well as a standalone new 
legislative action around the RRF, targeting all fraud cycle stage on multiple occasions. The first of two 
legislative  measures  creates  new  rules  on  financial  and  other  fraud  related  information.  The 
administrative  update  encompasses  an  information  exchange  agreement  across  various  relevant 
authorities. The RRF specific measure lays down rules for the systematic analysis of conflict of interest 
risks.  

42 

 
 
 
 
3.26.2.1.  Legislative Measure for Aligning Spanish Law with the Law Enforcement 

Access to Financial Information Directive 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected Result  

Anti-Fraud Measure #1 Taken by Spain in 2022 

Single  

Legislative  

New 

Fraud Prevention 

Fraud Detection 

Investigation and 
Prosecution  

Recovery and 
Sanction  

Horizontal  

Financial crime; Anti-
fraud or anti-corruption 
strategy.  

Competences 

To enforce the rules in line 
with developments in EU 
law 

The first of two legislative steps taken by Spain in the reporting period creates new rules on financial 
and other information for the prevention, detection, investigation, and prosecution of criminal offences. 
To this end, Organic Law 9/2022 amends Organic Law 8/1980 on the financing of Spain’s autonomous 
communities as well as Organic Law 10/1995 as regards the criminal code. Beyond facilitating the fight 
against fraud and other crimes against the EU’s financial interests, this legislative measure transposes 
Directive (EU) 2019/1153 on the use of financial and other information for the prevention, detection, 
investigation or prosecution of certain criminal offences, and regulating access to financial information 
by competent authorities for the purpose of combating serious crime, including fraud against the EU’s 
financial interests. 

3.26.2.2.  Administrative Measure for an Enhanced Information Exchange among 

Authorities Combating Tax Fraud and with OLAF 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected 
Result  

Anti-Fraud Measure #2 Taken by Spain in 2022 

Single  

Administrative 

Update 

Fraud 
Prevention 

Fraud 
Detection 

Investigation, 
Prosecution  

Recovery and 
Sanction  

Horizontal  

AFCOS; Whistleblowers; 
Shared management and 
control of EU funds; Anti-
fraud or anti-corruption.  

Monitoring/desk checks; On 
the spot checks; Audit 
checklist; Investigation; 
Irregularities reporting.  

To enhance 
existing 
measure  

Another  measure  adopted by  Spain in 2022  is  administrative.  It,  more  specifically,  encompasses  an 
information exchange agreement that aids its parties, the State Tax Administration Agency and the State 
Administration’s  General  Intervention,  in  combatting  tax  fraud  and  late  payments  in  commercial 
transactions with public sector entities, as well as fraud in obtaining and receiving aid and subsidies 
from public and EU funds. From 30 March, 2022, onwards, this update will improve information access 
by the Spanish AFCOS and their assistance to OLAF.  

3.26.2.3.  Legislative Measure for Spain’s Recovery and Resilience Plan  

Anti-Fraud Measure #3 Taken by Spain in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Single 

Legislative  

New 

Fraud 
Prevention 

Fraud 
Detection  

Sectoral: 
Recovery and 
Resilience Facility  

Conflict of interest; 
Shared management and 
control of EU funds. 

Definition of a 
specific topic 

To enforce the rules in 
line with developments 
in EU law.  

43 

 
 
 
For  2022,  the  second  of  two  legislative  steps  reported  by  Spain  lays  down  rules  for  the  systematic 
analysis of the conflict of interest risk that arises in the implementation of its Recovery, Transformation, 
and  Resilience  Plan  from  December  23,  2023.  Provision  112  of  Law  31/2022  governs  how  this 
automated analysis is carried out as well as how its results are treated. Having come into effect with 
Order HFP/55/2023 on January 24, 2023, it will be carried out in the contract awarding procedures and 
subsidies linked to Spain’s Recovery and Resilience Plan before bids and applications are evaluated. 
Lastly, the order created a dedicated unit in the General Intervention of the State Administration that 
will advise on the adopted conflict of interest risk analysis. With conflict of interest being the main RRF 
fraud risk, this ex ante control measure will likely make a valuable contribution toward curbing fraud 
in this sector.  

3.27. 
3.27.1.  NAFS  

Sweden  

Sweden neither pursues nor plans for a national anti-fraud strategy. However, its government adopted 
and has been following an anti-corruption strategy since 2020.  

3.27.2.  Measures 

Sweden reported three horizontal measures, including a singular organisational measure, and two mixed 
method packages, which jointly pertain to all stages of the anti-fraud cycle. The organisational measure 
is preparatory for Sweden joining the EPPO. The organisational and operational packaged update relates 
to the activities of a body that is solely dedicated to protecting the EU’s financial interests. Finally, a 
legislative update paired with novel administrative action pushed toward less subsidy abuse and lower 
VAT fraud and evasion rates.  

3.27.2.1.  Organisational Measure for Accommodating the EPPO in Swedish Legislation 

Anti-Fraud Measure #1 Taken by Sweden in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Single 

Organisational 

New 

Investigation and 
Prosecution 

Horizontal 

Financial crime; 
Organised crime.  

Competences 

Increased 
resources 

In 2022, Sweden initiated a new organisational measure, which would see the Member State join the 
EPPO. The report on how a European Delegated Prosecutor’s rights could be accommodated into the 
Swedish social security, pension, and insurance schemes was published on 25 October, 2022. It also 
sketches  out  legislation  that  could  resolve  the  identified  conflicts.  These  proposals,  the  Swedish 
government currently develops, as it has ranked joining the EPPO as a key step in effectively defending 
the EU’s financial interests.  

3.27.2.2.  Mixed Package for Comprehensive Anti-Fraud Activities by the SEFI Council 

Anti-Fraud Measure #2 Taken by Sweden in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-
Fraud Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Organisational  

Package  

Update  

Operational  

Fraud 
Prevention 

Fraud 
Detection 

Investigation, 
Prosecution  

Recovery and 
Sanction  

Horizontal  

Conflict of interest; AFCOS; 
Whistleblowers; 
Customs/TOR/illicit trade; 
Shared management and control 
of EU funds; Anti-fraud or anti-
corruption.  

Inter-agency 
cooperation; 
General trainings; 
Fraud awareness 
trainings.  

Structured 
cooperation with 
law enforcement 

Increased resources 

Enhanced 
coordination; 
Enhanced 
cooperation; 
Enhanced 
information flow.  

44 

 
 
Sweden has further flagged its Council for the Protection of the EU’s Financial Interests (SEFI) and 
this body’s work, which affects all stages of the anti-fraud cycle and all sectors. The Council, run by 
the  Swedish  Economic  Crime  Agency,  coordinates  anti-fraud  and  other  EU  fund  related  initiatives, 
bringing together the agencies that run EU programmes across the country. In 2022, the SEFI Council’s 
organisational activities revolved around its growth, from nine to twenty-one agencies, and managing 
its consequences, resulting in stronger coordination, cooperation, and information flow. In operational 
terms, the SEFI Council has focused on preparing and executing assigned to its new members, who 
have  been  tasked  with implementing  the  Swedish  RRP.  Alongside  these  trainings,  the  Council  also 
organised seminars on a range of anti-fraud issues to foster awareness and knowledge in the agencies 
involved. 

Lastly,  the  SEFI  Council  adopted  guidance  for  handling  suspected  crime  in  connection  with  the 
management of EU funds. This guidance targets managers and administrators at EU fund managing 
authorities in the Member State, aiming to support their assessment of whether a certain action in within 
the application for or payment of funds should be handled as suspected crime.  

3.27.2.3.  Mixed Package for Aligning Swedish Law with the PIF Directive  

Anti-Fraud Measure #3 Taken by Sweden in 2022 

Single / 
Package  

Type  

New / 
Update 

Stage in Anti-Fraud 
Cycle  

Horizontal 
/ Sectoral  

Area  

Scope  

Reason / Expected Result  

Legislative  

Update  

Package  

Administrative 

New 

Fraud Prevention 

Fraud Detection 

Investigation and  
Prosecution  

Recovery and 
Sanction  

Horizontal  

Financial 
crime; 
Organised 
crime; Anti-
fraud or anti-
corruption 
strategy.  

Not yet 
adopted 

To clarify or consolidate existing 
rules 

Investigation 

To clarify or consolidate existing 
rules; To enhance existing measure; 
new tools to combat tax fraud and 
evasion.  

Finally, Sweden reported a mixed measure package, consisting of legislative and administrative steps 
toward less subsidy abuse and lower VAT fraud and evasion rates respectively. In a proposal that has 
been submitted to the Legislative Council, the Swedish government suggests that the attempt to commit 
subsidy abuse or gross subsidy abuse should be criminalised. This update is due to enter into force on 
1 June, 2023. Administratively, the Swedish government has opened an inquiry into measures that could 
prevent VAT fraud and evasions as well as actions that would complete the implementation of Article 
3(2)(d) of Directive (EU) 2017/1371 (PIF Directive). Ensuring that these actions are treated as criminal 
offences whenever they are committed intentionally would then enable their proper prosecution and 
punishment for compromising the EU’s financial interests.  

45 

 
 
 
 
4.  Additional Measures 
4.1. Belgium  
4.1.1.  Federal Public Service for Strategy Support 

An updated version of the ethics framework for federal civil servants was published on 5 July, 2022, 
by  the  Federal  Public  Service  for  Strategy  and  Support.  This  new  framework  incorporates  the  new 
federal cross cutting values (trust, respect, public interest, professionalism, and social responsibility) 
and is based on practical examples enabling civil servants to better embrace those values.  

4.1.2.  Brussels Ombudsman  

On 1 September, 2022, the Brussels Ombudsman took up its duties around complaints from members 
of the public who encounter problems with the local authorities. Anyone may now submit a written or 
oral complaint to this office. As an independent public institution, the Brussels mediation service is 
responsible for upholding citizens’ rights and for safeguarding integrity and sound administration.  

4.1.3.  Wallonia Paying Agency  

Wallonia’s Paying Agency has reviewed its management of conflicts of interest. Staff that  reports a 
conflict of interest are required to disclose the identity of the persons concerned by that conflict. The 
internal-audit department carries out a second-level check on the basis of those disclosures, with a view 
to assessing the effectiveness of the action taken by the line manager. 

4.1.4.  ESF Measures  

Belgium additionally reported three ESF focused measured, which differed slightly by region.  

In the Brussels Capital Region, fraud prevention and detection have been strengthened after a careful 
examination of the procedures used in managing these funds. Checks prior to project implementation 
have  been enhanced, project,  state aid,  and eligible  expenditure  monitoring  have  been  implemented 
with the Simplified Costs Options, generic and specific risk analyses revised, and IT tools improved.  

In Flanders, the government has introduced a grants register containing a new database.  

In the German Speaking Community, the government has devised a handbook on internal audit systems, 
which is to control risks and safeguard the budget.   

4.2. Estonia  
4.2.1.  Tax and Customs Duties IT System 

For 2022, Estonia reported additional changes through measures in the customs sector. The Estonian 
Tax and Customs Board accordingly adjusted its customs declarations system, with the aim to make the 
collection of customs duties more efficient. A retrospective declaration is now also possible, ensuring 
that declarations would be more accurate in the future. 

4.3. Germany  
4.3.1.  RRP Audit 

Germany reported an additional measure that aimed to protect the EU’s financial interests in context of 
its national RRP. To this end, an RRP Audit Division was set up within the Federal Ministry of Finance, 
its primary responsibility being to oversee the anti-fraud action within the RRP. An audit strategy has 
already  been  developed,  based  on  which  both  operations  and  system  audits  were  performed.  The 
strategy also established processes that would define reporting channels for suspected fraud within RRP 
project in particular. Together with the Coordinating Unit, a project manual was further prepare and 
circulated to all impending bodies, intending to ensure that these bodies were aware of their obligations 
and  their  legal  bases.  In  the  future,  the  audit  division  will  coordinate  the  RRP  audit  country-wide, 

46 

 
 
including  the  summary  of  audits  declaration  prepared  for  the  payment  request  for  the  European 
Commission.  

4.3.2.  Transnational RRF Projects 

In 2022, Germany joined Operation SENTINEL. The Federal Criminal Police Office (BKA) is available 
to Europol as a strategic partner in Germany. The focus is placed on transnational projects of the RRF. 

4.3.3.  Transparency Register 

In 2022, Germany further created the legal basis for access to the transparency registers by way of an 
amendment  to  the  Anti-Money  Laundering  Act.  It  adopted  this  Sanctions  Enforcement  Act  II  on 
16 December 2022 Article 4(11)(a) contains a general clause that allows all authorities access to the 
transparency register, if they require it for their legal mandate. This Act was published in Federal Law 
Gazette I No 55 of 27 December, 2022. 

4.4. Hungary  
4.4.1.  Various Measures  

Beyond the three measures reported by Hungary above the Member State pointed to a variety of other 
preventative measures in the fraud and corruption domain for 2022.  

These  included,  but  were  not  limited  to,  amending  the  rules  on  conflicts  of  interest  and  the  asset 
declaration  system;  the  use  of  Arachne;  strengthening  the  professional,  operational  and  financial 
independence of the Directorate-General for Audit of European Funds (Investigating/Audit Authority) 
by granting it autonomous status under Act XLIV of 2022; setting up the Directorate of Internal Audit 
and Integrity, and, in relation to the revenue side of the budget, the introduction and implementation of 
measures to protect the financial interests of the EU. 

4.5. Italy  
4.5.1.  Cooperation with the EPPO 

For  2022,  Italy  reported  the  adoption  of  Decree  No  17/2022,  which  forms  the  legal  basis  for 
implementing the supplementing agreement between the Italian Ministry if Justice and the European 
Chief Prosecutor.  

4.5.2.  CAP Strategic Plans  

Italy additionally highlighted Decree No 660087 by the Minister for Agriculture, Food Sovereignty, 
and  Forestry  from  23  December,  2022,  which lays  translated  Regulation  (EU) 2021/2115 for direct 
payments under CAP Strategic Plans in domestic law.  

4.5.3.  Operations by the Guardia di Finanza 

Finally, Italy pointed to operational anti-fraud measures taken by the Guardia di Finanza, such as the 
adoption of a specific operational plan to prevent and combat excise fraud, or its participation in the 
2022 – 2025 EMPACT – Excise Fraud Policy Cycle.  

4.6. Latvia 
4.6.1.  Public Procurement Measures 

In  addition  to  the  measures  it  reported  through  the  main  PIF  Questionnaire,  Latvia  highlighted 
amendments  to  its  Public  Procurement  Law  and  the  Law  on  the  Procurements  of  Public  Service 
Providers, which tighten exclusion and enhance competition.  

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Accordingly, undertakings that have been found guilty of infringing competition legislation by entering 
into a horizontal cartel agreement will be excluded from participating in public procurement tenders for 
a three year period, rather than for just one year. 

4.6.2.  Fraud Sanctions  

Latvia further reported that of May 2022, the number of criminal proceedings for violating sanctions 
imposed by the EU had significantly increased. In 2022, 180 materials were received by the Tax and 
Customs Police Department and 110 criminal proceedings were initiated.  

4.6.3.  Inter-institutional Cooperation  

Finally, Latvia highlighted the successful cooperation amongst the Competition Council of Latvia, its 
AFCOS, and the EPPO by providing an example.  

On  4  August,  2022,  the  Competition  Council  adopted  a  decision,  detecting  a  prohibited  agreement 
between three companies on the conditions of participation in a private procurement in Latvia, imposing 
also the fines on the companies for the violation of the competition law.  

The prohibited agreement was detected based on the information provided by the AFCOS within the 
framework of a project organized by the private contracting entity and co-financed by the EU Funds. 
The Competition Council also cooperated with the EPPO, providing the information obtained during 
the investigation. The EPPO thus started criminal proceedings as a result of which the final beneficiary 
made a repayment of the EU co-financing. 

4.7. Romania 
4.7.1.  Management of Seized Assets 

Beyond the three priority measures reported, Romania pointed to Law No 230/2022, which extends the 
National Agency for the Management of Seized Assets’ mandate, enabling it to identify assets in foreign 
jurisdictions, manage and use seized assets.  

4.7.2.  Tax Audit Framework 

Romania  further  highlighted  an  amendment  to  the  legal  framework  for  tax  audits,  which intends to 
make  these  more  efficient  and  improved  the  customs  authorities’  activities  (GEO  No  85/2022, 
Government Decision No 237/2022, GEO No 188/2022). 

4.7.3.  Anti-Money Laundering Competences 

Lastly, Romania reported the National Office for the Prevention and Combating of Money Laundering 
had  been  strengthened,  through  amendments  to  its  supervisory  and  monitoring  functions  as  well  as 
specification  for  the  declaration  of  beneficial  ownership  by  autonomous  cooperation,  national 
companies, companies, and companies owned by the state (GEO No 53/2022, Government Decision 
No 1243/2022, GEO No 123/2022).  

4.8. Slovenia  
4.8.1.  PIF Directive Transposition 

Under anti-fraud measures, Slovenia further reported its follow-up on the letter of formal notice which 
it received on 9 February, 2022, for failing to transpose in full the PIF Directive.  

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4.9. Spain  
4.9.1.  Agricultural Funds Circular and Trainings 

Spain reported that in 2022, a new circular on fraud and conflict of interest had been drafted, as well as 
trainings  on  fraud  prevention  conducted.  The  Spanish  AFCOS  additionally  developed  more  general 
trainings.  

4.9.2.  AMIF Self-Assessment Tool and Trainings 

In relation to the AMIF, organisational and operational fraud prevention and detection measures have 
been incorporated in the areas of control of funds, anti-fraud, conflict of interest and double funding. A 
fraud risk self-assessment has been incorporated in the prevention phase, as a guide and prior to the 
adoption of an anti-fraud action plan for the AMIF and for the European Social Fund Plus. Training and 
awareness-raising actions in the fight against fraud have also been carried out. As regards the control 
of double funding, measures to avoid double funding of recruitment costs of reception centres have 
been included in the management and control manuals of the AMIF systems. 

4.9.3.  RRF Anti-Fraud Plans 

In  2022,  the  Ministries,  Autonomous  Communities  and  Local  Administration,  in  their  capacity  as 
decision-makers, executors and instrumental entities of the Recovery, Transformation and Resilience 
Plan, drew up Anti-Fraud Plans for the implementation of the funds coming from the aforementioned 
Plan.  These  Anti-Fraud  Plans  include  measures  at  all  stages  of  the  anti-fraud  cycle,  such  as  risk 
assessment, the establishment of anti-fraud committees and units, and procedures to prevent and address 
conflict of interest. 

They further elaborated guidelines for the implementation of anti-fraud measures in the RRP, such as 
the "Guide for the Implementation of Anti-Fraud Measures in the Implementation of the Recovery, 
Transformation and Resilience Plan" elaborated by the Spanish AFCOS.  

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