COMMISSION STAFF WORKING DOCUMENT National anti-fraud strategies (NAFS): state of play and assessment Accompanying the document Report from the Commission to the Council and the European Parliament 35th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2023
Date: 2024-07-25
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU strategy, activity report, corruption, digitisation, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 25.7.2024  SWD(2024) 192 final  COMMISSION STAFF WORKING DOCUMENT National anti-fraud strategies (NAFS): state of play and assessment Accompanying the document Report from the Commission to the Council and the European Parliament 35th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2023 {COM(2024) 318 final} - {SWD(2024) 187 final} - {SWD(2024) 188 final} - {SWD(2024) 189 final} - {SWD(2024) 190 final} - {SWD(2024) 191 final} - {SWD(2024) 193 final}  
 
 
I. OVERVIEW OF NATIONAL ANTI-FRAUD STRATEGIES 

In 2023, 21 out of 27 Member States indicated that they have an anti-fraud strategy in place for the protection of the 
EU’s financial interests1. The approach taken by the 21 Member States varied widely. 

A total of 10 Member States indicated they have a national anti-fraud strategy (NAFS) in place, covering all expenditure 
sectors. Those Member States were not asked to elaborate on other anti-fraud strategies in place at national level. 

On the question of possible preparation of a national anti-fraud strategy, of the 17 Member States who do not have a 
national  anti-fraud  strategy  covering  all  expenditure  sectors,  32  are  in  the  preliminary  stage  to  adopt  one  (i.e. 
establishing the legal framework), 13 is in the preparatory phase (i.e. state of play and fraud risk assessment), and 44 
declared neither having such a national anti-fraud strategy nor an ongoing procedure to adopt one. The remaining 95 
have other anti-fraud strategies in place. 

Figure 1 – Overview of the national anti-fraud strategies reported by Member States 

On the question of whether they have other anti-fraud strategies in place at national level, of the 17 Member States 
who do not have a NAFS covering all expenditure sectors, 11 indicated that they have other types of anti-fraud strategy 
in place targeting specific or multiple sectors such as expenditure (shared management, RRF), customs, VAT and anti-
corruption. Some of these 11 Member States have more than one strategy. The remaining 66 did not indicate other 
anti-fraud strategies in place. 

Member States with a federal structure found it more appropriate to set up crosscutting regional anti-fraud strategies 
covering  the  EU’s  financial  interests7.  Other  Member  States,  conscious  of  the  great  number  of  programmes  to 
implement and the plethora of national institutions involved in managing EU funds8, considered that a more granular 
approach, with anti-fraud strategies at programme level, was more effective in protecting the EU’s financial interests. 

At sector level, as part of the accreditation criteria for the current programming period, all paying agencies for the 
agricultural funds should have an anti-fraud strategy in place that should include measures to counter fraud and any 
illegal activities affecting the EU’s financial interests9. Similarly, for the funds under the Common Provisions Regulation, 
all managing authorities should have effective and proportionate anti-fraud measures and procedures in place, taking 
into account the risks identified10. 

1 The information was gathered via a dedicated questionnaire. See the document ‘Measures adopted by the Member States to 
implement Article 325 TFEU’ accompanying the report. 
2 Denmark, Lithuania, Netherlands. 
3 Luxembourg. 
4 Croatia, Ireland, Slovenia, Sweden. 
5 Austria, Belgium, Cyprus, Greece, Estonia, Finland, Germany, Poland, Spain. 
6 Croatia, Ireland, Luxembourg, Netherlands, Slovenia, Sweden. 
7 Germany. 
8 Poland. 
9 Annex I to Commission Delegated Regulation (EU) 2022/127 of 7 December 2021 supplementing Regulation (EU) 2021/2116 of 
the European Parliament and of the Council with rules on paying agencies and other bodies, financial management, clearance of 
accounts, securities and use of euro. 
10 Regulation (EU) 2021/1060 of the European Parliament and of the Council of 24 June 2021 laying down common provisions on 
the European Regional Development Fund, the European Social Fund Plus, the Cohesion Fund, the Just Transition Fund and the 

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Figure 2 – Overview of other types of anti-fraud strategies reported by Member States11 

II. ASSESSMENT OF NATIONAL ANTI-FRAUD STRATEGIES 

The Commission12, European Parliament13 and European Court of Auditors14 have actively encouraged Member States 
to adopt national anti-fraud strategies. Moreover, the European Parliament has called for the Commission to ‘assess 
the NAFS that have been adopted, to examine why Member States are lagging behind in adopting them, and to push 
the remaining Member States to progress with the adoption’15. 

The state of play on the NAFS presented in the Annual Report on the Protection of the European Union’s financial 
interests  and  the  Fight  against  fraud  (‘PIF  Report’)  is  based  on  the  Member  States’  replies  to  the  dedicated  PIF 
questionnaire. To allow for a more accurate and detailed overview of the state of play of anti-fraud strategies in place 
at national level, the Commission increased the level of detail of information requested in the 2023 PIF questionnaire. 
This is reflected in the overview in Section 3 of the Report. 

Furthermore, to address the  request for analysis of the adopted NAFS, the Commission performed an assessment 
which goes beyond the self-assessment in the replies to the PIF questionnaire. 

The assessment followed a two-step approach: the fulfilment of basic criteria and a qualitative assessment. 

First, the 10 NAFS indicated by the Member States in the PIF questionnaire have been assessed against three basic 
criteria:  

i. 

ii. 

is it national?  
is it anti-fraud, addressing (at least) fraud against EU funds?  

European Maritime, Fisheries and Aquaculture Fund and financial rules for those and for the Asylum, Migration and Integration 
Fund, the Internal Security Fund and the Instrument for Financial Support for Border Management and Visa Policy. 
11 Member States who replied ‘yes’ to the question ‘Do you have a NAFS in place?’ did not elaborate further on the other anti-
fraud strategies in place at national level, and therefore have not been included in Figure 2. 
12 Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud (‘PIF Report’) - 2017, 
2018, 2020, 2022. 
13 European Parliament resolutions on the protection of the European Union’s financial interests – combating fraud – annual 
reports 2016-2022. 
14 Special Report No 6/2019 Tackling fraud in EU cohesion spending: managing authorities need to strengthen detection, 
response and coordination. 
15 European Parliament Resolution of 7 July 2022 on the protection of the European Union’s financial interests – combating fraud 
– annual report 2020 (2021/2234(INI)). 

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iii. 

is it primarily forward-looking and multiannual? 

Furthermore,  the  strategies  have  been  assessed  against  seven  qualitative  criteria  derived  from  the  guidelines  on 
national anti-fraud strategies16: 

overall aspects (update, full anti-fraud cycle addressed) 

i. 
ii.  means and resources (consultation and involvement of authorities in preparing the NAFS; description of 

iii. 
iv. 
v. 
vi. 

available anti-fraud tools and procedures; reporting system for irregularities and fraud) 
evaluation of the previous NAFS 
specific fraud risk assessment 
objectives linked to the risks identified 
action plan (including measures and actions linked to the objectives, responsible services, target dates and 
indicators) 

vii.  monitoring of the implementation of NAFS. 

Figure 3 – Assessment of the national anti-fraud strategies covering all expenditure sectors 

Category of 
criteria 

Basic criteria 

Overall 
questions 

Means and 
resources 

Evaluation 

9 

No 

Criteria  

BG 

CZ 

FR 

IT 

LV 

HU  MT 

PT 

RO 

SK 

1 

2 

3 

4 

5 

6 

7 

8 

Is it a national?  

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

Is it anti-fraud? 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

Is it primarily forward-
looking and 
multiannual? 
Is the NAFS up-to-
date?  
Does the NAFS cover 
each stage of the anti-
fraud cycle? 
Has there been a wide 
consultation and 
involvement of 
authorities in 
preparing the NAFS?  
Does the NAFS include 
a description of 
available anti-fraud 
tools and procedures?  
Is there a reporting 
system for 
irregularities and 
fraud? 
Is an evaluation of the 
previous NAFS 
reflected in the 
current NAFS? 

yes 

yes 

yes 

no17 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no18 

yes 

yes 

yes 

yes 

no19 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes  

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes 

no  

yes 

yes 

no 

no 

no 

yes 

yes 

no 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

no 

yes 

yes 

yes 

no20 

no 

16 The guidelines on national anti-fraud strategies were developed in 2016 by a working group of Member States’ experts, 
directed and coordinated by the European Anti-Fraud Office (OLAF). The guidelines were shared with all Member States and are 
not legally binding. 
17 Italy is currently in the process of drafting a standalone NAFS. This will not be part of an annual report, as is the case now. 
18 Latvia is in the process of updating its NAFS. 
19 Slovakia considers its NAFS as applicable even though it was prepared for the 2014-2020 period. 
20 Romania considered the 2007 evaluation of the previous NAFS as outdated. Therefore it was not reflected in the current NAFS. 
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Fraud risk 
assessment 

Objectives 

Action plan 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

Monitoring of 
implementation  

21 

Has a specific fraud 
risk assessment for the 
NAFS been carried out 
and is reflected in the 
NAFS?  
Are the fraud risks 
identified and 
formulated/described? 
Have mitigating 
measures been 
identified where 
necessary?  
Does the NAFS include 
objectives? 
Are the objectives 
linked to the risks 
identified? 
Are key performance 
indicators (KPIs) 
determined? 

Does the NAFS include 
an action plan? 

Are the 
measures/actions 
linked to the 
objectives? 
Are the actors 
(responsible services) 
mentioned?  
Are the target dates 
(deadlines) 
mentioned?  
Are there specific, 
measurable and time-
bound indicators? 
Does the NAFS provide 
for regular monitoring 
of the 
implementation? 

yes 

no 

no 

no 

no 

no 

yes 

yes 

no21 

no 

yes 

no 

no 

no 

no 

no 

yes 

yes 

no 

no 

yes 

no 

no 

no 

no 

no 

yes 

no 

no 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

no 

no 

no 

no 

yes 

no 

no 

yes 

no 

yes 

no 

yes 

no 

yes 

yes 

yes 

no 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

no 

no 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

no 

yes 

no 

no 

yes 

yes 

no 

yes 

yes 

yes 

no 

no 

yes 

no 

yes 

yes 

yes 

All stages of the anti-fraud cycle (i.e. prevention, detection, investigation and prosecution, and recovery and sanctions) 
are covered in 9 out of 10 NAFS. 

Broad consultation and involvement of authorities in preparing the NAFS took place for 9 out of the 10 NAFS. However, 
only 6 out of 10 include a description of the available anti-fraud tools and procedures. 

Only 3 Member States carried out a specific fraud risk assessment and reflected it in the NAFS. Therefore, even if all 
NAFS include objectives, in only 2 cases are the objectives linked to the risks identified. Furthermore, 9 out of 10 NAFS 
include an action plan. 

Specific arrangements for monitoring the implementation of the NAFS are included in 7 out of 10 NAFS. 

21 The Romanian authorities carried out a specific fraud risk assessment; however, it is not detailed in the current NAFS. 

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