COMMISSION STAFF WORKING DOCUMENT Commission Anti-Fraud Strategy (CAFS) Action Plan Implementation monitoring: state of play 31 May 2024 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) 188 final  COMMISSION STAFF WORKING DOCUMENT Commission Anti-Fraud Strategy (CAFS) Action Plan   Implementation monitoring: state of play 31 May 2024 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) 189 final} - {SWD(2024) 190 final} - {SWD(2024) 191 final} - {SWD(2024) 192 final} - {SWD(2024) 193 final}  
 
 
LIST OF ABBREVIATIONS  

AFCOS  

Anti-Fraud Coordination Service  

AFIS  

CAFS 

CAP  

Anti-Fraud Information System  

Commission Anti-Fraud Strategy 

Common Agricultural Policy  

COCOLAF 

Advisory Committee for the Coordination of Fraud Prevention 

CBAM  

Carbon Border Adjustment Mechanism 

DAC 

DG 

ECA 

EDES 

EEAS 

EIPA 

Common Audit Directorate of DG REGIO and DG EMPL 

Directorate-General 

European Court of Auditors 

Early Detection and Exclusion System 

European External Action Service 

European Institute of Public Administration 

EMPACT 

European Multidisciplinary Platform Against Criminal Threats 

EPPO    

European Public Prosecutors’ Office  

EPSO 

ETS 

EUCI 

European Personnel Selection Office 

Emissions Trading System 

EU classified information 

FPDNet 

Fraud Prevention and Detection Network 

GETI 

GIPs 

IDOC 

IMS 

JRC 

MFF  

NAFS    

OLAF    

PIF  

RRF  

Get Intelligence system 

Guidelines on Investigative Procedures 

Investigation and Disciplinary Office 

Irregularity Management System  

Joint Research Centre 

Multiannual Financial Framework  

National Anti-Fraud Strategy  

European Anti-Fraud Office  

Protection of the EU’s Financial Interests  

Recovery and Resilience Facility  

SOCTA 

Serious and Organised Crime Threat Assessment 

TSI 

Technical Support Instrument 

UAFP   

Union Anti-Fraud programme 

UNCAC 

United Nations Convention against Corruption 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INTRODUCTION 

On 11 July 2023, the Commission adopted its new Commission Anti-Fraud Strategy (CAFS) action 
plan1. It includes 44 actions under seven themes that cover the Commission’s priorities in fighting fraud. 

This  document  presents  the  state-of-play  of  the  individual  actions  of  the  plan  and  is  part  of  the 
monitoring  of  the  CAFS  action  plan  implementation.  It  has  been  prepared  in  consultation  with 
Commission departments and Executive agencies to accompany the 2023 Report on the protection of 
the European Union’s financial interests, the so-called PIF report. 

The text in blue represents the actions as published in July 2023, while the remaining text reflect the 
state-of-play of the implementation of the actions on 31 May 2024.  

10 months after the adoption of the new action plan, the implementation of all actions is in progress.  

1 COM(2023) 405 final and SWD(2023) 245 final 

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1 

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

Due date 
2023 and 
continuous 

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

State-of-play May 2024  

While developing the future single integrated IT system (corporate Arachne), the current version of Arachne is being further improved to strengthen its 
capacity as an anti-fraud tool in shared management and RRF-like instruments.  

Since July 2023, there has been a significant increase of the offer and use of the tool by the Member States and Commission services. In the last quarter of 
2023, the data from the Financial Transparency System was integrated into Arachne, while several raising awareness events on the tool took place throughout 
2023 (e.g. in Italy, Romania, Portugal).  

Case-by-case access was provided to OLAF, ECA and EPPO in the first half of 2024. Member States can automatically upload data onto Arachne through a 
web service since January 2024. The ccompletion of beneficial owner data in Arachne was finalised in January 2024, as well as the setting up of an Arachne 
Academy with various tutorials on how to use Arachne and a forum where users can exchange ideas. Between July 2023 and April 2024, the number of 
Arachne active users increased by almost 30%. In the second quarter of 2024, DG EMPL is issuing guidelines for users in Member States, with practical 
examples on how to best use Arachne.  

As regards the use of Arachne as a tool for agricultural funds, the Commission is discussing with authorities in Spain, Romania, Hungary and Italy. Training 
on Arachne was provided in Spain in March 2024, and a presentation on conflict of interest and risk indicators was delivered at DG AGRI Learning Network 
in July 2023. Also a presentation of the latest developments for the Integrated Administration and Control System, through which Member States can upload 
CAP payments from their IT systems to Arachne, was delivered to the Learning Network in March 2024. 

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Continue developing the envisaged single integrated IT system (corporate Arachne) for data 
mining  and  risk  scoring,  in  line  with  the  Interinstitutional  Agreement  and  the  RRF 
Regulation2,  with  a  view  to  extend  its  use  to  all  Member  States  and  to  all  management 
modes. 

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

Due date 
2023 and 
continuous 

State-of-play May 2024  

According to the political agreement of 7 December 2023 on the Financial Regulation recast, the integrated IT system (corporate Arachne) will apply to all 
management modes. Its feeding with relevant information will be compulsory (including for all Member States) as from the post-2027 MFF programmes. Its 
mandatory use as proposed by the Commission but rejected by the Council, will be rediscussed at a later date pending an assessment by the Commission on 
the readiness of the tool by the end of 2027. In the meantime, the use of the tool will remain voluntary. 

Bilateral meetings with the Commission users of Arachne were finalised in January 2024. Phase 1 of the project was completed in the first quarter of 2024, 
and phase 2 is ongoing. A draft data protection questionnaire was submitted to the Information and Technology Cybersecurity Board (ITCB) in the first 
quarter of 2024, and the first meeting with the Data Protection Officer to receive further instructions on the procedural steps was held in February 2024. 

The creation of an Expert Group is ongoing, to establish cooperation between the Commission and the Member States in the design and development of the 
tool and preparation of the assessment of its readiness by the end of 2027. Member States will appoint representatives from technical fields, e.g. finances, IT 
or audit. 

2 Regulation (EU) 2021/241. 

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3 

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

Lead 
BUDG 

Due date 
2023 and 
continuous 

increasing the user-friendliness of the database; 

a. 
b.  exploring possibilities for interoperability and synergies with other corporate IT tools as well as national databases; 
c.  enhancing  dialogue  on  EDES  among  Commission  departments  and  Executive  agencies,  other  EU  institutions, 

Member States and implementing partners. 

State-of-play May 2024 

The Commission has continuously stressed the importance and benefits of the Early Detection and Exclusion System (EDES) in protecting the Union budget, 
notably for the prevention and detection effects on fraud and unreliable behaviours, and for ensuring effective sanctions. Following the 2023 negotiations on 
the Financial Regulation recast, the proposed targeted extension of EDES to expenditure under shared management as of 2028 was agreed. For the RRF, the 
use of EDES will remain voluntary. 

a.  The Commission had preliminary discussions on the identification of priorities (how to allocate the 2024 resources for the improvements of the database) 

in December 2023. DG BUDG is working on a tutorial on the EDES database for Commission users.  

b.  An information note on the possibility to link the EDES database to Member States databases was shared with the Member States in the Budget Committee 
of the Council of the EU in October 2023. Discussions are ongoing on the possibility to link the EDES database to SUMMA, the Commission’s future 
corporate financial system. 

c.  The Commission has enhanced the dialogue and increased the level of guidance on EDES. Within the Commission, the dialogue took place notably in 
the EDES experts platform, which had its first session in March 2024, and in the annual EDES workshop, organised in April in 2024. Ad hoc training 
sessions on EDES with several departments took place in January and February 2024. An EDES vademecum and revised guidelines on the use of OLAF 
Reports for the purpose of EDES are under preparation. Beyond the Commission, the link of the EDES public database was added to the Participants 
Portal (Funding & tenders (europa.eu)) to make it more visible to persons and entities seeking for funding opportunities and to reinforce the deterrent 
effect  of  those  sanctions  vis-à-vis  such  persons  or  entities.  The  Commission  has  also  prepared  a  general  template  to  publicise  new  exclusions  also 
externally. 

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

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

irregularities and provide analysis to DGs; 

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

Lead 

Due date 

BUDG: lead 
OLAF, spending DGs: 
support 
BUDG: lead 
DAC, EMPL: support 

2025 

2025 

2025 

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

BUDG 

State-of-play May 2024 

SUMMA is the Commission's future corporate financial system, which will modernise, harmonise and standardise the EU's financial business processes. It 
is expected to become operational in early 2025. To take full advantage of the new system, the possibilities to strengthen its anti-fraud functionalities are 
being considered. 

Awaiting the SUMMA go-live, the discussions on the use of SUMMA for anti-fraud purposes, for business partner screening and additional controls are still 
in their initial stages. 

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

Lead 
OLAF 

Due date 
2023 and 
continuous 

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

the EU’s financial interests. 

State-of-play May 2024  

IMS is the system through which Member States report on irregularities and fraud affecting the EU budget to the Commission, allowing the Commission to 
analyse for example trends and modus operandi. It has potential for greater interoperability with other corporate tools of the Commission, such as Arachne 
and EDES, and with digital tools in Member States. OLAF, which runs the IMS on behalf of the Commission, is continuosuly working on improving its user 
friendliness.  

These efforts have been stepped up in 2023 to ensure that full use is made of IMS as a reporting and analysis tool. Notably, to increase the user-friendliness 
of IMS, the upgrade of the underlying IT architecture was launched in the summer 2023, with a view to finalise it by end 2024. Further actions will be taken 
in 2025 to update IMS. Discussions are ongoing about possible enhancements to the current EDES-IMS interface and about possible use of IMS data within 
the next data mining and risk scoring tool (corporate Arachne).  

The improvements that will follow in 2025 and beyond will be based on consultations with the Member States.  

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Foster digitalisation and the use of IT tools to fight fraud  

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

Lead 
OLAF, SG, BUDG 

Due date 
2024 

State-of-play May 2024 

OLAF is continuously working with other Commission departments to improve the monitoring of the follow-up of OLAF recommendations. 

In the second half of 2023, following the definition of key business needs and its communication to the developers, OLAF retained SharePoint as a solution 
to improve the efficiency and accuracy of financial and administrative monitoring of follow-up of OLAF cases. The SharePoint solution was presented to the 
Commission departments and the Executive agencies in the  FPDNet in the autumn of 2023 and again in May 2024. The solution is planned to be made 
available to users in the second half of 2024. 

As regards EPPO notifications, discussions are ongoing on how to ensure that the Commission has an overview of such information received from the EPPO. 

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Foster digitalisation and the use of IT tools to fight fraud  

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

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

Lead 

Due date 

OLAF: lead 
SG: support 

2025 

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

OLAF 

2024 

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

State-of-play May 2024 

Communication with other Commission departments and Executive agencies on OLAF investigations will be facilitated by an increased use of digital tools.  

Since April 2024, OLAF documents marked as “SENSITIVE: OLAF Investigations” can be transmitted to Commission departments via ARES to users of 
the application.  

a.  An OLAF internal study on cases-related exchanges between OLAF and other stakeholders was  finalised in May 2024.  

b.  The obligation to update Commission departments and Executive agencies on the status of OLAF cases has been included in the new Guidelines on 
Investigative  Procedures  (GIPs),  which  are  currently  in  the  process  of  being  adopted.  Further  reflection  on  the  more  detailed  procedure  to  inform 
Commission departments and Executive agencies every six months will take place upon the adoption of the GIPs. 

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8 

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

Due date 
2024 

Lead 
OLAF: 
lead 
All DGs: 
support 

State-of-play May 2024 

The increased availability of documents and text on the Internet and the use of Artificial Intelligence (AI) lead to increased risks of plagiarism. Plagiarism 
can breach intellectual property rights, lead to double funding and pose reputational threats to the Commission. Digital solutions are thought to have the 
potential to mitigate some of the risks. 

To address it, a working group composed of 15 Commission departments and Executive agencies was established end of 2023. The kick off meeting took 
place in January 2024. A draft report on the main issues encountered by the Commission services, available tools and potential solutions is under preparation, 
for finalisation by the end of the year.  

Once finalised, the document will be shared within relevant fora, such as the Commission’s Information Technology and Cybersecurity Board. 

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

Lead  Due date 
OLAF  2026 

State-of-play May 2024 

GETI is an OLAF data analytical tool used for simultaneously searching in multiple data stacks of structured and unstructured data in multiple different 
languages. GETI finds information quicker and more efficiently, by bringing together data from different sources. 

In the first quarter of 2024, OLAF identified the types of data required, notably a set of six red flags, which were coded for automation in GETI. The results 
of the use of the six red flags were fed into various machine learning algorithms for testing.  

OLAF will collect the data needed by the end of 2024, and will identify the most relevant risk indicators at a later stage. 

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

Due date 
2024 

Lead 
OLAF: 
lead 
All DGs: 
support 

State-of-play May 2024 

The Commission is well aware of the risks associated with the use of external service providers and experts, notably of double funding and conflict of interest, 
as also highlighted by the Commission’s auditors. Digital solutions are thought to have the potential to mitigate some of the risks. 

A working group composed of 18 Commission services and executive agencies was established end of 2023. The kick off meeting took place in February 
2024. A draft report on the main issues encountered by the Commission services, available tools and potential solutions is under preparation, for finalisation 
by the end of the year.  

Once finalised, the document will be shared within relevant fora, such as the Commission’s Information Technology and Cybersecurity Board. 

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Further strengthen the Commission's IT and information security to respond quickly and effectively to evolving 
cyber-security threats, including the threat of cyber-fraud, and minimise potential impacts, notably by:  

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

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

b.  ensuring  close  cooperation  on  information  security  between  EU  institutions  and  bodies,  notably  on 
investigations of leaks of information, on common rules and tools to securely exchange information. 

State-of-play May 2024 

Lead 

Due date 

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

2023 and 
continuous 

2023 and 
continuous 

Cyber-security threats are constantly evolving. The Commission is committed to ensuring the safety and security of its digital assets and reputation, as well 
as maintaining the continuity of its operations.  

a.  DG DIGIT regularly monitors and reports on the cybersecurity posture of the Commission via the IT Security and Risk Report (ITSRR), released three 
times per year. The latest release for the 2023 ITSRR took place in March 2024. The report provides a snapshot on the Commission’s IT security risk 
posture, including updates and key developments in relation to the threat landscape, proactive and reactive cybersecurity and capability development. 
The actions of the IT Security Strategy 2023-2024 have been updated to keep the strategy in line with the priorities of the Commission, the evolution of 
the threat landscape, the new IT technical developments and the evolution of the compliance and incident management processes. Preparatory work for 
the 2025-2026 IT Security Strategy have started. The revision will incorporate the provisions of the Cybersecurity Regulation (2023/2841) entered into 
force in January 2024.  The adoption of the revised IT Security Strategy is foreseen by the first quarter of 2025. 

b.  The Commission presented its proposal for a Regulation on information security in all EU institutions and bodies to the co-legislators, in the Council 
Security  Committee  meetings  of  September,  October  and  December  2023  and  in  the  LIBE  Committee  meeting  of  September  2023.  The  Security 
Directorate of DG HR (HR.DS) provides constant support to decentralised agencies for the development of their rules and guidance on handling  EU 
classified information (EUCI) and sensitive non-classified information, including by providing IT tools and training for their security staff contributing 
to reducing the fraud risk. HR.DS conducts the security assessment visits to the premises of those agencies preparing for handling EUCI, together with 
counterparts from Council and EEAS. HR.DS participates in coordination meetings every 6 months with the investigative teams of the other institutions. 
The issue of leaks and how to prevent and investigate them is a recurring agenda point. 

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Foster digitalisation and the use of IT tools to fight fraud  

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12  Encourage  Member  States,  notably  through  available  funding  programmes,  to  digitalise  as  appropriate  fraud 
prevention, detection and investigation by supporting the development and use of IT tools for data collection and 
analysis using advanced data mining, machine learning technologies and forensics, as well as the exploration of 
emerging technologies such as artificial intelligence, block chain technology and biometrics.  

Lead 
All DGs providing 
such funding 

Due date 
2023 and 
continuous 

State-of-play May 2024 

In its 2022 PIF Report of July 2023, the Commission recommended Member States to keep the digitalisation of the fight against fraud high on their agendas. 
To support Member States in the digitalisation of their anti-fraud efforts, the Commission undertook several actions.  

DG REFORM presented funding opportunities under the Technical Support Instrument (TSI) to Member States at the COCOLAF Fraud Prevention meeting 
of December 2023, including the possibility of funding digitalisation projects. Several anti-fraud focused projects were selected for the TSI 2024 cycle. DG 
REFORM encourages in its TSI 2025 programming (January 2024-October 2024) reform project requests on how technology and especially AI can support 
anti-corruption and anti-fraud bodies to improve their capacities. This links directly with Enhancing the European Administrative Space (ComPAct) Pillar 
II: Capacity for Europe’s Digital Decade. DG REFORM endorsed in April 2024 a horizontal Flagship on Digitalisation, which can accommodate reform 
initiatives aiming to leverage technology and AI-supported models to enhance anti-corruption methodologies and processes. This flagship can accommodate 
relevant project requests from interested Member States. 

OLAF included in the 2024 Work programme for the Union Anti-Fraud programme (UAFP) funding opportunities for Member States authorities for the 
development and use of IT tools for data collection and analysis using advanced technologies. The UAFP Calls for proposals for 2024 were published in 
February 2024. OLAF intends to reinforce the digitalisation aspects in the future UAFP, post-2027. 

Beyond the funding opportunities, DG ECFIN is assessing the IT systems put in place by Member States to collect data on the implementation of the Recovery 
and Resilience Plan and to monitor the achievement of milestones and targets. OLAF has in the context of a COCOLAF expert group put together a “toolbox” 
on  the  anti-fraud  IT tools used  by  Member  States for  the  purpose  of  the  RRF. This  “toolbox”  is  currently  being  updated  with  the  aim  of  including  the 
description of the IT tools for all Member States. 

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

Nr  Action 
13 

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

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

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

identified in risk assessments; 

c.  continuing anti-fraud awareness raising and training; 
d.  encouraging Member States to make use of IMS to report irregularities related to the RRF in line with an 

ECA recommendation. 

State-of-play May 2024 

Lead 
ECFIN: lead 
OLAF: support 

Due date 
2023 and 
continuous 

With the large amounts involved in the RRF, the Commission is closely monitoring and taking action to address risks and instances of fraud, corruption, 
double funding and conflict of interest. In 2023, OLAF updated and disseminated an updated version of an “RRF risk framework”. 

a.  Discussions between OLAF and DG ECFIN on risk indicators took place in the second half of 2023 and in 2024. OLAF completed an evaluation of 

RRF data for anti-fraud purposes and shared it with DG ECFIN in April 2024. 

b.  DG ECFIN have carried out audits on the protection of EU’s financial interests in all Member States. Targeted audits on the protection of EU’s 

financial interests are conducted where specifics needs have been identified, such as for specific regions, authorities or measures.  

c.  OLAF has provided training for the Member States authorities, notably in the framework of Europe Institute of Public Administration (EIPA) seminars 

in October and November 2023. 

d.  Specifically concerning the use of IMS, the Member States’ audit authorities for RRF have been made aware of the advantages of using IMS for reporting 

irregularities during the 2023 and 2024 bilateral meetings organised by DG ECFIN.  

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

Lead 
ECFIN, shared 
management DGs 
and OLAF  

Due date 
2023 and 
continuous 

State-of-play May 2024 

The Member States are responsible for putting in place effective and proportionate anti-fraud measures to protect the financial interests of the Union. An 
appropriate framework for taking such measures are national anti-fraud strategies (NAFS), and the Commission, European Parliament and European Court 
of Auditors have therefore actively encouraged Member States to adopt such strategies. 

The European Parliament has called on the Commission to assess the NAFS that have been adopted and to  encourage the remaining Member States to 
progress with the adoption. To respond to this call, the 2023 PIF report is accompanied by  OLAF’s assessment of Member States’ NAFS. OLAF also 
regularly  provides  Member  States  with  information  and  guidance  on  the  development  of  NAFS  in  relevant  fora,  most  recently  in  the  2023  and  2024 
COCOLAF meetings. 

DG ECFIN encourages the adoption of NAFS in the context of its RRF audits on the protection of EU’s financial interests, notably by adding the adoption 
of such strategies as a milestone where appropriate. 

The Common Audit Directorate of DG REGIO and DG EMPL (DAC) disseminated in the second half of 2023 the “Methodological Note for the Assessment 
of Management and Control Systems in the Member States” that the Shared Management DGs REGIO, EMPL, MARE and HOME had issued earlier in the 
year. The note includes assessment criteria of Key Requirement 7: “Effective implementation of proportionate anti-fraud measures”. In February 2024, DG 
REGIO delivered a presentation to national authorities on the importance of having a NAFS in place, as part of an EIPA training on cohesion policy for EU 
Member State experts, “Identifying and preventing fraud and corruption in Structural and Cohesion Funds 2021-2022”. 

DG AGRI has reinforced the anti-fraud measures to be implemented by the Paying Agencies, in the accreditation criteria list (Annex I to Regulation (EU) 
2022/127) by imposing the need of having an anti-fraud strategy  covering the full anti-fraud cycle (prevention, detection, investigation and sanctions). 
Specific guidance on the implementation of the Antifraud Strategies of the Paying Agencies is provided each year with a document addressed to Paying 
Agencies and the Coordination Bodies. Specific guidance on the checks to be performed as regards the Paying Agencies’ compliance with the accreditation 
criteria is also provided each year with a document addressed to the Certification Bodies. DG AGRI furthermore performs accreditation missions focusing, 
among other topics, on the implementation of the anti-fraud strategy and anti-fraud measures, and organises expert group meetings with workshops on these 
subjects. 

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

Lead 
ECFIN, shared 
management 
DGs and OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2024 

The Commission provided the Member States authorities with anti-fraud training, awareness raising and exchanges of best practices in several fora throughout 
2023 and in 2024. 

For the RRF, DG ECFIN raised such topics in the annual conference with national authorities, in training and EIPA seminars on Arachne for the RRF, as 
well as in the COCOLAF meeting of December 2023. 

DAC presented notably findings on conflict of interest to the audit authorities and the findings of its audits to COCOLAF in December 2023. DG REGIO 
participated  together  with  OLAF  and  DG  REFORM  in  an  event  aimed  at  increasing  anti-fraud  and  anti-corruption  awareness  and  knowledge  among 
international experts as part of the Dutch Constituency Programme in early 2024. Furthermore, training targeting national and regional authorities responsible 
for the management of cohesion policy programme was provided in February 2024. DG REGIO also maintains the EU Funds Anti-Fraud Knowledge & 
Resource Centre website. 

DG AGRI regularly co-organises anti-fraud seminars with Member State paying agencies, contributes to discussions on anti-fraud issues at the Conferences 
of Directors of Paying Agencies organised by each Presidency of the Council and participates in the meetings of the Learning Network of the paying agencies.  

OLAF regularly provides training to different Member States on the reporting of irregularities and the protection of EU’s financial interests. Notably, OLAF 
provided training on reporting of irregularities in the context of an event organised by the German AFCOS in November 2023 and in the anti-fraud webinar 
organised by Slovenian authorities in March 2024. OLAF raised awareness and facilitated exchanges of good practices with Member State representatives 
in the AFCOS and COCOLAF meetings in 2023 and 2024. OLAF furthermore participated in anti-fraud training organised by EIPA. In 2024, OLAF also set 
up an expert group of national experts focusing on the topic of double funding.   

The Commission will continue providing regular training, awareness raising and exchanges of best practice to Member States  authorities, notably in the 
context of seminars on anti-fraud matters, conferences of Directors of Paying Agencies in agriculture, in bilateral annual coordination meetings with audit 
authorities in cohesion policy and in coordination meetings related the RRF. OLAF will continue to raise matters related to IMS in COCOLAF, and is 
currently considering how to enhance its IMS training offer. 

17 

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

Nr  Action 
16 

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

Lead 
BUDG: lead 
ECFIN, shared management DGs: 
support 

Due date 
2024 and 
continuous 

State-of-play May 2024 

Member States have the obligation, when implementing the EU budget in shared management, to take the necessary measures to avoid conflicts of interest. 
The Commission has stepped up its efforts to provide guidance and allow the Member States to share their experiences with each other. 

DG BUDG has set up a Commission internal working group with the shared management DGs to identify best practice and guidance for Member States on 
preventing, detecting, handling and reporting conflict of interest situations. The first meeting took place in January 2024. A consolidated document will be 
drafted and shared with the Member States in 2025. 

DG ECFIN invites Member States to share best practices on conflict of interest situations in annual events for national audit bodies. 

DG AGRI provided guidance and support on conflict of interest situations during specific seminars, Expert Group Meetings and workshops dedicated to anti-
fraud issues, and followed-up on issues involving potential conflict of interest at the level of the Governance Bodies.  

OLAF has enhanced its analysis of data on conflict of interest situations in IMS and includes, since 2023, a dedicated section in the Commission’s PIF report. 

18 

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

Nr  Action 
17 

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

Lead 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2024 

OLAF  continuously  strives  to  make  IMS  accessible  to  relevant  Commission staff.  IMS  can  for  example  support  auditors  with their risk analysis in  the 
planning of an audit. 

In 2023, following consultations on their needs, OLAF provided tailor-made training on IMS to auditors in DAC and DG ECFIN. In April 2024, OLAF 
collected the training needs on IMS for 2024 and consulted Commission departments on possible specific needs. 

OLAF will continue supporting the use of IMS by Commission auditors notably by providing training in line with the needs expressed by the Commission 
departments. 

19 

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

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

Lead 
ECFIN, 
shared 
management 
DGs 

Due date 
2023 and 
continuous 

State-of-play May 2024 

To ensure that the EU’s financial interests are protected, it is important that Member States have procedures in place for following up on detected fraud and 
irregularities. Audit authorities and certification bodies play an important role in verifying that this is the case. 

For the RRF, DG ECFIN reviews management declaration and audit reports received with payment requests, and issues recommendations following audits 
on the protection of EU’s financial interests. MAPAR is consulted in preparation of audits on the protection of EU’s financial interests, and the results are 
reflected in the preparation of audit checklists. The work done on audits on the protection of EU’s financial interests and the follow-up of reported irregularities 
are discussed during annual bilateral meetings with Member States audit bodies. 

In the area of shared management, a revised version of the checklist on Key Requirement 7  on the effective implementation of proportionate anti-fraud 
measures was developed jointly by DAC (DG REGIO, DG EMPL), DG MARE and DG HOME and shared with the Audit Authorities of the Member States 
in March 2024 in CIRCABC. The checklist constitutes part of the Early Preventive System Audits verifications. A template of a checklist on conflict of 
interest has also been shared during a meeting with staff of all Audit Authorities of the Member States and on the dedicated platform for sharing documents 
with national services, CIRCABC. 

In the agricultural policy area specifically, DG AGRI updated its checklist to further develop the checks on the work performed by the Certification Bodies 
as regards the identification of irregularities and the debt management control system put in place by the Paying Agencies. DG AGRI accreditation missions 
focus also on these matters. DG AGRI follows up, through conformity enquiries, on any findings from the Annual Reports of the Certification Bodies, from 
its  missions  and  on  any  other  relevant  information  it  receives  that  points  to  possible  issues  related  to  the  identification  of  irregularities  and  the  debt 
management control system of the Paying Agencies. DG AGRI provides guidance and support during Expert Group Meetings as regards irregularities and 
the recovery of undue payments. 

20 

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

Nr  Action 
19 

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

Lead 

Due date 

a.  developing and updating guidance on reporting, for example, the IMS handbook, including 

on issues related to conflicts of interest; 

OLAF: lead 
Shared management DGs: support 

2024 

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

State-of-play May 2024 

Shared management DGs: lead 
OLAF: support 

2023 and 
continuous 

For the EU to have a complete and correct picture of the irregularities and fraud against EU funding, the Member States need to report them in IMS. To 
support the Member States, OLAF issues guidance on reporting. In 2023, OLAF also addressed the matter of inadequate IMS reporting with a number of 
Member States bilaterally. By the end of 2023, OLAF had sent letters to eight Member States and is currently following up on  the replies received. The 
shared management DGs can also contribute to an increased level of reporting, notably by reminding the Member States authorities of their obligation to 
report in IMS. 

a.  In December 2023, OLAF started  revising the handbook on the reporting of irregularities in shared management. An expert group  on the topic was 

conveyed with Member State representatives. Two meetings of the expert group took place in spring 2024, in March and May respectively. 

b.  Since January 2024, letter templates of DG AGRI, DAC (DG REGIO, DG EMPL) and DG MARE have been updated to include a reference to the 
obligation of reporting in IMS and the request to provide confirmation of such reporting to the OLAF-IMS functional mailbox. This request concerns 
irregularities detected during Commission audits, OLAF’s investigations and ECA findings and the templates are in use since early 2024. 

21 

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

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

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

Lead 
External action DGs: 
lead 
OLAF, HR: support 

Due date 
2024 

State-of-play May 2024 

Staff  working  in  the  EU  Representations,  Delegations  and  Missions  need  appropriate  ethics  and  anti-fraud  training  to  develop  sound  knowledge  of  the 
Commission’s ethics and anti-fraud frameworks. 

Following a mapping of existing training on ethics and anti-fraud topics (cf. action 40 of this action plan), the Commission established a draft proposal for a 
joint ethics and anti-fraud training plan in March 2024. A working group was set-up and the first meeting took place in April 2024 to discuss the proposal. 

The external action DGs, DG HR, OLAF and the EEAS will continue its discussions in the working group with the aim of finalising the joint ethics and 
training plan by the end of 2024. 

22 

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

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

Lead 

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

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

notifying cases; 

b. 

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

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

Due date 

2024 

2023 and 
continuous 

State-of-play May 2024 

The  Commission  may  delegate  the  implementation  of  EU-funded  projects  to  partner  organisations  in  indirect  management.  To  ensure  that  the  partner 
organisation’s internal rules and procedures guarantee a high level of protection of EU funds, the organisation must pass a pillar assessment. Pillar-assessed 
partners have an obligation to notify the Commission of cases of detected irregularities, fraud and exclusion situations. 

a.  Discussions between DG INTPA and OLAF are on-going to assess the issues encountered and the minimum requirements on the pillar-assessed partners. 
DG INTPA is currently compiling applicable provisions (binding and non-binding), mapping the different types of situations and exploring the possibility 
of developing Commission-OLAF communication channels for cases notified by pillar-assessed partners in the context of their contractual obligations. 
DG INTPA will develop guidance in cooperation with OLAF and other relevant Commission departments. 

b.  OLAF was invited to technical meetings organised by DG INTPA with the UN Controller in October 2023, and to 19th EU-UN FAFA Working Group 
in June 2024. DG NEAR has requested that relevant staff in Commission headquarters and EU delegations inform OLAF of relevant meetings with pillar-
assessed partners. 

23 

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

Nr 
22 

Action 
Develop common lines of action with the EEAS to reduce the risks associated with local agents who remain 
in the same post for a long period of time in the Delegations. 

Lead 
External action 
DGs: lead 
OLAF, HR: support 

Due date 
2024 

State-of-play May 2024 

This action aims at tackling risks associated with local agents who remain in the same post for a long period of time in the EU Delegations. 

A Commission working group was set up to prepare common lines of action including preventive and corrective actions. Meetings took place in January and 
April 2024. The working group came up with proposals for actions to address the risks of local agents who remain too long in their posts in Delegations. 

The discussions in the working group will continue with the aim of developing common lines of action, also with the EEAS, by the end of 2024. 

24 

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

Nr  Action 
23 

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

a.  developing guidance on irregularity reporting in IMS; 

b.  providing training to relevant national authorities; 

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

correct manner. 

State-of-play May 2024 

Lead 

Due date 

OLAF: lead 
NEAR: support 
OLAF: lead 
NEAR: support 
NEAR, OLAF 

2024 

2023 and 
continuous 
2024 and 
continuous 

Under indirect management, the countries benefitting from pre-accession assistance (IPA) must report irregularities and fraud to the Commission, and keep 
the Commission informed about the progress of administrative and legal proceedings in relation to such irregularities. Such reporting is to be done through 
IMS. To ensure correct reporting, the Commission provides guidance and training to the candidate countries. 

a.  A document providing guidance on irregularity reporting to beneficiary countries of pre-accession assistance in indirect management is under preparation. 

This guidance is expected to be ready for dissemination in candidate countries in the second quarter of 2024. 

b.  During the AFCOS seminar in Montenegro of September 2023, a specific workshop, attended by representatives of all candidate countries involved in 
reporting, was held to raise awareness about the obligation of irregularities reporting. OLAF also explained IMS to Ukrainian authorities during a training 
organised by OLAF in February 2024. OLAF intends to continue using the AFCOS, multi- and bilateral meetings to provide training on IMS to candidate 
countries.  

c.  In March 2024, DG NEAR sent letters to the different National Authorising Officers (NAO), reminding them of their obligation to report irregularities 

in IMS on a regular basis. The NAO were requested to submit summarised quarterly report on irregularities and their follow-up. 

25 

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

Nr  Action 
24  Develop guidance and exchange of best practice on addressing the risks to spending in emergency situations 

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

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

Due date 
2024 

State-of-play May 2024 

The previous CAFS action plan of 2019 identified emergency spending as particularly vulnerable to fraud. Implementing the previous CAFS action related to 
emergency spending, a risk analysis was conducted. It identified conflict of interest as one of the main risks in this type of spending.  

The Commission therefore set up a working group on the risks to spending in emergency situations with focus on conflict of interest. The working group discussed 
and agreed on the outline of the guidance document which will contain anonymised cases of conflict of interest in emergency spending and mitigating measures 
to address risks to such spending. Discussions on the draft are ongoing. 

The guidance document is expected to be finalised by the end of 2024. 

26 

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

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

Lead 
OLAF  

corruption, notably by: 

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

i. 
ii. 

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

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

Due date 
2023 and 
continuous  

State-of-play May 2024 

The EU is spending large sums of money to support Ukraine in meeting present and future challenges. All players involved must do their utmost to ensure 
that the funds reach their intended recipients. 

a.  To strengthen national anti-fraud structures through capacity building: 

i.   OLAF delivered anti-fraud training to several Ukrainian authorities in February 2024. Further training activities are foreseen for 2024 for 
Ukrainian anti-fraud authorities on advanced analytical tools and methodologies for fraud detection and investigation. 

ii.  The negotiation and adoption process for Ukraine’s association to the Union Anti-Fraud Programme was successfully finalised in the beginning 
of 2024. The association agreement was formally signed in March 2024 by both parties and it is now in force. 

b.  OLAF  investigative  units  intensified  cooperation  with  Ukrainian  authorities  for  cases  of  fraud  or  irregularity  allegations.  OLAF  also  increased  the 

dialogue with investigative services of other major donors to Ukraine. 

27 

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

Nr  Action 
26 

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

Lead 
OLAF, JRC, 
TAXUD, BUDG: 
lead 

Due date 
2023 and 
continuous 

State-of-play May 2024 

Analytical tools and data sharing play an important role in boosting the EU's capacity to effectively tackle customs fraud.  

Since 2023, OLAF continues to develop an analytical platform in AFIS (FraudAP) to increase its analytical capacity to support OLAF and Member States in 
their operational work. OLAF has increased its knowledge and experience in data science, invested in the latest software tools and technology, and improved 
its access to the relevant data for anti-fraud purposes. The new analytical capabilities of OLAF contribute to joint operational activities between OLAF and 
the Member States, enabling national authorities to identify and take action against fraudulent economic operators.  

As  a  result  of  the  High-Level  Customs  Anti-Fraud  Conference  of  November  2023,  OLAF  together  with  the  Member  States  identified  as  a  priority  the 
development of a data analytical capability at EU level to support the exchange of best practices and training in this area. 

OLAF has been developing a B2B interface between the Customs Information System and Member State national systems with the support of the European 
Union Intellectual Property Office.  

A  new  administrative arrangement  for  2024-2027  was  signed  between  OLAF  and  JRC in  December  2023.  The  CAFET-2  project (Customs  Anti-Fraud 
Emerging Technologies) aims to further improve and develop various AFIS applications for undervaluation detection and container movements3. CAFET-2 
also aims to develop various AI projects to support data analysis for anti-fraud purposes. One important topic will be to assess to what extent recent advances 
in Large Language Models, and in particular Generative AI technologies (like GPT), can support customs anti-fraud activities. 

3 Automated Monitoring Tool (AMT) and Container Status Messages (CSM) directory. 

28 

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

Nr  Action 
27 

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

Lead 
TAXUD: lead 
OLAF, BUDG: support 

Due date 
2024 

a.  strengthening data sharing in the Customs Risk Management System; 
b.  developing and better defining risk indicators related to anti-dumping and undervaluation in the 

new Financial Risk Criteria Decision; 

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

State-of-play May 2024 

Data analysis is an increasingly important component of both customs risk management and customs anti-fraud activities. Access to the right data for risk 
management and anti-fraud purposes is essential. DG TAXUD is working on a number of initiatives to improve the access to relevant data for these purposes, 
including in 2024 the proposed revision of Implementing Regulation on technical arrangements for developing, maintaining and employing electronic systems 
for the exchange and storage of information.  

a.  DG TAXUD is developing a new capacity in the Customs Risk Management System (CRMS2) to share lists of data, while enhancing the capacity of the 
system to connect to other systems. To ensure complementarity between risk management and anti-fraud activities, a number of OLAF investigators and 
data analysts have been granted access to CRMS2 and will benefit from the improvements to the system. The new capacity is expected to be operational 
in 2025. 

b.  The Commission and the Member States jointly developed and refined the risk indicators related to undervaluation and anti-dumping to be updated in 
the Financial Risk Criteria Decision. The Commission implementing decision, adopted in April 2024, takes into consideration the main anti-fraud issues. 

c.  The identification of the main elements needed to establish  common risk criteria  for intellectual property rights at import  has been carried out by a 
subgroup of Member States. DG TAXUD will draft a proposal for an implementing decision, ensuring that relevant anti-fraud aspects are taken into 
account. 

29 

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

Nr 
28  

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

Lead 
OLAF, 
BUDG, 
TAXUD, 
CLIMA 

Due date 
Within two 
years of 
adoption 

State-of-play May 2024 

The Commission presented in June 2023 an adjusted proposal for a next generation of own resources that covered the Carbon Border Adjustment Mechanism 
(CBAM) and an extension of the Emission Trading System (ETS). 

CBAM entered into force in its transitional phase in October 2023. The adopted text includes a reference to the application of Regulation (EC) No 515/97 on 
mutual administrative assistance in customs matters. Reports for the first reporting period concerning the last quarter of 2023 were submitted by importers or 
their representatives in the first quarter of 2024. The relevant Commission departments are starting a joint reflection on the possible fraud risks associated 
with the CBAM. 

For ETS, see action 29. 

30 

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

Nr 
29 

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

Lead 

implementing and enhancing security measures; 

a. 
b.  exploring  alternative  operating  models  for  the  ETS  Union  Registry,  and  conducting  an  in-depth 
feasibility assessment and cost–benefit analysis to inform the decision on a potentially new operating 
model. 

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

Due date 

2023 and 
continuous 
2024 

State-of-play May 2024 

The EU Emissions Trading System (ETS) is the world's first major carbon market and remains the biggest one. With a market value of around EUR 770 
billion and a revenue of more than EUR 7 billion generated for the EU in 2023, it is vulnerable to cyberfraud. The Commission is therefore enhancing its 
security measures. 

a.  The Commission stepped up the implementation of the ETS IT security plan. 93.6% of the security measures in Union Registry and 50% of the additional 

security measures following the 2022 risk assessment were implemented at the end of 2023. 

b.  In august 2023,  the Commission signed a contract to explore alternative operating models for the ETS Union Registry. The risks of cyberfraud and 

mitigating measures will be considered. 

31 

 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture 

Nr  Action 
30 

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

Lead 

a.  providing guidance to Commission departments and Executive agencies; 

Central services as appropriate  

b.  establishing Commission wide cooperation on EDES and on the application of the 

BUDG 

Conditionality Regulation; 

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

implementation of the PIF Directive. 

State-of-play May 2024 

JUST: lead 
OLAF: support 

Due date 

2024 and 
continuous 
2023 and 
continuous 
2023 and 
continuous 

The Commission and the EPPO have a shared interest in fostering an effective and cooperative relationship for the purpose of protecting  EU’s financial 
interests.  

There are regular contacts between the EPPO, the central services of the Commission and different Commission departments.  

a.  There are ongoing Commission internal discussions on how to implement the workflows defined in the Commission-EPPO Agreement (Annex I),  

including on the provision of guidance, training and a possible helpdesk for Commission departments and Executive agencies. 

b.  DG BUDG has provided relevant information on EDES to the EPPO. The analysis of information provided by EPPO to the Commission in the context 

of the preparation of the 2024 Rule of Law Report is ongoing, considering its potential relevance for the conditionality mechanism. 

c.  The Commission sent Letters of Formal Notice against 19 Member States for non-compliance of national legislation with the PIF Directive. One Reasoned 
Opinion was sent against a Member State for non-compliance of national legislation with the PIF Directive. Two Reasoned Opinions for non-compliance 
with the PIF Directive were adopted in the April 2024 cycle. Six cases have been closed and further closures are expected in the next cycles. 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture 

Nr  Action 
31 

Strengthen the support to Decentralised agencies and Joint Undertakings4 in their effort to fight fraud, notably 
in establishing a coherent anti-fraud framework across agencies by: 

a.  providing training on ethics and anti-fraud matters; 

b.  providing methodology and advice on anti-fraud strategies; 
c.  sharing knowledge, allowing the agencies to publish relevant information on the inter-agency website; 
d.  regularly  participating  in  relevant  meetings  of  the  EU  Agencies  Network  to  inform  on  anti-fraud 

matters. 

State-of-play May 2024 

Lead 

Due date 

OLAF: lead 
HR: support 
OLAF 
OLAF 

2023 and continuous 

2023 and continuous 
2023 and continuous 

OLAF 

2023 and continuous 

The  EU  Decentralised  agencies  and  Joint  Undertakings  are  autonomous  bodies  with  own  legal  personality,  established  by  a  founding  regulation.  They 
contribute to the implementation of various EU policies, sometimes with an important budget. While they have different governance structures, mandates 
and tasks, they are all bound to follow financial rules similar to those of the European institutions and to prevent fraud and irregularities. 

a.  In the second half of 2023 and in the first quarter of 2024, upon request, OLAF delivered eight tailored-made training courses and presentations on 

ethics and anti-fraud matters to the Decentralised agencies and Joint Undertakings.  

b.  In May 2024, OLAF finalised a dedicated methodology and guidance for anti-fraud strategies in Decentralised agencies and Joint Undertakings. 

c.  OLAF will continue to provide advice and training on anti-fraud matters to the Decentralised agencies and Joint Undertakings, and to share relevant 

material, allowing the agencies to publish relevant information on the inter-agency website. 

d.  OLAF will present the methodology for anti-fraud strategies in Decentralised agencies and Joint Undertakings to the Heads of Agencies and Heads 
of Administrations, as well as to the Commission’s central services and partner DGs by the third quarter of 2024. OLAF will regularly participate in 
relevant meetings of the EU Agencies Network. 

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

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture 

Nr  Action 
32 

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

State-of-play May 2024 

Lead 
CNECT, 
JUST 

Due date 
2023 and continuous 

Investigative journalists are an important source of information on suspected fraud. The European Parliament has repeatedly requested their protection.  

The anti-SLAPP Directive was adopted by the  co-legislators in April 2024. A data collection exercise related to the implementation of the  anti-SLAPP 
Recommendation by Member States was launched in December 2023, and a report is expected for the fourth quarter of 2024. 

The  European  Media  Freedom  Act  was  adopted  by  the  co-legislators  in  April  2024.  An  external  study  to  monitor  Member  States  activities  under  the 
Recommendation on the safety of journalists was launched in July 2023. The publication of the report5 took place in May 2024.  

Since 2019, the Commission ensures the funding of projects in support of media of special relevance to democracy.  In the context of the 2023 Creative 
Europe call, two projects for investigative journalism were selected to receive grants. 

5 EU countries show progress in taking measures to improve journalists’ safety | Shaping Europe’s digital future (europa.eu) 

34 

 
 
 
 
 
  
 
Reinforce the EU anti-fraud architecture 

Nr  Action 
33 

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

Lead 
OLAF, DGs as 
appropriate 

Due date 
2024 

State-of-play May 2024 

Civil society plays an important role in the fight against fraud and corruption in many Member States and at the EU level, emphasised notably by the European 
Parliament.  

OLAF is in regular contact with Transparency International. Notably, in 2023, OLAF approached Transparency International EU to explore possible avenues 
for increased cooperation, notably on whistleblowing and reporting of suspicions of fraud, and meetings between OLAF and Transparency International EU 
have taken place in 2024. 

A high level representative of OLAF will participate in the 2024 International Anti-Corruption Conference, co-organised by Transparency International in 
Vilnius in June, notably to broaden OLAF’s contacts with civil society organisations and to encourage them to contribute to whistleblowing and reporting of 
suspicions of fraud. 

35 

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

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

Lead 
OLAF 

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

Due date 
2023 and 
continuous 

State-of-play May 2024 

OLAF Correspondents and other anti-fraud professionals in Commission departments and Executive agencies meet in the Fraud Prevention and Detection 
Network (FPDNetwork) and its subgroups. These meetings are organised and chaired by OLAF, and a forum to share the latest developments on anti-fraud 
policy, develop such policy and exchange experiences. In addition to the FPDNet subgroups, a number of ad hoc working groups have been created since the 
adoption of the revised CAFS Action Plan in July 2023 with the purpose of implementing different actions. The FPDNet is involved in the coordination and 
monitoring of the implementation of the CAFS Action Plan. 

To maintain a high level of coordination and cooperation in the FPDNet and its subgroups, OLAF conducted a survey in early 2024 to evaluate the activities 
of the network and identify new topics and priorities. The outcome of the survey was shared with the network in May 2024. OLAF will carefully consider 
the views and topics proposed by the services for its future planning of FPDNet plenaries and subgroup meetings, and keep the FPDNet informed of any 
future developments based on the outcome of this survey. 

The  FPDNet  has  a  dedicated  webpage  on  the  Commission’s  anti-fraud  website  which  is  being  revised  as  part  of  the  Commission’s  corporate  move  to 
SharePoint online. The new website will be enhanced with additional content and launched in June 2024, cf. action 40. 

36 

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

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

meetings, for example: 

a. 
the follow-up to OLAF's recommendations and – where applicable – information received from the EPPO; 
b.  overall progress in the implementation of the Commission's anti-fraud strategy and its accompanying action 

Lead 
SG, OLAF: lead 
All DGs: support 

Due date 
2023 and 
continuous 

plan. 

State-of-play May 2024 

The Commission’s Corporate Management Board (CMB) provides coordination, oversight, advice and strategic orientations on corporate management issues, 
including anti-fraud policy matters. OLAF’s Director-General is regularly invited to present aspects of the Commission’s anti-fraud policy. 

a.  In 2023, OLAF was invited to the September CMB meeting to discuss the follow-up of OLAF recommendations and information received from the 

EPPO. 

b.  In the November 2023 meeting of the CMB, the CMB discussed the Commission’s anti-fraud strategy, the revised action plan of July 2023 and the 

follow-up to second high level review of Commission – EPPO cooperation. 

Preparations are underway for OLAF’s participation in an upcoming CMB meeting, on the follow-up to OLAF recommendations and on information received 
from the EPPO. 

37 

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

Nr  Action 
36 

Improve continuously service-level anti-fraud strategies and their implementation, notably by: 
a.  updating such strategies and fraud risk assessments in principle every three years6; 
b.  seeking OLAF's advice at an early stage in the development of such a strategy or update, submitting the drafts 
for OLAF's mandatory review and to peer review, and justifying in writing when OLAF’s recommendations 
on the anti-fraud strategy have not been followed. Any issues that cannot be resolved between OLAF and the 
Commission department concerned may be discussed in suitable fora or be brought to the attention of the 
Corporate Management Board. 

State-of-play May 2024 

Lead 
All DGs and 
executive 
agencies: lead 
OLAF: support 

Due date 
2023 and 
continuous 

Service-level anti-fraud strategies help tailor anti-fraud measures to different policy areas and operations, thus increasing their effectiveness and efficiency. 
OLAF provides support for the elaboration of service-level anti-fraud strategies through methodological guidance elaborated in consultation with FPDNet, 
through training and tailor-made advice. 

a.  In 2023, five Commission departments and Executive agencies updated their service-level anti-fraud strategies together with their fraud risk assessments, 

in line with OLAF anti-fraud strategy methodology of June 2021.  

b.  In  the  FPDNet meeting  of  February  2024,  OLAF  reminded  Commission  departments  and  Executive  agencies  of the need to  update their  anti-fraud 
strategies every three years, and to involve OLAF at an early stage of the revision. OLAF reviewed all anti-fraud strategies submitted in 2023 and early 
2024. Since early 2024, all service-level anti-fraud strategies are subject to peer review. A great majority of departments and agencies follow the guidance 
of OLAF and no issues in this regard were brought to the attention of the CMB in 2023 or early 2024. 

6 In line with the 2019 CAFS and the anti-fraud strategy methodology of June 2021, ref. Ares(2021)4589215. 

38 

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

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

Lead 
OLAF 

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

Due date 
2024 and 
continuous 

State-of-play May 2024 

OLAF’s knowledge and experience from working in Member States with national authorities can be of relevance to the European Semester and the Rule of 
Law processes. 

As regards the European Semester process, OLAF participated in a number of meetings in 2023 and 2024, and got access to CeSaR (the Commission’s online 
database and monitoring tool for the Country Specific Recommendations), to better assess where OLAF’s contribution would be appropriate. 

As regards Rule of Law, OLAF contributed to the 2024 Rule of Law package and regularly participates in the discussions on individual Member States. To 
ensure that all potential Rule of Law issues are properly recorded and followed up upon, OLAF has intensified the screening of its investigations and of the 
investigative outcome for such issues, notably through a dedicated module in its Case Management System. 

39 

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

Nr 
38 

Action 
In  implementing  the  EU’s  anti-corruption  policy7,  exploit  the  synergies  between  anti-fraud  and  anti-corruption 
policies, notably by identifying common areas of high risk and measures to address such risks. 

Lead 
HOME, 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2024 

With its anti-corruption package of May 2023, the Commission stepped up its efforts to integrate the prevention of corruption into the design of EU policies 
and programs, and to actively support Member States' work to put in place strong anti-corruption policies and legislation. The EU Network Against Corruption 
has been created as an umbrella forum for relevant stakeholders to exchange best practices and develop anti-corruption policy. 

As part of these efforts, DG HOME ordered in 2023 a study on high-risk areas of corruption in the EU. A specific section on synergies between anti-fraud 
and anti-corruption policies is foreseen. OLAF and DG HOME have discussed and shared with the contractor areas of high risk of fraud. A presentation on 
the results of the study to the EU Network  Against Corruption is foreseen in the last quarter of 2024. It could be followed in 2025 by a specific  action 
exploring the synergies between anti-fraud and anti-corruption policy, depending on the findings of the study. 

OLAF continues to participate in Commission internal meetings and external events on the fight against corruption, and contributes to the Commission’s 
anti-corruption efforts, such as the UNCAC (United Nations Convention against Corruption) implementation  review of the  EU. OLAF will furthermore 
perform analysis of existing data with the aim of identifying sectors at risks of fraud and corruption. 

7 See the Anti-corruption package adopted by the Commission on 3 May 2023. 

40 

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

Nr  Action 
39 

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

Lead 
HOME, 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2024 

Fraud, corruption and organised crime are often interlinked. These interlinkages need to be better understood to allow for the development of holistic policies. 

In the framework of the EU Organised Crime Strategy, the platform of Organised Crime Experts Group will be used to identify, raise awareness and exchange 
best practices about sectors at high risks at the intersection of fraud, corruption and organised crime. A specific session dedicated to discussing relations 
between fraud, corruption and organised crime, notably in how organised crime and related criminal activities infiltrate the legal economy, could be organised 
by the end of 2024. 

The current policy cycle for the European Multidisciplinary Platform Against Criminal Threats (EMPACT) covers the 2022-2025 period. DG HOME and 
OLAF will closely follow the institutional dialogue on setting EMPACT priorities for the next policy cycle and map possible areas for future synergies. 

The first step in the next EMPACT cycle is the European Union Serious and Organised Crime Threat Assessment (SOCTA), prepared by Europol. OLAF 
has engaged with Europol to explore the scope of OLAF’s contribution to the 2024 SOCTA. 

41 

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

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

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

Due date 
2024 

State-of-play May 2024 

There is a continued need to strengthen the knowledge and maintain a high level of awareness among Commission staff regarding ethics and anti-fraud 
matters. The Commission is gradually strengthening training and awareness raising on ethics and anti-fraud in a holistic manner, as the two topics go hand 
in hand.  

In the autumn of 2023, the Commission launched an internal mapping of the existing ethics and anti-fraud training, to identify possible gaps in the existing 
training offer. The training material collected will be made available on the Commission’s revamped anti-fraud website in June 2024. 

Existing OLAF and HR training on anti-fraud and ethics have been included in the BUDG learning paths/packages in 2023. The corporate “Fraud – Staying 
Vigilant” training has been relaunched, with new training sessions offered in 2024.  

OLAF and relevant Commission departments discussed the gaps in the training offer in a meeting in April 2024 and agreed on the next steps. Notably, the 
ethics and anti-fraud elements will be reinforced in existing financial training. OLAF will continue providing  tailor-made anti-fraud training, with ethics 
elements  included,  while  the  target  audience  for  any  possible  additional  training  needs  to  be  defined.  Developing  anti-fraud  e-learning  options  will  be 
considered. OLAF will develop customisable anti-fraud training material, while DG HR will work on an interinstitutional awareness raising campaign. EPPO-
related training is being discussed in other fora, cf. action 30. 

42 

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

Nr  Action 
41 

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

Lead 
SG: lead 
OLAF, HR: support 

Due date 
2023 and 
continuous 

State-of-play May 2024 

The EU Treaties and the Code of Conduct for the Members of the European Commission lay down the rules on how Members should perform their duties. 
They shall observe the highest standards of ethical conduct. 

The Commission established in 2020 a Network of Ethics and Transparency Contact Points correspondents in the Cabinets of the Members of the Commission 
to raise awareness on the Members’ obligations in the areas of ethics and transparency. The Network is regularly used to exchange information, and regular 
meetings are organised with the Network. Two such meetings took place in 2023, and one in the first quarter of 2024, dedicated to ethical standards for the 
participation of the Members of the Commission in the election campaign to the European Parliament and in election campaigns at Member State level. The 
latter meeting followed the discussion, in College, of the President’s Guidelines for the participation of Members of the European Commission in election 
campaigns at member state level and in the election campaign to the European Parliament. In 2023, information meetings were held both with outgoing and 
incoming Members of the Commission to raise awareness as regards the ethical obligations applicable to them under the Treaty and the Code of Conduct, 
based on standard content. 

43 

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

Nr  Action 
42 

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

Lead 
BUDG 

Due date 
2024 and 
continuous 

State-of-play May 2024 

Direct expenditure in the form of grants and procurement represent a major part of the Union's expenditure. Simplified forms of funding have significant 
potential to reduce administrative burden and the overall error rate. Simplified cost options, such as lump sums or flat rates, are therefore increasingly used 
to provide funding in EU grants. 

DG BUDG provided regular training in 2023 to other Commission departments where anti-fraud matters and the avoidance of conflict-of-interest elements 
were highlighted. In September 2023, a new training video (video-capsule) on simplified cost options was developed and published on the BUDGpedia 
website, and advertised through BUDGpedia and the Finance Units Network (RUF). Promotion is on-going via various other Commission channels. Exercises 
focused  on  the  simplified cost  options  were already  included in the  Grants Workshops  and  will  be maintained throughout  2024.  The BUDGpedia  page 
dedicated to simplified cost options is regularly updated. 

EDES state of play is regularly presented at the RUF meetings and EDES elements were discussed in the Procurement Experts Platform of September 2023. 
A new EDES practitioner experts platform had its first session in March 2024. 

An internal discussion is ongoing on how to further strengthen anti-fraud messages in regular financial training sessions, cf. action 40. 

44 

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

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

strategic analysis and guidance, notably to: 

Lead 
OLAF: lead 
All DGs: support 

Due date 
2023 and 
continuous 

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

b. 

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

State-of-play May 2024 

To increase the anti-fraud knowledge of the Commission, partner organisations and Member States, notably on fraud risks, trends and modus operandi, OLAF 
has established a strategic analysis function within its Anti-Fraud Knowledge Centre. 

Among other analytical documents, OLAF disseminated in 2023 two strategic analysis reports on agriculture and cohesion policy to relevant Commission 
services and Member States, to feed into their fraud risk assessments. Updated versions of these reports will be disseminated in 2024. OLAF also updated 
and disseminated the risk framework for the RRF. 

OLAF continues to provide anti-fraud advice and tailor-made training to Commission departments, other institutions, agencies and Member States, and to 
support these partners in the development of fraud risk assessments and anti-fraud agencies, based on OLAF’s analysis of irregularities and fraud, on its 
investigative and policy experience, and on audit results. 

A case compendia with anonymised external action cases is under preparation with finalisation foreseen for June 2024. 

Relevant strategic analysis, guidance and compendia will be available on the Commission’s new internal anti-fraud website which will go live in June 2024. 

45 

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

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

Lead 
HR: lead 
OLAF: 
support 

Due date 
2023  

State-of-play May 2024 

With a workforce of over 32 000 staff in close to 200 places of employment, the Commission recruits every year  approximately 500 officials and 1 800 
temporary or contract agents. It is important to consider anti-fraud aspects in the recruitment process, to identify any unethical tendencies and potential 
wrongdoers and avoid recruitments potentially damaging for the institution.  

Therefore, anti-fraud checks are always present in the initial review of the recruitment process. Furthermore, DG HR is in the process of designing a new 
recruitment procedure that will take into account the changes in the selection procedure carried out by EPSO under its new competition model. As part of the 
new recruitment procedure, candidates’ data and eligibility will be checked by DG HR with the aim of identifying any attempts of fraud on the institution. 
The new recruitment procedure  will be in place by the time laureate lists issued under the new EPSO competition model are made available (currently 
foreseen for early 2025). 

DG  HR  ensures  a  thorough  review  of  copies  of  candidates’  qualifications  and  certificates,  including  by  consulting  the  National  Academic  Recognition 
Information Centre, competent national authorities and IDOC as needed.  

46