COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of article 325 TFUE 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) 191 final  COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of article 325 TFUE 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) 192 final} - {SWD(2024) 193 final}  
 
 
2.1. 

Contents 
List of abbreviations .................................................................................................................................................................... 4 
Introduction ................................................................................................................................................................................ 5 
Overview of measures taken by Member States ............................................................................................................... 6 
1. 
Single and package measures ............................................................................................................................. 6 
1.1. 
Types of measure ................................................................................................................................................ 6 
1.2. 
Nature of measures ............................................................................................................................................. 7 
1.3. 
Anti-fraud cycle ................................................................................................................................................... 8 
1.4. 
Areas reported .................................................................................................................................................... 8 
1.5. 
Overlapping themes ............................................................................................................................................ 9 
1.6. 
1.6.1.  Whistle-blowers .................................................................................................................................................. 9 
1.6.2.  Digitalisation ....................................................................................................................................................... 9 
2.  Measures taken by the Member States ........................................................................................................................... 11 
Austria .................................................................................................................................................................... 11 
Social benefit fraud .......................................................................................................................................................... 11 
High-density verifications ................................................................................................................................................ 12 
Belgium .................................................................................................................................................................. 13 
Protection of whistle-blowers ......................................................................................................................................... 13 
Combating cross-cutting fraud ........................................................................................................................................ 14 
Digitalisation of the fight against fraud: using the Arachne tool ..................................................................................... 15 
Bulgaria .................................................................................................................................................................. 17 
Management of irregularities under shared management ............................................................................................. 17 
Protection of whistle-blowers ......................................................................................................................................... 18 
Creation of a new Anti-Corruption Commission .............................................................................................................. 19 
Croatia .................................................................................................................................................................... 20 
IT tool for submitting applications and control of EU projects ........................................................................................ 20 
Work guidelines for monitoring the implementation of the National Recovery and Resilience Plan (NRRP) ................. 21 
OLAF training in preventing and detecting irregularities and fraud ................................................................................ 22 
Cyprus .................................................................................................................................................................... 23 
Establishment of the national coordinating body for combating fraud against the EU’s financial interests ................... 23 

2.3. 

2.4. 

2.5. 

2.2. 

2.6. 

2.7. 

Guidelines on protection of the EU’s financial interests in the context of implementation of the National Recovery and 
Resilience Plan ................................................................................................................................................................. 24 
Implementation of the Law on Transparency in Public Decisions and Related Matters (‘Lobbying Law’) ...................... 25 
Czechia ................................................................................................................................................................... 27 
Whistle-blower Protection Act ........................................................................................................................................ 27 
Fight against VAT fraud .................................................................................................................................................... 28 
Preventing corruption and fraud and increasing transparency in the implementation of EU funds ............................... 29 
Denmark ................................................................................................................................................................ 30 
Anti-fraud and anti-corruption strategy for the National Recovery and Resilience Plan ................................................. 30 
Digitalisation of the management of EU funds ................................................................................................................ 31 
Strategy and guidelines for fraud detection in the area of fisheries ............................................................................... 31 
Estonia ................................................................................................................................................................... 33 

2.8. 

1 

 
 
Strengthening the investigative capacity into corruption and economic crimes of the Estonian Police and Border 
Guard ............................................................................................................................................................................... 33 
New information systems for Customs clearance ........................................................................................................... 34 
Additions to the national e-procurement platform ......................................................................................................... 34 
Finland ................................................................................................................................................................... 36 
Customs food fraud project to fight the shadow economy and food fraud .................................................................... 36 
Anti-fraud training for the EU’s regional and structural policy programme .................................................................... 37 
France .................................................................................................................................................................... 38 
Establishment of an inter-ministerial monitoring unit to combat public aid fraud ......................................................... 38 
Working group on emerging fraud under RRF funds ....................................................................................................... 39 

2.9. 

2.10. 

2.11. 

2.12. 

Establishment of a system of financial liability for public administrators and development of relations between the 
judicial authority and the financial courts ....................................................................................................................... 41 
Germany ................................................................................................................................................................ 42 
Regional fraud risk assessment tool: Berlin ..................................................................................................................... 42 
Regional fraud risk assessment tool: Saxony ................................................................................................................... 43 
Regional anti-fraud measures: Schleswig-Holstein .......................................................................................................... 44 
Greece .................................................................................................................................................................... 45 
Integration of fraud prevention and detection within the Greek management and control system .............................. 45 
Introduction of Arachne in relation to the common agricultural policy .......................................................................... 46 
Launch of the ‘Complaints from citizens’ platform of the Independent Authority for Public Revenue .......................... 47 
Hungary .................................................................................................................................................................. 48 
Preventing, detecting and correcting cases of conflicts of interest in the management of EU funds ............................. 48 
Risk-based ex post and post-release controls in relation to the European Agricultural Guarantee Fund ....................... 49 

2.13. 

2.14. 

2.15. 

Cooperation agreement between the National Tax and Customs Administration and the Directorate of Internal Audit 
and Integrity .................................................................................................................................................................... 51 
Ireland .................................................................................................................................................................... 52 
Department of Justice anti-fraud and corruption policy ................................................................................................. 52 
Digitalisation of the fight against e-commerce VAT fraud ............................................................................................... 53 
Italy ........................................................................................................................................................................ 54 
General anti-fraud strategy for the implementation of the National Recovery and Resilience Plan (NRRP) .................. 54 
Digitalisation of the management of the RRF .................................................................................................................. 56 
Safeguarding the NRRP legislative measures. Prevention and suppression of fraud. ..................................................... 57 
Latvia ...................................................................................................................................................................... 58 

2.16. 

Adoption of the Action Plan to Prevent and Combat Corruption 2023-2025 and the Operational Strategy of the Bureau 
for Preventing and Combating Corruption 2023–2026 ................................................................................................... 58 
Fight against VAT fraud in the vehicle trade .................................................................................................................... 59 
Educational activities for public procurement organisers in the risks of competition in procurement ........................ 60 
Lithuania ................................................................................................................................................................ 61 
Regulatory measures ....................................................................................................................................................... 61 
Increasing the number of suppliers within public procurement ..................................................................................... 62 

2.17. 

2.18. 

Approval of the methodology for the application of sanctions for infringements of the provisions of legal Acts and the 
approval of the rules for the administration of infringements of legal provisions .......................................................... 62 
Luxembourg ........................................................................................................................................................... 64 
Ongoing activities for the adoption of a national anti-fraud strategy ............................................................................. 64 
2.19.  Malta ...................................................................................................................................................................... 65 
2 

 
 
2.20. 

2.21. 

2.22. 

Training in line with the NAFCS and Malta’s RRP commitments ..................................................................................... 65 
Netherlands ........................................................................................................................................................... 66 
Reporting of fraud to the EPPO ....................................................................................................................................... 66 
Administrative checks on actual land use ........................................................................................................................ 67 
Poland .................................................................................................................................................................... 68 
Guidelines for the controls under the development plan co-financed by the Recovery and Resilience Facility ............. 68 
Whistle-blower policy for the National Recovery and Resilience Plan ............................................................................ 69 
Managing authority guidelines regarding the strategic plan for the common agricultural policy (SP CAP) 2023-2027 .. 70 
Portugal .................................................................................................................................................................. 71 
Update of the National Anti-Fraud Strategy .................................................................................................................... 71 
Training of managing authorities in fraud risk assessment ............................................................................................. 72 
Systematic risk analysis within Customs .......................................................................................................................... 73 
Romania ................................................................................................................................................................. 74 
Combating tax evasion .................................................................................................................................................... 74 
Legislative measures regulating the obligation to refer a matter to the competent criminal authorities ...................... 75 

2.23. 

Adoption of the National Anti-Fraud Strategy 2023-2027 for the protection of the European Union’s financial interests 
in Romania ....................................................................................................................................................................... 76 
Slovakia .................................................................................................................................................................. 77 

2.24. 

Inventory of measures on the protection of the EU´s financial interests for prevention of the most serious 
irregularities in the context of RRF .................................................................................................................................. 77 

2.25. 

Establishment of the Board of Anti-Corruption Coordinators and updates to the anti-corruption programmes of 
individual ministries and other central authorities.......................................................................................................... 78 
Directive 2/2023 on conflict of interest in the Agricultural Paying Agency ................................................................. 78 
Slovenia .................................................................................................................................................................. 80 
Sets of measures for enhancing the protection of the EU’s financial interests ............................................................... 80 
Digitalisation of the fight against fraud: the Qlik Sense platform .................................................................................... 81 
Amending the transposition into Slovenian law of the PIF Directive ............................................................................... 82 
Spain ...................................................................................................................................................................... 84 

2.26. 

Adoption of Law 2/2023 of 20 February on the protection of persons who report breaches of the law and on the fight 
against corruption ........................................................................................................................................................... 84 

2.27. 

3. 

3.1. 
3.2. 
3.3. 
3.4. 

Systematic analysis of the risk of conflict of interest in the procedures implementing the Recovery, Transformation 
and Resilience Plan. ......................................................................................................................................................... 85 
Implementation of the Central Register of Beneficial Ownership ................................................................................... 86 
Sweden .................................................................................................................................................................. 88 
Study on improving the possibilities for exchanges of information between authorities ............................................... 88 
Increased cooperation on double funding and control methods .................................................................................... 89 
Additional measures reported by the Member States .................................................................................................... 90 
Belgium .................................................................................................................................................................. 90 
Denmark ................................................................................................................................................................ 90 
Estonia ................................................................................................................................................................... 90 
Germany ................................................................................................................................................................ 91 
Conflicts of interest: ........................................................................................................................................................ 91 
Whistleblower protection: ............................................................................................................................................... 91 
Reporting of irregularities ................................................................................................................................................ 91 
Anti-fraud measures ........................................................................................................................................................ 91 
3 

 
 
4. 

4.1. 

3.5. 
3.6. 
3.7. 

Italy ........................................................................................................................................................................ 91 
Latvia ...................................................................................................................................................................... 91 
Romania ................................................................................................................................................................. 92 
National Strategy for public procurement (SNAP) 2023-2027 ......................................................................................... 92 
Institutional and financial framework for the management of RRF ................................................................................ 92 
Case studies ..................................................................................................................................................................... 94 
Revenue ................................................................................................................................................................. 94 
Smuggling ........................................................................................................................................................................ 94 
Incorrect classification / misdescription / illegal cigarette production ............................................................................ 95 
4.2. 
Expenditure ............................................................................................................................................................ 96 
ANNEX 1 Specification of type of (legislative and administrative) measures ....................................................................... 98 
ANNEX 2 Nature of measures – various sectors ................................................................................................................. 100 
ANNEX 3 Anti-fraud cycle ................................................................................................................................................... 101 
ANNEX 4 Areas reported .................................................................................................................................................... 104 
ANNEX 5 Overview ............................................................................................................................................................. 107 

List of abbreviations  

AFCOS  

Anti-Fraud Coordination Service  

AFS  

CAP 

CDM  

EPPO  

ERDF  

ESF  

EU  

FEAD  

NAFS  

NRRP 

OLAF  

PIF  

RRF  

RRP  

VAT  

Anti-Fraud Strategy  

Common agricultural policy  

Centralised direct management  

European Public Prosecutors’ Office  

European Regional Development Fund  

European Social Fund  

European Union  

Fund for European Aid to the Most Deprived  

National anti-fraud strategy  

National Recovery and Resilience Plan 

European Anti-Fraud Office  

Protection of the EU’s financial interests  

Recovery and Resilience Facility  

Recovery and Resilience Plan  

Value Added Tax 

4 

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

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

To  compile  this  document,  the  Commission  asked  the  Member  States  to  report  on  up  to  three 
measures  adopted in 2023  they considered most important for the  protection  of  the EU’s financial 
interests.  Their  responses  were  collected  through  a  survey  (also  known  as  the  PIF  Questionnaire). 
Section 1 of this document presents an overview of the measures, while Section 2 includes the detailed 
information provided by Member States. 

The survey collected both structured and unstructured (free text) information. The table below shows 
the format used for presenting structured information on the measures from the PIF Questionnaire 
2023.  

1st 2nd 3rd anti-fraud measure taken by MS in 2023 

Single/ 
package  

Type of 
measure  

New or 
update  

Area 

Scope  

Nature of the 
measure and 
sector 
concerned  

Reason / 
expected 
result of the 
measure 

Legislative 

Administrative 

Operational 

Organisational 

Prevention 

Detection 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

Investigation 
and 
prosecution 

Reading guide:  

In the policy cycle shown in the table above, green denotes that this particular phase has been 
addressed in the measure reported. The phases that are not included in the measure are taken out of 
the figure.  

The various measures reported by Member States are denoted as MS-1, MS-2 and MS-3, i.e. the 
Member State and its first, second or third reported measure.  

Member States also had the opportunity where they felt it necessary to describe briefly additional 
measures and report case studies, which are presented, respectively, in Sections 3 and 4. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1. Overview of measures taken by Member States 

Using a questionnaire distributed by OLAF, all Member States reported a maximum of three national 
anti-fraud  measures  adopted  in  2023.  Based  on  these  findings,  this  document  provides  a 
comprehensive,  yet  non-exhaustive,  overview  of  all  the  reported  measures,  highlighting  new 
developments  in  light  of  the  anti-fraud  actions  taken  by  Member  States  aimed  at  improving  the 
protection of the EU’s financial interests.  

Based on the answers provided, Member States reported a total of 72 single and package measures. 
Package measures encompass a number of instruments adopted at the same time  that pursue  the 
same  objective.  The  table  below  reveals  that,  among  these  adopted  measures,  52  were  single 
measures  and  other  20  measures  were  packages  of  various  individual  measures.  These  packages 
consist of 39 individual actions. This means that a total of 91 individual measures were reported by 
Member  States,  of  which  42  were  new  measures  and  45  updates/amendments.  In  addition,  four 
package measures contained both new and updated measures.  

1.1. Single and package measures  

The overview below shows the number of single and package anti-fraud measures adopted by Member 
States in 2023 according to type of measure. 

y
c
n
e
u
q
e
r
F

Amount 

Single  
Package  
Total  

Administrative  
9 
12 
21 

Legislative  
18 
5 
23 

Type 

Operational  
16 
12 
28 

Organisational 
9 
10 
19 

Total 
52 
39 
91 

1.2. Types of measure  

All  reported  measures  are  categorised  as  either  administrative, 
legislative,  operational,  or 
organisational. An administrative measure concerns a legal Act adopted by an administrative body that 
implements actions provided by legislative Acts. A legislative measure refers to an Act adopted by a 
legislative body to enforce legal obligations. An organisational measure is a decision or any other non-
legislative action taken to change the organisational framework of an administration or body whose 
tasks  and  activities  relate  to  the  protection  of  the  EU’s  financial  interests.  Lastly,  an  operational 
measure is any action undertaken by an administration or body whose tasks and activities relate to the 
protection of the EU’s financial interests, with a direct impact on its operations. 

In 2023, most measures concerned operational measures (31% of the total reported). The remaining 
types  of  reported  measures  are  fairly  evenly  distributed  between  administrative  (23%),  legislative 
(25%) and organisational (21%). However, as the table below shows, package measures often contain 
more administrative (31%), operational (31%), and organisational (25%) measures. Only 13% of the 
reported measures refer to a legislative measure. Single measures rely mostly on legislative (35%) and 
operational  measures  (31%).  Most  legislative  measures  consist  of  laws/acts,  followed  by  decrees. 
Administrative measures mostly refer to Circulaires/Circulars, Instructions, Guidelines or Manuals. For 
a more detailed description of the breakdown of measures, see Annex 1.  

6 

 
 
 
 
 
T Y P E S  O F   A L L   M E A S U R E S  
A D O P T E D  

S I N G L E M E A S U R E S

21%

23%

Administrative

31%

25%

Legislative

Operational

Organisational

17%

17%

31%

35%

PA C K A G E  M E A S U R E S  

25%

31%

31%

13%

1.3. Nature of measures  

All anti-fraud actions are either horizontal or targeted at specific revenue or expenditure sectors. Out 
of  72  individual  measures,  27  were  horizontal,  as  opposed  to  44  sectoral  actions.  The  table  below 
shows  an  overview  of  the  sectors  targeted  by  individual  anti-fraud  measures  adopted  by  Member 
States  in  2023.  It  reveals  that  sectoral  measures  most  often  target  expenditure;  particularly  on 
agriculture, cohesion policy and the RRF. For a more detailed description of these sectors, see Annex 
2. 

Measure 
Single 
Package 
Total 

Horizontal 
19 
9 
27 

Sectoral  
33 
11 
44 

Sectors

Total  
52 
20 
72 

s
r
o
t
c
e
s

s
u
o
i
r
a
V

Expenditure - Cohesion policy
Expenditure - Recovery and Resilience Facility
Expenditure - Agriculture
Expenditure - Fisheries
Revenue - Tax fraud
Revenue - Customs
Expenditure - Migration and asylum
Expenditure - Fund for the most deprived
Expenditure - Globalisation Fund
Expenditure - Centralised direct management

0

20
10
Number of measures targeted at this specific sector

15

5

7 

 
 
 
 
 
 
  
 
 
1.4. Anti-fraud cycle  

The fight against fraud requires a holistic and comprehensive approach covering all stages of the anti-
fraud cycle, as the EU’s financial interests are protected by multiple actors and processes, which are 
deeply interconnected and influenced by one another. The anti-fraud cycle is divided into four stages: 
(1) prevention through risk analysis and self-assessment to quantify the likelihood and impact of fraud 
(2) detection of fraud through reporting processes (e.g. IT tools), aimed at increasing comparability 
and  interoperability,  (3)  investigation  and  prosecution  through  audit  controls,  and  (4)  imposing 
recovery and sanctions, often implemented by Member States. 

As in previous years, most measures, both single and package, focused on the first two stages of the 
anti-fraud cycle in 2023, i.e. fraud prevention and fraud detection. See Annex 3 for a detailed overview 
of the various measures reported for each stage of the policy cycle.  

Targeted at specific stages of the anti-fraud cycle 

Fraud prevention

Fraud detection

81

74

Fraud investigation and prosecution

43

e
l
c
y
c
y
c
i
l

o
p
n

i

e
g
a
t
S

Recovery and sanction

20

0

10

20

30

80
50
Number of measures targeted at this phase 

60

40

70

90

1.5. Areas reported  

The table below shows the areas to which the adopted measure relates. It demonstrates that shared 
management and control of EU funds, conflict of interest and anti-fraud or anti-corruption strategies 
are the most prominent areas among the reported measures. Annex 4 provides a detailed overview of 
the measures reported per area.  

Areas reported

s
a
e
r
a
s
u
o
i
r
a
V

Shared management and control of EU funds

Conflict of interest

Antifraud or anticorruption strategy

Public procurement

Financial crime (including money laundering)

Whistle-blower

Fraud definition

Organised crime

Corruption

AFCOS

Customs/ToR/illicit trade

Other

0

5

10

15

20

25

30

35

40

Number of measures aimed at this specific area

8 

 
 
 
 
 
 
 
 
1.6. Overlapping themes 

In general, two overlapping themes stand out: the protection of whistle-blowers and the role of 
digitalisation, both of which are becoming prominent areas of focus for various Member States.  

1.6.1.  Whistle-blowers 

As can be seen in the various areas reported (see above table), a relatively large number of measures 
are aimed at the protection of whistle-blowers. Additionally, various Member States reported single 
or package measures that focus on this issue. These measures often involve legislative measures. 

Belgium  reported  a  single  legislative  measure  in  this  regard,  by  reporting  that  a  royal  decree  was 
adopted  in  October  2023  with  the  purpose  of  defining  the  components  of  internal  reporting 
procedures and follow-up within federal public sector bodies on the protection of whistle-blowers.  

Bulgaria  also  reported  legislative  measure  to  protect  whistle-blowers.  The  measure  is  designed 
primarily  to  protect  individuals  in  the  public  and  private  sectors  who  report  or  publicly  disclose 
information on breaches of Bulgarian or EU law that come to their attention during or in connection 
with  their  work  or  while  performing  their  duties.  The  obliged  entities  under  this  measure  are  all 
employers in the public sector and designated employers in the private sector. 

In addition, Czechia reported a new measure designed to protect whistle-blowers and amend certain 
other  provisions  in  connection  with  the  measure’s  adoption.  The  purpose  of  this  legislation  is  to 
provide  means  for  employees  in  both  the  private  and  public  sectors  to  report  wrongdoing  which 
whistle-blowers  become  aware  of  within  their  employment  or  service.  Reporting  also  covers 
infringements in the case of protection of the EU's financial interests. 

Poland reported an administrative measure addressing the whistle-blower policy under its National 
Recovery  and  Resilience  Plan  (NRRP).  This  procedure  handles  reports  from  members  of  the  public 
concerning potential irregularities or fraud and the protection of individuals who report irregularities 
or fraud (part of the procedure for carrying out controls). The main aim of the procedure is to set up a 
system for reporting potential irregularities or fraud in projects implemented under the NRRP, which 
at  the  same  time  guarantees  protection  for  those  who  report  such  incidents  (‘whistle-blowers’)  by 
creating secure channels. The procedure also applies to anonymous reporting. 

Spain also reported legislative measures to address the role of whistle-blowers and ensure adequate 
protection  for  them  in  the  fight  against  fraud  and  corruption.  One  of  the  aims  of  this  legislative 
measure is to strengthen the information culture and the integrity infrastructures of organisations and 
promote an information or communication culture as a mechanism to prevent and detect threats to 
the  public  interest.  More  specifically,  this  measure  establishes  the  obligation  to  set  up  internal 
reporting systems throughout the Spanish public administration, and steps to protect whistle-blowers 
who report through internal or external channels as well as the rules to govern these channels and the 
creation of  an  independent  authority  to  protect  whistle-blowers. The  measure  also establishes  the 
sanctions necessary to effectively combat actions involving reprisals against whistle-blowers as well as 
breaches of the rules governing communication channels. 

Lastly, Slovenia reported on a measure to protect whistle-blowers through both internal and external 
whistle-blowing channels, adopting  instructions  for the  protection of external and  internal  whistle-
blowers.  

1.6.2.  Digitalisation 

Various other measures were reported in relation to the role of digitalisation in the fight against fraud. 
In light of the second recommendation in the 2022 PIF report on the role of digitalisation in this regard, 

9 

 
 
digitalisation is a relevant topic that warrants attention going forward (1). The recommendation states 
that the Member State should ensure that the digitalisation of the fight against fraud is part of their 
National  Anti-Fraud  Strategy  (NAFS).  The  relevant  approach  should  define  strategies  to  (1)  identify 
existing and future threats arising from new technologies, (2) develop the necessary IT architecture 
(inventories  of  existing  tools,  developing  new  ones,  ensuring  appropriate  interoperability  between 
tools); and (3) identify and address existing gaps, including in terms of skills requirements. 

In line with building a solid IT architecture, Belgium reported in 2023 that the Arachne tool had been 
introduced for use by the managing authorities of EU funds: the Brussels Capital Region, Wallonia and 
Flanders use Arachne as part of their ERDF, RRF and ESF programmes. Belgium’s assessment was that 
the use of Arachne would help to avert the risk of double financing between different European funds 
and mitigate the risk of conflicts of interest and, therefore, fraud.  

In addition, Denmark reported on the use of digitalisation for the management of EU funds. It referred 
to automatic checks in ‘e-indkomst’, an automated process that records if payments were made to the 
persons  registered/included  in  the  project  reporting  used  to  seek  reimbursement.  The  system  is 
expected to be fully incorporated in the course of 2024, making it easier to detect if a payment has 
taken place or not. 

Ireland also turned to legislation to address the role of digitalisation in the fight against e-commerce 
VAT fraud. The EU Central Electronic System of Payment Information (CESOP) is used to detect possible 
e-commerce VAT fraud by sellers established in another Member State or in a non-EU country. The 
information  reported  to  CESOP  can  help  tax  authorities  in  EU  Member  States  detect  fraudulent 
business activity and control VAT liabilities. 

Italy reported on the digitalisation of RRF management. In 2023, the special appendix adopted by RGS 
Circular No 27 of 15 September 2023, entitled ‘Collecting data on beneficial ownership pursuant to 
Article 22(2)(d)  of  Regulation  (EU) 2021/241  and  notifying  the  Financial  Intelligence  Unit  (FIU)  of 
suspicious transactions made by the public administration pursuant to Article 10 of Legislative Decree 
No 231/2007’,  was  issued.  It  supplements  the  reporting  and  control  guidelines  and  defines  the 
procedural steps that the bodies/departments implementing NRRP measures must put in place using 
the functionalities available through the ReGiS IT system. This operational measure aims to improve 
coordination and  cooperation  between  the  various  actors  involved  in the  implementation of  NRRP 
measures  by improving  ex ante  controls (beneficial owners with potential conflicts of interest) and 
encouraging the flow of information, including notifications of suspicious transactions. 

Lastly, Slovenia reported on addressing the role of digitalisation in the fight against fraud through ‘Qlik 
Sense’ (QS). This new IT platform allows new and enhanced applications to be created and developed 
for specific customs, tax and excise areas. These applications help with performing better risk analyses, 
implementing  risk  management,  and  targeting  suspicious  patterns,  transactions  and  economic 
operators. Predictive analyses, machine learning and artificial intelligence can then be carried out. 

(1)  Additional information related to the implementation of the recommendation can be found in the Staff Working 

Document ‘Follow-up by the Member States to the recommendations of the PIF Report 2022’ accompanying the 2023 
PIF Report. 

10 

 
 
 
 
 
2. Measures taken by the Member States 

2.1. Austria 

Austria reported the adoption of two measures in 2023, both related to cohesion policy. 

Social benefit fraud 
General, comprehensive and proactive actions to combat the unlawful receipt of social benefits (social 
benefit fraud) through the linear structure developed across Austria within the police (BK, LKA, BPK) 
and its recurring priority actions on social benefit fraud in the course of airport checks and GVS checks 
in Austria’s provinces (‘Länder’). 

Reason for reporting: to launch and conduct inquiries and international investigative measures in more 
than 80 countries around the world, through Europol, Interpol, Austrian embassies and liaison officers. 

The  aim  of  this  legislative  measure  was  to  facilitate  information  exchanges  between  the  money 
laundering reporting unit and competent national and foreign authorities, as well as with Europol. 

1st anti-fraud measure taken by AT in 2023 

Single/ 
package  

Type of 
measure  

New or 
update  

Single  

New  

Legislative – 
Law/Act 
01/08/2021* 

Nature of the 
measure and 
sector 
concerned  

Sectoral; 
Expenditure – 
Cohesion 
policy 

Area 

Scope  

Powers  

Financial 
crime 
(including 
money 
laundering) 

Reason / 
expected 
result of the 
measure 

To enforce the 
rules in line 
with 
developments 
in EU law 

Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

* Legislative Act: reference BGBl. (Federal Law Gazette) I No 123/2021 

11 

 
 
 
 
 
High-density verifications  
Pursuant to Article 125(4) of Regulation 1303/2013 for the 2014-2020 programming period, Member 
States must prevent irregularities. The verification procedure should allow the administrative bodies 
to check 100% of the expenditure submitted by the beneficiary. 

2nd anti-fraud measure taken by AT in 2023 

Area  

Scope  

Public 
procurement; 
Conflict of 
interest; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

Eligibility 
criteria; 
Management 
of funds; On-
the-spot 
checks; Audit 
checklist; 
Irregularities 
reporting; 
Recovery 

Reorganisatio
n of existing 
bodies; Inter-
agency 
cooperation; 
General 
training; Fraud 
awareness 
training; 
Simplification 
of procedures 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Other*** 

Reason / 
expected 
result  

Cross-cutting 
measure*; 
Multi-agency 
measure / 
Measure with 
impact on 
various 
bodies; 
Other**  

Neutral on 
resources 

Enhanced 
information 
flow; 
Targeting of 
checks 

Single/ 
package  

Type of 
measure 

New or 
update  

Package 

Update 

Administrative
- Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Nature of the 
measure and 
sector 
concerned  

Sectoral: 
Expenditure – 
Cohesion 
policy 

Organisational 
– 01/01/2024 

Update 

Operational – 
08/10/2015 

Update 

Prevention

Detection

Recovery and 
sanction 

* Formal requirements in the national rules on eligibility and in the management and control system should increase 
efficiency. Standardised forms (checklists) improve the quality of the accounts submitted. 

** Monitoring and ensuring the proper use of funds as well as notifying irregularities identified. 

*** Presentation of the entire funding operation, including the accounting process, in a central database. In addition, the 
Arachne data-mining tool, provided by the Commission, is used for risk evaluation and risk analysis. 

12 

 
 
 
 
 
 
2.2. Belgium  

Belgium reported on three measures adopted in 2023, two of them horizontal and one relating to 
cohesion policy. 

Protection of whistle-blowers 
Royal Decree of 20 October 2023 laying down the components of internal reporting procedures and 
follow-up,  the  purposes  and  content  of  keeping  records  of  reports  and  arrangements  for  public 
consultation pursuant to the fourth subparagraph of Article 10(1), the third subparagraph of Article 11, 
the  third  subparagraph  of  Article 27(5)  and  the  third  subparagraph  of  Article 76  of  the  Law  of 
8 December 2022  on  reporting  channels  and  the  protection  of  persons  who  report  breaches  of 
integrity in federal public sector bodies and the integrated federal and local police force. 

The main purpose of this Royal Decree is to define the components of internal reporting procedures 
and follow-up within federal public sector bodies, as defined in Article 6(1) of the abovementioned 
Law of 8 December 2022. Most of the provisions of the Royal Decree, namely Articles 2 to 13, concern 
said procedures and follow-up. 

1st anti-fraud measure taken by BE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Decree 
20/10/2023* 

New 
legislation 

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Area  

Scope  

Whistle-
blower 

Definition of a 
specific topic; 
Other**  

Reason / 
expected 
result  

Legislative 
measure to 
clarify or 
consolidate 
existing rules 

Detection 

Investigation 
and 
prosecution 

* Royal Decree laying down the components of internal reporting procedures and follow-up, the purposes and content of the 
keeping of records of reports and arrangements for public consultation, pursuant to the fourth subparagraph of Article 10(1), 
the third subparagraph of Article 11, the third subparagraph of Article 27(5) and the third subparagraph of Article 76 of the 
Law of 8 December 2022 on reporting channels and the protection of persons who report breaches of integrity in federal public 
sector bodies and the integrated federal and local police force. 

Link: http://www.ejustice.just.fgov.be/eli/arrete/2023/10/20/2023046353/justel 

**  The  Walloon  Government  also  adopted  a  decree  laying  down  various  rules  on  reporting  a  suspected  irregularity  in  a 
Walloon Government department or public service provider (Decree of 13 October 2022), which ensures that all reports of 
fraud within the Walloon public administration are treated in the strictest confidence. Internal and external reporting channels 
were also established. 

Description of legislative measure: the main purpose of this Royal Decree is to define the components of the procedures and 
follow-up for internal reporting channels within federal public sector bodies, as defined in Article 6(1) of the abovementioned 
Law of 8 December 2022. This also constitutes the subject-matter of most of the provisions of the Royal Decree, namely Articles 
2 to 13. 

13 

 
 
 
Combating cross-cutting fraud 
The  Strategy  Committee  of  the  Walloon  public  administration  (Service  Public  de  Wallonie,  SPW) 
adopted  a  policy  to  combat  cross-cutting  fraud,  comprising  a  number  of  specific  measures: 
commitment on the part of the Strategy Committee to an effective anti-fraud policy; adoption of a 
code of ethics for all staff; programme of cross-cutting and targeted training; risk analyses; measures 
to prevent and manage conflicts of interest; reporting mechanisms, etc. The Flemish Agriculture and 
Fisheries Agency also finalised its anti-fraud strategy in 2023. 

The  measure  goes  beyond  the  EU  funds  alone  and  concerns  all  SPW  departments  and  staff.  It  is 
designed to raise awareness, provide training and information inside and outside the administration, 
encourage  the  taking  of  responsibility,  and  introduce  clear  procedures  about  which  everyone  is 
informed (reporting, penalties, etc.). The Flemish Agriculture and Fisheries Agency put forward a clear 
vision and approach in its strategy. This vision provides a basis for tackling fraud as best possible. The 
strategy describes how Wallonia will deal with fraud reporting, which will reduce fraud in the future. 

2nd anti-fraud measure taken by BE in 2023 

Single/ 
package  

Type  

New measure 
or update  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

New measure 

Horizontal 

Package  

Administrative 
– Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Organisational 
– 14/12/2023 

New measure 

Operational - 
27/06/2023 

New measure 

Conflict of 
interest; Fraud 
definition; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

Irregularities 
reporting 

Competence; 
Inter-agency 
cooperation; 
Fraud 
awareness 
training; 
Other* 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Flagging 
practice; Risk 
indicators; 
Other** 

Reason / 
expected 
result  

Cross-cutting 
measure; 
Multi-agency 
measure / 
Measure with 
impact on 
various 
bodies*** 

Increased 
resources 

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

14 

 
 
Prevention 

Detection 

* On 27 June 2023, the AFS of the Flemish Agriculture and Fisheries Agency was finalised. It provides a basis for the anti-
fraud work that was already being done and that will continue. It gives an overview and analysis of the applicable measures, 
and provides clarification on the planned approach for the coming years. It puts forward a clear vision and approach 
strategy. This vision provides a basis for tackling fraud as best possible. The AFS describes how to address fraud reporting, 
which will reduce fraud in the future. 

** In 2023 the AFS of the Flemish Agriculture and Fisheries Agency was finalised. It provides a basis for anti-fraud efforts 
now and in the future. It gives an overview and analysis of the applicable measures, and clarifies the planned approach for 
the coming years. It puts forward a clear vision and strategy. This vision provides a basis for tackling fraud as best possible. 
The AFS describes how to address fraud reporting, which will reduce fraud in the future. 

*** Anti-fraud policy adopted and implemented throughout the Walloon public administration, applicable to all 
departments: SPW General Secretariat, SPW Mobility and Infrastructure, SPW Agriculture, Natural Resources and 
Environment, SPW Land, Housing, Heritage and Energy, SPW Interior and Social Action, SPW Economy, Employment and 
Research, and SPW Tax.  

Digitalisation of the fight against fraud: using the Arachne tool 
In 2023  Arachne  was introduced for  use  by  the  authorities  managing  European funds:  the Brussels 
Capital Region, Wallonia and Flanders use Arachne as part of their ERDF, RRF and ESF programmes. 

Using Arachne will allow the risk to be averted of double financing between different European funds 
and also mitigate the risk of conflicts of interest, and therefore fraud. For example, at ESF Flanders, an 
evaluation of a project proposal can only begin subject to a sworn declaration. Sworn declarations will 
be sampled. A possible conflict of interest within the sample population will be checked using Arachne. 

3rd anti-fraud measure taken by BE in 2023 

Single/ 
package  

Type  

New measure 
or update  

Package 

Administrative
-
Recommendat
ion  

Operational 
02/01/2023 

New measure 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Cohesion 
policy 

Reason / 
expected 
result  

Other* 

Area  

Scope  

Monitoring/ 
desk checks; 
On the spot 
checks 

Conflict of 
Interest; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

Risk indicators   Targeting of 

checks; 
Enhanced ex 
post controls 

15 

 
 
 
Prevention 

Detection 

*ESF Flanders: in accordance with Article 74(1)(c) of Regulation 1060/2021, the Managing Authority shall ensure effective 
and proportionate anti-fraud measures and procedures based on the risks identified. Ex-ante use of Arachne to detect a 
conflict of interest through data analysis is seen as a measure to detect fraud. 

16 

 
 
 
 
 
2.3. Bulgaria  

Bulgaria reported the adoption of three legislative measures on the management of irregularities, 
the protection of whistle-blowers, and the creation of a new anti-corruption commission. 

Management of irregularities under shared management 
Adoption  of  a  regulation  on  the  administration  of  irregularities  involving  EU  funds  under  shared 
management. 

Reason for reporting: the regulation governs how irregularities are administered. It sets out what to 
enter  in  the  register  of  reports  and  identified  irregularities  that  affect  EU  funds  under  shared 
management and funds allocated under the Strategic Plan for Agriculture and Rural Development, the 
procedure for carrying out checks to identify irregularities, and how to report these. The procedures 
for the administration of irregularities include registering reports of irregularities, carrying out checks 
to identify or confirm the absence of irregularities, etc. 

1st anti-fraud measure taken by BG in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Decree 
10/08/2023 * 

New 
Legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal  

Area  

Scope  

Competences; 
Powers 

Fraud 
definition; 
AFCOS; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds 

Reason / 
expected 
result  

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

Prevention 

Detection 

* Legislative Act – reference: Council of Ministers Decree No 111 of 10 August 2023. 

About the legislative measure: the regulation is an important part of the legal framework for combating offences affecting 
the EU’s financial interests. 

17 

 
 
 
 
 
Protection of whistle-blowers 
Adoption  of  a  measure  to  protect  individuals  who  report  or  publicly  disclose  information  on 
infringements in order to regulate the conditions, procedure and measures to protect individuals in 
the public and private sectors who report or publicly disclose information on breaches of Bulgarian or 
EU law and to transpose Directive (EU) 2019/1937 of the European Parliament and of the Council of 
23 October 2019 on the protection of persons who report breaches of EU law. 

Reason for reporting: the Act transposes into Bulgarian law Directive (EU) 2019/1937 on the protection 
of  persons  who  report  breaches  of  EU  law.  It  provides  protection  for  individuals  who  report 
irregularities in both the public and private sectors. Reporting is a constitutional possibility provided 
for in a number of legislative acts at national and European level. 

2nd anti-fraud measure taken by BG in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Law/Act 
02/02/2023*  

New 
Legislation  

Nature of the 
measure and 
sector 
concerned  

Horizontal 

Reason / 
expected 
result  

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

Area  

Scope  

Competences; 
Powers; 
Definition of a 
specific topic 

Public 
procurement; 
Financial 
crime 
(including 
money 
laundering); 
Fraud 
definition; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds 

Prevention 

Detection 

* Legislative Act – reference: Act on the protection of individuals who report or publicly disclose information on 
infringements, published in State Gazette (SG) No 11 of 2.2.2023, in force as of 4.5.2023. 

About this legislative measure: the main objective of the Act is to ensure protection for individuals in the public and private 
sectors who report or publicly disclose information on breaches of Bulgarian or EU law that have come to their attention 
during or in connection with their work or in the performance of their duties. The obliged entities under this Act are all 
employers in the public sector and employers in the private sector designated in the Act. 

18 

 
 
 
 
 
Creation of a new Anti-Corruption Commission  
The Anti-Corruption Act provides for the creation of a brand new anti-corruption commission to deal 
with  the  detection  and  investigation  of  a  range  of  corruption  offences  by  persons  in  senior  public 
positions,  the  identification  of  conflicts  of  interest,  the  verification  of  incompatibilities,  the 
identification of inconsistencies in the declared assets of persons in senior public positions, and the 
prevention of corruption. 

Entirely new categories of persons in public positions or entrusted with public spending have been 
added. Certain categories of persons in systems with a high risk of corruption have also been included. 
A new unitary and independent anti-corruption commission has been established. Relations between 
the new commission and the other competent institutions have been clearly regulated. The range of 
declared circumstances has been widened and the rules  on  declarations  have been changed. Asset 
verification  has  been  introduced  for  persons  in  senior  public  positions.  The  framework  has  been 
improved with regard to conflicts of interest. 

3rd anti-fraud measure taken by BG in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Law/Act 
06/10/2023*  

New 
Legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Area  

Scope  

Competences; 
Powers 

Conflict of 
interest; Fraud 
definition; 
Other** 

Reason / 
expected 
result  

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

Investigation 
and 
prosecution 

*Legislative Act – reference: Anti-Corruption Act, published in SG No 84 of 6/10/2023. 

** Verification of declarations of assets and interests of persons in public positions. 

About the legislative measure: the Act regulates four key strands of Bulgaria’s anti-corruption activities to be implemented 
by the new central administrative body – the Anti-Corruption Commission – and its agencies. In order of priority, these are: 
investigative  functions  within  the  meaning  of  the  Code  of  Criminal  Procedure  in  pre-trial  proceedings  initiated  by  the 
prosecutor’s office for serious corruption offences; proceedings for the identification of conflicts of interest; the declaration 
and verification of incompatibilities, assets and interests; and the prevention of corruption. 

19 

 
 
 
 
 
2.4. Croatia  

Croatia reported three measures implemented in 2023: two addressing shared management; the 
other involving the Recovery and Resilience Facility. 

IT tool for submitting applications and control of EU projects 
The introduction of an IT tool for submitting applications and control of EU projects financed by the 
European Maritime, Fisheries and Aquaculture Fund (the FISHNET system). 

The IT tool was introduced with the aim of digitalising the overall implementation of the European 
Maritime,  Fisheries  and  Aquaculture  Fund  in  Croatia  (submission  of  applications  by  beneficiaries, 
checking of applications, monitoring and reporting) and improving the effectiveness of the monitoring 
system in terms of using the tool. 

Reason for reporting: the introduction of the tool also improves the monitoring system and reduces 
the risk of fraud, as the tool will be automatically linked to national databases. 

1st anti-fraud measure taken by HR in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
01/01/2023 

New measure 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Fisheries 

Area  

Scope  

Shared 
management 
and control of 
EU funds 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Web 
reporting/ 
Hotline; 
Structured 
cooperation 
with law 
enforcement 

Reason / 
expected 
result  

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

Prevention 

Detection 

20 

 
 
 
 
 
Work guidelines for monitoring the implementation of the National Recovery and Resilience 
Plan (NRRP) 
With the aim of improving the procedures to check for potential conflicts of interest and uniform action 
by  bodies  in  the  system  for  managing  and  monitoring  the  implementation  of  activities  under  the 
National Recovery and Resilience Plan (NRRP) 2021-2026, the body responsible for coordinating the 
monitoring  of  NRRP  implementation  devised  working  guidelines,  which  it  distributed  to  all 
administration bodies in Croatia responsible for the NRRP component/sub-component as well as to 
NRRP implementing bodies. 

The  guidelines  include  an  overview  of  the  actions  to  be  taken  systematically  when  checking 
procurement procedures carried out within projects funded under the NRRP 2021-2026. 

Croatia’s administration bodies responsible for the NRRP component/sub-component and the NRRP 
implementing bodies are required to forward the guidelines to project beneficiaries in order to ensure 
that all beneficiaries act harmoniously, reducing the risk of subsequently identifying irregularities and 
financial corrections. 

2nd anti-fraud measure taken by HR in 2023 

Nature of the 
measure and 
sector 
concerned 

Public 
procurement; 
Conflict of 
interest 

Area  

Scope  

Reason / 
expected 
result  

Other* 

Targeting of 
checks; 
Enhanced ex 
ante controls 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
09/11/2023  

Update –
Sectoral: 
Expenditure - 
Recovery and 
Resilience 
Facility 

Detection 

* Checks and controls related to the eligibility of expenditure. 

21 

 
 
 
 
 
OLAF training in preventing and detecting irregularities and fraud 
Croatia’s AFCOS unit is in charge of areas such as organising training in protecting the EU’s financial 
interests for the bodies forming part of the Anti-Fraud Coordination System (AFCOS). 

Croatia’s  management  and  control  system  bodies  expressed  a  strong  desire  for  specific  training  in 
preventing and detecting irregularities and fraud, with the emphasis on experiences in other Member 
States and cooperation with OLAF. Croatia’s AFCOS unit duly asked OLAF to organise online training in 
order to present its experiences of administrative investigations. 

OLAF welcomed the Croatian request and, on 4 October 2023, representatives of OLAF held an online 
training session attended by 311 representatives of Croatia’s Anti-Fraud Coordination System.  

Reason  for  reporting:  the online  training  session  covered  topics  such  as  general  information  about 
OLAF,  the  selection  process  and  the  role  within  it  of  the  national  authorities,  the  life  cycle  of  the 
investigation process, the issue of conflict of interest and double funding (including case studies), and 
best practices for fraud prevention within the EU funds. 

Croatia’s AFCOS bodies were grateful to have an opportunity to hear about OLAF and its investigative 
experiences from OLAF experts, and they rated the online training session as excellent. 

3rd anti-fraud measure taken by HR in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Single  

Operational 
04/10/2023  

New measure   Horizontal 

Risk indicators 

Conflict of 
interest; 
Shared 
management 
and control of 
EU funds 

Prevention 

Detection 

Investigation 
and 
prosecution 

Reason / 
expected 
result  

Enhanced 
coordination; 
Enhanced 
cooperation; 
Enhanced 
information 
flow; 
Enhanced ex 
ante controls; 
Enhanced ex 
post controls 

22 

 
 
 
 
 
2.5. Cyprus  

Of the three measures reported by Cyprus for 2023, two were legislative and one was administrative. 
They covered the establishment of a national coordinating body for combating fraud affecting the 
EU’s financial interests, monitoring the implementation of the National Recovery and Resilience Plan, 
and implementing legislation known as the ‘Lobbying Law’. 

Establishment of the national coordinating body for combating fraud against the EU’s 
financial interests  
Draft law entitled ‘National Coordinating Body for combating fraud against the financial interests of 
the European Union’. The draft law was drawn up for the purposes of implementing Regulations (EC) 
2185/96, (EU) 883/2013, (EU) 2018/1046 and (EU) 2021/1060. The draft law contains provisions on 
the  functions  of  the  coordinating  body  (and  its  appointed  members  and  observers)  and  its 
responsibilities  and  powers.  The  Council  of  Ministers  approved  the  draft  law  on  18 May  2023  and 
submitted it to the House of Representatives for adoption. 

The draft law establishes the already established national coordinating body on the basis of Decisions 
of the Council of Ministers No 56.370 of 12 September 2002 and No 61.895 of 21 April 2005, with a 
view to protecting the EU’s financial interests against fraud and other irregularities. 

1st anti-fraud measure taken by CY in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Law/Act 
13/02/2024* 

New 
legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Area  

Scope  

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

Public 
procurement; 
Conflict of 
interest; Fraud 
definition; 
AFCOS; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds 

Reason / 
expected 
result  

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

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

* Legislative Act – reference: the draft law is awaiting adoption in the House of Representatives. The date of entry into force 
and reference number will be attributed by the vote. 

** 

* Criminal sanctions 

(a) new 

(b) less 

(c) more 

About the legislative measure: it is designed to regulate cooperation between the Cyprus AFCOS and OLAF and provide office 
staff with the support they need to perform their tasks effectively: preventive measures in cooperation with other competent 
23 

 
 
 
 
 
 
 
 
 
 
 
authorities to preserve evidence; access to information held by the Central Bank of Cyprus; the power to carry out on-the-spot 
checks on premises, together with OLAF; the establishment of a criminal offence in the event of failure to supply or destroying 
or falsifying data; and steps for reporting irregularities.  

Guidelines on protection of the EU’s financial interests in the context of implementation of 
the National Recovery and Resilience Plan 
The  Council  of  Ministers  approved  the  guidelines  on  protecting  the  EU’s  financial  interests  in  the 
context  of  implementing  Cyprus’s  Recovery  and  Resilience  Plan  (RRP),  developing  a  policy  and 
methodology for assessing the risk of fraud, and developing and implementing action plans to combat 
fraud in line with the relevant EU guidelines. 

A new relevant chapter and specific milestone was agreed with the EU, which had to be achieved in 
order to be able to submit the second payment request for the RRP. The new chapter and milestone 
aimed  to  ensure  that  the  control  framework  of  the  Cyprus  RRP  prevents,  detects  and  corrects 
corruption, fraud and conflicts of interest when using the facility’s resources, as well as the existence 
of arrangements to effectively address double funding under the RRF Regulation and other EU funding 
instruments. 

The RA decision will designate the competent authorities. 

Reason for reporting: further strengthening of the SEA was deemed necessary following a system audit 
carried out by the EU, where weaknesses were identified. The guidelines concern the specification and 
analytical mapping of the verification procedures carried out under the LPIS monitoring and control 
system,  and  aim  to  ensure  the  protection  of  the  EU’s  financial  interests,  focusing  on  preventing, 
detecting and correcting risks of fraud, corruption and conflicts of interest, as well as avoiding double 
funding from the RRF and other implemented EU programmes.. 

2nd anti-fraud measure taken by CY in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package 

New measure  

Administrative 
– Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manual– 
07/12/2023 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Recovery and 
Resilience 

Organisational   New measure  

Area  

Scope  

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

Public 
procurement; 
Conflict of 
interest; Fraud 
definition; 
AFCOS; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds 

Reason / 
expected 
result  

To validate or 
consolidate 
existing rules; 
The 
improvement 
existing 
measure; 
Cross-cutting 
measure, 
multi-agency 
measure/ 
Measure with 
impact on 
various 
bodies* 

Competence; 
Inter- agency 
cooperation 

Created 
resources 

24 

 
 
Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

* The decision of the Council of Ministers approving the guidelines and the revision of the fraud risk assessment procedure 
denotes the authorities that will apply the new procedures as well as the obligations of the bodies involved in the 
implementation of the National Recovery and Resilience Plan. 

Implementation of the Law on Transparency in Public Decisions and Related Matters 
(‘Lobbying Law’) 
In  2023,  the  2022  Law  on  Transparency  in  Public  Decisions  and  Related  Matters  (Law  20  (I)/2022) 
(‘Lobbying Law’) was gradually implemented; regulations regarding RAA 118/2023 on Transparency in 
Public  Decisions  and  Related  Matters  were  also  adopted  in  2023.  The  competent  authority  for  the 
purposes  of  this  Law,  based  on  Article  4,  is  the  Independent  Anti-Corruption  Authority.  The  Law 
provides for the entry in a register of persons who are involved in public decision-making processes 
known  by  the  international  term  ‘lobbyists-billers’,  as  well  as  when  a  person  is  removed  from  the 
register (Articles 7-14), provides for the rights and obligations of such persons (Articles 15-19), and for 
offences and penalties and the imposition of an administrative fine (Articles 20-25). The Independent 
Anti-Corruption Authority has issued a code of conduct for representatives of special interest groups 
who are entered in the register. 

Reason  for  reporting:  the  provisions  of  the  Law  promote  transparency  and  accountability,  with  an 
obligation to enter in the register every representative of a special interest group who intends to be 
involved  in  a  public  decision  process  before  any  such  activity  begins.  The  relevant  provisions  also 
regulate conflicts of interest and incompatibility. The purpose of the code is to formulate/regulate a 
framework  of  professional  standards  and  good  practices  for  the  representatives  of  special  interest 
groups who are listed in the register and to that end undertake to do so in writing.. 

3rd anti-fraud measure taken by CY in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package 

Legislative – 
Law/Act* 
13/04/2023 

New 
legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

New measure  

Administrative 
- Code of 
Conduct 

Area  

Scope  

Conflict of 
interest; 
Other** 

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

Monitoring/ 
desk checks; 
Other*** 

Reason / 
expected 
result  

To validate or 
consolidate 
existing rules 

To validate or 
consolidate 
existing rules; 
the 
improvement 
of existing 
measures 

25 

 
 
 
Prevention 

Detection 

Recovery 
and 
sanction 

*Legislative Act type: RAA 118/2023 

**Regularity and transparency measure 

*** The purpose of the code of conduct is to formulate a framework of professional standards and good practices for the 
representatives of special interest groups entered in the register. MACA issued an explanatory note on the application 
procedure for entries in the EGE register. 

About the legislative measure: the purpose of the regulations is to determine (a) the type of register of entries and (b) the 
procedures for collecting, processing, using, publishing, accessing, maintaining and deleting information and personal data 
for the purposes of the Law. The purpose of the code of conduct is to formulate/regulate a framework of professional 
standards and good practices for the representatives of special interest groups entered in the register. MACA issued an 
explanatory note on the application procedure for entries in the EGE register. 

26 

 
 
 
 
2.6. Czechia 

The three measures reported by Czechia in 2023 concerned the protection of whistle-blowers and 
the fight against VAT fraud as well as corruption and fraud within EU funds. 

Whistle-blower Protection Act 
On 1 August 2023, Act No 171/2023 Sb., on Whistle-blower Protection and the Act amending certain 
acts in connection with the adoption of the Whistle-blower Protection Act, came into force. 

Reason for reporting: the purpose of this legislation is to provide a means for employees in the private 
and  public  sectors  to  report  wrongdoing  of  which  they  become  aware  in  connection  with  their 
employment  or  service.  Reporting  also  covers  infringements  in  the  case  of  protection  of  the  EU’s 
financial interests. 

1st anti-fraud measure taken by CZ in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Law/Act 
20/06/2023 

New 
legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Reason / 
expected 
result  

To enforce the 
rules in line 
with 
developments 
in EU law 

Area  

Scope  

Whistle-
blower; 

Competences; 
Powers; 
Definition of a 
specific topic; 
Recovery; 
Financial 
penalties; 
Other; 
Administrative 
penalties; 
Criminal 
sanctions** 

Prevention 

Detection 

Investigation 
and 
prosecution 

*Legislative Act – reference: 171/2023 Sb., 172/2023 Sb. 

 ** 

* Criminal sanctions 

a) new 

b) less 

c) more 

About the legislative measure: the Whistle-blower Protection Act and the related amending Act transpose into Czech law 
Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons 
who report breaches of EU law. 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fight against VAT fraud 
A unified interpretative practice for the financial, police and judicial authorities (EPPO) in sanctioning 
VAT fraud related to the concealment of actual purchasers of goods. 

This operational measure significantly reduced MTIC fraud related to imports of goods released for 
free circulation in Czechia.. 

2nd anti-fraud measure taken by CZ in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational - 
28/02/2023 

Update 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue - Tax 
fraud 

Area  

Scope  

Structured 
cooperation 
with judicial 
authorities 

Financial 
crime 
(including 
money 
laundering); 
Organised 
crime 

Reason / 
expected 
result  

Enhanced 
cooperation; 
Enhanced 
information 
flow 

Prevention 

Detection 

Investigation 
and 
prosecution 

28 

 
 
 
 
 
Preventing corruption and fraud and increasing transparency in the implementation of EU 
funds 
In  the  course  of  2023,  all  methodological  documents  for  the  programming  period  2021–2027 
incorporating  anti-fraud  and  anti-corruption  elements  were  completed.  This  environment  was  also 
assessed and the system confirmed as functional and sufficiently robust. 

The measure represents a pillar of the fight against anti-corruption resistance within the framework of 
the implementation of EU funds in Czechia. Methodological documents form the basic framework for 
the  implementation  of  EU  funds;  the  inclusion  of  elements  preventing  corruption  and  fraud  and 
increasing the transparency of processes provides the basis of proper implementation. 

3rd anti-fraud measure taken by CZ in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational - 
26/07/2023 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Fisheries & 
Cohesion 
policy 

Area  

Scope  

Other* 

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

Reason / 
expected 
result  

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

Prevention 

* Methodological documents within the methodological environment for the period 2021–2027. 

29 

 
 
 
 
 
2.7. Denmark  

Two  of  the  three  measures  reported  by  Denmark  relate  to  anti-fraud  strategies:  one  covering  the 
National  Recovery  and  Resilience  Plan;  the  other,  fisheries  policy.  The  third  measure  concerns  the 
introduction of a new IT tool for the management of cohesion policy payments. 

Anti-fraud and anti-corruption strategy for the National Recovery and Resilience Plan 
Denmark  adopted  an  anti-fraud  and  anti-corruption  strategy  for  officials  working  with  the  Danish 
Recovery  and  Resilience  Plan.  The  strategy  contains  policies  to  prevent  and  counteract  serious 
irregularities  in  connection  with  the  administration  and  receipt  of  funds  from  the  Danish  RRP.  The 
policies were developed in accordance with a fraud risk assessment and effective and proportionate 
anti-fraud measures and Regulation (EU) 2021/241, with the aim of protecting the financial interests 
of the EU. 

The measure is important for ensuring that possible fraud can be prevented/detected/corrected. The 
strategy sets out several measures and apportions responsibilities so that Danish officials working with 
the RRP know how to act in cases of fraud. 

1st anti-fraud measure taken by DK in 2023 

Single/ 
package  

Type  

New or 
amendment  

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

New measure   Horizontal  

Single  

Administrative 
– Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Anti-fraud or 
anti-
corruption 
strategy 

Eligibility 
criteria; 
Management 
of funds; 
Monitoring/ 
desk checks; 
Irregularities 
reporting 

Cross-cutting 
measure, 
Multi-agency 
measure/ 
Measure with 
impact on 
various 
bodies* 

Prevention 

Detection 

Investigation 
and 
prosecution 

* The measure is ‘cross-cutting’ in the sense that multiple bodies (all of them responsible for funds from the Danish RRP) are 
concerned by the anti-fraud and anti-corruption strategy. 

30 

 
 
 
 
 
Digitalisation of the management of EU funds 
Automatic checks in ‘e-indkomst’, an automatic process that records if payments have been made to 
the persons registered/included in the project reporting used to seek reimbursement. The system is 
expected to be fully incorporated during 2024. 

This system makes it easier to detect if a payment has taken place or not. 

2nd anti-fraud measure taken by DK in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational – 
01/05/2024 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Cohesion 
policy 

Area  

Scope  

Other* 

IT tools (‘IT 
data feeding’, 
‘Other IT’) 

Reason / 
expected 
result  

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

Detection 

* Integrity and transparency measures, anti-fraud strategy. 

Strategy and guidelines for fraud detection in the area of fisheries 
In  2023,  the  Danish  Fisheries  Agency  updated  its  administrative  guidelines  and  strategy  for  the 
detection of fraud. The relevant staff were duly notified. 

Reason  for  reporting:  the  Danish  Fisheries  Agency  found  it  relevant  to  update  its  guidelines  and 
strategy for detecting fraud. 

3rd anti-fraud measure taken by DK in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

Organisational 
– 02/10/2023 

Update 

Area  

Scope  

Reason / 
expected 
result  

Competence  

Other* 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Fisheries 

Prevention 

Detection 

31 

 
 
 
 
 
* Strengthened competences within existing resources. 

32 

 
 
 
2.8. Estonia 

The three measures reported by Estonia concern the strengthening of the Estonian Police and Border 
Force’s  capacity  to  investigate  corruption  and  economic  crimes,  the  launch  of  a  new  information 
system in the area of Customs, and improvements to the national e-procurement platform. 

Strengthening the investigative capacity into corruption and economic crimes of the Estonian 
Police and Border Guard 
Since March 2023, the Estonian Police and Border Force has been allocated resources to recruit 10 
police officers to investigate corruption and economic crimes. 

The Estonian Police and Border Force now has an enhanced capability to investigate criminal cases 
against EU funds and corruption. 

1st anti-fraud measure taken by EE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Single  

Organisational 
01/03/2023 

Update  

Horizontal 

Financial 
crime 
(including 
money 
laundering); 
Organised 
crime; Conflict 
of interest 

Reorganisation 
of existing 
bodies; 
Competence; 
General 
training; Fraud 
awareness 
training 

Reason / 
expected 
result  

Increased 
resources 

Prevention 

Detection 

Investigation 
and 
prosecution 

33 

 
 
 
 
 
 
New information systems for Customs clearance 
The  systems  are  designed  to  bring  export  and  transit  Customs  formalities  into  line  with  the 
requirements  of  the  EU  Customs  Code,  exercise  more  effective  supervision  over  the  movement  of 
goods, and protect safety and security. 

2nd anti-fraud measure taken by EE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
02/10/2023 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – 
Customs 

Area  

Scope  

Reason / 
expected 
result  

Customs/TOR 
/illicit trade 

IT tools (‘IT 
data feeding’, 
‘Other IT’) 

Enhanced 
information 
flow 

Prevention 

Detection 

Additions to the national e-procurement platform  
The following additions were launched in the national e-procurement platform (Public Procurement 
Register: https://riigihanked.riik.ee) to increase transparency and integrity: 1) financing organisation 
data can be published in contractual details, and 2) it is now mandatory to justify the non-disclosure 
of contractual details. 

3rd anti-fraud measure taken by EE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

Single  

Operational 
12/05/2023 

Update  

Horizontal 

IT tools (‘IT 
data feeding’, 
‘Other IT’) 

Enhanced 
information 
flow 

Public 
procurement; 
Shared 
management 
and control of 
EU funds  

Prevention 

34 

 
 
 
 
 
 
35 

 
 
 
 
2.9. Finland 

Finland reported two measures: one concerning a customs project focused on food fraud; and another 
relating to anti-fraud training in the area of cohesion policy. 

Customs food fraud project to fight the shadow economy and food fraud 
The fight  against the  shadow economy and food fraud,  part of Customs’ fight against  fraud,  brings 
together a wide range of measures. The food fraud project concerned, inter alia, possible counterfeit 
and  unsafe  food,  legislative  measures,  any  related  financial  crimes,  and  preventing,  detecting  and 
combating crime. The project’s aims included detecting imports of food from non-EU countries that 
circumvented, for example, import taxes and levies, such as customs duties. 

For its part, Finnish Customs communicated about food fraud and was involved in raising awareness 
of  the  shadow  economy  and  the  fight  against  fraud,  including  through  expert  blogs  and  on  social 
media. Finnish Customs also presented the food fraud project at the EU Customs Chemists seminar 
held in Berlin in 2023. 

The  project  relates  to  the  EU’s  traditional  own  resources,  i.e.  the  fight  against  customs  fraud.  The 
project  examined  fraud  in  the  food  sector.  Among  other  things,  it  defined  fraud  in  terms  of  the 
workings  and legislation of Finnish Customs and the Finnish Food Authority. Alongside  food safety, 
another essential project component was the illegal trade in food and the control of levies and taxes 
on  imports  from  non-EU  countries.  The  project  also  took  account  of  the  involvement  of  organised 
crime in international food fraud. 

1st anti-fraud measure taken by FI in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package 

New measure  

Administrative 
– 
recommendati
on 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – 
Customs 

Organisational 
31/12/2023 

New measure  

Operational – 
31/12/2023 

New measure 

Area  

Scope  

Organised 
crime; Fraud 
definition; 
Customs/ToR/
illicit trade; 
Shared 
management 
and control of 
EU funds 

Monitoring/ 
desk checks; 
On-the-spot 
checks; 
Other*  

Inter- agency 
cooperation; 
Fraud 
awareness 
trainings; 
Other*** 

Web 
reporting/ 
Hotline; 
Increased 
number of 
checks; 
Structured 
cooperation 
with law 
enforcement 

Reason / 
expected 
result  

Cross-cutting 
measure, 
Multi-agency 
measure/ 
Measure with 
impact on 
various 
bodies** 

Increased 
resources 

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

36 

 
 
Prevention 

Detection 

Investigation 
and 
prosecution 

* Together with the Finnish Food Authority and the municipal food control authorities, Finnish Customs carried out a pilot 
project for intensive food checks. The project included documentary checks by Customs and the Finnish Food Authority, as 
well as physical checks of foodstuffs and investigations conducted by the Customs Laboratory. The project described and 
examined the processes for detecting and investigating food fraud and the need for these processes to be developed and 
enhanced by Customs and the Finnish Food Authority. 

** The project was a pilot project carried out jointly by Customs and the Finnish Food Authority. The project was 
implemented as part of the strategy for 2020-2023 to combat the shadow economy and financial crime. 

*** The project also made provision for additional international cooperation to detect and combat food fraud. The project 
developed the necessary cooperation models between the Finnish Food Authority and Customs. It also implemented official 
training programmes to identify, monitor and combat food fraud in different parts of Finland. A total of around 800 
participants from Customs, the police, the public prosecutor’s office and other key cooperation authorities participated in 
the training sessions. 

Anti-fraud training for the EU’s regional and structural policy programme 
In its capacity as the managing authority for the regional and structural policy programme in Finland, 
in 2023 the Ministry of Employment and the Economy organised two anti-fraud training sessions in 
fraud and corruption from different perspectives. These were specifically targeted at the intermediate 
bodies responsible for granting and controlling aid. The training sessions were organised remotely to 
achieve the widest possible coverage. The training activities were prepared in cooperation with the 
AFCOS national contact point and featured presentations by investigators and experts from different 
authorities,  including  the  EU  institutions  (namely  OLAF  and  the  EPPO).  The  training  sessions  will 
continue in 2024. 

The aim of the training sessions is to make the authorities managing EU funds more aware of fraud 
and thus improve the quality of controls. 

2nd anti-fraud measure taken by FI in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single 

Organisational 
– 06/11/2023 

New measure 

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Cohesion 
policy 

Shared 
management 
and control of 
EU funds 

General 
training; Fraud 
awareness 
training 

Reason / 
expected 
result  

Neutral on 
resources 

37 

 
 
 
Prevention 

Detection 

2.10. 

France  

France reported the setting-up of an inter-ministerial monitoring unit to combat public aid fraud, a 
working group to analyse emerging fraud in relation to the RRF, and the establishment of a system of 
financial  liability  for  public  administrators  and  the  development  of  relations  between  the  judicial 
authority and the financial courts 

Establishment of an inter-ministerial monitoring unit to combat public aid fraud 
The  task  of  this  monitoring  unit  is  to  detect  fraud  affecting  public  finances  by  cross-checking  and 
mobilising all the administrative and judicial actors concerned, and to prosecute such fraud by defining 
joint action strategies mobilising all the tools for administrative and judicial measures and penalties. It 
was created by Decree 2023-663 of 26 July 2023. 

1st anti-fraud measure taken by FR in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Package 

Organisational 
– 05/12/2023 

New measure   Horizontal 

Operational 
05/12/2023 

New measure  

Financial 
crime 
(including 
money 
laundering); 
Organised 
crime; Fraud 
definition; 
Other* 

Reorganisation 
of existing 
bodies; 
Competence; 
Inter-agency 
cooperation; 
Other** 

Other*** 

Reason / 
expected 
result  

Neutral on 
resources 

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

38 

 
 
 
Prevention 

Detection 

Investigation 
and 
prosecution 

*The monitoring unit will bring together all the responsible administrative departments of the Ministry of Economic Affairs 
and  Finance,  as  well  as  the  directorates  of  the  Ministry  of  the  Interior  and  the  overseas  departments  concerned,  and 
specialised judicial investigation services. It will also involve paying agencies and judicial  bodies. Its focus will be on initial 
efforts on energy renovation, which is part of the National Recovery and Resilience Plan. 

** By Decree No 2023-663 of 26 July 2023 the monitoring unit was attached to MICAF. 

*** The monitoring unit is tasked with mapping public aid schemes, helping to assess their vulnerability, sharing best practices, 
supporting the deployment of filters and blocking mechanisms before undue aid is paid, alerting all the government services 
concerned about identified fraud risks and patterns, enabling government services concerned to assess them, and encouraging 
inter-departmental support in relation to fraud. 

Working group on emerging fraud under RRF funds 
Under action 3.2.1 of the French National Anti-Fraud Strategy, a working group was set up to address 
emerging fraud under the Recovery and Resilience Facility. 

France’s Inter-ministerial Anti-Fraud Coordination Office (MICAF) runs this working group, which brings 
together the national actors responsible for the funds made available by the EU under the Recovery 
and Resilience Facility (RRF). Its aim is to allow regular exchanges between participants for the purpose 
of identifying fraud risks specifically linked to the allocation of these funds. 

2nd anti-fraud measure taken by FR in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Package 

Organisational 
– 21/03/2023 

Update  

Horizontal 

Operational  

New measure  

Organised 
Crime; Fraud 
definition; 
AFCOS; Anti-
fraud or anti-
corruption 
strategy; 
Other* 

Inter-agency 
cooperation; 
Other** 

Flagging 
practice; 
Structured 
cooperation 
with judicial 
authorities 

Prevention 

Detection 

Investigation 
and 
prosecution 

Reason / 
expected 
result  

Neutral on 
resources 

Enhanced 
coordination; 
Enhanced 
cooperation; 
Enhanced 
information 
flow;  

39 

 
 
 
 
*This working group brings together all the actors involved in the management of the funds made available to the EU under 
the RRF and used by France under its National Recovery and Resilience Plan (NRRP). 

** European Delegated Prosecutors in France, laying down the practical arrangements for transmitting these alerts 
(conditions of funds, form, method of transmission) and the ways of responding to alerts regarding action taken by the 
European Public Prosecutor’s Office. 

40 

 
 
 
 
Establishment of a system of financial liability for public administrators and development of 
relations between the judicial authority and the financial courts  
Order  No  2022-408  of  23  March  2022  introduced  a  unified  system  of  financial  liability  for  public 
administrators before France’s Cour des Comptes (Court of Auditors). It replaces the previous regime 
of liability for public accountants and authorising officers. To this end, the Cour des Comptes has set 
up a specific chamber known as the chamber for disputes and established a double level of jurisdiction, 
with the creation of a financial court of appeal, whose decisions may be appealed on a point of law 
before the Conseil d’État (Council of State). 

3rd anti-fraud measure taken by FR in 2023 

Single/ 
package  

Type  

New or 
amendment  

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

Package 

Amendment  

Horizontal 

Update  

Legislative - 
Regional law/ 
decree/ order 
- 23/03/2023*  

Administrative
-Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Financial 
penalties 

To clarify or 
consolidate 
existing rules 

Irregularities 
reporting  

To clarify or 
consolidate 
existing rules 

Public 
procurement; 
Financial 
crime 
(including 
money 
laundering); 
Corruption**; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

Detection 

Investigation 
and 
prosecution 

*About the legislative measure: a referral of this kind appears to be a promising alternative in proceedings where the 
characterisation of the intentional element is difficult to establish or where criminal proceedings appear inappropriate. In 
cases of fraud or impairment of probity, such referrals to the Court of Justice may also seek to establish the liability of 
administrators who, without being criminally liable directly for the fraud or impairment of the probity concerned, facilitated 
the commissioning of the fraud, in particular through culpable failings. 
Legislative Act – reference: Ordinance No°2022-408 of 23 March 2022, entry into force on 1 January 2023 
** Corruption within public procurement: in the public sector (including the political sphere); measures taken to prevent 
corruption among staff, including management.  

41 

 
 
 
 
 
2.11. 

Germany 

As  Germany  is  a  federal  state,  anti-fraud  measures  are  often  taken  at  regional  level.  Three  such 
measures were reported, involving Berlin, Saxony and Schleswig-Holstein. 

Regional fraud risk assessment tool: Berlin 
For  the  Berlin  ERDF  programme  over  the  funding  period  2021-2027,  the  ERDF  managing  authority 
assessed the risk of fraud for all programme actions in cooperation with the intermediate bodies. The 
fraud risk assessment tool for the ESI funds, developed and recommended by the Commission, was 
used and adapted to Berlin’s circumstances. 

The  legal  basis  for  the  deployment  of  this  tool  is  Article 74(1)(c)  of  Regulation  (EU)  2021/1060  – 
Implementation of effective and proportionate anti-fraud measures. 

1st anti-fraud measure taken by DE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
06/10/2023 

Update  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure - 
Cohesion 
policy 

Area  

Scope  

Reason / 
expected 
result  

Risk indicators 

Targeting of 
checks 

Shared 
management 
and control of 
EU funds 

Prevention 

42 

 
 
 
 
 
 
Regional fraud risk assessment tool: Saxony 
Implementation by the MA ERDF/JTF – Saxony of the fraud risk self-assessment recommended in the 
Commission’s guidelines  at  the  level of OP operations  and  specifically focusing on the fight  against 
fraud and corruption. 

2nd anti-fraud measure taken by DE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
31/03/2023 

Update  

Nature of the 
measure and 
sector 
concerned  

Sectoral: 
Expenditure – 
Cohesion 
policy 

Area  

Scope  

Reason / 
expected 
result  

Other*** 

Other**** 

Public 
procurement; 
Corruption*; 
Conflict of 
interest; 
Other** 

Prevention 

Detection 

*Within the public sector (including the political sphere) – Measures to improve control and audit effectiveness, e.g. smart IT 
tools, database, risk assessment, red flags, warning, audit and other mechanisms. 

** see 1.a 

Application and authorisation; 
Implementation and audit of operations/clearing of expenditure, payments and certificates; 
Procurement via the MA/intermediate body. 

*** Implementation by the MA ERDF/JTF of the fraud risk self-assessment recommended in the Commission’s guidelines at 
the level of OP operations. 

**** The fraud risk self-assessment is designed to assess the impact of widespread fraud risks and the likelihood of them 
occurring and, where appropriate, define risk mitigation measures. 

43 

 
 
 
 
 
Regional anti-fraud measures: Schleswig-Holstein  
Since  June  2023,  guidelines  on  anti-corruption  and  anti-fraud  measures  in  the ERDF  programme  in 
Schleswig-Holstein for 2021-2027. 

3rd anti-fraud measure taken by DE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Update  

Administrative 
– Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

Sectoral: 
Expenditure – 
Cohesion 
policy 

Anti-fraud or 
anti-
corruption 
strategy 

Monitoring/ 
desk checks; 
Irregularities 
reporting 

To enhance 
existing 
measure 

Prevention 

44 

 
 
 
 
 
2.12. 

Greece 

Greece reported three measures. The first integrated procedures to prevent and combat fraud within 
the management and control system for cohesion policy; the second concerned the introduction of 
the Arachne IT tool in relation to the common agricultural policy; and the third described the launch 
of an IT platform to gather complaints from the public in the area of customs and tax fraud. 

Integration of fraud prevention and detection within the Greek management and control 
system 
The management  and control system (MCS) for the programming period  2021-2027  relating to  the 
programmes  of  the  European  Regional  Development  Fund  (ERDF),  the  European  Social  Fund  Plus 
(ESF+), the Cohesion Fund (CF), the Just Transition Fund (JTF) and the European Maritime, Fisheries 
and Aquaculture Fund (EMFAF), was submitted on 30 June 2023. 

Preventing and combating fraud has been fully integrated into the MCS. It will be implemented via 
clear procedures, the operation of an internal cooperation network involving the managing authorities 
(MAs)  and  the  Special  Service  for  Institutional  Support  and  Information  Systems  (EYTHYPS), 
cooperation with the Financial Audit Committee (EDEL), the Anti-Fraud Coordination Service (AFCOS), 
as well as national bodies and the European Commission, the use of information systems, training of 
the entities involved, and continuous improvements. 

1st anti-fraud measure taken by EL in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Update  

Administrative 
-Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Reason / 
expected 
result  

Other** 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Cohesion 
policy and 
Fisheries 

Area  

Scope  

Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

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

Prevention 

* The measure covers a large number of procedures contained in the MCS 2021-2027 manual for the ERDF, ESF+, CF, JTF and 
EMFAF programmes. In addition to the above areas, it therefore also concerns the following: fraud risk assessment; ex ante 
checks on public procurement; all verifications carried out by the programmes’ managing authorities; the imposition of 
financial corrections and recoveries; the examination of indications of fraud; the reporting of suspected fraud; and the 
examination of complaints relating to co-financed projects. 

** The introduction and implementation of procedures for preventing and combating fraud in the MCS 2021-2027 results 
from both the European institutional framework, which establishes the issue of fraud as an obligation for Member States 
and the managing authorities, and the National Anti-Fraud Strategy Action Plan to combat fraud in structural actions. The 
MCS is aimed at the managing authorities and the certifying authority and constitutes the regulatory framework governing 
the implementation of the programmes for 2021-2027. 

45 

 
 
 
Introduction of Arachne in relation to the common agricultural policy 
Use of the Arachne tool by the Financial Audit Committee (EDEL) and the managing authority of the 
Rural Development Programme (RDP) 2014-2022 and the CAP Strategic Plan (SP) 2023-2027. The use 
of  Arachne  in  the  management  of  the  RDP  2014-2022  and  the  CAP  SP  2023-2027  is  expected  to 
strengthen  the  management  and  control  system  and  the  procedures  for  detecting  and  preventing 
fraud  and  irregularities  in  rural  development,  contributing  to  the  protection  of  the  EU’s  financial 
interests. 

Reason for reporting: update in 2023 of the methodology for systematically using the Arachne data 
mining  and  risk  scoring  tool  in  the  context  of  EDEL  audits  of  projects  funded  by  the  Recovery  and 
Resilience Facility, to detect indications of fraud/corruption/conflict of interest. 

In addition, the managing authority of the RDP2014-2022 and the CAP SP 2023-2027 obtained access 
to  the  Arachne  tool  database  and  the  staff  of  the  managing  authority  received  Arachne  technical 
training. 

2nd anti-fraud measure taken by EL in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

Operational 
14/02/2023 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Agriculture; 
Recovery and 
Resilience 
Facility 

Area  

Scope  

Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy  

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Risk 
indicators; 
Increased 
number of 
checks 

Reason / 
expected 
result  

Enhanced 
information 
flow; 
Targeting of 
checks; 
Targeting of 
investigations; 
Enhanced ex 
ante controls; 
Enhanced ex 
post controls 

Prevention 

Detection 

46 

 
 
 
 
 
 
Launch of the ‘Complaints from citizens’ platform of the Independent Authority for Public 
Revenue  
Reason for reporting: the Independent Authority for Public Revenue (IAPR) deployed its ‘Complaints 
from  citizens’  platform  in  2023.  The  platform  can  be  used  by  members  of  the  public  to  submit 
complaints, anonymous or signed, to help expose tax evasion, smuggling or corruption involving IAPR 
officials or services. 

3rd anti-fraud measure taken by EL in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
30/10/2023 

New measure 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – 
Customs and 
Tax fraud 

Area  

Scope  

Whistle-
blowers; 
Customs/TOR/
illicit trade 

Web 
reporting/ 
Hotline; 
Flagging 
practice; 
Increased 
number of 
checks 

Reason / 
expected 
result  

Enhanced 
information 
flow; 
Targeting of 
checks; 
Targeting of 
investigations 

Prevention 

Detection 

Investigation 
and 
prosecution 

47 

 
 
 
 
 
2.13. 

Hungary  

Hungary reported three measures. The first defines the tasks of the Directorate for Internal Audit and 
Integrity (DIAI) in relation to the prevention of conflicts of interest; the second develops cooperation 
between the National Tax and Customs Administration and the DIAI; and the third consists of a plan 
for European Agricultural Guarantee Fund ex post controls and an audit plan. 

Preventing, detecting and correcting cases of conflicts of interest in the management of EU 
funds 
The main tasks of the Directorate for Internal Audit and Integrity (DIAI) include investigating conflicts 
of  interest  within  the  area  of  development  policy  (government  officials,  staff),  identifying  and 
mitigating systemic risks to development policy, and raising integrity awareness through training to 
prevent conflicts of interest and corruption. 

DIAI strengthens the effectiveness of the fraud control and prevention mechanism designed to better 
prevent, detect and correct cases of conflict of interest among staff involved in the management of EU 
funds. It ensures that the integrity awareness of the institutions managing EU funds is reinforced and 
that  cooperation  with  law  enforcement  agencies  is  coordinated  and  streamlined.  DIAI  activities 
contribute effectively to the protection of the EU’s financial interests. 

1st anti-fraud measure taken by HU in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

Amendment  

Legislative – 
Act/Law 
28/09/2023 

Organisational 
01/01/2023 

New measure  

Operational 
13/10/2022 

New measure 
and update 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Agriculture, 
Fisheries, 
Cohesion 
policy, Fund 
for the most 
deprived, 
Migration and 
asylum, and 
Recovery and 
Resilience 
Facility 

Area  

Scope  

Financial 
crime 
(including 
money 
laundering); 
Conflict of 
interest; 
AFCOS; 
Whistle-
blower; Anti-
fraud or anti-
corruption 
strategy 

Other** 

Inter-agency 
cooperation; 
General 
training; Fraud 
awareness 
training; 
Other*** 

Web 
reporting/ 
Hotline; Risk 
indicators; 
Increased 
number of 
checks; 
Structured 
cooperation 
with law 
enforcement; 
Structured 
cooperation 
with judicial 
authorities 

Reason / 
expected 
result  

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

Neutral on 
resources 

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

48 

 
 
Prevention 

Detection 

Investigation 
and 
prosecution 

*About the legislative measure: extension of the authorisation to process data in order to allow DIAI to carry out conflict-of-
interest investigations. 

Legislative Act – reference: Act CXLI of 1997 on the Land Register (in force from 28 September 2023); Act CXXV of the 2018 
Government Administration (in force from 12 May 2023); Act LXVI of 1992 on the Registration of Citizens’ Personal Data and 
Addresses (in force from 1 July 2023); Government Decree No 146/1993 of 26 October 1993 implementing Act LXVI of 1992 
on the Registration of Citizens’ Personal Data and Addresses (in force from 27 June 2023); Government Decrees on 
development policy. 

** Changes to data processing necessary for effective conflict-of-interest investigations. 

*** Single-channel coordination of tasks related to anti-fraud measures by DIAI. 

Risk-based ex post and post-release controls in relation to the European Agricultural 
Guarantee Fund 
The Customs division of the National Tax and Customs Administration acted to issue and implement 
the plan for EAGF ex post controls in 2023-2024 and the post-release checks and audit plan for 2024. 

The preventive effects of organised, centrally coordinated, risk-based EAGF ex post and post-release 
controls  make  a  significant  contribution  to  protecting  the  EU’s  financial  interests  and  to  the  fight 
against fraud. 

2nd anti-fraud measure taken by HU in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

Administrative
*  

New measure  

Operational 
15/04/2023 

Update  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – 
Customs; 
Expenditure – 
Agriculture 

Area  

Scope  

Reason / 
expected 
result  

Customs/TOR/
illicit trade; 
Shared 
management 
and control of 
EU funds 

Investigation 

Other** 

Risk indicators   Targeting of 

checks; 
Enhanced ex 
post controls 

Prevention 

Detection 

*Type of Act for the administrative measure: order 

49 

 
 
 
 
 
** Effectively managing ex post risks for basic Customs procedures and ensuring an adequate level of control. 

50 

 
 
 
Cooperation agreement between the National Tax and Customs Administration and the 
Directorate of Internal Audit and Integrity 
In 2003, the National Tax and Customs Administration (NTCA) and the Directorate of Internal Audit and 
Integrity at the Prime Minister’s Office signed a cooperation agreement. 

Harnessing  the  potential  of  the  agreement  will  enhance  and  accelerate  cooperation.  A  significant 
proportion of the offences detected under the investigative powers of the NTCA fall within the scope 
of budget fraud (including offences affecting budgets or funds managed by or on behalf of the EU), 
making the establishment of a cooperation channel a priority. 

3rd anti-fraud measure taken by HU in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
09/03/2023 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – Tax 
fraud 

Area  

Scope  

Structured 
cooperation 
with law 
enforcement 

Financial 
crime 
(including 
money 
laundering); 
Organised 
crime 

Reason / 
expected 
result  

Enhanced 
coordination; 
Enhanced 
cooperation; 
Enhanced 
information 
flow 

Detection 

Investigation 
and 
prosecution 

51 

 
 
 
 
 
2.14. 

Ireland  

Ireland reported two measures concerning the ESF+ programme and the fight against e-commerce VAT 
fraud. 

Department of Justice anti-fraud and corruption policy 
The Department of Justice is an intermediate body for the administration of ESF+ funding in 2021-2027 

1st anti-fraud measure taken by IE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Organisational 
04/12/2023 

Update  

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

Sectoral: 
Expenditure – 
Cohesion 
policy 

Anti-fraud or 
anti-
corruption 
strategy 

Simplification 
of procedures 

Neutral on 
resources 

Prevention 

52 

 
 
 
 
 
 
Digitalisation of the fight against e-commerce VAT fraud 
EU Central Electronic System of Payment Information (‘CESOP’) used to detect possible e-commerce 
VAT fraud carried out by sellers established in another Member State or in a non-EU country. 

Reason for reporting: information reported to CESOP can facilitate tax authorities in EU Member States 
in their efforts to detect fraudulent business activity and control VAT liabilities.  

2nd anti-fraud measure taken by IE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Law/Act 
01/01/2024* 

New 
legislation  

Nature of the 
measure and 
sector 
concerned  

Sectoral: 
Revenue – Tax 
fraud  

Area  

Scope  

Other** 

Anti-fraud or 
anti-
corruption 
strategy 

Reason / 
expected 
result  

To enforce the 
rules in line 
with 
developments 
in EU law 

Detection 

*About the legislative measure: the legislation imposes record-keeping and reporting obligations on certain payment service 
providers (PSPs) established in the EU. 

Legislation – type of Act: Part 9A of the VAT Consolidation Act 2010, ‘Reporting Obligations of Certain Payment Providers’, 
introduced as of 1 January 2024. 

** Regulation (EU) 2020/283 amending Council Regulation (EU) 904/2010 on administrative cooperation and combatting 
fraud in the field of VAT. The legislation introduces new record-keeping and reporting requirements for EU-established PSPs 
in respect of certain cross-border payments facilitated by the PSP. 

53 

 
 
 
 
2.15. 

Italy 

The three measures reported by Italy concern its Recovery and Resilience Plan. 

General anti-fraud strategy for the implementation of the National Recovery and Resilience 
Plan (NRRP) 
The Anti-Fraud Strategy for the NRRP was prepared and implemented in 2023, and describes the basic 
principles  and  general  measures  of  the  anti-fraud  strategy  that  have  been  adopted  by  the  NRRP 
Inspectorate  General  to  ensure  that  the  provisions  of  Regulation  (EU) 2021/241  regarding  the 
protection of the financial interests of the EU are met in a manner consistent with Article 11 of the 
financing agreement between the European Commission and Italy, in line with the principle of sound 
financial management, which includes the prevention and effective prosecution of fraud. 

1st anti-fraud measure taken by IT in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Update  

Administrative 
Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Recovery and 
Resilience 
Facility 

Area  

Scope  

Reason / 
expected 
result  

Management 
of funds; 
Investigation; 
Irregularities 
reporting; 
Recovery; 
Other*** 

To clarify or 
consolidate 
existing rules; 
To enhance 
existing 
measures; 
Other**** 

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

Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

*Corruption in the public sector 

** With the adoption of the NRRP strategy, the departments responsible for NRRP measures were asked to transpose 
promptly the contents of the new document into their sectoral anti-fraud strategies for the NRRP measures within their 
respective remits. The contents of the document will also be incorporated into the relevant operational manuals for the 
NRRP measures. 

*** The NRRP strategy aims to guide the actions and measures adopted by each administration involved in the 
implementation of the NRRP measures, so as to ensure standardised and effective anti-fraud solutions and practices; in 
particular, these concern the identification and management of abnormal or unlawful activities or behaviour that might 
occur during the implementation of the plan or the various processes/activities throughout the life cycle of a project. 

**** The strategy adopted in RGS Circular No 290465 of 22 December 2023 consolidates the content of the previous version 
of the document, taking account of various factors, including the main legislative developments in this area, experiences 
gained during the first year of implementing the strategy, and the fruitful ongoing cooperation with the competent national 
and EU inspection bodies. 

54 

 
 
 
55 

 
 
 
 
Digitalisation of the management of the RRF 
2023 saw the issuing of the special appendix adopted by RGS Circular No 27 of 15 September 2023, 
entitled  ‘Collecting  data  on  beneficial  ownership  pursuant  to  Article 22(2)(d)  of  Regulation 
(EU) 2021/241  and  notifying  the  FIU  of  suspicious  transactions  made  by  the  public  administration 
pursuant to Article 10 of Legislative Decree No 231/2007’. It supplements the reporting and control 
guidelines  and  defines  the  procedural  steps  that  the  bodies/departments  implementing  NRRP 
measures must put in place using the functionalities available through the ReGiS IT system. 

2nd anti-fraud measure taken by IT in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational – 
15/09/2023 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Recovery and 
Resilience 
Facility 

Reason / 
expected 
result  

Enhanced 
coordination; 
Enhanced 
cooperation; 
Enhanced 
information 
flow; 
Enhanced ex 
ante controls 

Area  

Scope  

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Structured 
cooperation 
with law 
enforcement 

Public 
procurement; 
Financial 
crime 
(including 
money 
laundering); 
Conflict of 
interest; 
Shared 
management 
and control of 
EU funds; 
Other* 

Prevention 

Detection 

* This operational measure aims to improve coordination and cooperation between the various actors involved in the 
implementation of NRRP measures by improving ex ante controls (beneficial owners with potential conflicts of interest) and 
encouraging the flow of information, including notifications of suspicious transactions. 

56 

 
 
 
 
 
Safeguarding the NRRP legislative measures. Prevention and suppression of fraud. 
From a regulatory standpoint, the Guardia di Finanza’s role in safeguarding the NRRP has been further 
enhanced by the changes introduced under Article 1(4)(f)(3) of Decree-Law No 13 of 24 February 2023; 
the  possibility  of  concluding  specific  agreements  with  the  Guardia  di  Finanza,  which  was  already 
provided  to  the  central  government  departments  managing  activities  under  the  plan,  has  been 
extended to the regions, the Autonomous Provinces of Trento and Bolzano, local authorities, and other 
public entities implementing measures laid down in the NRRP. 

3rd anti-fraud measure taken by IT in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Amendment  

Legislative – 
Decree 
24/02/2023 

Nature of the 
measure and 
sector 
concerned  

Sectoral: 
Expenditure – 
Recovery and 
Resilience 
Facility 

Reason / 
expected 
result  

To clarify or 
consolidate 
existing rules 

Area  

Scope  

Competences  

Public 
procurement; 
Conflict of 
interest; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy; 
Other* 

Prevention 

Detection 

* The measure extends the synergies achieved by the Guardia di Finanza at central government level in monitoring 

NRRP funds down to local level, introducing the possibility of concluding memoranda of understanding with the 

regions, local authorities, and other public entities implementing the NRRP. The aim is to strengthen monitoring 

activities, including those to prevent and combat corruption and fraud, and to avoid conflicts of interest and the risk 

of duplicate public funding of activities. 

57 

 
 
 
 
 
2.16. 

Latvia 

Latvia  reported  three  measures.  The  first,  a  cross-cutting  measure,  addresses  anti-corruption;  the 
second focuses on VAT fraud in vehicle trade; the third focuses on public procurement. 

Adoption of the Action Plan to Prevent and Combat Corruption 2023-2025 and the 
Operational Strategy of the Bureau for Preventing and Combating Corruption 2023–2026 
Adoption of the  Corruption Prevention and Combating Action Plan 2023-2025. The  action  plan is a 
continuation of the Guidelines for Preventing and Combating Corruption 2015-2020. The action plan 
continues on the path for preventing and combating corruption previously defined in the guidelines, 
i.e. its main objectives and lines of action, but at the same time it includes a new set of tasks for public 
institutions  to  respond  flexibly  and  adapt  to  current  developments  and  problematic  situations  in 
society and the problems of applying legal provisions. 

Adoption of the Operational Strategy of the Bureau for Combating and Preventing Corruption 2023–
2026 (Approved by the Director of the Bureau for Combating and Preventing Corruption). 

The Bureau for Combating and Preventing Corruption is the national anti-corruption agency that also 
investigates cases of corruption within EU financial interests. Together, the two adopted documents 
can be seen as Latvia’s national anti-corruption strategy. 

1st anti-fraud measure taken by LV in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Package  

Administrative
* 

Update  

Horizontal 

Organisational 
11/04/2023 

Update  

Operational 
11/04/2023 

Update 

Public 
procurement; 
Financial 
crime 
(including 
money 
laundering); 
Corruption**; 
Conflict of 
interest; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy; 
Other*** 

Management 
of funds; 
Monitoring/ 
desk checks; 
Investigation; 
Irregularities 
reporting 

Inter-agency 
cooperation; 
General 
training; Fraud 
awareness 
training; 
Other**** 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Web 
reporting/ 
Hotline; Risk 
indicators; 
Structured 
cooperation 
with law 
enforcement 

Reason / 
expected 
result  

Other***** 

Neutral on 
resources 

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

58 

 
 
Prevention 

Detection 

Investigation 
and 
prosecution 

* Action plan and strategy 

**Corruption in the public sector (including the political sphere) and also the private sector. Measures taken include  

-  Measures addressing transparency in public procurement.  
-  Measures to improve the effectiveness of management of the public procurement.  
-  Measures to prevent corruption amongst personnel, including management.  
-  Measures addressing transparency of companies participating in public procurement.  
-  Measures to improve the effectiveness of control and audit.  

*** Integrity and transparency measures. 

**** Trainings in the investigation of financial crimes, financial analysis and confiscation. 

***** The action plan is a continuation of the guidelines for preventing and combating corruption in the previous period. 
The strategy continues on from the previous strategy covering 2020-2022. 

Fight against VAT fraud in the vehicle trade 
Since  22  March  2023,  Latvia’s  revenue  service,  in  order  to  combat  VAT  fraud,  when  legal  entities 
involve natural persons as intermediaries in the registration of vehicles, can apply a vehicle prohibition 
order  (‘prohibition  on  alienation  of  vehicle’)  for  up  to  30  days  (the  term  can  be  extended  if  an 
inspection is initiated) for an M1 or N1 category vehicle (not older than 5 years and acquired in another 
EU MS and registered for the first time in Latvia) that is registered as owned by a natural person. During 
the registration procedure, the applicant must indicate the country, the date of acquisition, the type 
of payment, the amount of the transaction, and the seller, and attach a document certifying the change 
of ownership rights and a confirmation of payment. The measure is designed to combat fraud involving 
VAT (part of the EU’s financial interests). 

2nd anti-fraud measure taken by LV in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Amendment  

Legislative – 
Law/Act 
08/03/2023* 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Tax Fraud  

Area  

Scope  

Reason / 
expected 
result  

Fraud 
definition 

Competences; 
Powers  

To remedy 
flaws  

Prevention 

59 

 
 
 
 
* In order to combat VAT fraud, when legal entities involve natural persons as intermediaries in the registration of vehicles, 
Latvia’s revenue service can apply a vehicle prohibition order (‘prohibition on alienation of vehicle‘) for up to 30 days (the 
term can be extended if an inspection is initiated). 
Legislative Act – reference: amendments to the Road Traffic Law, 08.03.2023. likums/LV, 57A, 21.03.2023./entry into force 
22 March 2023. 

Educational activities for public procurement organisers in the risks of competition in 
procurement 
In  2023,  the  Competition  Council  actively  trained  public  procurement  organisers  on  the  risks  of 
competition in procurement, including procurement related to EU funding. 

For example,  in 2023  the Competition  Council,  together  with  the  Procurement  Monitoring  Bureau, 
organised  six  seminars.  In  total,  more  than  1 000  procurement  specialists  from  public  bodies,  e.g. 
Ministry  of  Agriculture,  Ministry  of  Interior  Affairs,  Ministry  of  Transport,  received  training  in  the 
possible  risks  of  violations  within  procurement,  so  that  they  can  detect  and  prevent  potential 
infringements. 

Moreover, on 28 November 2023, the Competition Council participated in an international conference 
on fraud within EU funds in order to learn about violations of competition law and their correlation 
with fraud as it affects EU funds. 

Reasons for reporting: several cartel cases investigated recently by the Competition Council had also 
impacted on projects financed by EU funds, hence the importance of training contracting authorities 
in the risks of competition within procurement. 

3rd anti-fraud measure taken by LV in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned  

Single  

Organisational 
03/04/2023 

New measure   Horizontal 

Public 
procurement 

General 
training 

Reason / 
expected 
result  

Other* 

Prevention 

* Within the framework of limited resources, extensive educational training activities were carried out for a wide range of 
public buyers. 

Resources of the Competition Council (CC) and the Procurement Monitoring Bureau (PMB) involved in the training: the chair 
of the CC, the head of the PMB, a representative of the Department of Prohibited Cartel Agreements of the CC, and a 
representative of the Department of Application of Legislation of the PMB, with support from the Communications 
Department, took part in preparing and organising the training programme. 

60 

 
 
 
 
 
2.17. 

Lithuania  

Lithuania  reported  three  measures  in  total.  Two  related  to  strengthening  the  identification  of 
corruption through a legislative measure aimed at effective management of procurement processes 
and via training aimed at strengthening suppliers’ competences. The third measure involved an order 
issued by Lithuania’s Minister of Agriculture.  

Regulatory measures 
Effective management of procurement processes, reducing the likelihood of corruption occurring in 
procurement.  

1st anti-fraud measure taken by LT in 2023 

Single/ 
package  

Type of 
measure  

New or 
update  

Single  

Amendment  

Legislative – 
Law/Act – 
30/09/2021* 

Nature of the 
measure and 
sector 
concerned  

Sectoral; 
Expenditure – 
Centralised 
direct 
management 

Area 

Scope  

Other*** 

Public 
procurement; 
Corruption**; 
Conflict of 
interest 

Reason / 
expected 
result of the 
measure 

To clarify or 
consolidate 
existing rules 

Prevention 

*Amendment of the Law on Public Procurement of the Republic of Lithuania of 30 September 2021 No. XIV545, amending 
the Law on Procurement by Contracting Entities in the field of Water Management, Energy, Transport and Postal Services of 
the Republic of Lithuania of 30 September 2021 No. XIV-546. 

About the legislative measure: on 1 January 2023, the amendments to the laws of the Republic of Lithuania on public 
procurement and procurement by contracting entities in the field of water management, energy, transport and postal 
services, adopted on 30 September 2021, came into force, obliging municipal councils to ensure that purchases made by 
contracting authorities controlled (managed) by the municipality, the contract value of which exceeds EUR 15 000 excluding 
VAT, are carried out centrally.  

**Corruption in the public sector (including the political sphere). Measures taken in the fight against corruption within public 
procurement: 

•  Measures addressing transparency in public procurement 
•  Measures to improve the effectiveness of management of the public procurement.  
•  Measures to prevent corruption amongst personnel, including management. 
•  Measures to improve the effectiveness of control and audit. 

***Additional obligation for contracting authorities 

61 

 
 
 
 
 
Increasing the number of suppliers within public procurement 
During  the  project,  the  public  procurement  office  provided  training  for  suppliers.  These  training 
sessions strengthened suppliers’ competences, not only in terms of their ability to identify corruption, 
but also through increased competition to reduce the risk of corruption. 

2nd anti-fraud measure taken by LT in 2023 

Single/ 
package  

Type of 
measure  

New or 
update  

Area 

Scope  

Nature of the 
measure and 
sector 
concerned  

Single 

Organisational 
– 05/10/2023 

New measure 

Horizontal  

Public 
procurement; 
Corruption* 

Competence; 
General 
training 

Reason / 
expected 
result of the 
measure 

Neutral on 
resources 

Prevention

*Corruption within public procurement in the public sector (including the political sphere) and private sector. Measures 
taken in the fight against corruption within public procurement:  

•  Measures addressing the transparency of companies participating in public procurement.  

Approval of the methodology for the application of sanctions for infringements of the 
provisions of legal Acts and the approval of the rules for the administration of infringements 
of legal provisions  
Order of the Minister of Agriculture of the Republic of Lithuania No 3D-80 of 14 February 2023 ‘On the 
approval of the methodology for the application of sanctions for infringements of the provisions of 
legal Acts in the implementation of the intervention measures of the strategic plan for agricultural and 
rural development of Lithuania 2023-2027.’  

Order of the Minister of Agriculture of the Republic of Lithuania No 3D-80 of 5 February 2010 ‘On the 
approval of the rules for the administration of infringements of legal provisions in connection with the 
implementation of measures of the European Agricultural Guarantee Fund, the European Agricultural 
Fund for Rural Development and the European Fisheries Fund’ (last amended on 29 August 2023).  

3rd anti-fraud measure taken by LT in 2023 

Single/ 
package  

Type of 
measure  

New or 
update  

Area 

Scope  

Nature of the 
measure and 
sector 
concerned  

Single 

Legislative – 
Regional law/ 
decree/ order 
– 
14/02/2023* 

New 
legislation; 
amendment  

Sectoral; 
Expenditure – 
Agriculture, 
Fisheries 

Shared 
management 
and control of 
EU funds 

Definition of a 
specific topic; 
Recovery 

Reason / 
expected 
result of the 
measure 

To enforce the 
rules in line 
with 
developments 
in EU law 

62 

 
 
 
Prevention 

Recovery and 
sanction 

Investigation 
and 
prosecution 

*Order of the Minister of Agriculture of the Republic of Lithuania No 3D-80 of 5 February 2010 ‘On the approval of the rules 
for the administration of infringements of legal provisions in connection with the implementation of measures of the European 
Agricultural Guarantee Fund, the European Agricultural Fund for Rural Development and the European Fisheries Fund.’  

63 

 
 
 
 
 
2.18. 

Luxembourg  

Luxembourg reported about a single ongoing activity, concerning preparatory work for the adoption 
of their national anti-fraud strategy. 

Ongoing activities for the adoption of a national anti-fraud strategy 

1st anti-fraud measure taken by LU in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Single  

Organisational 
02/05/2024 

Update  

Horizontal 

Other 

Anti-fraud or 
anti-
corruption 
strategy 

Reason / 
expected 
result  

Neutral on 
resources  

Prevention 

64 

 
 
 
 
 
 
2.19. 

Malta  

Malta reported a measure focused on training, in line with Action Point 6 of the updated National Anti-
Fraud and Corruption Strategy (NAFCS) and Malta’s Recovery and Resilience Plan commitments.  

Training in line with the NAFCS and Malta’s RRP commitments 
During 2023, in line with Action Point 6 of the updated NAFCS and Malta’s Recovery and Resilience 
Plan (RRP) commitments, the Internal Audit and Investigations Department (IAID), in agreement with 
the Chartered Institute of Public Finance and Accountancy (CIPFA), organised two training programmes 
for  appointed  officials  from  the  national  authorities  forming  part  of  the  coordinating  committee, 
namely: 

- 
- 

International Certificate in Corruption Investigation (ICCI); and 
International Certificate in Corruption Risk Management (ICCRM). 

Both training programmes ran for over a number of months and comprised e-learning modules studied 
at  the  participant’s  own  pace,  supplemented  by  a  detailed  technical  reference  manual.  The  ICCI 
training programme also included five days of face-to-face training in order to embed the technical 
and theoretical content of the e-  learning in a practical context. Malta’s EU membership  entails  an 
obligation to protect the financial interests of the EU to the same degree as its own public funds. 

The ICCI and ICCRM training programmes provided participants with relevant knowledge and skills in 
the  area  of  fraud  and  corruption,  e.g.  analytical  and  investigative  techniques,  intelligence,  risk 
assessments, and prevention exercises. Training, moreover, is key to developing anti-fraud and anti-
corruption awareness. 

1st anti-fraud measure taken by MT in 2023 

Single/ 
package  

Type  

New or 
amendment  

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

Single  

Administrative 
– action plan  

New measure   Horizontal 

Other* 

Other** 

Anti-fraud or 
anti-
corruption 
strategy 

Prevention 

Detection 

Investigation 
and 
prosecution 

* To provide appointed officials from the national authorities forming part of the coordinating committee with relevant 
knowledge and skills in the area of fraud and corruption. 

** Training to enhance the fight against fraud and corruption. 

65 

 
 
 
 
 
2.20. 

Netherlands  

Two measures were reported by the Netherlands, focusing on the reporting of suspected fraud to the 
European Public Prosecutor’s Office (EPPO) and on checks involving actual land use. 

Reporting of fraud to the EPPO  
The reporting of cases of suspected fraud to the EPPO has been improved. The new measures aim to 
achieve  qualitative  and  quantitative  improvements  in  the  notices  provided  by  the  Dutch  customs 
authority to the EPPO. The improvement procedure formally began in 2023 and will also cover part of 
2024. 

1st anti-fraud measure taken by NL in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Package  

Organisational 
– 01/06/2023 

New measure   Horizontal 

Reorganisatio
n of existing 
bodies; 
Competence; 
Inter-agency 
cooperation; 
Simplification 
of procedures 

Financial 
crime 
(including 
money 
laundering); 
Organised 
crime; 
Customs/ToR/
illicit trade; 
Shared 
management 
and control of 
EU funds 

Detection 

Investigation 
and 
prosecution 

Reason / 
expected 
result  

Increased 
resources 

66 

 
 
 
 
 
Administrative checks on actual land use 
In  the  short  term  (2023  and  2024),  there  were  four  pilots  on  the  basis  of  which  additional 
administrative checks on actual land use were carried out to determine the most feasible method of 
data exchange and control. These pilots involved three bodies active nationally with extensive plots of 
land as well as a local organisation. 

Improved checks on actual land use, which is a variable of the expenses in the EU budget, are expected 
to increase the prevention of potential fraud in this area. 

2nd anti-fraud measure taken by NL in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

Operational – 
17/10/2023 

New measure  

Nature of the 
measure and 
sector 
concerned  

Sectoral: 
Expenditure -
Agriculture 

Area  

Scope  

Shared 
management 
and control of 
EU funds 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Flagging 
practice; 
Increased 
number of 
checks 

Reason / 
expected 
result  

Enhanced 
cooperation; 
Targeting of 
checks; 
Enhanced ex 
ante controls 

Prevention 

67 

 
 
 
 
 
2.21. 

Poland  

Two of the three measures reported by Poland concerned its Recovery and Resilience Plan. The third 
focused on agricultural policy. 

Guidelines for the controls under the development plan co-financed by the Recovery and 
Resilience Facility 
Reasons  for  reporting:  guidelines  for  the  controls  under  the  development  plan  co-financed  by  the 
Recovery and Resilience Facility. The guidelines create a common framework for the system of controls 
to be carried out by the institutions of the system for implementing the national recovery plan – a plan 
co-financed  by  EU  funds,  i.e.  the  Recovery  and  Resilience  Facility  (including  controls  to  detect  and 
correct serious irregularities, i.e. fraud, corruption and conflicts of interest, as well as double funding) 
and identify the IT tools used in those processes. 

1st Anti-fraud measure taken by PL in 2023 

Single/ 
package  

Type  

New or 
amendment  

 Single    

Operational 
16/11/2023 

Update  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Recovery and 
Resilience 
Facility 

Area  

Scope  

Reason / 
expected 
result  

Conflict of 
interest; 
Other* 

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

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

Prevention 

Detection 

Investigation 
and 
prosecution 

* Controls of EU funds implemented under the National Recovery Plan financed by the Recovery and Resilience Facility. 

68 

 
 
 
 
 
Whistle-blower policy for the National Recovery and Resilience Plan 
Procedure for handling reports from members of the public on potential irregularities or fraud and the 
protection of persons reporting irregularities or fraud (part of the procedure for carrying out controls). 

The main aim of the procedure is to set up a system for reporting potential irregularities or fraud in 
projects  implemented  under  Poland’s  Recovery  and  Resilience  Plan,  which  at  the  same  time 
guarantees  protection  for  those  who  report  such  incidents  (‘whistle-blowers’)  by  creating  secure 
channels. The procedure also applies to anonymous reporting. 

2nd anti-fraud measure taken by PL in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Update  

Administrative 
– Decision, 
Resolution 

Area  

Scope  

Whistle-
blower; 
Other* 

Irregularities 
reporting 

Nature of the 
measure and 
sector 
concerned  

Sectoral: 
Expenditure – 
Recovery and 
Resilience 
Facility 

Reason / 
expected 
result  

To clarify or 
consolidate 
existing rules; 
To enhance 
existing 
measure 

Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

* Controls of EU funds implemented under the National Recovery Plan financed by the Recovery and Resilience Facility. 

69 

 
 
 
 
 
Managing authority guidelines regarding the strategic plan for the common agricultural policy 
(SP CAP) 2023-2027  
The managing authority’s guidelines include matters involving procedures for granting and disbursing 
financial aid. They also specify the conditions for granting, disbursing and repaying that aid for SP CAP 
2023-2027 interventions where the aid is granted on the basis of an aid agreement. 

3rd anti-fraud measure taken by PL in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

New measure 

Administrative 
– Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Agriculture 

Area  

Scope  

Shared 
management 
and control of 
EU funds 

Eligibility 
criteria; 
Management 
of funds; 
Recovery  

Reason / 
expected 
result  

To clarify or 
consolidate 
existing rules; 
To enhance 
existing 
measures; 
Cross-cutting 
measure, 
Multi-agency 
measure/ 
Measure with 
impact on 
various 
bodies* 

Prevention 

Recovery 
and 
sanction 

*Cross-cutting measure: guidelines for the implementation of the SP CAP, issued by the minister responsible for rural 
development acting as the managing authority, addressed to the paying agency, implementing bodies, the body 
implementing financial instruments, intermediate bodies, local action groups and other relevant bodies and beneficiaries. 

70 

 
 
 
 
 
2.22. 

Portugal  

Portugal reported three measures. The first involved updating its national anti-fraud strategy (NAFS); 
the second concerned a training activity for managing authorities  in fraud risk assessment; and the 
third was aimed at strengthening systematic risk analysis within Customs. 

Update of the National Anti-Fraud Strategy 
The  National  Anti-Fraud  Strategy  was  updated  by  Order  No 7833/2023  of  the  Minister  for  the 
Presidency and the Minister for Finance in the context of preventing and combating fraud in the use 
of funds from the EU budget for the period 2023-2027. 

The National Anti-Fraud Strategy in the context of EU funds aims to define a framework and guidelines 
for the development of individual action plans for effective and proportionate anti-fraud measures in 
the management and control of funds from the general EU budget, including in funding instruments 
directly managed by the European Commission that involve audits and checks to be carried out by the 
national authorities. 

1st anti-fraud measure taken by PT in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Decision 
31/07/2023*  

New 
legislation  

Reason / 
expected 
result  

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

Area  

Scope  

Definition of a 
specific topic; 
Other**  

Public 
procurement; 
Conflict of 
interest; 
AFCOS; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Agriculture 
Fisheries, 
Cohesion 
policy, 
Centralised 
direct 
management, 
Fund for the 
most 
deprived, 
Globalisation 
Fund, 
Migration and 
asylum, 
Recovery and 
Resilience 
Facility 

Prevention 

Detection 

Recovery 
and 
sanction 

*About the measure: approval of the revision of the National Anti-Fraud Strategy and the corresponding action plan in the 
management and control of funds from the general EU budget, including funding instruments directly managed by the 
European Commission that involve audits and checks to be carried out by the national authorities. 
Legislative Act – reference: Order No 7833/2023 

** Anti-Fraud Strategy 

71 

 
 
 
 
 
Training of managing authorities in fraud risk assessment 
Training the managing authorities in fraud risk assessment, specifically through the development and 
dissemination of cross-cutting methodologies and guidelines, including tools enabling the managing 
authorities  to  implement  fraud  risk  assessments,  is  considered  highly  relevant  for  preventing  and 
detecting fraud within the use of EU funds. 

2nd anti-fraud measure taken by PT in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Update  

Administrative 
– Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Reason / 
expected 
result  

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

Area  

Scope  

Public 
procurement; 
Conflict of 
interest; Anti-
fraud or anti-
corruption 
strategy; 
double 
funding 

Eligibility 
criteria; 
Management 
of funds; 
Monitoring/ 
desk checks; 
On the spot 
checks; Audit 
checklist; 
Irregularities 
reporting 

Nature of the 
measure and 
sector 
concerned  

Sectoral: 
Expenditure – 
Agriculture, 
Fisheries, 
Cohesion 
policy, Fund 
for the most 
deprived, 
Globalisation 
Fund, 
Migration and 
asylum, 
Recovery and 
Resilience 
Facility 

Prevention 

Detection 

72 

 
 
 
 
 
 
Systematic risk analysis within Customs 
The development and implementation of specific risk measures in the risk engine for the systematic 
risk analysis of declarations for release for free circulation, in areas such as the fight against fraud – 
anti-dumping  and  end-use  –  from  a  Customs  policy  perspective,  aimed  at  strengthening  the 
implementation of Customs policy. 

3rd anti-fraud measure taken by PT in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational -
01/01/2023 

Update  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – 
Customs 

Reason / 
expected 
result  

Targeting of 
checks; 
Targeting of 
investigations 

Area  

Scope  

Customs/TOR/
illicit trade 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Risk 
indicators; 
Increased 
number of 
checks 

Prevention 

Detection 

73 

 
 
 
 
 
 
2.23. 

Romania  

The three measures adopted by Romania focused on VAT fraud, the reporting of suspicions of fraud to 
the EPPO and the adoption of the NAFS for the period 2023-2027. 

Combating tax evasion 
A new criminal offence has been introduced into the legislation on fighting tax evasion (in Article 9^1 
of Law No 241/2005), criminalising any act or omission committed in cross-border fraudulent schemes 
with the effect of reducing the resources of the European Union budget by the equivalent in national 
currency of at least EUR 10 million.  

1st anti-fraud measure taken by RO in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Law/Act 

Amendment  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – Tax 
fraud  

Area  

Scope  

Financial 
crime 
(including 
money 
laundering) 

Definition of a 
specific topic; 
Criminal 
sanctions** 

Reason / 
expected 
result  

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

Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

*About the legislative measure: in order to correctly transpose Directive (EU) 2017/1371 (in particular, Article 3 thereof), a 
new criminal offence was enacted to combat tax evasion (in Article 9^1 of Law No 241/2005), criminalising any act or 
omission committed in cross-border fraudulent schemes with the effect of reducing the resources of the European Union 
budget by the equivalent in national currency of at least EUR 10 000 000. 

Legislative Act – reference: Law No 125/2023 supplementing Law No 241/2005 on preventing and combating tax evasion 

** 

* Criminal sanctions 

a) new 

b) less 

c) more 

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
Legislative measures regulating the obligation to refer a matter to the competent criminal 
authorities 
The adopted legislative measures regulate the obligation to refer a matter to the competent criminal 
authorities (the EPPO or national authorities, as the case may be) if there are indications of fraud in 
obtaining and/or using European funds. They establish the possibility for the national AFCOS to carry 
out  additional  administrative  checks  if  these  cannot  be  carried  out  by  the  authorities  in  charge  of 
managing European funds. 

The obligation of the authorities in charge of managing European funds has been clarified as regards 
to whom they should promptly refer matters: the EPPO in the event of signs of fraud over which it has 
jurisdiction; or the Anti-Fraud Department (DLAF) and national prosecution bodies in cases where the 
EPPO is not competent to act. 

2nd anti-fraud measure taken by RO in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Amendment  

Legislative – 
Law/Act 
4 October 202
3 

Area  

Scope  

Competences; 
Powers 

Financial 
crime 
(including 
money 
laundering) 

Reason / 
expected 
result  

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

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Revenue – 
Expenditure – 
Agriculture, 
Fisheries, 
Cohesion 
policy, 
Centralised 
direct 
management, 
Fund for the 
most 
deprived, 
Globalisation 
Fund, 
Migration and 
asylum 

Detection 

Investigation 
and 
prosecution 

*About the legislative measure: it regulates the possibility for the national AFCOS to carry out additional administrative 
checks if these cannot be carried out by the authorities in charge of managing European funds. 

The obligation of the authorities in charge of managing European funds has been clarified as regards to whom they should 
promptly refer matters: the EPPO in the event of signs of fraud over which it has jurisdiction; or the Anti-Fraud Department 
(DLAF) and national prosecution bodies in cases where the EPPO is not competent to act. 

Legislative Act – reference: Law No 265/2023 approving Government Emergency Order No 97/2022 amending and 
supplementing Government Emergency Order No 66/2011 on preventing, detecting and sanctioning irregularities in 
obtaining and using European funds and/or related national public funds 

75 

 
 
 
 
 
Adoption of the National Anti-Fraud Strategy 2023-2027 for the protection of the European 
Union’s financial interests in Romania 
The need to set up a National Anti-Fraud Strategy (NAFS) stems from Romania’s primary obligation to 
protect  the  European  Union’s  financial  interests  in  Romania,  in  accordance  with  Article 325  of  the 
Treaty on the Functioning of the European Union (TFEU). 

3rd anti-fraud measure taken by RO in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Legislative – 
Decision 
19/12/2023* 

New 
legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Area  

Scope  

Reason / 
expected 
result  

Other** 

Other*** 

Anti-fraud or 
anti-
corruption 
strategy 

Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

*About the legislative measure: the NAFS, a document covering several fields and institutions, aims to strengthen the 
protection of the European Union’s financial interests in Romania by means of effective and efficient measures, carried out 
in a coordinated and transparent manner, in line with European guidelines. 

The NAFS aims to coordinate fraud prevention efforts undertaken by all national partners, so that European funds, including 
those allocated to Romania through the Recovery and Resilience Facility, can be absorbed as fully, and as well, as possible, 
so that Romania can fully contribute to the EU budget. 
Legislative Act – reference: Government Order No 1259/2023 approving the National Anti-Fraud Strategy 2023-2027 for the 
protection of the European Union’s financial interests in Romania 

** Field of the protection of the European Union’s financial interests 

*** The need to set up a National Anti-Fraud Strategy (NAFS) stems from Romania’s primary obligation to protect the 
European Union’s financial interests in Romania, in accordance with Article 325 of the Treaty on the Functioning of the 
European Union (TFEU). 

76 

 
 
 
 
 
2.24. 

Slovakia  

Slovakia reported three measures. The first concerns guidance to the bodies implementing its national 
RRP, the second aims at fostering cooperation among national bodies in the fight against corruption 
and the third focuses on conflicts of interest in the agricultural field. 

Inventory of measures on the protection of the EU´s financial interests for prevention of the 
most serious irregularities in the context of RRF  
The  Slovak  AFCOS,  in  cooperation  with  the  National  Implementation  and  Coordination  Authority 
(NICA), produced a document that contains a list of existing measures on protecting the EU´s financial 
interests  in  Slovakia  aimed  at  preventing,  detecting  and  correcting  the  most  serious  irregularities 
(fraud, corruption, conflicts of interest, double funding).The individual measures are grouped into the 
following thematic categories: integrity, cooperation with relevant partners at national and European 
level,  transparency,  the  public  procurement  process,  fraud  risk  assessment,  IT  tools,  audits  and 
controls,  detection  and  correction  of  irregularities  (including  their  reporting),  recovery,  and  other 
measures. Each measure carries a short description that includes its legal basis and recommendations 
for its effective operation. 

This document was created to offer guidance to the bodies responsible for implementing Slovakia’s 
Recovery and Resilience Plan. Its aim is to provide the relevant implementing bodies with an overview 
of existing measures on protecting the EU´s financial interests in Slovakia and thus achieve a uniform 
level of protection for the EU´s financial interests across all implementing bodies. As so many of these 
measures  can  be  applied  universally,  these  bodies  can  also  benefit  from  this  information  when 
implementing other forms of EU support. 

1st anti-fraud measure taken by SK in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Administrative
*  

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral – 
Expenditure – 
Recovery and 
Resilience 
Facility 

Reason / 
expected 
result  

To enhance 
existing 
measure 

Area  

Scope  

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

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

77 

 
 
Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

*Type of administrative measure: guideline on preventing, detecting and correcting the most serious irregularities 

** CORRUPTION WITHIN PUBLIC PROCUREMENT in the public sector (including the political sphere). Measures taken in the 
fight against corruption within public procurement: 

•  Measures addressing transparency in public procurement.  
•  Measures to improve the effectiveness of management of the public procurement.  
•  Measures to prevent corruption amongst personnel, including management. 
•  Measures addressing transparency of companies participating in public procurement. 
•  Measures to improve the effectiveness of control and audit.  

Establishment of the Board of Anti-Corruption Coordinators and updates to the anti-
corruption programmes of individual ministries and other central authorities 
This  platform  was  created  to  foster  cooperation  between  the  Government  Office  of  the  Slovak 
Republic (as coordinating authority in the area of corruption prevention) and other central authorities 
in the fight against corruption. Board members are expected to cooperate on developing a national 
anti-corruption  strategy,  harmonising  individual  anti-corruption  programmes,  and  designing  and 
implementing measures to eliminate risks relating to corruption and corrupt behaviour. 

2nd anti-fraud measure taken by SK in 2023 

Single/ 
package  

Type  

New or 
amendment  

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

Single  

Organisational 
– 02/05/2023 

New measure   Horizontal 

Corruption* 

Inter-agency 
cooperation 

Neutral on 
resources 

Prevention 

Detection 

* CORRUPTION WITHIN PUBLIC PROCUREMENT in the public sector (including the political sphere). Measures taken in the 
fight against corruption within public procurement: 

•  Measures to improve how effectively public procurement is managed.  
•  Measures to prevent corruption among staff, including management. 

Directive 2/2023 on conflict of interest in the Agricultural Paying Agency 
Prevention and detection of conflicts of interest of persons involved in the management of EU funds 
in the Agricultural Payment Agency. 

78 

 
 
 
 
3rd anti-fraud measure taken by SK in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Organisational 
24/04/2023 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral – 
Expenditure – 
Agriculture 

Area  

Scope  

Reason / 
expected 
result  

Conflict of 
interest  

Competence 

Neutral on 
resources 

Prevention 

Detection 

79 

 
 
 
 
 
2.25. 

Slovenia  

Two sets of measures were reported by Slovenia. The first aimed at strengthening controls within the 
CAP, and the second involving the deployment of an IT platform within Customs, plus a third measure 
amending the transposition into national law of the PIF Directive. 

Sets of measures for enhancing the protection of the EU’s financial interests 
Replies from the Ministry for Cohesion and Regional Development, the Agency for Agricultural Markets 
and Rural Development, and the Ministry of the Interior: 

Ministry  for  Cohesion  and  Regional  Development:  protection  of  whistle-blowers  (external  and 
internal). 

Agency for Agricultural Markets and Rural Development: start of implementation of a new intervention 
under  the  CAP  Strategic  Plan  2023-2027,  namely  IRP24  installation  support  for  young  farmers  and 
establishment of control procedures to detect fraud and artificial conditions. 

Ministry  of  the  Interior:  as  managing  authority,  the  ministry’s  European  Funds  Service  operates 
primarily in the field of fraud prevention, with an emphasis on  raising staff  awareness and training 
them in fraud detection, focusing on fraud indicators (‘red flags’), detecting conflicts of interest, and 
risks in public procurement procedures and contract implementation. 

Reasons for reporting: these measures all enhance the protection of the EU’s financial interests. 

1st anti-fraud measure taken by SI in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Operational 
19/06/2023 

New measure  

Reason / 
expected 
result  

Enhanced 
coordination; 
Targeting of 
checks; 
Enhanced ex 
ante controls 

Nature of the 
measure and 
sector 
concerned 

Sectoral – 
Expenditure – 
Agriculture, 
Cohesion 
policy 

Migration and 
asylum 

Area  

Scope  

Web 
reporting/ 
Hotline 

Public 
procurement; 
Conflict of 
interest; Fraud 
definition; 
Whistle-
blower; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy; 
Other* 

Prevention 

Detection 

* Whistle-blower protection system (internal and external whistle-blowing channels). Guidelines for protecting external and 
internal whistle-blowers have been adopted, including the following: https://www.gov.si/zbirke/storitve/prijava-
zascitenega-prijavitelja-glede-krsitve- predpisov-v-delovnem-okolju-ministrstvu-za-kohezijo-in-regionalni-razvoj/ 

80 

 
 
 
 
Digitalisation of the fight against fraud: the Qlik Sense platform 
A  new  IT  platform,  Qlik  Sense  (QS),  was  implemented.  It  allows  new  and  enhanced  ‘in  house’ 
applications to be devised for specific customs, tax and excise fields. 

These  applications  help  with  performing  better  risk  analyses,  implementing  risk  management  and 
targeting  suspicious  patterns,  transactions  and  economic  operators.  Predictive  analyses,  machine 
learning and artificial intelligence can then be carried out. 

2nd anti-fraud measure taken by SI in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

Update  

Administrative
- Circulaire/ 
Circular, 
Instructions, 
Guidelines, 
Manuals 

Operational 
01/03/2023 

New measure  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
revenue 
Customs, Tax 
Fraud 

Area  

Scope  

Shared 
management 
and control of 
EU funds; 
Other* 

Monitoring/ 
desk checks; 
On-the-spot 
checks; 
Irregularities 
reporting 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Risk 
indicators; 
Increased 
number of 
checks; 
Other*** 

Reason / 
expected 
result  

To clarify or 
consolidate 
existing rules; 
To enhance 
existing 
measures; 
Other** 

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

Prevention 

Detection 

* Implementation of the new Qlik Sense (QS) platform, which allows new and enhanced ‘in house’ applications to be 

created for specific customs, tax and excise fields. These applications allow risk management to be implemented 

more effectively by targeting suspicious patterns, transactions and economic operators. 

** Enhanced fraud management, reporting and better knowledge of possible irregularities. With predictive analyses 

it is possible to better manage mutual assistance requests, audits, post-audit controls and optimum usage of human 

resources. 

*** Training for advanced developers, advanced analysts and other end users and preparation of sources of 

information and the re-writing of program codes (script). New focuses for results visualisation and reports also need 
to be devised. 

81 

 
 
 
 
Amending the transposition into Slovenian law of the PIF Directive 
In reply to the 2022 questionnaire, Slovenia reported that the European Commission had sent a letter 
of formal notice on 9 February 2022 due to partial non-compliance with Directive (EU) 2017/1371, and 
that the Slovenian Government had submitted a legislative proposal to amend the Criminal Code (KZ-
1J) to the National Assembly for adoption in November 2022. The proposal included amendments to 
bring the Criminal Code into line with Directive (EU) 2017/1371. The amended Criminal Code KZ-1J was 
adopted  by  the  National  Assembly  in  January  2023, published  in  the  Uradni  List  RS  (UL RS;  Official 
Gazette of the Republic of Slovenia) No 16/23 on 7 February 2023, and came into force on 22 February 
2023. 

This is a change to the definition of ‘official of the European Union’ as an official in point 7 of Article 
99(1) of the Criminal Code (hereinafter: KZ-1). Prior to the amendment of the KZ-1J, the latter provided 
that an official under the KZ-1 may (also) be a person to whom an international public organisation 
confers the status of official and which meets the conditions laid down in points 1, 2 or 3 of the first 
paragraph of Article 99 KZ-1 (points 1, 2 and 3) of KZ-1 may designate officials in the Slovenian system 
for the purposes of KZ-1. Given that Article 4(4)(a)(i) of Directive (EU) 2017/1371 defines an official of 
the European Union only within the meaning of the Staff Regulations of Officials and the Conditions of 
Employment of Other Servants of the European Union laid down in Council Regulation (EEC, Euratom, 
ECSC)  No  259/68  –  i.e.  without  any  further  link  to  the  internal  systems of the  Member  States,  the 
provision of the Slovenian KZ-1 was too restrictive as regards the scope of Directive (EU) 2017/1371.  

Following the entry into force of the KZ-1J, point 7 of the first paragraph of Article 99 KZ-1 is amended 
to define as officials of an international organisation all those to which the international organisation 
confers official status, i.e. without the additional condition that they must also fulfil the conditions laid 
down in the definition of official in the Republic of Slovenia. 

3rd anti-fraud measure taken by SI in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single  

Amendment  

Legislative – 
Law/Act 
07/02/2023*  

Nature of the 
measure and 
sector 
concerned 

Sectoral: 
Expenditure – 
Recovery and 
Resilience 
Facility 

Area  

Scope  

Reason / 
expected 
result  

Other**** 

To remedy 
flaws 

Public 
procurement; 
Financial 
crime 
(including 
money 
laundering); 
Organised 
crime; 
Corruption*; 
Conflict of 
interest; Fraud 
definition; 
AFCOS; 
Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy; 
Other*** 

82 

 
 
Prevention 

Detection 

Investigation 
and 
prosecution 

*About  the  legislative  measure:  an  amendment  to  the  definition  of  ‘official  of  the  European  Union’  as  an  official  under 
Article 99(1)(7) of the Criminal Code (KZ-1). Before the Criminal Code was amended (as KZ-1J), it stated that an official under 
KZ-1 may (also) be a person on whom an international public organisation has conferred the status of official and who, in 
substantive terms, meets the conditions laid down in points 1, 2 or 3 of Article 99(1) KZ-1 (points 1, 2 and 3 define an official 
in the Slovenian system for the purposes of KZ-1). In view of this, please see the full text – which should have been included 
here – under ADDITIONAL MEASURES. 

Legislative Act – reference: Act amending the Criminal Code; EPA: 440-IX; UL RS No 16/23 

**  CORRUPTION  WITHIN  PUBLIC  PROCUREMENT  in  the  public  sector  (including  the  political  sphere)  and  private  sector. 
Measures taken in the fight against corruption in public procurement: 

-  Measures addressing transparency in public procurement 
-  Measures to improve the effectiveness of management of the public procurement. 
-  Measures to prevent corruption amongst personnel, including management. 
-  Measures addressing transparency of companies participating in public procurement. 
-  Measures to improve the effectiveness of control and audit 
- 

Other: Ministry of Justice: the specific and general preventive effects of the amendment to the definition of ‘official 
of the European Union’ as an official under Article 99(1)(7) of the Criminal Code. The current text states that an 
official under KZ-1 may (also) be a person on whom an international public organisation has conferred the status of 
official  and  who,  in  substantive  terms,  meets  the  conditions  laid  down  in  points 1,  2  or  3  of  Article 99(1)  KZ-1 
(points 1, 2, and 3 define an official in the Slovenian system for the purposes of KZ-1). Given that Article 4(a)(i) of 
Directive (EU) 2017/1371 defines an official of the European Union [continued under ‘Comment’] 

*** Comment by the Ministry of Justice: the measure applies to any offence where an official is specifically identified as the 
perpetrator. 

**** The measure applies to any offence where an official is specifically identified as the perpetrator. 

Comment: [continued] solely within the meaning of the Staff Regulations of Officials and the Conditions of Employment of 
Other Servants of the European Union laid down in Council Regulation (EEC, Euratom, ECSC) No 259/68 – in other words, 
without any additional link to Member States’ national systems – the Slovenian KZ-1 provision is too restrictive compared to 
the scope of Directive (EU) 2017/1371. 

Under the amended Criminal Code KZ-1J, Article 99(1)(7) has been amended so that anyone conferred with the status of official 
by an international organisation is defined as an official of an international organisation, without any further condition that 
they must also meet, in substantive terms, the conditions for the definition of an official in Slovenia. 

83 

 
 
 
2.26. 

Spain  

The measures reported by Spain focused on protecting whistle-blowers and the resources allocated 
to Spain from the RRF. 

Adoption of Law 2/2023 of 20 February on the protection of persons who report breaches of 
the law and on the fight against corruption 
Given  the  important  role  of  whistle-blowers  in  the  fight  against  fraud  and  corruption,  adequately 
protecting them is seen as fundamental. In addition, one of the aims of the law is to strengthen the 
information culture, the integrity infrastructures of organisations and the promotion of information 
or communication culture as a mechanism to prevent and detect threats to the public interest. 

1st anti-fraud measure taken by ES in 2023 

Single/ 
package  

Type  

New or 
amendment  

Single 

Legislative – 
Law/Act 
20/02/2023*  

New 
legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Reason / 
expected 
result  

To enforce the 
rules in line 
with 
developments 
in EU law 

Area  

Scope  

Competences; 
Powers; 
Definition of a 
specific topic; 
Financial 
penalties; 
Other 
administrative 
penalties; 
Other*** 

Public 
procurement; 
Financial 
crime 
(including 
money 
laundering); 
Organised 
crime; 
Corruption**; 
Conflict of 
interest; 
Fraud 
definition; 
AFCOS; 
Whistle-
blower; 
Customs/ 
ToR/illicit 
trade; Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

*About the legislative measure: the law establishes the obligation to set up internal reporting systems throughout the 
Spanish public administration, without exception, and measures to protect whistle-blowers who report through internal or 
external channels as well as the rules designed to govern these channels and the creation of the Independent Authority for 
Whistle-blower Protection. The law also establishes the sanctioning regime, which is necessary to effectively combat actions 

84 

 
 
 
involving reprisals against whistle-blowers, as well as breaches of the rules of communication channels. 
Legislative Act – reference: Law 2/2023 

**  CORRUPTION  WITHIN  PUBLIC  PROCUREMENT  in  the  public  sector  (including  the  political  sphere)  and  private  sector. 
Measures taken: measures to prevent corruption amongst personnel, including management. 

***EU rules included within the scope of Directive 2019/1937, as well as acts or omissions that may constitute a serious or 
very  serious  criminal  or  administrative  offence.  In  any  case,  this  will  include  all  serious  or  very  serious  criminal  or 
administrative offences that entail financial damage to the public finances and social security.  

Systematic analysis of the risk of conflict of interest in the procedures implementing the 
Recovery, Transformation and Resilience Plan. 
Reason  for  reporting:  this  ministerial  order  issued  by  the  Ministry  of  Finance  and  Public 
Administration, Order HFP/55/2023, of 24 January, regulates how the ex-ante systematic analysis of 
the  risk  of  conflict  of  interest  in  the  procedures  implementing  the  Recovery,  Transformation  and 
Resilience Plan will be carried out. Conflict of interest is one of the main risks against which measures 
need to be taken in the RRF. 

2nd anti-fraud measure taken by ES in 2023 

Single/ 
package  

Type  

New or 
amendment  

Package  

Legislative – 
Decree 
24/01/2023*  

New 
legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Area  

Scope  

Conflict of 
interest 

Powers; 
Definition of a 
specific topic; 
Other** 

Operational 
24/01/2023 

New measure  

Prevention 

IT tools (‘IT 
data feeding’, 
‘Other IT’); 
Flagging 
practice; Risk 
indicators 

Reason / 
expected 
result  

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

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

*About the legislative measure: the order regulates the minimum content of the declaration of absence of conflicts of 
interest, the description of the procedure for uploading information into the online tool of the State Tax Administration 
Agency (AEAT) for it to analyse the risk of conflict of interest, feedback from the results of the analysis, the procedure in 
cases of entities without real ownership information in the AEAT, and the specification of the effects of identifying the 
existence of a potential conflict of interest, marked with a red flag. 

Legislation – type of act: Order HFP/55/2023 

** Prevention of conflict of interest 

85 

 
 
 
 
 
Implementation of the Central Register of Beneficial Ownership 
Reason  for  reporting:  the  creation  of  a  centralised  register  containing  information  on  beneficial 
ownership is essential for the protection of the EU’s financial interests as well as national financial 
interests. Regulation 2021/241 governing the RRF requires certain standardised categories of data to 
be  collected  and  access  to  them  ensured,  such  as  first  name(s),  last  name(s)  and  date  of  birth  of 
beneficial owner(s) of the recipient of funds or contractor. 

3rd anti-fraud measure taken by ES in 2023 

Area  

Scope  

Public 
procurement; 
Financial 
crime 
(including 
money 
laundering); 
Organised 
crime; 
Corruption***
; Conflict of 
interest; 
Shared 
management 
and control of 
EU funds 

Competences; 
Powers 

Monitoring/ 
desk checks; 
Audit 
checklist; 
Investigation 

Reason / 
expected 
result  

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

To enhance 
existing 
measures; 
Cross-cutting 
measure, 
Multi-agency 
measure/ 
Measure with 
impact on 
various 
bodies**** 

Single/ 
package  

Type  

New or 
amendment  

Package 

Legislative – 
Decree 
11/07/2023*  

New 
legislation  

Nature of the 
measure and 
sector 
concerned 

Horizontal 

Administrative
** 

New measure  

Prevention 

Detection 

Recovery and 
sanction 

Investigation 
and 
prosecution 

*About the legislative measures: creation of a centralised register that will obtain its information in relation to Spanish legal 
persons  from  official  sources,  such  as  the  Spanish  Association  of  Property,  Mercantile  and  Movable  Property  Registrars 
(through the Mercantile Registries) or the General Council of Notaries, and will also include the registration of trusts and 
other  trust-like  legal  instruments  operating  in  Spain  through  direct  declaration  by  the  trustee,  allowing  the  beneficial 
ownership of all of them to be consulted. 

Legislative type of act: Royal Decree 609/2023 of 11 July creating the Central Registry of Beneficial Ownership and approving 
its regulations 

** Type of action for the administrative measure: electronic register/ database 

***  CORRUPTION  WITHIN  PUBLIC  PROCUREMENT  in  the  public  sector  (including  the  political  sphere)  and  private  sector. 
Measures taken: 

Measures addressing transparency within public procurement. 

86 

 
 
 
•  Measures addressing the transparency of companies participating in public procurement 

****  Cross-cutting  measure:  the  information  collected  in  this  register  will  be  accessible  –  free  of  charge  and  without 
restriction – to the authorities responsible for the prevention, detection, investigation and prosecution of terrorist financing, 
money  laundering  and  will  predicate  offences,  both  national  and  from  other  Member  States  of  the  European  Union.  For 
instance, it will also be accessible to national authorities and bodies managing, verifying, paying or auditing European funds.  

87 

 
 
 
 
2.27. 

Sweden  

Sweden reported two measures, both aimed at exploring ways to enhance exchanges of information 
and cooperation between national administrations. 

Study on improving the possibilities for exchanges of information between authorities 
In October 2023, the Swedish Government mandated a special investigator to consider and propose 
improved possibilities for exchanging information on individuals within and between authorities. The 
purpose  of the  enhanced exchange  of  information  is  to  allow  information  to  be  exchanged  to the 
extent necessary to enable the authorities, inter alia, to prevent, detect, investigate and deal with 
fraud,  undue  payments, 
irregularities  and  crime  as  effectively  as  possible,  but  without 
disproportionately impinging on privacy. 

1st anti-fraud measure taken by SE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Area  

Scope  

Nature of the 
measure and 
sector 
concerned 

Single 

Administrative
* 

New measure 

Horizontal 

Other** 

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

Reason / 
expected 
result  

To enhance 
existing 
measures; 
Other*** 

Detection 

Investigation 
and 
prosecution 

*Type of administrative measure: adoption of investigation directives 
https://www.regeringen.se/contentassets/df46f5a2185a45e99b332b74d72c696c/forbattrade-mojer-to-information 
exchange intergovernment/ 

**A special investigator  was tasked with considering and proposing improved possibilities for exchanging information on 
individuals within and between authorities and other bodies which, in accordance with the Public Access to Information and 
Secrecy Act (2009: 400), or OSL for short, are treated as public authorities. The assignment will be presented in August 2024 
and finalised in February 2025. There are currently no concrete legislative proposals. 

*** One of the inquiry’s aims is to put forward provisions making it possible to exchange information between authorities to 
a greater extent. The purpose of the enhanced exchange of information is so that information can be exchanged to the extent 
necessary  to  allow  the  authorities,  inter  alia,  to  prevent,  detect,  investigate  and  deal  with  fraud,  undue  payments, 
irregularities and crime as effectively as possible, but without disproportionately impinging on privacy. There are currently no 
concrete legislative proposals. 

88 

 
 
 
 
 
Increased cooperation on double funding and control methods 
The Swedish Council for the Protection of the European Union’s Financial Interests (SEFI Council) is 
responsible for coordinating initiatives in Sweden against fraud and other abuses. In December 2023, 
it decided to establish two working groups of experts: one on ‘How managing authorities can promote 
awareness of double funding and establish efficient measures to detect double funding and reduce 
the risks of such occurrences’, and another on ‘How managing authorities can enhance their ex ante 
and ex post control methods’. Both working groups are expected to report their findings in late 2024.  

2nd anti-fraud measure taken by SE in 2023 

Single/ 
package  

Type  

New or 
amendment  

Nature of the 
measure and 
sector 
concerned 

Area  

Scope  

Reason / 
expected 
result  

Single  

Organisational 
01/12/2023 

New measure   Horizontal 

Inter-agency 
cooperation  

Neutral on 
resources 

Shared 
management 
and control of 
EU funds; 
Anti-fraud or 
anti-
corruption 
strategy 

Prevention 

Detection 

89 

 
 
 
 
 
 
3. Additional measures reported by the Member States 
Through the survey, Member States could report, in summary, additional measures beyond the 
three requested. This section collects these contributions. 

- 

- 

- 

- 

3.1. Belgium 
SPF STRATÉGIE ET APPUI (BOSA) - Royal Decree of 18/04/2023 on integrity policy and integrity 
management within certain organisations of the federal executive – On 15/05/2022, Royal 
Decree adopted on organisational control within some departments of the federal executive. 
On 07/09 2022, a Ministerial Decree on the use of management domains and their respective 
evaluation grid by some departments of the federal executive power with reporting every year 
on 15 March.  
FPS FINANCE: — [Article 76 (1) of the VAT Code] Measure to improve the compliance of the 
taxable person with regard to his VAT returns. In order to do so, where the taxable person 
wishes to obtain a refund of excess VAT, a condition of compliance with his reporting 
obligations during the 6 months preceding the return which gave rise to the excess. The 
declaration showing the surplus must also be lodged within the prescribed time limit.  
ERDF BRUSSELS: — Training on the prevention and detection of irregularities, corruption, 
conflict of interest and fraud. Other training specifically regarding IT-security has also been icen- 
Acces to the national UBO register. Verification of the data of the ultimate beneficiary of the 
final beneficiaries and contractors of the RRF.  
ERDF FLANDERS: — In the RRF additional measures were taken or are taken with regard to 
double financing, conflict of interest, fraud prevention strategy.  

-  WALLONIAN PAYING BODY: – Adoption and communication to staff of a procedure for the 

prevention/management of conflicts of interest. — Develop an anti-fraud policy to improve the 
identification of potentially fraudulent irregularities and strengthen collaboration with the 
competent judicial authorities.  

-  WALLONIA: – Signature of declarations of absence of conflict of interest by staff involved in 
activities which are by nature more sensitive to the subject matter and keeping a register of 
links of interest within each SPW – Measures for (in) training for staff and beneficiaries on fraud 
and conflicts of interest – Additional measures on double financing, conflict of interest, etc. 
(specifically at RRF level) – Wallonia interfaced the IT programme for monitoring and managing 
RRF and ERDF funds with the Belgian UBO register – Exchange of best practices in risk analysis 
and fight against fraud, with the coordinator of the recovery plan (FWB). 

3.2. Denmark 

The Danish Business Authority updated their guidelines regarding eligibility for aid. It sets out the 
guidelines to follow in an easy understandable language and therefore minimises the risk of 
unintentionally violating the rules. The sector concerned is cohesion policy. 

- 

- 

3.3. Estonia 
The EU financial interest network ELFIK continued its activities and held two training courses 
("EPPO presentation" for about 100 and "Conflict of Interest and analysis" for 40 officials). 
In the area of public procurement training courses for buyers on “national security risks in 
public procurement” and “overview of foreign subsidies regulation“ were organised. 

-  Various measures to avoid conflict of interest were launched at managing authority’s level: 
o 

requirement that implementing bodies describe the verification of the content of confirmations 
of the absence of conflict of interest in work procedures and store the results of the verification 
in a way that enables written reproduction. 
risk-based control: the aim is to make sure that there are no transactions between related 
parties in the costs considered eligible. 

o 

-  New control guidelines for the 2021-2028 programming period in the Agricultural and Fishery 

area. 

90 

 
 
3.4. Germany (2) 
Conflicts of interest:  
- 

- 

- 

- 

By amending Section 23(1)(1) of the Money Laundering Act (GWG), authorities such as the audit 
and administrative authorities now have the possibility to consult the Transparency Register 
(see previous year) in order to check conflicts of interest.  
The Federal Ministry of Finance organised on 30-31/03/2023 a workshop with Audit Authorities 
with a view to raising awareness about conflicts of interest in the Ministry. 
The Federal Ministry of Food and Agriculture implemented the policy document on prevention 
and detection of conflicts of interest by the competent authorities in the agricultural/fisheries 
sector. The aim of this strategy paper is to achieve a uniform procedure in the German federal 
system in the area of conflicts of interest in the German competent authorities in the 
agricultural/fisheries sector. 

Whistleblower protection:  
Adoption of the Whistleblower Protection Act on 31.5.2023, entered into force on 2.7.2023: §. Point 
1(2)(1) of the HinSchG covers the notification and disclosure of infringements of the protection of 
the EU’s financial interests within the meaning of Article 325 TFEU (BGBl. 2023 I No 140). 

Reporting of irregularities 
An IMS workshop was organised in November 2023 at the Federal Ministry of Finance, Berlin, with 
the IMS managers to improve reporting quality for Germany. 

Anti-fraud measures 
- 

The ESF managing authority (MA) carried out the fraud risk assessment at the level of the ESF 
Federal Programme in the 2014-2020 funding period, as recommended in the Commission’s 
guidelines on fraud risk assessment and on effective and proportionate anti-fraud measures. 
For the current funding period 2021-2027, the future procedure in the Federal Programme is in 
the final vote.  
In order to fulfil the obligation under Article 74(1)(c) of Regulation (EU) 2021/1060 to 
implement effective and proportionate anti-fraud measures and procedures with regard to the 
financial management and control of the programme, taking into account the risks identified, 
the Federal Ministry for Economic Affairs and Climate Action carries out fraud risk self-
assessment at the level of the various policy areas of the cohesion policy, and improves it on a 
continuous basis.  

3.5. Italy 

In order to detect, prevent and punish customs fraud, the Guardia di Finanza has developed a 
specific strategy, contained in the operational plan entitled ‘Customs Fraud’ and participated in 
international cooperation initiatives promoted by the World Customs Organisation, OLAF, EUROPOL 
and the Law Enforcement Working Party (Customs). Guardia di Finanza also participated in the 
EMPACT project aimed at combating illicit tobacco products and the work of the Law Enforcement 
Working Party (Customs), joining the respective Joint Action Days and Joint Customs Operations. 

- 

3.6. Latvia 
The Latvian AFCOS has participated in the national expert group of project “Integrity Watch 3.0” 
implemented by Transparency International. AFCOS has given valuable input in evaluation of 
available open-data sets in Latvia and given consultations on available data for public sector 
that can be received by request. Within this cooperation with Transparency International the 
Latvian AFCOS has given 2 presentations on use of databases in work of AFCOS to students and 
employees of universities. 

(2) 

The managing authorities of the Länder in the area of cohesion also reported on various other measures. Three 
selected examples are detailed in Section 2.11. 

91 

 
 
 
- 

- 

- 

- 

The coordinating authority of the RRF has developed guidelines on detection, reporting and 
recovery of violations in the implementation of the RRF, which were updated in 2023 by 
including information on reporting to the EPPO based on procedure jointly developed by the 
AFCOS and the EPPO. The main aim of these guidelines is to inform the institutions involved in 
the implementation and supervision of the RRF and to develop a common understanding of the 
requirements for the necessary action in the case of identified breaches of the RRF. 
Legislative measures implemented by the Ministry of Agriculture and the Rural Support Service - 
the Cabinet of Ministers' regulations of 2023 No.113 "The general procedure for the allocation, 
administration and monitoring of state and European Union support for rural and fisheries 
development", which stipulates that an applicant or recipient of support applying for one of the 
EU funds for the development of agriculture, fisheries and rural areas funding must ensure that 
the bids received in its announced procurement are certified with an e-signature. Also 
Regulation No.113 stipulates that the project submitted by the aid applicant or aid recipient is 
rejected or the aid is not paid if a criminal proceeding has been initiated in connection with the 
implementation of the submitted project. 
In 2023 amendments to the Public Procurement Law have entered into force to improve 
competition, providing: 

o 

the obligation to cancel the procurement procedure when only one tender has been 
submitted; 

o  stricter conditions for procurement commission thus minimizing conflict of interest 

and corruption risks; 

o  broader definition of conflict of interest; 
o  specific regulation for market research. 

In accordance with the General Prosecutor's Office orders cases of fraud and embezzlement, if 
they are related to the use of EU funds, were determined to be especially urgent criminal cases. 
A special order was also assigned for control of these criminal cases. 

3.7. Romania 

National Strategy for public procurement (SNAP) 2023-2027 
Government Decision No 554/2023 approving the National Strategy for Public Procurement 2023-
2027, published in Official Gazette Part I No 540 of 16 June 2023, was adopted in 2023, a public 
policy document including the Government’s objectives for further reform of the national public 
procurement system between 2023 and 2027.  

SNAP 2023-2027 is aligned with the priorities of the European Commission and was developed in the 
context of the implementation of the National Recovery and Resilience Plan. The adoption of the 
strategy is also justified by the need to fulfil the country recommendations made by the European 
Commission regarding the area of public procurement.  

In order to implement the new public procurement strategy, the authorities and institutions 
nominated in the action plan should be involved, including central public authorities regulating areas 
such as those relating to the environment, work or research and innovation. The coordination of the 
activity is to be carried out by the National Public Procurement Agency (ANAP), the institution which 
ensures the design, promotion and implementation of public procurement policy, as part of the 
government’s policy.  

Institutional and financial framework for the management of RRF 
2. Furthermore, Government Emergency Order No 76/2023 amending and supplementing 
Government Emergency Order No 124/2021 establishing the institutional and financial framework 
for the management of European funds allocated to Romania under the Recovery and Resilience 
Facility, and amending and supplementing Government Emergency Order No 155/2020 on certain 
measures for drawing up the National Recovery and Resilience Plan necessary for Romania to access 

92 

 
 
repayable and non-repayable external funds under the Recovery and Resilience Facility, published in 
Official Gazette, Part I, No 858 of 22 September 2023, was adopted.  

In view of the aspects resulting from the implementation of the RRP up to the date of adoption of 
the legislative act, the need to amend and complete the legal framework on financial, monitoring, 
verification and control mechanisms and flows to enable the most efficient use to be made of non-
repayable/repayable external funds allocated to Romania under the Recovery and Resilience Facility 
and to ensure that the financial interests of the European Union are protected. 

93 

 
 
 
4. Case studies 
4.1. Revenue  

Within the framework of the  PIF questionnaire  2023, this section presents a series of case  studies 
reported by Member States, classified under traditional own resources (TOR). The section is divided 
into the two areas most represented by the case studies: smuggling and misclassification/description. 

With regard to smuggling, an initial overview shows that Member States reported a range of illicit 
activities, including trafficking in counterfeit medicines, illegal cigarette production and the smuggling 
of excisable products. 

Networks  active  in  the  illicit  trafficking  of  legitimate  and  counterfeit  medicines  were  uncovered, 
revealing the intricate web of criminal operations involved in this illicit trade. Similarly, other cases 
have shown the sophisticated nature of clandestine production facilities and cross-border distribution 
networks facilitating the illicit trade in tobacco products. 

With regard to cases involving misclassification/misdescription, cases of fraudulent practices aimed 
at circumventing customs duties and tariffs are reported. 

Smuggling 
Member State 
Greece 

Participation of the Hellenic Police in Operation SHIELD IV against the illicit trafficking of 
legitimate and counterfeit medicines 

CASE STUDY 

Illicit trafficking of legitimate and counterfeit medicine, doping substances and food 
supplements involving six criminal networks. The revenue from their criminal activity 
amounted to at least EUR 8 500 000 million. The investigations involved the seizure of more 
than 61 500 units of anabolic steroids (vials, ampoules and tablets) and other illegal 
pharmaceutical preparations, packaging material and equipment, and packages for 
distribution. 

Law enforcement, national/ EU authorities involved: Financial Police Directorate assisted by 
OLAF, Europol, Interpol, Frontex, the World Customs Organization (WCO), the World Anti-
Doping Agency (WADA) and other private entities. 
Exposure of an illegal cigarette factory 

Bulgaria 

An autonomous factory for the illegal production, storage and distribution across Bulgaria and 
the EU of cigarettes without excise bands was uncovered in the municipality of Pazardzhik. 
The raid revealed large quantities of consumables – dry cut tobacco, filters and foil, and 
packaging tools and materials. The whole operation was run by an organised crime network 
using a legal road freight transport business. Some of the members of the network were 
caught engaging in criminal activity in other European countries. Four operations were carried 
out by the authorities of the Ministry of the Interior and the Customs Agency in order to 
intercept and document the activities of the criminal network, which resulted in the following: 
1. 
2. 
around 4 000 kg of cut tobacco and 160 pallets of filters, papers, foil, and blank cigarette 
packets for the Marlboro, Richmond, L&B and American Legend brands; 
3. 
router; 
4. 
cigarettes without excise bands. 

A huge quantity of cigarettes was found in two warehouses in different localities; 
An assembly line for the manufacture of tobacco products was seized, along with 

24 pallets containing Marlboro blank packets were found, as well as a DVR and a 

 A lorry coupled to a semi-trailer was found loaded with Marlboro-branded 

Law enforcement, national/ EU authorities involved: Ministry of the Interior, Customs Agency 

Croatia 

Presumed amount of damage: EUR 5 641 025 
Detection of cigarette smuggling on the EU external border 

An X-ray inspection at Customs revealed goods other than those declared (cosmetics). In 
particular, the presence of cigarettes in cardboard boxes with declared goods was highlighted. 

94 

 
 
 
 
 
 
 
 
Estonia 

Law enforcement, national/ EU authorities involved: National Customs Administration  
Illegal Belarusian cigarette smuggling from Russia 

Smuggling of 969 900 ‘NZ Gold’ cigarettes with Belarusian tax stamps entering from the 
Russian Federation. A truck driven by a Latvian citizen entered from the Russian Federation to 
Estonia through the Narva border crossing point. The vehicle was directed to a radiological 
inspection. As result of the inspection, a false floor was discovered beneath which the 
cigarettes were hidden. 

Law enforcement, national/ EU authorities involved: National Customs Police 
Multi excise goods smuggling 

An x-ray at Customs discovered that goods did not correspond to the presented documents. 
Cigarettes and bottles of strong alcohol without excise stamps were discovered. A total of 
50 000 Winston White cigarettes without excise stamps, 440 000 Winston Blue cigarettes with 
Belarusian excise stamps, 160 000 Marlboro Red cigarettes without excise stamps, and 
100 000 NZ Gold cigarettes with Belarusian excise stamps were found. 

Law enforcement, national/ EU authorities involved: National Customs Police 

Incorrect classification / misdescription / illegal cigarette production 
Member State 
Italy 

CASE STUDY 

Custom tax fraud – Third Country Duty Evasion – Preferential Tariff Treatment 

The results of chemical laboratory analyses confirmed that various consignments of goods 
declared as Basmati rice classified under TARIC heading 1006209813, originating in Pakistan, 
differed from what was declared. 

Estonia 

Law enforcement, national/ EU authorities involved: national financial and economic police, 
Guardia di Finanza 
First discovery of illegal cigarette factory equipment in Estonia 

An illegal cigarette factory was discovered in a production building. Tobacco drying 
equipment, cigarette production, packaging equipment, and a large amount of raw materials 
such as filters, cigarette paper rolls, and Marlboro Gold cigarette pack cardboard layouts were 
found in the building. The Estonian Tax and Customs Board (ETCB) had not issued an excise 
licence to produce excise goods for the address of the building nor for the individuals detained 
in it. Based on the evidence collected by the ETCB, there were sufficient grounds to suspect 
that the individuals intended to start producing a very large quantity of illegal cigarettes. The 
production capacity of the discovered equipment would have been approximately one million 
cigarettes daily, which would have cost the Estonian budget approximately EUR 163 000 per 
day. 

Law enforcement, national/ EU authorities involved: ETCB, Police. 

95 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.2. Expenditure 

This section presents a collection of case studies reported by Member States regarding the budgetary 
area of expenditure, particularly within the framework of cohesion policy. 

These case studies provide a thorough overview of the various instances where financial irregularities 
and fraudulent activities have been detected in projects financed by EU funds. 

From  Romania's  fraudulent  submission  of  false  supporting  documents  to  Italy's  investigation  into 
mismanagement  of  investment  programmes,  each  case  study  reveals  irregularities  in  the  field  of 
expenditure. 

Similarly, Czechia’s prosecution for the unlawful use of EU funds and Latvia's findings of prohibited 
cartel  agreements  in  public  tenders  demonstrate  the  need  for  robust  enforcement  measures  to 
address financial misconduct. 

Member State 
Czechia 

Unlawful use of EU funds in relation to purchases of new CNC production machines 

CASE STUDY 

Denmark 

Unjustified use of subsidies provided from the European Regional Development Fund for the 
amount of EUR 3.6 million. The perpetrators fictitiously reported purchases of new CNC 
production machines, but the purchase of production machines either did not take place at all 
or old ‘second-hand’ machines were purchased. 

Law enforcement, national/ EU authorities involved: Police of the Czech Republic, National 
Organised Crime Agency 
Investment in fishing vessel 
The Danish Fisheries Agency has reported to the police in December 2022 a case according to 
the scheme "Investments in fishing vessels". This happened as a result of screening cases. The 
Agency has established, that the contractor has sold its vessel to a buyer outside the EU during 
the maintenance period without informing the Agency. The Agency has requested the police 
to investigate the matter. On July 27 2023, the police filed charges in the case for violation of 
the Criminal Code. 

Estonia 

Law enforcement, national/ EU authorities involved: Danish police, Danish Fisheries Agency 
Distribution of subsidies (establishment of solar farms) 

Six applicants submitted a separate application for support for the construction of solar parks. 
All the solar parks were designed as if with 6 separate connections, but structurally and 
visually the solar parks formed one whole. It was proved that, despite the fact that each 
separate applicant has its own electricity connection, in reality the investment objects are not 
used independently, and participation in one project is the common economic interest of the 
applicants, and thus it is not six, but one investment object. And the purpose of such 
distribution was to receive 6 times larger support instead of the support provided for one 
investment object. 
The change of a project promoter. 

On the operational level, the Managing Authority (MA) has set a condition to be consulted if 
the Intermediate Body (IB) has a need to change the project promoter/ final beneficiary. 
Although such cases are extremely rare and no written procedure has been established, MA is 
carrying out its inquiry. All the conditions for the initial selection procedure, state aid 
requirements, etc. must be strictly followed. Moreover, the risks of the potential new 
organization are assessed by MA, including fraud, conflict of interest, and corruptive 
situations. MA uses the assessment information from Arachne as well as co-operates closely 
with law enforcement agencies if in-depth information is needed. 
Lack of financial capacity of the applicant.  

The applicant applied for investment support, but during the processing of the application for 
the support, there was a suspicion that the applicant would not be able to fulfil the obligation 
to include self-financing. The measure decree did not contain sufficiently detailed 
requirements regarding the applicant's financial capacity. The applicant claimed that he could 
raise sources of self-financing, but the financial projections obtained from him showed 

96 

 
 
 
 
 
 
 
 
 
 
Italy 

indications that even if the applicant could find the means of self-financing, he would face 
financial problems in the future in fulfilling his obligations. Since the measure regulation did 
not provide sufficient grounds for excluding the grant of support in this situation, the given 
grounds were derived by interpreting the EU and other legal regulations contained in the 
measure regulation. Such grounds were the impossibility of implementing the investment and 
using it purposefully in the future due to the applicant's probable payment difficulties 
Unduly received public funding in the field of drinking water production and wastewater 
treatment 

The case concerned an investigation into the investment programme managed by an in-house 
company of the Municipality of Palermo in the field of drinking water production and 
wastewater treatment. Through this programme, the investee company received 
EUR 20 million in 2020 with a guarantee provided by the EU under the European Fund for 
Strategic Investments. The investigations not only revealed that various urban wastewater 
purifiers in some plants were not functioning properly and were systematically releasing 
significant amounts of sludge into the surrounding environment, but also that maintenance 
work included in the company’s multiannual business plan for 2018 and 2019 had not been 
carried out, without any valid economic justification. 

Latvia 

Law enforcement, national/ EU authorities involved: Guardia di Finanza, EPPO 
Prohibited agreement in three procurements with EU co-financing 

Romania 

Latvia’s Competition Council issued an official decision regarding the discovery of a prohibited 
cartel agreement involving three road companies in public tenders organised by the state 
entity VSIA ‘Latvijas Valsts ceļi’ for the construction of national and other roads in Latvia. 
Three out of seven unlawfully negotiated procurement tenders included co-financing by EU 
funds. The companies were fined more than EUR 4 million for this breach of competition law. 
False supporting documents in connection with the construction of a greenhouse 

A project financed by the European Agricultural Fund for Rural Development (EAFRD) under 
which non-repayable financial assistance was granted for the construction of a greenhouse for 
hydroponic lettuce production and the purchase of the equipment needed to carry out 
production and marketing activities. The financing contract, concluded in 2019, covered non-
repayable funds worth approximately EUR 1 990 000 in eligible expenditure, payable which 
were to be paid in five instalments. The beneficiary published an invitation to tender on the 
Rural Investment Financing Agency’s website to award the contract for construction works 
and for the purchase and installation of the machinery and equipment provided for under the 
project; the entire procedure was carried out online. Only one tender was submitted, by a 
company established in Bulgaria owned and managed by a Romanian national. The tender 
submitted by this economic operator was deemed to comply with the award criteria and a 
procurement contract of RON 10 122 778.65 (plus VAT) was concluded. It was found that the 
beneficiary’s legal representative had submitted false supporting documents as payment 
claims to the Rural Investment Financing Agency, i.e. false bank statements containing 
financial operations which could not be found in the bank account statements sent to DLAF by 
the issuing bank, as well as false payment orders. By using documents whose content had 
been modified by adding false financial operations, the beneficiary wrongly obtained a total 
amount of EUR 1 925 000. 

Law enforcement, national/ EU authorities involved: DLAF, EPPO 

97 

 
 
 
 
 
 
 
 
 
ANNEX 1 Specification of type of (legislative and administrative) measures  

Type of legislative act

Law/Act
Decree
Decision
Regional law/ decree/ order

0

5

10

15

Number of measures reported

Type of administrative measure

Circulaire/Circular, Instructions, Guidelines, Manuals
Recommentation
Action plan
Decision, Resolution
Other

t
c
a
e
v
i
t
a
l
s
i
g
e

l

f
o
e
p
y
T

e
r
u
s
a
e
m
e
v
i
t
a
t
r
t
s
i
n
m
d
a
f
o
e
p
y
T

i

Type of legislative Act  
Law/Act 
- 

Single  

- 
- 

Package  
Total 

Decree 

- 
- 
- 
Decision 
- 
- 
- 

Single  
Package  
Total 

Single  
Package  
Total 

Regional law/ decree/ order 

- 
- 
- 

Single  
Package  
Total 

Type of Act for the administrative 
measure:  
Decision, Resolution 

- 
- 
- 

Single  
Package  
Total 

Recommendation 

0

2

4

6

8

10

12

Number of measures reported

Member States  

Total  

AT-1, BG-2, BG-3, CY-1, CZ-1, ES-1, IE-2, LT-1, LV-2, RO-1, 
RO-2, SI-3 
CY-3, HU-1 

BE-1, BG-1, ES-2, ES-3, IT-3 

PT-1, RO-3 

LT-3 
FR-3 

Member States  

PL-2 

12 

2 
14 

5 

5 

2 

2 

1 
1 
2 
Total  

1 

1 

98 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 
- 
- 

Single  
Package  
Total 

Circulaire/Circular, Instructions, 
Guidelines, Manuals 

BE-3, FI-1 

Single  
Package  
Total 

Single  
Package  
Total 

- 
- 
- 
Action plan 
- 
- 
- 
Other 
- 
- 
- 

Single  
Package  
Total  

DE-3, DK-1, EL-1, IT-1, PT-2 
AT-2, BE-2, CY-2, FR-3, PL-3, SI-2 

MT-1 

ES-3*, SK-1**, SE-1*** 
CY-3****, HU-2*****, LV-1****** 

Electronic register/ database 
Advice with respect to the prevention, detection and correction of the most serious irregularities 
Adoption of investigation directives 
Code of conduct  

*  
** 
***  
**** 
*****  Order  
******  Action plan and strategy  

2 
2 

5 
6 
11 

1 

1 

3 
3 
6 

99 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 2 Nature of measures – various sectors  

Sector 
Revenue - Customs  
Revenue - Tax fraud 
Expenditure - Agriculture  

Expenditure - Fisheries 
Expenditure - Cohesion policy 

Expenditure - Centralised direct management 
Expenditure - Fund for the most deprived 
Expenditure - Globalisation Fund 
Expenditure - Migration and asylum 
Expenditure - Recovery and Resilience Facility 

Measures  
EE-2, EL-3, FI-1, HU-2, PT-3, SI-2 
CZ-2, EL-3, HU-3, IE-2, LV-2, RO-1, SI-2  
EL-2, HU-1, HU-2, LT-3, NL-2, PL-3, PT-1, PT-2, RO-2, SK-3, 
SI-1 
HR-1, CZ-3, DK-3, EL-1, HU-1, LT-3, PT-1, PT-2, RO-2 
AT-1, AT-2, BE-3, CZ-3, DE-1, DE-2, DE-3, DK-2, EL-1, FI-2, 
HU-1, IE-1, PT-1, PT-2, RO-2, SI-1 
LT-1, PT-1, RO-2 
HU-1, PT-1, PT-2, RO-2 
PT-1, PT-2, RO-2, 
HU-1, PT-1 PT-2, RO-2, SI-1, 
CY-2, EL-2, HR-2, HU-1, IT-1, IT-2, IT-3, PL-1, PL-2, PT-1, 
PT-2, SK-1, SI-3 

Total 
6 
7 
11 

9 
16 

3 
4 
3 
5 
13 

100 

 
 
 
 
ANNEX 3 Anti-fraud cycle 
Policy cycle  

Administrative  

Legislative  

Operational  

Organisational  

Total 

Fraud prevention  
Single  

Package  

Total  
Fraud detection  
Single  

Package  

Total 

DE-3, DK-1, EL-1, IT-1, MT-
1, PL-2, PT-2, SK-1  

AT-2, BE-2, BE-3, CY-2, CY-
3, ES-3, FI-1, HU-2, LV-1, 
PL-3, SI-2 

8 

AT-1, BG-1, BG-2, CZ-1, ES-1,  
IT-3, LT-1, LT-3, LV-2, PT-1, RO-1, 
RO-3, SI-3  
11  CY-3, ES-2, ES-3,  

HU-1  

13  DE-1, DE-2, EL-3, HR-2, HR-

14 

3, CZ-2, CZ-3, EE-2, EE-3, HR-
1, IT-2, PL-1, PT-3, SI-1 
AT-2, BE-2, BE-3, EL-2, ES-2, 
FI-1, FR-1, FR-2, HU-1, HU-2, 
LV-1, NL-2, SI-2 

13 

27 

4 

17 

EE-1, FI-2, IE-1, LT-2, 
LV-3, LU-1, SK-2, SK-3, 
SE-2 
AT-2, BE-2, CY-2, DK-3, 
FI-1, FR-1, FR-2, HU-1, 
LV-1 

DK-1, IT-1, MT-1, PL-2, PT-
2, SK-1, SE-1,  

AT-2, BE-2, BE-3, CY-2, CY-
3, ES-3, FI-1, FR-3, HU-2, 
LV-1, SI-2 

AT-1, BE-1, BG-1, BG-2, CY-1, CZ-
1, ES-1, IE-2, IT-3, PT-1, RO-1, 
RO-2, RO-3, SI-3,  

14  DE-2, HR-3, CZ-2, DK-2, EE-

12 

2, EL-3, HR-1, HU-3, IT-2, PL-
1, PT-3, SI-1 

EE-1, FI-2, SK-2, SK-3, 
SE-2  

11  CY-3, ES-3, FR-3, HU-1 

AT-2, BE-2, BE-3, EL-2, FI-1, 
FR-1, FR-2, HU-1, HU-2, LV-
1, SI-2 

4 

18 

11 

23 

AT-2, BE-2, CY-2, DK-3, 
FI-1, FR-1, FR-2, HU-1, 
LV-1, NL-1,  

10  36 

19 

7 

18 

6 

Fraud investigation and prosecution 

Single  

DK-1, IT-1, MT-1, PL-2, SK-
1, SE-1 

AT-1, BE-1, BG-3, CY-1, CZ-1, ES-
1, LT-3, RO-1, RO-2, RO-3, SI-3  

11  HR-3, CZ-2, EL-3, FI-1, HU-3, 

6 

EE-1 

PL-1 

Package  

CY-2, ES-3, FI-1, FR-3, LV-1  

5 

ES-3, FR-3, HU-1 

3 

FR-1, FR-2, HU-1, LV-1  

Total 

Recovery and sanction  

Single  

Package  

Total  

IT-1, PL-2, SK-1 

AT-2, CY-2, CY-3, ES-3, 
PL-3 

11 

3 

5 

8 

AT-1, CY-1, ES-1, LT-3, PT-1, RO-
1, RO-3 
CY-3, ES-3 

14 

7 

2 

9 

AT-2 

CY-2, FI-1, FR-1, FR-2, 
HU-1, LV-1, NL-1 

AT-2, CY-2 

4 

10 

0 

1 

1 

9 

44 

9 

37 

18  81 

5 

38 

15  74 

1 

24 

7 

8 

0 

2 

2 

19 

43 

10 

10 

20 

101 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
A N T I - F R AU D  C YC L E  - S I N G L E  
M E A S U R ES   

Recovery and sanction

Fraud investigation and prosecution

Fraud detection

Fraud prevention

0

10

20

30

40

50

A N T I - F R AU D  C YC L E  - PA C K AG E   

Recovery and sanction

Fraud investigation and prosecution

Fraud detection

Fraud prevention

0

5

10

15

20

25

30

35

40

102 

 
 
 
 
A N T I - F R A U D  C YC L E   - A D M I N I S T R AT I V E  
M E A S U R E S  

Recovery and 
sanction 
14%

Fraud 
prevention 
34%

Fraud 
investigation 
and 
prosecution
20%

Fraud 
detection 
32%

A N T I - F R A U D  C YC L E  - L E G I S L AT I V E  
M E A S U R E S  

Recovery and 
sanction 
15%

Fraud 
investigation 
and 
prosecution
24%

Fraud 
prevention 
28%

Fraud 
detection 
33%

A N T I - F R A U D  C YC L E   - O P E R AT I O N A L  
M E A S U R E S  

Recovery and 
sanction 
2%

Fraud 
investigation 
and 
prosecution
16%

Fraud 
detection 
38%

Fraud 
prevention 
44%

A N T I - F R A U D  C YC L E   - O R G A N I S AT I O N A L  
M E A S U R E S

Recovery and 
sanction 
5%

Fraud 
investigation 
and 
prosecution
19%

Fraud 
prevention 
39%

Fraud 
detection 
37%

103 

 
 
 
 
ANNEX 4 Areas reported  
Area 
Public procurement 

Financial crime (including money 
laundering) 
Organised crime 

Corruption 

Conflict of interest 

Fraud definition 

AFCOS 
Whistle-blower 

Customs/ToR/illicit trade 
Shared management and control of EU 
funds 

Anti-fraud or anti-corruption strategy 

Other*** 

*Corruption  

Member States  
AT-2, BG-2, DE-2, HR-2, CY-1, CY-2, CZ-3, EE-3, ES-1, ES-3, 
FR-3, IT-1, IT-2, IT-3, LT-1, LT-2, LV-1, LV-3, PT-1, PT-2, SK-
1, SI-1, SI-3 
AT-1, BG-2, CZ-2, EE-1, ES-1, ES-3, FR-1, FR-3, HU-1, HU-3, 
IT-2, LV-1, NL-1, RO-1, RO-2, SI-3, SE-1 
CZ-2, EE-1, ES-1, ES-3, FI-1, FR-1, FR-2, HU-3, NL-1, SI-3, SE-
1 
DE-2, ES-1, ES-3, FR-3, IT-1, LT-1, LT-2, LV-1, SK-1, SK-2, SI-3 
* 
AT-2, BE-2, BE-3, BG-3, DE-2, ES-1, ES-2, ES-3, HR-2, HR-3, 
CY-1, CY-2, CY-3, EE-1, HU-1, IT-1, IT-2, IT-3, LT-1, LV-1, PL-
1, PT-1, PT-2, SK-1, SK-3, SI-1, SI-3, 
BE-2, BG-1, BG-2, BG-3, CY-1, CY-2, ES-1, FI-1, FR-1, FR-2, 
LV-2, SK-1, SI-1, SI-3 
BG-1, CY-1, CY-2, CZ-3, ES-1, FR-2, HU-1, PT-1, SK-1, SI-3, 
AT-2, BE-1, BE-2, BG-1, BG-2, CY-1, CY-2, CZ-1, EL-3, ES-1, 
HU-1, LV-1, PL-2, SK-1, SI-1 
EE-2, EL-3, ES-1, FI-1, HU-2, NL-1, PT-3 
AT-2, BE-2, BE-3, BG-1, BG-2, DE-1, EL-1, EL-2, ES-1, HR-1, 
HR-3, CY-1, CY-2, CZ-3, EE-3, EL-2, ES-3, FI-1, FI-2, FR-3, HU-
2, IT-1, IT-2, IT-3, LT-3, LV-1, NL-1, NL-2, PL-3, PT-1, SK-1, 
SI-1, SI-2, SI-3, SE-2 
AT-2, BE-2, BE-3, DE-3, DK-1, EL-1, EL-2, ES-1, FR-2, FR-3, 
HU-1,IE-1, IE-2, IT-1, IT-3, LV-1, LU-1, MT-1, PT-1, PT-2**, 
RO-3, SK-1, SI-1, SI-3, SE-1, SE-2 
BG-3, CY-3, DE-2, DK-2, FR-1, FR-2, IT-1, IT-2, IT-3, LV-1,PL-
1, PL-2, SI-1, SI-2, SI-3 

Total  
23 

17 

11 

11 

26 

14 

10 
15 

7 
35 

26 

15 

DE-2: in the public sector (including the political sphere). Measures taken:  

•  Measures to improve the effectiveness of control and audit. For example: smart IT tools, database, risk 

assessment, red flags, mechanisms of warning, audit and other. 

ES-1: Corruption in the public procurement in the public sector (including the political sphere) and private sector. Measures 
taken:  

•  Measures to prevent corruption among personnel, including management. 

ES-3: measures addressing transparency within public procurement. 

•  Measures addressing the transparency of companies participating in public procurement 

FR-3: corruption within public procurement in the public sector (including the political sphere). Measures taken:  

•  Measures to prevent corruption among staff, including management.  

IT: Corruption in the public sector 

LT-1: **corruption in the public sector (including the political sphere). Measures taken in the fight against corruption within 
public procurement: 

•  Measures addressing transparency within public procurement 
•  Measures to improve how effectively public procurement is managed.  
•  Measures to prevent corruption among staff, including management. 
•  Measures to improve the effectiveness of control and audit. 

LT-2: *corruption within public procurement in the public sector (including the political sphere) and private sector. 
Measures taken in the fight against corruption within public procurement:  

•  Measures addressing the transparency of companies participating in public procurement.  

104 

 
 
 
 
LV-1: **Corruption in the public sector (including the political sphere) and private sector. Measures taken include: 

•  Measures addressing transparency within public procurement  
•  Measures to improve how effectively public procurement is managed  
•  Measures to prevent corruption among staff, including management  
•  Measures addressing the transparency of companies participating in public procurement  
•  Measures to improve control and audit effectiveness  

SI-3: CORRUPTION WITHIN PUBLIC PROCUREMENT: in the public sector (including the political sphere) and private sector. 
Measures taken in the fight against corruption within public procurement: 

•  Measures addressing transparency within public procurement 
•  Measures to improve how effectively public procurement is managed 
•  Measures to prevent corruption among staff, including management 
•  Measures addressing the transparency of companies participating in public procurement 
•  Measures to improve control and audit effectiveness 
•  Other: Ministry of Justice – Specific and general preventive effects of the amendment to the definition of ‘official of 
the European Union’ as an official under Article 99(1)(7) of the Criminal Code. The current text states that an official 
under KZ-1 may (also) be a person on whom an international public organisation has conferred the status of official 
and who, in substantive terms, meets the conditions laid down in points 1, 2 or 3 of Article 99(1) KZ-1 (points 1, 2, 
and 3 define an official in the Slovenian system for the purposes of KZ-1). Given that Article 4(a)(i) of Directive (EU) 
2017/1371 defines an official of the European Union [continued under ‘Comment’] 

SK-1: CORRUPTION WITHIN PUBLIC PROCUREMENT in the public sector (including the political sphere). Measures taken in 
the fight against corruption within public procurement:  

•  Measures addressing transparency within public procurement  
•  Measures to improve how effectively public procurement is managed  
•  Measures to prevent corruption among staff, including management 
•  Measures addressing the transparency of companies participating in public procurement 
•  Measures to improve control and audit effectiveness  

SK-2: Corruption within public procurement in the public sector (including the political sphere). Measures taken in the fight 
against corruption within public procurement: 

•  Measures to improve how effectively public procurement is managed  
•  Measures to prevent corruption among staff, including management 

** PT-2: On double funding 

*** Other  

BG-3: Verification of declarations of assets and interests of persons in public positions. 
CY-3: Regularity and transparency measure. 

• 
• 
•  DE-2: Application and authorisation. 

Implementation and audit of operations/clearing of expenditure, payments and certificates. 
Procurement via the MA/intermediate body. 

•  DK-2: Integrity and transparency measures, anti-fraud strategy. 
• 

FR-1: The monitoring unit will bring together all the responsible administrative departments of the Ministry of 
Economic Affairs and Finance, as well as the directorates of the Ministry of the Interior and the overseas 
departments concerned, and specialised judicial investigation services. It will also involve paying agencies and 
judicial bodies. Its initial efforts will focus on energy renovation, which is part of the National Recovery and 
Resilience Plan. 
FR-2: This working group brings together all the actors involved in the management of the funds made available 
to the EU under the RRF and employed by France under the National Recovery and Resilience Plan (NRRP). 
IT-1: With the adoption of the NRRP strategy, the departments responsible for NRRP measures were asked to 
transpose promptly the contents of the new document into their sectoral anti-fraud strategies for the NRRP 
measures within their respective remits. The contents of the document will also be incorporated into the relevant 
operational manuals for the NRRP measures. 

• 

• 

105 

 
 
 
• 

• 

• 
• 

• 

• 

• 

IT-2: * This operational measure aims to improve coordination and cooperation between the various actors 
involved in the implementation of NRRP measures by improving ex ante controls (beneficial owners with potential 
conflicts of interest) and encouraging the flow of information, including notifications of suspicious transactions. 
IT-3: * The measure extends the synergies achieved by the Guardia di Finanza at central government level in 
monitoring NRRP funds down to local level, introducing the possibility of concluding memoranda of 
understanding with the regions, local authorities and other public entities implementing the NRRP. The aim is to 
strengthen monitoring activities, including those to prevent and combat corruption and fraud, and to avoid 
conflicts of interest and the risk of duplicate public funding of activities. 
LV-1: Integrity and transparency measures. 
PL-1: Controls of EU funds implemented under the National Recovery Plan financed by the Recovery and Resilience 
Facility. 
SI-1: * Whistle-blower protection system (internal and external whistle-blowing channels). Instructions for the 
protection of external and internal whistle-blowers have been adopted, including the following: 
https://www.gov.si/zbirke/storitve/prijava-zascitenega-prijavitelja-glede-krsitve- predpisov-v-delovnem-okolju-
ministrstvu-za-kohezijo-in-regionalni-razvoj/ 
SI-2: Training for advanced developers, advanced analysts and other end users and also preparation of sources of 
information and the re-writing of program codes (script). New focuses for results visualisation and reports also 
need to be devised. 
SI-3: Ministry of Justice comment: the measure applies to any offence where an official is specifically identified as 
the perpetrator. 

106 

 
 
 
ANNEX 5 Overview  

MS 

Single  

Type - 1st 
measure  
New/old 

AT 

1 

BE 

1 

BG 

3 

CY 

1 

CZ 

3 

DE 

3 

Leg 

Leg 

Leg 

Leg 

Leg 

Oper 

New 

New 

New 

New 

New 

Upd 

DK 

2 

Admi
n 
New 

EE 

3 

Org 

Upd 

EL 

2 

Admi
n 
Upd 

ES 

1 

FI 

1 

Leg 

Org 

New 

New  

Hor 

Hor 

Sec 

Hor 

Hor 

Sec 

Hor 

Sec 

FR 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

HR 

3 

HU 

1 

IE 

2 

Oper 

Oper 

Org 

New 

New 

Upd 

IT 

3 

Admi
n 
Upd 

LT 

3 

LU 

1 

LV 

2 

Leg 

Org 

Leg 

upd 

Upd 

Upd 

Sec 

Sec 

Oper 

Upd 

Sec 

Oper 

New 

Hor 

X 

X 

X 

X 

X 

Sec 

Leg 

Sec 

Sec 

Hor 

Oper 

Org 

New 

New 

New 

Sec 

X 

X 

X 

Sec 

Leg 

Upd 

Sec 

Hor 

Leg 

Upd/
new 
Sec 

Oper 

Oper 

Oper 

Oper 

Oper 

Upd 

Upd 

New 

New 

New 

Sec 

Sec 

Sec 

Sec 

Sec 

Oper 

New 

Admi
n 
Upd 

Sec 

Sec 

X 

X 

X 

Oper 

Upd 

Hor 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Horiz./sect 

Sec 

Hor 

Type - 2nd 
measure  
New/old 

Horiz./sect 

Type - 3rd 
measure  
New/old 

Horiz./sect 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Hor 

Leg 

New 

Hor 

Leg 

New 

Hor 

Package  

1 

2 

Type – 1st 
measure  

New/old 

Admi
n/ 
Org 

Upd 

Admi
n/ 
Org/ 
Oper 

New 

Horiz./sect 

Sec 

Hor 

Type – 2nd 
measure  

New/Old 

Horiz./sect 

Type – 3rd 
measure 

New/old 

Horiz./sect 

X 

X 

X 

X 

X 

X 

Admi
n/ 
Oper 

New 

Sec 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

2 

Admi
n / 
Org 

New 

Sec 

Leg/A
dmin 

New 

Hor 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

1 

Org 

Upd 

Sec 

X 

X 

X 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Legislative : 18 / Operational: 16 / Administrative: 9 / Organisational: 9  
New: 30 / Update or amendment: 21 / both: 1 
Horizontal: 19 / Sectoral: 33 
x 

X 

1 

3 

2 

x 

x 

1 

2 

Oper 

Leg/ 
Oper 

New 

New 

Admi
n/ 
Org/ 
Oper 

New 

Org/ 
Oper 

New 

Sec 

Hor 

Sec 

Hor 

X 

X 

X 

X 

X 

X 

Leg/ 
Admi
n 

New 

Hor 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Org/ 
Oper  

Upd/
New 
Hor 

Leg/ 
Admi
n 

Upd 

Hor  

X 

X 

X 

X 

X 

X 

X 

X 

Leg/ 
Org/ 
Oper 

Upd/
New 

Sec 

Admi
n/ 
Oper 

Upd/
New 
Sec 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

MT 

1 

Admi
n 
New 

Hor 

X 

X 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

NL 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

2 

Org 

X 

X 

X 

1 

Admi
n 

New 

New 

Hor 

Sec 

Oper 

X 

New 

Sec 

X 

X 

X 

X 

X 

X 

X 

X 

Sec 

Org 

New 

Hor 

X 

X 

X 

1 

Admi
n/ 
Org/ 
Oper 

Upd 

Hor 

X 

X 

X 

X 

X 

X 

PL 

2 

PT 

3 

Oper 

Leg 

RO 

3 

Leg 

Upd 

New 

Upd 

Sec 

Sec 

Admi
n 
Upd 

Admi
n 
Upd 

Sec 

Leg 

52 

SE 

2 

Admi
n  
New 

Hor 

Org 

SI 

2 

Oper 

New 

Sec 

Leg 

SK 

3 

Admi
n 
New 

Sec 

Org 

Upd 

New 

Upd 

New 

Sec 

Sec 

Sec 

Hor 

Sec 

Oper 

Leg 

Upd 

New 

Sec 

Hor 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

1 

Admi
n/ 
Oper 

Upd 

Sec 

X 

X 

X 

X 

X 

X 

20 

 I

n
d
i
v
i
d
u
a

l

a
c
t
i
o
n
s
:
3
9

Hor 

Org 

New 

Sec 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

Total measures  

2 

3 

3 

3 

3 

3 

3 

3 

3 

3 

Legislative: 5 / Operational: 12 / Administrative: 12 / Organisational: 10  
New: 12 / Update or amendment: 5 / both: 3 
Horizontal: 9 / Sectoral: 11 
2 

3 

2 

3 

2 

3 

3 

X 

3 

1 

2 

3 

3 

3 

2 

3 

3 

72 

107