35th annual report on the protection of the European Union’s financial interests and the fight against fraud 2023 : report from the Commission to the Council and the European Parliament.
Date: 2024-08-06
Institutions: European Anti-Fraud Office
Subjects: EU office or agency, European Anti-fraud Office, European Union, action programme, budgetary control, corruption, fight against crime, financial interests of members, fraud, fraud against the EU, fund (EU), public awareness campaign

ISSN 2599-9478 

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

European 
Anti-Fraud Office

Print 

ISBN 978-92-68-15537-0 

ISSN 2599-9443 

doi:10.2784/085640  OB-AE-24-001-EN-C

PDF 

ISBN 978-92-68-15542-4 

ISSN 2599-9478 

doi:10.2784/25027 

OB-AE-24-001-EN-N

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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

Brussels, 25.7.2024 
COM(2024) 318 final

LIST OF ABBREVIATIONS

AFIS

AI

CAFS

CAP

DIAI

EDES

EPPO

ERDF

ESF

EU

Anti-Fraud Information System

Artificial Intelligence

Commission anti-fraud strategy

Common agricultural policy

Hungarian Directorate for Internal Audit and Integrity

Early Detection and Exclusion System

European Public Prosecutor’s Office

European Regional and Development Fund

European Social Fund

European Union

FEAD

Fund for European Aid to the Most Deprived

IMS

IPA

JCO

NAFS

OLAF

PIF

Irregularity Management System

Instrument for Pre-Accession

Joint Customs Operation

National Anti-Fraud Strategies

European Anti-Fraud Office

Protection of financial interests

PFIU audits

Audits on the protection of the financial interests of the Union

RRF

RRP

TFEU

TOR

UAFP

VAT

Recovery and Resilience Facility

National Recovery and resilience plan

Treaty on the Functioning of the European Union 

Traditional own resources

Union Anti-Fraud Programme

Value Added Tax

TABLE OF CONTENT

Executive summary ...........................................................................................................................................................5

1.  Introduction ....................................................................................................................................................................6

1.1.  The EU’s financial interests and their protection ................................................................................................................... 6

1.2.  Data sources ................................................................................................................................................................................................ 6

2.  Key measures at EU level .........................................................................................................................................9

2.1.  Financial Regulation recast ................................................................................................................................................................. 9

2.2.  Implementation of national recovery and resilience plans .............................................................................................. 9

2.3.  The Whistleblower Protection Directive – state of transposition ............................................................................... 10

2.4.  Revision of the action plan accompanying the Commission anti-fraud strategy ............................................ 10

2.5.  EU anti-corruption package .............................................................................................................................................................. 11

2.5.1.  Directive on combating corruption by criminal law ........................................................................................................ 11

2.5.2.  Communication on the fight against corruption .............................................................................................................. 11

2.5.3.  Expanding the Common Foreign and Security Policy sanctions toolbox to cover serious 

acts of corruption ............................................................................................................................................................................... 11

2.6.  The EU anti-fraud programme ........................................................................................................................................................12

2.7.  The European Parliament’s resolution on the 2022 PIF Report ..................................................................................12

2.8.  Anti-money laundering and counter-terrorist financing ..................................................................................................13

3.  Member States’ measures to protect the EU’s financial interests .....................................................14

3.1.  National anti-fraud strategies ........................................................................................................................................................14

3.2.  Anti-fraud measures adopted at national level ....................................................................................................................15

3.3.  Implementation of the 2022 Commission recommendations to Member States ............................................17

3.3.1.  Improving the detection, reporting and follow-up of suspected fraud ..............................................................17

3.3.2.  The digitalisation of the fight against fraud at Member State level ...................................................................17

3.3.3.  Strengthening anti-fraud governance in the Member States ..................................................................................18

4.  Combating irregularities, fraud, corruption and conflicts of interest detrimental 

to the EU budget .........................................................................................................................................................19

4.1.  General overview .....................................................................................................................................................................................19

4.1.1. 

Investigations by OLAF ................................................................................................................................................................... 20

4.1.2.  Investigations by the EPPO .......................................................................................................................................................... 20

4.2.  Revenue – traditional own resources ..........................................................................................................................................21

4.3.  Expenditure ................................................................................................................................................................................................ 22

4.3.1.  Agriculture .............................................................................................................................................................................................. 22

4.3.2.  Cohesion policy.................................................................................................................................................................................... 24

4.3.3.  Other budgetary areas ................................................................................................................................................................... 26

4.4.  Organised crime, corruption and conflicts of interest ...................................................................................................... 26

3

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20235.  Conclusions and recommendations .................................................................................................................. 28

5.1.  Building anti-fraud knowledge on complete, reliable and up-to-date data ....................................................... 28

5.2.  Better tools: accelerating the digitalisation of the fight against fraud ................................................................. 29

5.3.  Developing the governance of the anti-fraud architecture .......................................................................................... 29

LIST OF FIGURES

Figure 1 – Similarities and differences between the data sources used in this report ....................8

Figure 2 – Overview of national anti-fraud strategies covering all expenditure sectors  ............14

Figure 3 – Overview of other anti-fraud strategies reported by Member States 

without a national anti-fraud strategy covering all expenditure sectors ..................... 15

Figure 4 – Summary of measures reported by Member States in 2023 .............................................. 15

Figure 5 – Mapping the anti-fraud networks ..................................................................................................... 18

Figure 6 – Reported irregularities and related financial amounts – 2019-2023; 

irregularities and related financial amounts by budgetary area – 2023 .......................19

Figure 7 – Irregularities detected and reported in TOR and detection by type of control ............21

Figure 8 – Reported irregularities in CAP by type of expenditure and duration of 

irregularities (from beginning of irregular behaviour to closure of the case)............. 23

Figure 9 – Focus on the programming period 2014-2020 –irregularities reported by 

fund and typology  ................................................................................................................................... 24

4

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023Executive summary

In  line  with  the  obligation  laid  down  in  Article  325(5)  of  the  Treaty  on  the  Functioning 
of the European Union (TFEU), each year the European Commission, in cooperation with 
the EU Member States, submits a report (the Protection of Financial Interests Report/PIF 
Report) to the European Parliament and the Council on the measures taken to implement 
the Article. On the basis of the report, the European Parliament adopts its annual motion 
for a resolution on the protection of the EU’s financial interests and the fight against fraud.

The 2023 PIF Report highlights measures at EU and national level aimed at strengthening 
the protection of the EU’s financial interests.

By  the  end  of  2023,  a  political  agreement  was  reached  on  the  proposed  recast  of  the 
Financial  Regulation  to  strengthen  the  protection  of  the  EU’s  financial  interests.  The 
agreed  text  extends  the  scope  of  the  Early  Detection  and  Exclusion  System  to  include 
shared management. It also introduces the legal basis for a modernised data mining and 
risk scoring tool to be built on the existing tool called Arachne.

As spending linked to the implementation of the national recovery and resilience plans 
grows, the Commission is increasing its audit activities into the regularity and legality of 
spending and the protection of the EU’s financial interests. The revision of the national 
plans has also been an opportunity to reassess the adequacy and robustness of Member 
States’ control systems and include additional requirements where needed. 

The Commission adopted a package of anti-corruption measures, including a proposal for 
a Directive on combating corruption. The ambitious proposal aims to step up the prevention 
of  corruption  in  all  Member  States,  harmonise  corruption  offences  and  sanctions,  and 
ensure that law enforcement and prosecution authorities have the tools they need to fight 
corruption.

As the Commission’s 2019 anti-fraud strategy action plan had been fully implemented, in 
2023 the Commission adopted a new action plan focused on seven themes, among which 
the digitalisation of the fight against fraud.

The  EU’s  anti-fraud  programme  concluded  its  third  year  of  implementation,  financing 
initiatives  throughout  the  EU  to  strengthen  the  fight  against  fraud  and  supporting  the 
maintenance  and  development  of  IT  tools.  These  provide  administrative  assistance  to 
customs and support the reporting of irregularities.

In  2023,  21  out  of  27  Member  States  indicated  that  they  have  an  anti-fraud  strategy 
in place for the protection of the EU’s financial interests. The approach taken by the 21 
Member States varied widely, with 10 countries adopting a national anti-fraud strategy 
and the others relying on other types of strategies (sectoral, regional, programme-related).

Member States are also following the Commission’s recommendations to strengthen their 
anti-fraud governance and keep the digitalisation of the fight against fraud high on their 
agenda. Attention to this key aspect in the fight against fraud is also witnessed by the 
increasing number of measures adopted at national level.

The key indicators on detected fraud and irregularities remain in line with previous years, 
as  do  the  main  issues  identified,  for  example  in  relation  to  the  follow-up  of  suspected 
fraud. The Commission therefore reiterates the recommendations issued in the PIF Report 
2022. This will also ensure a continuous monitoring of measures adopted in relation to the 
strengthening of anti-fraud governance, digitalisation of the fight against fraud and the 
improvements linked to detection, reporting and follow-up of suspected fraud.

5

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20231.  Introduction

1.1.  The EU’s financial interests and their protection

The EU’s 2023 budget amounts to around EUR 186.6 billion in commitment appropriations 
and EUR 168.6 billion in payment appropriations. This represents an increase of +1.1% 
in  commitments  and  +1%  in  payments  compared  to  the  2022  budget.  The  2021-2027 
multiannual  financial  framework  amounts  to  EUR  1  074.3  billion.  Additional  resources 
come  from  NextGeneration  EU,  the  EU’s  post-COVID  economic  recovery  package.  It 
provides for EUR 750 billion to be spent between 2021 and 2026.

By  means  of  these  resources,  the  EU  finances  its  policies  and  promotes  its  aims  and 
values.

EU  Member  States  manage  the  largest  share  of  EU  expenditure  and  collect  VAT  and 
traditional own resources (TOR – mainly customs duties).

In accordance with Article 325 TFEU, the EU and its Member States must counter fraud 
and any other illegal activities that affect the EU’s financial interests1. In line with Article 
325(5)  TFEU,  each  year  the  Commission,  in  cooperation  with  the  EU  Member  States, 
submits a report to the European Parliament and the Council on the measures taken to 
implement the Article. This report, also known as the PIF Report, meets that obligation for 
2023. It is accompanied by seven working documents2. 

Section  2  of  the  report  focuses  on  measures  at  EU  level,  while  Section  3  covers  the 
measures taken at national level. Section 4 presents data and the main analytical findings 
on  the  fight  against  fraud,  corruption,  conflicts  of  interest  and  other  irregularities  that 
affect the EU budget. Section 5 provides conclusions and recommendations.

1.2.  Data sources

Section  3  of  this  report  relies  on  information  provided  by  the  Member  States  through 
dedicated questionnaires. Section 4 is based on irregularities detected and reported by 
the Member States3 (Sections 4.2 and 4.3), by the beneficiary countries of pre-accession 
assistance4  (Section  4.3.3)  and  on  recovery  orders  extracted  from  the  Commission 
accounting system, ABAC (direct management, Section 4.3.3). 

Sectoral  regulations  on  traditional  own  resources,  shared  management  funds  and  pre-
accession instruments specify the conditions under which Member States and beneficiary 
countries of pre-accession assistance must report irregularities detected in those areas. 
The reporting of irregularities is subject to certain limitations5.

1 

2 

3 

4 

5 

Article 310(6) TFEU.

This PIF Report is accompanied by seven Commission staff working documents:
a)  National anti-fraud strategies (NAFS) state of play and assessment;
b)  Measures adopted by Member States to protect the EU’s financial interests in 2023;
c) 

Follow-up on recommendations to the Commission report on the protection of the EU’s financial 
interests and the fight against fraud – 2022;

d)  Statistical evaluation of irregularities reported for own resources, natural resources, cohesion policy, 

pre-accession assistance and direct expenditure in 2023;
Implementation of the action plan accompanying the Commission anti-fraud strategy (CAFS);
Early Detection and Exclusion System (EDES) – Panel referred to in Article 143 of the Financial Regulation;

e) 
f) 
g)  Annual overview with information on the results of the Union anti-fraud programme in 2023.

See, in particular, Box 2 of the 2021 PIF Report, Section 6.1, p. 31.

Reported to the Commission via the Irregularity Management System (IMS).

For a description of these limitations, see Box 3 in the 2021 PIF Report , Section 6.1, p. 32.

6

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023Two  broad  categories  are  used  in  this  report  for  cases  reported  by  the  Member 
States  and  beneficiary  countries:  fraudulent  irregularities6  and  non-fraudulent 
irregularities7.

Section 4.1.1 summarises the main administrative investigative results of the European 
Anti-Fraud Office in 2023, taken from its annual report. The OLAF 2023 Annual Report8 
covers in particular all investigations closed in the reporting year.

Section 4.1.2 summarises the main judicial investigative results of the European Public 
Prosecutor’s Office (EPPO) in 2023, taken from its annual report. The EPPO 2023 Annual 
Report9 presents among others statistics on the investigations launched in the reporting 
year10 as well as on all investigations ongoing at the end of the reporting year11. 

The  data  sources  have  some  significant  underlying  differences  in  nature,  scope, 
budgetary areas covered and timelines12. 

The PIF Report primarily takes a single year approach, presenting irregularities reported 
in the reporting year, and shows the amounts calculated and reported by the Member 
States as the financial impact of the irregularities detected13.

The  following  table  summarises  the  main  differences  between  the  three  main  data 
sources.

6 

7 

8 

9 

Fraudulent irregularities are those for which the reporting country provided the classification of fraud in 
traditional own resources, suspected fraud or established fraud in relation to shared management and 
pre-accession.

All irregularities that have not been classified as fraudulent are considered as non-fraudulent.

https://ec.europa.eu/olaf-report/2023/index_en.html

https://www.eppo.europa.eu/sites/default/files/2024-03/EPPO_Annual_Report_2023.pdf 

10  Total number of investigations and estimated financial damage, number of VAT fraud investigations and 

related estimated financial damage.

11  These statistics are provided in the form of aggregated data on all ongoing investigations, including 

those initiated in previous years and not yet closed. They cover, among others, the number of offences 
investigated, broken down by type, and the number of investigations broken down by expenditure 
programme. Other aggregated statistics on the EPPO’s activities refer to the judicial activities and the 
number of complaints or reports received from national authorities.

12  The reporting workflow from the Member States and, ultimately, the availability of complete data 

for the preparation of this report depend heavily on information from the authorities detecting and 
investigating the irregularity or fraud. Reporting bodies in the Member States (mainly managing 
authorities or paying agencies in shared management and customs authorities in relation to traditional 
own resources) may report about criminal investigations only when the relevant judicial or law 
enforcement authorities provide them with the authorisation and the necessary information. This 
implies that while the EPPO, OLAF or national law enforcement are actively investigating a case, 
bodies responsible for reporting irregularities and fraud to the Commission might not be in the position 
to do so in certain cases because of the possible confidentiality of investigations. In such cases, 
this information will only become available when the investigation is completed and is therefore not 
included in the PIF Report until such time. 

13  These financial amounts to a large extent tend to be those for which recovery is effectively pursued.

7

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023FIGURE 1 – SIMILARITIES AND DIFFERENCES BETWEEN THE DATA SOURCES USED 
IN THIS REPORT

PIF Report

OLAF Report

EPPO Report

Scope

Specific to the activities of a single body

Fraudulent irregularities

Non-fraudulent irregularities

Territorial scope

EPPO participating Member States

Non-EPPO Member States

Non-EU countries

Budgetary area

Shared management

Customs fraud (non-VAT)

Indirect management (pre-accession)

Direct management (not RRF)

Direct management (RRF)

VAT fraud

Data sources

Direct (c)

Indirect (d)

Timeline

Year-to-year (e)

Aggregated (f)

No

Yes

Yes

Yes

Yes

Yes (b)

Yes

Yes

Yes

Yes

No

No

Partial

Yes

Yes

Partial

Yes

Yes (a)

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

No

Yes

Yes (a)

Yes (a)

Yes

Yes

Yes (a)

Yes

Yes

Yes

Yes

No

Yes

Partial

Partial

Yes

(a)  Within the limits of its mandate.
(b)  Limited to countries benefitting from pre-accession assistance
(c)  Direct data source means that the report refers to cases directly investigated by the reporting body. Data 

(d) 

on cases detected by the Commission is only a limited part of the data set used in the PIF Report.
Indirect data source implies that data reported come from a different data source. In the case of the PIF 
Report, the Commission uses data about irregularities (fraudulent and non-fraudulent) reported by national 
authorities of Member States and Candidate Countries.

(e)  The EPPO report shows information on the data referred to in the reporting year (opened investigations, 

freezing orders granted) as well as aggregated data (active investigations).

(f)  Aggregated data (usually the last 5 years) for the PIF Report are available in the staff working document 

‘Statistical evaluation of reported irregularities’, but not in the report itself. 
- The OLAF report provides aggregated data on some types of information, mainly referring to the last 5 years. 
- The EPPO report provides aggregated data when referring to active investigations.

8

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
 
 
 
 
 
 
 
 
 
2.  Key measures at EU level

This section focuses on the main developments in key policy and legislative initiatives at 
EU level to protect the EU’s financial interests. It is not an exhaustive list.

2.1.  Financial Regulation recast

Protection of the EU’s financial interests has been strengthened by political agreement on 
recasting the Financial Regulation of 7 December 2023. The amendments made to the 
Early Detection and Exclusion System (EDES) and the introduction of the legal basis for 
a risk scoring and data mining tool, as well as changes to the transparency system, are 
meant to address and improve fraud detection and prevention and the fight against fraud. 

First,  in  relation  to  the  EDES,  the  co-legislators  agreed  to  extend  its  scope  for  the 
most  serious  offences  (e.g.  fraud,  corruption,  money  laundering  activities)  to  shared 
management funds and funds disbursed under direct management with Member States. 
The amendment will be in force for programmes adopted or financed as from 1 January 
2028.  In  addition,  the  new  Financial  Regulation  will  bring  more  improvements  to  the 
system,  including  (i)  the  possibility  to  exclude  beneficial  owners  and  affiliated  entities 
of a primary excluded entity; (ii) new  grounds  of  exclusion  (e.g.  refusal to  cooperate  in 
investigations, checks or audits carried out by EU investigative bodies); (iii) the introduction 
of an expedited procedure before the EDES Panel.

The recast of the Financial Regulation also introduced the legal basis for a modernised 
data mining and risk scoring tool to be built on the existing tool called Arachne. The current 
tool is used by the Commission and a number of Member States on a voluntary basis in 
shared management and for the Recovery and Resilience Facility (RRF). The modernised 
data  mining  and  risk  scoring  tool  will  be  used  in  all  management  modes.  All  Member 
States will be required to feed the tool with data as from the next multiannual financial 
framework.  The  Commission  must  assess  the  readiness  of  the  revised  tool  by  2027  in 
terms  of  interoperability  with  other  IT  systems  and  databases  (avoiding  duplication  of 
reporting), risk indicators targeted to user needs, AI for analysing and interpreting data, 
and data protection. On that basis, the possibility of compulsory use may be discussed 
again by the co-legislators.

To  reduce  the  administrative  burden  for  the  Member  States  and  for  all  entities  that 
implement the EU budget, the Financial Regulation recast also introduced an element of 
interoperability and harmonised the data categories that will be extracted from the data 
mining and risk scoring tool into the Commission Financial Transparency System.

2.2.  Implementation of national recovery and resilience plans

In  2023,  alongside  RRF  implementation,  an  additional  priority  for  the  Commission  was 
the revision of the 27 recovery and resilience national plans (RRPs) to accommodate the 
changed circumstances resulting from energy market disruptions caused by Russia’s war 
of aggression against Ukraine. With the addition of REPowerEU chapters to the RRPs, the 
EU aims to rapidly reduce its dependence on Russian fossil fuels by accelerating the clean 
energy transition. 

In  2023,  the  Commission  disbursed  22  payments  to  Member  States  for  a  total  of  EUR 
74.4 billion (EUR 28.7 billion in loans). This brings the total disbursements to EUR 220.5 
billion  by  the  end  of  2023,  divided  into  141.6  billion  in  grants  (40%  of  the  total  RRF 
envelope of EUR 357 billion) and EUR 78.9 billion in loans (27% of the total RRF envelope 
of EUR 291 billion).

Since  the  start  of  the  RRF,  the  Commission  has  created  a  robust  audit  and  control 
framework  based  on  two  pillars.  The  first  pillar  ensures  the  regularity  and  legality  of 
spending. The second pillar deals with the protection of the EU’s financial interests (PFIU 

9

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023audits). According to Article 22(1) of the RRF Regulation, it is primarily the responsibility of 
the Member States to protect the EU’s financial interests and ensure that the use of funds 
in relation to measures supported by the RRF complies with applicable EU and national 
law. The Commission should receive reasonable assurance from Member States on this.

Benefiting from the findings and recommendations of Commission auditors (including from 
the Internal Audit Service), the European Court of Auditors and the European Parliament, 
the Commission strengthened its audit and control framework by verifying how Member 
States’ control systems ensure compliance with EU and national rules. RRP revisions have 
also been an opportunity to reassess the adequacy and robustness of Member States’ 
control  systems  and  include  additional  requirements  in  the  plans  where  needed  in  the 
form  of  new  audit  and  control  milestones.  The  disbursement  of  EU  funds  can  only  be 
authorised if such milestones are fulfilled satisfactorily.

In 2023, the Commission carried out 13 PFIU system audits14. They covered 12 coordinating 
bodies and 58 implementing bodies, such as ministries or agencies. By the end of 2023, all 
Member States had been audited at least once. 

Based  on  the  system  audit  work  carried  out  in  2023,  Member  States  have  started  to 
implement  the  necessary  improvements  stemming  from  audit  findings  in  the  audited 
implementing bodies but also in other relevant bodies.

In 2023, the Commission informed OLAF about 15 cases of potential fraud.

2.3.  The Whistleblower Protection Directive – state of 

transposition15

By the end of 2023, 24 Member States16 had adopted national legislation to transpose the 
Directive and declared their transposition complete. 

The  Commission  will  publish  in  July  2024  a  report  on  the  compliance  of  the  national 
measures  with  the  Directive,  to  assess  whether  the  Directive’s  provisions  have  been 
transposed completely and correctly and highlight the main shortcomings identified.

SNAPSHOT 1 – NATIONAL MEASURES TO TRANSPOSE THE DIRECTIVE17

The document ‘Measures adopted by the Member States’ that accompanies this report describes the specific 
measures adopted by five Member States18 to better protect whistleblowers. Previous PIF reports19 have already 
emphasised the key role that whistleblowers can play in boosting fraud detection, investigation and prosecution. 
This can have positive effects also on other stages of the anti-fraud cycle (prevention, recovery, etc).

2.4.  Revision of the action plan accompanying the Commission 

anti-fraud strategy

The  current  Commission  anti-fraud  strategy  (CAFS),  adopted  in  2019,  seeks  to  further 
improve the prevention, detection and sanctioning of fraud and frames the Commission’s 
ongoing efforts to decrease the level of fraud committed against the EU budget. As its 
accompanying  action  plan  was  implemented  by  2022,  the  Commission  adopted  a  new 
action plan in July 202320.

14  Austria, Belgium, Croatia, France, Germany, Hungary, Italy, Luxembourg, Netherlands, Portugal, Romania, 

Slovakia, and Sweden.

15  Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law, OJ L 305, p. 17.

16  All Member States but Belgium, Estonia and Poland.

17  Other measures for the transposition of the Directive reported by five Member States – Belgium, Cyprus, 

France, Greece and Romania – are described in the document Measures adopted by the Member States to 
protect the EU’s financial interests, accompanying the PIF Report 2022.

18  Belgium, Bulgaria, Czechia, Poland and Spain.

19  See Section 4.4 of the PIF Report 2022 and Recommendation 2 (p. 28) of the PIF Report 2017.

20  COM(2023) 405 final and SWD(2023) 245 final.

10

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023The new action plan includes 44 actions under seven themes that cover the Commission’s 
priorities in fighting fraud. With digitalisation as the plan’s first theme, a quarter of the 
actions focus on improving the Commission’s and Member States’ use of IT tools for anti-
fraud  purposes,  for  example  Arachne,  EDES  and  the  Irregularity  Management  System 
(IMS). The plan also provides for increased cooperation within the Commission and with 
key external partners and civil society to protect EU funding. Other themes include the 
RRF,  customs  fraud  and  further  strengthening  the  ethics  and  anti-fraud  culture  in  the 
Commission.

Implementation of the action plan is ongoing21.

2.5.  EU anti-corruption package

2.5.1. Directive on combating corruption by criminal law

In her 2022 State of the Union address, the President of the Commission announced that 
the  Commission  will  update  its  legislative  framework  for  fighting  corruption  ‘by  raising 
standards  on  offences  such  as  illicit  enrichment,  trafficking  in  influence  and  abuse  of 
power, beyond the more classic offences such as bribery’. Delivering on that commitment, 
the Commission adopted a package of anti-corruption measures in May 2023, including 
a proposal for a Directive on combating corruption22. The ambitious proposal aims to step 
up the prevention of corruption in all Member States, harmonise corruption offences and 
sanctions, and ensure that law enforcement and prosecution authorities have the tools 
they need to fight corruption. 

2.5.2. Communication on the fight against corruption

In  a  Joint  Communication23,  the  Commission  and  the  High  Representative  of  the  Union 
for Foreign Affairs and Security Policy brought together existing work and developed new 
directions and tools at both EU and Member State level to prevent and fight corruption, 
also feeding into a clear commitment to tackling corruption at global level. It established 
an EU network against corruption, bringing together law enforcement, public authorities, 
practitioners, civil society and other stakeholders to act as a catalyst to prevent corruption 
across the EU, create synergies for cooperation and develop best practices and practical 
guidance in areas of common interest. A first meeting took place in September 202324. 
OLAF, Eurojust, Europol and the European Public Prosecutor’s Office (EPPO) are all members 
of  the  network.  One  key  task  of  the  network  will  be  to  help  the  Commission  identify 
common areas where corruption risks are high across the EU. This outcome will be 
a building block for a future EU anti-corruption strategy.

Within the EU institutions there is zero tolerance of corruption. The Communication details 
the  ethical,  integrity  and  transparency  rules  in  place  to  prevent  corruption  within  the 
institutions.

2.5.3. Expanding the Common Foreign and Security Policy sanctions 

toolbox to cover serious acts of corruption

EU sanctions help to achieve key Common Foreign and Security Policy objectives such as 
preserving peace, strengthening international security, and consolidating and supporting 
democracy, international law and human rights. With the proposal, the EU will be able 
to target serious acts of corruption worldwide, no matter where they occur. It will 
complement and strengthen the EU’s internal and external instruments against corruption 
and show the EU’s determination to use any tools, including sanctions, to fight it. 

21  For a complete overview of the state of implementation of the actions, see ‘Commission Anti-Fraud 

Strategy (CAFS) action plan state-of-play May 2024’ accompanying this report.

22  COM (2023) 234 final.

23  JOIN(2023) 12 final of 3 May 2023.

24  EU network against corruption - European Commission (europa.eu).

11

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20232.6.  The EU anti-fraud programme

The EU anti-fraud programme (UAFP), with a budget of EUR 181 million for 2021-2027, 
provides  financial  support  for  (i)  the  protection  of  the  EU’s  financial  interests  by  its 
Member States; (ii) the organisation of mutual administrative assistance and cooperation 
in customs and agricultural matters (Anti-Fraud Information System – AFIS); and (iii) the 
development and maintenance of IMS for the reporting of irregularities by Member States.

The 2023 Financing Decision allocated EUR 16.1 million to the Hercule component, EUR 
8.4 million to the AFIS component and about EUR 1 million to the IMS component. The 
available  funds  were  successfully  implemented  in  2023  using  the  various  financing 
instruments available.

In 2023, OLAF received its first association request from a non-EU country, Ukraine, in 
relation to the UAFP. An association agreement covering the participation of Ukraine in the 
programme has been negotiated between the Commission (represented by OLAF) and the 
relevant authorities of Ukraine (adopted in March 2024). 

OLAF launched an interim evaluation of the programme in 2023, to be finalised by the 
end  of  2024.  It  is  being  carried  out  with  the  support  of  an  external  contractor,  who  is 
undertaking  an  independent  evaluation  study.  The  results  should  provide  valuable 
input on the programme’s efficiency, effectiveness and relevance, and indicate areas of 
improvement for the remaining programming period.

2.7.  The European Parliament’s resolution on the 2022 PIF Report

On 18 January 2024, the European Parliament adopted its resolution on the protection 
of the EU’s financial interests for 202225.

The Parliament welcomed the actions taken by the Commission in 2022 to improve the 
level  of  protection  of  the  EU’s  financial  interests,  but  called  for  further  vigilance  and 
complementary  actions  in  this  field.  The  resolution  maintains  that  digitalisation  has 
boosted  the  prevention  and  detection  of  fraud,  simplified  administrative  procedures 
and that it needs to be at the heart of every anti-fraud strategy, including the national 
anti-fraud strategies (NAFS). 

It emphasised that EDES has considerable potential for flagging people and companies 
that misuse EU funds and called for the system to be extended to all types of budget 
management modes, in particular shared management. 

The Parliament urged the Commission to improve its rate of recovering funds unduly 
spent and strengthen its control of the use of funds under NextGenerationEU. In addition, 
it expressed its belief that funds under the Global Europe: Neighbourhood, Development 
and International Cooperation Instrument for assistance to non-EU countries and the 
resources  allocated  for  the  EU’s  response  to  the  war  in  Ukraine  are  not  adequately 
monitored and controlled. 

Furthermore,  the  Parliament  recommended  the  suspension  of  budgetary  support  to 
non-EU  countries,  including  candidate  countries,  where  the  authorities  clearly  fail  to 
take  genuine  action  against  widespread  corruption,  while  ensuring  that  assistance 
reaches the civil population through alternative channels.

25  Procedure file 2023/2045(INI).

12

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023SNAPSHOT 2 – COMMISSION’S RESPONSE TO THE EUROPEAN PARLIAMENT RESOLUTION

The Commission is fully committed to continuing its efforts on the swift recovery of misused funds. 
The protection of the EU’s financial interests and sound implementation of the RRF remains a core priority for 
the Commission, which increased the number of audits conducted in 2023 and will further increase them in 
202426. Regulation (EU) 2023/435 requires Member States to publish twice per year information on the 100 final 
recipients receiving the highest amounts of RRF funding and, as required by the RRF Regulation, Member States 
are obliged to collect data on the contractors and subcontractors. Data on beneficial owners are collected and 
stored for audit and control purposes. 
The targeted revision of the Financial Regulation, on which political agreement was reached in January 2024, 
aims to increase the efficiency and quality of controls and audits with the help of digitalisation and emerging 
technologies. 
The fight against corruption is a major priority in pre-accession negotiations, with an embedded conditionality 
framework and a focus on capacity building. Programmes can be suspended and funds decommitted when 
deemed necessary.

2.8.  Anti-money laundering and counter-terrorist financing

Fraud against the EU budget may also be a predicate offense to money laundering and 
terrorist financing and a precursor to other crimes. Thus, even if not directly linked to the 
protection of the EU budget, the EU legal framework on anti-money laundering (AML) and 
counter-terrorist  financing27  is  highly  relevant  in  this  context.  With  the  recent  adoption 
of  the  ambitious  legislative  package28,  the  Commission  continues  to  reinforce  the 
implementation of the AML policy framework and strives to establish good cooperation 
and exchanges of information with the upcoming AML authority29. AMLA is expected to 
become operational mid-2025.

26  See Section 2.2.

27  Anti-money laundering and countering the financing of terrorism at EU level - European Commission 
(europa.eu). At the moment of the preparation of this report all Member States have reported full 
transposition of the fifth anti-money laundering directive (EU Directive 2018/843) on the prevention of the 
use of the financial system for the purposes of money laundering or terrorist financing.

28  Anti-money laundering and countering the financing of terrorism legislative package - European 

Commission (europa.eu).

29  AMLA - European Commission (europa.eu).

13

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20233.  Member States’ measures 

to protect the EU’s financial 
interests

3.1.  National anti-fraud strategies

In 2023, 21 out of 27 Member States indicated that they have an anti-fraud strategy in 
place for the protection of the EU’s financial interests30. The approach taken by the 21 
Member States varied widely.

Ten Member States indicated they have a NAFS that covers all expenditure sectors31. They 
were not asked to elaborate on other anti-fraud strategies in place with a more limited 
scope.

FIGURE 2 – OVERVIEW OF NATIONAL ANTI-FRAUD STRATEGIES COVERING ALL 
EXPENDITURE SECTORS 

AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IT LT LU LV MT NL PL PT RO SE SI SK

On the question of possible preparation of a NAFS, out of the 17 Member States who do 
not have one covering all expenditure sectors, 3 Member States32 are in the preliminary 
stage of adopting one, i.e. establishment of the legal framework, 133 is in the preparatory 
phase, i.e. state of play and fraud risk assessment, and 4 Member States34 declared not 
having  a  national  anti-fraud  strategy  nor  an  ongoing  procedure  for  adopting  one.  The 
remaining 935 have other anti-fraud strategies in place.

30  The information was gathered via a dedicated questionnaire. See the document ‘Measures adopted by the 

Member States to implement Article 325 TFEU’ accompanying this report.

31  For a detailed analysis of the anti-fraud strategies, see ‘National Anti-Fraud Strategies (NAFS): state of 

play and assessment’ accompanying this report.

32  Denmark, Lithuania, Netherlands.

33  Luxembourg.

34  Croatia, Ireland, Slovenia, Sweden. 

35  Austria, Belgium, Cyprus, Estonia, Finland, Germany, Greece, Poland and Spain.

MS
NAFS (all sectors)
Planned adoption

YES
NO

14

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023FIGURE 3 – OVERVIEW OF OTHER ANTI-FRAUD STRATEGIES REPORTED BY 
MEMBER STATES WITHOUT A NATIONAL ANTI-FRAUD STRATEGY COVERING ALL 
EXPENDITURE SECTORS

AT  BE CY DE DK EE EL ES FI HR IE LT LU NL PL SE SI

Other AFS

Regional

Sectoral national

Sectoral regional

Anti-corruption 

Authority level

Programme level

Other 

Sectors covered

Cohesion 

Agriculture

Fisheries 

Customs

VAT 

RRF

Other shared management funds

Other 

3.2.  Anti-fraud measures adopted at national level

Member States reported a total of 69 measures. Among the measures adopted, 49 were 
single measures and the other 20 were a package of individual measures. These packages 
consisted  of  39  actions.  This  means  that  a  total  of  88  individual  measures  were 
reported by Member States, comprising 41 new measures and 44 updates/amendments. 
In addition, 3 package measures contained both new and updated measures.

FIGURE 4 – SUMMARY OF MEASURES REPORTED BY MEMBER STATES IN 2023

Member State

Austria

Belgium

Bulgaria

Croatia

Measures adopted

Two measures related to cohesion policy. The first aims to facilitate the exchange of information between the money 
laundering reporting unit and relevant national and foreign authorities, as well as with Europol. The second strengthens 
checks on expenditure submitted by beneficiaries.

Three measures, two of which are of a cross-cutting nature (adoption of the legislation to protect whistleblowers and the 
Walloon policy to combat cross-cutting fraud) and one related to the use of Arachne as part of their European Regional 
Development Fund (ERDF), European Social Fund (ESF) and RRF programmes.

Three legislative measures on the management of irregularities, the protection of whistleblowers and creation of a new anti-
corruption commission.

Three measures: two dedicated to shared management (introduction of a new IT tool for the monitoring of the European 
Maritime and Fisheries Fund (EMFF) and anti-fraud training by OLAF) and one to the RRF.

15

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023Member State

Measures adopted

Cyprus

Czechia

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Ireland

Italy

Latvia

Two legislative and one administrative measures. They cover the establishment of a national coordinating body for combating 
fraud affecting the EU’s financial interests, the monitoring of RRP implementation and implementation of the ‘Lobbying Law’.

Three measures on the protection of whistleblowers, the fight against VAT fraud, and the fight against corruption and fraud in 
EU funds.

Two measures relate to anti-fraud strategies, one covering the national RRP and the second the fisheries policy. The third 
measure concerns the introduction of a new IT tool for the management of payments in cohesion policy.

The three measures concern the strengthening of the investigative capacity into corruption and economic crimes of the 
Estonian Police and Border Guard; the launch of a new information system in the area of customs; and some improvements 
to the national e-procurement platform.

Two measures: one on a customs project focused on food fraud, and the second related to anti-fraud training in the area of 
cohesion policy

Three measures: two provide for the setting up of an inter-ministerial monitoring unit to tackle public aid fraud and a working 
group to analyse emerging fraud in relation to the RRF; the third establishes a system of financial liability for public managers 
and the development of relations between the judicial authority and the financial courts.

As Germany is a federal state, anti-fraud measures are often taken at regional level. Three such measures were reported on 
the deployment of fraud risk assessment tools in Berlin, Saxony and Schleswig-Holstein.

The first measure integrates procedures on preventing and combating fraud into the management and control system of 
cohesion policy; the second concerns the introduction of the IT tool Arachne in relation to the common agricultural policy; and 
the third describes the launching of an IT platform to collect complaints from citizens in the area of customs and tax fraud.

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.

Two measures on the ESF+ programme and the fight against e-commerce VAT fraud.

The three measures concern the RRP: an anti-fraud strategy, improving the IT tool for monitoring and implementing the plan; 
and strengthening the investigative role of the economic and financial police in relation to the RRF.

Three measures: the first, of a cross-cutting nature, concerns anti-corruption; the second focuses on VAT fraud in vehicle 
trade; and the third deals with public procurement.

Lithuania

Three measures, two of which focus on public procurement and address related issues of conflicts of interest and corruption, 
and one that approves a methodology for the application of sanctions in relation to agricultural and fisheries policies.

Luxembourg

An organisational measure related to the preparatory work for the adoption of the national anti-fraud strategy.

Malta

Training programmes for national officials in the area of anti-corruption.

Netherlands

Two measures on reporting suspected fraud to the EPPO and checks on actual land use.

Two measures deal with the RRP: the adoption of guidelines on controls and the whistleblowers policy. The third measure 
concerns the adoption of guidelines on procedures for granting and disbursing financial aid in the common agricultural policy 
(CAP).

Three measures: an update of its NAFS; a training activity for managing authorities on fraud risk assessment; and the 
strengthening of systematic risk analysis in customs.

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

Three measures: the first provides a reference document on the measures to protect the RRF funds from serious irregularities; 
the second concerns the establishment of the anti-corruption board and its policy; and the third relates to guidelines to fight 
conflicts of interest in the CAP. 

Two sets of measures, the first aimed at strengthening controls in the CAP, and the second on the deployment of an IT 
platform in customs. The third measure concerns the correction of the transposition into national law of the PIF Directive.

The three measures focus on whistleblower protection and the protection of the resources allocated to Spain from the RRF.

Two measures, both aim to explore ways to improve information exchange and cooperation between national administrations.

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

16

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20233.3.  Implementation of the 2022 Commission recommendations 

to Member States

In its 2022 PIF Report, the Commission made three recommendations to Member States: 
a) the improvement of detection, reporting and follow-up of suspected fraud; b) the need 
to digitalise the fight against fraud; and c) the reinforcement of anti-fraud governance in 
the Member States36.

3.3.1. Improving the detection, reporting and follow-up of suspected 

fraud

Most  Member  States37  assess  their  country  as  having  a  low  incidence  of  fraud.  As  it 
remains hard to determine whether low levels of reported fraud accurately represent the 
success of certain anti-fraud measures, it is crucial that Member States continue to detect 
and  report  fraud,  while  developing  measures  and  tools  to  prevent  it.  Several  Member 
States38 indicate that they have conducted a fraud risk analysis to assess the reasons for 
low detection of suspected fraud.

While half of the Member States that analysed their low level of fraud identified weaknesses 
in fraud detection, most of them stated that successful interventions to prevent fraud are 
ensured  when  a  multi-stakeholder  and  multilevel  approach  is  in  place.  This  facilitates 
cooperation among all domestic, national and international players involved. 

Within this cooperation, it is important that certain core principles are respected: 

  a  clear  distribution  of  responsibilities  between  audit  and  control  bodies  within  the 

Member States;

  regular administrative and on-the-spot checks to keep the levels of incidence of fraud low; 

  continued reporting to the Commission via the IMS, to the EPPO as well as to national 
audit and control bodies of the Member States; these comparative data can then be 
used to assess the level of incidence of fraud; 

  initiatives that facilitate knowledge sharing and best practices, as well as benchmarking 
the  performance  of  Member  States,  while  acknowledging  the  varying  sizes,  specific 
situations etc. (as indicated by some Member States39);

  training  courses,  guidelines  and  workshops  to  keep  the  performance  and  quality  of 

performance high;

  internal  mechanisms  to  prevent  fraud  are  ensured  within  the  various  bodies,  e.g.  by 

taking measures such as the four-eyes principle within all institutions.

3.3.2. The digitalisation of the fight against fraud at Member State 

level

The case for digitalising the fight against fraud has been made in recent PIF reports, and 
progress is being made at Member State level. 

Among the measures implemented, Member States have indicated an inventory of existing 
tools, the maintenance of interoperability between these tools and the development of 
new tools for the IT architecture. Many Member States continue to invest in the revision 
and development of existing IT tools, in particular the data mining and risk scoring tool 

36  For a complete overview and detailed description of the follow-up actions summarised in this section, see 

‘Implementation of the 2022 recommendations by the Member States’ accompanying this report.

37  Austria, Belgium, Bulgaria, Croatia, Czechia, Denmark, Finland, Germany, Greece, Hungary, Ireland, Latvia, 

Lithuania, Malta, Netherlands, Portugal, Slovakia and Spain.

38  Austria, Belgium, Bulgaria, Croatia, Czechia, Finland, Germany, Greece, Hungary, Latvia, Lithuania, Malta, 

Netherlands, Portugal, Spain and Slovenia.

39  Estonia, Greece and Italy.

17

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023Arachne.  As  several  Member  States  have  just  started  implementing  their  NAFS,  it  is 
recommended to integrate IT tools from an early stage.

Over  half  of  the  Member  States40  have  reportedly  taken  steps  to  identify  and  address 
skills  gaps  in  digitalisation,  mostly  referring  to  a  lack  of  information  and/or  access  to 
data on digitalisation. Measures to address these gaps often involve knowledge sharing, 
training, and broadening of know-how and skills in the field of digitalisation, as well as 
continued development of the available systems.

However, developments in the area of new technologies also pose potential threats when 
it comes to fighting fraud. While over half of the Member States41 have acknowledged this 
issue, there are still several among them42 that have not yet integrated these concepts as 
part of their anti-fraud strategies. A few Member States43 have already fully implemented 
measures  to  identify  and  address  the  threats  posed  by  new  technologies,  but  most 
Member States44 have only implemented some measures.

3.3.3. Strengthening anti-fraud governance in the Member States

Most  Member  States45  have  an  anti-fraud  cooperation  network  in  place  or  under 
development. These networks consist of many different bodies. According to the survey, the 
following agencies are most commonly represented in the national anti-fraud networks: 
EU  fund  managing  authorities,  tax  administration  authorities,  customs  authorities, 
national audit authorities and law enforcement authorities. Figure 5 shows the various 
agencies that are represented (and how often they are included) within the national anti-
fraud  network.  Additionally,  almost  all  Member  States  actively  cooperate  with  EU-level 
investigative, prosecution and judicial and bodies, in particular with OLAF and the EPPO.

FIGURE 5 – MAPPING THE ANTI-FRAUD NETWORKS

21

20

19

18

18

13

12

12

8

7

7

6

4

4

2

Law enforcement authority
Dedicated anti-corruption agency
Judicial authority
Public procurement authority
Tax administration authority
EU fund managing authority
Competition authority
National audit authority
Custom authority
National security agency/ intelligence body
Conﬂict of interest agency
Border control authority
Dedicated anti-organized crime agency

Anti-counterfeit authority

Food/health authority

9

Other

Most  Member  States46  have  sufficient  staff  in  their  national  anti-fraud  coordinating 
structure. However, the majority of the Member States point out that there is a need to 
improve staff’s expertise level.

40  Austria, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, 

Italy, Latvia, Malta, Poland, Portugal, Romania, Slovenia, Slovakia, Spain and Sweden.

41  Austria, Belgium, Bulgaria, Denmark, Estonia, France, Greece, Hungary, Italy, Latvia, Lithuania, Malta, 

Portugal, Slovenia, Slovakia and Spain.

42  Croatia, Cyprus, Czechia, Finland, Germany, Netherlands, Poland, Romania, Sweden.

43  Germany, Italy, Poland, Romania.

44  Austria, Belgium, Bulgaria, Czechia, Denmark, Estonia, Finland, France, Hungary, Latvia, Lithuania, Portugal, 

Slovenia, Spain and Sweden.

45  Austria, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, 
Italy, Latvia, Malta, Poland, Portugal, Romania, Slovenia, Slovakia, Spain and Sweden. In development: 
Belgium, Ireland, Lithuania and Netherlands.

46  Adequately staffed with necessary expertise: Austria, Bulgaria, Czechia, Denmark, Germany, Greece, 

Hungary, Italy and Slovenia. Staffing needs improvement: Cyprus, Estonia, Finland, France, Latvia, Malta, 
Netherlands, Poland, Portugal, Romania, Slovakia, Spain and Sweden.

18

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20234.  Combating irregularities, fraud, 
corruption and conflicts of 
interest detrimental to the 
EU budget

4.1.  General overview

From  an  operational  point  of  view,  protecting  the  EU’s  financial  interests  from  fraud, 
irregularities and other illicit activities is entrusted to national authorities, OLAF and the 
EPPO.

A total of 13 563 fraudulent and non-fraudulent irregularities, amounting to EUR 1.90 
billion, were reported47 in 2023. There has been a slight increase in reported irregularities 
compared to 2022 (+2.3%) and in the related irregular amounts (+4.6%).

The number of fraudulent irregularities reported by national authorities to the Commission 
via the IMS has remained relatively stable over the last 5 years and amounted to 1 030 in 
2023 (-9.5% compared to 2022). The financial amounts linked to these cases have varied 
more due to a limited number of individual cases with high financial impact, and increased 
to EUR 585.8 million in 2023 (+103% compared to 2022) . 

The number and financial impact of the reported non-fraudulent irregularities peaked in 
2023 following a growing trend over the last 5 years, with 12 533 irregularities (+3.5% 
compared to 2022) involving a financial amount of EUR 1.31 billion (-14%).

FIGURE 6 – REPORTED IRREGULARITIES AND RELATED FINANCIAL AMOUNTS – 
2019-2023; IRREGULARITIES AND RELATED FINANCIAL AMOUNTS BY BUDGETARY 
AREA – 2023

Irregularities reported and related ﬁnancial amounts - 2019-2023 

s
e
s
a
c

f
o

°
N

16 000

14 000

12 000

10 000

8  000

6  000

4  000

2  000

 0

2019

2020

2021

Year

2022

2023

Fra udulent -  Irregular amounts (in EUR million)

Non-fraudulent  - Irregular amou nts (in EUR million)

Fra udulent -  Sum o f  cases

Non-fraudulent  - Sum  of cases

Number of reported irregularities by sector - 2023 

47 

Irregularities were reported by the Member States and non-EU countries in IMS in relation to expenditure 
and in OWNRES in relation to TOR. Irregularities related to direct management are extracted from the 
Commission accounting system ABAC.

5 210

4 212

2 948

Irregular ﬁnancial amounts by sector (in EUR million) - 2023 

2  500

2  000

s
n
o

i
l
l
i

M

1  500

1  000

 500

 0

s
t
n
u
o
m
a

l

r
a
u
g
e
r
r
I

892

257

4
4

19

1 064

489

53

27

20

Agriculture

Cohesion and ﬁsheries

Direct management

Internal policies

Pre-accession and Neighbourhood

Traditional Own Resources

250

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
s

e

s

a

c

f

o

°

N

16 000

14 000

12 000

10 000

8  000

6  000

4  000

2  000

 0

Irregularities reported and related ﬁnancial amounts - 2019-2023 

2019

2020

2021

Year

2022

2023

Fra udulent -  Irregular amounts (in EUR million)

Non-fraudulent  - Irregular amou nts (in EUR million)

Fra udulent -  Sum o f  cases

Non-fraudulent  - Sum  of cases

Number of reported irregularities by sector - 2023 

5 210

4 212

2 948

Irregular ﬁnancial amounts by sector (in EUR million) - 2023 

2  500

2  000

s

n

o

i

l

l

i

M

1  500

1  000

 500

 0

s

t

n

u

o

m

a

r

a

l

u

g

e

r

r

I

892

257

4
4

1 064

489

53

27

20

Agriculture

Cohesion and ﬁsheries

Direct management

Internal policies

Pre-accession and Neighbourhood

Traditional Own Resources

250

4.1.1. Investigations by OLAF

In 2023 OLAF concluded investigations into 265 cases, issuing 309 recommendations, of 
which 185 financial, for a total recommended amount for recovery of EUR 1 043.8 million 
and EUR 209.4 million prevented from being unduly spent48. Over the same period 190 
new investigations were opened, of which 26 (14%) were related to own resources and 
2 (1%) to illicit trade, 85 (45%) to shared management and the RRF, 23 (12%) to indirect 
management, and 39 (21%) to direct management. 18 (9%) investigations were opened 
in relation to internal matters49.

OLAF  investigated  allegations  and  instances  of  collusion,  manipulation  of  procurement 
procedures, conflicts of interest, inflated invoices, evasion of customs duties, smuggling 
and  counterfeiting.  One  emerging  trend,  which  was  very  visible  in  2023,  is  the  use  of 
administrative violations, preferably in artificially created cross-border situations, with the 
aim to defraud the EU budget without being detected. A trend that continued to grow in 
2023 was complex frauds taking place online and across multiple jurisdictions.

4.1.2. Investigations by the EPPO

In 2023, the EPPO opened 1 371 investigations corresponding to estimated damages of 
EUR 12.28 billion50. At the end of 2023, the EPPO had 1 927 active investigations involving 
an  estimated  damage  of  EUR  19.27  billion,  of  which  almost  60%  (EUR  11.50  billion) 
was linked to 339 VAT-related investigations. In terms of the EU’s financial interests at 
stake,  only  a  small  share  (0.3%)  of  the  VAT-related  financial  amounts  belongs  to  the 
EU  budget51.  1  349  investigations  involved  cases  of  expenditure  fraud  with  estimated 
financial damage of EUR 7.24 billion. Of these, 233 investigations refer to recovery and 
resilience programmes, with an estimated financial damage of EUR 1.86 billion.

Among the typologies identified in these active investigations, 1 486 offences (33.9% of the 
total) relate to non-procurement expenditure fraud, 379 (8.6%) to procurement expenditure 

48  The data reported in this section are included in the OLAF Annual Report 2023.

49  The sum of the investigations opened per budgetary area is higher than the total number of investigations 

opened in 2023 (190), as an investigation can cover more than one sector.

50  The data reported in this section are included in the EPPO Annual Report 2023.

51  For the period 2021-2027, a uniform call rate of 0.3% is being applied on each Member State’s VAT base.

20

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
fraud,  131  (3%)  to  corruption,  72  (1.6%)  to  misappropriation,  226  (5.2%)  to  money 
laundering, 405 (9.2%) to non-VAT revenue fraud and 873 (19.9%) to VAT revenue fraud.

4.2.  Revenue – traditional own resources52

In  2023,  the  number  of  fraudulent  and  non-fraudulent  irregularities  (5  118) 
relating to traditional own resources (TOR) was 10% higher than the average number of 
irregularities reported in the past 5 years. However, the total estimated and established 
amount  involved  decreased  by  12%  to  EUR  478  million.  The  number  of  fraudulent 
irregularities declined by 27%, while the number of non-fraudulent irregularities increased 
by  15%  compared  to  the  5-year  average  for  2019-2023.  The  related  estimated  and 
established amount involved decreased by 54% for fraudulent cases and by less than 1% 
for non-fraudulent cases compared to the 5-year period.

Smuggling  remains  one  of  the  main  modus  operandi  for  fraudulent  cases,  while  the 
most common type for non-fraudulent cases is incorrect classification/misdescription of 
goods. In monetary terms, most cases reported in 2023 relate to the incorrect value 
of goods (1 157 cases amounting to EUR 165 million involved). Textiles and footwear 
continue to be the most affected goods in terms of number of cases and value. China, 
the  United  States  and  Vietnam  remain  the  top  three  countries  of  origin  of  goods 
affected by irregularities.

FIGURE 7 – IRREGULARITIES DETECTED AND REPORTED IN TOR AND DETECTION 
BY TYPE OF CONTROL

TOR - irregularities reported as fraudulent and related ﬁnancial amounts - 2019-2023 

2019

2020

2021

2022

2023

TOR - irregularities reported as non-fraudulent and related ﬁnancial amounts - 2019-2023 

s
e
s
a
c

f
o

°
N

s
e
s
a
c

f
o

°
N

600
500
400
300
200
100
0

6 000

5 000

4 000

3 000

2 000

1 000

 0

s
t
n
u
o
m
a

l

r
a
u
g
e
r
r
I

s
t
n
u
o
m
a

l

r
a
u
g
e
r
r
I

s
e
n
o

l
l
i

M

250

200
150

100

50

0

s
e
n
o

l
l
i

M

800
700
600
500
400
300
200
100
0

2019

2020

2021

Year

2022

2023

  Estimated and established amount (in EUR million)

   Number of cases

Fraudulent irregularities detected by type of control - 2023 

Non-fraudulent irregularities detected by type of control - 2023 

140

104

9

76

8

3

2 095

1 133

618

244

585

103

Release controls

Post-release controls

Inspections by anti-fraud services

Tax audit

Voluntary admission

Other

52  For a detailed analysis of irregularities reported by the Member States in relation to TOR, see ‘Statistical 
evaluation of irregularities reported for own resources, natural resources, cohesion policy, pre-accession 
assistance and direct expenditure in 2023’ accompanying this report, Section 2.

21

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
 
 
 
SNAPSHOT 3 – DETECTING FRAUD AND IRREGULARITIES IN TOR

Release for free circulation remains the customs procedure most affected by irregularities (4 236 cases 
with an overall estimated and established amount of EUR 397 million, which translates, whether fraudulent or 
non-fraudulent, into 83% of all cases and amounts reported for 2023).
In 2023, inspections by national anti-fraud services (41% of cases and 61% of amounts) together with 
customs release controls and post-release controls played a crucial role in detecting fraudulent cases. Non-
fraudulent instances were primarily detected by post-release controls (44% of cases with 34% of amounts), 
although other methods of detection, such as release controls and tax audits, were also successful.

Thirteen  Member  States  reported  87  cases  of  smuggled  cigarettes,  with  nearly 
EUR 13 million of the estimated amount of TOR involved. In 2023, the highest number 
of cases was reported by Lithuania (23), and the highest amount of TOR was reported 
by Belgium (EUR 3.8 million in total). Compared to 2022, 11 Member States53 continue 
to have smuggling cases, whereas two54 reappear in the statistics. This might indicate a 
potential shift in fraud or cigarette smuggling routes to other Member States.

SNAPSHOT 4 – JOINT CUSTOMS OPERATIONS

Joint Customs Operations (JCOs) are targeted actions of a limited duration aimed at combating fraud and 
the smuggling of sensitive goods in specific areas at risk and/or on identified trade routes. In 2023, 13 
JCOs were co-organised or supported by OLAF covering a broad spectrum of targets: from the fight against 
tobacco smuggling, illegal waste shipments, counterfeit and substandard oncological medicines and hormonal 
substances, counterfeit food and beverages, counterfeit and/or hazardous toys to the detection of goods 
undervaluation and the smuggling of protected species55 of wild fauna and flora56.

4.3.  Expenditure

This section covers the areas of shared, indirect and direct management expenditure. 
The first two are based on the analysis of fraudulent and non-fraudulent irregularities 
reported  via  IMS  and  the  latter  on  data  extracted  from  the  Commission  accounting 
system ABAC.

4.3.1. Agriculture57

During the period 2019-2023, irregularities (both fraudulent and non-fraudulent) reported 
by the Member States in rural development increased, mainly due to rising detections 
during the programming period 2014-2020. The fraudulent irregularities under support 
to agriculture peaked in 2022, when the number was influenced by one Member State 
that reported many small interlinked cases. The irregular financial amounts involved in 
non-fraudulent  irregularities  fluctuated  significantly,  mainly  because  of  cases  involving 
high amounts for market measures.

Detection rates for rural development were much higher than for support to agriculture. 
However, one part of support to agriculture, market measures, accounted for the highest 
detection rates. The detection of irregularities, especially fraud, was concentrated in a few 
Member States.

53  Belgium, Bulgaria, Estonia, Greece, Spain, France, Croatia, Latvia, Lithuania, Poland and Romania.

54  Slovakia and Finland.

55  Under the Convention on International Trade in Endangered Species of Wild Fauna and Flora.

56  See OLAF Annual Report 2023. 

57  For a detailed analysis of irregularities reported by the Member States in relation to agriculture, see 

‘Statistical evaluation of irregularities reported for own resources, natural resources, cohesion policy, 
pre-accession assistance and direct expenditure in 2023’ accompanying this report, Section 3.

22

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023During  the  period  2019-2023,  fraudulent  irregularities  often  involved  falsification  of 
the aid request or of documentary proof. For market measures and rural development, 
violations  concerning  the  implementation  of  the  action  were  also  significant,  thus 
confirming patterns and risks already highlighted in previous reports58.

FIGURE 8 – REPORTED IRREGULARITIES IN CAP BY TYPE OF EXPENDITURE59 AND 
DURATION OF IRREGULARITIES (FROM BEGINNING OF IRREGULAR BEHAVIOUR TO 
CLOSURE OF THE CASE) 

FDR and IDR by type  
of expenditure - 2018-2022

FDR

Type of expenditure

IDR

0.02%

0.13%

0.11%

0.05%

Direct payments

Intervention in 
agricultural markets

Rural development

Total CAP

0.05%

0.30%

0.71%

0.33%

Average time from beginning of  
irregular behaviour to case closure

Fraudulent irregularities:  
8 years and 7 months

Non-fraudulent irregularities:  
5 years and 11 months

450

400

350

300

250

200

150

100

50

0

4.000

3.500

3.000

2.500

2.000

1.500

1.000

500

0

Fraudulent irregularities

2019

2020

2021

2022

2023

Non-fraudulent irregularities

2019

2020

2021

2022

2023

Support to agriculture (SA)

Rural development (RD)

SA/RD

TOTAL EU27

SNAPSHOT 5 – DETECTING FRAUD AND IRREGULARITIES IN THE COMMON AGRICULTURAL 
POLICY

Detection rates for rural development were much higher than for support to agriculture. However, one part 
of support to agriculture – market measures – accounted for the highest detection rates. The detection of 
irregularities, especially fraud, was concentrated in a few Member States.
During 2019-2023, risk analysis still only marginally contributed to detecting fraud in rural development 
and direct payments to farmers, while it seems to have played a more significant role in market measures (but 
only if scrutiny activities were actually based on risk analysis). Also the share of fraud detections based on 
tips from informants and whistleblowers was low, with the exception of market measures, where it reached 
11%. However, this figure may be volatile as it is based on very few cases. Fraud was never detected following 
information published in the media.
For 10% of the irregularities reported during 2014-2023, there was a suspicion of fraud (incidence 
of fraud). For just 16% of the irregularities with a suspicion of fraud, the suspicion was then confirmed as 
established fraud, and for 11% the suspicion was dismissed. There are significant differences between 
Member States and these are subject to ongoing examination.

58  See snapshot 3 in Section 4.3.1 of the PIF Report 2022.

59  The Fraud Detection Rate (FDR) is calculated as the percentage of financial irregular amounts linked to 

fraudulent irregularities on the total payments. The Irregularity Detection Rate (IDR) is calculated as the 
percentage of financial irregular amounts linked to non-fraudulent irregularities on the total payments.

23

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
4.3.2. Cohesion policy60

The  number  and  financial  amounts  of  non-fraudulent  irregularities  that  have  been 
reported for the programming period 2014-2020 are much lower than those reported 
during  the  first  10  years  of  implementation  of  the  programming  period  2007-2013.  It 
concerns all funds and most of the Member States61. It is much smaller, but a gap has 
been recently emerging also for the number of irregularities reported as fraudulent.

FIGURE 9 – FOCUS ON THE PROGRAMMING PERIOD 2014-2020 –IRREGULARITIES 
REPORTED BY FUND AND TYPOLOGY 

Types of irregularities detected during the programming period 2014-2020 as % of total (*)

Programming period 2014-2020: 
reported irregularities by Fund

Programming period 2014-2020: 
irregularities reported 2019-2023

Fraudulent

3%

7%

30%

CF

ERDF

ESF

EMFF

Non-Fraudulent

6%

9%

24%

Fraudulent irregularities

s
e
s
a
c

f
o

°
N

250

200

150

100

50

0

60%

2019

2020

2021

Year

EMFF

ESF

2022

2023

TOTAL EU27

CF

ERDF

Non-Fraudulent irregularities

s
e
s
a
c

f
o

°
N

3 000

2 500

2 000

1 500

1 000

500

0

50%

2019

2020

2022

2023

2021

Year

60  For a detailed analysis of irregularities reported by the Member States in relation to cohesion policy, see 
‘Statistical evaluation of irregularities reported for own resources, natural resources, cohesion policy, pre-
accession assistance and direct expenditure in 2023’ accompanying this report, Section 4.

61  An in-depth analysis of this trend was published in the 2021 PIF Report, snapshot 17, p. 38.

20%

24

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
 
Detected in 
non-fraudulent 
irregulariites (%)

13.0%

29.9%

35.8%

1.1%

7.3%

1.7%

3.1%

4.6%

2.1%

0.2%

0.7%

1.5%

0.1%

10.3%

2.2%

Detected in 
fraudulnet 
irregularities (%)

41.5% 

21.0% 

13.8% 

13.1% 

7.4% 

9.4% 

5.9% 

5.5% 

2.7% 

1.4% 

0.9% 

0.7% 

0.1% 

10.4% 

1.6% 

Categories of irregularities

Incorrect, missing, false or falsified supporting documents

Infringement of contract provisions/rules

Infringement of public procurement rules

Ethics and integrity

Eligibility / Legitimacy of expenditure/measure

Infringements concerning the request

Violations/breaches by the operator

Incorrect, absent, falsified accounts

Product, species and/or land

Multiple financing

Bankruptcy

State aid

Movement

Other

blank

(*)  The sum will not correspond to 100%, because one irregularity can refer to more than one category

On  fraud,  the  most  frequent  type  of  violations  involved  supporting  documents. 
High  financial  amounts  were  involved  in  fraudulent  irregularities  where  infringements 
of  contract  provisions/rules  took  place,  which  often  consisted  of  incomplete 
implementation  or  non-implementation  of  the  funded  action.  Infringements  of  public 
procurement rules were the most reported non-fraudulent irregularities. In relation to 
the number of infringements detected in relation to public procurement, the percentage 
of fraudulent cases is low (4%).

Most of the fradulent violations against ethics and integrity were related to conflicts of 
interest (about 70%), while about 23% involved corruption/bribery62.

SNAPSHOT 6 – DETECTING FRAUD AND IRREGULARITIES IN COHESION POLICY

During 2019-2023, risk analysis still only marginally contributed to detecting fraud, while civil society 
(including tips from informants, whistleblowers or information published in the media) played an increased 
role overall compared with the previous 5 years. In relation to non-fraudulent irregularities, neither risk 
analysis nor information from civil society played a noticeable role in detection.
The Fraud Detection Rate63 for the programming period 2014-2020 was 0.53%, which is similar to the 
programming period 2007-2013. The Irregularity Detection Rate64 was 0.67%, which is much lower than 
the rate recorded for the programming period 2007-2013 (2.5%). There are significant differences between 
Member States and these are subject to ongoing examination.

62  See also Section 4.4.

63  See footnote 59.

64  See footnote 59.

25

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.3.3. Other budgetary areas65

A  number  of  funds,  implemented  under  shared  management,  support  other  internal 
policies,  such  as  the  Youth  Employment  Initiative66,  the  Fund  for  European  Aid  to  the 
Most Deprived (FEAD), the Internal Security Fund, the European Globalisation Adjustment 
Fund, and the Asylum, Migration and Integration Fund. Over the 2014-2020 multiannual 
financial framework, 289 irregularities (of which 33 were reported as fraudulent) were 
reported,  involving  EUR  52  million  of  irregular  amounts  (of  which  EUR  8.2  million  was 
linked to fraudulent irregularities, mostly affecting FEAD). Of these, 44 irregularities were 
reported in 2023, for a total irregular amount of EUR 19.71 million.

The  Instrument  for  Pre-Accession  Assistance  (IPA)  is  the  means  by  which  the  EU 
has been supporting reforms in the enlargement region through financial and technical 
assistance  since  2007.  Irregularities  reported  by  the  beneficiary  countries  during  the 
period  2019-2023  in  relation  to  pre-accession  mainly  involved  funds  distributed  under 
the 2007-2013 Instrument for Pre-accession Assistance I (IPA I) and the 2014-2020 IPA 
II.  In  2023,  the  financial  amounts  involved  in  fraudulent  irregularities  peaked  at  about 
EUR  19  million,  mainly  due  to  one  irregularity  reported  from  Turkey  in  relation  to  the 
regional development component. The number of reported non-fraudulent irregularities 
significantly increased in 2022 and remained high in 202367. Overall, during the period 
2019-2023 half of the reported irregularities involved less than EUR 10 00068.

SNAPSHOT 7 – AREAS AT RISK IN PRE-ACCESSION

A majority of the irregularities (more than 70%) in IPA II relate to the rural development component. 
Fraudulent irregularities mainly relate to the falsification of supporting documents or accounts. For this 
component, they mainly involve projects for the production of honey and agricultural plants. In relation to 
non-fraudulent irregularities, projects related to the acquisition of equipment (e.g. tractors) frequently recur.
Fraudulent irregularities in other components mainly refer to projects that support civil society or transport.

Irregularities, both fraudulent and non-fraudulent, related to expenditure disbursed under 
direct management remained fairly stable over the period 2019-2023. More than 88% 
of the irregularities identified as potentially fraudulent were detected following OLAF 
investigations.

4.4.  Organised crime, corruption and conflicts of interest

Information  on  organised  crime  activity  against  the  financial  interests  of  the  EU  is 
available in the EPPO’s Annual Report. It indicated 209 investigated offences concerning 
PIF-focused criminal organisations in its active investigations up to the end of 2023.

65  For a detailed analysis of irregularities reported by the Member States in relation to pre-accession and 
direct management, see ‘Statistical evaluation of irregularities reported for own resources, natural 
resources, cohesion policy, pre-accession assistance and direct expenditure in 2023’ accompanying this 
report, Sections 5 and 6.

66  Under the multiannual financial framework 2021-2027, the initiative is part of the European Structural and 

Investment Funds.

67 

In the PIF Report 2022, a total financial amount of EUR 79.70 million was reported as affected by 
irregularities. This amount was largely due to irregularities reported by Albania for a total irregular amount 
of EUR 33.53 million. This amount, however, was the result of some reporting mistakes by the Albanian 
authorities linked to the incorrect use of national currencies rather than the euro. The revised irregular 
amount reported by Albania for 2022 is EUR 2.89 million.

68  While the threshold for reporting in shared management is EUR 10 000, for pre-accession there is no threshold.

26

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023In relation to corruption cases, the EPPO reported 131 investigated offences69 up to the 
end of 2023. Over the years 2019-2023, 65 cases were reported to the Commission via 
IMS by 11 countries, with 6 relating to agriculture, 56 to cohesion and 3 to pre-accession. 
The reported irregular amounts linked to such cases come to about EUR 50.5 million.

Over  the  same  period,  419  cases  related  to  conflicts  of  interest  were  reported  via 
IMS  (85%  referred  to  cohesion,  7%  to  agriculture  and  8%  to  pre-accession)  involving 
approximately EUR 112 million. The analysis of such irregularities reveals that reported 
conflicts of interest mainly concern relations between recipients of the funds and their 
contractors and sub-contractors, based on specific infringements of national rules.

69  Representing 3% of the offences investigated by the EPPO. See Section 4.1.2. 

27

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20235.  Conclusions and 
recommendations

The  EU  budget  is  used  to  finance  and  deliver  on  the  EU  policy  priorities.  By  pooling 
resources and standing together against common challenges the EU faces, the EU budget 
creates value added, strengthens Europe’s economy and its geopolitical standing.

In recent years, the EU budget has become an even stronger expression of solidarity by 
serving  as  the  EU’s  main  crisis  response  tool.  It  helps  address  the  biggest  challenges 
facing the EU, including the coronavirus pandemic, the war in Ukraine, addressing climate 
change and building Europe’s strategic autonomy, and ensuring energy independence.

Protecting these resources from fraud and irregularities ensures that they reach their full 
potential and achieve their intended goals. 

To  achieve  this  goal,  the  EU  has  developed  a  complex  and  sophisticated  anti-fraud 
architecture  over  time,  with  several  layers  of  protection,  at  national  and  EU  level.  The 
continuous  action  taken  by  control  and  investigative  bodies,  both  at  EU  and  national 
level,  has  led  to  the  detection  and  prosecution  of  a  significant  number  of  attempts  to 
defraud the EU budget. However, the repressive aspect of the fight against fraud is only 
one side of the coin, and the Commission has constantly underlined the importance of 
fraud prevention.

As  the  fraud  landscape  constantly  evolves  and  new  challenges  emerge,  the  response 
needs  to  adapt  continuously.  Pivotal  in  this  respect  are  three  elements:  anti-fraud 
knowledge, tools and governance structures.

5.1.  Building anti-fraud knowledge on complete, reliable and 

up-to-date data

In  previous  reports,  the  Commission  has  repeatedly  highlighted  the  need  for  complete, 
reliable  and  timely  data  on  fraud  and  irregularities.  This  information  is  at  the  basis  of 
the knowledge necessary to fight fraud more effectively and, ultimately, improve fraud 
prevention,  detection,  investigation  and  prosecution.  Even  though  data  quality  is 
constantly  improving,  the  analysis  conducted  this  year  shows  once  more  that  further 
action is needed. As highlighted in Section 1.2, investigations into fraud by EU bodies 
can only be reported when the required information is shared with the relevant national 
authorities.  Some  of  the  EPPO’s  and  OLAF’s  cases  are  already  included  in  the  figures 
detailed in this report. The Commission is working to ensure that the reporting systems 
can duly capture all necessary information to identify cases investigated by them. When 
this information becomes fully available, it will be possible to assess whether there is a 
change in the trends linked to fraud detection or if they are consistent and in line with the 
anti-fraud results of national investigative authorities reported over the years. 

RECOMMENDATION 1 – IMPROVING THE REPORTING AND FOLLOW-
UP OF SUSPECTED FRAUD

The reporting and follow-up of suspected fraud can still be significantly improved. 
Member States should ensure that reported cases of suspected fraud are updated 
in a timely manner with reliable and complete information and data. To this end, 
establishing  appropriate  communication  channels  with  law  enforcement  and 
prosecution  services;  and  exchanging  information  with  investigative  bodies  and 
timely reporting are prerequisites to effective follow-up.

Complete reporting also implies that national authorities report irregularities and 
fraud  detected  by  Commission  audit  services,  the  European  Court  of  Auditors, 
OLAF and the EPPO as soon as the necessary information becomes available.

28

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 20235.2.  Better tools: accelerating the digitalisation of the fight 

against fraud

The digitalisation of the fight against fraud is one of the key themes of the revised action 
plan accompanying the CAFS. Through this and previous PIF reports, the Commission has 
provided information about EU and national measures to digitalise the fight against fraud, 
showing  that  there  is  positive  momentum  to  ensure  that  the  fight  against  fraud  keeps 
pace with the latest technological developments. 

Nonetheless, this process now needs to accelerate, and the development of new or existing 
IT tools should be matched with their increased use to target fraud more efficiently in all 
areas  of  the  budget  implemented  by  the  Member  States.  In  parallel,  the  Commission 
will  continue  implementing  of  the  dedicated  measures  in  the  revised  action  plan  that 
accompanies the CAFS.

RECOMMENDATION 2 – ACCELERATING THE DIGITALISATION OF THE 
FIGHT AGAINST FRAUD

Digitalisation  of  the  fight  against  fraud  needs  to  be  at  the  heart  of  anti-fraud 
strategies. As fraudsters increasingly use and exploit new technologies to commit 
crime, the EU anti-fraud architecture must be equal to the challenge to prevent, 
detect and investigate it. 

Member States should ensure that the digitalisation of the fight against fraud is 
part of their strategic approach to fighting fraud.

Member  States  should  begin  their  preparations  for  the  next  phase  in  the 
development of the Commission’s risk scoring and data mining tool. All Member 
States  will  be  required  to  feed  the  tool  with  data  as  of  the  next  multiannual 
financial  framework.  Such  preparations  could  test  the  automated  feeding  of 
requested data and interoperability with national systems.

5.3.  Developing the governance of the anti-fraud architecture

The Commission welcomes the progress made in all Member States to build effective anti-
fraud governance and develop strategic approaches to fighting fraud at national, regional 
or  sectoral  level.  Setting  up  specific  networks  that  gather  together  national  anti-fraud 
players creates the foundations for exchanging good practices, knowledge, experiences 
and expertise in the most efficient way.

These  networks  create  the  ideal  conditions  for  developing  strong  anti-fraud  strategies 
based on exhaustive fraud risk assessments. They can be used to help correctly identify 
weaknesses and threats, devise effective mitigating actions, define concrete objectives and 
take timely corrective measures in case of sudden changes in the anti-fraud landscape.

RECOMMENDATION 3 – REINFORCING ANTI-FRAUD GOVERNANCE IN 
THE MEMBER STATES

Member States are requested to keep on reinforcing their anti-fraud governance 
structures, ensuring that they include all relevant players. 

Central to this at Member State level is the adoption of all necessary strategies to 
fight fraud, ideally at national level (by adopting a national anti-fraud strategy).

29

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023Annexes

to the

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

Brussels, 25.7.2024 
COM(2024) 318 final 
ANNEXES 1 to 2

31

35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023,

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35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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35th Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud — 2023 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
GETTING IN TOUCH WITH THE EU

In person

All over the European Union there are hundreds of Europe Direct information centres. 
You can find the address of the centre nearest you at: https://europa.eu/european-union/contact_en

On the phone or by email

Europe Direct is a service that answers your questions about the European Union.  
You can contact this service:

— by freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls),

— at the following standard number: +32 22999696 or

— by email via: https://europa.eu/european-union/contact_en

FINDING INFORMATION ABOUT THE EU

Online

Information about the European Union in all the official languages of the EU is available 
on the Europa website at: https://europa.eu/european-union/index_en

EU publications

You can download or order free and priced EU publications at:  
https://op.europa.eu/en/web/general-publications/publications.

Multiple copies of free publications may be obtained by contacting Europe Direct or your 
local information centre (see https://europa.eu/european-union/contact_en).

EU law and related documents

For access to legal information from the EU, including all EU law since 1952 in all the official 
language versions, go to EUR- Lex at: http://eur-lex.europa.eu

Open data from the EU

The EU Open Data Portal (http://data.europa.eu/euodp/en) provides access to datasets from the EU. 
Data can be downloaded and reused for free, for both commercial and non-commercial purposes.

FINDING INFORMATION ABOUT THE PIF REPORT

Previous reports

The previous PIF reports in all the official languages of the EU are available on OLAF website at: 
https://ec.europa.eu/anti-fraud/about-us/reports/communities-reports_en

Documents accompanying the 2023 PIF report

The documents accompanying the 2023 PIF report are available on OLAF website at: 
https://ec.europa.eu/anti-fraud/about-us/reports/communities-reports_en