COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions and to the European Court of Auditors Interim evaluation under Regulation (EU) 2021/785 of the European Parliament and of the Council of 29 April 2021 establishing the Union Anti-Fraud Programme and repealing Regulation (EU) No 250/2014
Date: 2024-12-17
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU financing, EU programme, administrative cooperation, corruption, exchange of information, fraud, fraud against the EU, tariff policy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.12.2024  SWD(2024) 279 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament, the Council, the European Economic and Social Committee, the Committee of the Regions and to the European Court of Auditors Interim evaluation under Regulation (EU) 2021/785 of the European Parliament and of the Council of 29 April 2021 establishing the Union Anti-Fraud Programme and repealing Regulation (EU) No 250/2014     {COM(2024) 572 final}  
 
 
Table of contents 

1. 

INTRODUCTION ................................................................................................................................ 8 

1.1. 

Purpose of the evaluation ............................................................................................... 9 

1.2. 

The scope of the evaluation ............................................................................................ 9 

1.3. 

The methodology .......................................................................................................... 10 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ..................................... 12 

2.1. 

The programme and its rationale, its objectives, its components and their rationale . 12 

2.1.1 

2.1.2 

The programme and its rationale .......................................................................... 12 

The programme’s general and specific objectives – context ................................ 15 

2.2. 

Points of comparison ..................................................................................................... 27 

2.2.1 

2.2.2 

Situation before the start of the intervention ...................................................... 27 

Overview of the points of comparison by evaluation criterion ............................ 30 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ....................... 34 

3.1. 

Implementation of the programme .............................................................................. 34 

3.2 

The funding of the programme’s components and actions .......................................... 38 

3.2.1 

3.2.2 

3.2.3 

3.2.4 

Budget and budget implementation ..................................................................... 38 

Annual work programmes (AWP) .......................................................................... 39 

Monitoring and reporting method ........................................................................ 40 

Actions under the Hercule component – analysis................................................. 43 

3.3 

Association agreement between the EU and Ukraine on participation........................ 48 

3.3.1 

Scope of the association ........................................................................................ 48 

3.3.2 
Terms and conditions of participation in the Union anti-fraud programme 
(excerpts of the related Commission Decision) .................................................................... 48 

3.4 

3.5 

Eligible actions of the UAFP – Hercule component ....................................................... 49 

Eligible entities – Hercule component .......................................................................... 50 

Implementation of the Irregularity Management System (IMS) and the Anti-Fraud 
3.6 
Information System (AFIS) ......................................................................................................... 51 

3.6.1 

3.6.2 

3.6.3 

3.6.4 

Implementation – 2023 ......................................................................................... 52 

Main activities ....................................................................................................... 52 

IMS – budgetary implementation ......................................................................... 53 

Maintenance and development ............................................................................ 53 

3.7 

3.8 

3.9 

IMS developments ......................................................................................................... 53 

The Anti-Fraud Information System – Implementation ................................................ 55 

Implementation of the UAFP in 2023 ............................................................................ 55 

 
 
 
3.10  AFIS – developments in the past decade ...................................................................... 57 

3.11  AFIS budget evolution between 2014 and 2023 ........................................................... 59 

4 

EVALUATION FINDINGS (ANALYTICAL PART) ....................................................................... 60 

4.1. 

To what extent was the intervention successful and why? .......................................... 60 

4.2 

4.3 

How did the EU intervention make a difference and to whom? .................................. 75 

Is the intervention still relevant? .................................................................................. 77 

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNT? .................................................... 79 

5.1 

5.2 

Conclusions .................................................................................................................... 79 

Lessons learnt ................................................................................................................ 81 

ANNEX I:   PROCEDURAL INFORMATION ........................................................................................... 85 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ................................................... 85 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

Principles ....................................................................................................................... 85 

Study tasks ..................................................................................................................... 88 

Data collection tools ...................................................................................................... 88 

Desk research ................................................................................................................ 88 

Documentation analysis ................................................................................................ 89 

Stakeholder consultations ............................................................................................. 89 

Case studies ................................................................................................................... 90 

Limitations to methodological approach and robustness of findings ........................... 91 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 

TO THE EVALUATION QUESTIONS (BY CRITERION) ............................................................. 92 

1. 

2. 

3. 

The evaluation matrix ................................................................................................... 92 

Details on the evaluation method and matrix ............................................................ 120 

Answers to the evaluation questions .......................................................................... 121 

3.1 Effectiveness ...................................................................................................................... 121 

3.1.1 Main conclusions: effectiveness of the UAFP ............................................................ 122 

3.1.2 To what extent have the training actions and technical assistance funded under the 
UAFP been effective in improving the activities linked to prevention, detection, and 
investigation of fraud and other illegal activities detrimental to the EU’s financial interests?
 ............................................................................................................................................. 122 

3.1.3 To what extent have the activities funded by the UAFP contributed to enhanced 
transnational cooperation? ................................................................................................. 127 

3.1.4 To what extent have the technical assistance interventions contributed to a 
multidisciplinary cooperation? ............................................................................................ 128 

3.1.5 What factors influenced the effective implementation of the technical and 
operational activities funded under the first component of the UAFP budget? ................ 130 

2 

 
 
3.1.6 How did technical assistance activities contribute to limiting the currently known 
exposure of the financial interests of the Union to fraud, corruption, or other illegal 
activities? ............................................................................................................................. 131 

3.2 Efficiency ........................................................................................................................... 132 

3.2.1 Main conclusions: efficiency of the UAFP .................................................................. 132 

3.2.2 To what extent have the desired effects been achieved at reasonable costs on the 
basis of a cost/benefits analysis? ........................................................................................ 133 

3.2.3 To what extent has the UAFP facilitated a more integrated use and simplified 
management of financial resources? .................................................................................. 142 

3.2.4 To what extent has your UAFP intervention led to any cost savings in your work 
related to the prevention, detection, and investigation of fraud and other illegal activities 
detrimental to the EU’s financial interests? ........................................................................ 145 

3.2.5 Budgetary flexibility .................................................................................................... 146 

3.3 Coherence ......................................................................................................................... 146 

3.3.1 Main conclusions: coherence of the UAFP ................................................................. 147 

3.3.2 To what extent are the three components and the different types of actions of the 
programme coherent among each other? .......................................................................... 148 

3.3.3 To what extent are the interventions of the programme coherent with other 
measures or actions taken at EU level by the Commission or institutions, bodies, agencies, 
which also may have contributed to the protection of the Union’s financial interests?.... 150 

3.3.4 Coherence with EU horizontal policies....................................................................... 150 

3.3.5 Coherence with other instruments and interventions ............................................... 151 

3.4 Relevance .......................................................................................................................... 159 

3.4.1 Main conclusions: relevance of the UAFP .................................................................. 160 

3.4.2 To what extent have the specific objectives been relevant to the general objectives in 
the period 2021-2024? ........................................................................................................ 160 

3.4.3 To what extent are the specific objectives still relevant to emerging trends, including 
in the development of new crime types and techniques? .................................................. 167 

3.4.4 To what extent have the activities of the programme been relevant for achieving its 
specific objectives in the period 2021-2024? ...................................................................... 172 

3.5 EU added value .................................................................................................................. 176 

3.5.1 Main conclusions: EU added value of the UAFP ........................................................ 176 

3.5.2 Does the intervention at EU level provide added value in terms of the efficient use 
of financial resources as compared to a possible intervention at national level? ........ 180 

ANNEX  IV.  OVERVIEW  OF  BENEFITS  AND  COSTS  -  SIMPLIFICATION  AND  BURDEN 

REDUCTION .................................................................................................................................... 184 

1. 

Hercule component ..................................................................................................... 188 

1.1.  Cost items ............................................................................................................... 188 

3 

 
 
1.2.  Benefits ................................................................................................................... 190 

1.3.  Comparison of costs and benefits ......................................................................... 191 

2. 

AFIS component – costs and benefits ......................................................................... 192 

2.1.  Cost items ............................................................................................................... 192 

2.2.  Benefits ................................................................................................................... 193 

2.3.  Comparison of costs and benefits ......................................................................... 194 

3. 

IMS component – costs and benefits .......................................................................... 194 

3.1.  Cost items ............................................................................................................... 195 

3.2.  Benefits ................................................................................................................... 195 

3.3.  Comparison of costs and benefits ......................................................................... 195 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ........................................... 196 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

Introduction and stakeholder consultation strategy .................................................. 196 

Approach to the consultation ..................................................................................... 196 

Online surveys ............................................................................................................. 197 

Overview of survey respondents................................................................................. 197 

Targeted interviews ..................................................................................................... 197 

Overview of interview participants ............................................................................. 198 

Main stakeholder feedback per evaluation question ................................................. 199 

7.1. 

Effectiveness ................................................................................................................ 199 

7.1.1. 

Surveys .................................................................................................................... 199 

7.1.2. 

Targeted interviews ................................................................................................. 200 

7.2. 

Efficiency ..................................................................................................................... 203 

7.2.1. 

Surveys .................................................................................................................... 203 

7.2.2. 

Targeted interviews ................................................................................................. 203 

7.3. 

Coherence ................................................................................................................... 204 

7.3.1. 

Surveys .................................................................................................................... 204 

7.3.2. 

Targeted interviews ................................................................................................. 204 

7.4. 

Relevance .................................................................................................................... 205 

7.4.1. 

Surveys .................................................................................................................... 205 

7.4.2. 

Targeted interviews ................................................................................................. 206 

7.5. 

Added Value ................................................................................................................ 207 

7.5.1. 

Surveys .................................................................................................................... 207 

7.5.2. 

Targeted interviews ................................................................................................. 208 

4 

 
 
ANNEX VI. LEGISLATIVE BACKGROUND OF COUNCIL REGULATION (EC) NO 515/97 
AND ITS ROLE IN THE PROTECTION OF THE FINANCIAL INTERESTS OF THE EU 
(CONTINUATION OF CHAPTER 2.1.1.4 ABOVE) ...................................................................... 210 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

Introduction ................................................................................................................. 210 

Objectives .................................................................................................................... 212 

Agricultural matters .................................................................................................... 213 

Customs matters: scope and definitions ..................................................................... 213 

Assistance on request ................................................................................................. 213 

Special watch on persons, goods and means of transport ......................................... 214 

Spontaneous assistance .............................................................................................. 215 

Relations with the Commission ................................................................................... 215 

Transport directory ..................................................................................................... 217 

Container Status Messages (CSM) .............................................................................. 217 

Import, Export and Transit (IET) .................................................................................. 217 

Relations with third countries ..................................................................................... 217 

Customs Information System (CIS) .............................................................................. 218 

Customs Files Identification Database (FIDE) .............................................................. 218 

Data analysis ................................................................................................................ 219 

5 

 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ACAs 

AES 

AFIS  

AMIF  

B2B  

BMVI  

CF  

CIRCABC  

CIS 

COM 

CONT  

CPR  

CSM 

DG AGRI  

DG BUDG 

DG COMP  

DG HOME  

DG NEAR  

Administrative cooperation arrangements (agreements) 

Automated Export System 

The Anti-Fraud Information System  

The Asylum, Migration and Integration Fund  

Business-to-business  

Border Management and Visa Instrument  

Cohesion Fund  

Communication 
and 
Administrations, Businesses and Citizens  

Information  Resource  Centre 

for 

Customs Information System 

The European Commission 

Committee on Budgetary Control (European Parliament) 

Common Provisions Regulation  

Container status messages 

Directorate-General for Agriculture and Rural Development  

Directorate-General for Budget 

Directorate-General for Competition  

Directorate-General for Migration and Home Affairs  

European Neighbourhood Policy and Enlargement Negotiations  

DG TAXUD 

Directorate-General for Taxation and Customs Union 

EC  

ECA  

EDES  

EDPB 

The European Commission  

The European Court of Auditors  

Early Detection and Exclusion System  

European Data Protection Board 

6 

 
 
EDPS 

EMAC 

ENP  

EP  

EPPO 

ERDF  

ESF  

EU  

FEAD  

FIDE 

GDPR 

IACS  

IET 

IMS  

IPA  

ISF  

JCO 

JRC 

KPI 

MA 

MAA  

MFF 

MS 

VAT  

European Data Protection Supervisor 

Expert group on mutual assistance in customs matters 

European Neighbourhood Policy  

The European Parliament  

The European Public Prosecutor’s Office 

European Regional Development Fund  

European Social Fund  

The European Union  

European Aid to the Most Deprived  

Customs Investigation Files Identification Database 

General Data Protection Regulation (Reg. (EU) 2016/679) 

Integrated Administration and Control System  

Import, Export and Transit directory 

Irregularity Management System  

Instrument for Pre-Accession Assistance  

Internal Security Fund  

Joint Customs Operations 

The European Commission’s Joint Research Centre 

Key performance indicator(s) 

Mutual assistance 

Mutual administrative assistance  

Multiannual financial framework 

Member State(s) 

Value added tax 

7 

 
 
1.  INTRODUCTION 

This  staff  working  document  (SWD)  on  the  interim  evaluation  of  the  Union  anti-fraud 
programme  (UAFP)1  describes  the  achievements  of  the  programme  between  early  2021  and 
early 2024, presents the findings, based primarily on an external study2, and suggestions as to the 
further implementation for the rest of the programme implementation period (2024-2027). 

The  UAFP,  the  successor  to  the  Hercule  III  programme  (2014-2020)3,  was  established  by  the 
adoption  of  Regulation  (EU)  2021/785  on  29  April  2021  (‘the  UAFP  Regulation’),  which 
entered into force retroactively on 1 January 2021, following the adoption in December 20204 of 
the 2021-2027 7-year EU budget (multiannual financial framework or MFF). 

The  UAFP,  managed  by  the  European  Commission  (through  the  European  Anti-Fraud  Office, 
OLAF) provides financial support to Member States’ law enforcement services and to academic 
and  non-profit  organisations  to  help  protect  the  EU’s  financial  interests,  i.e.  keeping  the  EU 
budget safe from irregularities, fraud or any other illegal activities.  

The programme also finances the operational management and development of OLAF's IT tool 
IMS (Irregularity Management System, the second component of the programme). This tool is 
used  by  Member  States,  participating  countries,  candidate  countries  and  other  beneficiaries  of 
EU  funding  to  report  irregularities,  confirmed  fraud  or  suspected  fraud  related  to  European 
funding under shared and indirect management. 

The third component finances the activities tasked to the Commission under Regulation (EC) No 
515/975 (‘Council Regulation 515/97’) by means of a technical IT support platform, managed by 
OLAF,  including  the  development  of  the  AFIS  (Anti-Fraud  Information  System).  Member 
States’  law  enforcement  services  and  customs  services  use  this  technology  platform,  which 
consists of a set of applications operated under a common information system managed by the 
Commission, to exchange information and data.  

Council Regulation 515/97 provides that the Union is to support mutual assistance between the 
administrative  authorities  of  the  Member  States  and  cooperation  between  the  latter  and  the 
Commission,  to  ensure  the  correct  application  of  the  law  on  customs  and  agricultural  matters. 

1 Regulation (EU) 2021/785 of the European Parliament and of the Council of 29 April 2021 establishing the Union 
Anti-Fraud Programme and  repealing Regulation (EU) No 250/2014 (OJ L 172, 17.5.2021, p. 110–122),  ELI: 
http://data.europa.eu/eli/reg/2021/785/oj.  

2  European  Commission:  European  Anti-Fraud  Office,  Charitakis,  S.,  Faion,  M.,  Gounev,  P.,  Vasileva,  V.  et  al., 
Study  in  support  of  the  Union  Anti-Fraud  Programme  (UAFP)  interim  evaluation  –  Final  study  report, 
Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235.  

3 Regulation (EU) No 250/2014 of the European Parliament and of the Council of 26 February 2014 establishing a 
programme to promote activities in the field of the protection of the financial interests of the European Union 
(Hercule III programme) and repealing Decision No 804/2004/EC, (OJ L 84, 20.3.2014, p. 6). 

4  Council  Regulation  (EU,  Euratom)  2020/2093  of  17  December  2020  laying  down  the  multiannual  financial 

framework for the years 2021 to 2027 (OJ L 433I, 22.12.2020, p. 11). 

5 Council Regulation (EC) No 515/97 of 13 March 1997 on mutual assistance between the administrative authorities 
of the Member States and cooperation between the latter and the Commission to ensure the correct application of 
the law on customs and agricultural matters (OJ L 082 22.3.1997, p. 1). 

8 

 
 
 
 
That  support  is  provided  to  a  number  of  operational  activities  as  described  in  Annex  I  of  the 
UAFP Regulation.  

The UAFP is set to run for the MFF from the beginning of 2021 to the end of 2027. 

1.1. Purpose of the evaluation 

The purpose of this interim evaluation of the UAFP has three aspects.  

First,  the  Commission  has  to  comply  with  a  legal  obligation.  Article  13(2)  of  the  UAFP 
Regulation provides that: 

‘The  interim  evaluation  of  the  programme  shall  be  performed  once  there  is  sufficient 
information available about the implementation of the programme, but no later than four years 
after the start of the implementation of the programme.’  

Therefore, under Article 13(4) of the same Regulation, the Commission ‘shall communicate the 
conclusions of the evaluation, accompanied by its observations, to the European Parliament, the 
Council,  the  European  Economic  and  Social  Committee,  the  Committee  of  the  Regions  and  to 
the European Court of Auditors’ by 31 December 2024 at the latest. 

Second, this evaluation should provide an overview of how the programme has worked so far, its 
achievements as well as its shortcomings in order to identify areas on which efforts can focus to 
improve implementation for the remaining period. 

The last  and third  aspect  relates  to  providing  a basis for a  potential impact assessment of the 
future programme for the next programming period, starting in 2028. 

This  evaluation  assesses  the  programme’s  effectiveness  (including  the  sustainability/durability 
of certain actions in the longer term), its efficiency, the coherence (both internal and external), 
the relevance of the programme’s aim and objectives, and the added value at EU level. As this 
assessment had to be conducted for each of the three components of the programme and given 
their different characteristics, this SWD has turned out lengthier than expected. 

1.2. The scope of the evaluation 

The  scope  of  the  interim  evaluation  has  been  limited  since  only  some  activities  and  projects, 
funded  by  the  programme  since  2021,  have  been  fully  implemented  and  finalised  (i.e.  paid) 
within the timeframe set for the evaluation (early 2021 to early 2024). 

In order to comply with the deadline of 31 December 2024 for the adoption and transmission of 
this report from the Commission to the other EU institutions, the external study supporting the 
Commission with this interim evaluation mainly covers the period between 1 January 2021 and 
31 January 2024.  

The  first  projects  granted  through  the  programme  effectively  started  from  early  to  mid-2022, 
following the time needed for the administrative procedure to receive, select, evaluate and award 
those  projects.  As  most  of  the  activities  granted  have  a  duration  of  between  18  to  24  months, 

9 

 
 
those contracts that started in 2022 ran (or will run), at least, until the end of 2023 or throughout 
2024 and 2025. The impact of COVID-19 also meant that many of the grant contracts’ duration 
was extended. 

For this reason, only the results and outcomes of a reduced number of finalised activities could 
be evaluated, addressing the main questions in relation to the evaluation criteria:  
- 

the  relevance  of  the  programme:  does  it  make  a  difference  and  does  it  provide  funding 
beyond the level of support that Member States can provide themselves? 
the effectiveness of the programme’s activities: can we measure an effect or an impact? 
the efficient use of human and financial resources: what are the costs and benefits for users? 
is it (still) worth funding this programme? 
is  there  internal  consistency  (coherence)  of  the  programme’s  activities,  as  well  as  external 
coherence  with  other  similar  EU  funding  programmes  active  in  the  field  of  fighting  fraud, 
corruption or any other illegal activities? 

- 
- 

- 

-  what  is  the  EU  added  value  of  the  programme?  I.e.  value  that  is  additional  to  what  would 

otherwise have been created solely by Member States acting on their own. 

The  sustainability  of  certain  measures  over  the  longer  term  will  be  considered  under  the 
‘effectiveness’ criterion (durability of equipment or tools beyond the contractual period).  

1.3. The methodology  

The  methodology  applied  to  this  evaluation  is  described  in  Annex  II.  This  staff  working 
document  is  mainly  based  on  the  external  study  by  the  contractor  ICF  S.A.  Belgium  (ICF)6, 
which has  been based  on recognised  evaluation  techniques, including  cross-checking  methods. 
The study report explains the rationale for the action at the time it was prepared and adopted, i.e. 
identifying  the  problems  or  the  needs  the  EU  was  trying  to  address  and  its  underlying  causes, 
what the programme expected to achieve and how that achievement was to be assessed7.  

In  the  inception  phase  of  the  external  study,  the  scope  was  adapted  in  agreement  between  the 
Commission (OLAF) and ICF. The main amendments, compared to the initial proposal by ICF 
before  the  contract  started,  included  an  analysis  of  each  of  the  three  components  of  the 
programme, their budgets, objectives, themes and priorities and a short overview of the  annual 
call(s) for applications and the grant data. 

This evaluation has also drawn, where possible, on the following sources: 
- 

the 2018 ex ante evaluation report in preparation of the UAFP Regulation8;  

6  European  Commission:  European  Anti-Fraud  Office,  Charitakis,  S.,  Faion,  M.,  Gounev,  P.,  Vasileva,  V.  et  al., 
Study  in  support  of  the  Union  Anti-Fraud  Programme  (UAFP)  interim  evaluation  –  Final  study  report, 
Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. 

7 Based on the intervention logic of the programme, see Chapters 2.1.1.2 and 3.1. 
8 An  ex ante evaluation was performed in connection with the  upcoming UAFP, in line with, at the time, Article 
30(4) of Regulation (EU, Euratom) No 966/2012 of the European Parliament and of the Council of 25 October 
2012 on the financial rules applicable to the general budget of the Union and repealing Council Regulation (EC, 
Euratom) No 1605/2002 (OJ L 298, 26.10.2012, p. 1–96). The evaluation was presented  in the form of a staff 

10 

 
 
 
 
- 

the explanatory memorandum and the preamble of the final text of the UAFP Regulation. 

The evaluation includes: 
- 
-  wherever  possible,  a  reference  to  one  or  more  of  the  17  UN  Sustainable  Development 

the points of comparison against which the intervention has been assessed; 

Goals9 (SDGs) that the intervention is considered to address or support; 

-  case studies: The purpose of the case studies was to conduct a thorough examination of the 
main themes of the evaluation. The introduction of Regulation 2021/785 has brought about 
notable themes and innovations regarding the primary focus and structure of the UAFP. As 
the programme is still being implemented and many actions are ongoing, the main emphasis 
of the case studies was to assess progress in achieving the strategic direction outlined for the 
programme, rather than evaluating longer-term impacts and outcomes.  

By taking this mid-term perspective on their design, the case studies offer a comprehensive 
understanding  of  whether  the  programme  is  advancing  towards  its  objectives,  allowing  for 
adjustments if necessary for the remainder of the programme.  

The four case studies10 covered the following topics: 
•  Case study 1: investigative capacity 
•  Case study 2: digitalisation, AI, data analytics 
•  Case study 3: transnational cooperation and exchange of information 
•  Case study 4: training. 

The results of the case studies have been incorporated into this document11. 

This  evaluation  complies  with  the  principles  outlined  in  the  Commission’s  Better  Regulation 
Guidelines12, which were adopted in May 201513 and updated on 3 November 202114; 

The study and this evaluation cover: 

-  geographically,  as  does  the  programme,  all  27  Member  States,  including  one  non-EU 
country  (third  country)  for  which  an  association  agreement  to  the  programme  has  become 

working 
content/EN/TXT/HTML/?uri=CELEX:52018SC0294. 

(SWD(2018) 

document 

294, 

30.5.2018), 

https://eur-lex.europa.eu/legal-

9   https://sdgs.un.org/goals 
10 Full details of the four case studies are available in Annex 3 of the study report by ICF: see footnote 11.  
11 European Commission: European Anti-Fraud Office, Charitakis, S., Faion, M., Gounev, P., Vasileva, V. et al., 

Study in support of the Union Anti-Fraud Programme (UAFP) interim evaluation – Final study report, 
Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. 
12 Commission Staff Working Document – Better Regulation Guidelines (SWD(2021) 305), 3.11.2021. 
13 COM(2015) 215, 19.5.2015, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52015DC0215. 
14 Available at: https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-

why-and-how/better-regulation-guidelines-and-toolbox_en 

11 

 
 
 
 
 
 
applicable  retroactively  on  1  January  2023,  the  association  agreement  with  Ukraine, 
signed on 20 March 202415. 

-  Where applicable, data relating to (reporting by) the United Kingdom16 has been included in 

this SWD where appropriate. 

-  all adopted Commission Implementing Decisions  on the annual work programmes (AWPs) 
within the scope (2021-2024). The Decisions concern the annual financing of the programme 
adopted,  including  (as  an  Annex  to  the  Decision)  the  AWP,  which  details  the  allocated 
budget, the eligible bodies and activities for funding in a particular year, and the criteria for 
measuring the potential impact of the programme. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. The programme and its rationale, its objectives, its components and their rationale 

2.1.1  The programme and its rationale 

Fraud and related illegal activities, such as corruption, money laundering and illicit trade, pose a 
serious problem to the EU and Member States as such activities are liable to undermine both the 
EU's economy and national economies.  
This  problem  is  all  the  more  pressing  now  that  the  EU’s  total  spending  has  grown  to  an 
unprecedented amount of around EUR 1.8 trillion, as established by the EU’s 2021-2027 multi-
annual budget, that is, if one includes the Recovery and Resilience Facility (RRF)17, created in 
2021  in  response  to  the  financial  and  economic  impact  of  the  COVID-19  pandemic.  This  is  a 
record  level  of  funding,  and  there  are  inevitable  risks  as  to  whether  all  funds  will  reach  their 
intended purpose.  

Efficient and proper spending of the EU’s budget, also in Member States, is key to maintaining 
the  public  and  taxpayers’  trust  and  to  boosting  the  strength  and  added  value  of  European 
integration. Conversely,  a high  prevalence of fraud can stifle economic growth  and undermine 
the broader economic recovery and fair competition. Reinforcing joint defences against fraud is 
therefore crucial in strengthening the EU’s resilience. 

Article 325 of the Treaty on the Functioning of the European Union (TFEU) provides for a 
shared  obligation  of  the  EU  and  Member  States  to  protect  the  EU's  financial  interests.  Past 
experience shows that the EU's financial interests are impacted by illegal activities, such as fraud 
and illicit trade, and by financial and other irregularities. Every year, the ‘Annual Report on the 

15 https://anti-fraud.ec.europa.eu/media-corner/news/ukraine-formalises-participation-union-anti-fraud-programme-

2024-03-21_en 

16 The Withdrawal Agreement entered into force on 1 February 2020, after having been agreed on 17 October 2019. 
17 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the 

Recovery and Resilience Facility (OJ L 057 18.2.2021, p. 17). https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02021R0241-20230301 

12 

 
 
 
 
 
protection  of  the  EU's  financial  interests’18  (‘PIF  Report’)  demonstrates  that  the  level  of  such 
irregularities,  including  fraud,  although  fluctuating,  requires  continuous  action  on  the  EU's 
part.  

In  addition,  the  current  MFF  was  drawn  up  against  the  background  of  significant  changes  in 
2017  to  the  legislative  and  institutional  framework  for  the  protection  of  the  EU's  financial 
interests, in  particular the  creation  of the European Public Prosecutor’s Office (EPPO)19 and 
the implementation of Directive (EU) 2017/1371 of the European Parliament and of the Council 
of  5  July  2017  on  the  fight  against  fraud  to  the  Union's  financial  interests  by  means  of 
criminal law (the ‘PIF Directive’)20. 

The  EPPO  was  set  up  to  conduct  criminal  investigations  and  prosecutions,  until  cases  are 
disposed of, in respect of crimes affecting the EU’s financial interests. The crimes falling within 
the material competence of the EPPO are set out in the PIF Directive21. 

In more recent years, at EU level, the anti-fraud landscape has undergone major changes with, 
for  instance,  the  operational  start  of  the  EPPO  on  1  June  2021  and  the  recent  revision  of 
Regulation  N°  883/201322  (‘the  OLAF  Regulation’),  strengthening  the  effectiveness  of 
administrative investigations carried out by OLAF.  

The  UAFP’s  predecessor,  the  Hercule  III  programme  (2014-2020),  also  had  the  general 
objective  of  protecting  the  EU’s  financial  interests  to  strengthen  the  competitiveness  of  the 
economy and protect taxpayers' money. The specific objective was to prevent and combat fraud, 
corruption and any other illegal activities affecting the EU’s financial interests. Action to protect 
the financial interests covered the whole expenditure side of the EU budget.  

On  the  revenue  side,  action  focused  on  the  traditional  own  resources  of  the  EU.  Article  33 
TFEU  provides  for  strengthening  customs  cooperation  among  Member  States  and  between 
Member States and the Commission. 

18 All PIF reports are accessible via the website of the Commission:  

https://ec.europa.eu/anti-fraud/about-us/reports/communities-reports_en  

19 Council Regulation (EU) 2017/1939 of 12 October 2017 implementing enhanced cooperation on the establishment 

of the European Public Prosecutor’s Office (‘the EPPO’). 

20 Directive (EU) 2017/1371 of the European Parliament and of the Council of 5 July 2017 on the fight against fraud 

to the Union's financial interests by means of criminal law (OJ L 198, 28.7.2017, p. 29). 

21 Article 4 of the EPPO Regulation: The EPPO shall be responsible for investigating, prosecuting and bringing to 

judgment the perpetrators of, and accomplices to, criminal offences affecting the financial interests of the Union 
which are provided for in Directive (EU) 2017/1371 and determined by this Regulation. In that respect the 
EPPO shall undertake investigations, and carry out acts of prosecution and exercise the functions of prosecutor 
in the competent courts of the Member States, until the case has been finally disposed of. 

22 Regulation (EU, Euratom) No 883/2013 of the European Parliament and of the Council of 11 September 2013 

concerning investigations conducted by the European Anti-Fraud Office (OLAF) and repealing Regulation (EC) 
No 1073/1999 of the European Parliament and of the Council and Council Regulation (Euratom) No 1074/1999 
(O J L 248, 18.9.2013, p. 1).  

13 

 
 
 
 
 
 
 
 
               
Implementation  of  the  EU  multi-annual  budget  has  been  accompanied  by  the  following  set  of 
measures to help Member States prevent and fight fraud affecting the financial interests of the 
EU, supporting mutual assistance in customs and agriculture matters. 

(a)  The  Hercule  III  programme  (2014-2020),  supporting  activities  against  fraud,  corruption 
and any other illegal  activities affecting the  financial interests of the  EU, now replaced by the 
UAFP. The UAFP Regulation covers the funding and implementation of the Hercule component 
(technical  assistance,  training  and  procured  activities),  the  Anti-Fraud  Information  System 
(AFIS) and the Irregularity Management System (IMS). 

(b)  The  Anti-Fraud  Information  System  (AFIS)  is  an  operational  activity  consisting 
essentially  of  a  set  of  customs  IT  applications,  running  under  a  common  information  system, 
managed  by  the  Commission  (OLAF).  It  was  set  up  to  perform  the  tasks  of  protecting  the 
financial interests of the EU, as entrusted to the Commission under Council Regulation 515/97, 
including the AFIS (Anti-Fraud Information System) to support mutual assistance between the 
administrative  authorities  of  the  Member  States  and  cooperation  between  the  latter  and  the 
Commission, to ensure the correct application of the law on customs and agricultural matters; 

and, 

(c) The Irregularity Management System (IMS) is a secure electronic communication tool that 
facilitates  Member  States’  obligation  to  report  detected  irregularities,  including  suspected  or 
confirmed  fraud  cases,  and  supports  the  management  and  analysis  of  these  cases  and  their 
related data.  

Although  it  is  difficult  to  quantify  these  measures’  financial  impact,  they  have  contributed  to 
recovering  large  amounts  of  diverted  money  back  to  the  EU  budget.  For  example,  Hercule  III 
funded  the  development  of  the  Automated  Monitoring  Tool  (AMT),  an  IT  tool  that  identifies 
anomalies  in  trade  flows.  It  was  used  in  several  customs  operations  and  was  instrumental  in 
identifying large undervaluation fraud schemes in the import of textile and footwear from  non-
EU countries. 

From a budget implementation perspective, the IMS is an operational activity. The Commission 
is tasked with the IMS activity under sectoral legislation. The IMS needs to be maintained and 
developed sufficiently to allow Member States to comply with their reporting obligations. It also 
provides the Commission with the necessary data to analyse the main achievements in detecting 
and reporting irregularities, including fraud, relating to  the EU's budget in shared management 
and pre-accession areas. 

The financial support provided to the IMS, the AFIS, from a budget implementation perspective, 
is  also  an  anti-fraud  operational  activity.  In  particular,  where  activities  developed  under  the 
AFIS string of the programme, aim at tackling the increasing sophistication of criminal groups 
and  new  challenges  arising  in  the  fight  against  fraud,  including  from  technological 
developments, there is still a real need for strenghtening the mutual administrative assistance 
activities between customs authorities and cooperation with the Commission. 

14 

 
 
2.1.2  The programme’s general and specific objectives – context 

The conclusions of the final evaluation of the Hercule III programme23 and the challenges posed 
by the increased EU expenditure brought some adjustments to the approach adopted previously. 
This was reflected in the Regulation setting up the UAFP in 2021.  

In  particular,  the  programme  now  focuses  more  on  the  expenditure  side  of  the  budget,  taking 
into account the new forms of EU expenditure, introduced by the MFF and RRF Regulations. It 
also puts an emphasis on new trends in crime, including cybercrime, reflected in the priorities 
set out in the AWPs of the programme. 

The  programme  is  objective-driven:  every  action  it  supports  has  to  refer  to  the  objectives 
outlined in the Regulation and in the AWP. 

Due to the parallel adoption of the Customs Control Equipment Instrument (CCEI)24, managed 
by DG TAXUD in the Commission, focusing on providing financial support to customs services, 
consideration is given to targeting UAFP support to purchasing types of equipment that are not 
covered by the instrument. 

Within  this  context,  Article  2  of  the  UAFP  Regulation  describes  the  general  and  specific 
objectives of the Union anti-fraud programme, as presented in the table hereafter. 

Table 1: The general and specific programme objectives 

Type of objectives 

General objectives 

Specific objectives 

Objectives 

-  Protect the Union’s financial interests. 
-  Support  mutual  assistance  between  the 
administrative authorities of the Member 
States and cooperation between Member 
States and the Commission to ensure the 
correct application of the law on customs 
and agricultural matters. 

-  Prevent  and  combat  fraud,  corruption 
and  any  other  illegal  activities  affecting 
the financial interests of the EU. 

-  Provide  tools  for  information  exchange 
and  support  for  operational  activities  in 
field  of  mutual  administrative 
the 
assistance  in  customs  and  agricultural 

23 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., Colaiacomo, E. 

et al., Final evaluation of the Hercule III programme – Final report, Publications Office, 
2021, https://data.europa.eu/doi/10.2784/62582 

24 Regulation (EU) 2021/1077 establishing a Customs Control Equipment Instrument as part of the Integrated 

Border Management Fund, for the period 2021-2027 (OJ L 234 of 2.7.2021, p. 1). 

15 

 
 
 
matters. 

-  Support  the  reporting  of  irregularities, 
including  fraud,  with  regard 
the 
shared  management  funds  and  pre-
accession  assistance  funds  of  the  EU 
budget. 

to 

The  main  beneficiaries  of  the  programme  are  the  Member  States’  authorities  involved  in  the 
fight  against  fraud  although  the  programme  also  provides  for  the  participation  of  non-EU 
countries (Ukraine, e.g.) under certain conditions as explained in more detail in Chapter 3.2.4.6. 

2.1.2.1  The Hercule programmes (I-II-III) 

In  2004,  the  Hercule  programme  was  set  up  by  Decision  No  804/2004/EC  of  the  European 
Parliament and of the Council. It  was amended  and extended by Decision No 878/2007/EC  of 
the  European  Parliament  and  of  the  Council  (the  ‘Hercule  II  programme’).  This  has  made  it 
possible for the past 20 years to promote and improve the activities carried out by the EU and 
Member  States  to  counter  fraud,  corruption  and  any  other  illegal  activities  affecting  the  EU's 
financial interests. 

Although  tangible  progress  has  been  achieved  over  these  last  two  decades  through  the  first 
Hercule  programme  (2004-2007),  the  Hercule  II  programme  (2007-2013)  and  the  Hercule  III 
programme (2014-2020), the level of protection of the EU’s financial interests among Member 
States remains uneven. 

This  differentiation  can  be  influenced  by  various  factors.  These  include:  (i)  different 
enforcement  and/or government  priorities;  (ii) different  technical  capacities  (the UAFP might 
not be the only programme/funding tool the Member State is working with); (iii) a different level 
of PIF awareness in the Member State; (iv) the geographical location in Europe (especially on 
the  revenue  side);  (v)  the  size  and  wealth  of  the  Member  State  in  question  and  the  related 
resources they allocate  or wish to  allocate  to  law enforcement and justice administrations;  and 
(vi) countries' differing levels of fraud and corruption.  

The Hercule III programme ended on 31 December 2020. The programme provided protection 
by  financially  supporting  national  and  regional  administrations,  research  and  educational 
institutes  and  other  non-profit  making  entities,  which  ‘promote  the  strengthening  of  action  at 
Union level to protect the financial interests of the Union’, including comparative research and 
scientific publications on fraud-related topics.  

The total budget for Hercule III amounted to EUR 104.9 million over 2014-2020 (UAFP 2021-
2027:  EUR  181.2  million  or  72.7%  more).  The  programme  was  implemented  on  the  basis  of 
annual cycles that carried out the AWPs. 

The 2018 mid-term evaluation of the Hercule III programme found that, like the final report of 
the Hercule II programme, stakeholders almost unanimously recognised the added value of the 

16 

 
 
 
programme  and  its  essential  contribution  to  generating  benefits25.  More  specifically,  the 
programme’s  added  value  was  principally  seen  as  acting  as  an  enabler  for  cross-border 
cooperation,  cross-border  exchanges  of  information  and  the  sharing  of  best  practices, 
including on cybercrime. 

The  Commission  submitted  in  December  2021  the  ‘Report  from  the  Commission  to  the 
European Parliament and to the Council’26, with an accompanying staff working document, on 
the  final  evaluation  of  the  Hercule  III  programme  and  its  merits  with  regard  to  relevance, 
efficiency, effectiveness, coherence, added value and durability (sustainability). 

This Commission report was supported by a study by an external contractor (Ramboll (Belgium) 
S.A.),  providing  the  necessary  elements  to  submit  conclusions  and  recommendations  to  the 
legislators27. 

The conclusions of both the mid-term and final evaluations of the Hercule III programme 
found that the programme was successful in meeting its objectives and providing EU added 
value, contributing to the general objective of the programme. 

Hercule III was seen as highly relevant in addressing the main problems faced by stakeholders 
because  it  complemented  the  work  carried  out  by  Member  States.  The  stakeholders  consulted 
indicated a high level of satisfaction with the programme.  

The final evaluation of the Hercule III programme28 confirmed the success of the programme and 
concluded  that  the  programme  had  been  effective.  The  technical  assistance  measures  (such  as 
financing  the  purchase  of  scanners  to  detect  smuggled  goods  or  funding  training  in  digital 
forensics) supported the law enforcement authorities in Member States in their work to combat 
illegal cross-border activities.  

25 European Commission (2017). Mid-term Evaluation of the 
      Hercule III programme, prepared by CEPS, Economisti Associati, CASE, wedoIT. https://anti-

fraud.ec.europa.eu/system/files/2021-07/herculeiii_midterm_evaluation_en.pdf 

      European Commission Staff Working Document (2016). Mid-Term evaluation of the Regulation (EU) No 
250/2014 of the European Parliament and of the Council of 26 February 2014 establishing a programme to 
promote activities in the field of the protection of the financial interests of the European Union (Hercule III 
programme) and repealing Decision No 804/2004/EC (SWD (2018) 3), https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2018:0003:FIN:EN:PDF 

26 Report from the Commission to the European Parliament and the Council, Final evaluation of the Regulation 

(EU) No 250/2014 of the European Parliament and of the Council of 26 February 2014 establishing a 
programme to promote activities in the field of the protection of the financial interests of the European Union 
(Hercule III programme) and repealing Decision No 804/2004/EC (COM/2021/809 final, 16.12.2021), 
https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52021DC0809 

27 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., Colaiacomo, E. 

et al., Final evaluation of the Hercule III programme – Final report, Publications Office, 
2021, https://data.europa.eu/doi/10.2784/62582  

28 European Commission Staff Working Document (2021). Final evaluation of the Regulation (EU) No 250/2014 of 
the European Parliament and of the Council of 26 February 2014 establishing a programme to promote activities 
in the field of the protection of the financial interests of the European Union (Hercule III programme) and 
repealing Decision No 804/2004/EC (SWD (2021) 386, 16.12.2021), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52021SC0386 

17 

 
 
 
 
 
 
However,  the  evaluation  also  found  aspects  that  could  hamper  the  effectiveness  of  the 
programme. These included the lack of resources in Member States’ administrations (which is 
not an aspect the Commission could influence or change) and the corresponding lower ability to 
cope with the administrative requirements, which could have led to fewer applications.  

The  final  evaluation  showed  that  the  programme  had  been  efficient  across  both  training 
activities  and  technical  assistance  projects.  The  benefits  of  the  programme  were  found  to 
outweigh the costs incurred by the beneficiaries.  

Differences  in  the  administrative  capacity  of  Member  State  administrations  posed  a  challenge 
that  could  be  overcome  by  providing  more  guidance  for  applicants  and,  where  possible, 
simplifying the procedures.  

In  terms  of  internal  and  external  coherence,  no  specific  overlaps  or  duplication  were 
identified. The evaluation identified a high degree of complementarity between the  Hercule III 
programme and the AFIS. 

The overall view  of  all  stakeholders  was that the programme provided  clear  EU added value. 
The  programme  acted  as  an  enabler  and  driver  for  Member  States  to  use  a  higher  standard  of 
equipment  to  detect  and  reduce  the  risks  of  fraud  than  would  have  been  possible  without  the 
programme.  The  programme  was  also  seen  to  act  as  a  facilitator  for  EU-level  cooperation 
between  Member  States,  specifically  through  the  funding  of  training  activities,  conferences, 
funded access to databases and associated tools.  

70% of the 99 respondents consulted at the time by the contractor Ramboll stated that the same 
results  could  not  have  been  achieved  at  national  or  regional  levels.  Crucially,  the  evaluation 
showed  that  a  withdrawal  of  the  programme  would  have  led  to  an  increase  in  fragmentation 
between Member States and created an uneven playing field in the fight against fraud, resulting 
in uneven protection across the EU.  

Moreover,  respondents  indicated  that  the  Hercule  III  programme  served  as  a  deterrent. 
Therefore,  withdrawing  the  programme  risked  sending  a  message  that  fighting  fraud  is  not  a 
priority or no longer a priority, thereby potentially emboldening criminal actors29. 

2.1.2.2  The Union anti-fraud programme (2021-2027) 

Acknowledging  the  contribution  of  the  Hercule  III  programme  and  based  on  the  2018  ex  ante 
evaluation of the UAFP Regulation30, the Commission proposed a new Regulation, establishing 
the UAFP, to start under the 2021-2027 MFF. 

29 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., Colaiacomo, E. 

et al., Final evaluation of the Hercule III programme – Final report, Publications Office, 
2021, https://data.europa.eu/doi/10.2784/62582 

30 European Commission, Commission Staff Working Document, Ex-ante evaluation accompanying the Proposal 
for a Regulation of the European Parliament and of the Council establishing the EU Anti-Fraud Programme 
(SWD (2018) 294). Available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294 

18 

 
 
 
The  legislative  proposal  was  adopted  on  29  April  2021  as  Regulation  (EU)  2021/785,  with  a 
total budget of EUR 181 207 000. The programme has been established for 7 years to align its 
duration with that of the MFF laid down in Council Regulation (EU, Euratom) 2020/209331. 

The  2018  ex  ante  evaluation  of  Hercule  III  highlighted  the  following  needs  to  which  the 
proposed programme should respond (summarised): 

- 

- 

the lack of up-to-date technical equipment and support in Member States; 

the rise in new forms  of fraud  and the  rapid  development  of sophisticated technical  tools 
used by criminals32;  

-  more  cooperation  between  stakeholders  (including  the  exchange  of  best  practices  and 

experiences); 

-  access and exchange of data and information between stakeholders and Member States. 

The  independent  study  underpinning  the  Commission  ex  ante  evaluation  outlined  some  ideas 
that have been proposed, including  possible objectives  and activities for  the programme going 
forward.  This  includes  cross-border  cooperation  between  Member  States  and  cooperation  with 
non-EU partners, including on technological challenges.  

The study concluded, on the basis of the final reports of the actions and surveys of beneficiaries, 
that  training  activities  generated  results  that  were  largely  in  line  with  the  expected  output. 
Nonetheless,  it  found  that  only  a  few  training  activities  involved  staff  exchanges  between 
national administrations or international participation. 

Most  of  the  suggestions  from  the  2018  evaluation  have  been  addressed,  as  the  Commission, 
since 2017, has been using an electronic management system for the submission, processing and 
management of grant applications under the Hercule III programme. The improvements brought 
about  by  the  electronic  management  system  include  digitalising  the  whole  application  process 
and introducing the use of digital signatures. The electronic system has noticeably alleviated the 
administrative burden and the related time and resources spent by applicants on their proposal, 
as well as facilitated the monitoring of earlier and ongoing or closed projects. 

The programme’s intervention logic was drafted, based on the identified needs, the established 
objectives, the known financial input, the planned activities and the expected results and impact. 

The  UAFP  is  the  main  EU-level  programme  specifically  designed  to  protect  the  EU’s 
financial interests. The UAFP may act in synergy with other EU instruments providing technical 
support  in  the  fight  against  fraud  and  corruption,  such  as  the  Technical  Support  Instrument 

31 Council Regulation (EU, Euratom) 2020/2093 of 17 December 2020 laying down the multiannual financial 

framework for the years 2021 to 2027 (OJ L 433I, 22.12.2020, p. 11). 

32 This view was echoed by two beneficiaries of Hercule III funding, who were interviewed. They both stated that a 

key emerging challenge was the proficiency of criminals with complex encryption technology and 
communications.  

19 

 
 
 
(TSI)33, as well as other EU programmes, such as the Customs programme34, the CCEI and the 
Fiscalis programme35. 

Although the IMS is an IT tool running under the platform provided by  the AFIS, the AFIS is 
considered to be the third component of the programme (and not the second). This is because of 
how  the  budget  line  numbering  was  attributed  to  these  components  during  the  legislative 
preparatory activities. During the adoption process of the UAFP Regulation, the same order was 
maintained36.  This  meant  that  the  IMS  was  mentioned  as  the  second  component  (although 
financially the smallest) before the third component, the AFIS (in light green below). 

Figure 1: Intervention logic of the UAFP  

33 Regulation (EU) 2021/240 of the European Parliament and of the Council of 10 February 2021 establishing a 

Technical Support Instrument (OJ L 57, 18.2.2021, p. 1). 

34 Regulation (EU) 2021/444 of the European Parliament and of the Council of 11 March 2021 establishing the 

Customs programme for cooperation in the field of customs and repealing Regulation (EU) No 1294/2013 (OJ L 
87, 15.3.2021, p. 1). 

35 Regulation (EU) 2021/847 of the European Parliament and of the Council of 20 May 2021 establishing the 

Fiscalis programme for cooperation in the field of taxation and repealing Regulation (EU) No 1286/2013 (OJ L 
188, 28.5.2021, p. 1). 

36 Recital 9 UAFP Regulation: ‘The Programme should therefore comprise a component similar to the Hercule III 

programme, a second component ensuring the financing of IMS and a third component that finances the 
activities tasked to the Commission under Regulation (EC) No 515/97, including the AFIS platform.’ 

20 

 
 
 
 
 
As  of  July  2024,  24  of  the  27  Member  States37  participate  in  the  EPPO38.  Therefore,  different 
forms  of  cooperation  between  the  EPPO,  the  European  Commission  and  national  judicial  and 
administrative authorities have been established. Specifically, for the purpose of establishing and 
maintaining  a  cooperative  relationship,  the  EPPO  and  the  Commission  have  concluded  an 
agreement on 18 June 202139 while the EPPO and OLAF concluded a working arrangement on 5 
July 202140.  

A  major  change  in  the  recent  implementation  of  the  UAFP  has  been  the  adoption  of  a 
Commission  Decision41  allowing  Ukraine  to  become  an  associated  candidate  country  to  the 
programme. See Chapter 3.3 for details. 

Table 2: Overview of the UAFP characteristics  

General objectives  

Article 2(1) of the UAFP Regulation: 
(a) protect the financial interests of the Union;  
(b) support mutual assistance between the administrative authorities of 
the  Member  States  and  cooperation  between  the  latter  and  the 
Commission  to  ensure  the  correct  application  of  the  law  on  customs 
and agricultural matters. 

Specific objectives   Article 2(2) of the UAFP Regulation: 

(a) prevent and combat fraud, corruption and any other illegal activities 
affecting the financial interests of the Union;  
(b) support the reporting of irregularities, including fraud, with regard 
to the shared management funds and pre-accession assistance funds of 
the Union budget;  
(c) provide tools for information exchange and support for operational 
activities  in  the  field  of  mutual  administrative  assistance  in  customs 
and agricultural matters. 

Article 10(2) of the UAFP Regulation: 
(a)  public  authorities  which  can  contribute  to  achieving  one  of  the 
objectives referred to in Article 2 and are established in:  
(i) a Member State or an overseas country or territory linked to it;  
(ii) a third country associated to the programme; or  

Bodies  eligible  for 
funding 

37 With Poland having joined in February 2024 (Commission Decision 2024/807 of 29 February 2024) and Sweden 
in July 2024 (Commission Decision 2024/1952 of 16 July 2024), currently only Denmark - due to its opt-out 
status -, Hungary and Ireland do not participate in the EPPO. 

38 In fact, all 27 Member States cooperate with the EPPO, in accordance with the relevant EU judicial cooperation 
instruments:https://www.eppo.europa.eu/en/faq#:~:text=Which%20EU%20countries%20take%20part,participat
e%20in%20the%20enhanced%20cooperation. 

39 2021.073_Agreement_EPPO_European_Commission_final.pdf (europa.eu) 
40 Working_arrangement_EPPO_OLAF.pdf (europa.eu) 
41 Commission Decision C(2024) 760 of 12 February 2024 amending Decision C(2023) 6114 on the approval of an 
agreement between the European Union and Ukraine on the participation of Ukraine in the Union anti-fraud 
programme. 

21 

 
 
 
(iii) a third country listed in the work programme under the conditions 
specified in paragraph 3; 
(b)  research  and  educational  institutes  and  non-profit-making  entities 
which can contribute to the achievement of the objectives referred to in 
Article  2,  provided  that  they  have  been  established  and  have  been 
operating for at least one year in:  
(i) a Member State;  
(ii) a third country associated to the programme; or  
(iii)  a  third  country  listed  in  a  work  programme  under  the  conditions 
specified in paragraph 3;  
(c)  any  legal  entity  created  under  Union  law  or  any  international 
organisation.  

Article 10(3) of the UAFP Regulation: 
Entities referred to in paragraph 2 established in a third country which 
is  not  associated  to  the  programme  shall  be  exceptionally  eligible 
under  the  programme  where  this  is  necessary  for  the  achievement  of 
the objectives of a given action. Such entities shall in principle bear the 
cost of their participation, except in cases which shall be duly justified 
in the work programme. 

Eligible bodies that received financial support, i.e. have been awarded 
a grant or benefited from a procurement or a contract. 

Staff  that  operates  the  equipment  purchased  through  a  technical 
assistance  grant  or  which  is  a  participant  in  training  activities,  or 
obtained  access  to  databases,  or  received  support  through  an  AFIS 
application. 

Entities  that  applied  without  success  to  the  calls  for  proposals  for 
technical assistance or for training actions. 

in 

Individuals taking part in events (conferences, seminars, training, etc.) 
funded by the UAFP. 

Individuals accessing services purchased under procurement and made 
available  to  EU,  national  and  regional  institutions.  Users  of  services 
comprise users of statistics and IT tools, users of databases, and users 
of  services  to  carry  out  chemical  analyses  of  samples  from  tobacco 
and/or cigarette seizures. 

A small share of tax revenue raised by Member States is transferred to 
the  EU  budget,  which  has  three  streams  of  traditional  own  resources: 
tariffs and duties (agricultural tariffs, sugar customs duties, and general 
tariffs), VAT-based income and gross national income-based revenue. 

22 

Beneficiaries 

End beneficiaries 

Unsuccessful 
applicants 

Participants 
events 

Users of services 

Traditional 
resources’ 

‘own 

 
 
 
2.1.2.3  Aim and rationale of the UAFP’s Hercule component (protection of the EU’s financial 

interests) 

As mentioned earlier, in response to the COVID-19 pandemic crisis, the EU adopted the 2021-
2027 MFF  and the RRF42. With a total amount of EUR 1.8 trillion, this is  the largest package 
ever  financed  through  the  EU  budget.  It  is  therefore  more  important  than  ever  to  pursue  the 
objective of protecting this budget, which represents EU taxpayers’ money, and to ensure that it 
is collected and spent correctly.  

For the expenditure side of the EU budget, the UAFP aims to help Member States implement 
various types of budget management, whether direct, indirect or shared. 

To  achieve  this  objective  of  protecting  the  EU  budget  as  best  as  possible,  together  with  the 
Member States, the EU has recently strengthened its anti-fraud architecture, featuring:  

- 

- 
- 
- 

a  European  Anti-Fraud  Office  (OLAF)  with  strengthened  investigative  powers  through  a 
revision of the OLAF Regulation  in 2020; 
the criminal investigative and prosecutorial powers of the EPPO; 
the analytical capacity of the EU Agency for Law Enforcement Cooperation (Europol);  
the coordinating role of the EU Agency for Criminal Justice Cooperation (Eurojust).  

The UAFP complements this strengthened regulatory framework by offering direct and indirect 
financial support to Member States, bearing a joint responsibility to counter fraud, corruption 
and any other illegal activities affecting the EU’s financial interests. 

To this effect, this first component of the UAFP allocates EUR 114 207 000 for 2021-2027, of 
which EUR 16 075 789 has been allocated for 2024. This budget funds activities to fight fraud, 
corruption and any other illegal activities affecting the EU budget.  

The Commission implements this first component of the UAFP by: 

- 
- 
- 

- 

awarding grants following annual calls for proposals (direct support);  
concluding public procurement contracts following calls for tender (indirect support); 
entering  into  administrative  arrangements  with  the  Commission’s  Joint  Research  Centre 
(JRC), providing indirect support; 
reimbursing  costs  incurred  by  representatives  from  eligible  entities  who  participate  in 
training and operational activities (direct support).  

To be eligible for funding, proposed actions must implement the UAFP’s objectives. Financial 
resources allocated to the UAFP are also intended to contribute to the corporate communication 
of the EU’s political priorities, in particular those related to the UAFP’s objectives.  

Some of the actions financed under Hercule, this first component of the UAFP, are therefore also 
likely to help deliver on the EU’s current political priorities by:  

-  preparing for the challenges and opportunities of the green and digital transitions; 

42 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing the 

Recovery and Resilience Facility (OJ L 57, 18.2.2021, p. 17). 

23 

 
 
 
-  making  EU  economies  and  societies  more  resilient  to  shocks  in  the  future,  provided  these 

actions are linked to the UAFP’s objectives.  

It is important to tackle climate change in line with: 

- 

- 

the  commitments  of  the  EU  to  implement  the  Paris  Agreement  adopted  under  the  UN 
Framework Convention on Climate Change;  
the UN Sustainable Development Goals43.  

Reflecting the importance of these efforts, the UAFP aims to help ensure that climate action is 
integrated into all policy areas and aims at helping achieve an overall target of 30% of the EU 
budget supporting climate objectives. 

Therefore, the UAFP may, for example, enable Member States to be better equipped to prevent 
the  import  of  certain  illicit  products  that  do  not  comply  with  standards  laid  down  in  EU 
environmental and climate legislation. In doing so, the actions taken under the UAFP not only 
prevent  infringements  of  EU  customs  legislation  but  also  protect  the  environment  (as  one 
example of the EU added value of the programme). 

The  UAFP  can  also  support  cooperation  between  customs  and  other  competent  authorities  to 
fight  certain  fraudulent  activities  that  damage  the  environment  and  people’s  health,  such  as 
activities  related  to  illegal  waste  shipments,  the  illicit  trade  in  endangered  species,  illegal 
chemical products and fraudulent or substandard food products. 

The UAFP also strives to support Member States’ digital transition, for instance, by: 

- 

- 

funding the purchase of IT tools supporting data analysis to detect fraud that affects revenues 
or expenditures; 
continuing to build national expertise on digital forensics (through specialised training). 

2.1.2.4  Aim and rationale for the Anti-Fraud Information System (AFIS) platform 

The main legal basis for the operation of the AFIS is Council Regulation 515/97.  

The  programme  supports  mutual  administrative  assistance  activities  under  Council  Regulation 
515/97,  including  the AFIS. This  assistance helps  ensure a  correct application of the law on 
customs and agricultural matters. 

For  the  legislative  background  of  Council  Regulation  515/97  and  its  crucial  role  in  the 
protection of the financial interests of the EU44, see Annex VI for a more detailed description. 

Council  Regulation  515/97,  together  with  the  UAFP  Regulation,  are  the  cornerstones  of 
mutual  assistance  in  customs  and  agricultural  matters  at  EU  level.  Effective  cooperation  in 

43 https://sdgs.un.org/goals 
44 Source: Commission Staff Working Document (SWD(2023) 428, 15.12.2023), Evaluation of Council Regulation 

(EC) No 515/97 on mutual assistance between the administrative authorities of the Member States and 
cooperation between the latter and the Commission to ensure the correct application of the law on customs and 
agricultural matters, https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=SWD:2023:428:FIN. 

24 

 
 
 
 
these  fields  strengthens  the  protection  of  the  EU’s  financial  interests  and  contributes  to  the 
safety and health of citizens and the protection of the environment. 

AFIS is an IT platform that consists of a set of anti-fraud IT applications, run by OLAF under a 
common technical infrastructure. The aim of this set of IT applications is the timely and secure 
exchange of fraud-related information between national authorities and EU institutions, bodies, 
offices and agencies, as well as the storage and analysis of relevant data.  

The  AFIS  platform  has  more  than  9 000  registered  end  users  in  Member  States,  partner  third 
countries, international organisations, the Commission and other EU institutions. AFIS enables 
substantial  economies  of  scale  and  synergies  in  developing,  maintaining  and  operating  such  a 
wide and diverse set of IT services and tools. 

AFIS supports mutual assistance in customs by providing collaboration tools such as:  

-  VOCU (Virtual Operations Coordination Unit) for joint customs operations;  
- 
-  databases such as CIS (Customs Information System) and FIDE (Customs Investigation Files 

secure web mail (AFIS Mail); 

Identification Database);  
the Container Status Messages (CSM) directory; 
the Import, Export and Transit (IET) directory. 

- 
- 

AFIS  also  provides  support  in  the  form  of  data  analysis  tools,  such  as  AMT  (Automated 
Monitoring Tool) and a platform for strategic and operational data analysis.  AFIS also supports 
electronic  workflow  applications  such  as  ToSMA  (the  Tobacco  Seizures  Management 
Application).  

This  third  component  of  the  UAFP  also  covers  expenditure  relating  to  the  use  of  the  CIS 
database,  provided  for  in  instruments  adopted  under  Article  87  TFEU45  (police  and  law 
enforcement  agencies’  cooperation  in  combating  crime),  in  particular  in  Council  Decision 
2009/917/JHA46,  insofar  as  those  instruments  require  such  expenditure  to  be  borne  by  the  EU 
general budget.  

Through this component, EUR 60 000 000 has been allocated through the UAFP for 2021-2027, 
of which EUR 8 445 091 has been reserved for 2024, to provide tools for information exchange 
and support for operational activities. 

2.1.2.5  Aim and rationale for the IMS tool 

The  second  component  of  the  UAFP  finances  the  development  and  maintenance  of  the  IMS, 
which supports the reporting of detected cases of irregularities and fraud.  

45 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A12008E087  
46 Council Decision 2009/917/JHA of 30 November 2009 on the use of information technology for customs 

purposes (OJ L 323, 10.12.2009, p. 20). 

25 

 
 
 
The IMS is a secure electronic communications tool, operated under the AFIS platform, which 
helps Member States, candidate countries and potential candidate countries fulfil their obligation 
to report detected irregularities. The IMS also enables managing and analysing the reported data, 
which  is  a  unique  tool  within  the  community  of  law  enforcement  agencies  and  of  the 
management and control systems of EU funds. 

For  this  component,  EUR  7  000  000  has  been  allocated  through  the  UAFP  for  2021-2027,  of 
which EUR 985 119 has been allocated for 2024.  

EU  legislation  for  various  funds  requires  Member  States,  candidate  countries,  potential 
candidates  and  third  countries  to  report  irregularities  and  fraud  affecting  the  EU’s  financial 
interests. This obligation can be found in the EU legislation that sets out rules for:  

- 
- 
- 
- 
- 
- 
- 
- 

- 
- 
- 

the European Agricultural Guarantee Fund; 
the European Agricultural Fund for Rural Development; 
the European Regional Development Fund; 
the European Social Fund; 
the Cohesion Fund; 
the European Maritime and Fisheries Fund; 
the Asylum, Migration and Integration Fund; 
the Instrument for financial support for police cooperation, preventing and combating crime 
and crisis management; 
the Fund for European Aid to the Most Deprived; 
the Fund for pre-accession assistance; 
the Recovery and Resilience Facility (here exclusively on a voluntary basis).  

2.1.2.6  New features in the UAFP programme since 2021 

The  UAFP  introduced  major  changes  from  the  now  concluded  Hercule  III  programme,  as 
clarified by the Regulation. One of these changes is the circle of entities eligible for support. 
Under  Article  10  of  the  UAFP  Regulation,  the  eligibility  of  non-EU  countries  now  generally 
depends on the conclusion of association agreements in accordance with Article 4, binding these 
countries  to  the  implementation  of  the  programme.  This  was  the  case  for  Ukraine,  which  was 
associated  to  the  programme  in  February  2024,  with  retroactive  applicability  from  1 January 
2023. 

Another  new  feature  is  set  out  in  Article  10(2)(c)  of  the  UAFP  Regulation,  which  opens  the 
possibility for international organisations to participate in the programme.  

The  addition  of  any  international  organisation  has  been  inspired,  during  the  preparatory 
legislative  work  on  the  Regulation,  by  the  fact  that  the  programme  was  initially  supposed  to 
directly fund the annual contribution for the running costs of the secretariat of the Framework 
Convention for Tobacco Control (‘FCTC’). This  particular  funding required the possibility for 
specific indirect budget management in the programme. 

26 

 
 
Therefore, Article 5(1) of the UAFP Regulation allowed the possibility of indirect management 
implementation,  although  the  main  components  of  the  programme  are  implemented  through 
direct  management.  Funding  the  annual  contribution  to  the  FCTC,  through  a  specific  budget 
line, is done with a specific Commission implementing decision on financing, including a work 
programme for the FCTC, covering each time a period of two years. 

Another  change,  impacting  the  practical  focus  of  the  programme’s  support,  arises  from  the 
parallel  adoption  of  Regulation  (EU)  2021/1077,  establishing  a  Customs  Control  Equipment 
Instrument (CCEI), as part of the Integrated Border Management Fund. Both are managed by 
DG TAXUD, the Commission department dealing with taxation and the customs union.  

CCEI  is  equipped  with  a  substantial  budget  of  around  EUR  1  billion  for  the  current  budget 
period.  It  can  offer  support  in  an  area  that  had  received  substantial  support  under  the  past 
Hercule  programmes.  The  Commission  pointed  out  that  technical  assistance  under  the  UAFP 
will now be targeted at the purchase of types of equipment that are not covered by the CCEI in 
order to avoid any overlap or duplication of EU financial support. 

As a result, implementation of the programme is now focusing more on expenditure fraud. One 
of the recent developments this interim evaluation has looked into is the use of UAFP funding to 
build up national capacity to better protect expenditure against fraud. 

In  a  shift  away  from  costly  customs  equipment,  the  UAFP  should  also  free  up  resources  to 
strengthen support for other state-of-the-art equipment for operational anti-fraud work, such as 
advanced data analytics technologies and data mining tools. This more data-oriented approach 
is  also  in  line  with  the  2019  Commission’s  anti-fraud  strategy  (CAFS),  which  highlights 
improved data analysis as a tool to better detect fraud. 

2.2. Points of comparison  

2.2.1  Situation before the start of the intervention 

This section assesses the baseline scenario of what would have happened if the situation before 
the  adoption  of  the  UAFP  had  remained  the  same  compared  with  the  results  and  progress 
achieved to date. 

As set out in the Better Regulation Toolbox47 (Tool #60), a baseline is a ‘no-policy-change’48  
scenario that makes it possible to assess how the UAFP has evolved since the last programming 
period.  The  baseline  gives  the  evaluation  a  comparison  point  and  benchmark  against  which  to 
assess the UAFP achievements in meeting its objectives.  

47 The Better Regulation Toolbox is a result of the Inter-Institutional Agreement of 13 April 2016 on Better Law 

Making (OJ L 123,12.5.2016, p.1). 

48 European Commission, Better Regulation Toolbox (version 20.7.2023). Available at: 

https://commission.europa.eu/law/law-making-process/planning-and-proposing-law/better-regulation/better-
regulation-guidelines-and-toolbox_en 

27 

 
 
 
The points of comparison that could be identified in the legislative financial statement, i.e. the 
annex  to  the  ‘Explanatory  memorandum’,  which  is  part  of  the  May  2018  ‘Proposal  of  the 
Commission for a Regulation establishing an EU anti-fraud programme’49, are as follows: 

-  Added  value  of  EU  involvement  (For  the  purposes  of  this  point  'added  value  of  EU 
involvement' is the value resulting from EU intervention that is additional to the value that 
would have been otherwise created by Member States alone.)  

o  Reasons for action at European level in 201850: 

Fraud affecting the EU's  financial interests is  a cross-border phenomenon, affecting 
all EU Member States, as shown by statistics published in ‘the PIF Reports. There is 
a  need  for  coordinated  action  to  tackle  fraud  and  also  to  facilitate  mutual 
administrative  assistance  in  customs  matters.  Hercule,  AFIS  and  the  IMS  are  all 
well-established tools supporting the Member States and the EU in this respect. This 
proposal aims to streamline the financial support for these tools for the duration of 
the next MFF.  

o  Expected generated EU added value: 

The programme is expected to continue supporting the Member States and the EU in 
fighting fraud affecting the EU's financial interests by financing activities (technical 
assistance and training), which otherwise might not be available at national level in 
all Member States. It will also provide services (AFIS and IMS) that, to meet their 
objectives,  should  be  delivered  in  a  centralised  and  horizontal  manner  for  all 
Member  States.  The  programme  will  also  allow  for  savings  as  has  been  the  case 
with the centralised purchase of access to various databases.  

-  Lessons learnt from similar experiences in the past (before 2018): 

Hercule,  AFIS  and  the  IMS  are  well-established  EU  tools  for  combating  fraud  and 
irregularities  that  harm  the  EU  budget  and  for  supporting  mutual  administrative  assistance 
between  customs  administrations  and  cooperation  with  the  Commission.  They  have  been 
subject 
largely 
to  regular  evaluations  and  user  satisfaction  surveys,  which  have 
demonstrated their added value.  

As an operational activity, AFIS has been subject to user satisfaction surveys, internal audit 
activities, as well as participants’ evaluations, joint customs operations (JCOs) and training 
sessions.  AFIS  was  positively  appreciated,  showing  a  satisfaction  rate  of  more  than  80% 

49 COM(2018) 386, Proposal for a Regulation of the European Parliament and of the Council establishing the EU 
Anti-Fraud Programme, 30.5.2018, including the SWD(2018) 294, 30.5.2018. Reference of the European 
Council file of this Proposal: 2018/0211 (COD). 

50 An ex ante evaluation was performed in 2018 in connection with the upcoming UAFP, in line with Article 30(4) 

of the then in force 2012 Financial Regulation, in the form of a staff working document, https://eur-
lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52018SC0294. 

28 

 
 
 
 
among users for functionality, performance and training activities. Moreover, the European 
Court  of  Auditors  concluded  that  the  information  on  Container  Status  Messages  and  fair 
prices, provided by the AFIS applications CSM directory and Automated Monitoring Tool, 
are  effective  tools  in  identifying  potential  cases  of  fraud  related  to  the  misdescription  of 
origin and undervaluation/underinvoicing.  

The  IMS is  analysed in  close collaboration with  Member States,  as  part  of the ‘Reporting 
and  Analysis’  component  of  the  COCOLAF51  advisory  committee  of  the  Commission 
(OLAF).  

-  Compatibility and possible coordination with other appropriate instruments: 

The conclusions of the final evaluation of the Hercule III programme and the new challenges 
posed by the increased EU expenditure brought some changes to the new programme (2021).  

Most  notably,  the  programme  now  focuses  more  on  the  expenditure  side  of  the  budget, 
taking into account the new forms of EU expenditure introduced by the MFF and the RRF 
Regulation.  It  also  puts  a  stronger  emphasis  on  new  trends  in  crime  patterns  through  its 
AWPs, reflecting possibilities for funding projects related to a non-exhaustive list of new or 
developing  trends.  Continuous  coordination  between  Commission  services  managing 
programmes that are related to the objectives of the UAFP, such as the CCEI or the Customs 
programme,  ensures  that  potential  financial  double  funding  is  avoided.  This  coordination 
takes place, in particular, during the annual evaluation exercise of new applications received 
for funding by these programmes or instruments. 

Furthermore,  the  ex  ante  evaluation  of  the  UAFP  demonstrated  the  clear  EU  added  value  of 
AFIS and IMS. The EU added value of AFIS is linked to the critical importance of the effective 
in  collaboration  with  the 
performance  of  the  national  customs  authorities’  missions, 
Commission.  The  contribution  of  AFIS  to  cross-border  coordination,  especially  in  terms  of 
collection of and access to data, proved vital to this effective performance.  

IMS is  the only  database in  the EU  that  consolidates  reported information about  irregularities, 
including fraud, in the shared management and pre-accession funds. Information is available by 
field of EU action and by Member State (and reporting country). It allows for various types of 
analyses  and  helps  further  develop  an  evidence-based  EU  anti-fraud  policy.  Through  the 
analyses developed by OLAF, it also feeds into the Member States’ fraud risk assessments. 

The  added  value  of  such  an  EU-wide  framework  allows  for  identifying  common  risks  and 
patterns  and  drawing  up  and  implementing  common  approaches  to  fighting  fraud.  This 
contributes  to  the  effective  and  equal  protection  of  the  EU’s  financial  interests  throughout  the 
EU. 

51 Advisory Committee for the Coordination of Fraud Prevention. 

29 

 
 
 
The  following  overview  table  presents  the  indicators  to  measure  the  performance  of  the 
UAFP and how its components performed in the context of these indicators. They are listed per 
evaluation criterion and have been developed by the contractor ICF and further refined through 
desk research, literature review and ICF’s consultations with stakeholders.  

For the development of the baseline, particular attention was placed on  the Commission’s PIF 
Reports, the final evaluation of the Hercule III programme and the 2019 AFIS Survey summary 
report52. 

2.2.2  Overview of the points of comparison by evaluation criterion 

Table 3: Points of comparison identified per evaluation criterion 

Indicators 

Effectiveness 

Baseline 

Perception  by  end  users  of  the  effectiveness  of 
the Hercule component projects 

87%  agree  that  the  Hercule  III  programme 
contributed  to  supporting  law  enforcement 
agencies  in  their  work  to  combat  illegal 
cross-border  activities;  75%  agree  projects 
contributed to  reducing  the risk of cigarette 
smuggling. 

Perception  of  end  users  of  the  effectiveness  of 
training 

93% satisfaction rate among trainees. 

Perception  of  the  contribution  of  technical 
assistance projects to transnational cooperation 

found 

the 
Generally,  stakeholders 
on 
had 
projects 
transnational  cooperation,  but  no  specific 
data from the end-user survey are available. 

that 
effect 

positive 

a 

AFIS:  number  of  information  items  on  mutual 
assistance 

According  to  PIF  reports,  targets  in  2019 
and  2020  were  not  achieved.  The  baseline 
number  of  information  items  on  mutual 
assistance is 18 639 53. 

52 This summary report detailed the results of the AFIS user satisfaction survey conducted from 6 May 2019 to 19 

July 2019. The purpose of the survey was to measure the level of satisfaction of the users concerning:  

      1. the AFIS Helpdesk;  
      2. AFIS applications;  
      3. training and user manuals;  
      4. general opinion about the AFIS Portal and its applications. 
53 Source: European Commission. Anti-Fraud – Performance (2023). Available at: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en. 

30 

 
 
 
 
Indicators 

Baseline 

Perception  by  end  users  of  the  effectiveness  of 
AFIS 

According  to  the  2019  AFIS  user  survey, 
57%  agree  that  AFIS  applications  respond 
to their professional needs, and 27% slightly 
agree.  

IMS performance  

of 

the 

quality 

Issues  with 
data 
(completeness  and  consistency  of  entries), 
difficulties  with  the  search, and  the need  to 
improve  communication  on  system  updates 
were identified. 

Perception  by  end  users  of  the  effectiveness  of 
IMS 

The user satisfaction rate for IMS users was 
72%  in  2019.  IMS  had  more  than  3 000 
users  across  Member  States,  candidate 
countries  and  potential  candidate  countries 
in 2019 54. In 2023, the user satisfaction rate 
had  already  increased  with  19  percentage 
points to 91%. 

Efficiency 

funded 

Perception of the contributions of the UAFP to 
organisational, 
organisations’ 
the 
investigative,  and  technical  capacities,  among 
other capabilities 

the  EU.  However, 

The Hercule III programme met the needs of 
stakeholders working to protect the financial 
interests  of 
the 
development  of  new  and  emerging  threats 
needed  to  be  taken  into  account  for  the 
design of the current programme in order to 
allow beneficiaries to be reactive. 

Perception  of  stakeholders  regarding  the  cost 
effectiveness  of  the  application  process  for  a 
grant  

The  benefits  of  the  Hercule  III  programme 
outweighed  the  costs  incurred  although 
applicants  should  have 
received  more 
guidance and processes should be simplified 
(see point below). 

Perception  about  the  administrative  burden  of 
the application process.  

The application process for grants under the 
(which  was 
Hercule 
evaluated 
the 
that 
some 
application 

III  programme 

in  2021) 

procedure 

needed 

found 

54 Source: PIF Report 2019: https://anti-fraud.ec.europa.eu/document/download/cbf4c2bc-1217-4123-a3b0-

a7cbb9355931_en?type:pdf. 

31 

 
 
 
Indicators 

Baseline 

improvements,  including  simplification  and 
better guidance for applicants. 

Number  of  users,  number  of  cash  declarations 
registered  in  the  AFIS  system  and  number  of 
improvements. 

The  AFIS  Customs  Information  System 
(CIS+) module had more than 2 200 users. 

In  December  2021,  AFIS  CIS+  contained 
data  on  31 500  cash  declarations  and  1 800 
infringements  of  the  new  Cash  Control 
Regulation, Regulation 2018/1672 (this was 
6 months after going live). 

The  baseline  figure  for  AFIS  information 
(under 
items 
Regulation 97/515) is 18 639 (2019)55. 

on  mutual 

assistance 

Number of irregularities 

Coherence 

Internal coherence  

In 2019, 11 726 irregularities were reported 
to the Commission, involving approximately 
EUR 1.6 billion. Of these, 939 irregularities 
were reported as fraudulent.  

Existence  of 
overlaps among the three components   

internal  coordination  and/or 

Hercule  III  programme  funding  activities 
showed  internal  coherence,  with  minimal 
overlap;  however,  synergies  among  funded 
actions appeared underused.  

Hercule  III  programme  and  the  AFIS  were 
considered  to  be  coherent  as  Hercule  III 
supported customs anti-fraud activities 

External coherence 

Existence  of  coordination  and/or  overlaps  with 
other  relevant  instruments  and  interventions  at 

in  conjunction  with 

the 
IMS  worked 
Hercule  III  programme  and  AFIS  to  ensure 
the  exchange  of 
the 
protection of the EU’s financial interests. 

information  and 

Hercule III programme demonstrated strong 

55 European Commission. Anti-Fraud – Performance (2023). Available at: https://commission.europa.eu/strategy-

and-policy/eu-budget/performance-and-reporting/programme-performance-statements/anti-fraud-
performance_en. 

32 

 
 
 
 
 
 
 
 
Indicators 

EU level  

Relevance 

Baseline 

coherence  with  relevant  EU  legislation  and 
initiatives, playing a supportive role in other 
initiatives.  The  programme’s 
EU-level 
synergies with DG TAXUD and DG HOME 
programmes,  covering 
the  fight  against 
corruption  and  VAT  fraud  should  be 
ensured and maintained.  

Perception  of  programme  funding  recipients  of  
the relevance of the UAFPs objectives to protect 
the EU’s financial interests 

High  level  of  relevance  of  the  objectives 
under the Hercule III programme according 
to funding recipients. 

Percentage of Member States receiving support 
in  a  given  year  under 
III 
programme 

the  Hercule 

81%  of  Member  States  received  support 
under the Hercule III programme in 2020. 

Assessment of AFIS user needs as part of 2019 
AFIS satisfaction survey 

Positive  perception  among  AFIS  users  of 
AFIS’s ability to meet their needs. 

User satisfaction rate for the use of IMS  

The  user  satisfaction  rate  for  users  of  the 
IMS was 72% in 2019, surpassing the target 
of  70%.  In  2023,  it  had  already  increased 
with 19 percentage points to 91%. 

Added value 

Perception  of  recipients  of  programme  funding 
under the Hercule component as to whether the 
same  level  of  intervention  would  be  possible 
without EU support 

Of the 99 respondents surveyed for the final 
evaluation  of  the  Hercule  III  programme, 
70%  disagreed  that  the  same  results  were 
possible at national level alone56. 

Number of instances in which mutual assistance 
information  is  made  available  and  number  of 
supported  mutual  assistance-related  activities 
relative to yearly target (AFIS) 

At  the  beginning  of  2021,  the  number  of 
instances  of  available 
information  was 
19 125.  The  annual  overview  of  the  2021 
UAFP  programme  states  that  this  indicator 
had previously missed the yearly targets for 
2019  (18 639  available  out  of  a  targeted 

56 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., Colaiacomo, E. 

et al., Final evaluation of the Hercule III programme – Final report, Publications Office, 
2021, https://data.europa.eu/doi/10.2784/62582  

33 

 
 
 
 
Indicators 

Baseline 

21 500) and 2020 (19 125 available out of a 
targeted 24 000).  

Source: ICF analysis 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1. Implementation of the programme 

The  UAFP  is  being  implemented  by  the  Commission  through  the  adoption  of  AWPs,  which 
cover each year of implementation. 

The Commission adopts these work programmes under Article 11 of the UAFP Regulation and 
Article  110  of  Regulation  (EU,  Euratom)  2018/104657,  (the  ‘Financial  Regulation’).  On  that 
basis, each work programme sets out the priorities for funding in a particular year, as well as the 
objectives  pursued, 
the  methods  of 
implementation.  The  work  programme  also  responds  to  specific  requirements  and  needs 
arising  from  the  UAFP  Regulation’s  provisions  and  the  feedback  received  from  beneficiaries 
and stakeholders  (internal and external) during exchanges of information,  evaluation reporting, 
workshops, etc. 

the  expected  results  (using 

indicators)  and 

During  implementation  of  the  programme,  OLAF  measures  the  fulfilment  of  the  specific 
objectives through two performance indicators upon finalisation of the project(s) or action(s).  

The  first  indicator  relates  to  the  added  value  and  effective  use  of  the  co-financed  technical 
equipment funded under the UAFP (as reported by direct users). In the final project reports for 
2021,  beneficiaries  expressed  a  97%  satisfaction  rate  for  the  equipment  funded  under  the 
programme, surpassing the target of 75%58.  

In  addition,  the  programme  performed  well  in  the  second  performance  indicator,  which 
measures  the  number  of  training  activities  funded  and  the  associated  satisfaction  rate.  For  the 

57 Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on the 

financial rules applicable to the general budget of the Union, amending Regulations (EU) No 1296/2013, (EU) 
No 1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) No 1316/2013, (EU) No 
223/2014, (EU) No 283/2014, and Decision No 541/2014/EU and repealing Regulation (EU, Euratom) No 
966/2012 (OJ L 193, 30.7.2018, p. 1). 

     This regulation was replaced as of 30 September 2024 by Regulation (EU, Euratom) 2024/2509 of 23 
September 2024 on the financial rules applicable to the general budget of the Union, (OJ L 2024/2509, 
26.9.2024). However, since Regulation (EU, Euratom) 2018/1046 was applicable during the period under 
evaluation, all references in this document to the ‘Financial Regulation’ are made in relation to the latter. 

58 European Commission, Programme Performance Statements (PPS, 2023), available at: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-
performance_en#:~:text=In%202023%2C%20the%20programme%20committed,of%20the%20COVID%2D19
%20period 

34 

 
 
  
 
 
training  grants  finalised  in  2021,  participants  and  trainees  had  a  satisfaction  rate  of  91%  and 
considered that the activities were very well-suited to their needs59. 

Example: The 2024 AWP: Indicators to measure the expected results (excerpt) 

‘The Commission will support the following four categories of technical assistance actions. 
The  expected  results  from  the  actions,  together  with  the  indicators  enabling  them  and  the 
added value and effective use of the co-financed technical equipment to be measured, are as 
follows: 

1. investigation and surveillance equipment and methods: 

The  purchase  and  maintenance  of  investigation  and  surveillance  equipment  and  methods 
used by beneficiaries in the fight against irregularities, fraud and corruption, detrimental to 
the Union’s financial interests. The purchase of adapted transport equipment, IT hardware 
and  software  and  audio-visual  equipment  may  be  included,  provided  an  applicant  clearly 
demonstrates  that  the  purchase  helps  to  achieve  the  first  specific  objective  of  the  UAFP. 
Specialised training to enable staff to operate these tools has to be planned as part of the 
action. 

2. digital forensic hardware: 

The purchase and maintenance of digital forensic equipment and software, mobile forensic 
tools  and  computer  forensic  collaborative  systems  used  in  the  fight  against  (fraudulent) 
irregularities,  fraud  and  corruption  detrimental  to  the  Union’s  financial  interests.  Cross-
border cooperation enabling the exchange of information and best practices, in particular 
at operational level, is strongly encouraged. 

3. data analytics technologies and data purchases: 

The  purchase  and  maintenance  of  commercial  specialised  databases,  data  analysis 
platforms capable of running analysis in big data environments, risk and predictive analysis 
and  data  mining  tools,  as  well  as  systems  supported  by  artificial  intelligence  used  in  the 
fight against irregularities, fraudulent activities and corruption, detrimental to the Union’s 
financial  interests.  These  purchases  include  capacity  building  in  Member  States  for 
developing,  using  and  sharing  databases  and  business  intelligence  tools.  These  purchases 
may also enable the acquisition of integrated packages, comprising for example hardware 
and software, access and training, including training for the ‘Tobacco Tracking & Tracing’ 
database. 

59 European Commission, Programme Performance Statements (PPS, 2023), available at: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-
performance_en#:~:text=In%202023%2C%20the%20programme%20committed,of%20the%20COVID%2D19
%20period 

35 

 
 
 
 
 
Expected  results  for  actions  1-3: Strengthening  and  improvement  of  beneficiaries’ 
investigative  and  operational  capacity,  as  measured,  for  example,  by  the  number  of 
successful operations carried out with the purchased products in support of investigations 
into  activities  detrimental  to  the  Union’s  financial  interests.  This  includes  the  number  of 
arrests, convictions, seizures, confiscations, recoveries, prevented losses to the national and 
Union budgets, and fraud schemes uncovered. 

4. detection of illicit trade: 

The  purchase  and  maintenance  of  equipment  to  strengthen  beneficiaries’  operational  and 
technical  capacity  to  detect  smuggled  and  counterfeited  goods,  including  cigarettes  and 
tobacco, imported into the Union with the intention of evading VAT, customs duties and/or 
excise taxes. 

Expected  result:  Strengthening  and  improvement  of  beneficiaries’  (in  particular,  customs 
authorities’) technical capacity to  carry out  verifications of  trucks, containers  and (other) 
vehicles,  as  measured  by  the  number  of  verifications  and  ‘hits’  following  the  use  of  the 
equipment.’ 

In  order  to  avoid  any  duplication  in  EU  support,  the  UAFP  targets  its  support  at  the 
acquisition of types of equipment that do not fall under the scope of the CCEI or for equipment 
for which the beneficiaries are authorities other than the authorities targeted by that instrument. 
The  Commission  consistently  considers  any  potential  overlap  while  evaluating  the 
coherence and added value of a proposal for funding by the programme. 

36 

 
 
Figure 2: Intervention logic of the UAFP, established by ICF 60 

60 Based on identified needs and the field work executed by the external contractor. To be noted that in this presentation, the association agreement with Ukraine was not yet 

taken into consideration, as signed in February 2024, outside the study period envisaged. 

37 

 
 
 
 
3.2  The funding of the programme’s components and actions 

3.2.1  Budget and budget implementation 

Article 3 of the UAFP Regulation has set the available UAFP budget for the 2021-2027 MFF 
at EUR 181.2 million in current prices.  

According  to  the  UAFP  Regulation,  the  programme  will  be  implemented,  in  principle,  in 
direct management in line with the Financial Regulation, or (rather exceptionally) in indirect 
management  with  a  body  (for  example,  an  international  organisation)  referred  to  in  Article 
62(1), first subparagraph, point (c) of the Financial Regulation. 

Under Article 5 of the UAFP Regulation: 

-  The  programme  may  provide  funding  in  any  of  the  forms  laid  down  in  the  Financial 
Regulation,  in  particular  grants  and  procurement,  as  well  as  the  reimbursement  of 
travel and subsistence expenses as provided for in Article 238 of the Financial Regulation. 
The  programme  may  provide  funding  for  actions  carried  out  in  line  with  Council 
Regulation (EC) No 515/97, in  particular, to  cover the types of  costs referred to  in  the 
indicative list in Annex I to that Regulation. 

-  Where  the  supported  action  involves  the  purchase  of  equipment,  the  Commission  is 
required, if appropriate,  to  set  up  a  coordination mechanism to ensure  efficiency and 
interoperability  between  all  the  equipment  purchased  with  the  support  of  other  EU 
programmes (e.g. through DG TAXUD’s CCEI).  

Grants may cover up to 80% of the eligible costs. In exceptional and duly justified cases, if 
the proposed project is a ‘priority action’, this percentage may be increased to a maximum of 
90%61 under the conditions set out below62. 

1)  For the technical assistance call, the percentage may be increased when: 

(i)   the proposal reflects the findings of the PIF reports, in particular by identifying situations 
that  are  vulnerable  and  that  pose  the  greatest  threat  to  protecting  the  EU’s  financial 
interests; or 

(ii)  the  proposal  reflects  the  findings  of  the  European  Court  of  Auditors’  Special  report 

19/2017 on import procedures63. 

2)  For the training call, the percentage may be increased when: 

61 UAFP Regulation, Article 8 – Co-financing: ‘The co-financing rate for grants awarded under the Programme 
shall not exceed 80% of the eligible costs. Any funding in excess of that ceiling shall only be granted in 
exceptional and duly justified cases, which shall be defined in the work programmes referred to in Article 11, 
and such funding shall not exceed 90% of the eligible costs.’ 

62 The conditions, are as published each year in the annual calls for proposals related to technical assistance and 

to training. 

63 https://www.eca.europa.eu/en/publications?did=44169 

38 

 
 
 
 
(i)  projects  undertaken  by  scientific  and/or  research  organisations  fulfil  at  least  one  of  the 

criteria (a) and (b) below, in addition to criterion (c): 

(a) the project has been specifically created to promote studies in European criminal 

law; or 

(b) the project supports the creation of networks in this area; and 

(c) these activities are geared towards protecting the EU’s financial interests; or 

(ii) training projects cover one of the exceptional cases listed for the technical assistance call. 

Public  procurement  contracts  may  be  awarded  to  any  legal  entity  that  satisfies  the 
requirements  set  out  in  the  applicable  legal  framework.  Public  procurement  is  used  for 
purchasing (access to) databases, conferences and (specialised) training and the development 
of specific IT tools.  

3.2.2  Annual work programmes (AWP) 

In the Annex to the annual Financing Decisions, there is an overview of the activities to be 
carried  out  in  a  given  year  and  the  available  budget  per  sector  of  activities  (technical 
assistance  and  IT  support,  training,  conferences,  access  to  databases,  etc.).  It  also  lists  the 
calls for proposals to be published as well as the contracts to be concluded with the budget of 
that year. 

The table presented hereafter provides detailed figures on the adoption dates, references and 
amounts allocated to the different components of the programme, starting with the year 2020, 
i.e. the last year of implementation of the Hercule III programme. 

Table  4:  Overview  table  on  adopted  acts  (Financing  Decision  and  annual  work 
programmes / annual overviews), situation as of 2 July 2024 

Financing Decisions and AWP 
Year  Reference 

HERCULE III 

Adoption date 

Commitments 

Budget in EUR 
Payments 

Paid 
in % 

2020  C(2020) 28 

16.1.2020 

16 443 100 

16 293 436.44 

99.1% 

UAFP 

2021  AFIS64 C(2021)2120  7.4.2021 
2021  UAFP: C(2021) 5338  23.07.2021 

See figures below 
First component: 

64 For business continuity reasons, and, as the 2021-2027 MFF Regulation had not yet been adopted at the 
beginning of 2021, AFIS required a specific Commission Decision on financing and an annual work 
programme, covering a number of months at the beginning of 2021 until the adoption of the first 
Commission implementing decision on financing the UAFP in July 2021. 

39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
15 160 000 
AFIS:   7 964 000 
IMS:      929 000 
Total: 24 053 000 
First component: 
15 425 034 
AFIS:   8 009 640 
IMS:      934 325 
Total: 24 368 999  
First component: 
15 662 329 
AFIS:   8 227 888 
IMS:      959 783 
Total: 24 850 000 
First component: 
16 075 789 
AFIS:   8 445 091 
     IMS:      985 119 
  Total:   25 505 999 

14 518 248 
7 964 000 
914 476 
23 396 724 

10 236 438 
7 642 666 
837 162 
18 716 266 

14 133 748 
 7 518 587 
1 285 052 
22 937 387 

14.573.800 
7.011.793 
984.815 
22.570.408 

   95.8% 
100% 
98% 
97.3% 

66.4%  
 95.4%  
 89.6%  
 76.8% 

90.2% 
91.3% 
133.89% 
92.30% 
 (26.11.2024) 
90,7% 
83% 
99,7% 
88,5%  

N.A. 
N.A. 
N.A. 

N.A. 
N.A. 
N.A. 

2022  UAFP: C(2022) 1139  25.02.2022 

2023  UAFP: C(2023) 813 

07.02.2023 

2024  UAFP: C(2024) 645 

05.02.2024 

Annual implementation reports UAFP (Annual 
overview) 
2021  SWD(2022) 30565 
2022  SWD(2023) 27666 
2023  SWD(2024) 187 

23.9.2022 
27.7.2023 
25.7.2024 

3.2.3  Monitoring and reporting method 

Article 12 of the Regulation states that: 

‘Indicators  to  report  on  the  progress  of  the  programme  towards  the  achievement  of  the 
general  and  specific  objectives  laid  down  in  Article  2  are  set  out  in  Annex  II  [to  the 
Regulation].’  

To ensure an effective assessment of the programme’s progress towards the achievement 
of its objectives, the Commission is empowered to adopt delegated acts, in line with Article 
14, to amend Annex II with regard to the indicators where considered necessary, as well as to 
supplement  this  Regulation  with  provisions  on  the  establishment  of  a  monitoring  and 
evaluation framework. 

65 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=SWD:2022:305:FIN 
66 https://eur-lex.europa.eu/legal-content/LT/TXT/?uri=CELEX%3A52023SC0276 

40 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
The Regulation sets out that the Commission should report or continue to report annually on 
the  performance  of  the  programme  to  the  European  Parliament  and  to  the  Council  in  the 
framework of its ‘Annual Report on the protection of the Union’s financial interests – Fight 
against  fraud’.  The  progress  of  the  implementation  of  the  programme  is  measured 
through an ‘Annual Overview’, annexed to the PIF Report (See Table 4 above). 

As  part  of  the  discussions  on  the  PIF  reports,  the  European  Parliament  may  make 
recommendations for the annual work programme. The Commission must duly take those 
recommendations into account. 

The Commission’s annual performance reporting system must ensure that data for monitoring 
the implementation and the results of the programme are collected efficiently, effectively and 
in  a timely manner. To that end,  proportionate  reporting requirements must  be  imposed 
on recipients of EU funds and, where relevant, on the Member States.67 

In  line  with  Article  12(1)  of  the  UAFP  Regulation  and  its  Annex  II,  the  programme 
implementation is monitored through a set of key indicators, in relation  to which data will 
and are being collected, per objective, per year of implementation, published year +1 in the 
‘Programme Performance Statement’ by the Commission, per programme68. 

-  Specific  objective  1  (‘Hercule’):  Preventing  and  combating  fraud,  corruption  and  any 
other illegal activities affecting the financial interests of the EU. 

Indicator  1:  Support  in  preventing  and  combating  fraud,  corruption  and  any  other 

• 
illegal activities affecting the financial interests of the EU, as measured by: 

▪  1.1:  the  satisfaction  rate  of  activities  organised  and  financed  or  co-financed 

through the programme; 

▪  1.2:  the  percentage  of  Member  States  receiving  support  each  year  from  the 

programme. 

-  Specific  objective  2  (‘IMS’):  Supporting  the  reporting  of  irregularities,  including  fraud, 
with  regard  to  the  shared  management  funds  and  pre-accession  assistance  funds  of  the  EU 
budget. 

• 

Indicator 2: the user satisfaction rate for the use of IMS. 

67 See Article 12, Regulation (EU) 2021/785 of the European Parliament and of the Council of 29 April 2021 
establishing the Union Anti-Fraud Programme and repealing Regulation (EU) No 250/2014, (OJ L 172, 
17.5.2021, p. 110 -122). 

68 https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-

performance-statements/anti-fraud-performance_en  

41 

 
 
 
 
-  Specific  objective  3  (‘AFIS’):  Providing tools for information  exchange  and support for 
operational  activities  in  the  field  of  mutual  administrative  assistance  in  customs  and 
agricultural matters. 

Indicator  3:  the  number  of  instances  in  which  mutual  assistance  information  is 

• 
made available and the number of supported mutual assistance-related activities. 

The  programme  has  a  limited  financial  size  and  is  managed  by  a  small  team  in  OLAF.  In 
addition,  the  initial  intention  of  the  legislators  was  not  to  create  a  large  set  of  performance 
indicators in the UAFP Regulation so that the administrative burden would stay reasonable. 
For  these  reasons,  OLAF  applies  an  internal  working  method  on  how  it  monitors  and 
evaluates  the  implementation  and  outcome  of  the  programme’s  actions.  This  includes 
selected  on-the-spot  visits  to  beneficiaries’  premises  to  verify  the  existence  of  the  funded 
purchases for technical assistance (equipment). 

This  method  also  takes  into  consideration  the  result  indicators  mentioned  above  for  each 
specific  objective,  as  well  as  certain  input  and  output  indicators,  in  particular  on  budget 
and programme implementation (consumption of the budget, number of grant agreements 
and contracts, etc.).  

Consideration  has  to  be  made  for  the  fact  that  COVID-19  caused  the  duration  of  a 
considerable number of projects to be extended because certain equipment was not delivered 
in  2021  and  2022.  This  resulted  in  final  payments  being  postponed  until  the  delayed  final 
report was received. For this reason, payments were also delayed, showing likely a delayed 
‘consumption’ of the annual budget. 

Furthermore, the Commission (OLAF) also monitors the impact of the programme through 
information  in  grant  beneficiaries’  or  contractors’  final  technical  reports.  These  reports 
cover  the  results  achieved  with  the  activities  funded  under  the  programme  and  the 
contribution  made  to  the  protection  of  the  EU’s  financial  interests.  This  reporting 
accompanies their request to OLAF for final payment.  

For technical assistance, this information consists, for example, of the number of seizures of 
cigarettes  or  counterfeit  goods  that  were  made  with  the  purchased  technical  equipment. 
Beneficiaries also report (where available or quantifiable) on the estimated financial impact 
of  seizures  and  the  losses  to  national  and  EU  budgets  as  well  as  the  number  of  persons 
under investigation or detained suspects in relation to seizures or other operations. 

Moreover,  beneficiaries  of  technical  assistance  grants  must  submit  a  final  implementation 
report  within  1  year  after  the  closing  date  of  a  grant  agreement.  Through  this  final 
implementation  report,  the  beneficiary  can  report  more  extensively  on  the  achievements 
linked to the purchased equipment and demonstrate the contribution of the action and its 
results in achieving the programme’s objectives.  

42 

 
 
 
The beneficiaries  are  requested to  indicate what difficulties they had to overcome during 
the  implementation  of  the  grant  agreement,  such  as  procurement  problems  or  difficulties 
with the installation or maintenance of the technical equipment. 

For conferences, seminars and training events, the final technical reports contain the  results 
of  participant  surveys  on  the  usefulness  and  relevance  of  the  activities  for  daily  work 
and/or the fight against fraud.  

3.2.4  Actions under the Hercule component – analysis 

Table 5: Overview of the Hercule budget between 2014 and 2020 

Programme and period 

Allocated budget 

Hercule III (2014-2020) 

EUR 104.9 million 

UAFP (2021-2027) – Hercule component 

EUR 114.207 million  
(8.9% more than whole H-III programme) 
The  allocated  budget  has  increased  significantly  over  time  with  each  new  programming 
period, i.e. from EUR 12 million for Hercule I (EUR 4 million per year) to EUR 98.5 million 
for Hercule II and EUR 104.9 million for Hercule III. The UAFP has a budget of around EUR 
181.2  million  for  2021-202769  of  which  the  majority,  63%,  is  allocated  to  the  Hercule 
component (EUR 114.207 million). 

The  second  largest  part,  33%,  is  allocated  to  the  AFIS  component  and  the  remaining  part, 
3.8%, is allocated to the IMS component. 

3.2.4.1  Type of calls 
Between  2021  and  2023,  the  Hercule  component  of  the  programme  awarded  grants  to  98 
projects (74 for technical assistance and 24 for training and studies). 

Figure 3: Hercule component by type of calls (2021-2023) 

69 OLAF Union Anti-Fraud Programme (UAFP). Available at: https://anti-fraud.ec.europa.eu/policy/union-anti-

fraud-programme-uafp_en.  

43 

 
 
 
 
 
3.2.4.2  Activities and output 
The awarded projects included a variety of procurement (purchase of equipment) and training 
activities, reflecting a wide range of needs. These needs included acquiring new systems and 
equipment  to  boost  investigative  capacity  and  capabilities,  upgrading  systems  and  training 
staff to take advantage of technological advancements (e.g. digital forensics, deployment of 
artificial  intelligence),  and  sharing  information  and  best  practices  among  competent 
authorities in charge of combating fraud and irregularities.   

Based  on  the  review  of  the  calls  for  proposals  and  the  project  applications,  the  planned 
activities and output were grouped into the categories listed below. 

3.2.4.3  Technical Assistance 

1.  investigation and surveillance equipment and methods 
2.  digital forensic hardware 
3.  data analytics technologies and data purchases 
4.  detection of illicit trade. 

3.2.4.4 

 Training 

1.  specialised training sessions  
2.  conferences, workshops, and seminars  
3.  staff exchanges  
4.  comparative law studies and periodical publications.  

Figure 4 below presents the relative weight of the different types of activities/output. 

Figure 4: Hercule component by type of activities and output (2021-2023 calls) 

Source: ICF analysis of the documentation of the Hercule component projects 

44 

 
 
 
 
3.2.4.5  Size of grants 
The size of grants varies from over EUR 1 million for three technical assistance projects to 
less  than  EUR  50  000  for  some  training  grants  (minimum  threshold:  EUR  40  000  for 
training). About half the overall grant amount for the Hercule component was awarded to 20 
projects with grants over EUR 500 000. A total of 29 technical assistance projects have grants 
below EUR 300 000, amounting to 17% of the total grant amount.  

Most grants for training activities and conferences are around or below EUR 100 000, with 
only three grants above EUR 200 000 (one for a publication and two for comparative studies). 

3.2.4.6  Beneficiary countries 
Between 2021 and 2023, grants were awarded to applicants from 17 Member States.  

After an evaluation of all the received applications, over 77% of the total grant amount and 
almost 80% of the number of projects were awarded to beneficiaries from six Member States: 
Romania, Italy, Latvia, Spain, Poland and Lithuania.  

The uneven distribution of grants is mostly due to the lack of applications from many of the 
eligible countries (and to the differences in project size and budget). One of the main reasons 
communicated for the absence of applications from several Member States is the availability 
of national funds. OLAF does a lot of dissemination via its various networks about the launch 
of  the  calls  for  proposals.  At  various  training  sessions  and  presentations  in  OLAF  and 
Member  States,  the  programme  and  its  purpose  is  regularly  highlighted.  However,  on  the 
procurement  side  of  the  Hercule  component,  all  Member  States  receive  valuable  support 
(through  free  access  to  commercial  databases,  IT  analytical  tools  and  specialised  anti-fraud 
training). 

At  the  same  time,  through  its  AFIS  and  IMS  components  and  training  for  digital  forensic 
analysts, the UAFP does reach all Member States and other eligible countries. 

Figure 5: Hercule component 2021-2023 – distribution of grants by beneficiary country  

Source: ICF analysis of the documentation of the Hercule component projects 

45 

 
 
 
 
 Type of beneficiaries 

3.2.4.7 
The beneficiaries of the Hercule component are law enforcement agencies (LEAs), customs 
authorities,  public  agencies,  regional  authorities,  universities  and  non-governmental 
organisations. The distribution of funds among these groups is shown in Figure 6 hereafter. 

As  expected,  most  beneficiaries  are  public  agencies  (such  as  tax  administration,  anti-
corruption agencies and investigation units). They received 42% of the grant total and LEAs 
received 41%. Customs agencies were awarded 11 grants, accounting for 11% of all grants.  

All grants awarded to universities and NGOs are for training, academic studies, seminars and 
workshops (as these type of organisations can submit eligible proposals). 

Figure 6: Hercule component – grants by type of beneficiaries 

Source: ICF analysis of the documentation of the Hercule component projects 

3.2.4.8  End date of projects 
The  end  date  of  the  awarded  projects  is  important  in  the  context  of  this interim  evaluation. 
This is because it indicates how many of the projects would have been completed by the cut-
off date for the analysis of the projects’ output and impacts. 

Only 14 of the awarded projects were planned to  finish by the end of 2023 (of them, seven 
were planned to be completed in November or December 2023). Therefore, most analysis and 
conclusions  have  been  based  on  planned  objectives  and  output  and  interim  results,  where 
available, considering delays relating to COVID-19. 

3.2.4.9  Procured access to external databases 
In  addition  to  grants,  the  Hercule  component  of  the  UAFP  provides  funding  for  the 
procurement of equipment and services and for access to external databases, which are used 
by customs and other law enforcement authorities in all Member States. 

46 

 
 
 
 
 
In the evaluation period, access to the following three external databases was procured70. 

-  Worldwide  companies  information  (Dun  &  Bradstreet).  This  supports  customs 
investigations  carried  out  by  Member  State  authorities  related  to  fraud  undermining  the 
financial  interests  of  the  EU.  The  database  enables  the  creation  of  risk  profiles  and  the 
verification  of  certain  information  on  companies,  company  structures  and  beneficiary 
owners.  

-  Global trade statistics (IHS Global Trade Atlas). This provides import and export data, 
specifically the quantities and values of certain goods imported into a given Member State 
from  non-EU  countries.  The  database  can  support  investigations  into  trans-shipment, 
evasion  of  anti-dumping  or  countervailing  duties,  misrepresentation  of  the  country  of 
origin, exporter or container swapping, and undervaluation fraud.  

-  Vessel  and  maritime  information  (source:  Lloyds).  This  provides  information  on 
vessels and movements  and supports risk analysis and intelligence related to  worldwide 
commercial vessel operations. The database is used to cross-check the origin of goods in 
containers,  detect  potentially  suspicious  import  transactions  and  risky  shipments  and 
develop risk profiles. 

The  total  budget  for  the  procured  access  set  out  in  the  AWPs  between  2021  and  2023  was 
EUR 3 469 329, and the amount spent was EUR 2 517 76071. The procurement is based on 
framework contracts with those companies owning the respective databases.  

The number of users and the usage rates were stable between 2021 and 2023. The latest user 
statistics (2023 data) for the three databases are presented in the table below. 

Table 6: User statistics for the three databases 

Database 

Worldwide 
information 

Users/accounts 

Activity 

companies 

68 user accounts 

About 3 000 logins/year 

Global trade statistics 

750 user accounts 

About 5 500 logins/year 

Vessel 
information 

and 

maritime 

40 user accounts  

About 8 000 visits/year 

Source: ICF analysis of data provided by OLAF 

User  surveys  have  been  carried  out  on  an  annual  basis.  Overall,  customs  and  investigative 
authorities  have  pointed  out  that  the  databases  are  useful  tools  supporting  their  daily 

70 Information collected from the PIF Report - 2022. 
71 Interview with OLAF. Information provided by OLAF. 

47 

 
 
 
 
operations (9 out of 27 Member States responded to the 2024 survey; the survey is managed 
with open questions, and quantitative results are not available).  

Users also indicated that the external databases provide complementary data and are used in 
combination  with  the  internal  applications  hosted  in  AFIS,  such  as  CSM,  or  with  national 
databases72. 

3.3  Association agreement between the EU and Ukraine on participation 

3.3.1  Scope of the association 

According to Commission Decision C(2024) 760 of 12 February 2024 on the approval of an 
agreement  between  the  EU  and  Ukraine  on  the  participation  of  Ukraine  in  the  UAFP  (‘the 
Commission  Decision’)73,  ‘Ukraine  will  participate  as  an  associated  country  in  and 
contribute to all parts of the programme referred to in Article 2(2), point (a) of Regulation 
(EU)  2021/785.  This  is  subject  to  the  condition  that  the  applicable  legal  requirements,  the 
nature or the scope of the actions financed allow for third-country participation. 

This  association  does  not  affect  the  possibility  for  Ukraine  to  participate  in  certain 
operational activities under Article 2(2), points (b) and (c) of Regulation (EU) 2021/785. The 
conditions for such participation are governed by the applicable legal framework.’ 

3.3.2  Terms and conditions of participation in the Union anti-fraud programme 

(excerpts of the related Commission Decision) 

According  to  Article  2(1)  of  the  Commission  Decision,  ‘Ukraine  shall  participate  in  the 
programme  in  accordance  with  the  conditions  laid  down  in  Protocol  III  on  a  Framework 
Agreement  between  the  European  Union  and  Ukraine  on  the  General  Principles  for  the 
Participation of Ukraine in Union programmes and under the terms and conditions set forth 
in this Agreement, in the legal act referred to in Article 1 of this Agreement, as well as in any 
other  rules  pertaining  to  the  implementation  of  the  programme,  in  their  most  up-to-date 
versions.’ 

Article  2(2)  of  the  Commission  Decision  states  that,  ‘unless  otherwise  provided  for  in  the 
terms and conditions referred to in paragraph 1 of this Article, legal entities established in 
Ukraine  may  participate  in  actions  of  the  programme  under  conditions  equivalent  to  those 
applicable  to  legal  entities  established  in  the  Union,  including  respect  for  EU  restrictive 
measures.’ 

72 User feedback and survey results provided by OLAF. 
73 Commission Decision of 12.2.2024 amending Decision C(2023) 6114 on the approval of an Agreement 
between the European Union and Ukraine on the participation of Ukraine in the Union anti-fraud 
programme, C(2024) 760, 12.2.2024. 

48 

 
 
 
 
It  has  also  been  decided  that English  shall  be  used  for  the  procedures  related  to  requests, 
contracts  and  reports,  as  well  as  for  other  administrative  aspects  of  the  participation  of 
Ukraine in the programme. 

This participation entered into force retroactively on 1 January 2023, allowing Ukraine to file 
applications for funding, among other things, in relation to the Hercule component, covering 
technical assistance as well as training opportunities to be funded. 

So far, Ukraine has filed applications for funding in the following areas of eligible actions of 
the programme: 

-  one application for financial support in the field of technical assistance in 2023: the 
application  was  unsuccessful,  and  the  grant  was  not  awarded  due  to  a  lack  of 
sufficient budget; 
five  applications  for  financial  support  in  the  field  of  technical  assistance  in  2024: 
following  the  evaluation  of  the  applications  and  the  scoring,  one  is  considered 
eligible for funding under the 2024 call. 

- 

3.4  Eligible actions of the UAFP – Hercule component 

Only  actions  implementing  the  objectives  of  the  programme  are  eligible  for  funding. 
Regardless  of  any  other  action  provided  for  in  the  AWPs  under  Article  11  of  the  UAFP 
Regulation, the following actions may be considered eligible for funding (in 2024): 

-  provide  technical  knowledge,  specialised  and  technically  advanced  equipment  and 
effective  IT  tools  leading  to  closer  transnational  and  multidisciplinary  cooperation  and 
cooperation with the Commission; 

- 

improve  staff  exchanges  for  specific  projects,  provide  the  necessary  support  for  these 
exchanges  and  facilitate  investigations,  in  particular  by  setting  up  joint  investigation 
teams and cross-border operations;  

-  provide  technical  and  operational  support  for  national  investigations,  in  particular  for 
customs  and  law  enforcement  authorities,  to  step  up  the  fight  against  fraud  and  other 
illegal activities; 

-  build  IT  capacity  in  the  Member  States  and  third  countries,  increase  data  exchange  and 

develop and provide IT tools for investigating and monitoring intelligence work; 

-  organise  specialised  training,  fraud  analysis  workshops,  conferences  and  studies  to 
improve cooperation and coordination between departments responsible for protecting the 
financial interests of the EU. 

Where the action to be supported involves the purchase of equipment, the Commission must 
ensure that the funded equipment is appropriate for contributing to the protection of the EU’s 
financial  interests.  This  is  verified  before  granting  funds  to  the  project  by  an  evaluation 

49 

 
 
 
committee that checks the submitted project proposals by applicants on, among other criteria, 
their eligibility and EU added value.  

In  addition,  the  appropriateness  and  efficient  use  of  the  equipment  purchased  is  verified 
through the received (ex post) reporting by the beneficiaries to the Commission (OLAF) and 
by planned visits at the premises of the beneficiaries. 

Such  on-the-spot  visits  took  place  in  the  first  quarter  of  2024,  involving  three  beneficiaries 
from a Member State. The verifications included an assessment of whether: (i) the purchased 
equipment was in line with the description of the action; (ii) the costs declared were in line 
with  the  invoices  incurred  by  the  beneficiary  during  the  period  provided  in  the  grant 
agreement and recorded in the beneficiary’s accounts; (iii) the equipment was present at the 
declared location, in working order and used; and (iv) the operators were trained or certified 
(where relevant) and able to use the equipment. 

No  error  was  detected  during  these  verifications.  The  grant  beneficiaries  gave  positive 
feedback about the programme, especially related to: 

- 

- 
- 

the focus on purchasing equipment and allowing a selection of state-of-the-art technology, 
which is needed in a fast-moving technological and fraud environment; 
the absence of requiring an EU partner, which limits the administrative burden; 
the swift assessment and award of grant files.  

3.5  Eligible entities – Hercule component 

According to Article 10(1) of the UAFP Regulation, the complementary eligibility criteria set 
out in the Regulation apply, in addition to the criteria set out in Article 197 of the Financial 
Regulation.  This  means  that,  as  specified  in  Article  10(2)  of  the  UAFP  Regulation,  the 
following entities are eligible under the programme: 

a)  public  authorities  that  can  contribute  to  achieving  one  of  the  objectives  referred  to  in 
Article 2 of the Regulation and are established in: 

i.  a Member State or an overseas country or territory linked to it; 

ii.  a third country associated to the programme;  

iii. a  third  country  listed  in  the  work  programme  under  the  conditions  specified  in 
paragraph 3; 

b)  research and educational institutes and non-profit-making entities that can contribute to 
the achievement of the objectives referred to in Article 2 of the UAFP Regulation, provided 
that they have been established and have been operating for at least 1 year in: 

i.  a Member State; 

50 

 
 
 
 
ii.  a third country associated to the programme;  

iii. a third country listed in a work programme under the conditions specified in paragraph 
3; 

c)  any legal entity created under EU law or any international organisation. 

Moreover,  according  to  Article  10(3)  of  the  UAFP  Regulation:  ‘Entities  referred  to  in 
paragraph  2  established  in  a  third  country  that  is  not  associated  to  the  programme  are 
exceptionally eligible under the programme where this is necessary for the achievement of the 
objectives  of  a  given  action.  Such  entities  in  principle  bear  the  cost  of  their  participation, 
except in cases that must be duly justified in the AWP’. 

3.6 

Implementation  of  the  Irregularity  Management  System  (IMS)  and  the  Anti-
Fraud Information System (AFIS) 

Like AFIS, IMS is not a financing programme supporting grantees’ projects. Its main role is 
to facilitate reporting detected cases of irregularities and of suspected or established fraud in 
the  implementation  of  EU  funds.  The  system  is  used  by  EU  Member  States  and  other 
beneficiaries  (spread  over  34  countries  and  used  by  789  organisations  and  over  3 230 
registered users as of March 2024)74.  

IMS is perceived by users and stakeholders as a useful reporting and tracking tool having, in 
particular, on the one hand, the following strengths: 

- 

- 

it is the only IT system in the EU where data on past and closed cases of irregularities are 
collected and can be searched; 
IMS  provides  contextual  information  on  irregularities  and  on  the  state  of  the  fraud 
identified in the Member States, candidate countries and third countries; 
IMS provides a standardised tool to collect data on irregularities; 

- 
-  most  users  find  the  system  reliable  and  user-friendly,  highlighting  features  like  the 
visibility  of  data,  the  ability  to  download  it  and  the  availability  of  data  in  all  EU 
languages; 
the IMS interfaces with national databases and can support automatic data transfer. 

- 

On the other hand, the evaluation identified certain IMS weaknesses related to technical 
properties and the management of the system, and also to the way users were entering data in 
the system. Additionally, there is a need to ensure the quality of data because not all cases 
were entered into the system (which obviously depends on the identifying partner country) 
and not all information on the cases was available (completeness, depending on the partner 
again). The input of data by different users in distinct Member States, regions, etc. was not 

74 Data provided by OLAF (IMS team). 

51 

 
 
 
 
 
always consistent, homogeneous or coherent (reliability and consistency). The data were not 
always up to date with the most recent developments (promptness). 

The technical weaknesses that were mentioned, i.e. issues related to authentication, 
difficulties when searching for information and time-consuming checks of irregularities, 
insufficient communication on updates and improvements to IMS, and insufficient guidance 
on which information to enter, have largely been tackled by the very recent October 2024 
IMS release, striving to solve the mentioned issues in the near future (as training and further 
guidance is still ongoing). 

There are no penalties for countries that fail to fully report. This may – to a certain extent – 
explain  the  system’s  lower  rate  of  use  by  contributing  authorities.  OLAF  investigators  and 
selectors and Commission users from shared management programmes also use data from the 
IMS to a relatively low extent. This stems from the issues already mentioned as well as a lack 
of awareness of how the system works and what it can offer. 

3.6.1 

Implementation – 2023 

The IMS operates under the AFIS platform. The common information system requires stable 
financing over time to ensure its sustainability.  
The UAFP finances the IMS. Through this component, the UAFP allocated EUR 7 000 000 
for  2021-2027  and  EUR  985  119  for  2024.  The  aim  is  to  support  reporting  irregularities, 
including  fraud,  of  the  shared  management  funds  and  pre-accession  assistance  funds  of  the 
EU budget. 

The implementation is reported on for the most recent period, in this case 2023, as reported 
in 2024 by the Commission. 

3.6.2  Main activities  

To  protect  the  EU’s  financial  interests,  EU  law  requires  Member  States  managing  EU 
spending under shared management and countries benefiting from pre-accession assistance to 
notify the Commission of any irregularities (including suspected and proven fraud) detected 
in areas where the EU provides financial support (see list in Chapter 2.1.1.5).  

To  facilitate  the  reporting  of  irregularities,  the  IMS  has  been  developed  and  put  at  the 
disposal  of  the  Member  States  and  other  beneficiary  countries.  This  dedicated  electronic 
system is being used by 34 countries.  

Member  States,  candidate  countries  and  other  non-EU  countries  have  set  up  a  hierarchical 
reporting  structure  with  multiple 
levels  of  responsibility.  Around  750  reporting 
organisations,  covering  over  3 000  IMS  users,  are  responsible  for  the  timely  reporting  of 
irregularities.  

52 

 
 
 
 
The  reporting  workflow  includes  multiple  hierarchical  levels  and  various  roles  within  the 
same level to ensure that several quality checks are performed before the reports are sent to 
the Commission. 

Reporting authorities provide information on: 

-  who committed the irregularity/fraud (persons involved); 

- 

- 

the support measure such as fund, programme, project, budget line; 

the financial impact (expenditure and irregular/fraudulent amount); 

-  how the irregularity/fraud was committed; 

-  when the irregularity/fraud was committed; 

-  where the irregularity/fraud was committed; 

-  how the irregularity/fraud was detected;  

-  what administrative, judicial or penal follow-up sanctions were imposed. 

3.6.3 

IMS – budgetary implementation 

The  2023  AWP  had  a  budget  of  EUR 959  783  dedicated  to  IMS  maintenance,  IT 
development  and  studies.  The  full  available  amount  for  2023  was  committed.  The  total 
indicative budget for this component for 2021-2027 is EUR 7 million.  

3.6.4  Maintenance and development 

In 2023, eight releases were launched. Features included allowing IMS users to manage and 
monitor EDES75-hits,  adding  case summaries and  descriptions of codes,  improving the B2B 
services and fixing a number of identified issues. 

3.7 

IMS developments 

Overall,  the  IMS  is  perceived  by  users  and  stakeholders  as  a  useful  tool  for  reporting  and 
tracking irregularities and fraud. The strength of the IMS lies in its facility to search for past 
and closed cases, which enables tracking irregularities. Another strength of the IMS is that the 
system is considered to be reliable and provides users access to the information they enter.  

The IMS is the only EU system where such data are collected. For some EU Member States, 
it is also the only tool to gather such data and where that data can be consulted. This means 
that it is a unique system, sometimes even at  national level. The data gathered provides the 
main  source  of  knowledge  about  the  scale  and  impact  of  detected  fraud  and  irregularities 
tracked and reported through annual PIF reports.  

75 The Early Detection and Exclusion System (of the Commission). 

53 

 
 
 
 
Some  users  highlighted  challenges  related  to  authentication,  difficulties  in  searching  for 
information, time-consuming checks of irregularities, insufficient communication on updates 
and improvements in the IMS, insufficient guidance on which information to enter, the need 
to  better  reconcile  information  in  the  IMS  with  other  IT  tools,  and  the  need  to  ensure  the 
quality of data.  

In addition to the challenges with how the tool itself works, broader issues connected to the 
tool relate to a lack of sufficient knowledge and training among some users preventing them 
from using the tool effectively. 

There  is  also  a  need  to  modernise  certain  aspects  of  the  IMS  user  interface  to  improve  the 
overall user experience. Furthermore, there was a relatively low usage rate of this data across 
OLAF investigators and selectors (who evaluate the merits of new incoming information for 
opening  investigations)  and  Commission  users  from  shared  management  programmes.  This 
low rate was attributed to a low awareness of what the system is and does, how to use it and 
find the cases of interest in the system, and how to reconcile the information with other data 
sources and IT systems. 

In  the  respective  annexes  to  the  annual  PIF  reports  published,  figures  do  not  include  third 
countries (including pre-accession countries) or direct expenditure irregularities. 

The number of irregularities reported as ‘fraudulent’ measures the results of Member States' 
work  to  counter  fraud  and  other  illegal  activities  affecting  the  EU's  financial  interests. 
Therefore, the figures should not be interpreted as indicating the level of fraud in Member 
States.  

In  2019,  11  726  irregularities  were  reported  to  the  Commission  (OLAF),  involving  a  total 
amount  of  approximately  EUR  1.6  billion.  Of  these  irregularities,  939  were  reported  as 
fraudulent,  representing  an  amount  of  approximately  EUR  444  million  (not  taking  into 
account the amount reported as fraudulent by the UK, which was about EUR 2.3 million)76. 

In 2021, 10 232 irregularities were reported to the Commission, involving a total amount of 
approximately  EUR  3.2  billion.  Of  these  irregularities,  948  were  reported  as  fraudulent, 
representing  an  amount  of  approximately  EUR  1.8  billion  for  EU-2777.  This  much  higher 
amount  includes  an  amount  of  EUR  1.4  billion  on  the  expenditure  side,  reported  by  one 
Member State in 2021. 

76 Source: European Commission (2020), 31st Annual Report on the protection of the European Union's 
financial interests - Fight against fraud – 2019 (COM(2020) 363) (PIF Report 2019), https://anti-
fraud.ec.europa.eu/document/download/cbf4c2bc-1217-4123-a3b0-a7cbb9355931_en?type:pdf.  
77 Source: European Commission (2022), 33rd Annual Report on the protection of the European Union’s 

financial interests and the Fight against fraud – 2021 (COM(2022) 482), https://anti-
fraud.ec.europa.eu/document/download/ac7fe82e-c7df-44c0-8df7-277f73032d4b_en?filename=pif-report-
2021_en_0.pdf. 

54 

 
 
 
 
In 2023, 12 240 irregularities were reported, involving a total amount of approximately EUR 
1.8 billion (EU-27). Of these irregularities, 988 were reported as fraudulent, representing an 
amount of approximately EUR 564.3 million for EU-2778. 

Between  2021  and  2023,  the  overall  number  of  reported  irregularities  increased  by  19.6%, 
after  having  decreased  between  2019  and  2021.  Between  2021  and  2023,  the  number  of 
irregularities reported as fraudulent increased by 4%. 

3.8  The Anti-Fraud Information System – Implementation 

Unlike  the  Hercule  component,  AFIS  does  not  provide  applicants  with  financial  support  to 
develop projects. Its main objective is to facilitate the exchange of fraud-related information 
between national and EU administrations. 

The  effectiveness  of  its  implementation  can  be  evaluated  by  its  output  (e.g.  the  number  of 
new  applications  developed,  the  number  of  upgrades  performed  or  features  added  and  the 
number of mutual assistance activities, such as joint customs operations supported).  

A  key  performance  indicator  for  AFIS  is  the  number  of  information  items  on  mutual 
assistance made available. For assessing the impact of AFIS output, the key indicator is the 
level of satisfaction of AFIS users as measured by  periodic user surveys. The results from 
the latest survey in 2023 are compared with the results from the previous one (in 2019) in the 
table below.  

The  AFIS  budget  performance  is  determined  by  the  OLAF-set  indicator,  which  reflects  the 
amount of mutual assistance information made available and the number of supported mutual 
assistance-related activities. For 2021-2023, the targets for this indicator were exceeded. The 
AFIS budget also contributed to improving mutual administrative assistance among customs 
authorities  in  the  EU.  It  supported,  between  2021  and  2023,  a  total  of  35  joint  customs 
operations  and  helped  organise  training  sessions  for  key  AFIS  applications,  such  as  CIS, 
VOCU, CSM and AMT79.  

3.9 

Implementation of the UAFP in 2023 

The implementation of the programme is reported on for the most recent period, in this case 
2023, as reported in 2024 by the Commission. 

Through  this  third  component  of  the  programme,  the  UAFP  allocated  EUR  60  million  for 
2021-2027  to  AFIS,  of  which  EUR 8 445 091  has  been  allocated  for  2024.  The  aim  is  to 

78 Source: European Commission (2024), 35th Annual Report on the protection of the European Union’s 

financial interests and the Fight against fraud – 2023 (COM(2024) 318, 25.7.2024). 

79 Data provided by OLAF (AFIS team). 

55 

 
 
 
 
provide  tools  for  information  exchange  and  support  for  operational  activities  in  the  field  of 
mutual administrative assistance in customs and agricultural matters.  

This component of the UAFP also covers the cost of using the Customs Information System 
(CIS) provided for in instruments adopted under Article 87 TFEU, in particular in Decision 
2009/917/JHA, given that those instruments state that such expenditure is to be borne by the 
general  budget  of  the  EU.  The  Customs  Information  System  is  an  automated  information 
system. It helps Member States prevent, investigate and prosecute activities that are in breach 
of customs or agricultural legislation. It does so by increasing, through faster dissemination of 
information,  the  effectiveness  of  the  cooperation  and  control  procedures  of  the  customs 
administrations whose remit covers such activities. 

The AFIS platform launched 44 releases, consisting of several combined application releases. 
A new version of the Import, Export and Transit directory (IET) and several other application 
releases  and  fixes  were  developed  in  2023,  totalling  more  than  110  releases.  Among  these 
were several major releases: 

- 

- 

- 

a  new  version  of  the  Import  Export  and  Transit  directory  that  allows  users  to  carry  out 
advanced searches, set alarms and export data (e.g. in Excel format) on imports, exports 
and transits; 

two  new  versions  of  the  Container  Status  Message  directory  implementing  visual 
analytics for container trips and the new Container Origin Signals module, which signals 
potential origin fraud; 

an  improvement  to  the  anti-fraud  analytics  platform,  providing  extended  computing 
resources, improved access, added data sources and enabling OLAF analysts to combine 
customs and trade data from different sources and conduct advanced analysis. 

In 2023, AFIS also provided technical support to 13 joint customs operations’ meetings. 

The 2023  user survey confirmed that AFIS remains a useful tool for its end users, and  that 
AFIS  is  able  to  deliver  functioning  tools  for  information  exchange  in  its  dedicated  area  of 
action. Two thirds of the survey respondents believed that the applications available in AFIS 
are up-to-date tools that help tackle the latest trends in fraud and related irregularities. 

The  percentage  of  users  who  are  satisfied  with  the  functionality  and  performance  of  the 
various AFIS applications remains high  (with the most frequently used  applications  scoring 
satisfaction rates above 80%). There are some minor differences compared with the results of 
the 2019 AFIS satisfaction survey (see Table 7 hereafter). 

56 

 
 
 
 
 
Table  7:  Comparison  of  the  2023  AFIS  satisfaction  survey  with  the  2019  survey  (key 
applications) 

Indicator 

AFIS 2019 
result 

AFIS 2023 result  Change % points 

Number of responses (total) 

799 

1 320 

(availability/ 

92% / 89% 

93% / 90% 

+65% 

+1 / +1 

Helpdesk 
performance) 

AFIS  Mail 
performance) 

+ 

CIS 
performance) 

CSM 
performance) 

(functionality/ 

87% / 86% 

86% / 86% 

-1% / = 

(functionality/ 

85% / 86% 

83% / 86% 

-2% / = 

(functionality/ 

91% / 92% 

87% / 88% 

-4% / -4% 

General  opinion  (relevant  to 
– 
professional 
agree/slightly agree) 

needs 

57% / 27% 

59% / 23% 

+2% / -4% 

Source: AFIS satisfaction survey 2019 and 2023 (N=1320) 

3.10  AFIS – developments in the past decade80 

As  AFIS  is  not  a  financial  programme,  it  has  not  been  subject  to  the  corresponding 
(programme)  evaluation  cycles.  Nevertheless,  there  is  a  set  of  indicators  that  can  help 
evaluate the performance of the related operational activities81. 

In particular, OLAF's Internal Audit Capability (IAC )  conducted  an  audit  to  assess  the 
performance  of  AFIS  in  2013  and  2014.  Its  2014  report82  confirmed  the  efficiency  and 
effectiveness of AFIS and the adequacy of the management and coordination mechanisms. It 
concluded that stakeholders considered the quality of AFIS services as satisfactory to highly 
satisfactory. 

80 Source: Commission staff working document (Staff Working Document, SWD(2013) 428, 15.12.2023), 
Evaluation of Council Regulation (EC) No 515/97 on mutual assistance between the administrative 
authorities of the Member States and cooperation between the latter and the Commission to ensure the 
correct application of the law on customs and agricultural matters. 

81 Notably on the basis of the Commission annual reports on AFIS activities (pursuant to Art. 51a of Council 

Reg. 515/97) as part of the Commission report on the protection of the EU's financial interests (PIF Report). 

82 Audit report on performance audit of AFIS, Ares(2014)2592647 (OLAF internal document).  

57 

 
 
 
 
Overall, already back in 2014, the operational activities under AFIS were a valuable support 
to Member States' and the Commission's operational and investigative work, which aimed to 
detect customs infringements, recover customs duties and improve customs cooperation in the 
anti-fraud  area.  The  efforts  made  before  in  addressing  identified  shortcomings  have 
contributed  to  increasing  the  level  of  trust,  participation  and  satisfaction  of  Member  States' 
competent authorities. 

More  specifically,  the  permanent  physical  (Permanent  Operational  Coordination  Unit  – 
POCU) and IT infrastructure (Virtual Operation Coordination Unit – VOCU) for the support 
of  JCOs  has  been  regularly  used  by  the  Commission,  Member  States,  third  countries  and 
organisations on many occasions. 

The  evaluation  reports  submitted  after  the  completion  of  JCOs  show  that  this  physical 
structure  and  AFIS  application  strongly  facilitate  the  coordination  tasks  associated  to  JCOs 
with a large number of participants. Their use is frequently recommended in the evaluation of 
these  operations.  The  fact  that  these  facilities  are  also  frequently  used  for  operational 
activities  in  the  area  of  law  enforcement  cooperation  (free  of  charge  for  the  participants)  is 
additional proof of Member States' appreciation of the AFIS. 

Importantly,  covering  the  expenses  for  transport,  accommodation  and  daily  allowances  for 
representatives  from  Member  States  attending  training  courses  and  meetings  related  to 
investigative and operational actions, including JCOs, has proven to be critical in securing the 
participation of a large number of Member States in these initiatives83. 

Following  Member  States’  recommendations  provided  at  workshops  organised  by  the 
Commission, OLAF has strengthened, between 2014 and 2018, the involvement of Member 
States in all stages of development of new or updated AFIS applications, aiming to improve 
its  use  and  user  satisfaction.  This  was  the  case  during  the  update  of  AFIS  VOCU84,  AFIS 
Mail85,  Customs  Information  System  (CIS)86  and  IMS87,  which  involved  a  large  number of 
Member  State  participants  in  the  above-mentioned  workshops.  As  a  result  of  this 

83 Annex I of the UAFP Regulation provides for an indicative list of costs referred to in Article 5(3) that the 

UAFP will fund for actions carried out in line with Regulation (EC) No 515/97. 

84 VOCU: four workshops, with participants from: Belgium, Bulgaria, Germany, Spain, France, Ireland, Italy, 
Malta, the Netherlands, Portugal, Slovakia, and the United Kingdom on 15 & 16 May 2012, 29 & 30 April 
2013, 4 & 5 June 2013 and 6 & 7 June 2013. 

85 AFIS MAIL: two workshops, with participants from: Germany, Denmark, Spain, France, Malta, the 

Netherlands, Portugal, and the United Kingdom on 5/6 February 2015 and 2 June 2015.  

86 CIS: six workshops, with participants from: Austria, Germany, Denmark, Spain, France, Greece, Hungary, 
Italy, the Netherlands, Poland, Portugal, and the United Kingdom on 15 March 2016, 6 December 2016, 6 
April 2017, 5 October 2017, 27 October 2017 and 15 March 2018. 

87 IMS: one workshop took place during the development of IMS5 in which participants of 17 Member States 
and one candidate country participated (16 October 2014 and 3 February 2015). The four IMS5-training 
sessions (October – December 2015) were attended by representatives of all (28) Member States.  

58 

 
 
 
 
collaboration,  Member  States’  acceptance  and  use  of  these  applications  significantly 
improved, along with an increase in the size of these user communities. 

In terms of AFIS and IMS, as IT platforms being directly managed by OLAF, they were not 
subject to the same evaluation process as the Hercule III programme (as they were not part of 
the programme at the time). As such, there is limited data on their use in the years before their 
integration into the UAFP. Nevertheless, some evaluative evidence exists.  

Results  from  the  2019  AFIS  satisfaction  survey  showed  that  most  of  the  applications  were 
evaluated  positively  by  the  participants  of  the  survey  in  terms  of  both  functionality  and 
performance, with satisfaction rates often exceeding 80%88. On the available training options, 
one third of the participants declared that they used at least one of the training options on the 
AFIS  Portal,  and  most  of  them  (more  than  67%)  identified  the  user  portal  manuals  as  their 
main training source for the AFIS Portal and its applications. 

Figure  7:  2019  AFIS  survey:  Distribution  among  the  AFIS  applications  based  on 
measuring their regular use 

3.11  AFIS budget evolution between 2014 and 2023 

The total indicative budget for this component for 2021-2027 is EUR 60 million. The 2021 
budged reached EUR  8.89 million  and was 19.3% higher than in  2020 due to  specific  IMS 
funds included in 2021. 

In  2021,  AFIS  was  allocated  an  amount  of  EUR 7 964 000  for  the  first  working  year. 
However, from this budget allocation, EUR 2 775 704.46 had already been committed under 

88 OLAF (2020). AFIS Survey 2019, Summary Report. 

59 

 
 
 
 
 
Commission  Decision  C(2021)2120  of  7  April  2021  on  the  interim  financing  of  the  AFIS 
and the adoption of its 2021 work programme89. 

That  Decision  was  then  repealed  with  effect  from  17  May  2021  (the  day  on  which  the 
Regulation establishing the UAFP entered into force)  but did not affect the actions initiated 
under that Decision. This legal arrangement was necessary to cover the financing of the AFIS 
between 1 January 2021 and 29 April 2021 when the Regulation was adopted. 

For  2021,  this  left  a  budget  of  EUR  5  188  295.54  available  for  the  remainder  of  the  2021 
AFIS work programme. EUR 8 445 091 has been allocated to AFIS for the year 2024. This is 
an increase of 6.04 percentage points, compared to 2021. 

4  EVALUATION FINDINGS (ANALYTICAL PART) 

This Chapter presents a summary of the main evaluation findings, following the analysis and 
triangulation  of  the  evidence  collected  by  the  external  study  by  ICF.  To  keep  the  reporting 
here succinct, the questions, responses and analysis are described in full detail in Annex III. 

4.1. To what extent was the intervention successful and why? 

This section summarises the analysis presented in the study in relation to the three criteria of 
effectiveness, efficiency and coherence, covering the three programme components. 

The  intervention  is  considered  to  have  been,  within  the  budgetary  limitations,  (very) 
successful during the period covered by this evaluation. The evaluation study has been able to 
confirm that the technical assistance (purchase of equipment) and training actions, as well as 
procured activities, that have been funded and provided under the UAFP, have been effective 
or  could  still  be  effective  in  improving  the  prevention,  detection  and  investigation  of  fraud 
and other illegal activities detrimental to the EU's financial interests. 

So far, the study has indicated that activities supported under the three components of the 
UAFP make the following indirect, yet successful contributions to limiting the exposure 
of the EU’s financial interests to fraud, corruption, and other illegal activities. 

In  relation  to  the  ‘Hercule’  component,  it  was  demonstrated  that  the  technical  assistance 
projects  boost  the  capacity  of  enforcement  agencies  to  investigate  or  prevent  the  known 
exposure by providing up-to-date technological and knowledge resources to combat fraud and 
irregularities. With regard to the training actions, publications, and studies supported by the 
UAFP contribute to improving the capacity of customs and enforcement agencies’ staff and 
developing  the  knowledge  base  needed  for  combating  fraud,  corruption  and  other  illegal 
activities. 

89 Commission Decision C(2021)2120 of 7 April 2021 on the interim financing of the Anti-Fraud Information 

System and the adoption of the work programme for 2021. 

60 

 
 
 
 
The  evaluation  has  shown  that  activities  supported  by  the  UAFP  have  contributed  to  a 
significant  extent  to  the  improvement  of  the  beneficiaries’  work  (claimed  by  77%  of 
consulted  beneficiaries).  Beneficiaries  also  point  out  that  the  programme  has  significantly 
contributed  to  the  improvement  of  their  investigative  capacity  (84%),  operational  capacity 
(69%) and technical capacity (71%).  

All  consulted  beneficiaries  agree  that  the  projects  supported  by  the  programme  have 
contributed to them acquiring new skills and knowledge of specialised methodologies. 

The  evaluation  has  allowed  for  a  number  of  challenges  to  be  identified  during  the 
implementation of the programme, described as follows: 

-  The  Commission’s  application  platform,  particularly  the  reporting  platform,  were 
perceived  by  some  beneficiaries  as  not  being  sufficiently  user-friendly.  In  general, 
beneficiaries  complained  that  they  had  to  call  technical  support  to  understand  how  the 
platform works.  

-  Potential  applicants  are  not  automatically  alerted  electronically  when  a  new  call  is 
published. Several groups and networks of stakeholders are informed by OLAF through 
different  communication  channels  when  calls  are  published  and  are  asked  to  send  the 
information  to  their  colleagues  and  members  in  their  organisations.  Beneficiaries 
appreciated, however, that the calls follow a regular cycle.  

- 

-  Beneficiaries have expressed an interest in being informed about similar projects that are 
being implemented. This request was addressed in 2022 and 2023 when OLAF organised 
workshops where beneficiaries attended and also presented their own projects.  
In projects where advanced technology is to be procured, between the time of application 
and  the  time  of  procurement,  technological  advancements  may  make  the  technological 
solution  envisaged  in  the  application  less  useful.  Prices  may  also  change  significantly 
during this timeframe.  

-  The  importance  of  ensuring,  as  much  as  possible,  interoperability  between  the  AFIS 
applications  and  with  other  systems  of  customs  relevance,  in  particular  the  support  of 
searches  across  different  AFIS  databases  and  systems,  was  particularly  underlined  by 
Member  States.  In  the  specific  field  of  analysis,  the  creation  of  an  AFIS  data  lake  to 
enhance  the  exploration  of  the  information  stored  in  the  various  AFIS  customs 
applications was recommended.  

-  A  number  of  possible  (AFIS)  improvements  were  indicated,  such  as  the  creation  of 
working groups and the organisation of workshops dedicated to the sharing of experiences 
and  best  practices,  the  need  for  additional  on-line  AFIS  training  materials  and  training 
packages for specific purposes, as well as the organisation  of AFIS trainings on a more 
regular basis, including training dedicated to specific areas such as analysis. 

The  evaluation,  also  based  on  the  2023  AFIS  user  survey,  confirmed  that  AFIS  remains  a 
useful  tool  for  its  end  users,  and  that  AFIS  is  able  to  deliver  functioning  tools  for 

61 

 
 
 
 
information  exchange  in  its  dedicated  area  of  action.  The  evaluation  has  shown  that  AFIS 
supports customs officers in the timely exchange of up-to-date information to prevent fraud.  

As for IMS, this tool supports successfully the timely exchange and sharing of irregularities 
information,  enabling  its  users  to  use  agencies’  past  experiences  in  drawing  up  fraud 
preventive  measures.  The  2023  AFIS  satisfaction  survey  contained  questions  on  the 
functionality  and  performance  of  IMS  for  which  the  satisfaction  rate  was  approximately 
91%90. This compares very favourably to the 2019 results, showing an increase now with 19 
percentage points.  

The  IMS  and  its  associated  specific  objective  have  been  relevant  to  achieving  the  general 
objective of protecting the EU’s financial interests as the IMS is showing encouraging signs 
of being a useful tool for Member States to report irregularities and contribute to the broader 
fight against fraud.  

At  the  same  time, interviews  with  several  IMS  country  managers  revealed  certain  areas  for 
improvement.  For  instance,  some  forms  have  too  many  fields,  and  these  fields  sometimes 
have confusing descriptions.  

The ongoing upgrading of IMS (Q4 2024) has not yet been able to identify a measurable 
improvement  to  the  user  experience  yet,  while  users  are  increasingly  expected  to  report 
more data and to improve the quality of the existing data. These issues may also affect their 
satisfaction  levels.  This  is  not  purely  an  OLAF/IMS  issue  but  reflects  a  general  greater 
‘overall’  demand  for  data  to  be  registered,  reported  and  exchanged  for  various  purposes, 
including accountability.   

With  regard  to  the  evaluation  of  the  programme  in  relation  to  the  efficiency  criterion,  an 
integral benefits and costs analysis has been presented in detail in Annex IV. 

The  analysis  done  suggests  that  the  implementation  of,  and  the  participation  in  the 
programme  can  be  considered  to  be  an  efficient  use  of  resources  based  on  a  (partial) 
cost-benefit  analysis.  However,  the  data  available  at  this  interim  stage  of  the  programme 
does not  make  it possible to  produce  a complete, quantitative mapping of programme costs 
and benefits or to monetise all costs and benefits for direct comparison with one another. For 
this  reason,  the  comparison  between  costs  and  benefits  has  been  primarily  made  (in  the 
external study) on a qualitative basis.  

90 AFIS satisfaction survey (2023). The satisfaction rate of IMS users is a combination of the satisfaction rate of 
functionality and performance of the application after the removal of the ‘I do not know’ responses. This 
approach was adopted to match the approach currently taken by OLAF in assessing satisfaction with IMS. 

62 

 
 
 
 
Concerning  the  efficiency  of  the  administrative  processes  of  the  Hercule  component, 
three  sub-sections  can  be  considered, 
the  project 
i.e. 
implementation period and the budgetary flexibility.  

the  application  procedure, 

The  application  procedure  for  grants  under  the  Hercule  component  of  the  current  UAFP  is 
found to be highly efficient based on consultations with applicants. The set-up of the current 
application  process  shows  it  has  taken  on  board  the  feedback  received  during  the  final 
evaluation of the Hercule III programme (end of 2021). 

The  final  evaluation  suggested  some  improvements  to  make  the  application  process  more 
efficient  for  the  benefit  of  the  applicants.  The  final  evaluation  found  the  application 
procedures  more  efficient  than  the  previous  evaluation  period  (mid-term  evaluation  of 
2018)  because  applicants  took  less  time  to  prepare  their  application,  compared  with  the 
previous Hercule programmes. However, the 2021 final evaluation recommended improving 
the application process by providing additional and more refined guidance to applicants on 
how  to  adequately  fill  in  the  application  form  because  applicants  had  incurred  human 
resources costs, allocating civil servants or staff to proceed and help with the application91. 

This  cost  aspect  (time  and  human  resources)  of  the  application  procedure,  however,  was 
not  found  to  be  as  severe  as  to  deter  applicants  from  applying  to  the  programme. 
Nevertheless,  the  2021  Hercule  III  final  evaluation  recommended  providing  sufficient 
information to applicants (Recommendation 9.1), such as through best practices and example 
boxes directly in  the online application form.  It  also  recommended  setting  up a platform or 
appointing  a  contact  person  to  answer  questions  (Recommendation  9.2)  and  organising  an 
annual  workshop  or  seminar  focused  on  the  application  process  (Recommendation  9.3). 
Lastly,  it  recommended  that  the  application  procedure  should  avoid  ambiguous  questions 
(Recommendation 9.4). 

These  recommendations  have  since  all  been  implemented  in  the  current  UAFP.  Most  of 
the applicants92 found the guidance and instructions provided to prepare the application clear 
and readily available93. The call documents94, published under each annual work programme, 

91 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 

Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications Office, 
2021, https://data.europa.eu/doi/10.2784/62582. 

92 Survey of applicants and beneficiaries, Question 9. The vast majority of successful applicants and applicants 

that are waiting to know if their application was successful were very satisfied or satisfied with the 
availability and clarity of instructions and guidance for preparing the application: 26 out of 29 respondents 
were very satisfied or satisfied with the availability and clarity of instructions and guidance to help them 
prepare the application form.  

93 Survey of applicants and beneficiaries, Question 9.  
94 OLAF (2023) Union Anti-Fraud Programme (EUAF) Call for proposals Technical Assistance (EUAF-2023-

TA) Training, Conferences, Staff Exchanges, and Studies (EUAF-2023-TRAI). Available at: 

63 

 
 
 
 
 
provide a clear overview of the projects eligible for funding and present the eligibility criteria 
clearly.  Furthermore,  each  call  is  now  accompanied  by  an  online  manual  for  proposal 
preparation and submission, which is easy and intuitive to navigate.  

Applicants  can  also  receive  support  if  they  have  technical  difficulties,  through  the  Portal 
Submission System, as well as with specific non-IT related questions for which two different 
email addresses are available. Only a minority of stakeholders would have liked to see even 
more guidance: this is particularly the case for researchers who stated they had not received 
adequate support from their own institution when preparing the application, which is beyond 
the Commission’s influence or control. 

In  terms  of  procedural  efficiency,  the  application  procedure  has  proven  to  be  efficient  by 
avoiding  requesting  the  same  information  several  times  throughout  the  application  process: 
most survey respondents stated that they were not asked to input the same information several 
times, which would have added unnecessary administrative and time-consuming steps95.  

The fact that the application form and process require information relevant to the objective of 
evaluating  the  project  (therefore  avoiding  unnecessary  and  resource-consuming  steps, 
documents  or  additional  administrative  steps)  confirms  the  high  efficiency  of  the 
application96.  Therefore, 
the  administrative  and  financial  requirements  are  overall 
proportional and reasonable97.  

The in-depth interviews with stakeholders have revealed some points for further improving 
the  application  process  in  the  Hercule  component  (technical  assistance  and  training  part). 
First,  accessibility  and  inclusion  needs  to  be  improved.  Some  applicants  with  visual 
impairments,  for  example,  are  unable  to  access  the  application  platform  because  Oracle 
platforms do not support all screen-reading software. Although the portal is very easy to use 
for most people, the general  ease of  access  for people  with  disabilities  should  be examined 
(although this is a technical feature, which does not fall under the remit of OLAF)98.  

Second,  several  stakeholders  indicated  that  the  application  process  should  be  tailored  to 
how  large  and  complex  the  project  is,  which  would  simplify  the  procedure  for  smaller 

https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/euaf/wp-call/2023/call-fiche_euaf-
2023-ta_euaf-2023-trai_en.pdf. 

95 Survey of applicants and beneficiaries, Q9. 17 out of 28 survey respondents were very satisfied or satisfied 
with this aspect of the application process. This result is corroborated by the analysis of the available 
documentation. Only a minority of stakeholders consulted found some redundancies in the information 
asked. 

96 Survey of applicants and beneficiaries, Q9, 26 out of 29 respondents were very satisfied or satisfied with the 
relevance and proportionality of the information required. This result is corroborated by the analysis of the 
available documentation. 

97 Survey of applicants and beneficiaries, Q9. 
98 Interview with beneficiary and case study on digitalisation. 

64 

 
 
 
 
projects99.  This  request  may  however  encounter  some  technical  issues  with  regard  to  the 
existing templates for filing an application, as well as issues of equal treatment. 

The  proportion  of  successful  applicants  increased  considerably  between  2021  and  2023, 
implying that less time is lost by applicants on unsuccessful applications100. This increase in 
efficiency may have been driven by the procedural changes to the online application process 
and  by  the  two  workshops  organised  by  OLAF  in  2022  and  2023  with  potential  applicants 
and past beneficiaries (the workshops included updated guidance on the application process). 

With  regard  to  the  second  sub-section  of  the  project  efficiency  evaluation,  namely  the 
‘Hercule’  project  implementation  period,  half  of  the  beneficiaries  of  technical  assistance 
(TA) under the UAFP Hercule component, who were  surveyed for this  evaluation, reported 
that UAFP funding has contributed to their project achieving notable outcomes and results101. 
This finding needs however further validation, which should be through evidence from any 
available  data  on  the  (later)  reported  results  of  the  finalised  projects  and  their  costs  of 
implementation.  

In this context, the Commission (OLAF) refers to the examples given in the specific annex to 
the  annual  PIF  report,  i.e.  the  ‘Annual  Overview  on  the  implementation  of  the  UAFP’  (per 
year). 

The  financial  support  provided  via  the  TA  component  has  so  far  led  to  significant  or  very 
significant cost savings in a third of the cases and to some cost savings in almost half of the 
cases102. In terms of resources, in a minority of cases, the funds and resources made available 
were not enough to support implementing the action103. This may have been due to budgetary 
planning  or  other  factors,  which  have  not  been  possible  to  identify  based  on  the  available 
data. 

The  grants  received  have  allowed  agencies  to  increase  their  operational  and  investigative 
efficiency. The purchase of equipment,  for example, allows  them  to  save time in  extracting 
and  analysing  data  for  criminal  proceedings104.  Therefore,  beneficiaries  noted  that  the 
improved  capacity  and  capabilities  will  not  only  allow  them  to  be  more  efficient  in 
carrying  out  operations  in  their  countries  but  will  also  make  them  better  equipped  to 

99 Interviews with beneficiaries. 
100 PIF report 2022.  
101 Survey of applicants and beneficiaries, Q 10(2), 50% of the respondents claim that the amount of available 

funds and resources supported their intervention and contributed to the achievements of the project. 
102 Survey of applicants and beneficiaries, Q 15(4): 7.7% of beneficiaries rated the cost savings as very 

significant, 23.1% as significant and 46.2% as somewhat significant. According to 23.1%, the cost-saving 
was not significant at all. 

103 Survey of applicants and beneficiaries, Q 11(2), 21.4% of the respondents claim that the amount of available 

funds and resources supported their intervention and contributed to the achievements of the project. 

104 Interview with beneficiaries and case study on investigative capacity. 

65 

 
 
 
 
respond  to  requests  for  mutual  assistance  and  joint  investigations  with  EU  partner 
agencies105.  

As  for  the  programme’s  budgetary  flexibility,  the  grant  agreement  gives  beneficiaries  a 
good  degree  of  budgetary  flexibility106.  After  receiving  the  grant,  applicants  can  request  to 
make  changes  to  the  budget  breakdown  by  transferring  budgetary  resources  between 
participants and between budget categories (as long as this does not involve any substantive 
or significant change to the description of the action)107. Interviewees who have made use of 
the budgetary flexibility were satisfied with this aspect of the UAFP, which allowed them to 
change  some  aspects  of  the  project  without  having  to  complete  a  formal  project 
amendment108. 

The budgetary flexibility in these cases increases the projects’ efficiency since it reduces the 
administrative  burden  for  beneficiaries.  Commission  (OLAF)  programme  managers  and 
financial  officers  do  note  an  increasing  workload  due  to  a  higher  number  of  requests  for 
changes within projects and/or of their budgets in recent years. 

A  third  and  final  evaluation  criterion  tackled  under  this  first  evaluation  question  on  the 
successfullness  of  the  programme,  is  the  assessment  of  the  programme’s  coherence.  This 
assessment  focuses  on  two  aspects,  namely  the  internal  and  the  external  coherence  (or 
consistency) of the UAFP and its interventions. 

The  internal  coherence  assessment  examines  the  extent  to  which  the  three  components 
(Hercule component, AFIS component and IMS component) and the different types of actions 
of the UAFP are sufficiently clear and  coherent  with  one another  and do not  contradict but 
rather support each other’s implementation by creating synergies.  

The external coherence or consistency explores the extent to which the interventions of the 
UAFP  are  in  line  with  other  relevant  legislative  and  policy  instruments  and  interventions 
taken at EU level. Several other EU programmes mentioned below were selected for the in-
depth analysis of coherence, as indicated in the following sections. 

The  coherence  assessment  has  been  based  on  the  results  of  desk  research  (external  study), 
including the analysis of the UAFP Regulation and other programmes with similar objectives, 
and is informed by the analysis of stakeholders’ views (interviews and surveys). 

In  particular,  interviews  were  carried  out  with  beneficiaries  and  with  a  number  of 
Commission departments to gather input on internal coherence and the external coherence of 

105 Case study on investigative capacity. 
106 Section 5.4 of the grant agreement form. 
107 Internal overview of grant agreements. 
108 Interviews with applicants. 

66 

 
 
 
 
the  UAFP  with  other  EU  programmes,  focusing  on  potential  duplication  (financial 
overlap/double funding) and synergies (complementarity). 

Information  provided  by  stakeholders  on  coherence  based  on  the  survey  for  applicants  – 
including beneficiaries – was cross-referenced for this assessment. 

The  research  also  looked  at  the  calls  for  proposal  and  the  projects  funded  under  the  UAFP 
and  other  EU  initiatives.  However,  their  broad  description  does  not  make  it  possible  to 
highlight any major duplication, assuming they exist.  

Based  on  the  analysis  of  the  relevant  programmes  as  well  as  the  results  of  the  stakeholder 
consultation  conducted  for  the  evaluation,  the  UAFP  is  considered  to  be  coherent 
(internally)  and  consistent  (externally).  Nevertheless,  some  overlaps  and  areas  for 
improvements are identified (as indicated in the following sections).  

The  external  coherence  or  coordination  assessment  focuses  on  the  extent  to  which  the 
UAFP and interventions implemented through the UAFP are coherent with other instruments 
and interventions with similar objectives. In addition, it also examines the coherence with EU 
horizontal policies. 

On the topic of coherence with (other) EU horizontal policies, and as indicated in the UAFP 
AWPs,  implementation  of  the  UAFP  is  intended  to  be  in  line  with  the  EU’s  political 
priorities109 and related policy initiatives. 

Among  the  cross-cutting  policies,  the  UAFP  reflects  the  EU’s  commitments110  to  tackle 
climate  change  in  line  with  the  Paris  Agreement  adopted  under  the  United  Nations 
Framework Convention on Climate Change (UNFCCC)111.  

The  programme  aims  to  contribute  to  mainstreaming  climate  action  and  helps,  where 
possible,  in  achieving  an  overall  target  (for  the  Commission)  of  30%  of  the  EU  budget 
supporting climate objectives112.  

During  the  consultation  for  the  study,  it  was  reported  that  applicants  are  encouraged  to 
highlight  proposed  activities  in  their  applications  that  take  into  consideration  the  climate 

109 European Commission (2019). Political Guidelines for the European Commission 2019-2024. Available at: 

https://commission.europa.eu/document/download/063d44e9-04ed-4033-acf9-
639ecb187e87_en?filename=political-guidelines-next-commission_en.pdf. 

110 European Commission (2019). Communication from the Commission to the European Parliament, the 

European Council, the Council, the European Economic and Social Committee and the Committee of the 
Regions, The European Green Deal (COM/2019/640 final). https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52019DC0640 

111 United Nations (2015). Paris Agreement to the United Nations Framework Convention on Climate, Change. 

Available at: https://unfccc.int/documents/184656   

112 European Commission, Anti-Fraud Programme Performance Statements (PPS, 2023). 

67 

 
 
 
 
objectives  of  the  EU.  Funding  under  the  UAFP  was  provided  to  beneficiaries  to  purchase 
energy-efficient equipment, such as specialised electric or hybrid vehicles113.  

The  UAFP  might  also  be  used  to  better  equip  Member  States  to  prevent  imports  of  certain 
illicit  products  that  do  not  comply  with  the  EU  environmental  and  climate  framework114. 
Despite  these  efforts,  some  stakeholders  stressed  that  the  size  of  the  UAFP  is  limited  and 
cannot significantly contribute to addressing climate change concerns115.  

In addition, it was highlighted that, although UAFP funding is given to projects that aim to be 
in line with energy-efficient standards, the actual implementation of the projects might not be 
in  line  with  such  standards.  This  is  because  public  procurement  processes  put  in  place  by 
national administrations often favour the lowest-cost bidder over other considerations. 

The digital transition is another key priority of the EU and part of its digital strategy116. The 
UAFP supports Member States’ digital transitions through all three components.  

For  instance,  this  already  partly  occurs  through  the  UAFP  funding  to  Member  States’ 
beneficiaries for the purchase of IT tools supporting data analysis to detect fraud affecting 
revenue  or  expenditure  and  by  building  up  expertise  on  digital  forensics117.  Financial 
support is also provided to purchase and maintain software and hardware that is needed to 
improve  the  IT  capacity  of  the  beneficiary  and  to  strengthen  its  organisation,  including 
judicial and law enforcement capabilities. 

The financial support mentioned above (funding of IT related equipment and tools, plus the 
budget  allocated  to  AFIS  and  IMS)  is  considered  a  100%  contribution  to  the  UN  SDG 
Number 16  –  Peace,  justice and stronger institutions. The  UAFP  contribution to  this  digital 
transition was estimated at around EUR 11.6 million in 2021 and around EUR 11.94 million 
in  2022.  EUR  16.4  million  has  been  allocated  in  2023  to  run  and  manage  IMS  and  AFIS, 
including  also  a  number  of  grants  for  technical  assistance  projects  in  the  field  of  IT  and 
digitalisation of law enforcement agencies. The latter projects will continue to run and have 
an impact in 2024 and 2025. 

113 Interviews with the European Commission. 
114 European Commission (2023). Annex to the Commission Implementing Decision on the financing of the 
Union Anti-Fraud Programme and the adoption of the work programme for 2023 (C (2023) 813 final). 
Available at: https://anti-fraud.ec.europa.eu/system/files/2023-
02/uafp_work_programme_2023_annex_en.PDF   

115 Interviews with European Commission staff. 
116 European Commission (2020). Shaping Europe’s Digital Future. https://commission.europa.eu/strategy-and-

policy/priorities-2019-2024/europe-fit-digital-age/shaping-europes-digital-future_en. 

117 European Commission (2021). Annex to the Commission Implementing Decision on the financing of the 
Union Anti-Fraud Programme and the adoption of the work programme for 2021 (C (2021) 5338 final). 
https://anti-fraud.ec.europa.eu/system/files/2021-10/uafp_work_programme_2021_en.pdf. 

68 

 
 
 
 
This funding is stemming from the overall annual budget of the programme, which typically 
ranges  between  EUR 23-24  million  per  year  and  includes  the  AFIS  and  IMS  budget.  The 
AFIS and IMS budget are considered to fully boost the programme’s IT capacity building of 
its beneficiaries. 

The programme indirectly helps building effective, accountable and inclusive institutions in 
Member States at various levels of national and/or regional administrations (law enforcement 
agencies), in particular through support given, leading to an enhanced digital transition. 

However,  given  the  limited  size  of  the  UAFP  budget,  it  was  stressed  that  this  contribution 
would not be significant enough to facilitate fully reaching the digital transition objectives118. 

Regarding the coherence of the UAFP with other single instruments and interventions, as 
noted  already  in  the  mid-term  evaluation  of  the  Hercule  III  programme,  most  of  the 
stakeholders consulted at that time reported more synergies than potential overlaps with other 
EU-funded programmes. However, they indicated more coordination was needed in the future 
with other programmes managed by DG TAXUD and DG HOME, covering the fight against 
VAT fraud and against corruption or other organised crime types119. 

The consultations revealed that OLAF is exploring the possibilities of expanding the scope of 
its  investigative  work  in  new  areas,  including,  food  fraud,  chemical  waste,  waste  shipment 
and other environmental issues. For this study, the potential coherence of OLAF's expanded 
scope  with  financing  programmes  managed  by  other  Commission  departments  could  be 
explored in future studies.  

For the external coherence analysis, several key EU programmes were selected in the study 
(see Box 1 hereafter). Only the two closest related ones are described in detail hereafter120. 

Overall, the coherence with the other EU programmes is confirmed by the results of the 
desk research during the study and by most of the stakeholder interviewees. In particular, one 
beneficiary underlined the unique characteristics of the UAFP, which is recognised as filling 
a critical gap by funding projects that would not otherwise be covered by other EU funds121. 

Box 1 - Key instruments and interventions for external coherence analysis 

Key instruments and interventions for external coherence analysis 

118 Interviews with the European Commission; European Commission, Programme Performance Statements, 
Anti-fraud, 2023, available at: https://commission.europa.eu/strategy-and-policy/eu-budget/performance-
and-reporting/programme-performance-statements/anti-fraud-performance_en. 

119 European Commission (2017) Mid-term Evaluation of the Hercule III programme, prepared by CEPS, 

Economisti Associati, CASE, wedoIT. https://op.europa.eu/en/publication-detail/-/publication/472e59a1-
07cd-11e8-b8f5-01aa75ed71a1/language-en/format-PDF/source-68460881 
120 The other programmes are described in detail in Annex 2 of the ICF study report. 
121 Interview with a beneficiary. 

69 

 
 
 
 
•  Regulation  (EU)  2021/1077  establishing,  as  part  of  the  Integrated  Border 
Management Fund, the instrument for financial support for customs control 
equipment (CCEI) 

•  Regulation (EU) 2021/444 (‘Customs programme’) 
•  Regulation (EU) 2021/240 establishing a Technical Support Instrument (‘TSI’) 
•  Regulation (EU) 2021/693 (‘Justice programme’) 
•  Regulation  (EU)  2021/695  (‘Horizon  Europe’  Cluster  3  -  Civil  security  for 

society) 

•  Regulation (EU) 2021/840 establishing a programme to protect the euro against 

counterfeiting for the 2021–2027 period (‘Pericles IV programme’) 

•  Regulation (EU) 2021/847(‘Fiscalis programme’) 

The UAFP is also aligning more and more with the 2019 Commission’s anti-fraud strategy, 
which places more attention on the collection and use of data for anti-fraud purposes122.  

Interventions financed under the UAFP aim to focus on cross-border cooperation in fighting 
fraud  and  to  ensure  there  is  complementarity  and  interoperability  with  equipment  and  tools 
purchased under other EU-funded programmes123. 

Existing mechanisms aiming to prevent (financial) overlapping between the UAFP and 
other financial instruments  

Mechanisms, consultations and cooperation measures bring together the various stakeholders 
involved to prevent financial instruments’ objectives from overlapping. 

Formal  and  informal  mechanisms  are  in  place  to  facilitate  cooperation  across  the 
Commission’s  departments,  prevent  or  resolve  potential  overlaps  and  ensure  optimal 
synergies between EU-funded programmes.  

The  formal  cooperation  takes  place  during  the  preparation  of  the  AWPs  for  the  different 
funding instruments. The programmes and their legislative activities (adopting the financing 
decisions  and  annual  or  multi-annual  work  programmes)  are  subject  to  inter-service 
consultations (internal cross-departmental consultations in the Commission). 

The legislative proposals are submitted to all relevant Commission departments for their input 
and  agreement  to  ensure  coordination  between  the  programmes  managed  by  those 
departments. 

122 European Commission (2019). Communication from the Commission to the European Parliament, the 

Council, the European Economic and Social Committee, the Committee of the Regions, and the Court of 
Auditors. Commission Anti-Fraud Strategy: enhanced action to protect the EU budget (COM (2019) 196). 
https://anti-fraud.ec.europa.eu/system/files/2021-09/2019_commission_anti_fraud_strategy_en.pdf 

123 PIF report 2021. 

70 

 
 
 
 
The  Commission  departments  also  coordinate  their  work  for  the  launch  of  calls  for 
applications  and  during  the  evaluation  of  the  applications  received.  The  applications  are 
examined to identify any overlaps and to prevent over- or double-financing. 

In practical terms, this means that OLAF staff are part of the different evaluation committees 
set  up  each  year  for  the  assessments  of  the  applications  received  under  other  programmes. 
Similarly,  staff  of  other  Commission  departments  participate  each  year  in  the  evaluation 
committee for the assessment of applications submitted for UAFP funding. 

In addition to the formal mechanisms above, there are informal channels  of cooperation for 
exchanges  at  the  level  of  policy  officers  of  the  relevant  units.  This  level  of  informal 
cooperation is considered essential in leveraging the in-house expertise on the differences in 
scope  and  areas  of  competence  between  the  UAFP  and,  for  example,  DG  TAXUD’s 
programmes124. 

Strengthened and regular coordination is ensured between DG TAXUD and OLAF125, as well 
as between DG JUST and OLAF to avoid overlaps in providing grants and training to similar 
target audiences126. 

At  a  higher  level,  there  is  also  cooperation  when  developing  and  adopting  the  legislation 
setting out the instruments (e.g. DG TAXUD contributed to the impact assessment prepared 
ahead of the UAFP Regulation) and when evaluating their implementation and results127. 

The  study  provided  a  comparative  analysis  of  the  UAFP  and  related  EU  programmes,  of 
which two are described hereafter, i.e. Regulation (EU) 2021/1077 establishing, as part of the 
Integrated Border Management Fund, the instrument for financial support for customs control 
equipment (CCEI), and  Regulation (EU) 2021/444 establishing the Customs programme for 
cooperation in the field of customs (‘Customs programme Regulation’) 128. 

The  CCEI  is  one  component  of  the  EU’s Integrated  Border  Management  Fund  (BMF).  For 
2021-2027, it aims to contribute to adequate and equivalent customs controls by supporting 
Member  States  in  purchasing,  maintaining  and  upgrading  state-of-the-art  customs  control 
equipment.  

During the interviews with Commission’s officials, the highest risk of duplication in funding 
was identified as existing between the UAFP and the CCEI. In fact, the two programmes have 
similar  eligible  activities.  The  UAFP’s  scope  covers  the  protection  of  the  EU’s  financial 

124 Interview with the European Commission. 
125 Ibid. 
126 Ibid. 
127 Ibid. 
128 Customs programme, Regulation (EU) 2021/444 of the European Parliament and of the Council of 11 March 
2021 establishing the Customs programme for cooperation in the field of customs and repealing Regulation 
(EU) No 1294/2013, (OJ L 87, 15.3.2021), p. 1, preamble, paragraph (5). 

71 

 
 
 
 
  
interests,  which  is  also  one  of  the  areas  covered  by  the  CCEI  but  not  its  main  priority.  In 
addition, the UAFP comprises of activities related to customs, which is the sole area covered 
by the CCEI. The UAFP includes customs authorities among its beneficiaries, which are the 
only specific beneficiaries of the CCEI.  

However,  although  the  CCEI  has  a  much  larger  budget  than  the  UAFP,  its  scope  is  more 
limited  than  the  UAFP’s  since  the  CCEI  focuses  on  customs  equipment  specifically.  The 
complementarity between the two programmes was already identified at the proposal stage of 
the  UAFP  Regulation.  However,  the  Regulation  indicated  that  each  of  them  focuses  on 
different types of support, namely to national authorities and customs authorities129.  

Regarding  technical  assistance  support,  the  adoption  of  the  CCEI  allowed  for  the  UAFP  to 
focus more on advanced tools and technologies, including data analysis. This created valuable 
synergies (complementarity) across the two programmes, while also avoiding overlaps in the 
funding, including financial overlaps130. 

To limit and avoid such duplication, OLAF and DG TAXUD provided guidance to applicants 
and  beneficiaries  to  help  them  distinguish  between  the  UAFP  and  the  CCEI.  Efforts  were 
regularly made to ensure closer and more effective cooperation and consultation between 
OLAF and DG TAXUD. This was carried out via formal  cooperation (such as inter-service 
steering  group  meetings  and  joint  meetings  at  different  levels)  and  informal  cooperation 
(including  regular  and  ad  hoc  exchanges  between  policy  officers)  to  avoid  duplication  and 
optimise coordination.  

Consultation  took  place  at  different  stages,  in  particular  when  preparing  the  relevant 
regulations (e.g. with DG TAXUD and other Commission departments providing input to the 
UAFP  impact  assessment),  developing  the  AWPs,  launching  the  calls  for  applications  and 
evaluating the applications received (e.g. to avoid double-financing). 

Regulation  (EU)  2021/444 establishes  the  Customs  programme  to  further  modernise  the 
Customs Union, support the development and uniform implementation of customs legislation 
and  policy  and  facilitate  cooperation  in  the  field  of  customs  for  the  2021-2027  financial 
period.  It  includes  funding  for  collaborative  activities,  administrative  and  IT  capacity 
building,  including  human  skills  and  training,  and  the  development  and  operation  of  EU 
electronic systems and innovation in customs policy. 

129 European Commission (2018). Commission Staff Working Document, Ex-ante evaluation accompanying the 
document Proposal for a Regulation of the European Parliament and of the Council establishing the EU Anti-
Fraud Programme (SWD (2018) 294 final), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52018SC0294. 

130 European Commission, Programme Performance Statements (PPS, 2023), available at: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en 

72 

 
 
 
 
The  above-mentioned  Regulation  indicates  that  the  Customs  programme  should  exploit 
possible  synergies  with  other  EU  measures  in  related  fields,  such  as  the  UAFP,  in  order  to 
ensure cost effectiveness. 

The  external  study131  identified  common  points  and  areas  of  potential  overlap  between  the 
UAFP and the Customs programme, as presented in the table hereafter. These common points 
raised  questions  with  the  interviewees  during  the  study  about  their  differences  and  how  to 
avoid duplicating efforts in the customs area132. 

Table 8: Scope for coherence and overlap between the UAFP and the Customs Control 
Equipment Instrument (light pink colour) 

Member States 

EEA countries  

Acceding countries, candidate countries and potential candidates 

ENP countries 

Other non-EU countries  

Protecting the financial interests of the Union 

Promoting mutual assistance between the administrative authorities of the Member States and cooperation 
between these administrative authorities and the Commission to ensure that the law on customs and 
agricultural matters is correctly applied 

l

  Preventing and combating fraud, corruption and any other illegal activities affecting the financial interests of the 
e
u
c
r
e
H

Union 

I

S
F
A

Providing tools for information exchange and supporting mutual administrative assistance in customs and 
agricultural matters 

  Supporting the reporting of irregularities, including fraud, found in the shared management funds and pre-
S
M

accession assistance funds of the Union budget 

I

Technical knowledge, specialised and technically advanced equipment and effective IT tools enhancing 
transnational and multidisciplinary cooperation and cooperation with the Commission 

Staff exchanges for specific projects, ensuring the necessary support and facilitating investigations, in particular 
setting up joint investigation teams and cross-border operations 

Technical and operational support to national investigations, particularly to customs authorities and LEAs, to 
strengthen the fight against fraud and other illegal activities 

e
p
o
c
s

l
a
c
i
h
p
a
r
g
o
e
G

s
e
v
i
t
c
e
j
b
o

l
a
r
e
n
e
G

s
e
v
i
t
c
e
j
b
o
c
i
f
i
c
e
p
S

s
n
o
i
t
c
a

e
l
b
g

i

i
l

E

IT capacity in the Member States and third countries, increasing data exchange and developing and providing 

131 European Commission: European Anti-Fraud Office, Charitakis, S., Faion, M., Gounev, P., Vasileva, V. et 
al., Study in support of the Union Anti-Fraud Programme (UAFP) interim evaluation – Final study report, 
Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. Annex 2 – 
Coherence tables: Table 25. 

132 Interview with the European Commission. 

73 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
IT tools for the investigation and monitoring of intelligence work 

Specialised training, risk analysis workshops, conferences and studies to improve cooperation and coordination 
among services concerned with the protection of the financial interests of the Union 

Any other action provided by the work programmes that is necessary to achieve the general and specific 
objectives  

Public authorities 

Research and educational institutes, and non-profit entities 

s
e
i
t
i
t
n
e

e
l
b
g

i

i
l

E

Any legal entity created under EU law 

International organisations 

One of the main common  points  is that they both aim to  contribute to  the protection of  the 
EU’s  financial  and  economic  interests  and  may  address  the  same  customs  and  trade  policy 
topics (as part of the general and specific objectives of the two programmes). Although this is 
common ground, the nature and scope of the two programmes is clearly distinguishable. The 
Customs  programme  focuses  solely  on  customs  cooperation  and  customs  union  aspects, 
whereas the UAFP supports the fight against fraud, which is not in the scope of the Customs 
programme. The UAFP is not specific in terms of the law enforcement aspects and, as such, 
goes beyond the customs domain. 

In terms of eligible actions, both programmes  can finance electronics and IT systems. They 
also  both  can  support  organising  specialised  training,  risk  analysis  workshops,  conferences 
and  studies  that  aim  to  improve  cooperation  and  coordination.  However,  the  Customs 
programme cannot do so if the objective goes beyond its legal scope133. 

Regarding the technical  assistance provided under the UAFP, the UAFP is used to fund the 
purchase  of  highly  specialised  technical  equipment  with  possible  uses  that  are  not  only 
limited to customs activities, with OLAF focusing increasingly on the expenditure side of the 
programme.  The  purchase  of  similar  technical  equipment  is  excluded  under  the  Customs 
programme.  

Considering  the  common  points  and  to  avoid  overlaps,  DG  TAXUD  and  OLAF  work  very 
closely together (formally and informally) to coordinate and build complementarities. A clear 
understanding  has  been  reached  between  the  relevant  Commission  departments  on  the 
differences between the two programmes134. They have also engaged actively with applicants 
and beneficiaries to provide guidance on  how the two programmes work and what are their 
specific  objectives.  The  similarities  were  already  evident  at  the  time  of  the  Hercule  III 

133 The legal basis of the Customs programme Regulation does not refer to Art. 87 nor to Art. 325 TFEU. 
134 Interview with the European Commission. 

74 

 
 
 
 
 
 
 
 
programme.  However,  cooperation  made  it  possible  to  tackle  similar  policy  aspects  in 
different ways as confirmed by stakeholders during the final evaluation of Hercule III135.  

4.2  How did the EU intervention make a difference and to whom? 

This  section,  focussing  on  EU  added  value  provided  by  the  programme,  assesses  the 
potential  change  for  beneficiaries  or  the  public  as  a  result  of  the  EU  intervention  and 
measures  the  impact  above  and  beyond  the  reasonably  expected  results  of  national  actions 
alone.  

Due to the limited availability of data on finalised projects for this evaluation, there have been 
limitations in determining the (full) added value of the programme’s components.  

From the available data and the collected information from beneficiaries and stakeholders, it 
appears  that  the  (expected  and  yet  seen)  results  delivered,  could  not  have  been  possible 
without  EU  action  and  co-funding  through  grants  or  procurement.  The  extent  to  which  the 
UAFP  has  enabled  a  more  efficient  use  of  financial  resources  for  the  Member  States’ 
beneficiaries, than if Member States had acted alone, is, although not fully measurable at this 
stage, clearly identified by the consulted stakeholders and beneficiaries. 

The following assessment is based on a thorough review of available reports and literature on 
the  UAFP,  targeted  surveys  of  Hercule  component  beneficiaries  and  applicants,  targeted 
surveys of AFIS users, and interviews with key stakeholders. 

Interviews  with  beneficiaries  and  the  case  studies  of  selected  projects  showed  that  the 
supported actions focus on the output and benefits described below. 

Improved investigative and surveillance capabilities and capacities by purchasing state-of-
- 
the-art  communication  surveillance  equipment,  upgrading  existing  surveillance  systems  and 
tools and training personnel to operate the newly acquired equipment; 

Improved  quality  of  collected  data  and  evidence  and  the  ability  to  exchange  data  with 
- 
partners  from  other  Member  States  and  EU  agencies  and  participate  in  trans-border 
investigations; 

Improved performance of investigative and law enforcement authorities: (i) by purchasing 
- 
equipment  and software, which increases both  the volume of data they  can process  and the 
speed of processing; and (ii) by enabling the use of artificial intelligence and digitisation in 
activities like evidence review, data classification and identity verification; 

135 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 

Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications Office, 
2021, https://data.europa.eu/doi/10.2784/62582. 

75 

 
 
 
 
Training  activities,  conferences,  study  visits  and  publications  have  improved  transnational 
cooperation among the parties involved in the protection of the EU’s financial interests and 
have  contributed  to  applying  a  multidisciplinary  approach  in  combating  fraud  and  other 
illegal activities, including by bringing together academic researchers and practitioners. 

Many respondents highlighted additional benefits beyond the scope and efficiency benefits 
mentioned  above.  One  beneficiary  of  technical  assistance  highlighted  that  the  UAFP 
programme was vital in ensuring that their office could stay up to date. This respondent stated 
that  IT  technologies  develop  very  fast  and  are  adopted  very  quickly  by  organised  criminal 
groups. It  is  very difficult for the respondent  to keep  up with  these developments,  and they 
consider UAFP funding as a vital resource helping them stay up to date136.  

Two  beneficiaries  of  training  activities  highlighted  that  the  participation  of  OLAF  greatly 
improves  interest  and  encourages  participation  in  training  and  conferences.  OLAF 
funding lends substantial credibility to the training activities, which results in more people 
attending them137.  

Lastly, an applicant for training activities stated that funding for these activities at an EU 
level gives more added value because the assessment process is more neutral. At national 
level, there is a much smaller circle of professionals involved in this area, which makes an 
objective evaluation of the proposals difficult. By contrast, EU funding ensures a neutral 
review process138. 

As  for  potential  contributions  to  sustainable  development  goals  and  other  benefits,  the 
UAFP programme provides additional benefits partly through its contribution to meeting key 
sustainable  development  goals.  Specifically,  financial  support  from  the  EU  through  the 
technical  assistance  grants  contributes  to  the  sustainable  development  goal  of  reducing 
inequalities  within  and  among  administrations  in  Member  States.  The  technical 
assistance  grants  support  this  goal  by  indirectly  helping  to  harmonise  the  financial 
resources  available  to  Member  States  by  bolstering  the  budgetary  capacity  of  national 
administrations139.  

136 Interviews with beneficiaries. 
137 Interviews with beneficiaries.  
138 Interviews with beneficiaries.  
139 European Commission. Anti-Fraud – Performance, Union Anti-Fraud Programme, 2023. Available at: 
https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en . 

76 

 
 
 
 
Furthermore,  the  programme  indirectly  helps  build  effective,  accountable  and  inclusive 
institutions through its support to law enforcement agencies. This support is particularly 
evident through grants dedicated to supporting an improved digital transition140.  

4.3 

Is the intervention still relevant? 

Relevance  addresses  the  relationship  between  the  needs  and  problems  at  the  time  of  the 
implementation of the intervention – in this case, over the 2021-2024 period of the UAFP. It 
also considers the relationship between current  and future needs and problems in the EU in 
this policy area according to the objectives of the intervention. 

The  ex-ante  evaluation  of  the  UAFP  in  2017-2018  identified  the  needs  of  stakeholders 
working  within  the  programme  (particularly  at  Member  State  level)  in  relation  to  the  fight 
against  fraud  for  the  upcoming  period.  It  concluded  that  support  provided  at  the  time  by 
Hercule  III  was  crucial  to  countering  cross-border  fraud  against  EU  financial  interests  and 
that this should remain a priority for the EU, to be pursued by the next such iteration.  

The  main  needs  identified  during  the  legislative  preparatory  works  towards  the  adoption  of 
the UAFP Regulation were: 

-  Lack of up-to date technical equipment and support in the Member States; 
- 

Increase  in  new  forms  of  fraud  and  rapid  development  of  sophisticated  technical  tools 
used by criminals ;  

-  Need for cooperation between stakeholders (including the exchange of best practices and 

experiences); 

-  Need for access and exchange of data and information between stakeholders and Member 

States.  

The interim evaluation has revealed that the UAFP's specific objectives generally align with 
the programme's broader goals, showcasing its relevance overall. Nevertheless, there is 
room for improvement in providing targeted support to address emerging crime trends, 
particularly through the adoption of digitalisation measures. 

According to stakeholder feedback, survey responses and interviews, the specific objectives 
of the Hercule component are strongly aligned with the UAFP’s general objectives and with 
stakeholder needs. 

Overall,  the  UAFP  is  and  remains  relevant  to  emerging  trends  in  fraud  prevention  by 
addressing  digitalisation  and  e-commerce-related  fraud  through  funding  initiatives  and 
training  projects.  While  there  is  a  growing  emphasis  on  digital  preparedness  to  combat 
evolving criminal tactics, efforts to address emerging trends explicitly should be consolidated.  

140 European Commission. Anti-Fraud – Performance, Union Anti-Fraud Programme, 2023. Available at: 
https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en . 

77 

 
 
 
 
The  AFIS  component's  annual  work  plan,  user  satisfaction  surveys,  and  functionality 
assessments  demonstrate 
information  exchange  and 
operational activities in customs matters.  

in  facilitating 

its  relevance 

For  example,  the  AFIS  component,  particularly  the  Tobacco  Seizure  Management 
Application  (ToSMA),  contributes 
tobacco  smuggling  by  enhancing 
to  combating 
investigators' awareness and leveraging statistical models.  

The IMS component, while perceived as useful and relevant, has, until very recently, faced 
challenges in effectively supporting the reporting of irregularities and combating fraud within 
the  EU  budget.  Stakeholders  pointed  to  the  need  for  system  upgrades,  for  example.  This 
upgrade  has  now  been  launched  in  October  2024  and  requires  some  time  to  get  fully 
implemented this and next year, addressing most challenges identified in this evaluation. 

The  expansion  of  the  programme’s  beneficiaries  to  Ukraine  and,  potentially,  other  EU 
candidate  countries  since  2023,  as  well  as  increasing  market  prices  for  hardware  and 
artificial  intelligence  (AI)  technologies,  could  further  limit  the  current  (financial)  ability  of 
the programme to address forthcoming and increasing request for financial support to answer 
the needs. 

For example, the Hercule component already rejects about two-thirds of all grant applicants 
each  year  since  2022,  due  to  budgetary  limits.  This  may  suggest  increasing  and  unsatisfied 
financing  needs  by  the  Member  States  and  the  associated  country  Ukraine,  which  could 
prompt frustration and dissatisfaction among applicants in the future. 

Fluctuating inflation rates also have an impact on the budget that can be allocated to a project. 
As  a  comparison,  in  Belgium,  the  inflation  rate  in  2022  was  10.32%,  up  7.11  percentage 
points from 3.21% in 2021.  

In  2023,  the  inflation  rate  in  Belgium  was  down  again  to  2.29%,  a  decrease  of  0.92 
percentage points between 2021 and 2023.  

Figure 8 hereafter visualises the fluctuation in annual inflation rates in % for the EU-27 and 
within the euro area, triggering the rising trend in applications for financial support in the 
field of technical assistance funded by the programme to include a forecasted price increase 
in  the  planned  application  budget  for  a  new  project  (e.g.  between  5%  and  10%  added  for 
equipment or IT tools as the procurement procedure can take up to one year to finalise).  

In  this  sense,  a  reflection  on  a  steady  and  substantial  budget  increase  for  the  (future) 
programme may need to be considered. 

78 

 
 
 
Figure 8: Annual inflation rates in % for the EU and within the euro area (Eurostat)141 

5  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNT? 

This section presents the conclusions and lessons learnt of this interim evaluation, based on 
the  external  study  report  and  available  data  and  documentation,  consulted  throughout  this 
evaluation exercise. 

5.1  Conclusions 

At  this  moment  in  time,  passed  halfway  the  programme’s  implementation  period,  it  can  be 
stated that the UAFP has achieved its two general objectives, as well as its three specific 
objectives, so far and within the limits of the budgetary possibilities. The evaluation found 
that the specific objectives of the programme are generally relevant to the general objectives.  

The  activities  implemented  under  the  Hercule  component  have  been  found  to  be  highly 
relevant to the specific objectives of the programme as well as to catering convincingly to 
the needs of applicants and beneficiaries of the programme. 

The  yearly  calls  for  proposals,  the  various  activities  proposed  within  them,  and  the  tools 
provided  to  users  (AFIS  in  particular)  are  highly  relevant  to  the  needs  of  beneficiaries, 
participants, applicants and users of AFIS platforms.  

141 https://ec.europa.eu/eurostat/web/products-euro-indicators/w/2-18062024-ap   

79 

 
 
 
         
 
 
 
 
The programme is  structured in  such a  way that  allows for beneficiaries to  respond to  fast-
emerging  trends  in  the  fight  against  fraud  and  sets  a  promising  starting  point  for  such 
responses in the future. 

Most  projects  carried  out  under  the  Hercule  component  of  the  UAFP  could  not  have  been 
completed if they were only funded at national or regional level. Even where national funding 
is  available,  without  the  support  of  EU  funding,  the  projects  carried  out  under  the  Hercule 
component could not be completed with the same scope and the same level of quality.  

The  research  funding  provided  under  UAFP  occupies  a  unique  position,  and  without  this 
funding,  many  important  research  topics  relating  to  the  protection  of  the  EU’s  financial 
interests would simply not receive funding or sufficient funding. 

The  programme’s  actual  performance  has  matched  the  beneficiaries  expectations  in  a 
large  way  and  in  different  aspects,  including  unexpected  benefits,  both  for  programme 
beneficiaries as for the general public, for example by contributing to two (UN) sustainable 
development  goals  (‘SDG’),  described  hereafter.  Although  participating  in  the  programme 
does  require  input  from  human  and  financial  resources  (minimum  20%  co-financing  for 
‘Hercule’ projects), the UAFP has enabled national investigative units to optimise their use 
of  resources,  leading  to  a  more  effective  fight  against  serious  crimes  that  undermine  the 
EU's financial interests. 

On cost savings, the interim evaluation of the first component of the UAFP, Hercule, revealed 
that  beneficiaries  experienced  some  reduction  in  costs.  On  the  application  process,  the 
current  technical  application  process  provided  by  OLAF  is  a  substantial  improvement 
compared with the previous programme’s process and is recognised as being highly efficient. 

The  increased  internal  coherence  achieved  with  the  three-component  structure  under  the 
UAFP  (compared  to  the  Hercule  III  programme)  is  primarily  observed  in  the  reduction  of 
the administrative work and costs, simplification in the management of funding, budget 
flexibility and redistribution of funds within and across the three components.  

Nevertheless,  there  is  room  for  further  internal  coordination  (within  OLAF),  particularly  in 
the  early  annual  preparation  and  development  of  the  AWPs  and  in  the  financial  resource 
allocation,  to  ensure  better  coherence  between  the  components  of  the  programme  and  the 
priorities identified. 

On  the  external  coherence,  the  closest  synergies  and  potential  for  complementarity  is 
observed between the UAFP and the CCEI (managed by DG TAXUD).  
As  already  mentioned,  there  are  also  common  points  between  the  UAFP,  the  Customs 
programme and the Fiscalis programme, both managed by DG TAXUD.  

80 

 
 
 
 
 
 
 
 
 
 
Although  each  year  all  the  applications  filed  under  the  Hercule  component  require  careful 
analysis and coordination between OLAF and DG TAXUD to avoid potential overlaps, 
no significant duplications were found. The relevant Commission departments will continue 
working closely at different levels and at different stages in the grant process to ensure  it is 
clear  to  applicants  and  beneficiaries  how  the  programmes  work  and  what  activities  are 
eligible for funding. 

Overall, EU financial support provides a substantial benefit to the scope and efficiency of 
projects  funded  through  the  programme.  The  annual  overview  and  annual  programme 
performance  reporting  indicate  that  the  structure  of  the  programme  may  support  key 
synergies, such as the flexibility to transfer funding between and within components. 

The  UAFP  programme  provides  additional  added  value  through  reputational  gains. 
Receiving UAFP funds and participating in OLAF training and networking projects result in a 
reported increase in the interest, credibility and level of participation. 

The  programme  implementation  has  shown  the  existence  of  additional  benefits  to  the  EU 
citizens,  in  particular  through  the  programme’s  indirect  contribution  to  meeting  key 
sustainable development goals (SDGs). Specifically, financial support from the EU through 
the  technical  assistance  grants  contributes  also  to  the  sustainable  development  goal 
specifically  linked  with  reducing  inequalities  within  and  among  countries  (SDG  Number 
10), here at national and/or regional governance level in particular.  

The  technical  assistance  grants  support  this  goal  by  indirectly  helping  to  harmonise  the 
financial  resources  available  to  Member  States  by  bolstering  national  administrations’ 
budgets.  

Furthermore,  the  programme  indirectly  helps  build  effective,  accountable  and  inclusive 
institutions in the beneficiary countries by supporting law enforcement agencies, particularly 
through grants to help fund an improved digital transition (SDG Number 16).  

5.2  Lessons learnt 

This  evaluation  and  the  study  have  made  it  possible  to  learn  about  the  existence  of,  for 
example,  unexpected  benefits  for  the  beneficiaries  of  the  ‘Hercule’  component  from  the 
successful implementation of the programme so far. 

Also, a number of challenges remain to be tackled further as described hereafter. 

Many consulted respondents highlighted additional benefits beyond the scope and efficiency 
benefits  mentioned  earlier.  The  respondents  consider  UAFP  funding  as  a  vital  resource 
helping them stay up to date with the latest technologies in their fight against fraud and other 
offences detrimental to the EU’s financial interests.  

81 

 
 
 
 
 
 
 
The programme’s funding also lends substantial credibility to (the organisers of) the training 
activities, which results, among other benefits, in more participants and better networking.  

This  reinforces  the  idea  that  the  level  and  scope  of  funding  under  UAFP  should  at  least  be 
maintained  as  applicant  and  beneficiary  feedback  shows  that  the  programme  fills  a  unique 
niche. Any reduction in funding opportunities through UAFP would leave a significant gap in 
the fight against fraud or any other irregularities detrimental to the EU’s financial interests. 

This interim evaluation noted that the number of (mainly) technical assistance proposals for 
the  Hercule  component  of  the  UAFP  has  doubled  in  recent  years  (between  2022,  2023  and 
2024). This significant increase has shown that the Commission’s (OLAF’s) efforts, in 2022 
and  2023,  to  organise  workshops  for  beneficiaries  has  been  boosting  the  success  of  the 
programme. 

Informing  potential  beneficiaries  of  the  calls  for  proposals  in  a  more  targeted  way  could 
further increase the number of applicants and the number of Member States participating in 
the programme, especially from countries that submit none or fewer applications.  

Targeted  information  sessions  involving  Member  State  institutions  could  be  organised  in 
countries where the number of EU fraud cases and irregularities is high but few applications 
are  submitted.  This  may  help  increase  the  participation  rate  and  result  in  a  more  even 
distribution of the funds among as many Member States as possible, including the associated 
partner Ukraïne. Nevertheless, some countries might not be interested in participating in the 
UAFP. 

Transnational cooperation can be improved by providing incentives to beneficiaries to set up 
multinational project teams and multi-beneficiary projects. 

The (‘Hercule’) project reporting platform should be upgraded to make it more user-friendly 
and intuitive for beneficiaries. 

A more quantitative comparison of costs and benefits of the programme could be facilitated 
with data on benefits. This would allow for these benefits to be monetised as far as possible, 
e.g. more standardised reporting on the monetary value or estimated value of benefits enjoyed 
by Hercule grant recipients. 

The application procedure for Hercule grants has significantly improved, compared with the 
previous edition and is  considered to be highly efficient. Nonetheless, there is still potential 
for  improvements  in  efficiency.  The  efficiency  of  the  application  process  may  benefit  from 
including,  if  technically  possible,  a  feature  in  the  Commission’s  online  portal  for  calls  and 
tenders, to notify applicants (directly and/or automatically) when a call has been launched. 

82 

 
 
 
 
 
 
 
 
 
 
 
Greater  user-friendliness  for  users  with  disabilities,  such  as  those  with  visual  impairments, 
may also make the process less resource-intensive for some applicants. 
The evolving challenges in the customs anti-fraud environment call for a reinforcement of the 
financial  means  of  the  activities  under  Council  Regulation  No  515/97,  in  particular  for  the  
modernisation  of the AFIS infrastructure and the enhancement of the data management and 
data exploitation functionalities. This would increase the operational capacity of investigators 
and data analysts to pro-actively detect cases of fraud  and to monitor existing and evolving 
trends.  

This modernisation process should be carried out with the use of the latest technologies and 
advanced  analytical  tools  and  techniques  for  searching  and  combining  data,  as  well  as 
visualising  results.  Machine  learning,  artificial  intelligence  (AI),  text  mining  and  advanced 
statistical  techniques  will  provide  an  automated  framework  for  processing  big  data  (for 
example e-commerce data). 

With regard to the further implementation of AFIS, it seems that, although the AFIS training 
and information materials are deemed useful, not all users are aware that they exist. 

The  increasing  costs  of  the  maintenance  and  development  of  the  AFIS  platform  and  the 
elevated costs of the needed state of the art technology and equipment for its modernisation 
call for a significant increase in the allocated budget within the (future) programme. 

The databases under the AFIS umbrella are all considered efficient. Resource utilisation can 
be  optimised  and  less  hardware  is  required  on  a  central  EU  level.  Administration  costs  are 
lower. As data is stored centrally, fewer components are needed and the data storage is done 
in a coordinated way. 

The existing services offered by AFIS as an intelligence platform to facilitate the sharing of 
the  results  of  analysis  carried  out  at  EU  level  sould  be  further  enhanced.  Certain  AFIS 
modules show exceptionally strong evidence of benefits (e.g. CIS+). 

Current trends in crime show that projects enabling the fight against digitally enabled fraud 
require  more  funding.  Hence,  the  future  overall  programme  budget  might  benefit  from  a 
planned  increase  to  address  and  mitigate  the  increasing  proportion  of  applications  in  the 
Hercule component of the programme that are  unsuccessful, mainly due to budgetary limits 
(now about three quarters of all the applications under technical assistance). 
Applicants highlighted the lack of similar financial support from national or other sources. 

The  high  costs  of  hardware  and  the  need  for  policymakers  to  keep  up  with  technological 
developments might require an increase in the budget of the (future) programme to continue 
supporting national authorities in combating fraud, corruption or any other illegal activities.  

83 

 
 
 
 
 
Lastly,  such  a  budget  increase  should  take  into  consideration  the  extension  of  the 
programme’s geographical scope, following Ukraine’s association to the programme since 1 
January 2023. 

In this way, the potential is created for extending the programme to other candidate countries.

84 

 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

−  Lead DG: DG OLAF 
−  DECIDE Reference: PLAN/2023/753 
−  The specific Inter-service Steering Group (ISG, composed of staff members from DG 
SG, SJ, TAXUD, JUST, HOME and BUDG) agreed with a specific Call for Evidence 
with  targeted  questions/interviews  to/with  dedicated  groups  of  interest  as  the 
stakeholders of the programme are very specific national or regional services dealing 
with the protection of the EU’s financial interests, among other priorities. The general 
public has not been specifically consulted. The ISG has held three meetings, one for 
the approval of the Terms of Reference for the selection of the contractor, one for the 
presentation of the inception report by the contractor ICF and one for the presentation 
of the draft final study report by ICF (on 16 April 2024). 

−  The  interim  evaluation  preparatory  activities  were  launched  in  the  autumn  of  2022, 
including the reopening of a competition within an existing Commission Framework 
Contract (FWC) from DG HOME between the companies within that FWC. This in 
order to select one company to set up and finalise an external study in order to assist 
the  Commission  (OLAF)  with  this  interim  evaluation  exercise.  The  contract  was 
signed  with  the  Belgian  branch  of  the  company  ICF,  located  in  Brussels,  together 
with  its  subcontractors.  The  contract  ran  between  17  May  2023  and  17  May  2024, 
resulting in the submission of a final study report142 on the interim evaluation on 17 
May  (last  update  9  July  2024).  The  Report  from  the  Commission  with  its 
accompanying staff working document is due to be adopted by 31 December 2024 at 
the latest. The study  and the  Commission Report (+SWD) will be published on the 
Commission  (OLAF)  website.  The  ICF  study  report  (finalised  in  July  2024  for 
publication) is available here: https://data.europa.eu/doi/10.2784/1075235. 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

1.  Principles 

The  external  study  by  ICF  on  the  interim  evaluation  of  the  programme,  including 
four extensively developed case studies, is considered to be of high quality (taking 
into  account  the  rather  limited  number  of  finalised  projects  and  the  low  response 
rate  of  the  surveys)  and  has  respected  and  followed  the  following  principles,  as 
required by the Better Regulation’s guidelines on evaluations: 
▪  comprehensiveness – covering the following (five) criteria: 

o  effectiveness; 
o  efficiency (including sustainability or durability of the action/materials); 
o  coherence (both internal and external);  

142 European Commission: European Anti-Fraud Office, Charitakis, S., Faion, M., Gounev, P., Vasileva, V. 
et al., Study in support of the Union Anti-Fraud Programme (UAFP) interim evaluation – Final study 
report, Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. 

 
 
 
o  relevance; and, 
o  EU added value. 

▪ 

▪  proportionality  –  the  scope  of  the  evaluation  (study)  has  been  tailored  to  the 
particular intervention, the time since its implementation and the available data.  
For some criteria, new data had to be collected, analysed and compared with other 
findings. For others, a short summary has been provided, on the basis of existing 
reports and information, or a standard explanation has been provided. 
independence  and  objectivity  –  Through  ICF,  an  independent  and  objective 
evaluation  has  delivered  robust  and  reliable  results.  The  analysis  done  in  the 
evaluation  is considered  to  be  independent  and objective, including  for the staff 
working  document  and  the  Report  from  the  Commission  based  on  that  study, 
since it has been based on all relevant information; it has been conducted without 
influence  or  pressure  by  third  parties  and  the  study  and  the  SWD  and  Report 
reflect transparently the positive as well as the negative elements of the analysis; 
▪  evidence-based approach – This evaluation has been based on the best available 
evidence  drawn  from  a  diverse  and  appropriate  range  of  methods  and  sources 
(triangulation). Not all sources were equally robust considering when and how the 
(reduced)  available  evidence  was  collected.  As  far  as  could  be  identified,  the 
evidence is considered not to have been subject to bias or uncertainty. 
Any  limitations  related  to  the  evidence  and  the  methodology,  particularly  in 
terms of their ability to support the conclusions, has been clearly explained, both 
in the study and in the introductory part of this staff working document. 

- 

ICF  has  been  able  to  establish  a  clear  link  between  the  evaluation  questions 
addressed and the corresponding methodology; 

-  The main evaluation questions which have been addressed, in line with the Better 

Regulation Guidelines’ evaluation criteria (mentioned above) are: 
▪  What  have  been  the  outcomes  of  the  interventions,  implemented  by  the 
programme, so far, considering the ex-ante evaluation of the legislative proposal 
in  2018,  the  preamble  of  the  adopted  legal  text,  and  the  final  evaluation  of  the 
Hercule III programme in 2020? 

▪  How  has  the  programme  implementation  evolved  over  the  interim  evaluation 
period  (considering  specific  circumstances  such  as  e.g.  the  impact  of  Corona 
measures in the Member States)? 

▪  To  what  extent  can  the  intervention  be  considered  successful  and  why?  Where 
possible,  each  of  the  five  main  evaluation  criteria  have  been  assessed: 
effectiveness,  efficiency,  coherence,  relevance  as  well  as  EU  added  value  of 
the  programme’s  actions,  also  in  relation  to  other  programmes  (synergies, 
complementarity)  with  similar  objectives  and/or  target  audience  (in  particular, 
the CCEI and the Customs programme). 

▪  Are  the  objectives  and  the  activities  of  the  intervention  still  relevant  today  and 

for the future? 

▪  How  did  the  EU  intervention  make  a  difference,  compared  to  what  has  been 
(financially  or  administratively)  possible  on  a  national  or  regional  governance 
level?  

86 

 
▪  What is the EU added value of the programme? 
▪  What are the conclusions and lessons learnt, as well as the way forward? 

-  Quantitative  and  qualitative  indicators  have  been  identified  by  ICF  and  used  as 

much as possible throughout the evaluation process; 

A  representative  sample  of  measures  and  activities  examined  has  been  drawn  up  (and 
agreed  upon,  in  consultation  with  the  contractor  and  the  ISG,  the  inter-service  steering 
group,  at  the  presentation  of  the  Inception  Report)  in  a  manner  suitable  for  each 
evaluation  question, and has enabled the  evaluators to  draw general  conclusions on the 
measures  and  address  the  key  application  issues,  as  identified  by  the  inter-service 
steering group and the consulted stakeholders. 

The  sections  hereafter  present  the  methodology  used  in  the  ICF  study  to  support  the 
interim evaluation of the UAFP. It utilises a mixed-methods approach, comprising both 
qualitative  and  quantitative  research  techniques,  to  answer  the  evaluation  questions 
shown  in  the  evaluation  framework.  Figure  9  below  presents  an  overview  of  the 
methodological approach.  

Figure 1: Schematic overview of the methodological framework 

Source: ICF analysis. 

87 

 
 
2.  Study tasks 

Source: ICF analysis. 

3.  Data collection tools  

To gather the evidence necessary to evaluate the UAFP, the study team used several data 
collection tools: 

▪ 
▪ 
▪ 
▪ 

desk research; 
documentation analysis; 
stakeholder consultations; 
case studies143. 

4.  Desk research  

The desk research comprised the collection and analysis of secondary sources (included 
those provided by OLAF) for the period of the interim evaluation: 

▪ 

▪ 

▪ 

▪ 

policy, legal, and strategic documents, such as policy and legal documents at EU 
and national level; 
programme-specific  documents,  including  PIF  reports  and  (AFIS)  steering 
committee meeting inputs; 
action-level  documents,  including  grant  applications,  implementation  reports, 
and final reports of grant recipients; 
other relevant documents, including academic or other (external) studies. 

143 European Commission: European Anti-Fraud Office, Charitakis, S., Faion, M., Gounev, P., Vasileva, V. 
et al., Study in support of the Union Anti-Fraud Programme (UAFP) interim evaluation – Final study 
report, Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. 

88 

 
 
 
ICF collected, catalogued and systematically stored the relevant sources, which were then 
coded  and  collated  into  an  evidence  table.  The  data  gathered  during  the  desk  research 
were analysed and incorporated into the answers to the evaluation questions (see section 
5).   

5.  Documentation analysis 

The  documentation  analysis  consisted  of  a  detailed  review  and  analysis  of  key 
programme documents for each component of the UAFP: 

the AFIS surveys in 2019, 2021 and 2023, Summary reports; 

▪ 
▪  OLAF’s annual activities reports; 
▪ 
▪  PIF reports on fraud, covering the years 2017-2023; 
▪ 

the 2021 study report on the final evaluation of the Hercule III programme; 

▪ 

annual  overviews  with  information  on  the  results  of  the  UAFP  in  2021,  2022 
and 2023; 
progress reports and final reports (where available) for projects funded under the 
‘Hercule’ component of the UAFP; 
▪ 
grant agreements for funding awarded under the UAFP; 
▪ 
data on (pending) applications for funding under the UAFP, provided by OLAF; 
▪  minutes  of  the  AFIS  steering  committee  meeting  in  December  2022,  on  the 

▪ 

protection of the European Union’s financial interests; 
documents  and  presentations  from  the  AFIS  steering  committee,  covering 
programme implementation and budgeting. 

The contents of these documents were analysed and incorporated into the findings.  

6.  Stakeholder consultations 

The stakeholder consultations included three targeted online surveys, targeted interviews, 
and  a  planned  workshop.  The  results  of  the  stakeholder  consultations  can  be  found  in 
Annex V. 

The  study  foresaw  targeted  surveys  to  gather  inputs  from  national-level  stakeholders. 
They included surveys targeting applicants to the Hercule component call for proposals, 
including beneficiaries, applicants awaiting a decision, and applicants whose application 
had been rejected, as well as a survey of registered AFIS users. 

ICF  completed  and  sent  surveys  to  all  applicants  to  the  Hercule  component,  which 
participated  in  the  calls  between  2021  and  2023.  To  maximise  the  response  rate,  ICF 
extended  the  survey  period  and  followed-up  with  survey  recipients  to  encourage  a 
response. All participants received the survey twice and, in cases where the survey was 
not complete, they also received individual reminders/invites to complete the survey. 

This  round  of  surveys  produced  29  usable  survey  answers  from  beneficiaries  (29 
successful  respondents)  and  14  usable  survey  answers  from  applicants  (14  usable 
respondents).  Only  one  unsuccessful  participant  responded.  Survey  respondents 

89 

 
provided  insights  into  the  process  and  results  of  their  applications  and  interventions 
(where successful) under the UAFP.  

ICF analysed the responses and incorporated the results into the findings of the study.  

The survey of the Council Working Party on Combating Fraud was drafted by ICF and 
distributed by the Council Secretariat-General through OLAF. It yielded just three usable 
replies. 

The targeted survey of AFIS users was completed, with ICF providing inputs and survey 
questions, and circulated directly to AFIS users via AFIS Liaison Officers in the Member 
States. ICF received the raw data from the surveys on 9 February 2024.     

▪  The  study  team  conducted  eight  scoping  interviews  at  the  inception  stage,  as 
well as further scoping interviews with OLAF officials during the interim phase 
of  the  study  to  understand  how  AFIS  functions  and  to  adjust  the  additional 
interview questionnaire for the AFIS satisfaction survey; 

▪  The study team  conducted 43 stakeholder interviews at national  and EU  level. 
The results of the interim report were used to identify data gaps and adjust the 
interview  questionnaires  to  address  those  information  gaps.  The  study  team 
consulted the following stakeholders: 

o  Beneficiaries of the Hercule component (technical assistance and training 

activities); 

o  European  Commission  stakeholders  (particularly  on  coherence):  staff  of 

various Commission DGs;  

o  AFIS and IMS stakeholders.  

▪  Finally, ICF incorporated inputs from a stakeholder workshop on 16 April 2024. 
It  presented  the  draft  final  report  to  European  Commission  officials  (Inter-
Service  Steering  Group  members  and  other  Commission  staff)  at  OLAF’s 
premises. 

7.  Case studies 

The  purpose  of  the  case  studies144  was  to  thoroughly  examine  the  main  themes  of  the 
evaluation. The Regulation introduced notable themes and innovations in respect of the 
primary focus and structure of the UAFP. As the programme is still being implemented 
and  many  actions  are  ongoing,  the  case  studies  focused  on  assessing  progress  towards 
achieving  the  strategic  direction  for  the  UAFP,  rather  than  evaluating  longer-term 
impacts and outcomes (typically done in final ex-post evaluations).  

By  taking  this  mid-term  perspective  on  their  design,  the  case  studies  offer  a 
comprehensive  understanding  of  whether  the  programme  is  advancing  towards  its 

144 European Commission: European Anti-Fraud Office, Charitakis, S., Faion, M., Gounev, P., Vasileva, V. 
et al., Study in support of the Union Anti-Fraud Programme (UAFP) interim evaluation – Final study 
report, Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. 

90 

 
 
objectives,  allowing  for  adjustments  or  re-orientation  if  necessary  for  the  remainder  of 
the  programme.  The  study  team  completed  four  case  studies.  The  case  studies  covered 
the following topics: 

1.  Case study on investigative capacity; 
2.  Case study on digitalisation, AI, data analytics; 
3.  Case study on transnational cooperation and exchange of information; 
4.  Case study on training related activities. 

The results of the case studies have been incorporated into this report. Full details of the 
four  case  studies  are  available  in  Annex  3  of  the  study  report,  available  here: 
https://data.europa.eu/doi/10.2784/1075235. 

8.  Limitations to methodological approach and robustness of findings  

This section outlines the primary constraints and methodological adaptations encountered 
during the study. 

Given the delayed adoption of the UAFP’s legal basis and the late implementation of the 
2021 activities (COVID-19), the completion of project outputs and subsequent reporting 
processes has been held up.  

Consequently, drawing conclusions on the programme's long-term impacts and outcomes 
proves  challenging.  In  addition,  quantifying  the  extent  to  which  the  UAFP  has  met  its 
overarching  objective  and  assessing  its  long-term  effects  are  hindered  by  the  indirect 
nature of UAFP-funded activities. For instance, establishing a direct causal link between 
the  programme's  actions  and  their  impact  on  the  financial  interests  of  the  EU,  such  as 
through the training of national customs authorities, presents difficulties. 

To address these issues, the study team took several measures during the inception phase: 

▪  Streamlined 
the 
impact 
framework, 
recognising 
comprehensive analysis; 

indicators  and  questions  within 
the  anticipated  scarcity  of 

the  analytical 
for 

relevant  data 

▪  Revised  the  analytical  framework  and  associated  data  collection  tools  to 

prioritise qualitative indicators and data; 

▪  Engaged stakeholders to  provide insights  into the expected achievement  of the 
UAFP’s objectives, facilitating qualitative assessment of progress. This involved 
soliciting  stakeholder feedback on project  alignment with  objectives, including 
for projects still in progress. 

These  adjustments  enhanced  the  study's  adaptability  to  the  dynamic  nature  of  UAFP 
implementation and its indirect impact pathways. 

91 

 
 
 
ANNEX III. EVALUATION  MATRIX  AND,  WHERE  RELEVANT, DETAILS  ON  ANSWERS 
TO THE EVALUATION QUESTIONS (BY CRITERION) 

1.  The evaluation matrix  

The  evaluation  framework,  presented  hereafter  in  a  schematic  format,  has  been 
developed following the key principles of the European Commission’s Better Regulation 
Guidelines  and  its  toolboxes  and  evaluates  the  relevance,  efficiency,  effectiveness, 
coherence, and added value of the UAFP. 

Table 1 – Evaluation matrix 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

RELEVANCE 

Q1. To what extent are the specific objectives/activities of UAFP relevant to the general 

objective of protecting EU financial interests from fraud? 

Q1.1 To what 
extent have the 
specific 
objectives145 been 
relevant to the 
general objectives 
in the period 
2021-2024? 

Q 1.2 To what 
extent are the 
specific 
objectives still 
relevant to 
emerging trends, 
including in the 
development of 
new crime types 
and techniques? 

Context-related 
indicators  
Developments and 
trends of detected 
customs fraud, and 
related criminal 
activities as 
corruption, money 
laundering and 
illicit trade in the 
period 2021-2024 
Trends in detected 
smuggling and 
consumption of 
illicit tobacco 
products observed 
in the period 2021-
2024, including, but 
not limited to, the 
emerging routes of 
tobacco-related 
activities. 
Number of illegal 

The 
programme’s 
specific 
objectives have 
been relevant in 
protecting the 
financial interests 
of the Union. 
The 
programme’s 
specific 
objectives have 
been adequate to 
support the 
prevention of 
emerging crime 
types and 
techniques 
related to fraud. 

Desk 
research 
Analysis of 
fraud and 
customs 
related 
irregularities 
and crime 
statistics and 
reports 
(OLAF, 
Europol, 
national 
authorities) 
International
, regional, 
and national 
crime trend 
reports (e.g., 
from 
Interpol, 
Europol) 

145  According to Art 2 of the UAFP Regulation, the specific objectives of the programme are to: 

(a) Prevent and combat fraud, corruption and any other illegal activities affecting the Union’s financial 

interests.   

(b) Support the reporting of irregularities, including fraud, found with the shared management funds 

and pre-accession assistance funds of the Union budget.  

(c) Provide tools for information exchange and support for operational activities in the field of mutual 

administrative assistance in customs and agricultural matters. 

92 

 
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

activities and cases 
of fraud  

Opinion-based 
indicators 
Share of consulted 
stakeholders who 
agree that the 
specific objectives 
have been relevant 
to the general 
objectives in the 
period 2021-2024 

Q1.3. To what 
extent have the 
activities of 
programme been 
relevant for 
achieving its 
specific 
objectives in the 
period 2021-
2024? 

Context-related 
indicators  
as Q1.1. above 

Opinion-based 
indicators 
Share of consulted 
stakeholders who 
agree that the 
specific activities 
have been relevant 
to the specific 
objectives in the 
period 2021-2024 

There is clear 
evidence that the 
activities of 
programme been 
relevant for 
achieving its 
specific 
objectives in the 
period 2021-
2024 
Stakeholders 
agree that the 
activities of 
programme 
across its 
different 
components have 
been relevant for 
achieving its 
specific 
objectives in the 
period 2021-
2024. 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

      Consultation 
activities 
Semi-
structured 
interviews 
with OLAF 
and other 
DGs and EU 
institutions 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, applicants, 
service users 
(IMS and 
AFIS) 

Desk 
research 
Participants 
Feedback 
Post-activity 
reports 
Feedback 
forms from 
training 
participants.  

Consultation 
activities 
Surveys 
with 
applicants, 
beneficiaries
, service 
users 
(Hercule, 
AFIS and 
IMS), 
training 
recipients. 

EFFECTIVENESS 

Q2 To what extent have the training and technical assistance provided under UAFP 
been effective in improving the activities linked to prevention, detection, and 
investigation of fraud and other illegal activities detrimental to the EU’s financial 

93 

 
 
 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

      Desk 

research: 
Statistics on 
crimes, 
investigation
s, and 
prosecutions 
Users’ 
metrics 
Reports 
from the 
beneficiaries 

Consultation 
activities: 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, applicants 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

The UAFP has 
been 
highly/somehow/
little effective in 
protecting the 
financial interests 
of the European 
Union by 
fighting fraud, 
corruption, and 
other illegal 
activities under 
the OLAF’s 
remit. 

interests?  

TECHNICAL ASSISTANCE 

Q 2.1 To what 
extent have the 
technical 
assistance been 
effective in 
improving the 
activities linked 
to prevention, 
detection, and 
investigation of 
fraud and other 
illegal activities 
detrimental to 
the EU’s 
financial 
interests? 

 

 

 

 

the grants 
awarded under 
the technical 
assistance 
interventions.  
the purchasing 
and maintaining 
of the 
investigations 
and surveillance 
tools and 
methods.  
the purchasing of 
digital forensic 
hardware 
including 
equipment and 
software, mobile 
forensic tools, 
and computer 
forensic 
collaborative 
systems 
the procurement 
of IT databases, 
awarded under 
the technical 
assistance 

Quantitative indicators 
Number of issues / 
incidents reported 
via the systems. 
Displacement of the 
illegal activity 
(Number of 
issues/incidents) to 
another entry port 
or another entry 
means after the 
acquisition of a new 
scanner, or other 
means to combat 
fraud through the 
programme at an 
entry port.  

Opinion-based 
indicators 
Share (%) of 
surveyed 
stakeholders 
agreeing / 
disagreeing with the 
fact that the UAFP 
contributed to 
improving the 
activities linked to 
prevention, 
detection, and 
investigation of 
fraud and other 
illegal activities 
detrimental to the 
EU’s financial 
interests 
Stakeholders’ views 
on how the systems 
and its features 
have contributed to 
the objectives of the 
programme. 
Stakeholders view 
on what they would 

94 

 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

have done if they 
had not received 
funding from the 
UAFP. 
Stakeholders’ view 
on whether as a 
result of the funding 
they have prevented 
more crime, illicit 
activities than they 
would have 
otherwise. 

 

 

 

interventions. 
the purchasing of 
data analytics 
technologies and 
data including 
the acquisition 
and maintenance 
of dedicated 
platform (e.g., 
commercial 
databases, data 
analysis/mining 
tools, etc.) 
the procurement 
of IT tools and 
tobacco analysis 
awarded under 
the technical 
assistance 
interventions. 
the purchasing of 
equipment for 
the detection of 
illicit trade  

Q3 To what extent have the activities contributed to an enhanced transnational 

cooperation and cooperation? 

Q 3.1 To what 
extent did the 
different 
interventions 
funded under the 
technical 
assistance 
component prove 
effective to 
enhance cross-
border / 
international 
cooperation? 

The technical 
assistance 
interventions 
contributed to an 
enhanced 
transnational 
cooperation, 
including in the 
following 
activities:   
purchasing and 
maintaining of 
the investigations 
and surveillance 
tools and 
methods   
purchasing of 
digital forensic 
hardware 
including 

      Desk 

research: 
Metrics on 
systems’ 
usage 
Statistics on 
crimes 
reported, 
losses 
preventions 
and assets 
recovered, if 
available 

Consultation 
activities: 
Semi-
structured 
interviews 
and Surveys 

Quantitative 
indicators 
Number of cross-
border / 
transnational 
cooperation 
activities funded 
under the UAFP 
Hercule 
component.  
Number of projects 
implemented by 
beneficiaries from 
more than two 
countries. 
Number of research 
studies 
Number of 
scientific 
publications 

95 

 
 
 
 
 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

with 
beneficiaries 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

equipment and 
software, mobile 
forensic tools, 
and computer 
forensic 
collaborative 
systems  
purchasing of 
data analytics 
technologies and 
data including 
the acquisition 
and maintenance 
of dedicated 
platforms (e.g., 
commercial 
databases, data 
analysis/mining 
tools, etc.)   
purchasing of 
equipment for 
the detection of 
illicit trade 
Degree to which 
each single 
activity funded 
under technical 
assistance 
(Hercule 
component of the 
UAFP) 
manifested a 
degree of 
transnational 
cooperation. 

distributed. 

Quantitative/opinio
n-based: 
Share (%) of the 
surveyed / 
interviewed 
stakeholders 
highlighting that the 
funded technical 
assistance / training 
contributed to the 
enhancement of 
transnational 
cooperation:   
Share (%) of 
surveyed 
stakeholders 
agreeing / 
disagreeing that 
certain factors 
influenced the 
transnational nature 
(or the lack of 
transnational 
nature) of the 
interventions. 

 Qualitative: 
Reports or studies / 
analysis carried out 
in the context of 
technical assistance 
interventions 
proving these 
activities were 
effective in 
enhancing 
transnational 
cooperation.  
Degree to which 
each single activity 
funded under 
technical assistance 
(Hercule 
component of the 
UAFP) manifested 

96 

 
  
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

a degree of 
transnational 
cooperation. 
Measured, for 
instance, through:  

Q4. To what extent have the technical assistance interventions contributed to a multi-

disciplinary cooperation? 

Q 4.2 Which 
factors effectively 
enhanced multi-
disciplinary 
cooperation, if 
applicable? 

  The following 
list of factors 
shall be 
considered non-
exhaustive:   
  Human resource-
related factor. 
For instance, 
whether the 
beneficiaries of a 
certain activity 
were from 
different 
departments, 
thus, ensuring 
multi-
disciplinarity;   

  Funds and 
resources. 
Whether the 
allocated 
resources were 
sufficient to 
ensuring a 
certain degree of 
multi-
disciplinarity  
  Other exogenous 

factors 
contributing to or 
hindering the 
multi-
disciplinarity of 

Degree to which 
each single 
activity funded 
under technical 
assistance 
(Hercule 
component of the 
UAFP) was 
designed with a 
degree of multi-
disciplinary 
cooperation.  

Consultation 
activities: 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, service 
users 
(Hercule) 

Quantitative/opinio
n-based 

Share (%) of 
surveyed 
stakeholders 
agreeing / 
disagreeing that 
certain factors 
influenced the 
multi-disciplinary 
nature (or the lack 
of multi-
disciplinary nature) 
of the interventions 

97 

 
Evaluation 
questions and 
sub-questions 

the activities 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

Q5. What factors limited the effective implementation of the technical and operational 

activities funded under the Hercule component of the UAFP budget?  

      Desk 

research 
Participants’ 
feedback to 
the training 
sessions 
Post-activity 
reports 

Consultation 
activities: 
Semi-
structured 
interviews 
with: 
beneficiaries
, non-
successful 
applicants 

Q 5.1 What 
factors 
influenced/impact
ed intended 
effects of 
technical 
assistance and 
training? The 
following list of 
factors shall be 
considered non-
exhaustive:   

  Human resource-
related factor. 
For instance, 
whether the 
beneficiaries of a 
certain activity 
were sufficiently 
trained/competen
t to effectively 
use a certain 
intervention;   

  Funds and 
resources. 
Whether the 
allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 
certain 
intervention  
  Other exogenous 

factors 
contributing to or 
hindering the 
effectiveness of a 
certain 
intervention. 

Quantitative/Opinio
n-based 
Share (%) of 
surveyed / 
interviewed 
stakeholders 
agreeing / 
disagreeing that the 
following list of 
factors influenced / 
impacted the 
effectiveness of the 
activities funded 
under the technical 
assistance of the 
UAFP in 
contributing to 
national 
investigations, in 
particular for 
customs and law 
enforcement 
authorities:   

  Human resource-
related factor. For 
instance, whether 
the beneficiaries of 
a certain activity 
were sufficiently 
trained/competent 
to effectively use a 
certain 
intervention;   

  Funds and 

resources. Whether 
the allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 
certain 
intervention  

98 

Identification of 
factors that 
affected the 
effectiveness of 
the activities 
funded. 

Degree to which 
each factor has 
potentially 
impacted on the 
effectiveness of 
the activities 
funded. 

  The training 

activities funded 
under the 
Hercule 
component of 
the UAFP 
contributed to 
improving the 
prevention and 
investigation of 
fraud and other 
illegal activities 
through an 
enhanced 
transnational 
and multi-
disciplinary 
cooperation.  
  Evidence of 
KPIs for the 
measuring the 
impact of 
training 
activities 

  Appropriateness 

of the 
methodologies 
used for 

 
 
 
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

assessing the 
training needs 
and impacts 

  Other exogenous 

factors contributing 
to or hindering the 
effectiveness of a 
certain 
intervention.  
  Share (%) of 
surveyed 
stakeholders 
agreeing / 
disagreeing on the 
existence of 
contributing / 
hindering factors 
influencing the 
improvement of the 
prevention and 
investigation of 
fraud and other 
illegal activities 
through an 
enhanced 
transnational and 
multi-disciplinary 
cooperation.  
  Share (%) of 
surveyed 
stakeholders in the 
context of the 
training activities 
agreeing 
/disagreeing that 
that activity 
contributed to 
enhancing their 
skills in the 
prevention and 
investigation of 
fraud and other 
illegal activities 
through an 
enhanced 
transnational and 
multi-disciplinary 
cooperation.  
  Comments/feedbac
k of participants 
and relevant 

99 

 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

authorities on the 
factors that 
facilitated or 
hindered capacity 
building via 
training activities 
  Reports and studies 
on the training 
activities (e.g., 
final reports) 
introducing KPIs 
for the 
measurement of the 
effectiveness of the 
training activities  

Q6. How did technical assistance activities contribute to limiting the currently known 

exposure of the financial interests of the Union to fraud, corruption, or other illegal 
activities?  

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries 

      Desk 

research 

The technical 
assistance 
activities 
contributed to 
limiting the 
currently known 
exposure of the 
financial interests 
of the Union to 
fraud, corruption, 
or other illegal 
activities.  

Extent to which 
is activities is 
deemed to 
have/not 
contributed to 
limiting the 
exposure of the 
financial interests 
of the Union to 
fraud and other 
illegal activities 

Q8.1 To what 
extent have 
technical 
assistance 
activities funded 
under the Hercule 
component of the 
UAFP budget 
effectively 
contributed to 
limiting the 
currently known 
exposure of the 
financial interests 
of the Union to 
fraud, corruption, 
or other illegal 
activities? 

Quantitative/Opinio
n-based 

Share (%) of the 
surveyed / 
interviewed 
stakeholders 
highlighting that the 
following activities 
did / did not 
contribute to 
limiting the 
currently known 
exposure of the 
financial interests 
of the Union to 
fraud, corruption, or 
other illegal 
activities such as:   

  purchasing and 

maintaining of the 
investigations and 
surveillance tools 
and methods   
  purchasing of 

digital forensic 
hardware including 
equipment and 

100 

 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

software, mobile 
forensic tools, and 
computer forensic 
collaborative 
systems  

  purchasing of data 

analytics 
technologies and 
data including the 
acquisition and 
maintenance of 
dedicated 
platforms (e.g., 
commercial 
databases, data 
analysis/mining 
tools, etc.)   
  purchasing of 

equipment for the 
detection of illicit 
trade  

Qualitative 
Evidence from 
Reports or studies / 
analysis carried out 
in the context of 
technical assistance 
interventions 
proving that these 
activities were 
effective in 
contributing to 
limiting the 
currently known 
exposure of the 
financial interests 
of the Union to 
fraud, corruption, or 
other illegal 
activities. 

Q 6.2 In case a 
specific technical 
assistance activity 
funded by 

Quantitative/opinio
n-based 
Share (%) of 
surveyed / 

Evidence/list of 
factors that 
influenced the 
pursuit of 
limiting the 

Consultation 
activities 
Semi-
structured 
interviews 

101 

 
 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

and Surveys 
with: 
beneficiaries 
Desk 
research 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

known exposure 
to the financial 
interests of the 
Union 

UAFP’s budget 
effectively 
contributed to the 
pursuit of limiting 
the currently 
known exposure 
of the financial 
interests of the 
Union to fraud, 
corruption, or 
other illegal 
activities, were 
there factors that 
influenced/impact
ed this outcome? 
The following list 
of factors shall be 
considered non-
exhaustive:   

  Human resource-
related factor. 
For instance, 
whether the 
beneficiaries of a 
certain activity 
were sufficiently 
trained/competen
t to effectively 
use a certain 
intervention;   

  Funds and 
resources. 
Whether the 
allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 
certain 
intervention  

  Practical 

experience. For 
instance, whether 
the beneficiaries 

interviewed 
stakeholders 
agreeing / 
disagreeing that the 
following list of 
factors influenced / 
impacted the 
effectiveness of the 
activities funded 
under the technical 
assistance of the 
UAFP in limiting 
the currently known 
exposure of the 
financial interests of 
the Union to fraud, 
corruption, or other 
illegal activities, 
were there factors 
that 
influenced/impacted 
this outcome:   

  Human resource-
related factor. For 
instance, whether 
the beneficiaries of 
a certain activity 
were sufficiently 
trained/competent 
to effectively use a 
certain 
intervention;   

  Funds and 

resources. Whether 
the allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 
certain 
intervention  
  Other exogenous 

factors contributing 

102 

 
  
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

to or hindering the 
effectiveness of a 
certain 
intervention.  

of funds gained 
already a 
practical 
experience in 
making use of 
the technical 
system activities 
in practice.  
  Other exogenous 

factors 
contributing to or 
hindering the 
effectiveness of a 
certain 
intervention.  

TRAINING 

Q7. To what extent have training activities contributed to improving the prevention and 
investigation of fraud and other illegal activities through an enhanced transnational 
and multi-disciplinary cooperation? 

Q7.1 To what 
extent have the 
following training 
activities 
contributed to 
improving the 
prevention and 
investigation of 
fraud and other 
illegal activities 
through an 
enhanced 
transnational and 
multi-disciplinary 
cooperation?  

Desk 
research: 
Participants 
Feedback 
Post-activity 
reports 
Feedback 
forms from 
training 
participants.  

      Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, training 
participants 
(Hercule) 

Quantitative 

  The training 

activities funded 
under the 
Hercule 
component of 
the UAFP 
contributed to 
improving the 
prevention and 
investigation of 
fraud and other 
illegal activities 
through an 
enhanced 
transnational 
and multi-
disciplinary 
cooperation.  

  Coherence 
between 
identified gaps 
and activities 
planned. 

  Appropriateness 

of the 
methodologies 

  Number and types 

of training 
activities funded 
through the UAFP 
(Hercule 
component) per the 
following activity 
types: 

  Staff exchanges 
between national 
and regional 
administrations 
(including 
candidate and 
neighbouring 
countries) to help 
further develop, 
improve, and 
update staff’s 
competences in 
protecting the EU’s 
financial interests.  

  Share of training 
activities-related 

103 

 
 
 
 
 
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

used for 
assessing the 
training needs 

actors (e.g., 
participants, 
organisers, etc.) 
agreeing / 
disagreeing that 
training activities 
contributed to 
improving the 
prevention and 
investigation of 
fraud and other 
illegal activities, an 
enhanced 
transnational and 
multi-disciplinary 
cooperation. 

  Number of 
participants 

Quantitative/Qualita
tive 
Feedback received 
from participants to 
training sessions, 
staff exchanges and 
other relevant 
events. 

Share of 
participants that 
believe the training 
activities have 
contributed to 
improving the 
prevention and 
investigation of 
fraud and other 
illegal activities 
through an 
enhanced 
transnational and 
multi-disciplinary 
cooperation 

Q8. To what extent have training activities facilitated the exchange of information, 
experiences, and best practices with a view to strengthening the fight against fraud 
detrimental to the EU’s financial interests?  

104 

 
 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

Desk 
research: 
Post-activity 
reports; 
Participants’ 
feedback 

Consultation 
activities: 
Semi-
structured 
interviews 
and Surveys 
with 
beneficiaries 
and training 
participants 
(Hercule),  

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Q8.1 To what 
extent have the 
following training 
activities 
facilitated the 
exchange of 
information, 
experiences, and 
best practices 
with a view to 
strengthening the 
fight against 
fraud detrimental 
to the EU’s 
financial 
interests?  

Quantitative/opinio
n based: 

  Share of training 
activities-related 
actors (e.g., 
participants, 
organisers, etc.) 
agreeing / 
disagreeing that the 
following training 
activities facilitated 
the exchange of 
information, 
experiences, and 
best practices with 
a view to 
strengthening the 
fight against fraud 
detrimental to the 
EU’s financial 
interests. 

 

 Share of 
participants that 
believe the training 
activities have 
facilitated the 
exchange of 
information, 
experiences, and 
best practices with 
a view to 
strengthening the 
fight against fraud 
detrimental to the 
EU’s financial 
interests. 

105 

  The training 
activities 
facilitated the 
exchange of 
information, 
experiences, and 
best practices 
with a view to 
strengthening 
the fight against 
fraud 
detrimental to 
the EU’s 
financial 
interests.  
  Conferences, 

workshops and 
seminars (a) 
facilitated the 
exchange of 
information, 
experience and 
best practices, 
including in the 
field of data 
analysis; (b) 
created networks 
and improve 
coordination 
between 
Member States, 
candidate 
countries, other 
third countries, 
EU institutions 
and international 
organisations; 
(c) facilitated 
multidisciplinary 
cooperation 
between anti-
fraud 
practitioners and 
academics on 
protecting the 
EU’s financial 
interests, 

 
 
 
 
 
 
   
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

including 
support to 
associations for 
European 
criminal law and 
for the 
protection of the 
EU’s financial 
interests; and (d) 
raised the 
awareness of the 
judiciary and 
other legal 
professionals of 
this matter. 
  Staff exchanges 
between national 
and regional 
administrations 
(including 
candidate and 
neighbouring 
countries) 
helped further 
develop, 
improve, and 
update staff’s 
competences in 
protecting the 
EU’s financial 
interests 

Q 9To what extent have training activities contributed to develop the legal and 
judicial protection of EU’s financial interests?  

Q 9.1 To what 
extent have 
training activities 
contributed to 
developing 
comparative law 
studies and 
organising 
activities to raise 
awareness among 
the judiciary and 
other branches of 
the legal 
profession on 

Number of 
comparative law 
studies and organising 
activities to raise 
awareness among the 
judiciary and other 
branches of the legal 
profession on 
protecting the EU’s 
financial interests, 
including the 
dissemination of 
relevant scientific 

106 

The training 
activities 
contributed to 
development of 
the legal and 
judicial 
protection of 
EU’s financial 
interests  

Desk 
research 
Post-activity 
reports 
Feedback 
from 
participants 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 

 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

with 
beneficiaries 
and training 
participants 
(Hercule), 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

protecting the 
EU’s financial 
interests, 
including the 
dissemination of 
relevant scientific 
knowledge 
through 
periodical 
publications?  

knowledge through 
periodical publications 
funded through the 
UAFP (Hercule 
component)  
Share (%) of surveyed 
stakeholders agreeing 
/disagreeing that the 
UAFP fund proved 
effective in 
developing:   
  comparative law 

studies,  
  organising 

activities to raise 
awareness among 
the judiciary and 
other branches of 
the legal profession 
on protecting the 
EU’s financial 
interests.  
including the 
dissemination of 
relevant scientific 
knowledge through 
periodical 
publications  

 

Q 10. To what extent has the IMS component of the UAFP’s budget been effective in 
strengthening the IMS system and in contributing to the enhanced reporting of 
irregularities and fraud within OLAF’s strategic priorities remit?  

Q 10.1 To what 
extent were new 
developments/fea
tures of the IMS 
introduced as a 
direct result of 
the activities 
funded under the 
UAFP? To what 
extent are these 
interventions on 
the IMS 
contributing to 
the effective 

Quantitative 
Number of new 
developments/ 
features of the IMS 
introduced as a 
direct result of the 
activities funded 
under the UAFP.  

Quantitative/opinio
n-based 
Share (%) of 

107 

The IMS 
component of the 
UAFP’s budget 
have 
strengthened the 
IMS system and 
contributed to the 
enhanced 
reporting of 
irregularities and 
fraud within 
OLAF’s strategic 
priorities remit  

Desk 
research 
Monitoring 
and 
evaluation 
reports 

Consultation 
activities 
Semi-
structured 
interviews 
with service 
users (IMS),  

 
 
  
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

achievement of 
OLAF’s strategic 
priorities for the 
period 2020-2024 
and beyond?  

Q 10.2 To what 
extent did the 
new 
developments / 
features of the 
IMS funded 
through the 
UAFP 
programme prove 

stakeholders 
agreeing / 
disagreeing that 
these interventions 
on the IMS 
contributed to the 
effective 
achievement of 
OLAF’s strategic 
priorities for the 
period 2020-2024 
and beyond.  

Qualitative 
Reports or studies 
(e.g., evaluation of 
the IMS activities) 
highlighting that the 
new 
developments/featur
es of the IMS 
introduced as a 
direct result of the 
activities funded 
under the UAFP 
contributed to the 
effective 
achievement of 
OLAF’s strategic 
priorities for the 
period 2020-2024 
and beyond.  

Quantitative/Opinio
n  
Share (%) of 
stakeholders 
agreeing / 
disagreeing that 
these interventions 
on the IMS 

108 

The IMS 
component of the 
UAFP’s budget 
have 
strengthened the 
IMS system and 
contributed to the 
enhanced 
reporting of 

Desk 
research 
Monitoring 
and 
evaluation 
reports 

Consultation 
activities 

 
 
 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

Semi-
structured 
interviews 
with service 
users (IMS),  

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

irregularities and 
fraud within 
OLAF’s strategic 
priorities remit  

beneficial for 
enhancing the 
exchange of 
information on 
irregularities and 
fraud and, 
conversely, in 
boosting the 
interoperability of 
the exchange of 
information 
systems across 
the EU Member 
States?  

contributed to the 
effective exchange 
of information on 
irregularities and 
fraud and, 
conversely, in 
boosting the 
interoperability of 
the exchange of 
information systems 
across the EU 
Member States  

Qualitative 
Reports or studies 
(e.g., evaluation of 
the IMS activities) 
highlighting that the 
new 
developments/featur
es of the IMS 
introduced as a 
direct result of the 
activities funded 
under the UAFP 
exchange of 
information on 
irregularities and 
fraud and, 
conversely, in 
boosting the 
interoperability of 
the exchange of 
information systems 
across the EU 
Member States  

Q10.3 To what 
extent the 
activities funded 
under IMS 
component of the 

Quantitative/Opinio
n-based 

A share (%) of the 

The activities 
contributed to 
limiting the 
currently known 

Consultation 
activities 
Semi-
structured 
interviews 

109 

 
 
 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

with service 
users (IMS),  

Desk 
research 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

UAFP’s budget 
effectively 
contributed to 
limiting the 
currently known 
exposure of the 
financial interests 
of the Union to 
fraud, corruption, 
or other illegal 
activities? 

exposure of the 
financial interests 
of the Union to 
fraud, corruption, 
or other illegal 
activities.  

Extent to which 
is activities is 
deemed to 
have/not 
contributed to 
limiting the 
exposure of the 
financial interests 
of the Union to 
fraud and other 
illegal activities 

surveyed / 
interviewed 
stakeholders 
highlighting that the 
following activities 
did / did not 
contribute to 
limiting the 
currently known 
exposure of the 
financial interests of 
the Union to fraud, 
corruption, or other 
illegal activities. 

Qualitative 
Evidence from 
Reports or studies / 
analysis conducted 
in the context of 
technical assistance 
interventions 
proving that these 
activities were 
effective in 
contributing to 
limiting the 
currently known 
exposure of the 
financial interests of 
the Union to fraud, 
corruption, or other 
illegal activities. 

Q 10.4 In case a 
specific activity 
funded under IMS 
component of the 
UAFP’s budget 
effectively 
contributed to the 

Quantitative/opinio
n-based 
Share (%) of 
surveyed / 
interviewed 
stakeholders 
agreeing / 

Evidence/list of 
factors that 
influenced the 
pursuit of 
limiting the 
known exposure 
to the financial 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries

110 

 
  
 
 
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

, non-
successful 
applicants, 
service users 
(IMS),  

Desk 
research 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

interests of the 
Union 

pursuit of limiting 
the currently 
known exposure 
of the financial 
interests of the 
Union to fraud, 
corruption, or 
other illegal 
activities, were 
there factors that 
influenced/impact
ed this outcome? 
The following list 
of factors shall be 
considered non-
exhaustive:   

  Human resource-
related factor. 
For instance, 
whether the 
beneficiaries of a 
certain activity 
were sufficiently 
trained/competen
t to effectively 
use a certain 
intervention;   

  Funds and 
resources. 
Whether the 
allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 
certain 
intervention  

  Practical 

experience. For 
instance, whether 
the beneficiaries 
of funds gained 
already a 
practical 
experience in 

disagreeing that the 
following list of 
factors influenced / 
impacted the 
effectiveness of the 
activities funded 
under the technical 
assistance of the 
UAFP in limiting 
the currently known 
exposure of the 
financial interests of 
the Union to fraud, 
corruption, or other 
illegal activities, 
were there factors 
that 
influenced/impacted 
this outcome:   

  Human resource-
related factor. For 
instance, whether 
the beneficiaries of 
a certain activity 
were sufficiently 
trained/competent 
to effectively use a 
certain 
intervention;   

  Funds and 

resources. Whether 
the allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 
certain 
intervention  
  Other exogenous 

factors contributing 
to or hindering the 
effectiveness of a 
certain 

111 

 
  
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

intervention.  

making use of 
the technical 
system activities 
in practice.  
  Other exogenous 

factors 
contributing to or 
hindering the 
effectiveness of a 
certain 
intervention.  

Q 11. To what extent has the AFIS component of the UAFP’s budget been effective in 
strengthening the AFIS system and in contributing to the enhanced development of 
the set of anti-fraud IT applications operated by OLAF?  

The AFIS 
component of the 
UAFP’s budget 
has been 
effective in 
strengthening the 
AFIS system and 
in contributing to 
the enhanced 
development of 
the set of anti-
fraud IT 
applications 
operated by 
OLAF  

Desk 
research 
Monitoring 
and 
evaluation 
reports 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with service 
users 
(AFIS),  

Q11.1 To what 
extent has the 
AFIS component 
of the UAFP’s 
budget 
contributed to the 
effective 
development of 
additional 
application 
releases / fixes 
contributing to 
enhancing AFIS’ 
implementation?  

Quantitative 
Number of 
additional 
application releases 
/ fixes contributing 
to enhancing AFIS’ 
implementation 
developed as part of 
the AFIS 
component of the 
UAFP budget.  

Quantitative/opinio
n-based 
Share (%) of 
stakeholders 
agreeing / 
disagreeing that the 
AFIS component of 
the UAFP’s budget 
contributed to the 
effective 
development of 
additional 
application releases 
/ fixes contributing 
to enhancing AFIS’ 

112 

 
 
 
  
 
Methodolog
ical tools 
for data 
collection 
and 
analysis 

Desk 
research 
Monitoring 
and 
evaluation 
reports 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with service 
users (AFIS) 

Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Q11.2 To what 
extent the 
activities funded 
under AFIS 
component of the 
UAFP’s budget 
effectively 
contributed to 
limiting the 
currently known 
exposure of the 
financial interests 
of the Union to 
fraud, corruption, 
or other illegal 
activities? 

The activities 
contributed to 
limiting the 
currently known 
exposure of the 
financial interests 
of the Union to 
fraud, corruption, 
or other illegal 
activities.  

Extent to which 
is activities is 
deemed to 
have/not 
contributed to 
limiting the 
exposure of the 
financial interests 
of the Union to 
fraud and other 
illegal activities 

implementation. 

Quantitative/Opinio
n-based 

Share (%) of the 
surveyed / 
interviewed 
stakeholders 
highlighting that the 
following activities 
did / did not 
contribute to 
limiting the 
currently known 
exposure of the 
financial interests of 
the Union to fraud, 
corruption, or other 
illegal activities. 

Qualitative 
Evidence from 
Reports or studies / 
analysis conducted 
in the context of 
technical assistance 
interventions 
proving that these 
activities were 
effective in 
contributing to 
limiting the 
currently known 
exposure of the 
financial interests of 
the Union to fraud, 
corruption, or other 
illegal activities. 

Q 11.2 In case a 

Quantitative/opinio

Evidence/list of 

113 

 
 
 
  
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

factors that 
influenced the 
pursuit of 
limiting the 
known exposure 
to the financial 
interests of the 
Union 

specific activity 
funded under IMS 
component of the 
UAFP’s budget 
effectively 
contributed to the 
pursuit of limiting 
the currently 
known exposure 
of the financial 
interests of the 
Union to fraud, 
corruption, or 
other illegal 
activities, were 
there factors that 
influenced/impact
ed this outcome? 
The following list 
of factors shall be 
considered non-
exhaustive:   

  Human resource-
related factor. 
For instance, 
whether the 
beneficiaries of a 
certain activity 
were sufficiently 
trained/competen
t to effectively 
use a certain 
intervention;   

  Funds and 
resources. 
Whether the 
allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 
certain 
intervention  

  Practical 

n-based 
Share (%) of 
surveyed / 
interviewed 
stakeholders 
agreeing / 
disagreeing that the 
following list of 
factors influenced / 
impacted the 
effectiveness of the 
activities funded 
under the technical 
assistance of the 
UAFP in limiting 
the currently known 
exposure of the 
financial interests of 
the Union to fraud, 
corruption, or other 
illegal activities, 
were there factors 
that 
influenced/impacted 
this outcome:   

  Human resource-
related factor. For 
instance, whether 
the beneficiaries of 
a certain activity 
were sufficiently 
trained/competent 
to effectively use a 
certain 
intervention;   

  Funds and 

resources. Whether 
the allocated 
resources were 
sufficient to 
ensuring the 
effectiveness of a 

114 

 
  
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

certain 
intervention  
  Other exogenous 

factors contributing 
to or hindering the 
effectiveness of a 
certain 
intervention.  

experience. For 
instance, whether 
the beneficiaries 
of funds gained 
already a 
practical 
experience in 
making use of 
the technical 
system activities 
in practice.  
  Other exogenous 

factors 
contributing to or 
hindering the 
effectiveness of a 
certain 
intervention.  

Q 12. To what extent are the (positive) effects of the intervention likely to last after 
the intervention has ended? 

Q 12.1 To what 
extent are there 
activities or 
aspects of the 
interventions 
reinforcing 
OLAF’s priorities 
from Hercule I to 
the current UAFP 
programme?  

What factors of 
the overall 
intervention 
contributed to 
determine its 
positive effects?  

What factors 
hindered the 
positive effects of 
the interventions? 

Share (%) of 
surveyed 
stakeholders 
agreeing 
/disagreeing that 
there are activities 
or aspects of the 
interventions that 
have been 
constantly 
reinforcing OLAF’s 
priorities from 
Hercule I to the 
current UAFP 
programme, 
including 
contributing and 
hindering factors to 
determine its 
positive outcome.  

Perceptions of 

115 

The (positive) 
effects of the 
intervention are 
likely to last after 
the intervention 
has ended  

Desk 
research 
Post-activity 
reports 
Feedback 
from 
participants 
to the 
activities 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, non-
successful 
applicants, 
service users 
(IMS, 
AFIS),  

 
 
 
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

stakeholders of 
activities that are 
reinforcing OLAF’s 
priorities from 
Hercule I to the 
current UAFP 
programme?  

Perceptions of 
stakeholders of 
factors 
that contribute and 
hinder the positive 
outcome of the 
intervention. 

EFFICIENCY 

Q13 To what extent have the desired effects been achieved at reasonable costs on the 
basis of a cost/benefits analysis (with quantification and qualitative analysis)?  

Q13.1 To what 
extent have the 
desired effects 
been achieved at 
reasonable costs 
on the basis of a 
cost/benefits 
analysis (with 
quantification and 
qualitative 
analysis)?  

The desired 
effects have been 
achieved at 
reasonable costs 
based on a 
cost/benefits 
analysis (with 
quantification 
and qualitative 
analysis 

Desk 
research 
Internal 
reports 
(OLAF) 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, non-
successful 
applicants, 
service users 
(IMS, 
AFIS),  

Case studies 

  Cost/benefit results 
indicating that the 
desired effects of 
the UAFP 
interventions have 
been achieved at 
reasonable costs.  

  Share (%) of 
surveyed and 
interviewed 
stakeholders 
highlighting that 
the cost of the 
interventions was 
reasonable for 
obtaining the 
desired outcomes.  

  The total cost of 
the intervention 
should be taken 
into account when 
responding to the 
survey question(s) 
about costs and 
benefits, and not 

116 

 
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

only the costs 
borne by the 
authority.  

Q14 To what extent have the UAFP facilitated a more integrated use and simplified 
management of financial resources? Could the same degree of effects have been 
achieved with lower costs with simpler procedures, involving less administrative 
burden and/or with different implementation mechanisms?  

Desk 
research 
Internal 
reports 
(OLAF) 
Post-activity 
reports 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, non-
successful 
applicants, 
service users 
(IMS, 
AFIS),  

  The UAFP has 
facilitated 
financial 
management and 
the internal anti-
fraud control. 
  The same degree 
of effects has 
been achieved 
with lower costs 
with simpler 
procedures, 
involving less 
administrative 
burden and/or 
with different 
implementation 
mechanisms.  
  The budgetary 

flexibility of the 
UAFP allows to 
better face 
changing 
priorities and 
unforeseen 
events 

Q 14.1 To what 
extent have the 
UAFP facilitated 
a more integrated 
use and 
simplified 
management of 
financial 
resources?  

Q 14.2 Could the 
same degree of 
effects have been 
achieved with 
lower costs with 
simpler 
procedures, 
involving less 
administrative 
burden and/or 
with different 
implementation 
mechanisms?  

Q 14.3 To what 
extent has does 
the UAFP allow 
for more 
budgetary 
flexibility?  

Quantitative/opinio
n-based 

  Share (%) of 
stakeholders 
agreeing / 
disagreeing that the 
three components 
led to a simplified 
management of 
financial resources. 

  Share (%) of 
surveyed and 
interviewed 
stakeholders 
highlighting that 
the effects could 
have been achieved 
with lower costs 
with simpler 
procedures, 
involving less 
administrative 
burden and/or with 
different 
implementation 
mechanisms.  

Qualitative/opinion 
base 
Positive/negative view 
of stakeholders on the 
degree to which 
financial resources can 
be more easily 
managed. 

117 

 
 
 
 
 
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

Methodolog
ical tools 
for data 
collection 
and 
analysis 

COHERENCE 

Q15 Are, and to what extent, the three components and the different types of actions of the 
programme coherent among each other? (Internal coherence):  

Q15.1 (internal 
coherence): Are, 
and to what 
extent, the three 
components and 
the different types 
of actions of the 
programme 
coherent among 
each other? 

The three 
components and 
the different 
types of actions 
of the 
programme are 
coherent among 
each other  

Desk 
research 
Internal 
reports 
(OLAF) 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, non-
successful 
applicants, 
service users 
(IMS, 
AFIS),  

  Share (%) of 
stakeholders 
surveyed and 
interviewed 
pointing out that 
(a) the three 
components of the 
UAFP and (b) the 
different types of 
actions of the 
programme 
coherent among 
each other.  
  Number of 

activities covering 
the specific 
objectives of the 
UAFP   

  Number of actions 
per OLAF strategic 
objectives  
  Share (%) of 

activities, which 
are complementary 
to each other. 

Q16 To what extent are the interventions of the programme coherent with other 
measures or actions taken at EU level by the Commission or Institutions, bodies, 
agencies, which also may have contributed to the protection of the Union’s financial 
interests? (External coherence):  

Q16.1 (external 
coherence): To 
what extent are 
the interventions 
of the programme 
coherent with 
other measures or 
actions taken at 
EU level by the 

  Typology of 
similar 
interventions at an 
EU level   
  Share (%) of 
surveyed and 
interviewed 
stakeholders 

The interventions 
of the 
programme are 
coherent with 
other measures 
or actions taken 
at EU level by 
the Commission 
or Institutions, 

Desk 
research 
OLAF’s 
Strategic 
Plan 
European 
Commission
’s policies 
on anti-fraud 

118 

 
 
 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

bodies, agencies, 
which also may 
have contributed 
to the protection 
of the Union’s 
financial 
interests   

Commission or 
Institutions, 
bodies, agencies, 
which also may 
have contributed 
to the protection 
of the Union’s 
financial 
interests? 

agreeing / 
disagreeing on the 
fact that the 
interventions of the 
Programme are 
coherent with other 
measures or actions 
taken at EU level 
by the Commission 
or Institutions, 
bodies, agencies, 
which also may 
have contributed to 
the protection of 
the Union’s 
financial interests.  

  Share (%) of 
similar / 
complementary 
activities funded 
through different 
EU instruments.  

Methodolog
ical tools 
for data 
collection 
and 
analysis 

and anti-
corruption 

Consultation 
activities 
Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, non-
successful 
applicants, 
service users 
(IMS, 
AFIS),  

 EU ADDED VALUE 

Q17 Has the programme allowed delivering results that could not, or to a lesser 
extent, be achieved by interventions undertaken only at national or regional level?  

The programme 
allowed 
delivering results 
that could not, or 
to a lesser extent, 
be achieved by 
interventions 
undertaken only 
at national or 
regional level  

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, non-
successful 
applicants, 
service users 
(IMS, 
AFIS),  

Q17.1 Has the 
programme 
allowed 
delivering results 
that could not, or 
to a lesser extent, 
be achieved by 
interventions 
undertaken only 
at national or 
regional level? 

Q17.2 Does the 
intervention at 
EU level provide 
added value in 
terms of the 
efficient use of 
financial 
resources as 

Share (%) of 
surveyed and 
interviewed 
stakeholders 
agreeing / 
disagreeing that the 
programme allowed 
delivering results 
that could not, or to 
a lesser extent, be 
achieved by 
interventions 
undertaken only at 
national or regional 
level  

119 

 
 
 
 
Evaluation 
questions and 
sub-questions 

Indicators 

Judgement 
criteria 

compared to a 
possible 
intervention at 
national level? 

Q17.3 Does the 
intervention at 
EU level provide 
added value in 
terms of the 
efficient use of 
financial 
resources as 
compared to a 
possible 
intervention at 
national level? 

The intervention 
at EU level 
provided added 
value in terms of 
the efficient use 
of financial 
resources as 
compared to a 
possible 
intervention at 
national level  

Share (%) of 
surveyed and 
interviewed 
stakeholders 
agreeing / 
disagreeing that the 
intervention at EU 
level provide added 
value in terms of 
the efficient use of 
financial resources 
as compared to a 
possible 
intervention at 
national level  

Methodolog
ical tools 
for data 
collection 
and 
analysis 

Consultation 
activities 
Semi-
structured 
interviews 
and Surveys 
with: 
beneficiaries
, non-
successful 
applicants, 
service users 
(IMS, 
AFIS),  

2.  Details on the evaluation method and matrix 

As concluded during the inception phase, the stakeholder consultations conducted under 
this  study  include  three  targeted  online  surveys,  targeted  interviews,  and  a  planned 
workshop. The results of the consultations can be found in Annex V. 

The  study  planned  targeted  surveys  in  order  to  gather  inputs  from  national  level 
stakeholders.  These  surveys  included  surveys  targeting  applicants  to  the  Hercule 
component  call  for  proposals  including  beneficiaries,  applicants  pending  a  decision, 
applicants whose application was rejected, as well as a survey of registered AFIS users. 

ICF  has  completed  the  surveys  of  applicants  under  the  Hercule  component  call  for 
proposals.  ICF  sent  surveys  to  all  applicants  of  the  Hercule  component  from  2021  to 
2023.  To  maximise  the  response  rate  from  applicants,  ICF  extended  the  survey  period 
and  followed  up  with  survey  recipients  to  encourage  response.  All  participants  have 
received the survey twice and, in cases when the survey was not complete, they have also 
received individual reminders/invites to complete the survey. 

This  round  of  surveys  produced  29  usable  survey  answers  from  beneficiaries  (29 
successful  respondents),  14  usable  survey  answers  from  applicants  (14  usable 
respondents),  and  only  one  unsuccessful  participant  answered  the  survey.  Survey 

120 

 
 
respondents  provided  insights  into  the  process  and  results  of  their  applications  and 
interventions (where successful) under the UAFP.  

ICF  has  analysed  the  responses  received  through  these  surveys  and  incorporated  the 
results into the findings below.  

The survey of the Council Working Party on Combating Fraud members was completed. 
There were only three replies (three usable respondents). The survey was drafted by ICF 
and distributed by the Council Secretariat-General, through OLAF. 

The  targeted  survey  of  AFIS  users  has  also  been  completed.  As  agreed,  ICF  has 
contributed  to  the  design  and  creation  of  this  survey.  ICF  has  provided  inputs  and 
contributed  survey  questions  into  the  AFIS  satisfaction  survey,  which  was  circulated 
directly via the AFIS Liaison Officers in the Member states to AFIS users. ICF received 
the raw data from the surveys on the 9th of February 2024.     

The study team has also conducted eight scoping interviews at the inception stage. It also 
conducted some further scoping interviews with OLAF officials during the interim phase 
of the study. This, to further understand how AFIS functions and to adjust the additional 
interview questionnaire to be provided in the AFIS satisfaction survey. 

Additionally, the study team has conducted 43 stakeholder interviews at both the national 
and  EU  level.  ICF  has  used  the  results  of  the  interim  report  to  identify  data  gaps  and 
adjust  the  interview  questionnaires  in  order  to  address  such  gaps  into  the  interview 
process. The study team consulted the following stakeholders: 

•  Beneficiaries  of  the  Hercule  component  (both  technical  assistance  and  training 

activities) 

•  European  Commission  stakeholders  (particularly  regarding  coherence):  staff 

members from different Directorates-General of the Commission 

•  AFIS and IMS stakeholders.  

Finally, ICF has incorporated inputs from a stakeholder workshop organised on the 16th 
of  April  2024.  ICF  presented  the  draft  final  report  to  European  Commission  officials 
(Inter-Service  Steering  Group  members  and  other  Commission  staff)  at  the  OLAF 
premises. 

3.  Answers to the evaluation questions   

This section presents the analysis and cross-referencing of the evidence collected by the 
study team to respond to the evaluation questions of the study. 

3.1 Effectiveness 

This section examines the extent to which the three components of the UAFP have been 
effective  in  reaching  their  respective  objectives,  as  well  as  the  factors  that  either 
facilitated or hindered the implementation  of planned interventions. It  also reviews the 

121 

 
 
activities 
multidisciplinary cooperation.  

from 

the  perspective  of  enhancing 

transnational  cooperation  and 

3.1.1 Main conclusions: effectiveness of the UAFP 

  The  assessment  of  all  data  sources  indicates  that  the  UAFP  interventions  have  been 
effective. At this stage of the implementation of the three components of the programme, 
the activities  have  improved  (or  have the  potential  to  improve) the  prevention, detection, 
and investigation of fraud and other illegal activities detrimental to EU financial interests. 
The three components also have the potential to contribute to enhancing transnational and 
multidisciplinary  cooperation.  Overall,  compared  to  the  baseline,  effectiveness  has 
remained at the same level or has improved since the start of the programme 

  According 

to  survey  responses  from  applicants/beneficiaries  and  feedback  from 
beneficiaries  of  the  Hercule  component,  the  technical  assistance  interventions  have 
contributed significantly to multidisciplinary cooperation 

  Several  factors  influence  the  effective  implementation  of  technical  and  operational 
activities,  both  positively  and  negatively.  Survey  responses  from  applicants/beneficiaries 
highlighted administrative capacity, internal procedures within the their organisations, and 
the availability of (national) funds and resources 

Source: ICF analysis. 

3.1.2 To what extent have the training actions and technical assistance funded 
under the UAFP been effective in improving the activities linked to prevention, 
detection, and investigation of fraud and other illegal activities detrimental to the 
EU’s financial interests? 

3.1.2.1 Hercule component 

Overall,  the  training  actions  and  technical  assistance  funded  and  provided  under  the 
UAFP  have  been  effective  and/or  have  the  potential  to  be  effective  in  improving  the 
prevention, detection and investigation of fraud and other illegal activities detrimental to 
EU financial interests.  

About  73%  of  the  2021  budget,  allocated  to  the  first  component  of  the  UAFP,  or  an 
equivalent amount of EUR 11 100 000, was to be allocated to fund activities by awarding 
grants  to  prevent  and  combat  fraud,  corruption  and  any  other  illegal  activities  affecting 
the Union’s financial interests. The Commission published a specific call for proposals to 
provide  financial  support  for  training,  conferences,  seminars,  studies,  webinars  and  e-
learning activities. 

The  overall  indicative  budget  for  the  training  call  in  2021  was  EUR 1  600  000  or 
approximately  14.4%  of  EUR  11  100  000  being  allocated  to  training  activities  through 
grants, contributing to achieving this specific objective of the programme. 

OLAF  measures  the  fulfilment  of  this  specific  objective  through  two  performance 
indicators.  The  first  accounts  for  the  added  value  and  effective  use  of  the  co-financed 
technical equipment funded under the UAFP (as reported by direct users).  

122 

 
In the final project reports for 2021, beneficiaries recorded a 97% satisfaction rate for the 
equipment  funded  under  the  UAFP,  surpassing  the  target  of  75%146.  In  addition,  the 
programme  performed  well  on  the  second  performance  indicator,  which  measures  the 
number of training activities funded and the associated satisfaction rate. For the training 
grants finalised in 2021, participants and trainees had a satisfaction rate of 91%, stating 
that the activities were very well suited to their needs147. 

The  activities  supported  by  the  UAFP  have  contributed  significantly  to  improving 
beneficiaries’  work  (77%).  Beneficiaries  also  pointed  out  that  the  programme  has 
contributed  significantly  to  improving  their  investigative  capacity  (84%),  operational 
capacity  (69%),  and  technical  capacity  (71%).  All  beneficiaries  agreed  that  the  projects 
supported by the UAFP have contributed to the acquisition of new skills and knowledge 
of specialised methodologies and techniques. 

Figure 2 - Improvements attributed to the UAFP Hercule component 

Source: OLAF, survey of applicants/beneficiaries (N=29). 

Compared  to  the  budgeted  amounts,  the  commitment  rate  was  96%  in  2021,  and  over 
98%  in  2022,  indicating  that  the  UAFP  funds  were  used  to  support  activities  linked  to 
prevention, detection and investigation of fraud and other illegal activities.  

The  interviews  with  beneficiaries  and  the  case  studies  on  selected  projects  showed  that 
the supported actions focus on the following outputs and benefits: 

 

Improved  investigative  and  surveillance  capabilities  and  capacities  through 
acquiring  state-of-the-art  communication  surveillance  equipment,  upgrading 

146  European Commission, Programme Performance Statements (PPS), Anti-fraud, 2023, available here: 
https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-
performance_en#:~:text=In%202023%2C%20the%20programme%20committed,of%20the%20COVID
%2D19%20period  

147  Idem supra. 

123 

 
 
 
 

existing  surveillance  systems  and  tools,  and  training  personnel  to  operate  the 
newly acquired equipment; 
Improved  quality  of  data  and  evidence,  and  the  ability  to  exchange  data  with 
partners  from  other  Member  States  and  EU  agencies  and  participate  in  trans-
border investigations; 

  Enhanced  performance  of  investigative  authorities  and  LEAs  through  the 
acquisition of equipment and software that increases the volume and speed of data 
processing by enabling the use of AI and digitisation in activities such as evidence 
review, data classification, and identity verification; 

  Training  activities,  conferences,  study  visits  and  publications  have  enhanced 
transnational  cooperation  among  the  parties  involved  in  protecting  the  EU’s 
financial interests and have contributed to  applying  a multidisciplinary approach 
to  combating  fraud  and  other  illegal  activities,  including  bringing  together 
academic researchers and practitioners. 

3.1.2.2 AFIS component 

Unlike the Hercule component, AFIS does not provide financial support to applicants to 
develop  projects.  It  is  organised  and  managed  by  annual  working  programmes  and  its 
main  objective  is  to  facilitate  the  exchange  of  fraud-related  information  between 
competent national and EU administrations. 

AFIS’s  effectiveness  can  be  evaluated  by  its  outputs  (e.g.  number  of  new  applications 
developed, number of upgrades performed or features added, number of mutual assistance 
activities, such as JCOs, supported).  

A KPI for AFIS is the number of information items on mutual assistance made available. 
In assessing the impact of AFIS’s outputs, the key indicator is the level of satisfaction of 
its users, as measured by periodic user surveys.  The results from the latest (2023) survey 
are compared to results from the previous one (2019) in the table shown below. 

AFIS’s  budget  performance  is  determined  by  the  OLAF-established  indicator,  which 
reflects  the  amount of mutual  assistance information  made  available and the number of 
supported  mutual  assistance-related  activities.  For  the  period  2021-2023,  the  targets  for 
this indicator were exceeded.  

The  AFIS  budget  has  enhanced  mutual  administrative  assistance  among  customs 
authorities in the EU, supporting 35 JCOs and organising training sessions for key AFIS 
applications, such as CIS, VOCU, CSM and AMT148.  

The  2023  user  satisfaction  survey  confirmed  that  AFIS  remains  a  useful  tool  for  end 
users.  The  percentage  of  users  satisfied  with  the  functionality  and  performance  of  the 
various  AFIS  applications  remained  at  a  high  level  (with  the  most  frequently  used 

148 Data provided by OLAF (AFIS). 

124 

 
 
 
application  achieving  over  80%  satisfaction  rates).  There  are  some  minor  variations 
compared to the results of the 2019 AFIS satisfaction survey (see table hereafter). 

There  was  a  notable  decline  in  the  satisfaction  rates  for  the  CSM  application  (4 
percentage points (pp)), but  it nevertheless remained well above 80%. The 2023 survey 
results are based on 1 320 responses, while the 2019 survey was based on 799 responses 
(65% increase in respondents).  

Table 2 - Comparison of satisfaction with AFIS’s key applications: 2019 and 2023 

Indicator 

AFIS 2019 result 

AFIS 2023 result 

Change (%points) 

Number  of  responses 
(total) 

Helpdesk  (availability/ 
performance) 

799 

1 320 

+65 

92% / 89% 

93% / 90% 

+1 / +1 

AFIS 
(functionality/ 
performance) 

Mail 

87% / 86% 

86% / 86% 

-1 / = 

CIS+ 
performance) 

(functionality/ 

CSM 
performance) 

(functionality/ 

opinion 
General 
(relevant 
to 
professional  needs  – 
agree/slightly agree) 

85% / 86% 

83% / 86% 

91% / 92% 

87% / 88% 

-2 / = 

-4 / -4 

57% / 27% 

59% / 23% 

+2 / -4 

Source: AFIS satisfaction survey 2019 and 2023 (N=1 320). 

The 2023 survey confirmed that AFIS is able to deliver functioning tools for information 
exchange  in  its  dedicated  area  of  action.  Two-thirds  of  respondents  believed  that  the 
available applications in AFIS provide up-to-date tools to tackle the latest trends in fraud 
and related irregularities.  

3.1.2.3 IMS component 

Like  AFIS,  IMS  is  not  a  financing  programme  supporting  grantees  on  a  project  basis. 
Rather,  its  main  function  is  to  facilitate  the  reporting  of  suspected  and/or  detected 
irregularities in the implementation of EU funds. The system is used by Member States 
and other beneficiaries (34 countries, 789 organisations, with over 3 230 registered users 
as of March 2024)149.   

149  Data provided by OLAF (IMS). 

125 

 
 
Users  and  stakeholders  perceive  the  system  as  a  useful  reporting  and  tracking  tool  and 
identified several strengths: 

 

 

It  is  the  only  system  in  the  EU  where  data  on  past  and/or  closed  cases  of 
irregularities are collected and can be searched; 
IMS  provides  contextual  information  on  irregularities  and  on  the  state  of  the 
fraud, identified in the Member States, candidate countries and third countries; 
IMS provides a standardised tool to collect data on irregularities; 

 
  The  majority  of  users  find  the  system  reliable  and  user-friendly,  highlighting 
features  such  as  visibility  of  data,  downloadable,  availability  of  data  in  native 
languages of Member States; 
IMS interfaces with national databases and can support automatic data transfer. 

 

Identified  weaknesses  in  IMS’s  technical  properties  and  management  of  the  system,  as 
well as users’ data entry are: 

 
Issues related to authentication; 
  Difficulties  when  searching  for 

information, 

time-consuming  checks  of 

irregularities; 
Insufficient communication on updates and improvements to IMS; 
Insufficient guidance on which information to insert; 

 
 
  Data quality: not all cases were entered into the system and not all information on 
the cases was available (completeness). The insertion of data by different users in 
distinct Member States, regions, etc. was not always consistent, homogeneous, or 
coherent  (reliability  and  consistency).The  data  were  not  always  up-to-date  with 
the most recent events (promptness). 

There  are  no  sanctions  for  countries  that  do  not  fully  report,  and  this  may  somewhat 
explain  the  lower  rate  of  use  of  the  system  by  contributing  authorities.  OLAF 
investigators  and  selectors,  as  well  as  Commission  users  from  shared  management 
programmes,  also  use  data  from  IMS  to  a  relatively  low  extent.  This  stems  from  the 
issues described, as well as a lack of awareness of how the system functions and what it 
can offer. 

However, the IMS and its associated specific objective have been relevant to achieving 
the  general  objective  of  protecting  the  Union’s  financial  interests,  with  the  system 
showing  encouraging  signs  of  being  a  useful  tool  for  Member  States  to  report 
irregularities and contribute to the broader fight against fraud.  

The  2023  AFIS  satisfaction  survey  contained  questions  on  the  functionality  and 
performance of IMS. The combined satisfaction rate (functionality and performance) of 
IMS users was approximately 91%150, compared to 72% in 2019.  

150  AFIS satisfaction survey 2023. The satisfaction rate of IMS users is a combination of the satisfaction 
rate of functionality and performance of the application after the removal of the 'do not know’ 
responses. This matches the approach taken by OLAF in assessing satisfaction with IMS. 

126 

 
 
At  the  same  time,  interviews  with  several  IMS  country  managers  revealed  areas  for 
improvement; for instance, there are too many fields and their descriptions are sometimes 
confusing.  The  ongoing  upgrade  of  IMS  has  yet  to  improve  the  user  experience,  with 
users instead faced with increasing demands to report more data and improve the quality 
of data entry, which may also affect their satisfaction levels.  

3.1.3 To what extent have the activities funded by the UAFP contributed to 
enhanced transnational cooperation? 

The  activities  supported  by  the  UAFP  have  contributed  significantly  to  enhanced 
transnational cooperation among the beneficiaries. This conclusion is based on the review 
of  the  OLAF  survey  of  applicants/beneficiaries,  interviews  with  beneficiaries  of  grants 
awarded  under  the  Hercule  component,  and  the  exchange  of  information  between 
Member States and EU authorities facilitated by AFIS and IMS. 

Of  the  beneficiaries  of  the  Hercule  component,  71%  agreed  that  the  UAFP  has 
contributed to trans-border cooperation. More specifically, the interventions have created 
networking  opportunities  and  facilitated  the  exchange  of  information  and  best  practice. 
The  strongest  impact  was  on  cooperation  among  EU  Member  States  (71%),  while  the 
programme's impact on cooperation with non-EU countries was relatively limited (about 
two-thirds of respondents believed that the programme made little or no contribution to 
cooperation with non-EU countries).  

However,  Member  State  applicants  may  apply  for  support  with  projects  involving  non-
EU  countries,  where  relevant  and  necessary  for  ensuring  the  protection  of  the  EU 
financial  interests,  and  the  amount  of  these  projects  depends  on  the  amount  of 
applications received. Beneficiaries of Hercule III agreed that the projects had a positive 
effect on transnational cooperation, but no specific data were available from the end user 
survey to draw a direct comparison with the UAFP results on this indicator. 

Figure 3 - Contribution of UAFP interventions to transnational cooperation 

Source: OLAF survey of applicants/beneficiaries (N=15). 

127 

 
 
The technical assistance and training awards granted under the Hercule component have 
made  a  strong  contribution  to  transnational  cooperation,  as  evidenced  by  the  in-depth 
review  of  ongoing  and  completed  projects.  Several  ways  of  enhancing  transnational 
cooperation have been identified:  

  Projects under the calls for training, conferences, staff exchanges and studies provide 
opportunities  for  networking  at  conferences,  seminars  and  bilateral  study  visits,  and 
for the exchange of ideas and information through academic research and periodicals 
(e.g. Eucrim platform that serves as a forum for Europe-wide criminal law); 

  Technical  assistance projects  enhance transnational  cooperation even when activities 
are focused on one Member State. Beneficiaries  reported  reaching  out  to  partners in 
other  countries  during  their  market  research  on  equipment  and  suppliers  as  part  of 
their  procurement  efforts.  In  addition,  the  technical  assistance  projects  improved 
beneficiaries’  ability  to  respond  to  requests  from  EU  partners  for  investigative 
evidence  or  data  related  to  fraud,  corruption  and  the  shadow  economy.  Another 
benefit  mentioned  is  stronger  capacity  to  engage  in  joint  operations  with  other 
Member States, Europol, Eurojust and other international organisations.  

Further  details  on  specific  modes  of  transnational  cooperation  (e.g.  training  involving 
both  trainees  and  trainers  from  several  Member  States)  are  presented  in  the  four  case 
studies. For instance, one project in Lithuania delivered training to forensic experts from 
four Member States (Estonia, Croatia, Latvia and Lithuania) and Ukraine.   

Transnational  cooperation  is  enhanced  by  the  functioning  of  AFIS  and  IMS,  both  of 
which provide a platform for the exchange of information between users from all Member 
States. The transnational dimension is also seen as one of IMS’ strengths.  

Several  AFIS  applications  (the  Anti-Fraud  Transit  Information  System  (ATIS),  VOCU, 
AFIS  Mail,  etc.)  enhance  cooperation  with  a  large  number  of  non-EU  countries.  The 
JCOs  supported  by  AFIS  also  contribute  to  cooperation  with  EU  and  international 
organisations (e.g. Europol, Frontex, EUBAM, and the World Customs Organization)151. 

3.1.4 To what extent have the technical assistance interventions contributed to a 
multidisciplinary cooperation? 

The  technical  assistance  interventions  have  contributed  to  multidisciplinary  cooperation 
to a large extent, according to responses from OLAF’s survey of applicants/beneficiaries 
and  feedback  from  beneficiaries  of  Hercule  component  projects.  From  the  application 
stage  to  the  preparation  of  the  technical  specification,  carrying  out  the  procurement 
procedures, organising training and knowledge exchanges, the project teams have relied 
on the coordinated activities of experts from a variety of disciplines.  

Multidisciplinary  cooperation  has  also  been  enhanced  by  the  participation  in  project 
teams of practitioners from law enforcement agencies and anti-fraud agencies, as well as 

151 Stakeholder consultation with OLAF (AFIS). 

128 

 
 
academics and trainers from universities and research institutions. Of the beneficiaries of 
to 
the  Hercule  component,  73%  confirmed 
multidisciplinary cooperation. 

the  UAFP  has  contributed 

that 

Figure 4 - Contribution of UAFP interventions to multidisciplinary cooperation 

Source: OLAF survey of applicants/beneficiaries (N=15). 

The  feedback  from  Hercule  project  beneficiaries  confirmed  that  the  preparation  of  the 
applications and the implementation of the project activities would have been impossible 
without  the  involvement  of  multidisciplinary  teams.  More  specifically,  the  following 
types  of  experts  have  collaborated  under  the  UAFP:  law  enforcement  officers, 
prosecutors, tax and customs officers, software and hardware engineers, video and audio 
communication  experts,  statisticians,  economists,  legal  experts,  project  managers,  and 
financial  experts.  All  projects  reviewed  in  the  case  studies  have  demonstrated  this 
multidisciplinary approach in their activities.  

For instance, the project in Latvia, on new surveillance equipment, required the expertise 
of  mobile  communication  engineers,  automobile  experts,  investigators  (with  knowledge 
of tobacco and excise goods smuggling), procurement experts and project managers.   

Similarly, a Spanish project targeting the criminal use of parcel services to smuggle illicit 
goods  in  and out of Spain  necessitated a multidisciplinary approach to  the procurement 
and  training  on  scanner  vans,  portable  scanners  and  remotely  operated  underwater 
vehicles.  

Most of the other projects focusing on digital forensics and data analytics create enhanced 
cooperation between IT experts and fraud investigators. Studies, conferences and training 
bring  together  social  science  researchers  with  practitioners  from  national  customs  and 
anti-corruption authorities. 

One  beneficiary  pointed  out  that  the  multidisciplinary  approach,  particularly  the 
participants  at  conferences  and  training  activities,  is  a  strength  that  helps  the  UAFP  to 
compare  favourably  to  other  EU  programmes,  which  tend  to  be  more  restrictive  in  the 
selection  of  beneficiaries.  Another  strong  point  is  the  opportunities  it  creates  for 
practitioners and academics to work together in the framework of one intervention (e.g. a 
study in Italy and a periodical in Germany). 

129 

 
 
AFIS’s  support  to  JCOs  is  an  example  of  interventions  that  enhance  multidisciplinary 
cooperation,  as  the  JCOs  often  involve  participants  from  law  enforcement  and  border 
security services, in addition to customs agents.  

3.1.5 What factors influenced the effective implementation of the technical and 
operational activities funded under the first component of the UAFP budget? 

Several  factors influenced the effective implementation  of the technical  and operational 
activities,  both  positively  and  negatively.  The  main  factors  mentioned  by  survey 
respondents are administrative capacity, internal procedures within their organisation, and 
the amount of funds and resources available. 

Among the positive factors, respondents most often mentioned the amount of funds and 
resources (50%) and administrative capacity (43%). The clarification support provided by 
the Commission was also noted as a positive factor by 43% of beneficiaries. 

Figure 5 - Factors supporting the implementation of UAFP interventions 

Source: OLAF survey of applicants/beneficiaries (N=15). 

The highest weight among the negative factors was attributed to the lack of administrative 
capacity (36% of beneficiaries) within the applicants’ administration, followed by internal 
procedures  in  their  organisation  (29%),  and  the  amount  (lack)  of  funds  and  resources 
(21%). 

Figure 6 - Factors hindering the implementation of UAFP interventions 

130 

 
 
Source: OLAF survey of applicants/beneficiaries (N=15). 

Certain  factors,  such  as  administrative  capacity  and  the  amount  of  resources  available, 
were mentioned by some beneficiaries as contributing to the effective implementation of 
their  projects,  but  by  others  as  factors  preventing  the  implementation  of  the  planned 
activities.  This  highlights  the  significance  of  national  specifics  influencing  the 
effectiveness of the programme's interventions.  

3.1.6 How did technical assistance activities contribute to limiting the currently 
known exposure of the financial interests of the Union to fraud, corruption, or other 
illegal activities? 

In general,  it is  difficult  to  isolate and quantify the impact  of  a specific intervention on 
fraud,  corruption,  and  other  illegal  activities,  particularly  given  the  short  evaluation 
period  and  the  limited  number  of  completed  projects.  Accordingly,  the  study  team 
focused  on  collecting  data  on  stakeholders’  perceptions  rather  than  quantitative  data  on 
measured impacts. 

The majority of respondents to the survey of applicants/beneficiaries supported the idea 
that  the  project  awarded  under  the  UAFP  effectively  contributed  to  limiting  the  known 
exposure of EU financial interests to fraud, corruption, or other illegal activities.  

One-fifth  of  respondents  did  not  agree,  while  one-third  of  respondents  did  not  answer. 
The case studies confirmed that the UAFP’s interventions have the potential to contribute 
to  limiting  the  current  exposure  to  fraud  and  corruption  by  improving  investigation 
capabilities and capacities and raising awareness of fraud and corruption risks. 

Figure 7 - To what extent has your intervention under UAFP effectively contributed 
to  limiting  the  currently  known  exposure  of  the  financial  interests  of  the  Union  to 
fraud, corruption, or other illegal activities? 

131 

 
 
14,3%

28,6%

21,4%

35,7%

To a significant extent

To a large extent

Somewhat

Do not know / Not applicable

Source: OLAF survey of applicants/beneficiaries (N=15). 

The activities supported under the three components of the UAFP make several indirect 
contributions  to  limiting  the  exposure  of  the  financial  interests  of  the  Union  to  fraud, 
corruption, and other illegal activities:  

  Technical  assistance  projects  enhance  the  capacity  of  LEAs  to  investigate  or 
prevent  known  exposure  by  providing  up-to-date  technological  and  knowledge 
resources to combat fraud and irregularities; 

  Training, publications and studies supported by the UAFP enhance the capacity of 
customs  and  LEA  personnel  and  develop  the  knowledge  base  needed  to  combat 
fraud, corruption, and other illegal activities; 

  AFIS supports customs officers to exchange timely information to prevent fraud; 
 

IMS  supports  the  timely  exchange  and  sharing  of  irregularities  information, 
enabling its users to utilise other LEAs’ past experiences when establishing fraud 
prevention measures.  

3.2 Efficiency 

This section presents the evaluation findings on the efficiency of the UAFP. 

3.2.1 Main conclusions: efficiency of the UAFP 

  Overall,  as  a  result  of  the  Hercule  component  of  the  UAFP,  the  EU  and  national 
organisational units with investigative authority have used their resources more efficiently 
to  fight  serious  crimes  that  harm  EU  financial  interests.  The  interviews  yielded  the  most 
detailed  and  comprehensive  overview  of  the  main  observable  benefits.  Although  full 
assessment  was  complicated  by  the  status  of  project  implementation,  it  was  possible  to 
identify  the  main  areas  where  the  UAFP  has  contributed  to  higher  efficiency  in cost  and 
resource  management.  These  include:  equipment  purchase,  fraud-related  data  gathering, 
analysis and exchange, training actions, relationship building and investigations 

  The  current  application  process  represents  a  significant  improvement  to  that  under  the 
previous programme, with stakeholders finding it highly efficient. The current UAFP takes 
on  board  the  feedback  and  recommendations  of  the  Hercule  III  evaluation  (2021)  to 
simplify  the  application  procedure  and  provide  more  guidance  to  applicants152.  Based  on 

152 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582. 

132 

 
 
 
stakeholders’ feedback and desk research, efficiency improvements include the streamlined 
application  procedure  and  form,  as  well  as  the  higher  level  of  guidance  and  support 
provided  to  applicants.  Although  it  is  difficult  to  clearly  quantify  the  time  and  human 
resources  needed to  complete the application,  or  to  establish  whether  this is significantly 
lower or higher than the previous programme, stakeholders provided positive feedback on 
the new application 

  The  interim  evaluation  of  the  Hercule  component  found  that  beneficiaries  reported  some 
cost savings, with one-third estimating these savings to be very significant or significant. 
Beneficiaries  noted  that  their  improved  capacity  and  capabilities  will  allow  them  to  be 
more efficient in carrying out operations in their countries. This increased efficiency has a 
snowball effect and benefits EU partner agencies: UAFP participants are better equipped to 
respond to requests for mutual assistance and joint investigations with EU partner agencies 
as a result of improved equipment and skills acquired with the help of UAFP grants 

  Some benefits of AFIS were noted, such as its contribution to 10 JCOs in 2022. IMS users 
believe that UAFP funding for the IMS represents an efficient use of resources. However, 
the  efficiency  associated  with  the  improvements  to  the  two  systems  is  difficult  to  assess 
from the data available for this evaluation 

Source: ICF analysis. 

3.2.2 To what extent have the desired effects been achieved at reasonable costs on 
the basis of a cost/benefits analysis? 

This  section  assesses  whether  the  identified  costs  of  the  UAFP  are  exceeded  by  the 
benefits identified under the effectiveness criterion. It examines the costs associated with 
each of the three components of the UAFP (Hercule, IMS and AFIS) and compares these 
with the benefits of each component. There is a particular focus on costs and benefits in 
2021  and  2022,  for  which  data  on  spending  are  available,  together  with  some 
achievements.  

The  analysis  suggests  that  the  costs  incurred  by  the  UAFP  are  commensurate  with  its 
benefits,  i.e.  the  UAFP  represents  an  efficient  use  of  resources  on  the  basis  of  a  cost-
benefit  analysis.  However,  the  limited  data  available  at  this  interim  stage  of  the 
programme prevent  a complete, quantitative mapping of programme costs and benefits, 
or direct comparison of all monetised costs and benefits. Rather, the comparison between 
costs and benefits here is made primarily on a qualitative basis.  

3.2.2.1 The UAFP budget 

Of  the  programme,  the  Hercule  component  makes  up  the  largest  share  of  the  budget 
(63%), followed by AFIS (33%) and IMS (4%)153. 

Table 3 - Yearly budgets, by components of UAFP (EUR) 

153  European Commission, 33th Annual Report on the Protection of the European Union’s financial 

interests (PIF Report 2021), https://anti-fraud.ec.europa.eu/document/download/ac7fe82e-c7df-44c0-8df7-
277f73032d4b_en?filename=pif-report-2021_en_0.pdf.  

133 

 
 
Component 

2021 

2022 

2023-2027 

2021-2027 

Hercule component  15.2  million  

15.4  million  
(63%) 

83.6 
(63%) 

million  

(63%) 

8.0 
(33%) 

million  

8.0  million  
(33%) 

44 
(33%) 

million  

114.2 
(63%) 

60 
(33%) 

million  

million  

0.9 
(4%) 

million  

0.9  million   
(4%) 

5.1 
(4%) 

million  

7 
(4%) 

million  

AFIS 

IMS 

Source: ICF analysis. 

The UAFP budget has increased significantly on previous years, growing from EUR 12 
million with Hercule I to EUR 104.9 million with Hercule III154. 

The remainder of this section discusses costs incurred for each of the three components, 
benefits realised, and how these compare.  

3.2.2.2 Hercule component  

This section identifies and compares the main costs and benefits associated with the 
Hercule component of the UAFP.  

3.2.2.3 Hercule cost items 

Over 2021 and 2022155, EUR 29.7 million was committed by the UAFP to the technical 
assistance  and  training  component  (EUR  14.5  million  in  2021;  EUR  15.2  million  in 
2022).  This  was  relative  to  the  budgeted  amounts  of  EUR  15.2  million  for  2021,  EUR 
15.4 million for 2022, and EUR 114 million for the period 2021-2027.   

Over two-thirds of UAFP spending under the Hercule component during 2021 and 2022 
was on grants, with EUR 20.3 million spent on technical assistance grants and EUR 1.88 
million on anti-fraud training grants. Of the EUR 7.44 million spent on procurement, the 
largest item (EUR 3.21 million) was digital forensics and analyst training.  

Table 4 - Technical assistance and training spending (EUR) 

Item/year 

2021 

2022 

Total 

154  European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582; European Commission, Final evaluation of the 
Regulation (EU) No 250/2014 of the European Parliament and of the Council of 26 February 2014 
establishing a programme to promote activities in the field of the protection of the financial interests of 
the European Union (Hercule III programme) and repealing Decision No 804/2004/EC, SWD(2021) 
386 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021SC0386. 

155  Consideration of costs is limited to 2021-2022 to align with the data available on Hercule benefits.  

134 

 
 
Item/year 

Grants 

Technical 
assistance 
grants 

Anti-fraud 
training grants 

2021 

2022 

Total 

10 678 299 

9 578 008 

20 256 307 

802 285 

1 076 935 

1 879 220 

Procurement 

IT databases 

  707 360 

707 360 

1 414 720 

717 961 

733 673 

1 451 634 

tools  and 

IT 
tobacco 
analysis 

Conferences 

144 715 

1 165 845 

1 310 560 

1 414 000 

1 799 543 

3 213 543 

53 628 

0 

53 628 

Digital 
forensics 
analyst 
training 

and 

WHO 
Framework 
Convention  for 
Tobacco 
Control 
(FCTC) 

Total 

14 518 248 

15 175 260  

29 693 508 

Source: ICF analysis; PIF Reports 2021, 2022. 

These  spending  figures  describe  the  amounts  disbursed  by  the  UAFP  to  beneficiaries. 
However,  they  do  not  capture  additional  administrative  costs  that  arise.  Administrative 
costs for beneficiaries include costs related to applying for grants and to monitoring and 
reporting  on  funded  projects,  while  administrative  costs  for  the  UAFP  include  costs  of 
setting  up  annual  work  programmes,  publishing  and  disseminating  calls  for  proposals, 
and selecting beneficiaries. 

It  is  difficult  to  quantity  the  typical  time  and  human  resources  needed  to  apply  for 
Hercule funding. Applicant organisations’ reported amounts varying from three days to 
up to three months156. Although efficient overall, the application represents a significant 
undertaking  for  some  applicants,  with  several  of  those  interviewed  noting  that  the 

156  Interviews with beneficiaries. 

135 

 
 
 
 
 
application is long and requires a lot of information. The degree of variation in the time 
to  complete  the  application  may  be  explained  by  several  factors,  including  applicants’ 
groundwork before the call (e.g. reaching out to consortium partners and providers) and 
their familiarity with the application process. Several noted that the application was less 
time-consuming when they had prior experience with it157. 

Applicants'  interview  responses  showed  that  the  application  process  has  significantly 
improved compared to the previous programme (Annex 1). The administrative burden of 
the application seems proportionate, with 23 (of 29) applicants/beneficiaries responding 
that  the  administrative  and  financial  requirements  of  preparing  and  submitting  their 
application  were  ‘reasonable’  or  ‘very  reasonable’.  Only  three  considered  the 
requirements ‘burdensome’.  

However,  some  beneficiaries  of  training  actions  expressed  dissatisfaction  with  the 
administrative  burden  of  project  reporting,  which  may  be  onerous  and  demanding  (e.g. 
documents, statements, declarations)158. 

3.2.2.4 Hercule benefits  

In 2021-2022, 66 grants were distributed under the UAFP’s Hercule component, seven of 
which were scheduled to end before October 2023159. To date, these grants have greatly 
increased recipients’ organisational capabilities, with national authorities better placed to 
combat  fraud  and  reduce  budgetary  and  economic  losses  resulting  from  fraud.  Hercule 
funding has helped national authorities with:  

•  Equipment purchases: The UAFP has enabled organisations to acquire modern 
tools  with  higher  technical  standards  than  might  otherwise  have  been  possible 
with  national/own  funding.  The  purchase  of  new  state-of-the  art  equipment  has 
contributed  to  the  quality  of  forensic  services,  improving  national  authorities’ 
ability to detect fraud and prevent losses; 

•  Data collection, analysis and sharing: The UAFP has funded projects that make 
use of information systems to collect, automate and process large volumes of data. 
These  data  contribute  to  investigations,  increasing  the  likelihood  of  success  in 
detecting and deterring fraud;  

•  Training:  UAFP  training  has  helped  national  authorities  to  upgrade  their 
knowledge and practical skills. Authorities can apply new knowledge and skills to 
combat fraud more effectively, eventually reducing the impact of fraud on public 
funds; 

•  Networking,  exchanges  and  good  practices:  Participants  in  training  and  other 
events,  such  as  study  visits  and  conferences,  have  developed  a  better 
understanding of how colleagues in other jurisdictions tackle corruption and fraud 
the 
and  collaborate  with  EU  agencies  and  authorities.  This  facilitates 

157  Interviews with beneficiaries. 
158  Interviews with beneficiaries. 
159  Key evaluation documents such as final technical reports and final implementation reports for these 

grants are not yet available for most projects. 

136 

 
 
implementation  of  best  practices  for  preventing  fraud  across  the  EU,  leading  to 
more effective national efforts against fraud;  

•  Investigations:  The  funded  projects  improve  data-sharing  between  national  and 
European authorities and between relevant national authorities, including tax and 
police  authorities.  New  equipment,  data  analysis  capacity,  and  knowledge  and 
skills  may  improve  the  quality  of  investigations,  reduce  the  resource  need  and 
increase  the  chances  of  success,  ultimately  reducing  the  damaging  impacts  of 
fraud on public funds and the economy.  

Survey  respondents  had  mixed  views  on  the  extent  to  which  their  activities  under  the 
UAFP  grant  have  contributed  to  cross-border  cooperation.  For  each  of  several  types  of 
cross-border  cooperation,  a  minority  of  respondents  reported  that  their  activities  under 
the UAFP grant have contributed ‘to a large extent’ or ‘to a great extent’.  

that  UAFP-funded 

interventions  have  contributed 

These  responses  suggest 
to 
organisations’  capacities  to  fulfil  their  individual  mandates  but  have  fewer  benefits  in 
improving  EU-wide  coordination  and  structures.  These  results,  however,  reflect  the 
perceptions of a limited sample of applicants at an interim stage of the implementation of 
their grant projects. A more thorough understanding of the benefits of different projects 
will only be possible once these have been completed and data reported to illustrate their 
outcomes.  In  addition,  the  survey  results  do  not  cover  the  full  population  of  funded 
entities, and projects also receive funding (20%) outside the UAFP, such as national co-
funding. As such, the benefits might not be attributable to the UAFP alone. 

3.2.2.5 Comparison of costs and benefits 

UAFP-funded interventions have contributed to applicants’ organisational, investigative, 
and  technical  capacities.  According  to  the  beneficiaries  interviewed,  UAFP  grant  costs 
yield benefits. Applicants do not view the administrative costs of applying for a grant as 
particularly burdensome, indicating that the benefits are likely to outweigh these costs.  

However,  six  (of  12  successful  applicants)  responded  that  their  costs  related  to  the 
implementation of the project outweighed the benefits (at least a ‘little’)160.  

The UAFP seems to have led to cost savings in different areas. In evidence gathering, for 
example, the funds disbursed have contributed to the acquisition of devices that extract 
data at  the crime scene that  can later be used in  criminal  proceedings. The adoption of 
such  devices  save  costs  compared  to  the  previous  situation,  when  investigative 
authorities had to seize devices and pay an expert to extract the data161.  

3.2.2.6 AFIS component 

This section identifies the main costs and benefits associated with the AFIS component 
of the UAFP and compares these costs and benefits.  

160 Survey of applicants and beneficiaries, Q 15.4. 
161 Interviews with beneficiaries. 

137 

 
 
3.2.2.7 AFIS Cost items 

Over 2021 and 2022, EUR 16.0 million was committed by the UAFP to AFIS (EUR 7.96 
million  in  2021;  EUR 8.01 million  in  2022). This  was  relative to  budgeted amounts of 
EUR  7.96  million  for  2021,  EUR  8.01  million  for  2022,  and  EUR  60  million  for  the 
period 2021-2027. EUR 8.23 million was budgeted for 2023.  

The largest AFIS spending item across 2021 and 2022 was IT studies, development, and 
maintenance,  at  EUR  7.81  million  (49%  of  total  spending).  This  was  followed  by 
production  services  (EUR  3.50  million)  and  acquisition,  maintenance  and  updating  of 
software  and  hardware,  and  related  IT  services  (EUR  2.22  million).  These  three  items 
were also assigned the largest budget for 2023 (EUR 4.00 million, EUR 2.42 million, and 
EUR 1.15 million, respectively). 

Table 5 - AFIS spending (EUR) 

Item/year 

2021 

2022 

2023 
(budgeted) 

Total 

studies, 

IT 
development, 
and 
maintenance 

Production 
services 

Technical 
assistance, 
training, 
coordination, 
and 
quality 
control services 

Acquisition, 
maintenance 
and updating of 
software 
and 
hardware,  and 
related 
IT 
services 

Funds 
delegated 
DG TAXUD 

co-
to 

4 056 540 

3 754 627 

3 995 000 

11 806 167 

1 750 021 

1 749 767 

2 420 000 

5 919 788 

194 797 

231 235 

405 000 

831 032 

 1 246 975 

968 770 

1 150 856 

3 366 601 

 252 279 

239 246 

257 032 

748 557 

138 

 
  
  
Item/year 

2021 

2022 

2023 
(budgeted) 

Total 

Contingency162  463 388 

1 065 508 

0 

1 528 896 

Total 

7 964 000 

8 009 153 

8 227 888 

24 201 041 

Source: ICF analysis; PIF Reports 2021, 2022. 

Overall AFIS spending in both 2021 and 2022 matched the budget allocation. In terms of 
time  allocation  (measured  in  person  days),  ‘application  development’  was  the  most 
resource intensive activity163 in 2021 (5 325 person days164), 2022 (6 168 person days)165, 
and the first half of 2023 (3 197)166. In 2021 and the first half of 2023, ‘technology stack’ 
was the next largest use of person days (at 1 957 and 732, respectively), but in 2022 the 
second  largest  use  was  for  the  ‘Fraud  Analytical  Platform’  (1 520  person  days).  That 
Platform was also the third largest use in the first half of 2023 (533 person days).  

3.2.2.8 AFIS Benefits 

UAFP  funding  for  AFIS  yields  identifiable  benefits.  AFIS  is  used  by  9 000  registered 
end users in countries within and outside the EU167. Survey responses from AFIS users 
indicated that AFIS has a beneficial effect on the capacity of fraud authorities to carry out 
their  duties.  A  majority  of  surveyed  AFIS  users  disagreed  with  the  statement,  ‘in  the 
absence of AFIS, I would be able to perform my duties using a similar existing national 
system’. Users believe that AFIS improves the quality of cooperation between LEAs and 
services  in  neighbouring  countries168.  This  helps  national  authorities  to  reduce  the 
monetary value of fraud-related losses to public funds and the economy.    

The 2021 PIF Report highlighted the work of the AFIS CIS+ module in the context of the 
Cash  Control  Regulation  implemented  in  2021:  ‘In  December  2021,  six  months  after 
going  live,  CIS+  had  more  than  2,200  users  and  contained  data  on  31,500  cash 
declarations  and  1,800  infringements  of  the  Regulation’169.  In  the  first  five  months  of 
2023, CIS+ detected an average of 9 573 cash declarations with infringements per month. 

162   This line item is provided in the cost tables included in the UAFP PIF Reports. Typically, the 

‘Contingency’ item is used to capture (relatively small) unforeseen costs, although the PIF reports do 
not specify the unforeseen costs in this case.   

163   Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2022, C(2022) 1139, https://anti-
fraud.ec.europa.eu/document/download/7824f63f-724b-486a-b7b9-
d8880e4d5456_en?filename=uafp_work_programme_2022_annex_en.pdf. 

164  Data for January to November.  
165  Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2023, C(2023) 813. 

166  Ibid. 
167  Figures shared with ICF by OLAF. 
168  Interviews with beneficiaries, Survey of applicants and beneficiaries and evidence from desk research 

some similar benefits.  

169  Ibid. 

139 

 
 
The  2022  PIF  report  highlighted  that  AFIS  supported  10  JCOs  that  year.  These  data 
points  provide  some  indication  of  the  benefits  of  AFIS  (and,  by  extension,  UAFP 
funding) in preventing and detecting fraud. 

At a technical and operational level, UAFP funding enables AFIS to continue delivering 
benefits  for  users,  i.e.  to  continue  its  function  as  a  secure  portal  for  national  and  EU 
administrations  to  exchange  information  on  fraud.  The  UAFP  allows  AFIS  to  be 
maintained  and  improved.  UAFP  funding  was  used  to  provide  eight  AFIS  platform 
releases in 2021 (including CIS+) and 15 in 2022. In the first six months of 2023, AFIS 
delivered 61 minor releases across 10 platforms170. UAFP funding also allows for support 
to be provided to AFIS users: 73% of surveyed AFIS users reported contacting the AFIS 
IT Helpdesk in  the previous two years  and the vast  majority (over 90%)  were satisfied 
with the support received.  

3.2.2.9 AFIS - Comparison of costs and benefits 

These  benefits  provide  indicative  evidence  that  the  funding  provided  by  the  UAFP  for 
AFIS  enables  the  provision  and  improvement  of  a  useful  tool  for  end  users.  Certain 
modules  within  AFIS  –  in  particular,  CIS+  –  appear  to  be  registering  notable 
achievements  in  detecting  potential  cases  of  fraud.  A  recent  AFIS  satisfaction  survey 
showed  that  respondents  are  very  satisfied  overall  with  the  new  functionalities, 
particularly noting that the speed of access improves the efficiency of operations171. 

3.2.2.10 IMS component 

This section identifies and compares the main costs and benefits associated with the IMS 
component of the UAFP.   

3.2.2.11 IMS Cost items 

Over  2021  and  2022,  the  UAFP  committed  EUR  1.82  million  to  the  IMS  (EUR  0.914 
million in 2021; EUR 0.934 million in 2022). This was relative to budgeted amounts of 
EUR  0.929  million  for  2021,  EUR  0.934  million  for  2022,  and  EUR  7  million  for  the 
period 2021-2027.  

To  date,  87%  of  spending  on  the  IMS  has  gone  towards  development,  maintenance, 
training, and support. 

3.2.2.12 IMS Benefits 

UAFP  funding  enables  the  IMS  to  continue  its  function  as  an  integrated  irregularity 
reporting system used by around 3 230 end users in 34 countries within and outside the 

170  Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2023, C(2023) 813. 

171 AFIS satisfaction survey 2023, launched in autumn 2023, finalised early 2024. 

140 

 
 
EU172. IMS is perceived by users and stakeholders as a useful tool for both reporting and 
tracking  irregularities  and  fraud’173.  The  IMS  allows  national  authorities  to  fulfil 
reporting obligations to the Commission in a standardised, simplified way. The absence 
of  such  a  system  would  likely  increase  reporting  costs  for  national  authorities  and 
management  costs  for  the  Commission.  The  IMS  thus  facilitates  EU  and  national 
authorities’ efforts to use available fraud prevention budgets as effectively as possible to 
prevent fraud-related damage to public funds and the economy. 

IMS  shows  several  features  that  contribute  to  the  system’s  perceived  usefulness, 
including its uniqueness as a database where past and/or closed cases of irregularities can 
be searched (12 455 irregularities were reported to the IMS in 2022). To the extent that 
the IMS helps national and EU authorities to identify, understand, and eventually prevent 
irregularities, including fraud, its ongoing functionality can be considered a benefit of the 
UAFP, which merits its continued funding and development.  

UAFP funding has been used to improve the IMS. Four new features were developed and 
released in each of 2021 and 2022.  

In  2021,  new  features  included:  improved  reporting  of  RRF  irregularities;  uploading 
irregularities  directly  from  national  databases;  rights  of  IMS  country  officers;  and 
uploading of reports by business owners174. 

The  2022  PIF  Report  described  new  feature  developments  as  ‘allowing  business 
managers  to  manage  code  list  values,  [improving]  the  B2B  services  and  [fixing]  a 
number of identified issues’175. 

3.2.2.13 IMS Comparison of costs and benefits 

The consulted documentation on IMS offered indicative evidence that UAFP funding for 
the  IMS  represents  an  efficient  use  of  resources,  at  least  according  to  users.  However, 
without  more  detailed  data,  it  is  difficult  to  understand  the  effects  of  the  IMS  on  the 
ultimate  goals  of  protecting  the  EU’s  financial  interests  and  facilitating  cooperation 
between Member State administrations.  

Further benefits and costs-effectiveness could be realised through greater awareness and 
training on IMS functionalities. 

172 Figures from IMS User Registration Tool data, shared by OLAF.  
173 The countries utilising the IMS are those for which the reporting obligation is set in a legal text, either 

through an EU regulation or a financing agreement. This is not the case for all countries that receive EU 
assistance. 

174 PIF Report 2021.  
175 PIF Report 2022.  

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3.2.3 To what extent has the UAFP facilitated a more integrated use and simplified 
management of financial resources? 

The data do not allow definitive conclusions to be drawn on whether the UAFP has led to 
more  efficient  management  of  financial  resources  by  the  EU  and  national  authorities. 
Available  data  indicate  that  the  UAFP  has  led  to  a  more  efficient  project  delivery, 
compared to national funding. This is because the programme allows for equipment to be 
purchased  quickly  and  in  greater  volumes.  While  beneficiaries  did  not  have  specific 
suggestions  on  how  the  management  of  the  UAFP  could  be  made  less  costly,  several 
found the reporting process burdensome, which may warrant further examination176. 

The  evaluation  finds  that  the  current  UAFP  has  taken  into  account  the  feedback  and 
recommendations  of  the  final  evaluation  of  Hercule  III  (2021)  and  provided  a  more 
streamlined  application  procedure,  guidance  and  support  to  applicants.  The  application 
procedure for the Hercule component is found to be efficient. 

3.2.3.1 Administrative processes for the Hercule component 

This sub-section presents the analysis of evidence on the efficiency of the administrative 
processes of the Hercule component. It is divided into three sub-sections: the application 
procedure, project implementation, and budgetary flexibility.  

3.2.3.2 Application procedure 

The application procedure for grants under the Hercule component of the current UAFP 
is  found  to  be  highly  efficient,  based  on  the  applications  and  consultations  with 
applicants.  The  current  application  process  has  taken  on  board  the  feedback  received 
during the previous evaluation (2021). 

The final evaluation of the Hercule III (2021) suggested some improvements to make the 
application  process  more  efficient  for  applicants.  The  final  evaluation  of  Hercule  III 
found the application procedures more efficient than the previous evaluation period (mid-
term evaluation of 2018), as applicants needed less time to prepare their applications177. 
However, the 2021 final evaluation recommended providing additional and more refined 
guidance  to  applicants  on  how  to  complete  the  application  form,  as  applicants  had 
reported incurring human resources costs. 

Although not sufficiently severe as to deter applicants from applying to the programme, 
the  2021  evaluation178  nevertheless  recommended  providing  more  information  to 
applicants  (Recommendation  9.1),  such  as  via  best  practice  and  example  boxes.  It  also 

176 Interviews and survey of applicants and beneficiaries. 
177 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582 

178 European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582 

142 

 
 
recommended  setting  up  a  platform  or  contact  person 
to  answer  questions 
(Recommendation  9.2)  and  an  annual  workshop  or  seminar  on  the  application  process 
(Recommendation  9.3).  Finally,  it  recommended  that  the  application  procedure  should 
avoid ambiguous questions (Recommendation 9.4). 

All  these  four  recommendations  have  been  implemented  in  the  current  UAFP.  Most  of 
the applicants179 judged the guidance and instructions on preparing the application clear 
and readily available180, an important improvement on the previous evaluation. The call 
documents181 published under each annual work programme provide a clear overview of 
the  projects  eligible  for  funding  and  eligibility  criteria.  The  call  is  accompanied  by  an 
online  manual  for  proposal  preparation  and  submission,  which  is  intuitive  and  easy  to 
navigate182.  

Applicants  can  also  receive  support  in  case  of  technical  difficulties  with  the  portal 
submission system,  as well as with  non-IT related questions,  for which two  separate  e-
mail  addresses  (for  the  technical  assistance  call  and  for  the  training  call)  are  made 
available183. Only a minority of stakeholders would like to see more guidance, notably 
researchers, who reporting inadequate support from their own institutions when preparing 
the application184. 

The  application  procedure  avoids  needless  repetitions  of  the  same  information 
throughout  the  application  process:  most  survey  respondents  stated  that  they  were  not 
asked to input the same information several times, which would have added unnecessary 
administrative and time-consuming steps185.  

A  minority  of  stakeholders  indicated  that  there  were  some  redundancies  in  the 
application  was  not  corroborated  by  the  textual  analysis  of  the  application  form.  In 
addition, the stakeholders surveyed perceived the information requested as relevant to the 

179 Survey of applicants and beneficiaries, Q9: The vast majority of successful applicants and applicants 

waiting to know if their application was successful were very satisfied or satisfied with the availability 
and clarity of instructions and guidance for preparing the application: 26 out of 29 respondents were 
very satisfied or satisfied with the availability and clarity of instructions and guidance to help them 
prepare the application form.  

180 Survey of applicants and beneficiaries, Q9.  
181 OLAF, Union Anti-Fraud Programme (UAFP) Call for proposals Technical Assistance (EUAF-2023-

TA) Training, Conferences, Staff Exchanges, and Studies (EUAF-2023-TRAI), 2023, 
https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/euaf/wp-call/2023/call-
fiche_euaf-2023-ta_euaf-2023-trai_en.pdf. 

182  European Commission, Funding & tender opportunities portal, https://ec.europa.eu/info/funding-
tenders/opportunities/portal/screen/opportunities/topic-search?programmePeriod=2021%20-
%202027&frameworkProgramme=43251842   

183  OLAF-FMB-HERCULE-TA@ec.europa.eu for the technical assistance call; OLAF-ANTI-FRAUD-

TRAINING@ec.europa.eu for the training activities call. 

184  Interviews with beneficiaries. 
185  Survey of applicants and beneficiaries, Q9: 17 of 28 survey respondents were very satisfied or satisfied 
with this aspect of the application process. This result is corroborated by the analysis of the available 
documentation. Only a minority of stakeholders found some redundancies in the information asked. 

143 

 
 
application  process.  The  fact  that  the  application  form  and  process  require  information 
relevant  to  the  objective  of  evaluating  the  project,  thereby  avoiding  unnecessary  and 
resource-consuming  steps,  documents,  or  additional  administrative  steps,  confirms  the 
high  efficiency  of  the  application186.  The  administrative  and  financial  requirements  are 
thus proportional and reasonable overall187.  

Finally,  the  possibility  to  complete  and  submit  the  application  online  makes  the 
application  process  more  time-efficient,  according  to  the  (appreciative)  majority  of 
applicants188.  Applicants  can  submit  their  applications  via  an  online  participant  portal, 
which shows the status of the application and the deadline, and allows the application to 
be saved for later completion.  

The  stakeholder  interviews  revealed  some  areas  for  improvement  in  the  application 
process.  Firstly,  in  its  accessibility  and  inclusion.  Not  all  applicants  with  visual 
impairments,  for  example,  are  able  to  access  the  application  platform,  as  Oracle 
platforms do not support all reading software for blind people. This is a technical feature 
that  does  not  fall  under  OLAF’s  remit189.  Secondly,  several  stakeholders  indicated  that 
the application process should be adapted based on how large and complex the project is, 
with a simpler procedure for smaller projects190. 

The proportion of successful applicants increased between 2021 and 2022, implying that 
less  time  is  lost  by  applicants  on  unsuccessful  applications191.  This  improvement  in 
efficiency  may  have  been  driven  by  the  procedural  changes  stemming  from  the  2021 
evaluation and recommendations.  

3.2.3.3 Project implementation 

Half  of  the  surveyed  beneficiaries  of  technical  assistance  under  the  UAFP  Hercule 
component  reported  that  UAFP  funding  has  contributed  towards  their  project’s 
achievements  and  outcomes192.  This  finding  needs  future  validation,  which  should  be 
provided by evidence from any available data reporting on the results of the projects and 
the costs of implementation.  

The  financial  support  provided  via  the  technical  assistance  component  has  led  to  very 
significant or significant cost savings in one-third of cases, and to some cost savings in 

186  Survey of applicants and beneficiaries, Q9: 26 of 29 respondents were very satisfied or satisfied with 

the relevance and proportionality of the information required. This result is corroborated by the analysis 
of the available documentation. 

187  Survey of applicants and beneficiaries, Q9. 
188  Survey of applicants and beneficiaries, Q9: 26 of 28 survey welcomed the possibility to complete and 

submit the application fully online. 

189  Interview with beneficiary, and case study on digitalisation and AI. 
190  Interviews with beneficiaries. 
191  PIF Report 2022.  
192  Survey of applicants and beneficiaries, Q 10(2): 50% of respondents claimed that the amount of 

available funds and resources supported their intervention and contributed to the achievements of the 
project. 

144 

 
 
almost  half of cases193. In  a  minority of cases, the funds and resources made available 
were  not  adequate  to  support  implementation194.  This  may  have  been  due  to  budgetary 
planning or other factors that were not been possible to identify from the data. 

The  grants  received  have  increased  operational  and  investigative  efficiency.  The 
purchase of equipment, for example, allows beneficiaries to save time in extracting and 
analysing  data  for  criminal  proceedings195.  They  noted  that  the  improved  capacity  and 
capabilities  will  allow  them  to  be  more  efficient  in  carrying  out  operations  in  their 
countries  and  also  better  equip  them  to  respond  to  requests  for  mutual  assistance  and 
joint investigations with EU partner agencies196.  

In one-third of cases, the implementation of funded actions did not yield any cost savings 
at  all.  Figure  15  presents  the  share  of  successful  beneficiaries  believing  that  the  funds 
received led to significant, large, some, or no cost savings. 

3.2.4 To what extent has your UAFP intervention led to any cost savings in your 
work related to the prevention, detection, and investigation of fraud and other 
illegal activities detrimental to the EU’s financial interests? 

Figure 8 - The share of successful beneficiaries believing that the funds received led 
to significant, large, some, or no cost savings 

Source: OLAF survey of applicants/beneficiaries (N=15). 

Evidence  on  whether  the  implementation  of  the  UAFP  in  2021-2023  simplified  the 
management of financial resources was scarce and contradictory.  

A minority197 of surveyed delegates of the Council Working Group on Combating Fraud 
(GAF)  reported  that  the  UAFP  may  not  have  simplified  the  management  of  financial 

193  Survey of applicants and beneficiaries, Q 15(4): 7.7% of beneficiaries rated the cost savings as very 
significant, 23.1% as significant and 46.2% as somewhat significant. According to 23.1%, the cost 
savings were not significant at all. 

194  Survey of applicants and beneficiaries, Q 11(2): 21.4% of respondents claimed that the amount of 

available funds and resources supported their intervention and contributed to the achievements of the 
project. 

195  Interview with beneficiaries and case study on investigative capacity. 
196  Case study on investigative capacity. 
197  Survey with the Delegates of the Council working party on fraud (GAF): 1 of 3 disagreed that the 
programme has simplified the management of financial resources. 2 of 3 did not know whether the 

145 

 
 
 
 
resources, and that the degree to which simplification has occurred needs to be carefully 
evaluated. However, given that the GAF survey received only three responses, there was 
insufficient evidence to assess whether and how the UAFP could have better simplified 
the management of financial resources198. There was also insufficient evidence to assess 
whether  the  current  UAFP  has  involved  better  management  of  financial  resources  than 
Hercule III199.  

3.2.5 Budgetary flexibility 

The grant agreement allows beneficiaries a good degree of budgetary flexibility200. After 
receiving the grant, applicants can request to make changes to the budget breakdown by 
transferring budgetary resources between participants and between budget categories (as 
long  as  this  does  not  imply  any  substantive  change  to  the  description  of  the  action)201. 
Interviewees who have made use of this budgetary flexibility were satisfied, as it allowed 
them  to  change  some  aspects  of  the  project  through  e-mail  correspondence,  without 
completing  a  formal  project  amendment202.  That  budgetary  flexibility  added  to  the 
project  efficiency  by  minimising  the  administrative  burden  for  beneficiaries.  On  the 
Commission  side,  the  programme  managers  and  financial  officers  do  note  an  increase 
however in workload and administrative tasks given the increasing number of requests. 

3.3 Coherence 

This section presents the analysis of coherence of the UAFP. The coherence assessment 
focuses  on  two  aspects:  the  internal  and  external  coherence  of  the  UAFP  and  its 
interventions. 

The internal coherence assessment examines the extent to which the three components 
(Hercule component, AFIS  component, and  IMS component) and the different  types of 
actions  of  the  UAFP  are  sufficiently  clear  and  coherent  with  one  another,  and  support 
rather than contradict each other’s implementation through the development of synergies.  

The external coherence assessment explores the extent to which the interventions of the 
UAFP  are  in  line  with  selected  relevant  (legislative  and  policy)  instruments  and 
interventions at EU level. 

programme has simplified the management of financial resources because their authorities never 
applied for UAFP support or implemented actions.  

198  Survey with GAF: 1 of 3 neither agreed nor disagreed that the programme could have simplified the 

management of financial resources and 2 did not know. 

199  Survey with GAF: 1 of 3 answered that it does not, while the qualitative comment said the opposite. 2 

of 3 did not know. 

200  Section 5.4 of the Grant Agreement form. 
201  Internal overview of grant agreements. 
202  Interviews with applicants. 

146 

 
 
The coherence assessment is based on the results of desk research, including the analysis 
of the UAFP Regulation and other  relevant  programmes with  similar objectives, and is 
informed by analysis of the stakeholder consultation (interviews and surveys). 

Interviews  were  carried  out  with  beneficiaries  and  with  a  number  of  relevant  DGs  to 
gather inputs on internal coherence and the external coherence of the UAFP with other 
EU  programmes,  focusing  on  potential  duplication  (financial  overlap/double  funding) 
and synergies (complementarity). 

Applicants’ survey responses on coherence were triangulated for this assessment. 

The  research  also  looked  at  the  calls  for  proposal  and  the  projects  funded  under  the 
UAFP and other  EU initiatives. However, their broad description does not  allow major 
duplications to be highlighted.   

Based  on  the  analysis  of  the  relevant  programmes  and  the  results  of  the  stakeholder 
consultation,  the  UAFP  is  considered  coherent  overall,  both  internally  and  externally. 
Nevertheless, some overlaps and/or areas of improvements are identified and discussed. 

3.3.1 Main conclusions: coherence of the UAFP 

 

Internal  coherence:  The  research  found  that  the  three-component  structure  of  the  UAFP 
reduced  the  administrative  burden  and  simplified  the  management  of  funding,  budget 
flexibility  and  redistribution  of funds  across the  three  components,  compared  to  previous 
programmes203. Additional efforts are encouraged, particularly in preparation of the annual 
working programmes, as part of the annual financing decision, to ensure better synergies 
among the three components, and in terms of resource allocation204   

  External  coherence:  The  research  focused  on  a  number  of  key  EU  programmes.  The 
highest risk of duplication was identified between the UAFP and the CCEI, and, to a much 
lesser extent, with two other funding programmes by DG TAXUD (Customs programme; 
Fiscalis  programme).  The  CCEI  specifically  provides  financial  support  to  the  customs 
authorities,  whereas  OLAF’s  UAFP  is  more  focused  on  LEAs,  for  which  the  CCEI  does 
not  provide  funding205.  Rather,  the  CCEI  focuses  on  customs’  activities,  in  particular 
developing  the  capacity  of  customs  at  border-crossing  points  and  customs  laboratories, 
while the  UAFP  focuses  on  preventing  (financial)  irregularities  and  fraudulent behaviour 
considered harmful to EU financial interests206 

  The consultation did not point to major duplications between the funding provided by DG 
TAXUD  to  national  customs  authorities  and  the  interventions  funded  under  the  UAFP. 
This is mainly due to the differences in the scope of these programmes and the fact that the 
competent DGs work closely at different levels and stages to ensure coordination between 
funds  and  to  provide  clarity  to  the  applicants  and  beneficiaries  on  the  functioning  of  the 
programmes  and  eligible  activities207.  Based  on  the  research,  the  UAFP  continues  to  be 

203 Interviews with the European Commission. 
204 Interviews with the European Commission. 
205 Interviews with the European Commission. 
206 Interviews with the European Commission. 
207 Interviews with the European Commission. 

147 

 
 
coherent with other relevant funding programmes, in line with the previous programming 
period 

  Coordination and synergies between the UAFP and the other relevant programmes208: Two 
interviewees  from  the  European  Commission  noted  that  the  DGs  could  benefit  from  an 
overarching mechanism of coordination that would allow the Commission an overview of 
the implementation of the relevant programmes, their links and overall coherence status209.  
This  point  was  challenged  by  several  Commission  participants,  who  argued  that  such  a 
mechanism would be practically difficult, given the differences between the programmes in 
relation to their budgets, targets, objectives, implementation process, and reporting.   

Source: ICF analysis. 

3.3.2 To what extent are the three components and the different types of actions of 
the programme coherent among each other? 

The analysis focuses on the internal coherence between the three components (Hercule 
component, AFIS component, IMS component) set out by the UAFP Regulation, and the 
initiatives they funded. It analyses the extent to which the three components and funded 
initiatives  do  not  contradict  one  another,  overlaps  and  duplications  are  avoided,  and 
synergies  are  ensured.  Research  and  analysis  shows  that,  overall,  there  is  internal 
coherence among the three components.  

The  three  components  are  aligned  with  the  specific  objectives  of  the  UAFP.  The  first 
specific  objective  is  to  prevent  and  combat  fraud,  corruption  and  any  other  illegal 
activities  affecting  the  EU’s  financial  interests.  The  second  specific  objective  is  to 
provide tools for information exchange and support for operational activities in the field 
of  mutual  administrative  assistance  in  customs  and  agricultural  matters.  The  third 
specific objective is to support the reporting of irregularities, including fraud, found with 
the shared management funds and pre-accession assistance funds of the Union budget, as 
well as with the RRF210.   

The  UAFP  was  set  up  to  increase  synergies  and  budgetary  flexibility  and  to  simplify 
management of the support provided by the EU to beneficiaries211. Combining the three 
components was intended to continue providing existing specialised services, as well as 
to  increase  synergies,  alleviate  administrative  burden  and  simplify  the  management  of 
funding212.  Budgetary  flexibility  within  the  programme  enables  the  reallocation  of 

208  Interviews with the European Commission. 
209  Interviews with the European Commission. 
210  Protecting the EU’s financial interests from fraud and corruption, summary of Regulation (EU) 

2021/785 establishing the Union anti-fraud programme: https://eur-lex.europa.eu/legal-
content/EN/LSU/?uri=uriserv:OJ.L_.2021.172.01.0110.01.ENG. 

211  Recital 8 of the UAFP Regulation. 
212  European Commission, Ex-ante evaluation accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 

148 

 
 
 
funding  within  the  three  strands  of  the  programme  to  one  or  another  activity  part213.  
Accordingly, the UAFP  brought  together three previously  separate strands, i.e. Hercule 
III, AFIS and IMS, and streamlined them under a single programme.  

According to the Commission’s 2018 proposal, this integration of the three components 
into a single programme aimed to guarantee the continuity of funding for administrative 
assistance  and  increase  the  exchange  of  information  between  national  authorities,  and 
between the Commission and national authorities. 

The final evaluation of Hercule III noted its complementarity with AFIS214. As a system 
allowing  the  safe  and  efficient  exchange  of  mutual  assistance  information,  AFIS  was 
encouraged by the Hercule (III) Regulation.  

At  that  time,  stakeholders  highlighted  the  complementarity  between  Hercule  III  and 
AFIS, noting that AFIS was a useful system to implement technical assistance activities 
funded by Hercule III. AFIS includes several tools that are relevant for Hercule-funded 
activities, such as ATIS and the Tobacco Seizures Management Application (ToSMA).  

According  to  the  Commission’s  2018  ex-ante  evaluation,  operational  synergies  were  in 
place between the IMS and the other two components. The IMS is an operational activity 
delivered  through  the  AFIS  IT  platform,  while  Hercule  III  funded  training  for  national 
authorities on the irregularity reporting linked to IMS215. 

Interviewees  from  the  European  Commission  reported  that,  compared  to  the  previous 
programme, the three-component structure introduced by the UAFP Regulation reduced 
the  administrative  burden  and  simplified  the  management  of  funding  within  the 
Commission (OLAF). 

The development and implementation of annual work programmes improved coherence 
among the three components216. One interviewee also stressed that the UAFP allows for 
better budget flexibility and redistribution of funds across the three components. Another, 
however, believed that overall internal coherence remains underdeveloped. 

The consultation revealed that it might be advisable to increase the regular meetings on 
planning and reporting between the managers of the three components. Additional efforts 
could  be  made  to  enhance  cooperation  within  OLAF  in  determining  funding  amounts, 

213  PIF Report 2021. 
214  European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582. 

215  European Commission, Ex-ante evaluation accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 

216  Interviews with the European Commission. 

149 

 
 
content  preparation  (particularly  regarding  the  annual  work  programmes),  and  resource 
allocation to the relevant IT tools217.  

Interviews  with  UAFP  beneficiaries  did  not  provide  much  information  on  internal 
coherence,  as  many  applied  for  funding  to  one  component  only.  Two  beneficiaries 
indicated  that  the  activities  under  the  three  components  are  complementary,  while  two 
others  noted  the  potential  for  more  synergies,  coordination  and  knowledge  sharing 
among the different components. 

The survey of applicants for funding, including beneficiaries, gathered information on the 
Hercule  component.  The  results  of  the  survey  clearly  indicated  a  significant  level  of 
coherence  among  the  eligible  activities  under  the  call  for  proposals,  and  coherence 
between  the  calls  for  technical  assistance  and  the  calls  for  training,  conferences,  staff 
exchanges and studies. 

3.3.3 To what extent are the interventions of the programme coherent with other 
measures or actions taken at EU level by the Commission or institutions, bodies, 
agencies, which also may have contributed to the protection of the Union’s financial 
interests?  

The  external  coherence  assessment  focuses  on  the  extent  to  which  the  UAFP  and  its 
associated  interventions  are  coherent  with  other  instruments  and  interventions  with 
similar objectives. It also examines coherence with EU horizontal policies. 

3.3.4 Coherence with EU horizontal policies  

As indicated in the UAFP’s annual work programmes, its implementation is intended to 
be in line with the Union’s political priorities218 and connected policy initiatives. 

Accordingly, the UAFP reflects the EU’s commitments219 to tackle climate change in line 
with the Paris Agreement adopted under the United Nations Framework Convention on 
Climate  Change  (UNFCCC)220.  The  programme  aims  to  contribute,  where  possible,  to 
mainstreaming climate actions and achieving an overall target of 30% of the EU’s budget 
supporting climate objectives221.  

217  Interviews with the European Commission. 

218 European Commission, Political Guidelines for the European Commission 2019-2024, 2019, 

https://commission.europa.eu/document/download/063d44e9-04ed-4033-acf9-
639ecb187e87_en?filename=political-guidelines-next-commission_en.pdf. 

219 European Commission (2019). Communication from the Commission to the European Parliament, the 
European Council, the Council, the European Economic and Social Committee and the Committee of 
the Regions, The European Green Deal, COM/2019/640 final. Available at: https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019DC0640. 

220  United Nations, Paris Agreement to the United Nations Framework Convention on Climate Change, 

2015, https://unfccc.int/documents/184656. 

221  European Commission, Anti-Fraud Programme Performance Statements (PPS, 2023) 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-

150 

 
 
 
The consultation revealed that applicants are encouraged to highlight proposed activities 
that take into consideration the climate objectives  of the EU. Funding  under the UAFP 
was  provided  to  beneficiaries  to  purchase  energy-efficient  equipment,  such  as  electric 
specialised vehicles222.  

The  UAFP  might  be  used  to  better  equip  Member  States  to  prevent  the  importation  of 
certain  illicit  products  that  do  not  comply  with  the  EU  environmental  and  climate 
framework223.    Despite  these  efforts,  some  stakeholders  stressed  that  the  size  of  the 
UAFP  is  limited  and  cannot  significantly  contribute  to  addressing  climate  change 
concerns224.  

They highlighted that while UAFP funding is assigned to projects proposed to be in line 
with energy efficient standards, the actual implementation of the projects might not be in 
line  with  such  standards,  as  public  procurement  processes  of  national  administrations 
often favour the lowest cost bidder over other considerations. 

The digital transition is another key priority of the EU and part of its’ digital strategy225. 
The UAFP supports the Member States’ digital transition through all three components. 
For  instance,  this  might  be  achieved  through  the  UAFP  funding  the  acquisition  of  IT 
tools  supporting  data  analysis  to  detect  fraud  affecting  revenue  or  expenditure,  and  by 
building expertise in digital forensics226.  

Interviews with  European Commission  officials  confirmed the potential  contribution  of 
the  UAFP  to  supporting  the  digitalisation  of  national  administrations,  with  funding 
assigned to purchase new digital tools. They also confirmed the potential future impact of 
AFIS and IMS on better digitalisation of such administration. However, given the limited 
size  of  the  UAFP  budget,  this  contribution  would  not  be  significant  in  facilitating  or 
achieving the (full) objective of digital transition227.  

3.3.5 Coherence with other instruments and interventions 

In  the  mid-term  evaluation  of  Hercule  III,  most  of  the  stakeholders  reported  more 
synergies  than  overlaps  with  other  EU  funded  programmes.  However,  increased 

performance-statements/anti-fraud-
performance_en#:~:text=In%202023%2C%20the%20programme%20committed,of%20the%20COVID
%2D19%20period 

222  Interviews with the European Commission. 
223  Annex to the Commission Implementing Decision on the financing of the Union Anti-Fraud 

Programme and the adoption of the work programme for 2023, C (2023) 813 final, https://anti-
fraud.ec.europa.eu/system/files/2023-02/uafp_work_programme_2023_annex_en.PDF. 

224  Interviews with the European Commission. 
225  European Commission, Shaping Europe’s Digital Future, 2020, https://commission.europa.eu/strategy-

and-policy/priorities-2019-2024/europe-fit-digital-age/shaping-europes-digital-future_en. 
226  Annex to the Commission Implementing Decision on the financing of the Union Anti-Fraud 

Programme and the adoption of the work programme for 2021, C (2021) 5338 final, https://anti-
fraud.ec.europa.eu/system/files/2021-10/uafp_work_programme_2021_en.pdf. 

227  Interviews with the European Commission. 

151 

 
 
 
synergies  were  indicated  with  other  programmes  managed  by  DG  TAXUD  and  DG 
HOME on fighting corruption and VAT fraud228. 

Consultations  with  the  European  Commission  revealed  that  OLAF  is  exploring  the 
possibility  of  expanding  the  scope  of  its  investigative  work  activities  into  new  areas, 
including  food  fraud,  chemical  waste,  waste  shipment  and  other  environmental  issues. 
The potential coherence of OLAF's expanded scope with financing programmes provided 
by other DGs could be explored in future studies.  

Several key EU programmes were selected for the external coherence analysis. Overall, 
coherence with other EU programmes was confirmed by the results of the desk research 
and  most  stakeholders  interviewed.  Notably,  one  beneficiary  stressed  the  unique 
characteristics  of  the  UAFP,  which  is  recognised  as  filling  a  critical  gap  by  funding 
projects that would not otherwise be covered by EU-level funds229. 

Key instruments and interventions for external coherence analysis 

Key instruments and interventions for external coherence analysis: 

•  Regulation (EU) 2021/1077 establishing, as part of the Integrated Border Management Fund, 

the instrument for financial support for customs control equipment (CCEI)  

•  Regulation (EU) 2021/240 establishing a Technical Support Instrument (TSI Regulation) 
•  Regulation (EU) 2021/444  (Customs programme regulation) 
•  Regulation (EU) 2021/693 (Justice programme regulation) 
•  Regulation (EU) 2021/695 (Horizon Europe Cluster 3 Civil Security for Society) 
•  Regulation (EU) 2021/840 establishing a programme to protect the euro against counterfeiting for 

the 2021–2027 period (Pericles IV programme regulation) 
•  Regulation (EU) 2021/847 (Fiscalis programme regulation) 

The  UAFP  is  increasingly  aligned  with  the  Commission’s  2019  anti-fraud  strategy, 
which places increased focus on the collection and use of data for anti-fraud purposes230. 
Interventions  financed  under  the  UAFP  aim  to  emphasise  cross-border  cooperation  on 
anti-fraud and complementarity and interoperability with equipment and tools purchased 
under other EU-funded programmes231. 

Data  from  the  survey  with  applicants  for  funding  under  the  UAFP  point  to  coherence 
(strongly  agree  around  35%;  and  agree  around  57%)  between  the  calls  for  proposals 
(launched under the UAFP) and other EU anti-fraud instruments.  

Figure 9 - Coherence between UAFP and other relevant instruments 

228  European Commission, Mid-term evaluation of the Hercule III programme, CEPS, Economisti 

Associati, CASE, wedoIT, 2017, https://op.europa.eu/en/publication-detail/-/publication/472e59a1-
07cd-11e8-b8f5-01aa75ed71a1/language-en/format-PDF/source-68460881. 

229  Interview with beneficiary. 
230  Communication from the Commission to the European Parliament, the Council, the European 
Economic and Social Committee, the Committee of the Regions, and the Court of Auditors. 
Commission Anti-Fraud Strategy: enhanced action to protect the EU budget, COM(2019) 196 final, 
https://anti-fraud.ec.europa.eu/system/files/2021-09/2019_commission_anti_fraud_strategy_en.pdf. 

231  PIF Report 2021. 

152 

 
 
Source: OLAF survey of applicants/beneficiaries (N=15). 

The following  sections  provide a comparative  analysis of the UAFP and  other selected 
EU programmes. 

Annex 2 of the study report provides an overview of key elements of the UAFP and the 
other  programmes  analysed  for  external  coherence.  It  describes  the  scope,  objectives, 
eligible  action  and  beneficiaries  of  the  UAFP  and  the  programmes  analysed,  and 
indicates their common elements. 

5.2.1.1  Regulation (EU) 2021/1077 establishing, as part of the Integrated Border 

Management Fund, the instrument for financial support for customs 
control equipment (CCEI) 

The CCEI is one component of the EU’s BMF and is dedicated to checking goods. For 
the period 2021-2027, it aims to contribute to adequate and equivalent customs controls 
by supporting Member States to purchase, maintain, and upgrade state-of-the-art customs 
control equipment.  

European  Commission  officials  interviewed  identified  the  highest  risk  of  duplication 
between the UAFP and CCEI. In fact, the two programmes present several similarities. 
The  UAFP’s  scope  covers  the  protection  of  the  financial  interests  of  the  EU,  which  is 
also  one of the areas covered by the CCEI, albeit not  its  main priority. In addition,  the 
UAFP  comprises  activities  related  to  customs,  which  is  the  sole  area  covered  by  the 
CCEI.  The  UAFP  includes  customs  authorities  among  its  beneficiaries,  which  are  the 
sole and specific beneficiaries of the CCEI.  

Although the CCEI has a much larger budget than the UAFP, its scope is more limited, 
as it focuses on customs equipment specifically. The complementarity between the two 
programmes  was  identified  at  the  proposal  stage  of  the  UAFP  Regulation;  however,  it 
was  noted  that  each  focuses  on  different  types  of  support  to  national  and/or  customs 
authorities232.  

232 European Commission, Ex-ante evaluation accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 

153 

 
 
 
On  technical  assistance,  the  adoption  of  the  CCEI  allowed  the  UAFP  to  focus  on 
advanced  tools  and  technologies,  including  data  analysis.  This  generated  valuable 
synergies and complementarity across the two programmes, while avoiding overlaps233. 

To  limit  and  avoid  such  duplication,  OLAF  and  DG  TAXUD  provided  guidance  to 
applicants and beneficiaries to distinguish between the UAFP and CCEI. Regular efforts 
were  made  to  ensure  closer  and  more  effective  cooperation  between  OLAF  and  DG 
TAXUD,  via  formal  (e.g.  Inter-Service  Steering  Group  meetings;  joint  meetings  at 
various levels) and informal (e.g. regular and ad hoc exchanges between officers) means 
to avoid duplication and increase synergies.  

Cooperation  took  place  at  different  stages,  in  particular  when  setting  up  the  relevant 
Regulations  (e.g.  DG  TAXUD  and  other  Commission’s  services  providing  input  to  the 
impact assessment for the UAFP), developing the annual work programmes for the two 
instruments,  launching  the  calls  for  applications,  evaluating  the  applications  received 
(e.g. to avoid double-financing), and evaluating effectiveness. 

5.2.1.2  Regulation (EU) 2021/444 establishing the Customs programme for 

cooperation in the field of customs (Customs programme Regulation)234 

Regulation (EU) 2021/444 establishes the Customs programme to further modernise the 
Customs  Union,  supporting  the  development  and  uniform  implementation  of  customs 
legislation  and  policy  and  facilitating  cooperation  on  customs  for  the  financial  period 
2021-2027.  It  includes  funding  for  collaborative  activities,  administrative  and  IT 
capacity-building,  including  human  skills  and  training,  and  the  development  and 
operation of EU electronic systems and innovation in customs policy. 

The  Customs  programme  Regulation  indicates  that  the  programme  should  exploit 
possible synergies with other Union measures in related fields, such as the UAFP235, with 
a view to ensuring cost-effectiveness. 

Table 27 in Annex 2 of the ICF study report indicates the common elements between the 
UAFP and the Customs programme. These common aspects raised questions about their 
differences and the avoidance of duplication of efforts236. 

233 European Commission, Anti-Fraud – Performance, Union Anti-Fraud Programme: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en.  

234 Regulation (EU) 2021/1077 of the European Parliament and of the Council of 24 June 2021 

establishing, as part of the Integrated Border Management Fund, the instrument for financial support for 
customs control equipment, PE/43/2021/INIT, OJ L 234, 2.7.2021, pp. 1-17. 

235 Preamble, Paragraph (5) of the Customs programme regulation, Regulation (EU) 2021/444 of the 

European Parliament and of the Council of 11 March 2021 establishing the Customs programme for 
cooperation in the field of customs and repealing Regulation (EU) No 1294/2013, (OJ L 87, 15.3.2021, 
p. 1). 

236  Interview with the European Commission. 

154 

 
 
One  the  most  significant  common  aspects  is  the  fact  that  both  programmes  aim  to 
contribute  to  the  protection  of  EU  financial  and  economic  interests  and  may  therefore 
address  the  same  customs  and  trade  policy  topics  (as  part  of  their  general  and  specific 
objectives). While this is common ground, the nature and scope of the two programmes 
is  clearly  distinguishable:  the  Customs  programme  focuses  solely  on  customs 
cooperation and aspects  of the customs union,  while the UAFP provides  support to  the 
fight against fraud, which is outside the scope of the Customs programme. The UAFP is 
non-specific  in  its  law  enforcement  aspects  and,  as  such,  goes  beyond  the  customs 
domain. The scope of the two programmes thus does not overlap fully.   

Despite the fact  that both programmes may  finance  electronic/IT systems and both  can 
support specialised training, risk analysis workshops, conferences and studies to improve 
cooperation  and  coordination,  the  Customs  programme  cannot  do  so  if  the  objective 
reaches beyond its legal scope237. 

Through its provision on technical assistance, the UAFP is used to fund the acquisition of 
highly specialised technical equipment that can be used beyond customs activities, with 
OLAF  increasingly  focused  on  the  expenditure  side.  The  purchase  of  any  similar 
technical equipment is excluded under the Customs programme.  

To  avoid  overlaps,  DG  TAXUD  and  OLAF  work  together  very  closely  (formally  and 
informally) to coordinate and build complementarities. The competent DGs have reached 
a clear understanding of the differences between the two programmes238. They have also 
engaged  actively  with  applicants  and  beneficiaries  to  provide  guidance  on  the  specific 
objectives  and  functioning  of  the  programmes.  The  similarities  were  already  evident  at 
the  time  of  Hercule  III,  but  similar  policy  aspects  were  addressed  through  cooperation 
(confirmed by stakeholders during the final evaluation of Hercule III)239.  

5.2.1.3  Regulation (EU) 2021/847 establishing the ‘Fiscalis’ programme for 

cooperation in the field of taxation (Fiscalis programme regulation)240 

Regulation  2021/847  establishes  the  Fiscalis  programme  (2021-2027),  which  supports 
cooperation on taxation,  particularly to protect EU and national financial and economic 
interests, including against tax fraud, evasion, and avoidance. 

The  Fiscalis  programme  has  the  specific  objective  to  support  tax  policy  and  the 
implementation of EU law relating to taxation, foster cooperation between tax authorities 
(including  the  exchange  of  tax  information)  and  provide  administrative  capacity-

237  Legal basis of the Customs programme does not include Article 87 or Article 325 of the TFEU. 
238  Interview with the European Commission. 
239  European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582. 

240  Regulation (EU) 2021/847 of the European Parliament and of the Council of 20 May 2021 establishing 
the ‘Fiscalis’ programme for cooperation in the field of taxation and repealing Regulation (EU) No 
1286/2013, PE/35/2021/INIT, OJ L 188, 28.5.2021, pp. 1-17. 

155 

 
 
building.  Both  the  Fiscalis  programme  and  the  UAFP  relate  to  protecting  the  financial 
interests of the Union.  

To combat fraud and tax evasion, the Fiscalis programme presents indirect links with the 
UAFP and OLAF’s activities. Among the activities eligible for funding under the Fiscalis 
programme  are  training  activities,  human  competency-building,  and  other  capacity-
building actions. 

Several  of  the  actions  eligible  for  funding  under  the  Fiscalis  programme  are  similar  to 
those  eligible  under  the  UAFP,  as  training  activities,  administrative  cooperation  and 
capacity development can be funded under both programmes. Cooperation, both formal 
(e.g.  evaluations  of  applications)  and  informal  (exchanges  between  officers)  between 
OLAF and DG TAXUD is essential to ensure that the funding under the two programmes 
cover different aspects of the mission to protect EU financial interests241. 

5.2.1.4  Regulation (EU) 2021/240 establishing a Technical Support Instrument 

(TSI Regulation)242 

the structural  reform  support  programme 
The  TSI  (DG  REFORM)  builds  on 
(SRSP) established  by  Regulation  (EU) 2017/825243.  It  ensures  that  the  European 
Commission  provides  support  to  Member  States  to  improve  their  institutional  and 
administrative capacity to develop and implement reforms. 

The  scope  of  the  TSI  is  broader  than  the  UAFP.  The  objectives  of  the  TSI  Regulation 
refer  to  several  policy  areas,  including  institutional  reform,  simplification  of  rules  and 
procedures,  reform  of  justice  systems,  strengthening  financial  supervision,  and 
reinforcement  of  the  fight  against  fraud,  corruption,  and  money  laundering.  Within  the 
TSI, support is also provided for the design and implementation of anti-fraud strategies 
and customs reforms. 

The  research  did  not  identify  overlaps  between  the  two  programmes,  each  of  which  is 
intended to reinforce the fight against fraud and facilitate the digital transition.  

5.2.1.5  Regulation (EU) 2021/693 establishing the Justice programme (Justice 

programme regulation)244 

The Justice programme is designed to further develop a European area of justice based 
on  the  rule  of  law,  mutual  recognition  and  mutual  trust,  and  judicial  cooperation.  Its 

241  Interview with the European Commission. 
242  Regulation (EU) 2021/240 of the European Parliament and of the Council of 10 February 2021 

establishing a Technical Support Instrument, OJ L 57, 18.2.2021, pp. 1-16. 

243  Regulation (EU) 2017/825 of the European Parliament and of the Council of 17 May 2017 on the 

establishment of the Structural Reform Support Programme for the period 2017 to 2020 and amending 
Regulations (EU) No 1303/2013 and (EU) No 1305/2013, OJ L 129, 19.5.2017, pp. 1-16.  

244  Regulation (EU) 2021/693 of the European Parliament and of the Council of 28 April 2021 establishing 
the Justice programme and repealing Regulation (EU) No 1382/2013, PE/24/2021/INIT, OJ L 156, 
5.5.2021, pp. 21-38. 

156 

 
 
specific  objectives  include  promoting  and  supporting  judicial  cooperation  in  civil  and 
criminal matters and developing and implementing training activities for the judiciary.  

The target audience of both the Justice programme and the UAFP includes judiciaries or 
public prosecutors, implying that there might be overlaps and complementarities between 
the training activities financed under the two programmes. This was confirmed during the 
stakeholder consultation.  To avoid  duplication, the DG for Justice and Consumers (DG 
JUST)  and  OLAF  work  closely  together  through  official  coordination  meetings  and  ad 
hoc exchanges at desk officer level to provide targeted training to stakeholders, covering 
different aspects relevant to the protection of the financial interests of the Union245.  

5.2.1.6  Regulation (EU) 2021/695 establishing Horizon Europe – the framework 
programme for research and innovation, laying down its rules for 
participation and dissemination (Horizon Europe, Cluster 3 - Civil Security 
for Society)246 

Horizon  Europe  is  the  EU’s  key  funding  programme  for  research  and  innovation.  It 
facilitates  collaboration  and  strengthens  the  impact  of  research  and  innovation  in 
developing, supporting and implementing EU policies, while tackling global challenges. 
It  supports the  creation  and (better) diffusion of excellent  knowledge and technologies. 
Legal entities from the EU and associated countries can participate.  

Cluster  3  of  Pillar  2  (Global  Challenges  and  European  Industrial  Competitiveness)  is 
dedicated  to  Civil  Security  for  Society.  It responds  to  the  challenges  deriving  from 
security 
including  cybercrime,  as  well  as  natural  and  man-made 
disasters. Accordingly,  Cluster  3  funds research  and  innovation  projects  on crisis 
management,  the  fight  against  crime  and  terrorism,  external  and  border  security, 
cybersecurity, privacy, and trust.  

threats, 

Cluster 3 has a broad scope, as it seeks to support policies for internal security. Funded 
areas  include  projects  related  to  the  authentication  of  documents  and  cryptocurrency 
transactions  (for  criminal  purposes),  which  are  relevant  for  internal  security  and  to 
combat other illicit activities, such as financial fraud247.  

Under Cluster 2 (Culture, creativity and inclusive society), the funds for Democracy and 
Governance  are  directed  to  research  focused  on  strengthening  democratic  governance 
and  trust  in  institutions  and  protecting  fundamental  rights.  This  includes  funds  for 

245  Interview with the European Commission. 
246  Regulation (EU) 2021/695 of the European Parliament and of the Council of 28 April 2021 establishing 
Horizon Europe – the Framework Programme for Research and Innovation, laying down its rules for 
participation and dissemination, and repealing Regulations (EU) No 1290/2013 and (EU) No 
1291/2013, OJ L 170, 12.5.2021, pp. 1-68. 

247  Decision C (2023) 2178, Horizon Europe Work Programme 2023-2024, 6. Civil Security for Society, 

https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/horizon/wp-call/2023-2024/wp-
6-civil-security-for-society_horizon-2023-2024_en.pdf.  

157 

 
 
initiatives  covering  corruption,  although  the  scope  is  broader  than  for  anti-fraud 
initiatives under the UAFP.  

Although  the  training  section  of  UAFP  provides  funding  for  training,  conferences, 
seminars,  comparative  studies,  webinars,  and  e-learning  activities,  as  well  as  the 
publication  of  the  European  Criminal  Law  Associations’  Forum,  the  scope  of  these 
projects  is  more  limited  than  the  studies  financed  under  Horizon  Europe,  which  are 
intended for research and innovation and thus take a more forward-looking approach248.  

5.2.1.7  Regulation (EU) 2021/840 establishing a programme to protect the euro 
against counterfeiting for the 2021–2027 period (Pericles IV programme 
Regulation)249 

Regulation  2021/840  establishes  an  exchange,  assistance,  and  training  programme 
(Pericles  IV)  to  protect  the  euro  against  counterfeiting.  Its  general  objectives  are  to 
prevent  and  combat  counterfeiting  and  related  fraud  and  preserve  the  integrity  of  euro 
banknotes  and  coins.  The  Pericles  IV  programme  supports  and  supplements  national 
measures  and  helps  national  and  EU  authorities  to  develop  close  cooperation  and 
exchange best practices. 

The support can take the form  of grants  for co-financing  projects  proposed by national 
authorities.  Among  the  activities  eligible  for  funding  this  component  are:  training  and 
information  exchange;  technical,  scientific  and  operational  assistance;  and  purchase  of 
equipment  used  by  specialised  anti-counterfeiting  authorities  of  third  countries  for 
protecting the euro against counterfeiting. The Pericles IV programme provides funding 
for projects initiated by the Commission, such as transnational conferences, training and 
workshops. 

There is some complementarity between the two programmes, although the Pericles IV 
programme  has  a  more  limited  scope,  focusing  solely  on  the  protection  of  the  euro 
against counterfeiting and related fraud. By contrast, the UAFP supports action to combat 
fraud, corruption and any other illegal activities affecting the Union’s financial interests.  

5.2.1.8  Mechanisms aimed to prevent overlapping between the UAFP and other 

financial instruments  

Mechanisms and cooperation measures bring together the various stakeholders to prevent 
overlaps of financial instruments with similar objectives. 

248  Interview with the European Commission. 
249  Regulation (EU) 2021/840 of the European Parliament and of the Council of 20 May 2021 establishing 
an exchange, assistance, and training programme for the protection of the euro against counterfeiting 
for the period 2021-2027 (the ‘Pericles IV’ programme), and repealing Regulation (EU) No 331/2014, 
OJ L 186, 27.5.2021, pp. 1-11. 

158 

 
 
To allow for cooperation, formal and informal mechanisms are in place across the DGs to 
avoid  or  remedy  potential  overlaps  and  ensure  better  synergies  between  EU-funded 
programmes.  

The  formal  cooperation  takes  place  during  the  preparation  of  the  annual  work 
programmes for the different funding instruments. The programmes and their legislative 
activities  (adopting  the  financing  decisions  and  annual/multiannual  work  programmes) 
are subject to inter-service consultations, which see the legislative proposal submitted to 
all relevant Commission services for their advice and consent and to ensure coordination 
between the programmes managed by those services. 

The DGs  also  coordinate their work for the launch of the calls for applications and the 
subsequent  evaluation  of  those  applications  to  identify  those  that  may  contain  overlaps 
and to prevent over- or double financing. In practical terms, this means that officials of 
OLAF are part of the evaluation committees set up each year to assess the applications 
received  under  other  programmes,  and  that  officials  of  other  DGs  participate  in  the 
evaluation committee for the assessment of applications submitted for UAFP funding. 

In addition  to  these  formal mechanisms, there are informal  channels  of  cooperation  for 
exchanges  at  the  level  of  policy  officers  of  the  competent  units.  This  informal 
cooperation is crucial to leverage the in-house expertise on the differences in scope and 
area of competence between the UAFP and, for example, DG TAXUD’s programmes. 

Enhanced and regular coordination is ensured between DG TAXUD and OLAF, as well 
as between  DG JUST  and OLAF, to  avoid  overlaps in  providing grants  and training to 
(partly) the same target audience. 

At  a  higher  level,  cooperation  was  guaranteed  when  developing  and  adopting  the 
regulations  founding  the  instruments  (e.g.  DG  TAXUD  contributed  to  the  impact 
assessment for the UAFP Regulation), as well as when evaluating their implementation 
and results. 

3.4 Relevance 

Relevance addresses the relationship between the needs and problems at the time of the 
implementation  of  the  intervention  –  in  the  present  case,  over  the  2021-2024  period  of 
the  UAFP.  It  also  considers  the  relationship  between  current  and  future  needs  and 
problems  in  the  EU  in  the  policy  area  in  question,  according  to  the  objectives  of  the 
intervention.  

The  ex-ante  evaluation  of  the  UAFP  in  2017-2018  identified  the  needs  of  stakeholders 
working  within  the  programme  (particularly  at  Member  State  level)  in  relation  to  the 
fight  against  fraud  for  the  upcoming  period.  It  concluded  that  support  provided  by 
Hercule  III  was  crucial  to  countering  cross-border  fraud  against  EU  financial  interests 

159 

 
and  that  this  should  remain  a  priority  for  the  EU,  to  be  pursued  by  the  next  such 
iteration250.  

The main needs identified during the legislative preparatory works towards the adoption 
of the UAFP Regulation were: 

-  Lack of up-to-date technical equipment and support in the Member States; 
- 

Increase in new forms of fraud and rapid development of sophisticated technical tools 
used by criminals251;  

-  Need for cooperation between stakeholders (including the exchange of best practices 

and experiences); 

-  Need  for  access  and  exchange  of  data  and  information  between  stakeholders  and 

Member States. 

3.4.1 Main conclusions: relevance of the UAFP 

  The  relevance assessment finds  that the  objectives  and  activities  of the  UAFP  have  been 
broadly relevant over the course of the evaluation period, both to the general objectives of 
the programme and to the needs of its applicants, beneficiaries (Hercule) and users (AFIS 
and IMS)  

  Hercule and AFIS have been relevant in identifying and combating emerging trends in the 
area of fraud against the EU’s financial interests, despite some evidence to suggest that the 
Hercule component would benefit from a significant increase in financial resources to keep 
up with new trends in digitalisation (characterised by intense innovation and change) and 
the  fact  that  yearly  applications  have  increased  considerably  (2021-2023:  100%  increase 
for technical assistance and training applications) Although costly, the exploration of AI-
based options should be considered. The upcoming expansion of the programmes’ reach to 
Ukraine, and potentially to other candidate countries, further supports this suggestion  
  The  activities  (primarily  under  the  Hercule  component)  are  deemed  to  have  been  highly 

relevant, particularly in view of stakeholders’ needs  

Source: ICF analysis. 

3.4.2 To what extent have the specific objectives been relevant to the general 
objectives in the period 2021-2024?  

This section examines the relevance of each of the three UAFP specific objectives to its 
broader general objectives:  

-  To protect the Union’s financial interests;  

250   European Commission, Ex-ante evaluation accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 

251   View echoed in interviews with two beneficiaries of Hercule III funding, who both stated that a key 

emerging challenge is criminals’ proficiency with complex encryption technology and 
communications.  

160 

 
 
-  To  support  mutual  assistance  between  the  administrative  authorities  of  the  Member 
States and cooperation between the latter and the Commission to ensure that the law 
on customs and agricultural matters is correctly applied.  

Protection  of  the  EU’s  financial  interests  is  necessary  to  maintain  citizens’  trust  in  the 
sound and efficient spending of the EU budget. As key agents in the fight against fraud, 
protecting the interests of the UAFP’s key stakeholders is crucial to ensuring that the EU 
is prepared for ongoing threats. Meeting these interests is thus a direct success factor for 
the achievement of the general objectives. Assessing how the objectives of the UAFP are 
relevant  to  the  current  situation  requires  understanding  current  threats  to  EU  financial 
interests,  as  well  as  the  needs  of  stakeholders  identified  prior  to  the  start  of  the 
programme.  

The specific objectives of the UAFP are considered relevant to the programme’s general 
objectives. The relevance of the first specific objective to the general objectives has been 
carried over from the previous iteration of the programme and is  supported by positive 
evidence  from  the  survey  of  applicants/beneficiaries,  interviews  and  case  studies.  The 
Hercule  component  also  demonstrates  relevance  to  the  needs  identified  at  the  ex-ante 
stage, and responds clearly to the expressed needs of its beneficiaries.  

The second specific objective and the AFIS platform have been found to be relevant to 
the general  objectives.  The consultative process  of developing the AFIS  work plan and 
the clear feedback from the consultation show that AFIS is clearly suited to current user 
needs and to the needs identified ex ante.  

The third specific objective and the IMS reporting tool are deemed to be well grounded 
in  the  context  and  operational  needs  of  OLAF,  Member  States  and  other  beneficiary 
authorities, and is also relevant to the wider objectives of the UAFP. The IMS responds 
to the need to react to expenditure fraud (identified at the start of the programme), and, 
supported  by  the  high  2023  user  satisfaction  rate  of  91%,  its  ability  to  respond  to  user 
needs remains high.  

3.4.2.1 Specific Objective 1 (Hercule component) 

As  part  of  its  first  specific  objective,  the  UAFP  aims  to  prevent  and  combat  fraud, 
corruption and other activities that affect the Union’s financial interests. This sub-section 
explores  how  this  stated  objective  is  relevant  to  the  programme’s  general  objectives.  It 
also assesses the relevance of the Hercule component to the scope and stakeholder needs 
identified at the time of the ex-ante evaluation of the UAFP. This information is analysed 
alongside stakeholders’ views, specifically how this component responds to their needs. 
The  following  information  should  be  read  together  with  the  data  and  analysis  of 
effectiveness, as this objective is inextricably linked with the performance of the UAFP 
over the evaluation period.  

The final  evaluation  of the Hercule  III  programme found that specific  objective 1 (still 
specific objective 1: prevent and combat fraud, corruption and other activities that affect 

161 

 
the  Union’s  financial  interests)  was  already  highly  relevant  to  achieving  the  goal  of 
protecting the Union’s financial interests252.  

At the time of the previous evaluation, 83% of all respondents to the surveys stated that 
specific objective 1 was completely or highly relevant to protecting the financial interests 
of  the  EU253.  In  principle,  this  objective  has  maintained  its  relevance  to  the  general 
objectives in the current evaluation period (2021-2024), as it addresses the same issues. 

In  the  context  of  the  current  study,  surveyed  applicants  and  beneficiaries  of  Hercule 
funding  overwhelmingly  agreed  that  this  specific  objective  is  relevant  to  the  general 
objective  of  protecting  the  Union’s  financial  interests.  A  large  majority  (14  out  of  15 
beneficiaries, 93%) either agreed or strongly agreed that Specific Objective 1 (to prevent 
and  combat  fraud,  corruption  and  any  other  illegal  activities  affecting  the  EU  financial 
interests)  is  relevant  to  its  general  objective  to  protect  the  EU’s  financial  interests, 
corresponding to a 10 percentage points’ increase since the Hercule III evaluation254.  

Five  beneficiaries  of  Hercule  grants  who  participated  in  semi-structured  interviews 
confirmed that the specific objectives of the UAFP are relevant to the general objectives. 
One participant praised the broad remit of the general objectives for their ability to cater 
to the needs of users across a large number of Member States255. 

All 14 survey respondents with unknown status of applications agreed or strongly agreed 
that  this  specific  objective  is  relevant  to  the  general  objective  to  protect  the  EU’s 
financial interests256.  

The  relevance  of  the  Hercule  programme  in  relation  to  its  ability  to  comply  with  the 
stated  needs  of  its  recipients  was  also  measured  previously:  for  the  training  grants 
finalised in 2021, participants and trainees had a satisfaction rate of 91%, considering the 
activities  very  well  suited  to  their  needs257.  This  was  confirmed  by  the  results  of  the 
current consultation, with 18 beneficiaries of Hercule grants interviewed stating that the 
specific objectives of the UAFP are relevant to their operational needs as organisations. It 
also complies with one of the needs identified before the programme (the lack of up-to-
date  equipment  and  support),  in  that  the  Hercule  component  is  tasked  with  providing 
technical  assistance  and  training  support  to  its  beneficiaries.  Stakeholders  believed  that 
this need has now been covered. 

The case study on investigative capacity found that ‘beneficiaries (…) confirmed that the 
equipment and skills acquired with the financial support of the programme corresponded 
to the needs of their organisations to upgrade the available investigative resources and the 

252  European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582. 

253  76% of users of services (N=134), 83% of participants (N=71), 91% of applicants (N=127). 
254  Survey of applicants and beneficiaries, Q7: ‘Yes’ respondents. 
255  Interviews with beneficiaries. 
256  Survey of applicants and beneficiaries, Q13: ‘I don’t know’ respondents. 
257  Survey of applicants and beneficiaries, Q13: ‘I don’t know’ respondents. 

162 

 
 
needs of end users (members of investigative teams  operating surveillance systems  and 
processing surveillance data) to be trained in the newly acquired equipment and systems’. 

Figure 10 - To what extent do you agree with the following statements: The specific 
objective  of  the  UAFP  ‘tо  prevent  and  combat  fraud,  corruption  and  any  other 
illegal  activities  affecting  the  EU  financial  interests’  is  relevant  to  its  general 
objective to protect the EU financial interests? 

Beneficiaries (N=15)

46,7%

46,7%

6,7%

Applicants (N=14)

78,6%

21,4%

Strongly agree

Agree

Neither agree nor disagree

Source: OLAF survey of applicants/beneficiaries (N=15). 

The  proportion  of  Member  States  receiving  UAFP  funding  is  an  indicator  of  how  well 
the  UAFP  supports  Member  State  authorities  to  combat  fraud  and  support  mutual 
assistance  between  administrative  authorities.  By  extension,  how  well  this  specific 
objective is being achieved reflects its relevance to both overarching general objectives.  

In  2021-2023,  the  percentage  of  Member  States  benefiting  from  support  was  100%, 
surpassing the target of 81%, and also surpassing the target set for 2027 (the final year of 
the UAFP)258. 

This coverage was 89% in years where data are available for Hercule III, 2014-2016259. 
These data  reflect  the programme’s catering  (under Specific  Objective 1) for the stated 
needs  of  its  recipients  in  the  fight  to  prevent  and  combat  fraud,  corruption  and  other 
activities that affect EU financial interests.  

3.4.2.2 Specific Objective 2 and AFIS component 

Specific  Objective  2  of  the  UAFP  is  to  provide  tools  for  information  exchange  and 
support  for  operational  activities  in  the  field  of  mutual  administrative  assistance  in 
customs matters. Again, this objective is aligned with the general objective of ‘protecting 
the  Union’s  financial  interests’,  as  any  tool  that  furthers  the  cooperation  of  institutions 
involved in customs cooperation, in principle, furthers EU and Member States’ ability to 
fight fraud.  

This  objective  is  clearly  aligned  with  the  general  objective  of  ‘supporting  mutual 
assistance between the administrative authorities of the Member States and cooperation 
between the latter and the Commission to ensure that the law on customs and agricultural 

258  European Commission, Anti-Fraud – Performance, Union Anti-Fraud Programme: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en. 

259  European Commission, Mid-term evaluation of the Hercule III programme, CEPS, Economisti 

Associati, CASE, wedoIT, 2017, https://op.europa.eu/en/publication-detail/-/publication/472e59a1-
07cd-11e8-b8f5-01aa75ed71a1/language-en/format-PDF/source-68460881. 

163 

 
 
 
matters  is  correctly  applied’.  The  formulation  of  this  objective  (and  the  evidence 
described below) suggests that the key need identified at the beginning of the programme 
to ‘access and exchange data and information between stakeholders and Member States’ 
is covered by the AFIS component of the UAFP. 

The relevance of the UAFP under this objective, and the relevance of this objective to the 
overarching  general  objectives  of  the  UAFP,  was  primarily  determined  through 
information on how the AFIS component and its associated applications are designed and 
perform. Indeed, the Commission Implementing Decision on the financing of the Union 
anti-fraud  programme  and  the  adoption  of  the  annual  work  programme  for  2021 
describes  the  three  components  as  individually  linked  with  each  of  the  specific 
objectives260. This is further supported by the close alignement in the stated purposes of 
the specific and general objectives.  

To remain relevant over the lifetime of the UAFP, AFIS needs to remain in touch with 
the  needs  of  its  users.  Accordingly,  the  AFIS  work  plan  is  drafted  annually  in 
consultation  with  OLAF  business  managers,  and  following  feedback  from  users  in 
Member States and OLAF on the improvements and priority developments needed. The 
work plan and its progress is presented and validated by the AFIS Steering Committee in 
June  and  December  each  year261.  AFIS  end  users  in  OLAF  and  Member  States  are 
involved  in  developing  the  systems  from  early  on,  or  in  relevant  updated  versions  via 
dedicated  workshops  and  training  sessions.  Their  input  is  also  gathered  through  the 
Expert  Group  for  mutual  assistance  on  customs  matters  (EMAC)  and  other  relevant 
meetings with Member States. A user satisfaction survey on AFIS is conducted by OLAF 
every two years (2019, 2021 and 2023)262.  

Users’ reported experience of AFIS’s ability to suit their needs is a direct indicator 
of its relevance under both general objectives, as it is a testament to their increased 
ability to protect the Union’s financial interests, and a marker of increased mutual 
assistance between Member State authorities and the Commission in the fight against 
fraud. 

In 2019, when asked whether the AFIS applications they most frequently used responded 
to their professional needs, 57% of surveyed users agreed, while 27% slightly agreed263.  

The  results  of  the  survey  for  this  current  study  allow  a  consolidated  assessment  of  the 
AFIS  applications.  When  asked  whether  ‘The  AFIS  application(s)  I  use  the  most 
frequently respond(s) to my professional needs’, 59% of users agreed, while 23% slightly 
agreed. The level of satisfaction of AFIS users in the applications they most commonly 
use has remained consistently positive over the course of the evaluation period. 

260  Annex to the Commission Implementing Decision on the financing of the Union Anti-Fraud 

Programme and the adoption of the work programme for 2021, https://anti-
fraud.ec.europa.eu/system/files/2021-10/uafp_work_programme_2021_en.pdf 

261  Interview with OLAF (AFIS). 
262  Interview with OLAF (AFIS). 
263  OLAF, AFIS Survey 2019 Summary Report, 2020. 

164 

 
 
AFIS  users  were  surveyed  on  the  functionality  of  the  applications  they  use. 
‘Functionality’ describes the level of quality in the design of an application and may refer 
to  the  quality,  variety  and  usefulness  of  its  available  features.  It  relates  to  the  level  at 
which an application can satisfy the needs of users and is therefore a useful indicator of 
relevance.  

Figure  11  presents  the  level  of  user  satisfaction  with  the  functionality  of  AFIS 
applications, ordered from most used (AFIS Mail)264 to least used (ToSMA)265. The rate 
of satisfaction with functionality was generally high, with an average of 81% across all 
AFIS  applications.  The  highest  satisfaction  rate  for  functionality  was  for  the  Mutual 
Assistance System (MAS) (94%)266.  

The  user  survey  revealed  that  the  applications  are  well  designed  in  the  quality  of  their 
response  to  user  needs.  The  AFIS  component  therefore  performs  sufficiently  well  to 
assess Specific Objective 2 as clearly relevant to the general objectives of the UAFP.  

Figure  11  -  AFIS  satisfaction  survey  (aggregation  of  questions):  Are  you  satisfied 

with the functionality (does it have the features you need) of: 

Source: AFIS satisfaction survey 2023 (N=1 320). 

3.4.2.3 Specific Objective 3 – the IMS component 

Specific  Objective  3  of  the  UAFP  to  ‘support  the  reporting  of  irregularities, 
including fraud, found with the shared management funds and pre-accession assistance 
funds  of  the  Union  budget’  is,  in  virtue  of  this  context,  directly  relevant  to  the  general 
objective of protecting the Union’s financial interests. 

264  AFIS satisfaction survey 2023: AFIS Mail users: 632 respondents out of 1 311. 
265  AFIS satisfaction survey 2023: ToSMA users: 73 respondents out of 1 311. 
266  AFIS satisfaction survey 2023: ‘Are you satisfied with the FUNCTIONALITY (does it have the 

features you need)’: Satisfied: 105 respondents; No opinion: 5 respondents; Dissatisfied: 1 respondent.  

165 

 
 
 
The  performance  of  the  UAFP  under  this  specific  objective,  and  its  relevance  to  the 
general objectives, was primarily determined by the performance of the IMS component, 
which is tasked with supporting the reporting of irregularities. 

Although the number of fraudulent and non-fraudulent irregularities fluctuates little and 
is generally stable, it nevertheless remains at a level that necessitates action on the part of 
the  EU267.  Recent  years  have  seen  steady  increases  in  the  financial  volumes  linked  to 
fraudulent irregularities, both for revenue (TOR) and expenditure. In 2021, compared to 
the  five-year  average  in  the  period  of  2017-2021,  the  financial  amounts  linked  to 
fraudulent irregularities  (TOR) increased  by 32%, with  a fraud detection rate  (FDR) of 
0.63%  for  2021268.  The  increase  observed  was  mirrored  by  the  situation  for  fraud  on 
expenditure.  Although,  financial  amounts  linked  to  fraudulent  activities  in  the  area  of 
agriculture decreased by 28% in the same period, the FDR was nearly the lowest of any 
expenditure stream, at 0.06%269. The need for a strong tool for Member States to detect 
and manage irregularities is crucial to the success of the UAFP. 

IMS is generally perceived as a useful tool for reporting and tracking irregularities and 
fraud.  The  IMS  is  the  only  system  at  EU  level,  and  the  only  system  in  some  Member 
States,  that    gathers  data  on  past  and  closed  cases  of  irregularities.  It  is  also  the  only 
application in the AFIS environment that is focused on expenditure, and its acquisition of 
its  own  separate  budget  was  a  reflection  of  its  importance  within  the  broader  AFIS 
infrastructure270. One of the key needs identified at the time of the ex-ante evaluation of 
the UAFP was ‘the need for the programme to place an increased focus on expenditure 
fraud’271.  The  IMS  is  also  found  to  be  reliable  and  to  provide  a  standardised  way  for 
Member States to collect data on irregularities272. 

Between 2019 and 2021, the user satisfaction rate for the IMS, as measured by OLAF, 
increased from  70% to  84% and surpassed its stated target  of 72% for 2021. The  2023 
survey showed a satisfaction rate of 91% (across functionality and performance)273.  

One interviewee at OLAF pointed to certain challenges, however, noting that new users 
are  starting  to  use  the  system  without  sufficient  training,  and  that  the  system  has  not 
undergone any major improvement for a long time274.   

267  European Commission, Ex-ante evaluation accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 

268  PIF Report 2022. 
269  PIF Report 2022. 
270  Interview with OLAF (IMS). 
271  European Commission, Ex ante evaluation accompanying the document Proposal for a Regulation of 
the  European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 
272  European Commission, Anti-Fraud – Performance, Union Anti-Fraud Programme, 2023, 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en .  

273  AFIS satisfaction survey 2023.  
274  Interview with OLAF. 

166 

 
 
A new version of IMS was deployed on 1 October 2024, consisting of a deep upgrade to 
state-of-the-art  technologies  and  additional  improvements  to  the  look  &  feel  of  the 
interface,  improved  search  and  better  statistics.  This  was  accompanied  by  reviewed 
manuals and planned training until the end of 2024 for all IMS users.  

3.4.3 To what extent are the specific objectives still relevant to emerging trends, 
including in the development of new crime types and techniques? 

This  section examines whether the specific objectives of the UAFP  are still  relevant  to 
emerging trends in the realm of the fight against fraud, including the development of new 
crime types and techniques.  

Overall,  the  specific  objective  of  the  UAFP  determining  the  direction  of  the  Hercule 
component  provides  an  adequate  platform  to  prevent  fraud  that  affects  the  Union's 
financial interests in the context of new and emerging crime trends. However, operational 
results  suggest  that  more  concrete  support  could  be  provided  to  beneficiaries 
implementing  projects  explicitly  targeting  this  objective,  i.e.  by  cementing  the 
importance of digitalisation in the language of the specific objectives, or increasing the 
funds available for projects promoting the digital transition. The findings on the second 
objective,  which  is  the  basis  for  the  AFIS  component,  shows  that  AFIS  enables  the 
identification of new and emerging  trends (although in  a more specific policy context), 
and is therefore deemed to be relevant to emerging trends. This assessment is supported 
by the positive results from the survey of AFIS users. 

3.4.3.1 Hercule component 

There is room to examine the extent to which funding can support the fight against fraud 
in the context of new and emerging trends. Under calls for proposals for UAFP support, 
the  Commission  encourages  applicants  to  explore  certain  indicative  policy  areas, 
including  ‘the  fight  against  revenue  fraud,  including  customs  data  analysis  and  new 
challenges in the field (such as e-commerce)’275.  

OLAF identifies digitalisation as an important trend in the fight against fraud, and one for 
which Member State authorities and the Commission need to be prepared. E-commerce 
has seen steady growth  over the past decade, with accelerated growth as a result of the 
COVD-19 pandemic276. This has increased the potential for several types of fraud related 

275  OLAF, Union Anti-Fraud Programme (UAFP) Call for proposals Technical Assistance (EUAF-2023-

TA) Training, Conferences, Staff Exchanges, and Studies (EUAF-2023-TRAI), 2023, 
https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/euaf/wp-call/2023/call-
fiche_euaf-2023-ta_euaf-2023-trai_en.pdf. 

276  Since 2019, the growth in the percentage of internet users buying goods or services online has outpaced 

the growth in the number of internet users as a whole: European E-commerce, 2022, 
https://ecommerce-europe.eu/wp-content/uploads/2022/06/CMI2022_FullVersion_LIGHT_v2.pdf. 

167 

 
 
to  e-commerce,  such  as  the  rise  in  small  value  parcels  and  other  forms  of  cybercrime-
related fraud277.  

OLAF  states  that,  ‘Despite  having  been  the  object  of  several  recommendations  in  the 
past, the focus on the digitalisation of the fight against fraud is more relevant than ever. 
The opportunities offered by new technologies should be exploited to the full, in order to 
counter fraudsters who appear to be more organised and tech-savvy than ever’278.  

That assessment signifies that the scope and trajectory of the UAFP remains relevant to 
the problems identified in the final Hercule III evaluation in 2021, where the ‘increase in 
new  forms  of  fraud  and  rapid  development  of  sophisticated  technical  tools  used  by 
criminals’ was  highlighted as a key operational  need to  be addressed in  the subsequent 
programming period279. 

Generally,  the  Hercule  component  has  funded  a  large  number  of  projects  to  increase 
digital readiness, including both technical support and training projects centring on new 
digital tools280 and the fight against cybercrime281.  

In  2021,  procurement  under  the  Hercule  component  amounted  to  EUR 707 360  for 
(access  to)  IT  databases  and  EUR 717 961  for  IT  tools  and  tobacco  analysis282. 
Beneficiaries cited the need to develop, increase or upgrade IT tools for investigating and 
monitoring intelligence work as the most frequent reason to apply for a call for proposals 
(60%)283. This is in line with the 2021 assessment that Member States lacked ‘up-to-date 
technical equipment and support’284. 

Beneficiaries  interviewed  emphasised  the  importance  of  digital  readiness  as  a  key 
component  of  the  current  landscape  of  the  fight  against  fraud.  Some  interviewees  even 
suggested  adding  a  specific  objective  on  ‘technology  enabled  fraud’  to  further  support 
this  area.  While  the  specific  objectives  are  already  relevant  to  emerging  trends,  some 
beneficiaries  noted  that  their  statement  of  purpose  in  the  context  of  emerging  trends, 

277  European Commission, Ex-ante evaluation accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 

278  PIF Report 2022. 
279  European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582. 

280  An analysis of application forms for the Hercule component found 14 projects to deliver digital tools.  
281  An analysis of application forms for the Hercule component found four projects to develop new 

methods in the fight against various forms of cybercrime, specifically new forms of fraud against the 
EU’s financial interests.  

282  PIF Report 2021. 
283  Survey of applicants and beneficiaries, Q8: ‘Yes’ respondents. 
284  European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582. 

168 

 
 
specifically digital preparedness, could be consolidated through a potential update of the 
specific objectives. 

Some  responses  to  the  survey  of  applicants  and  beneficiaries  indicated  that  the  UAFP 
may be able to support Member States’ ability to respond to new challenges in the fight 
against fraud by funding relevant areas in anti-fraud investigations. Of the beneficiaries 
of  grants  under  the  Hercule  component,  eight  out  of  14  (57%)  had  received  grants  to 
strengthen investigations, as well as data analysis and forensics. 

Six  beneficiaries  (43%)  have  received  grants  to  strengthen  their  capacity  in  the  fight 
against  illicit  tobacco  trade  and  smuggling,  and  illicit  trade  and  smuggling  of  other 
products.  Another  four  (29%)  have  received  grants  to  strengthen  their  capacity  to  fight 
customs, VAT and excise fraud285.  

Figure 12 - What was your interest in applying to one of the calls for proposals?  

Need to develop, increase, or upgrade IT tools for…

Need to increase or replace equipment at our…

60%

53,3%

Need to improve investigative practices and tools…

40,0%

Need to increase operational cross-border…

Need to improve control and surveillance practices…

33,3%

33,3%

Need to train staff in our or in partner organisation(s)

26,7%

Need to further research a certain legal area linked …

13,3%

Source: OLAF survey of applicants/beneficiaries (N=29). 

Figure 13 - What policy area(s) did your grant application cover? 

Conduction of investigations
Data analysis and forensics
Anti-corruption
Illicit tobacco trade and smuggling
Illicit trade and smuggling of other products
Customs, VAT, and excise fraud

Improving cooperation between Member States’ …

Public budget irregularities and fraud
Other instances of economic and financial crime
Other (please specify below)

7%

29%

21%
21%
21%

57%
57%

50%

43%
43%

Source: OLAF survey of applicants/beneficiaries (N=29). 

Some  training  projects  have  the  explicit  goal  of  directly  investigating  the  potential  for 
emerging criminal threats. One in particular (IT) aims to identify the new threats to the 
EU’s financial interests that  might  arise from  the digitalisation of processes relevant  to 
fiscal  operations.  Notably,  it  seeks  to  investigate  criminal  behaviours  facilitated  by  the 

285  Survey of applicants and beneficiaries, Q4.1: ‘Yes’ respondents. 

169 

 
 
 
 
use  of  ICT  in  trading  operations,  invoicing  and  disclosure  of  tax  information,  which 
could create new opportunities to commit VAT fraud in the cyber space.  

Another  has  the  long-term  goal  of  equipping  employees  with  the  necessary  skills  and 
knowledge  to  tackle  new  and  emerging  forms  of  fraud,  corruption,  and  other  illegal 
activities, and to lead to more efficient and effective protection of EU financial interests. 

Statistical  analysis  of  the  application  forms  for  the  Hercule  component  reveals  that  at 
least  seven  applicant  institutions  directly  state  under  the  ‘Impact  and  ambition’  section 
that they seek to prepare for the likely scenario where new trends and modi operandi will 
emerge in their area of enforcement, namely digital and digital payments fraud, criminal 
intelligence and procedural aspects of fraud crime investigations.  

In  all  projects  covered  by  the  case  study  on  digitalisation,  the  calls  for  proposals  were 
highly  relevant  to  beneficiaries’  needs,  as  they  aimed  to  prevent  and  combat  fraud  by 
reinforcing the investigative capabilities and capacity of national authorities through the 
use of digitalisation, purchase of software for data analysis/surveillance equipment, and 
upgrading digital forensics.  

Although AI-related tools would increase time and task efficiency for OLAF or national 
authorities,  the  costs  of  purchasing  the  necessary  hardware  would  be  substantial  and 
necessitate  an  expansion  of  the  UAFP286.  The  increased  cost  of  hardware  is  also 
applicable to areas beyond AI, covering existing tools funded by the UAFP. 

While the Hercule component is relevant to supporting the fight against emerging trends 
through  its  thorough  focus  on  providing  digital  tools  to  beneficiaries,  its  broader 
relevance  would  benefit  from  increasing  the  volume  of  funding  and  projects  explicitly 
focused  on  these  issues.  OLAF  stakeholders  noted  the  importance  of  an  increase  in 
funding, in particular in light of the expansion of the UAFP to Ukraine – an agreement 
was  signed  in  February  2024,  allowing  Ukrainian  authorities  access  to  the  funding 
provided.  

3.4.3.2 AFIS component 

The  Commission,  including  OLAF,  has  designated  tobacco  smuggling,  in  addition  to 
significant  public  health  and  organised  crime  risks,  as  causing  ‘heavy  losses  to  the 
budgets of EU countries and the EU institutions’287, 288. It has stepped up the fight against 

286 Interview with OLAF. 
287 OLAF, Tobacco smuggling, n.d., https://anti-fraud.ec.europa.eu/investigations/investigations-related-

eu-revenue/tobacco-smuggling_en.  

288 Cigarette smuggling costs national and EU budgets more than EUR 10 billion annually in lost public 
revenue and is a major source of organised crime, including terrorism (Michalopoulos, S., EU  anti-
fraud official: Tobacco smuggling is “major source” of organised crime’, Euractiv, 7 February 2017, 
https://www.euractiv.com/section/trade-society/interview/olaf-official-tobacco-smuggling-major-
source-for-organised-crime/ . 

170 

 
 
illegally traded tobacco, in accordance with the relevant Council Conclusion of 2017289. 
Although the fight against tobacco smuggling has been a priority of Commission services 
for  several  years,  there  is  evidence  to  suggest  that  this  area  is  experiencing  new  and 
emerging  crime  trends290.  The  ex-ante  evaluation  of  the  UAFP  had  also  found  that 
‘Today  more  than  ever,  especially  in  view  of  the  increasing  sophistication  of  criminal 
groups,  customs  fraud  can 
there  can  be  undervaluation, 
take  various  forms: 
misclassification  of  goods,  origin  fraud  and  outright  smuggling,  including  notably  of 
tobacco and other excisable products’291. 

The  AFIS  component  of  the  UAFP  has  remained  relevant  to  tobacco  smuggling.  In 
particular, the ToSMA supports Member States and OLAF in submitting requests for the 
analysis  of  seized  tobacco  products.  ToSMA  may  have  the  long-term  advantage  of 
increasing  investigators’  awareness  of  the  provenance  of  illegal  tobacco  products  and 
determining  new  trends  in  tobacco  smuggling292,  293.  ToSMA’s  operations  enables  the 
Commission’s  Joint  Research  Centre  (JRC)  to  maintain  a  repository  of  commercially 
available  cigarettes  purchased  at  licensed  tobacconists  around  the  world,  from  which 
statistical models are built. The repository now contains 1 165 tobacco products from 71 
countries, against which new products can be compared294.  

ToSMA,  despite  being  among  the  lowest-used  applications  under  AFIS,  is  one  of  the 
highest-rated  for  functionality,  at  89%  satisfaction.  This  was  confirmed  by  the  targeted 

289 Council document no 15638/17 of 11 December 2017. 
290 A study commissioned by Philip Morris International has found, for example, that ‘there is increasing 

reason to be concerned about the continued and significant rise in counterfeit cigarettes, which 
escalated by 6.2% in 2022, reaching 13.1 billion cigarettes, and now accounts for 36.5% of the EU’s 
total illicit cigarette consumption, marking the highest-ever recorded share and volume to date’ (Philip 
Morris International, Illicit cigarette consumption in the EU, UK, Norway, Switzerland, Moldova and 
Ukraine: 2022 results, 2023,  https://www.pmi.com/resources/docs/default-source/itp/kpmg-report---
illicit-cigarette-consumption-in-the-eu-uk-norway-switzerland-moldova-and-ukraine---2022-
results.pdf?sfvrsn=26f369c9_2  

291 European Commission, Ex-ante evaluation accompanying the document Proposal for a Regulation of 
the European Parliament and of the Council establishing the EU Anti-Fraud Programme, SWD(2018) 
294 final, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018SC0294. 

292 In the period from 11 July 2021 to 12 July 2022, the JRC processed 80 requests from 10 Member States 
for analysis of seized cigarettes and raw/fine-cut tobacco samples. It was possible to draw connections 
between cigarettes seized in various places in the EU at various moments (42 samples could be 
connected to previous seizures) (UAFP, Annual overview, 2022). 

293 In the period from 12 July 2020 to 11 July 2021, the JRC processed 144 requests from 11 Member 
States for analysis of seized cigarettes and raw/fine-cut tobacco samples. It was possible to identify 
cigarettes that had been smuggled into the EU market and to draw connections between cigarettes 
seized in various places in the EU at various moments. Some 100 seizures were connected to each 
other. (European Commission, Annual overview with information on the results of the Union anti-fraud 
programme in 2021, COM(2022) 482, 2022, https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2022%3A482%3AFIN. 

294 European Commission, Annual overview with information on the results of the Union anti-fraud 

programme in 2022, SWD(2023) 276, 2023, https://eur-lex.europa.eu/legal-
content/LT/TXT/?uri=CELEX%3A52023SC0276. 

171 

 
 
survey of AFIS users. When asked whether the applications in AFIS provide up-to-date 
tools to tackle latest trends in fraud and related irregularities, 40% of users agreed, 25% 
slightly agreed, and 5% of users either disagreed or slightly disagreed.  

Figure 14 - Do you agree with the following statement: ‘The available  applications 
in  AFIS  provide  up-to-date  tools  to  tackle  latest  trends  regarding  the 
crime of fraud and related irregularities’? 

40%

25%

29%

4%

Agree

Slightly agree

No opinion

Slightly disagree

Disagree

Source: AFIS satisfaction survey 2023 (N=1 320). 

Notes:  Agree:  529  respondents;  Slightly  agree:  336  respondents;  No  opinion:  387  respondents;  Slightly 
disagree: 169 respondents; Disagree: 19 respondents. 

3.4.4 To what extent have the activities of the programme been relevant for 
achieving its specific objectives in the period 2021-2024? 

The  training  and  technical  assistance  activities  implemented  under  the  Hercule 
component  are  found  to  be  relevant  to  achieving  the  specific  objective,  based  on 
evidence  gathered  from  the  study  surveys,  interviews  and  case  studies.  Although  this 
question focuses mainly  on activities under Hercule, it holds true for AFIS and IMS as 
well. 

3.4.4.1 Hercule component 

The  activities  covered  under  training  grants,  i.e.  to  strengthen  cross-border  cooperation 
and networking activities and contribute to the protection of the financial interests of the 
EU, were divided as follows295:  

-  Activities covered under training grants 

▪  Conferences, workshops and seminars to: (i) facilitate the exchange of information, 
experience  and  best  practices,  including  in  data  analysis;  (ii)  create  networks  and 
improve  coordination  between  Member  States,  candidate  countries,  other  third 
countries,  EU 
facilitate 
multidisciplinary  cooperation  between  anti-fraud  practitioners  and  academics  on 
protecting  the  EU’s  financial  interests,  including  support  to  associations  for 
European criminal law and for the protection of the EU’s financial interests; and (iv) 
raise awareness among the judiciary and other legal professionals;  

international  organisations; 

institutions  and 

(iii) 

295  Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2022, C(2022) 1139, https://anti-
fraud.ec.europa.eu/document/download/7824f63f-724b-486a-b7b9-
d8880e4d5456_en?filename=uafp_work_programme_2022_annex_en.pdf. 

172 

 
 
 
▪  Specialised training sessions to improve investigation and data analysis abilities by 
acquiring new skills and knowledge of specialised methodologies and techniques;  
▪  Staff exchanges between national and regional administrations (including candidate 
and  neighbouring  countries)  to  develop,  improve  and  update  staff  competence  in 
protecting the EU’s financial interests;   

▪  Developing  comparative  law  studies  and  organising  activities  to  raise  awareness 
among  the  judiciary  and  other  branches  of  the  legal  profession  on  protecting  the 
EU’s  financial 
the  dissemination  of  relevant  scientific 
interests, 
knowledge through periodical publications.  

including 

Source: ICF analysis. 

Activities covered under technical assistance grants were divided as follows296: 

-  Activities covered under technical assistance grants 

▪  Purchasing  and maintaining  investigation and surveillance tools and methods used 
in  the  fight  against  irregularities,  fraud  and  corruption  perpetrated  against  the 
financial  interests  of  the  EU,  including  specialised  training  needed  to  operate  the 
investigation tools;  

▪  Purchasing  digital  forensics  hardware,  including  equipment  and  software,  mobile 
forensic tools and computer forensic collaborative systems used in the fight against 
(fraudulent)  irregularities,  fraud,  and  corruption  detrimental  to  the  EU’s  financial 
interests;   

▪  Purchasing  data  analytics  technologies  and  data,  including  the  acquisition  and 
maintenance  of:  (i)  commercial  specialised  databases;  (ii)  data  analysis  platforms 
capable of running analyses in Big Data environments, risk and predictive analyses, 
and  data-mining  tools;  and  (iii)  systems  supported  by AI  used  in  the  fight  against 
irregularities, fraudulent activities, and corruption detrimental to the EU’s financial 
interests;  

▪  Purchasing  equipment  for  the  detection  of  illicit  trade  to  strengthen  beneficiaries’ 
operational  and  technical  capacity  to  detect  smuggled  and  counterfeited  goods, 
including cigarettes and tobacco, imported into the EU with the intention of evading 
VAT, customs duties and/or excise taxes.   

Source: ICF analysis. 

One year after each grant’s closing date, beneficiaries of technical assistance grants are 
requested to submit final implementation questionnaires designed to reflect the UAFP’s 
activities’ contribution to achieving the specific objectives.  

296  Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2022, C(2021) 5338, https://anti-
fraud.ec.europa.eu/document/download/7824f63f-724b-486a-b7b9-
d8880e4d5456_en?filename=uafp_work_programme_2022_annex_en.pdf. Annual work programmes 
for 2022, 2023, and 2024, https://anti-fraud.ec.europa.eu/policy/union-anti-fraud-programme-
uafp/union-anti-fraud-programme-hercule-component_en. 

173 

 
 
The  technical  equipment  purchased  under  the  remaining  technical  assistance  grants  for 
the Hercule III programme, such as detection tools, enabled concrete achievements in the 
prevention  of  fraud,  corruption  and  other  activities  affecting  the  Union’s  financial 
interests, contributing directly to the first objective of the UAFP.  

OLAF  reported  that  with  these  activities,  beneficiaries  managed  to  ‘seize  substantial 
amounts  of  smuggled  cigarettes,  counterfeit  goods  and  tobacco  products’297.  National 
authorities  reported  that  equipment  to  support  investigations,  such  as  communication 
equipment, cameras,  IT tools and forensic software and hardware, facilitated the lawful 
gathering  of  evidence  during  operations  to  protect  EU  revenue,  expenditure  and  assets. 
Both groups in the survey of applicants and beneficiaries agreed or strongly agreed that 
the goals and eligible activities of the call for proposals covered all of their operational 
needs related to the protection of EU financial interests298.  

The majority of beneficiaries surveyed stated that their intervention under the UAFP has 
contributed  to  ‘an  improvement  of  overall  work  related  to  prevention,  detection  and 
investigation  of  fraud  and  other  illegal  activities  detrimental  to  the  EU’s  financial 
interests’299.  It  is  clear  that  training  activities  undertaken  under  UAFP  support  were 
highly successful, with 90% of training participants reporting them as very well suited to 
their needs300. 

The survey of applicants and beneficiaries suggested a high degree of relevance of UAFP 
activities  with  the  specific  objectives.  All  14  respondents  with  unknown  application 
statuses  stated  that  ‘it  was  clear  to  them  how  the  call  for  proposals  was  effectively 
contributing to the objectives of the programme’301. Of these, 13 agreed that ‘the terms of 
the  call  for  proposals  provided  clear  guidance  to  ensure  proposals  would  effectively 
contribute to the objectives of the programme’302.  

Beneficiaries agreed or strongly agreed (14) that the eligible activities under the call for 
proposals  were  clearly  relevant  to  the  UAFP’s  specific  objectives.  Respondents  with 
unknown  application  statuses  (13)  also  agreed  or  strongly  agreed  that  the  eligible 
activities  under  the  call  for  proposals  were  clearly  relevant  to  achieve  the  specific 
objectives of the programme303.  

297  Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2022, C(2021) 5338, https://anti-
fraud.ec.europa.eu/document/download/7824f63f-724b-486a-b7b9-
d8880e4d5456_en?filename=uafp_work_programme_2022_annex_en.pdf. Annual work programmes 
for 2022, 2023, and 2024, https://anti-fraud.ec.europa.eu/policy/union-anti-fraud-programme-
uafp/union-anti-fraud-programme-hercule-component_en. 

298  Survey of applicants and beneficiaries, Q13: 14 of 14 ‘I don’t know’ respondents agreed or strongly 

agreed; Q7: 14 of 15 ‘Yes’ respondents agreed or strongly agreed.  

299  Survey of applicants and beneficiaries, Q9: ‘Yes’ respondents. 
300  PIF Report 2022.  
301  Survey of applicants and beneficiaries, Q14: ‘I don’t know’ respondents. 
302  Survey of applicants and beneficiaries, Q14: ‘I don’t know’ respondents. 
303  Survey of applicants and beneficiaries, Q13: ‘I don’t know’ respondents; Q7: ‘Yes’ respondents. 

174 

 
 
The case study on training found that ‘the  scope and activities of the reviewed projects 
were to a great extent relevant to achieving the objectives of the programme’304.  

Figure 15 - To what extent do you agree with the following statements: 

Source: OLAF survey of applicants/beneficiaries (N=29). 

The evidence from the interviews corroborates this view: four interviewees stated that the 
activities under the UAFP are relevant to their needs and to the specific objectives, while 
two stated that they are highly relevant.  

3.4.4.2 AFIS component 

A  number  of  tools  for  information  exchange  were  released  through  AFIS  since  2021. 
These include: the MAS, an application to automate the manual collection and processing 
of  data  and  gather  all  mutual  assistance-related  files  in  a  central  place305;  two  major 
upgrades  of  the  CSM  directory  and  a  new  module  for  CIS+  to  (also)  support  the  new 
Cash Control Regulation306. 

The example of CIS+ demonstrates the relevance of the information exchange activities 
under AFIS to  its specific objective.  In mid-2022, the system  counted more than 2 200 
users  and  contained  data  on  31 500  cash  declarations  and  1 800  infringements  of  the 
UAFP  Regulation307.  An  even  higher  number  of  activities  were  dedicated  to  enabling 
information exchange, including 70 application releases.  

304  The training activities in the projects reviewed promoted all three specific objectives of the UAFP, i.e. 
they improved the capacity of competent authorities to prevent and combat fraud and corruption, 
enhanced information exchange and mutual assistance, and supported the identification and reporting of 
irregularities affecting the EU financial interests. 

305  MAS was the highest-rated AFIS application for functionality, at 94% satisfaction. 
306  Regulation (EU) 2018/1672 of the European Parliament and of the Council of 23 October 2018 on 

controls on cash entering or leaving the Union and repealing Regulation (EC) No 1889/2005, OJ L 284, 
12.11.2018, pp. 6-21. 

307  PIF Report 2022. 

175 

 
 
 
3.4.4.3 IMS component 

The  IMS  has  been  generally  well  received  and  is  clearly  relevant  to  the  third  specific 
objective  of  ‘supporting  the  reporting  of  irregularities,  including  fraud,  found  with  the 
shared management funds and pre-accession assistance funds of the Union budget’. 

3.5 EU added value 

EU added value assesses the potential change for beneficiaries or citizens as a result of 
the  EU  intervention  and  measures  the  impact  above  and  beyond  reasonably  expected 
results  of  national  actions  alone.  The  section  first  addresses  the  current  availability  of 
data and identifies existing limitations to determining added value.  

It then assesses the EU added value of the UAFP, considering first the extent to which 
the  results  delivered  would  have  been  feasible  without  intervention,  and  second  by 
identifying  the  extent  to  which  the  UAFP  enabled  more  efficient  use  of  financial 
resources than intervention at Member State level alone.  

The assessment is based on a thorough review of available reports and literature on the 
UAFP,  targeted  surveys  of  Hercule  component  beneficiaries  and  applicants,  targeted 
surveys of AFIS users, and interviews with key stakeholders.  

The  data  reflect  that,  overall,  the  UAFP  programme  performed  well  against  the 
baseline indicators on EU added value. 

3.5.1 Main conclusions: EU added value of the UAFP 

  Recipients  of  funding  under  the  Hercule  component  indicated  a  very  high  level  of 
perceived  satisfaction  and  confirmed  that  the  same  level  of  intervention  would  not  have 
been  possible  at  national  level.  Respondents  to  the  targeted  surveys  and  interviews  all 
confirmed  this  finding.  The  baseline  for  this  indicator  is  based  on  the  survey  of  99 
beneficiaries surveyed for the final evaluation of the Hercule III programme, 70% of whom 
disagreed that the same results would be possible at national level alone308. The majority 
(53.9%) surveyed here disagreed or strongly disagreed that the same intervention would be 
possible  with  national  funding309.  Although  this  proportion  has  fallen,  it  does  not 
necessarily reflect negatively on the UAFP: No survey respondent agreed that their project 
could be  completed  at  a  national  level;  and  many  of  the  projects  begun  under the  UAFP 
have yet to be finalised. Interviewees, including both beneficiaries and applicants, agreed 
that their  proposed  project  could not  have been  completed  if funded solely  at national  or 
regional  level.  Only three interviewees, including two  case  study  respondents, stated that 
the project would have been possible at national level310, although not at the same scale or 
with the same quality of results311.  

308  European Commission: European Anti-Fraud Office, Landes, F., Aparicio Jodar, L., Riccardi, M., 
Colaiacomo, E. et al., Final evaluation of the Hercule III programme – Final report, Publications 
Office, 2021, https://data.europa.eu/doi/10.2784/62582. 

309  Survey of applicants and beneficiaries. 
310  Interviews with beneficiaries. 

176 

 
 
  AFIS: Data under UAFP indicate a steady increase in the availability of mutual assistance 
information and it regularly meets the yearly targets. The number of instances in which this 
information  was  available at  the  beginning  of  2021 was  19 125312,  growing  to 19 212  by 
the end of the year, slightly below the target of 19 500313. By the end of 2022, however, it 
had risen to 26 367 (target of 21 500) and by the end of 2023, it was 29 419 (surpassing the 
target of 24 000)314. The overall target was set as 24 000 instances of information available 
by 2024, which was already greatly exceeded by the end of 2023315.   

  IMS:  Data  reflect  generally  high  satisfaction  with  IMS.  Survey  data  from  2023  indicate 

that approximately 91% of respondents are satisfied overall with the IMS tool316.  

Source: ICF analysis. 

Has the programme allowed delivering results that could not, or to a lesser extent, 
be achieved by interventions undertaken only at national or regional level? 

Data  indicate  that  the  UAFP  allowed  Member  States  to  achieve  results  in  the  fight 
against  fraud  that  would  not  have  been  possible  through  interventions  at  national  and 
regional level  alone. Crucially,  they reflect that not  only  has the scope of interventions 
been greater due to EU-level support, but in many cases the intervention would not have 
been possible at all.  

Many key IT programmes and investigative tools would not have been made available to 
Member States without EU-level support for such access.  

3.5.1.1 Hercule component 

The  survey  responses,  interview  results  and  initial  final  reports  indicate  that  the  UAFP 
has  provided  a  clear  benefit  to  Member  States,  enabling  them  to  achieve  results  in  the 
fight  against  fraud  that  would  not  be  feasible  or  would  be  less  effective  without  EU 
intervention.  The  interview  responses  highlighted  that,  according  to  programme 
participants,  the  UAFP  funding  fulfils  a  critical  role,  without  which  many  important 
interventions would not be possible.     

The  survey  asked  successful  applicants  whether,  in  their  opinion,  project  results  could 
have  been  achieved  without  EU  level  support317.    Of  13  respondents,  a  majority  either 
disagreed  or  strongly  disagreed  that  project  results  would  be  possible  without  EU 
intervention, none believed that project results could have been achieved through action 
at national or regional level alone, and the remainder responded neutrally, did not know, 
or felt the question did not apply to them.  

311  Interviews with beneficiaries. 
312  AFIS Steering Committee Meeting Presentation, 2021. 
313 AFIS Steering Committee Meeting Presentation, 2021. 
314 AFIS Steering Committee Meeting Presentation, 2022; AFIS Steering Committee Meeting Presentation, 

2023. 

315 AFIS Steering Committee Meeting Presentation, 2022; AFIS Steering Committee Meeting Presentation, 

2023. 

316 AFIS satisfaction survey 2023. 
317 Of 29 total respondents, the 15 successful applicants received this question, 13 of whom responded. 

177 

 
 
Figure 16 - To what extent do you agree that the results achieved thanks to UAFP 
support  could  be  achieved  through  other  means  at  national  or  regional 
level? 

23,1%

30,8%

23,1%

23,1%

Neither agree nor disagree

Disagree

Strongly disagree

Do not know / Not applicable

Source: OLAF survey of applicants/beneficiaries (N=29). 

Final results from many projects funded under the Hercule component of UAFP (2021, 
2022,  2023)  are  not  yet  available,  as  the  projects  are  ongoing  or  the  implementation 
reporting is pending (due 12 months after the end of the project).  

However,  ongoing  projects  from  Hercule  III  are  monitored  under  the  UAFP  and  were 
completed in 2022. Although begun under the preceding programme, these projects were 
finalised under the UAFP and point to the EU added value of the Hercule component.  

Feedback on training activities funded under Hercule III but conducted during 2022 were 
overwhelmingly positive, with 90% of participants rating them as excellent or good318.  

Additionally,  feedback  from  projects  completed  in  2022  identified  EU  added  value  in 
indicative  programme  gains  and  qualitative  feedback  from  participants.  The  2022 
Commission  PIF  report  credits  the  seizure  of  substantial  quantities  of  smuggled  and 
counterfeit goods to activities supported via the UAFP.  

For example, Slovenia was supported to purchase an X-ray scanner for its maritime cargo 
port.  This  scanner  was  deployed  in  two  international  investigations,  resulting  in  the 
seizure  of  illicit  goods  including  584  kilogrammes  (kg)  of  cocaine,  216  kg  of  heroin, 
1 655 kg of smuggled commercial goods, and 570 tonnes of goods infringing intellectual 
property.  

Participants  in  the  calls  for  proposals  for  technical  assistance  projects  generally  agreed 
that the project activities either could not be completed without UAFP assistance or could 
not be completed with the same scope and effectiveness. They highlighted, for example, 
that  the  UAFP  enables  them  to  purchase  highly  specialised,  advanced  equipment, 
whereas  national  assistance  typically  only  provides  for  basic  equipment319.  In  addition, 
national  funding  generally  does  not  prioritise  projects  with  the  scale  and  specialisation 
that UAFP funding enables them to achieve.  

318 PIF Report 2022.  
319 Interviews with beneficiaries.  

178 

 
 
 
A  small  number  of  respondents  who  received  funding  for  technical  assistance  projects 
stated  that  their  project  would  have  been  possible  at  national  level.  However,  they  all 
indicated that the intervention was more efficient and effective with UAFP support. 

Participants  in  the  calls  for  proposals  for  training  activities  similarly  agreed  that  the 
project  activities  could  not  be  completed  with  support  from  national  level  alone.  Many 
had  received  or  applied  for  funding  for  conferences  and  seminars  in  conjunction  with 
research on topics relevant to the protection of EU financial interests, an area for which 
EU-level funding is absolutely necessary. Several respondents highlighted that funding at 
national level often and increasingly focuses on national issues. One stated that, ‘There is 
no way this research would be funded at the national or regional level. The only possible 
way to fund this kind of project is at the EU level.  

3.5.1.2 AFIS 

The EU added value of the AFIS component is its presence and functionality as a unique 
platform  allowing  communication  and  cross-border  collaboration  across  the  EU.  The 
results  achieved  by  AFIS  are  solely  achievable  through  this  programme  component,  as 
the core function would not otherwise exist. 

The functionality of AFIS continued to expand, with eight platform releases for AFIS in 
2021  and  13  in  2022320.  Overall,  AFIS  had  more  than  70  releases  in  2022,  including 
component  releases  and  hotfixes321.  During  the  first  half  of  2023  (until  3  July),  AFIS 
expanded  further,  with  six  platform  releases  (bundles)  and  61  releases  of  individual 
components322.  These  developments  contributed  to  additional  functionality  of  the 
platform and thus to the UAFP.  

As an example of these releases’ contribution to EU added value, the successful release 
of CIS+ in  2021 brought a KPI for  the UAFP (number of information  items  on mutual 
assistance  made  available)  back  on  track  to  meet  its  target  (having  lagged  in  previous 
years323).  Over  the  course  of  the  UAFP,  AFIS  reached  and  exceeded  the  target  for  this 
indicator. By the end of 2022, this number had risen to 26 367 (target of 21 500) and by 
the end of 2023, it was 29 419 (target of 24 000)324. The overall target for this indicator 
was set  at 24 000 instances of information  available by 2024, a target greatly exceeded 
by the end of 2023.  

AFIS also demonstrated EU added value by supporting 10 JCOs in 2022. It continued to 
release  multiple  additional  components  across  several  platforms  and  saw  increased 

320 European Commission, Annual overview with information on the results of the Union anti-fraud  

programme in 2022, SWD(2023) 276, https://eur-lex.europa.eu/legal-
content/LT/TXT/?uri=CELEX%3A52023SC0276. 
321 AFIS Steering Committee Meeting Presentation, 2022. 
322 AFIS Steering Committee Meeting Presentation, 2023. 
323 European Commission, Annual overview with information on the results of the Union anti-fraud 

programme in 2022, SWD(2023) 276, 2023, https://eur-lex.europa.eu/legal-
content/LT/TXT/?uri=CELEX%3A52023SC0276. 

324 AFIS Steering Committee Meeting Presentations (2022 & 2023). 

179 

 
 
usership  of  functions  such  as  CIS+  in  the  first  half  of  2023.  Reporting  from  AFIS 
indicates steady increases in usage statistics for multiple components of AFIS each year 
from 2021325, indicating widespread and growing use of this unique programme326. 

Results of the surveys of AFIS users, however, returned mixed results on the EU added 
value  of  the  IT  platform  overall.  Respondents  were  asked  whether,  in  the  absence  of 
AFIS, they could perform their duties using a similar existing national system. Of 1 320 
respondents,  37% either slightly disagreed (13%) or disagreed (24%), and only  slightly 
fewer agreed (20%) or slightly agreed (13%) that they could perform their job duties in 
the absence of AFIS. A large number of respondents (30%) did not have an opinion327.  

These survey results  alone are inconclusive on the EU added value of AFIS. However, 
AFIS provides a range of unique functions for cross-border cooperation that might not be 
fully realised at national level, leading more respondents to affirm the EU added value of 
AFIS than otherwise.  

Overall,  the  continued  development  of  AFIS  functionality  and  its  growing  usage  rates 
indicate  that  AFIS  has  EU  added  value.  Many  interview  respondents  stated  that  they 
could  not  complete  their  job  duties  with  national  resources,  although  others  noted  that 
their national systems would allow them to complete their duties, even in the absence of 
AFIS.  

3.5.1.3 IMS 

The  IMS  contributes  to  EU  added  value  by  facilitating  EU-level  coordination.  It  is  the 
only  system  of  its  kind  that  enables  the  collection  and  distribution  of  data  on 
irregularities  across  the  EU,  thus  in  its  absence,  these  data  would  not  be  available  in  a 
single  system  for  the  entire  EU.  For  some  Member  States,  IMS  is  the  only  system 
available to record and share data on irregularities at regional or national level. Crucially, 
the  data  collected  through  the  IMS  provides  a  unique  resource  for  tracking  and 
understanding  the  scale  and  impact  of  fraud,  e.g.  it  forms  the  basis  for  analysing  and 
presenting fraud in the PIF reports.  

As such, the IMS is central to understanding fraud in the EU and informing programme 
decisions.  Feedback on the system  in  2022 indicates a high  level  of satisfaction among 
surveyed users, at 82%328. Overall satisfaction remains high, at approximately 91% in the 
2023  survey329.  Although  the  function  of  the  IMS  represents  a  valuable  tool,  some 
problems  in  relation  to  data entry, low awareness,  and low usage rates  were identified. 
These  implementation  challenges  reflect  issues  in  training  and  guidance  rather  than 
technical limitations of the tool itself.  

3.5.2 Does the intervention at EU level provide added value in terms of the efficient 
use of financial resources as compared to a possible intervention at national level? 

325 AFIS Steering Committee Meeting Presentation, 2021-2023. 
326 AFIS Steering Committee Meeting Presentation, 2023. 
327 AFIS satisfaction survey 2023. 
328 PIF Report 2022. 
329 AFIS satisfaction survey 2023. 

180 

 
 
The data collection returned relatively few responses on financial efficiency specifically. 
However,  many  interview  respondents  indicated  that  similar  interventions  are  not 
available at national level, preventing a direct comparison of relative financial efficiency. 
The data available suggest that the UAFP generally provides EU added value through the 
efficient use of financial resources.  

Benefits  to  the  scope  and  process  of  the  UAFP  delivery  and  the  flexibility  in  funding 
indicate EU added value of the programme.  

3.5.2.1 Hercule component 

Survey  results  indicate  that,  overall,  funding  under  the  UAFP  has  contributed  to  the 
scope of intervention and process of delivery. Most respondents indicated a large benefit 
(46.2%) or at least some benefit (7.7%) to the scope of intervention.  

Several  respondents  did  not  know the overall benefit or noted that the question did  not 
apply (38.5%). Respondents from Spain and Croatia indicated a significant contribution, 
with the respondent from Spain stating that the contribution of EU funds has resulted in a 
significantly  increased  capacity  to  fight  fraud  and  smuggling  due  to  new  technical 
equipment  and  associated  training  of  end  users,  and  the  respondent  from  Croatia 
indicating  that  the  relevant  project  implementation  would  not  have  been  possible  at  all 
without EU intervention.  

Figure  17  -  To  what  extent  there  have  been  any  benefits  in  terms  of  volume  and 
scope of the intervention and the process of its delivery owing to the fact that it was 
funded at EU level? 

46,2%

7,7% 7,7%

38,5%

To a large extent

Somewhat

Little

Do not know / Not applicable

Source: OLAF survey of applicants/beneficiaries (N=29). 

Interviewees  were  asked  whether  the  UAFP  programme  provided  EU  added  value  in 
terms of the efficient use of financial resources. Very few provided feedback, with most 
referring to the lack of comparable alternative funding at national  and regional level or 
even  through  other  EU-level  programmes.  These  responses  indicate  that,  often,  no 
alternative programme exists with which respondents can compare relative efficiency.  

The  few  respondents  of  technical  assistance  funding  who  indicated  that  their  project 
would be possible at national level also stated that the project was more efficient because 
of  UAFP  support330.  They  noted  that  UAFP  support  either  allowed  them  to  purchase 

330  Interviews with beneficiaries. 

181 

 
 
 
equipment faster and in  greater volumes, or ensured that the procurement process  itself 
was quicker and more efficient331. These responses indicate that even where alternative 
funding is available at national level, the UAFP provides substantial EU added value by 
ensuring a more efficient and effective process. 

3.5.2.2 AFIS and IMS 

The AFIS and IMS components are unique platforms that enable coordination across the 
EU. The core functions of these tools are only available to Member States and associated 
beneficiaries because they exist at EU level. Without these programme strands, Member 
States could still develop and maintain their own national versions of these platforms, but 
only  at  considerable  expense,  particularly  to  guarantee  a  functional  link  between  these 
individual programmes.  

3.5.2.3 Programme synergies 

A  key  intended  benefit  of  the  UAFP  in  bringing  together  previously  separate  antifraud 
activities  (Hercule,  IMS  and  AFIS)  is  the  potential  for  flexibility  in  the  allocation  of 
funding  between  the  programme  components  and  in  the  financial  management  of  the 
programme. The budget flexibility enables transfer of funds easily from one programme 
component to another, or within each component, where required, representing a useful 
coordination  between  the  components  of  the  UAFP332.  While  current  data  do  not  show 
substantial  transfers  of  funds  between  programme  components,  the  2022  PIF  report 
highlighted  that  this  budget  flexibility  enabled  funds  initially  earmarked  for  anti-fraud 
training to be allocated to technical assistance activities333.  

3.5.2.4 Contributions to sustainable development goals and additional or 
unexpected benefits 

The UAFP provides additional benefits,  in  part through its contribution  to  meeting key 
sustainable development goals (SDGs). More specifically, financial support from the EU 
through  the  technical  assistance  grants  contributes  to  the  SDG  (No  16)  of  reducing 
inequalities  within and among  countries.  The technical  assistance grants  indirectly help 
to  harmonise  the  financial  resources  available  to  Member  States  by  bolstering  the 
budgetary  capacity  of  national  administrations334.  The  UAFP  also  indirectly  helps  to 
build  effective,  accountable  and 
law 
enforcement  agencies.  This  support  is  particularly  evident  through  grants  dedicated  to 
supporting enhanced digital transition335 (SDG No 10).  

through  support  of 

institutions 

inclusive 

331  Interviews with beneficiaries.  
332  PIF Report 2022. 
333  PIF Report 2022. 
334  European Commission, Anti-Fraud – Performance, Union Anti-Fraud Programme: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en. 

335  European Commission, Anti-Fraud – Performance, Union Anti-Fraud Programme: 

https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/programme-
performance-statements/anti-fraud-performance_en. 

182 

 
 
Many  respondents  highlighted  additional  benefits  beyond  the  scope  and  efficiency 
benefits already referenced. One beneficiary of technical assistance stated that the UAFP 
was  vital  to  ensuring  that  its  office  could  stay  up-to-date.  IT  develops  very  fast  and  is 
adopted very quickly by organised criminal groups and UAFP funding is a vital resource 
to keep pace with these developments336.  

Two beneficiaries of training activities reported that OLAF’s participation boosts interest 
and  incentivises  participation  in  training  and  conferences,  as  OLAF  funding  gives 
substantial credibility to the training activities and results in more participants337.  

Finally,  one applicant  for training activities stated that funding at  EU level  provides an 
additional  layer  of  EU  added  value  to  the  review  process.  At  national  level,  there  is  a 
much smaller circle of professionals, creating difficulties for neutral review of proposals. 
By contrast, EU funding ensures a neutral review process338. 

336  Interviews with beneficiaries. 
337  Interviews with beneficiaries. 
338  Interviews with beneficiaries.  

183 

 
 
 
 
ANNEX  IV.  OVERVIEW  OF  BENEFITS  AND  COSTS  -  SIMPLIFICATION  AND  BURDEN 
REDUCTION 

Table 1: Schematic overview of the benefits and costs identified in the evaluation 

The full details of this overview can be found in Annex 4 of the study report339 by ICF. 

DG OLAF 

Quantitati
ve 
(in 
EUR) 

MS Administrations 

Comment 

Quantitative 
(in EUR) 

Comment 

Hercule Component Costs 

to 

Grants 
MS 
administrations  (Direct 
compliance cost) 

Recurrent 
cost 

22,135,527  n/a 

n/a 

Recurrent 
cost 

7,557,981  n/a 

n/a 

n/a 

n/a 

Procurement  of  goods 
and services (for use by 
administrations) 
MS 
(Direct 
compliance 
cost) 

Administrative  burden 
associated 
with 
implementing  technical 
assistance  and  training 
sessions 
(e.g., 
processing applications, 
grants, 
disbursing 
conducting 
procurement, 
monitoring) 
compliance cost) 

(Direct 

to 

Administrative  burden 
associated 
with 
and 
applying 
reporting  on  received 
technical assistance and 
sessions 
training 
(Indirect  cost  –  given 
administrations 
MS 
to 
choose  whether 

Recurrent 
cost 

Not 
available 

n/a 

n/a 

Primarily 
labour  costs. 
Data 
on 
labour  time  / 
not 
expense 
available 
for 
interim 
evaluation.  

Recurrent 
cost 

n/a 

n/a 

Not available 

labour 
Primarily 
costs, 
although 
time  /  expense  not 
quantifiable  with 
available data. 

339 European Commission: European Anti-Fraud Office, Charitakis, S., Faion, M., Gounev, P., Vasileva, V. 
et al., Study in support of the Union Anti-Fraud Programme (UAFP) interim evaluation – Final study 
report, Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. 

184 

 
 
 
apply) 

Hercule Component Benefits 

Improved  capacity  of 
MS  administrations  to 
combat  and  prevent 
fraud  as  a  result  of 
technical assistance and 
sessions 
training 
funded  under  Hercule 
component 
(which 
enable  new  equipment 
improved 
purchases; 
data collection, analysis 
and 
sharing 
improved 
capabilities; 
knowledge  and  skills; 
and 
wider 
implementation  of  best 
practices) 
(Direct 
benefit) 

Reduced budgetary  and 
losses 
economic 
resulting 
fraud 
from 
(Indirect benefit) 

Improved  capacity  of 
MS  administrations  to 
combat  and  prevent 
fraud  as  a  result  of 
technical assistance and 
training 
sessions 
funded  under  Hercule 
(which 
component 
enable  new  equipment 
purchases; 
improved 
data collection, analysis 
sharing 
and 
capabilities; 
improved 
knowledge  and  skills; 
wider 
and 
implementation  of  best 

Recurrent 
benefit 

n/a 

n/a 

Not available.  Could 

be 
quantified  as  total 
monetary  value  of 
fraud 
additional 
but 
prevented, 
data 
insufficient 
currently  available 
for estimation.  

Recurrent 
benefit 

n/a 

n/a 

Not available 

be 
Could 
quantified  as  total 
additional 
prevented 
budgetary 
economic 
but 
data 
available 
estimation.  

and 
losses, 
insufficient 
currently 
for 

Recurrent 
benefit 

n/a 

n/a 

Not available.  Could 

be 
quantified  as  total 
monetary  value  of 
fraud 
additional 
but 
prevented, 
insufficient 
data 
currently  available 
for estimation.  

185 

 
Recurrent 
benefit 

n/a 

n/a 

Not available 

Could 
be 
quantified  as  total 
additional 
prevented 
budgetary 
economic 
but 
data 
available 
estimation.  

and 
losses, 
insufficient 
currently 
for 

Recurrent 
benefit 

n/a 

n/a 

Not available.  Could 

be 
quantified  as  total 
monetary  value  of 
fraud 
additional 
but 
prevented, 
data 
insufficient 
currently  available 
for estimation.  

practices) 
benefit) 

(Direct 

Reduced budgetary  and 
losses 
economic 
fraud 
from 
resulting 
(Indirect benefit) 

Improved  capacity  of 
MS  administrations  to 
combat  and  prevent 
fraud  as  a  result  of 
technical assistance and 
sessions 
training 
funded  under  Hercule 
component 
(which 
enable  new  equipment 
improved 
purchases; 
data collection, analysis 
and 
sharing 
improved 
capabilities; 
knowledge  and  skills; 
and 
wider 
implementation  of  best 
(Direct 
practices) 
benefit) 

AFIS Component Costs 

IT 
development, 
maintenance 
cost) 

studies, 
and 
(Indirect 

Recurrent 
cost 

Production 
(Indirect cost) 

services 

Technical 
assistance, 
training,  coordination, 
quality-control 
and 
services (Indirect cost) 

Recurrent 
cost 

Recurrent 
cost 

Acquisition, 
and 
maintenance 
updating  of  software 

Recurrent 
cost 

7,811,167  n/a 

n/a 

n/a 

3,499,788  n/a 

426,032 

n/a 

n/a 

n/a 

n/a 

n/a 

2,215,745  n/a 

n/a 

n/a 

186 

 
hardware, 
IT 

and 
related 
(Indirect cost) 

and 
services 

491,525 

n/a 

n/a 

n/a 

Recurrent 
cost 

Funds  co-delegated  to 
the  Directorate-General 
and 
for 
Taxation 
(DG 
Customs  Union 
TAXUD) 
(Indirect 
cost) 

Contingency 
cost) 

(Indirect 

One-off cost  1,528,896   n/a 

n/a 

n/a 

AFIS Component Benefits 

Recurrent 
benefit 

n/a 

n/a 

Improved  capacity  of 
to 
administrations 
combat  and  prevent 
fraud  as  a  result  of 
information 
improved 
and  mutual 
sharing 
assistance 
(Direct 
benefit) 

Full 
quantification 
of  benefit  not 
available. 
However, it has 
been  identified 
that: 

Reduced budgetary  and 
losses 
economic 
fraud 
from 
resulting 
(Indirect benefit) 

Recurrent 
benefit 

n/a 

n/a 

Not available 

Improved  capacity 
of  administrations 
to 
and 
combat 
prevent  fraud  as  a 
result  of  improved 
information 
sharing and mutual 
assistance 
(Direct 
benefit) 

Could 
be 
quantified  as  total 
additional 
prevented 
budgetary 
economic 
but 
data 
available 
estimation.  

and 
losses, 
insufficient 
currently 
for 

IMS Component Costs 

Development, 
maintenance, 
training, 
and  support  (Indirect 
cost) 

Recurrent 
cost 

1,589,230  n/a 

n/a 

n/a 

Contingency 
cost) 

(Indirect 

One-off cost  26,980  

n/a 

Recurrent 
benefit 

n/a 

n/a 

Reduced  costs  for  MS 
administrations 
in 
fulfilling 
irregularity 
reporting  requirements 
to the Commission as a 

n/a 

n/a 

n/a 

be 
Could 
quantified  as  total 
cost 
reporting 
but 
savings, 
data 
insufficient 

187 

 
currently  available 
for estimation. 

n/a 

n/a 

result  of  standardised 
simplified 
and 
reporting 
system 
(Direct benefit) 

Reduced  costs  for  the 
Commission 
in 
managing  irregularities 
data  reported  by  MS 
administrations  as  a 
result  of  standardised, 
consolidated 
reporting 
system (Direct benefit) 

Improved  capacity  of 
administrations 
to 
combat  and  prevent 
fraud  as  a  result  of 
searchable  database  of 
reported 
irregularities 
across 
countries 
reporting  to  the  IMS 
(Direct benefit) 

Recurrent 
benefit 

Not 
available 

be 
Could 
quantified  as 
total 
data 
management 
cost  savings, 
but 
insufficient 
data  currently 
available 
for 
estimation.  

Recurrent 
benefit 

n/a 

n/a 

Source: ICF analysis 

1.  Hercule component  

This section identifies the main costs and benefits associated with the Hercule component 
of the UAFP and compares these costs and benefits.  See also  Chapter 5.2 of the Study 
report by ICF on ‘efficiency’. 

1.1. Cost items 

Over two thirds of UAFP spending under the Hercule component during 2021 and 2022 
was  on  grants,  with  EUR  20.3  million  being  spent  on  technical  assistance  grants  and 
EUR  1.88  million  being  spent  on  anti-fraud  training  grants.  Of  the  EUR  7.44  million 
which  was  spent  on  procurement,  the  largest  item  (EUR  3.21  million)  was  the  digital 
forensics and analyst training (‘DFAT’).  

Table 2: Technical assistance and training spending (EUR)340 341 

Item / Year 

2021 

2022 

Total 

340  PIF Report 2021.  
341  PIF Report 2022. 

188 

 
 
 
 
Item / Year 

Grants 

2021 

2022 

Total 

Technical 
assistance grants 

10,678,299 

9,578,008 

20,256,307 

Anti-fraud 
training grants 

802,285 

1,076,935 

1,879,220 

Procurement 

IT databases 

  707,360 

707,360 

1,414,720 

IT 
and 
tools 
tobacco analysis 

717,961 

733,673 

1,451,634 

Procured 
conferences 

144,715 

1,165,845 

1,310,560 

1,414,000 

Digital  forensics 
and 
analyst 
training 

1,799,543 

3,213,543 

FCTC 

Total 

53,628 

0 

53,628 

14,518,248 

15,175,260  

29,693,508 

The spending figures provided above for grants describe the amounts in euro, disbursed 
by  the  UAFP  to  beneficiaries.  However,  these  figures  do  not  capture  additional 
administrative  costs  that  arise  for  beneficiaries  and  for  the  programme  (managers, 
OLAF). Administrative costs for beneficiaries include costs related to applying for grants 
and  to  monitoring  and  reporting  on  funded  projects,  while  administrative  costs  for  the 
programme include costs related to setting up annual work programmes; publishing and 
disseminating calls for proposals; and evaluating/selecting successful project proposals. 

Considering  beneficiary-side  administrative  costs,  it  is  difficult  to  quantity  the  typical 
time and human resources needed to  apply  for Hercule funding, as these varied greatly 
between applicant organizations, from a few days (minimum three days) to several weeks 
(up to three months)342. Although found to be efficient overall (as discussed further on), 
the  application  appears  to  represent  a  significant  undertaking  for  some  applicants,  with 
several  of  those  interviewed  noting  that  the  application  file  is  long  and  requires  many 
boxes to be filled out.  

The degree of variation in  time taken to  complete the application may be explained by 
several  factors.  These  include  the  groundwork  that  different  applicants  may  have  done 
before  the  call,  such  as  reaching  out  to  consortium  partners  and  providers,  and  their 

342  Interviews with beneficiaries. 

189 

 
 
 
 
 
 
familiarity  with  the  application  process.  Several  interviewed  applicants  also  noted  that 
the  application  is  less  time-consuming  to  complete  when  one  has  prior  experience  of 
filing an application343. 

1.2. Benefits  

In  2021-2022,  66  grants  were  distributed  under  the  UAFP’s  Hercule  component3.2.4. 
Seven  of  these  grants  were  scheduled  to  end  before  October  2023  344.  As  discussed  in 
relation  to  the  effectiveness  criterion,  thus  far,  the  grants  have  greatly  increased  the 
organisational  capabilities  of  the  recipients  in  a  range  of  areas.  Recipient  national 
authorities  are  resultantly  better  placed  to  combat  fraud  and  reduce  budgetary  and 
economic losses resulting from fraud.  

UAFP funding has helped national authorities with:  

-  Equipment  purchases:  the  UAFP  has  enabled  organisations  to  acquire  modern 
tools  with  higher  technical  standards  than  those,  which  their  other  (national  / 
own) funding may have allowed. The purchase of new state-of-the art equipment 
has contributed to the quality of forensic services, improving national authorities’ 
ability to detect fraud and prevent losses. 

-  Data collection, analysis and sharing: the UAFP has funded projects that make 
use  of  information  systems  that  are  able  to  collect,  automate  and  process  large 
volumes of data. This data contributes to investigations, increasing the likelihood 
of success at detecting and deterring fraud.  

-  Training: UAFP training has helped national authorities upgrade their knowledge 
and  practical  skills.  Authorities  can  apply  new  knowledge  and  skills  to  combat 
fraud more effectively, eventually reducing the impact of fraud on public funds. 
-  Networking,  exchanges  and  good  practices:  participants  in  training  and  other 
events,  such  as  study  visits  and  conferences,  have  developed  a  better 
understanding  of  how  colleagues  in  other  jurisdictions  tackle  corruption,  fraud 
and  collaborate  with  EU  agencies  and  authorities.  This  facilitates 
the 
implementation  of  best  practices  for  preventing  fraud  across  the  EU,  leading  to 
more effective national efforts against fraud.  
Investigations: the funded projects improve the sharing of data between national 
and European authorities, and between relevant national authorities, including tax 
and  police  authorities.  New  equipment;  data  analysis  capacity;  and  knowledge 
and  skills  may  also  make  investigations,  better  quality,  less  resource  intensive, 
and more likely to succeed, ultimately reducing the damaging impacts of fraud on 
public funds and the economy.  

- 

343  Interviews with beneficiaries. 
344  Key evaluation documents such as final technical reports and final implementation reports for these 

grants are not yet available for most projects. 

190 

 
 
 
However,  when  asked  about  the  extent  to  which  their  activities  under  the  UAFP  grant 
had contributed to cross-border cooperation, surveyed recipients provided mixed views. 
For each of several types of cross-border cooperation, a minority of respondents reported 
that  their  activities  under  the  UAFP  grant  had  contributed  “to  a  large  extent”  or  “to  a 
great extent”.  

These responses suggest that UAFP-funded interventions contribute to organisations’ 
capacities  to  fulfil  their  individual  mandates  but  have  lesser  benefits  in  terms  of 
improving EU-wide coordination and structures. These results, however, speak only 
to  the  perceptions  of  a  limited  sample  of  applicants  at  an  interim  stage  of  the 
implementation of their grant projects. A more thorough understanding of the benefits of 
different projects will only be possible once these have been completed and data reported 
to illustrate their outcomes. It should be noted that the survey results do not cover the full 
population  of  funded  entities.  Additionally,  projects  also  receive  funding  that  does  not 
stem  from  the  UAFP  (the  ‘national  part’,  minimum  20%  of  overall  project  costs), 
considered as national co-funding. As such, the benefits might not be attributable to the 
UAFP only. 

1.3. Comparison of costs and benefits 

The  UAFP-funded  interventions  under  the  Hercule  component  have  contributed  to  the 
organisational,  investigative,  and  technical  capacities,  among  other  capabilities  of 
applicants.  In  the  perception  of  grant  recipients,  UAFP  grant  costs  are  yielding 
benefits345. Applicants also do not view the administrative costs of applying for a grant as 
being particularly burdensome, indicating that the benefits are likely to outweigh these 
costs.  

It  should  be  noted  though  that  six  (out  of  12  successful  applicants)  responded  that  the 
costs (on the applicant’s side) related to the implementation of the project outweighed 
the  benefits  (at  least  a  “little")346.  In  addition,  the  UAFP  seems  to  have  led  to  cost-
savings, in different areas.  

In the area of evidence gathering, for example, the funds disbursed have contributed to 
the  acquisition  of  devices  that  allow  to  extract  data  already  at  the  crime  scene.  Such 
evidence can be used later in criminal proceedings. The adoption of such devices lead to 
cost-savings  compared  to  the  previous  situation;  whereas  previously,  the  investigative 
authorities had to seize devices and pay an expert fee in order to have the data extracted, 
the acquisition of a new device allows to already extract and save contents, which may be 
used as evidence without additional costs for subsequent expert involvement 347.  

345  Interviews with beneficiaries. 
346  Survey of applicants and beneficiaries, Question 15.4. 
347  Interviews with beneficiaries. 

191 

 
 
2.  AFIS component – costs and benefits 

This section identifies the main costs and benefits associated with the AFIS component 
of the UAFP and compares these costs and benefits.  See also  Chapter 5.2 of the Study 
report by ICF on ‘efficiency’348 

2.1. Cost items 

The largest AFIS spending item across 2021 and 2022 was IT studies, development, and 
maintenance, on  which  EUR 7.81 million was spent  (49% of total  spending). This  was 
followed  by  production  services  (EUR  3.50  million)  and  acquisition,  maintenance  and 
updating  of  software  and  hardware,  and  related  IT  services  (EUR  2.22  million).  These 
three items are also assigned the largest budget for 2023 (EUR 4.00 million, EUR 2.42 
million, and EUR 1.15 million respectively). 

Table 3: AFIS spending (EUR)349 350 

Item / Year 

2021 

2022 

2023 
(budgeted) 

Total 

4,056,540 

3,754,627 

3,995,000 

11,806,167 

1,750,021 

1,749,767 

2,420,000 

5,919,788 

194,797 

231,235 

405,000 

831,032 

 1,246,975 

968,770 

1,150,856 

3,366,601 

studies, 

IT 
development, 
and 
maintenance 

Production 
services 

Technical 
assistance, 
training, 
coordination, 
quality-
and 
control services 

Acquisition, 
maintenance 
and updating of 
and 
software 
hardware,  and 
IT 
related 

348 European Commission: European Anti-Fraud Office, Charitakis, S., Faion, M., Gounev, P., Vasileva, V. 

et al., Study in support of the Union Anti-Fraud Programme (UAFP) interim evaluation – Final study 
report, Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2784/1075235. 

349 PIF Report 2021.  
350 PIF Report 2022.  

192 

 
 
Item / Year 

2021 

2022 

2023 
(budgeted) 

Total 

 252,279 

239,246 

257,032 

748,557 

services 

co-
Funds 
delegated to the 
Directorate-
for 
General 
Taxation 
and 
Customs  Union 
(DG TAXUD) 

Contingency 

463,388 

1,065,508 

0 

1,528,896 

Total 

7,964,000 

8,009,153 

8,227,888 

24,201,041 

Source: ICF analysis 

The  overall  AFIS  spending,  in  both  2021  and  2022,  matched  the  budget  allocation.  In 
terms of time allocation (measured in person days),  ‘Application development’ was the 
most  resource  intensive  AFIS  activity  in  2021351,  2022352,  and  the  first  half  of  2023353 
(5,325354;  6,168;  and  3,197  person  days  respectively).  In  2021,  and  in  the  first  half  of 
2023, ‘Technology Stack’ was the next largest use of person days (1,957 and 732 person 
days  respectively),  but  in  2022,  the  second  largest  use  was  for  the  ‘Fraud  Analytical 
Platform’ (1,520 person days). The Fraud Analytical Platform was also the third largest 
use of person days in the first half of 2023 (533 person days).  

2.2. Benefits 

UAFP  funding  for  AFIS  yields  identifiable  benefits.  AFIS  is  used  by  9,000  registered 
end-users  in  countries  within  and  outside  of  the  EU355.  Survey  responses  from  AFIS 
users  indicate  that  AFIS  has  a  beneficial  effect  on  the  capacity  of  fraud  authorities  to 
carry out their duties. A majority of surveyed AFIS users do not agree with the statement: 
"in the absence of AFIS, I would be able to perform my duties using a similar existing 
national  system".  In  the  perception  of  users,  AFIS  effectively  improves  the  quality  of 
cooperation  between  law  enforcement  authorities  and  services  in  neighbouring 

351 European Commission (2022). Commission Implementing Decision on the financing of the Union anti-

fraud programme and the adoption of the work programme for 2022, C(2022) 1139. 
https://antifraud.ec.europa.eu/document/download/7824f63f-724b-486a-b7b9-
d8880e4d5456_en?filename=uafp_work_programme_2022_annex_en.pdf 

352 Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2023, C(2023) 813, 25.2.2022. 

353 Ibid. 
354 Data for January to November 2021.  
355 Figures shared with ICF by OLAF. 

193 

 
  
  
 
countries356. In this way, AFIS can help national authorities to reduce the monetary value 
of losses to public funds and the economy resulting from fraud.  

As an illustrative example, the 2021 PIF Report  highlights the work of the AFIS CIS+ 
module in the context of the new ‘Cash Control Regulation’, which was implemented in 
2021 – ‘In December 2021, six months after going live, CIS+ had more than 2,200 users 
and  contained  data  on  31,500  cash  declarations  and  1,800  infringements  of  the 
Regulation.’ 357  

In  the  first  five  months  of  2023,  CIS+  detected  an  average  of  9,573  cash  declarations 
with  infringements  per  month.  The  2022  PIF  report  highlights  that  AFIS  supported  ten 
joint  customs  operations  that  year.  These  data  provide  some  indication  of  the  benefits 
that AFIS, and UAFP funding for it, have in preventing and detecting fraud. 

At a technical and operational level, UAFP funding enables AFIS to continue delivering 
benefits for users – i.e., to continue performing its function as a secure portal for national 
and EU administrations to exchange information about fraud. The UAFP allows AFIS to 
be  improved,  as  well  as  maintained.  UAFP  funding  was  used  to  provide  eight  AFIS 
platform releases in 2021 (including CIS+, mentioned above) and 15 in 2022. In the first 
six  months  of  2023,  AFIS  delivered  61  minor  releases  across  ten  platforms358.  UAFP 
funding  also  allows  for  support  to  be  provided  to  AFIS  users.  Some  73%  of  surveyed 
AFIS  users  have  contacted  the  AFIS  IT  Helpdesk  in  the  past  two  years  and  the  vast 
majority (over 90%) are satisfied with the support received.  

2.3. Comparison of costs and benefits 

The above-mentioned benefits provide indicative evidence that the funding provided by 
the  UAFP  for  AFIS  enables  the  provision  and  improvement  of  a  useful  tool  for  end-
users.  Certain  modules  within  AFIS  –  in  particular,  the  CIS  –  appear  to  be  registering 
notable  achievements  in  terms  of  detecting  potential  cases  of  fraud.  AFIS  satisfaction 
surveys show that the respondents are overall very satisfied with the new functionalities 
and mention that the speed of access improves the efficiency of operations359. 

3.  IMS component – costs and benefits 

This section identifies the main costs and benefits associated with the IMS component of 
the UAFP and compares these costs and benefits.   

356 Interviews with beneficiaries, Survey of applicants and beneficiaries and evidence from desk research 

converge in showing these benefits.  

357 Ibid. 
358 Commission Implementing Decision on the financing of the Union anti-fraud programme and the 

adoption of the work programme for 2023, C(2023) 813. 

359 AFIS satisfaction survey (2023). 

194 

 
 
 
3.1. Cost items 

Thus far, 87% of spending on the IMS tool has gone towards development, maintenance, 
training, and support. IMS spending in both 2021 and 2022 has been within the budget 
allocation.  

3.2. Benefits 

UAFP  funding  enables  the  IMS  to  continue  performing  its  function  as  an  integrated 
irregularity reporting system used by around 3,230 end users in 34 countries within and 
outside of the EU360. The IMS allows national authorities to fulfil reporting obligations to 
the Commission in a standardised, simplified way. The absence of such a system would 
likely increase reporting costs for national authorities and the costs to the Commission of 
managing the collected data. Thus, the IMS facilitates the efforts of the EU and national 
authorities to use available fraud-prevention budgets as effectively as possible to prevent 
the damage done by fraud to public funds and the economy. 

As  discussed  under  the  effectiveness  criterion,  the  consulted  IMS  documentation 
identifies  several  features  of  the  IMS  which  contribute  to  its  perceived  usefulness, 
including its uniqueness as a database where past and/or closed cases of irregularities can 
be searched (12,455 irregularities were reported to the IMS in 2022). To the extent that 
the IMS helps national and EU authorities to identify, understand, and eventually prevent 
irregularities, including fraud, the ongoing functionality of this tool can be considered a 
benefit of the UAFP, which merits its continued funding and development.  

UAFP  funding  has  also  been  used  to  facilitate  improvements  in  the  IMS.  Four  new 
features  were  developed  and  released  in  each  of  2021  and  2022.  In  2021,  new  feature 
developments improved: reporting of RRF irregularities; uploading irregularities directly 
from  national  databases;  rights  of  IMS  country  officers;  and  uploading  of  reports  by 
business  owners361.  The  2022  PIF  Report  describes  new  feature  developments  in  that 
year  as  ‘allowing  business  managers  to  manage  code  list  values,  [improving]  the  B2B 
services and [fixing] a number of identified issues362.’ 

3.3. Comparison of costs and benefits 

The consulted documentation on IMS offers indicative evidence that UAFP funding for 
the  IMS  represents  an  efficient  use  of  resources,  at  least  in  the  perception  of  users. 
However, without more detailed data, it is difficult to understand the effects of the IMS 
on  the  ultimate  goals  of  protecting  the  EU’s  financial  interests  and  facilitating 
cooperation  between  Member  State  administrations  and  to  produce  a  complete  cost-
benefit analysis. 

360  Figures from IMS User Registration Tool data, shared with ICF by OLAF.  
361  PIF Report 2021.  
362  PIF Report 2022.  

195 

 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

1.  Introduction and stakeholder consultation strategy  

This Synopsis Report provides an overview of the results of the stakeholder consultation, 
carried out as part of the UAFP interim evaluation by the contractor ICF.  

It accompanies the final report of the study done by ICF in 2023-2024 and can be read in 
conjunction with it. Section 1 presents the methodological approach adopted by the team 
to carry out the consultations during the first 10 months of the study (May 2023 – March 
2024: stakeholders targeted and consulted, and mode of consultation used), while Section 
2  summarises  the  responses  and  findings  for  each  evaluation  question  and  by  mode  of 
consultation. 

2.   Approach to the consultation 

The  table  shown  below  provides  an  overview  of  the  consultation  activities  that  have 
taken place during the course of this study, up to the date of writing this report (17 May 
2024). The stakeholders targeted by the study team are presented, as well as the modes of 
exchange  with  them  and  the  number  of  interviews  or  responses  obtained  for  each. 
Stakeholders  were  selected  in  order  to  obtain  as  comprehensive  and  representative  a 
range of data and views as possible, and all these groups - at European, and national level 
were given the opportunity to share their views and experiences on the implementation of 
the  UAFP.  The  consultation  drew  on  a  range  of  complementary  methods,  including 
online surveys and semi-structured interviews. 

Table 1 - Consultation strategy activities and tools, by stakeholder group 

Stakeholder Group 

Consultation activities 

Number of responses 

Beneficiaries 

Survey 

Beneficiaries 

Interviews 

Applicants 

Applicants 

AFIS users 

Survey 

Interviews 

Survey 

IMS users 

Survey 

the  Council 
Delegates  of 
Working Party on Combating 
Fraud (GAF) 

Online survey 

European Commission 

Interviews 

196 

15 

25 

14 

3 

1320 (which includes IMS 
users) 

314 

3 

9 

 
3.  Online surveys 

Three surveys were launched as part of the initial data collection, targeting: 

•  Beneficiaries  of  the  UAFP's  Hercule  component  (both  technical  assistance  and 

training); 

•  Applicants of the UAFP's Hercule component (both applicants that do not know 

the results of their application and applicants that did not receive funding); 

•  GAF (Groupe antifraude) Delegates at the European Council; 
•  AFIS and IMS users. 

The survey of beneficiaries and applicants of the (Hercule component) of the UAFP was 
launched in August 2023 and closed mid-October 2023 (after a two-week extension). The 
GAF survey was also launched in August 2023 and closed mid-October 2023. Lastly, the 
AFIS  users’  survey  (which  included  users  of  IMS)  was  not  launched  by  ICF,  but  by 
OLAF.  ICF  contributed  to  the  questionnaire  of  this  survey.  ICF  received  the  raw  data 
results of the survey in February 2024. The surveys launched by ICF used the software 
Qualtrics. The overview of the respondents of the survey is presented below. 

4.  Overview of survey respondents 

Table 2: Survey respondents: Group, Member State, received replies 

Stakeholder Group 

Member State 

Number of responses 

Beneficiaries and Applicants  DE,  EL,  ES,  HR,  HU,  LT, 

29 

LV, PL, PT, RO, SK 

AFIS users 

Not provided 

1320 (including 314 IMS 
users) 

GAF  Delegates 

DE, EE, IT 

3 

Source: ICF analysis 

It should be noted that the GAF survey is not included in the summary, as the response 
rate was very low. The results of the scoping interviews are not presented, as they did not 
answer the research questions of the study.  

5.  Targeted interviews 

Targeted interviews were conducted during three phases: during the inception phase, the 
interim phase and the final phase.  

During  the  inception  phase,  nine  scoping  interviews  were  conducted  with  EU-level 
experts at the Commission (OLAF, DG JUST, HOME, and TAXUD) as well as with one 
beneficiary of the UAFP, and two scoping interviews with OLAF were completed in the 
interim phase. 

197 

 
The bulk  of the 43 interviews were conducted by the study team,  between late January 
2024 and late February 2024 (final phase), with the following target groups: 

•  Beneficiaries of the Hercule component; 
•  Applicants of the Hercule component; 
•  Staff members of the European Institutions; 
•  Stakeholders from AFIS and IMS. 

The study team developed pre-written questionnaires so as to ensure the comparability of 
the  answers  across  stakeholder  groups.  Most  of  the  interviews  were  conducted  through 
video calls, while some stakeholders provided their answers in writing. The study team 
prepared write-ups of each interview, which were then collated and structured in matrixes 
by stakeholder type and question to allow for easy comparison.  

In the final phase of the report, after assessing the information collected and the feedback 
from  OLAF, the study team  conducted a number of follow-up interviews with  selected 
stakeholders in order to fill data gaps and to answer questions emerging as a result of the 
previous analysis. 

It is crucial to acknowledge that despite the extensive number of interviews carried out, 
they  were  targeted  in  nature  and  reflect  the  perspectives  and  experiences  of  specific 
experts. Unlike surveys, these interviews were not designed to offer a comprehensive or 
representative overview but rather to complement and contribute to the data triangulation 
process. 

6.  Overview of interview participants 

Table 3: Overview of stakeholder groups, Member State, number of replies 

Stakeholder Group 

Member State 

Number of responses 

Beneficiaries 

DE, ES, FI, HR, HU, IT, LT, 
LV, LU, PL, RO 

Applicants 

NL, HU, PL 

European Commission 

IMS users 

DE, EL, ES, PL, RO 

Source: ICF analysis 

25 

3 

9 

6 

Lastly,  a  Call  for  Evidence  was  launched  by  the  European  Commission  between  22 
March  2023  and  3  May  2023.  Eight  members  of  the  public  replied.  Six  respondents 
provided opinions outside of the scope of this evaluation. Only one respondent actually 
expressed a view on the topic of the interim evaluation of the UAFP. 

They  stated  that  the  programme  would  benefit  from  this  interim  evaluation  through 
corrective measures with regard to improving its efficiency. 

198 

 
 
7.  Main stakeholder feedback per evaluation question  

7.1.  Effectiveness 

7.1.1.  Surveys 

The 2023 AFIS satisfaction survey gathered feedback from 1320 direct users of the AFIS 
system including users of the IMS programme. 

According  to  the  AFIS  satisfaction  survey,  the  AFIS  Helpdesk  has  effectively 
responded to the issues encountered by users. A minority of respondents has contacted 
the AFIS IT Helpdesk in the last two years363. The vast majority of these were satisfied 
with  the  availability  of  the  Helpdesk364,  and  more  specifically  with  the  quality  of 
solution, speed of response, speed of resolution, communication and follow-up provided. 
Therefore, the AFIS IT Helpdesk has been effective in providing support to users.  

The vast majority of AFIS functionalities satisfied the needs of users. This includes the 
AFIS  Library,  the  AFIS  Mail,  the  AMT,  the  ATIS,  CIS  +,  CSM,  FIDE,  IET,  MAS, 
ToSMA,  URT,  VOCU.  For  all  these  applications,  only  a  minority  of  respondents 
expressed some level of dissatisfaction.  

Most of the users are also satisfied with the IMS functionality and its performance365. 

The  separate  survey  of  beneficiaries  and  applicants  (Hercule  component)  confirmed 
that the interventions funded by the UAFP have been perceived as effective, contributing 
to the general and specific objectives of the programme. More specifically, 77% agreed 
(to a great or to a large extent) that the interventions have contributed to the improvement 
of  overall  work  related  to  prevention,  detection,  and  investigation  of  fraud  and  other 
illegal activities detrimental to the EU’s financial interests; 86% agreed the interventions 
have  improved  the  investigative  capacity;  69%  agreed  the  interventions  have  improved 
the operational capacity; and 71% agreed that the technical capacity has been improved.   

The  contribution  of  the  programme  to  transnational  cooperation  has  been  perceived  as 
positive  by  71%  of  respondents.  The  strongest  impact  was  on  cooperation  among  EU 
Member  States  (71%),  while  the  impact  on  cooperation  with  non-EU  countries  was 
relatively limited (about 2/3 of respondents believed the programme had made little or no 
contribution to cooperation with non-EU countries)366. 

Among the beneficiaries of the Hercule component,  73% confirmed that  the UAFP has 
contributed to  multi-disciplinary cooperation (with 40% saying  it  contributed to  a large 
extent, and 33%, it contributed somewhat to enhancing multi-disciplinary cooperation). 

363  AFIS satisfaction survey (2023), 27% have contacted the Helpdesk versus 73%. 
364  AFIS satisfaction survey (2023), 93% of respondents were satisfied with the Helpdesk service received. 
365  95% of IMS users are satisfied with the system’s performance.  
366  It should be noted that the applicants of the Hercule component of UAFP are encouraged to propose 

projects that involve non-EU countries. 

199 

 
 
The top main factors contributing to the effectiveness of the interventions, according to 
the respondents of the survey, are administrative capacity, internal procedures within the 
beneficiary's organization, and the amount of available funds and resources. 

Among  the  positive  factors,  the  amount  of  funds  and  resources  and  the  administrative 
capacity  were  mentioned  by  most  respondents  of  the  applicants'/beneficiaries'  survey 
(50%  and  43%  respectively).  The  clarification  support  provided  by  the  European 
Commission was also mentioned as a positive factor by 43% of the beneficiaries. 

The highest weight among the factors with negative impact respondents attributed to the 
lack of administrative capacity (mentioned by 36% of beneficiaries). Internal procedures 
in  the  beneficiary's  organisation  was  mentioned  by  29%,  and  the  amount  of  funds  and 
resources (or the lack of it) was mentioned by 21%. 

7.1.2.  Targeted interviews 

In relation to the overall effectiveness of the UAFP, the majority of beneficiaries (18 out 
of 20 interviewees) of grants for training and technical assistance provided under UAFP 
confirmed  that  their  projects  have  either  improved  their  work  linked  to  prevention, 
detection, and investigation of fraud and other illegal  activities detrimental  to  the EU’s 
financial  interests  or  will  be  effective  once  completed.  Only  two  beneficiaries  stated  it 
was too early to define the effectiveness of their projects. 

Among those claiming benefits, some had recently completed their projects, while others 
were  still  implementing  theirs  but  had  already  observed  improvements.  These 
improvements  included  increased  opportunities  for  mutual  assistance  and  cooperation, 
enhanced personnel knowledge and skills through training, and other exchanges such as 
conferences. 

Examples of effective contributions include: 

• 

Improved  investigative  and  surveillance  capabilities  through  the  acquisition  of 
state-of-the-art  communication  surveillance  equipment  and  upgrading  existing 
systems. 

• 

•  Enhanced  data  quality  and  evidence  collection,  along  with  improved  data 
exchange  with  partners  from  other  Member  States  and  EU  agencies  for  cross-
border investigations. 
Increased  performance  of  investigative  and  law  enforcement  authorities  through 
the  acquisition  of  equipment  and  software  enabling  higher  data  processing 
volume  and  speed.  This  includes  the  use  of  artificial  intelligence  and 
digitalization for activities like evidence  review, data classification, and  identity 
verification. 

•  One  beneficiary  highlighted  the  importance  of  the  programme's  flexibility  in 
allowing  them  to  conduct  research  work,  while  another  mentioned  that  the 
maximum  term  of  24  months  for  research  projects,  though  improved  from  the 
previous limit of 18 months, was still insufficient. 

200 

 
Regarding transnational cooperation, more than half of the interviewed beneficiaries (12 
out  of  20)  reported  that  their  projects  had  strengthened  the  transnational  cooperation. 
This  was  achieved  directly 
international 
conferences,  study  visits,  and  expert  training  across  multiple  countries,  or  indirectly 
through  improved  data  exchange  with  partners  from  other  Member  States,  responsive 
investigation requests, and participation in joint initiatives and operations. 

through  activities  such  as  organizing 

Furthermore, beneficiaries of technical  assistance grants  highlighted another avenue for 
enhancing  transnational  cooperation.  During  the  procurement  process,  they  conducted 
market research and engaged with counterparts in other Member States to gather insights 
on  the  equipment  and  software  they  planned  to  acquire,  thereby  gaining  valuable 
knowledge through these interactions. 

The  beneficiaries  emphasized  enhanced  cooperation  among  Member  States  as  well  as 
with EU institutions and agencies. Additionally, some mentioned cooperation with non-
EU  countries,  such  as  Switzerland  and  Turkey,  although  one  beneficiary  expressed  a 
desire to include Ukraine in project activities but faced limitations in doing so. However, 
most  beneficiaries  did  not  consider  cooperation  with  non-EU  countries  as  relevant  to 
their projects.  

In  terms  of  multi-disciplinary  cooperation,  the  overwhelming  majority  of  beneficiaries 
interviewed  (15  out  of  20)  emphasized  that  their  projects  have  significantly  enhanced 
multi-disciplinary  cooperation.  This  collaborative  effort  under  UAFP  has  brought 
together  various  experts,  including  law  enforcement  officers,  prosecutors,  tax  and 
customs  officials,  software  and  hardware  engineers,  communication  specialists, 
statisticians, economists, legal experts, project managers, and financial analysts. 

One beneficiary highlighted that the multi-disciplinary approach is a key strength of the 
programme and advocated for its continuation, emphasizing the importance of having all 
stakeholders interested in combating fraud by collaborating closely. They expressed the 
sentiment that having everyone involved in fighting fraud in the same room fosters more 
effective outcomes. 

With regard to the sustainability of results, the majority of beneficiaries claimed that the 
results of their projects would remain sustainable after the end of the intervention (17 out 
of 20 interviewees). For the beneficiaries of technical assistance, the sustainability of the 
acquired  systems  and  equipment  would  be  secured  through  regular  maintenance,  as 
national budgets are used to pay for the maintenance after the warranty period expires.  

The  beneficiaries  of  training  and  conferences  pointed  out  that  the  networking 
opportunities, in particular those involving cross-border collaboration, would last beyond 
the duration of the respective projects. 

Several IMS users interviewed during this evaluation study indicated that IMS is overall 
effective  in  that  it  provides  a  unique  source  of  information  on  irregularities  for  the 
Commission enabling the Commission to obtain this data for analysis and dissemination 
through the annual PIF reports. 

201 

 
Many interviewed IMS users indicated that, from their perspective, their use of IMS does 
not  necessarily  enhance  transnational  cooperation  as  their  own  use  is  focused  on  a 
national level. However, as noted above, interviewed IMS users also highlighted that this 
data is aggregated from all Member States and used in the PIF reports.  

Some  of  the  IMS  users  interviewed  identified  limitations  to  the  effectiveness  of  IMS 
overall  including  the  design  of  the  form  itself.  They  indicated  that  the  system  uses  a 
single  form  for  input  and  that  not  all  of  the  fields  included  in  the  form  are  considered 
relevant.  

Commission staff working with IMS provided context through the interviews for certain 
limitations  with  the effectiveness  of  IMS  including  the declining  satisfaction rates. The 
Commission  identified  that  the  IMS  system  is  undergoing  a  major  upgrade  but  that 
progress so far has not been visible to end users.  

The  Commission  also  identified  that  no  major  training  since  2017.  According  to  the 
interview, the current budget allocation is not sufficient to support major upgrades such 
as  changes  to  the  user  interface,  major  training  activities  on  IMS,  or  increased 
interoperability with other systems. 

The Commission also identified that the scope of IMS would be expanded to include the 
West  Balkans  and  Ukraine,  which  would  necessitate  additional  financial  and  human 
resources for IMS.  

Interview participants from AFIS highlighted the continued satisfaction of end users with 
the AFIS system as well as feedback received during the recent evaluation of Regulation 
515/97  highlighting  the  importance  of  AFIS  as  a  unique  system  providing  an  effective 
and secure channel of communication for customs antifraud purposes.  

The  interview  highlighted  in  particular  the  benefit  to  mutual  cooperation  provided 
through AFIS between both Member States and non-EU countries. Several AFIS systems 
including  AFIS  mail  as  well  as  participation  in  Joint  Customs  Operations  (JCOs)  are 
open  to  participation  from  non-EU  countries  and  that  OLAF  provides  further  support 
with  the  installation  of  dedicated  IT  systems  (VOCU)  and  operational  rooms  (POCU). 
The  interview  highlighted  that  feedback  from  users  indicates  a  very  high  level  of 
satisfaction  among  end  users  for  systems  such  as  VOCU  and  that  the  JCOs  are 
considered to be highly valuable by Member States.  

The AFIS interview did highlight a few potential limitations to the effectiveness of AFIS 
including  the  range  of  data  collected  in  the  “container  message  status”  (CMS)  and 
“import,  export,  transit”  (IET)  directories,  the  issue  of  multiple  reporting  in  the  CIS 
system, and the lack of cases reported/engagement by all Member States with the FIDE 
system.  

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7.2.  Efficiency 

7.2.1.  Surveys 

According to the survey of (Hercule component) beneficiaries and applicants, overall, 
as  a  result  of  the  UAFP,  national  organisational  units  with  investigative  authority  have 
used  more  efficiently  their  resources  to  fight  effectively  serious  crimes  that  harm  the 
financial interests of the EU. While it is not possible to quantify the time spent on project 
application,  based  on  the  data  available,  it  is  however  possible  to  conclude  that  the 
application process has significantly improved compared to the previous programme.  

From the perspective of the applicants, assessing the time and human efforts involved in 
the  application  process  is  rather  difficult,  either  because  of  lack  of  internal  tracing,  or 
because  of  great  discrepancy  in  the  amount  of  efforts  of  different  organizations. 
Moreover,  applicants  were  satisfied  with  the  level  of  clarity  and  streamlining  of  the 
application process, as well as with the level of guidance received 

Concerning  the  application  process,  the  application  procedure  was  also  efficient  in 
avoiding  needless  repetitions  of  the  submitted  information  throughout  the  application 
process:  most  survey  respondents  stated  that  they  were  not  asked  to  input  the  same 
information several times, which would have added unnecessary administrative and time-
consuming  steps.  Survey  respondents  were  satisfied  with  the  instruction  and  guidance 
received for preparing their application.  

The AFIS satisfaction survey provides little to no information on the cost-savings which 
resulted  from  the  AFIS  and  IMS  new  functionalities,  while  it  provided  a  wealth  of 
information on the benefits for the programme effectiveness.  

7.2.2.  Targeted interviews 

Regarding  the  application  process,  it  is  challenging  to  quantify  the  time  and  resources 
required.  Beneficiaries  reported  that  it  ranged  from  several  days  (minimum  3  days)  to 
several weeks (up to 3 months), encompassing conceptualization, proposal planning, and 
drafting.  Organizations  with  prior  groundwork  and  established  partnerships  spent  less 
time  on  applications.  Results  regarding  the  comparison  of  application  times  between 
editions were mixed. 

Targeted  interviews  provided  a  detailed  overview  of  observable  project  benefits, 
although  full  assessment  was  hindered  by  project  implementation  status.  Key  areas 
relevant to OLAF’s mandate include: 

•  Equipment  Acquisition:  Beneficiaries  noted  significant  benefits  from  UAFP 
Hercule  grants  in  acquiring  advanced  equipment,  enhancing  efficiency  and 
forensic capabilities while supporting budgetary efficiency. 

•  Data  Collection  and  Exchange:  Grants  improved  fraud-related  data  collection, 
analysis, and exchange among organizations, enhancing overall effectiveness. 

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•  Training:  Hercule-funded  training  improved  knowledge,  technical  skills,  and 

cooperation among participants, enhancing efficiency. 

•  Relationship  Building: Hercule  component  facilitated  relationship  building,  best 

• 

practice sharing, and information exchange among organizations. 
Investigations:  Data  exchange  via  AFIS  and  IMS  platforms,  equipment 
acquisition, and best practice sharing accelerated investigation processes. 

However, stakeholders provided limited information on cost-savings from AFIS and IMS 
platforms, impacting cost-benefit analysis. 

One of the IMS country officers interviewed indicated that systematic review of the IMS 
has helped improve the efficiency of preparing the annual PIF report. Many of the IMS 
country officers interviewed, however, responded that they either observed no issues with 
the efficiency in terms of funds available or were not best placed to respond.  

The interview with AFIS business manager that, while overall they consider AFIS to be 
efficient,  evolving  technologies  require  increased  budget  allocation  in  order  to  ensure 
continued quality of services. The interview highlighted that developing analytical tools 
to explore data in order to protect and prevent customs fraud has been highlighted as a 
priority by users but would require additional funding to speed up this development. The 
interview  further  highlighted  that  the  flexibility  clause  regarding  the  UAFP’s  budget 
could  be  used  more  proactively  in  order  to  reinforce  the  financial  envelope  especially 
when yearly allocations have not been spent.  

7.3.  Coherence 

7.3.1.  Surveys 

Information  on  coherence  was  provided  by  stakeholders  through  the  survey  for 
applicants – including beneficiaries.  

On  internal  coherence,  the  survey  with  applicants  for  funding,  including  beneficiaries, 
gathered  information  on  the  Hercule  component.  The  results  of  the  survey  clearly 
indicated a significant level of coherence among the eligible activities under the call for 
proposals  for  the  Hercule  component,  and  coherence  between  the  calls  for  technical 
assistance and the calls for training, conferences, staff exchanges and studies (as per the 
Figure below). 

For external coherence, data from the survey with applicants for funding under the UAFP 
point  to  coherence  (strongly  agree  around  35%;  and  agree:  around  57%)  between  the 
calls for proposals (launched under the UAFP) and other EU anti-fraud instruments. 

7.3.2.  Targeted interviews 

Regarding the coherence analysis, interviews were conducted with representatives from 
various  Directorates-General  of  the  European  Commission  and  beneficiaries  to 
evaluate both internal and external coherence of the UAFP. 

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For internal coherence among the three components (Hercule, AFIS, IMS), Commission 
officials  reported  positive  aspects  such  as  reduced  administrative  burden  and  improved 
coherence  due  to  the  new  structure  introduced  by  the  UAFP  Regulation.  However, 
challenges  include  insufficient  regular  meetings  among  component  managers  and 
underdeveloped cooperation in funding determination, content preparation, and resource 
allocation.  

Beneficiaries  generally  found  the  activities  under  the  components  complementary  but 
suggested more synergies, coordination, and knowledge sharing. 

Regarding  external  coherence  with  other  EU  legislation/programmes,  interviews 
confirmed  overall  coherence.  Efforts  were  made  to  ensure  cooperation  between  OLAF 
and relevant Directorates-General to avoid duplications and increase synergies. However, 
greater  coordination  and  synergies  are  recommended,  particularly  between  OLAF  and 
other relevant Directorates-General, to achieve a high-level overview of coherence status 
among programmes. 

The highest risk of duplication was identified between UAFP and CCEI, which focus on 
similar beneficiaries but differ in scope and budget. To mitigate duplication, guidance is 
provided  to  distinguish  potential  duplication  or  overlap  of  funding  between  the  two 
programmes. 

the  possibility  of  one  overarching 
Stakeholder  suggestions 
programme/fund  addressing  fraud  and  coordinating  between  Directorates-General  to 
monitor fraud tendencies at EU and regional levels. 

included  assessing 

Regarding key EU horizontal objectives, UAFP was seen as potentially supporting digital 
transition through funding for new digital equipment and climate actions through support 
for  energy-efficient  equipment.  However,  concerns  were  raised  regarding  the  actual 
implementation  of  projects  in  line  with  energy-efficient  standards  due  to  national 
procurement processes favouring the lowest bidder. 

Overall,  while  the  UAFP  has  made  strides  in  coherence,  there  are  opportunities  for 
improvement  in  internal  cooperation  and  coordination  with  other  programmes  to 
maximize effectiveness and address key objectives. 

7.4.  Relevance 

7.4.1.  Surveys 

The majority of beneficiaries stated that the specific objective of the UAFP “to prevent 
and  combat  fraud,  corruption  and  other  illegal  activities  affecting  the  EU’s  financial 
interests” was relevant to its general objective to protect the EU’s financial interests, with 
46.7% agreeing with this statement and 46.7% strongly agreeing.  

The majority of beneficiaries stated that the eligible activities under the call for proposals 
were  clearly  relevant  to  the  specific  objective  of  the  programme,  with  66.7%  agreeing 
with this statement and 26.7% strongly agreeing. They also indicated that the goals and 

205 

 
eligible  activities  of  the  call  for  proposals  were  covering  all  their  operational  needs 
related  to  the  protection  of  EU  financial  interests,  with  86.7%  agreeing  with  this 
statement and 6.7% strongly agreeing. 

In  addition,  the  majority  of  applicants  pointed  out  that  the  specific  objective  of  the 
UAFP “to prevent and combat fraud, corruption and other illegal activities affecting the 
EU’s  financial  interests”  was  relevant  to  its  general  objective  to  protect  the  EU’s 
financial interests, with 46.7% agreeing with this statement and 46.7% strongly agreeing.  

Moreover,  the  majority  of  applicants  provided  that  the  eligible  activities  under  the  call 
for  proposals  were  clearly  relevant  to  the  specific  objective  of  the  programme,  with 
73.3%  agreeing  with  this  statement  and  26.7%  strongly  agreeing.  The  majority  of 
applicants also stated that the goals and eligible activities of the call for proposals were 
covering  all  their  operational  needs  related  to  the  protection  of  EU  financial  interests, 
with 66.7% agreeing with this statement and 13.3% strongly agreeing. 

Lastly,  all  applicants  have  stated  that  it  was  clear  how  the  call  for  proposals  was 
effectively  contributing  to  the  objectives  of  the  programme,  with  35.7%  agreeing  with 
this statement and 64.3% strongly agreeing. It was also clear to a majority of applicants 
that  their  response  to  the  call  for  proposals  needed  to  demonstrate  how  they  would 
contribute to the objectives of the programme effectively.  

Regarding  the  2023  AFIS  satisfaction  survey,  a  majority  of  AFIS  users  stated  that  the 
applications  they  most  frequently  use  respond  to  their  professional  needs,  with  23% 
slightly agreeing with this statement and 59% agreeing. The level of satisfaction of AFIS 
users in the functionality of AFIS applications was high on average, with 81% across all 
applications.  The  Mutual  Assistance  System  (MAS)  is  the  highest-rated  application  in 
this regard, with 94% satisfaction.  

A majority of AFIS users also indicated that the available applications in AFIS provide 
up-to-date  tools  to  tackle  latest  trends  regarding  the  crime  of  fraud  and  related 
irregularities, with 25% slightly agreeing and 40% agreeing. 

While  IMS  is  the  AFIS  application  with  the  lowest  rate  of  satisfaction  in  terms  of 
functionality, the satisfaction rate remains high at 87.5%. 

7.4.2.  Targeted interviews 

Overall, beneficiaries interviewed expressed a positive outlook on the specific objectives 
of  the  UAFP.  Five  beneficiaries  emphasized  the  relevance  of  these  objectives  to  the 
programme's  overarching  goals.  One  beneficiary  noted  that  the  general  objectives 
effectively cover the needs of users across most Member States and should remain broad. 
The objective aimed at supporting mutual assistance and cooperation was highlighted as 
particularly pertinent by one interviewee, leading to a noticeable increase in cooperation. 

Six beneficiaries affirmed the continued relevance of the programme's specific objectives 
to  emerging  trends  in  the  fight  against  fraud.  Additionally,  one  beneficiary  mentioned 

206 

 
that  their  project  work  had  contributed  to  identifying  new  crime  trends  in  their  field. 
Suggestions were made regarding areas of fraud that should receive more attention in the 
UAFP, including VAT frauds, frauds of bad faith, and tobacco smuggling frauds.  

Another  suggestion  was  to  include  topics  such  as  fraud  investigation  procedures  and 
prosecution in training calls. Furthermore, one participant proposed adding an objective 
focused  on  combating  "technology-enabled  fraud,"  emphasizing  the  importance  of 
addressing cybercrime separately. 

Several beneficiaries noted that activities conducted under the programme were relevant 
or  highly  relevant  to  achieving  its  specific  objectives.  Applicants  generally  agreed  that 
the  specific  objectives  were  relevant  both  to  the  programme's  overarching  goals  and  to 
their own needs as potential beneficiaries. Some emphasized that training projects could 
benefit from a stronger focus on research alongside training and dissemination. 

Regarding  the  relevance  of  specific  objectives  to  emerging  trends,  most  applicants  had 
limited perspectives but received positive feedback from colleagues. Differences in how 
fraud  develops  between  Member  States  made  it  challenging  to  assess  relevance 
uniformly. 

Overall,  most  applicants  considered  the  programme's  activities,  as  reflected  in  the  calls 
for proposals, relevant to its specific objectives and capable of addressing research gaps 
in their respective fields. 

The interview conducted with AFIS business managers provided further insight into the 
mechanisms  used  to  ensure  that  AFIS  stays  relevant  to  the  needs  of  its  end  users.  The 
interview highlighted that AFIS end users both within OLAF and in the Member States 
are involved early on in the development of AFIS systems through dedicated workshops 
and training sessions. OLAF also receives user input through expert group sessions and 
the user satisfaction survey.  

An interview with OLAF staff identified potential  challenges to maintaining relevance, 
specifically challenges related to adopting new hardware and software in order to ensure 
OLAF  support  stays  relevant  to  the  needs  of  beneficiaries.  Developing  additional 
capacity  to  support  AI  operations  could  help  solve  challenges;  however,  the  hardware 
and software costs are significant. Providing these items across all Member States could 
not be achieved with the current allocation of funding and would require an increase in 
the  programme  funds.  The  interview  further  identified  that  developing  additional 
capacity relating to satellite imagery would be beneficial to support customs operations.  

7.5.  Added Value 

7.5.1.  Surveys 

The survey of beneficiaries provided valuable insights, although not conclusive, into the 
added  value  of  the  UAFP.  Survey  results  indicated  that  UAFP  funding  has  generally 
contributed to expanding the scope of interventions and improving their delivery process. 

207 

 
A  majority  of  respondents  indicated  a  significant  benefit  to  the  scope  of  intervention 
(46.2  percent),  while  others  noted  at  least  some  benefit  (7.7  percent  responding 
somewhat beneficial). However, a notable portion of respondents either did not know the 
overall benefit or found the question not applicable (38.5 percent of respondents). 

The survey of AFIS users returned mixed results regarding the perceived added value of 
AFIS.  While  many  respondents  indicated  they  could  not  perform  their  duties  using  an 
existing national system, many others indicated that they either could perform the same 
duties on an existing national system or that they did not have an opinion.  

Respondents were asked whether, in the absence of AFIS, they could perform their job 
duties  using  a  similar  existing  national  system.  Out  of  1320  respondents,  37  percent 
either slightly disagreed  (13 percent) or disagreed (24 percent) that they  could perform 
their job  duties using  a  similar national  system.  Only slightly fewer AFIS users agreed 
(20 percent) or slightly agreed (13 percent) that they could perform their job duties in the 
absence  of  AFIS.  Finally,  a  large  number  of  respondents  (30  percent)  replied  that  they 
did not have an opinion. 

7.5.2.  Targeted interviews 

In  general,  interview  participants  overwhelmingly  agreed  that  the  UAFP  programme 
offers significant added value, with many considering it indispensable to their work. 

Beneficiaries  conducting  technical  assistance  projects  under  the  Hercule  component 
emphasized that the support provided by UAFP is more specialized than what is available 
at  the national  level.  With  UAFP funding, they  were able to  acquire highly  specialized 
equipment  and  arrange  necessary  training,  which  would  have  been  challenging  with 
national-level  support.  Some  applicants  noted  that  they  had  previously  attempted  to 
secure funding at the national level for similar projects but were rejected due to budget 
constraints. 

While a few participants acknowledged that their projects could have been feasible at the 
national level, they highlighted the enhanced effectiveness and quality achieved through 
UAFP funding. 

Participants in training activities agreed that similar projects could not be completed with 
support solely from the national level. Many stressed the necessity of EU-level funding 
for  enabling  research  relevant  to  protecting  the  EU's  financial  interests,  as  national 
funding often prioritizes local issues. 

Respondents widely agreed that the research funding provided under UAFP addresses a 
unique  niche,  covering  topics  crucial  to  safeguarding  the  EU's  financial  interests  that 
might otherwise go unfunded. 

Few  respondents  provided  detailed  information  about  the  efficient  use  of  financial 
resources, citing the lack of comparable funding sources as a reason. 

208 

 
Several  respondents  noted  additional  benefits  beyond  efficiency,  such  as  staying  up  to 
date  with  rapidly  evolving  IT  technologies,  increased  credibility  and  participation  in 
training activities due to OLAF's involvement, and a neutral review process facilitated by 
EU-level funding. 

Overall, interview participants underscored the vital role of UAFP funding in supporting 
their work and addressing critical research gaps that would otherwise remain unfunded. 

209 

 
 
 
ANNEX  VI.  LEGISLATIVE  BACKGROUND  OF  COUNCIL  REGULATION  (EC)  NO 
515/97 AND ITS ROLE IN THE PROTECTION OF THE FINANCIAL INTERESTS OF THE 
EU367 (CONTINUATION OF CHAPTER 2.1.1.4 ABOVE) 

1.  Introduction 

Council Regulation (EC) No 515/97 of 13 March 1997 (‘Council Regulation 515/97’) on 
mutual  assistance  between  the  administrative  authorities  of  the  Member  States  and 
cooperation between the latter and the Commission, to ensure the correct application of 
the  law  on  customs  and  agricultural  matters,  together  with  the  UAFP  Regulation, 
are  the  cornerstones  of  mutual  assistance  in  customs  and  agricultural  matters  at 
European  level.  Effective  cooperation  in  these  fields  strengthens  the  protection  of  the 
financial interests of the Union and contributes to the safety and health of citizens and 
the protection of the environment.  

Council  Regulation  515/97  sets  out  the  rules  under  which  customs  and  agriculture 
administrations may cooperate administratively at bilateral and Union level to ensure the 
correct  application  of  customs  and  agriculture  law.  This  cooperation  is  carried  out  by 
using  mutual  administrative  assistance  mechanisms  in  the  form  of  exchange  of 
information, joint operational actions, training courses or collection of evidence and 
other support provided during administrative enquiries. 

It  can  take  place  between  Member  States  or  between  these  and  the  Commission  or  at 
international  level  with  non-EU  countries.  The  nature  and  outcome  of  such  activities 
varies  considerably  in  terms  of  duration,  number  of  authorities  involved,  allocated 
resources and necessary efforts to achieve the proposed aim. 

The first legal instrument setting up the provisions for mutual assistance in the customs 
domain  was  the  Naples  Convention  (later  known  as  ‘Naples  I  Convention’)  adopted  in 
1967, which recognised that cooperation between customs administrations would help to 
ensure accuracy in the collection of customs duties and other import and export charges 
investigating  and  prosecuting 
and 
contraventions of customs laws. It covered all customs aspects.  

the  effectiveness  of  preventing, 

improve 

After the creation of the Customs Union in 1973, the Commission made a proposal for a 
Regulation  on  mutual  assistance  between  Member  States  and  cooperation  with  the 
Commission in customs and agricultural matters. This proposal was adopted in 1981 as 

367 Source: Commission Staff Working Document, SWD(2013) 428, 15.12.2023, Evaluation of Council 

Regulation (EC) No 515/97 on mutual assistance between the administrative authorities of the Member 
States and cooperation between the latter and the Commission to ensure the correct application of the 
law on customs and agricultural matters. 

210 

 
 
Regulation  1468/81368.  Regulation  1468/81  became  the  counterpart  of  Naples  I  for  EU 
aspects, while this Convention applied for issues not covered by the new Regulation. 

In 1997, as  part of a far-reaching  reform, Regulation  1468/81  was replaced by Council 
Regulation  (EC)  No  515/97.  One  of  the  main  achievements  was  the  creation  of  a 
database  for  the  collection  and  storage  of  customs  information  at  European  level  for 
anti-fraud purposes. This database was named Customs Information System (CIS). The 
aim of CIS is to  assist in the prevention, investigation and prosecution of operations in 
breach of customs  and agricultural  legislation by increasing,  by means of a more  rapid 
circulation of information, the effectiveness of the cooperation and control procedures of 
the competent authorities. 

The  Naples  II  Convention,  introduced  in  1997,  replaced  the  previous  Naples 
Convention  with  a  view  to  preventing  and  detecting  infringements  of  national  customs 
provisions  and  prosecuting  and  punishing  infringements  of  Community  and  national 
customs provisions not harmonised at Union level.  

The second convention, the CIS Convention369 adopted in 1995, focused on the use of 
information technology for customs cooperation in areas of the competence of Member 
States.  In  2009, 
in  Council  Decision 
2009/917/JHA (CIS Decision)370. 

the  CIS  Convention  was 

transformed 

These  two  legal  instruments  relate  to  cooperation  activities  in  the  fight  against 
criminal  offenses,  established  by  Member  State  national  laws  and  falling  under 
Article 87 of the Treaty on the Functioning of the European Union (TFEU).  

Together  with  Council  Regulation  515/97,  they  cover  the  customs  mutual  assistance 
spectrum at EU level. 

The  mutual  assistance  with  non-EU  countries  is  based  on  mutual  administrative 
assistance (MAA) provisions, often in the form of a protocol, in international cooperation 
or  free  trade  agreements.  Regulation  515/97  complements  the  MAA  provisions  under 
international  agreements,  allowing  information  to  be  communicated  to/exchanged  with 
third countries that do not have an international agreement with the Union. 
In 2008, Regulation (EC) No 766/2008371 of the European Parliament and of the Council 
amended Council Regulation 515/97 and introduced two new IT systems: 

368 Council Regulation (EEC) No 1468/81 of 19 May 1981 on mutual assistance between the administrative 
authorities of the Member States and cooperation between the latter and the Commission to ensure the 
correct application of the law on customs or agricultural matters. 

369 Convention of 26 July 1995 on the use of information technology for customs purposes (OJ C 316, 27.11.1995, p. 

33). 

370 Council Decision 2009/917/JHA of 30 November 2009 on the use of information technology for customs purposes 
371 Regulation (EC) No 766/2008 of the European Parliament and of the Council of 9 July 2008 amending Council 
Regulation (EC) No 515/97 on mutual assistance between the administrative authorities of the Member States 
and cooperation between the latter and the Commission to ensure the correct application of the law on customs 
and agricultural matters. 

211 

 
 
- 

- 

the transport directory, a directory of data reported by carriers to detect movements of 
goods that are the object of operations in potential breach of customs and agricultural 
legislation, and the means of transport used for that purpose; and 
the  Customs  Files  Identification  Database  (FIDE)  which  contains  data  about 
companies  or  persons  subject  to  investigation  by  the  customs  or  agriculture 
authorities. FIDE was also integrated in the CIS Decision. 

In 2015, Regulation  (EU) 2015/1525  of the European Parliament  and of the Council372, 
which has applied since 1 September 2016, introduced the directory for Container Status 
Messages (CSMs) and the directory for Import, Export and Transit (IET). 

Over  time,  a  reference  to  the  Regulation  was  included  in  a  number  (altogether  19)  of 
specific legal instruments as support for mutual administrative assistance purposes. 

The Anti-Fraud Information System (AFIS) was set up by the Commission in 1997 as the 
single  technical  infrastructure  hosting  the  various  IT  applications  for  the  storage  and 
exchange  of  information  for  the  purposes  of  the  Regulation.  The  AFIS  system  is 
available to users in Member States, partner third countries, international organisations, 
Commission services and other EU Institutions. 

The  information  exchanged  by  Member  States  can  be  used  by  the  Commission  to 
disseminate  fraud  alerts  to  Member  States  (usually  in  the  form  of  mutual  assistance 
communications) or to initiate administrative enquiries. 

The access to AFIS and its applications is granted by the AFIS liaison officers designated 
in each Member State. 

2.  Objectives 

Two main objectives were set at the last revision of Council Regulation 515/97, initiated 
in 2013:  

1.  Increase  the  detectability,  prevention  and  prosecution  of  breaches  of  customs  and 
agricultural  legislation by enhanced  collaboration both  between the Member States and 
between the Member States and the Commission: 

Improve the process related to customs mutual assistance; 

- 
-  Create  conditions  for  improved  fighting  of  customs  fraud  especially  related  to  mis-
declaration of goods' origin, to mis-description of goods to misuse of the transit 
system, and to undervaluation; 
Improve the availability and management of customs data. 

- 

372 Regulation (EU) 2015/1525 of the European Parliament and of the Council of 9 September 2015 
amending Council Regulation (EC) No 515/97 on mutual assistance between the administrative 
authorities of the Member States and cooperation between the latter and the Commission to ensure the 
correct application of the law on customs and agricultural matters (OJ L 243, 18.9.2015, p. 1–12), ELI: 
http://data.europa.eu/eli/reg/2015/1525/oj.  

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2.  Improve the process related to administrative enquiries in the area of customs mutual 
assistance. 

The provisions of Council Regulation 515/97 are meant to contribute to the achievement 
of these objectives. 

3.  Agricultural matters 

Council  Regulation  515/97  sets  the  provisions  for  mutual  administrative  assistance  in 
agricultural matters in particular, where specific provisions are not established under the 
related legislation. 

'Agricultural legislation' is defined by the Regulation as the body of provisions adopted 
under the common agricultural policy and the special rules adopted with regard to goods 
resulting from the processing of agricultural products. 

In  order  to  ensure  that  the  competent  authorities  are  able  to  respond  quickly  to  health 
emergencies,  tracking  and  tracing  of  movements  of  products  subject  to  agricultural 
legislation is of utmost importance. To ensure that such goods are tracked and traced at 
all  stages  of  movement,  information  should  be  provided  concerning  importation, 
exportation,  transit,  temporary  storage  and  intra-EU  movements  of  such  goods.  This 
information is exchanged using the Customs Information System (CIS). 

4.  Customs matters: scope and definitions 

Council  Regulation  515/97  starts  by  stating  its  scope  and  providing  key  definitions 
(Articles  1-3)  to  ensure  a  consistent  understanding  and  application  by  the  parties 
involved. 

5.  Assistance on request 

The rules  for  assistance  on request  of another Member State’s authority  are defined by 
Articles 4-12 of Council Regulation 515/97. 

At  request  of  an  authority  of  another  Member  State,  Members  States’  authorities  shall 
transmit any information that enable to ensure compliance with the provisions of customs 
or  agricultural  legislation.  In  order  to  obtain  this  information,  the  requested  authority 
shall proceed as though acting on its own account or at the request of another authority in 
its  own  country.  This  information  shall  include  any  related  attestation,  document  or 
certified true copy of a document in its possession. 

At  request  of  the  applicant  authority,  the  requested  Member  State  shall  notify  the 
addressee  of  all  instruments  or  decisions,  which  emanate  from  the  administrative 
authorities  and  concern  the  application  of  customs  or  agricultural  legislation.  The 
requests for notification shall mention the subject of the decision and be accompanied by 
a translation in the official language of the requested Member State. 

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Member  States  shall  carry  out  administrative  enquiries  on  request  of  another  authority 
related to operations that are or appear to constitute breaches of customs or agricultural 
legislation.  The  results  of  the  administrative  enquiries  shall  be  communicated  to  the 
requesting authority. 

Information  or  documents  obtained  by  recourse  to  mutual  assistance  may  constitute 
admissible evidence in administrative and judicial proceedings of the requesting Member 
State, unless explicitly stated when the information is provided. 

6.  Special watch on persons, goods and means of transport 

Where  there  are  reasonable  grounds  of  suspicion  of  breaches  in  the  customs  or 
agricultural  legislation,  Member  States  authorities  shall  keep  or  arrange  for  a  special 
watch  on  persons  and  their  movements,  on  places  where  goods  are  stored,  on  the 
movements of goods and on means of transport. This special watch is done on their own 
initiative  or  at  request  of  another  Member  State  or  the  Commission  and  take  often  the 
format of a joint  customs operation (JCO). A JCO is  an operational  action of a limited 
duration of time and with targeted measures, coordinated and jointly implemented by the 
Member  States  or  by  these  and  the  Commission,  for  combating  cross-border  illicit 
trafficking of goods. 

Special watch actions, including JCOs are organised with multiple objectives: 

-  To  improve  practical  cooperation  between  the  participant  customs  administrations, 
between  customs  and  the  European  Commission  and  with  other  law  enforcement 
services  and  any  other  relevant  organisations  involved  in  the  action  (such  as  with 
Europol or the World Customs Organization (WCO)); 

-  Enhance  enforcement  capabilities  of  customs  administrations,  in  the  EU  Member 
States  and  the  third  countries  participating  in  the  operation,  notably  by  developing 
their operational capacities; 

-  Establish  a  workable  mechanism  for  information  exchange  between  all  involved 

partners; 

-  Collect additional information that cannot be obtained during daily work; 
-  Prevent the traffic of illicit goods destined to the European Union territory; 
-  Deliver tangible results in terms of seizures/detentions of goods; 
- 
-  Develop more accurate risk profiles for effective targeting and update the existing 

Identify new threats and/or new modi operandi; 

threat assessment based on the information collected; 

-  Assure  appropriate  follow-up  action  in  conjunction  with  the  law  enforcement 

authorities; 

-  Develop  or  extend  the  investigative  activities  on  basis  of  the  positive  results 

identified during the operational action. 

The  Virtual  Operation  Coordination  Unit  (VOCU)  is  the  communication  system  of  the 
AFIS  platform,  used  for  the  secure  exchange  of  information  during  these  operational 
actions.  This  system  is  established  on  the  bases  of  the  Regulation,  as  part  of  the 
permanent  technical  infrastructure  provided  by  the  Commission  for  the coordination  of 
JCOs and special watch actions. 

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The  Permanent  Operational  Co-ordination  Unit  (P-OCU)  is  the  other  part  of  the 
infrastructure  made  available  to  Member  States  for  operational  support.  This  secure 
room, located in the premises of the Commission’s European Anti-Fraud Office (OLAF) 
in  Brussels,  can  accommodate  liaison  officers  from  the  Member  States  and  participant 
third countries and organisations for the entire duration of the actions, with the purpose 
of jointly coordinate the operational activities. 

All costs of installing and maintaining the permanent technical infrastructure are financed 
by  the  Commission  on  the  basis  of  Council  Regulation  515/97,  through  the  UAFP’s 
budget. 

7.  Spontaneous assistance 

Member States’ authorities can spontaneously provide assistance to other Member States 
(without prior request), when this is considered useful to assure compliance with customs 
or  agricultural  legislation  (Articles  13-16  of  Council  Regulation  515/97).  This  includes 
keeping the above mentioned special watch activities and communicating all information 
in their possession including documents. 

Member  States  may  also  communicate  other  information  to  the  competent  authority  of 
another  Member  State,  with  the  purpose  of  preventing  or  detecting  operations  which 
constitute,  or  appear  to  constitute,  breaches  of  customs  or  agricultural  legislation.  This 
can  be  done  by  regular  automatic  exchange  or  occasional  automatic  exchange.  Such 
information may concern the entry, exit, transit, storage and end-use of goods, including 
postal  traffic, moved between the customs territory of the EU and other territories, and 
the  presence  and  movement  within  the  customs  territory  of  the  Union  of  non-EU  and 
end-use goods, where necessary. 

Information  or  documents  obtained  by  recourse  to  mutual  assistance  may  constitute 
admissible evidence in administrative and judicial proceedings of the requesting Member 
State, unless explicitly stated when the information is provided. 

8.  Relations with the Commission 

The  terms  of  the  relations  established  between  the  Commission  and  Member  States  on 
mutual administrative assistance are defined by Council Regulation 515/97 (Articles 17-
18e). On these terms, the competent authorities of each Member State shall communicate 
to  the  Commission  any  relevant  information  concerning  goods,  methods  or  practices 
related  to  breaches  of  customs  or  agriculture  legislation,  as  well  as  requests  for 
assistance, actions taken and information exchanged that are capable to reveal fraudulent 
tendencies in the field of customs or agriculture. 

This  information  is  of  importance  when  these  operations  are  of  particular  relevance  at 
Union  level  or  when  they  might  have  ramifications  in  other  Member  States  or  third 
countries, or where it appears likely that similar operations have also been carried out in 
other Member States. Member States shall communicate to  the Commission  as soon as 
possible,  either  on  their  own  initiative  or  in  response  to  a  reasoned  request  from  the 

215 

 
Commission,  any  relevant  information  (be  it  in  the  form  of  documents  or  copies  or 
extracts thereof) needed to determine the facts, so that the Commission may coordinate 
the steps taken by the Member States. The Commission shall convey this information to 
the competent authorities of the other Member States. 

On  the  other  hand,  the  Commission  shall  communicate  to  Member  States  any  helpful 
information  to  enforce  customs  and  agriculture  legislation.  This  is  usually  done  in  the 
format  of  mutual  assistance  (MA)  communications,  an  information  or  a  request  for 
assistance made in a structured way, whose format has been agreed with Member States 
at  the  former  Mutual  Assistance  Committee  (Article  43),  today  replaced  by  the 
Commission Expert Group on Mutual Assistance in Customs matters (EMAC).  

Where  the  Commission  considers  that  irregularities  have  taken  place  in  one  or  more 
Member  States,  it  shall  inform  the  Member  State  or  States  concerned  thereof  and  that 
State or those States shall, at the earliest opportunity, carry out an administrative enquiry. 
Where  these  enquiries  do  not  have  an  impact  on  the  Union’s  financial  interests,  the 
Commission  acting on the basis of  Council  Regulation  515/97,  can take a coordination 
role  by  ensuring  work  synergies  among  the  services  involved,  by  facilitating  the 
collection and exchange of information from the national and Commission databases, by 
organising joint  operational  meetings  and by providing analytical  support. The findings 
of the enquiries shall be communicated to the Commission as soon as possible. 

For  cases  where  the  financial  interests  of  the  Union  are  involved,  the  Commission 
acting on the basis of the OLAF Regulation, may exercise its powers for the coordination 
of  the  administrative  enquiries  lead  by  the  Member  States,  to  provide  these  with 
assistance in the coordination of their investigations and other related activities for 
the protection of the EU financial interests, or for conducting its own administrative 
investigations.  

Where the Commission has opened a coordination case under Article 1(2) of the OLAF 
Regulation,  it  shall  provide  all  necessary  assistance  to  the  competent  administrative 
authorities  of  the  Member  States  and  to  coordinate  and  contribute  to  the  investigations 
carried  out  by  these  authorities.  The  assistance  provided  by  the  Commission  facilitates 
the  collection  and  exchange  of  evidence  and  ensures  investigation  synergy  among  the 
relevant competent authorities. 

Where  the  Commission  has  opened  an  investigation  case  under  Article  3  of  the  OLAF 
Regulation,  it  may  carry  out  on  the  spot  checks  and  inspections  in  the  EU  and  third 
countries,  in  accordance  with  the  cooperation  and  mutual  assistance  agreements  and/or 
any other legal instrument in force (e.g. Council Regulation 2185/96373). 

373 Council Regulation (EURATOM, EC) No 2185/96 of 11 November 1996 concerning on-the-spot checks and 
inspections  carried out by the Commission in order to protect the European Communities' financial interests 
against fraud and other irregularities. 

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9.  Transport directory 

The Commission is entitled to establish and manage a transport directory (Article 18a of 
Council Regulation 515/97) of data reported by carriers for movements of goods, persons 
and  companies,  for  movements  by  air,  by  train,  by  road  and  by  post.    This  Transport 
Directory is expected to provide the full picture of the movements of goods transported 
into  and  out  of  the  Union  territory.  Access  is  restricted  to  designated  competent 
authorities of Member States and Commission. 

10. Container Status Messages (CSM) 

The Commission establishes and manages a Container Status Messages (CSMs) directory 
(Articles 2, 18a, 53, 43b of Council Regulation 515/97). The Container Status Messages 
(CSM) directory collects data related to movements of containers destined to be brought 
by maritime vessel into the customs territory of the Union from a third country, as well 
as export-movements goods subject to excise duties in the following categories: alcohol, 
cigarettes/tobacco  or  energy  products.  The  CSM  directory  has  been  operational  since 
September 2016.  

Carriers are obliged by the Regulation to transmit defined CSM data directly to the CSM 
directory. The frequency of reporting of container status messages, the format of the data 
and the method of transmission are defined under Commission Implementing Regulation 
(EU) 2016/345. 

11. Import, Export and Transit (IET) 

The Commission  establishes  and manages  a directory containing  data on imports of all 
type  of  goods,  transit  of  all  type  of  goods  and  export  of  restricted  goods  relating  to 
alcohol,  cigarettes/tobacco  or  energy  products  (Article  18d).  This  directory  is  named 
Import,  Export  and  Transit  (IET).  IET  does  not  include  data  on  direct  exports,  neither 
national transit messages. 

To leverage existing resources, the Commission systematically replicates data from other 
sources operated by the Commission. Thus, the IET directory receives and stores import 
and export declarations from the Surveillance system, export declarations from the AES 
system  and  transit  declarations  from  the  NCTS  system.  For  the  moment,  transit 
declarations are also stored in Anti-fraud transit information system (ATIS).  

12. Relations with third countries 

The  section  on  the  relations  with  third  countries  (Article  19-22  of  Council  Regulation 
515/97)  provides  the  legal  basis  for  mutual  assistance  with  third  countries  with  which 
there is no mutual administrative assistance (MAA) agreement.  

Council Regulation 515/97 allows pursuant information to be communicated/exchanged 
between  the  Commission  and  the  Member  States  with  third  countries  in  cases  of 
particular interest for the European Union. Furthermore, it contemplates the possibility of 

217 

 
the  Commission,  in  coordination  with  Member  States,  to  conduct  administrative  and 
investigative cooperation missions in third countries.  

In  the  absence  of  an  agreement  on  cooperation  and  mutual  administrative  assistance  in 
customs  matters  between  the  European  Union  and  a  third  country,  the  assistance  may 
take place with the third country concerned under the conditions laid down in Article 19 
of  Council  Regulation  515/97.  It  can  also  complement  the  MAA  provisions  under 
existing agreements. 

13. Customs Information System (CIS) 

The  Customs  Information  System  (CIS)  (Articles  23-41  of  Council  Regulation  515/97) 
was built to secure the rapid and systematic exchange of information on infringements in 
the customs and agriculture domain at Union level.  

The  aim  of  the  CIS  is  to  assist  in  preventing,  investigating  and  prosecuting  operations 
which are in breach of customs or agriculture legislation, by making relevant information 
available  more  rapidly  and  thereby  increasing  the  effectiveness  and  suitability  of  the 
cooperation  and  control  procedures  applied  by  the  competent  authorities.  The  CIS 
consists  of  a  central  database,  assessable  to  all  Member  States  and  the  Commission 
comprising  data,  including  personal  data,  on  suspicious  or  established  customs 
infringements in the following categories: commodities, means of transport, businesses, 
persons, goods and cash.  

Personal data can solely be included in the CIS for the purpose of actions of sighting and 
reporting,  discreet  surveillance,  specific  checks  and  operational  analysis.  The  access  to 
the  data  is  restricted  to  designated  customs  competent  authorities  from  Member  States 
and the Commission. 

Due to amendments made to Council Regulation 515/97 through the years, the CIS was 
developed  in  successive  IT  applications  since  its  creation  in  1997.  It  was  initially 
developed  as  a  stand-alone  AFIS  application.  In  2010,  it  was  integrated  in  the  Mutual 
Assistance  Broker,  a  system  consisting  of  several  modules  for  the  exchange  of 
intelligence and operational information in the customs domain: CIS, CigInfo (containing 
information  on  cigarettes  seizures),  MarInfo  (for  exchange  of  intelligence  on  sensitive 
goods  transported  by  maritime  cargo),  YachtInfo  (for  exchanges  of  intelligence  on 
sensitive goods transported by non-commercial vessels).  

The  system  was  last  updated  in  2018,  to  introduce  the  new  provisions  following  the 
recast  of  the  regulation.  The  CIS  was  then  technically  updated  as  a  single  application 
integrating  the  information  contained  in  the  CIS,  CigInfo,  MarInfo  and  YachtInfo 
applications.  

14. Customs Files Identification Database (FIDE) 

The Customs Files Identification Database (FIDE) (Articles 41a-d of Council Regulation 
515/97) is a database managed and set up by the Commission with the objective to help 

218 

 
prevent  operations  which  are  in  breach  of  customs  and  agriculture  legislation  and  to 
facilitate  and  accelerate  their  detection  and  prosecution.  The  data  of  the  centralised 
database covers persons and businesses subject to an administrative enquiry or a criminal 
investigation,  as  well  as  the  field  concerned  and  the  details  of  the  Member  States 
competent authority in charge of the file.  

The purpose of the FIDE is to allow the Commission, when it opens a coordination file 
or  prepares  a  Community  mission  in  a  third  country  within  the  meaning  of  Council 
Regulation 515/97, and the competent authorities of a Member State, when they open an 
investigation  file,  to  identify  the  competent  authorities  in  other  Member  States  or  the 
Commission  departments  which  are  or  have  been  investigating  the  same  persons  or 
businesses concerned. The system does not contain the details of the case.  

15. Data analysis 

The data exchanged between the Member States and the Commission may be stored and 
used for the purpose of operational and strategic analysis and the results of this analysis 
may be interchanged between them (Article 2 of Council Regulation 515/97). 

219