Report 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 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  COM(2024) 572 final  Report 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 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      {SWD(2024) 279 final}  
 
 
1. 

INTRODUCTION 

Fraud and related illegal activities can have a serious detrimental impact on the European 
Union’s  (EU)  and  its  Member  States’  financial  interests.  This  problem  is  all  the  more 
pressing  as  the  EU’s  total  budget  under  its  multiannual  budget  for  2021-2027  (‘MFF’) 
has grown to an unprecedented volume of around EUR 1.8 trillion, partially in response 
to the COVID-19 pandemic. Efficient and proper spending of the EU budget, also in the 
Member  States,  is  key  to  maintaining  the  public’s  and  taxpayers’  trust.  Conversely,  a 
high  prevalence  of  fraud  can  stifle  economic  growth  and  undermine  the  broader 
economic recovery. Improving our joint defences against fraud, both within the EU and 
outside,  therefore  plays  an  important  role  in  strengthening  the  EU’s  resilience  in 
particularly uncertain times. 

Under Article 325 of the Treaty on the Functioning of the European Union (‘TFEU’), the 
Member States and the EU have a joint obligation to protect the EU’s financial interests. 
The  anti-fraud  landscape  has  undergone  major  changes  at  EU  level  in  the  past  decade, 
with: 

• 

• 

• 

the  adoption  of  the  Directive  on  the  fight  against  fraud  to  protect  the  EU’s 
financial interests by means of criminal law (1) in 2017; 
the  launch  of  operational  activities  of  the  European  Public  Prosecutor’s  Office 
(EPPO) in June 2021; and 
the  revision  of  Regulation  (EU,  EURATOM)  No  883/2013(2)  (‘OLAF 
the  effectiveness  of  administrative 
Regulation’) in  2020 
investigations carried out by the European Anti-Fraud Office (OLAF)  (3). 

to  strengthen 

There is a general recognition that the EU should support Member States in their work to 
protect its financial interests. After all, most cases of fraud and irregularities are detected, 
investigated and prosecuted at national level. 

Like its predecessor, the Hercule III programme, the UAFP provides targeted anti-fraud 
financing to eligible beneficiaries from Member States and associated countries.  

(1) 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, 28.07.2017). 

(2)  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),  as  amended: 
http://data.europa.eu/eli/reg/2020/2223/oj 

(3) Regulation (EU, Euratom) 2020/2223 of the European Parliament and of the Council of 23 December 
2020  amending  Regulation  (EU,  Euratom)  No 883/2013,  as  regards  cooperation  with  the  European 
Public Prosecutor’s Office and the effectiveness of the European Anti-Fraud Office investigations (OJ 
L 437, 28.12.2020). 

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2.  THE UNION ANTI-FRAUD PROGRAMME 

The  UAFP  is  the  EU’s  main  financing  instrument  dedicated  to  protecting  the  EU’s 
financial interests from fraud, corruption or any other irregularities. 

The UAFP Regulation sets out the following programme objectives: 

‘1. The general objectives of the Programme are to: 

(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. 

2. The specific objectives of the Programme are to: 

(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 13  of  the  UAFP  Regulation  mandates  the  Commission  to  carry  out  an  interim 
evaluation of the programme: 

‘2.  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. 

(…) 

4.  The  Commission  shall  communicate  the  conclusions  of  the  evaluations, 
accompanied  by  its  observations,  to  the  European  Parliament,  the  Council,  the 
European Economic and Social Committee, the Committee of the Regions and the 
Court of Auditors, and shall publish them on the Commission’s website.’ 

The deadline of 4 years after the start of the programme elapses on 31 December 2024. 

During  the  preparations  for  the  current  multiannual  budget,  the  irregularities  and 
suspected fraud cases detected during the implementation of the budget and reported by 

2 

 
Member  States (4)  under  Article 325(5)  TFEU  were  analysed.  This  revealed  that  the 
detrimental financial impact over the years remained high enough for the EU to continue 
enforcing its obligation to protect the EU budget through a programme like the UAFP. 

The  programme  is  being  implemented  on  the  basis  of  annual  financing  decisions  and 
work programmes adopted by the Commission. Article 3(1) of the UAFP Regulation has 
set the available UAFP budget for the 2021-2027 MFF at EUR 181.2 million. 

Under the UAFP Regulation, the programme must be implemented, in principle, in direct 
management,  according  to  Regulation  (EU,  Euratom)  No  2018/1046(5)  (‘the  Financial 
Regulation’), or (exceptionally) in indirect management with another body referred to in 
Article 62(1), point (c) of the Financial Regulation (e.g. an international organisation). 

Under Article 5(2) of the UAFP Regulation, the programme may provide funding in any 
of the forms  laid down in the Financial  Regulation. These include,  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 activities carried out according to Council Regulation (EC) No 515/97 (6), in 
particular, to cover the types of costs referred to in the indicative list in Annex I to that 
Regulation. 

Also, under Article 5(4) of the UAFP Regulation, where the supported activity 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 Customs Control Equipment Instrument (CCEI)). 

Grants  awarded  under  the  programme  may  cover  up  to  80%  of  the  eligible  costs.  In 
exceptional  and  duly  substantiated  cases,  if  the  proposed  project  is  a  ‘priority  action’ 
(according to the relevant annual work programme), this percentage may be increased to 
a maximum of 90% (7), under the conditions set out below. 

(4) Annual reports under Article 325 of the Treaty on the Functioning of the EU on the protection of the 
Union’s financial interests (PIF Reports) are available at: https://ec.europa.eu/anti-fraud/reports_en. 
(5) 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 that regulation. 

(6) 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  82,  22.3.1997,  p. 1).  The 
Regulation  was  evaluated  by  the  Commission  (OLAF)  in  2023:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2023%3A429%3AFIN. 

(7) Article 8 of the UAFP Regulation,  on  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 

3 

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

(i)  the  proposal  reflects  the  findings  of  the  annual  reports  on  the  implementation  of 
Article 325  TFEU  on  combating  fraud,  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 procedures (8). 

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

(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,  funding  conferences  and  (specialised)  training,  and  for 
the development of specific IT tools. 

The  eligible  beneficiaries  of  the  programme  are  national  or  regional  administrations  of 
Member  States  or  associated  countries,  research  bodies,  educational  institutes  and  non-
profit  entities  that  were  set  up  in  a  Member  State  and  have  been  operating  there  for  at 
least 1 year, as well as international organisations. 

On  20  March  2024,  an  Association  Agreement  was  signed  between  the  European 
Commission  and  Ukraine,  making  it  the  first  non-EU  country  that  has  formalised  its 
participation in the UAFP, with retroactive effect as of 1 January 2023. 

3.  THE INTERIM EVALUATION 

Following  the  indications  provided  in  Article 13  of  the  UAFP  Regulation  and  the 
Commission’s  Better  Regulation  Guidelines,  the  interim  evaluation  uses  five  criteria  to 
assess the programme: 

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.’ 

(8) https://www.eca.europa.eu/en/publications?did=44169  

4 

 
 
 
• 

• 
• 
• 
• 

the  programme’s  effectiveness  in  attaining  its  objectives  and  expected  results, 
including the sustainability (durability) of the acquired equipment and tools; 
the efficient use of (financial and human) resources; 
the programme’s internal and external coherence with other areas of EU action; 
the relevance of all programme objectives; and 
the programme’s EU added value. 

The period covered by the evaluation is 1 January 2021 to 31 July 2024. This evaluation 
is  based  on  the  findings  of  an  external  study,  finalised  in  May  2024  (9),  covering  the 
period 1 January 2021 to 31 January 2024. 

4.  THE EVALUATION METHODOLOGY 

In carrying out this evaluation, the Commission drew primarily on the above-mentioned 
study.  It  also  drew  on  the  2018  ex  ante  evaluation  carried  out  in  preparation  for  the 
legislative  proposal  for  the  UAFP  programme,  the  annual  work  programmes  of  the 
UAFP, and the annual overviews on the implementation of the programme, prepared by 
the Commission and annexed to the Commission annual report on the protection of the 
EU’s financial interests (‘PIF Reports’). 

An  inter-service  steering  group  of  relevant  Commission  departments  was  set  up  to 
support the evaluation process.  

The scope of the interim evaluation covers the three components of the programme (the 
‘Hercule’ part, AFIS and IMS),  all  the measures funded  under the  programme,  and the 
preparatory and implementing work carried out by the stakeholders for those measures. It 
also  covers  potential  beneficiaries’  grant  applications  (under  the  ‘Hercule’  component) 
that  were  unsuccessful  following  the  proposal  evaluation  process.  This  because,  either 
the  eligible  applications  were  not  awarded  a  grant  due  to  lack  of  funds,  either  the 
applications were ineligible as their scores were below the minimum threshold of 60%. 

5.  MAIN FINDINGS OF THE INTERIM EVALUATION 

Overall, based on the evidence collected,  the evaluation found that the programme has, 
so far, successfully  met  its  general  and  specific  objectives. Echoing  the  views of many 
beneficiaries,  the  evaluation  also  concluded  that  it  is  necessary  to  maintain  a  funding 
programme  to  support  them  in  their  efforts  to  protect  the  EU’s  financial  interests.  The 
beneficiaries  considered  that  the  results  obtained  and  the  programme’s  overall  output 
largely  outweighed  the investment  of time, effort  and  costs required  to  participate. The 
participants also considered the recognition and improved reputation resulting from their 
participation in the programme to be a valuable asset as unexpected added value. 

(9) The study was performed by ICF Belgium S.A., Brussels. Available at: https://op.europa.eu/s/zXCm  

5 

 
 
 
5.1.  Effectiveness 

The  assessment  of  all  the  available  data  sources  indicates  that  the  programme  and  its 
activities  have  been  effective.  In  particular,  at  this  stage  of  implementing  the  three 
components  of  the  programme,  the  supported  activities  have  improved  (or  could 
improve) the prevention, detection, and investigation of fraud and other illegal activities 
that  are  detrimental  to  the  EU’s  financial  interests.  The  three  components  could  also 
improve  transnational  and  multi-disciplinary  cooperation.  Overall,  compared  to  the 
baselines  identified  for  each  of  the  components,  which  refer  to  performance  indicators 
used  between  2019  (Hercule  III)  and  2022  (UAFP),  the  effectiveness  has  remained  the 
same or improved since the start in 2021. 

The  final  evaluation  of  Hercule  III  found  aspects  that  may  have  hampered  the 
programme’s effectiveness; notably, that certain  Member States’ administrations lacked 
the resources to enable them to cope with the programme’s administrative requirements. 
However, despite that, the number of applications  in  recent  years (from  2022 to 2024), 
received for the ‘Hercule component’ of the UAFP (technical assistance proposals), has 
doubled. This significant increase shows that the Commission’s efforts in 2022 and 2023 
to  organise  workshops  for  past  and  potential  beneficiaries,  have  been  effective  in 
boosting the awareness and attractiveness of the financing opportunities. This increased 
offer  of  guidance  also  replied  to  a  recommendation  from  the  Hercule  III  programme 
evaluation in 2021. 

Informing potential beneficiaries of the calls for proposals in a more targeted way could 
further  increase  the  number  of  applicants,  as  well  as  the  number  of  Member  States 
participating in the programme, especially from countries that currently submit fewer or 
even no applications. 

Targeted information sessions involving the Member States that report a high number of 
EU fraud cases/irregularities, could boost the participation rate and result in a more even 
distribution  of  the  funds  amongst  Member  States.  Nevertheless,  it  should  be  noted  that 
for  various  reasons  (such  as,  for  example,  the  availability  of  national  funds),  some 
countries might not be interested in participating in the grants component of the UAFP. 

Transnational cooperation can be improved by providing incentives to beneficiaries to set 
up multinational project teams and involve partners from other Member States. 

Regarding  sustainability  (durability),  the  evaluation  demonstrated  that  the  measures 
funded  by  the  programme  are  sustainable,  i.e.  they  produced  effects  that  lasted  beyond 
the  end  date  of  the  project.  The  study  revealed  that  the  sustainability  of  technical 
assistance depends on the nature and costs of the purchased equipment. 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. 

6 

 
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 the relevant national and EU administrations.  The effectiveness of 
AFIS can be evaluated by its output. 

A  key  performance  indicator  for  AFIS  is  the  number  of  information  items  on  mutual 
assistance  made  available  and  the  number  of  supported  mutual  assistance-related 
activities. The yearly targets for this indicator were exceeded for the 2021-2023 period. 

The key indicator for assessing the impact of AFIS’ output is the level of satisfaction of 
AFIS  users,  as  measured  by  periodic  user  surveys.  The  results  from  the  latest  (2023) 
survey confirmed that AFIS is able to deliver functioning tools for information exchange 
in its area of activity.  

This  latest survey  also  contained questions on the functionality  and performance of the 
IMS tool. Users’ combined satisfaction rate (with the functionality and performance) of 
IMS was approximately 91%. This compares very favourably to the 2019 results, where 
users’ satisfaction rate was 72%. 

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

It  should  be  noted  that  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 and traceability. 

A  new  version  of  the  IMS  was  deployed  on  1  October  2024. IMS  underwent  a  deep 
upgrade to state-of-the-art technologies, which made the system more performant, while 
creating  the  conditions  for  easier  support  and  efficient  development  of  future 
requirements. Technical work was also complemented by various other improvements: a 
modern  look  and  feel,  easier  navigation,  improved  search  tool,  better  statistics  and 
updated user manuals. 

Training on the new and upgraded system  is planned until  the end of 2024 for  all  IMS 
users in OLAF, the Commission services and the Member States. 

The  interim  evaluation  of  the  UAFP  also  found  aspects  that  may  have  hampered  the 
programme’s effectiveness.  The  already mentioned  Member State  administrations’ lack 
of  resources  and  subsequent  inability  to  cope  with  the  programme’s  administrative 
requirements  may  lead  to  fewer  applications.  Making  more  guidance  available  to 
(‘Hercule’)  applicants  and  to  users  (of  the  IMS  tool)  could  be  key  in  remedying  this 
issue. 

7 

 
5.2.  Efficiency 

Overall,  implementing  the  programme’s  first  component  has  enabled  the  EU  and  the 
national  investigative  authorities  to  use  their  resources  more  efficiently  to  fight  serious 
offences that harm the financial interests of the EU effectively. Even though most of the 
technical  assistance  and  training  projects  are  still  in  the  implementation  stage,  the 
evaluation was able to identify the main areas where the (Hercule) grants contributed to 
managing costs and resources more efficiently. These include equipment purchase, fraud-
related  data  gathering,  analysis  and  exchange,  training  activities,  relationship  building 
and investigations. 

The current application process is significantly better than under the previous programme 
and stakeholders find it highly efficient. The feedback and recommendations to simplify 
the  application  procedure  and  provide  more  guidance  to  the  applicants,  which  were 
provided under the final evaluation of the Hercule III programme, have been taken into 
account in the current programme, resulting in more applications each year. 

Most  of  the  applicants  found  the  guidance  and  instructions  provided  to  prepare  the 
application clear and readily available. The annual call documents published under each 
annual  work programme provide  a  clear overview of the proposals  eligible for funding 
and  present  the  eligibility  criteria  clearly.  The  call  is  also  accompanied  by  an  online 
manual  for  proposal  preparation  and  submission,  which  applicants  found  easy  and 
intuitive to navigate. 

Greater user-friendliness for users with disabilities such as visual impairments may also 
make the process less resource-intensive for some applicants. 

The  grant  agreement  allows  beneficiaries  a  good  degree  of  budgetary  flexibility.  This 
flexibility increases project efficiency, since it reduces the administrative burden both for 
beneficiaries and Commission (OLAF) programme managers. 

The  interim  evaluation  of  the  UAFP’s  first  component  (‘Hercule’)  found  that 
beneficiaries had achieved some cost savings. One third of beneficiaries estimated those 
savings  to  be  very  significant  or  significant.  Beneficiaries  noted,  with  respect  to  the 
technical component, that their improved capacity and capabilities allowed them to carry 
out  operations  more  efficiently  in  their  countries.  Another  important  factor  is  that  this 
increased efficiency has  a snowball effect  and  also  benefits  EU partner agencies. Thus, 
UAFP participants are better equipped to respond to requests for mutual  assistance and 
joint investigations with EU partner agencies. 

This evaluation found that AFIS has become more efficient. For example, it has offered 
technical  support  to  a  few  dozen  joint  customs  operations  since  2021.  Users  perceive 
UAFP funding for the IMS to be an efficient use of resources. However, it is difficult to 
assess the overall efficiency associated with the improvements made to the two systems 
on the basis of the data available for this evaluation. 

8 

 
The  analysis  suggests  that  the  UAFP  appears  to  represent  an  efficient  use  of  resources 
based  on  a  cost-benefit  analysis.  It  is  important  to  note,  however,  that  with  the  data 
available at this interim stage of the programme, it is not possible to produce a complete, 
quantitative  mapping  of  programme  costs  and  benefits,  or  to  monetise  all  costs  and 
benefits for a direct comparison with one another. 

5.3.  Coherence 

Based  on  the  analysis  of  the  relevant  programmes,  as  well  as  the  results  of  the 
stakeholder  consultation  conducted  for  the  evaluation,  the  programme  is  considered 
generally coherent, both internally and externally. Nevertheless, some potential overlaps 
and/or areas for improvement have been identified. 

The  research  found  greater  internal  coherence  compared  to  the  previous  programming 
period  because  the  programme’s  three-component  structure  reduces  the  administrative 
burden,  and  simplifies  the  management  of  funding,  budget  flexibility  and  the 
redistribution of funds across the three components.  

For  the  external  coherence,  the  research  focused  on  a  number  of  relevant  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 provided by DG 
TAXUD,  i.e.  the  Customs  programme  and  the  Fiscalis  programme.  In  terms  of 
programme beneficiaries, the CCEI provides financial support specifically to the Member 
States’ customs authorities. In contrast, the UAFP is (more) focused on law enforcement 
authorities, which do not receive CCEI funding. The CCEI focuses on customs activities, 
particularly on developing customs capacity at border crossing points and the capacity of 
customs laboratories, while the UAFP focuses on preventing (financial) irregularities and 
fraudulent behaviour that harm the EU’s financial interests. 

The  consultations  conducted  in  this  evaluation  did  not  identify  any  major  duplications 
between  the  funding  provided  by  DG  TAXUD  to  national  customs  authorities  and  the 
activities funded under the UAFP. This is mainly due to the differences in the scope of 
those  programmes  and  the  fact  that  the  competent  Directorates-General  work  closely 
together at different levels and at different stages of the granting procedure. That allows 
them to ensure coordination and provide clarity to the applicants and beneficiaries on the 
functioning  of  the  programmes  and  the  activities  eligible  for  funding.  Based  on  the 
research conducted by the study, the UAFP continues to be generally coherent with the 
other relevant funding programmes, in line with the previous programming period. 

5.4.  Relevance 

The  relevance  assessment  finds  that  the  UAFP’s  activities  have  been  broadly  relevant 
over the course of this evaluation period, for both achieving the general objectives of the 
programme  and  addressing  the  needs  of  its  applicants,  beneficiaries,  participants 
(Hercule), and users (AFIS and IMS). 

9 

 
Hercule  and  AFIS  have  also  been  found  to  be  relevant  in  identifying  and  combating 
emerging  trends  in  the  area  of  fraud  against  the  EU’s  financial  interests,  despite  some 
evidence  to  suggest  that  Hercule  would  benefit  from  a  significant  increase  in  financial 
resources, as highlighted in this report. 

Current  trends  in  fraudulent  behaviour  show  that  projects  supporting  the  fight  against 
digitally enabled fraud need extra funding. Providing continuing support to the national 
authorities  to  combat  fraud  and  other  illegal  activities  that  harm  the  EU  budget  might 
require a considerable increase to the programme’s current budget to cover the high costs 
of  equipment  or  hardware,  as  well  as  the  need  for  policymakers  to  keep  up  with 
technological developments. 

Such  a  budget  increase  should  also  take  into  consideration  the  extension  of  the 
programme’s  geographical  scope  to  Ukraine,  now  an  associated  country  to  the 
programme, and any potential extension to other (new) candidate countries. 

Applicants  and  beneficiaries  of  funding  under  the  Hercule  component  indicated 
substantial  demand  for  additional  support  through  technical  assistance  and  training 
activity  projects,  and  highlighted  the  lack  of  similar  support  from  national  or  other 
sources. 

Finally, the budget might also have to be increased to cover the increasing proportion of 
annual Hercule applications that are currently being unsuccessful in receiving grants, due 
to budgetary limits, i.e. around three quarters of the applications received under technical 
assistance in recent years. 

5.5.  EU added value 

The analysed data reflect that, overall, the UAFP programme performed well against the 
baseline indicators on EU added value. 

Recipients  of  funding  under  the  Hercule  component  indicated  a  very  high  level  of 
perceived satisfaction and confirmed that the same level of support would not have been 
possible  at  national  level.  Respondents  to  the  targeted  surveys  and  interviewees  all 
confirmed this finding. 

The  UAFP  data  on  AFIS  indicate  a  steady  increase  every  year  in  the  availability  of 
mutual  assistance  information  under  the  programme,  which  regularly  meets  the  annual 
targets for this indicator. 

The  data  reflect  generally  high  satisfaction  with  IMS,  as  a  large  majority  of  users  are 
satisfied with the tool. 

The  UAFP  programme  provides  additional  benefits  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 

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reducing inequalities within and among countries by bolstering national administrations’ 
budgets. 

Furthermore,  the  programme  indirectly  helps  build  effective,  accountable  and  inclusive 
institutions by supporting law enforcement agencies, particularly through grants to boost 
the digital transition, as well as through the tools and support provided by AFIS and IMS. 

OLAF’s involvement also lends substantial credibility to the training activities organised 
by various beneficiaries, resulting in more participants and greater visibility. 

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 and that any loss 
of UAFP funding opportunities would leave a significant gap. 

6.  CONCLUSIONS AND RECOMMENDATIONS 

Reassuringly,  most  of  the  conclusions  presented  in  the  study  report  are  already  largely 
reflected  in  the  current  implementation  of  the  UAFP.  Thus,  this  evaluation  not  only 
supports  the  Commission’s  current  practice,  but  is  also  a  benchmark  for  future 
programme-related developments. 

Taking  into  account  the  findings  presented  in  the  previous  sections,  the  Commission 
considers  that  the  programme  provides  a  solid  basis  to  help  Member  States  and 
associated countries tackle the ever-evolving fraud landscape. It also takes into account 
the new European institutional set-up, with the operational launch of the EPPO in 2021. 

The UAFP is considered to be responding to today’s challenges in several ways. 

First of all, as more and more criminal activities are run in cyberspace, the programme 
helps Member States to strengthen their digital capacity to detect and investigate fraud. 
The  UAFP  therefore  supports  the  purchase  of  advanced  analytical  tools  and  databases, 
and provides expert training  on digital forensics. This  type of support  provided is  fully 
aligned  with  the  new  Commission  anti-fraud  strategy,  which  strongly  promotes  the 
deployment of advanced analytical and IT tools. 

Second,  considering  the  increase  in  EU  expenditure  under  the  new  budget  and 
NextGenerationEU,  the  bulk  of  UAFP  funding  is  directed  to  fighting  fraud  against 
expenditure,  including  expenditure  under  the  Recovery  and  Resilience  Facility.  This  is 
supported by the fact that the EU has now set up the CCEI for the purchase, upgrade and 
maintenance of customs control equipment. With its budget of around EUR 1 billion for 
the current 7-year period, this instrument has freed up significant resources for the UAFP 
that were allocated before by Hercule III to fund customs control equipment and tools. 

At  a  more  operational  level,  when  summarising  the  key  findings  of  the  evaluation  in 
terms of recommendations for the future implementation, two aspects stand out. 

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First, stakeholders have asked the Commission for more detailed guidance on preparing 
an  application.  OLAF  will  therefore  provide  more  support  and  guidance  to  grant 
applicants,  especially  in  the  countries  that  are  the  newest  members  of  the  programme. 
The programme’s web presence on OLAF’s external  page will be  expanded to  provide 
further information, best practices and manuals for the grant component. 

Second, the evaluation’s findings may suggest to consider the delicate balance between 
the  strong  desire  to  minimise  the  administrative  burden  on  applicants  and  the  need  for 
more  readily  available  information  for  reporting,  monitoring  and  ex  post  assessments. 
This balance is not easy to strike, and the Commission may want to look into possibilities 
for further fine-tuning its reporting and monitoring tools to that end. 

As  regards  the  programme’s  external  consistency  and  coherence,  the  Commission 
services  coordinate  with  one  another  when  preparing  and  adopting  their  annual  work 
programmes  for  EU  financing  instruments  related  to  the  fight  against  fraud  and 
corruption. 

Under  the  current  MFF,  the  Commission  has  developed  a  cross-cutting  evaluation  and 
monitoring framework for all spending programmes. The programme has also improved 
the  current  framework  by  developing  an  appropriate  number  of  indicators  specific  to 
eligible  projects.  They  are  used  for  reporting  on  the  programme’s  implementation 
progress each year in the programme’s annual overview (as part of the Commission’s PIF 
reports).  Since  2017,  all  projects,  that  have  been  awarded  a  grant,  are  registered  in  the 
Commission’s  ‘e-Grant’  tool,  a  valuable  database  for  the  implementation  of  the 
programme. 

This interim evaluation has provided a basis for a future impact assessment in the light of 
the  legislative  preparations  for  the  next  programme.  The  continued  relevance  and  the 
increasing  size  of  the  programme  in  terms  of  activities  within  its  components, 
highlighted  by  this  evaluation,  provide  grounds  to  justify  supporting  a  considerably 
increased overall budget for the future programme (2028-2034). 

Considering  all  of  the  above,  the  programme  is  assessed  as  being  efficient,  effective, 
relevant and coherent, as well as providing significant EU added value. The Commission 
will continue to actively support Member States and associated countries’ authorities to 
strengthen their capacity to fight fraud and irregular activities affecting the EU budget.  

The  Commission  will  further  look  into:  (i)  improving  the  guidance  provided  to 
applicants;  (ii)  updating  the  type  of  activities  financed,  taking  into  account  the  rapid 
technological  progress;  and  (iii)  ensuring  a  continued  systematic  Commission-level 
coordination and coherence between the UAFP and other EU programmes. 

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