COMMISSION STAFF WORKING DOCUMENT on the mid-term evaluation of the Programme for exchange, assistance and training for the protection of the euro against counterfeiting ('Pericles IV' Programme) Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN CENTRAL BANK on the mid-term evaluation of the Programme for exchange, assistance and training for the protection of the euro against counterfeiting ('Pericles IV' Programme)
Date: 2025-02-20
Institutions: Directorate-General for Economic and Financial Affairs, European Commission
Subjects: EU programme, counterfeiting, cross-border cooperation, euro, exchange of information, fraud, fraud against the EU, vocational training

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 20.2.2025  SWD(2025) 44 final  COMMISSION STAFF WORKING DOCUMENT on the mid-term evaluation of the Programme for exchange, assistance and training for the protection of the euro against counterfeiting ('Pericles IV' Programme)  Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN CENTRAL BANK  on the mid-term evaluation of the Programme for exchange, assistance and training for the protection of the euro against counterfeiting ('Pericles IV' Programme)  {COM(2025) 54 final}  
 
 
Table of contents 

1. 

INTRODUCTION ................................................................................................................................ 1 

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

2.1 

Description of the intervention and its objectives .......................................................... 2 

2.2 Points of comparison ............................................................................................................. 4 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ....................... 10 

Current state of play.................................................................................................................. 10 

4. 

EVALUATION FINDINGS ............................................................................................................... 12 

4.1.  TO WHAT EXTENT WAS THE INTERVENTION SUCCESSFUL AND WHY? ................... 12 

4.2.  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE AND TO WHOM? ............. 20 

4.3.  IS THE INTERVENTION STILL RELEVANT?.......................................................................... 21 

4.4.  IS THE INTERVENTION SUSTAINABLE? ................................................................................ 23 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ................................................. 25 

5.1.  CONCLUSIONS ............................................................................................................................... 25 

5.2.  LESSONS LEARNED ...................................................................................................................... 28 

ANNEX I: PROCEDURAL INFORMATION............................................................................................. 30 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ................................................... 31 

ANNEX III. EVALUATION MATRIX ....................................................................................................... 33 

ANNEX IV. OVERVIEW OF COSTS AND BENEFITS ........................................................................... 45 

ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT ............................................... 47 

 
 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AWP 

CAC 

CNA 

Annual Work Programme 

Counterfeit Analysis Centre 

Competent National Authority 

DG ECFIN 

Directorate-General for Economic and Financial Affairs 

ECB 

ECEG 

EQ 

ESCB 

ETSC 

Eurojust 

Europol 

FTE 

European Central Bank 

Euro Counterfeit Experts Group 

Evaluation Question 

European System of Central Banks 

European Technical and Scientific Centre (ETSC) 

European Union Agency for Criminal Justice 
Cooperation 

European Union Agency for Law Enforcement 
Cooperation 

Full-Time Equivalent 

INTERPOL 

International Criminal Police Organization 

MS 

SOCTA 

SWD 

Member State 

Serious and Organised Crime Threat Assessment 

Staff Working Document 

 
 
 
1. 

INTRODUCTION 

The mid-term evaluation of the Pericles IV programme (the ‘programme’) was conducted 
in  accordance  with  Article  13  of  Regulation  (EU)  No  2021/840  of  the  European 
Parliament  and  of  the  Council  (the  ‘Regulation’).  The  programme  (covering  the  period 
2021-2027)  was  established  by  the  Regulation  to  help  to  protect  the  euro  against 
counterfeiting  and  related  fraud.  For  this  purpose,  the  programme  finances  seminars, 
workshops, training activities, staff exchanges, studies, and the provision of equipment to 
anti-counterfeiting  authorities  in  EU  Member  States  and  non-EU  countries.  It  replaces 
the Pericles 2020 programme which ran for the period 2014-2020. 

This staff working document (the ‘SWD’) presents the Commission’s views on the mid-
term  evaluation  of  the  programme,  building  on  multiple  sources.  This  assessment  is 
primarily  based  on  an  independent  external  evaluation  report  (the  ‘supporting  study 
report’)  commissioned  by  the  Commission  and  prepared  by  ECORYS.  The  supporting 
study report was concluded in August 2024 and is published together with this SWD.  

The purpose of the evaluation is twofold: to review the performance of the programme to 
date  and,  on  the  basis  of  that  review,  to  draw  lessons  for  the  remaining  programme 
period. It covers the five Commission Better Regulation evaluation criteria of relevance, 
effectiveness,  efficiency,  coherence,  and  EU  added  value,  and  also  assesses  the 
programme’s sustainability. 

The  evaluation  reviews  the  programme’s  implementation  from  January  2021  to  March 
2024,  covering  both  Member  States  (including  euro  area  and  non-euro  area  Member 
States)  and  non-EU  countries.  This  mid-term  evaluation  has  involved  various 
stakeholders,  including  national  competent  authorities  from  EU  Member  States, 
programme  applicants  and  beneficiaries,  participants  in  programme-funded  actions,  EU 
institutions  such  as  the  European  Central  Bank,  Europol,  Eurojust  and  the  European 
Commission;  and  international  partners  such  as  competent  authorities  from  non-EU 
countries and INTERPOL. 

The evaluation reviews all types of actions under the programme, including conferences 
and large events for disseminating information, meetings, seminars, workshops, training 
activities, studies, and equipment purchases. 

While the supporting study report which provides the basis for this evaluation adopted a 
robust  approach  combining  desk  research  with  fact-finding  work  through  stakeholder 
consultations,  active  observation,  and  case  studies,  certain  data  gaps  were  identified 
including  reduced  stakeholder  participation 
the 
methodology  provided  significant  benefits  by  integrating  diverse  data  points,  thereby 
fostering  a  holistic  understanding  of  the  programme’s  impact.  The  wide  geographical 
representation  during  interviews  and  the  effort  to  maximise  participant  consultation 
during case studies further increased the reliability of the exercise. The methodological 

in  certain  areas.  Nevertheless, 

1 

 
 
rigour and overall high response rates ensured that the findings set out in the supporting 
study report remained robust and representative. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1  Description of the intervention and its objectives 

Pericles IV is the fourth iteration and enhancement of the Pericles  programme. Its legal 
basis is Article 133 of the Treaty on the Functioning of the European Union (TFEU). The 
programme  pursues 
the  general  objective  of  preventing  and  combating  euro 
counterfeiting  and  related  fraud  and  preserving  the  integrity  of  the  euro  banknotes  and 
coins, thus strengthening the trust of citizens and businesses in the genuineness of these 
banknotes  and  coins  and  therefore  enhancing  the  trust  in  the  EU’s  economy,  while 
securing the sustainability of public finances. The specific objective of the programme is 
to  protect  euro banknotes and coins  against counterfeiting  and related fraud.  It  seeks to 
achieve  this  objective  in  two  main  ways.  The  first  way  is,  by  supporting  and 
supplementing  the  measures  undertaken  by  Member  States.  The  second  way  is  by 
assisting the competent national  authorities in their efforts to  develop  close and regular 
cooperation and an exchange of best practices among themselves, with the Commission 
and, where appropriate, with non-EU countries and international organisations. 

As outlined in the explanatory memorandum accompanying the proposal for a Regulation 
establishing the Pericles IV programme1, counterfeiting of the euro poses a real problem 
for, and substantial and continued threats to, the EU. Pericles IV therefore builds on the 
foundations  laid  by  its  predecessors,  adapting  to  new  challenges  and  incorporating 
modern  approaches  to  fighting  counterfeiting.  The  programme  aims  to  support  and 
supplement  measures  undertaken  by  Member  States  and  assist  national  authorities  in 
their efforts to protect euro banknotes and coins against counterfeiting. 

The  programme  can  thus  broadly  be  described  as  a  capacity-building,  information-
dissemination and networking initiative. Its activities are aimed at: 

 (i)  the  exchange  and  dissemination  of  information;  (ii)  the  provision  of  technical, 
scientific  and  operational  assistance;  (iii)  the  purchase  of  equipment  to  be  used  by 
specialised  anti-counterfeiting  authorities  of  non-EU  countries  for  protecting  the  euro 
against counterfeiting. 

The programme is inspired by three key principles:  

(i) transnationality, whereby all programme activities must involve the participation of at 
least two countries;  

1 European Commission, Explanatory Memorandum accompanying the Commission Proposal for 
a Regulation establishing the ‘Pericles IV programme', available here. 

2 

 
 
 
(ii) multidisciplinarity, to facilitate the adoption of a common approach to euro protection 
by the target groups mentioned below; 

(iii)  complementarity,  with  programme  activities  intended  to  supplement  –  and  not 
replace  –  other  euro-protection  initiatives  implemented  by  Member  States  or  by 
EU/international institutions. 

In line with its multidisciplinary approach, the programme seeks to benefit a wide range 
of target groups, including:  

(i)  law  enforcement  authorities  (e.g:  police,  customs,  interior  ministries,  intelligence 
personnel);  

(ii) monetary authorities (e.g: national central banks, mints, finance ministries);  

(iii) judicial authorities (e.g: justice ministries, judges, prosecutors);  

(iv) commercial banks and other financial sector operators (money exchange or transport 
companies, etc.);  

(v) other relevant specialist groups (chambers of commerce, etc.). 

Figure 1: Pericles IV programme intervention logic for the period 2021-2027 

The  programme’s  intervention  logic,  as  presented  in  Figure  1  above,  can  be  described 
with reference to six main elements, set out in the bullet points below. 

•  The  first  element  refers  to  the  needs  addressed  by  the  programme,  i.e.  the 
growing international dimension and changing nature of euro counterfeiting. 

3 

 
 
•  The second element consists of the inputs available to address these needs, which 
the  programme’s  financial,  human  and  managerial/administrative 

include 
resources, and the resources of the other entities involved. 

•  The third element concerns the actual deployment of available resources through 
the  implementation  of  Pericles  IV  actions,  i.e.  the  organisation  of  conferences, 
staff exchanges, etc.  

•  The  fourth  element  refers  to  the  outputs  delivered  by  the  programme  actions, 
which can be described in terms of staff trained, best practices disseminated, etc. 
•  The fifth element relates to the ‘transformation’ of the outputs into outcomes, i.e. 
the  discrete  changes  in  euro-protection  capabilities  that  the  programme  is 
expected  to  generate  (in  terms  of  increased  operational  capacities,  closer 
institutional cooperation, etc.). 

•  Finally, the sixth element refers to the programme’s impact, i.e. its contribution to 
the  general  improvement  in  euro  protection,  which  in  turn  is  expected  to 
contribute to the end goal of improving general economic conditions. 

2.2 Points of comparison  

The Pericles IV programme continues and builds on the previous Pericles programmes, 
which  operated  from  2001  to  2020,  and  all  of  which  aimed  to  protect  the  euro  as  the 
single  currency  against  the  ongoing  threat  of  counterfeiting  at  EU  level.  Those  earlier 
Pericles  programmes  also  ran  alongside  additional  measures  and  actions  taken  against 
euro  counterfeiting  at  national  level.  As  reflected  in  the  staff  working  document 
accompanying  the  Commission  proposal  to  set  up  the  Pericles  IV  programme,  the 
programme  was  continued  to  sustain  the  long-term  effectiveness  of  the  fight  against 
counterfeiting and to build on the success of the previous three processor programmes  2. 
Previous  evaluations  pointed  towards  the  high-level  of  EU  added  value  of  the 
programme,  which  is  derived  from  its  unique  focus  on  promoting  transnational  and 
multidisciplinary  cooperation  beyond  the  reach  of  individual  EU  Member  States,  as 
reflected in its legal basis in Article 133 TFEU3. This makes Pericles stand out in relation 
to  other  EU  programmes  and  national  measures.  This  unique  EU  added  value  is  also 
why,  at  the  time,  the  programme  was  continued  with  a  similar  design,  target  groups, 
eligible actions and intervention logic to the previous three iterations of the programme, 
while also ensuring that it addressed evolving needs in the protection of the euro against 
counterfeiting.  

2  European  Commission,  Staff  Working  Document  (SWD  (2018)  281  final)  accompanying  the 
Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  establishing  an 
exchange, assistance and training programme for the protection of the euro against counterfeiting 
for the period 2021-2027, available here. 

3 European Commission, Staff Working Document (SWD (2022) 207 final) Evaluation report on 
the final evaluation of the Programme for exchange, assistance and training for the protection of 
the euro against counterfeiting(‘Pericles 2020’ programme), available here. 

4 

 
 
In  terms  of  its  monitoring  framework,  the  programme  has  maintained  a  set  of  two 
quantitative performance indicators from previous generations of the programme, which 
provide a point of comparison, alongside three additional qualitative indicators4 that were 
added to measure the programme’s effectiveness (and are therefore addressed under that 
chapter).  The  two  quantitative  indicators  are  a.  the  number  of  euro  counterfeits 
(banknotes  and  coins)  detected  in  circulation,  and  b.  the  number  of  illegal  workshops 
(print  shops  and  mints)  dismantled.  The  target  for  both  indicators  is  for  the  number  of 
counterfeits  detected  and  workshops  dismantled  annually  to  remain  within  a  reference 
band range of +/- 5% (i.e. the target is for these figures not to increase by more than 5% 
or  decrease  by  more  than  5%)  compared  to  the  baseline  (average  2014-2020).  In  this 
way,  these  indicators  assess  whether  the  criminal  activity  of  euro  counterfeiting  stays 
under  control.  However,  and  as  emphasised  in  the  annual  programme  statements5,  the 
link between the programme and these indicators is only indirect. As is the case with any 
measurement of criminal phenomena, a variety of external factors play an important role 
in  the  development  of  these  indicators.  Such  factors  include  the  quality  of  detection 
mechanisms  in  place, the quality  of counterfeits,  criminal  intent  and location  of certain 
crime groups,  priorities set  by Member States’ law enforcement bodies, and length and 
scope of police investigations. 

With  this  in  mind,  the  indicator  for  the  number  of  counterfeit  banknotes  detected  in 
circulation should be examined as a primary point of comparison. In the years before the 
implementation of the programme (i.e. the period up to and including 2020, which is the 
relevant  period of time for the purpose of this  point of comparison),  a downward trend 
can be identified in this number6. Specifically, the ECB data highlight that the number of 
counterfeit  banknotes  detected  in  circulation  peaked  at  899 000  in  2015  and  then 
followed a broadly downward trajectory, reaching 460 000 in 20207.  

Figure 2 – Counterfeit euro banknotes detected in circulation (2014-2023) 

4 These are: (c) the number of competent authorities applying to the Pericles IV programme; (d) 
the satisfaction rate of participants in the actions financed by the Pericles IV programme; and (e) 
the  feedback  of  participants  that  have  already  taken  part  in  previous  Pericles  actions  on  the 
impact  of  the  Pericles  IV  programme  on  their  activities  in  protecting  the  euro  against 
counterfeiting. 

5 European Commission, Pericles IV Performance Statement 2023, available here. 

6

  The  trend  for  the  period  2021-2023,  i.e.  the  first  years  of  the  current  programme’s 
implementation, is examined in Section 4 on relevance. 

7 ECB, Number of counterfeit euro banknotes remains low in 2023, available here. 

5 

 
 
Source: ECB, Number of counterfeit euro banknotes remains low in 2023, available here. 

According  to  the  ECB  data,  the  banknote  denominations  which  were  most  frequently 
detected  to  be  counterfeit  in  2018,  before  the  implementation  of  the  Pericles  IV 
programme, were 20 and 50 euro banknotes, accounting for about 85% of the total, while 
counterfeit  100  euro  banknotes  accounted  for  9%  of  the  total,  with  all  other 
denominations accounting cumulatively for less than 8% of the total8.  

Figure  3  –  Breakdown  of  euro  counterfeit  banknotes  detected  by  denomination  (2018  vs 
2023) 

Source: ECB, Number of counterfeit euro banknotes remained low in 2023, available here. 

On counterfeit euro coins detected prior to the implementation of the current Pericles IV 
programme (i.e. the period up to and including 2020, which is the relevant period of time 

8 ECB, Euro banknote counterfeiting remained low in first half of 2018 (see here); ECB, Euro 
banknote counterfeiting decreased further and remained low in the second half of 2018 (see 
here). 

6 

 
 
 
for  the  purpose  of  this  point  of  comparison9),  they  had  remained  relatively  stable, 
amounting to a total of 210 400 in 2020 according to data from the European Technical 
and Scientific Centre (ETSC) 10.  

9

  The  trend  for  the  period  2021-2023  (i.e.  the  first  years  of  the  current  Programme’s 
implementation) is examined in Section 4 on relevance. 

10 ETSC annual reports, available here. 

7 

 
 
 
Figure 4 – Counterfeit coins detected in circulation (2014-2023) 

Source: ETSC annual reports, available here. 

The  breakdown  of  detected  counterfeit  euro  coins  by  denomination  highlights  a  clear 
trend  towards  higher  denominations  since  2014,  when  counterfeit  2  euro  coins 
constituted  68%  of  the  total  number  of  counterfeit  coins  detected,  while  in  2020  they 
increased to 87% of the total11.  

Figure 5 – Breakdown of euro coin counterfeits by denomination (2014-2022) 

Source: ETSC annual reports, available here. 

The  second  performance  indicator  carried  forward  from  previous  iterations  of  the 
Pericles programme and applied to the current Pericles IV programme is the dismantling 
of  illegal  workshops,  which  can  lead  to  the  seizure  of  counterfeits  before  their 
circulation. A significant number of illegal workshops were dismantled in the years prior 

11 ETSC annual reports, available here. 

8 

 
 
 
 
to  the  implementation  of  the  programme  (the  reference  period  of  this  point  of 
comparison), amounting to 189 during the programming cycle of Pericles 202012. 

Figure 6 - Total number of illegal workshops dismantled (2014-2023) 

Source: European Commission, Annual Report on Pericles IV for 2021, available here; European 
Commission, Annual Report on Pericles IV for 2022, available here; European Commission, Annual 
Report on Pericles IV for 2023, available here. 

The current outputs of the performance indicators that form the points of comparison do 
not lie within the above-mentioned reference band. While the number of coins is higher 
than  the  reference  band  (the  +/-  5%  target),  the  number  of  counterfeit  bank  notes  and 
workshops  dismantled are lower than  the target  range. This  again  attests to  the indirect 
nature  of  these  indicators  to  the  programme  performance,  as  other  external  factors  not 
related  to  the  programme  are  at  play,  such  as  the  potential  influence  of  the  COVID-19 
pandemic on the production and detection of counterfeits, the emergence of a particular 
high-quality counterfeit coin in south-east Europe, and different priorities and duration of 
law  enforcement  investigations.  However,  stakeholders  do  confirm,  that  the  euro-
counterfeiting  statistics  do  imply  that  the  situation  is  relatively  ‘under  control’  at  the 
moment, but that continued vigilance is necessary, underlining the important role of the 
programme. 

Finally, when determining the effect of counterfeit cash in circulation, some might argue 
that the overall use of cash in the economy should be taken into account. The data on this 
shows that, in 2016, the share of cash payments at points of sale was 76% in terms of the 
total  number  of  transactions  and  54%  in  terms  of  the  total  value  of  transactions, 
decreasing to 72% and 47% respectively in 201913. However, such statistics only capture 
part  of  the  situation,  as  the  total  amount  of  cash  in  circulation  continued  to  increase 

12 European Commission, Final evaluation report for Pericles 2020, available here; Europol, 
Annual report on euro counterfeiting 2020. 

13 ECB, Study on the payment attitudes of consumers in the euro area (SPACE) 2022, available 
here. 

9 

 
 
during  the  same  time  period  and  its  also  possible  that  cash  might  be  withheld  from 
circulation and stored as savings. Importantly, while a reduction in the use of cash would 
mean  a  lesser  prejudice  of  counterfeiting  on  citizens  and  the  economy,  the  need  to 
maintain  trust  in  Europe’s  single  currency  remains  unchanged.  The  use  of  cash  is 
therefore a relevant element to consider, but it is not a suitable indicator of comparison 
for assessing the relevance or the effectiveness of the programme. 

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

Current state of play 

The programme has a total budget of EUR 6.2 million for its overall programming cycle 
from 2021 to 2027. The annual budgets were EUR 0.8 million for 2021, EUR 0.9 million 
for  2022  and  EUR 0.6  million  for  2023  with  an  additional  EUR 200 000  as  a  support 
budget line for 202314. Up to 2023, which marks the last publicly available data point, a 
total  of  19  grants  were  provided  under  the  programme,  in  addition  to  7  procured 
Commission actions and the annual e-Grant fee15. 

Table 1 - Amount division of actions under the Pericles IV programme in 2021, 2022 and 
2023  

Year 

Grants 

Procured Commission actions 

e-Grant contribution 

2021 

2022 

2023 

5 

5 

9 

3 

3 

1 

Total 
Source: European Commission, Pericles IV annual reports, available here. 

19 

7 

1 

1 

1 

3 

Over  the  past  three  years,  eight  bodies  have  received  grants  under  the  programme:  the 
German  Federal  Police  (BKA),  the  Bank  of  Portugal  (BDP),  the  Italian  anti-
counterfeiting  agency  (CCAFM),  the  Bank  of  Spain  (BDE),  the  Bank  of  Spain’s 
monetary offences investigation brigade (BIBE), the Italian financial crime investigation 
unit  (GdF),  the  French  central  office  for  the  repression  of  money  counterfeiting 
(OCRFM) and the Croatian National Bank. The European Commission is also marked as 
a  recipient,  for  the  procured  actions  directly  organised  by  the  European  Commission 
itself16. 

14 The support line was used for the procurement of the mid-term evaluation (EUR 156 502.50) 
and for the partial funding of the e-Grant tool (EUR 18 613.50). 

15 European Commission, Pericles IV annual reports, available here. 

16 European Commission, Pericles IV annual reports, available here. 

10 

 
 
 
Figure  7  -  Total  amount  from  the  Pericles  IV  programme  (2021,  2022  and  2023)  by 
recipient

Source: European Commission, Pericles IV annual reports, available here. 

The programme has financed a wide variety of eligible actions, reflecting those that are 
provided for in Article 6 of the Regulation. Specifically, between 2021 and 2023, 39% of 
all  funds  provided  were  allocated  to  technical  training,  24%  to  seminars,  19%  to  staff 
exchanges, 10% to administrative tasks and 8% to studies17. 

Figure 8 - Total amount from the Pericles IV programme (2021, 2022 and 2023) by activity 
type 

17 European Commission, Pericles IV annual reports, available here. 

11 

 
 
 
Source: European Commission, Pericles IV annual reports, available here. 

4.  EVALUATION FINDINGS 

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

The  programme  has  effectively  contributed  to  preventing  and  combating  euro 
counterfeiting,  thereby  preserving  the  integrity  of  euro  banknotes  and  coins.  It  has 
fostered cooperation and increased the capacity to protect the euro among institutions in 
Member  States  and  non-EU  countries  through  technical  training,  seminars,  staff 
exchanges  and  studies.  Participating  competent  national  authorities  (CNAs)  have 
included  staff  members  representing  law  enforcement  agencies,  national  central  banks, 
judiciary,  customs,  mints  and  national  ministries  There  has  also  been  participation  by 
private  sector  bodies,  such  as  commercial  banks  and  companies  that  make  and  operate 
coin-processing  machines18.  Participants  have  reported  that  the  programme  has  helped 
them to improve their skills in detecting and identifying counterfeit banknotes and coins, 
and  increase  their  knowledge  of  technical  equipment19.  Non-EU  authorities  have 
particularly benefited from technical training, which has supported their ability to prevent 
and combat euro counterfeiting. The programme has also bolstered institutional capacity 
in  Member  States  and  non-EU  countries,  contributing  to  improved  procedures  and 
enhanced legal frameworks. The programme has ensured an efficient use of resources in 
achieving  its  outputs,  results  and  impacts,  and  remains  complementary  to  initiatives  by 
other EU institutions. 

Effectiveness 

18 Supporting study report. 

19 Survey conducted as part of the supporting study report. 

12 

 
 
The Pericles IV programme has successfully fostered cooperation and increased the 
capacity to protect the euro among relevant institutions in Member States and non-
EU  countries.  The  programme’s  actions  have  helped  to  establish  critical  contacts  and 
exchange  information  and  best  practices,  both  between  other  countries  and  among 
different stakeholders within countries (i.e. cooperation between police, central bank and 
judiciary).  This  has  significantly  improved  institutional  and  operational  capabilities20. 
The transnational and multidisciplinary nature of the implemented Pericles IV actions in 
particular  brings  multiple  benefits.  For  example,  it  facilitates  cross-border  cooperation, 
the  exchange  of  best  practices  and  the  transfer  of  information  among  countries  and 
between 
the  fight  against 
counterfeiting, all tackling together a transnational phenomenon that is not restricted by 
borders. 

institutional  stakeholders 

the  different 

involved 

in 

By  providing  technical  training,  seminars,  staff  exchanges  and  studies,  the  programme 
has  supported  and  supplemented  measures  undertaken  by  Member  States.  Particularly 
where national funding is limited, the programme has successfully fostered cooperation 
and  the  exchange  of  best  practice  between  Member  States,  EU  authorities,  non-EU 
countries and international organisations. This has created formal and informal contacts, 
facilitating enquiries and collaborative investigations21. 

The  programme’s  success  is  largely  a  result  of  its  current  design  as  a  stand-alone 
programme,  where  Member  States  and  DG  ECFIN  have  the  opportunity  to  cooperate 
closely22.  This  management  style  yields  significant  benefits,  precisely  because  the  DG 
ECFIN unit managing the programme acts as an operational business unit. By acting as 
an  operational  business  unit  in  this  area  DG  ECFIN  is  integral  not  only  to  developing 
strategy,  planning  actions  and  coordinating  efforts  within  the  ECEG,  but  also  to 
implementing  actions.  This  is  key  to  both  staying  on  top  of  new  developments  in  the 
sphere  of  euro  counterfeiting  and  aligning  the  programme  with  the  needs  of  Member 
States  and  participants.  The  unit’s  close 
in  both  planning  and 
implementation  ensures  a  coherent  and  focused  approach,  which  brings  added  value  to 
Member States and non-EU countries and ensures the programme’s effectiveness23. 

involvement 

20 Supporting study report. 

21 Supporting study report. 

22 Based on consultation with stakeholders who appreciated the support provided by the EC 
experts (involved in the Pericles management) during both the application and implementation 
process. 

23 European Commission, Staff Working Document (SWD (2017) 443 final) Evaluation report on 
the mid-term evaluation of the Programme for exchange, assistance and training for the 
protection of the euro against counterfeiting (‘Pericles 2020’ programme), available here. 

13 

 
 
Programme  participants  have  reported  several  benefits,  with  more  than  70%  of  those 
surveyed finding the programme actions useful to a large extent for learning about best 
practices and establishing contacts within the EU24. Among other actions, staff exchanges 
in  particular  were  deemed  useful  for  the  exchange  of  best  practice,  knowledge  and 
practical skills, a benefit valued to a large extent by 46% of survey respondents. 

Programme participants also reported that the programme actions improved their skills in 
detecting,  identifying,  and  classifying  counterfeit  banknotes  and  coins,  and  increased 
their knowledge of technical  equipment25.  In addition,  the  programme  helped to bolster 
institutional  capacity  both  in  Member  States  (such  as  through  improved  currency 
authentication  procedures  in  commercial  banks)  and  –  in  particular  –  in  non-EU 
countries,  where  participation  has  helped  improve  legal  frameworks  and  operational 
capabilities,  (these  operational  capacities  are  often  built  on  the  basis  of  information 
gathered  during  participation  in  programme  actions).  For  example,  after  contacts  were 
established  through  Pericles  IV,  a  joint  investigation  involving  Argentina  and  Peru 
addressed  the  smuggling  of  counterfeit  euro  and  dollars  by  Peruvian  criminals  through 
Argentina,  which  led  to  the  seizure  of  3 million  euro  and  5 million  euro  in  counterfeit 
euro  respectively26.  Furthermore,  participation  in  Pericles  IV  actions  such  as  those 
organised by the Spanish BIBE and the Commission itself have helped several non-EU 
countries,  such as  Chile, Uruguay, Kosovo27 and Moldova, to  begin setting up  national 
central offices for coordinating investigations related to euro counterfeiting. 

The overall satisfaction rate of participants in the actions financed by the programme has 
remained  consistently  at  very  high  levels,  with  an  average  annual  satisfaction  rate  of 
99.1% – much higher than the target set of 75%28. Furthermore, 97% of participants who 
have  already  taken  part  in  previous  Pericles  actions  report  that  the  programme  had  a 
positive impact on their activities to protect the euro against counterfeiting – significantly 
higher  than  the  75%  target.  The  data  also  show  an  increasing  number  of  unique 
competent authorities applying to participate in the programme, with 8 having applied as 
of 2023, although it could prove difficult to reach the target of having 24 apply by 2027 
without additional promotional activities and/or adjustments to the work programmes. In 
addition,  the  data  for  the  previous  Pericles  programmes  shows  that  the  number  of 
participants  in  Pericles  IV  was  almost  100  fewer  on  average  per  year  than  its  previous 
iteration,  Pericles  2020.  This  fall  can  likely  be  explained  by  the  programme’s  reduced 

24 Survey conducted as part of the supporting study report. 

25 Supporting study report. 

26 Interview with a non-EU stakeholder as part of the supporting study report. 

27 This designation is without prejudice to positions on status and is in line with UNSCR 1244 
and the ICJ opinion on Kosovo Declaration of Independence. 

28 Survey conducted as part of the supporting study report. 

14 

 
 
budget, as well as by sharply reduced participation during the COVID-19 pandemic and 
post-pandemic  period.  Moreover,  the  total  number  of  participants  depends  also  on  the 
types  of  actions  financed  in  a  given  year:  while  conferences  generally  involve  more 
attendees, actions such as staff exchanges or technical training are by design addressed to 
fewer attendees. Compared to the previous programme period (Pericles 2020, which ran 
from  2014-2020),  the  programme’s  current  implementation  has  thus  far  included  a 
relatively  higher  number  of  such  staff  exchanges  and  technical  training  compared  with 
conferences, thereby also contributing to a lower number of total participants29. 

Efficiency 

The  programme’s  coordination,  management,  and  administrative  structures  are 
generally  adequate.  Nevertheless,  the  paragraphs  below  set  out  some  areas  of 
improvement  (for instance relating  to  the  participation and  duration of  ECEG meetings 
and the subsistence unit costs). Acting on these areas of improvement would generally 
ensure  a  more  efficient  use  of  resources  to  achieve  outputs,  results  and  impacts30. 
The digitalisation of the application process via the e-Grants portal simplified the process 
by removing burdens such as the need to send grant agreements for signature by post, by 
streamlining  the  application  file  into  one  easy-to-manage  digital  platform,31  and  by 
facilitating quick and direct communication between the Commission and applicants. The 
timeframe for the signature of grant agreements increased slightly (61 days in Pericles IV 
compared to 57 under Pericles 2020), due to the change to the process for signing grant 
agreements process: The Commission e-Grants portal requires the applicant to follow a 
number  of  steps  before  the  grant  agreement  can  be  signed,  in  order  to  establish  the 
approval  of  both  contracting  parties  to  the  agreement  and  avoid  future  amendments32. 
Furthermore,  applicants  still  consider  it  relatively  time-consuming  to  apply  to  the 
programme,  although  they  claim  that  the  benefits  outweigh  the  costs33.  The  more 
complex and sizeable the action in terms of audience and logistics, the higher the number 
of  staff  days  spent  on  the  application-preparation  process.  Finally,  more  than  85%  of 
grant  recipients  agreed  that  the  support  provided  during  the  various  stages  of 
implementation by the unit managing the programme was highly valuable34. 

29 European Commission, Staff Working Document (SWD (2022) 207 final) Evaluation report on 
the final evaluation of the Programme for exchange, assistance and training for the protection of 
the euro against counterfeiting (‘Pericles 2020’ programme), available here. 

30 Supporting study report. 

31 The EU funding and tenders portal (e-Grants portal) available here. 

32 The grant agreement process is explained in the Commission manual, available here. 

33 Stakeholder consultation as part of the supporting study report. 

34 Stakeholder consultation as part of the supporting study report. 

15 

 
 
that  has  extended 

On  the  programme’s  management,  partner  institutions  like  the  ECB  and  Europol  also 
gave  a  positive  assessment  of  their  cooperation  with  DG  ECFIN,  demonstrating  the 
positive  collaboration 
through  programming  periods.  This 
collaboration is also being expanded to include judicial authorities by adding Eurojust to 
the  list  of  ECEG  meeting  participants.  These  meetings  are  key  to  the  programme’s 
coordination  and  management  and  take  place  three  times  a  year.  ECEG  meetings  have 
proven valuable to stakeholders, who have reported that all topics discussed therein have 
been useful. Nevertheless, some stakeholders indicate that fitting all discussions into one 
single day is a limiting factor, and that the meetings should be extended to a second day. 
Stakeholders  also  mention  the  possibility  of  involving  Member  State  judiciaries  on  a 
more structural basis35. 

The  annual  management  costs  of  the  programme  in  2023  were  around  EUR 201 125 
(1.37 FTEs), which was lower than those of the last year of Pericles 2020 implementation 
–  around  EUR 224 000  in  2020  (1.46  FTEs).  This  represents  an  approximate  annual 
saving of EUR 22 875. The total annual programme budget for 2023 was EUR 867 060, 
with the programme management costs accounting for 23.2% of this total budget. While 
the  management  costs  of  the  Pericles  IV  programme  remain  higher  than  the  average 
management costs of similar programmes, efficiency gains are noted due to a reduction 
in  the  FTEs  required  compared  to  the  previous  Pericles  2020  programme.  These 
efficiency gains can be mainly attributed to the digitalisation of the application process. 
However, reduction in required FTEs did not result in lower relative management costs 
compared to the previous iteration of the programme, because of the general budget cut 
to  the  programme’s  allocation  under  the  current  Multiannual  Financial  Framework 
(MFF), which offset this potential gain36. The Pericles programme is also subject to two 
independent  evaluations  per  programming  cycle  –  one  mid-term  evaluation  and  one  ex 
post  evaluation.  This  is  normal  practice  for  MFF  initiatives.  However,  given  the 
programme’s unique size and the fact that Pericles is a continuous iteration of previous 
programmes,  which  ensures  continuity,  the  question  of  the  proportionality  of  two 
evaluation requirements per cycle in relation to the limited overall budget may need to be 
considered. 

There are several other drivers affecting Pericles IV’s management cost structure. First, 
Pericles  IV  is  managed  by  the  active  business  unit.  The  Commission’s  direct 
involvement  in  implementing  Member  State  actions  ensures  Member  State  buy-in  and 
also serves as a monitoring mechanism by making possible on-the-spot monitoring of the 
implementation of actions. DG ECFIN staff participate in most programme events, often 

35 Stakeholder consultation as part of the supporting study report. 

36 1.9 FTEs were required in 2015 under the Pericles 2020 programme and 1.7 FTEs in 2020 
under the same programme. These statistics are provided in: Staff Working Document 
(SWD(2017) 443 final), available here; Staff Working Document (SWD(2022) 0207 final), 
available here. 

16 

 
 
chairing them, delivering presentations, leading workshops, co-drafting conclusions and 
using  the  resulting  outputs.  They  also  chair  and  moderate  the  ECEG  meetings,  which 
take place three times a year.  

The  programme  is  characterised  by  appropriate  programming  and  resource  allocation, 
achieving  high  levels  of  commitments.  In  2022,  commitments  amounted  to  97.41%  of 
the overall budget,  and  100% in  2021. The latest  figures for 2023 show  a commitment 
rate of 99.88% of the total budget37. 

Grant  beneficiaries’  absorption  rates  deviated  from  the  high  levels  of  allocation.  Data 
from  eight  grant  beneficiaries  showed  an  average  difference  of  -11%  between  planned 
and  actual  grants,  totalling  over  EUR 170 000.  Deviations  ranged  from  0%  to  -27%, 
mainly  due  to  changes  in  costs  for  travel,  subsistence,  hotel,  staff,  equipment  and 
subcontracting. For seven out of eight reviewed cases, the budgets actually implemented 
were  lower  than  those  planned,  yet  the  scope  and  objectives  were  largely  achieved, 
indicating efficient resource use. The final evaluation of Pericles 2020 showed a similar 
divergence  for  beneficiaries  requesting  maximum  eligible  amounts  to  avoid  overruns38. 
Programme  attendance  records,  maintained  as  part  of  beneficiary  reporting  duties, 
demonstrate  that  unforeseen  circumstances  also  contributed  to  some  participants 
dropping out of individual actions, although this is not systematic. 

The main challenge for action organisers is the unit costs for subsistence. he programme 
uses unit costs for subsistence as a key cost category in line with Commission Decision 
C(2021)  351,  amended  by  Commission  Decision  C(2023) 49282.  However,  travel  and 
accommodation  costs  are  reimbursed  on  the  basis  of  actual  costs.  According  to  the 
stakeholders organising Pericles IV funded actions, inflation has made subsistence costs 
a  major  challenge  and  the  latest  update  to  the  Commission  Decision  did  not  address 
this39.  A  new  amendment,  to  be  published  on  the  EU  funding  and  tenders  portal,  is 
expected  to  update  accommodation  and  subsistence  rates.  Despite  these  challenges, 
stakeholders  have  not  reported  significant  efficiency  issues  in  the  implementation 
process40. 

37 European Commission, Annual Report on Pericles IV for 2021, available here; European 
Commission, Annual Report on Pericles IV for 2022, available here; European Commission, 
Annual Report on Pericles IV for 2023, available here. 

38 European Commission, Staff Working Document (SWD (2022) 207 final) Evaluation report on 
the final evaluation of the Programme for exchange, assistance and training for the protection of 
the euro against counterfeiting(‘Pericles 2020’ programme), available here. 

39 C(2024) 5405 final, available here; stakeholder consultation as part of the supporting study 
report. 

40 Stakeholder consultation as part of the supporting study report. 

17 

 
 
Non-applicants  cited  financial  constraints  and  internal  procedures  as  barriers  to 
participation in the programme. For some, euro counterfeiting is not a high priority due 
to low levels of suspected counterfeiting in their countries41. 

For the 19 actions awarded a grant, the average co-financing rate is 81%. While 58% of 
projects awarded a grant received co-financing at the standard rate of 75%, 42% were co-
financed  at  a rate of 90%. These 42%  were  complex and cost-intensive actions  outside 
the EU, or  addressed new programme  priorities. To date, during the  implementation  of 
Pericles IV, there has been an increase in requests for higher co-financing compared with 
Pericles  2020.  The  90%  co-financing  rate  is  therefore  a  vital  tool  to  ensure  the 
programme’s  effectiveness  by  encouraging  applicants  to  address  key  priorities  and 
organise  more  logistically  complex  actions.  By  giving  more  actions  the  higher  co-
financing  rate,  the  programme  limits  the  budget  for  future  actions,  with  the  difference 
between the 75% and 90% rates amounting to EUR 162 709.19, equating to roughly 1.5 
fewer grants that could  have been implemented. The conditions for higher co-financing 
are  therefore  carefully  monitored  by  DG  ECFIN,  the  business  unit  managing  the 
programme and evaluated annually as part of the annual work programme. As a higher 
co-financing  rate  without  an  increased  overall  budget  is  undesirable,  the  current  setup 
(75% standard, 90% in justified cases) is appropriate.  

Any  further  budget  cuts  would  negatively  impact  the  programme’s  scope,  with  recent 
cuts already reflected in the decrease in actions and participants in Pericles IV compared 
with Pericles 2020. In its first two years, the programme funded 10 grants, a 50% drop 
from  Pericles  2020.  The  decrease  is  attributed  to  inflation  and  to  the  horizontal  cuts 
applied  to  the  programme’s  budget  in  the  context  of  the  current  MFF  cycle.  Based  on 
budget  allocations  in  the  first  four  years  of  Pericles  IV,  the  impact  of  the  combined 
effects  of  these  reductions  on  the  budget  is  estimated  at  minus  32%,  in  real  terms,  as 
compared  to  Pericles  2020.  Concerns  regarding  the  budget  are  also  reflected  in  the 
feedback  from  stakeholders,  who  are  largely  of  the  opinion  that  the  budget  is  not 
sufficient and that it results in a more limited set of implemented actions, as organisers 
have  to  choose  between  different  action  types.  Survey  responses  pointed  out  that  an 
increase in the Pericles programme budget would be beneficial for eligible participants as 
it would allow them to implement more actions42. 

Figure 9 - Evolution of the Pericles IV budget expressed in current and 2020 constant prices 

41 Stakeholder consultation as part of the supporting study report. 

42 Survey responses as part of the supporting study report. 

18 

 
 
Source: Supporting Study Report. 

Coherence 

On  consistency  and  complementarity  with  other  relevant  EU  programmes  and 
activities, the programme distinct transnational and multidisciplinary approach, its 
emphasis  on  capacity  building  and  its  thematic  focus  on  euro  anti-counterfeiting. 
These  set  the  programme  apart  from  other  EU  programmes  such  as  the  Internal 
Security  Fund  (ISF),  the  technical  assistance  and  information  exchange  (TAIEX), 
twinning  instruments43,  and  international  initiatives,  which  rarely  display  the  same 
features  simultaneously.  Indeed,  several  CNAs  and  non-EU  authorities  have  been 
involved in other programmes but, as stated in the stakeholder interviews, they regard the 
Pericles IV programme as unique, complementing other initiatives effectively44. 

While  coordination  between  the  programme  and  international  initiatives  such  as  those 
organised by INTERPOL could be improved (e.g. more coordination on cooperation with 
China45),  there  is  a  high  degree  of  coordination  both  with  other  EU  bodies  and  with 
international partners. This coordination is primarily achieved through the organisation of 
three annual ECEG meetings, during which the plans and results of actions are actively 
discussed by all stakeholders to  ensure their complementarity. During  ECEG meetings, 
potential applicants are also informed of the remaining annual budget available, allowing 
them to  consider whether, and with  what  type/size of action, to  apply. This  leads to  an 
overall  positive  assessment  of  the  programme’s  complementarity  with  other  existing 
initiatives.  

43 Information about the ISF is available here; information about the TAIEX instrument is 
available here; information about the Twinning instrument is available here. 

44 Stakeholder consultation as part of the supporting study report. 

45 Interview with international institution as part of the supporting study report. 

19 

 
 
 
In  particular,  the  activities  organised  by  the  ECB  are  of  a  technical  nature  and  provide 
new insights into the technical aspects of counterfeit production. To this end, the ECB’s 
activities  are  mostly  relevant  to  national  central  banks,  while  those  carried  out  by  the 
ECB’s  Counterfeit  Analysis  Centre  supplement  the  activities  carried  out  under  the 
Pericles umbrella. Europol (in particular through the European multidisciplinary platform 
against criminal threats (EMPACT)46) also seeks to provide training and contribute to the 
capacity building of law enforcement. This task overlaps, in part, with the objectives of 
the  Pericles  programme.  For  this  reason,  Europol  (EMPACT)  and  DG  ECFIN  agreed47 
that,  given  its  specialisation  and  interdisciplinarity,  the  Pericles  programme  would  take 
the initiative in this regard and allow EMPACT to put  its additional brand on  the most 
relevant  Pericles  initiatives.  This  would  enable  Europol  to  focus  its  activities  on 
operational  support.  This  agreement  has  been  effectively  put  into  practice,  thereby 
avoiding  the  above-mentioned  overlap  and  maximising  the  efficient  use  of  resources. 
Lastly, given that the role and objectives of the ETSC are closely aligned with those of 
the programme and since the ETSC is managed by the same business unit in ECFIN as 
the  Pericles  IV  programme,  complementarity  and  close  cooperation  is  ensured  through 
central coordination within the business unit. 

On  consistency  and  complementarity  with  existing  actions  implemented  by  Member 
States themselves, the fulfilment of the programme’s strict transnationality requirement is 
carefully scrutinised when the actions to be implemented are selected. This minimises the 
risk  of  overlap  with  Member  State  initiatives,  which  are  usually  solely  national  in 
scope48.  On  the  whole,  the  activities  aimed  at  preventing  counterfeiting  of  the  euro  at 
Member State level remain limited and consist of elementary training, not least due to the 
limited priority generally given to currency counterfeiting, as reported by stakeholders49. 
This  shows,  as  was  also  indicated  during  evaluations  of  previous  iterations50,  that  the 
Pericles IV programme is addressing something that receives relatively little attention at 
the  national  level–.  The  programme’s  activities  can  therefore  be  regarded  as  fully 
complementary and additional to national initiatives, without any overlap. 

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

The protection of the European single currency as a public good has a clear transnational 
dimension, and euro protection therefore goes beyond the interest and the responsibility 

46

 EMPACT fosters multidisciplinary and multiagency operational cooperation to fight organised 

crime at EU level. More information on EMPACT is available here. 

47 Exchange of emails between ECFIN C5 and EMPACT Driver. The agreement was 
subsequently presented to the experts at the following ECEG meeting. 

48 Active observation of Pericles IV funded action as part of the supporting study report 

49 Stakeholder consultation as part of the supporting study report. 

50 ECORYS, final evaluation Pericles 2020, available here. 

20 

 
 
of  individual  EU  Member  States.  Considering  the  cross-border  circulation  of  the  euro, 
the  deep  involvement  of  international  organised  crime  in  euro  counterfeiting,  and  the 
increasing threats posed by the internet and altered design banknotes, national protection 
frameworks  need  to  be  complemented  in  order  to  ensure  homogeneous  national  and 
international  cooperation,  and  to  deal  with  possible  emerging  transnational  risks.  The 
Pericles  IV  programme’s  continued  added  value  lies  essentially  in  its  ability  to 
support collective forms of international cooperation, between  Member States and 
with  non-EU  countries,  which  are  beyond  the  reach  of  individual  national 
authorities51.  These  collective  forms  of  international  cooperation  include  establishing 
collaboration channels with Chinese and Turkish authorities on emerging counterfeiting 
threats such as altered-design banknotes, which is more difficult and less effective when 
carried  out  only  at  Member  State  level52.  Pericles  IV  also  takes  the  initiative  to 
consolidate  information  and  knowledge  on  new  trends,  threats  and  developments,  of 
which  the  study  on  movie  money  is  one  example.  The  threat  posed  by  altered-design 
banknotes such as movie money is aggravated by the different interpretations of the EU 
legal  framework  and  corresponding  approaches  in  the  Member  States.  To  address  this 
threat  effectively,  coordination  and  continuous  exchange  between  Member  States  is 
needed  to  reduce  legal  loopholes.  This  is  another  area  where  the  Pericles  programme 
offers added value. 

The provision of dedicated financial or capacity resources specifically designed to protect 
the euro from counterfeiting is also important in maintaining a high level of protection. 
This high level of protection would otherwise not exist given budgetary and geopolitical 
limitations  that  make  it  more  difficult  for  individual  Member  States  to  cooperate  with 
specific non-EU countries like China outside an EU institutional context.  

4.3. 

Is the intervention still relevant? 

The general and specific objectives are relevant and are likely to remain so during 
the  programme’s  cycle.  Protecting  the  euro  against  counterfeiting  is  a  continuous 
requirement with an evolving threat. Despite the uptick in the detection of counterfeit 
euro  banknotes  in  2023,  as  evidenced  in  Figures  2  and  3,  the  relatively  lower  average 
number of counterfeit banknotes detected on an annual basis during the current Pericles 
IV programme period compared to the previous programme period should not necessarily 
lead  to  the  conclusion  that  criminals  have  a  decreasing  interest  in  euro  counterfeiting. 
This is primarily because the trend can be interpreted as being the result of the deterrent 
effect of detection mechanisms, cooperation and investigations successfully set up and in 

51 Interviews with successful applicant Member States and interviews with non-applicant 
Member States as part of the supporting study report. 

52 Interviews with successful applicant Member States and interviews with non-applicant 
Member States as part of the supporting study report. 

21 

 
 
 
place  at  EU  level.  It  also  is  difficult  to  assess  the  full  extent  and  scope  of  the 
counterfeiting  issue,  for  lack  of  complete  information  on  illicit  activities  (i.e.  the  dark-
figure  problem).  Conversely,  according  to  the  views  of  stakeholders  across  the  board, 
there does not appear to be a correlation between a lower number of detected counterfeit 
banknotes and the decline in the use of cash53. 

The  euro-counterfeiting  statistics  do  indeed  imply  that  the  situation  is  relatively  ‘under 
control’  at  present.  However,  continuous  attention  is  needed  to  maintain  this  situation; 
the  situation  escalating.  Such  escalation  risks 
diverting  attention  would  risk 
compromising the integrity of citizens and businesses and their trust in the authenticity of 
euro  banknotes  and  coins,  thereby  affecting  overall  trust  in  the  EU  economy.  For  this 
reason, vigilance must remain high, because,  as  long  as cash  is  used, the risk posed by 
counterfeits persists. This is also demonstrated by the recent and significant increase in 
counterfeit euro coins detected in circulation, as shown in Figure 4, with the amount of 
counterfeit  coins  detected  almost  doubling  to  414 400  in  2023  compared  to  the  total 
amount  detected  in  202054.  This  is  primarily  due  to  the  emergence  of  a  particularly 
threatening counterfeit coin class, predominantly detected in south-east Europe. 

Up until now the programme has funded a variety of actions that specifically address the 
most pressing current threats, including the higher quality of counterfeits, altered design 
banknotes and the ease with which counterfeits can be purchased, especially because of 
online distribution. Therefore, as threats develop rapidly, there is a continued need for the 
programme, the design and implementation of which must be reassessed continuously in 
the light of evolving and future threats to the euro55. These threats include counterfeiting 
risks posed by criminals active in key non-EU countries such as China and Türkiye, from 
which  counterfeit  products,  such  as  altered-design  banknotes,  and  counterfeit  security 
features,  such  as  illegal  holograms  are  imported.56.  Particularly  deceptive  counterfeits 
such as counterfeit coin classes circulating in south-east Europe will also require further 
attention  in  the  future.  Another  ongoing  priority  is  the  close  monitoring  of  new  and 
evolving distribution channels for counterfeit currency on the internet and darknet. And 
potential  future  developments,  such  as  the  use  of  artificial  intelligence  and  the  future 
introduction of the digital euro pertain to the continued relevance of protecting the single 
currency.  

Stakeholders consider both the different types of actions financed and the participation of 
target  groups  to  be  highly  relevant.  Although  public  prosecutors  are  included  in  the 
programme’s  key  target  groups  and  have  already  participated  in  several  actions,  they 

53 Supporting study report. 

54 ETSC annual reports, available here. 

55 Survey of Programme participants as part of the supporting study report. 

56

 As confirmed by the annual Pericles strategy annexed to the AWP, available here. 

22 

 
 
could be involved more actively in the programme, which would allow it to cover more 
parts of the counterfeiting process (i.e. it would allow the programme to  also cover the 
prosecution of alleged counterfeiters). Moreover, stakeholders also suggest that involving 
the  judiciary  is  particularly  relevant,  given  differences  in  the  legal  interpretation  of  the 
use and possession of altered-design banknotes57. Similarly, customs authorities and the 
private sector were also identified as relevant stakeholders to involve more actively than 
at  present.  Although  customs  and  postal  and  delivery  services  could  play  a  key  role  in 
identifying parcels with  counterfeit banknotes, knowledge on anti-counterfeiting among 
these stakeholders remains limited. 

It  is  important  to  note,  however,  that  the  needs  of  Member  States  seem  to  differ 
according  to  their  anti-counterfeiting  approach  and  the  priority  they  give  to  this  issue. 
Whereas  some  Member  States  are  relatively  advanced  and  want  to  explore  how  the 
programme could provide protection against future threats, other Member States (or non-
EU countries) want to develop the basic capabilities to identify counterfeits and train law 
enforcement personnel on how to respond58. To meet the needs of these different groups, 
it would be worth ensuring sufficient targeted focus and corresponding actions for each 
of these tracks. 

4.4. 

Is the intervention sustainable? 

The  Pericles  IV  programme  is  the  most  recent  of  an  uninterrupted  series  of  Pericles 
programmes starting in 2002. By taking advantage of the positive implementation of the 
previous  measures,  the  programme  has  successfully  ensured  the  sustainability  over 
time  of  its  outputs  and  future  progress  towards  its  objectives.  International 
networking through the programme could be further expanded and further solutions may 
be sought to address language barriers, which have occasionally posed challenges during 
training  and  networking  activities.  Nevertheless,  participants  have  widely  adopted 
structured  knowledge-sharing  practices,  both  formal  and  informal,  and  these  have 
strengthened operational capacities and facilitated the use of new methods and contacts 
within the EU.  

Feedback from participants shows strong  engagement in  dissemination  activities within 
their  institutions  and  countries,  with  participants  sharing  information  through  various 
informal 
channels.  The  most  common  practices 
information  transfer  during  regular  activities,  internal  memos  and  presentations.  Less 
frequent methods include newsletters, articles, e-learning platforms and formal training59.  

include  distributing  materials, 

57 supporting study report. 

58 Interviews with successful applicant Member States and EU-level stakeholders as part of the 
supporting study report. 

59 Survey conducted as part of the supporting study report. 

23 

 
 
For  instance,  countries  in  the  south-eastern  Europe  network  organise  national-level 
training to transfer knowledge on using technical equipment and identifying counterfeits. 
The  Montenegrin  authorities  hold  frequent  training  sessions  at  the  police  academy  for 
border  control  officers.  These  sessions,  held  jointly  with  the  police,  central  bank,  and 
prosecutor’s  office  focus  on  recognising  counterfeits  and  new  trends  in  counterfeiting 
and  are  used  to  disseminate  knowledge  on  best  practice  obtained  during  Pericles  IV 
actions. Such national activities complement, but do not replace, Pericles IV activities. 

Participants  who  have  already  taken  part  in  previous  Pericles  actions  also  offer  very 
positive feedback (an average of above 97%) on the impact of the Pericles IV programme 
on their activities to protect the euro against counterfeiting60. 

It  is  interesting  to  note  the  inclusion  of  diverse  stakeholders,  such  as  supermarket  and 
airport  cashiers,  in  dissemination  activities.  This  is  particularly  relevant  in  Balkan 
countries where the euro is used unofficially. 

Regular follow-up actions and ongoing support ensure that this knowledge is maintained 
and updated. Stakeholders appreciate staying abreast of counterfeiting developments but 
also  point  to  the  issue  of  frequent  staff  turnover,  emphasising  the  need  for  repeated 
training every two or three years61. This is also reflected in the list of actions financed by 
Pericles IV and its predecessor programmes. Continued support is especially crucial for 
non-EU countries to  institutionalise processes acquired through training workshops and 
to  strengthen  regional  cooperation,  such  as  that  in  south-eastern  Europe  and  Latin 
America62. 

On  institutional  engagement,  commitment  and  obstacles,  participants  in  programme 
actions have seen their roles evolve in a positive manner, with increased involvement in 
euro-protection  activities.  This  is  reflected  in  higher  quality  investigations,  improved 
police  operations  and  refined  skills.  A  high  retention  rate  among  participants  in  these 
actions contributes to institutional capacity building while new colleagues are effectively 
onboarded through existing materials and training. 

Although  there  is  strong  strategic  and  institutional  commitment  to  continuing  euro-
protection  activities,  perceptions  of  resource  availability  vary.  Some  stakeholders, 
especially from non-EU  countries, highlight a lack of resources  for euro counterfeiting, 
underscoring the importance of the programme.63  

60 Supporting study report. 

61 Interviews with non-EU countries as part of the supporting study report. 

62 Regional cooperation is explained in the annex to the yearly Pericles strategy and in the AWP, 
available here. 

63 Supporting study report. 

24 

 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1.  Conclusions 

The overall assessment of the findings of the evaluation, taken together, is positive. Up to 
2023,  a  total  of  19  grants  were  provided  for  actions  to  be  organised  by  the  Member 
States,  in  addition  to  7  procured  actions  organised  by  the  European  Commission.  This 
demonstrates  that  the  programme  has  been  implemented  effectively.  The  programme’s 
current  structure  will  also  allow  it  to  continue  to  be  implemented  effectively  for  the 
remainder of the MFF period. Although there is room for small improvements, it is clear 
from the evaluation that Pericles IV performs well in respect of all six evaluation criteria, 
as set out in the summary below. 

Effectiveness 

information  exchange,  significantly 

The  programme  is  effectively  meeting  its  objectives  as  outlined  in  Article  2  of  the 
Regulation.  It  has  successfully  improved  cooperation  and  capacity  to  protect  the  euro 
among  institutions  in  Member  States  and  non-EU  countries  while  its  actions  have  also 
improving 
facilitated  critical  contacts  and 
institutional  and operational  capabilities64. Thus, for the remainder of the programming 
period, attention should be paid to ensuring that this balance is maintained. Maintaining a 
balance of types of action is essential to address the multifaceted nature of counterfeiting, 
allowing the programme to remain relevant, adaptable and flexible, ready to respond to 
new  challenges  and  trends.  In  addition,  the  different  actions  often  involve  different 
stakeholders and address various aspects of counterfeiting, with different  outcomes and 
results.  A  balanced  approach  ensures  that  all  necessary  skills  and  knowledge  areas  are 
covered,  providing  a  more  comprehensive  learning  experience  for  the  participants.  The 
programme’s  success  is  largely  due  to  its  design,  which  reflects  its  unique  focus  and 
allows  for  close  cooperation  between  Member  States  and  the  European  Commission 
through  DG  ECFIN.  As  Pericles  IV  is  a  stand-alone  programme,  the  Commission 
department  managing  it  acts  as  an  operational  business  unit,  integral  to  strategy 
development, planning and implementation of actions. This ensures that the programme 
remains aligned with the needs of Member States and action participants, bringing added 
value and effectiveness. Merging the programme with other EU programmes to achieve 
economies of scale could result in a loss of specificity and an erosion of expertise of the 
highly  effective  framework  protecting  the  euro.  The  Commission  has  previously  also 
assessed a merger as not legally feasible given the programme’s two unique legal bases 
in the Treaty (Article 133 TFEU (ordinary legislative procedure) and Article 352 TFEU 
(special legislative procedure))65. 

64 As reflected in Figure 8. 

65 As noted in the impact assessment accompanying the document ‘Proposal for a Regulation of 
the Parliament and of the Council establishing an exchange, assistance and training programme 
for the protection of the euro against counterfeiting (the “Pericles 2020” programme)’, 
SEC(2011) 1615 final. 

25 

 
 
 
By  providing  technical  training,  seminars,  staff  exchanges  and  studies,  the  programme 
has supported measures undertaken by Member States, especially where national funding 
is  limited.  The  programme  has  also  fostered  cooperation  and  the  exchange  of  best 
practices  among  Member  States,  EU  authorities,  non-EU  countries  and  international 
organisations,  resulting  in  formal  and  informal  contacts  that  facilitate  enquiries  and 
the  shared 
investigations.  Non-EU  countries  have  benefited  from 
collaborative 
knowledge  and  experience  of  EU  Member  States,  leading  to  successful  joint 
investigations and improved institutional frameworks. 

The programme has shown positive achievements, with a high satisfaction rate (99.1%) 
among  participants66.  There  is  an  increasing  number  of  unique  competent  authorities 
applying to the programme, and the number of conferences/workshops is consistent with 
previous  programmes.  While  the  number  of  participants  has  decreased  by  nearly  100 
compared  to  the  Pericles  2020  programme,  likely  due  to  a  reduced  budget  and  lower 
participation  during  the  pandemic,  Pericles  IV  actions  have  succeeded  in  establishing 
interinstitutional  contacts  and  disseminated  best  practices  and  information  on  emerging 
counterfeiting trends. 

Efficiency 

The  Pericles  IV  programme’s  coordination,  management  and  administrative  structures 
are adequate, ensuring efficient use of resources. DG ECFIN’s prompt support is highly 
appreciated, and partner institutions such as the ECB and Europol positively assess their 
cooperation with DG ECFIN. 

While  management  costs  are  comparatively  high  in  relative  terms  compared  to  similar 
programmes,  this  is  mainly  due  to  the  limited  overall  budget  of  the  Programme.  Their 
overall  share  is  also  declining  due  to  digitalisation,  indicating  overall  efficiency  gains. 
The  close  involvement  of  DG  ECFIN  in  action  coordination  and  implementation, 
including  by  chairing  ECEG  meetings,  ensures  Member  State  buy-in  and  effective 
monitoring. The  programme undergoes full mid-term  and  ex post evaluations,  although 
its small size raises questions about the proportionality of these requirements. 

The  programme  has  achieved  a  high  allocation  percentage  (over  97%),  demonstrating 
effective resource programming. Maintaining a balance of actions is essential to address 
counterfeiting comprehensively. The programme’s actions involve various stakeholders, 
ensuring a comprehensive learning experience and optimising resources. 

On the budgets for individual grants, a difference can be noted between forecast and final 
costs. This is due mainly to changes in cost elements such as travel and subsistence. The 
current co-financing arrangement of 75% (the standard co-financing rate) and 90% (the 
exceptional co-financing rate) is appropriate, with an average co-financing rate of 81%. 

Although  the  programme’s  budget  is  considered  generally  appropriate,  a  decrease  in 
funding has meant that fewer actions were implemented and fewer participants trained. 

Coherence 

66 Supporting study report. 

26 

 
 
The programme operates within a landscape of EU and national initiatives, each with its 
own  focus  and  objectives.  Actions  organised  by  other  European  Commission 
Directorates-General  are  aligned  with  the  programme,  minimising  any  overlap  of 
activities. This complementarity extends to actions implemented by other EU institutions, 
such  as  the  ECB,  and  agencies,  such  as  Europol.  The  ECB  focuses  on  sharing 
information  to  combat  euro  counterfeiting,  primarily  targeting  national  banks,  whereas 
Pericles  IV  includes  law  enforcement  agencies.  Europol’s  operational  activities 
complement the programme’s emphasis on training, relationship-building and the sharing 
of information. 

At Member State level, initiatives are limited in scope. The programme fills this gap by 
offering  actions  that  provide  expertise  and  foster  the  building  of  relationships  among 
Member States and with non-EU countries. 

EU added value 

The  programme  provides  significant  EU  added  value  by  establishing  and  improving 
relationships  among  Member  States  and  with  non-EU  countries,  EU  institutions  and 
international  organisations  that  go  beyond  the  scope  of  individual  national  authorities. 
These  relationships  ensure  that  national  authorities  have  clear  points  of  contact  for 
information,  knowledge  sharing  and  cooperation.  The  programme  also  plays  a  crucial 
role in disseminating information about emerging trends in euro counterfeiting. 

Pericles  IV  addresses  a  critical  gap  in  many  Member  States,  where  resources  for 
organising  international  and  multidisciplinary  training  on  euro  counterfeiting  are  often 
limited. By providing targeted support, the programme strengthens the EU’s capacity to 
combat euro counterfeiting and supports the development of new relationships, networks 
and transnational cooperation efforts.  

Relevance 

The  programme  remains  crucial  even  though  the  average  number  of  annually  detected 
counterfeit banknotes during this programme period is lower than in the previous period. 
Cash  continues  to  be  used  widely  in  the  EU,  necessitating  ongoing  protection  against 
counterfeiting  of  the  single  currency.  To  remain  relevant,  the  programme  must 
progressively reassess its design and implementation and remain flexible in adapting to 
emerging  and  future  threats  such  as  artificial  intelligence,  highly  deceptive  counterfeit 
coins and the counterfeiting risks posed by criminals active in key non-EU countries such 
as  China  and  Türkiye.  Continuous  development  of  technical  skills  is  essential,  as 
Member States and non-EU countries vary in their anti-counterfeiting knowledge.  

Sustainability 

The  programme  has  effectively  ensured  the  sustainability  over  time  of  its  outputs  and 
future  progress  towards  its  objectives.  Participants  share  Pericles  training  materials 
within  their  teams  and  organisations  through  informal  discussions  and  formal 
presentations. This strategy integrates knowledge within institutions and extends its reach 
to external entities, including law enforcement academies and the retail sector. 

27 

 
 
5.2.  Lessons learned 

In  view  of  the  conclusions  outlined  in  this  report,  a  number  of  lessons  may  be  learned 
and  implemented  during  the  remainder  of  the  programme’s  cycle.  These  are  examined 
below. 

Effectiveness 

-  Member  State  beneficiaries  typically  invite  other  Member  States  or  non-EU 
countries with which they are seeking to establish or foster relationships. In order 
to  ensure  that  the  actions  organised  are  as  effective  and  relevant  as  possible,  it 
would be beneficial to focus on connecting countries that are specifically relevant 
to the issue at hand. By including Member States and non-EU countries that have 
a  direct  stake  or  expertise  in  a  particular  area,  the  programme  can  ensure  that 
actions  are  more  meaningful  and  productive.  This  approach  would  not  only 
optimise the use of resources, but also address the most pertinent challenges more 
effectively. 

-  Maintaining the balance between the different types of action funded through the 
programme  will  be  key  throughout  the  remainder  of  the  programming  period. 
This can be achieved by encouraging specific types of action, such as studies and 
the  purchase  of  equipment  for  non-EU  countries,  through  the  annual  Pericles 
strategy  papers  and  the  meetings  of  the  Euro  Counterfeiting  Experts  Group 
(ECEG). 

Efficiency 

-  Extending the length of the ECEG meetings to two days would allow for more in-
depth  discussion.  It  might  also  be  worth  encouraging  the  representatives  of 
judicial  authorities  to  get  more  involved  in  the  meetings  (and  the  Pericles  IV 
programme in general). 

-  The design of the programme ensures the ability to respond efficiently to current 

and future threats.  

-  Given the relatively small value of the programme and its iterative nature, greater 

proportionality could be applied to evaluation requirements. 

Relevance 

-  The relevance of the programme can be further increased by focusing on current 
and upcoming threats. These include potential threats relating to the future digital 
euro  and  the  impact  of  artificial  intelligence  on  counterfeit  currency  production 
and  identification.  The  Pericles  programme  might  need  to  attract  specific 
expertise to address these threats in the future. 

-  The programme may consolidate its two-track approach, ensuring that sufficient 
attention  is  paid  to  Member  States  (and  non-EU  countries)  needing  to  develop 
basic  technical  anti-counterfeiting  skills,  as  well  as  to  those  ready  to  address 
emerging threats. 

-  Further  to  the  previous  lesson  learned,  the  needs  of  audiences  attending  actions 
funded  by  the  programme  vary  depending  on  their  familiarity  with  euro 
counterfeiting  and  their  involvement  in  the  programme.  Sharing  the  agenda  and 

28 

 
 
topics in advance of these actions allows the content to be adapted to the expected 
audience. Continued coordination as part of the ECEG is vital in this regard. 
-  The  fight  against  euro  counterfeiting  is  most  effective  when  all  relevant 
stakeholders in  detection, investigation and prosecution  are involved.  Continued 
active involvement of the judiciary, customs and parcel and delivery services in 
programme  actions would thus be relevant, especially given the need to counter 
recent threats such as methods of distribution over the internet and altered-design 
banknotes. 

Sustainability 

- 

Identifying  stakeholder  groups  where  language  barriers  could  impede  the 
effectiveness  of  Pericles  IV  actions  can  improve  the  sustainability  of  the 
programme. Fostering collaboration between implementers and participants, with 
actions held  in  or  interpreted into  a national  language, would  help  achieve such 
objectives. 

-  Taking  sufficient  follow-up  actions  and  providing  regular  training  sessions  can 
help correctly apply and reinforce learning outcomes. It also ensures that updates 
on current trends and developments are shared widely by continuing to highlight 
the threat posed by euro counterfeiting. This need also continues to evolve due to 
the constantly changing nature of the threats posed by counterfeiting. Therefore, 
in order to keep abreast of developments in counterfeiting and to account for staff 
turnover, it is necessary for training to be repeated every 2-3 years. 

29 

 
ANNEX I: PROCEDURAL INFORMATION 

The  mid-term  evaluation  of  the  Pericles  IV  programme  was  led  by  DG  ECFIN,  which 
has  primary  responsibility  for  the  oversight,  implementation  and  evaluation  of  the 
programme. The Decide planning entry for the mid-term evaluation is PLAN/2023/339. 

In line with the requirements set out in the Commission Better Regulation Guidelines, the 
mid-term  evaluation  considered  the  criteria  of  relevance,  effectiveness,  efficiency,  EU 
added value and coherence. In addition, the evaluation also considered the sustainability 
of Pericles IV. 

The  evaluation  exercise  relied  primarily  on  an  external  independent  supporting  study 
commissioned by the Commission in November 2023 and concluded in August 2024. A 
third-party  contractor  was  engaged  to  conduct  an  independent  study  and  compile  a 
comprehensive, quality-assured report that forms the primary basis of the evaluation. 

In order to ensure validity, the analysis and conclusions of the supporting study are based 
on the evidence obtained using several evaluation methods (including: (i) desk research; 
(ii) interviews with EU institutions and international partners, as well as with successful 
applicants,  non-applicants  and  participants;  (iii)  an  online  survey  with  participants  in 
activities implemented under the programme; (iv) active observation during an action; (v) 
a focus group; and (vi) two case studies). The evaluation covers the period from 2021 to 
March 2024. 

An  interservice  steering  group  (ISG)  was  set  up  to  guide  the  mid-term  evaluation.  The 
ISG included  representatives from  DG ECFIN,  DG HOME and SG.  It  was responsible 
for  finalising  the  evaluation  call  for  evidence67,  determining  the  terms  of  reference  for 
appointing an external contractor and assessing the quality of each stage of the reporting 
process.  The  ISG  met  seven  times  between  12 December  2023  and  16 July  2024. 
Additionally,  the  ISG  completed  a  significant  portion  of  its  work  through  written 
procedures throughout the evaluation process. 

67 European Commission, Call for evidence, available here. 

30 

 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

This annex outlines the methodology of the mid-term evaluation, detailing the approach, 
limitations and robustness of each data collection activity. 

Desk research 

Desk research was conducted to support the evaluation, focusing on: 

- 
- 
- 
- 

current and future threats to the euro; 
statistics on euro counterfeits, print shops, mints and cash usage; 
implementation status of the Pericles IV programme and its financial aspects; 
implementation status of adjacent programmes to assess coherence. 

Findings  were  compiled  into  a  database  of  indicators,  forming  the  basis  for  analysis. 
Desk  research  began  in  January  2024  and  informed  the  preparation  of  interview 
guidelines, surveys and case studies. Key documents reviewed included Pericles annual 
reports, ECB press releases and Europol threat assessments. One limitation was the lack 
of 2023 data from some sources, such as the ETSC annual reports. 

Survey 

An online survey targeted participants in Pericles IV activities from 2021 to March 2024, 
including  attendees  and  trainers.  The  survey  assessed  the  programme’s  effectiveness, 
relevance, coherence and sustainability. Sent on 5 March to 515 recipients, it closed on 
2 April,  having  received  169  responses  (32%  response  rate).  The  survey  was  made 
available  in  several  languages  (English,  French,  German,  Italian  and  Spanish)  to 
maximise participation. 

Interviews 

Interviews were a cornerstone of the stakeholder consultation, providing qualitative and 
in-depth information. A total of 48 semi-structured interviews were conducted, ensuring 
geographic  and  stakeholder  diversity.  Interviews  were  organised  by  evaluation  criteria 
to facilitate integration into the analysis. Despite some challenges in identifying the right 
contacts  and  securing  responses,  reminders  and  native-language  interviews  helped 
mitigate these issues. Only two interviewees declined to participate because they did not 
know enough about the programme or had participated in earlier surveys. 

Active observation 

Two evaluators  attended a Pericles  IV action in  March 2024 to  gain  practical  insights 
and gather participant feedback. This observation provided valuable information on the 
relevance, effectiveness and EU added value of the programme. The action observed was 
particularly  innovative,  offering  insights  into  the  relevance  of  such  actions,  the  topics 
covered and the stakeholders involved. 

31 

 
 
Focus group at ECEG meeting 

Two evaluators attended the 94th ECEG meeting in March 2024 to gain insights into the 
relevance  of  the  programme  and  investigate  emerging  trends  and  needs.  The  meeting 
also  assessed  the  effectiveness  of  the  programme’s  coordination  and  communication. 
Members  included  central  banks,  law  enforcement  authorities,  Europol,  the  European 
Central  Bank  and  Eurojust.  The  absence  of  some  Member  States  was  noted  as  a 
limitation. 

Case studies 

Two case studies were developed: one on the south-eastern Europe network and another 
on  Pericles  IV  actions  focusing  on  the  web.  These  studies  involved  preparatory  desk 
research  and  interviews  with  various  stakeholders,  providing  detailed  insights  into 
specific  themes  relevant  to  the  programme.  Efforts  were  made  to  maximise  participant 
input through group interviews and feedback gathered during active observation. 

Limitations and mitigation measures 

Some sources, such as the ETSC annual reports, lacked data for 2023, limiting the scope 
of  the  evaluation.  Additionally,  identifying  the  right  contacts  for  interviews  was 
occasionally  challenging.  Mitigation  measures  included  reminders,  native-language 
interviews and group interviews to maximise participant input. 

Reliability and quality assurance 

The  data  collected  are  considered  reliable,  with  comprehensive  desk  research,  a  well-
structured  survey  and  in-depth  interviews  providing  a  robust  foundation.  The  external 
contractor’s  work  was  critically  assessed,  and  their  conclusions  were  in  most  cases 
corroborated due to the thoroughness of the work and its alignment with the evaluation 
criteria. Any uncertainties in the analytical results were addressed by cross-referencing 
multiple data sources and ensuring consistency in findings. 

Critical assessment of contractor’s work 

The external contractor took a detailed and methodical approach, ensuring a high level 
of  reliability  in  the  data  collected.  Their  adherence  to  the  evaluation  criteria  and 
comprehensive stakeholder consultation were key strengths. The few disagreements with 
their  conclusions  were  minor  and  related  to  the  interpretation  of  specific  data  points, 
which were resolved through further analysis. 

Steps to assure quality 

Quality  assurance  steps  included  cross-referencing  data  sources,  validating  survey 
responses and ensuring a wide range of interviewees. The use of multiple data collection 
methods and continuous stakeholder feedback loops helped maintain the robustness and 
accuracy of the evaluation. 

32 

 
This  methodology  ensured  a  comprehensive  and  robust  evaluation  of  the  Pericles  IV 
programme, providing valuable insights into its effectiveness and areas for improvement. 

ANNEX III. EVALUATION MATRIX 

In this section, each criterion of the evaluation matrix is presented. 

Relevance 

Table 2 – Evaluation matrix relevance 

Evaluation Matrix: Relevance (EQ #1.1 – 1.4)  

Evaluation Questions 
1.1 To what extent is there a need to protect the euro against counterfeiting and related fraud? 
1.2 To what extent is the Programme relevant to meet this need and any possible evolution of this need? 
1.3 To what extent are the specific objectives of the Programme (i.e. enhance institutional capacity) relevant to 
achieve its overall objective (i.e. euro protection)? 
1.4 To what extent are the Programme actions and target groups relevant to achieve its overall and specific 
objectives? 

What do we want to measure? 
The analysis of relevance of the Pericles IV Programme assesses the rationale of the Programme in relation to its 
objectives (EQ #1.3), the defined actions and, target groups (EQ #1.4) and the problems to be addressed (both initial 
needs and actual needs or ‘new threats’) (EQ #1, EQ #2), as defined in the Regulation 2021/840 and other relevant 
programming documents (e.g., Commission Decisions for the AWPs, Pericles 2023 Strategy, etc). 
The analysis can be divided into two main lines of inquiry. The first line of inquiry will assess: (1) the actual extent 
and nature of the current euro counterfeit problem and how it has evolved since the Programme was launched (i.e. 
Is the initial need still relevant today?) (EQ #1.1); and (2) whether the Programme’s objectives (specific and 
general) remain relevant to address actual needs, including ‘new threats’ (EQ #1.2). The aim is to determine 
whether the rationale underlying the Programme in general and its specific objectives and priorities in particular, are 
still appropriate and are expected to remain appropriate. 
The second line of inquiry will examine the logical design of the Programme and its strategic orientations (EQ# 1.3, 
EQ#1.3). This analysis can be cascaded in two steps. The first step will assess the alignment between the specific 
objectives of the Programme (i.e. enhanced institutional capacity to protect the euro within relevant institutions) and 
the general objective of the Programme (i.e. euro protection). The second step will assess the alignment and 
relevance of the various types of actions (Article 6) and target groups (Article 5) with the general and specific 
objectives. 

Judgement criteria 

Indicators 

JC1.1: Actual and 
perceived need to address 
the euro counterfeit 
problem (severity) 

•  Number and importance of countries identified as ‘at risk’ (trends in production 

and/or distribution of counterfeits detected) 

•  Counterfeit  euro  banknotes  and  coins  detected  in  circulation  (ECB  and  ETSC 

reports on euro counterfeiting) 
Illegal printshops and mints discovered (ECB and ETSC reports) 

• 
•  Nature  and  severity  of  actual  euro  counterfeiting  problem  across  countries 

(stakeholder perception) 

• 
• 

•  Nature  and  severity  of  ‘new  threats’  resulting  from  innovative  forms  of 
counterfeiting  production  and/or  distribution  (e.g.  distribution  on  the  internet) 
(Europol and Interpol reports, ETSC meeting) 
Stakeholders’ perceptions of threat severity 
Status  of  operational  capabilities  to  protect  the  euro  against  ‘new  threats’ 
(trends in production and/or distribution of counterfeits detected) 
Stakeholders’ assessment of capacity building needs 
Stakeholder  motivations  to  participate  in  the  Programme  (e.g.,  improve 
understanding of euro counterfeiting issues, establish contacts in EU and non-
EU countries, learn best practices, acquire practical skills, etc.) 
Stakeholders’ perceptions regarding the usefulness of different types of actions 
to addressed needs (initial needs and actual needs / new threats) 

• 
• 

• 

JC1.2: Actual and 
perceived adequacy of the 
institutional capacity to 
protect the euro 

JC1.3: Degree to which the 
various types of actions 

33 

 
• 

Stakeholder views regarding the appropriateness of actions to meet the needs of 
‘at risk’ countries 

•  Gap between perceived usefulness of actions and initial and/or actual needs) 
• 

Stakeholders’ perceptions regarding relevance of target groups 

correspond to actual and 
perceived needs and 
Programme objectives  

JC1.4: Degree of the 
appropriateness of the 
target groups to improve 
capacity within relevant 
institutions 

Methods and approach 
The analysis relies primarily on a qualitative content analysis of the relevant programming documents, 
complemented with consultations with CNA’s, third-country authorities and Programme participants. Perceptions of 
EU and international stakeholders were collected to triangulate the results. 
The analysis sketches the actual and perceived current needs, as well as the evolution of needs over the period of 
implementation according to, inter alia, objectives set in the relevant Programme and action documents, other 
documentary evidence and stakeholder consultations. The analysis focuses in particular on the adequacy of 
institutional and operational capacities to protect the euro, taking into account the differing levels of capabilities and 
needs across countries and the degree to which there is a collective or targeted need for continued capacity-building 
support. 
Four all four evaluation questions, a mapping exercise was conducted to identify if there are: (i) gaps between initial 
and actual needs (i.e. the continued relevance of initial needs), (ii) gaps between actual needs / new threats and 
objectives set in the corresponding programming documents (i.e. continued relevance of the Programme); (iii) gaps 
between actions / target groups and objectives; and (iv) gaps between specific and general objectives. 

Sources 
• 

Programme and Action Documents (e.g. legal texts, AWPs, Annual reports, Working Programme Statements, 
ECEG meeting reports, etc.)  

•  Other documentary sources (e.g. statistics published by ECB, ETSC, Europol reports (SOCTA), etc.) 
• 
Interviews with CNAs (Implementers, Non-applicants) and supported third country authorities 
• 
Interviews with EU and other international institutions 
• 
Survey to Programme participants 
• 
ECEG meetings 
•  Case studies 

34 

 
 
 
 
Effectiveness 

Table 3 – Evaluation matrix effectiveness 

Evaluation Matrix: Effectiveness (EQ # 3.1 – 3.4)  

Evaluation Questions 
3.1 To what extent have the specific objectives of the Programme been achieved? 
3.2 What have been the qualitative and quantitative effects of the intervention, within the meaning of Article 2 of 
the Regulation? 
3.3 To what extent have the actions financed under the Programme contributed to achieving its specific objectives? 
3.4 To what extent have all objectives of the Programme contributed to the EU's priority of an economy that works 
for people? 

What do we want to measure? 
The assessment of effectiveness looks at the extent to which the Programme’s actions delivered the intended 
outputs and results (EQ #3.1, EQ #3.2) and explores evidence of the expected and achieved contribution of the 
implemented actions to the specific and general objectives of the Programme in terms of improved institutional 
capabilities and impact on euro protection operations (EQ #3.3, EQ #3.4). 

Judgement criteria 

Indicators 

JC3.1: Degree of improvement in institutional 
and operational capacities within relevant 
institutions 
JC3.1.2: Degree to which involvement of 
participating organisations in euro protection 
activities has evolved (increased) 

JC3.2.1: Degree of improvement in the 
effectiveness of operational counterfeit 
repression activities (achievement of 
performance targets defined in the Regulation 
Annex) 
JC3.2.2: Contribution (of Pericles) to 
sustainability of public finances 

JC3.3.1: Contribution (of Pericles) to enhance 
the institutional capacity (i.e. degree of 
improvement in capacity within relevant 
institutions attributable to the Programme) 
JC3.3.1: Degree to which participation in 
initiatives resulted in more regulator cooperation 
with EU and non-EU countries, improved 
operational capabilities of staff, improved 
methods, etc. 

• 

State of the legal and institutional frameworks in countries 
that  participated 
(i.e.  establishment  of 
institutions,  adoption  of 
legislation  aimed  at  euro 
protection)  

in  Pericles 

•  Number of NCOs established in third countries 
•  Number of Administrative Cooperation Agreement signed 
• 
Status  of  operational  capabilities  to  protect  the  euro 
improved 
against  existing  and  new 
investigative techniques effectively adopted)  
Intensity  and  quality  of  transnational  coordination  / 
cooperation activities  

threats 

(e.g. 

• 

• 

• 

•  Number  of  countries  (or  countries’  authorities)  that 
engaged in transnational coordination / cooperation  
Percentage of administrations that made use of a working 
practice/guideline  developed  with  the  support  of  the 
Programme  
Percentage  of  beneficiaries  that  organised  internal  follow 
up  events  to  share  their  experiences,  lessons  learned,  and 
the knowledge acquired during staff exchanges 
Evolution  over  time  of  indicators  mentioned  in  Article  2 
illegal  workshops  dismantled, 
(counterfeit  detected, 
competent  authorities  applying,  participants’  satisfaction 
rate, previous Pericles actions participants feedback) 
•  Avoidance of losses in government budget revenue. 

• 

•  Actual  utilization  of 

contacts  developed 

and/or 

• 

• 

• 

information / knowledge / skills acquired in practice 
Stakeholders’  assessment  on  contribution  of  Pericles 
actions  to  enhancing  the  institutional  and  operational 
capacity  of  relevant  authorities  in  both  the  EU  Member 
States and Third Countries 
Stakeholders’ perceptions on the role and impact of other 
external factors in contributing to enhanced capacities 
Satisfaction rate of participants in the actions financed by 
the Programme 

JC3.3.2: Contribution (of Pericles) to improve 
the protection of the euro as measured by 
indicators in the Regulation Annex)  

•  Concrete  examples  of  Programme  actions  contributing  to 
improvements in indicators mentioned in the Annex 
•  Concrete  examples  of  Programme  actions  contributing  to 

35 

 
JC3.4: Contribution to EU's priority of an 
economy that works for people  

tangible  positive  results  in  the  prevention  of  and/or  fight 
against  the  counterfeiting  of  the  euro  and  related  fraud, 
e.g. seizure of illegal mints, strengthening of procedures in 
commercial  banks, 
smugglers  of 
counterfeited euros, etc 
Stakeholders’ perceptions on the  role and impact of other 
external factors in contributing to effective euro protection 
operations 

identification  of 

• 

•  Contribution  of  the  Programme  to  the  economic  policy 
objectives  for  stability,  environment,  productivity  and 
fairness 
Perceptions  on 
economic’ effects (Eurobarometer) 

the  possible  contribution 

to  ‘broad 

• 

Methods and approach 
The analysis starts by reviewing qualitatively the relevant documents concerning Pericles IV actions implemented 
so far and to be agreed upon with DG ECFIN during the inception phase (i.e., Case Studies). Relevant documents 
consulted include, inter alia: (i) awarded grant applications submitted by CNAs and the ToR prepared by DG 
ECFIN for the direct actions; (ii) Technical Reports summarising results achieved; (iii) the Programme’s strategic 
and implementation documents, including annual implementation reports; and (iv) previous evaluations and impact 
assessment documents. The first category is used to refine an understanding of the action-specific theories of 
change in terms of how the selected activities are expected to lead to the desired outputs and ultimately contribute to 
the intended outcomes. 
The document analysis is complemented with stakeholder consultations (interviews with CNA’s and third-country 
authorities and the survey to Programme participants) to provide detailed information on the progress of 
implementation and achieved outputs from specific actions. In particular, questions are formulated to collect factual 
information and insights regarding the concrete and tangible ways in which these outputs (i.e. contacts that were 
developed and/or the knowledge, skills and information acquired through participation in the Programme’s actions) 
have been put into practice at both the personal and institutional level and how these changes have contributed to 
enhanced institutional capacity to protect the euro against counterfeiting (e.g. through dismantling illegal 
workshops, strengthening of procedures in commercial banks, identification of smugglers of counterfeited euros, 
etc). The study visits shed further light with specific illustrations on what worked and what not in terms of 
contribution to institutional capacity. 
To assess the relationship between the delivery of capacity building outputs and the effectiveness (or results) of 
operational counterfeit repression activities, the analysis of key performance indicators is supplemented with 
qualitative inputs and analysis derived from both documentary sources (e.g. SOCTA) and primary sources 
(interviews and survey). The data on performance indicators is used to formulate targeted interview and survey 
questions around identifying whether (and to what extent) particular operational activities in selected situations can 
be directly or indirectly linked to improvements in institutional capacity resulting from participation in specific 
Programme actions (i.e. contribution analysis). External enabling and/or hindering factors will also be explored 
during the interviews.  

Interviews with CNAs, third-country authorities, EU / international institutions 
Participants survey 

Sources 
•  Action and Programme Documents (Action Technical Reports, Annual Implementation Reports) 
• 
• 
•  National statistics / EU reports (e.g., Europol, ECEG, ETSC, etc.) 
• 
•  Case studies 
•  Observation of actions 
• 
European Green Deal 
• 
European Semester 

ECEG meeting  

36 

 
 
 
 
Efficiency 

Table 4 – Evaluation matrix efficiency 

Evaluation Matrix: Efficiency (EQ # 2.1 – 2.4) 

Evaluation Questions 
2.1 To what extent do the coordination (with MS, ECB, Europol and other stakeholders), management and 
administrative structures currently in place ensure efficient use of resources in the achievement of the Programme 
outputs, results and impacts? 
2.2 To what extent are the actions and outputs of the Programme delivered at a reasonable cost? 
2.3 To what extent is the co-financing rate appropriate? 
2.4. To what extent is the budget allocated to the Programme appropriate? 

What do we want to measure? 
The analysis of efficiency examines the extent to which the established coordination, management and 
administrative structures enable the Programme to deliver the intended outputs and contribute to outcomes in an 
efficient manner (EQ #8); the appropriateness of the co-financing rate for actions (EQ #10); and the overall cost-
effectiveness of the implemented actions and delivered outputs (EQ v#9). 
The management and coordination structures comprise the programming documents (e.g. Pericles IV Strategy, 
AWPs, etc) and ECEG meetings. The study assesses the extent to which the established structures and 
administrative procedures have facilitated or otherwise hindered the implementation of high-quality and priority 
actions. The analysis focuses on the extent to which the established structures enable the Programme to deliver the 
planned outputs, thereby contributing to the intended outcomes in an efficient manner. 

Judgement criteria 

Indicators 

JC2.1.1: Degree to which existing management and 
coordination structures and procedures ensure efficient 
use of resources  

• 

• 

• 

and 
in 

relevance 

assessment  of 
information  communicated 

Stakeholders’ 
usefulness  of 
programming documents 
Support  provided  during  the  various  stages  of 
implementation  by 
the 
Programme 
Stakeholders’  views  regarding  the  efficiency  of 
and 
for 
ECEG  meetings 
communicating capacity-building plans 

the  unit  managing 

coordinating 

•  Costs 

(time 

commitment) 
attendance at ECEG meetings 

associated  with 

JC2.1.2: Degree to which the established administrative 
procedures ensured efficient use of resources 

•  Costs  associated  with  Programme  management 

(Pericles, similar Programmes) 

•  Average time to inform applicants of the outcome 

of the evaluation of the application 

•  Average time to sign agreements or to notify grant 

decisions 

•  CNAs’ perceptions regarding clarity of procedures 
and quality of assistance provided by ECFIN 
•  Administrative  burden  borne  by  CNAs  (proposal 

preparation, reporting) 

• 

•  Administrative  burden  borne  by  beneficiaries  in 
other,  similar  EU-funded  Programmes  (to  the 
extent available/comparable) 
Stakeholders’  motivations  for  applying  or  not 
applying  for  funding  (if  linked  to  management  / 
administrative procedures) 
Proportionality of administrative costs to delivered 
outputs  (burdens  relative  to  action  budgets  and/or 
achieved outputs) 

• 

•  CNAs’  assessment  of  cost-benefit  ratio,  areas  for 

improvement in reducing / simplifying procedures 
•  CNAs’  views  regarding  areas  for  improvement  in 
the administrative and financial arrangements  

37 

 
JC2.2.1: Degree of cost effectiveness of Programme 
outputs (actions) and outcomes 

•  Unit  cost  of  Pericles  actions  per  participant  for 

specific outputs 

•  Unit  cost  of  EU  contribution  per  participant  for 

specific outputs 

•  Unit  costs  (total  and EU  contribution)  for  specific 
outputs  /  outcomes  in  other,  similar  EU-funded 
external  operators  offering 
Programmes  or 
counterfeiting  training  (to  the  extent  available  / 
comparable) 

•  Difference between budgeted and actual costs 
• 
Personnel costs of CNAs as implementers  
•  Cost-benefit  ratio  for  sample  selection  of  actions’ 

JC2.3.1: Degree to which the mobilization of co-
financing discourages participation 
JC2.3.2: Degree to which different co-financing rates 
enable focus on top priorities / themes 
JC2.3.3: Degree to which different co-financing rates 
affect (broaden / shrink) the pool of interested 
applicants 

JC2.4.1: Degree to which the allocated Programme 
budget is appropriate 

• 

• 

outputs / outcomes 
Satisfaction  rate  of  participants  in  the  actions 
financed by the Programme 
Stakeholders’  views  on  capacity  built  following 
participation in Programme’s actions  
•  Co-financing rates applied to actions 
•  Number,  quality  and  focus  of  applications  for 
at  different  EU 

CNA-implemented 
contribution rates 
Stakeholders’  views  on  the  ability  to  mobilise  co-
financing and incentivization of top priority actions 
•  Data  on  co-financing  rates  in  other,  similar  EU-

actions 

• 

funded Programmes 
• 
Share of the budget per work Programme  
•  Difference between budgeted and actual costs 
•  Maximum  %  envisaged  for  cumulated  changes  to 

• 

the allocations to specific actions 
Stakeholders’  views  on  the  appropriateness  of  the 
budget 

Methods and approach 
The assessment of the efficiency of established coordination, management and administrative structures relies 
primarily on sources collected via interviews with CNAs, complemented with a review of financial reports to 
estimate the quantitative costs associated with Programme implementation. Costs associated with the management 
of the Pericles Programme are quantified and monetised on the basis of DG ECFIN Annual Reports, according to 
the reported Full-Time Equivalent (FTE) staff requirement for Programme implementation and management. The 
overall Programme management costs is compared with similar Programmes to establish the relative cost-efficiency 
of the Pericles Programme.  
Focused interview questions are formulated around the allocation of CNA staff resources (staff time spent in FTE) 
for the preparation of Pericles actions (proposal preparation) and compliance with reporting requirements, as well as 
perceptions of the cost-benefit ratio. Staff costs were quantified and monetised by multiplying the amount of time 
spent (FTE) in preparing proposals and complying with reporting requirement by the average daily labour cost as 
indicated in available the Financial Reports summarising costs incurred. The proportionality of administrative 
burdens borne by CNAs is analysed by comparing the administrative cost estimates with the average budgets of the 
different types of actions implemented. The findings are complemented with stakeholder perceptions on the cost-
benefit ratio and documentary evidence from Technical Reports summarising the results achieved. 
Information on the budgetary outlays to fund Pericles actions are collected from the relevant Action Documents 
(i.e., grant applications and/or Financial Reports summarising costs incurred). Stakeholder perceptions regarding 
the cost-benefit ratio of funded actions are collected via interviews and the survey to Programme participants, 
supplemented with concrete examples of tangible results (quantitative and qualitative) that can be linked to 
participation in Programme actions. The results are additionally considered against the corresponding values of 
other, comparable EU-funded Programmes that support public administrations using similar implementing 
modalities. 
The assessment of the co-financing rate rely on a combination of interviews with CNAs (Implementers and Non-
Applicants) and documentary sources. The latter includes a review of the grant applications submitted by CNAs 
(including proposed budgets) and corresponding Tender specifications prepared by DG ECFIN in order to identify 
potential variations in the number and types of applicants, the quality of applications submitted and the focus on top 
priorities / themes based on the co-financing rate applied. The results will additionally be compared against data on 
co-financing rates in other, similar EU-funded Programmes. 

38 

 
 
Sources 
•  Action documents (Technical and Financial Reports, ToRs, Grant Agreements, etc.) 
•  Documentation from other EU Programmes (Implementation / Financial reports, Evaluations, etc.) 
• 
Interviews with CNAs (Implementers, Non-applicants) and supported third country authorities 
• 
Interviews with EU and other international institutions 
• 
Survey to Programme participants 
•  Case study on South Eastern Europe network and observation of actions  
• 

ECEG meetings 

39 

 
 
 
 
EU added value 

Table 5 – Evaluation matrix EU added value 

Evaluation Matrix: EU Added Value (EQ # 4.1) 

Evaluation Question 
4.1 To what extent does the Programme provide EU added value? 

The assessment of EU Added Value (EQ #4.1) of the Pericles Programme is addressed from three perspectives: 
• 

The added value resulting from the intervention(s) compared to what could be achieved by Member States at a 
national  level.  The  study  focuses  in  particular  on  the  Programme’s  ability  to  support  collective  forms  of 
international  cooperation  that  are  beyond  reach  of  individual  national  authorities,  the  provision  of  dedicated 
financial resources specifically designed to protect the euro from counterfeiting and political leverage provided 
to reinforce direct actions of the Commission. 
The  most  likely  consequences  of  stopping  or  withdrawing  the  Programme.  The  analysis  investigates  the 
feasibility for MS to perform the same types of transnational activities on a comparable scale if the Programme 
were  to  be  discontinued.  The  analysis  will  focus  in  particular  on  the  role  and  importance  of  Pericles  IV 
financial support and the importance of an EU Programme in providing visibility for the action and attracting 
participants from different countries. 
The extent to which the needs addressed by the intervention continue to require action at EU level. This line of 
investigation draws on the findings regarding the continued relevance of the Programme (EQ #1.1, EQ #1.2) 
with  particular  focus  on  the  role  and  relevance  of  the  Programme  in  creating  and  fostering  a  transnational 
network and promoting cross-border cooperation.  

• 

• 

Judgement criteria 

Indicators 

JC4.1.1: Ability and feasibility of EU Member 
States to implement transnational actions without 
Pericles 

JC4.1.2: Degree to which the Programme has 
promoted transnational cooperation 

• 

• 

• 

• 

• 

resources  dedicated 

to  comparable  euro 

Financial 
protection activities at Member State level 
Stakeholders’  views  regarding  possible  developments  in 
case the Programme were to be discontinued  
Stakeholder  perceptions  /  assessment  of  the  ability  to 
implement  similar  transnational  actions  without  Pericles 
(role / impact of EU financial support and visibility of EU 
Programme) 
Stakeholders’ views on the importance of the Programme 
in triggering transnational actions (and feasibility of such 
actions in the absence of financial support) 
Stakeholders’  assessment  on 
transnational approach to enhance euro protection 

importance  of  a 

the 

Methods and approach  
These three methodological steps guide the preparation of targeted questions included in the targeted survey and 
interview consultations. Interviews provide critical insights on the more qualitative benefits of transnational 
cooperation activities supported by Programme in relation to strengthening euro protection through the creation of a 
transnational network, promoting cross-border cooperation and fostering relationships with more challenging third 
countries (e.g., China, Colombia). Interviews provided expert judgement on how the Programme compares to what 
could be achieved by the Member States alone. Information collected from interviews is complemented by a 
comparative assessment of the financial resources dedicated to comparable euro protection activities at Member 
State level. 

Sources 
•  Answers to the previous evaluation questions 
• 
• 
• 
•  Deep dives 
• 

ECEG meetings 

Interviews with CNAs and third-country authorities  
Participants survey 
Institutional websites / Financial reports of other Programmes at national / EU level  

40 

 
 
 
 
Coherence 

Table 6 – Evaluation matrix coherence 

Evaluation Matrix: Coherence (EQ # 5.1 – 5.2)  

Evaluation Questions 
5.1. To what extent have the coordination and cooperation mechanisms in place for the Programme ensured 
consistency and complementarity with other relevant EU Programmes and activities? 
5.2. To what extent have the coordination and cooperation mechanisms in place for the Programme ensured 
consistency and complementarity with existing actions implemented by Member States, the ECB and Europol, with 
the view to achieving the overall objective of protecting the euro against counterfeiting? 
What do we want to measure? 
The evaluation of coherence looks at the consistency and complementarity of the Programme and the implemented 
actions with other relevant EU Programmes and initiatives (EQ #5.1) and/or existing actions implemented at by 
Member states or by the ECB and Europol (EQ #5.2) seeking to protect the euro against counterfeiting and related 
fraud. In addition to evidence of coherence, collected from the detailed consideration of similar EU mechanisms, 
the evaluators looked for signs of incoherence, inconsistency or unnecessary duplication across different 
interventions. 
At the national level, related initiatives are likely to include trainings on the authentication of banknotes and coins. 
At the EU and international level, the assessment consider, inter alia: 
• 

capacity-building  initiatives  supported  by  the  Commission,  such  as  EMPACT,  ISF,  TAIEX  and  Twinning 
instruments; 
analytical and technical assistance support provided by entities such as the European Technical and Scientific 
Centre (ETSC) (e.g. trainings on coin analysis), the ECB (e.g. TA related to euro banknotes) and the Central 
Bank Counterfeit Deterrence Group (CBCDG); and 
operational  and  tactical  assistance  provided  to  law  enforcement  authorities  by  EU  and  international  entities 
such as Europol (e.g. intelligence gathering and operational support to investigations), Interpol (e.g. technical 
forensic support, sharing of counterfeit data) and Eurojust (e.g. financial support to JITs). 

• 

• 

A final topic investigated is the degree to which the established coordination and cooperation mechanisms have 
either helped to ensure, or alternatively hindered consistency and complementarity between the Pericles Programme 
and other relevant Programmes and initiatives at national, EU and international levels. The analysis focuses on the 
role and effectiveness of coordination mechanisms in reducing and/or avoiding overlaps with other initiatives at the 
programming stage, during the selection of the actions to be implemented as well as the implementation of specific 
actions. 

Judgement criteria 

Indicators 

JC5.1.1: Degree of complementarity / overlap 
with other EU / international euro protection 
initiatives  
JC5.1.2: Contribution of established 
coordination and cooperation mechanisms to 
achieved consistency / complementarity with EU 
/ international initiatives 

JC5.2.1: Degree of complementarity / overlap 
with national initiatives and operations  
JC5.2.2: Contribution of established 
coordination and cooperation mechanisms to 
achieved consistency / complementarity with 
national initiatives 

•  Number,  nature,  scope  of  capacity  building,  analytical 
and/or  technical  support  initiatives  implemented  by  EC, 
ECB, Interpol 

•  Number, nature, scope of operational activities supported 

• 

• 

by Europol, Eurojust and Interpol 
Stakeholders’  views  on  complementarity  of  Programme 
actions  and  other  EU  /  international  Programmes  and 
initiatives 
Stakeholders’  assessment  on  the  role  and  contribution  of 
coordination  and  cooperation  mechanisms  (e.g.,  ECEG 
meetings) 

•  Number,  nature,  scope  of  national 

initiatives  and 
training  on  authentication  methods 

operations  (e.g., 
implemented by Central Banks or banking associations) 
Stakeholders’  views  on  complementarity  of  Programme 
actions and initiatives implemented at a national level  
Stakeholders’  assessment  on  the  role  and  contribution  of 
coordination  and  cooperation  mechanisms  (e.g.,  ECEG 
meetings) 

• 

• 

Methods and approach 
The assessment of coherence is based on a qualitative review of various documentary sources, including 
institutional websites, websites of other Programmes and initiatives, such as ISF and the database of TAIEX events, 
as well as information gathered via stakeholder consultations. The latter includes interviews with CNAs, third 

41 

 
country authorities, Programme participants and relevant EU and international entities. The interviews with CNAs, 
including during the Study visits, includes Implementers and Non-applicants. Interviews with non-applicants serves 
to mitigate potential selection bias among responses. Specifically, targeted questions are formulated to assess the 
degree to which a lack of coherence and complementarity between Pericles actions and those at the national level 
was a factor behind CNAs’ decisions not to apply. 

Sources 
•  Documentation (e.g. annual reports) on capacity building initiatives of EC, ECB, Interpol 
•  Documentation on operational activities of Europol, Eurojust, Interpol 
• 
• 
• 
• 
• 
• 

ECEG reports 
Interviews with EU / International organisations 
Interviews with CNAs, third-country authorities 
Participants survey 
Study visits 
ECEG meetings 

42 

 
 
 
 
Sustainability 

Table 7 – Evaluation matrix sustainability 

Evaluation Matrix: Sustainability (EQ 6) 

Evaluation Questions 
6. To what extent are the delivered outputs and results achieved (likely to be) sustainable? 

What do we want to measure? 
The evaluation of sustainability assesses the extent to which the outputs and progress towards the achievement of 
intended outcomes are likely to endure over time. Specifically, the assessment investigates the measures and 
practices adopted by participating Member States’ and supported third countries’ CNAs to ensure that delivered 
outputs of the supported actions are implemented or otherwise institutionalised after support ends, and how such 
measures have been implemented and performed in practice. 
Measures to ensure sustainability might include: 
• 
• 
• 
• 
• 

formal or informal distribution of materials received through the Programme action; 
preparation of reports, memos, etc on the action;  
delivery of a presentation at internal team meetings, workshops, etc outside the Pericles IV Programme; 
delivery of a formal training course; 
sharing  of  acquired  contacts,  information,  knowledge,  skills,  etc.  with  colleagues  through  informal 
mechanisms or regular operational activities; 
regular organisation of follow-up actions; or 
other forms of dissemination. 

• 
• 
•  Typical challenges to sustainability include: 
• 
• 
• 
• 
• 

insufficient mobilisation of national resources (financial support); 
staffing shortages and/or high staff turnover; 
political and/or legislative support; 
stakeholder commitment; or 
cultural barriers, such as language barriers. 

The assessment of both the current sustainability (based on existing established practices) and the likely future 
sustainability of delivered results take into account these and other relevant barriers as part of the analysis.  

Judgement criteria 

Indicators 

JC6.1: Programme 
participants have adopted 
measures or practices to 
ensure sustainability of 
delivered outputs / progress 
towards results 
JC6.2: Adopted measures or 
practices to ensure 
sustainability of delivered 
outputs / progress towards 
results have been 
implemented in practice 

JC6.3: Involvement of 
participating organisations in 
euro protection activities has 
evolved (increased) 

JC6.4: Level of strategic and 
institutional commitment to 
the continuation of euro 
protection activities linked to 
Programme activities 

•  Number of follow-up actions organised 
•  Measures  adopted  to  ensure  sustainability  of  delivered  outputs  /  progress 
towards outcomes (i.e. delivery of internal trainings, preparation of memos or 
reports,  sharing  of  contacts  /  knowledge,  delivery  of  presentations,  etc). 
Actual  utilisation  of  contacts  developed  and/or  information  /  knowledge  / 
skills acquired in practice 
Stakeholders’  assessment  on  the evolvement  of  their  role  since  participating 
in the Programme 
Stakeholders’  assessment  on  the  role  and  impact  of  external  factors  in 
contributing to (or hindering) sustainability of results 

• 

• 

• 
• 

Intensity and quality of transnational coordination / cooperation activities 
Increased  quantity  and  quality  of  investigations  and  police  operations 
(stakeholder input) 

•  New  administrative  and  technical  skills  used  on  a  daily  basis  by  third 

• 

• 

• 

countries NCAs 
Stakeholders’  assessment  on  the  role  and  impact  of  external  factors  in 
contributing  to  (or  hindering)  increased  involvement  in  euro  protection 
activities  
Stakeholders’  experiences  regarding  the  availability  and  allocation  of 
resources (financial, human) to sustain the outputs / results achieved to date. 
Stakeholders’  perceptions  regarding  prospects  for  future  sustainability  in 
terms of allocation of resources and strategic commitment, external enabling / 
hindering factors, etc. 

43 

 
 
Methods and approach  
The assessment relies primarily on evidence gathered through the interview consultations with CNAs and third 
country authorities and the survey of Programme participants, complemented with a review of Action documents to 
identify organised follow-up action as well as concrete measures that were envisioned by the actions to ensure 
sustainability of delivered outputs as needed. 
Building on the analysis of effectiveness, the approach takes as the starting point the collection of factual 
information and insights regarding the concrete and tangible ways in which the delivered outputs (i.e. contacts that 
were developed and/or the knowledge, skills and information acquired through participation in the Programme’s 
actions) have been put into practice at both the personal and institutional level and stakeholder perceptions 
regarding the likely sustainability of such practices in the mid- to long-term. The consultations examine a mix of 
actions that have been implemented over the Programme duration, though with particular emphasis on a 
representative sample of actions that were implemented during the first half of the Programme in order to 
understand how outputs and results have been sustained (i.e. continued to be utilised) over a longer timeframe. 
Targeted interview and survey questions are formulated around identifying (i) the specific types of measures 
adopted by Programme participants to utilise and further disseminate the delivered outputs, and (ii) how these 
measures and practices have been implemented in practice, and (iii) the degree to which there is evidence of the 
Programme having contributed to increased involvement in euro protection activities among the Programme 
participants.  

Interviews with CNAs, third country authorities, EU institutions 
Participants survey 

Sources 
• 
• 
•  Case studies 
• 
•  Action Documents (proposals, Technical reports) 

ECEG meetings 

44 

 
 
 
 
ANNEX IV. OVERVIEW OF COSTS AND BENEFITS 

Table 8. Overview of costs and benefits identified in the evaluation 

Type of cost/benefit 

European 
Commission 

Costs 

Direct costs: 
Administrative 
costs: 

-  Preparation of 
calls for 
proposals 
-  Evaluation of 

applications 

- 

Implementation 
of actions 

Estimated 
average number 
of days spent 
per call for 
proposal: 0.123 
FTEs (full-time 
equivalents) 
Evaluation of 
applications: 
0.438 FTEs 

Implementation 
of actions: 
0.33 FTEs 
Follow-up of 
implementation: 
0.569 FTEs 

Programme/project 

management 

EUR 199 042, 
i.e. 1.44 FTEs 

Indirect costs: 
adjustment costs 
(simplification of the 
application process 
and changes of 
procedure resulting 
from learning 
experiences and 
previous evaluation 
of the programme) 

Simplified 
evaluation of 
applications and 
data 
management 

Beneficiaries 
(national 
administrations, 
central banks, 
law enforcement 
offices and other 
relevant 
agencies) 

Private 
entities 

Citizens 

16 staff/days 
(weighted 
average) 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Not possible to 
provide a 
realistic estimate 
of time spent on 
implementation 
because most 
employees 
responsible for 
implementing 
actions also 
perform other 
duties in addition 
to those related 
to Pericles 

Simplified 
application 
procedure for 
implementers of 
Pericles IV 
actions. No 
challenges 
reported in shift 
to use of e-
Grants system 

45 

 
 
 
 
 
Benefits 

Direct benefits: 

1.  Strengthening 
the trust of 
citizens and 
business in the 
genuineness of 
these banknotes 
and coins 
(improved 
market 
efficiency) 

2.  Improved 

cooperation 
between 
national 
authorities in 
the field of euro 
counterfeiting 

3.  Promoting 
knowledge 
sharing and 
improving 
CNAs’ 
understanding 
of the issues in 
order to 
increase 
operational 
capacity 

Indirect benefits: 
1.  Reduced 

expenditure on 
law 
enforcement 
activities due to 
lower levels of 
illegal acts 

Trust in currency stability ultimately supports increased investment 
and growth, helping to secure the sustainability of public finances 

n/a 

n/a 

Improved 
cooperation 
among 
authorities can 
help make crime 
prevention and 
detection more 
effective 

Enhanced 
capabilities and 
knowledge of 
Member States’ 
institutions in 
fighting 
counterfeiting of 
the euro through 
better detection 
of the 
manufacturing 
and distribution 
of counterfeit 
euro banknotes 
and coins 

Enhanced security due to 
effective crime prevention and 
detection 

Enhanced 
operational 
capacities of 
commercial 
banks and 
other 
stakeholders 
relevant for 
detection of 
counterfeit 
euros 

Stable currency 
which functions 
effectively, 
enhancing the 
competitiveness 
of the EU 
economy and 
contributing to 
securing the 
sustainability of 
public finances 

Benefits resulting from “freed” budget due to reduced expenditure on 
law enforcement activities, which can be allocated to other priorities 

46 

 
 
 
 
ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT  

This synopsis report summarises the stakeholder consultation activities conducted as part of the 
mid-term  evaluation  of  the  Pericles  IV  programme,  starting  on  12 December.  The  evaluation 
considered  six  criteria:  relevance,  effectiveness,  efficiency,  EU  added  value,  coherence  and 
sustainability. 

Consultation activities undertaken 

The stakeholder consultations  involved a targeted survey, interviews, active observation and a 
focus  group.  The  survey  targeted  participants  in  and  organisers  of  programme  actions;  it  was 
open  for  four  weeks,  from  5 March  to  2 April  2024,  and  elicited  169  responses  from  515 
recipients:  a response rate  of 32%.  A total of 48 interviews  were conducted  between February 
and  June  2024  with  EU-level  stakeholders, 
international  organisations,  successful  and 
unsuccessful  applicant  Member  States  and  relevant  non-EU  countries.  The  active  observation 
involved approximately 40 participants in the OCRFM (Office central pour la répression du faux 
monnayage – French Central Office for the Prevention of Money Counterfeiting) action from 25 
to  29 March  2024.  The  focus  group  included  around  30  participants  in  the  ECEG  meeting  on 
12 March 2024. 

Stakeholder groups consulted 

interviews.  One 

interview  was  conducted  with 

EU-level  stakeholders  included  DG  ECFIN,  Eurojust,  EMPACT  and  CEPOL,  which were  consulted 
through  seven 
INTERPOL,  representing 
international organisations. National stakeholders – both successful and unsuccessful applicant 
Member States – were consulted through 23 interviews, participation in the ECEG meeting and 
the OCRFM action. Stakeholders from non-EU countries, primarily counterfeit experts involved in 
Pericles  IV  actions,  were  consulted  through  nine  interviews.  Participants  in  Pericles  IV  actions 
were consulted through a targeted survey sent to 515 stakeholders, with 169 responses. 

Data-processing tools and methodologies 

The  survey  was  programmed  in  EUSurvey,  an  open-source  software  solution  funded  by  the 
European  Commission,  facilitating  efficient  analysis.  Qualitative  information  from  interviews, 
active  observation  and  focus  groups  was  documented  in  minutes  and  summary  reports, 
reviewed by at least two colleagues and stored centrally. These reports were structured to allow 
easy extraction and integration into the analysis of specific evaluation criteria. 

Results of the consultation activities 

The  survey,  structured  into  five  sections,  covered  respondent  profiles,  action  organisation, 
results,  involvement  and  overall  assessment.  Most  respondents  (74%)  were  from  EU  Member 
States, with 47% from national central banks and 30% from law enforcement authorities. High 
satisfaction with the programme was reported, with 98% of respondents rating it positively and 
96%  expressing  interest  in  future  participation.  The  exchange  of  best  practices  and  staff 
exchanges between Member States and non-EU nationals were highly appreciated. 

Interviews revealed a continued need for action against euro counterfeiting, with the Pericles IV 
programme  providing  valuable  network-building  and  knowledge  updates.  Stakeholders 

47 

 
indicated  that  the  programme  effectively  facilitates  the  development  of  contacts  and  updates 
knowledge  of  trends  and  developments.  However,  suggestions  were  made  to  target  actions 
more  directly  at  participants  and  ensure  that  the  right  audience  is  invited.  The  new  online 
application  process  was  seen  as  an  improvement,  although  organising  actions  still  required 
substantial  resources.  Early  communication  of  upcoming  actions  was  recommended  to  allow 
stakeholders to make informed decisions. 

The programme’s added value was highlighted, particularly in providing information, knowledge 
and operational support beyond national efforts. It was seen as complementary to national and 
other EU/international activities, using clear communication and the division of responsibilities 
to  avoid  overlaps.  Various  strategies  were  employed  to  share  knowledge  within  organisations 
and  beyond.  Regular  follow-up  actions  were  needed  to  ensure  that  account  was  taken  of 
previously acquired knowledge. 

Active  observation  of  the  OCRFM  action  revealed  that  practical  workshops  and  house  search 
exercises  were  highly  relevant,  although  language  barriers  were  noted.  The  training  was 
effective  in refreshing  knowledge  and  explaining  legal  procedures.  Suggestions  were  made  for 
broader  participation  and  a  better  balance  between  local  and  international  participants. 
Participants indicated that they would be able to attend actions provided that their costs were 
covered by Pericles IV. Early information on actions was needed to manage opportunity costs. 

The  focus  group  at  the  ECEG  meeting  emphasised  the  programme’s  relevance  in  enhancing 
international  collaboration  and  addressing  new  challenges  in  counterfeiting.  Emerging  trends 
included  a  rise  in  low-quality  counterfeits  and  the  use  of  digital  printing  and  cryptocurrencies. 
There  was  a  critical  need  for  enhanced  legal  definitions,  stronger  international  cooperation, 
improved  training  and  increased  involvement  of  customs  and  prosecutors.  Challenges  in 
cooperation with countries such China and Türkiye were noted, and suggestions were made to 
improve the efficiency and operability of ECEG meetings by setting up smaller, multidisciplinary 
groups  and  making  the  meetings  longer.  Budget  constraints  were  highlighted  as  a  significant 
obstacle to the ability to take effective action against counterfeiting. 

This  comprehensive  stakeholder  consultation  ensured  a  robust  evaluation  of  the  Pericles  IV 
programme, providing valuable insights into its effectiveness and areas for improvement. 

48