WHITE PAPER for the Anti-fraud Architecture Review
Date: 2025-07-16
Institutions: Directorate-General for Budget, European Commission
Subjects: EU budget, EU control, EU strategy, administrative check, digital technology, fight against crime, financial control, fraud, fraud against the EU, institutional cooperation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.7.2025  COM(2025) 546 final  WHITE PAPER for the Anti-fraud Architecture Review  
 
 
1.  Introduction 

The Treaties of the European Union (“EU”) provide that countering fraud and any other illegal 
activities affecting the EU’s financial interests is the shared responsibility of the EU and its 
Member  States 1.  The  European  Commission  has  a  key  responsibility  to  protect  the  EU’s 
financial interests2, through its Authorising Officers by Delegation (“AODs”), and works to 
fulfil this together with several specialised bodies, offices and agencies that have been set up 
over  the  years.  It  also  takes  into  account  the  recommendations  of  the  European  Court  of 
Auditors (the ECA). Together with the Member States’ competent authorities and the AODs 
of  all  institutions,  bodies,  offices  and  agencies  (IBOAs),  they  form  the  EU  anti-fraud 
architecture. 

The  EU  anti-fraud  architecture  (AFA)  has  evolved  over  time  to  address  the  ever-changing 
threats to the EU’s financial interests. Transnational fraud, including VAT fraud, or the activity 
of  organised  crime  networks  targeting  EU  funds  have  increased.  There  is  also  growing 
evidence of the key role of organised crime in fraud schemes, and, conversely, of the important 
role  of  fraud  in  financing  other  forms  of  serious  and  organised  crime,  including  terrorism.  
Fraudsters now make use of advanced technologies like artificial intelligence (AI), encrypted 
communication, and crypto currencies, to carry out and hide their criminal activities adds to 
the challenge. Moreover, management modes are evolving and the sheer increase in the size of 
the EU’s budget, driven by NextGenerationEU, has led to a rise in the amounts that are at risk 
of fraud and irregularities. Reviewing the AFA framework is an opportunity to better address 
all challenges and bridge existing gaps in the protection of the EU’s financial interests. The 
AFA  review  process  will  also  be  an  opportunity  to  improve  and  streamline  cooperation 
between  the  various  AFA  actors.  The  present  White  Paper  seeks  to  prepare  the  process  by 
putting  forward  for  a  broad  reflection  several  key  questions  that  could  be  explored  in  the 
upcoming review.  

The  AFA  review  complements  the  preparatory  work  on  the  next  multiannual  financial 
framework (the MFF). The aim is to ensure that the next MFF can benefit from a strengthened 
and more efficient anti-fraud architecture to protect the EU’s financial interests by making the 
best possible use of resources (particularly as regards the complementarity and coordination of 
the  functions  and  activities  of  all  relevant  actors).  It  will  contribute  to  delivering  on  the 
objectives set out by the Commission in its proposals for the EU’s next long-term budget. It 
will  do  so  by,  in  particular,  addressing  the  complexities,  weaknesses  and  constraints  of  the 
current system; maximising the impact of every euro spent on focusing on EU priorities and 
objectives where the EU action brings most added value; and ensuring the accountability and 
traceability of EU funds.  

The AFA review also complements a number of other recent or ongoing policy initiatives in 
areas closely related to anti-fraud, such as the proposal for a directive on combating corruption 
through criminal law3, the Conditionality Regulation4 and monitoring under the annual Rule of 
Law Report. 

1 Articles 310(6) and 325 TFEU. 
2 Article 317 TFEU. 
3  COM/2023/234 final  
4 Regulation (EU, Euratom) 2020/2092 of the European Parliament and of the Council of 16 December 2020 on 
a general regime of conditionality for the protection of the Union budget, OJ L 433I, 22.12.2020, p. 1–10. 

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The  European  Parliament  attaches  significant  importance  to  the  review  of  the  AFA.  The 
European Parliament’s Committee on Budgetary Control, in its ‘Report on the protection of 
the  EU’s  financial  interests  –  combating  fraud  –  annual  report  2023’  (the  CONT  Report) 5, 
highlighted  the  urgent  need  to  strengthen  and  modernise  the  AFA  in  response  to  emerging 
challenges and opportunities 6. In particular, the CONT Report emphasises the need to assess 
and  minimise  duplications  and  overlaps  of  AFA  actors;  promote  anti-fraud  strategies  at 
national level; boost the use of digital tools and databases; consider a centralised governance 
structure; provides strategic oversight and address structural gaps; and improve the reporting 
framework  by  incorporating  results  from  all  components  into  the  annual  report  on  the 
protection of the EU’s financial interests (the PIF Report) in order to enhance transparency and 
accountability.  

The ECA has also adopted several special reports on anti-fraud 7 and is conducting other fraud-
related  audits 8.  In  particular,  it  is  assessing  the  working  arrangements  and  coordination 
between  the  European  Public  Prosecutor’s  Office  (EPPO),  the  European  Anti-Fraud  Office 
(OLAF), the EU Agency for Criminal Justice Cooperation (Eurojust) and the EU Agency for 
Law Enforcement Cooperation (Europol)9; as well as the effectiveness of the national control 
systems in managing the funds of the Recovery and Resilience Facility (RRF)10 in preventing, 
detecting  and,  where  appropriate,  correcting  fraud11.  A  third  ongoing  audit12  will  assess  the 
effectiveness of the action plan of the Commission’s 2019 anti-fraud strategy (CAFS)13 .  

The AFA review will be carried out using a holistic approach. It will map the key AFA actors; 
identify  and  address  loopholes  that  can  be  detrimental  to  the  EU’s  financial  interests;  and 
promote efficiency at every stage of the anti-fraud cycle (prevention, detection, investigation, 
prosecution  and  corrections/recoveries).  As  set  out  in  ProtectEU  -  the  European  Internal 
Security  Strategy 14,  the  results  of  the  AFA  review  will  support  the  enhancement  of 
complementarity between the AODs, the EPPO, OLAF, Europol, Eurojust, the Anti-Money 
Laundering  Authority  (AMLA)  and  the  proposed  EU  Customs  Authority.  The  fight  against 
fraud can benefit from focusing on better information collection, a better use of information 
and data sharing, a strengthened access to data, the use of modern technologies, including AI, 
for  better  detecting  and  investigating  fraud,  improved  synergies  in  the  use  of  investigative 
means, both criminal and administrative, and improved cooperation. Effective deterrence and 

5 Report on the protection of the EU’s financial interests – combating fraud – annual report 2023, 1 April 2025, 
European Parliament, Committee on Budgetary Control, reporting member: Gilles Boyer. 
6 See also ‘EU anti-fraud architecture – the role of EU-level players, how they cooperate and the challenges they 
face’, a study requested by the European Parliament’s Committee on Budgetary Control, Policy Department for 
Budgetary Affairs Directorate-General for Internal Policies, PE 763.761, by Centre for Strategy and Evaluation 
Services (CSES), August 2024. 
7 For  example,  Special  Report  7/2024  of  the  European  Court  of Auditors  on  the  Commission’s  systems  for 
recovering irregular EU expenditure. 
8 For  example,  on  the  Recovery  and  Resilience  Fund  (RRF)  and  Member  States’  control  systems,  and  on  the 
Commission anti-fraud strategy (CAFS). 
9 Publication is scheduled for September 2025. The reporting member is J. Gregor. 
10 Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing 
the Recovery and Resilience Facility, OJ L 57, 18.2.2021, p. 17–75. 
11 Publication is scheduled for December 2025. The reporting member is I. Maletíc. 
12 Publication is scheduled for September 2026. The reporting member is still to be decided. 
13 Commission Anti-Fraud Strategy Action Plan – 2023 revision, COM(2023) 405 final. 
14Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions of 1 April 2025, ‘ProtectEU: a European Internal Security 
Strategy’, COM (2025)148. 

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response  will  be  at  the  heart  of  the  review.  While  the  review  will  focus  specifically  on 
improving the anti-fraud architecture to ensure that EU funds are better protected against fraud, 
the review may also support the fight against other serious crimes.  

This white paper puts forward some avenues to be explored in the upcoming AFA review. The 
outcome of the AFA review will be presented in a Commission Communication in 2026, which 
will  be  accompanied  by  possible  legislative  proposals,  as  appropriate.  This  will  follow  the 
results of the ongoing evaluations of the legal frameworks applicable to certain actors relevant 
to the AFA, and of the Regulation on the protection of EU financial interests15, as well as the 
Directive on the fight against fraud against the EU’s financial interests (the PIF Directive) 16. 

2.  The EU AFA and its actors 

The EU’s capacity to combat fraud and irregularities has evolved over the years and has been 
strengthened  with  new  actors,  each  contributing  to  a  concerted  effort.  At  EU  level,  the 
responsibility for safeguarding the EU’s financial interests was first entrusted to the Anti-Fraud 
Coordination Unit (UCLAF) in 198817, and then to OLAF. Several other entities involved in 
anti-fraud efforts have since been gradually established in order to enhance the effectiveness 
of the system protecting the EU’s financial interests.  

These are the main actors at EU level whose responsibilities are relevant to the fight against 
fraud and who together form the EU AFA: 

• 

In  the  institutions,  bodies,  offices  and  agencies,  the  Authorising  Officers  by  Delegation 
(AODs) are responsible for the regular expenditure and sound use of the EU budget, in line 
with  the  policy  priorities  and  modalities  defined  by  the  co-legislators  in  pluriannual 
programmes, also taking into account the recommendations of the Internal Audit Service. 
In  doing  so,  they  must  also  detect  and  prevent  fraud  and  irregularities  and  take 
administrative measures to protect the EU budget and recover unduly spent EU funds in 
accordance with the relevant provisions of the Financial Regulation (also “FR”)18. Under 
the  Recovery  and  Resilience  Facility  Regulation,  where  the  primary  responsibility  to 
prevent, detect and correct fraud, corruption and conflict of interest lies with the Member 
States. the AODs need to provide assurance that the Member States fulfil this obligation19. 
In the revenue area, the AODs make sure that the Member States fulfil their responsibility 
to make the own resources available to the EU budget in a timely and correct manner. 

15 Council Regulation (EC, Euratom) No 2988/95 of 18 December 1995 on the protection of the European 
Communities financial interests, OJ L 312, 23.12.1995, p. 1–4. 
16 Directive (EU) 2017/1371 of the European Parliament and of the Council of 5 July 2017 on the fight against 
fraud to the Union’s financial interests by means of criminal law, OJ L 198, 28.7.2017, p. 29. 
17 The UCLAF was a taskforce created as part of the Secretariat-General of the European Commission. It led to 
OLAF’s creation in 1999. See Commission Decision 1999/352/EC of 28 April 1999 establishing the European 
Anti-fraud Office (OLAF), OJ L 136, 31,5,1999, p.20. 
18 Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 2024 
on the financial rules applicable to the general budget of the Union (recast), OJ L, 2024/2509, 26.09.2024. 
19  Regulation (EU) 2021/241 of the European Parliament and of the Council of 12 February 2021 establishing 
the Recovery and Resilience Facility, OJ L 57, 18.2.2021, p. 17–75. 

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•  OLAF  is  responsible  for  carrying  out  administrative  investigations  to  protect  the  EU’s 
financial interests against fraud, corruption and any other illegal activity. OLAF exercises 
its  investigative  powers  (including  on-the-spot  checks)  in  full  independence  in  both  the 
expenditure and revenue areas. Several regulations govern its investigations as well as its 
cooperation  with  Member  States’  competent  authorities  and  other  AFA  actors 20.  In 
addition, OLAF is the Commission’s lead service in the conception and development of a 
European Anti-Fraud policy.21  

•  Since 2021, the EPPO22 has been operating as a single office across the participating EU 
Member States 23, which have transferred to the EPPO the power to investigate, prosecute 
and bring to court perpetrators of criminal offences that affect the EU’s financial interests 
as set out in the PIF Directive (“PIF offences”), including fraud, corruption and money-
laundering, as well as organised crime when the focus is on PIF offences, in accordance 
with the EPPO Regulation. The EPPO combines EU and national prosecutorial efforts in a 
unified approach to the fight against PIF offences. 

•  Eurojust24 was set up in 2002. It is an EU agency that acts as a hub so that national judicial 
authorities can work together to fight serious cross-border crime, including corruption. It 
supports and coordinates the efforts of national authorities (from non-EU countries as well 
as  EU  Member  States)  in  investigating  and  prosecuting  transnational  crime  (e.g. fraud, 
organised crime and terrorism). 

•  Europol25 started its operation in 1999. Its mission is to support the EU Member States law 
enforcement authorities in preventing and combating all forms of serious international and 
organised crime, cybercrime and terrorism. It provides analytical and operational assistance 
to  these  authorities  and  collaborates  with  non-EU  partner  states  and  international 
organisations to enhance cooperation. 

20 These regulations are: 
•  Regulation No 883/2013 of the European Parliament and of the Council of 11 September 2013 concerning 

investigations conducted by the European Anti-Fraud Office (OLAF) (‘OLAF Regulation’); 

•  Regulation  No  2016/2030  of  the  European  Parliament  and  of  the  Council  of  26  October  2016  amending 
Regulation No 883/2013, as regards the secretariat of the Supervisory Committee of the European Anti-Fraud 
Office (OLAF); 

•  Regulation No 2020/2223 of the European Parliament and of the Council of 23 December 2020 amending 
Regulation  No  883/2013,  as  regards  cooperation  with  the  European  Public  Prosecutor’s  Office  and  the 
effectiveness of the European Anti-Fraud Office investigations; 

•  Council Regulation No 2185/96 of 11 November 1996 concerning on-the-spot checks and inspections carried 
out by the Commission in order to protect the European Communities’ financial interests against fraud and 
other irregularities; 

•  Council  Regulation  No 2988/95  of  18 December 1995  on  the  protection  of  the  European  Communities’ 

financial interests; and 

•  Council Regulation No 515/97 of 13 March 1997 on mutual assistance between the administrative authorities 
of the Member States and cooperation between the latter and the Commission to ensure the correct application 
of the law on customs and agricultural matters.  

21 Governance in the European Commission’, Communication to the Commission of 24.6.2020, C(2020) 4240 
final, p. 16. 
22 Council  Regulation  (EU)  2017/1939  of  12 October 2017  implementing  enhanced  cooperation  on  the 
establishment of the European Public Prosecutor’s Office (the EPPO Regulation), OJ L 283, 31.10.2017, p. 1. 
23 All Member States currently participate in the EPPO, except Denmark, Ireland and Hungary. 
24 Regulation  (EU)  2018/1727  of  the  European  Parliament  and  of  the  Council  of  14 November 2018  on  the 
European  Union  Agency  for  Criminal  Justice  Cooperation  (Eurojust),  and  replacing  and  repealing  Council 
Decision 2002/187/JHA, PE/37/2018/REV/1, OJ L 295, 21.11.2018, p. 138. 
25 Council Decision 2009/371/JHA of 6 April 2009 establishing the European Police Office (Europol), OJ L 121, 
15.5.2009, p. 37. 

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•  As  the  EU’s  external  auditor,  the  ECA  examines  all  the  EU’s  revenue  and  expenditure 
accounts with a view to providing the European Parliament and the Council with an annual 
statement of assurance on the reliability of the accounts and the legality of the underlying 
transactions.  In  doing  so,  it  also  reports  on  irregularities.  In  addition,  the  ECA  adopts 
special reports and reviews on a broad range of areas of EU spending and policies.  

•  AMLA was created in 2024 to prevent money-laundering and the financing of terrorism. It 
will be fully operational as from 1 January 2028. Its powers will enable it to support the 
operational coordination of national authorities tasked with supervision or with producing 
financial intelligence. In addition, AMLA has been conferred direct supervisory powers, 
including  the  possibility  to  impose  pecuniary  sanctions  and  administrative  measures  on 
operators and financial institutions (including banks) under its direct supervision,  to ensure 
that they correctly and consistently apply the EU rules on anti-money laundering and on 
countering  the  financing  of  terrorism.  These  rules  have  been  overhauled  and  will  apply 
across the EU as of mid-2027. 

•  On 17 May 2023, the Commission proposed the establishment of an EU Customs Authority 
as part of the customs reform package26. The aim is to adopt via this new authority a more 
centralised  digital  approach,  especially  with  respect  to  customs  risk  management  and 
controls,  to ensure a more efficient, strengthened and fraud-proof customs union and play 
a key role in fighting fraud at the EU external borders. 

Cooperation  between  EU  institutions  and  Member  States,  and  between  Member  States 
themselves,  is  key  because  the  protection  of  the  EU’s  financial  interests  is  a  common 
responsibility  for  the  EU  and  national  authorities.  The  Member  States  are  responsible  for 
adopting, implementing and enforcing the rules and procedures that effectively safeguard the 
EU’s financial interests. They also have a leading role and specific obligations in detecting, 
reporting and addressing fraudulent activities against the EU’s budget. For instance, in the field 
of taxation, the Eurofisc Member States’ network27 was set up in 2010 to combat cross-border 
VAT fraud. Its mandate covers joint processing and data analysis, coordination of follow-up 
actions, and access to customs data on VAT exempt importations28. 

EU  law  provides  for  a  sincere  and  effective  cooperation  between  the  Commission  through 
OLAF and the Member States’ competent authorities, as well as for OLAF  supporting EPPO’s 
criminal  cases    or  complementing  them  with  administrative  investigations.  A  good  level  of 
cooperation  has  already  been  achieved  between  the  anti-fraud  actors.  This  includes  OLAF 
supporting  the  EPPO’s  criminal  cases  or  complementing  them  with  administrative 
investigations;  coordinating  investigative  activities  of  Member  Sates’  authorities,  providing 
assistance  to  those  authorities,  conducting  joint  investigations  with  the  support  and 
participation of EPPO, Europol, Eurojust, OLAF and Member States’ authorities, operational 

26 See, in particular, the proposal for a regulation of the European Parliament and of the Council establishing the 
Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013, 
COM/2023/258 final. The proposal is with the co-legislators. 
27 Council Regulation (EU) No 904/2010 of 7 October 2010 on administrative cooperation and combating fraud 
in the field of value added tax (recast), OJ L 268, 12.10.2010, p. 1. 
28 Europol, Eurojust and Eurofisc are still characterised by the ‘intergovernmental third pillar spirit’ in that they 
depend on the final decision taken by national authorities, which they are not intended to replace. 

5 

 
 
 
 
 
meetings, and an annual exchange of views between OLAF29, the EPPO, Europol, Eurojust and 
the ECA with the European Parliament, the Council and the Commission.  

A strategic focus on synergies and resource optimisation has become essential, given both the 
diverse mandates and capabilities of the various anti-fraud actors and the addition of the new 
actors to the architecture. It is key that each entity can play its part in a seamless and efficient 
system to prevent and combat fraud affecting the EU financial interests. 

3.  Areas of focus for the AFA review  

3.1 Strengthened preventive measures 

Strong anti-fraud prevention systems for EU funds are already in place and the Commission 
has taken steps to continuously improve them as part of its internal control strategy. In addition, 
the 2024 Financial Regulation (the ’FR’)30 has introduced several innovations that will help 
further  strengthen  the  prevention  and  detection,  correction  and  follow-up  of  irregularities, 
including fraud and corruption from the next MFF onward. They include: 

- 

- 

several improvements31 to the Early Detection and Exclusion System (EDES)32 and the 
extension of its scope to shared management (and to direct management with the Member 
States)  as  from  1 January 2028.  The  EDES  allows  to  detect  fraudulent  or  unreliable 
economic  operators  at  an  early  stage  and  based  on  alleged  facts.  If  misconduct  is 
established, an economic operator can be temporarily excluded from receiving EU funds 
for up to five years. EDES cases can also, in certain conditions, lead to the imposition of 
financial penalties. Decisions are registered in a central database that can be accessed by 
all IBOAs and Member State authorities. 

the compulsory feeding of the single data mining and risk-scoring tool (Arachne+) for 
audit and control purposes as from 1 January 2028. Data collected by all Member States’ 
authorities as regards all funds will be included in a single EU-wide tool. This will enhance 
control and audit functions across the EU and assist national authorities and AFA actors in 
the prevention, detection, correction and follow-up of fraud, corruption and irregularities, 
including  conflicts  of  interest  and  double-funding.  The  use  of  Arachne+  by  managing 
authorities  will  remain  voluntary,  but  the  European  Parliament,  the  Council  and  the 
Commission  have  agreed  to  re-examine  the  compulsory  use  of  Arachne+  based  on  an 
assessment of the readiness of the tool to be delivered by the Commission in 2027. 

Fraud  prevention  efforts  must  continue  and  could  be  further  enhanced.  OLAF  has 
developed considerable experience and an extensive network of contact points with Member 

29 Article 16 of Regulation No 883/2013 of the European Parliament and of the Council of 11 September 2013 
concerning investigations conducted by the European Anti-Fraud Office (OLAF) and repealing Regulation (EC) 
No 1073/1999 of the European Parliament and of the Council and Council Regulation (Euratom) No 1074/1999, 
OJ L 248, p. 1. 
30 Regulation 2024/2509 of the European Parliament and of the Council of 23 September 2024 on the financial 
rules  applicable 
(recast),  OJ L,  2024/2509,  26.9.2024, 
ELI: http://data.europa.eu/eli/reg/2024/2509/oj. 
31 These  improvements  include  an  expedited  procedure,  a  legal  presumption  of  notification,  the  possibility  of 
excluding beneficial owners, and a few new cases of grave professional misconduct that can lead to exclusion. 
32 The EDES was set up in 2016 as one of the instruments to protect the EU’s financial interests. 

the  general  budget  of 

the  Union 

to 

6 

 
 
 
 
 
 
States and third countries and in developing anti-fraud strategies in Member States and non-
EU countries. OLAF’s invaluable expertise in fraud and corruption prevention should be used 
by all AFA actors to the maximum possible extent. AFA actors should also be encouraged to 
use the anti-fraud coordination services (AFCOS), which are coordinated by OLAF, to bolster 
collaboration  between  national  and  EU-level  bodies  in  fraud  and  corruption  prevention. 
Information exchange under Council Regulation (EC) No 515/97 should also be better used to 
enhance mutual assistance between national administrative authorities in the context of fraud 
prevention33.  

Fraud prevention is particularly important in the revenue area where authorities are unlikely 
to be able to recover from the perpetrators the amounts that they have evaded. It is the 
Member  States’  responsibility  to  recover  the  amounts  lost  (especially  VAT  and  customs 
duties).  However,  most  losses  cannot  be  recovered  by  national  authorities  (even  when  the 
fraudsters  are  identified,  prosecuted  and  convicted)  because  they  usually  organise  their 
insolvency  or  bankruptcy  or  are  located  outside  the  EU’s  jurisdiction.  The  focus  of 
administrative  investigations  is  therefore  currently  to  detect  fraud  at  an  early  stage,  and 
coordinate  controls  by  national  authorities  to  prevent  further  fraudulent  imports  and  adopt 
precautionary measures to protect the EU budget. The focus of criminal investigations in this 
area  is  largely  on  identifying  the  criminal  networks  behind  fraud,  stopping  their  activities, 
disrupting criminal networks and avoiding future fraudulent activity and the related losses. 

Anti-fraud  strategies  are  essential  for  tackling  fraud  and  corruption  in  a  comprehensive 
manner  that  integrates  measures  throughout  the  anti-fraud  cycle,  including  prevention.  The 
Commission’s anti-fraud strategy and its action plan were revised in 2023. The new action plan 
includes 44 actions under 7 themes that cover the Commission’s priorities in fighting fraud. 
Digitalisation  is  the  plan’s  first  theme  and  a  quarter  of  the  actions  focus  on  improving  the 
Commission’s and Member States’ use of IT tools for anti-fraud purposes (e.g. Arachne, EDES 
and the IMS34). The action plan also provides for increased cooperation within the Commission 
and with key external partners and civil society to protect EU funding. Other themes include 
the  RRF,  customs  fraud  and  further  strengthening  ethics  and  the  anti-fraud  culture  in  the 
Commission. Implementation of the action plan is ongoing. In addition, Commission services 
and executive agencies have sectorial anti-fraud strategies which further strengthen the anti-
fraud framework in place. 

To further enhance prevention, anti-fraud strategies with related action plans could also be put 
in  place  at  the  national  level.  Not  all  Member  States  have  national  anti-fraud  strategies  at 
present and the existing strategies do not necessarily follow a consistent approach. This can 
lead to weaknesses and gaps in the global anti-fraud approach.  

33 Council Regulation No 515/97 of 13 March 1997 on mutual assistance between the administrative authorities 
of the Member States and cooperation between the latter and the Commission to ensure the correct application of 
the law on customs and agricultural matters, OJ L 82, 22.3.1997, p. 1. 
34 The Irregularity Management System (IMS) is a dedicated electronic system for reporting irregularities. It has 
been developed and put at the disposal of Member States and beneficiary countries. The IMS is operated under 
the Anti-Fraud Information System (AFIS) and is used by 35 countries. 

7 

 
 
 
3.2 Improving detection 

Detecting  irregularities,  fraud  and  other  illegal  activities  affecting  the  Union’s  financial 
interests  at  the  earliest  possible  stages  is  a  necessary  precondition  for  the  effective 
implementation of the anti-fraud cycle at both national and EU level. 

a. Reporting 

At  national  level,  Member  States  have  the  main  responsibility  for  detecting  and  timely 
reporting fraud and corruption to the EPPO for investigation and prosecution, and to swiftly 
report other irregularities to OLAF, providing it with reliable data on fraud activities. These 
are a fundamental step for the Commission to be aware of the indispensable information on the 
established or suspected irregularities and fraud detected in the Member States. In this regard, 
the next MFF is an opportunity to review the appropriateness of national reporting procedures.  

The use of existing instruments, such as the IMS, OWNRES35 and EDES (for its early detection 
part),  can  significantly  contribute  to  further  disseminating  the  information  that  may  lead  to 
taking the appropriate preventive measures and the early detection of fraud cases. 

Moreover, whistleblower protection is a powerful tool in the fight against fraud and corruption. 
It can play a pivotal role in supporting the transparency and accountability both of government 
and of corporate conduct and bring to light fraudulent activities that are otherwise difficult to 
detect. The effective implementation of the EU Whistleblower Directive36 can contribute to 
better and earlier detection of fraudulent activities affecting the financial interests of the EU. 

b. Information exchange between the AFA actors 

Eurojust  and  Europol  enhance  the  EU’s  capacity  to  combat  fraud  by  ensuring  effective 
coordination between the respective judicial and law enforcement bodies and facilitating the 
exchange of information. They help overcome the limitations posed by national borders and 
differing legal frameworks, thereby strengthening the EU’s collective response to fraud and 
corruption  as  well  as  hindering    perpetrators’  ability  to  exploit  disparities  between  national 
systems.  It  is  crucial  for  Europol  and  Eurojust  to  enhance  their  collaboration  to  ensure 
comprehensive coverage of the entire criminal justice process, thereby facilitating the transition 
of investigations into successful prosecutions and convictions of criminals. 

Cooperation  and  the  sharing  of  data  and  information  between  AFA  actors  is  crucial  for 
detection.  Taking  into  account  the  growing  volume  of  data,  any  mechanism  that  would 
facilitate information exchange, based on consistent and harmonised data, could be helpful. If 
feasible, such exchange could be done in real time and on an interoperable basis, in compliance 
with data protection rules, to improve the effectiveness of information sharing and to facilitate 
timely and coordinated action by all the relevant actors. For example, an immediate sharing of 
actionable information, is key in view of facilitating the reporting of suspicions of crimes to 

35 The Commission has developed the own resources database (OWNRES) as an electronic system to facilitate 
the  reporting  and  monitoring  of  cases  of  fraud  and  irregularities  that  affect  entitlements  to  traditional  own 
resources. 
36 Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the 
protection of persons who report breaches of Union law, OJ L 305, 26.11.2019, p. 17–56. 

8 

 
 
 
the  EPPO  without  undue  delay37.  Another  example  is  that  data  collected  by  OLAF  during 
investigations  on  customs  fraud  can  be  useful  to  Europol  in  its  work  on  combatting  the 
circumvention of EU restrictive measures (sanctions). 

c. Use of new technologies and AI, data analysis and intelligence sharing 

Fraudsters are using new technologies to find new ways to commit fraud. However, AI and 
new IT tools can also help AFA actors step up the fight against fraud. These tools’ capacity to 
analyse large amounts of data can be particularly helpful in detecting fraud at early stages.  

On prevention and detection, key questions that the AFA review could explore are:  

-  How  can  it  be  ensured  that  all  actors  take  appropriate  actions  (including  sharing 
necessary  information)  as  early  as  possible  at  both  national  and  EU  level  in  order  to 
enhance prevention and detection capabilities of fraud throughout the EU?  

-  How can early access to actionable information on reported irregularities and fraud be 

ensured, including amongst independent investigative EU bodies?  

-  Which  legislative  amendments  are  needed  to  facilitate  access  by  all  AFA  actors  to 
relevant data, information-sharing and the pooling of technical support, building on the 
strengths  of  each  specific AFA  actor  and  subject  to  appropriate  procedural  and  data 
protection safeguards? 

-  How can national anti-fraud strategies strengthen the fight against fraud? 

-  How can the effective reporting by Member States of suspected cases of irregularities 

and fraud (IMS, OWNRES) and its use for prevention and detection be ensured?  

-  How can the use by Member States and AFA actors of new AI tools, as well as that of 
existing tools such as EDES and Arachne+ be leveraged in order to increase the level of 
prevention/detection? 

3.3 Improving investigation and prosecution capabilities 

a.  Data-sharing,  operational  analysis  and  forensics  capacities  in  the 
investigation phase 

There is a significant potential for collection, sharing and analysis of the data available in the 
respective AFA actors’ digital tools, including with the use of AI. However, this potential is 
constrained by the differences in how the Member States use and exchange information. Such 
discrepancies  may  occur  at  different  stages  of  the  anti-fraud  chain  but  still  have  important 
consequences in the investigation phase. 

AFA actors can already access each other’s databases, but the conditions in which such access 
and  data-sharing  take  place  can  be  improved  still  further.  For  instance,  it  may  be  useful  to 
create,  under  certain  conditions  and  subject  to  appropriate  procedural  and  data  protection 
safeguards,  specific  rules  that  allow  OLAF  and  the  EPPO  to  exchange  information  with 

37 See Article 24 of the EPPO Regulation. 

9 

 
 
 
 
 
Eurofisc and provide them with centralised access at EU level to certain VAT information so 
that they can investigate potential fraud or VAT-related irregularities.  

Another area where better synergies can be developed relates to the use of expertise. All AFA 
actors use internal analytical capabilities and/or forensic expertise to carry out their work. In 
the  context  of  resource  constraints  for  EU  administration,  appropriate  administrative 
arrangements could be put in place to allow the pooling of existing expertise and the building 
of joint capacities for modern anti-fraud investigations involving different AFA actors.  

Among  EU  AFA  actors,  OLAF  and  Europol  have  a  unique  longstanding  experience  in 
forensics  and  operational  analysis.  Europol  already  facilitates  the  exchange  of  information 
between law enforcement authorities, including police and customs. Without pre-empting the 
results of the ongoing evaluation, an increased role for Europol as potentially the key EU player 
for data analysis and forensic acquisition could be considered in the AFA review and in the 
context of the update of Europol’s mandate, announced in ProtectEU – the European Internal 
Security  Strategy38.  Furthermore,  close  cooperation  and  information  exchange  between  the 
AFA actors could also allow follow up on leads for other serious crimes, that may emerge in 
fraud investigations. 

Finally, the EU Customs Data Hub, operated by the new EU Customs Authority39, will provide 
a pool of real-time data on customs flows and enhanced data analytics capacity that will allow 
for a better risk management and customs controls at the external borders. 

b. Enhanced complementarity and coordination between the EPPO and OLAF  

Given  the  EPPO  and  OLAF’s  common  objective  to  protect  the  EU  budget,  the  EPPO 
Regulation  expressly  prohibits  parallel  administrative  investigations  by  OLAF  on  the  same 
facts on which the EPPO is conducting a criminal investigation, while the EU legislator has 
made it clear that the EPPO and OLAF should establish and maintain close cooperation aimed 
at ensuring the complementarity of their respective mandates and avoiding duplication. The 
EPPO Regulation specifies that the EPPO may request OLAF ‘to support or complement’ the 
EPPO’s activities, including by conducting administrative investigations40. The subsequently 
amended  OLAF  Regulation  labelled  these  administrative  investigations  as  ‘complementary 

38 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social Committee and the Committee of the Regions of 1 April 2025, ‘ProtectEU: a European Internal Security 
Strategy’, COM (2025)148. 
39 See the Proposal for a Regulation of the European Parliament and of the Council establishing the Union Customs 
Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013, COM/2023/258 
final. 
40 See Article 101(3) of the EPPO Regulation: ‘In the course of an investigation by the EPPO, the EPPO may 
request OLAF, in accordance with OLAF’s mandate, to support or complement the EPPO’s activity in particular 
by:  (a) providing  information,  analyses  (including  forensic  analyses),  expertise  and  operational  support; 
(b) facilitating coordination of specific actions of the competent national administrative authorities and EU bodies; 
(c) conducting administrative investigations’. See also Article 12e of the OLAF Regulation (‘The Office’s support 
to the EPPO’) which states: ‘1. In the course of an investigation by the EPPO, and at the request of the EPPO in 
accordance with Article 101(3) of Regulation (EU) 2017/1939, the Office shall, in accordance with its mandate, 
support  or  complement  the  EPPO’s  activity,  in  particular  by:  a. providing  information,  analyses  (including 
forensic  analyses),  expertise  and  operational  support;  b. facilitating  coordination  of  specific  actions  of  the 
competent national administrative authorities and EU bodies; c. conducting administrative investigations.’ 

10 

 
 
 
 
investigations’  although  they  may  not  always  involve  investigative  activities,  providing  a 
specific legal framework for OLAF to conduct them and cooperate with the EPPO. 

OLAF’s  support  to  the  EPPO  and  complementary  investigations  are  also  reflected  in  the 
Working Arrangement between OLAF and the EPPO41, which states that ‘they should aim at 
facilitating the collection of relevant information for the adoption of precautionary measures 
or  the  conduct  of  financial,  disciplinary  or  administrative  measures’.  Complementary 
investigations  and  activities  from  OLAF  may  be  needed,  in  particular,  in  the  following 
situations: (i) the statute of limitations applicable to the criminal offence investigated by the 
EPPO  poses  a  concrete  obstacle  to  the  effective  recovery;  (ii)   there  is  a  need  to  take 
administrative precautionary measures, and, whenever possible, launch recovery actions at an 
early stage, pending the EPPO’s criminal investigation; (iii) there is a threat to the EU’s budget 
by virtue of the damage deriving from the presumed criminal offence; (iv) there are reasonable 
grounds  to  believe  that  recommendations  could  be  needed  or  justified  for  disciplinary  or 
administrative measures to be taken (including recommendations to refer the case to the EDES 
panel); and (v) there is evidence of non-fraudulent irregularity.  

However, the use of complementary administrative investigations has remained rather limited 
so far 42, although both types of investigations (criminal and administrative) are essential  and 
contribute to  fully protect the EU budget and prevent or limit damage. For example, for an 
effective protection of the EU budget, adequate administrative measures taken to safeguard the 
funds already disbursed and to prevent further funds from being unduly spent, including EDES 
measures, need to be taken as early as possible. By employing all available tools to their full 
extent,  and  at  the  same  time  ensuring  that  there  is  no  duplication  between  criminal  and 
administrative investigations, the EU can better protect its financial interests and promote a 
transparent, accountable and sustainable financial environment. 

It is therefore worth considering concrete ways of enhancing cooperation and complementarity 
between the EPPO and OLAF (as well as with other AFA actors) in order to avoid the risk of 
uncoordinated actions; ensuring the clearest possible demarcation of their respective roles; and 
formalising the conditions under which different activities are carried out. 

c. Better support to prosecution 

The EPPO is competent to investigate, prosecute and bring before national courts perpetrators 
of criminal offences that affect the EU’s financial interests as set out in the PIF directive, in 
accordance with the EPPO regulation.  

In light of experience, some improvements may be necessary at both the national and the EU 
level for the EPPO’s activities to be more effective. At national level, dedicated and specialised 
law enforcement authorities could support the EPPO more effectively, in particular in areas 
such  as  customs,  tax  fraud,  and  financial  crime.  At  EU  level,  increased  cooperation  with 

41 Point 6.2  of  the  Working Arrangement  between  the  European Anti-Fraud  Office  and  the  European  Public 
Prosecutor’s Office, 5 July 2021: 
https://www.eppo.europa.eu/sites/default/files/2021-07/Working_arrangement_EPPO_OLAF.pdf. 
42 See  comparison  between  the  complementary  investigations  and  the  overall  investigative  activity  of  the  two 
offices:  after  3.5 years  of  operational  cooperation,  OLAF  and  EPPO  have  worked  together  on  some  136 
investigations (the EPPO had carried out 1 927 active investigations by 31 December 2023). 

11 

 
 
 
 
 
Europol  as  regards  risk  analysis  and  operational  support,  and  with  Eurojust  as  regards  the 
functioning of the Joint Investigation Teams (JITs), would allow for greater support to EPPO, 
particularly in cross-border cases. In addition, a semi-automated hit/no-hit system tailored for 
the EPPO, Eurojust, Europol, and OLAF, which, while respecting procedural guarantees and 
mandates of each of the bodies and agencies, could improve early detection of cross-border 
criminal patterns and facilitate cooperation.  

On data-sharing and analytical/forensic capacities, investigation and prosecution, key 
questions that the AFA review could explore are:  

-  How could the criminal investigations conducted by the EPPO be complemented, where 
appropriate,  by  administrative  investigations  conducted  by  OLAF  in  a  more  effective 
way, with a view to establishing a solid basis for the early adoption by the Commission 
of administrative measures, including precautionary and/or recovery measures? 

-  How could access to the relevant data regarding suspicion of fraud or financial crimes 

affecting the interests of the EU be improved? 

-  How could timely access and transmission of relevant information between AFA actors 

be improved? 

-  How could the use of new technologies and  AI to increase the efficiency of the AFA 

actors be leveraged? 

-  How could the effectiveness of investigation and prosecution of PIF crimes be improved 

at national and EU level? 

3.4 Towards a more efficient recovery process for the EU budget 

The recovery process relies on Member States (particularly on the revenue side) and IBOAs 
(on the expenditure side). It is a complex process which requires cooperation not only within 
the Commission but also with a number of other actors (including independent investigative 
bodies such as OLAF and EPPO and the relevant national authorities) 43. The establishment of 
the EPPO has significantly strengthened the overall AFA, and its prosecution activities have 
brought results as regards indictments, convictions and confiscation of assets, although in the 
current legal framework the EPPO has only a limited role in the recovery process. Recent case 
law of the Court of Justice of the European Union44 related to the PIF Regulation45 and the 
Financial  Regulation  provide  the  legal  bases  for  the  development  of  additional  tools  for 

43 This is not always the case. During the negotiations for the 2024 FR revision, the Council refused to extend to 
the Commission the right to use the mutual assistance mechanism that the Member States have applied among 
themselves  to  recover  national  debts  for  many  years. This  delays  the  recovery  process  because  it  obliges  the 
Commission to find for itself the key information that it needs (e.g. on the debtor’s identity, solvency, address or 
assets) in order to recover funds. 
44 Judgments of 26 September 2024 in joint cases C-160 and 161/22P, Commission v HB; of 4 October 2024 in 
case C-721/22P, Commission v PB and of 29 February 2024 in case C-437/22, Eesti Vabariik. 
45 Council Regulation (EC, Euratom) No 2988/95 of 18 December 1995 on the protection of the European 
Communities financial interests, OJ L 312, 23.12.1995, p. 1–4. 

12 

 
 
 
 
 
 
recovery,  including  from  physical  persons  that  are  responsible  for  the  fraud,  by  means  of 
administrative decisions. Overall, as ECA also noted 46, further improvements are needed in 
order to increase the efficiency of the recovery process for the EU budget. 

a. Revenue 

In terms of revenue, Member States have primary responsibility for the establishment and the 
collection of customs duties which are referred to as traditional own resources (“TOR”) and 
which directly finance the EU budget. Therefore, Member States are obliged to put in place 
adequate  control  systems  to  ensure  that  their  national  customs  authorities  carry  out  their 
customs controls in an appropriate way. National customs authorities play a crucial role in the 
AFA, acting as the first line of defence against illegal activities that impact the EU’s financial 
interests.  In  the  current  MFF  (2021-2027),  Member  States  retain  a  25%  share  of  the  total 
collection of customs duties collected. The financial damage estimated by the EPPO and OLAF 
in this area is mostly related to customs fraud resulting in a lower collection of customs duties, 
and consequently the corresponding TOR made available to the Union budget being lower than 
what  is  due.  Since  recoveries  from  fraudulent  importers  tend  to  be  limited,  the  focus  of 
administrative  investigations  is  to  detect  fraud  at  an  early  stage  in  coordination  with  the 
Member States, to facilitate the adoption of precautionary measures to protect the EU budget. 

Furthermore,  the  new  EU  Customs  Authority  will  allow  for  additional  coordination  of  risk 
management at EU level, while integrating the results of the identified frauds in future actions, 
e.g., via the future EU Customs Data Hub.  

Regarding VAT, the VAT-based own resource to which the EU is entitled is calculated on the 
basis  of  VAT  actually  collected  by  Member  States.  Accordingly,  any  shortfall  in  VAT 
collection not only reduces revenue for Member States, but also reduces VAT own resources 
for the general budget of the EU, with consequences for the level of the GNI-resource for all 
Member  States  47.  Moreover,  a  significant  amount  of  the  VAT-related  damage  comes  from 
cross-border VAT fraud, often committed in the framework of criminal organisations. This can 
be more effectively and efficiently tackled through closer cooperation between Member States 
and EU institutions and bodies (EPPO, OLAF, Commission, etc.); and closer cooperation in 
the judicial area including with non-EU countries and international organisations, building on 
the  many  administrative  arrangements  concluded  by  OLAF  that  significantly  improve 
transnational administrative cooperation and facilitate access to information and the support 
that can be provided by Eurojust Furthermore, Eurofisc will continue to have a pivotal role in 
the fight against VAT fraud.  

46 Special Report 7/2024 of the European Court of Auditors on the Commission’s systems for recovering irregular 
EU expenditure. 
47 See, to that effect, judgment in Åkerberg Fransson, C‑617/10, EU:C:2013:105, paragraph 34 and the case-law 
cited. 

13 

 
 
 
 
b. Expenditure 

Financial recommendations issued by OLAF between 2012 and 2023 show that recovery rates 
depend on different variables (e.g. the budget management mode and the legal complexity of 
the individual cases).  

The  expenditure  side  covers  direct,  indirect  and  shared  management  modes.  In  direct 
management, the lessons learned from OLAF recommendations have already resulted in the 
Commission adopting, on 6 February 2024, an enhanced corporate strategy for the management 
of the Commission’s debtors. This strategy aims at recovering more and faster and has a double 
objective:  

- 

- 

to close the gap between the amounts recommended by OLAF for recovery and the amounts 
established to be recovered48, through better interaction between OLAF and the AODs; and  
to  close  the  gap  between  established  and  recovered  amounts  by  enhancing  the 
to  OLAF 
Commission’s 
recommendations.  

internal  monitoring  mechanism 

following  up 

for 

Recoveries for the EU budget still need to improve.  Reflections should therefore continue on 
how  to  effectively  ensure  in  practice  that  the  Union  budget  obtains  compensation  for  the 
damage it has suffered.   

At the request of the Commission, the EPPO agreed to revise its notification templates in order 
to  transmit  to  AODs  the  timely,  detailed  and  actionable  information  needed  to  take  the 
appropriate measures to protect the EU’s financial interests49. 

Without prejudice to possible legislative changes, the Commission is also considering short-
term actions to improve the internal monitoring of OLAF recommendations and the follow-up 
to the EPPO’s notifications50, with a view to bring about improvements in practice. 

The  protection  of  the  EU’s  financial  interests  would  not  be  complete  without  necessary 
complementarity between (i) the efficient investigation and prosecution of offences against the 
EU’s financial interests; and (ii) recovery and administrative/precautionary measures, taken at 
both the EU and national level (e.g. exclusion from future EU funding and compensation for 
the  damage  which  has  been  caused  to  the  EU  budget  through  a  civil  action).  This 
complementarity is required by the Treaties and the Financial Regulation51. 

Effective  deterrence  is  not  possible  without  a  combination  of  swift  criminal  investigations, 
final  convictions,  administrative  measures  adopted  by  the  AODs,  including  precautionary 
measures, sanctions imposed by courts or administrative authorities and efficient recoveries. 

48 The  authorising  officer  of  the  service  that  receives  the  OLAF  recommendation  (in  customs  matters  the 
authorities of the Member State concerned) may reject the OLAF recommendation in whole or in part. The amount 
established to be recovered is therefore the final amount that the recipient of the recommendation will claim for 
recovery or, in the case of shared management, will claim to exclude from EU financing. 
49 Revised  templates  are  annexed  to  the  Agreement  establishing  the  modalities  of  cooperation  between  the 
Commission and the EPPO of 2 June 2021. They have applied since November 2024. 
50 Such actions could include designating a Commission service to be in charge of supporting the AODs in taking 
early precautionary measures and timely recovery steps; and enhancing cooperation among relevant services and 
reporting tools. 
51 See Articles 325 TFEU, 129 FR and 138 FR. 

14 

 
 
 
With a view to making the recovery process more efficient, key questions that the AFA 
review could explore are: 

-  How  can  the  EU’s  budget  be  protected  by  ensuring  that  the  AODs  can  adopt 
precautionary  as  well  as  recovery  measures  and  effectively  obtain  compensation  for 
damage to the EU’s financial interests in a timely manner?  

-  How can recoveries to the EU budget be facilitated, particularly through the transfer of 
proceeds from insolvency procedures and from seized and confiscated assets following 
EPPO’s investigations, including by leveraging  the EPPO’s role in criminal proceedings 
to support  the recovery of such assets in favor of the Union’s budget? 

-  How can deterrence actions by AFA actors be further strengthened? 

3.5 Improving the governance of the anti-fraud architecture 

In its CONT Report, the European Parliament’s Committee on Budgetary Control has called 
for a more measurable and result-oriented AFA governance; a more effective deployment of 
adequate resources and their more efficient use; a more holistic approach in reporting through 
the PIF report; and more coordination and cooperation between AFA actors52. 

The AFA review will take into account the results of relevant ongoing evaluations and build 
on the work of all AFA actors. On that basis, the review will consider their mandates as well 
as their complementarity and coordination and ensure a better integrated AFA.  

With the current legal framework, AFA actors have their own set of obligations to report on 
their  anti-fraud  activities.  This  has  led  to  differences  in  the  individual  approaches  to 
cooperation and reporting. The lack of a consistent approach hampers a clear overall picture of 
how the protection of the EU’s financial interests is ensured by the different actions throughout 
the AFA. 

On the governance of the anti-fraud architecture, key questions that the AFA review 
could explore are: 

-  How can coordination of all relevant actors be improved, including on reporting on the 

actions taken to protect the EU’s financial interest? 

- 

Is there a need to define a common set of indicators to ensure consistent reporting and to 
obtain a clearer overview of how the AFA actors collectively protect the EU’s financial 
interests, within their respective mandates? 

-  How can regular strategic and operational dialogue and exchange of best practices be 
enhanced, as well as monitoring of the implementation of the actions to be decided in the 
context of the AFA review? 

4.  Conclusions: way forward 

52 Report on the protection of the EU’s financial interests – combating fraud – annual report 2023, 1 April 2025, 
European Parliament, Committee on Budgetary Control, reporting member: Gilles Boyer, paragraphs 3, 4, 6 and 
7. 

15 

 
 
 
 
 
 
The present White Paper puts forward some avenues to be explored for the review of the AFA 
and  its  areas  of  focus.  The  Commission  invites  the  traditional  stakeholders  (the  European 
Parliament, Council and ECA) as well as all the AFA actors to contribute to the reflection based 
on the above-mentioned  orientations and questions. This will make it possible to take these 
views into account together with the results of the ongoing evaluations of the legal frameworks 
applicable to certain actors relevant to the AFA (e.g. Eurojust, Europol, the EPPO and OLAF) 
and the PIF Directive reports. 

The outcome of the AFA review will be presented in a Commission communication in 2026. 
It may be accompanied, as appropriate, by possible legislative proposals related to the OLAF, 
EPPO, Eurojust, Europol or Eurofisc Regulations and the PIF Directive. This could be a unique 
opportunity to ensure a more coherent AFA with simplified and operational answers in reply 
to the issues mentioned in this white paper and attuned to the new MFF. Some of these issues 
require  further  analysis  to  be  conducted  in  the  context  of  the  ongoing  evaluations.  The 
Commission therefore proposes to take the debate on the future of the EU AFA forward in this 
context. 

16