COMMISSION STAFF WORKING DOCUMENT Commission Anti-Fraud Strategy (CAFS) Action Plan Implementation monitoring: state of play 31 May 2025 Accompanying the document Report from the Commission to the Council and the European Parliament 36th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2024
Date: 2025-07-25
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU strategy, activity report, corruption, digitisation, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 25.7.2025  SWD(2025) 197 final  COMMISSION STAFF WORKING DOCUMENT Commission Anti-Fraud Strategy (CAFS) Action Plan Implementation monitoring: state of play 31 May 2025 Accompanying the document Report from the Commission to the Council and the European Parliament 36th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2024 {COM(2025) 426 final} - {SWD(2025) 196 final} - {SWD(2025) 198 final} - {SWD(2025) 199 final} - {SWD(2025) 228 final} - {SWD(2025) 229 final} - {SWD(2025) 230 final}  
 
 
LIST OF ABBREVIATIONS  

AFCOS  

Anti-Fraud Coordination Service  

AFIS  

CAFS 

CAP  

Anti-Fraud Information System  

Commission Anti-Fraud Strategy 

Common Agricultural Policy  

COCOLAF 

Advisory Committee for the Coordination of Fraud Prevention 

CBAM  

Carbon Border Adjustment Mechanism 

DAC 

DG 

ECA 

Common Audit Directorate of DG REGIO and DG EMPL 

Directorate-General 

European Court of Auditors 

EMFAF 

European Maritime, Fisheries and Aquaculture Fund 

EDES 

EEAS 

EIPA 

Early Detection and Exclusion System 

European External Action Service 

European Institute of Public Administration 

EMPACT 

European Multidisciplinary Platform Against Criminal Threats 

EPPO    

European Public Prosecutors’ Office  

EPSO 

ETS 

EUCI 

European Personnel Selection Office 

Emissions Trading System 

EU classified information 

FPDNet 

Fraud Prevention and Detection Network 

GETI 

GIPs 

IDOC 

IMS 

JRC 

MFF  

NAFS    

OLAF    

PIF  

RRF  

Get Intelligence system 

Guidelines on Investigative Procedures 

Investigation and Disciplinary Office 

Irregularity Management System  

Joint Research Centre 

Multiannual Financial Framework  

National Anti-Fraud Strategy  

European Anti-Fraud Office  

Protection of the EU’s Financial Interests  

Recovery and Resilience Facility  

SOCTA 

Serious and Organised Crime Threat Assessment 

TSI 

Technical Support Instrument 

UAFP   

Union Anti-Fraud programme 

UNCAC 

United Nations Convention against Corruption 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INTRODUCTION 

On 11 July 2023, the Commission adopted its revised Commission Anti-Fraud Strategy (CAFS) action 
plan1. It includes 44 actions under seven themes that cover the Commission’s priorities in fighting fraud. 

This  document  presents  the  state-of-play  of  the  individual  actions  of  the  plan  and  is  part  of  the 
monitoring  of  the  CAFS  action  plan  implementation.  It  has  been  prepared  in  consultation  with 
Commission departments and Executive agencies to accompany the 2024 Report on the protection of 
the European Union’s financial interests, the so-called PIF report. 

The text in blue represents the actions as published in July 2023, while the remaining text reflect the 
state-of-play of the implementation of the actions on 31 May 2025.  

Some actions have been completed. Other actions of a more continuous nature have been implemented 
but work will continue. For some others, implementation is still ongoing. 

1 COM(2023) 405 final and SWD(2023) 245 final 

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Further develop, promote and increase the use of the current Arachne system in the Commission and in Member 
States notably by increasing user-friendliness and exploring possibilities for interoperability and synergies with 
other corporate IT tools as well as national databases. 

Due date 
2023 and 
continuous 

Lead 
DAC, EMPL: 
lead 
Shared 
management 
DGs, JRC: 
support 

State-of-play May 2025 

While developing the future single integrated IT system (corporate Arachne), the current version of Arachne is being further improved to strengthen its 
capacity as an anti-fraud tool in shared management and RRF-like instruments. Throughout 2024, the Commission has continued promoting Arachne with 
Member States.  

In July-September 2024, DG AGRI organised a survey on the use and interoperability of the tool. The results of the survey and the future use of the tool for 
CAP were discussed in an expert group meeting organised in September 2024 and the discussions further continued in the framework of the certification of 
accounts expert group meeting in December 2024. 

The work of the risk indicator specifications continued in the Learning Network of the CAP Paying Agencies meeting organised by the Member States with 
the Commission participation in January and April 2025. The Commission aims to finalise the IACS requirement specification work by mid 2025. The 
Commission also provided training on the use of Arachne, with  28 trainings sessions organised for Member States where the trainings also covered AGRI 
Funds. Five of the sessions were dedicated just to CAP expenditure.  

In 2025, 35 online training sessions were addressed to authorities of the Member States concerning funds managed by EMPL, REGIO, AGRI, ECFIN, and 
MARE. One of the training sessions covered all Member States as regards CAP.  

As  regards  RRF  funds,  17  Member  States2  are  actively  using  ARACHNE  by  uploading  data  to  the  tool,  while  six  Member  States3  are  unlikely  to  use 
ARACHNE, as they intend to use alternative national systems. The Commission is in discussions with  three Member States4 regarding potential use of 
ARACHNE, while one Member State5 has an audit and control  milestone that requires the use of ARACHNE which still needs to be assessed. 

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

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Continue developing the envisaged single integrated IT system (corporate Arachne) for data 
mining  and  risk  scoring,  in  line  with  the  Interinstitutional  Agreement  and  the  RRF 
Regulation6,  with  a  view  to  extend  its  use  to  all  Member  States  and  to  all  management 
modes. 

Lead 
BUDG, DAC, EMPL: lead 
Spending DGs, OLAF, DIGIT, 
JRC: support 

Due date 
2023 and 
continuous 

State-of-play May 2025  

Following the political agreement of 7 December 2023 on the Financial Regulation recast, the integrated IT system (corporate Arachne) will apply to all 
management modes and its feeding with relevant information will become mandatory as of the post-2027 MFF programmes. Its mandatory use as proposed 
by the Commission but rejected by the Council, will be rediscussed at a later date pending an assessment by the Commission on the readiness of the tool by 
the end of 2027. In the meantime, the use of the tool will remain voluntary. 

The  transition  to  the  new  tool  is  progressing  according  to  plan.  The  intermediate  steps  established  have  been  met  reflecting  the  real  status  quo  of  the 
development of the tool. The Steering Committee formally adopted the name "Arachne+" in March 2025 to reflect the tool’s wider external use.  

In January 2025, the first meeting of the Group of Experts (tasked with designing Arachne+) , established by Commission Decision C (2024) 7889, was held. 
The aim is to foster cooperation between the Commission and Member States in developing the tool and preparing for its readiness assessment by the end of 
2027. It will continue to meet quarterly in 2025 and 2026 to contribute to the readiness assessment, focusing on risk indicators, interoperability, artificial 
intelligence, and data protection. A Best Practices Workshop on handling big data tools took place on 14 May 2025, with contributions from DG HOME, the 
EIB and the Belgian Financial Intelligence Unit. 

6 Regulation (EU) 2021/241. 

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3 

Further develop and increase use of EDES in the Commission and in Member States based on user feedback, in view of its 
possible extension to shared management, notably by: 

Lead 
BUDG 

Due date 
2023 and 
continuous 

increasing the user-friendliness of the database; 

a. 
b.  exploring possibilities for interoperability and synergies with other corporate IT tools as well as national databases; 
c.  enhancing  dialogue  on  EDES  among  Commission  departments  and  Executive  agencies,  other  EU  institutions, 

Member States and implementing partners. 

State-of-play May 2025 

The Commission has continuously stressed the importance and benefits of the Early Detection and Exclusion System (EDES) in protecting the Union budget, 
notably for the prevention and detection effects on fraud and unreliable behaviours, and for ensuring effective sanctions.  

Since its entry into force in September 2024, the new Financial Regulation makes it possible to exclude natural persons, unreliable guarantors, affiliated 
entities and/or beneficiaries of an excluded primary entity from obtaining EU funds. The Financial Regulation extended the scope of EDES to funds disbursed 
under shared management and direct management with Member States for programmes adopted or financed as from 1 January 2028. 

a. The Commission has carried out improvements to EDES Database user friendliness such as an upgrade on the unlocking of users and a full user manual.  

b. The EDES Database had been linked to SUMMA, the Commission's new corporate financial system in February 2025. A new external webservice was 
developed that will allow national databases to query the EDES database. 

c. The Commission has enhanced the dialogue and increased the level of guidance on EDES. Within the Commission, the dialogue took place notably in the 
EDES experts platform, which had two sessions in July and October 2024, and in the annual EDES workshop, organised in May in 2025. Ad hoc training 
sessions on EDES with several departments took place between June and February 2025. A revised guidelines on the use of OLAF Reports for the purpose 
of EDES for the use of Commission departments, Executive agencies and other EU institutions, has been published in December 2024. Further guidelines 
including an EDES Vademecum are in preparation. 

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Explore the possibility to strengthen the anti-fraud functionalities in SUMMA, notably by: 

a.  considering the creation of a dashboard on unusual patterns in transactions to detect potential 

irregularities and provide analysis to DGs; 

b.  considering,  after  the  SUMMA  go-live,  a  screening  of  other  databases  such  as  Arachne  and 
commercial  databases  via  the  SUMMA  Business  Partner  Integrity  Screening,  similar  to  the 
envisaged screening of EDES and the Financial Sanctions Database, and exploring if and how 
these anti-fraud functionalities could be used in the Commission and beyond; 

Lead 

Due date 

BUDG: lead 
OLAF, spending DGs: 
support 
BUDG: lead 
DAC, EMPL: support 

2025 

2025 

c.  considering additional controls of business partners (legal entities). 

BUDG 

2025 

State-of-play May 2025 

SUMMA is the Commission's new corporate financial system, which went live in January 2025.  

a.  As SUMMA started being used as of January 2025, a working group BUDG-OLAF will be set up to consider the creation of a dashboard. 

b.  The  integration  of  Arachne  and  external  databases  (such  as  Orbis)  is  in  the  exploratory  phase.  The  future  of  this  integration  largely  depends  on  the 
revamping  of  Arachne  for  the  next  MFF,  which  aims  to  expand  the  use  of  Arachne  and  external  databases  to  all  management  modes.  For  direct 
management, integration with corporate systems like E-grants, E-procurement, and/or SUMMA will be crucial. However, this corporate vision is still in 
its early stages and is currently being defined.  

c. BUDG has been monitoring corporate initiatives across the European Commission such as Natural Identity Management and Optical Character Recognition 
(OCR) initiatives to identify opportunities and quick wins for improving business partner identity verification and data encoding accuracy. These projects 
are still in their early stages. DG BUDG will continue to monitor possible options to further develop Business Partners information. 

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5 

Increase  the  user-friendliness  of  the  Irregularity  Management  System  (IMS)  for Member  States  authorities and  relevant 
Commission staff, the use of the system and therefore the completeness and accuracy of the data in the system, notably by: 

Lead 
OLAF 

Due date 
2023 and 
continuous 

a.  upgrading the system technically; 
b.  exploring the possibilities for interoperability with other Commission and national systems dedicated to protecting 

the EU’s financial interests. 

State-of-play May 2025  

IMS is the system through which Member States report on irregularities and fraud affecting the EU budget to the Commission, allowing the Commission to 
analyse for example trends and modus operandi. It has potential for greater interoperability with other corporate tools of the Commission, such as Arachne 
and EDES, and with digital tools in Member States. OLAF, which runs the IMS on behalf of the Commission, is continuosuly working on improving its user 
friendliness.   

a.  In 2024, IMS underwent two major releases, the first updating to the latest standards the underlying IT architecture and software, including some 
“look  and  feel”  changes  to  the  users’  interface;  and  the  second,  improving  the  search-function  possibilities  (distinguishing  between  simple  and 
advanced search), and increasing the attachments size. 

b.  BUDG and OLAF have initiated a review of the functioning of the interface beween EDES and IMS. In view of collecting feedback from the users 
of such interface, a survey will be addressed to its users (to be launched in June 2025) to collect their feedback and understand any potential gap that 
would beed to be addressed. Once analysed the results, BUDG and OLAF will identify if corrective measures or new developments are needed. Initial 
contacts were also established to identify how Arachne could profit from data reported via IMS.  

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Explore options to improve the efficiency and accuracy of financial and administrative monitoring of follow-up of 
OLAF cases, notably by increasing data interaction possibilities between OLAF and Commission departments and 
where appropriate monitoring of the follow-up of EPPO cases based on information received from the EPPO.  

Lead 
OLAF, SG, BUDG 

Due date 
2024 

State-of-play May 2025 

OLAF is continuously working with other Commission departments to improve the monitoring of the follow-up of OLAF recommendations. 

In the second half of 2024, the technical solution to improve the efficiency and accuracy of financial and administrative monitoring of follow-up of OLAF 
cases was made available to users. The new SharePoint based tool for tracking OLAF recommendations, the OLAF Monitoring Site, allows for centralised, 
efficient communication exclusively within the Commission and its executive agencies. It enables continuous updates on OLAF recommendations, allowing 
users to add information as soon as updates are available. The action has been completed. 

As  regards  EPPO  notifications, following the revision  of the  Annexes  I  and  III  of the  EPPO-Commission  Agreement,  new  templates  have  been  agreed 
between EPPO and Commission on the EPPO communications to the Commission (see also action 30a.)  

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Explore options to improve internal communication on cases of fraud and irregularities by: 

a.  exploring  the  possibilities  of  developing  IT  solutions  for  communication  between  OLAF,  Commission 
departments and Executive agencies along the full life cycle of a case - from communicating suspicions of fraud 
to OLAF, through selection and investigation, to follow-up and monitoring (including on information received 
from the EPPO, where appropriate) - to make such communication more regular and efficient, while respecting 
the confidentiality of investigations; 

Lead 

Due date 

OLAF: lead 
SG: support 

2025 

b.  updating Commission departments and Executive agencies bilaterally, as well as the Secretariat-General where 

OLAF 

2024 

appropriate, on the status of OLAF cases every six months in the meantime 

State-of-play May 2025 

Communication with other Commission departments and Executive agencies on OLAF investigations will be facilitated by an increased use of digital tools.  

a.  An OLAF internal study on cases-related exchanges between OLAF and other stakeholders was finalised in May 2024. Any further study and related 

development of IT solutions will depend on the outcome of ongoing discussions related to the EU anti-fraud architecture. 

b.  OLAF investigative units update bilaterally Commission departments and Executive agencies on the status of OLAF cases every six months. This sub-

action has been completed. 

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8 

Set up a working group to explore available and possible future options for strengthening digital control against plagiarism, 
also for 'external' plagiarism comparing not only documents prepared for the Commission but also other documents. 

Due date 
2024 

Lead 
OLAF: 
lead 
All DGs: 
support 

State-of-play May 2025 

The increased availability of documents and text on the Internet and the use of Artificial Intelligence (AI) lead to increased risks of plagiarism. Plagiarism 
can breach intellectual property rights, lead to double funding and pose reputational threats to the Commission. Digital solutions are thought to have the 
potential to mitigate some of the risks. 

To address it, a working group composed of 15 Commission departments and Executive agencies was established end of 2023 and met a few times times in 
2024, both in plenary and bilateral format. Beginning of 2025, the working group produced a report on plagiarism tools at the Commission, which still needs 
to be formally adopted.  

The action has been completed. 

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Develop a  matrix  of  risk  indicators  in  GETI  (Get  Intelligence  system)  to  contribute to  fraud  prevention  and  to  pro-actively 
identify  high  risk  projects  and  entities,  targeting  aspects  such  as  unusual  behaviour,  financial  information  and  contractual 
patterns. 

Lead  Due date 
OLAF  2026 

State-of-play May 2025 

GETI is an OLAF data analytical tool used for simultaneously searching in multiple data stacks of structured and unstructured data in multiple different 
languages. GETI finds information quicker and more efficiently, by bringing together data from different sources. 

Following the collection of data needed, in the last quarter of 2024, a new subset of risk indicators was created. The new indicators are linked to other datasets 
in the GETI stacks. All the risk indicators developed so far are being currently tested on an initiative to identify irregularities on projects. 

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Set up a working group to explore available and possible future options for strengthening digital control of external service 
providers and experts, notably checking that they do not claim reimbursement for the same hours from several sources. 

Due date 
2024 

Lead 
OLAF: 
lead 
All DGs: 
support 

State-of-play May 2025 

The Commission is well aware of the risks associated with the use of external service providers and experts, notably of double funding and conflict of interest. 
Digital solutions are thought to have the potential to mitigate some of the risks. 

A working group composed of 18 Commission services and executive agencies was established end of 2023. Several meetings took place throughout 2024. 
A draft report on the main issues encountered by the Commission services, available tools and potential solutions is under preparation.  

Once finalised, the document will be shared within relevant fora within the Commission. 

The action has been completed. 

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Further strengthen the Commission's IT and information security to respond quickly and effectively to evolving 
cyber-security threats, including the threat of cyber-fraud, and minimise potential impacts, notably by:  

a.  regularly revising the IT security strategy and, as applicable, the IT security plans based on comprehensive 

risk assessments that take the possibility of cyber-fraud into account; 

b.  ensuring  close  cooperation  on  information  security  between  EU  institutions  and  bodies,  notably  on 
investigations of leaks of information, on common rules and tools to securely exchange information. 

State-of-play May 2025 

Lead 

Due date 

DIGIT: lead 
strategy 
All DGs: lead 
plans 
OLAF: support 
HR: lead 
OLAF: support 

2023 and 
continuous 

2023 and 
continuous 

Cyber-security threats are constantly evolving. The Commission is committed to ensuring the safety and security of its digital assets and reputation, as well 
as maintaining the continuity of its operations.  

a.  DG DIGIT regularly monitors and reports on the cybersecurity posture of the Commission via the IT Security and Risk Report (ITSRR). The latest 
release for the 2024 ITSRR took place in March 2025. The report provides a snapshot on the Commission’s IT security risk posture, including updates 
and key developments in relation to the threat landscape, proactive and reactive cybersecurity and capability development. The actions of the IT Security 
Strategy 2023-2024 have been completed, and the 2025-2026 European Commission Corporate Cybersecurity Strategy has been developed, and adopted 
by  the  ITCB  in  January  2025.  The  strategy  is  in  line  with  the  priorities  of  the  Commission,  the  evolution  of  the  threat  landscape,  the  IT  technical 
developments and the evolution of the compliance and incident management processes. The 2025-2026 Corporate Cybersecurity Strategy incorporates 
the provisions of the Cybersecurity Regulation (2023/2841) entered into force in January 2024.  

b.  HR.DS continues to equip the Commission with the necessary tools that allow to respond effectively to the dramatic development of the threat landscape 
and to secure the institution assets. HR.DS has continued to defend its proposal for an InfoSec regulation in the Council Security Committee, aiming to 
creating a common standard of security for the information handled by all Union entities. Similarly, HR.DS has supported the decentralised agencies in 
enhancing the protection of their information by providing the appropriate IT tools (Zeus certificates, RUE-X, RTOP, SUE). 

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12  Encourage  Member  States,  notably  through  available  funding  programmes,  to  digitalise  as  appropriate  fraud 
prevention, detection and investigation by supporting the development and use of IT tools for data collection and 
analysis using advanced data mining, machine learning technologies and forensics, as well as the exploration of 
emerging technologies such as artificial intelligence, block chain technology and biometrics.  

Lead 
All DGs providing 
such funding 

Due date 
2023 and 
continuous 

State-of-play May 2025 

In its 2023 PIF Report of July 2024, the Commission recommended Member States to accelerate the digitalisation of the fight against fraud. To support 
Member States in the digitalisation of their anti-fraud efforts, the Commission undertook several actions.  

The Union Anti-Fraud programme (UAFP) calls for proposals for 2024 have been evaluated, and five projects (out of 21 awarded) received financing for 
data analytics technologies and tools. OLAF included in the 2025 Work programme for the funding opportunities for Member States authorities for the 
development and use of IT tools for data collection and analysis using advanced technologies. The UAFP Calls for proposals for 2025 were published in 
February 2025. OLAF intends to reinforce the digitalisation aspects in the future UAFP, in the framework of the new MFF (2028-2034).  

SG REFORM supports digitalisation-related projects under its Technical Support Instrument (TSI). In its TSI 2026 programming (January 2025-October 
2025) SG REFORM encourages reform projects requests on how IT tools and technologies like Large Language Models can enhance Anti-corruption and 
Anti-fraud bodies capacity to use predictive analytics to detect anomalies and potential fraud when relevant to the TSI 2026 flagship on “Technical support 
for the implementation of country-specific recommendations”. 

13 

 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds  

Nr  Action 
13 

Further improve the prevention and detection of fraud to the RRF, notably by: 

a.  developing risk indicators on fraud, corruption, conflict of interest and double funding, for the purposes of 
auditing and identifying potential cases to be transmitted to OLAF for possible investigation or transmission 
to the EPPO; 

b.  carrying  out  system  audits  on  the  protection  of  the  EU's  financial  interests  focusing  on  high-risk  areas 

identified in risk assessments; 

c.  continuing anti-fraud awareness raising and training; 
d.  encouraging Member States to make use of IMS to report irregularities related to the RRF in line  with an 

ECA recommendation. 

State-of-play May 2025 

Lead 
ECFIN: lead 
OLAF: support 

Due date 
2023 and 
continuous 

With the large amounts involved in the RRF, the Commission is closely monitoring and taking action to address risks and instances of fraud, corruption, 
double funding and conflict of interest.  

a.  Discussions between OLAF and DG ECFIN on risk indicators took place in the second half of 2023 and in 2024. OLAF completed an evaluation of RRF 

data for anti-fraud purposes and shared it with DG ECFIN in April 2024.  

b.  DG ECFIN has carried out audits on the protection of EU’s financial interests in all Member States. Targeted audits on the protection of EU’s financial 
interests are conducted where particular needs have been identified, such as for specific topics, measures, regions or authorities. In order to ensure that 
risks are adequately monitored and addressed throughout the life of RRF, ECFIN undertakes further audit work based on the risk assesment updated in 
February 2025. 

c.  The Technical Working Meeting with National Audit Bodies on the Recovery and Resilience Facility (RRF) was held in Brussels on 21-22 November 
2024, and presented and discussed in the plenary session the topic of "Protecting the EU budget: prevention and detection of irregularities and fraud in 
the context of public procurement”, and during the focus groups sessions the topics of “Prevention and detection of conflict of interest: best practices and 
use of data mining tools”, and “Auditing fraud: audit techniques and approach”. 

d.  Specifically concerning the use of IMS (which is not mandatory under the RRF Regulation), the Member States’ audit authorities for RRF have been 

made aware of the advantages of using IMS for reporting irregularities during the 2024 bilateral meetings organised by DG ECFIN. 

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Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds  

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Encourage Member States to put in place effective and proportionate anti-fraud measures, such as strategies 
at  national,  plan,  programme  or  authority  level  and,  as  applicable,  provide  guidance  and  support  in  this 
respect. 

Lead 
ECFIN, shared 
management DGs 
and OLAF  

Due date 
2023 and 
continuous 

State-of-play May 2025 

The Member States are responsible for putting in place effective and proportionate anti-fraud measures to protect the financial interests of the Union. An 
appropriate framework for developing such measures are national anti-fraud strategies (NAFS), and the Commission, European Parliament and European 
Court of Auditors have therefore actively encouraged Member States to adopt such strategies. 

DG REGIO, with the cooperation of the European Institute of Public Administration, delivered a presentation to national authorities on the importance of 
having National Anti-Fraud Strategies (NAFS) in place. The presentation was part of the training sessions on Cohesion Policy for EU Member State Experts 
“Identifying and preventing fraud and corruption in Structural and Cohesion Funds 2021-2027”. Each training session (June 2024, October 2024 and March 
2025) was attended by approximately 30 participants.  

DG MARE encouraged Member State authorities to consider putting in place NAFS whenever Key Requirement 77 was within the scope of audit missions. 
Between July 2024 and May 2025, four such audits have been carried out, which brought the total Member States covered to 17. A related question in the 
checklist for Key Requirement 7 audit assignments under the European Maritime, Fisheries and Aquaculture Fund will be included by the end of 2025. 

DG ECFIN encourages the adoption of NAFS in the context of its RRF audits on the protection of EU’s financial interests, notably by adding the adoption 
of such strategies as a milestone where appropriate.  

7 Key requirement 7: Effective implementation of proportionate anti-fraud measures. 

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Action 
Provide,  as  relevant,  regular  training,  awareness  raising  and  exchanges  of  best  practice  examples  with 
Member State authorities, either dedicated to or including as an important element anti-fraud matters, such 
as prevention, detection and handling of irregularities, as well as reporting in the IMS. 

Lead 
ECFIN, shared 
management 
DGs and OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2025 

The Commission provided the Member States authorities with anti-fraud training, awareness raising and exchanges of best practices in several fora in 2024. 

The  Shared  Management  DGs  (REGIO,  EMPL,  MARE  and  AGRI)  continued  to  provide  training  and  raise  awareness  of  anti-fraud  matters,  as  well  as 
exchanging best practice, in various instances and fora. These included meetings with Audit Authorities, anti-fraud seminars and conferences for Paying 
Agency representatives, and dedicated training sessions for programme authorities. Notably, 28 Annual Coordination meetings with the Audit Authorities 
(ACMs) included an OLAF presentation on the detected and reported fraud irregularities by cohesion policy investment area.  

DG REGIO, with the cooperation of the European Institute of Public Administration, delivered regular training sessions on Cohesion Policy for EU Member 
State Experts titled “Identifying and preventing fraud and corruption in Structural and Cohesion Funds 2021-2027”. Modules and workshops on prevention, 
detection  and  handling  of  irregularities  were  included  (for  example  “Introduction  to  identifying  and  preventing  fraud;  fraud  indicators”,  “Workshop  on 
innovative methods to combat fraud”, “Models for assessing risk of fraud”, Specific challenges in preventing fraud”, etc.). Each training session (June 2024, 
October 2024 and March 2025) was attended by approximately 30 participants. A presentation on Conflict of Interest was delivered to audit authorities in 
December 2024. OLAF delivered a presentation on “Protecting the EU budget: challenges and developments” at the homologues meeting with all Member 
States audit authorities, in October 2024. 

DG AGRI delivered three seminars on anti-fraud topics in 2024, while antifraud issues were included in both Presidency conferences organised in 2024 
(Belgium and Hungary). 

For the RRF, DG ECFIN raised such topics in the annual technical meeting with national audit authorities in November 2024, bilateral meetings with national 
authorities, as well as in the COCOLAF meeting in December 2024. 

16 

 
 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds  

Nr  Action 
16 

Promote sharing of best practice and provide guidance for Member States on preventing, 
detecting, handling and reporting conflict of interest situations. 

Lead 
BUDG: lead 
ECFIN, shared management DGs: 
support 

Due date 
2024 and 
continuous 

State-of-play May 2025 

Member States have the obligation, when implementing the EU budget in shared management, to take the necessary measures to avoid conflicts of interest. 
The Commission has stepped up its efforts to provide guidance and allow the Member States to share their experiences with each other. 

DG BUDG has set up a Commission internal working group with shared management DGs to identify best practices and prepare a guidance for Member 
States on preventing, detecting, handling and reporting conflict of interest situations. A consolidated document on best practices has been drafted and it was 
disseminated to relevant Member States authorities in May 2025. The best practices guidance was presented to the Advisory Committee for the Coordination 
of Fraud Prevention (COCOLAF) on 15 May 2025 and was published on BUDGPedia.  

DG ECFIN invites Member States to share best practices on conflict of interest situations in annual Technical Working Meeting for national audit bodies. In 
2024,  a  dedicated  focus  group  on  conflict  of  interest prevention  and  detection  was  organised  during  the  annual  Technical  Working  Meeting  with  audit 
authorities. 

17 

 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds  

Nr  Action 
17 

Promote  and  support  the  use  of  IMS  by  Commission  auditors  for  fraud  risk  assessment  purposes,  notably  by  providing 
training. 

Lead 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2025 

OLAF  continuously  strives  to  make  IMS  accessible  to  relevant  Commission staff.  IMS  can  for  example  support  auditors  with their risk analysis in  the 
planning of an audit. 

In April 2024, OLAF collected the training needs on IMS for 2024 and consulted Commission departments on possible specific needs. Services indicated 
that enough auditors have been trained at this time and that they will indicate when further training is required. In 2024, all IMS resources were allocated to 
the refactoring of IMS (see action 5).  

OLAF will continue supporting the use of IMS by Commission auditors notably by providing training in line with the needs expressed by the Commission 
departments. 

18 

 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds  

Nr  Action 
18  Verify, as relevant, that the work done by audit authorities and certification bodies includes checking on the existence of 
adequate procedures for timely and accurate reporting of detected irregularities, their handling, follow-up and transmission 
of  information  to  the  competent  investigative  bodies.  This  might  include  cases  where  the  irregular  expenditure  is 
withdrawn from EU funding or, in the case of the RRF, corrected and recovered from the final recipients.  

Lead 
ECFIN, 
shared 
management 
DGs 

Due date 
2023 and 
continuous 

State-of-play May 2025 

To ensure that the EU’s financial interests are protected, it is important that Member States have procedures in place for following up on detected fraud and 
irregularities. Audit authorities and certification bodies play an important role in verifying that this is the case. 

For the RRF, DG ECFIN reviewed management declarations and audit reports received with payment requests, and issued recommendations following audits 
on the protection of EU’s financial interests. The work done on audits on the protection of EU’s financial interests and the follow-up of reported irregularities 
were discussed during annual bilateral meetings with Member States’ audit bodies.  

In the area of Cohesion Policy, the Joint Audit Directorate of DG REGIO and DG EMPL has reinforced its audit work to obtain reasonable assurance that 
the Management and Control Systems (MCS) established and implemented by Member States function effectively to prevent, detect, correct and report errors 
and irregularities. In this respect, actions taken include sharing thematic anti-fraud checklists for 2021-2027 with Audit Authorities, reviewing  approaches 
for compliance audits and carrying out early verifications of the completeness and adequacy of the methodological tools, checklists, and procedures used by 
the Audit Authorities.    

DG MARE has updated Key Requirement 7 checklist to include the aspect of adequate reporting procedures not only for fraud, but also for non-fraudulent 
irregularities and the reporting in IMS in cases where the financial impact on the EU budget exceeds €10.000. The updated checklist was used throughout 
the audits whenever Key Requirement 7 (anti-fraud measures at Member State level) was in the scope of the audit mission. By May 2025, 17 such audit 
missions took place. 

19 

 
 
 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds  

Nr  Action 
19 

Support Member State authorities to improve the quantity and quality of irregularity reporting to 
the Commission via the IMS, notably by: 

Lead 

Due date 

a.  developing and updating guidance on reporting, for example, the IMS handbook, including 

on issues related to conflicts of interest; 

OLAF: lead 
Shared management DGs: support 

2024 

b.  reminding  Member  State  authorities  in  the  communication  on  the  outcome  of  a 
Commission  audit  or  an  investigation  on  the  obligation  to  report  in  IMS  irregularities 
above the threshold, also when identified during a Commission audit or an investigation, 
and  to  confirm  explicitly  their  reporting  of  those  irregularities  to  allow  for  their  exact 
identification. 

State-of-play May 2025 

Shared management DGs: lead 
OLAF: support 

2023 and 
continuous 

For the EU to have a complete and correct picture of the irregularities and fraud against EU funding, the Member States need to report them in IMS. To 
support the Member States, OLAF issues guidance on reporting.  

a.  The working group comprising Member State experts, which was set up by OLAF in spring 2024 to revise the 2017 Handbook on the reporting of 
irregularities, continued its work, meeting at regular intervals to discuss the issues at stake. The final draft of the revised Handbook was sent to all Member 
States in mid-May 2025, and its formal adoption is expected to follow. The revised Handbook includes guidance on the reporting of irregularities relating  
to conflicts of interest.  This sub-action will be completed with the adoption of the revised Handook, expected by Q3 2025. 

b.  The Shared Management DGs continue to remind Member State authorities in the communication on the outcome of their audits of  the obligation to 

report irregularities in IMS.  

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Nr  Action 
20  Develop a joint ethics and anti-fraud training plan with the EEAS, to ensure that specialised training is delivered 

consistently for targeted groups of staff notably in the Representations, Delegations and Missions. 

Lead 
External action DGs: 
lead 
OLAF, HR: support 

Due date 
2024 

State-of-play May 2025 

Staff  working  in  the  EU  Representations,  Delegations  and  Missions  need  appropriate  ethics  and  anti-fraud  training  to  develop  sound  knowledge  of  the 
Commission’s ethics and anti-fraud frameworks. 

Following a mapping of existing training on ethics and anti-fraud topics (cf. action 40 of the action plan), the Commission established a draft proposal for a 
joint ethics and anti-fraud training plan in March 2024. A dedicated working group was set-up by DG INTPA and the first meeting took place in April 2024 
to discuss and agree upon a joint ethics and anti-fraud training plan (learning path) to guide staff in EU Delegations (both Commission and EEAS) and at 
Headquarters on their choices in terms of ethics and anti-fraud training courses.  

The end goal was to offer a training package rather than standalone training offers by designing a joint anti-fraud and ethics learning path consisting of three 
interconnected modules. The learning path has been prepared and is available in the EU Learn. A joint note from DG INTPA and OLAF was sent out on 20 
May 2025 to raise the awereness of colleagues and encourage them to participate in the training sessions.  

In addition, OLAF is invited to and takes part in joint training sessions organised by DG INTPA and delivered with support from DG FPI, DG MENA and 
DG ENEST (four times a year). 

The action has been completed. 

21 

 
 
 
 
 
 
 
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Nr  Action 
21  Raise awareness of pillar-assessed partners in the field of external action on their obligation to notify the 

Lead 

Commission of cases of detected irregularities, fraud and exclusion situations, notably by: 

a.  providing the partners with guidance on the information to be shared with the Commission when 

notifying cases; 

b. 

inviting OLAF to participate in relevant meetings with major recipients of EU funding. 

INTPA: lead 
External action DGs, OLAF, 
BUDG: support 
External action DGs: lead 
OLAF: support 

Due date 

2024 

2023 and 
continuous 

State-of-play May 2025 

The  Commission  may  delegate  the  implementation  of  EU-funded  projects  to  partner  organisations  in  indirect  management.  To  ensure  that  the  partner 
organisation’s internal rules and procedures guarantee a high level of protection of EU funds, the organisation must pass a pillar assessment. Pillar-assessed 
partners have an obligation to notify the Commission of cases of detected irregularities, fraud and exclusion situations. 

a.  DG INTPA and OLAF continued to engage in discussions with pillar-assessed entities to raise awareness on their obligation to notify the Commission 
of  cases  of  irregularities,  fraud  and  exclusion.  Specifically,  they  have  highlighted  the  obligation  enshrined  in  Article  158(7)  of  the  new  Financial 
Regulation (Recast) which requires implementing entities to notify the Commission without delay of cases of established fraud and irregularities  and 
their follow-up, as well as any information relating to suspected cases of fraud, corruption or any other illegal activity affecting the financial interests of 
the Union. DG INTPA is working on including necessary clarifications and explantions in the existing guidance for the pillar-assessed entities. The work 
should be finalised by the end of 2025. 

b.  OLAF is being invited to the meetings with pillar-assessed entities to clarify reporting obligations. OLAF was invited to the 19th EU-UN FAFA Working 
Group on 13-14 June 2024 and to the meeting with the OECD on 17 March 2025 regarding the obligation for implementing partners to notify “suspected 
fraud” as per Article 158(7) of the Financial Regulation (recast).  

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22 

Action 
Develop common lines of action with the EEAS to reduce the risks associated with local agents who remain 
in the same post for a long period of time in the Delegations. 

Lead 
External action 
DGs: lead 
OLAF, HR: support 

Due date 
2024 

State-of-play May 2025 

This action aims at tackling risks associated with local agents who remain in the same post for a long period of time in the EU Delegations. 

A Commission working group was set up by DG INTPA (lead service) to prepare common lines of action including preventive and corrective actions. By 
the end of 2024, the discussions in the working group led to the development of a set of common lines of action, also with the EEAS, in the form of an action 
plan. The common note from DG INTPA and OLAF encouraging DGs to implement the action plan was sent out to respective Comission services and EEAS 
on 20 May 2025. 

The Action Plan comprises five activities: (i) ethics training, (ii) promotion of the available trainings on ethics and fraud prevention via anti-fraud networks 
on a regular basis and for all staff members, (iii) integration of risk assessment of staff mobility during supervision missions (Commission) and inspection 
missions (EEAS), (iv) examination of possibility to enlarge the number of fixed-term contracts in Delegations for Local Agents, in the framework of the 
upcoming  review  of  the  decision  covering  Local  Agents  working  arrangements  and  (v)  ethics  guidance  for  all  staff  in  Delegations  to  avoid  overlaps, 
contradictions and bureaucracy with the aim to consolidate existing training offer for staff members. 

The action has been completed. 

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Nr  Action 
23 

Improve the use of IMS in candidate countries, notably by: 

a.  developing guidance on irregularity reporting in IMS; 

b.  providing training to relevant national authorities; 

c.  raising awareness among relevant authorities on the need to report  irregularities in IMS in a complete and 

correct manner. 

State-of-play May 2025 

Lead 

Due date 

OLAF: lead 
NEAR: support 
OLAF: lead 
NEAR: support 
NEAR, OLAF 

2024 

2023 and 
continuous 
2024 and 
continuous 

Under indirect management, the countries benefitting from pre-accession assistance (IPA) must report irregularities and fraud to the Commission, and keep 
the Commission informed about the progress of administrative and legal proceedings in relation to such irregularities. Such reporting is to be done through 
IMS. To ensure correct reporting, the Commission provides guidance and training to the candidate countries. 

a.  DG NEAR cosigned a joint letter with OLAF and DG AGRI and contributed to the “Guidance on the reporting of irregularities by beneficiary 

countries of pre-accession assistance in indirect management” published in November 2024. The note and Guidance were disseminated through 
OLAF contact points in each IPA EU delegations. The sub-action has been completed. 

b.  DG NEAR participated actively to the 2024 AFCOS Conference on 15-16 October organised by OLAF for candidate and potential candidate 

countries. OLAF provided a Workshop on irregularities reporting in IMS to a Serbian delegation. 

c.  DG ENEST8 assigned Irregularity Officers in the EU Delegations in order to liaise with the national authorities and follow up on the irregularities 

reporting. National authoritities continue to report quarterly on follow-up of irregularities to DG ENEST as requested. 

8 As of 1 February 2025, DG NEAR was restructured into DG MENA (Middle East, North Africa, Gulf) and DG ENEST (Enlargement and Eastern Neighbourhood). 

24 

 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area 

Nr  Action 
24  Develop guidance and exchange of best practice on addressing the risks to spending in emergency situations 

(follow-up to 2019 CAFS action 29), focusing on conflict of interest. 

Lead 
ECHO, FPI, HOME: lead 
OLAF, BUDG: support 

Due date 
2024 

State-of-play May 2025 

The previous CAFS action plan of 2019 identified emergency spending as particularly vulnerable to fraud. Implementing the previous CAFS action related to 
emergency spending, a risk analysis was conducted. It identified conflict of interest as one of the main risks in this type of spending.  

The Commission therefore set up a working group on the risks to spending in emergency situations with focus on conflict of interest. The guidance and best 
practice document was finalised by the working group and adopted in April 2025, covering broader scope of conflict of interest situations.  

The action has been completed. 

25 

 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area 

Nr  Action 
25  Cooperate with Ukraine authorities, international donors and their anti-fraud services to protect EU funding from fraud and 

Lead 
OLAF  

corruption, notably by: 

a.  strengthening national anti-fraud structures through capacity building, in particular by: 

i. 
ii. 

providing targeted anti-fraud support to national authorities, e.g. through training and exchange of expertise; 
supporting accession to the Union Anti-Fraud Programme; 

b.  collaborating on possible cases affecting the EU’s financial interests, including through exchange of information. 

Due date 
2023 and 
continuous  

State-of-play May 2025 

The EU is spending large sums of money to support Ukraine in meeting present and future challenges. All players involved must do their utmost to ensure 
that the funds reach their intended recipients. 

Throughout 2024, OLAF continued its engagement to protect the EU’s financial interest with regard to funding to support Ukraine, in particular: 

a. To strengthen national anti-fraud structures through capacity building:  

i. OLAF delivered a dedicated anti-fraud training to relevant Ukrainian authorities in February 2024. In addition, individual Ukrainian authorities 
participated in OLAF conferences and training events to exchange expertise and good practices, such as the joint conference of the national Anti-
Fraud Coordination Services (AFCOS) from the EU Member States and their counterparts in candidate countries and potential candidate in October 
2024 in Brussels. 

ii.  The  negotiation  and  adoption  process  for  Ukraine’s association to  the  Union  Anti-Fraud  Programme  was  successfully  finalised in  2024.  The 
association agreement was formally signed in March 2024 by both parties and it is now in force. 

b. OLAF investigative units continued their cooperation with Ukrainian authorities for cases of fraud or irregularity allegations. OLAF also increased the 
dialogue with relevant counterparts, such as Ukrainian civil society organisations and the EU Delegation in Kyiv, to raise awareness about reporting fraud 
allegations to OLAF. Discussions have been launched in relation to the setting up of workflow for the reporting of irregularities via IMS. 

26 

 
 
 
 
 
 
 
 
Reinforce the EU's capacity to fight customs fraud and protect EU revenues 

Nr  Action 
26 

Strengthen the Commission’s and Member States’ analytical capacities in the customs anti-fraud area by 
developing  data  analysis  tools  and  increasing  exchange  of  and  access  to  relevant  data  for  anti-fraud 
purposes, to improve the prevention and detection of customs fraud. 

Lead 
OLAF, JRC, 
TAXUD, BUDG: 
lead 

Due date 
2023 and 
continuous 

State-of-play May 2025 

Analytical tools and data sharing play an important role in boosting the EU's capacity to effectively tackle customs fraud.  

The Anti-Fraud Information  System (AFIS)  analytical platform (FraudAP) is fully operational. Between June 2024-May 2025, various applications and 
intelligence reports were produced using the FraudAP. On 10 April 2025, online training was provided to Member States customs authorities. The release of 
the bulk import upload mechanism of the Customs Information System (CIS) took place on 30 April 2025. The development of the B2B interface between 
the CIS and Member State national systems is on-going. 

JRC  is  actively  contributing  to  strengthening  the  Commission's  and  Member  States'  analytical  capacities  in  the  customs  anti-fraud  area  through  its 
involvement  in  the  Customs  Anti-Fraud  Enabling  Technologies  2024-2027  (CAFET-2)  project,  funded  by  OLAF.  Currently,  JRC  is  working  on  the 
development of alternative market indexes to support customs anti-fraud activities, leveraging alternative and disaggregated data sources. This effort aims to 
enhance the prevention and detection of customs fraud by providing more accurate and reliable data analysis tools. 

27 

 
 
 
 
 
 
Reinforce the EU's capacity to fight customs fraud and protect EU revenues 

Nr  Action 
27 

Ensure effective complementarity between customs risk management and anti-fraud activities, notably 
by: 

Lead 
TAXUD: lead 
OLAF, BUDG: support 

Due date 
2024 

a.  strengthening data sharing in the Customs Risk Management System; 
b.  developing and better defining risk indicators related to anti-dumping and undervaluation in the 

new Financial Risk Criteria Decision; 

c.  developing new common risk criteria for intellectual property rights at import. 

State-of-play May 2025 

Data analysis is an increasingly important component of both customs risk management and customs anti-fraud activities. Access to the right data for risk 
management and anti-fraud purposes is essential. DG TAXUD is working on a number of initiatives to improve the access to relevant data for these purposes. 

a.  On 26 March 2025, the Customs Risk Management System was further improved by the deployment of new features for lists of data and system-to-

system. This sub-action has been completed. 

b.  On 4 April 2024, the Commission adopted an implementing decision Decision C(2024)1998 for the revision of the financial risk framework to better 

protect the financial interests of the Member states and the Commission. This sub-action has been completed. 

c.  Common risk criteria and standards  will be proposed to Member States by the end of 2025. The implementation date has been postponed to 31 
December 2025. The Commission established a Subgroup of the Customs Expert Group on Customs Controls and Risk Management to develop, 
with volunteering MS, Common Risk Criteria (CRC) for IPR. The Subgroup prepared a draft legal text (Commission Implementing Decision and 
the relevant Annexes) and envisaged CRC are now being tested, to assess their efficiency and effectiveness, by means of pilot actions (a first pilot 
was performed in 2024, the second is running at the moment). 

28 

 
 
 
 
 
 
 
 
Reinforce the EU's capacity to fight customs fraud and protect EU revenues 

Nr 
28  

Action 
Define an anti-fraud strategy for new own resources and identify and implement mitigating measures on fraud risks 
concerning  the  Carbon  Border  Adjustment  Mechanism,  the  EU  Emissions  Trading  System  and  other  new  own 
resources. 

Lead 
OLAF, 
BUDG, 
TAXUD, 
CLIMA 

Due date 
Within two 
years of 
adoption 

State-of-play May 2025 

The Commission presented in June 2023 an adjusted proposal for a next generation of own resources that covered the Carbon Border Adjustment Mechanism 
(CBAM) and an extension of the Emission Trading System (ETS). 

During 2024, pending a decision over the future status of CBAM as Own Resource, progress was made toward the rollout of a CBAM Risk Management 
Framework  and  the  preparation  of  the  Anti-Circumvention  Strategy.  A  Risk  Management  Network  was  established,  engaging  both  national  competent 
authorities  and  national  customs  authorities  to  facilitate  joint  efforts.  Additionally,  the  foundation  was  laid  for  CBAM  risk  management  data  analytics 
capabilities, including the design and specification of IT tools needed to enable risk profiling and circumvention detection. These initiatives form part of a 
structured, forward-looking approach to reinforce the integrity and operational effectiveness of CBAM.  

Furthermore, analytical efforts started on the broader review of CBAM, together with the drafting of a related legislative proposal expected in the last quarter 
of 2025.  

For ETS, see action 29. 

29 

 
 
 
 
 
 
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Nr 
29 

Action 
Minimise the potential fraud risks associated with the EU Emissions Trading System (ETS), notably by: 

Lead 

implementing and enhancing security measures; 

a. 
b.  exploring  alternative  operating  models  for  the  ETS  Union  Registry,  and  conducting  an  in-depth 
feasibility assessment and cost–benefit analysis to inform the decision on a potentially new operating 
model. 

CLIMA 
CLIMA: lead 
SG, BUDG, DIGIT,  
TAXUD: support 

Due date 

2023 and 
continuous 
2024 

State-of-play May 2025 

The EU Emissions Trading System (ETS) is the world's first major carbon market and remains the biggest one.  With a market value of around EUR 770 
billion and a revenue of more than EUR 7 billion generated for the EU in 2023, it is vulnerable to cyberfraud. The Commission is therefore enhancing its 
security measures. 

a.  The Commission stepped up the implementation of the ETS IT security plan. 75%9% of the security measures in Union Registry and 80% of the additional 

security measures following the 2022 risk assessment were implemented at the end of 2024. 

b.  During 2024, the interservice group led by DG CLIMA, comprising SG, DG BUDG, DIGIT, DG FISMA and DG TAXUD presented the results of an 
in-depth  cost  and  risk reduction  analysis  to the  Corporate  Management  Board.  The  analysis recommended an  external operating model.  During the 
remainder of 2024, DG CLIMA explored different options for financing such a model with various stakeholders inside the Commission but also with 
external stakeholders such as the Climate Change Expert Group and the European Climate Policy Group. This sub-action has been completed. Now the 
effort shifted towards finding the financing model of a new operating model. 

9 During the revison some measures were closed and the new added, therefore the score is lower than in the previous implementation report  

30 

 
 
 
 
 
 
 
 
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Nr  Action 
30 

Ensure  effective  cooperation  between  the  Commission  and  the  European  Public 
Prosecutor’s Office (EPPO), notably by: 

Lead 

a.  providing guidance to Commission departments and Executive agencies; 

Central services as appropriate  

b.  establishing Commission wide cooperation on EDES and on the application of the 

BUDG 

Conditionality Regulation; 

c.  assessing potential compliance issues with the Member States’ transposition and 

implementation of the PIF Directive. 

State-of-play May 2025 

JUST: lead 
OLAF: support 

Due date 

2024 and 
continuous 
2023 and 
continuous 
2023 and 
continuous 

The Commission and the EPPO have a shared interest in fostering an effective and cooperative relationship for the purpose of protecting  EU’s financial 
interests.  

There are regular contacts between the EPPO, the central services of the Commission and different Commission departments.  

a.  Following the revision of the Annexes of the Commission-EPPO Agreement (November 2024), the register of EPPO contact persons and functional 
mailboxes  within  the  DG’s  of  the  Commission  was  updated.  The  revised  internal  workflows  table  has  been  communicated  to  the  DGs  along  with 
guidelines regarding the Ares registration process for each type of notification received. EPPO informed OLAF that they will soon be ready to start the 
deployment of the EPPO Box10 in the DGs. OLAF will continue providing guidance to Commission departments and Executive agencies. 

b.  DG BUDG’s participation in the Commission-EPPO Working Group regarding early notification of issues that might be relevant for the application of 
the Early Detection and Exclusion System was concluded with the adoption of the amendment of the annexes of the Commission – EPPO Agreement. 
The analysis of information provided by EPPO to the Commission in the context of the preparation of the 2025 Rule of Law Report is ongoing, considering 
its potential relevance for the conditionality mechanism. 

c.  The Commission sent Letters of Formal Notice to 19 Member States for non-compliance of national legislation with the PIF Directive. Nine cases have 

been closed and further closures are expected in the next cycles. Seven cases remain open. 

10 EPPO Box: a secured database, associated with email notifications to a functional mailbox in the respective Directorate-General or Service whenever the database includes a new document for their attention. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture 

Nr  Action 
31 

Strengthen the support to Decentralised agencies and Joint Undertakings11 in their effort to fight fraud, notably 
in establishing a coherent anti-fraud framework across agencies by: 

a.  providing training on ethics and anti-fraud matters; 

b.  providing methodology and advice on anti-fraud strategies; 
c.  sharing knowledge, allowing the agencies to publish relevant information on the inter-agency website; 
d.  regularly  participating  in  relevant  meetings  of  the  EU  Agencies  Network  to  inform  on  anti-fraud 

matters. 

State-of-play May 2025 

Lead 

Due date 

OLAF: lead 
HR: support 
OLAF 
OLAF 

2023 and continuous 

2023 and continuous 
2023 and continuous 

OLAF 

2023 and continuous 

The  EU  Decentralised  agencies  and  Joint  Undertakings  are  autonomous  bodies  with  own  legal  personality,  established  by  a  founding  regulation.  They 
contribute to the implementation of various EU policies, sometimes with an important budget. While they have different governance structures, mandates 
and tasks, they are all bound to follow financial rules similar to those of the European institutions and to prevent fraud and irregularities. 

a.  Throughout 2024 and in the first quarter of 2025, upon request, OLAF delivered 11 tailored-made training courses and presentations on ethics and 

anti-fraud matters to the Decentralised agencies and Joint Undertakings and their cooperation networks dealing with anti-fraud matters.  

b.  In May 2024, OLAF finalised a dedicated methodology and guidance for anti-fraud strategies in Decentralised agencies and Joint Undertakings. The 
methodology was sent to decentralised agencies and joint undertakings in June 2024 and was consistently used by agencies since then during the 
drafting or updating of their anti-fraud strategies. 

c.  OLAF continues providing advice on anti-fraud matters to the Decentralised agencies and Joint Undertakings, and to share relevant material to be 

published on the inter-agency website and/or on local websites of agencies. 

d.  OLAF  presented  in  2024 the  methodology  for  anti-fraud  strategies  in  Decentralised agencies  and  Joint  Undertakings to the  Inter-Agency  Legal 
Officers Network (IALN) and to the Performance Development Network (PDN), as well as to the AuditNet group (IAS auditors and internal auditors 
of the agencies). OLAF regularly participates in relevant meetings of the EU Agencies Network working groups related to anti-fraud. 

11 Bodies set up under the Treaty on the Functioning of the European Union and Euratom Treaty and referred to in Articles 70 and 71 of Regulation (EU, Euratom) 2018/1046. 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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32 

Protect and empower investigative journalists as an important source of information on suspected fraud, 
notably by ensuring that appropriate EU legislation is in place including on SLAPP (strategic lawsuit 
against public participation) and on media freedom (European Media Freedom Act), and that Member 
States take appropriate measures to put in practice the Commission Recommendation on SLAPP and 
that on the safety of journalists, while funding projects in support of investigative journalism. 

State-of-play May 2025 

Lead 
CNECT, 
JUST 

Due date 
2023 and continuous 

The  EU  has  adopted a  comprehensive  package to  protect  persons  who  engage in  public  participation  against  abusive  court  proceedings,  also  known  as 
‘Strategic Lawsuits against Public Participation’ (SLAPP). The initiative is a combination of legislation by way of Directive (EU) 2024/1069 on protecting 
persons who engage in public participation from manifestly unfounded claims or abusive court proceedings, and a non-legislative measure in the form of a 
Recommendation (C/2022/2428).  

The Directive entered into force on 6 May 2024. Member States are expected to transpose it into their national law by 7 May 2026 and the Commission is 
closely monitoring and assisting them in the transposition process to guarantee effective implementation. The Recommendation, which has been applicable 
since its adoption on 27 April 2022, encourages Member States to ensure that national legal frameworks provide the necessary safeguards to address domestic 
cases of SLAPPs. The Recommendation also focusses on training, awareness raising, support and monitoring. Measures to follow-up on the implementation 
of the Recommendation started immediately after its adoption and the Commission is working with all Member States to this end. 

Investigative journalists are an important source of information on suspected fraud. The European Parliament has repeatedly requested their protection.  

The Commission has cooperated with Member States to make sure that they are ready to implement the European Media Freedom Act (EMFA). Further to a 
preparatory meeting in December 2024 to discuss the provisions of the Regulation where Member States have a role to play, a questionnaire was sent to all 
Member States in January 2025 and readiness checks run with each Member State between January and April 2025. An analysis of the state of Member 
States’ preparedness was planned by May 2025. 

The Commission has continued its monitoring of the actions taken by Member States to put the Recommendation on the safety of journalists in practice. The 
Commission has also participated in the Council of Europe’s campaign on protection of journalists.   

The financial support to media sectors of special relevance to democracy (including investigative journalism) under the cross-sectoral strand of Creative 
Europe since 2023 continues with €13.9 million awarded so far. 

33 

 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture 

Nr  Action 
33 

Enhance the involvement of civil society in the Commission’s anti-fraud efforts, notably by exploring the possibility to 
work with civil society organisations to increase whistleblowing and reporting of suspicions of fraud. 

Lead 
OLAF, DGs as 
appropriate 

Due date 
2024 

State-of-play May 2025 

Civil society plays an important role in the fight against fraud and corruption in many Member States and at the EU level, emphasised notably by the European 
Parliament.  

In November 2024, OLAF trained more than 30 attendants from several Ukrainian civil society organisations to raise their fraud awareness and facilitate 
reporting of suspected fraud and irregularities. 

In January 2025, OLAF and JUST explored ways to strengthen the involvement of civil society in the Commission’s anti-fraud efforts. Notably, OLAF 
checked  whether  national  strategies  on  anti-fraud  contain  actions  on  whistleblowing  and  shared  the  information  with  DG  JUST.  OLAF  includes 
whistleblowing in internal Commission training sessions and will further reinforce this element in training to Member States authorities.  

The action is completed. OLAF is considering additional streams of work to continue involving civil society. 

34 

 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
34  Maintain a high level of coordination and cooperation on anti-fraud matters between Commission departments and Executive 

Lead 
OLAF 

agencies through the Fraud Prevention and Detection Network (FPDNet) and its subgroups.  

Due date 
2023 and 
continuous 

State-of-play May 2025 

OLAF Correspondents and other anti-fraud professionals in Commission departments and Executive agencies meet in the Fraud Prevention and Detection 
Network (FPDNetwork) and its subgroups. These meetings are organised and chaired by OLAF, and a forum to share the latest developments on anti-fraud 
policy, develop such policy and exchange experiences. In addition to the FPDNet subgroups, a number of ad hoc working groups have been created since the 
adoption of the revised CAFS Action Plan in July 2023 with the purpose of implementing different actions. The FPDNet is involved in the coordination and 
monitoring of the implementation of the CAFS Action Plan. 

The FPDNet has a dedicated webpage on the Commission’s anti-fraud website which was revised as part of the Commission’s corporate move to SharePoint 
online. The website was launched in June 2024 and is regularly updated. 

35 

 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
35  Regularly include aspects of the Commission’s anti-fraud policy on the agenda of the Corporate Management Board 

meetings, for example: 

a. 
the follow-up to OLAF's recommendations and – where applicable – information received from the EPPO; 
b.  overall progress in the implementation of the Commission's anti-fraud strategy and its accompanying action 

Lead 
SG, OLAF: lead 
All DGs: support 

Due date 
2023 and 
continuous 

plan. 

State-of-play May 2025 

The Commission’s Corporate Management Board (CMB) provides coordination, oversight, advice and strategic orientations on corporate management issues, 
including anti-fraud policy matters. OLAF’s Director-General is regularly invited to present aspects of the Commission’s anti-fraud policy. 

a.  In 2024, OLAF was invited to the October CMB meeting to discuss the follow-up of OLAF recommendations and information received from the 

EPPO. 

b.  In this meeting, the CMB also discussed the state of play of the implementation of the CAFS action plan.   

In April 2025, the CMB was updated on two ECA audits on the EU’s anti-fraud architecture and the Commission’s anti-fraud strategy.  

36 

 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
36 

Improve continuously service-level anti-fraud strategies and their implementation, notably by: 
a.  updating such strategies and fraud risk assessments in principle every three years12; 
b.  seeking OLAF's advice at an early stage in the development of such a strategy or update, submitting the drafts 
for OLAF's mandatory review and to peer review, and justifying in writing when OLAF’s recommendations 
on the anti-fraud strategy have not been followed. Any issues that cannot be resolved between OLAF and the 
Commission department concerned may be discussed in suitable fora or be brought to the attention of the 
Corporate Management Board. 

State-of-play May 2025 

Lead 
All DGs and 
executive 
agencies: lead 
OLAF: support 

Due date 
2023 and 
continuous 

Service-level anti-fraud strategies help tailor anti-fraud measures to different policy areas and operations, thus increasing their effectiveness and efficiency. 
OLAF provides support for the elaboration of service-level anti-fraud strategies through methodological guidance elaborated in consultation with FPDNet, 
through training and tailor-made advice. 

a.  In 2024, OLAF reviewed and approved the service-level anti-fraud strategies together with their fraud risk assessments of eight Commission departments 

and Executive agencies, in line with OLAF anti-fraud strategy methodology of June 2021.  

b.  In  the  FPDNet meeting  of  February  2024,  OLAF  reminded  Commission  departments  and  Executive  agencies  of the need to  update their  anti-fraud 
strategies, in principle, every three years, and to involve OLAF at an early stage of the revision. OLAF reviewed all anti-fraud strategies submitted in 
2024 and early 2025. Since early 2024, all service-level anti-fraud strategies are subject to peer review. A great majority of departments and agencies 
follow the guidance of OLAF and no issues in this regard were brought to the attention of the CMB in 2024. 

12 In line with the 2019 CAFS and the anti-fraud strategy methodology of June 2021, ref. Ares(2021)4589215. 

37 

 
 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
37  Make  use  of  OLAF’s  investigative  experience  in  the  Commission’s  work  with  individual  Member  States,  notably  in  the 

Lead 
OLAF 

European Semester and in the Rule of Law processes where appropriate. 

Due date 
2024 and 
continuous 

State-of-play May 2025 

OLAF’s knowledge and experience from working in Member States with national authorities can be of relevance to the European Semester and the Rule of 
Law processes. 

As regards the European Semester process, OLAF participated in a number of meetings in 2024 and 2025, and got access to CeSaR (the Commission’s online 
database and monitoring tool for the Country Specific Recommendations), to better assess where OLAF’s contribution would be appropriate.  

As regards Rule of Law, OLAF contributed to the 2025 Rule of Law package and regularly participates in the discussions on individual Member States. To 
ensure that all potential Rule of Law issues are properly recorded and followed up upon, OLAF has continued the screening of its investigations and of the 
investigative outcome for such issues, notably through a dedicated module in its case management system. The initial trainings of OLAF staff concerning the 
RoL  module  in  OLAF’s  Case  Management  System  were  completed  in  2024.  Additionally,  OLAF  performed  in  2024  an  analysis  of  its  administrative 
recommendations from a Rule of Law conditionality point of view.  

38 

 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr 
38 

Action 
In  implementing  the  EU’s  anti-corruption  policy13,  exploit  the  synergies  between  anti-fraud  and  anti-corruption 
policies, notably by identifying common areas of high risk and measures to address such risks. 

Lead 
HOME, 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2025 

With its anti-corruption package of May 2023, the Commission stepped up its efforts to integrate the prevention of corruption into the design of EU policies 
and programs, and to actively support Member States' work to put in place strong anti-corruption policies and legislation. The EU Network Against Corruption 
has been created as an umbrella forum for relevant stakeholders to exchange best practices and develop anti-corruption policy. 

As part of these efforts, DG HOME committed in 2023 a study on high-risk areas of corruption in the EU. The study was published on 4 November 2024 
and provides a comprehensive mapping of areas most at risk of corruption and in-depth analysis of the nature of and reasons behind these risks. The study 
notes that these areas also have a high risk of fraud. The findings of the corruption risk assessment were presented and discussed at the 2nd plenary meeting 
of the EU Network Against Corruption on 3 October 2024, highlighting areas such as public procurement, construction and infrastructure, and healthcare as 
being particularly vulnerable to corruption. 

OLAF continues to participate in Commission internal meetings and external events on the fight against corruption, and contributes to the Commission’s 
anti-corruption efforts, such as the UNCAC (United Nations Convention against Corruption) implementation review of the EU.  

On 23 January 2025, DG HOME organised a webinar focusing on recent anti-corruption projects stemming from Horizon Europe and Internal Security Fund. 
The  main  purpose  was  to  present  the  achievements  of  six  ongoing  initiatives  (RESPOND,  BRIGEGAP,  FALCON,  KLEPTOTRACE,  POSEIDON  and 
iMonitor), share relevant policy developments and observations concerning gaps in data, missing phenomena analysis and similar aspects where security 
research could potentially help. OLAF also participated. 

Between September 2024 and March 2025, based on data from the Irregularity Management System (IMS) and with the support of a number of Member 
States, OLAF carried out an analysis of the interaction between corruption and fraud against the EU’s financial interests. A  summary of the findings is 
published in the Statistical Evaluation accompanying the 2024 PIF Report.  

13 See the Anti-corruption package adopted by the Commission on 3 May 2023. 

39 

 
 
 
 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
39 

Exploit the synergies between policies against organised crime, fraud and corruption, notably by identifying sectors at risk of 
fraud and corruption by organised crime, and of its infiltration in the legal economy, and measures to address such risks. 

Lead 
HOME, 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2025 

Fraud, corruption and organised crime are often interlinked. These interlinkages need to be better understood to allow for the development of holistic policies. 

In the framework of the EU Organised Crime Strategy, the platform of Organised Crime Experts Group will be used to identify, raise awareness and exchange best practices 
about sectors at high risks at the intersection of fraud, corruption and organised crime.  To support this effort, in  the third quarter of 2024, as part of the European 
Ports Alliance public-private partnership, DG HOME organised a dedicated workshop, addressing the issue of combating the infiltration of organised crime 
in European ports, with a particular focus on corruption risks. In December 2024, an additional meeting took place with competent authorities from Member 
States focusing on the administrative approach to tackle criminal infiltration in the society, with an outlook to potential synergies with fraud. 

OLAF has contributed to the development of the 2025 Serious and Organised Crime Threat Assessment (SOCTA) by sharing its strategic analysis in July 
2024. This contribution underscores OLAF's commitment to enhancing the quality and scope of the assessment, thereby enriching the understanding of threats 
related to organised crime, fraud, and corruption. 

OLAF is involved in EMPACT Operational Action OA 2.4, which focuses on fraud involving EU funds. OLAF contributed to a survey aimed at national 
judicial police responsible for investigating criminal fraud against the EU budget. By proposing three targeted questions, OLAF seeks to identify potential 
links between fraud on EU funds and organised crime. The collection and analysis of survey results will provide valuable insights into how organised crime 
may exploit EU funding mechanisms and help refine future strategic responses. 

40 

 
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
40  Map, enhance and promote existing ethics and anti-fraud training and awareness raising for staff at all levels across 
the Commission, and reinforce the existing financial learning activities with additional messages on ethics and anti-
fraud matters. 

Lead 
OLAF, HR, SG, 
BUDG: lead 
All DG’s: support 

Due date 
2024 

State-of-play May 2025 

There is a continued need to strengthen the knowledge and maintain a high level of awareness among Commission staff regarding ethics and anti-fraud 
matters. The Commission is gradually strengthening training and awareness raising on ethics and anti-fraud in a holistic manner, as the two topics go hand 
in hand.  

The existing corporate training – Fraud Staying Vigilant has been revamped and is being delivered across Commission services. OLAF has carried out a 
survey among Commission services and executive agencies to assess if anti-fraud training should become mandatory or at least highly recommended for 
certain categories of Commission staff and will follow up on the results.  

Another strand of action is to prepare a common customisable  anti-fraud training material available to services, which can then further tailor it to their 
specificities.  A  draft  has  been  prepared  and  distributed  to  the  Commission  services  for  comments.  Following  the  reception  of  comments  the  work  will 
continue.  This  initiative  is  complemented  by  a  “train-the-trainer”  component,  where  OLAF  colleagues  train  colleagues  across  Commission  to  deliver 
customisable training in their respective services. 

In addition, OLAF has also started working on the e-learning module on fraud prevention in EULearn.  

The ethics e-learning module is going to be revamped to integrate modules of ethics and anti-fraud. Results of a compliance feature pilot show an increase 
in uptake in the participating DGs. DG HR is working on an interinstitutional awareness raising campaign on ethics. 

DG BUDG produced a training video on conflicts of interests in the management of EU budget, and how to spot, prevent and address them to safeguard the 
integrity of the EU budget and addressing professional conflicting interest in the field of procurement. Strengthened messages on the protection of the EU 
financial interests and avoidance of conflict of interest were added to the regular BUDG training sessions. 

The action has been completed. Further streams of work (e.g. development of an anti-fraud e-learning module) deriving from the mapping exercise will 
continue throughout 2025. 

41 

 
 
 
 
  
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
41 

Promote awareness on Members’ ethical obligations among Members of the Commission and Cabinets through 
the  Network  of  Ethics  and  Transparency  Contact  Points  and  through  targeted  information  for  Members  at  the 
beginning and end of their mandates. 

Lead 
SG: lead 
OLAF, HR: support 

Due date 
2023 and 
continuous 

State-of-play May 2025 

The EU Treaties and the Code of Conduct for the Members of the European Commission lay down the rules on how Members should perform their duties. 
They shall observe the highest standards of ethical conduct. 

In 2020, the Commission established a Network of Ethics and Transparency Contact Points composed of correspondents in the Cabinets of the Members of 
the Commission. The aim is to raise awareness on the Members’ obligations in the areas of ethics and transparency. The Network serves as a regular platform  
for the exchange of information, and meetings are organised on routine basis. In 2023 two such meetings were held, followed by three meetings in 2024. 
Among the 2024 meetings, one focussed specifically on ethical standards for the participation of the Members of the Commission in the European Parliament 
election campaign, as well as in national election campaigns. Another meeting addressed post-mandate activities for outgoing Members.  

In the first half of 2025, two additional meetings took place, including one dedicated to updates of the Members’ declarations of interests. Furthermore, 
information sessions were held for both outgoing and incoming Members of the Commission, aiming to raise awareness as regards the ethical obligations 
applicable to them under the Treaty and the Code of Conduct. In addition, since December 2024, dedicated training on ethics and the application of the Code 
of Conduct was provided to 12 out of 27 Cabinets (44%) further supporting awareness and compliance efforts. 

42 

 
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
42 

Provide  corporate  training  and  guidance  on  grants  and  procurement,  including  on  simplified  forms  of  reimbursement  for 
grants, while ensuring that the training and guidance contain relevant anti-fraud elements.  

Lead 
BUDG 

Due date 
2024 and 
continuous 

State-of-play May 2025 

Direct expenditure in the form of grants and procurement represent a major part of the Union's expenditure. Simplified forms of funding have significant 
potential to reduce administrative burden and the overall error rate. Simplified cost options (SCO), such as lump sums or flat rates, are therefore increasingly 
used to provide funding in EU grants. 

In 2024, the grants dedicated pages on BUDGpedia were updated and workshops of grants were organsied, with specific exercises on SCOs. Workshops on 
procurement were organised, highlighting anti-fraud matters, conflict of interest and professional conflicting interest. Strengthened messages on the protection 
of  the EU financial interests and conflict of interest were added in the regular BUDG training courses. 

A new training video was produced, breaking down what conflicts of interests are when managing the EU budget, how to spot, prevent and address them to 
safeguard the integrity of the EU budget and addressing professional conflicting interest in the field of procurement.  

A training campaign on the changes brought by the Financial Regulation recast was designed, including stronger protection of the EU budget against fraud, 
corruption and conflict of interest. Specific sessions were organised on the procurement experts platform and EDES experts platform.  

43 

 
 
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
43  Based on identified needs and priorities of Commission departments and Member States, perform and disseminate 

strategic analysis and guidance, notably to: 

Lead 
OLAF: lead 
All DGs: support 

Due date 
2023 and 
continuous 

a.  feed into training and awareness raising, fraud risk assessments, and other prevention and detection activities 

b. 

of Commission departments, agencies, Member States and other anti-fraud partners; 
translate audit results and experience from investigations into concrete advice on fraud risks, fraud patterns 
and red flags, for example, in the form of case compendia. 

State-of-play May 2025 

To increase the anti-fraud knowledge of the Commission, partner organisations and Member States, notably on fraud risks, trends and modus operandi, OLAF 
has established a strategic analysis function within its Anti-Fraud Knowledge Centre. 

In 2024, OLAF disseminated two strategic analysis reports on agriculture and cohesion policy to relevant Commission services and Member States, to feed 
into their fraud risk assessments. Updated versions of these reports will be disseminated in 2025. OLAF also carried out an analysis of the impact of fraud in 
the different areas of the cohesion policy and an analysis of the interaction between corruption and fraud against the EU’s financial interests.  

44 

 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
44  Consider  anti-fraud  aspects  when  reviewing  the  recruitment  process  in  the  context  of  the  implementation  of  the 
Commission's  new  HR  strategy,  notably  in  the  behavioural  assessments  and  in  the  training  of  selection  panels,  and 
reinforce the checks of originals of qualifications and certificates of candidates. 

Lead 
HR: lead 
OLAF: 
support 

Due date 
2023  

State-of-play May 2025 

With a workforce of over 32 000 staff in close to 200 places of employment, the Commission recruits every year approximately 500 officials and 1 800 
temporary or contract agents. It is important to consider anti-fraud aspects in  the recruitment process, to identify any unethical tendencies and potential 
wrongdoers and avoid recruitments potentially damaging for the institution.  

In 2024 and at the beginning of 2025, DG HR designed a New Recruitment Model (NRM) for appointing officials drawing from the laureates on reserve lists 
established under EPSO’ new competition model, after 1 January 2025 (“new reserve lists”). Designed to attract top talent, but also to strengthen anti-fraud 
efforts, the NRM introduces several key measures. Notably, HR Representatives will now be mandatory participants in all recruitment panels for EPSO 
competition  laureates  from  the  new  reserve  lists.  Their  main  responsibility  will  be  to  evaluate  candidates'  general  skills,  but  also  to  spot  any  potential 
irregularities and fraud. Selected based on their recruitment experience, these representatives unbdergo mandatory training of three half-a-day modules on 
interviewing  technicques  to  acquire  the  skills  for  mapping  general  skills  and  abilities,  including  focusing  on  observing  a  candidate’s  consistency  and 
questioning to verify credibility of provided replies.  

Additionally, DG HR is facilitating regular exchanges with the  HR Representatives to promote the sharing of experiences and best practices, including with 
an emphasis on fraud detection strategies. The NRM is currently being rolled out by DG HR with the first EPSO laureates’ list published in March 2025. 

45