COMMISSION STAFF WORKING DOCUMENT National anti-fraud strategies (NAFS): state of play and assessment Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 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) 229 final  COMMISSION STAFF WORKING DOCUMENT National anti-fraud strategies (NAFS): state of play and assessment Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL 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) 197 final} - {SWD(2025) 198 final} - {SWD(2025) 199 final} - {SWD(2025) 228 final} - {SWD(2025) 230 final}  
 
 
I. OVERVIEW OF NATIONAL ANTI-FRAUD STRATEGIES 
In  2024,  all  27 Member  States  indicated that  they  have  anti-fraud  strategies  in place  for the  protection  of  the  EU’s 
financial interests1. The approach taken by the Member States varied widely. 

A total of 10 Member States indicated they have a national anti-fraud strategy (NAFS) in place. These 10 NAFS are 
further assessed in Section II. 

7 out of the 10 NAFS cover both EU expenditure and revenue, 22 NAFS cover only EU expenditure and the remaining 
one3 covers both national and EU funds.  

For 8 out of the 10 NAFS, the national anti-fraud coordination service (AFCOS) was in charge of coordinating the 
elaboration of the strategy. For the remaining 2, the coordination was done by other services. 

7 of the 17 Member States who do not have a national anti-fraud strategy for the protection of EU’s financial interests, 
are in the process of adopting one. 44 Member States are in the preliminary stage (i.e. defining the legal and institutional 
framework and the scope of the strategy), 15 is in the preparatory phase (i.e. state of play and fraud risk assessment), 16 
is in the elaboration phase (i.e. establishment of objectives, related performance indicators and action plan) and 17 is in 
the formal approval phase.  

The remaining 108 declared neither having a national anti-fraud strategy for the protection of EU’s financial interests 
nor an ongoing procedure to adopt one.  

Table 1 – Overview of the national anti-fraud strategies (NAFS) reported by Member States 

23 out of 27 Member States indicated that they have other types of anti-fraud strategy for the protection of EU’s financial 
interests  in  place:  regional  cross-cutting,  sectoral  national,  sectoral  regional,  authority/programme  level  or  anti-
corruption. Many of these 23 Member States have more than one anti-fraud strategy for the protection of EU’s financial 
interests in place. The remaining 49 have a NAFS in place. 

1 The  information  was  gathered  via  a  dedicated  questionnaire.  See  the  document  ‘Measures  adopted  by  the  Member  States  to 
implement Article 325 TFEU’ accompanying the report. 
2 Hungary and Portugal 
3 Malta 
4 Belgium, Cyprus, Denmark, Lithuania 
5 Luxembourg 
6 Netherlands 
7 Spain 
8 Austria, Croatia, Estonia, Finland, Germany, Greece, Ireland, Poland, Slovenia, Sweden 
9 Bulgaria, Czechia, France, Slovakia 

1 

 
 
 
 
 
 
 
 
Table 2 – Overview of other types of anti-fraud strategies reported by Member States 

1010 Member States indicated they have in place a strategy for the protection of the national budget, 1511 indicated they 
did not, while the remaining 212 did not provide any answer. Out of the 15 Member States not having a strategy for the 
protection of the national budget in place, 313 declared they are planning to adopt one and 12 that they do not have such 
plans. 

II. ASSESSMENT OF NATIONAL ANTI-FRAUD STRATEGIES 
The Commission14, European Parliament15 and European Court of Auditors16 have actively encouraged Member States 
to adopt national anti-fraud strategies. Moreover, the European Parliament has called for the Commission to ‘assess the 
NAFS that have been adopted, to examine why Member States are lagging behind in adopting them, and to push the 
remaining Member States to progress with the adoption’17. 

The state of play on the NAFS presented in the Annual Report on the Protection of the European Union’s financial 
interests  and  the  Fight  against  fraud  (‘PIF  Report’)  is  based  on  the  Member  States’  replies  to  the  dedicated  PIF 
questionnaire. To allow for a more accurate and detailed overview of the state of play of anti-fraud strategies in place at 
national level, the Commission increased the level of detail of information requested in the PIF questionnaire. This is 
reflected in the overview in Section 2.2.2 of the Report. 

Furthermore, to address the request for analysis of the adopted NAFS, the Commission performed, for the first time in 
the 2023 PIF Report, an assessment that goes beyond the self-assessment in the replies to the PIF questionnaire. 

In 2024, two18 Member States adopted new NAFS. Therefore, the NAFS assessment has been updated to include these 
new NAFS. 

The assessment followed a two-step approach: the fulfilment of basic criteria and a qualitative assessment. 

First, the 10 NAFS indicated by the Member States in the PIF questionnaire have been assessed against three basic 
criteria:  

i. 

ii. 

iii. 

is it national?  
is it anti-fraud, addressing (at least) fraud against EU funds?  
is it primarily forward-looking and multiannual? 

10 Austria, France, Germany, Ireland, Italy, Latvia, Malta, Poland, Portugal, Spain 
11 Belgium, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, Greece, Hungary, Lithuania, Netherlands, Romania,  Slovakia, 
Slovenia, Sweden 
12 Bulgaria, Luxembourg 
13 Lithuania, Netherlands, Romania 
14 Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud (‘PIF Report’)  - 2017, 
2018, 2020, 2022, 2023. 
15 European Parliament resolutions on the protection of the European Union’s financial interests – combating fraud – annual reports 
2016-2023. 
16 Special Report No 6/2019 Tackling fraud in EU cohesion spending: managing authorities need to strengthen detection, response 
and coordination. 
17 European Parliament Resolution of 7 July 2022 on the protection of the European Union’s financial interests – combating fraud 
– annual report 2020 (2021/2234(INI)). 
18 Italy and Latvia 

2 

 
 
 
 
 
 
Furthermore, the strategies have been assessed against seven qualitative criteria derived from the guidelines on national 
anti-fraud strategies19: 

overall aspects (scope, update, full anti-fraud cycle addressed) 

i. 
ii.  means and resources (consultation and involvement of authorities in preparing the NAFS; description of 

iii. 
iv. 
v. 
vi. 

available anti-fraud tools and procedures; reporting system for irregularities and fraud) 
evaluation of the previous NAFS 
specific fraud risk assessment 
objectives linked to the risks identified 
action plan (including measures and actions linked to the objectives, responsible services, target dates and 
indicators) 

vii.  monitoring of the implementation of NAFS. 

Table 3 – Assessment of the national anti-fraud strategies (NAFS) 

Category of 
criteria 

Basic criteria 

Overall 
questions 

Means and 
resources 

Evaluation 

9 

Fraud risk 
assessment 

10 

No 

Criteria  

BG 

CZ 

FR 

IT 

LV  HU  MT 

PT 

RO 

SK 

1 

2 

3 

4 

5 

6 

7 

8 

Is it a national?  

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

Is it anti-fraud? 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

Is it primarily forward-
looking and 
multiannual? 
Is the NAFS up-to-
date?  
Does the NAFS cover 
each stage of the anti-
fraud cycle? 
Has there been a wide 
consultation and 
involvement of 
authorities in preparing 
the NAFS?  
Does the NAFS 
include a description 
of available anti-fraud 
tools and procedures?  
Is there a reporting 
system for 
irregularities and 
fraud? 
Is an evaluation of the 
previous NAFS 
reflected in the current 
NAFS? 
Has a specific fraud 
risk assessment for the 
NAFS been carried out 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no20 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes  

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes 

yes  

yes 

yes 

no 

no 

no 

yes 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no21 

yes 

yes 

yes 

yes 

no22 

no 

yes 

no 

no 

yes 

yes 

no 

yes 

yes 

no23 

no 

19 The guidelines on national anti-fraud strategies were developed in 2016 by a working group of Member States’ experts, directed 
and coordinated by the European Anti-Fraud Office (OLAF). The guidelines were shared with all Member States and are not legally 
binding. 
20 Slovakia considers its NAFS as applicable even though it was prepared for the 2014-2020 period. 
21 The NAFS reported by Italy in previous years  was the annual report to the national Parliament on the protection of the EU’s 
financial interests, which did not include an action plan.  
22 Romania considered the 2007 evaluation of the previous NAFS as outdated. Therefore, it was not reflected in the current NAFS. 
23 The Romanian authorities carried out a specific fraud risk assessment; however, it is not detailed in the current NAFS. 

3 

 
 
 
 
  
 
  
 
and is reflected in the 
NAFS?  

Are the fraud risks 
identified and 
formulated/described? 
Have mitigating 
measures been 
identified where 
necessary?  
Does the NAFS 
include objectives? 
Are the objectives 
linked to the risks 
identified? 
Are key performance 
indicators (KPIs) 
determined? 

Does the NAFS 
include an action plan? 

Are the 
measures/actions 
linked to the 
objectives? 
Are the actors 
(responsible services) 
mentioned?  

Are the target dates 
(deadlines) mentioned?  

Are there specific, 
measurable and time-
bound indicators? 
Does the NAFS 
provide for regular 
monitoring of the 
implementation? 

Objectives 

Action plan 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

Monitoring of 
implementation  

21 

yes 

no 

no 

yes 

no 

no 

yes 

yes 

no 

no 

yes 

no 

no 

yes 

no 

no 

yes 

no 

no 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

yes 

no 

no 

no 

yes 

no 

no 

yes 

no 

yes 

no 

no 

no 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

no 

yes 

no 

no 

yes 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

no 

yes 

yes 

yes 

All stages of the anti-fraud cycle (i.e. prevention, detection, investigation and prosecution, and recovery and sanctions) 
are covered in 9 out of 10 NAFS. 

Broad consultation and involvement of authorities in preparing the NAFS took place for 9 out of the 10 NAFS, while 7 
out of 10 NAFS include a description of the available anti-fraud tools and procedures. 

Only 5 Member States carried out a specific fraud risk assessment and reflected it in the NAFS. Therefore, even if all 
NAFS include objectives, in only 3 cases are the objectives linked to the risks identified.  

All 10 NAFS include an action plan. Specific arrangements for monitoring the implementation of the NAFS are included 
in 9 out of 10 NAFS. 

4