COMMISSION STAFF WORKING DOCUMENT Follow-up by Member States to the recommendations of the PIF Report 2023 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) 199 final  COMMISSION STAFF WORKING DOCUMENT Follow-up by Member States to the recommendations of the PIF Report 2023 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) 197 final} - {SWD(2025) 198 final} - {SWD(2025) 228 final} - {SWD(2025) 229 final} - {SWD(2025) 230 final}  
 
 
Introduction ............................................................................................................................................. 7 

1.  Overview of Member States’ replies to the questionnaire ................................................................ 8 

1.1. 

Recommendation 1: Improving the reporting and follow-up of suspected fraud................................ 8 

1.1.1 Confidence in reporting systems ..................................................................................................... 8 

1.1.2 Issues with information flow .......................................................................................................... 9 

1.1.3 Best practices mentioned by Member States .................................................................................. 10 

1.2. 

Recommendation 2: Accelerating the digitalisation of the fight against fraud ................................ 10 

1.2.1 Current status and challenges in digitalisation ................................................................................ 11 

1.2.2. Approaches to achieve interoperability mentioned by Member States ............................................. 15 

1.2.3. State-of-play and utilisation of ARACHNE .................................................................................. 16 

1.2.4. Advantages vs difficulties with the use of ARACHNE .................................................................. 18 

1.3. 

Recommendation 3: Reinforcing anti-fraud governance in the Member States............................... 19 

1.3.1. State-of-play in national anti-fraud governance structures .............................................................. 19 

1.3.2. Best practices in anti-fraud governance ........................................................................................ 20 

2. Responses from the Member States .................................................................................................... 21 

Q.1.1 Have you reviewed the effectiveness of your reporting in the Irregularity Management System (IMS) in 
2024? ................................................................................................................................................. 21 

Q.1.2 If “YES” to Q.1.1, What were the main findings of your evaluation? .............................................. 21 

Q.1.3  How  would  you  evaluate  your  level  of  maturity  of  your  current  reporting  process  for  reporting 
irregularities and, in particular, fraud? ................................................................................................... 24 

Following Q1.3, please specify "Other". ................................................................................................ 25 

Q.1.4 Can you provide examples of well-established reporting systems or practices that have been effective in 
capturing and reporting suspected fraud cases and irregularities? ............................................................. 25 

Q.1.5 Have you identified in 2024 new weaknesses in your reporting practices that could hinder the timely and 
exhaustive reporting in IMS, in particular of suspected fraud cases? ........................................................ 33 

Q.1.6 If “YES” to Q.1.5, in which of the following areas did you encounter new difficulties? .................... 33 

Following Q1.6, please specify "Other". ................................................................................................ 33 

Q.1.7 Have you made significant improvements to the quality of your reporting on suspected fraud cases and 
irregularities in 2024? .......................................................................................................................... 34 

Q.1.8 What are the main steps you have taken to improve the reporting of irregularities? .......................... 34 

Following Q1.8, please specify "Other". ................................................................................................ 35 

Q.1.9 If “NO, not yet” or “NO” to Q.1.7, what are the main reasons preventing you from further improving the 
quality of reporting in 2024? ................................................................................................................ 36 

Following Q1.9, please specify "Other”. ................................................................................................ 36 

Q.1.10  In  2024,  have  you  encountered  any  difficulties  in  providing  timely  updates  about  the  follow-up  to 
irregularities, and in particular, fraudulent irregularities? ........................................................................ 36 

Q.1.11  In  which  areas  did  you  encounter  more  difficulties  when  updating  already  reported  fraudulent 
irregularities? ...................................................................................................................................... 37 

 
 
 
Following Q1.11, please specify "Other". .............................................................................................. 37 

Q.1.12 Regarding previous question, please provide additional explanation about the difficulties encountered.
 .......................................................................................................................................................... 38 

Q.1.13 Has the information flow between judicial and reporting authorities improved in 2024? ................. 40 

Q.1.14  If  “YES,  fully”  and  “YES,  partly”  to  Q.1.13,  what  steps  have  been  taken  in  2024  to  improve  the 
exchange of information between judicial and reporting authorities? ........................................................ 40 

Following Q1.14, please specify "Other". .............................................................................................. 41 

Q.1.15  Can  you  provide  a  short  description  of  the  organisational  structure  and  procedures  for  exchanging 
information between judicial authorities and reporting authorities in your Member State? ......................... 42 

Q1.16 What methods are used for exchanging information between judicial and reporting authorities? ....... 49 

Following Q1.16, please specify "Other". .............................................................................................. 50 

Q1.17  Do  you  see  possible  improvement  in  the  exchange  of  information  between  judicial  and  reporting 
authorities? If yes, which ones? How can OLAF / the Commission support this? ...................................... 53 

Q.1.18 Please feel free to share any additional thoughts or experiences you have regarding the topics discussed 
in this section. ..................................................................................................................................... 56 

Q.2.1. Have you ensured that the digitalisation of the fight against fraud is part of your NAFS (National anti-
fraud strategy)? ................................................................................................................................... 59 

Following Q.2.1, please specify "Digitalisation of the fight against fraud is part of another strategy / assessment 
/ policy". ............................................................................................................................................. 59 

Q.2.2. If “YES” to Q.2.1, please describe how it has been implemented. .................................................. 61 

Q.2.3. If “NO” to Q.2.1, please explain why the digitalisation of the fight against fraud is not part of your 
NAFS nor of any other strategic approach. ............................................................................................ 70 

Q.2.4 What are the main gaps you have identified in the digitalisation of your anti-fraud efforts?............... 70 

Q.2.5 What steps have you undertaken to address gaps in the digitalisation of your anti-fraud efforts? ....... 71 

Following Q.2.5, please specify "Other". ............................................................................................... 72 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit  fraud?  Inventory  of  existing  tools:  conduct  a  thorough  inventory  of  existing  digital  tools  and 
technologies used in the fight against fraud. ........................................................................................... 73 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud? Benchmarking on new trends: conduct benchmarking research on new trends and technologies 
used in the fight against fraud. .............................................................................................................. 73 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud?: Evaluation and updates of existing IT tools. .................................................................... 74 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud?: Development/deployment of new, dedicated IT tools. ...................................................... 74 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud?: Improve interoperability between systems already in use to enhance data sharing. ............. 74 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud?: Dedicated allocated staff / resources / taskforce. ............................................................. 75 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud?: Trainings of the staff. .................................................................................................... 75 

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Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud?: Risk analysis assessment. .............................................................................................. 75 

Q.2.6.  What  actions  have  you  taken  or  are  you  taking  to  keep  up  with  evolving  new  technologies  used  to 
commit fraud?: Other (please specify in the next question). ..................................................................... 76 

Q.2.7 Following Q.2.6, please specify any other actions you have taken, or you have planned on taking to keep 
up with evolving new technologies used to commit fraud. ....................................................................... 76 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Inventory of existing tools: conduct a thorough inventory of existing digital tools and technologies used in the 
fight against fraud................................................................................................................................ 78 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Benchmarking on new trends: conduct benchmarking research on new trends and technologies used in the fight 
against fraud ....................................................................................................................................... 79 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Evaluation and updates of existing IT tools ............................................................................................ 79 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Development/deployment of new, dedicated IT tools .............................................................................. 80 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Improve interoperability between systems already in use to enhance data sharing ..................................... 80 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Dedicated allocated staff / resources / taskforce ..................................................................................... 80 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Trainings of the staff ............................................................................................................................ 81 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-fraud efforts.: 
Risk analysis assessment ...................................................................................................................... 81 
Polar plot of the Average Level of Importance Assigned to Anti-Fraud Action ......................................................................... 82 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Use of AI (Artificial Intelligence) ......................................................................................................... 82 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Data Analysis tools (external) ............................................................................................................... 83 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Automated data analysis tools (integrated) ............................................................................................. 83 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Predictive analytics .............................................................................................................................. 83 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Database integration ............................................................................................................................ 84 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Fraud case management system ............................................................................................................ 84 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Cross-agency data sharing .................................................................................................................... 84 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Cybersecurity measures ....................................................................................................................... 85 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-fraud efforts?: 
Automation of information exchange .................................................................................................... 85 

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Spiderplot of Average Stage of Implementation of Digital Tools and Technologies Across All Member States ............................. 86 

Q.2.10  Following  Q.2.9,  please  specify  any  other  digital  tools  or  technologies  you  are  using,  or  you  are 
planning to use. ................................................................................................................................... 86 

Q.2.11 Are your data analysis tools integrated directly into your databases, or do you deploy external systems 
for data analysis? ................................................................................................................................. 90 

Following Q.2.11, please specify "Other". ............................................................................................. 90 

Q.2.12 Does your data management system facilitate interoperability? ..................................................... 91 

Q.2.13 If YES to Q.2.12, could you describe how interoperability is achieved between your data analysis tools 
and databases? .................................................................................................................................... 91 

Q.2.14 Does your digitalisation strategy prioritize the standardized use of digital tools and technologies across 
local levels and different administrations so that all authorities involved in the anti-fraud strategy can access 
it? ...................................................................................................................................................... 94 

Following Q.2.14, please specify "Other". ............................................................................................. 94 

Q.2.15  How  do  you  evaluate  the  successful  implementation  of  the  digital  tools  at  different  administrative 
levels? ................................................................................................................................................ 95 

Following Q.2.15, please specify "Other". ............................................................................................. 95 

Q.2.16 To what extent have digital tools been spread and adopted across different administrative levels? ... 96 

Following Q.2.16, please specify "Limited dissemination to specific regions/localities only ". ................... 96 

Following Q.2.16, please specify "Other”. ............................................................................................. 96 

Q.2.17 What are the key challenges you face in accelerating the digitalisation of your fight against fraud? . 97 

Following Q.2.16, please specify "Other”. ............................................................................................. 98 

Q.2.18 Has your Member State conducted evaluations to assess the interoperability of national systems with 
Arachne? ............................................................................................................................................ 98 

Q.2.19  If  “YES”  to  Q.18,  Please  provide  key  findings  or  the  stage  of  completion  concerning  system 
interoperability. ................................................................................................................................... 99 

Q.2.20 What steps have you undertaken to ensure your systems are prepared to feed data into Arachne for the 
upcoming multiannual financial framework? Please refer to the indicative milestones from figure 1 and select 
the ones you have reached. ................................................................................................................. 100 

Following Q.2.20, please specify "Other ". .......................................................................................... 101 

Q.2.21 Currently, what are the factors preventing you from being able to feed the data into Arachne? ...... 102 

Q.2.22 What type of support would facilitate your successful integration of data into Arachne by the required 
deadline? .......................................................................................................................................... 103 

Following Q.2.21, please specify "Other ". .......................................................................................... 103 

Q.2.22 What type of support would facilitate your successful integration of data into Arachne by the required 
deadline? .......................................................................................................................................... 104 

Following Q.2.22, please specify "Other ". .......................................................................................... 104 

Q.2.23 As part of your anti-fraud strategies, are you considering the use of Arachne? ............................. 105 

Q.2.24 If “Already in use” or “planning to use” to Q.2.21, please elaborate on your (planned) use of the tool. 
If “No plans to use”, please provide a brief explanation for not planning to use Arachne. ........................ 105 

Q.2.25 Has your Member State implemented ARACHNE? ................................................................... 109 

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Q.2.26 If “YES” to Q.2.25, please specify the entities or individuals that have access to the Member State's 
data within the Arachne system. ......................................................................................................... 109 

Following Q.2.26, please specify "Other ". .......................................................................................... 109 

Q.2.27 If “YES” to Q.2.25, what is the tool used for? ........................................................................... 110 

Q.2.28 If “YES” to Q.2.25, since implementing it, how has it impacted the efficiency and effectiveness of your 
anti-fraud efforts? .............................................................................................................................. 111 

Q.2.29 If “YES” to Q.2.25, what specific functionalities of Arachne have proven most effective in your state’s 
fight against fraud? ............................................................................................................................ 111 

Following Q.2.29, please specify "Other ". .......................................................................................... 111 

Q.2.30  If  “YES”  to  Q.2.25,  are  there  procedures  in  place  to  address  risk  alerts  generated  by  the  Arachne 
system? ............................................................................................................................................ 112 

Q.2.31 If “YES” to Q.2.25, does your system have dedicated resources or a task force for handling the outputs 
and alerts generated by Arachne? ........................................................................................................ 112 

Q.2.32 Please feel free to share any additional thoughts or experiences you have regarding the topics discussed 
in this section. ................................................................................................................................... 113 

Q.3.1 Have there been any changes in your anti-fraud governance structures in place in 2024? ................ 116 

Q.3.2 If “YES, we set up an anti-fraud governance structure” or “YES, we modified the existing anti-fraud 
governance structure” to Q.3.1, what are the key changes implemented? ................................................ 117 

Q.3.3 If “YES, we set up an anti-fraud governance structure” or “YES, we modified the existing anti-fraud 
governance  structure”  to  Q.3.1,  Which  authorities  have  you  newly  included  in  your  anti-fraud  governance 
structures in 2024?............................................................................................................................. 119 

Following Q.3.3, please specify "Other". ............................................................................................. 120 

Q.3.4 Please rate the effectiveness of the statements below.: Your anti-fraud governance structure facilitates 
knowledge exchange and good practices to fight fraud. ......................................................................... 120 

Q.3.4 Please rate the effectiveness of the statements below.: Your anti-fraud governance structure is the ideal 
forum to elaborate a comprehensive risk assessment to support anti-fraud effort ..................................... 120 

Q.3.4 Please rate the effectiveness of the statements below.: Your anti-fraud governance structure provides a 
comprehensive understanding of anti-fraud issues. ............................................................................... 121 

Q.3.4 Please rate the effectiveness of the statements below.: Your anti-fraud governance structure contributes 
to the development / update of anti-fraud policies/strategies at the national level. .................................... 121 

Q.3.4 Please rate the effectiveness of the statements  below.: Your anti-fraud governance structure responds 
quickly to new threats in the anti-fraud environment. ............................................................................ 122 

Q.3.4 Please rate the effectiveness of the statements below.: Your anti-fraud governance structure contributes 
to drafting anti-fraud legislation. ......................................................................................................... 122 

Q.3.4 Please rate the effectiveness of the statements below.: Your anti-fraud governance structure contributes 
to the development and implementation of training to staff on anti-fraud. ............................................... 122 
Polarplot of the Average Level of Self-Reported Governance Effectiveness in Anti-Fraud Efforts Across All Member States ...... 124 

Q.3.5 Could you describe any best practices or innovative methods that your anti-fraud governance structures 
have implemented to enhance effectiveness and collaboration? ............................................................. 124 

Q.3.6 Has there been any change regarding the staffing of your national anti-fraud structure coordinating the 
anti-fraud governance (AFCOS) in 2024? ............................................................................................ 130 

Following Q.3.6, please specify "Other". ............................................................................................. 131 

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Q.3.7 What are the main challenges currently faced in enhancing the anti-fraud governance in your Member 
State? ............................................................................................................................................... 131 

Following Q.3.7, please specify "Other". ............................................................................................. 131 

Q.3.8 What type of support from the EU would you need to address the challenges identified in improving 
your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least  important  (1)  to  the  most 
important (6).: Increased funding / financial assistance ......................................................................... 132 

Q.3.8 What type of support from the EU would you need to address the challenges identified in improving 
your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least  important  (1)  to  the  most 
important (6).: Training programs for staff........................................................................................... 132 

Q.3.8 What type of support from the EU would you need to address the challenges identified in improving 
your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least  important  (1)  to  the  most 
important (6).: Facilitated cooperation initiative / sharing good practices among Member States .............. 133 

Q.3.8 What type of support from the EU would you need to address the challenges identified in improving 
your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least  important  (1)  to  the  most 
important (6).: Guidance on legal or regulatory framework adjustments ................................................. 133 

Q.3.8 What type of support from the EU would you need to address the challenges identified in improving 
your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least  important  (1)  to  the  most 
important (6).: Technological support .................................................................................................. 134 

Q.3.8 What type of support from the EU would you need to address the challenges identified in improving 
your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least  important  (1)  to  the  most 
important (6).: Other (please specify in the following question) ............................................................. 134 
Bar plot of the Average Level of Support Requested for Anti-Fraud-Policy Across All Member States ...................................... 135 

Q.3.9  If  you  selected  “Other”  to  Q.3.8,  please  specify  any  other  types  of  support  you  would  need  and  its 
importance ........................................................................................................................................ 135 

Q.3.10 Please feel free to share any additional thoughts or experiences you have regarding the topics discussed 
in this section. ................................................................................................................................... 136 

Q.4.1 Which national services were consulted to reply to this questionnaire? .......................................... 137 

Q.4.2 How could we improve this questionnaire? Please share any suggestions for enhancements or specific 
areas that could be improved for future iterations. ................................................................................ 142 

6 

 
 
 
 
 
Introduction 

In its 2023 PIF Report the Commission made recommendations to Member States, covering: a) improving the 
reporting and follow-up of suspected fraud b) accelerating the digitalisation of the fight against fraud c) reinforcing 
anti-fraud governance in the Member States.  

A specific questionnaire has been addressed to the Member States to collect information about how they have 
implemented these recommendations. Their replies are analysed in this document, which is divided in two parts: 
the first provides an overview and analysis of their replies, while the second part details, for each question of the 
survey, the specific replies given. 

Overarching Themes and Guiding Principle 

Two central themes emerged from the Member States' responses. First, there was a strong call for more training 
modules and detailed guidance, highlighting the importance of training in addressing various challenges. Second, 
there was significant demand for enhanced collaboration and an exchange of best practices, both with OLAF and 
among Member States. This formed a guiding principle for the analysis. Where applicable, the analysis compiles 
best practices that Member States identified in addressing common issues to provide an overview of potential 
solutions. 

7 

 
 
 
 
 
 
 
1. Overview of Member States’ replies to the questionnaire 

1.1.  Recommendation 1: Improving the reporting and follow-up of suspected 

fraud. 

The reporting and follow-up of suspected fraud can still be significantly improved. Member 
States should ensure that reported cases of suspected fraud are updated in a timely manner 
with reliable and complete information and data. 

To this end, establishing appropriate communication channels with law enforcement and 
prosecution services; and exchanging information with investigative bodies and timely 
reporting are prerequisites to effective follow-up. 

Complete reporting also implies that national authorities report irregularities and fraud 
detected by Commission audit services, the European Court of Auditors, OLAF and the 
EPPO as soon as the necessary information becomes available. 

1.1.1 Confidence in reporting systems 

A  significant  majority  of  Member  States  showed  a  high  degree  of  confidence  in  their  reporting  systems.  11 
Member States1 reported using a “well-established reporting system capturing all relevant data on suspected fraud 
cases and irregularities”, with 9 stating that they “have a strong reporting system but with some gaps in capturing 
all relevant data2”. Importantly, 17 Member States actively engage in regular reviews to assess the effectiveness 
of their reporting mechanisms3, underscoring a commitment to maintaining and improving system robustness. 

1 Austria, Czechia, Estonia, Finland, France, Germany, Luxembourg, Malta, Poland, Romania, Slovakia 
2 Belgium, Bulgaria, Croatia, Denmark, Hungary, Italy, Latvia, Slovenia, Sweden 
3 Bulgaria,  Cyprus,  Czechia,  Denmark,  Estonia,  Germany,  Hungary,  Italy,  Latvia,  Lithuania,  Malta,  Poland, 
Portugal, Romania, Slovakia, Slovenia, Spain 

8 

 
 
 
 
 
 
1.1.2 Issues with information flow 

Member  States  have  reported  some  persistent  challenges.  Some  13  Member  States  reported  issues  related  to 
information  flow4,  commonly  between  judicial  and  reporting  authorities.  Problems  often  arise  when  judicial 
proceedings  are  prolonged,  or  investigation  secrecy  obstructs  thorough  reporting.  These  gaps  can  affect  the 
timeliness  and  efficiency of follow-ups on reported  cases. This  communication  issue  emphasises  the  need  for 
better  collaborative measures and  improved procedural  clarity  to  ensure  effective  reporting  systems  across  all 
governance levels. Notably, 17 Member States reported some improvement in their follow-up procedures over 
the past year5. 

4 Bulgaria,  Croatia,  Cyprus,  Denmark,  Estonia,  Hungary,  Lithuania,  Poland,  Portugal,  Romania,  Slovakia, 
Slovenia, Spain 
5 Bulgaria,  Czechia,  Denmark,  Estonia,  Germany,  Hungary,  Italy,  Latvia,  Lithuania,  Luxembourg,  Malta, 
Netherlands, Poland, Portugal, Romania, Slovakia, Spain 

9 

 
 
 
 
 
 
1.1.3 Best practices mentioned by Member States 

Member States identified the following best practices in addressing and preventing information flow difficulties: 

•  Centralised Coordination: 

o  Establishing central contact points and specialized units to streamline communication between 
managing  authorities,  investigative  bodies,  and  judicial  authorities.  This  ensures  efficient 
information flow and enhances interagency cooperation. 

•  Comprehensive Guidelines and Systems: 

o  Developing detailed anti-fraud strategies and integrate national IT systems for monitoring and 
recording  irregularities.  Standardising  procedures  facilitates  consistent  data  exchange  across 
sectors and prevents knowledge loss during handovers. 

•  Legal Frameworks and Obligations: 

o 

Introducing legislation mandating information disclosure to prevent disputes between reporting 
and judicial authorities by establishing clear rules for information sharing. Such legal measures 
enhance  transparency,  create  clear  communication  channels,  and  promote  accountability.

•  Routine and Direct Communication: 

o  Encouraging regular and structured communication between authorities with designated contact 
persons. This approach promotes timely updates and flexible coordination, ensuring effective 
information sharing. 

•  Collaborative Networks and Liaison Roles: 

o  Forming  interagency  networks  and  maintain  liaison  roles  for  ongoing  dialogue  with  judicial 
authorities. These collaborations ensure comprehensive case follow-up and optimize oversight 
of suspected fraud and irregularities 

1.2. Recommendation  2:  Accelerating  the  digitalisation  of  the  fight  against 

fraud 

Digitalisation of the fight against fraud needs to be at the heart of anti-fraud strategies. As fraudsters 
increasingly use and exploit new technologies to commit crime, the EU anti-fraud architecture must be equal 
to the challenge to prevent, detect and investigate it. 

Member States should ensure that the digitalisation of the fight against fraud is part of their strategic 
approach to fighting fraud. Member States should begin their preparations for the next phase in the 
development of the Commission’s risk scoring and data mining tool. 

All Member States will be required to feed the tool with data as of the next multiannual financial framework. 
Such preparations could test the automated feeding of requested data and interoperability with national 
systems. 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1.2.1 Current status and challenges in digitalisation 
Digitalisation is a stated priority in all but two Member States6' anti-fraud efforts. In contrast, only  6 Member 
States consider standardisation a crucial component of their digitalisation initiatives7. This indicates that although 
many are adopting digital tools, ensuring data is comparable across borders to improve fraud detection remains a 
lesser priority. 

To  address  these  gaps,  Member  States  primarily  rely  on  training,  with  178 using  it  as  their  main  approach  to 
tackling deficiencies. Gap analysis and internal assessments are also used by 8 Member States9 each. This shows 
a significant focus on capacity building and continuous evaluation to enhance digitalisation efforts and align with 
anti-fraud objectives.

6 Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Greece, Hungary, 
Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, 
Sweden 
7 Belgium, France, Italy, Malta, Portugal, Slovakia 
8 Austria,  Belgium,  Bulgaria,  Cyprus,  Czechia,  Germany, Greece,  Hungary,  Italy,  Lithuania,  Malta,  Romania, 
Slovakia, Slovenia, Spain, Sweden, Finland 
9 Internal assessment: Czechia, Denmark, Estonia, Germany, Greece, Italy, Luxembourg, Romania 
Gap Analysis: Belgium, Czechia, Germany, Italy, Romania, Slovakia, Slovenia, Spain 

11 

 
 
 
 
 
 
 
 
Progress in digital transformation and it tool adoption among Member States 
20 Member States report at least partial success in implementing IT tools10, marking significant progress in their 
digital transformation. The measures adopted reveal that Member States prioritise staff training, risk analysis, and 
the development of interoperable data systems, which are deemed vital for enhancing anti-fraud measures. Data 
analysis  tools  are  widely  used,  with  24  Member  States  either  already  using  or  planning  to  use  external  and 
integrated data analysis tools11. Conversely, predictive analytics and AI are the least used digital tools in combating 
fraud, though AI is  among the most planned for future use. Predictive analytics, currently underutilised, offers 
potential for optimising resource allocation and improving fraud detection efficiency.  

Interoperability advances and challenges in fraud detection systems  

When examining the key challenges Member States face while digitalising their fight against fraud, two issues are 
most frequently cited: legal or regulatory barriers and data privacy and security concerns. The most mentioned 
challenges mainly relate to resource issues rather than a lack of commitment. This implies that while Member 
States are dedicated to digitalisation, certain obstacles hinder their progress rather than a lack of motivation. 

10 Partially successful: Austria, Belgium, Bulgaria, Denmark, Estonia, Finland, France, Greece, Lithuania, Latvia, 
Netherlands, Portugal, Slovakia, Slovenia, Spain, Sweden 
Totally successful: Hungary, Italy, Malta, Poland 
11 External (In use): Austria, Belgium, Croatia, Cyprus, Czechia, Denmark, Estonia, France, Germany, Greece, 
Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia, Slovenia, Spain, 
Sweden;  
External (Planned): Portugal 
Integrated  (In  use):  Belgium,  Czechia,  France,  Germany,  Hungary,  Italy,  Lithuania,  Netherlands,  Poland, 
Romania, Slovakia, Slovenia, Sweden 
Integrated (Planned): Bulgaria, Denmark, Estonia, Finland, Greece, Latvia, Luxembourg, Malta, Portugal, Spain 

 
 
 
 
 
 
 
 
While  16  Member  States  have  developed  interoperable  data  management  systems12,  11  have  not13.  Achieving 
interoperability  is  essential  for  ensuring  seamless  data  sharing  and  enhancing  fraud  detection  mechanisms, 
highlighting an area for potential improvement and standardisation in future efforts. 

12 Austria, Belgium, Czechia, Estonia, France, Hungary, Ireland, Italy, Luxembourg, Malta, Netherlands, Poland, 
Portugal, Romania, Slovakia, Slovenia 
13 Bulgaria, Croatia, Cyprus, Denmark, Finland, Germany, Greece, Latvia, Lithuania, Spain, Sweden 

 
 
 
 
 
 
 
1.2.2. Approaches to achieve interoperability mentioned by Member States 

Member States identified the following approaches to aid the interoperability of their data management systems.  

•  Adopting standard protocols and frameworks: 

o  Using standardised protocols for data exchange. 

o  Maintaining compliance with relevant industry standards. 

•  Data integration and exchange: 

o  Establishing  interfaces  with  external  and  internal  systems  for  seamless  data  integration  and 

automated exchange. 

o  Enabling real-time data sharing across platforms. 

•  Centralised information systems: 

o  Developing centralised data platforms that support multiple data formats. 

o  Providing capabilities for generating both ad hoc and standardised reports. 

•  Using of existing databases and registers: 

o 

Integrating national registers and external databases for automatic data verification. 

o  Ensuring automatic data retrieval and updates. 

•  Data analysis and verification: 

o 

Implementing  systems  for  automatic  cross-referencing  and  validation  of  data  from  multiple 
sources. 

o  Using scoring models and algorithms to detect irregularities across various databases. 

 
 
 
 
 
1.2.3. State-of-play and utilisation of ARACHNE 

As the compulsory feeding of the data mining and risk scoring tool developed by the Commission draws closer, 
22 Member States are using ARACHNE as part of their anti-fraud strategies14. Key actors in implementation are 
managing and auditing authorities. ARACHNE serves as a critical tool for detecting fraud and conflicts of interest, 
particularly within European Social Fund (ESF) procedural rules. It is extensively employed across various EU 
funds, including ESIF, RRF, and ERDF, where it aids mostly in prevention and detection through its risk scoring, 
profiling, and pattern recognition to identify potential fraud and irregularities. Despite its widespread adoption, 
Member States stress the need for comprehensive training and support to maximise the tool’s effectiveness. 

14 Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Estonia, France, Greece, Hungary, Ireland, Italy, Latvia, 
Lithuania, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, Slovenia, Spain 

 
 
 
 
 
Integration challenges and data management issues with ARACHNE 

Member  States  mentioned  some  difficulties  integrating  ARACHNE  into  national  systems  and  showed  varied 
adoption levels of the tool ranging from full integration to initial exploration. ARACHNE requires Member States 
to incorporate data from external databases or convert internal data into compatible formats, which imply potential 
interoperability issues and possible administrative burden. These issues about file-types to be used were commonly 
brought up by several Member States. 
Half of the Member States reported moderate to significant improvements in their processes with ARACHNE15. 
Some difficulties  remain  in interpreting risk indicators and aligning outputs with the required scale of control. 
Legal  clarity,  especially  concerning  data  protection,  and  continued  improvements  in  system  functionalities  are 
key.  Member  States  advocate  for  robust  support  mechanisms  and  adaptations  to  fully  exploit  ARACHNE’s 
capabilities, in order for the system to meet the specific needs and challenges within each national framework. 

15Moderate improvement: Austria, Belgium, Czechia, Malta, Portugal, Romania, Slovakia, Spain 
   Significant improvement: Cyprus, Greece, Italy 

 
 
 
 
 
 
 
 
1.2.4. Advantages vs difficulties with the use of ARACHNE 

Advantages 

Integral  tool:    The  tool  is  recognised  for 
effectively  detecting  fraud  and  conflicts  of 
interest,  especially  in  EU  fund  management 
verification processes. 

fraud  detection:  Effective 

Cross-border 
in 
evaluating the risk of fraud, conflicts of interest, 
and 
irregularities,  aiding  compliance  with 
financial regulations. 

Role  in  risk  assessment:  Useful  for  monitoring 
risk 
further 
and 
investigation when required. 

categories 

initiating 

Supportive 
in  national  processes:  Assists 
countries in improving and their control systems 
and  effectively  allocate  resources  to  enhance 
fraud prevention and detection. 

Self-improving: The tool becomes more efficient 
with increased usage and implementation. 

Common difficulties 

Administrative  burden: 
requires 
significant 
administrative workload. 

  Managing 
effort, 

the 

tool 
increasing 

Difficulties in interpretation:  Risk indicators and 
information may be difficult to interpret and may 
not align with necessary management controls. 

Data accuracy and updates: Concerns are present 
over  data  reliability  and  timeliness  which  may 
lead  to  potential  inaccuracies  in  risk  assessment 
(false alerts). 

with 

Compatibility 
legislation:  
Challenges exist concerning compliance with data 
protection laws and public information access. 

national 

Training  and  guidance:  More  training  modules 
and  technical  guidance  is  requested  to  reduce 
administrative burden. 

 
 
 
 
 
 
 
 
 
 
 
 
 
1.3. Recommendation  3:  Reinforcing  anti-fraud  governance  in  the  Member 

States 

Member States are requested to keep on reinforcing their anti-fraud governance structures, 
ensuring that they include all relevant players. 

Central to this at Member State level is the adoption of all necessary strategies to fight 
fraud, ideally at national level (by adopting a national anti-fraud strategy). 

1.3.1. State-of-play in national anti-fraud governance structures 

Anti-fraud  governance  largely  remains  unchanged,  with  74%  of  Member  States  noting  no  significant 
developments during the last year16. Governance frameworks typically need time to implement and evaluate new 
strategies and policies. However, Member States express high confidence in their anti-fraud governance structures. 
Among those Member States that did implement changes17, the focus was predominantly on enhancing the role 
and capabilities of Anti-Fraud Coordination Services (AFCOS). Enhanced cooperation and staff training are the 
types  of  support  which  Member  States  most  frequently  requested  for  improving  their  anti-fraud  governance. 
Despite the static nature of current governance structures, Member States have identified several best practices 
aimed at strengthening their anti-fraud strategies. 

16 Austria, Belgium, Bulgaria, Croatia, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, 
Ireland, Lithuania, Malta, Poland, Portugal, Romania, Slovakia, Slovenia, Sweden 
17 Cyprus, Latvia, Luxembourg, Netherlands, Italy, Spain 

 
 
 
 
 
 
 
 
 
 
1.3.2. Best practices in anti-fraud governance 

•  Codified collaboration 

o  Foster  formal  agreements  and  cooperation  protocols  to  coordinate  anti-fraud  actions  within  and 
across  borders.  These  collaborations  enable  shared  best  practices  and  enhance  comprehensive 
monitoring and risk management. 

•  Training and educational initiatives 

o  Emphasise regular interactions and structured training among stakeholders. This strengthens anti-
fraud efforts by enhancing information exchange, ensuring staff are well-prepared to tackle fraud-
related challenges. 

•  Comprehensive monitoring and documentation 

o  Utilise digital technologies and centralised document systems to boost transparency and accessibility. 
These innovations facilitate efficient tracking and real-time data sharing, which are vital for effective 
oversight. 

 
 
 
 
 
 
2. Responses from the Member States 

Q.1.1 Have you reviewed the effectiveness of your reporting in the Irregularity Management 
System (IMS) in 2024? 

Response 

Frequency 

Percentage 

Member States 

YES 

NO 

17 

63.0% 

10 

37.0% 

LT,  SI,  CZ,  ES, 
HU, SK, PL, DE, 
BG, MT, CY, EE, 
RO, PT, LV, DK, 
IT 

IE,  LU,  HR,  SE, 
NL,  FR,  EL,  BE, 
AT, FI 

Q.1.2 If “YES” to Q.1.1, What were the main findings of your evaluation? 

Member 
State 

Response 

LT 

SI 

CZ 

ES 

The evaluation identified that internal institutions in Lithuania are not sufficiently collaborating in 
terms of reporting and sharing information. As a result, there is a gap in communication and data 
exchange, which has affected the overall efficiency of the system. To address this issue, we  are 
actively working on improving these processes to ensure better coordination and more  effective 
information sharing between institutions moving forward 

Some institutions report YES, some institutions report NO. 

Minor shortcomings in closure of cases. 

All the management authorities consulted answered no to this question, except one. In the case of 
the management authority that replied yes, the main finding was that the communications carried 
out have allowed for adequate monitoring 

HU 

The timeliness of recording the status of suspected fraud cases can be improved upon. 

SK 

AFCOS has reviewed the 2024 reporting effectiveness within the IMS internally, and the results are 
positive. We've identified some minor refinements to further improve efficiency. 

PL 

The  effectiveness  of  reporting  in  the  IMS  was  verified  in  2024  by  AFCOS,  which  in  Poland  is 
responsible  for  organising  and  coordinating  the  process  of  reporting  to  the  Commission 
irregularities found in the context of spending EU funds implemented under shared management. 
The results of this verification were described in an analytical document, which was submitted for 
appropriate  use  to  the  relevant  national  reporting  institutions  at  the  next  two  levels  of  the  IMS 
reporting structure.  
The  analysis  covered  the  irregularities  reported  under  the  2014-2020  financial  perspective,  and 
particular attention was paid to cases of (suspected) fraud, as well as the timeliness of reporting 

 
 
 
 
 
Member 
State 

Response 

irregularities. In order to obtain a horizontal view, the analysis also covered the closure status of the 
2007-2013 PP cases in the IMS system. 
It showed that the reporting institutions continued to apply the good practices implemented with 
regard  to  whistleblowing,  which  had  been  developed  and  expanded  over  various  financial 
perspectives. It was found that approx. 2000 reports of irregularities concerning the 2014-2020 PP 
remain open in the IMS due to ongoing investigations by law-enforcement authorities and time-
consuming, challenging recovery proceedings. At the same time, many 2007-2013 PP cases remain 
open, which creates an additional administrative burden for the reporting institutions (the need for 
regular monitoring and appropriate action.  

AFCOS found the results of the analysis satisfactory: it was established that, as a general rule, the 
reporting  deadlines  were  respected  in  relation  to  the  primary  administrative  or  judicial  findings 
(PACA) and that the completeness of the data in individual cases remained high. AFCOS also issued 
appropriate  recommendations  to  speed  up  efforts  to  bring  cases  from  the  previous  financial 
perspectives to a close so that attention could be redirected to the 2021-2027 PP, which is already 
being implemented. 

As examples: The Schleswig-Holstein ERDF Managing Authority: Reporting functions reliably and 
effectively thanks to detailed provisions in the guidance on anti-corruption/anti-fraud measures and 
irregularities.  

The Saarland ESF Managing Authority: Reports of irregularities were followed up until the case 
was closed, and the comments of the BMS were taken into account and fed back. Corrections were 
made to cases. No cases of fraud. 

We prepared an Analysis of the reported irregularities for 2023 where we have made a statistical 
analysis  of  the  reported  fraudulent  and non-fraudulent  irregularities  on  national  level  and  in  the 
IMS. Also, we have made a review of the national procedures for administering of irregularities. 
The general conclusion is that the reporting system provides timely, correct and complete reporting 
of irregularities.  

The IMS is currently updated to include the new look and feel. After reviewing the reporting in the 
IMS  in  2024,  it  was  found  that  the  reporting  was  done  correctly,  with  filled  in  up-to-date  and 
comprehensive information. The identified gaps are of a technical nature, due to the large volume 
of  cases,  and  are  being  eliminated  in  a  timely  manner  and  within  the  work  process.  
The reporting in IMS follows the reporting in Information System for Management and Monitoring 
EU Funds in Bulgaria 2020 (ISUN2020). The reporting in both systems is double checked by the 
AFCOS  which  tackles  the  mistakes  that  may  occur.  The  reported  cases  of  suspected  fraud  are 
updated in a timely manner with reliable and complete information and data.  

A  control  is  introduced  by  a  second  Irregularity  Officer  and  Supervising  Manager  in  order  to 
improve the irregularity reporting. 

The Maltese AFCOS already has effective reporting measures in place. In addition, in 2024, the 
Financial Investigations Directorate (FID) within the Internal Audit and Investigations Department 
(IAID),  in  its  role  as  the  Maltese  AFCOS,  has  been  strengthened  with  the  recruitment  of  new 
personnel, who are primarily responsible for reporting of irregularities in IMS. This is ensuring that 
the four-eyes principle is always adhered to (IMS Creator inputs a case; IMS Manager finalizes the 
case).  

DE 

BG 

MT 

 
 
 
  
Member 
State 

Response 

Once a case is closed, the Maltese AFCOS confirms that any data already inputted in IMS is correct 
by reconciling this data with the latest information received from the relevant Authorities.   

CY 

Issues with coordination between various entities regarding the status of cases, issues with timely 
reporting between entities. 

EE 

Estonian AFCOS, as the IMS Country Officer, checks open cases in the IMS annually to follow the 
quality  and  continuity  of  reports  and  supports  the  reporting  authorities  with  knowhow.  
Estonian  Cohesion  Policy  Managing  Authority  regularly  carries  out  checks  on  the  reporting  of 
irregularities to ensure whether the data is accurate. In general, the system works well, with minor 
errors  occurring  occasionally.  Cases  that  have  been  referred  to  investigative  bodies  are  more 
complex  to  report,  as  early-stage  notification  is  often  not  possible.  Premature  reporting  could 
jeopardize  the  investigation  and  subsequent  criminal  proceedings.  For  such  cases,  we  await 
authorization from EPPO or the other investigative body before reporting.  
On a positive note, cooperation between the implementing agencies, the Managing Authority, and 
AFCOS is functioning, and we have an overview of the cases under investigation. 

- The Department for the Fight Against Fraud - DLAF: Communication is conducted in a timely 
manner, data completeness has been improved, solid cooperation with the reporting authorities. 

-  Paying  Agency  for  Rural  Investments  (AFIR):  No  deficiencies  in  the  method  of  reporting 
irregularities or system deficiencies were detected.   

- The Ministry of Agriculture and Rural Development  - Managing Authority for the Operational 
Programme for Fisheries and Maritime Affairs (DGP-AMPOPAM): Irregularities were reported in 
the  IMS  for  all  notifications  and  verifications  of  which  the  Managing  Authority  was  aware. 
However,  there  were  cases  of  delays  in  the  information  received  from  the  institutions  with 
audit/control  functions  concerning  the  submission  of  cases  for  investigation/verification  to  the 
judicial authorities. This then affected the reporting. 

RO 

- The Ministry of Energy: The suspected irregularities related to: (1) setting up project teams with 
overlapping tasks and activities, failing to respect the guide on the call for projects, (2) the legal 
regime governing documents, (3) the justification for co-financing. 

- The Ministry of Investments and European Projects (MIPE) – Directorate-General for Sustainable 
Development Programmes (DGPDD): The effectiveness of reporting was found to have improved, 
due to the  updating of operational procedures, the frequency of use  of prevention tools, and the 
performance of fraud risk assessment. 

- The Ministry of Investments and European Projects (MIPE) – Managing Authority for the Human 
Capital Operational Programme (MA POCU): The reporting system has been improved compared 
to  the  version  from  the  previous  year.  The  criteria  for  filtering  previously  notified  irregularity 
reports  do  not  allow  for  identification  using  the  internal  reference  number.  The  history  of 
irregularity reports by operational programme can be consulted only by exporting the data available 
on each page viewed. 

PT 

LV 

As regards the irregularities related to the Cohesion Policy Funds in the 2014-2020 PP, there was 
some delay in the reporting to OLAF. Procedures are being reviewed to improve coordination and 
the timely reporting of irregularities. 

For  the  Ministry  of  Agriculture  and  Rural  Support  Service:  The  reporting  process  is  working. 
Reports are submitted complete in terms of content, updated in a timely manner where necessary 

 
 
 
Member 
State 

Response 

with  reliable  and  complete  information  and  data,  and  submitted  within  the  specified  deadlines. 
Information  exchange  and  cooperation  between  institutions  is  working  and  continuously 
developing. Communication channels (official correspondence) and operational communication are 
appropriate. 

Most of the contributions to the survey reported a “No” in Q.1.1.  

DK 

The Danish Agency for Green Land Conversion and Water Environment reported “Yes” and noted: 
The reporting authority performs ongoing quality checks of our reporting to make it uniform and 
complete. 

IT 

The review of the Irregularity Management System (IMS), performed on an ongoing basis by the 
national  liaison  officers,  gives  an  essentially  positive  picture  as  regards  the  consistency, 
completeness  and  correctness  of  the  data.  This  is  primarily  thanks  to  continuous  analysis, 
monitoring and control of reports, carried out at central level in close connection and consultation 
with the managing authorities, both when reports are sent and when they are updated. 

For example, it is worth passing on the information received from the Ministry of Education and 
Merit, within whose remit, in 2024, the MA for the NOP/NP ‘School’ reported 5 cases to the IMS, 
classifying them as IRQ2 ‘irregularities’. In compliance with the [national] ‘Guidelines on how to 
notify the European Commission of irregularities and fraud against the EU budget’, the reports in 
question were preceded by careful internal investigations. These took account of the findings of the 
inspections  ordered,  the  on-the-spot  checks  carried  out  at  beneficiaries,  the  details  obtained 
following  dialogue  with  beneficiaries,  and  the  information  obtained  via  feedback  from  external 
control  bodies  so  as  to  ascertain  whether  any  criminal  proceedings  were  ongoing  for  suspected 
criminal offences against the EU budget in respect of the NOP ‘School’ projects being examined. 
The reports can thus be considered effective as they are complete, timely, detailed and reflect the 
findings of all the checks carried out. 

Q.1.3 How  would you  evaluate your level of maturity of your  current  reporting process for 
reporting irregularities and, in particular, fraud? 

Response 

Frequency 

Percentage 

Member States 

We use a well-established reporting system capturing 
all  relevant  data  on  suspected  fraud  cases  and 
irregularities 

11 

40.7% 

We have a strong reporting system but with some gaps 
in capturing all relevant data 

9 

We  are  currently  improving  our  reporting  system  to 
better  capture  and  report  suspected  fraud  cases  and 
irregularities 

Other (please specify) 

5 

2 

LU,  FR,  AT,  FI, 
CZ,  SK,  PL,  DE, 
MT, EE, RO 

HR,  SE,  BE,  SI, 
HU, BG, LV, DK, 
IT 

NL, EL, LT, CY, 
PT 

33.3% 

18.5% 

7.4% 

IE, ES 

 
 
 
 
Following Q1.3, please specify "Other". 

Member 
State 

Response 

IE 

ES 

The vast bulk of expenditure is incurred initially via the Central fund/Vote management process 
and  comes  under  the  anti-fraud  policy  of  the  relevant  Department.  It  is  subject  to  audit  by  the 
Comptroller and Auditor General and where any instances of irregularities are discovered they are 
reported  where  required  and  excluded  from  the  payment  application  submitted  to  the  European 
Commission. Fraud and suspected fraud are reported as required. 

Some managing authorities have replied ´We use a well-established reporting system capturing all 
relevant data on suspected fraud cases and irregularities´ while others have replied ´We are currently 
improving our reporting system to better capture and report suspected fraud cases and irregularities´. 

Q.1.4 Can you provide examples of well-established reporting systems or practices that have 
been effective in capturing and reporting suspected fraud cases and irregularities? 

Member 
State 

Response 

IE 

LU 

HR 

All fraud and suspected fraud cases are reported using the IMS. All payments are checked by the 
MAs and where an irregularity is found the case is removed from the payment claim. 

Prior checks, ex-post checks, regular risk analysis and follow-ups in addition to support/guidance 
for beneficiaries. 

Contribution from Ministry of Finance, Tax Administration:  

The Tax Administration has a special Unit that cooperates with the European Public Prosecutor's 
Office  (further  in  the  text:  EPPO)  and  other  criminal  prosecution  bodies  on  investigations 
(Independent Sector for Financial Investigations). 

Contribution from AFCOS unit:  

AFCOS  unit  drafts  Irregularity  Management  Guidelines  that  contain  procedures  describing 
proceedings  in  the  area  of  prevention  and  detection  of  irregularities;  proceedings  related  to 
suspicions of irregularities and identified irregularities, reporting on irregularities and follow-up of 
reported irregularities in the context of management and control of using EU funds. The objective 
of the Guidelines is to develop consistent practice in applying legal framework for the protection of 
European Union financial interests and to ensure high quality of irregularity reports.   

Furthermore, AFCOS unit performs check of technical correctness of irregularity reports sent by 
Management and Control system bodies (further in the text: MCS bodies). If errors and/or omissions 
are detected during such a check, AFCOS unit rejects such reports, and it provides instructions for 
modification / correcting the report.  

Finally, AFCOS unit provides trainings on the use of IMS. There are basic one-on-one trainings 
intended for each new IMS user during installation of IMS certificate, consultations with current 
users and periodical trainings for a larger number of trainees (e.g. employees of MCS bodies for a 
certain programme). Finally, user support in the form of phone consultations is ensured at any time.  

SE 

Irregularities and suspected fraud are detected during project audits and controls. The authorities 
have an expert function in support of administrators, covering compliance and the countering of 

 
 
 
Member 
State 

Response 

irregularities.  Case  handlers  responsible  for  payments  are  required  to  report recoveries, and  any 
recoveries decided on are followed up. It is also ensured that suspected fraud cases are reported. 

NL 

n/a 

FR 

EL 

BE 

For CAP funds, agricultural irregularities are reported to the Secretariat of the CICC EAGF by the 
four paying agencies (ASP, FRANCEAGRIMER, ODARC and ODEADOM). The data are checked 
carefully by the bodies responsible, then forwarded to the Secretariat to be verified, coordinated and 
validated. 

Recovery and Resilience Facility Coordination Agency (RRFA): Regulation (EU) 2021/241 does 
not  require  Member  States  to  use  the  Irregularity  Management  System  (AFIS/IMS)  to  report 
irregularities  found  in  Recovery  and  Resilience  Facility  projects  to  the  European  Commission. 
Nevertheless,  relevant  information  is  sent  to  OLAF  by  email,  setting  out  all  the  relevant  data 
concerning  the  irregularities  or  suspected  cases  of  fraud  as  referred  to  in  the  Irregularity 
Management System (IMS). In any case, it should be noted that to date, no irregularities giving rise 
to the suspicion of fraud have been detected. 

ERDF,  JTF  and  RRF  at  the  SPW  (Walloon  Public  Service):  The  OLAF  working  group  meets 
quarterly. It is charged by the Walloon government with reporting irregularity cases to OLAF where 
this is required or reporting an absence of irregularity cases, pursuant to EU rules and with reference 
to the European Development Fund (ERDF), the Just Transition Fund (JTF) and Wallonia’s parts 
of the National Recovery and Resilience Plan (NRRP) and the Brexit Adjustment Reserve (BAR). 
The working group is made up of members representing the various administrations responsible. 
Minutes  are  taken  of  all  OLAF  working  group  meetings. These  set  out  the  proposals  put  to  the 
working group members for examination, and, for in-person meetings, the decisions taken by the 
working group, as well as all the related documents sent to all members following the meeting. The 
secretariat reports irregularities to OLAF electronically. If, for the period concerned, there are no 
irregularities that need to be reported, the secretariat also reports this fact to OLAF electronically. 
Suspicions of fraud involving criminal offences are passed on to the Belgian judicial authorities. 

AT 

The  Federal  Ministry  of  Agriculture’s  IMS  reporting  system  focuses  on recoveries  made  by  the 
Paying Agency and determines their causes on a case-by-case basis. 

The  intermediate  bodies  for  the  EU's  regional  and  structural  policy  programme  systematically 
record  all  suspected  fraud  and  other  observations  in  the  programme's  EURA  2021  information 
system.  

FI 

LT 

During the training organised for the intermediate bodies by the managing authority for regional 
and structural policy, the importance of a low threshold for reporting crimes was emphasised. Where 
necessary, the intermediate body also reports suspected fraud to the European Public Prosecutor's 
Office 
provides.  
Where required, the managing authority provides the intermediate bodies with support and guidance 
in cases of suspected fraud. The central authorities responsible for the management and control of 
programmes are responsible for reporting via the Irregularities Management System (IMS). 

accordance  with 

instructions 

(EPPO) 

EPPO 

the 

the 

in 

One example of an effective reporting system in addressing suspected fraud and irregularities is the 
strengthened collaboration between the European Union (EU) funds management agencies and the 
Financial Crime Investigation Service (FCIS) in Lithuania. This partnership aims to ensure timely 
receipt  of  information  and  proper  processing  of  data.  By  fostering  better  communication  and 

 
 
Member 
State 

Response 

SI 

CZ 

ES 

HU 

SK 

PL 

coordination  between  these  institutions,  the  system  improves  the  detection  and  reporting  of 
irregularities and fraud related to EU funding, enhancing overall effectiveness and responsiveness 
in combating financial crimes 

no 

Carefully  developed  methodological  environment  within  each  programming  period,  national 
monitoring systems, centralised recording. 

(1) The existence of irregularities may be detected by any of the bodies involved in the management 
of the funds and will in all cases be recorded in their FAMI III (formerly FAMI II) application, prior 
to the relevant communication to the Commission.  

(2) The authority which has definitively established the existence of the irregularity to be reported 
to OLAF shall register it in the IMS (Irregularities Management System). Once the irregularity has 
been reported in the IMS system, the relevant box shall be ticked in the FAMI III application.  

(3) The Control Unit shall be responsible for the follow-up of reported irregularities and, where 
appropriate, related administrative and judicial proceedings and shall keep the Managing Authority 
and  the  Intermediate  Body  informed  so  that  they  can  take the  necessary fraud  risk  management 
measures. 

There has been long-standing and successful cooperation between national reporting organisations 
and  Anti-Fraud  Coordination  Services  (AFCOS).    AFCOS  organises  quarterly  meetings  for  the 
Irregularity  Reporting  Working  Group  with  the  participation  of  national  reporting  bodies 
(Managing  Authorities,  Certifying  Authority,  Paying  Agency  and  judicial  bodies)  to  support 
reporting  in  IMS.  AFCOS  also  provides  practical  IMS  training  on  reporting  obligations  and 
experience to Hungarian users on an annual basis. These measures form an important element of 
the action plan for an anti-fraud and anti-corruption strategy for EU funds. 

their 

within 

system 

updates 

information 

republic  has  a  well-functioning  national 

The  Slovak 
(ITMS/ 
ITMS2014+/ITMS21+)  for  Cohesion  policy.  According  to  the  national  law,  the  Managing 
Authority and the Intermediate Body  are required to provide information about any irregularities 
and 
the  
15 
typical qualification of irregularities (IRQ2, IRQ3 and IRQ5), we have also introduced an additional 
identification SIG “signal of irregularity”, which represents an initial detection of a violation. At 
this stage, the irregularity is already recorded in the national information system. This indicator SIG 
helps us, at the national level, to improve the detection and reporting of irregularities. Another well 
-functioning system for collecting data in the agricultural funds is AGIS MFR information system. 
The  reports  from  these  systems  are  inserted  into  IMS.  JEMS  -  IT  system  is  another  IT  tool  for 
Interreg used at the national level which collects data of the beneficial owner data. 

working 

Among 

days. 

Under  the  Code  of  Criminal  Procedure,  central  and  local-government  institutions  in  Poland 
(including the institutions of the management and control system for EU funds) are legally obliged 
to  report  to  the  law  enforcement  authorities  criminal  offences  prosecuted  ex  officio  where  such 
offences are detected by those institutions in the course of their activities. Reporting an offence may 
give rise to an investigation or inquiry. When reporting a criminal offence, it is necessary to provide 
evidence  to  substantiate  the  suspicion,  which  is  why  the  reporting  institutions  make  their  own 
findings, taking into account the information and data identified, including data from dedicated IT 
tools supporting the fight against fraud. Where applicable, information on suspected fraud and on 

 
 
Member 
State 

Response 

the involvement of law enforcement authorities is reflected in the IMS, in accordance with the rules 
resulting  from  the  relevant  EU  sectoral  regulations  and  the  national  procedure  that  has  been 
designed in line with those regulations. 

An example of good practices ensuring that cases of suspected fraud are reported to the Commission 
is the cooperation agreement between the National Public Prosecutor and the Minister responsible 
for regional development, which regulates the provision of information on ongoing and concluded 
proceedings concerning projects co-financed by European funds. On the basis of that agreement, 
there is a regular exchange of data on the beneficiaries of EU funds against whom investigative 
measures have been taken, and some institutions also make use of the possibility to directly contact 
the designated representatives of the Public Prosecutor’s Office where it is necessary to obtain data 
on ongoing proceedings without delay.  

solutions 

that  have  been 

include:  
Examples  of 
1. agreements on the transmission to the organisational units of the Central Anti-Corruption Bureau, 
by  means  of  distance  communication,  of  information  collected  in  the  ICT  systems  SL2014  and 
CST2021 supporting the implementation of the programmes;  

implemented 

in  Poland 

also 

2.  cooperation  agreements  between  the  Minister  responsible  for  regional  development  and  the 
Agency  for  Restructuring  and  Modernisation  of  Agriculture  (the  Paying  Agency)  concerning 
cooperation: 

(a)  as  regards  the  implementation  of  cross-checks  aimed  at  detecting  and  eliminating  double 
financing of cohesion policy expenditure and agricultural and fisheries programmes under the 2014-
2020 PP; 
b)  as  regards  the  exchange  of  data  on  beneficiaries  implementing  projects/operations/actions  in 
programmes under: Cohesion Policy 2021-2027, the European Funds for Fisheries Programme and 
the Strategic Plan for the Common Agricultural Policy 2023-2027 (CAP SP);   
c)  as  regards  the  implementation  of  cross-checks  aimed  at  detecting  and  eliminating  double 
financing of expenditure under SP, FERS and the CAP SP;  

3. granting designated OLAF and EC staff access to the SL2014 main application in order to enable 
independent analysis of information on applicants, beneficiaries, expenditure items being settled 
and checks; 

4. the Paying Agency’s procedures to ensure the collection and use of fraud-related data (dedicated 
databases  that  allow  the  recording  of  suspected  and  proven  fraud  cases,  operated  by  all 
organisational units of the Agency and entities performing delegated tasks which are involved in 
the  detection  of  irregularities  and  fraud;  the  data  collected  significantly  facilitate  the  analysis, 
investigation and prevention of detected and suspected fraud cases). 

All these arrangements are effective in contributing to detecting cases of irregularities, including 
cases  of  suspected  fraud  (which  results  in  reports  being  submitted  to  the  Commission,  where 
appropriate).  

In general: 
Drawing  on  IMS  data  findings  and  the  corresponding  explanations  from  the  reporting  bodies; 
regular exchanges with the managing and audit authorities. Below are examples from the competent 
ministries and ERDF authorities: 

DE 

The Federal Ministry of Labour and Social Affairs (BMAS): In the context of the European Social 
Fund Plus (ESF Plus), there is a guidance document for the ESF Plus Federal Programme which 
deals with the reporting of irregularities (including suspected cases of fraud). Under the ESF Plus 

 
 
 
 
Member 
State 

Response 

Federal Programme, cases are examined by the managing authority and the intermediate managing 
bodies. Where necessary, the managing authority instructs the relevant granting authority to take 
action, which may include, in particular, an on-the-spot check. The granting authority sends an IMS 
report to OLAF and, where necessary, notifies the offence to the national public prosecutor’s office 
or the European Public Prosecutor’s Office. 

The Bremen ERDF Managing Authority: The intermediate bodies implement operations. Potential 
cases of fraud are reported to the managing authority while, at the same time, detailed checks are 
carried out in order to either confirm or dispel the suspicion of possible fraud. If the suspicion of 
fraud is confirmed, the intermediate body in turn notifies the managing authority and the public 
prosecutor’s office. 

The Lower Saxony ERDF Managing Authority: Direct reporting to law enforcement has proven 
effective.  Furthermore,  the  establishment  of  the  Investitions-  und  Förderbank  Niedersachsen 
(NBank) has proven to be the only intermediate body. The centralisation of the implementation of 
all EU funding programmes to only one body guarantees the proper fulfilment of the tasks assigned 
and a sustainable flow of information. 
In  addition,  the  retention  of  the  100%  verification  of  supporting  documents  contributes  to  a 
significant reduction in the number of suspected fraud cases within the framework of the calls for 
funds.  The  Schleswig-Holstein  ERDF  Managing  Authority:  Communication  channel  with  the 
public prosecutor’s office; timely reporting of any suspicion, backed up by legal expertise. 

The  national  reporting  system  is  based  on  the  rules of  the  National  regulation for  administering 
irregularities  and  the  Methodological  guidelines  for  administering  irregularities  issued  by  the 
AFCOS  Directorate.  They  transfer  on  the  national  level  the  EU  regulations,  the  Handbook  on 
reporting  irregularities  in  shared  management  and  the  IMS  manuals.  The  effective  work  of  the 
national reporting system is guaranteed by regular trainings for the irregularity officers and a regular 
control of the compliance with the rules by the AFCOS Directorate.    
For instance, in cases of suspected fraud, after performed administrative proceedings on submitted 
signal for irregularity the “Territorial Cooperation Management” (TCM) Directorate at the Ministry 
of  Regional  Development  and  Public  Works  (MRDPW)  is  obliged  to  send  the  case  to  the 
Prosecutor’s Office. 
After  performed  investigation  the  TCM  Directorate  is  informed  about  the  prosecutor’s  decision 
whether there are/ are not enough grounds to open an investigation or abandons an investigation 
that has been opened.  
Our  reporting  system  contains  clearly  defined  rules  and  processes  with  specifically  named 
responsible persons for every task. There are check-lists to ensure rightful completion of the tasks. 

We report fraud cases and irregularities in 1-month period after every quarter in both ISUN2020 
and IMS. We are also kept in touch with the prosecutor office every 6 months for decisions on fraud 
cases.    
When the need arises, joint inspections are carried out with the AFCOS Directorate at the Ministry 
of  Interior;  Methodological  instructions  are  provided  by  the  AFCOS  Directorate  for  the 
administration of irregularities; Position from the AFCOS is given, including by phone/e-mail on 
the correct proceeding with the administration of irregularities; 
The  AFCOS  Directorate  gives  instructions  on  the  correct  entry  of  information  into  IMS;   
Trainings  for  irregularity  stuff  conducted  by  the  AFCOS  Directorate  is  available,  regarding 
operations with IMS and administration of irregularities. 

BG 

 
 
 
 
 
 
 
 
 
Member 
State 

Response 

The Prosecutor’s Office of the Republic of Bulgaria (PORB) is a key institution in the fight with 
crimes against the EU’s financial interests in Bulgaria.  
By order of the General Prosecutor in 2021, in parallel with the start of the work of the EPPO, 
Department  08  “Crimes  against  the  EU’s  financial  interests  and  interaction  with  the  European 
Public Prosecutor’s Office” within the Supreme Cassation Prosecutor’s Office (at that time) was 
established in order to organize and ensure the interaction between the Prosecutor’s Office of the 
Republic of Bulgaria (PORB) and the European Public Prosecutor’s Office, as well as optimizing 
the  work  of  the  Bulgarian  prosecutors  on  files  and  pre-trial  proceedings  for  crimes  against  the 
financial 
The  fore-mentioned  department  became  contact  point  between  PORB  and  OLAF,  managed  to 
achieve very high results in various directions of countering the crimes associated with European 
funds,  as  well  as  in  increasing  the  efficiency  in  cooperation  and  reporting  with  all  national  and 
international partners in the field.   
All strategic analysis and targeted reports from the Commission, OLAF, EPPO, etc. are received, 
analysed,  taken  into  account  and  practically  implemented  according  to  the  competences  of  the 
Prosecutor's Office. Cooperation agreement on interaction and cooperation between the Prosecutor's 
Office of the Republic of Bulgaria and the Ministry of Interior in countering offenses affecting the 
EU’s financial interests was signed on 11.06.2024. 

interests 

the 

of 

EU.   

The Maltese AFCOS receives all irregularity reports from the Managing Authorities of EU Funds 
on  a  quarterly  basis,  which  reports  are  reviewed  based  on  standing  regulations  and  guidelines.    

On a quarterly basis, the Maltese AFCOS also holds the Irregularity Reporting Sub-group meeting 
with  the  Managing  Authorities  of  EU  Funds,  Audit  Authority  and  Paying  Agency  to  ensure  the 
correct reporting of irregularities to OLAF via IMS.  

to 

indicate 

Under selected shared management programs there is an automated process when documenting an 
irregularity 
For  Cyprus  Agricultural  Payment  Organisation-  The  reporting  system  is  integrated  into  the 
information systems used by CAPO for administrative checks and in the accounting information 
system. Data can be retrieved and accessed automatically. 

requirement 

irregularity 

complete 

the 

an 

to 

report.   

Main  weaknesses  arrive  from  non-shared  management  programs/direct  management  from 
Commission/Territorial Cooperation programs where more than one MS authorities are involved.   

In  our  national  grants  information  system,  each  project  has  a  module  for  irregularities  where 
information about specific project-related irregularities is entered, if necessary, with the same level 
of  detail  as  the  information  reported  to  OLAF.  All  cases  of  suspected  irregularities  or fraud  are 
recorded from the first euro cent, and the information remains even if it is later determined during 
the proceedings that no irregularity or fraud has occurred. Estonia uses a single grants information 
system that encompasses projects from various funds (ESI Funds, RRF, Norway/EEA, AMIF/ISF 
national support etc), enabling the implementing agency to check whether the beneficiary has had 
any  irregularities  and  what  kind.  The  same  information  system  has  been  in  use  for  several 
programming periods, allowing us to also see irregularities from previous periods.  
We have a similar reporting system for AGRI/FISH funds too. We have  created a possibility to 
perform cross-checks between these two systems. The persons who have right to do cross-checks 

MT 

CY 

EE 

 
 
 
 
  
 
 
Member 
State 

Response 

can  see  whether  the  beneficiary  has  irregularities  in  other  system.  For  more  details  they  must 
communicate with the owner of this project. 

- DLAF: Clear reporting regulations. Obligation to designate an irregularity officer in the reporting 
authority. Solid cooperation with the reporting authorities and continuous training of staff involved. 
Interinstitutional cooperation protocols. Operational irregularity reporting network. 

- The Ministry of Energy: REGAS platform, ARACHNE platform. 

- MIPE – DGPDD - Reporting of all cases of suspected fraud recorded in the RD and in the other 
records specific to the activity of detecting irregularities and fraud, in accordance with operational 
procedures. 

- MIPE – Directorate-General for Health Programmes (DGPS): A communication channel with the 
National  Anticorruption  Directorate  (DNA)  has  been  created  (contact  person  at  MIPE  level  and 
exchange  of  information  from  a  specific  e-mail  address  through  the  contact  person),  since  the 
exchange  of  information  with  the  national  investigative  authorities  and  timely  reporting  are 
prerequisites for effective monitoring. 

RO 

OP 

aspects 

included 

DGMMRR 

-  MIPE  –  Directorate-General  for  Management  of  the  Recovery  and  Resilience  Facility 
(DGMMRR): 
A)  Reporting  based  on  controls  by  the  National  Coordinator  the  Audit  Control,  Recovery  and 
Monitoring Service of the DGMMRR performs the following activities: 
1. The control mandate is issued in the event of confirmation of the suspicion of irregularity/serious 
irregularity/ whistleblowing, where this is confirmed on the basis of checks carried out in light of 
No  
in 
the 
10- ‘Checklist for suspensions of irregularity/fraud and mandate approval’. The persons included 
in the control mandate must make declarations concerning: - the absence of conflict of interest, - 
impartiality and confidentiality.    
2. If there is a notification regarding a suspicion of  fraud and if this is confirmed by the  checks 
carried out on the checklist included in Procedure No 10, the control mandate will be issued. Based 
on the control findings and if the suspicion of serious irregularity is confirmed by the evidence, the 
control team applies Government Emergency Ordinance No 70/2022, as amended, in which case 
the control body will notify the DLAF/OLAF, EPPO/DNA or other relevant prosecution authorities 
as 
(immediately). 
B) Reporting based on controls by the reform and/or investment coordinators through the National 
Coordinator in line with the following provisions: 
i)  EMERGENCY  ORDINANCE  No  70/2022  on  the  prevention,  verification  and  detection  of 
irregularities/double funding, and serious irregularities found in obtaining and using external grants 
and loans allocated to Romania through the Recovery and Resilience Facility and/or national public 
funds related to them and the recovery of the resulting debts, ii) EMERGENCY ORDINANCE No 
124/2021 establishing the institutional and financial framework for the management of European 
funds  allocated  to  Romania  under  the  Recovery  and  Resilience  Facility  and  amending  and 
supplementing Government Emergency Order No 155/2020 on certain measures for drawing up the 
National Recovery and Resilience Plan necessary for Romania to obtain external grants and loans 
under  the  Recovery  and  Resilience  Facility.  The  reform  and/or  investment  coordinators  provide 
immediate/quarterly notification through (the Register of suspected irregularities/fraud and debtors) 
the specialised control body within the MIPE - the National Coordinator (NC) of referrals made by 
the bodies it coordinates and their result (debt securities/debt recovery notes), or whenever the NC 

possible 

soon 

as 

 
 
 
 
 
 
 
 
Member 
State 

Response 

so requests, concerning the status of the recovery of budget debts/the finalisation of the recovery 
process. 

- Ministry of the Environment, Water Resources and Forestry (MMAP): Reporting of all cases of 
suspected fraud recorded in the  RD and in the other records specific to the  activity of detecting 
irregularities and fraud, in accordance with operational procedures. 

PT 

The information system aggregating the results of administrative checks, on-the-spot checks and 
audits  in  the  context  of  the  collection,  storage,  processing  and  reporting  of  irregularities  and 
suspected fraud cases has been optimised. 

LV 

There are no specific examples. 

DK 

IT 

The Danish Business Authority reported that potential whistleblowers have the opportunity to make 
contact and draw attention to a situation anonymously by making use of a whistleblower scheme. 

The  managing  authority  makes  use  of  an  external  auditor  that  is  obliged  to  tell  the  managing 
authority if they encounter a case of possible fraud. 

to 

in 

the 

the 

the 

quality 

information 

At the start of 2024, the Guardia di Finanza Unit for Combatting Fraud against the European Union, 
as  technical  secretariat  of  the  Committee  for  Combatting  Fraud  against  the  European  Union 
(COLAF), issued all managing authorities with specific ‘Guidelines for improving the procedures 
for filling in/populating irregularity/fraud reporting forms in the IMS’. The aim of these guidelines 
was 
IMS. 
of 
improve 
Specifically, the guidance concerned: 
a.  how  to  create,  save  and  finalise  irregularity/fraud  reporting  forms,  with  specific  reference  to 
populating the various fields correctly, fully and consistently; 
b. the timescales for updating cases as new developments occur; 
c. details of case types in previous programming periods; 
d.  drafting  of  the  special  report  in  cases  where  sums  to  be  charged  to  the  EU  budget  are 
irrecoverable; 
e. updating of cases in the system that have already been closed (e.g. owing to decertification, total 
recovery, etc.) but for which the associated judicial/administrative/accounting proceedings are still 
ongoing; 
f.  close  monitoring  of  all  cases  in  the  system  in  which  the  judicial  authorities  are  known  to  be 
involved. 
In  addition,  should  difficulties  arise  in  any  dialogue  with  the  judicial  authorities,  the  competent 
managing  authorities  have  been  given  permission  to  immediately  contact  the  aforementioned 
Guardia  di  Finanza  Unit,  which  will  provide  support  including,  where  possible,  by  facilitating 
involved. 
contact 
These  guidelines  have  helped  to  make  the  reporting  of  suspected  fraud  and  irregularities  more 
effective. 
To use the example of a specific case, the MA of the Ministry of Education and Merit’s NOP/NP 
‘School’  has  stated  that  the  system  for  detecting  and  subsequently  reporting  irregularities  or 
suspected fraud is composed of various stages that can be concisely summarised as follows:  
- detection: via ordinary first- and second-level checks, checks by higher-ranking control bodies, 
checks ordered following reports from third parties (e.g. complaints, reports, news stories, etc.);  
- assessment and examination of cases detected through e.g. specific on-the-spot checks, inspections 
at beneficiaries’ premises by the competent Regional Education Department (USR), and procedures 

prosecutors 

judges 

with 

the 

or 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Member 
State 

Response 

for dialogue and information exchange with external control bodies where information has been 
proceedings; 
received 
- reporting: a report is made once the checks ordered have been completed, if conditions requiring 
the MA to make a report are fulfilled. 

criminal 

possible 

ongoing 

relevant 

on 

Q.1.5 Have you identified in 2024 new weaknesses in your reporting practices that could hinder 
the timely and exhaustive reporting in IMS, in particular of suspected fraud cases? 

Response 

Frequency 

Percentage 

Member States 

NO 

YES 

23 

85.2% 

IE,  LU,  HR,  SE, 
NL,  FR,  EL,  BE, 
AT,  FI,  LT,  CZ, 
HU, SK, PL, DE, 
BG, MT, RO, PT, 
LV, DK, IT 

4 

14.8% 

SI, ES, CY, EE 

Q.1.6 If “YES” to Q.1.5, in which of the following areas did you encounter new difficulties? 

Response 

Frequency 

Percentage 

Member States 

Providing high quality and complete data in suspected 
(and established) fraud reporting 

Reporting suspected fraud in a timely manner 

Other (please specify) 

Reporting all cases of suspected fraud 

Technical issues with the reporting system (IMS) 

4 

3 

2 

2 

1 

14.8% 

SI, ES, CY, EE 

11.1% 

SI, ES, EE 

7.4% 

7.4% 

3.7% 

CY, EE 

SI, ES 

ES 

Following Q1.6, please specify "Other". 

Member 
State 

Response 

CY 

EE 

Programs funded directly by EU not under shared management e.g. RRF or Erasmus programs or 
CEF programs where the initiation of the process may come from EPPO or another MS. 

In cases under criminal investigation where the investigation has been initiated by the investigative 
body on its own initiative, the implementing agency often lacks sufficiently detailed information 
about  the  circumstances.  As  a  result,  it  is  not  possible  to  prepare  comprehensive  reporting. 

 
 
 
 
 
Member 
State 

Response 

Additionally, reports cannot always be created or notifications made without authorization from the 
investigative body, as this could hinder a swift and effective investigation. 

Q.1.7 Have you made significant improvements to the quality of your reporting on suspected 
fraud cases and irregularities in 2024? 

Response 

Frequency 

Percentage 

Member States 

NO, it was not necessary 

9 

33.3% 

YES,  we  have  improved  the  completeness  of  the 
reporting 

9 

33.3% 

YES, we have improved the accuracy of the reporting  7 

25.9% 

NO, not yet 

5 

18.5% 

YES, we have improved the timeliness of the reporting  5 

18.5% 

SE,  BE,  AT,  CZ, 
DE, MT, EE, LV, 
DK 

FR,  EL,  SI,  ES, 
PL,  BG,  RO,  PT, 
IT 

SI,  PL,  DE,  BG, 
RO, PT, IT 

HR,  NL,  LT,  ES, 
CY 

FI,  HU,  SK,  RO, 
IT 

Not applicable 

NO 

3 

1 

11.1% 

IE, LU, SI 

3.7% 

DE 

Q.1.8 What are the main steps you have taken to improve the reporting of irregularities? 

Response 

Frequency 

Percentage 

Member States 

Enhanced training for staff members 

16 

59.3% 

Improving exchange of information with investigative 
bodies 

12 

Increase  of  the  collaboration  with  law  enforcement, 
prosecution services and/or other national authorities 

11 

44.4% 

40.7% 

HR, FR, EL, AT, 
FI,  ES,  HU,  SK, 
PL, DE, BG, CY, 
EE, RO, DK, IT 

SE,  LT,  SI,  HU, 
SK, DE, BG, CY, 
EE, RO, DK, IT 

LT,  SI,  HU,  DE, 
BG, CY, EE, RO, 
PT, DK, IT 

 
 
 
 
Response 

Frequency 

Percentage 

Member States 

Modifying policies and procedures 

11 

40.7% 

SE,  BE,  LT,  ES, 
SK,  PL, DE,  BG, 
CY, RO, PT 

LU,  HR,  BE,  SI, 
MT, RO 

IE,  HR,  NL,  CZ, 
MT, RO 

HR,  SI,  ES,  RO, 
PT 

22.2% 

22.2% 

18.5% 

14.8% 

IE, AT, ES, LV 

3.7% 

3.7% 

RO 

RO 

Hiring  additional  human 
to  manage 
reporting  requirements,  including  data  entry  and 
analysis 

resources 

Other (please specify) 

Better  technical  infrastructures  /  adoption  of  new  IT 
tools 

No steps taken to improve the quality of reporting 

Allocation of more resources for system upgrades and 
maintenance 

More  formalised  communication  channels  with  EU 
bodies 

6 

6 

5 

4 

1 

1 

Following Q1.8, please specify "Other". 

Member 
State 

Response 

IE 

HR 

NL 

CZ 

MT 

RO 

There  was  an  ESF+  specific  IT  system  developed,  and  article  94  simplified  cost  options  were 
adopted. 

AFCOS unit periodically checks press releases of EPPO and State Attorney’s Office. If AFCOS 
unit gets an information that EPPO / State Attorney’s Office requested indictment of natural / legal 
persons  in  Croatia,  it  checks  whether  the  case  has  been  reported  via  IMS  and  it  contacts  the 
competent MCS body to create follow up or initial request.  

new coordination anti-fraud expenditure as part of AFCOS to improve the anti-fraud (reporting) 
process. 

The system mechanisms (methodologies, processes established) have been further developed. 

Kindly refer to Questions 1.2 and 1.4. 

NAFS (national anti-fraud strategy) – establishment of the irregularity reporting network 

 
 
 
 
Q.1.9 If “NO, not yet” or “NO” to Q.1.7, what are the main reasons preventing you from further 
improving the quality of reporting in 2024? 

Response 

Frequency 

Percentage 

Member States 

Insufficient 
investigative bodies 

exchange 

of 

information  with 

Legal or regulatory constraints 

Staff  not  adequately  trained  or  skilled  to  manage 
reporting requirements 

Limited  human  resources 
requirements, including data entry and analysis 

to  manage  reporting 

Insufficient technical infrastructures 

Other (please specify) 

4 

4 

4 

3 

2 

1 

Following Q1.9, please specify "Other”. 

Member 
State 

Response 

14.8% 

HR, LT, ES, CY 

14.8% 

HR, NL, ES, DE 

14.8% 

HR, NL, LT, ES 

11.1% 

HR, ES, DE 

7.4% 

3.7% 

HR, ES 

DE 

The  Federal  Ministry  of  Labour  and  Social  Affairs  (BMAS):  Currently,  no  improvements  are 
considered to be required. 

DE 

The  Bremen  ERDF  Managing  Authority:  The  mandatory  reporting  procedures  in  place  are 
sufficient. Moreover, as there were no cases of fraud in Bremen, it has not been necessary to improve 
the quality of reporting. 

Q.1.10 In 2024, have you encountered any difficulties in providing timely updates about the 
follow-up to irregularities, and in particular, fraudulent irregularities? 

Frequency 

Percentage 

Member States 

14 

51.9% 

IE,  LU,  SE,  NL, 
FR,  EL,  BE,  AT, 
FI,  CZ,  DE,  MT, 
LV, IT 

HR,  LT,  SI,  HU, 
SK,  PL,  BG,  EE, 
RO, PT, DK 

YES, only fraudulent irregularities 

YES, all irregularities 

11 

2 

40.7% 

7.4% 

ES, CY 

Response 

NO 

 
 
 
 
 
 
Q.1.11  In  which  areas  did  you  encounter  more  difficulties  when  updating  already  reported 
fraudulent irregularities? 

Response 

Frequency 

Percentage 

Member States 

11 

10 

8 

6 

6 

3 

40.7% 

37.0% 

29.6% 

22.2% 

22.2% 

IE,  LU,  FR,  BE, 
AT,  FI,  CZ,  ES, 
DE, MT, LV 

HR,  LT,  SI,  ES, 
HU, SK, DE, EE, 
DK, IT 

SE,  NL,  SI,  ES, 
PL, BG, EE, RO 

HR, ES, DE, CY, 
EE, RO 

HR,  EL,  BE,  ES, 
DE, PT 

11.1% 

NL, SI, PL 

No difficulties encountered 

Timeliness of follow-up 

Completeness of information received 

No information received 

Other (please specify) 

Accuracy of information received 

Following Q1.11, please specify "Other". 

Member 
State 

Response 

HR 

EL 

BE 

ES 

DE 

Contribution  from  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  for  Support  in 
Agriculture and Rural Development: Timeliness of information received. 

Financial Audit Committee (EDEL): Lack of  awareness among and no exchange of information 
between  the  judicial  authorities  and  the  reporting  authorities.  Recovery  and  Resilience  Facility 
Agency  (RRFA):  To  date,  no  irregularities  giving  rise  to  the  suspicion  of  fraud  (‘fraudulent’ 
irregularities) have been detected. 

The  exchange  of  information  between  judicial  and  administrative  bodies  could  be  streamlined 
(EFRD, JTF and RRF at the SPW). 

Technical difficulties, need to adapt IT systems, which are being improved. 

The Rhineland-Palatinate ERDF Managing Authority: Prosecution and judicial proceedings take a 
long time, and we usually only receive information after actively asking about the case in question. 

PT 

Follow-up of judicial proceedings 

 
 
 
 
Q.1.12  Regarding  previous  question,  please  provide  additional  explanation  about  the 
difficulties encountered. 

Member 
State 

Response 

IE 

LU 

HR 

SE 

NL 

FR 

EL 

BE 

AT 

FI 

LT 

SI 

CZ 

ES 

n/a 

No difficulties encountered. 

Contribution  from  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  of  Fisheries:  
Lack of feedback from investigative bodies on the outcome of the reported case causes difficulties 
in reporting/follow up of such cases. However, communication and information sharing during the 
investigations are restricted by law so there is not much space for the improvement. 
Contribution from AFCOS-unit:   
Some MCS bodies are not proactive enough in obtaining information needed for reporting updates 
of  already  reported  fraudulent  irregularities.  In  addition,  the  flow  of  information  from  judicial 
authorities to reporting authorities is not always prompt. 
Contribution  from  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  for  Support  in 
Agriculture and Rural Development: 
We  have  encountered  difficulties  in  providing  timely  updates  about  the  follow-up  to  fraudulent 
irregularities due to the length of court proceedings.  

In  2024,  the  Swedish  Economic  Crime  Authority  (Swedish  AFCOS)  found  that  the  managing 
authorities’ investigations relating to reported crimes were legally incomplete, in particular with 
regard to the nature of the suspected infringement. Therefore, it is difficult to prove that an offence 
has been committed. 

Just setting up the coordination for antifraud, therefor the organisational structure is still in working 
progress 

X 

The  judicial  authorities  have  not  informed  the  reporting  authorities  of  any  notified  cases  of 
suspected fraud. Consequently, the reporting authorities cannot update these cases 

The  exchange  of  information  between  judicial  and  administrative  bodies  could  be  streamlined 
(EFRD, JTF and RRF at the SPW). 

No information. 

No difficulties encountered 

Due  to  recent  personnel  changes,  we  are  experiencing  a  loss  of  institutional  memory,  which 
occasionally hinders our ability to fully update cases or retrieve historical irregularities. 

without additional explanation 

N/A 

There are many difficulties in getting information from the EPPO and the courts. 

HU 

The channelling of judicial information could be improved upon 

 
 
 
 
 
Member 
State 

Response 

SK 

PL 

In individual cases of criminal investigation, access to more detailed information is not possible in 
order not to interfere with the investigation procedure.  
Another problem is the length of the criminal investigation process. 

In some cases, in which criminal proceedings are still ongoing, it is difficult to obtain up-to-date 
data from law enforcement authorities due to the confidentiality of proceedings. In particular, this 
concerns cases where the reporting institution was not the party reporting the criminal offence.   
Due to the specific nature of criminal cases and the nomenclature used in court judgments, it is 
sometimes difficult for the reporting institution to establish all personal data of the convicted natural 
person that must be included in the IMS reporting form. This is because in their judgments, courts 
do not use the personal identification (PESEL) number, or the registered residence address of the 
person concerned. 
A  separate  category  of  criminal  cases  are  particularly  long  criminal/judicial  proceedings,  the 
duration of which exceeds the relevant financial perspective.  

DE 

- 

of 

(art.34 

authorities 

On behalf of the PORB and cooperation with the EPPO office in Bulgaria we could detect some 
difficulties  in  obtaining  timely  and  correct  information  concerning  the  cases  which  are  already 
reported to the EPPO, the European Delegated Prosecutors decided not to evoke the case (art.27, 
par.8 of the Regulation) and therefore they have to be referred without undue delay to the competent 
national 
Regulation).  
The Ministry of Justice established a procedure in accordance with Art. 24 par. 2 of the Regulation, 
according to which each prosecutor or investigator, part of the prosecution system (PORB), reports 
directly  to  the  European  Public  Prosecutor's  Office  when  a  suspicion  of  an  offence  within  its 
competence is identified. The centralized channel of communication was overruled which brought 
to some difficulties and misunderstandings in the process of the exchange of documents.  
The PORB and especially Department 08 within Supreme Cassation Prosecutor’s Office, actively 
cooperates and assists the EPPO in the process of ensuring prompt, relevant and efficient manner 
of reporting.  
The Managing Authorities claimed that receiving a timely information about the measures taken is 
crucial for the accurate irregularity reporting. 

the 

Not applicable. 

Bodies initiating cases do not respect the procedure of following up on open cases. 

In cases under criminal investigation where the investigation has been initiated by the investigative 
body on its own initiative, the implementing agency often lacks sufficiently detailed information 
about  the  circumstances.  As  a  result,  it  is  not  possible  to  prepare  comprehensive  reporting. 
Additionally, reports cannot always be created or notifications made without authorization from the 
investigative body, as this could hinder a swift and effective investigation. 

- Ministry of Development, Public Works and Administration (MDLPA): difficulties regarding the 
status  of  the  checks  undertaken  by  the  other  institutions  involved.  Please  note  that  the  judicial 
authorities have their own investigation deadlines. Please note that in cases where the MA is not 
party to the process, they do not receive information concerning its finalisation. 

BG 

MT 

CY 

EE 

RO 

 
 
 
 
 
 
 
Member 
State 

Response 

-  AFIR  (Agency  for  the  Financing  of  Rural  Investments):  Exchange  of  information  –  the 
investigative bodies do not always provide all the information needed to complete the report 

PT 

The difficulties in obtaining information on the follow-up of judicial proceedings are essentially 
due to the fact that they are subject to legal confidentiality. 

LV 

No difficulties encountered. 

DK 

Regarding timeliness of follow-up, the Danish Business Authority explains that when a suspected 
case of fraud is reported to the police for further investigation it is not always, that the Managing 
Authority is noticed of the progress and results of the investigation and decisions made by the police, 
which makes it difficult to update IMS. 

Q.1.13 Has the information flow between judicial and reporting authorities improved in 2024? 

Response 

Frequency 

Percentage 

Member States 

YES, partly 

15 

55.6% 

NO 

YES, fully 

10 

2 

37.0% 

7.4% 

LU, HU 

Q.1.14 If “YES, fully” and “YES, partly” to Q.1.13, what steps have been taken in 2024 to 
improve the exchange of information between judicial and reporting authorities? 

Response 

Frequency 

Percentage 

Member States 

Establishment  of  clear  instructions  for  handing  over 
cases and defined guidelines 

Increased  trainings  for  both  judicial  and  reporting 
bodies 

Other (please specify) 

Regular  inter  agency  meetings  or  working  groups  to 
discuss ongoing cases and share information 

No significant changes have been made in 2024 

8 

8 

6 

6 

4 

29.6% 

29.6% 

22.2% 

22.2% 

LU,  CZ,  ES,  DE, 
BG, RO, DK, IT 

ES, HU, SK, DE, 
BG, MT, RO, IT 

PL,  DE,  RO,  PT, 
LV, DK 

LT,  CZ,  ES,  BG, 
RO, IT 

14.8% 

PL, DE, EE, LV 

NL,  LT,  CZ,  ES, 
SK,  PL, DE,  BG, 
MT, EE, RO, PT, 
LV, DK, IT 

IE,  HR,  SE,  FR, 
EL,  BE,  AT,  FI, 
SI, CY 

 
 
 
 
Response 

Frequency 

Percentage 

Member States 

3 

3 

2 

1 

11.1% 

ES, HU, RO 

11.1% 

HU, BG, RO 

7.4% 

3.7% 

MT, RO 

NL 

Appointment  of 
facilitate 
communication and coordination between authorities 

liaison  officers 

to 

Establishment  of  formal  communication  protocols 
(regular  reporting  schedules,  standardized  reporting 
formats) 

Implementation  of  a  digital  platform  for  real-time 
sharing of information between authorities 

Setting up of a joint team 

Following Q1.14, please specify "Other". 

Member 
State 

Response 

PL 

DE 

RO 

PT 

In 2024, there was no significant change in the tools used for the exchange of information, while 
the amount of correspondence between judicial authorities and the reporting institution (queries, 
replies, clarifications) went up, which also increased the flow of information between entities 

The Rhineland-Palatinate ERDF Managing Authority: We (ERDF Managing Authority) are now 
frequently asking for updates from prosecution officers. 

- NAFS (national anti-fraud strategy) – establishment of the irregularity reporting network 

- AFIR: Every six months, the DCA expert who notified the suspicion of fraud asks the notified 
authorities  about  the  measures  subsequently  taken.  Protocol  of  collaboration  with  the  EPPO. 
Clarification in the control and anti-fraud working procedure on how to notify the EPPO  

The information-sharing mechanisms have been consolidated and set in place on support platforms 
(shared, restricted-access folders updated on the basis of new information in each case). 

LV 

Cooperation between institutions is constantly promoted and improved. 

DK 

The Danish Agency for Green Land Conversion and Water Environment: Communication with the 
judicial authorities has been improved through meetings, clearer instructions when handing over 
cases and communication about the outcome of cases. Regular follow up with the police regarding 
the status of the cases. 

 
 
 
 
Q.1.15 Can you provide a short description of the organisational structure and procedures for 
exchanging information between judicial authorities and reporting authorities in your Member 
State? 

Member 
State 

Response 

IE 

LU 

HR 

SE 

NL 

FR 

EL 

BE 

Where a fraud or suspected fraud is identified, the process to be followed is set out in the various 
anti-fraud strategies of the managing authority 

Organizational  structure  and  procedures  for  the  exchange  of  information  between  judicial 
authorities and reporting authorities detailed in a guideline. 

Contribution from Ministry of Finance, Tax Administration:  
The Tax Administration exchanges information with judicial authorities based on Article 8 of the 
General Tax Law (no tax secrecy) and the Tax Administration Act. A special Unit  - Independent 
Sector for Financial Investigations was established to cooperate with the EPPO. 

Contribution from AFCOS unit:    
Reporting authorities can request AFCOS unit to organize a meeting with State Attorney’s Office 
and  the  Police  (so  called  AFCOS  Network  meeting)  in  order  to  discuss  suspected  fraud  cases. 
However, they are encouraged to establish direct communication with judicial authorities in order 
to speed up the obtaining of information on status of reported suspected fraud and to update the 
IMS case.  
Ministry of Agriculture, Forestry and Fisheries, Directorate for Support in Agriculture and Rural 
Development have established a special organizational unit for managing irregularities at the level 
of the Paying Agency responsible for the exchange of information with the judicial authorities.  

All cases reported in IMS are sent to the Swedish Economic Crime Authority. If necessary, the 
prosecutor is contacted to discuss cases.  In addition to reporting suspected fraud to the Swedish 
Economic  Crime  Authority,  information  is  exchanged  at  a  more general  level  through  the  SEFI 
Council,  the  national  OLAF  network  (approx.  2  meetings  a  year),  meetings  of  OLAF’s  ‘Fraud 
Prevention, Analysis and Reporting’ Fraud Prevention Group 

There was no coordination for expenditure, in 2024 the AFCOS got this new responsibility, and the 
organisation is still setting up for better reporting purposes 

x 

Information is exchanged by email between the judicial authorities and the reporting authorities in 
order to either provide information or take the appropriate measures to attribute or write off debts. 

ERDF, JTF and RRF at the SPW: Exchange of information between the SPW (ERDF, JTF, RRF) 
and the judicial authorities. The current procedure is as follows: A file is submitted to the Public 
Prosecutor’s  Office  if  there  is  a  suspected  irregularity  involving  a  criminal  offence.  The  Public 
Prosecutor’s Office may request additional information concerning the file submitted.  Legal basis: 
Article 29 of the Code of Criminal Procedure - Walloon decrees and/or Walloon government orders 
specifying  the  arrangements  for  communicating  information  to  the  authorities  depending  on  the 
subject concerned.  The information exchange procedures have not yet been formally set down in a 
written procedure 

AT 

In the event of a notification/message in the IMS, information is requested promptly and provided 
within a few days. 

 
 
 
 
 
Member 
State 

Response 

ESF:  The  procedures  and  organisational  structure  for  exchanging  information  are  set  out  and 
explained in detail in the management and control system of the ESF Managing Authority. The 
management and control system has been approved by the European Commission. 

The  authorities  responsible  for  the  implementation  of  EU  programmes  are  administrative 
authorities, and they exercise administrative powers. Administrative authorities have the power and 
the obligation, as enshrined in sectoral legislation, to monitor and audit grants and, where necessary, 
recover them. If administrative authorities have reason to suspect fraud, they make a request to the 
pre-trial  investigation  authority,  such  as  the  police,  for  an  investigation  into  the  matter.  The 
administrative  authorities are also responsible for IMS reporting. The Police or Customs, which 
have the power to conduct criminal investigations, conduct the preliminary investigation. Following 
this, the prosecutor issues a decision to bring charges. After that, the matter is dealt with in court.

Roles  and  powers  are  split  among  the  various  authorities.  The  Police,  Customs  and  the  public 
prosecutors, i.e. the enforcement authorities and judicial authorities, operate independently and have 
the power to conduct criminal investigations and take coercive measures. Administrative authorities 
do not have those sorts of powers, but they do communicate the necessary data  for the pre-trial 
investigation authorities to use in connection with a request for an investigation. 

The Financial Crime Investigation Service (FCIS), serving as the primary body for reporting and 
investigating fraud related to EU funds in Lithuania, collects all relevant information from the EU 
paying agencies in the country and subsequently reports it to OLAF. A key challenge, however, lies 
in addressing regular irregularities that do not constitute fraud. In such cases, the paying agencies 
are not obligated to report these instances to the FCIS. 

While Ministry for Cohesion and Regional Development answer is YES; The Financial Admin of 
the  Republic  of  Slovenia  answers:  NO.  Agency  for  Agricultural  Markets  explains:  Judicial 
authorities are separate from reporting authorities in organisational terms and work independently. 
Information  is  exchanged  with  judicial  authorities  in  order  to  meet  the  needs  of  administrative 
procedures. Supreme State Prosecutor's Office of the  Republic of Slovenia answers: In our legal 
system, the police act as the investigating authority, the public prosecutor acts as the prosecuting 
authority  and  the  court  acts  as  an  independent  judicial  body.  In  certain  cases,  particularly  more 
serious  offences,  the  prosecution  service  may  provide  guidance  to  the  police  during  the 
investigation.  Once  the  investigation  is  complete,  the  police  submit  a  criminal  report  to  the 
prosecutor, together with all the evidence they have collected. The prosecutor then decides whether 
to initiate criminal proceedings. Our legal system follows the principle of legality, which means 
that the prosecutor is obliged to initiate criminal proceedings if there is a reasonable suspicion that 
a criminal offence has been committed and that the perpetrator should be prosecuted ex officio 

The  reporting  authority  is  the  managing  authority  of  the  operational  programme.  The  reporter 
submits the criminal complaint to the Police of the Czech Republic/EPPO, and it is then dealt with 
at  the  Public  Prosecutor’s  Office,  and  an  action  is  subsequently  brought before  the  court.  If  the 
managing authority needs to contact the judicial authorities, the procedure depends on the nature of 
the  particular  information.  Routine  communication  (such  as  the  police  asking  for  more  detailed 
information  about  the  project)  can  also  take  place  directly.  Where  necessary,  other  bodies  (the 
certifying authority, the national co-ordination authority, the audit authority) are also included in 
the communication. In the case of irregularities involving amounts above the established thresholds, 
AFCOS is also included in the communication. 

FI 

LT 

SI 

CZ 

 
 
 
 
 
Member 
State 

Response 

ES 

HU 

SK 

PL 

In  some  OPs,  there  is  a  coordinator  of  audits,  controls  and  irregularities.  This  staff  member 
communicates with the judicial authorities and the notifying authorities. 

The Spanish AFCOS carries  out information and monitoring functions for the classification and 
communication of suspected fraud, informing the authorities of the existence of legal proceedings 
in progress, as well as their completion, requesting information from the judicial bodies, all on the 
basis of the criteria contained in the document ‘Classification criteria and procedure for action with 
regard to irregularities and suspected fraud that are the subject of criminal legal proceedings’ issued 
by the AFCOS. 

The Directorate for Internal Audit and Integrity serves as a single contact point for a two-way flow 
of information between managing authorities and investigative and judicial bodies, the procedural 
details of which are laid down in cooperation agreements with the Public Prosecutor’s Office, the 
police and the National Tax and Customs Administration. 

The  process  of  reporting  irregularities  to  OLAF  involves  several  key  steps  which  flows  from 
Managing  Authority  (MA)  or  Intermediate  Body  (IB)  through  Certifying  Authority/Paying 
Authority  (CA/PA)  to  National  Office  for  OLAF.  The  MA/IB  is  responsible  for  a  reporting  of 
detected irregularity and recording the information about irregularity into the national IT monitoring 
system. For this reason, the MA/IB receives information about any initiated and ongoing procedures 
from the authorities conducting the procedure. 
The national monitoring system contains detailed information about the given irregularity, on the 
basis  of  which  the  CA/PA  assesses  their  reporting  to  National  Office  for  OLAF  (AFCOS)  and 
afterwards  the  National  Office  for  OLAF  is  reporting  the  cases  to  IMS.  There  is  regular 
communication and exchange of information between all mentioned bodies (for example regarding 
legal procedures, technical procedures). 
 Other  bodies  such  as  the  Audit  Authority,  criminal  agency,  etc.  are  involved  if  necessary.  
In  agricultural  funds  judicial  authorities  contact/inform  the  Agricultural  Paying  Agency  (APA). 
Then 
to  AFCOS.  
The exchange of information regarding fraudulent irregularities is based on cooperation agreement 
between AFCOS and the General Prosecutor´s Office of the SR. 

follows:  APA  via 

the  exchange  of 

information 

is  as 

IMS 

The competent institution of the management and control system, after examining a particular case, 
reports  suspected  criminal  offences  to  the  law  enforcement  authorities,  providing  the  necessary 
details  substantiating  its  suspicion.  In  the  area  of  cohesion  policy,  where  the  law  enforcement 
authorities decide to initiate proceedings, further information about the stage of such proceedings 
is exchanged on the basis of the cooperation agreement between the National Public Prosecutor and 
the Minister responsible for regional development, which regulates the provision of information on 
ongoing and concluded proceedings concerning projects co-financed by European funds. On the 
basis of that agreement, there is a  regular, periodic exchange  of data on the beneficiaries of EU 
funds against whom investigative measures have been taken, and some institutions also make use 
of the possibility to directly contact the designated representatives of the Public Prosecutor’s Office 
to  obtain  data  on  ongoing  proceedings  without  delay.  
where 
In the area of agriculture, the institution referring a case to law enforcement authorities is obliged 
to keep the data on criminal proceedings in the relevant register of irregularities up to date until the 
proceedings come to an end. As a general rule, the exchange of information between the institution 
and the law enforcement authorities takes place on a regular basis to ensure that the case is kept up 
to date in the Irregularity Management System. In the absence of information about the current stage 

is  necessary 

it 

 
 
 
 
Member 
State 

Response 

of criminal proceedings being conducted by law enforcement authorities, the competent entity must 
request that such information be sent to the contact point in charge of the respective proceedings, 
and, on this basis, it must update the data in the register. 
Information obtained from law enforcement authorities forms the basis for possible reporting or 
updating of the case in the IMS by the competent reporting institution.  

The Federal Ministry of Labour and Social Affairs (BMAS): In the context of the European Social 
Fund Plus (ESF Plus), there is a guidance document for the ESF Plus Federal Programme which 
deals with the reporting of irregularities (including suspected cases of fraud). Under the ESF Plus 
Federal Programme, cases are examined by the managing authority and the intermediate managing 
bodies. Where necessary, the managing authority instructs the relevant granting authority to take 
action, which may include, in particular, an on-the-spot check. The granting authority sends an IMS 
report to OLAF and, where necessary, notifies the offence to the national public prosecutor’s office 
or the European Public Prosecutor’s Office. 

The  Federal  Ministry  of  Food  and  Agriculture  (BMEL):  Where  necessary,  cases  in  the  area  of 
agriculture and fisheries are reported to the judicial authorities or the European Public Prosecutor’s 
office by the paying agencies or managing authorities, with the involvement of their legal services.

The Bremen ERDF Managing Authority: The intermediate bodies implement operations. Potential 
cases of fraud are reported to the managing authority while, at the same time, detailed checks are 
carried out in order to either confirm or dispel the suspicion of possible fraud. If the suspicion of 
fraud is confirmed, the intermediate body in turn notifies the managing authority and the public 
prosecutor’s office. The public prosecutor’s office investigates the case or closes the investigation. 
The  outcome  is  communicated  to  the  intermediate  body,  which  in  turn  informs  the  managing 
authority. 

DE 

The  Baden-Württemberg  ERDF  Managing  Authority:  Through  Section  2  of  the  Subsidies  Act 
(SubvG), Germany has obliged (reporting) authorities to disclose facts relevant to subsidies. Under 
Section  3  of  the  SubvG,  beneficiaries  are  required  to  communicate  facts  which  constitute  an 
impediment to subsidies, as well as facts which are relevant to the recovery of subsidies in full or 
in  part.  Moreover,  Section  6  of  the  SubvG  requires  the  (reporting)  authorities  to  notify  the  law 
enforcement authorities if, in the exercise of their duties, they become aware of facts giving rise to 
suspicions 
fraud.  
 As a result, a complete chain is established in criminal law between the beneficiary or beneficiaries, 
the authorities and the law enforcement authorities.  

subsidy 

of 

The Rhineland-Palatinate ERDF Managing Authority: We formally inform the prosecution officers 
about  any  cases  as  required  by  German  federal 
the  SubvG). 
The  Lower  Saxony  ERDF  Managing  Authority:  In  justified  cases  of  suspected  fraud,  a  direct 
notification  (criminal  complaint)  is  made  by  the  intermediate  body  to  the  competent  public 
prosecutor's  office.  The  Intermediate  body  (NBank),  investigating  authorities  and  judicial 
authorities are in regular exchange during the proceedings. The managing authority shall be kept 
regularly informed of the progress of the procedure. 

law  (Section  6  of 

The  Schleswig-Holstein  ERDF  Managing  Authority:  The  MA’s  guidance  document  on  anti-
corruption and anti-fraud measures deals with the handling of suspicious cases and the reporting 
process. The reporting process is always the same, whichever institution detects a (suspected) case 
of fraud: If administrative checks confirm a (suspected) case of fraud, a submission is made to the 
public prosecutor’s office via the Electronic Court and Administrative Mailbox (EGVP). An IMS 

 
 
 
 
 
 
 
 
Member 
State 

Response 

report is also made. The subsequent investigation is the responsibility of the public prosecutor’s 
office.   

The Thuringia ERDF Managing Authority: Cases where suspicions cannot be dispelled are reported 
to the law enforcement authorities by the ERDF MA or an intermediate body. If the case is closed, 
the aforementioned parties are notified. If there are sufficient grounds to believe that an offence has 
been committed (cf. Section 203 of the Code of Criminal Procedure (StPO)), the law enforcement 
authorities bring charges.  

In  the  field  of  penal  investigation  judicial  authorities  provide  information  only  in  case  when 
Managing Authority is constituted as a victim in the indictment. The Managing Authorities provide 
assistance to the European prosecutor's Office at requests made for provision of information and 
documents in order to counteract irregularities and fraud affecting the EU’s financial interests.    
Following the Regulation (EU) 2017/1939 all reporting authorities as well as each prosecutor or 
investigator,  part  of  the  prosecution  system  (PORB),  reports  directly  to  the  European  Public 
Prosecutor's Office when a suspicion of an offence within its competence is identified. As a primary 
point for organizing and ensuring the interaction with EPPO, department 08 within the Supreme 
Cassation Prosecutor’s Office  is also reliable link between reporting and judicial authorities and 
EPPO. The pointed procedures are ongoing practice for years in Bulgaria. 

BG 

MT 

The exchange of information with respect to reported fraudulent cases is established by Article 18 
of the Internal Audit and Financial Investigations Act (Cap. 461 of the Laws of Malta). 

For CAPO, they report suspected fraud cases to the relevant authorities (e.g. Police, EPPO, Attorney 
General- depending on the case), as well as to AFCOS (via IMS and otherwise). 

AFCOS Organizational Structure:  
The AFCOS is presided by the Accountant General of the Republic and the following authorities 
are its members: 

CY 

EE 

of 

Interior, 

Cyprus  Agricultural 

(Managing and Control Authorities): Treasury of the Republic of Cyprus, Directorate General for 
Growth,  Ministry 
Payments  Organization. 
(Legal  and  Investigation  Authorities):  Tax  Department,  Customs  and  Excise  Department. 
(Prosecution Authorities) Law Office of the Republic, Cyprus Police.  
(Audit Authorities): The Cyprus Audit Office and the Internal Audit Service are observers. Other 
relevant  authorities  which  AFCOS  has  cooperation  with  is  the  Independent  Authority  Against 
Corruption  and  the  European  Delegated  Prosecutor  (EPPO).  Memorandums  of  Cooperation 
between the Cyprus AFCOS and other competent authorities involved in the fight against fraud to 
formalize communication and cooperation forms a deliverable of the TSI project that Cyprus is a 
beneficiary, and its expected delivery is between August and October of 2025. 

The  irregularity  report  is  created  by  the  institution  responsible  for  managing  of  the  specific 
project/beneficiary (implementing agency) in the information system. If the irregularity or fraud is 
identified  by  another  party  (e.g.,  the  Managing  Authority,  auditing  authority,  ECA,  OLAF, 
investigative  body)  or  comes  from  a  whistleblower  tip,  the  information  is  forwarded  to  the 
implementing agency responsible for managing of the case. This agency has the legal basis to make 
financial corrections if necessary or submit a request to the investigative body to initiate a criminal 
investigation. All irregularities/fraud are recorded to national grant information system from the 
first euro cent, and the information remains in the system even if it is later determined during the 
proceedings that no irregularity or fraud has occurred.  

 
 
 
 
 
 
Member 
State 

Response 

The  Managing  Authority reports  irregularities  quarterly via  IMS,  ensuring  that  the  irregularities 
have been updated and contain the required information. This includes verifying whether reporting 
has  been  initiated  for  cases  they  are  aware  of.  Our  investigative  bodies  generally  share  detailed 
information  only  with  the  institution  managing  this  project.  They  do  not  provide  separate 
notifications to the Managing Authority or AFCOS. The Managing Authority obtains the necessary 
information from the implementing agency or through the reporting system. 

- DLAF: Standardised form in follow-up to DNA/DLAF cases 

- AFIR: In the framework of the Agency for the Financing of Rural Investment, the Control and 
Anti-Fraud  Directorate  (DCA)  reports  directly  to  the  Director-General,  who  fulfils  the  duties 
concerning the role of scrutiny over contracted projects, with a view to the prevention/identification 
of irregularities and suspected fraud which affect the financial interests of the European Union and 
the  National  Budget  of  Romania.  Alongside  the  control  missions  carried  out  on  the  basis  of 
sanctions and reporting, the Control and Anti-Fraud Directorate ensures ongoing collaboration with 
bodies responsible for investigating cases of irregularities and (suspected) fraud, representing the 
main contact point for the AFIR with these institutions. In this regard, the Control and Anti-Fraud 
Directorate, through the External Operational Cooperation Service, collaborates with OLAF, EPPO, 
DLAF, DNA, the Police and the Public Prosecution Service on verifying, ascertaining, assessing 
and monitoring cases of irregularities and suspected fraud. Depending on the information received 
from the EPPO, DLAF and OLAF, the Control and Anti-Fraud Directorate follows the cases under 
investigation  by  the  DNA  on  an  ongoing  basis,  regularly  asking  about  the  status  of  enquiries 
concerning  projects  financed  by  the  EAFRD,  and  of  the  result  of  OLAF/EPPO/DLAF/DNA 
investigations,  depending  on  the  way  in  which  the  DCA  is  handling  the  cases  assigned  to  the 
Directorate:  following  the  administrative  and  judicial  procedures  opened  after  the  discovery  of 
irregularities/fraud, initiating the debt recovery procedure, entering the necessary information in the 
quarterly report on irregularities, etc. Taking into account the collaboration framework described 
above,  the  Control  and  Anti-Fraud  Directorate,  through  the  External  Operational  Cooperation 
Service takes over, centralises and analyses the notifications and information received from OLAF, 
EPPO,  
DLAF, DNA, the Police and the Public Prosecution Service and cases of suspected fraud opened 
by other services under the DCA, where necessary ensuring quarterly reporting, monitoring and/or 
control of cases of irregularity and suspected fraud which have arisen. 

-  DGP-AM  POPAM:  The  Managing  Authority  notifies  cases  of  suspected  fraud  on  the  basis  of 
current national legislation, both in writing and through the EPPO website. Information, documents 
and  the  outcome  of  checks/investigations  are  communicated  in  electronic  and/or  paper  format 
depending on each individual case. 

- The Ministry of Energy: Interinstitutional collaboration protocols have been opened in which ways 
of avoiding irregularities and serious irregularities, such as double financing, fraud or corruption, 
were  identified.  -  South  Muntenia  Regional  Development  Agency  (AMPR  S–M):  establishing 
official communication protocols, appointing liaison officers in order to facilitate communication 
and  coordination  between  authorities,  regular  meetings  between  agencies  or  working  groups  in 
order to discuss ongoing cases and to exchange information. 

-  MIPE  –  DGPDD:  Within  the  DGPDD  –  DACNMISC,  the  Irregularities  Officers  Department 
receives  requests  for  information  and  data  from  the  judicial  bodies,  responds  to  requests  and 
regularly  requests  information  on  the  status  of  the  investigations  carried  out  by  the  judicial 
authorities. 

RO 

 
 
 
Member 
State 

Response 

-  MIPE  –  DGMMRR:  Under  Procedure  No  PO.  DGMMRR.10-  Control  of  irregularities/double 
financing,  serious  irregularities  arising  in  the  obtaining  and  use  of  external  grants  and  loans 
allocated  to  Romania  through  the  PNNR  or  related  national  public  funds  and  the  recovery  of 
resulting  debts.  The  Audit  Control,  Recovery  and  Monitoring  Service  enters  in  the  register  of 
suspected irregularities/fraud and debtors all cases of suspected irregularities/fraud identified in the 
checks by the DGMMRR-CN or in findings with financial implications submitted by institutions 
with 
Prosecutor’s 
Office/DLAF/DNA/OLAF/ANI/DIICOT, etc. Where appropriate, it informs them of the fact that 
in the course of the checks carried out, a reasonable suspicion arose concerning the identification 
of evidence of suspected fraud/serious irregularities. 

audit/European 

responsibilities 

Public 

field 

this 

in 

- MMAP: Within the framework of the Legal and Debt Recovery Service of the Directorate-General 
for the National Recovery and Resilience Plan (DGPNRR  – SJRC), the Department for Controls 
and the Establishment of Irregularities receives requests for information and data from the judicial 
bodies, responds to requests and regularly requests information on the status of the investigations 
carried out by the judicial authorities.  

Here,  we  should  point  out  the  information  sharing  with  the  Central  Criminal  Investigation  and 
Prosecution Department (DCIAP) and the European Public Prosecutor’s Office (EPPO). The Funds’ 
coordinating bodies are responsible for providing information on operations, beneficiaries, and their 
respective shareholders/managers/administrators, as well as service providers/suppliers. In turn, the 
DCIAP and the EPPO provide information on the state of play of proceedings initiated. 
The Funds’ coordinating bodies compile and validate data on irregularities to be reported to OLAF 
and  monitor  cases  reported  to  the  Public  Prosecutor’s  Office  (suspected  fraud  cases)  or  to  the 
relevant  Operational  Programmes,  with  a  view  to  characterising  beneficiaries  in  terms  of  good 
standing, so as to prevent their renewed involvement in similar situations. The information is sent 
to the AFCOS, which validates it and submits it to OLAF via the IMS. 

the 

European 

If,  while  administering  EU  funds  (instruments  or  other  programmes),  a  possible  illegal  act  is 
detected or an act that does not comply with the conditions for implementing EU funds and raises 
suspicions  of  fraud  that  may  affect  the  financial  interests  of  the  EU,  this  act  is  reported  to  the 
European  Delegated  Prosecutor's  Office  in  Latvia  and  the  European  Public  Prosecutor's  Office 
(EPPO). The law enforcement authorities can also be contacted - the State Police, the Corruption 
Prevention  and  Combating  Office  -  to  receive  the  necessary  advice,  while  at  the  same  time 
informing 
Latvia.  
The  exchange  of  information  between  institutions  is  determined  in  the  AFCOS  procedure 
"Methodological  material  on  cooperation  and  exchange  of  information  between  the  Anti-Fraud 
Coordination Service of the Ministry of Finance (AFCOS), national institutions and the European 
Anti-Fraud  Office  (OLAF)  in  the  field  of  protection  of  the  financial  interests  of  the  European 
Union"  and  AFCOS  procedure  "Procedure  for  institutions  to  report  to  the  European  Public 
Prosecutor's  Office  (EPPO)  on  suspected  fraud  against 
interests".  
Each  EU  funds  administering  institution  has  a  contact  person  for  communication  with  the 
investigative authorities, and on the side of the investigative authorities there is a contact person for 
communication with the EU funds institution. 

the  EU's  financial 

Prosecutor's 

Delegated 

Office 

in 

The Danish Business Authority: When we, as a managing authority, find a case, where we after 
investigations have a reasonably certainty, that we have a case of fraud on our hands, we make a 
report to the police, who conducts further investigations and decides if it is a case suitable to take 
to court. We rarely communicate with the police regarding reported cases and almost never with the 

PT 

LV 

DK 

 
 
 
Member 
State 

Response 

judicial authorities. When that is said it is also important to underline, that we have very few cases 
of fraud.  

The Danish Agency for Green Land Conversion and Water Environment: A special department of 
the  reporting  authority  designated  to  handle  fraud  is  in  charge  of  the  communication  with  the 
judicial authorities. 

As  stated  in  the  aforementioned  ‘Guidelines  on  how  to  notify  the  European  Commission  of 
irregularities and fraud against the EU budget’ issued in 2024, all managing authorities have been 
reminded  to  always  bear  in  mind  that,  in  the  event  of  difficulties  in  dialogue  with  the  judicial 
authorities, they can contact the Guardia di Finanza Unit for Combatting Fraud against the European 
Union at the Prime Minister’s Office, which will seek to facilitate contact with the local branch of 
the body concerned. 
In addition, by Order No 6 of 6 December 2024, the Prosecutor General at the Court of Auditors 
confirmed that at least one staff member authorised to access the IMS platform would be designated 
at each local public prosecutor’s office. 
In order to allow the data  in the  database to be updated in a timely manner, the regional public 
prosecutor’s offices have been asked to share information with managing authorities on summonses, 
case dismissals and judgments regarding fraud against the EU budget, with the public prosecutor’s 
offices at the courts of appeal and Court of Cassation being subject to a similar requirement to share 
information on judgments issued in appeals. 

IT 

Q1.16  What  methods  are  used  for  exchanging  information  between  judicial  and  reporting 
authorities? 

Response 

Frequency 

Percentage 

Member States 

Other (please specify) 

24 

88.9% 

Standardised digital forms 

11 

40.7% 

Secured online platforms 

Regular meetings 

IMS 

Shared  case  management  system  for  tracking  and 
reporting suspected fraud case 

6 

5 

4 

3 

IE,  LU,  HR,  SE, 
NL,  FR,  EL,  BE, 
AT,  FI,  SI,  HU, 
SK,  PL, DE,  BG, 
MT, CY, EE, RO, 
PT, LV, DK, IT 

LU, HR, SE,  BE, 
LT,  CZ,  ES,  DE, 
BG, EE, RO 

SI,  CZ,  DE,  MT, 
RO, IT 

HR, CZ, SK, BG, 
RO 

22.2% 

18.5% 

14.8% 

AT, CZ, ES, DE 

11.1% 

CZ, ES, RO 

 
 
 
 
 
Response 

Frequency 

Percentage 

Member States 

Automated data exchange systems 

2 

7.4% 

ES, EE 

Following Q1.16, please specify "Other". 

Member 
State 

Response 

IE 

? 

LU 

HR 

SE 

In  addition  to  response  to  Q.1.15.,  conventional  communication  methods  (e.g.,  email,  written 
correspondence, telephone calls, etc.) are equally used. 

Contribution from AFCOS unit: Formal written communication.  

Contribution  from  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  for  Support  in 
Agriculture and Rural Development: Inquiries sent by post or email.  

The  Swedish  Economic  Crime  Authority  is  notified quarterly  of  any  reported  cases.    Following 
discussions  with  the  Swedish  Economic  Crime  Authority,  information  is  shared  in  the  most 
appropriate  way.  It  can  be  done  by  encrypted  email,  by  letter  or  on  a  USB  stick.  The  Swedish 
Economic  Crime  Authority’s  website  has  digital  forms  for  reporting  crimes  and  filling  in  other 
relevant information. There are also links to tip-off functions and to the Swedish Economic Crime 
Authority’s  whistle-blower  channel  for  reporting  wrongdoing  involving  the  Union’s  financial 
interests in Sweden. 

NL 

At this moment the AFCOS is trying to get IMS authorisation for a better insight of the irregularities 

For the CAP  - The exchange of information takes place between the  judicial authorities and the 
paying agencies. These exchanges are then forwarded to the Secretariat of the CICC EAGF, which 
is responsible for officially submitting fraudulent and non-fraudulent data to OLAF.  
Equally, for the NRRP - In January 2024, an agreement was signed by the MICAF, the Treasury 
DG  and  the  European  Public  Prosecutor’s  Office  (EPPO)  on  operational  cooperation  on  the 
reporting of offences in the context of the national recovery and resilience plan (NRRP) that fall 
within  the  competence  of  the  EPPO.  This  working  arrangement  will  act  as  a  framework  for 
enhanced cooperation between the EPPO and the French authorities in charge of administrating this 
funding. A form for reporting fraud to the EPPO in France and a practical manual were annexed to 
the working arrangement. 

Any information from the judicial authorities is sent by letter and/or by email. 

Via email 

Direct  communication  –  as  befits  the  particular  situation  -  is  conducted  by  email  with  the 
Authorising Body and/or the Paying Agency. 

ESF: By means of electronic files (ELAK). 

A request for an investigation is made in a standard format, and a digital form or other form of 
notification can be used. 

FR 

EL 

BE 

AT 

FI 

 
 
 
 
 
Member 
State 

Response 

SI 

AAMRD answers: Communication in writing by means of correspondence, which is recorded in 
the Agency’s document database. Supreme State Prosecutor's Office of the  Republic of Slovenia 
answers:  Information  exchange  between  judicial  and  reporting  authorities  is  primarily  based  on 
document-based  communication.  Although  a  limited  form  of  electronic  exchange  has  been 
established  between  police,  prosecutors’  offices  and  courts,  the  operational  processes  are  still 
predominantly  based  on  the  exchange  of  physical  documents.  This  traditional  approach  ensures 
compliance  with  procedural  and  legal  requirements.  Efforts  are  underway  to  improve  electronic 
data exchange and streamline communication, but full digitisation has not yet been achieved 

HU 

The information exchange process set out in cooperation agreements. 

SK 

Documentations  and  information  received  in  accordance  with  Cooperation  agreement  and  law 
obligation. 

A regular exchange of information on the basis of the cooperation agreement between the National 
Public  Prosecutor  and  the  Minister  responsible  for  regional  development,  as  regards  the 
transmission of information on ongoing and concluded proceedings concerning projects co-financed 
by European funds: 

-  periodic  cooperation  –  receiving  from  the  National  Public  Prosecutor’s  Office  information  on 
proceedings  in  cases  in  which  the  public  prosecutor  handling  the  case  has  consented  to  the 
transmission of information regarding those proceedings to the institution; 

PL 

-  ongoing  cooperation  –  exchange  of  information  via  a  dedicated  e-mail  address  where  it  is 
necessary to obtain data on specific proceedings; 

-  direct  referral  of  questions  by  managing  authorities  to  individual  public  prosecutors’  offices 
regarding specific ongoing proceedings. 

- The exchange of information at the stage of judicial proceedings is a formal process governed by 
the  relevant  legislation.  In  addition,  the  competent  national  institutions  have  access  to  digitised 
casefiles  and  to  a  judicial  information  portal,  which  facilitates  communication  and  exchange  of 
information  between  the  judicial  authorities  and  these  institutions.  However,  the  decision  on 
whether or not to grant access to casefiles (including in digital form) is taken, in accordance with 
the relevant legislation, by the authority handling the case. 

The Federal Ministry of Labour and Social Affairs (BMAS): In the context of the ESF Plus Funding 
Programme, ESF managing authorities report suspected cases of fraud to OLAF via the IMS system. 
The judicial authorities (public prosecutor’s offices) are informed in writing of suspected cases of 
fraud, outside of the IMS. 

The Federal Ministry of Food and Agriculture (BMEL): Parallel transmission of the relevant case 
files. 

DE 

The Rhineland-Palatinate ERDF Managing Authority: Report via letters (on paper). 

The Lower Saxony ERDF Managing Authority: In the case of a criminal complaint, an official letter 
from  intermediate  body  (NBank)  is  sent  to  the  public  prosecutor's  office.  There  is  no  regular 
exchange. 

The Saarland ESF Managing Authority: Forwarding to the internal legal department. 

The Thuringia ERDF Managing Authority: Email, letter, telephone. 

 
 
Member 
State 

Response 

BG 

MT 

CY 

EE 

Written reports and correspondence. Receiving judicial follow-ups, when the Managing Authorities 
are constituted as a party in trial. 

In cases reported as fraudulent by IAID, the information is forwarded to judicial authorities by hand. 
(registered as private and confidential). 

Confidential correspondence (Email and Letter Communication) 

Meetings and information exchange regarding fraud suspicions. 

- DLAF: standardised form (legal follow-up) 

- DGP-AM POPAM: written correspondence 

RO 

- MIPE – DGPDD: The transmission of requests in digital form and the communication of responses 
in digital/paper form, depending on the situation. 

- MIPE – DGMMRR: to the European Commission audit services (DG EC-FIN) and ECA secure 
online platforms. To the judicial authorities in letters and supporting documents. 

PT 

Information  is  shared  by  means  of  restricted  email  and  joint  recording  in  secure-access  folders 
reserved for the parties involved in the proceedings. 

LV 

Official correspondence, electronic correspondence, telephone communication. 

The Danish Business Authority: The occasional phone call or e-mail. 

The Danish Agricultural and Fisheries Agency: Secure tunnel mail system. 

DK 

IT 

The  Danish  Agency  for  Green  Land  Conversion  and  Water  Environment:  The  specialised 
department of the reporting authority sends a report to the police via secure digital mail and any 
communication between the authorities is by secure digital mail. 

Judicial  authorities  and  reporting  authorities  (MAs)  exchange  information  through  formal  data 
update requests. The reporting authority sends such a request directly to the judicial authority or, if 
the IMS report originated from a notification received from an external control body (e.g. a police 
force), sends it via that body. In the latter case, on each occasion the body concerned will request 
the necessary prior approval from the judicial authority that is conducting the investigation. 
See the information given in response to Q.1.4 and Q.1.5 for cases where problems or difficulties 
arise in the flow of information. 
In  the  context  of  the  activities  aimed  at  fighting  fraud  against  the  European  budget,  the  control 
bodies  in  general  (with  specific  reference  to  the  police  forces)  draft  a  summary  report  upon 
completion of their inspection activities, in parallel with the notifications of findings that are sent 
to  the  competent  criminal-law  and  accounting-law  judicial  authorities  to  allow  them  to  move 
forward  with  their  proceedings.  They  send  this  report  by  email  to  the  Office  of  the  Prosecutor 
General  at  the  Court  of  Auditors  for  statistical  analysis,  for  coordination  with  the  local  public 
prosecutor’s offices and possibly so that action can be taken. 

 
 
  
  
 
 
 
Q1.17 Do you see possible improvement in the exchange of information between judicial and 
reporting authorities? If yes, which ones? How can OLAF / the Commission support this? 

Member 
State 

Response 

IE 

LU 

HR 

SE 

NL 

AFCOS are working with the relevant MAs to ensure the process is clear to all parties. 

No need for improvement identified. 

Ministry  of  Regional  Development  and  EU  funds  -  Directorate  for  the  Implementation  of  the 
Operational Programmes and Financial Instruments propose that OLAF regularly informs Member 
States about the start and end of investigations it conducts. 

 Contribution from Ministry of Finance, Tax Administration: 
 Conclusion of a working agreement with EPPO and enabling EPPO to have direct access to certain 
databases of the Tax Administration.  

Contribution from AFCOS unit: 
The  exchange  of  information  between  judicial  and  reporting  authorities  could  be  improved  by 
mutual trainings (MCS bodies could be trained in the area of Criminal Act, Criminal Proceedings 
Act and practice of judicial and investigative bodies while judicial and investigative bodies could 
be 
funds).  
OLAF  could  contribute  as  an  organizer  of  targeted  training  activities  or  a  speaker  at  training 
activities organized by Croatian authorities. In addition, a round table could be organized in order 
to discuss difficulties related to handling suspected fraud cases from the aspect of MCS bodies and 
judicial bodies. 

of  management 

control 

trained 

area 

and 

EU 

the 

of 

in 

Contribution  from  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  for  Support  in 
Agriculture and Rural Development:  
The exchange of information can be improved by using standardized digital forms between judicial 
and reporting authorities.  

Training  of  case  handlers  working  for  the  managing  authorities,  and  enabling  the  authorities  to 
strengthen  their  internal  processes,  including  justifying  why  an  identified  regularity  is  not 
considered a suspected crime 

The new responsibility takes time to get the organisational structure in place, at this moment no 
help is needed from OLAF/Commission 

FR 

x 

EL 

BE 

The exchange of information between judicial and reporting authorities could be improved through 
the development of an automated data exchange platform (to which all parties involved would have 
access). 

ERDF, JTF and RRF at the SPW:  Yes, work is under way to formally set down an information 
exchange procedure between the judicial authorities and the reporting authority. The purpose of this 
is not only to improve cooperation and the regular exchange of information but also to standardise 
the procedural practices for the submission of files reporting suspected infringements involving a 
criminal offence.  OLAF can support the creation of these procedures by providing information on 
the information exchange procedure between the judicial authorities and OLAF and also by giving 

 
 
  
 
 
 
Member 
State 

Response 

examples of the file submission and information exchange procedure in other Member States or the 
standard procedures expected by OLAF. 

No, support from OLAF is not necessary. 

This is a national competence, and the Commission has no role to play in it. 

Automated data exchange systems or IMS can be used for internal information exchange 

Supreme  State  Prosecutor's  Office  of  the  Republic  of  Slovenia  answers:  Yes,  there  is  room  for 
improvement in the exchange of information between judicial and reporting authorities. Key areas 
for improvement include:  

- Automated transfer of attachments from police to prosecution registers - This would reduce 
administrative workload and minimise manual data entry and document scanning. A pilot test has 
started but has been delayed due to technical constraints. The plan is to gradually extend the test to 
other regions if the technical feasibility is confirmed. 

AT 

FI 

LT 

SI 

start 

early 

-  Electronic  filing  of  court  documents  -  Intensive  discussions  have  taken  place  with  the 
courts to initiate its use and the necessary system upgrades are being tested. The first phase of testing 
will 
cases.  
OLAF  and  the  Commission  could  assist  by  facilitating  technical  solutions,  promoting 
interoperability  standards  and  providing  funding  or  expertise  for  digital  transformation projects. 
Promoting  cross-border  best  practices  and  ensuring  alignment  with  EU-wide  digital  justice 
initiatives would also be beneficial.  

lower 

focus 

court 

2025 

will 

and 

on 

in 

CZ 

Cooperation is at a very high level. No calls for improvements have been received. 

ES 

HU 

SK 

PL 

An improvement would be to be able to obtain more information from the EPPO and for it to be 
communicated to AFCOS in a systematic way, at least annually, with basic information within the 
limits 
of: 
- cases that have been transferred to the National Court, cases that have been finalised in the EPPO, 
and. cases where there is an ongoing investigation in the EPPO. OLAF could help by establishing 
general rules. 

regulations 

allowed 

the 

by 

It  could  be  improved  by  continuing  the  ongoing  development  of  internal  cooperation  between 
Member States’ bodies. OLAF can support such processes by comparing and disseminating existing 
national practices. 

More trainings to strengthen the prevention and detection of fraud and irregularities, creating new 
secure online platform. 

Yes, with regard to some aspects of cooperation, we saw opportunities to improve the exchange of 
information  between  the  judicial  authorities  and  the  reporting  bodies.  For  example,  preparatory 
work is currently underway at the Institution Coordinating the Partnership Agreement in connection 
with the conclusion of an agreement with the National Public Prosecutor, which covers information 
on draft cohesion policy programmes under the 2021-2027 financial perspective. The objective of 
the  agreement  is  to  define  new  rules  of  cooperation  and  the  methods  and  means  of  exchanging 
information.  
The Paying Agency’s cooperation with law enforcement authorities consists in providing all the 
information these authorities require for their investigations in its entirety and in a timely manner. 

 
 
 
 
 
Member 
State 

Response 

Professional representatives of the institutions, both at the stage of preparatory proceedings and, 
potentially, at the stage of judicial proceedings, carry out all the procedural steps provided for by 
law and submit requests to the law enforcement authorities for access to information concerning the 
stage of the relevant proceedings. However, it is for law enforcement authorities and courts to take 
any decisions regarding the scope of information on ongoing proceedings to be provided and on the 
manner of providing it. At the same time, new solutions, such as the above-mentioned digitalisation 
of casefiles and the judicial information portal, have greatly facilitated the institutions’ process of 
obtaining information about ongoing proceedings. However, the decision on whether or not to grant 
access to casefiles (including in digital form) is taken, in accordance with the relevant legislation, 
by the authority handling the case. 

The Baden-Württemberg ERDF Managing Authority: No, there is currently no need to improve the 
exchange of information between judicial and reporting authorities.    

DE 

The Bremen ERDF Managing Authority: No, the existing possibilities for exchanging information 
are sufficient. 

The  Thuringia  ERDF  Managing  Authority:  Faster  processing  by  OLAF;  definition  of  
vague  legal  concepts;  updated  manual/guidance  on  irregularities;  recommendations  for  action; 
presentation of ‘best practice’ procedures. 

BG 

Through specialized targeted trainings and awareness-raising tools (online materials) for specialized 
units  in  the  structure  of  the  reporting  authorities.    Strengthening  and  increasing  the  level  of 
cooperation  with  the  Prosecutor’s  Office  of  the  Republic  of  Bulgaria.  Updating  the  cooperation 
agreement between OLAF and Prosecutor’s Office of the Republic of Bulgaria. Amendments in 
criminal  procedural  legislation  are  needed.  An  improvement  in  the  exchange  of  information 
between  judicial  and  reporting  authorities  can  be  achieved  through  informing  the  reporting 
authorities of the results of judicial proceedings/sending final judicial decisions. Start using digital 
platforms, like automated data exchange systems. 

MT 

Yes, receiving periodical feedback from judicial national authorities and the EPPO. 

CY 

EE 

RO 

Yes,  establishment of an online  secured platform via which all the national authorities (AFCOS 
members  and  Judicial  Bodies  e.g.  Attorney  General/EPPO  /Independent  Authority  Against 
Corruption/Police can exchange information on reporting and also on status of cases. 

We  exchange  general  information  on  a  regular  basis,  but  it  is  not  possible  to  share  detailed 
information on specific cases. This is regulated at the national legal level. 

-  DLAF:  Yes.  The  communication  of  specific  information  on  the  reporting  criteria  in  the  IMS. 
Specific regulations concerning reporting by the judicial authorities. 

- AFIR: Yes. Following criminal investigations, insofar as irregularities in the use of EU funds are 
found,  the  competent  bodies  could  send  evidence  to  the  AFIR  with  a  view  to  triggering  the 
procedures for detecting irregularities and establishing budget debts independently of the outcome 
of criminal investigations.  The organisation of the training session on reporting. 

- DGP-AM POPAM: Yes, through the conclusion of protocols between the judicial and reporting 
authorities  for  the  quarterly  matching  of  cases  referred  for  investigation.  We  think  that  the 
Commission could regulate this type of activity.   

 
 
 
Member 
State 

Response 

-  The  Ministry  of  Energy:  By  providing  regular  information  at  courses  or  seminars  specifying 
methods for avoiding the risk of fraud and corruption arising from relevant cases or from allowing 
access to databases or reports generated from them for companies considered to be ineligible and 
to be avoided. 

- West Regional Development Agency (ADR VEST): The exchange of information between the 
judicial and reporting authorities can be improved by the adoption of mechanisms and procedures. 
Possible  measures  include:  the  conclusion  of  agreements/protocols  between  the  judicial  and 
reporting  authorities.  The  organisation  of  joint  training  sessions:  these  could  improve  mutual 
understanding  of  the  needs  and  responsibilities  of  each  party  involved.  The  development  of 
automated systems for the supply of/access to data/information  – interoperability of databases.  - 
MIPE – DGPDD: Through the creation of an automated data exchange system 

- MIPE – AM POCU: Yes, through the implementation of a digital platform for the exchange of 
information in real time between authorities  

- MIPE – DGPS: Yes, through the organisation of regular meetings or through the creation of an 
automated data exchange system. 

-  MIPE  -  DGMMRR:  The  judicial  authorities  have  access  to  the  platforms  used  in  the 
management/implementation  of  the  PNRR.  In  this  respect,  collaboration  protocols  have  been 
concluded between MIPE -DGMMR and institutions with investigative/control tasks. 

- MIPE - Directorate-General for Just Transition and Economic Competitiveness (DGTJCE): there 
is a common DLAF/DNA/EPPO database  

- MMAP: Through the creation of an automated data exchange system 

PT 

LV 

Yes,  through  the  creation  of  dedicated  IT  platforms  to  be  used  jointly  by  judicial  bodies  and 
administrative authorities, in order to enable up-to-date monitoring of cases and faster information 
sharing. 

Develop  more  secure  and  specialized  information  exchange  channels.  Financial  support  for 
developing digital tools. 

DK 

No possible improvement reported. 

IT 

The European Public Prosecutor’s Office (EPPO) established by Regulation (EU) 2017/1939 has 
been fully operational for around three years and is competent for almost all types of crime against 
the  financial  interests  of  the  EU.  We  thus  believe  that  there  should  be  a  more  robust  form  of 
information sharing between OLAF and the EPPO, including as regards the possible introduction 
of a single fraud detection and monitoring system. OLAF could support this process as part of its 
relations with the EPPO. 

Q.1.18 Please feel free to share any additional thoughts or experiences you have regarding the 
topics discussed in this section. 

Member 
State 

Response 

IE 

n/a 

 
 
 
Member 
State 

Response 

LU 

N/A 

Contribution from AFCOS unit:    
In October 2023 OLAF organised an online training for Croatian authorities that was attended by 
more  than  300  participants.  In  addition,  in  October  2024  OLAF  organised  a  webinar  on  IMS 
refactoring.  Croatian  authorities  found  the  trainings  very  informative.  However,  they  expressed 
need  for  more  specific  trainings  that  would  include  case  studies  and  exchange  of  practice  with 
OLAF  and  member  states  as  well  as  periodical  trainings  on  the  use  of  IMS  where  reporting 
challenges could be presented and discussed.  

N/A 

N/A 

x 

No further comments required. 

/ 

No information. 

- 

- 

- 

- 

Possibly one way to get authorities to report irregularities to OLAF completely, correctly and on 
time  would  be  to  establish  some  kind  of  consequence  for  non-compliance  depending  on  the 
seriousness of the non-compliance and applying the principle of proportionality. 

The establishment of a single contact point (Directorate for Internal Control and Integrity) has, on 
the basis of experience so far, already added significant value in its cooperation with investigative 
and judicial bodies. 

x 

None 

The  Lower  Saxony  ERDF  Managing  Authority:  The  exchange  between  the  authorities  and 
intermediate body (NBank) in case of a criminal complaint via the direct communication channels 
and the close exchange is guaranteed at all times. 

Bremen: There were no potential cases of fraud in 2024. 

N/A 

Kindly refer to the replies provided. 

HR 

SE 

NL 

FR 

EL 

BE 

AT 

FI 

LT 

SI 

CZ 

ES 

HU 

SK 

PL 

DE 

BG 

MT 

 
 
Member 
State 

Response 

CY 

No additional thoughts. 

EE 

RO 

PT 

If possible, the EPPO regulation could stipulate the exchange of information on investigations and 
cooperation with AFCOS’s. 

The Ministry of Energy: We consider that access to interconnected databases in which to check 
financial and legality aspects in order to exclude companies which are not eligible would help to 
mitigate possible irregularities.  

The purpose of establishing a body of facts preventing and restricting access to the EU Funds is to 
prevent and combat fraudulent practices in connection with receiving financing from the Funds, 
based on rigorous scrutiny of applicants. This is achieved through the creation, management and 
consultation of a database containing relevant information on the good standing and debt situation 
of parties that have already benefited or will benefit from support from the EU Funds. The European 
Commission’s growing concerns about fraud and the establishment of channels for the handling of 
complaints/reports on the use of support co-financed by the Cohesion Policy Funds have made it 
necessary  to  adopt  a  specific  methodology  for  determining  parties’  good  standing  and  debt 
situations,  which  enables  this  access  requirement  to  be  managed  effectively.  This  should  be 
instrumental  in  assessing  the  level  of  risk  that  parties  may  present,  thereby  making  a  decisive 
contribution to the effective protection of the financial interests of the EU and of the Member States, 
based on the coordination of various sources of information found in databases held by national 
authorities 
Commission.  
For  Portugal  2030,  the  codification  regarding  good  standing,  reliability  and  debt  situation  to  be 
observed in the classification of parties receiving or applying for support from the Cohesion Policy 
Funds has been approved, as has the procedure for managing this information. In other words, the 
information on the good standing, reliability and debt situation of beneficiaries of the EU Funds 
must be kept in a specific information system, which supports the action of all the bodies involved 
in  Portugal  2030,  and  determines  the  subsequent  action  of  the  managing,  paying  and  auditing 
authorities in respect of applications or projects of beneficiaries that have already been approved.  
The  codification  of  this  information  was  based  on  data  contained  in  audit/monitoring  reports, 
complaints, criminal or administrative proceedings for violations of legislation on child labour and 
discrimination  in  work  and  employment,  enforced  collection  proceedings  through  the  tax  courts 
(tax enforcement proceedings), insolvency proceedings and special revitalisation proceedings. 

European 

available 

made 

and 

the 

by 

LV 

NA 

DK 

The Danish Agency for Green Land Conversion and Water Environment: Denmark reports cases of 
suspected  fraud  to  the  Commission  when  such  a  case  is  handed  over  to  the  police.  A  police 
investigation  can  be  time-consuming,  and  it  is  natural  that  it  will  occasionally  disprove  the 
suspicion. Those conditions contribute to the observed trends with cases being open for a long time 
and cases that do not lead to prosecution. Nevertheless, there is still a potential for improvement in 
the  area  and  the  paying  agency  for  agricultural  support  has  implemented  a  significant  effort  to 
2022-2024.  
achieve 
The Agency has set up a unit to follow up on cases of suspected fraud or circumvention in order to 
secure resources and the right skills for the task. This has significantly reduced case processing time 
and improved the quality of police reports in the paying agency, which provides better conditions 
for 
follow 
Since  the  end  of  2023,  the  case  processing  time  at  the  police  has  also  gradually decreased  with 

period 

police 

the 

the 

the 

on 

up 

to 

in 

reports.   

 
 
Member 
State 

Response 

regard to reports of suspected subsidy fraud. The paying agency held a meeting with the Director 
of  Public  Prosecutions  in  February  2024.  The  meeting  has  improved  cooperation  between  the 
authorities through a better common understanding of the legal basis. In the second half of 2024, 
the paying agency has noted an increase in the number of reports coming before a court. The Paying 
Agency  for  Agricultural  Support  will  maintain  the  cooperation  and  internal  efforts  with  the 
expectation of achieving further improvements in the area. 

Q.2.1. Have you ensured that the digitalisation of the fight against fraud is part of your NAFS 
(National anti-fraud strategy)? 

Response 

YES 

Not  yet,  but  we  intend  /  are  in  the  process  of 
developing this part of the strategy 

Digitalisation  of  the  fight  against  fraud  is  part  of 
another strategy / assessment / policy (please specify) 

NO 

8 

7 

2 

Frequency 

Percentage 

Member States 

10 

37.0% 

FR, AT, ES,  HU, 
SK, MT, RO, PT, 
LV, IT 

LU,  NL,  BE,  FI, 
LT, CZ, BG, CY 

HR,  SE,  EL,  SI, 
PL, EE, DK 

29.6% 

25.9% 

7.4% 

IE, DE 

Following  Q.2.1,  please  specify  "Digitalisation  of  the  fight  against  fraud  is  part  of  another 
strategy / assessment / policy". 

Member 
State 

Response 

HR 

The Republic of Croatia has adopted two anti-fraud strategies related to the protection of the EU´s 
financial interests so far and they were both communicated to OLAF. One covered the period 2010-
2012 (adopted 14/01/2010) while the other covered the period 2014-2016 (adopted 23/01/2014), 
and both strategies were fully implemented. Considering that the Anti-Fraud Coordination System 
in the Republic of Croatia has been established, fully operational, and no major weaknesses were 
identified, there were no new anti-fraud strategies aimed at protection of financial interests of the 
EU  adopted,  neither  update  of  the  existing  ones  have  been  made.  Yet,  AFCOS  system  in  the 
Republic of Croatia has been constantly fine-tuned through softer measures. Contribution from the 
Ministry  of  Finance,  Custom  Administration:  In  Implementation  Programme  of  the  Ministry  of 
Finance   
(https://mfin.gov.hr/UserDocsImages/dokumenti/proracun/stratesko/Provedbeni%20program%20
Ministarstva%20financija%20za%20razdoblje%202025.-2028.pdf)  –  Measure  29  prescribes 
“Enhancement of digitalisation and adjustment of e-customs, excise and other information systems 
and optimization of infrastructure and equipment. 
In addition, Ministry of Agriculture, Forestry and Fisheries, Directorate for Support in Agriculture 

 
 
 
 
 
Member 
State 

Response 

and Rural Development and Directorate of Fisheries highlighted the following answer: Not yet, but 
we intend / are in the process of developing this part of the strategy. 

SE 

Implementing  authorities,  AFCOS  and  audit  body  all  have  different  digitalisation  strategies  and 
policies. 

Digitalisation  concerns  the  sectoral  Anti-Fraud  Strategy  (Structural  Funds)  of  the  programmes 
under the 2021-2027 Partnership Agreement for Regional Development (ESPA). In particular with 
regard  to  the  reception  and  examination  of  complaints  concerning  the  programmes/projects  co-
financed under the 2021-2027 Partnership Agreement for Regional Development, Article 50(1) of 
Law  4914/2022  states  that  ‘The  Secretariat-General  for  Public  Investments  and  the  Partnership 
Agreement  for  Regional  Development (ESPA)  of  the  Ministry  of  Development  and  Investment, 
through  the  Special  Service  for  Institutional  Support  and  Information  Systems  (EYTHYPS),  is 
responsible for ensuring that complaints which fall within the scope of the programme are examined 
by  means  of  the  management  and  control  system(s).  In  order  to  simplify  and  accelerate  the 
procedure between the stakeholders, complaints and examination findings are recorded, information 
is exchanged, and the related documents are transmitted electronically by authorised users, through 
the integrated information system (IIS).’ Implementation of the above-mentioned provision in the 
IIS  is  expected  to  start  later  this  year.  The  MAs,  responsible  for  detecting  irregularities  in  co-
financed  projects,  exchange  relevant  information  using  the  authorised  access  of  the  Anti-Fraud 
Officer  in  each  MA  to  the  special  space  created  for  the  Internal  Anti-Fraud  Network  on  the 
DIAVLOS electronic platform. The technical infrastructure of the IIS has been set up to allow it to 
interconnect  with  the  central  beneficial  ownership  register.  The  pilot  operation  phase  has  been 
completed and full operation is expected in the immediate future. The NTA/AFCOS networking 
platform is used by AFCOS and the competent ESPA authorities to facilitate the management and 
best possible identification of complaints submitted concerning co-financed projects and operations. 
Cooperation  through  this  tool  is  always  encrypted  using  strong  authentication  procedures  for 
accredited users only. 

Financial Amin. of the Republic of Slovenia: Indeed, the digitalisation is the part of the Strategy of 
the Financial Administration of the Republic of Slovenia (FARS), FARS Work Program and the 
FARS  Annual  Report.  Furthermore,  the  risk  management,  risk  analysis  and  Compliance  Risk 
Management (CRM) are also included in such strategy for particular working fields. 

Poland has not adopted a national anti-fraud strategy (NAFS). Poland has not decided to create such 
a document, and the European Commission does not oblige Member States to do so. The competent 
institution of the management and control system, on the other hand, have mechanisms under which 
they carry out their anti-fraud mission, including the digitalisation of anti-fraud measures. 
The managing authorities of all cohesion policy programmes are required to draw up a document 
on  how  to  prevent  and deal with  corruption  and  fraud,  including  conflicts  of  interest  within  the 
respective programme. The authorities also include information on the digitalisation of anti-fraud 
measures in their documents. This programme-based approach allows for a proper assessment of 
the  current  situation  with  regard  to  anti-fraud  measures,  and  for  risk  assessment  and  the 
development  and  introduction  of  proportionate  measures  to  combat  fraud  at  the  lowest  possible 
management level.  
When drawing up programme documents, the institutions involved in the implementation of EU 
funds also take account of the fact that fraudulent operators use new technologies to commit fraud. 
To counter this, growth concepts are being developed for the existing IT tools and ways in which 

EL 

SI 

PL 

 
 
  
 
Member 
State 

Response 

they  can  be  used  to  combat  fraud.  In  this  way,  the  digitalisation  of  the  area  of  implementation, 
management  and  control  of  cohesion  policy  is  constantly  evolving  (implementing  new 
functionalities and improving existing functionalities), and it is at a rather advanced stage in Poland. 
There are direct possibilities for the digitalisation of the fight against fraud and the use of modern 
technologies in Poland by the relevant investigation services. 

Estonia's digitalization strategy can be called the "Digital Society Development Plan 2030" (DAK), 
and to implement it, each ministry prepares an ICT strategy for its own field. The DAK does not 
contain sectoral digitalization goals, and these should be included in the ICT strategy of the MoF, 
which is not a public document.    
We do not have a NAFS at the national level. We have several different strategies, and all these 
documents  have  digitalisation  information.  We  have  established  minimum  requirements  for 
controls,  created  a  cross-check  possibility  between  different  databases.  Additionally,  we  have 
proposed cooperation with national investigative bodies, which could contribute even more to the 
analysis  of  digital  data  related  to  grants  to  identify  potential  vulnerabilities  and  fraud.  Once 
agreements  are  reached,  they  can  also  be  formalized  or  confirmed  at  the  level  of  a  strategy, 
cooperation agreement, or other document. 

EE 

DK 

Digitalisation  of  the  fight  against  fraud  is  part  of  the  anti-fraud  strategy  of  EMFF/EMFAF  in 
Denmark. 

Q.2.2. If “YES” to Q.2.1, please describe how it has been implemented. 

Member 
State 

Response 

FR 

in 

to 

order 

establish 

In combating revenue fraud, for example, the French customs administration plans to make use of 
data  mining 
traders.  
On the expenditure side, the DGEFP has developed a  complete data  science platform making it 
possible to identify risk elements in the files and, thereby help the departments managing the ESF 
to detect fraud.   
France’s NAFS has promoted regular use of the Early Detection and Exclusion System (EDES) to 
various authorities. 

profiles 

rapidly 

at-risk 

the 

of 

AT 

Use of the ARACHNE data mining tool 

ES 

HU 

The NAFS includes measures such as the improvement of tools for risk analysis, the widespread 
use of databases for prevention and detection purposes, and the analysis of the interoperability of 
databases. On the other hand, the guidelines of the State Tax Agency’s tax and customs control plan 
focus on the use of technology in the fight against fraud.  

On the basis of the periodic review of the EUPR and FAIR system with a view to exploring and 
taking advantage of opportunities to prevent fraud and corruption, improvements have been made 
to the fraud prevention function, to manage project  transfers and succession, strengthen the link 
with  the  Irregularity  Management  Database  and  enable  ARACHNE  commitments  to  be 
implemented. 

 
 
 
Member 
State 

Response 

SK 

The Slovak Republic aims to ensure that the digitalization of the fight against fraud is an integral 
part of our National Anti-Fraud Strategy (NAFS). This strategy emphasizes the need to utilize all 
available  IT  tools  (including  ARACHNE)  in  the  fight  against  fraud  and  calls  on  the  relevant 
authorities to use these tools in their activities for the prevention and detection of fraud cases and 
other irregularities. The structured exchange of data and information between anti-fraud authorities 
and  managing  authorities  is  highlighted  in  the  NAFS  as  a  fundamental  principle  of  fraud 
investigation and prosecution. 

A Central Document Repository System (CDRS) has been implemented through the creation of a 
digital platform that allows file and document sharing between the members of the Co-ordinating 
Committee, set up in terms of Article 23 of the Internal Audit and Financial Investigations Act (Cap. 
461  of  the  Laws  of  Malta)  'to  co-ordinate  the  activities  of,  and  to  facilitate  the  exchange  of 
information  between,  different  entities  charged  with  the  protection  and  safeguarding  of  public 
funds'.   
The  CDRS  was  set  up  in  line  with  Action  Points  13  and  14  of  the  National  Anti-Fraud  and 
Corruption  Strategy  (NAFCS),  as  well  as  Malta's  Recovery  and  Resilience  Plan  (RRP) 
commitments, and has the following features: 

MT 

- Stores electronic documents;  
- Offers a centralised access to documents that can be easily retrieved by the  

members of the Co-ordinating Committee; and 

- Provides the necessary security for sensitive information.  

In addition, IAID has compiled a list of software tools that are being used to assist each member of 
the Co-ordinating Committee in the prevention, detection, reporting, investigation, prosecution and 
correction 

corruption 

irregularities.   

fraud 

and 

of 

Information provided regarding (1) the procurement method used and (2) the involvement of the 
Ministries’ respective Information Management Unit (IMU) in the procurement of new software 
restricts procurement duplications and also ensures that the use of such software is optimized, as 
well as enables the sharing of best practices in the use of software tools.  

-  ADR  VEST:  Specific  objective  No  1.4.  Streamlining  the  reporting  of  irregularities  within  the 
framework of the 2023-2027 NAFS aims to standardise and create a uniform reporting process, and 
ensure the quality and comparability of the data provided by the Romanian authorities, bearing in 
mind the need for the European Commission to set up a uniform digital, interoperable system for 
the collection of comparable data on irregularities and cases of fraud from the EU Member States. 

Control 

-  AFIR:  The  existence  of  the  Register  for  Suspected  Fraud  and  Indicators  of  Fraud  and  of  the 
Electronic Register of Evidence of AFIR correspondence with EPPO, DNA,  DLAF, IPJ, OLAF, 
DG Agri, and ECA: both registers are managed by the External Operational Cooperation Service of 
the 
Directorate. 
In the Register for Suspected Fraud and Indicators of Fraud, the irregularities officer, a position 
provided for by Article 25 of Government Decision No 875/2011 approving the implementing rules 
for Government Emergency Order No 66/2011, keeps a record of the referrals to the EPPO/DNA, 
DLAF pursuant to Article 8(1) or (11) of Government Emergency Order No 66/2011 concerning 
projects  relating  to  the  2007-2013  and  2014-2020  NRDPs  and  the  transition  period  in  which 
suspected fraud or attempted fraud has been identified. 

Anti-Fraud 

and 

RO 

 
 
 
 
 
 
 
  
 
  
Member 
State 

Response 

The Electronic Register of AFIR correspondence with EPPO, DNA, DLAF, IPJ, OLAF, DG Agri 
and  the  ECA  records  all  correspondence  between  the  AFIR  (headquarters,  regional  centres  and 
county offices) and these institutions, correspondence which has or may have possible fraud in the 
subject.  
implementation 

EAFRD 

projects 

its 

as 

of 

Also, the local structures of the AFIR are required to report to the Director-General and Control and 
Anti-Fraud  Directorate  all  situations  in  which  CRFIR/OJFIR  staff  are  asked  to  appear  at  the 
headquarters  of  the  control  or  criminal  investigation  bodies  in  order  to  be  consulted  on  aspects 
relating  to  the  projects  implemented  and/or  the  work  carried  out  depending  on  the  duties  of  the 
service, 
procedure. 
type 
- MIPE – AM POCU: Through regular working meetings 

irrespective 

judicial 

the 

of 

of 

PT 

LV 

IT 

The  NAFS  includes  a  specific  measure  on  the  general  use  of  all  tools  made  available  by  the 
European Commission for the purposes of assessing and mitigating the risk of fraud, particularly 
ARACHNE  and  OLAF’s  Early  Detection  and  Exclusion  System 
(EDES)  database.  
The systems covered by Portugal 2030 are already sending data to ARACHNE. 

Ensuring access to various databases of national importance, introducing automatic controls is a 
determining factor for both fraud prevention, detection and investigation and it is included in the 
NAFS.  In  the  NAFS  period  from  2024  to  2026,  it  is  planned  to  continue  optimizing  the  use  of 
available national information systems for combating fraud, analysing which national information 
systems  could  still  be  interconnected  and  what  are  the  problems  of  data  analysis,  as  well  as 
identifying opportunities for automatic controls. 

On this point, the situation in Italy is that there is a comprehensive system that fully meets the need 
to  prevent  and  combat  fraud  against  the  EU.  Each  institution,  agency  and  body  responsible  for 
managing EU resources in various capacities and according to various remits has set up over time 
– as part of an ongoing process of digitalising the fight against fraud – many systems, applications 
and databases, as well as methods and procedures, to properly ensure prior assessment of the risk 
of  fraud,  corruption,  conflicts  of  interest  and  double  funding  in  connection  with  EU  budget 
implementation.  
With  regard  to  budget  revenue  and  specifically  traditional  own  resources,  the  Customs  and 
Monopolies Agency has reported that risk analysis activity in 2023 was based on examining the 
main information sources, with particular focus on information from reliable sources such as OLAF 
(around  50  INF  MA  mutual  assistance  reports)  concerning  all  of  the  main  financial  risk  areas: 
evasion  of  anti-dumping  duties  or  countervailing  duties,  under-invoicing,  misclassification  of 
goods, abuse of preferential origin, abuse of procedure 42/63. 
Analysis of the INF MA reports triggered the following activities: 

- 
- 

addition of more than 300 new risk profiles (relating to goods or to natural/legal persons); 
 amendment and/or recalibration of almost 400 existing risk profiles. 

In addition, more than 300 RIFs (Risk Information Forms) were issued via CRMS2 (Customs Risk 
Management  System  2.0).  These  concerned  tax-related  risks  and  led  to  the  addition  of  around 
80 new risk profiles. 
What  is  more,  risk  profiles  are  still  in  place  for  the  fight  against  under-invoicing  using  various 
control strategies targeting both goods and persons.  
As  regards  checks  when  customs  declarations  are  submitted,  the  fight  against  under-invoicing 
follows two parallel tracks: 

 
 
 
 
 
 
Member 
State 

Response 

- 

- 

for the first track, the analysis tool used to identify value thresholds is the dashboard 
in the THESEUS database provided by the Commission; 
the second track uses CREDIBILITY, a new tax monitoring methodology for the fight 
against 
Agency.  
was 
On the issue of e-commerce, a risk analysis strategy based on a statistical approach is 
being developed and tested with the aim of identifying any anomalies in the value of 
imports. 

under-invoicing 

developed 

that 

the 

by 

the  basis  of  analysis  of 

the  Cognos  Datawarehouse  on 

The statistical analysis is based on processing a significant quantity of data on e-commerce extracted 
from 
the  H7  dataset.  
With informatics support from specific artificial intelligence algorithms based on the programming 
language  Python,  the  statistical  analysis  aims  to  identify  items/declarations  with  anomalous  unit 
values (€/kg) (‘outliers’), i.e. values below a given threshold or above a given ceiling. 
During 2023, work also continued on assessing risks using some specific methodologies in use at the 
Agency. These include the Fiscal Vigilance methodology. This consists in an analysis application 
which, using various search criteria such as the 10-digit customs code (TARIC) and the country of 
origin, calculates the ‘threshold value’ of goods via an algorithm based on the maximum number of 
transactions in a given period of time (usually two months). The ‘threshold value’ or statistical limit 
value is the value beneath which an amount entered on a declaration is considered to be an under-
invoicing risk. The algorithm subdivides the transactions carried out into percentiles (calculated on 
a  base  of  10 or  100)  and,  by  applying  Gaussian  distribution  (a  bell  curve  representing  a  precise 
statistical  curve),  calculates  the  values  that  are  at  either  end  of  the  curve  and  thus  considered 
borderline cases and/or anomalous values. The application can also be used to adjust the risk profiles 
by ‘categorising’ the findings of checks. Every finding of a checking activity is ‘categorised’ as either 
compliant or non-compliant and according to the type of non-compliance (nature, quantity, value). 
At the end of the categorisation, the application is asked to calculate the threshold value with which 
the  profile  should  be  associated  (for  a  given  profile,  declarations  are  selected  based  on  the 
‘< threshold value’ criterion, meaning that if the value declared is less than (‘<’) the ‘threshold value’, 
under‑invoicing).  
it 
Another interoperability system and tool used for risk analysis is the aforementioned Customs Risk 
Management System (CRMS). This EU system for sharing risk reports between the Member States 
allows the customs authorities and the Commission to cooperate and priority control areas and crises 
to be managed. This application is hosted on a dedicated, protected network and allows the Member 
States to exchange risk information in real time.  
The CRMS comprises various domains designed for different purposes: 

deemed 

case 

be 

of 

to 

is 

a 

- 

-  RIF  (Risk  Information  Form):  for  exchanging  information  received  from  all  Member 
frauds;  
States 

non-tax 

and 

tax 

on 

-  CM 

(Crisis  Management):  crisis  management  dashboard 

(e.g.  COVID,  etc.);  

- 

PCA  (Priority  Control  Area):  priority  control  areas  determined  by  the  European 
Commission;  

-  RMCS (Risk Management Collaboration Service): a collaboration request (CLR) is created 
when it is deemed necessary to request an action or some information to confirm the risk 
indicator or anomaly for a specific consignment, whether incoming, in transit or outgoing;  
PRCI (Platform of Risk and Control Information): where specific risk detection methods 
exist (X-Ray Risk Form, K9 ‘Canine’ Cases Form and Rummage Cases Form.  

- 

Platform members add other details on risks using messages and secure email. Further assistance in 
mitigating the risk of fraud comes from ‘reports’ and ‘searches’ on the platform concerning all types 
infringements.  
of 

 
 
 
 
 
 
Member 
State 

Response 

In  the  same  year,  the  Anti-Fraud  Directorate  trialled  an  Excel  spreadsheet  for  the  LEA  (Logic, 
Experience  and  Analysis)  project,  which  gives  concrete  form  to  a  risk  matrix  aimed  at  the 
development of predictive models by:  

- 

- 

using an overall set of information that can be derived from the databases available to the 
Agency concerning imports, exports, cash import declarations and citations for cash import 
infringements;  
obtaining  open-source  information  concerning  economic  studies,  statistical  publications, 
etc.,  so  as  to  analyse  potential  inconsistencies  (concerning  individual  persons  or  general 
categories  of  ATECO  code  or  business/goods  sector)  in  the  relationship  between  cross-
border movements of cash and the income declared by the offender or the person engaged 
in transit.  

The  risk  matrix  was  used  in  2023  in  relation  to  various  reports  sent  to  the  national  financial 
intelligence unit (FIU) in order to prevent and combat money laundering linked to tax evasion and/or 
other serious tax and non-tax offences potentially involving cross-border movements of cash. The 
trialling of the LEA project led to dozens of reports also being sent to the Public Prosecutor’s Office’s 
Anti-Mafia  and  Anti-Terrorism  Directorate  and  the  local  offices  of  the  Customs  and  Monopolies 
Agency responsible for border crossings in order for targeted checks to be carried out on movements 
of cash and goods deemed to pose a risk of tax evasion, customs infringements linked to the taxable 
amount (under-invoicing or over-invoicing), infringements linked to the nature, quantity and origin 
of the goods declared for import and export, and money laundering.  
Work  is  also  being  done  to  deploy  the  LEA  model  for  the  purposes  of  applying  Article 7  of 
Regulation  (EU)  2018/1672  and  thus  temporarily  detaining  cash  that  is  moved  cross-border  in  a 
suspicious manner. 
Again with regard to budget revenue, and specifically VAT, the Revenue Agency has taken specific 
steps to prevent losses to the exchequer as a result of intra-EU VAT fraud by ensuring that national 
entities that commit VAT evasion by operating as shell companies in fraudulent schemes (‘missing 
traders’ or ‘defaulters’) have their VAT number swiftly cancelled or are excluded from VIES (VAT 
Information Exchange System) pursuant to Article 35(15-bis) of Presidential Decree No 633/1972 
and  the  new  paragraphs  15-bis-1  and  15-bis-2  (introduced  with  effect  from  1 January  2023).  
In this context, particular emphasis was placed on data from electronic invoices issued and received 
and  on  some  innovative  tools  for  cooperation  with  other  European  countries.  With  regard  to  the 
database  of  electronic  invoicing  data,  since  2023  it  has  been  possible  to  access,  under  certain 
conditions, specific data concerning the goods to which invoices relate. This allows for more detailed 
control and monitoring of the transactions carried out by high-risk entities.  
The TNA (Transaction Network Analysis) tool developed by the European Commission for Eurofisc 
purposes  continues  to  make  a  particularly  important  contribution.  It  makes  it  possible  to  obtain 
information from the VIES of all EU Member States and analyse that information in one go. Intensive 
work continues to fight VAT fraud committed through the submission of false letters of intent. The 
entities posing the highest risk were identified thanks to timely analysis of all declarations of intent 
sent and, once irregularities were proven, formal notices were issued, and warning letters were sent 
to the sellers so as to stop the flow of fraudulent invoices and prevent further losses to the exchequer. 
The extent of the phenomenon has reduced significantly in the fuel sector thanks to the introduction 
of Article 6 of Decree-Law No 124/2019, and the sectors most affected are the clothing and clothing 
accessories sectors.  
The intention for the coming years is to strengthen the activities described above by stepping up risk 
analysis activities, including new AI and machine learning tools. In terms of technology, a new anti-
fraud analysis tool, TAXNET, is fully operational. Through the interoperability of various databases 
(electronic invoices, declaration data, personal data, bank transfers, VIES, etc.), it makes it possible 

 
 
 
 
 
 
Member 
State 

Response 

to  automatically  reconstruct  the  entire  fraud  chain  and  rapidly  map  the  links  and  recurrent 
connections  between  the  various  entities  (natural  and/or  legal  persons)  involved  in  fraudulent 
transactions. 
With regard to budget expenditure, risk assessment in relation to cohesion policy funding is one of 
the  main  control  functions  of  the  various  managing  authorities.  The  MAs  widely  apply  EGESIF 
Guidance Note No 14-0021-00 issued by the European Commission on 16 June 2014 and concerning 
‘Fraud Risk Assessment and Effective and Proportionate Anti-Fraud Measures’ and extensively use 
Arachne. 
The Arachne risk assessment system was developed by the European Commission to help Member 
States prevent fraud. It processes and analyses the data provided by EU countries on beneficiaries, 
contractors  and  other  project  stakeholders  and  carries  out  cross-checks  between  that  data  and 
information  from  external  databases  on  undertakings  and  linked  persons,  making  it  possible  to 
identify projects, beneficiaries and contractors posing a fraud risk.  
Originally developed for the cohesion policy, the tool was extended to the CAP via a pilot project 
launched  in  February  2019  for  rural  development  projects.  Various  national  administrations 
expressed the need to have uniform national guidance on how to use Arachne as a tool to improve 
the identification, prevention and detection of fraud, in line with the requirements of their respective 
management  and  control  systems.  To  answer  this  need,  the  administrations  were  notified  of  the 
establishment of a technical working group for this purpose chaired by the Inspectorate-General for 
Financial Relations with the European Union at the State General Accounting Department, which 
comes  under  the  Ministry  of  Economic  Affairs  and  Finance,  and  made  up  of  representatives  of 
several managing authorities and audit authorities for ERDF and ESF operational programmes 2014-
2020, the Agency for Territorial Cohesion and the National Agency for Active Labour Market Policy.

That working group, which was established by Decision of the Head of the State General Accounting 
Department of 18 January 2019, drew up the ‘National guidelines for using the EU anti-fraud system 
Arachne’.  Aimed  at  managing  authorities,  certification  authorities,  audit  authorities  and  the 
intermediate bodies of operational programmes, those guidelines provide specific guidance on how 
the use the tool so as to help ensure compliance with anti-fraud legislation. 
In relation to their respective management and control systems, each administration, on the basis of 
its internal organisation, structural staffing level, and verification and oversight requirements, was 
able to choose the administrative stages at which the system would be used, in line with the existing 
specifications of EGESIF Guidance Note No 14-0021-00 of 16 June 2014. 
At  central  level,  as  part  of  its  role  of  coordinating  authorities  and  audit  functions,  the 
Inspectorate‑General for Financial Relations with the European Union (IGRUE) (part of the State 
General Accounting Department, which comes under the Ministry of Economic Affairs and Finance) 
issued  its  own  Handbook of Audit  Procedures  2021-2027 of  29 February  2024,  which  includes a 
specific section on risk assessment.  
In  this  context,  IGRUE  has  developed  a  national  risk  assessment  methodology,  available  on  the 
MyAudit information system, which has a greater level of detail, and some differences compared to 
the methodology set out in the aforementioned EGESIF Guidance Note, especially as regards the 
method for calculating the risk score. 
IGRUE is also responsible for managing the Single Database (BDU), which contains all information 
on the planning and implementation of measures financed with regional policy funding from EU and 
national sources.   
The Guardia di Finanza has economic/financial police functions that cover all types of infringement 
against the national and European budget, and as a result it carries out risk analysis and assessment 

 
 
 
 
 
 
 
 
 
 
Member 
State 

Response 

activities in respect of both revenue and expenditure.  
In order to combat VAT fraud, the Special Unit for Protecting Revenue and Combatting Tax Fraud 
conducts  ongoing  risk  analysis  to  identify  undertakings  presumed  to  be  involved  in  fraudulent 
schemes  and  then  charges  the  force’s  local  departments  with  carrying  out  the  necessary 
investigations. 
This analysis is based, firstly, on an examination of information from the Eurofisc network, as part 
of which the aforementioned TNA platform has been running since 2021. This makes it possible to 
use  advanced  analysis  tools  to  rapidly  and  specifically  identify  potential  cases  of  intra‑EU  VAT 
fraud. 
This  information  is  cross-checked  against  search  results  from  the  many  databases  to  which  the 
Guardia di Finanza has access, including:  

- 

- 

- 

- 

the  STAF  (Anti-Fraud  Tool)  application,  which  ensures  effective  monitoring  of 
VAT‑registered taxpayers so as to promptly identify entities involved in tax fraud and assign 
a risk score to each of them; 
- the Invoices and Payments portal and the @-Fattura [@-Invoice] application, which allow 
targeted and integrated analysis of electronic invoice data; 
-  the  EMCS-eAD  Dogane  [Customs]  and  COGNOS  -  Dogane  e  Accise  [Customs  and 
Excise] applications, which make it possible to monitor the circulation of products subject 
to excise duty and operators in the sector. These applications are particularly useful in the 
fight against VAT fraud relating to fuels; 
- COGNOS - area Analisi libera Italia [Italy free analysis area], a partition of the ‘Customs 
declarations’  section  of  the  COGNOS  business  intelligence  platform,  which  makes  it 
possible to carry out multidimensional processing using historical customs declaration data 
concerning the month preceding the query. It is especially useful for selecting entities for 
post-clearance customs controls, for conducting any subsequent in-depth investigations and 
for  carrying  out  any  other  investigative  activities  requiring  the  reconstruction  of 
international trade flows, including from past periods. 

Further  specific  analyses  have  been  developed  by  the  Special  Unit  for  Protecting  Revenue  and 
Combatting Tax Fraud so as to combat undue offsetting and fraud in the assignment to third parties 
of  building  and  energy  tax  credits,  including  the  ‘110%  Superbonus’  scheme  co-financed  by  the 
National Recovery and Resilience Plan (NRRP). Some of the main applications used for this are: 

- 

P.  Ris.  M.A.  -  Collections,  Monitoring  and  Applications  Portal,  which  allows  precise 
consultation of taxpayers’ subsidised tax credits and data on assignments of credits to third 
parties; 

-  Moni. C. - Monitoring of Offsetting, which allows both individual and bulk searches to be 
carried out by processing the data from F24 tax payment forms to detect undue offsetting of 
tax credits. 

is 

to 

Tax 

which 

linked 

Revenue 

Agency’s 

Another  key  tool  for  risk  analysis  in  the  area  of  tax  is  the  record  of  accounts  with  financial 
institutions, 
Register. 
the 
The record of accounts with financial institutions is organised on  the basis of the tax code of each 
person holding an account. Every month, financial institutions send data concerning accounts and 
non-account transactions (transactions carried out directly at the bank counter using bank drafts or 
cash) and personal data on the persons linked to the account, specifying their role. 
Every year, meanwhile, financial institutions send data on account balances, both the opening balance 
as of 1 January and the closing balance as of 31 December of the year to which the communication 
relates, or, for accounts closed during the year, the opening balance and the balance booked prior to 
the date of closure. Also sent are the total values of movements, broken down into debits and credits, 
the  annual  average  deposits  held  in  bank  and  post  office  deposit  and  current  accounts, and  other 
accounting data for other types of account.   

 
 
 
 
 
Member 
State 

Response 

For particular types of accounts with banks or other financial institutions, there is a requirement to 
send further data in addition to the data on deposits and annual flows. For example, for safe deposit 
boxes, the bank must report how many times the taxpayer accessed the box during the year. 
The financial institutions required to send periodic reports to the record of accounts with financial 
institutions belong to various different categories, with the main ones being banks, the Italian post 
office,  mutual  guarantee  societies  and  cooperatives,  investment  companies,  collective  investment 
undertakings  (CIUs  and  SICAVs),  asset  management  companies  (AMCs),  trusts,  and  insurance 
companies 
activities. 
The record of accounts with financial institutions is currently used for financial investigations, to 
draw up selective lists for tax evasion risk analysis and for the checks and controls carried out for the 
purposes of the ISEE (Equivalent Economic Situation Indicator). Recently, revenue collection agents 
have made increased use of the data in the record of accounts with financial institutions in procedures 
to enforce attachment orders against third parties, since it is debtors’ bank accounts that are attached.

institutions 

financial 

regards 

their 

and 

as 

for 

and 

from 

customs 

entry/exit 

procedures 

As  regards  digitalisation  and  the  use  of  new  tools  aimed  at  improving  interoperability  between 
systems in the fight against customs fraud, the Customs Agency has launched a project to digitalise 
the 
ports.  
loading/unloading 
During the development of this initiative, which is already in operation at the port of Bari and is 
being  gradually  extended  to  other  ports  (Ancona,  Livorno  and  Venice),  the  MRN  (Movement 
Reference Number) has been entered in each customs declaration processed by the competent offices. 
This is a unique identifier created by the customs systems when a declaration is submitted for the 
import, export or internal/external transit of goods. It makes it possible to identify, at any moment, 
the consignment with which the declaration is associated. The identifier is also available in a live 
environment in AIDA (Integrated Customs and Excise Automation). 
This  new  development  simplifies  operations  at  customs  posts,  as  the  Guardia  di  Finanza  officers 
responsible  for  affixing  the  ‘exit  stamp’  can  read  the  barcodes  on  customs  declarations  using 
e.g. optical readers and thus access information on the consignment more quickly.  
In relation to public expenditure, a memorandum of understanding has been signed with the State 
General Accounting Department at the Ministry of Economic Affairs and Finance with the aim of 
regulating  cooperation  on  making  data  available,  establishing  suitable  access  procedures  and 
ensuring interoperability of information systems.  In this context, a Technical Committee has been 
set up to determine the arrangements for implementing the agreement.  
application 
envisaged by the agreement encompasses:  

The 

- 

- 

the Guardia di Finanza dashboard in BDAP (Database of the Public Administration), which 
is a single standardised and streamlined tool for surveying, measuring and analysing the 
public finances. It makes it possible to carry out precise searches for data on payments made 
by the central administrations to the beneficiary concerned, in the financial years selected, 
with the data then being further processed using predefined ‘analysis contexts’;  
the  aforementioned  BDU-IGRUE,  the  Single  Database  of  the  General  Inspectorate  for 
Relations  with  the  European  Union  at  the  State  General  Accounts  Department,  which 
collates  data  on  the  payments  made  under  the  operational  programmes  financed  by  the 
structural funds. This data  is  used by the Guardia di Finanza to populate the Anti-Fraud 
Information System (SIAF) discussed below; 

-  ReGiS,  the  platform  that  all  parties  involved  (central  administrations  and  implementing 
bodies)  must  use  for  management,  reporting,  control  and  monitoring  activities  linked  to 
NRRP initiatives.  

To make the prevention and combatting of fraud against EU budget expenditure more effective, the 
Special Unit for Public Expenditure and Combatting Fraud against the European Union handled the 
evolutionary maintenance of SIAF (Anti-Fraud Information System), which was created as part of a 

 
 
 
 
 
 
 
Member 
State 

Response 

project financed under the National Operational Programme ‘Governance’ and Technical Assistance 
2007-2013. 
SIAF  is  a  business  intelligence  platform  that  supports  operational  analyses  in  the  field  of  public 
expenditure. By collating the information obtained, including from the other databases used by the 
Guardia di Finanza, it is possible to extract lists of public funding beneficiaries potentially posing a 
risk of irregularities. 

With specific reference to the NRRP, the Guardia di Finanza’s Special Unit for Public Expenditure 
and Combatting Fraud against the European Union, with the support of the Guardia di Finanza Unit 
at  the  Department  for  European  Affairs  at  the  Prime  Minister’s  Office,  which  acts  as  Technical 
Secretariat  of  COLAF,  has  prepared  detailed  checklists  with  specific  risk  indicators  separately 
applicable to the disbursement of support or the performance of public works and the provision of 
services.  Through  the  Network  of  NRRP  Anti-Fraud  Contact  Persons  established  alongside  the 
Coordination Committee for NRRP Reporting and Control by Decision No 57 of 9 March 2022, and 
through the ReGiS system developed by the State General Accounting Department, these checklists 
have been made available to all central and local administrations responsible for measures and to the 
implementing  bodies  involved  in  the  implementation  of  the  Plan,  thus  enabling  those  entities  to 
improve their independent capacity to identify anomalous situations requiring further investigation.

An  important  new  development  in  the  measures  taken  by  Italy  to  strengthen  risk  analysis  in  the 
management of EU funds is the Integrated Anti-Fraud Platform (PIAF-IT) developed by the General 
State  Accounting  Department  in  cooperation  with  COLAF  and  cofinanced  by  the  European 
Commission (OLAF) with Hercule III funding. Specifically, PIAF-IT is an integration platform that 
extracts, aggregates and reconciles data  from national sources (Revenue Agency, the Chamber of 
Commerce Information System (Infocamere), Court  of Auditors) and EU sources (the Irregularity 
Management  System  (IMS),  which  directly  comes  under  OLAF,  and  the  Financial  Transparency 
System  (FTS),  which  is  managed  by  the  European  Commission’s  DG  Budget  in  relation  to 
beneficiaries of funds under direct management) to generate factsheets on natural or legal persons, 
providing a useful input for assessments of possible fraud. Its aim is to: 

- 

- 
- 

intensify information exchange and thus strengthen the ‘fraud prevention’ stage as far as 
possible;  
centralise and make visible all key information on beneficiaries of EU public funding; 
develop specific outputs for analysing that information through a comparison against data 
in other databases via a search on a single information system, in an aggregated manner and 
searches.  
without 

separate 

several 

having 

make 

to 

The  platform  is  used  as  an  effective  tool  supporting  Arachne  with  the  aim  of  consolidating  and 
strengthening the fight against irregularities, fraud and other illegal activities against the EU budget 
both  before  expenditure  is  certified  and  during  the  ex-post  control  stage,  as  well  as  during 
administrative  checks  on  implementation  of  the  National  Recovery  and  Resilience  Plan. 
The technical context of PIAF-IT, which includes a microservices architecture able to store big data, 
has the following additional functionalities: 

- 

- 

it can be used to perform online searches (ordinary and historical views of natural or legal 
persons) and generate and display detailed factsheets; 
it is highly extensible in the future to other data sources that would allow the entry concerned 
to be examined in greater detail as regards the person/activity involved (e.g. the data from 
the Ministry of Justice’s Criminal Records Information System concerning past convictions 
for specific offences involving fraud against the national and EU budget, and the Kohesio 
database managed by the Commission’s DG REGIO, which has up-to-date information on 

 
 
 
 
 
 
Member 
State 

Response 

projects 

and 

beneficiaries 

co-financed 

by 

the 

EU 

cohesion 

policy). 

In  addition,  for  2024,  in  order  to  achieve  ever-improved  results  in  the  fight  against  fraud,  the 
Carabinieri confirmed the validity of its memorandum of understanding with AGEA (Agricultural 
Payments Agency). Under this memorandum, the fraud risk indicators for the CAP have been refined 
and the Criminal Focus Area dashboard has been further developed. Using aerial photographs, the 
dashboard records and analyses qualitative and quantitative changes in elements that point to criminal 
activity  that  hinders  socio-economic  development,  identifying  risk  areas  that  require  constant 
monitoring. The cooperation with AGEA is also making it possible to run a series of training events 
for all staff, enabling Carabinieri officers to deepen their knowledge of the new control tools being 
put in place by the Agency. In order to step up the fight against fraud, a licence to use the anti-fraud 
platform  SAS  was  requested  during  a  meeting  with  AGEA’s  Anti-Fraud  and  Risk  Management 
Office. 
In 2024, the Cyber Investigation Section at the Operational Department of the Carabinieri Agri‑Food 
Protection Unit became operational with the aim of training and upskilling officers to be deployed 
against threats coming from new IT technologies and enabling the use of investigation techniques 
and digital tools to be made available to the Carabinieri to fight crime committed using IT equipment. 

Q.2.3. If “NO” to Q.2.1, please explain why the digitalisation of the fight against fraud is not 
part of your NAFS nor of any other strategic approach. 

Member 
State 

Response 

IE 

Ireland does not have a NAFS; each MA has their own anti-fraud strategy for the protection of EU 
funds. 

General comment: As a federal state, Germany does not have a national anti-fraud strategy. 
However, in this context, we would refer to Germany’s Digital Strategy 2022-2025, p. 51 et seq.

DE 

(https://digitalstrategie-deutschland.de/static/fcf23bbf9736d543d02b79ccad34b729 
/Digitalstrategie_Aktualisierung_25.04.2023.pdf 
https://digitalstrategie-deutschland.de/). 
Measures reported here have been taken at Länder level. Replies to Q 2.1 from the Länder (ERDF) 
range from ‘Not yet, but we intend/are in the process of developing this part of the strategy’ to ‘NO’.  

+ 

Q.2.4 What are the main gaps you have identified in the digitalisation of your anti-fraud efforts? 

Response 

Frequency 

Percentage 

Member States 

Difficulty in scaling digital solutions across the state 

14 

51.9% 

Lack of funding for digital tools 

14 

51.9% 

HR,  SE,  BE,  LT, 
CZ, ES,  DE,  BG, 
CY, EE, RO, PT, 
LV, IT 

HR, NL, EL, BE, 
FI,  SI,  CZ,  ES, 

 
 
 
 
 
 
 
 
Response 

Frequency 

Percentage 

Member States 

SK, DE, BG, EE, 
RO, LV 

SE,  NL,  BE,  LT, 
CZ,  ES,  SK,  PL, 
DE, CY, EE, RO, 
LV, IT 

LU, HR, SE, NL, 
EL,  FI,  CZ,  ES, 
HU, SK, DE, BG, 
MT, RO 

HR, NL,  CZ, ES, 
SK, BG, RO, LV 

LU,  NL,  EL,  SI, 
CZ, ES, CY, RO 

IE,  FR,  AT,  SI, 
RO, DK 

LU, HR, SE,  CZ, 
BG 

Legal or regulatory barriers 

14 

51.9% 

Limited technical expertise within your organisation 

14 

51.9% 

Insufficient training for the staff and digital tools and 
processes 

Outdated IT systems 

No steps taken to identify gaps in digitalisation 

Resistance to change from the staffs and stakeholders 
involved 

Cybersecurity vulnerabilities 

8 

8 

6 

5 

2 

29.6% 

29.6% 

22.2% 

18.5% 

7.4% 

CZ, RO 

Q.2.5 What steps have you undertaken to address gaps in the digitalisation of your anti-fraud 
efforts? 

Response 

Frequency 

Percentage 

Member States 

Training and development for staff 

17 

63.0% 

Other (please specify) 

Conducted internal assessments or audits 

Performed  a  gap  analysis  comparing  the  current 
capabilities with desired capabilities 

9 

8 

8 

33.3% 

29.6% 

29.6% 

SE,  EL,  BE,  AT, 
FI,  LT,  SI,  CZ, 
ES, HU, SK, DE, 
BG,  MT,  CY, 
RO, IT 

IE,  SE,  CZ,  PL, 
MT, CY, EE, PT, 
DK 

LU, EL, CZ, DE, 
EE, RO, DK, IT 

BE,  SI,  CZ,  ES, 
SK, DE, RO, IT 

 
 
 
Response 

Frequency 

Percentage 

Member States 

No specific actions taken yet to address gaps 

Secured budget for digital improvements 

Developed a detailed digitalisation strategy addressing 
identified gaps 

Hired external consultants or experts 

5 

5 

3 

3 

18.5% 

18.5% 

HR,  NL,  FR,  ES, 
LV 

SI,  CZ,  MT,  CY, 
RO 

11.1% 

CZ, ES, SK 

11.1% 

LU, EL, CZ 

Following Q.2.5, please specify "Other". 

Member 
State 

Response 

IE 

? 

SE 

CZ 

PL 

MT 

There  is  ongoing  cooperation  with  other  authorities  (the  Swedish  Agency  for  Economic  and 
Regional Growth, the Migration Agency and the Swedish Board of Agriculture) owing to the lack 
of digital tools. Paving the way for future development, such as structured data based on data from 
applicants and introducing organisation registers that retrieve data from public databases. See also 
point 2.7. 

Preparation  of  the  complete  digitalisation  of  administrative  processes  at  prosecutorial  level  is 
ongoing. 
Links to external systems have been created (the Register of Beneficial Owners information system 
(ESM) and MS2021+, ARACHNE and MS2021+) and access has been ensured to the non-public 
part of the ESM and Register of Trust Funds information systems). 
Applications were procured for screening (CRIBIS) and using web interfaces for detecting fraud 
(such  as  double  funding),  use  of  the  ESM.  Information  sharing  has  been  expanded  using  cloud 
solutions. 

The  Institution  Coordinating  the  Partnership  Agreement  cooperates  on  an  ongoing  basis  with 
national bodies external to the institutions of the management and control system in the transmission 
of information on entities and persons with links to those entities obtained from external registers 
managed  by  these  institutions.  Where  required,  the  Institution  Coordinating  the  Partnership 
Agreement concludes agreements on rules of cooperation with register-managing entities for the 
exchange  of  data  necessary  to  carry  out  verifications  in  relation  to  the  detection  of  conflicts  of 
interest and the fight against irregularities and fraud. 

With reference to Question 2.4, notwithstanding that the Maltese AFCOS has limited technical IT 
expertise, it is being assisted by IMU within the Office of the Prime Minister. Furthermore, the co-
ordination  between  the  members  of  the  Co-ordinating  Committee  facilitates  knowledge  sharing 
with respect to Information and Communication Technology (ICT).  

CY 

Steps are sectoral and there are no steps for mainstream programs. 

 
 
 
 
 
Member 
State 

Response 

We have begun reviewing our monitoring system to map out our current needs and subsequently 
implement  changes,  including  addressing  the  need  to  enhance  the  fight  against  fraud  through 
increased digitalization. Additionally, we are exploring greater opportunities for cooperation with 
investigative bodies, which already have the necessary tools and expertise. Including we are using 
internal risk analysis capabilities and Arachne. 

Contacts with public administration bodies have been established to improve and extend the set of 
interoperability solutions available/to be made available. 

EE 

PT 

DK 

The Danish Business Authority: We have made a fraud-risk assessment. 

Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud? Inventory of existing tools: conduct a thorough inventory of existing 
digital tools and technologies used in the fight against fraud. 

Response 

Action taken 

Action planned 

Action not taken nor foreseen 

Frequency 

Percentage 

Member States 

10 

37.0% 

9 

8 

33.3% 

29.6% 

SE,  LT,  SI,  CZ, 
PL, DE, BG, MT, 
RO, IT 

LU, HR, FR, AT, 
ES, HU, SK, CY, 
LV 

IE,  NL,  EL,  BE, 
FI, EE, PT, DK 

Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud? Benchmarking on new trends: conduct benchmarking research on new 
trends and technologies used in the fight against fraud. 

Response 

Frequency 

Percentage 

Member States 

Action not taken nor foreseen 

13 

48.1% 

Action planned 

Action taken 

9 

5 

33.3% 

18.5% 

IE,  LU,  HR,  NL, 
EL,  AT,  FI,  ES, 
PL,  EE,  PT,  LV, 
DK 

FR, BE, CZ, HU, 
SK, BG, MT, CY, 
RO 

SE,  LT,  SI,  DE, 
IT 

 
 
 
 
Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud?: Evaluation and updates of existing IT tools. 

Response 

Frequency 

Percentage 

Member States 

Action planned 

Action taken 

Action not taken nor foreseen 

11 

10 

6 

40.7% 

37.0% 

22.2% 

LU,  HR,  FR,  FI, 
LT, ES, BG, MT, 
CY, RO, PT 

SE,  BE,  SI,  CZ, 
HU, SK, PL, DE, 
LV, IT 

IE,  NL,  EL,  AT, 
EE, DK 

Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud?: Development/deployment of new, dedicated IT tools. 

Response 

Frequency 

Percentage 

Member States 

Action planned 

11 

40.7% 

Action not taken nor foreseen 

Action taken 

9 

7 

33.3% 

25.9% 

LU, NL, FR,  BE, 
FI,  LT,  ES,  DE, 
MT, RO, DK 

IE,  HR,  EL,  AT, 
HU, BG, CY, EE, 
LV 

SE,  SI,  CZ,  SK, 
PL, PT, IT 

Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud?:  Improve interoperability between systems already in use to  enhance 
data sharing. 

Response 

Frequency 

Percentage 

Member States 

Action planned 

16 

59.3% 

LU, NL, FR, AT, 
FI,  LT,  CZ,  ES, 
SK, DE, BG, CY, 
EE, RO, LV, DK 

SE,  BE,  SI,  HU, 
PL, MT, PT, IT 

Action taken 

Action not taken nor foreseen 

8 

3 

29.6% 

11.1% 

IE, HR, EL 

 
 
 
 
 
Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud?: Dedicated allocated staff / resources / taskforce. 

Response 

Frequency 

Percentage 

Member States 

Action taken 

14 

51.9% 

Action planned 

Action not taken nor foreseen 

8 

5 

29.6% 

18.5% 

SE,  NL,  BE,  LT, 
SI,  CZ,  HU,  SK, 
PL,  DE,  CY,  PT, 
LV, IT 

LU,  HR,  FR,  ES, 
BG, MT, EE, RO 

IE,  EL,  AT,  FI, 
DK 

Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud?: Trainings of the staff. 

Response 

Frequency 

Percentage 

Member States 

Action taken 

18 

66.7% 

Action planned 

Action not taken nor foreseen 

7 

2 

25.9% 

7.4% 

IE, EL 

Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud?: Risk analysis assessment. 

Response 

Frequency 

Percentage 

Member States 

Action taken 

17 

63.0% 

SE,  NL,  BE,  AT, 
LT,  SI,  CZ,  ES, 
HU, SK, PL, DE, 
MT, CY, EE, LV, 
DK, IT 

LU,  HR,  FR,  FI, 
BG, RO, PT 

LU,  SE,  NL,  BE, 
SI,  CZ,  HU,  SK, 
PL, DE, MT, CY, 
EE, RO, LV, DK, 
IT 

HR,  FR,  FI,  LT, 
ES, BG, PT 

Action planned 

Action not taken nor foreseen 

7 

3 

25.9% 

11.1% 

IE, EL, AT 

 
 
 
 
 
Q.2.6. What actions have you taken or are you taking to keep up with evolving new technologies 
used to commit fraud?: Other (please specify in the next question). 

Response 

Frequency 

Percentage 

Member States 

Action not taken nor foreseen 

18 

66.7% 

IE,  LU,  HR,  NL, 
FR,  BE,  AT,  LT, 
ES,  SK,  PL,  BG, 
MT, CY, PT, LV, 
DK, IT 

SE,  FI,  SI,  CZ, 
HU, DE, RO 

Action taken 

Action planned 

7 

2 

25.9% 

7.4% 

EL, EE 

Q.2.7 Following Q.2.6, please specify any other actions you have taken, or you have planned 
on taking to keep up with evolving new technologies used to commit fraud. 

Member 
State 

Response 

IE 

There is no national anti-fraud strategy in place, 

LU 

In addition to the actions described above, one stakeholder is in process of  engaging an external 
consultant in anti-fraud matters and plans to recruit an anti-fraud officer in 2025. 

HR 

No other action is taken nor foreseen. 

SE 

Paving the way for future development;  
1. Introducing an integrated organisation register in the My Application/Nyps aid case system that 
retrieves  public  data  on  the  organisation.  The  payment  method  (bankgiro  and  plusgiro)  of  the 
applicant organisation is verified automatically through checks against external services.  
2. Reporting of data from the project in a structured way in My Application/Nyps.  
3. The structured data in Nyps has made it possible for us to check whether there is double reporting 
of certain costs in ERUF9. With the ProDiver analysis programme, which retrieves data from Nyps, 
we can systematically analyse data on personnel costs and actual costs and detect possible double 
funding. 

NL 

N/a 

EL 

Together with the AFCOS of Cyprus and the AFCOS of Bulgaria, the EYTHYPS is participating 
in the transnational project ‘Strengthening national anti-fraud strategies in the financial interests of 
the EU’, financed through the Technical Support Instrument (TSI) of the European Commission. 
The  Directorate-General  for  Structural  Reform  Support  (DG  REFORM)  of  the  European 
Commission is responsible and the OECD is the beneficiary. The project’s aim is ‘the improvement 
of national anti-fraud strategies and the development of a comprehensive methodology with clear 
procedures and indicators to support the monitoring, assessment and updating of national anti-fraud 
strategies, including capacity-building in relation to the use of the methodology’ and, specifically 

 
 
 
 
 
 
 
Member 
State 

Response 

for  Greece,  the  assessment  of  the  National  Anti-Fraud  Strategy  implemented  in  the  ESPA,  its 
updating and the development of a monitoring and assessment methodology. 

BE 

/ 

FI 

SI 

CZ 

HU 

DE 

BG 

MT 

EE 

RO 

IT 

Participation of national experts in the Commission’s expert groups dealing with digital tools to 
protect the EU budget. 

In this moment we plan no further actions as mentioned in Q.2.6. 

risk 

analysis 

Training  of  an  expert  team  of  data  analysts,  implementation  of  new  AI  tools,  architecture  of 
electronic 
tools. 
A self-assessment system has been put in place in accordance with the Commission’s guidelines. 
Staff participate not only in training specialised in fraud and fraud prevention, but also, for example, 
in the use of artificial intelligence, including training abroad. Furthermore, the managing authority 
prepares annual reports and evaluates the checks carried out under the Fraud Prevention Directive. 

development 

risk-analysis 

strategy, 

own 

of 

Providing  training  on  the  application  of  artificial  intelligence  in  the  institutional  system  for 
development policy, not yet linked to specific workflows. 

The Federal Ministry of Food and Agriculture (BMEL) under ‘Other’: Use of new databases (e.g. 
the Transparency Register). 

N/A 

Not applicable. 

Developing  risk  systems  in  Customs  and  Tax  areas  -  we  are  taking  risk  models  to  next  SAS 
platform, 

- AFIR: The Paying Agency for Rural Investments has international certification for the standard 
ISO 37001:2016, which is applicable to the anti-bribery management system. 

- MIPE - DGMMRR: Training planned at the start of 2025 with the Arachne team, analysis and 
verification of the information in the EDES Database - 
https://commission.europa.eu/strategy-and-policy/eu-budget/how-it-works/annual-
lifecycle/implementation/anti-fraud-measures/edes/edes-database_en  

is 

as 

far 

legislation 

concerned,  mention 

As 
of: 
1)  Law  No 90/2024  laying  down  provisions  on  strengthening  national  cybersecurity  and  on 
cybercrime. The changes made by this law are linked to the second recommendation in the 2023 
PIF  report,  namely,  to  accelerate  the  digitalisation  of  the  fight  against  fraud,  specifically  by 
strengthening national bodies’ ‘cyber resilience’ measures and the tools for fighting cybercrime. Its 
provisions include, in particular:   

be  made 

should 

a)  making  penalties  more  severe  and  introducing  aggravating  circumstances  for  cyber  offences 
(Articles 615-ter,  615-quater,  617-bis,  617-quater,  617-quinquies,  617-sexies  of  the  Criminal 
Code);  
b)  introducing,  for  cyber  offences,  the  mitigating  circumstance  of  particularly  minor  nature  and 
cooperation; c) redefining the offence of damaging IT or electronic systems of public interest; 
d)  coordinating  with  the  new  provisions  on  extending  the  end  dates  of  investigations  and  on 

 
 
 
 
Member 
State 

Response 

maximum duration;  
e) extending to cybercrime the coordination role of the National Anti-Mafia and Anti‑Terrorism 
Prosecutor,  the  provisions  on  state  witnesses  and  criminals  who  turn  state’s  evidence  and  the 
provisions on wiretapping for organised crime offences; 
f) extending corporate liability for cyber extorsion offences;  
1) Decree of the Minister for Justice of 15 March 2024 establishing the national register of reports, 
documents  and  recordings  of  wiretaps  carried  out  in  proceedings  in  which  the  European  Public 
Prosecutor’s Office has exercised its power and any other documents related thereto. This provides 
for the units of the European Public Prosecutor’s Office to use the recently established inter-district 
digital  infrastructure  to  save  all  conversations  and  communications  recorded  with  Public 
Prosecution Office equipment used to investigate the offences referred to in the PIF Directive. 
Also, on the issue of accelerating the process of digitalising the fight against fraud, the Department 
for Technological Innovation (DIT) at the Ministry of Justice has stated that: 

- 

- 

- 

- 

the digitalisation of the fight against fraud has been ensured by structured monitoring of 
data  on  PIF  offences  using  the  applications  made  available  to  Italian  law  enforcement 
authorities (NDR), lawyers (PDP) and prosecutors/judges (REGEWEB and APP); 
the  difficulties  in  rolling  out  digital  solutions  nationwide  have  been  remedied  by  staff 
training and development; 
so as to keep pace with the  development of new  technologies used to commit fraud, the 
action  taken  has  been  to  draw  up  an  in-depth  inventory  of  the  existing  digital  tools  and 
technologies used in the fight against fraud, and to assess and update the existing IT tools 
and develop new bespoke IT tools; 
the planned actions consist in making the systems already in use more interoperable so as 
to improve data sharing and staff training. 

Specifically, the creation of the criminal law data  lake via the central applications of the Italian 
electronic criminal-law process (NDR, PDP and ADP) will make it possible to improve and broaden 
the quality of the data and, as a result, the activities of prevention, investigation and punishment.

In  addition,  particular  importance  has been placed on  the inventory  of  existing  digital  tools  and 
technologies used in the fight against fraud, the setting up of a special task force, staff training and 
the assessment of risk analyses. 
Utmost importance has also been placed on comparative analysis of new trends, with comparative 
research into the new technologies used in the fight against fraud, and on how to make the systems 
already 
sharing. 
Also in use are (integrated) automated data analysis tools, database integration and cybersecurity 
measures. 
Also planned are a system for managing fraud cases, data sharing between agencies and automation 
of information exchange. 

interoperable 

use  more 

improve 

data 

so 

as 

to 

in 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Inventory of existing tools: conduct a thorough inventory of existing digital tools 
and technologies used in the fight against fraud 

Response 

Important 

Frequency 

Percentage 

Member States 

14 

51.9% 

LU, HR, SE, NL, 
BE,  LT,  SI,  CZ, 

 
 
 
 
 
 
 
 
 
 
Response 

Frequency 

Percentage 

Member States 

Very important 

No opinion 

Neutral 

Not important 

HU, SK, DE, BG, 
CY, EE 

FR,  ES,  PL,  MT, 
RO, LV, IT 

25.9% 

11.1% 

IE, EL, AT 

7.4% 

3.7% 

PT, DK 

FI 

7 

3 

2 

1 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Benchmarking on new trends: conduct benchmarking research on new trends and 
technologies used in the fight against fraud 

Frequency 

Percentage 

Member States 

Response 

Important 

Very important 

Neutral 

No opinion 

Somewhat important 

Not important 

13 

48.1% 

LU,  SE,  NL,  BE, 
CZ, ES,  HU,  SK, 
DE, BG, CY, EE, 
LV 

FR,  LT,  SI,  MT, 
RO, IT 

22.2% 

11.1% 

HR, PL, PT 

7.4% 

7.4% 

3.7% 

IE, AT 

EL, DK 

FI 

6 

3 

2 

2 

1 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Evaluation and updates of existing IT tools 

Response 

Frequency 

Percentage 

Member States 

Very important 

14 

51.9% 

Important 

Neutral 

7 

4 

25.9% 

14.8% 

HR, SE, CZ, DK 

FR,  BE,  LT,  SI, 
ES,  SK,  PL,  DE, 
BG, MT, RO, PT, 
LV, IT 

LU,  NL,  EL,  FI, 
HU, CY, EE 

 
 
 
 
Response 

No opinion 

Frequency 

Percentage 

Member States 

2 

7.4% 

IE, AT 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Development/deployment of new, dedicated IT tools 

Frequency 

Percentage 

Member States 

Response 

Important 

Very important 

Neutral 

No opinion 

11 

40.7% 

29.6% 

18.5% 

8 

5 

3 

LU, HR, NL, EL, 
FI,  LT,  CZ,  DE, 
BG, EE, PT 

FR,  SI,  ES,  SK, 
PL, MT, RO, IT 

SE, BE,  CY, LV, 
DK 

11.1% 

IE, AT, HU 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Improve interoperability between systems already in use to enhance data sharing 

Response 

Frequency 

Percentage 

Member States 

Very important 

15 

55.6% 

Important 

No opinion 

10 

2 

37.0% 

7.4% 

IE, AT 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Dedicated allocated staff / resources / taskforce 

Response 

Important 

Frequency 

Percentage 

Member States 

13 

48.1% 

SE,  NL,  EL,  FI, 
SI,  HU,  SK,  PL, 
DE, MT, EE, PT, 
LV 

LU,  HR,  SE,  FR, 
EL,  BE,  SI,  ES, 
PL, DE, MT, RO, 
PT, LV, IT 

NL,  FI,  LT,  CZ, 
HU, SK, BG, CY, 
EE, DK 

 
 
 
 
 
Response 

Frequency 

Percentage 

Member States 

Very important 

Neutral 

No opinion 

9 

3 

2 

33.3% 

LU, HR, FR, BE, 
LT, ES, CY,  RO, 
IT 

11.1% 

CZ, BG, DK 

7.4% 

IE, AT 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Trainings of the staff 

Response 

Frequency 

Percentage 

Member States 

Very important 

16 

59.3% 

Important 

No opinion 

9 

2 

33.3% 

7.4% 

IE, AT 

Q.2.8 Please indicate the level of importance you assign to each of the following actions in anti-
fraud efforts.: Risk analysis assessment 

Response 

Frequency 

Percentage 

Member States 

Very important 

17 

63.0% 

Important 

No opinion 

Neutral 

7 

2 

1 

25.9% 

7.4% 

3.7% 

LU, HR, NL, FR, 
EL,  BE,  SI,  ES, 
SK, PL, DE, MT, 
CY, EE, RO, PT, 
IT 

SE,  FI,  LT,  CZ, 
HU, BG, LV 

IE, AT 

DK 

HR, NL, FR, BE, 
FI,  LT,  SI,  ES, 
SK, DE, MT, CY, 
EE, RO, PT, IT 

LU,  SE,  EL,  CZ, 
HU, PL, BG, LV, 
DK 

 
 
 
 
Polar plot of the Average Level of Importance Assigned to Anti-Fraud Action 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Use of AI (Artificial Intelligence) 

Response 

Frequency 

Percentage 

Member States 

Planned to use 

13 

48.1% 

Not used / Not planned to use 

Used 

9 

5 

33.3% 

18.5% 

HR,  SE,  EL,  LT, 
CZ,  ES,  SK,  DE, 
BG, MT, EE, RO, 
PT 

IE,  LU,  NL,  BE, 
AT,  FI,  HU,  CY, 
DK 

FR,  SI,  PL,  LV, 
IT 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Data Analysis tools (external) 

Response 

Frequency 

Percentage 

Member States 

Used 

23 

85.2% 

LU, HR, SE, NL, 
FR,  EL,  BE,  AT, 
LT,  SI,  CZ,  ES, 
HU, SK, PL, DE, 
MT, CY, EE, RO, 
LV, DK, IT 

Not used / Not planned to use 

Planned to use 

3 

1 

11.1% 

IE, FI, BG 

3.7% 

PT 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Automated data analysis tools (integrated) 

Frequency 

Percentage 

Member States 

Response 

Used 

Planned to use 

Not used / Not planned to use 

13 

48.1% 

40.7% 

11 

3 

11.1% 

IE, AT, CY 

SE,  NL,  FR,  BE, 
LT,  SI,  CZ,  HU, 
SK,  PL, DE,  RO, 
IT 

LU,  HR,  EL,  FI, 
ES, BG, MT, EE, 
PT, LV, DK 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Predictive analytics 

Response 

Frequency 

Percentage 

Member States 

Not used / Not planned to use 

12 

44.4% 

Planned to use 

Used 

9 

6 

33.3% 

22.2% 

IE,  LU,  NL,  BE, 
AT,  FI,  HU,  PL, 
BG, MT, CY, DK 

HR,  EL,  CZ,  ES, 
DE,  EE,  PT,  LV, 
IT 

SE,  FR,  LT,  SI, 
SK, RO 

 
 
 
 
 
Response 

Used 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Database integration 

Frequency 

Percentage 

Member States 

16 

59.3% 

SE,  FR,  BE,  LT, 
SI,  CZ,  ES,  HU, 
SK, PL, BG, MT, 
EE, RO, PT, IT 

LU, HR, NL, EL, 
DE, CY, LV 

Planned to use 

Not used / Not planned to use 

7 

4 

25.9% 

14.8% 

IE, AT, FI, DK 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Fraud case management system 

Response 

Frequency 

Percentage 

Member States 

Used 

16 

59.3% 

Not used / Not planned to use 

Planned to use 

6 

5 

22.2% 

18.5% 

LU,  NL,  FR,  EL, 
BE,  LT,  CZ,  ES, 
HU,  DE,  BG, 
MT, EE, RO, LV, 
IT 

IE,  AT,  FI,  SK, 
CY, DK 

HR,  SE,  SI,  PL, 
PT 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Cross-agency data sharing 

Frequency 

Percentage 

Member States 

16 

59.3% 

LU,  NL,  EL,  LT, 
CZ, HU, SK, PL, 
DE, BG, MT, EE, 
RO, PT, DK, IT 

HR,  SE,  FR,  BE, 
SI, ES, CY, LV 

Planned to use 

Not used / Not planned to use 

8 

3 

29.6% 

11.1% 

IE, AT, FI 

Response 

Used 

 
 
 
 
 
Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Cybersecurity measures 

Response 

Frequency 

Percentage 

Member States 

Used 

19 

70.4% 

Not used / Not planned to use 

Planned to use 

5 

3 

18.5% 

11.1% 

HR, FR, EL 

Q.2.9 Which digital tools or technologies are currently in use or planned for use in your anti-
fraud efforts?: Automation of information exchange 

Frequency 

Percentage 

Member States 

Response 

Used 

15 

55.6% 

Planned to use 

Not used / Not planned to use 

8 

4 

29.6% 

14.8% 

IE, AT, FI, DK 

LU,  SE,  NL,  BE, 
LT,  SI,  CZ,  ES, 
HU, SK, PL, DE, 
BG, MT, EE, RO, 
PT, LV, IT 

IE,  AT,  FI,  CY, 
DK 

SE,  NL,  FR,  BE, 
LT,  CZ,  ES,  HU, 
SK,  PL, MT, EE, 
RO, PT, IT 

LU,  HR,  EL,  SI, 
DE, BG, CY, LV 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Spiderplot of Average Stage of Implementation of Digital Tools and Technologies Across All Member States 

Q.2.10 Following Q.2.9, please specify any other digital tools or technologies you are using, or 
you are planning to use. 

Member 
State 

Response 

IE 

HR 

SE 

NL 

FR 

EL 

BE 

There is no national anti-fraud strategy in place, it is hard to answer these questions where there are 
a number of MAs with responsibility for managing EU funds 

Ministry of Agriculture, Forestry and Fisheries, Directorate for Support in Agriculture and Rural 
Development is using POWER BI (OLAP) tool. 

A simpler analysis model in ProDiver. 

Planning to use new ARACHNE 

Within the framework of the NAFS, use of the Transaction Network Analysis (TNA) tool or of data 
from EUCARIS (the system for sharing data on driver’s licences and registration documents among 
EU Member States) to combat VAT fraud. 

The  EYTHYPS  and  the  ESPA  authorities  use  automated  information  exchange  in  the  field  of 
expenditure. 

Calista, Arachne 

 
 
 
Member 
State 

Response 

AT 

FI 

SI 

CZ 

HU 

SK 

Arachne 

The possibility of introducing the ARACHNE system will be explored. 

Financial Administration of the Republic of Slovenia: Digital tools - platforms, which are used in 
FARS are SAP Business Intelligence – BOBJ, QlikView, QlikSense and KNIME, which can all be 
bought on the market. These tolls access different internal and external data sources. These sources 
are further digital treated within specific IT program codes (scripts), which are written upon the 
specific  needs  within  the  self-developed  applications.  Applications  are  usually  daily  overnight 
updated. 

of 

Trust 

Register 

Use of links to external systems (the Register of Beneficial Owners information system (ESM) and 
MS2021+, ARACHNE and MS2021+) as well as use of access to the non-public part of the ESM 
and 
systems.  
Use of the CRIBIS application, use of Arachne, use of web interfaces to detect, for example, double 
funding:  https://dotaceeu.cz/cs/statistiky-a-analyzy/mapa-projektu,  https://red.financnisprava.cz/, 
https://kohesio.ec.europa.eu/en/projects. 
The public prosecution service is preparing the digitalisation of internal administrative processes; 
this involves an in-house tool not directly linked to the systems of other public authorities, which is 
also  motivated  by  the  nature  of  criminal  proceedings  and  the  nature  of  the  performance  of  the 
activities of the public prosecution service. 

information 

Funds 

The  Development  Policy  Database  and  Information  System  (FAIR),  the  European  Union 
Programme System (EUPR), which includes a fraud prevention function, and also ARACHNE. 

Various  Slovak  authorities,  including  the  audit  authority  use  the  Arachne  tool  and  following 
websites to verify information: www.transparex.sk, www.orsr.sk (Business register), www.zrsr.sk 
(The trade register), www.foaf.sk and www.oversi.gov.sk. 

PL 

None 

DE 

The Federal Ministry of Food and Agriculture (BMEL): Use of national databases and registers 
(e.g. the Transparency Register, the Trade Register). 

The Lower Saxony ERDF Managing Authority: The processes and procedures for handling and 
managing the multi-fund programme 2021-2027 in Lower Saxony are supported by different IT 
systems. The Investitions- und Förderbank Niedersachsen (NBank) uses the ABAKUS accounting 
system. On basis of the ABAKUS, the additional IT system NIBAS (Lower Saxony Information, 
Reporting and Billing System) was developed, which includes in particular the areas of evaluation 
and  supplementary  areas  of  application.  In  addition  to  the  accounting  and  settlement  systems 
(ABAKUS and NIBAS), there is also increased digitalisation in NBank's funding processing as part 
of IT security, which also has an impact on anti-fraud. Among other things, a digital application is 
made possible by NBank's IDA customer portal, which is intended to simplify the application and 
project processing. In addition, suspected fraud is reported online via digital means to the competent 
authorities and institutions. 

The Schleswig-Holstein ERDF Managing Authority: 

-  Authentication via the service portal; 
- 

safeguards, such as the use of TLS certificates for encrypted communication.  

 
 
 
Member 
State 

Response 

MT 

(i) 
Scarlet:  a  data  mining  app  aggregating  shareholding  information  available  on  the  Malta 
Business Registry in order to understand any linkages between Malta-based enterprises registered 
on the MBR and their shareholders, and the composition of the respective undertaking and its UBOs 
thereof;  
(ii)  Malta Association for Credit Management (MACM): a website which provides information 
on Malta-based enterprises’ VAT number and whether enterprises or individuals have had any court 
orders or notices, dishonoured cheques, creditors, judicial letters or civil cases;  
(iii) 
on any individual which is under scrutiny.  

The Public Employment Service database: this database provides the employment history 

EE 

Tax and Customs colleagues are testing machine learning and network analysis tool. 

-AFIR: I. The AFIR IT system: 
 1) The rural development claim processing system (SPCDR) with the following main modules: 

a)  Submission  and  evaluation  of  the  funding  application,  including  the  project  selection  and 
resolution of challenges to the assessment of the funding application,  
b) Signing and amendment of the funding contract, c) Procurement, d) Payment authorisation, e) 
recovery.  
Ascertainment 

irregularities, 

Establishing 

debt 

debt 

and 

of 

f) 

RO 

FUNCTIONALITY: recording of funding applications in the AFIR IT system and their assessment, 
verification  of  eligibility  and  of  selection  criteria  for  the  projects  submitted,  submission  of  the 
proposal for the on-site visit and drafting of reports following on-site visits, drafting of assessment 
reports, selection and responses to assessment, notifying applicants of the status of their funding 
application, settlement of appeals, drafting and signing of contracts/financing decisions/additional 
documents,  submission  and  verification  of  procurement  documents,  submission  of  payment 
instalment  declarations  and  of  payment  application  documents,  preparation  of  orders,  payment 
certificates and orders for payment to beneficiaries, recording in the accounts of the payments made, 
the constitution of debts and their recovery, reports to the European Commission. In the SPCDR, 
applicants/beneficiaries  of  grants  can  submit  documents  relating  to  all  stages  of  project 
implementation online. 

2) The online reference price database ensures access to information for applicants for European 
funding, at the same time simplifying the procurement procedure. It will be possible for the elements 
found  in  this  database  to  be  purchased  by  private  NRDP  beneficiaries,  directly,  without  going 
through  any  other  procurement  procedure.  The  database  is  structured  in  line  with  the  following 
criteria: CPV code, make, model, standard equipment and price in euro (or USD), excluding VAT. 
The  identity  of  the  person  submitting  the  data  remains  confidential.  The  AFIR  ensures  that  the 
online reference price database is completed through the collection, verification and validation of 
offers sent by the manufacturers, importers or distributors of vehicles, tools, specialised equipment, 
greenhouses, silos, buildings, sheds and furnishings. The AFIR conducts additional checks of the 
prices submitted and enters prices in the database which may have been found to be lower than 
those  initially  presented  by  the  tenderer.  Where  the  AFIR  finds  differences  between  the  prices 
communicated  and  those  practised  on  the  market,  the  checks  will  be  extended  to  all  the  prices 
communicated  and,  until  the checks  are  finalised,  will  exclude  from  the  database  all  equipment 
communicated by the manufacturer, importer or distributor in question. In order to offer interested 
parties, the possibility of comparing equipment from the database, the degree of accuracy of the 
information  entered  needs  to  be  improved,  and  the  information  on  the  characteristics  and 

 
 
 
 
 
 
Member 
State 

Response 

performance  of  the  equipment  included  in  the  online  reference  price  database  also  needs  to  be 
standardised. To this end, technical sheets have been developed setting out the minimum obligatory 
information to be provided concerning the degree of equipment of the elements entered or to be 
entered in the database with AFIR reference prices. 

 3)  The  application  for  the  on-site  visit  for  mobile  devices  ensures  that  AFIR  experts  take 
photographs of the project implementation locations and send them to the SPCDR.  

4) The registry ensures that the input/output/document transfer flows at AFIR level are recorded.  

5) The accounting of payments from European funds ensures a record of the funding of the accounts 
from which payments are made to beneficiaries, and the preparation of payment orders.  

6) The financial accounting system of the AFIR ensures the processing and recording of financial 
accounting activities in the county offices, regional centres and central headquarters of the AFIR. 
II.  ARACHNE.  III.  COLLABORATION  PROTOCOLS:  The  purpose  of  these  protocols  is  the 
exchange of databases/access to databases for both the 2014-2020 NRDP and the SP CAP 2023-
2027. They have been concluded with the following institutions: the ONRC, the National Labour 
Inspectorate, the National Veterinary Health and Food Safety Authority, the Ministry of Health and 
the  National  Environment  Agency  and  the  National  Environmental  Guard,  the  MDLPA and  the 
National  Investments  Company,  APIA,  the  Competition  Council,  the  DG  for  Persons’  Records, 
ANAF and the EPPO.  

- DGP-AM POPAM: The website www.romanian-universe.ro used for the collection of data and 
information. We intend to regain access to RECOM by signing a protocol with the ONRC, and also 
REVISAL and ARACHNE. 

- MDLPA: Joint Electronic Monitoring System for the period 2021-2027, Electronic Monitoring 
System for the period 2014-2020   

- MIPE – AM POCU: SMIS, ARACHNE, SFC, SICAP, RECOM 

- MIPE - DGMMRR: Arachne (under development), AFIS-IMS 

Arachne  and  nationally  available  information  systems  (e.g.  e-cohesion,  Electronic  Procurement 
System, System of the Tax Authority, Enterprise Register, etc.). 

The Danish Agency for Green Land Conversion and Water Environment: We are examining the 
potential use of ARACHNE for identifying red flags regarding fraud and circumvention. 

The managing authority of the Ministry of Education and Merit’s NOP/NP ‘School’ has adopted a 
digital transformation strategy that aims to make control procedures more effective by digitalising 
them through solutions that use AI to check the documentation submitted by beneficiaries, systems 
for  automating  data  entry  through  optical  character  recognition  (OCR),  checks  that  can  be 
automated through interoperability and, in general, the (at least partial) automation of controls.   
In addition, the Ministry of Justice has stated that the Senate  is currently examining a draft law 
laying  down  provisions,  and  delegating  power  to  the  government,  in  relation  to  AI.  
In  light  of  the  recommendation  to  accelerate  the  digitalisation  of  the  fight  against  fraud,  the 
provisions of this draft law include delegating power to the government to systematically define 
rules 
purposes.  
The  delegation  ‘constitutes  a  supplementary  measure  that  provides  for  the  introduction  of  an 
offence,  a  generic  aggravating  circumstance  and  specific  aggravating  circumstances  for  certain 
offences.  

cases  where  AI 

unlawful 

systems 

used 

are 

for 

for 

LV 

DK 

IT 

 
 
 
 
 
 
Member 
State 

Response 

More specifically, the delegated legislator has been called upon, firstly, to provide for tools in civil, 
administrative and criminal law, including interim measures, aimed at removing, and preventing 
the  spread,  of  content generated  illegally,  including  with  AI  systems,  backed up by  a  system  of 
effective, proportionate and dissuasive penalties. 
In addition, the government will have to introduce one or more separate offences, penalised as either 
deliberate or negligent acts, consisting in the failure to adopt, or failure to update, security measures 
for the production, release and professional use of AI systems and further offences, penalised as 
deliberate acts, intended to protect specific legal interests that are at risk of being compromised 
through the use of AI systems and cannot be properly protected by prosecuting existing offences. 

Thirdly,  when  the  delegation  is  exercised,  a  specific  aggravating  circumstance  will  have  to  be 
introduced for deliberate offences subject to penalties other than life imprisonment, in which the 
use  of  AI  systems  contributes  very  seriously  to  the  damage  done  to  the protected  legal  interest, 
including cases of damage to interests of persons or the State.  
Lastly, in order to bring about an overall rationalisation of the system, the delegated legislator has 
been  called  upon  to  review  the  substantive  and  procedural  legislation  in  force  concerning  the 
introduction  of  a  generic  aggravating  circumstance  where  an  offence  is  committed  using  AI 
systems;  the  introduction  of  a  new  offence  of  unlawful  distribution  of  content  generated  or 
manipulated  with  AI  systems;  the  insertion  into  the  Criminal  Code  of  specific  aggravating 
circumstances linked to the use of AI systems in the commission of offences 

Q.2.11 Are your data analysis tools integrated directly into your databases, or do you deploy 
external systems for data analysis? 

Response 

Frequency 

Percentage 

Member States 

External data analysis tools 

15 

55.6% 

Other (please specify) 

Not applicable 

Data analysis tools integrated to databases 

5 

4 

3 

18.5% 

14.8% 

11.1% 

LU, HR, NL, BE, 
AT,  LT,  SI,  CZ, 
DE, CY, EE, RO, 
PT, LV, DK 

SE,  EL,  ES,  HU, 
MT 

IE, FR, FI, BG 

SK, PL, IT 

Following Q.2.11, please specify "Other". 

Member 
State 

Response 

SE 

ProDiver is an external analytical tool that retrieves data from Nyps (support system) 

 
 
 
 
 
 
 
 
Member 
State 

Response 

Use  of  the  fraud  risk  assessment  tool  (E.VIII.1_1),  developed  in  Excel  format.  It  captures  and 
assesses  the  potential  risks  of  fraud for  the  Programme  and  is  based  on  a  specific  methodology 
developed by the European Commission (GUIDANCE NOTE ON FRAUD RISK ASSESSMENT 
AND EFFECTIVE AND PROPORTIONATE ANTI-FRAUD MEASURES (EGESIF 14-0021-00, 
16/06/2014). It was used during the 2014-2020 programming period, updated in line with the new 
requirements, and is also being used in the 2021-2027 programming period. 

Most of the entities consulted have ´Data analysis tools integrated to databases´. In one case the 
answer was ´External data analysis tools´ 

EL 

ES 

HU 

We also use data analytics tools integrated into databases and external data analytics tools. 

MT 

Our data analysis combines integrated and external tools. Malta uses the ARACHNE tool, which 
accesses  data  from  the  Maltese  centralized  information  system,  while  additional  analysis  is 
conducted  using  external  tools.  Scarlet  aggregates  shareholding  data  from  the  Malta  Business 
Registry  to  identify  links  between  enterprises  and  their  Ultimate  Beneficial  Owners.  The  Malta 
Association for Credit Management (MACM) provides insights into enterprises, including VAT 
numbers  and  any  associated  court  orders  or  financial  issues.  The  Jobsplus  database  offers 
employment history on individuals under scrutiny. This combined approach ensures comprehensive 
data-driven decision-making. 

Q.2.12 Does your data management system facilitate interoperability? 

Response 

Frequency 

Percentage 

Member States 

YES 

NO 

16 

59.3% 

11 

40.7% 

IE,  LU,  NL,  FR, 
BE,  AT,  SI,  CZ, 
HU, SK, PL, MT, 
EE, RO, PT, IT 

HR,  SE,  EL,  FI, 
LT,  ES,  DE,  BG, 
CY, LV, DK 

Q.2.13 If YES to Q.2.12, could you describe how interoperability is achieved between your 
data analysis tools and databases? 

Member 
State 

Response 

IE 

LU 

For example, the ESF+ permits interoperability as it is designed to comply RestAPI requirements 
on the Microsoft platform 

Analysis and exchange of information between services and MA, including the use of SFC web 
services. 

 
 
 
 
Member 
State 

Response 

NL 

FR 

BE 

In cooperation with different intern department which collect and combine information 

x 

ERDF, JTF and RRF at the SPW: All projects are fed into ARACHNE, and this is going to be done 
on a quarterly basis. ARACHNE is able to calculate a wide range of risk indicators as long as certain 
external or internal data is input. The external data comes from the World Compliance and Orbis 
databases, while the internal data is taken from an XLS file converted to XML (the format required 
by ARACHNE) and originating from the CALISTA database. The internal data is selected on the 
basis of the information required by ARACHNE for the ERDF OP. The Excel file generated by 
CALISTA is based on the file proposed by the Commission on ARACHNE (see Excel Arachne-
XMLGenerator). It should be noted that the types of data to be input might change over time in line 
with any developments to ARACHNE or CALISTA. 

AT 

Upload from the IDEA database in ARACHNE 

SI 

CZ 

HU 

SK 

Financial Administration of the Republic of Slovenia: As mentioned above the interoperability is 
achieved between our data analysis tools and databases thought direct access. In further steps, the 
databases are connected with different unique keys among data sources and become a part of the 
whole  specific  applications  for  further  IT  treatment  (calculations,  grouping  for  particular 
dimensions…).  Finally,  the  data  are  clearly  dynamic  analysed  and  presented  as  state-of-play, 
graphs, tables, reports, trends, clusters, etc. In this way, the suspicion patters, economic operators, 
or transaction can be identified quickly and easily. 

Automated  downloading  of  data  from  the  Commercial  and  Insolvency  Register  into  the  State 
Agricultural Intervention Fund information system.  
This  involves  interfaces  with  external  systems  (the  ESM  information  system  and  MS2021+, 
ARACHNE and MS2021+). A single search tool; data segment sharing between systems, internal 
data warehouse (in-house data). 

The EUPR and FAIR system has a fraud prevention function, the use of which is an integral part of 
our workflow. We also use of a number of external databases. 

The ITMS21+ system provides and will provide an online interface for the availability of machine-
processable  data  recorded  in  the  system,  which  are  fully  available  for  interoperability  with  any 
information system. The following systems are currently integrated in ITMS21+: ISUF, Register of 
addresses, Register of legal entities, Register of natural persons, Register of public sector partners, 
National  Labor  Inspectorate,  Register  of  bankrupts,  Tax  administration  (e.g.  information  on  tax 
arrears), Register of accounting financial statements, Health Insurance Company, Social Insurance 
Company. The integration of the criminal record system and EVO (Electronic Public Procurement) 
is  still  being  prepared.  Data  exchange  takes  place  through  the  standardized  REST  and  SOAP 
protocols.  These  systems  are  connected  to  ITMS21+  mainly  for  the  purpose  of  obtaining  and 
verifying data, such as information on legal entities, real estate ownership, or information on health 
and social insurance. For Slovak RRF works the secured storage for the database in the government 
cloud and their application communicates via API connection. The module is under development 
but based on API. 

PL 

For example, in one of the national IT tools, the ‘Cross-checks’ (Kontrole Krzyżowe) application, 
the data analysis concerns financial documents (invoices and documents with equivalent probative 

 
 
Member 
State 

Response 

value) contained in the ‘Projects’ (Projekty) application, which is also part of the central IT system 
CST2021. The algorithm generates correlated invoice groups (Grupy Faktur Skorelowanych, GFS) 
when it identifies that the same financial document, with the same issuer identifier and date of issue, 
appears  several  times  in  payment  applications  in  at  least  two  different  projects,  and  the  sum  of 
eligible  expenditure  from  the  documents  constituting  the  correlated  invoice  group  exceeds  the 
highest gross amount indicated in these documents. The system defines correlated invoice groups 
containing groups of settlement documents recognised by the system as invoices requiring cross-
checking. Each group is established on the basis of a score resulting from model rules indicating 
the  likelihood  of  double  funding.  The  overall  score  consists  of  6 main  components,  where  each 
component score seeks to assess and detect irregularities using a different method. 

Our  centralized  information  system  supports  interoperability  through  multiple  mechanisms.  It 
generates reports in Excel or XML format, ensuring compliance with the requirements of relevant 
national  authorities.  Additionally,  the  system  integrates  various  internal  and  external  APIs  to 
minimize manual data entry and enhance data validation and verification at the point of entry. For 
more specific needs, ad hoc reports can be developed with the support of the information system 
development team. 

The  grants  information  system  has  several  interfaces  with  various  national  registers,  enabling 
certain data to be automatically retrieved/used and verified. For example, control of the Business 
Register, the Public Procurement Register and the Punishment Register data. 

- The Ministry of Energy: By consulting platforms dedicated to the call for projects, or those which 
manage information applied concerning State aid  

- REGAS or risk management - ARACHNE, the real beneficiary - ONRC, the irregularity advisers 
facilitate the process of understanding how to make use of the information received and/or obtained 
in order to validate or invalidate the suspicion of irregularity. 

- ADR VEST: Using XML files 

- North-West Regional Development Agency (ADR NORD-VEST): Interoperability is  achieved 
through APIs. (There is currently interoperability between our internal database and MySMIS2021). 

-  The  CENTRE  Regional  Development  Agency  -  The  RECOM  database  of  the  Trade  Register 
Office is integrated into MySMIS 2021. 

-  MDLPA:  Jems  Architecture  components,  Jems  Web/Application  server,  MariaDB-  database 
storage, MinIO  

file 

- 
https://jems.scrollhelp.site/manual/v12 /system-architecture) 

storage, 

system 

Search 

Elastic 

- 

logging 

(Details 

available 

at: 

- MIPE - DGMMRR: Interconnection of existing platforms at Ministry of Finance level, ONRC, 
MIPE-SMIS 

Interoperability is achieved through the integration platform and the data platform, where the data 
is  stored  and  managed.  The  technological  architecture  allows  data  from  different  sources  to  be 
integrated into an automated and orchestrated standardised process, and the model implemented 
supports different databases, files and APIs. 

As already stated, the Integrated Anti-Fraud Platform (PIAF-IT) was developed, and cofinanced by 
the European Commission (OLAF) with Hercule III funding, in order to strengthen risk analysis in 

MT 

EE 

RO 

PT 

IT 

 
 
 
Member 
State 

Response 

the management of EU funds. Specifically, it is an IT tool that extracts, aggregates and reconciles 
data from national and EU sources to generate factsheets on natural or legal persons.  
The  platform  is  used  as  an  effective  tool  supporting  Arachne  with  the  aim  of  consolidating  and 
strengthening the fight against irregularities, fraud and other illegal activities against the EU budget 
both  before  expenditure  is  certified  and  during  the  ex-post  control  stage,  as  well  as  during 
administrative checks on implementation of the National Recovery and Resilience Plan. 
PIAF-IT has recently been upgraded to improve its reporting functionalities and thus provide new 
information and an improved user experience. In particular, the platform has been connected to new 
databases  to  improve  the  information  content  of  the  modules  and  provide  more  complete  and 
detailed  information  to  be  used  during  the  assessment  process,  with  the  additional  information 
coming from increased interoperability. 

Q.2.14  Does  your  digitalisation  strategy  prioritize  the  standardized  use  of  digital  tools  and 
technologies across local levels and different administrations so that all authorities involved in 
the anti-fraud strategy can access it? 

Response 

Frequency 

Percentage 

Member States 

33.3% 

22.2% 

IE,  HR,  SE,  EL, 
AT,  FI,  CZ,  ES, 
HU 

FR, BE, SK, MT, 
PT, IT 

14.8% 

LU, SI, PL, EE 

11.1% 

NL, BG, RO 

11.1% 

LT, DE, DK 

7.4% 

CY, LV 

Not applicable (unable to provide an evaluation) 

Yes, standardization of digital tools is a central goal of 
our strategy 

Other (please specify) 

No, but we are planning to focus on standardization in 
future initiatives 

Standardization  is  not  considered  essential  in  our 
digitalisation efforts 

We  are  currently  assessing 
standardizing digital tools 

the  benefits  of 

9 

6 

4 

3 

3 

2 

Following Q.2.14, please specify "Other". 

Member 
State 

Response 

LU 

SI 

We are planning to focus on standardization in future initiatives. Note that the first answer is also 
applicable. 

Financial  Administration  of  the  Republic  of  Slovenia  (FARS)  answers  YES  standardization  of 
digital tools is a central goal of our strategy and in addition FARS explains: We evaluate totally 

 
 
 
 
 
 
Member 
State 

Response 

successful implementation of the digital tools at different administrative levels in FARS, but we 
cannot evaluate this topic at different administrative levels outside FARS. 

The  managing  authorities  of all  cohesion  policy  programmes  are  required  to  draw  up their  own 
document on how to prevent and deal with corruption and fraud, including conflicts of interest in 
the respective programme (the document must also include information on the digitalisation of the 
fight against fraud). Regardless of the level of administration, the competent ministry ensures access 
to digital tools and technologies designed for the purpose of fighting fraud. However, it is up to the 
managing authority to decide how these tools are used. The aim is to ensure the most effective use 
of  tools  in  the  process  of  combatting  fraud  at  programme  level.  The  tools  developed  by  the 
EC/OLAF (mainly IMS) are an exception, and they are used by the institutions in a standardised 
manner, resulting from the relevant EU regulations and national procedure. 

Estonia's digitalization strategy can be called the "Digital Society Development Plan 2030" (DAK), 
and to implement it, each ministry prepares an ICT strategy for its own field. The DAK does not 
contain sectoral digitalization goals, and these should be included in the ICT strategy of the MoF, 
which is not a public document. 

PL 

EE 

Q.2.15  How  do  you  evaluate  the  successful  implementation  of  the  digital  tools  at  different 
administrative levels? 

Response 

Frequency 

Percentage 

Member States 

Partially successful 

16 

59.3% 

SE,  NL,  FR,  EL, 
BE,  AT,  FI,  LT, 
SI,  ES,  SK,  BG, 
EE, PT, LV, DK 

IE,  LU,  HR,  CZ, 
DE, RO 

22.2% 

14.8% 

HU, PL, MT, IT 

3.7% 

CY 

Other (please specify) 

Totally successful 

Not successful 

6 

4 

1 

Following Q.2.15, please specify "Other". 

Member 
State 

Response 

IE 

LU 

HR 

n/a 

We are planning to focus on standardization in future initiatives. 

Ministry of Agriculture, Forestry and Fisheries, Directorate for Support in Agriculture and Rural 
Development is planning to implement of the digital tools at their administrative levels. 

 
 
 
 
Member 
State 

Response 

CZ 

No such evaluation has taken place. 

DE 

The  Bremen  ERDF  Managing  Authority:  Digitalisation  is  constantly  being  developed.  The 
Schleswig-Holstein ERDF Managing Authority: Partially successful 

RO 

AFIR: Insufficient data taken over from ARACHNE existing in Romania. 

Q.2.16  To  what  extent  have  digital  tools  been  spread  and  adopted  across  different 
administrative levels? 

Response 

Frequency 

Percentage 

Member States 

Not applicable (unable to provide an evaluation) 

13 

48.1% 

Achieved dissemination to all administrative levels 

10 

37.0% 

IE,  HR,  SE,  BE, 
AT,  FI,  LT,  SI, 
CZ, ES, BG, CY, 
EE 

NL, EL, HU, SK, 
DE, MT, RO, PT, 
LV, IT 

Other (please specify) 

Limited  dissemination  to  specific  regions/localities 
only (please specify) 

4 

1 

14.8% 

LU, FR, EL, PL 

3.7% 

DK 

Following Q.2.16, please specify "Limited dissemination to specific regions/localities only ". 

Member 
State 

Response 

DK 

The Danish Business Authority: The managing authority makes use of an external auditor, that, in 
order  to  carry  out  audits  on  all  projects  has  been  granted  access  to  the  reporting  system  of  the 
managing authority. 

Following Q.2.16, please specify "Other”. 

Response 

Frequency 

Percentage 

Member States 

Digitalisation concerns procedures in general and not 
specifically fraud. 

The institutions of the system for the implementation, 
management  and  control  of  cohesion  policy  at 
different  levels  have  the  appropriate  digital  tools  at 

1 

1 

3.7% 

3.7% 

EL 

PL 

 
 
 
 
 
Response 

Frequency 

Percentage 

Member States 

their disposal to fight fraud. Access to those tools has 
been  ensured  by  the  Institution  Coordinating  the 
Partnership Agreement. In addition, some institutions 
have their own anti-fraud tools that they have created 
or purchased themselves. 

Use  of  external  tools  and  frequent  exchange  of 
information.  
Dissemination 
stakeholders. 

successfully 

achieved 

key 

to 

x 

1 

1 

3.7% 

LU 

3.7% 

FR 

Q.2.17  What  are  the  key  challenges  you  face  in  accelerating  the  digitalisation  of  your  fight 
against fraud? 

Response 

Frequency 

Percentage 

Member States 

Data privacy and security concerns 

19 

70.4% 

Legal or regulatory barriers 

19 

70.4% 

Budget limitations 

17 

63.0% 

Integration challenges with legacy systems 

17 

63.0% 

Lack of expertise 

15 

55.6% 

IE,  SE,  NL,  EL, 
BE,  AT,  FI,  SI, 
CZ, ES,  HU,  SK, 
PL,  DE,  EE,  RO, 
PT, DK, IT 

IE,  HR,  SE,  NL, 
EL,  BE,  FI,  SI, 
CZ,  ES,  PL,  DE, 
BG, MT, CY, EE, 
RO, LV, IT 

LU, HR, NL, EL, 
BE,  FI,  SI,  CZ, 
ES,  HU,  SK,  PL, 
DE, BG, EE, RO, 
LV 

IE,  LU,  HR,  NL, 
EL,  BE,  SI,  ES, 
SK,  PL, DE,  BG, 
EE, RO, LV, DK, 
IT 

LU, HR, NL, EL, 
BE,  FI,  SI,  CZ, 
ES, HU, SK, DE, 
BG, RO, PT 

 
 
 
Response 

Frequency 

Percentage 

Member States 

Resistance to change 

9 

33.3% 

Accessibility at a regional / local administration level 

8 

29.6% 

LU, HR, EL, CZ, 
ES, BG, CY, RO, 
LV 

IE,  HR,  EL,  BE, 
CZ, CY, RO, DK 

Other (Please specify) 

3 

11.1% 

SI, DE, RO 

Following Q.2.16, please specify "Other”. 

Member 
State 

Response 

Financial Administration of the Republic of Slovenia answer: We believe that the key challenges 
we face in accelerating the digitalisation of our fight against fraud are the access of data different - 
additional  sources,  data  integration  and  data  conformability  (unique  structures)  and  also  data 
privacy  and  security  concerns.  Furthermore,  we  believe  that  the  lack  of  advanced  IT  experts, 
developers and analytics remains the most important issue in public sector. Nevertheless, the lack 
of human resources could be also one of the challenges, which we face with. 

The Bremen ERDF Managing Authority: Conceptual preparatory work still to be done. 

AFIR: ARACHNE 

SI 

DE 

RO 

Q.2.18 Has your Member State conducted evaluations to assess the interoperability of national 
systems with Arachne? 

Response 

Frequency 

Percentage 

Member States 

Not applicable (system already used) 

YES 

NO 

10 

10 

6 

37.0% 

37.0% 

22.2% 

FR,  EL,  BE,  AT, 
HU, SK, BG, MT, 
LV, IT 

LU,  SE,  FI,  CZ, 
ES,  PL,  CY,  RO, 
PT, DK 

IE,  HR,  NL,  SI, 
DE, EE 

 
 
 
 
 
Q.2.19 If “YES” to Q.18, Please provide key findings or the stage of completion concerning 
system interoperability. 

Member 
State 

Response 

LU 

One  stakeholder  reports  difficulties  in  connecting  ARACHNE  with  their  systems.  The 
administrative effort is very high and not sensible in terms of costs/benefits. 

SE 

As part of a public inquiry (SOU 2024:22 A new way to organise the management of EU funds), 
the  Swedish  government  has  examined  the  need  for  a  common  digital  platform.  The  inquiry 
concludes that Arachne should be used, but that it is necessary to analyse more carefully whether 
the system is compatible with Swedish legislation on public access and secrecy. To this end, the 
Government  has  launched  a  new  inquiry  (Use  of  certain  tools  to  protect  the  Union’s  financial 
interests - Regeringen.se). The purpose of this inquiry is to ensure that data is entered in accordance 
with Swedish legislation and to analyse whether using Arachne for purposes other than data entry 
is compatible with Swedish legislation. 

FI 

Exploratory work in relation to certain EU funds is still ongoing. 

CZ 

As  part  of  the  pre-analysis  so  far,  the  Directorate-General  for  Finance  has  focused  on  the 
interoperability  of  systems,  i.e.  the  possibility  of  using  ARACHNE  as  an  integrated  preventive 
technology tool provided by the European Commission as part of its process of developing control 
plans, data mining and risk identification. The ARACHNE tool aims to make it easier for staff to 
check specific activities and to develop a control plan with the best possible targeting of checks on 
structural  funds,  specifically  the  European  Social  Fund  (ESF)  and  the  European  Regional 
Development Fund (ERDF).  

1. Basic key findings: 
Incorporation of ARACHNE into the process of developing control plans: ARACHNE is expected 
to  enable  more  effective  identification  of  risk  areas  and  contribute  to  better  targeting  of  control 
mechanisms.  The  integration  of  these  data  into  the  analytical  processes  of  the  Financial 
Administration  will  strengthen  the  prevention  and  detection  of  possible  irregularities  in  project 
funding. Interconnection of available data from other sources (State Treasury, Subsidies Register - 
ReD information system, Model - Risk Indicator Set - Subsidies) and information from ARACHNE: 
To prepare a model that is directly linked to the outputs of the subsidy data publication working 
group (PSPDD), i.e. the expected transfer of subsidy data from the State Treasury (for a certain 
period from the ReD information system), where it is expected that these data will be supplemented 
with information from ARACHNE in the future. It is expected that, in order to identify projects, 
recipients of public contracts and suppliers with a higher likelihood of fraud, conflict of interest and 
other  irregularities,  the  individual  pieces  of  information  will  be  linked  with  the  already existing 
Model – Risk Indicator Set – Subsidies.  

2. Completion phase:  
The Subsidy Risk Coordinators Working Group (KONDOR) is testing the ARACHNE tool, i.e. the 
possibility  of  using  the  information  presented here  for  the  development  of  control  plans.  At  the 
Directorate-General  for  Finance,  testing  is  underway  on  exporting  data  from  ARACHNE  and 
subsequently linking them to other data sources, specifically the ReD information system and Model 
– Risk Indicator Set – Subsidies. Both areas are in the initial phase of testing, which is expected to 
be completed by the end of 2025.  

 
 
 
 
 
 
Member 
State 

Response 

One of the managing authorities indicated that the data reported in Arachne are different from those 
in the national systems and registers. 

ES 

Work is underway to adapt the FEGA paying agency's management applications to generate upload 
files in Arachne with the necessary information for a useful risk analysis. 

In the area of cohesion policy, an assessment was carried out of the interoperability of the national 
systems  with  the  Arachne  tool.  The  analysis  was  performed  on  the  available documentation  for 
Arachne. A comparative analysis of the functionality of the national IT tools with Arachne was also 
carried out in terms of the rationale behind creating applications, risk analysis, the impact of users 
on risk analysis, changes in risk analysis parameters, application type, data origin, scope of data, 
integration with additional databases, additional administrative burden, detection of irregularities, 
‘economic intelligence’ functions, use of AI. The analysis showed that Arachne, in its current form, 
is  not  fully  suited  to  the  needs  of  the  institutions.  Some  flaws  in  the  functions  of  the  tool  and 
difficulties in using it were identified, including but not limited to the presence of false positive 
results,  legal  barriers,  in  particular  as  regards  compliance  with  national  data  protection  rules, 
additional administrative burden related to the collection of data for Arachne, unclear algorithms 
for the calculation of individual risk indicators, lack of an error-handling tool.  
In  addition,  Arachne  is  currently  used  as  part  of  the  National  Recovery  and  Resilience  Plan, 
including the cyclical transmission of input data. 

System interoperability at the moment is not possible. We can feed data to Arachne. At the moment 
we are planning to upload back to our MIS data from Arachne through an XML file. 

Ministry of Energy: The ARACHNE system is implemented at DGI-ME level and is consulted in 
order to obtain information on how to effectively manage irregularities. 

is 

that 

this  reporting 

At  present,  Fund data  is  integrated  by  uploading an  XML  file  to  the  ARACHNE  platform.  The 
the  future. 
is  done  by  means  of 
intention 
Considering  that  the  process  of  implementing  interoperability  is  in  the  phase  where  the 
specifications of the services provided by the ARACHNE platform are being analysed, it is not yet 
possible to draw conclusions on this topic at this stage. 

interoperability 

in 

of 

the 

Most 
in  Q.2.18.  
The Danish Agency for Green Land Conversion and Water Environment reported “Yes” and noted: 
We are at a very early stage in our evaluations. 

contributions 

reported 

survey 

“No” 

the 

to 

a 

PL 

CY 

RO 

PT 

DK 

Q.2.20 What steps have you undertaken to ensure your systems are prepared to feed data into 
Arachne  for  the  upcoming  multiannual  financial  framework?  Please  refer  to  the  indicative 
milestones from figure 1 and select the ones you have reached. 

Response 

Frequency 

Percentage 

Member States 

Data identification: Identified data sources 

11 

40.7% 

HR,  BE,  ES,  SK, 
BG, CY, EE, RO, 
PT, LV, IT 

 
 
 
Response 

Frequency 

Percentage 

Member States 

Scoping/Assessment:  Assessed 
operational requirements 

technical 

and 

10 

37.0% 

LU,  BE,  ES,  SK, 
PL, CY,  EE,  RO, 
DK, IT 

IE,  HR,  NL,  FR, 
EL,  FI,  LT,  SI, 
DE 

HR,  SE,  CZ,  ES, 
SK, PL, MT, CY, 
RO 

HR, BE, AT, SK, 
CY, EE, RO, PT 

BE,  SI,  CY,  EE, 
RO, LV, IT 

BE,  ES,  SK,  CY, 
EE, RO 

BE,  ES,  EE,  RO, 
IT 

BE,  ES,  CY,  EE, 
RO 

33.3% 

33.3% 

29.6% 

25.9% 

22.2% 

18.5% 

18.5% 

11.1% 

BE, HU, BG 

9 

9 

8 

7 

6 

5 

5 

3 

No preparation actions taken in 2024 

Other (please specify) 

Data Mapping: Mapped the data (ensured that the data 
and  system  structure  are  compatible  with  Arachne’s 
system) 

Testing:  Conducted 
capability to feed data 

tests 

to  confirm  system’s 

Development 
necessary system modifications 

/Adjustment:  Started  or  completed 

Planning: Developed detailed plans for integration 

Resource Allocation: Allocated necessary budget and 
human resources 

Completed 
systems with Arachne 

Integration:  Successfully 

integrated 

Following Q.2.20, please specify "Other ". 

Member 
State 

Response 

HR 

SE 

CZ 

ES 

Our  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  for  Support  in  Agriculture  and 
Rural Development highlighted the following answers: Data identification: Identified data sources 
and Data Mapping: Mapped the data (ensured that the data and system structure are compatible with 
Arachne´s system) 

An inquiry has been launched to ensure that the legal conditions will be in place. 

Given the connection of the MS2021+ national information system to Arachne and the data sharing 
that is already set up and fully operational, it is not considered necessary to further modify this area. 

The answers provided to Q2.20 refer only to one authority. The other authorities´ answer was No 
preparation actions taken in 2024 

 
 
 
Member 
State 

Response 

SK 

PL 

MT 

CY 

RO 

The RRF is preparing automation of data export for API integration on Arachne. The process of 
API  integration  has  already  been  discussed  with  the  Arachne  support  team  in  the  European 
Commission. 

Arachne  is  currently  used  as  part  of  the  National  Recovery  and  Resilience  Plan,  including  the 
cyclical transmission of the input data. 

The  process  to  upload  data  on  Arachne  starts  with  the  extraction  of  xml  files  from  the national 
management  information  systems.  Prior  to  uploading,  these  files  are  validated  on  the  Arachne 
database itself to check whether the xml text contains any errors (using the Data Upload icon and 
selecting the field ‘File Validation’). If the files are validated successfully, these files are uploaded 
on  Arachne  (using  the  Data  Upload  icon  and  selecting  the  field  ‘File  Upload’).  The  database 
prompts you whether the files have been uploaded satisfactorily or not. 

Arachne is used for Cohesion and Fisheries funds programs and the RRP. Planned to be used for 
agricultural policy programs and migration programs. Data is imported in Arachne through an XML 
file. 

AFIR: At present, data are entered manually (XML loading). In the first quarter of 2025, we plan 
to develop software for the automatic uploading of data 

Q.2.21 Currently,  what  are the factors preventing you from being  able to feed the data into 
Arachne? 

Response 

Frequency 

Percentage 

Member States 

Not applicable, already using it 

18 

66.7% 

Technical limitations 

Uncertainty about tool’s effectiveness 

Budget constraints 

Lack of staff expertise 

Legal constraints 

Other tool(s) already in use 

7 

7 

5 

5 

5 

4 

25.9% 

25.9% 

18.5% 

18.5% 

18.5% 

IE,  LU,  HR,  FR, 
EL,  BE,  AT,  SI, 
CZ, HU, SK, BG, 
MT, CY, RO, PT, 
LV, IT 

NL,  FI,  LT,  CZ, 
ES, RO, DK 

FI,  LT,  CZ,  PL, 
DE, EE, DK 

NL,  FI,  CZ,  ES, 
EE 

FI,  LT,  ES,  RO, 
DK 

SE,  NL,  FI,  ES, 
DE 

14.8% 

CZ, ES, PL, DK 

 
 
 
Q.2.22 What type of support would facilitate your successful integration of data into Arachne 
by the required deadline? 

Response 

Frequency 

Percentage 

Member States 

Training programs  /  Information  sharing (handbooks 
etc.) 

16 

59.3% 

Technical assistance 

13 

48.1% 

Financial support 

10 

37.0% 

Not applicable 

Other (please specify) 

9 

4 

Following Q.2.21, please specify "Other ". 

Member 
State 

Response 

HR,  NL,  AT,  FI, 
LT,  SI,  CZ,  ES, 
PL, DE, BG, MT, 
RO, PT, DK, IT 

HR,  NL,  FI,  LT, 
CZ,  ES,  SK,  DE, 
BG,  MT,  RO, 
DK, IT 

HR,  NL,  FI,  CZ, 
ES,  DE,  BG,  EE, 
RO, IT 

IE,  LU,  FR,  EL, 
BE,  SI,  HU,  CY, 
LV 

33.3% 

14.8% 

SE, PL, MT, EE 

SE 

PL 

Legal support, ensuring timely answers to questions so that Sweden can assess the system’s legal 
implications 

1. Streamlining the data input process to reduce the administrative burden. 
2. Strengthening the function allowing users to remove red flags that have already been noticed and 
assessed as ‘clear’, i.e. not reflecting real fraud risks, in order to reduce the number of false positive 
results.  
3. Providing Member States with details of the risk analysis applied (currently users see only the 
end result). 
4. A well-functioning Service Desk where flaws in the functioning of the tool could be reported and 
followed up until feedback is received confirming or ruling out the flaw. 

MT 

Financial support provided by the European Commission. 

EE 

ARACHNE should be developed to make data analysis broad and useful. Overly general evaluation 
criteria will not yield results. 

 
 
 
 
 
 
 
Q.2.22 What type of support would facilitate your successful integration of data into Arachne 
by the required deadline? 

Response 

Frequency 

Percentage 

Member States 

Training programs  /  Information  sharing (handbooks 
etc.) 

17 

63.0% 

Technical assistance 

14 

51.9% 

Financial support 

11 

40.7% 

Not applicable 

Other (please specify) 

6 

6 

22.2% 

22.2% 

LU, HR, NL, AT, 
FI,  LT,  SI,  CZ, 
ES,  PL,  DE,  BG, 
MT, RO, PT, DK, 
IT 

LU,  HR,  NL,  FI, 
LT,  CZ,  ES,  SK, 
DE, BG, MT, RO, 
DK, IT 

LU,  HR,  NL,  FI, 
CZ, ES,  DE,  BG, 
EE, RO, IT 

FR, EL,  BE, HU, 
CY, LV 

IE,  LU,  SE,  PL, 
MT, EE 

Following Q.2.22, please specify "Other ". 

Member 
State 

Response 

IE 

LU 

SE 

PL 

There is no national anti-fraud strategy in place, so the management of EU funds is devolved so 
difficult to answer for all, but points raised include the lack of a national id number, and GDPR 
concerns around data sharing 

Customized guidance taking into account the specificities of national programs and the available 
data (type and formats). 

Legal support, ensuring timely answers to questions so that Sweden can assess the system’s legal 
implications 

1. Streamlining the data input process to reduce the administrative burden. 
2. Strengthening the function allowing users to remove red flags that have already been noticed and 
assessed as ‘clear’, i.e. not reflecting real fraud risks, in order to reduce the number of false positive 
results.  
3. Providing Member States with details of the risk analysis applied (currently users see only the 
end result). 
4. A well-functioning Service Desk where flaws in the functioning of the tool could be reported and 
followed up until feedback is received confirming or ruling out the flaw. 

MT 

Financial support provided by the European Commission. 

 
 
 
 
 
Member 
State 

Response 

EE 

ARACHNE should be developed to make data analysis broad and useful. Overly general evaluation 
criteria will not yield results. 

Q.2.23 As part of your anti-fraud strategies, are you considering the use of Arachne? 

Response 

Frequency 

Percentage 

Member States 

Already in use 

18 

66.7% 

LU, HR, FR, EL, 
BE,  AT,  SI,  CZ, 
HU, SK, PL, BG, 
MT, CY, RO, PT, 
LV, IT 

IE,  FI,  ES,  DE, 
DK 

Undecided 

Planning to use 

5 

4 

18.5% 

14.8% 

SE, NL, LT, EE 

Q.2.24 If “Already in use” or “planning to use” to Q.2.21, please elaborate on your (planned) 
use of the tool. If “No plans to use”, please provide a brief explanation for not planning to use 
Arachne. 

Member 
State 

Response 

LU 

HR 

SE 

The use of ARACHNE is primarily limited to the import of our data into the ARACHNE system. 

NB: One stakeholder reports that they have no plans to use it. 

Contribution from Ministry of Labour, Pension System, Family and Social Policy, Directorate for 
the Management of EU:    
Arachne is a mandatory tool for fraud detection in the ESF procedural rules.    

Ministry of Agriculture, Forestry and Fisheries, Directorate for Support in Agriculture and Rural 
Development has detected two risk indicators to track, “Beneficiaries involved in multiple Ops” 
and  “Links  between  beneficiaries  and  contractors”  which  they  will  try  to  use  to detect potential 
cases of undisclosed double financing and conflict of interest between beneficiaries and contractors. 
The projects with high score on these indicators are checked more thoroughly.  

Sweden intends to comply with the  requirements of the Financial Regulation. Sweden also sees 
benefits in using the system more extensively also for ex ante controls to ensure that double funding 
and conflicts of interest do not occur. However, such use  must be compatible with the Swedish 
Public Access to Information and Secrecy Act, and this is currently being investigated. 

NL 

Planning to use new Arachne 

 
 
 
 
 
 
 
Member 
State 

Response 

FR 

Not  all  the  bodies  that  manage  cohesion  policy  funds  use  Arachne.  Arachne  enables  the 
management bodies that use it to bolster their procedures for the prevention and detection of risks 
of irregularities or fraud.  
However,  it  also  increases  the  administrative  burden  on  the  staff  responsible  for  management 
checks. Arachne contains an array of information that makes it difficult to understand, with risk 
indicators  that  are  difficult  to  interpret.  The  risks  that  the  system  can  highlight  are  not  always 
relevant or of a scale proportionate to the control and management of financial transactions funded 
by the cohesion policy. 
The management bodies also use various databases which can be consulted instead of or as well as 
Arachne  (Manageo,  Fiben,  Societe.com,  Infogreffe,  Diane,  Pappers,  API  entreprise,  etc.).  The 
consultation  of  digital  tools  or  information  systems  for  data  on  beneficiaries  of  EU  funds  is 
integrated  into  all  the  managing  authorities’  management  verification  procedures  and  anti-fraud 
measures.  
In other areas, in line with the recommendations of the European Commission, consulting Arachne 
is one of the means to detect fraudulent practices as decided upon by the management bodies of the 
YEI and ESF national operating programmes for the 2014-2020 programming period.   
As far as the CAP is concerned, the paying agencies have not begun to use Arachne at this stage. 
Work is under way to gain familiarity with how the tool works and to anticipate with DG AGRI and 
the paying agencies any adaptations of the system that might be necessary to the specificities of the 
CAP.  

EL 

Recovery and Resilience Facility Coordination Agency (RRFA): The tool is used for the  ex-ante 
control of absence of conflict of interest in public procurement and loan contracts. 

BE 

ERDF, JTF and RRF at the SPW: All projects are fed into ARACHNE, and this is going to be done 
on a quarterly basis. ARACHNE is able to calculate a wide range of risk indicators as long as certain 
external or internal data is input. The external data comes from the World Compliance and Orbis 
databases, while the internal data is taken from an XLS file converted to XML (the format required 
by ARACHNE) and originating from the CALISTA database. The internal data is selected on the 
basis of the information required by ARACHNE for the ERDF OP. The Excel file generated by 
CALISTA is based on the file proposed by the Commission on ARACHNE (see Excel Arachne-
XMLGenerator) 

AT 

No information. 

LT 

SI 

CZ 

MoF currently awaits for training from the EC on Arachne. After the training we will carry out a 
trial to evaluate how long does it take to update data in Arachne and will start required actions to 
adapt our national IT system for ESIF and RRF to Arachne. 

Arachne  is  already  in  use  and  will  continue  to  be  used  for  management  verifications.  We  also 
provide  users  with  training  on  how  to  use  the  tool.  Note:  Arachne  is  used  by  the  Managing 
Authority, the Intermediate Body, the Implementing Body and the Audit Authority 

Evaluation of projects/applicants and subsequently beneficiaries; one of the bases for risk analysis; 
monitoring  the  connections  between  ownership  structures,  checking  conflicts  of  interest  under 
Article  61  of  the  Financial  Regulation  (in  particular,  checking  conflicts  of  interest  with  the 
implementation structure and conflict of interest in public procurement), checking sanctions lists 
checked; 
and 

funding 

relation 

project 

double 

being 

the 

in 

to 

 
 
 
 
Member 
State 

Response 

in 

relation 

in  particular 

one of several different tools used to identify the risk of, in particular, conflicts of interest, fraud or 
double funding; there is a strong emphasis on inputting new data into the tool, but the priority is no 
longer to update data, including deleting outdated or false data (e.g. when a project is supported first 
from Programme A, then the subsidy is withdrawn and the same project is supported from another 
programme.  As  a  result,  there  may  be  two  identical  projects  financed  from  different  sources  in 
Arachne, which is not the case, because support was actually provided only from programme B). 
We  consider  that  both  technical  and  financial  assistance  from  the  EC  is  necessary  to  ensure 
satisfactory functionality and increased use of the tool. 
Use in the control process. Extending the functionalities to include improvements in the  ex-ante 
evaluation  or  checks  of  whether  the  entity  being  inspected  is  subject  to  the  application  of  the 
sanction  Regulations  would  be  very  welcome.  use 
to: 
— evaluating the aid application and issuing the legal act; — administrative verification; — on-the-
spot checks. 
The risk coordinator coordinates the use of Arachne within the OP implementation structure. They 
keep record of the findings of the verifications of the entities before issuing the legal act and during 
administrative verification, and subsequently take these findings into account when developing the 
risk analysis of the projects for drawing up the plan for the on-the-spot checks. 
Based on the annual risk analysis that is the basis for  establishing the on-the-spot check plan, when 
performing  public  procurement  checks  using  public  registers  and  Arachne  to  check  potential 
conflicts of interest, the managing authority carries out regular data and information analyses across 
operations in order to identify and subsequently carry out a more thorough follow-up of operations 
showing  fraud  indicators  (e.g.  by  means  of  an  on-the-spot  check).  The  managing  authority  is 
required  to  use  these  identified  and  evaluated  data  for  its  control  activities,  i.e.  in  particular  to 
identify operations with an increased risk of fraud; verification of the risk of fraud, possible conflict 
of interest, for example, in the case of persons acting on behalf of tenderers for tenders ranked in 
the first three places in the selection/tendering procedure, checks are made on connections between 
the  selected  contractors  and  the  contracting  authority  and  other  possible  links,  duplication  in 
projects, insolvency and other risk situations; use for ex ante analyses. 
One managing authority uses the system only marginally because it does not contain, for example, 
regional subsidies and is therefore not very useful for the authority. 

HU 

SK 

Data specified in EU legislation are uploaded to ARACHNE every 2 months. Applying ARACHNE 
and documenting the application is generally an integral part of development policy processes. A 
methodology for the application of ARACHNE and the use of its results has been developed. The 
methodology will be reviewed annually. 

The Arachne tool functions as a compulsory auxiliary search tool of the data contained in it for 
cohesion policy, in order to identify projects that could potentially be susceptible to fraud risks, 
conflicts of interest and irregularities. MA/IB primarily try to use the Arachne tool in the project 
approval phase as well to verify conflicts of interest as one of the possible verification tools. The 
Arachne tool is also used in implementation phase of projects (payment claims, on the spot checks). 
Arachne is used by the audit authority as a tool in the performance of audits.  Slovak RRP: The line 
ministries  as  implementing  bodies  already  use  Arachne.  The  coordinating  body  (National 
Implementation and Coordination Authority – NICA) collects all the data on the implementation of 
the RRP; these are then exported to xml file and uploaded to Arachne on a monthly basis. 

PL 

Arachne  is  currently  used  as  part  of  the  National  Recovery  and  Resilience  Plan,  including  the 
cyclical transmission of the input data. The Institutions responsible for investments have developed 

 
 
 
 
 
 
Member 
State 

Response 

procedures that take account of the use of Arachne in the control process. In the case of cohesion 
policy programmes, since documents concerning anti-fraud measures are drawn up at programme 
level, individual managing authorities have discretion in this regard.   
At  the  Paying  Agency,  the  Arachne  system  is  used,  among  other  things,  for  the  verification  of 
personal and capital links between entities in the context of applications for co-financing of projects 
or for the disbursement of support. In the course of the checks, the control staff establish the facts 
and compare them with the state of affairs as required by the rules, procedures and interpretations 
of  the  procedures.  The  use  of  Arachne  as  a  tool  for  data  acquisition  and  risk  assessment  in  the 
context of the NRRP supplements the existing management and control systems used in carrying 
out verification and control activities and serves to strengthen the control systems, including fraud 
prevention, avoidance of conflicts of interest and double funding and their detection, and it possibly 
serves to reduce the rate of occurrence of serious irregularities. 

-  Check  for  presence  or  absence  of  conflict  of  interest  of  the  composition  of  evaluation 
commissions: Carrying out a Check for the presence or absence of a Conflict of Interest, according 
to  Art.  61  of  Regulation  (EU,  Euratom)  No.  2018/1046  of  the  European  Parliament  and  of  the 
Council of July 18, 2018, presence of connectivity within the meaning of § 1, item 9 of the DR of 
the ZPK and hierarchical dependence of the proposed composition of the evaluation commission. 
The verification is performed by extracting data from the ARAHNE.   
-  Using  the  ARAHNE  for  fraud  risk  assessment:  After  completion  of  an  evaluation  procedure 
through  the  selection  of  project  proposals  submitted  by  private  legal  entities  or  non-profit  legal 
entities, before a decision for the  grant is made by the  Head of the MA, a check is made in the 
ARAHNE for the presence of a risk of fraud and suspected conflicts of interest. The reference is 
made on the basis of the information available in ISUN about the submitted project proposals.    
- Conducting an inquiry in the ARAHNE for the presence of fraud risk and suspected conflict of 
interest, in the event of a reported irregularity when identifying indicators of fraud ("red flags"). 
The inquiry is conducted by an employee of the "Irregularities" department." 

As stated in Q.2.18 and Q2.20, Arachne is already in use. The menu ‘entity search’ is used to check 
the  extent  of  risk  of  specific  projects,  contracts,  companies  and  persons.  There  are  seven  risk 
categories,  namely  procurement,  contract  management,  eligibility,  performance,  concentration, 
reasonability, and reputational and fraud. Each of these 7 risk categories are further subdivided into 
risk indicators (more than 100). The level of risk and sub-risks of these 7 categories are monitored 
for any red flags that may ensue in relation to projects and/or contracts, e.g. (1) a high ‘reputational 
and fraud risk’ would feature a red flag of potential conflict of interest in relation to the entity in 
question; and (2) a high ‘concentration risk’ would feature a red flag of potential double funding in 
relation to a contract. A high risk would trigger further work outside Arachne to determine whether 
the red flags translate in actual irregularities/fraud. 

BG 

MT 

CY 

Already using it. 

EE 

The first mapping of our specific needs has been completed. We found that Arachne, on its own, 
does  not  help  in  identifying  the  specific  risks  associated  with  funding  measures.  Regardless  of 
whether or how extensively Arachne is used, a specific risk assessment based on the measure itself 
is still necessary. However, Arachne could serve as a supportive tool alongside other administrative 
control. 

LV 

Evaluation of risk indicators. Identification of risk signs. Evaluation of inter-company relationships. 

 
 
Q.2.25 Has your Member State implemented ARACHNE? 

Response 

Frequency 

Percentage 

Member States 

YES 

NO 

22 

81.5% 

5 

18.5% 

IE,  LU,  HR,  FR, 
EL,  BE,  AT,  LT, 
SI,  CZ,  ES,  HU, 
SK, PL, BG, MT, 
CY, EE, RO, PT, 
LV, IT 

SE,  NL,  FI,  DE, 
DK 

Q.2.26 If “YES” to Q.2.25, please specify the entities or individuals that have access to the 
Member State's data within the Arachne system. 

Response 

Frequency 

Percentage 

Member States 

Audit authorities 

18 

66.7% 

Only managing authorities 

15 

55.6% 

Other (please specify) 

12 

44.4% 

AFCOS 

Law enforcement 

Not applicable 

9 

2 

1 

33.3% 

7.4% 

3.7% 

LU, HR, EL, BE, 
AT,  LT,  SI,  CZ, 
ES,  HU,  SK,  PL, 
BG, MT, RO, PT, 
LV, IT 

HR,  FR,  EL,  BE, 
AT, LT, CZ, HU, 
SK, BG, MT, EE, 
PT, LV, IT 

LU, HR,  CZ, ES, 
HU, SK, PL, CY, 
EE, RO, LV, IT 

BE,  LT,  CZ,  ES, 
SK,  BG,  EE,  PT, 
LV 

LT, LV 

IE 

Following Q.2.26, please specify "Other ". 

Member 
State 

Response 

LU 

Managing Authorities 

 
 
 
 
 
Member 
State 

Response 

HR 

Intermediate Bodies 

CZ 

ES 

HU 

SK 

PL 

CY 

EE 

RO 

LV 

Implementation entities in the National Recovery Plan (component owners = managing authorities), 
inspection officers, intermediate bodies. 

Managing authorities 

Directorate for Internal Audit and Integrity, Central Coordination 

Slovak  RRF  implementing  bodies  (line  ministries),  coordinating  body  (NICA)  and  CA  (the 
certifying authority). 

Institutions of the National Recovery and Resilience Plan 

Treasury  of  the  Republic  under  its  competence  to  perform  controls  on  behalf  of  the  authorities 
managing the EU Funds. 

Implementing Agencies 

MANAGEMENT AUTHORITIES 

Paying agency for EU funds for agricultural and rural development, Accounting Body of the ESF, 
ERDF and CF, Procurement Monitoring Bureau 

Q.2.27 If “YES” to Q.2.25, what is the tool used for? 

Response 

Frequency 

Percentage 

Member States 

Detection 

21 

77.8% 

Prevention 

19 

70.4% 

Investigation 

Not applicable 

12 

1 

44.4% 

3.7% 

IE 

LU, HR, FR, EL, 
BE,  AT,  LT,  SI, 
CZ, ES,  HU,  SK, 
PL, BG, MT, CY, 
EE,  RO,  PT,  LV, 
IT 

LU, HR, FR, EL, 
BE,  AT,  LT,  SI, 
CZ, HU, SK, PL, 
BG, CY, EE, RO, 
PT, LV, IT 

LU, HR, BE, LT, 
CZ,  ES,  PL,  MT, 
CY, RO, LV, IT 

 
 
 
 
Q.2.28  If  “YES”  to  Q.2.25,  since  implementing  it,  how  has  it  impacted  the  efficiency  and 
effectiveness of your anti-fraud efforts? 

Response 

Frequency 

Percentage 

Member States 

Moderately improved 

No significant change 

No evaluation was conducted 

Significantly improved 

8 

6 

5 

3 

29.6% 

22.2% 

18.5% 

BE,  AT,  CZ,  ES, 
SK, MT, RO, PT 

LU,  SI,  HU,  PL, 
EE, LV 

IE,  HR,  FR,  LT, 
BG 

11.1% 

EL, CY, IT 

Q.2.29 If “YES” to Q.2.25, what specific functionalities of Arachne have proven most effective 
in your state’s fight against fraud? 

Response 

Frequency 

Percentage 

Member States 

Risk scoring and profiling 

15 

55.6% 

Pattern detection through data mining 

9 

33.3% 

Reporting and analytics for supporting investigations 

5 

Not applicable 

Other (please specify) 

Automated alerts for irregular activities 

4 

4 

3 

18.5% 

14.8% 

14.8% 

11.1% 

HR, EL, BE, AT, 
SI,  CZ,  HU,  SK, 
BG,  MT,  CY, 
RO, PT, LV, IT 

HR,  SI,  CZ,  SK, 
BG, CY, RO, PT, 
IT 

LU,  CZ, ES,  CY, 
RO 

IE, FR, LT, EE 

EL, CZ, PL, MT 

HR, BG, RO 

Following Q.2.29, please specify "Other ". 

Member 
State 

Response 

EL 

CZ 

Recovery and Resilience Facility Coordination Agency (RRFA): The tool is used for the  ex-ante 
control of absence of conflict of interest in public procurement and loan contracts. 

Inspection of projects (entities); searching for companies with a  link to owners and managers, as 
well  as  searching  and  sorting  by  project;  identifying  ownership  structure  using  ORBIS  data; 

 
 
 
 
Member 
State 

Response 

establishing  links  between  high-risk  entities;  checking  links  between  stakeholders,  as  a  tool  for 
fraud prevention and detection. 

PL 

Access to data from other Member States provided by institutions based abroad. 

MT 

With reference to Q2.28, it is to be noted that, to date, the potential benefits ensuing from Arachne 
are still not being exploited to the full. Once Arachne will be made use of to the full depending on 
Malta’s exigencies,  the efficiency and effectiveness of our anti-fraud efforts will be expected to 
improve significantly. 

Q.2.30 If “YES” to Q.2.25, are there procedures in place to address risk alerts generated by the 
Arachne system? 

Response 

Frequency 

Percentage 

Member States 

YES 

NO 

Not applicable 

18 

66.7% 

LU, HR, FR, EL, 
BE,  AT,  SI,  CZ, 
HU, SK, PL, BG, 
MT, CY, RO, PT, 
LV, IT 

3 

1 

11.1% 

IE, ES, EE 

3.7% 

LT 

Q.2.31  If  “YES”  to  Q.2.25,  does  your  system  have  dedicated  resources  or  a  task  force  for 
handling the outputs and alerts generated by Arachne? 

Response 

Frequency 

Percentage 

Member States 

YES 

NO 

In planning 

Not applicable 

11 

40.7% 

5 

3 

3 

18.5% 

11.1% 

11.1% 

LU,  EL,  BE,  CZ, 
ES,  SK,  PL,  MT, 
CY, LV, IT 

IE,  HR,  LT,  HU, 
PT 

BG, EE, RO 

FR, AT, SI 

 
 
 
 
 
Q.2.32 Please feel free to share any additional thoughts or experiences you have regarding the 
topics discussed in this section. 

Member 
State 

Response 

HR 

NL 

FR 

EL 

BE 

The Audit Authority would appreciate to receive more training and on-the-job practical experience. 

N/a, as mentioned the planning is to use New Arachne 

Since 2023, the MICAF (France’s AFCOS) has had a unit monitoring fraud involving funding for 
government aid. The unit is tasked, with the support of the investigative, administrative and judicial 
bodies and the judicial authorities concerned, with mapping aid mechanisms, helping in evaluating 
their  vulnerabilities,  sharing  best  practices,  supporting  the  rollout  of  filters  and  blocking 
mechanisms before government aid is paid unduly, alerting the ministries involved of the risks and 
of identified fraudulent ventures, enabling the same ministries to analyse them and putting into place 
the necessary synergy for a collective response to fraud by those ministries. 

In  specific  question  fields  (e.g.  QUESTION  2.9)  further  clarification  could  be  given  for  the 
concepts/definitions  listed  in  the  questions  (e.g.  the  concept/definition  of  ‘Data  Analysis  tools 
(external)’). This concept/definition covers several fields and there is a risk that the Member States 
might give a response concerning only one of those fields. 

At  this  stage,  the  fact  that  it  is  necessary  to  have  XML  data  export  tools  that  can  be  read  by 
ARACHNE and that no web is service available. 

AT 

No information. 

CZ 

of 

of 

for 

the 

due 

and 

legal 

three 

types 

every 

every 

month 

context 

updated 

analysis 

different 

important 

(1) The current Arachne system has the following limitations: 
No  possibility  to  search  in  Arachne  retrospectively  back  to  a  selected  date  in  history  –  This 
functionality would allow the analysis of ownership structures in specific historical periods, which 
diligence. 
of 
is 
Update frequency of Arachne –updating every 3-4 months is not often enough. External data should 
be 
months.  
instead 
Flagging-up  in  ARACHNE  of  persons/companies  in  breach  of  sanctions,  including  displaying 
individual shareholders’ shares – This element is necessary to ensure compliance and protect against 
risks associated with subsidising entities on sanctions lists, for example the Russian sanction lists 
in 
Ukraine. 
the 
The  absence  of  the  above  elements  means  that  Member  States  are  forced  to  use  alternative 
instruments, which in turn leads to inefficient spending of additional funds. 
2) The usefulness of Arachne is significantly affected by the quantity of input data in it and how up 
to date it is. Ensuring data transfers from national systems to Arachne is very demanding technically, 
financially and in terms of human resources.  In order to improve the quality of the data contained 
in it and thereby make the system more useful, the entities providing the data would need to be 
provided with rather extensive support by the Arachne system administrator in all three areas. 
3)  One  of  the  issues  currently  being  addressed  by  all  Member  States  is  how  to  set  up a  control 
system for sanctioned entities. This is a complex area where the main problem is that managing 
authorities, such as grant providers or contracting entities, do not have sufficient and appropriate 
sources of information for high-quality assessment of individual entities. For example, they do not 
have access to beneficial ownership registers in all Member States, let alone non-EU countries. Or, 
if they want to obtain access, it is expensive, which is certainly not an efficient use of money. The 
Arachne  tool  contains  unique  information  and  could  be  a  leader  and  innovator  in  this  field, 

aggression 

in 

 
 
 
 
 
Member 
State 

Response 

providing  those  entities  with  information  that  they  can  use  in  their  screening  and  monitoring. 
Arachne is linked to the Register of Beneficial Owners of the Czech Republic and, we assume, of 
other Member States too. This, in conjunction with the Orbis and World-check databases and other 
information contained in Arachne, could provide a basis for such verification. We believe it would 
be appropriate and possible for this functionality to be added, including the use of this information 
to identify further links and control pursuant to Articles 5 l and 5k of Regulation 833/2014. Given 
the  plans  to  make  further  and  more  intensive  use  of  Arachne,  this  could  be  another  reason  to 
convince all Member States of the appropriateness and usefulness of the tool. 

ES 

Compatibility of management applications with the tool and preparation of files for the tool's feed 
is a major challenge for paying agencies. Working groups are being set up with paying agencies in 
other Member States to identify the most useful risk indicators for each population. 

1. Making bulk exports more flexible in the framework of ARACHNE reports would improve the 
effectiveness of work to protect the EU’s financial interests.  
2. From a quality assurance point of view, the monitoring of users’ activities on the ‘Admin’ page 
of the User Management Module is justified. 
3.For compliance with the GDPR, it is important that individuals’ data is automatically concealed 
when screenshots are taken.  
4. We need to speed up the creation of conditions for automatic data links between ARACHNE and 
Member States’ monitoring systems (e.g. FAIR in Hungary). 
5. Detailed and practical information is needed on the intended successor to ARACHNE after 2028.

6.  The  ARACHNE  search  system  needs  to  be  improved  upon,  as  it  is  difficult  to  find  data  and 
organisations.  This  has  a  negative  effect  on  the  practical  application  of  ARACHNE  and  thus 
threatens the protection of financial interests (e.g. a person entitled to use a program is not able to 
see alerts based on data uploaded to another programme). 
7. In the case of false alerts (red flags), the user is unable to indicate the low risk of the alert (e.g. 
several companies on one site may be standard procedure in a single office building). 
8. The ARACHNE interface displays indicators in several locations, but there are a number of cases 
where it is not possible to access the details on the basis of which a given indicator takes its values. 

The Central coordinating body issued the Manual for Arachne version 1.0 for the program period 
2021-2027.  After  several  meetings  with  intermediary  bodies,  the  public  procurement  office,  the 
Audit  authority,  we  came  to  conclusions  which  should  make  work  with  the  Arachne  tool  more 
efficient and also reflect changes, which entails a new analysis of public procurement risks.  Outputs 
and alerts are to be handled by the line ministries in RRF. 

HU 

SK 

PL 

None 

The Baden-Württemberg ERDF Managing Authority: ARACHNE is not currently used because:

DE 

1. it is disproportionate under German privacy and data protection law since it encroaches on the 
rights of beneficiaries and their contractual partners;  
2. it appears to be of little use since it is not able to make nuanced statements about beneficiaries, 
their legal and procedural compliance, and their social and business relationships; and   
3. it is unlawful since no authorisation for this kind of data collection and analysis is currently in 
place. 

 
 
 
 
 
 
 
 
 
 
 
 
Member 
State 

Response 

MT 

While  on-line  video  tutorials  on  Arachne  Academy  are  very  useful,  Malta recommends that  the 
Arachne User Manual be more user-friendly.  
Malta does actually tackle the risks ensuing from searches on Arachne. To cite an example already 
described in answer to question Q.2.24, a high ‘reputational and fraud risk’ would feature a red flag 
of potential conflict of interest in relation to the entity in question, and this is acted upon. Thus, the 
fact that there are no formal procedures to address risk alerts generated by the Arachne system, this 
does  not  imply  that  Malta  is  not  utilizing  the  IT  Tool’s  outputs  effectively  as,  in  actual  fact, 
emerging  risks  are  tackled.  Moreover,  plans  are  underway  to  allocate  dedicated  resources 
specifically  tasked  with  handling  Arachne's  outputs  and  alerts.  This  proactive  approach 
demonstrates that Malta is committed to leveraging Arachne's capabilities and reflects its dedication 
to improving risk management and ensuring compliance with EU funding standards.  

CY 

Arachne is a good tool however a lot more additional work is required in order to further investigate 
the flags identified in Arachne and corroborate the reality of the flags through other information and 
databases. Frequently flags raised are not corroborated. 

Our ARIB has some slides to introduce their experience. 

EE 

 
 
 
 
 
 
Member 
State 

Response 

PT 

DK 

There is a need to integrate ARACHNE data with the application systems, so, as with the services 
for the interoperability of data reporting, there should be services for providing ARACHNE data 
that can be integrated into our systems. 

The Danish Business Authority: Uncertainty about the interoperability between the current Arachne 
and the new one under development is not demanding for a decision to start using Arachne. 

Q.3.1 Have there been any changes in your anti-fraud governance structures in place in 2024? 

Response 

Frequency 

Percentage 

Member States 

NO, no changes to the existing anti-fraud governance 
structure were introduced 

20 

YES, we modified the existing anti-fraud governance 
structure 

NO, we do not have an existing anti-fraud governance 
structure 

6 

1 

74.1% 

22.2% 

IE,  HR,  SE,  FR, 
EL,  BE,  AT,  FI, 
LT,  SI,  CZ,  HU, 
SK, PL, BG, MT, 
EE, RO, PT, DK 

LU, NL, ES, CY, 
LV, IT 

3.7% 

DE 

 
 
 
 
 
Q.3.2 If “YES, we set up an anti-fraud governance structure” or “YES, we modified the existing 
anti-fraud governance structure” to Q.3.1, what are the key changes implemented? 

Member 
State 

Response 

LU 

NL 

ES 

CY 

LV 

IT 

Analysis and Update of the anti-fraud system. 

New Coordination of anti-fraud is set up and placed with AFCOS 

The Statute of the Independent Authority for the Protection of Whistleblowers has been approved, 
a state authority whose purpose is to guarantee the protection of the whistleblower, to serve as an 
institutional pillar in the prevention and fight against fraud and corruption, and to guarantee  the 
integrity of the administrations and personnel in the service of the public sector.  
Two similar Independent Whistleblower Protection Authorities have also been created at regional 
level.   One post has been created for an Economic Crimes Chamber Prosecutor and one post for a 
Public Administration Crimes Chamber Prosecutor, specialising mainly in the fight against public 
and private corruption, organised crime and gender-based violence.    
At internal level, some entities have developed anti-fraud structures. For example, The Civil Guard 
Sustainability Plan 2021-2025 is currently in force. This Plan contemplates five Projection Axes, 
the  first  of  which  is  Governance.  It  contains  the  following  commitments,  each  of  them 
contemplating two differentiated areas of action:  

- 
Institutional Governance (two areas both related to Regulatory Footprint).  
-  Human Rights (internal training and awareness-raising; external promotion)  
- 
-  Transparency (Management, Public Tendering)  
- 

Sustainable Innovation (Green Procurement; Innovation, Innovation)  

Fight against Corruption (Code of Ethics; Corruption prevention)  

The Ministry of Interior in its competence as the managing authority for Home Funds has been 
added in the anti-fraud governance structure. 

New NAFS is approved. Managing Authority of the Social Climate Fund is newly included in our 
anti-fraud governance structures in 2024. 

The  Committee  for  Combatting  Fraud  against  the  European  Union  (COLAF)  is  the  government 
‘tool’ charged with drawing up and developing the national strategy for fighting irregularities and 
fraud against the European Union budget and for ensuring cooperation and coordination between 
all of the national administrations with roles of various types in this area, and also between those 
administrations and the competent Commission departments. COLAF has been designated as the 
‘Anti-fraud coordination service’ (AFCOS) pursuant to Article 12a of Regulation (EU, Euratom) 
No 883/2013  and  is  thus  responsible  for  facilitating  cooperation  and  information  exchange  with 
OLAF, including of an operational nature, and for drawing up the national anti-fraud strategy. 
In 2024, Article 3 of Decree-Law No 19 of 2 March 2024 converted into law, with amendments, by 
Law No 56 of 29 April 2024 broadened COLAF’s remit in line with needs linked to implementation 
of the NRRP. Specifically: 

- 

- 

paragraph 1 extended COLAF’s functions under Article 3(1) of Presidential Decree No 91 
of  14 May  2007  to  combat  fraud  against  the  European  Union  within  the  meaning  of 
Article 54(1) of Law No 234 of 24 December 2012 so that they now cover the NRRP too, 
the aim being to strengthen the overarching strategy of activities to prevent and combat 
fraud and other offences affecting NRRP funding, the cohesion policy for the 2021-2027 
programming period and national funds linked with those funds in any way; 
in accordance with paragraph 2, and without prejudice to Articles 6 and 7 of Decree-Law 
No 77/2021  converted  into  law,  with  amendments,  by  Law  No 108/2021,  for  the 

 
 
 
 
 
 
Member 
State 

Response 

• 

• 

• 

the  aforementioned  Decree-Law  No 77/2021  and  monitor 

aforementioned functions COLAF is required, in particular, to: 
request information on the steps taken by institutions, agencies and bodies to prevent and 
combat the fraud and other offences referred to in paragraph 1;  
encourage  the  signing  of  memorandums  of  understanding  within  the  meaning  of 
Article 7(8)  of 
their 
implementation;  
assess the appropriateness, including on the basis of the activity referred to in the first point 
of  drafting proposals,  including  legislative  proposals,  to  be  submitted  to  the  competent 
administrations or the steering committee referred to in Article 2 of the aforementioned 
Decree-Law No 77/2021. 
develop analysis activities, including in light of the trend in the results of action to prevent 
and 
offences. 
For these purposes, paragraph 3 of the aforementioned Decree-Law extended COLAF’s 
membership following the assignment of the new tasks under the provision in question.  

combat 

fraud 

other 

and 

More  specifically,  pursuant  to  Article 3(2)  of  Presidential  Decree  No 91/2007,  the  Committee  is 
composed of: 

- 
- 

- 
- 

the Head of the Department for European Affairs at the Prime Minister’s Office; 
the Commander of the Guardia di Finanza Unit for Combatting Fraud against the European 
Union, as mentioned in the next section; 
the directors-general of the offices of the Department for European Affairs; 
the directors-generals designated by the administrations involved in the fight against tax 
and  agricultural  fraud  and  in  the  correct  use  of  EU  funds,  who  are  nominated  by  the 
Minister for European Affairs, Southern Italy, Cohesion Policy and the NRRP; 

-  members designated by the Joint Conference referred to in Article 8 of Legislative Decree 

No 281 of 28 August 1997.  

Pursuant to Article 3(3) of Decree-Law No 19/2024, and in order to achieve the aims laid down in 
paragraphs 1 and 2 of that article, COLAF’s membership has been supplemented with: 

- 

- 

as  ‘ex  officio  members’,  the  coordinator  of  the  NRRP  Unit  referred  to  in  Article 2  of 
Decree‑Law No 13/2023 converted into law, with amendments, by Law No 41/2023, the 
Head of the Department for Cohesion Policy and Southern Italy at the Prime Minister’s 
Office,  the  coordinator  of  the  Special  Economic  Zones  (SEZ)  Unit  referred  to  in 
Article 10(2) of Decree‑Law No 124/2023 converted into law, with amendments, by Law 
No 162/2023, the Chair of the Network of NRRP Anti-Fraud Contact Persons established 
at  the  State  General  Accounting  Department  at  the  Ministry  of  Economic  Affairs  and 
Finance and the Chair of the Coordination Committee established at the Ministry of the 
Interior pursuant to Article 39(9) of the Public Procurement Code laid down in Legislative 
Decree No 36 of 31 March 2023; 
as  ‘designated  members’,  one  representative  each  of  the  General  Headquarters  of  the 
Carabinieri, the General Headquarters of the Guardia di Finanza, the Guardia di Finanza’s 
Special Unit for Public Expenditure and Combatting Fraud against the European Union, 
the  Italian  Court  of  Auditors,  the  National  Anti-Corruption  Authority,  the  Financial 
Intelligence  Unit  at  the  Bank  of  Italy,  the  National  Anti-Mafia  and  Anti-Terrorism 
Directorate,  and  the  Central  Criminal  Police  Directorate  and  Anti-Mafia  Investigation 
Directorate at the Ministry of the Interior.   

The  performance  of  the  tasks  assigned  to  COLAF  is  facilitated  by  the  presence,  within  the 
Department for European Affairs at the Prime Minister’s Office, of the Guardia di Finanza Unit for 
Combatting  Fraud  against  the  European  Union,  established  by  the  Prime  Ministerial  Decree  of 
11 January 1995, as COLAF’s Technical Secretariat. The functions of that unit were laid down by 
Article 3(2)  and  (4)  of  Presidential  Decree  No 91/2007  and  Article 54(2)  of  Law No 234  of 
24 December  2012  and  recently  updated  and  better  defined  by  Article 10  of  the  Decree  of  the 
Minister for European Affairs, Southern Italy, Cohesion Policy and the NRRP of 23 November 2023.

 
 
 
 
 
Member 
State 

Response 

More specifically, in accordance with the latter provision, the Guardia di Finanza Unit that acts as 
technical secretariat for COLAF: 

- 

- 

- 

- 

reports to the Head of Department, performs advisory and guidance functions to coordinate 
the activities to fight against fraud and irregularities concerning, in particular, tax and the 
CAP  and  structural  funds,  and  carries  out  the  associated  activities  to  share  information 
with the European Commission; 
in the areas within its remit, follows the work of EU bodies, in particular the Advisory 
Committee for the Coordination of Fraud Prevention (COCOLAF) and the Working Party 
on Combating Fraud (GAF), and oversees the adoption of the national position to be taken 
in those forums; 
helps  COLAF  to  perform  all  the  tasks  assigned  to  it,  to  implement  the  decisions  taken 
during its deliberations and to carry out the initiatives decided upon;  
in relation to COLAF’s designation as the ‘Anti-fraud coordination service’ pursuant to 
Article 12a  of  Regulation  (EU,  Euratom)  No 883/2013,  it  is  responsible  for  facilitating 
cooperation and information exchange with OLAF, including of an operational nature, and 
for drawing up the national anti-fraud strategy;  

- 

- 

-  manages  the  flow  of  communications  concerning  irregularity  and  fraud  cases  affecting 
European funds via the Irregularity Management System (IMS), ensuring interconnection 
with  OLAF,  the  competent  national  central  authorities  and  the  managing  authorities, 
including  so  as  to  resolve  any  technical  problems  that  arise  and  ensure  harmonised 
procedures;  
analyses the data from the IMS, including for the purposes of general fraud risk assessment 
at national level and to make a comparison with how the fight against irregularity and fraud 
is developing at European level;  
gathers information and data from the national administrations involved in fighting fraud 
against  the  EU  and  then  answering  the  ‘Questionnaires’  to  be  sent  to  the  European 
the  Commission’s 
the  basis  of  Article 325  TFEU,  following 
Commission  on 
Recommendations and the guidance from other EU institutions on protecting the financial 
interests of the Union; in partnership with other national and foreign institutions, and also 
as part of projects financed by the EU, participates in training and study initiatives aimed 
at improving the fight against fraud, and ensures that correct information is provided on 
the actions taken by the EU and national institutions to protect the financial interests of the 
Union. 

Q.3.3 If “YES, we set up an anti-fraud governance structure” or “YES, we modified the existing 
anti-fraud governance structure” to Q.3.1, Which authorities have you newly included in your 
anti-fraud governance structures in 2024? 

Response 

Frequency 

Percentage 

Member States 

EU fund managing authority 

Other (please specify) 

Judicial authority 

Dedicated agency fighting against conflict of interest 

Dedicated agency fighting against organized crime 

Dedicated anti-corruption agency 

3 

3 

2 

1 

1 

1 

11.1% 

11.1% 

7.4% 

3.7% 

3.7% 

3.7% 

CY, LV, IT 

LU, NL, ES 

ES, IT 

IT 

IT 

IT 

 
 
 
 
Response 

Frequency 

Percentage 

Member States 

Law enforcement authority 

National audit authority 

Public procurement authority 

Tax administration authority 

1 

1 

1 

1 

3.7% 

3.7% 

3.7% 

3.7% 

IT 

IT 

IT 

IT 

Following Q.3.3, please specify "Other". 

Member 
State 

Response 

LU 

Anti-fraud officer 

NL 

AFCOS  is  part  off  Customs  and  already  responsible  for  revenue.  New  responsible  will  be  the 
coordination of antifraud for expenditure 

ES 

Independent Authorities for the Protection of Whistleblower 

Q.3.4  Please  rate  the  effectiveness  of  the  statements  below.:  Your  anti-fraud  governance 
structure facilitates knowledge exchange and good practices to fight fraud. 

Response 

Frequency 

Percentage 

Member States 

Effective 

17 

63.0% 

IE,  LU,  HR,  SE, 
EL,  BE,  AT,  FI, 
LT,  SI,  CZ,  ES, 
SK,  DE, BG, PT, 
DK 

FR, HU, PL, MT, 
RO, LV, IT 

Highly effective 

Mildly effective 

7 

3 

25.9% 

11.1% 

NL, CY, EE 

Q.3.4  Please  rate  the  effectiveness  of  the  statements  below.:  Your  anti-fraud  governance 
structure is the ideal forum to elaborate a comprehensive risk assessment to support anti-fraud 
effort 

Response 

Effective 

Frequency 

Percentage 

Member States 

13 

48.1% 

LU, EL, BE, AT, 
LT,  SI,  HU,  SK, 
DE, BG, PT, LV, 
DK 

 
 
 
 
 
Response 

Mildly effective 

Highly effective 

Neutral 

Frequency 

Percentage 

Member States 

6 

5 

3 

22.2% 

18.5% 

HR, SE, NL,  CZ, 
ES, CY 

FR, PL, MT, RO, 
IT 

11.1% 

IE, FI, EE 

Q.3.4  Please  rate  the  effectiveness  of  the  statements  below.:  Your  anti-fraud  governance 
structure provides a comprehensive understanding of anti-fraud issues. 

Frequency 

Percentage 

Member States 

Response 

Effective 

Highly effective 

Mildly effective 

Neutral 

16 

59.3% 

IE,  LU,  BE,  AT, 
LT, CZ, HU, SK, 
DE, BG, MT, CY, 
EE, PT, LV, DK 

FR,  EL,  SI,  PL, 
RO, IT 

6 

4 

1 

22.2% 

14.8% 

HR, SE, NL, ES 

3.7% 

FI 

Q.3.4  Please  rate  the  effectiveness  of  the  statements  below.:  Your  anti-fraud  governance 
structure contributes to the development / update of anti-fraud policies/strategies at the national 
level. 

Response 

Effective 

Highly effective 

Mildly effective 

Neutral 

Not applicable 

Frequency 

Percentage 

Member States 

15 

55.6% 

5 

3 

3 

1 

18.5% 

11.1% 

11.1% 

3.7% 

LU, EL, BE, AT, 
FI,  LT,  SI,  ES, 
HU, SK, PL, DE, 
BG, CY, DK 

FR, MT, RO, LV, 
IT 

HR, CZ, PT 

IE, NL, EE 

SE 

 
 
 
 
 
Q.3.4  Please  rate  the  effectiveness  of  the  statements  below.:  Your  anti-fraud  governance 
structure responds quickly to new threats in the anti-fraud environment. 

Response 

Frequency 

Percentage 

Member States 

Effective 

18 

66.7% 

Highly effective 

Mildly effective 

Neutral 

3 

3 

3 

11.1% 

11.1% 

11.1% 

IE,  LU,  EL,  BE, 
AT,  FI,  LT,  SI, 
CZ, ES, HU, DE, 
BG, MT, EE, RO, 
LV, DK 

FR, PL, IT 

HR, SK, PT 

SE, NL, CY 

Q.3.4  Please  rate  the  effectiveness  of  the  statements  below.:  Your  anti-fraud  governance 
structure contributes to drafting anti-fraud legislation. 

Response 

Effective 

Highly effective 

Mildly effective 

Neutral 

Not applicable 

Frequency 

Percentage 

Member States 

13 

48.1% 

5 

4 

3 

2 

18.5% 

14.8% 

11.1% 

7.4% 

EL,  FI,  LT,  SI, 
CZ, ES,  HU,  SK, 
PL, DE, BG, CY, 
PT 

FR, MT, RO, LV, 
IT 

HR, SE, NL, EE 

IE, LU, BE 

AT, DK 

Q.3.4  Please  rate  the  effectiveness  of  the  statements  below.:  Your  anti-fraud  governance 
structure contributes to the development and implementation of training to staff on anti-fraud. 

Response 

Effective 

Highly effective 

Mildly effective 

Frequency 

Percentage 

Member States 

10 

37.0% 

EL,  BE,  FI,  LT, 
SI,  CZ,  SK,  DE, 
CY, EE 

FR,  ES,  HU,  PL, 
MT, RO, PT, LV, 
IT 

33.3% 

9 

3 

11.1% 

HR, SE, NL 

 
 
 
 
Response 

Neutral 

Not applicable 

Frequency 

Percentage 

Member States 

3 

2 

11.1% 

IE, LU, BG 

7.4% 

AT, DK 

 
 
 
 
 
Polarplot of the Average Level of Self-Reported Governance Effectiveness in Anti-Fraud Efforts Across All 
Member States 

Q.3.5  Could  you  describe  any  best  practices  or  innovative  methods  that  your  anti-fraud 
governance structures have implemented to enhance effectiveness and collaboration? 

Member 
State 

Response 

IE 

LU 

HR 

n/a 

Not applicable. 

Contribution from Agency for the Audit of European Union Programmes Implementation System 
(ARPA):  
It was the development of National irregularity management guidelines with all relevant annexes 
and  appendices.  The  MCS  structures  need  such  document  as  a  kind  of  “cookbook”  with 
descriptions, processes, steps, etc. 

Contribution from Ministry of Finance, Customs Administration:  
Greater use of customs mutual administrative assistance framework (for example strengthening of 

 
 
 
 
 
  
 
Member 
State 

Response 

cooperation 

with 

neighbouring 

third 

countries).  

Contribution  from  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  for  Support  in 
Agriculture and Rural Development:  
From the point of view of the managing authority (Ministry of Agriculture, Forestry and Fisheries), 
we can say that we are constantly working to improve the exchange of information with the Paying 
agency,  which  is  the  implementing  body  in  the  system  of  management  and  controls  of  EU 
agricultural funds.  

Cooperation between the SEFI Council and the various working groups under the SEFI Council 
enhances collaboration and knowledge sharing in anti-fraud work. A vibrant dialogue within the 
organisation but  also  with other  organisations  to raise  awareness  of  the  issues.  Cooperation  and 
exchange of information and knowledge between authorities. Exchange of staff between authorities. 
Targeted  tailor-made  training  requested  by  individual  authorities  is  provided  through  the  SEFI 
Council and the Swedish Economic Crime Authority upon request. 

NAFS is being prepared (concept). Organising network meetings with management authorities and 
different other parties involved with the expenditure like national audit agency in order to establish 
a better cooperation. 

At  national  level,  the  MICAF,  in  partnership  with  the  lead  managing  directorates,  oversees 
attentively 10 national anti-fraud operating groups (Groupes opérationnels nationaux anti-fraude - 
GONAF). The task of these GONAF is to break down barriers by sharing information and analysis, 
mapping  risks  jointly,  and  developing  action  strategies  and  coordinated  investigations.  This 
includes,  inter  alia,  identifying  and  combating  complex,  organised  fraud  more  effectively  by 
promoting better coordination of administrative and judicial action. 

Recovery  and  Resilience  Facility  Coordination  Agency  (RRFA):  The  anti-fraud  cooperation 
network for projects which are implemented using funding from the Recovery and Resilience Fund, 
which is made up of the competent ministries, large implementing bodies for NRRP actions/projects 
and the NRRP Coordination Service. The Greek Anti-Fraud Coordination Service (NTA/AFCOS) 
and the Control Authority of the Recovery and Resilience Facility may participate in the network. 
The Independent Anti-Fraud Coordination Service of the National Transparency Authority (NTA) 
has  organised  an  online  communication  platform  between  competent  national  bodies  where 
accredited  users  can  exchange  information, be  informed  and  participate  in  discussion  forums  to 
resolve issues. 

ERDF, JTF and RRF at the SPW: For the  SPW, a  robust anti-fraud culture, a regularly updated 
management  and  control  system,  the  establishment  of  procedures,  the  transposition  of  the 
Whistleblowing Directive through the appointment of contact persons for integrity in 2024, and the 
drafting of a full training programme that is to be implemented in 2025. 

SE 

NL 

FR 

EL 

BE 

AT 

No information. 

FI 

At the request of the administrative authority, the intermediate bodies for the EU’s regional and 
structural policy programme have nominated their contact persons for fraud prevention. The persons 
in question constitute a network which is used for the sharing of up-to-date information and the 
dissemination of good practices. Similar practices are also employed in other EU programmes. 

 
 
  
 
Member 
State 

Response 

LT 

- 

The  Ministry  of  Cohesion  and  Regional  Development  (MKRR),  in  its  role  as  MA  for  the 
implementation of the European cohesion policy programme, has concluded an agreement with the 
Agency of the Republic of Slovenia for agricultural markets and rural development [ARSKTRP] – 
the manager of the European Agricultural Fund – on cooperation between the two bodies in order 
to prevent double funding from public sources. The two bodies agreed/committed to exchange data 
about beneficiaries, public invitations to tender, etc. with a view to preventing double funding from 
the  two  different  EU  funds,  to  keep  each  other  informed  of  any  matches  and  to  carry  out  an 
additional review where there is a risk of double funding 

Start  of  work  on  using  ARACHNE  data  for  analytical  activities.  The  Directorate-General  for 
Finance understands that the data contained in IS ReD are a valuable source of information that will 
allow the identification of key trends, patterns, and risk profiles in conjunction with ARACHNE. 
These analyses serve as an important tool for planning, allocation of funds and control activities of 
other government bodies. The Working Group on the Publication of Subsidy Data, which includes 
representatives from the Ministry of Finance and the Directorate-General for Finance, was launched 
in April 2024. The Working Group is to define the requirements for the integration of archived data 
from ReD and to coordinate the activities of the IISSP (integrated State treasury information system) 
process  teams  related  to  the  preparation  and  subsequent  implementation  of  the  publication  of 
subsidy data in the Monitor, i.e. to ensure coordination of the data collection activities necessary 
for the publication of the subsidy data and the activities of the Ministry of Finance and the Financial 
Administration related to the provision of the data necessary to ensure the Directorate-General for 
Finance’s  own  internal  processes  (e.g.  ensuring  analytical  search  and  control  processes  for 
subsidies).  Work  has  started  on  amending  the  legislation,  in  particular  amendments  to  Act  No 
218/2000 on budgetary rules. At the same  time, we have automated the transfer of State budget 
subsidy and grant data from the RISPF (computerised information system for programme financing) 
to the Management Information System, which is part of the  IISSP and where the requirements for 
publishing  such  data  on  the  open-access  Monitor  website  (Monitor  –  Information  Portal  of  the 
Ministry of Finance) are now being defined. 
Improving  synergies  with  law  enforcement  and  judicial  authorities.  Improving  the  satellite 
monitoring system for agricultural land. 
A proven approach is to provide staff with training on preventing corruption and fraud as soon as 
they take up their duties, introducing codes of ethics, and introducing checklists and the four-eyes 
control principle for all operations and payments. It is essential to apply precaution and continuous 
awareness of the risk of fraud at all stages in the implementation of the National Recovery  Plan. 
Project risk cards have been introduced as part of the internal sharing. 

Coordination  meetings  have  been  held  with  the  units,  as  well  as  working  groups  and  training 
courses. In addition, new manuals and protocols have been produced and disseminated. 

Cooperation between organisations involved in the fight against fraud is ensured both formally and 
through cooperation agreements with detailed arrangements. In addition, the Hungarian AFCOS 
organises a number of professional events per year to which anti-fraud actors are invited to present 
and disseminate a priority theme, and where workshops permit both exchanges of experience and 
peer-to-peer reflection. 

SI 

CZ 

ES 

HU 

 
 
 
 
Member 
State 

Response 

At the level of MA 2021-2027, the following measures were implemented in the recent past, which 
are also related to the issue of combating fraud. Internal control aimed at compliance with the duties 
of the employees of the Programme Slovakia Managing authority in connection with the conflict of 
interests. Establishment of working groups for fraud risk management for the Programme Slovakia, 
the Interreg Slovakia – Czech Republic and Interreg Slovakia – Austria Programs and the Recovery 
and Resilience Plan of the Slovak Republic (component 17). Adoption of the "Anti-Fraud Policy" 
of 
MIRRI 
Authorities involved in the implementation of EU funds use a unified IT monitoring system, which 
contains  detailed  information  about  the  given  cases.  Regular  communication  and  exchange  of 
information among all authorities (CA/PA, IB, AA, law enforcement authorities, etc.) Issue/update 
manuals  and  guidelines  on  the  protection  of  the  EU's  financial  interests.  Train  the  employees, 
strengthen  and  streamline  cooperation  among  AFCOS  partners  in  identifying  new  methods  of 
harming  the  EU's  financial  interests.  Provide  the  public  conditions  for  reporting  potential  fraud, 
which 
interests.  
Slovak RRF: PIF related training activities for employees of implementing bodies (line ministries) 
and NICA (National Implementation and Coordination Authority); round tables organised by NICA 
to discuss specific issues with the line ministries.  

financial 

protect 

helps 

EU´s 

also 

the 

to 

SR.   

The Institution Coordinating the Partnership Agreement organises annual conferences on the topic 
of checks and irregularities in the spending of structural funds and co-financing under the Cohesion 
Fund, which are attended by representatives of the institutions involved in the implementation of 
the Structural Funds and the Cohesion Fund, including national and regional managing authorities 
and selected intermediate bodies and audit authorities. The topic of each conference depends on the 
current themes that are important from the point of view of control and prevention of irregularities. 
In different years, representatives of the European Commission, the National Public Prosecutor’s 
Office or the Police also participated in those meetings. 
The  Institution  Coordinating  the  Partnership  Agreement  has  developed  and  made  available 
information and guidance materials on conflicts of interest in the form of YouTube podcasts. The 
materials are mainly aimed at the staff of the institutions that manage and control the spending of 
EU funds. The materials discuss key issues relating to conflicts of interest, including how to tackle 
conflicts of interest at the different stages of programme and project implementation.    
Regular anti-fraud training for staff is provided at the Paying Agency. A list of signs of fraud has 
been drawn up and it is kept up to date. Work is underway to adapt (extend) internal applications 
by adding new tools (e.g. Register of artificial conditions) that may be useful in the fight against 
fraud. 

The Bremen ERDF Managing Authority:    
•  Regular  jour  fixe  meetings  between  the  managing  authority  and  intermediate  bodies.  
• Staff awareness training. 

With the professional support and expertise of Department 08 within PORB, as a specialized unit 
in the structure of the Prosecutor’s Office in Bulgaria, four seminars for prosecutors, investigators, 
reporting and executive authorities and representatives of the EPPO office in Sofia, Bulgaria were 
organized and conducted. These specialized events were organized and funded by the America for 
Bulgaria Foundation as a part of a three-year "Supporting the Counteraction to Fraud and Organized 
project.  
Crime" 
Following the initiative of the Head of the 08 Department series of events and work meetings with 
representatives  of  the  reporting  and  responsible  institutions  and  authorities  aiming  better 

SK 

PL 

DE 

BG 

 
 
 
Member 
State 

Response 

cooperation and understanding of the specific requirements of matters in  the work of the judicial 
system were held throughout 2024.  
Prosecutors from the 08 Department actively take part in all international events and forums in the 
area,  participate  as  speakers/lecturers,  not  only  by  invitation  of  various  institutions  and 
organizations,  but  also  initiate  training  modules  for  magistrates  around  the  country,  support  the 
activities  of  working  groups  on  amendments  of  the  national  legislation  and  transposition  of 
European legislation, etc.  
Again, as an initiative of the 08 Department cooperation agreement on interaction and cooperation 
between  the  Prosecutor's  Office  of  the  Republic  of  Bulgaria  and  the  Ministry  of  Interior  in 
countering  offenses  affecting  the  financial  interests  of  the  European  Union  was  signed  on 
11.06.2024. 

MT 

The implementation of a Central Document Repository System (CDRS), in line with Action Points 
13 and 14 of the Maltese NAFCS, as well as Malta's RRP commitments. 

CY 

N/A 

EE 

RO 

training 

Our  network  collaborates  as  needed,  we  have  at  least  annual  regular  meeting,  and  we  organize 
specific 
skills.  
We have proposed to our national investigative bodies to analyse all grants data. This cooperation 
could  contribute  to  the  identification  of  the  potential  threats,  vulnerabilities  and  fraud. 
Complex fraud cases cannot be detected through administrative-level controls only. 

courses 

support 

share 

and 

our 

to 

Operationalisation  of  professional  anti-fraud  networks,  in  permanent  communication  with  each 
other,  in  the  following  areas:  policies  and  legislation,  vocational  training,  communication, 
investigations,  risk  analysis,  reporting  of  irregularities,  debt  recovery,  contributions  to  the  EU 
budget and European cooperation. 

PT 

Conclusion of protocols between the Funds’ coordinating bodies and the judicial authorities 

LV 

DK 

IT 

In  2024  we  implemented  "job  shadowing"  initiative,  where  employees  of  anti-fraud  governance 
structures could "shadow" jobs of employees from other institutions. For  example, employees of 
the law enforcement authorities could participate in the project on-the-spot checks carried out by 
the  EU  managing  authority,  gaining  better  understanding  about  project  implementation  and 
administration. 

The  members  of  the  Danish  AFCOS  meet  at  least  once  a  year  to  discuss  changes  to  existing 
practices, to share best practices and to facilitate a common understanding of the task.  

The members of the Danish AFCOS meet with representative from the European Court of Auditors 
at a yearly meeting facilitated by the Danish AFCOS. The Court of Auditors presents their annual 
report  concerning  the  previous  financial  year.  The  members  of  the  Danish  AFCOS  get  to  ask 
questions and gain a better understanding of contemporary topics.  

The Danish AFCOS regularly shares news, information and upcoming events with member of the 
AFCOS. 

With  regard  to  the  strengthening  of  anti-fraud governance,  the  Italian  AFCOS  ensures  ongoing, 
systematic interconnection between all the authorities and administrations responsible in various 
capacities  for  fighting  and  preventing  fraud,  including  through  targeted  consultations  aimed  at 

 
 
 
 
Member 
State 

Response 

determining the national position to be taken at interinstitutional and EU level and at disseminating 
new  guidelines  and  lines  of  action  for  the  fight  against  fraud,  risk  analysis  and  improving  the 
procedures for protecting the EU budget, including in relation to the NRRP. 

With  input  from  all  institutions  making  up  the  AFCOS,  two  documents  have  been  drafted 
concerning: 
a. ‘Measures to prevent and combat fraud and other offences against the NRRP’, which contains a 
full  survey  of  all  the  measures  in  place  to  prevent  and  combat  such  fraud,  including  measures 
introduced specifically for the NRRP and also general measures under national law that are directly 
effective as preventive safeguards in relation to the NRRP too; 
b.  the  ‘Main  risk  indicators  for  NRRP  fraud’,  which  gives  a  full  overview  of  the  ‘anomaly 
indicators’  developed  by  various  EU  and  national  institutions  to  guide  the  control  actions  for 
situations that need to be investigated. 

A  new  National  Anti-Fraud  Strategy  (NAFS)  has been  prepared  taking  on  board  guidelines  and 
proposals from all the institutions involved in protecting the financial interests of the EU. This is 
part of a broad process agreed upon collegially by the Committee that has also led to the production 
of an Action Plan for 2024-2027. There will be monitoring of the correct implementation of the 
profiles  within  the  remit  of  the  various  administrations,  and  of  the  guidance  and  targets  in  the 
aforementioned Action Plan, which gives a forward-looking view of the objectives that the various 
national authorities envisage achieving in the 2024-2027 reference period, specifying the indicators 
and  timescales  for  each  of  the  four  stages  of  the  ‘anti-fraud  cycle’:  prevention,  detection, 
investigation, recovery and penalties. 

Lastly, with regard to the new functions linked to implementation of the NRRP, and pursuant to 
Article 3 of Decree-Law No 19 of 2 March 2024, the AFCOS closely follows the steps taken by 
institutions,  agencies  and  bodies  to  prevent  and  combat  fraud  and  other offences  in  the specific 
sector  of  the  cohesion  policy  and  national  funds  linked  with  it  in  any  way,  monitors  the 
memorandums of understanding signed with the Guardia di Finanza by the central administrations 
responsible  for  NRRP  measures,  the  regions,  the  autonomous  provinces  of  Trento  and  Bolzano, 
local authorities and other public entities, assesses any proposals, including legislative proposals, 
to be submitted to the competent administrations or the NRRP Steering Committee at the Prime 
Minister’s Office and develops analysis activities, including in light of the trend in the results of 
action to prevent and combat fraud and other offences.  

Particular attention is also given to communication and training. In this connection, two projects 
have  been  developed  and  are  co-financed  by  the  European  Commission  as  part  of  the  Union 
Anti‑Fraud Programme: 

1) in cooperation with Luiss University in Rome, a European project called ‘Better Knowledge for 
Next Generations’ (BETKONEXT). 
This project involves a comparative law study and targeted training activities aimed at improving 
cooperation and coordination between academia and the Member States’ AFCOSs so as to achieve 
ever higher standards in the protection of the financial interests of the European Union. The project 
therefore has the specific objective of conducting a scientific research project aimed, in particular, 
at assessing the fitness for purpose of the existing regulatory tools and at perfecting multilateral and 
multi-level cooperation between institutions, academia and control bodies.  
Intense  international  cooperation  will  see  the  involvement of  national  institutions  (including  the 
National Anti-Corruption Authority, the Guardia di Finanza, the Financial Intelligence Unit at the 
Bank  of  Italy  and  the  Central  Criminal  Police  Directorate),  EU  institutions  (OLAF,  EPPO  and 

 
 
 
 
 
 
 
Member 
State 

Response 

Europol),  experts  from  universities  and  AFCOSs  in  the  EU  countries  involved  in  the  project 
(Belgium, Poland and Spain) and Italian and foreign students; 
2)  in  cooperation  with  Sapienza  University  of  Rome,  another  European  project  called  ‘Fraud 
Repression  through  Education’  (FRED 2).  Through  intense  cooperation  between  Italian  and 
European universities and the AFCOSs of the participating foreign countries (Belgium, Finland and 
Greece), the project objectives are to:  

- 

- 

- 

develop  an  experiential  co-lab-learning  course  with  the  participation  of  academics  and 
professionals so as to develop innovative, value-for-money approaches that will provide 
participants  with  better  know-how  for  determining  fraud  risks  and  comparing  control 
strategies in the fight against irregularities and fraud against the EU budget;  
create a European task force of academics and professionals that will develop a pilot study 
for analysing risk profiles for possible illegal behaviours or situations of improper use of 
EU funds;  
set up, in parallel, a permanent Anti-Fraud Observatory, intended to have a trans-national 
European  dimension  in  future,  that  will  allow  the  new  network  to  endure  through 
relationships  aimed  at  improving  awareness  of  fraud  and  other  illegal  activities  by 
strengthening trans-national and multidisciplinary cooperation. 

Lastly, in the area of training, it is important to stress the objective, set in the NAFS Action Plan, of 
ensuring that the culture of combatting fraud against EU funds  is also spread to national bodies 
responsible for checks in other sectors. 
In particular, a training activity was run for inspection staff of the National Labour Inspectorate 
(INL)  with  the  aim of  providing  them  with  the  necessary competencies  to  identify,  analyse  and 
assess the various types of irregularity/fraud affecting the agricultural policy, cohesion policy and 
NRRP and to identify the types of penalties that apply and the associated reports to be sent to the 
competent bodies. 

Q.3.6 Has there been any change regarding the staffing of your national  anti-fraud structure 
coordinating the anti-fraud governance (AFCOS) in 2024? 

Response 

Frequency 

Percentage 

Member States 

No change in staffing levels 

12 

44.4% 

Cannot assess / Not applicable 

Other (please specify) 

Same staffing levels, but more efficient 

Increased staffing with the necessary expertise 

Staffing levels decreased 

4 

4 

4 

2 

1 

14.8% 

14.8% 

14.8% 

7.4% 

3.7% 

SE,  FI,  LT,  SI, 
CZ,  ES,  SK,  DE, 
BG, EE, LV, DK 

IE, FR, AT, CY 

NL, BE, PL, MT 

LU, HU, RO, IT 

HR, PT 

EL 

 
 
 
 
 
 
Following Q.3.6, please specify "Other". 

Member 
State 

Response 

NL 

BE 

PL 

MT 

Setting up coordination antifraud for expenditure as part of AFCOS 

AFCOS 

Due to the number of institutions cooperating in the area of fight against fraud, it is not possible to 
provide reliable information on the changes in staffing levels at each of these institutions. 

Three new employees joined the Maltese AFCOS in 2024, who are currently gaining the necessary 
expertise. 

Q.3.7 What are the main challenges currently faced in enhancing the anti-fraud governance in 
your Member State? 

Response 

Frequency 

Percentage 

Member States 

Greater cooperation needed among existing entities 

21 

77.8% 

Need more expertise and skilled staff 

13 

48.1% 

More funding required 

12 

44.4% 

Legal or regulatory obstacles 

Other (please specify) 

7 

5 

25.9% 

18.5% 

LU, HR, SE, NL, 
FR,  EL,  LT,  SI, 
CZ,  ES,  SK,  PL, 
DE, BG, CY, EE, 
RO, PT, LV, DK, 
IT 

LU,  HR,  SE,  FI, 
SI,  ES,  HU,  SK, 
DE, BG, RO, PT, 
LV 

LU,  HR,  FI,  SI, 
CZ,  ES,  SK,  DE, 
BG, EE, RO, LV 

HR,  SE,  NL,  ES, 
DE, BG, RO 

IE,  BE,  AT,  MT, 
IT 

Following Q.3.7, please specify "Other". 

Member 
State 

Response 

IE 

BE 

There is no national anti-fraud strategy in place -- not a challenge just a statement. 

AFCOS 

 
 
 
 
Member 
State 

Response 

AT 

MT 

IT 

No information. 

No main challenges are currently being faced. 

It  would  be  appropriate  for  the  national  AFCOSs  to  be  fully  and  effectively  involved  in  the 
implementation of OLAF’s recommendations. The Guardia di Finanza Unit at the Prime Minister’s 
Office, as Technical Secretariat of COLAF, has asked OLAF for this on several occasions, and it 
was  specifically  envisaged  in  the  European  Commission’s  letter  ref. ARES (2013)3403880  of 
4 November 2013 providing guidance on the main tasks and responsibilities of an AFCOS.  
More  specifically,  as  envisaged  in  the  aforementioned  2013  ARES  letter,  when  OLAF 
recommendations are being implemented, the AFCOS should facilitate the exchange of information 
between the  national authorities involved, ensure the effective exchange of relevant information 
with OLAF, particularly as regards recovery of EU funds used improperly, and report to OLAF on 
the  actions  taken  following  the  information  sent  pursuant  to  Article 11,  paragraphs 1 et  seq.,  of 
Regulation (EU, Euratom) No 883/2013. 

Q.3.8 What type of support from the EU would you need to address the challenges identified 
in  improving  your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least 
important (1) to the most important (6).: Increased funding / financial assistance 

Response 

Frequency 

Percentage 

Member States 

5 

6 

3 

4 

Support not needed 

2 

8 

6 

5 

4 

3 

1 

29.6% 

22.2% 

18.5% 

14.8% 

11.1% 

3.7% 

HR, NL, FR, AT, 
SI, DE, CY, EE 

LU, BE, CZ, BG, 
RO, IT 

IE,  LT,  HU,  MT, 
PT 

ES, SK, PL, LV 

SE, EL, DK 

FI 

Q.3.8 What type of support from the EU would you need to address the challenges identified 
in  improving  your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least 
important (1) to the most important (6).: Training programs for staff 

Response 

6 

Frequency 

Percentage 

Member States 

13 

48.1% 

FR,  BE,  AT,  FI, 
SI,  ES,  SK,  DE, 

 
 
 
 
 
Response 

Frequency 

Percentage 

Member States 

4 

5 

3 

BG, RO, PT, DK, 
IT 

CZ, HU, MT, CY, 
EE 

SE,  NL,  EL,  LT, 
HR 

18.5% 

18.5% 

14.8% 

IE, LU, PL, LV 

5 

5 

4 

Q.3.8 What type of support from the EU would you need to address the challenges identified 
in  improving  your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least 
important  (1)  to  the  most  important  (6).:  Facilitated  cooperation  initiative  /  sharing  good 
practices among Member States 

Response 

Frequency 

Percentage 

Member States 

6 

4 

5 

3 

1 

10 

37.0% 

FR,  EL,  BE,  SI, 
HU, BG, RO, PT, 
DK, IT 

LU, HR, SE, NL, 
AT, ES, SK, DE 

LT, PL, MT, CY, 
EE 

29.6% 

18.5% 

11.1% 

IE, FI, CZ 

3.7% 

LV 

8 

5 

3 

1 

Q.3.8 What type of support from the EU would you need to address the challenges identified 
in  improving  your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least 
important  (1)  to  the  most  important  (6).:  Guidance  on  legal  or  regulatory  framework 
adjustments 

Response 

Frequency 

Percentage 

Member States 

4 

5 

6 

7 

6 

6 

25.9% 

22.2% 

22.2% 

LU, NL, PL, BG, 
CY, IT, HR 

EL,  FI,  SK,  DE, 
PT, LV 

SE,  BE,  AT,  ES, 
RO, DK 

 
 
 
 
Response 

Frequency 

Percentage 

Member States 

3 

2 

5 

3 

18.5% 

IE,  FR,  LT,  SI, 
HU 

11.1% 

CZ, MT, EE 

Q.3.8 What type of support from the EU would you need to address the challenges identified 
in  improving  your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least 
important (1) to the most important (6).: Technological support 

Response 

Frequency 

Percentage 

Member States 

5 

6 

3 

4 

2 

Support not needed 

7 

7 

5 

5 

2 

1 

25.9% 

25.9% 

18.5% 

18.5% 

7.4% 

3.7% 

NL,  EL,  SI,  CZ, 
SK, DE, BG 

FR,  BE,  AT,  ES, 
CY, RO, IT 

IE,  LU,  SE,  HU, 
MT 

FI,  LT,  EE,  PT, 
HR 

PL, LV 

DK 

Q.3.8 What type of support from the EU would you need to address the challenges identified 
in  improving  your  anti-fraud  governance?  Please  rank  the  following  proposition  from  least 
important (1) to the most important (6).: Other (please specify in the following question) 

Response 

Frequency 

Percentage 

Member States 

Support not needed 

21 

77.8% 

LU, HR, NL, FR, 
AT,  FI,  LT,  SI, 
CZ, ES,  HU,  SK, 
PL, DE, BG, MT, 
CY, RO, PT, LV, 
DK 

6 

2 

3 

5 

3 

1 

1 

1 

11.1% 

EL, BE, IT 

3.7% 

3.7% 

3.7% 

SE 

IE 

EE 

 
 
 
  
 
Bar plot of the Average Level of Support Requested for Anti-Fraud-Policy Across All Member States 

Q.3.9 If you selected “Other” to Q.3.8, please specify any other types of support you would 
need and its importance 

Member 
State 

Response 

IE 

SE 

EL 

BE 

EE 

IT 

hard to answer a Likert scale across a number of MA's 

It would be good to receive information and intelligence earlier, if the Commission detects, e.g., 
problems or suspected crimes in any area – rapid sharing 

The answers and detail given above cover the response to this question. 

ERDF,  JTF  and  RRF  at  the  SPW:  Fraud  is  often  international,  while  the  European  regulatory 
framework and the national or regional regulatory frameworks very often hinder access to the data 
required for the fight against fraud. A specific example is the collection and analysis of data on the 
beneficial owners of fund beneficiaries and their contractors. This data is easily available at national 
level but extremely difficult to obtain from outside the country. The European regulatory framework 
should allow direct access to this data whenever it is required by sector-specific regulations. The 
EU should collate the national data of its Member State and make this data available to the managing 
authorities rather than requiring them to have theoretical access via individual procedures that differ 
between the Member States. Such data could be integrated into ARACHNE, for example. 

pan-European 

Proper 
The same rules for all funds and simplification of rules. 

databases 

that 

can 

analyse 

data 

and 

identifying 

risks.  

As envisaged in the aforementioned 2013 ARES letter, when OLAF recommendations are being 
implemented,  the  AFCOS  should  facilitate  the  exchange  of  information  between  the  national 
authorities involved, ensure the effective exchange of relevant information with OLAF, particularly 

 
 
 
Member 
State 

Response 

as  regards  recovery  of  EU  funds  used  improperly,  and  report  to  OLAF  on  the  actions  taken 
following the information sent pursuant to Article 11(6) of Regulation (EU, Euratom) No 883/2013. 

Q.3.10 Please feel free to share any additional thoughts or experiences you have regarding the 
topics discussed in this section. 

Member 
State 

Response 

IE 

LU 

HR 

SE 

NL 

FR 

EL 

BE 

AT 

FI 

LT 

SI 

CZ 

ES 

HU 

n/a 

Not applicable. 

- 

The EU currently offers financial support for developing, e.g., anti-fraud tools: The dilemma is that 
the  administrative  burden  of  applying  for  and  receiving  such  aid  is  so  heavy  that  it  greatly 
discourages Swedish authorities from applying for such aid. 

N/A 

x 

There must be cooperation at both national and European level between all the competent authorities 
involved  in  order  to  effectively  address  fraud  linked  to  EU  funding.  This  is  the  basis  for  the 
development of any successful national strategy which, in combination with the ultimate integration 
of new technologies in all aspects of public administration, can play a very important role in meeting 
the new challenges of our digital era. 

/ 

No information. 

Administrative arrangements for fraud prevention in the Member States are a competence of the 
Member States. 

- 

more training, would be appreciated 

- 

In a country as decentralised as Spain, coordination between all the entities that form part of the 
anti-fraud architecture is much more complicated. 

We consider the exchange of good practices in the Member States under question 3.8 as a priority, 
for which OLAF could provide an excellent platform with the help of the working groups under 
OLAF’s  authority.  The  effectiveness  and  efficiency  of  the  fight  against  fraud  in  a  context  that 
increasingly  focuses  on  digital  solutions  largely  depends  on  Member  States  mobilising  their 

 
 
 
Member 
State 

Response 

resources  (such  as  expertise  or  IT  solutions)  individually  and  potentially  in  fragmentation  or 
exploiting synergies in cooperation. 

SK 

PL 

DE 

BG 

MT 

X 

None 

- 

N/A 

In terms of Article 23 of the Internal Audit and Financial Investigations Act (Cap. 461 of the Laws 
of Malta), Malta has a Co-ordinating Committee to 'co-ordinate the activities of, and to facilitate 
the  exchange  of  information  between,  different  entities  charged  with  the  protection  and 
safeguarding of public funds'. 

CY 

N/A 

develop 

It is difficult to give nationwide answers to such detailed questions. Institutions have different tasks 
and 
opposite.  
For  the  sake  of  comparability,  please  distinguish  between  topics  (investigative-,  implementing 
institutions etc.) in the next questionnaires. 

it  means 

different 

answers 

paces; 

their 

are 

at 

N/A 

Sharing best practices could help to improve the functioning of the existing governance structures. 

NA 

Nothing to report. 

EE 

RO 

PT 

LV 

DK 

Q.4.1 Which national services were consulted to reply to this questionnaire? 

Member 
State 

Response 

IE 

LU 

HR 

all MA's 

Managing Authority / ESF 

Ministry of Agriculture, Forestry and Fisheries, Directorate for Support in Agriculture and Rural 
Development - Managing Authority for the Rural Development Programme 2014.-2022. and for the 
Strategic Plan of the Common Agricultural Policy 2023.-2027.  
Ministry of Labour, Pension System, Family and Social Policy, Directorate for the Management of 
EU  Operational  Programmes  -  Managing  Authority  for  the  Operational  Programme  Efficient 
Human Resources 2014-2020 and Programme Efficient Human Resources 2021-2027.   
Ministry  of  Regional  Development  and  EU  funds  -  Directorate  for  the  Implementation  of  the 
Operational  Programmes  and  Financial  Instruments  -  Managing  Authority  for  the  Operational 
Programme  Competitiveness  and  Cohesion  2014-2020  and  Programme  Competitiveness  and 

 
 
 
 
Member 
State 

Response 

Cohesion 2021-2027.  
Ministry of Finance, Customs Administration  
Ministry of Finance, Tax Administration    
Ministry of Agriculture, Forestry and Fisheries, Directorate of Fisheries - Managing Authority for 
Operational  Programme  for  Maritime  Affairs  and  Fisheries  2014-2020  and  the  Programme  for 
fisheries and aquaculture 2021.-2027.  
Agency for the Audit of European Union Programmes Implementation System (ARPA) – The Audit 
Authority  
Croatian AFCOS Unit 

SE 

Implementing authorities and Swedish AFCOS 

NL 

Departments of Finance, economic affairs, social affairs and agriculture, fisheries, food security and 
nature 

FR 

MICAF, CAP, cohesion funds 

for 

for 

Support 

Systems 

Information 

Institutional 

1. Ministry of Economy and Finance, 
-  1.1.  Secretariat-General  for  Fiscal  Policy  Directorate-General  for  Audits  of  Co-financed 
Programmes Financial Audit Committee,    
- 1.2. Secretariat-General for Tax Policy and Public Property Directorate-General for the Financial 
and Economic Crime Unit, 
-  1.3. Secretariat-General 
for  Regional  Development,  
the  Partnership  Agreement 
- 1.3.1. Special Service – Authority for Certification and Verification of Co-financed Programmes,  
-  1.3.2.  ESPA  National  Coordination  Authority  Directorate-General  for  Institutional  and 
Operational  Support  for  the  Partnership  Agreement  for  Regional  Development  (ESPA)  Special 
Service 
(EYTHYPS),  
and 
- 1.3.3. Special Service for State Aid and Financial Tools,  
- 1.4. Recovery and Resilience Facility Coordination Agency. 
2. Ministry of Citizen Protection Financial Police Directorate. 
3. Ministry of Justice. 
4. Ministry of Rural Development and Food, 
- 4.1. Office of the Secretary-General for Rural Policy and International Relations, 
-  4.2.  Directorate-General  for  Administrative  Services  and  e-Government  Directorate  for 
Legislative Initiative and Management of Infringements. 
5.  Payment  and  Control  Agency  for  Guidance  and  Guarantee  Community  Aid  (OPEKEPE).  
6.  Ministry  of  Migration  and  Asylum  Special  Service  for  the  Coordination  and  Management  of 
Migration and Home Affairs Programmes.  
7. National Transparency Agency.  
8 Independent Authority for Public Revenue, 
- 8.1. Office of the Governor, 
- 8.2. Directorate-General for Customs and Excise,   
- 8.3. Coordination Operational Centre for combating smuggling (SEK).  
9. Single Public Procurement Authority. 

Federal Public Economy Service - Coordination of Fraud Control – AFCOS BE 

Federal Public Finance Service  

EL 

BE 

 
 
 
 
 
 
  
  
 
 
  
  
 
 
  
 
 
 
 
Member 
State 

Response 

Federal Public Policy and Support Service 

Federal Public Justice Service 

Communities (German-speaking, Flemish & French) 

Regions (Brussels - Capital, Flemish & Walloon) 

European Social Fund Brussels-Capital 

European Social Fund Flanders 

European Regional Development Fund Brussels-Capital 

European Regional Development Fund, Recovery and Resilience Facility & European Social Fund 
Wallonia (The SPW services involved in protecting EU interests in the fight against fraud) 

European Regional Development Fund Flanders 

Walloon Paying Agency 

Agency for Agriculture & Fisheries 

Federal Police 

AT 

All federal ministries. Replies were received from the Federal Ministry of Agriculture, as well as 
the Federal Ministry of Labour and Economy (ESF Managing Authority and ESF Audit Authority). 

Ministry of Agriculture and Forestry  
Ministry of the Interior    
Ministry of Economic Affairs and Employment  
Ministry of Finance 
Police of Finland 
Finnish Food Authority   
Finnish Customs 
State Treasury 
Tax Administration 

Special Investigation Service of the Republic of Lithuania, Customs of the Republic of Lithuania,

 Ministry  of  the  Interior  of  the  Republic  of  Lithuania,  Ministry  of  Finance  of  the  Republic  of 
Lithuania, 
Prosecutor  General‘s  Office,  Ministry  of  Agriculture  of  the  Republic  of  Lithuania,  Public 
Procurement Office. 

Ministry for Cohesion and Regional development, FARS-Financial Administration of the Republic 
of Slovenia, Agency for Agricultural Markets and Rural Development (AAMRD), the Recovery 
and Resilience Office, Supreme State Prosecutor's Office of the Republic of Slovenia and others. 

National Coordination Authority, Delivery Unit, Managing authorities, Component owners, Police 
of the Czech Republic - National Organized Crime Agency, Prosecutor General’s Office, General 
Customs Directorate, General Financial Directorate 

European Social Fund Administration Unit (UAFSE)   
Sub-Directorate  General  Economic  Management  and  European  Funds  (managing  authority  for 
AMIF)   

FI 

LT 

SI 

CZ 

ES 

 
 
 
 
 
 
 
 
 
 
 
 
 
Member 
State 

Response 

Sub-Directorate  General  Economic  Sustainability  and  Social  Affairs  (  managing  authority  for 
European Maritime, Fisheries and Aquaculture Fund)  
Sub-Directorate  General  Inspection  and  Control  (Directorate-General  for  European  Funds)  
Sub-Directorate  General  European  Territorial  Cooperation  (managing  authority  for  ETC 
programmes)  
Sub-Directorate  General  Agricultural  Funds-  FEGA  (Spanish  Agricultural  Guarantee  Fund  - 
coordinating body of the paying agencies)   
FEGA Internal Audit Division  
Sub-Directorate General ERDF (managing authority for ERDF)  
Sub-Directorate General Planning and Management of Infrastructures and Resources for Security 
(managing authority for ISF))   
Sub-Directorate Genera for the Management of the National Recovery Plan ( Directorate General 
for the Recovery and Resilience Plan and Mechanism, General Secretariat for European Funds)   
State  Agency 
(AEAT)-  Customs  and  Excise  Department  
State  Agency  for  Tax  Administration  (AEAT)-  Department  of  Financial  and  Tax  Inspection. 
Undersecretariat of the Ministry of Agriculture, Fisheries and Food -Anti-fraud and Internal Control 
Unit (Civil Guard)  
National Police 

for  Tax  Administration 

HU 

The National Development Centre Internal Audit and Integrity Directorate, OLAF Coordination 
Office at the Central Management of the National Tax and Customs Administration (AFCOS). 

Bratislava Self-Governing Region - Interact, Ministry of Transport of the Slovak Republic, Ministry 
of  Finance  of  the  Slovak  Republic,  Ministry  of  Investments,  Regional  Development  and 
Information of the Slovak  Republic, Ministry of Agriculture and Rural Development of the Slovak 
Republic, Ministry of Health of the Slovak Republic, Ministry of the Environment of the Slovak 
Republic,  Supreme  Audit  Office  of  the  Slovak  Republic,  Antimonopoly  Office  of  the  Slovak 
Republic,  Public  procurement  office,  Government  Office  of  the    Slovak  Republic,  Ministry  of 
Justice of the Slovak Republic, Ministry of Labour, Social affairs and family of the Slovak Republic, 
Ministry  of  Economy  of  the  Slovak  Republic,  Ministry  of  the  Interior  of  the  Slovak    Republic, 
Ministry of Culture of the Slovak Republic, Financial Directorate of the Slovak Republic, General  
Prosecutor´s Office of the Slovak Republic and Ministry of Education, Research, Development and 
Youth 
of  
the Slovak Republic. 

Ministry of Finance (AFCOS)  
Ministry  of  Development  Funds  and  Regional  Policy  (Partnership  Agreement  Coordinating 
Institution) 
The Agency for Restructuring and Modernisation of Agriculture (Paying Agency) 

The Federal ESF Managing Authority within the Federal Ministry of Labour and Social Affairs 
(BMAS) 
The Federal Ministry of Food and Agriculture (BMEL) 
The Saarland ESF Managing Authority 
Through the Federal Ministry of Economic Affairs and Climate Action (BMWK), the following 
managing authorities 
The Baden-Württemberg ERDF Managing Authority 
The Bremen ERDF Managing Authority 

SK 

PL 

DE 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Member 
State 

Response 

The North Rhine-Westphalia ERDF Managing Authority 
The Rhineland-Palatinate ERDF Managing Authority 
Investitions- und Förderbank Niedersachsen (Nbank), the intermediate  body for the ERDF/ESF+ 
Managing Authority  
The Schleswig-Holstein ERDF Managing Authority 
The Thuringia ERDF Managing Authority 

The  Bulgarian  AFCOS  Council  (Managing  authorities,  Audit  authorities,  Accounting  Body, 
Customs Agency, National Revenue Agency, State Agency for National Security) 

To obtain the necessary replies, the Maltese AFCOS liaised with the Office of the Prime Minister - 
EU Funds, Equality, Reforms and Social Dialogue. 

AFCOS 

We sent the 2023 follow-up questionnaire to 12 institutions and received eight responses. 

Development, 

the  Ministry 

of  Agriculture 

and  Rural  Development, 

36 national services were consulted: 
The  National  Agency  for  Fiscal  Administration,  the  Paying  Agency  for  Rural  Investments,  the 
National  Agency  of  Public  Civil  Servants,  the  Agency  for  Payments  and  Intervention  for 
Agriculture, the Audit Authority, the Certification and Payment Authority, the Ministry of Internal 
Affairs, 
the  Ministry  
of the Economy, Digitalisation, Entrepreneurship and Tourism, the Ministry of Culture, the Ministry 
of 
Works  
and Administration, the Ministry of Education and Research, the Ministry of Energy, the Ministry 
of 
Family,  
Youth and Social Solidarity, the Ministry of Finance, the Ministry of Investments and European 
Projects,  
the Ministry of Justice, the Ministry of the Environment, Water and Forestry, the Ministry of Health, 
the Ministry of Transport and Infrastructure, the Secretariat-General of the Government, the North-
East  Regional  Development Agency,  the  South-East  Regional  Development  Agency,  the  South-
Muntenia Regional Development Agency, the West Regional Development Agency - ADR West, 
the South-West Oltenia Regional Development Agency, the Bucharest Ilfov Regional Development 
Agency,  the  North-West  Regional  Development  Agency,  the  Centre  Regional  Development 
Agency - ADR Centre. 

Labour, 

Public 

The Tax and Customs Authority (AT), the Development and Cohesion Agency (AD&C), and the 
Institute for Agricultural and Fisheries Financing (IFAP) 

AFCOS network institutions, including EU Funds managing authorities (and intermediate bodies), 
Paying agency for EU funds for agricultural and rural development, law enforcement authorities. 

The 
• 
• 
• 
• 

• 

members 

of 

the 

Danish 

AFCOS, 

i.e.:  

The Agency for Green Land Conversion and Water Environment  
The Agricultural and Fisheries Agency 
The Business Authority 
The Ministry of Taxation    
o 
Tax 
The Special Crime Unit (NSK) 

Agency 

Incl. 

The 

The 

and 

Customs 

Agency  

BG 

MT 

CY 

EE 

RO 

PT 

LV 

DK 

 
 
 
 
 
 
 
  
  
  
 
Member 
State 

Response 

IT 

Department for European Affairs at the Prime Minister’s Office; 
- Department for Cohesion Policy and Southern Italy at the Prime Minister’s Office;  
- Department of Public Administration at the Prime Minister’s Office;  
- Department for Regional Affairs and Autonomies at the Prime Minister’s Office;  
- NRRP Unit at the Prime Minister’s Office;  
- Special Economic Zones (SEZ) Unit at the Prime Minister’s Office;  
- Italian Court of Auditors;  
- Network of NRRP Anti-Fraud Contact Persons at the State General Accounting Department;    
-  Coordination  Committee  for  High-Level  Oversight  of  Priority  Infrastructure  and  Construction 
Projects (CCASIIP);  
- Carabinieri;  
- Guardia di Finanza;  
- National Anti-Corruption Authority (ANAC);  
- Financial Intelligence Unit (FIU) at the Bank of Italy;  
- National Anti-Mafia and Anti-Terrorism Directorate;  
- Central Criminal Police Directorate;  
- Anti-Mafia Investigation Directorate;  
- Ministry of the Interior;  
- Ministry of Justice;  
- Ministry of Economic Affairs and Finance;  
- Ministry of Enterprises and Made in Italy;  
- Ministry of Agriculture, Food Sovereignty and Forestry;  
- Ministry of Infrastructure and Transport;   
- Ministry of Labour and Social Policy;  
- Ministry of Education and Merit;  
- Customs and Monopolies Agency;  
- Revenue Agency;  
- Agricultural Payments Agency (AGEA);   
Joint Conference. 

Q.4.2  How  could  we  improve  this  questionnaire?  Please  share  any  suggestions  for 
enhancements or specific areas that could be improved for future iterations. 

Member 
State 

Response 

IE 

n/a 

LU 

HR 

Important to provide the possibility for answers that are not mutually exclusive to include different 
statements from involved stakeholders. The way the questionnaire is structured, it does not enable 
opposing statements by stakeholders; mutually exclusive options are not a good tool where a variety 
of stakeholders with different feedback is involved. 

EUSurvey web page and follow-up questionnaire is structured in a way that one can provide only 
unified  answers.  Namely,  we  usually  ask  several  national  administrations  (authorities)  for  the 
contribution to the Questionnaire, but „EUSurvey“ web page is structured in a way that one can 

 
 
  
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Member 
State 

Response 

provide only unified answers without possibility to provide other types of answers.  
For  example,  first  question  is  „Have  you  reviewed  the  effectiveness  of  your  reporting  in  the 
Irregularity Management System (IMS) in 2024?“ and it is possible that one national administration 
(authority)  answers  YES,  and  other  answers  NO.  In  that  case,  different  options  of  answering 
appears. So maybe you should consider possibility of making space within the questionnaire so to 
be able to add different types of answers.    
In addition, in relation to some questions we would like to add certain explanations in order to better 
clarify the answers provided so more space would be appreciated. 

The  questions  in  the  form  should  be  better  adapted  to  the  administrative  arrangements  of  the 
Member States. At present, it is difficult for individual managing authorities to answer questions 
that presuppose central governance on substantive issues that do not exist in Sweden. 

N/A 

x 

With the help of the competent national authorities, this questionnaire brings together data from all 
the Member States, thereby optimising the contribution of all recent institutional, administrative, 
organisational and operational developments to the defence of the economic interests of both the 
Member States themselves and of the European Union as a whole. Any comments/suggestions for 
improvement have been set out in detail in question 2.32. 

/ 

No information. 

- 

- 

Concerns specifically in the 2.6, 2.8 and 2.9: Answers from FARS are inserted. While answers from 
State Prosecutors office cannot be inserted, although they are different from FARS answers. System 
does not allow different answers in the same line. It is not possible to mark two circles, it allows 
only one marking in one line. 

One of the entities mentioned the length of the questionnaire (22 pages). The questionnaire should 
be optimised in order to reduce the number of questions and to provide guidance on answering any 
unclear questions. Terms and concepts should be further explained. 
The type of checkboxes (one-only/multiple) in the word document in national language, which is 
distributed  to  the  respondents,  differs  from  those  in  the  website  questionnaire  which  is  an 
unwelcome surprise requiring modification of several replies at the very final stage of filling-in the 
questionnaire. 

SE 

NL 

FR 

EL 

BE 

AT 

FI 

LT 

SI 

CZ 

ES 

No suggestions 

HU 

Protection of the EU’s financial interests affects an increasing number of policy sectors and thus an 
increasing  number  of  areas,  with  the  result  that  the  rules  of  the  Member  States  and  the  related 
institutional  set-up  have  been  adapted  to  these  specificities  with  different  tasks,  mandates  and 
operational environments. In order to provide an accurate picture of the Member States on the basis 

 
 
 
 
Member 
State 

Response 

of the replies to the follow-up report, we consider it important to provide for separate answers at 
least on the expenditure and revenue sides of the budget for topics that can be interpreted across 
several EU policies, as certain questions may vary considerably depending on the field the question 
addresses. 

SK 

X 

as 

State 

The anti-fraud system in Poland consists of a number of independent but cooperating institutions 
and bodies, including law enforcement authorities. The competent authorities of the management 
and control system have their own mechanisms on the basis of which they carry out their mission, 
including the fight against fraud, which may differ in terms of their development or implementation 
stage. At the same time, the questions contained in this Follow-up Questionnaire (as in the Article 
325 Questionnaire) are addressed to each of the Member States individually. Similarly, the answers 
expected by the Commission should represent a national position (from the point of view of the 
Member 
whole).  
The  specific  requirements  of  working  with  these  questionnaires  therefore  necessitate  some 
harmonisation and compromises in the manner of presenting answers. It is necessary to consult a 
number of relevant institutions at times, as well as to select information that jointly translates into 
the single ‘national’ answer in the broadest sense and to present it in a synthetic form, which is often 
the result of the space restrictions in the online form. This should always be taken into account by 
the Commission when interpreting the replies received from Member States in these questionnaires.  
A technical point worth mentioning is that one would expect the editable form to function better (it 
is a Word file generated by the system): making a choice by selecting an item from a multiple- or 
single-choice list or filling in specific text fields should be possible without running into technical 
problems. This is particularly true for the Article 325 Questionnaire form  – the Word file is very 
badly developed from a technical point of view. In view of the need to use it in broad national-level 
consultations at the stage of preparing answers for the Commission, the unstable behaviour of the 
file makes working with it very difficult.  

a 

the  management 

The  Federal  Ministry  of  Food  and  Agriculture  (BMEL):  More  targeted  questions,  taking  into 
account 
State.  
The Rhineland-Palatinate ERDF Managing Authority: You could give more “not applicable/cannot 
assess” options for the questionnaire on topics about practices/plans on a national level. In a federal 
state, managing authorities do not always have knowledge about the plans on a federal level. 

each  Member 

systems 

control 

and 

in 

N/A 

The questionnaire is very detailed as it is. 

The  questions  on  Arachne  tool  focus  on  the  integration  rather  than  the  use  of  the  tool,  lack  of 
integration starts from the Commission side and the tool is unable to be integrated at the moment. 
Arachne only works through uploading of XML files at the moment. 

It is difficult to give nationwide answers to such detailed questions. Institutions have different tasks, 
and 
development.  
different 
To  ensure  comparability,  please  distinguish  topics  for  different  institutions  (investigative-, 
implementing institutions etc.). 

stages 

they 

are 

of 

at 

PL 

DE 

BG 

MT 

CY 

EE 

RO 

N/A 

 
 
Member 
State 

Response 

PT 

LV 

DK 

Earlier dissemination of the questionnaire 

The questionnaire is well prepared. 

Nothing to report.