COMMISSION STAFF WORKING DOCUMENT ex-ante evaluation Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the exchange, assistance and training programme for the protection of the euro against counterfeiting for the period 2028-2034 (the 'Pericles V' programme) and repealing Regulation (EU) 2021/840
Date: 2025-09-03
Institutions: Directorate-General for Economic and Financial Affairs, European Commission
Subjects: EU programme, counterfeiting, cross-border cooperation, euro, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.9.2025  SWD(2025) 253 final  COMMISSION STAFF WORKING DOCUMENT ex-ante evaluation Accompanying the document Proposal for a  REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the exchange, assistance and training programme for the protection of the euro against counterfeiting for the period 2028-2034 (the 'Pericles V' programme) and repealing Regulation (EU) 2021/840      {COM(2025) 462 final}  
 
 
Glossary 

Term or acronym 

Meaning or definition 

Competent National Authority 

Competent National Authorities 

Directorate-General for Economic and Financial 
Affairs 

Directorate-General for Neighbourhood Policy and 
Enlargement Negotiations  

Directorate-General for Migration and Home Affairs 

Directorate-General for neighbourhood and  
enlargement policies 

European Central Bank 

Euro Counterfeit Experts Group 

European Multidisciplinary Platform Against 
Criminal Threats 

European Technical and Scientific Centre (ETSC) 

European Union 

European Union Agency for Law Enforcement 
Cooperation 

Internal Security Fund 

Staff Working Document 

Technical Assistance and Information Exchange 

Treaty on the Functioning of the European Union 

 CNA 

 CNAs 

DG ECFIN 

DG ENEST 

DG HOME 

DG NEAR 

ECB 

ECEG 

EMPACT 

ETSC 

EU 

Europol 

ISF 

SWD 

TAIEX 

 TFEU 

1 

 
 
 
 
1.  PROBLEM ANALYSIS AND NEEDS ASSESSMENT 

1.1. 

Scope and context 

The euro is, as the single currency of the Union, a core European interest, the integrity of 
which needs to be protected in all its dimensions. Counterfeiting of the euro poses a real 
problem  for  the  EU  Member  States  and  institutions.  Counterfeits  harm  citizens  and 
businesses that are not reimbursed for counterfeits even if received in good faith. More 
generally, it impacts the legal tender status, as well as the trust, of citizens and businesses 
in  genuine  euro  notes  and  coins.  Therefore,  a  solid  protection  of  the  euro  against 
counterfeiting helps to preserve the integrity of the euro, thereby strengthening the trust of 
citizens  and  business  in  the  genuineness  of  the  euro  and  contributing  to  ensuring  the 
effective functioning of the euro and safeguarding fiscal and financial stability in the EU. 
Since the introduction of the euro as a single currency, there is the need to protect the euro 
against  counterfeiting  at  EU  level  and  to  have  a  specific  programme  dedicated  for  this 
purpose. As the single currency of the Union, the euro entails a high risk of counterfeiting 
which  in  turn  has  the  potential  to  undermine  trust  in  the  euro.  Therefore,  the  Pericles 
programme was established in 2001. The legal basis of the programme for the euro area 
Member States is Article 133 of the Treaty on the Functioning of the European Union. The 
application  of  the  Pericles  programme  is  extended  to  the  Member  States  that  have  not 
adopted the euro as their single currency, through a proposal for a parallel Regulation based 
on Article 352 TFEU. 

The current ''Pericles IV'' programme is specifically dedicated to the protection of the euro 
against  counterfeiting1.  The  Programme  is  ensuring  and  facilitating  an  exchange, 
assistance  and  training  regarding  counterfeiting  and  counterfeiting-related  activities.  It 
supports  the  pillars  on  which  the  Commission's  anti-counterfeiting  policy  is  based: 
prevention, repression and cooperation. The programme was established by Regulation 
(EU) 2021/840 of the European Parliament and of the Council of 20 May 20212. Its 
application  was  extended  to  the  non-participating  Member  States  by  Council 
Regulation (EU) 2021/1696 of 21 September 20213.  

In  line  with  the  requirements  set  out  by  the  Financial  Regulation4,  programmes  which 
provide continuity as regards content and structure and/or are of relatively small budget, 
do not require an impact assessment but rather an ex-ante evaluation. The present ex-post 
evaluation  is  linked  to  the  Commission  proposal  to  continue  the  Pericles  programme, 
beyond 2027. 

1 It replaces the Pericles 2020 programme that was established in 2014 and ran during the period 2014-2020. 
2  Regulation (EU) 2021/840 of the European Parliament and of the Council of 20 May 2021 establishing an exchange, assistance and 
training programme for the protection of the euro against counterfeiting for the period 2021-2027 (the ‘Pericles IV’ programme), and 
repealing Regulation (EU) No 331/2014 (OJ L 186, 27.5.2021, p. 1).. 

3  Council  Regulation  (EU)  2021/1696  of  21  September  2021  extending  to  the  non-participating  Member  States  the  application  of 
Regulation  (EU)  2021/840  of  the  European  Parliament  and  of  the  Council  establishing  an  exchange,  assistance  and  training 
programme for the protection of the euro against counterfeiting for the period 2021-2027 (the ‘Pericles IV programme’) (OJ L 336, 
23.9.2021, p. 1-2). 

4 European Commission: Directorate-General for Budget, Financial regulation applicable to the general budget of the 

Union (recast), Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2761/686790 

2 

 
 
 
The status of counterfeiting 

According to the latest information on euro banknotes prepared by the European Central 
Bank, 554,000 counterfeit euro banknotes were  withdrawn from circulation in 20245. 
This corresponds to an increase of 18.6% when compared with 2023 and is 47.3% more 
than in 2022. The actual number of counterfeit euro banknotes has increased compared 
with recent years, when the number of counterfeits was exceptionally low following the 
COVID-19 pandemic. Nonetheless, the number of counterfeits remains lower than in the 
years leading up to the pandemic6. 

The  €20  and  €50  denominations  continued  to  be  the  most  commonly  counterfeited, 
together accounting for more than 75% of the total amount. 97.8% of the counterfeits were 
found in euro area countries, while 1.3% were found in non-euro area EU Member States 
and 0.9% in other parts of the world.  

According  to  the  latest  Europol  Annual  Report  on  euro  counterfeiting7,  in  2023  police 
forces  seized  393,556  pieces  of  counterfeit  euro  banknotes  before  being  put  into 
circulation. The total face value of these  counterfeit banknotes is €43 million. Europol 
noticed a notable (38.64%) increase in the number of counterfeits seized before circulation 
with  a  13.87%  growth  of  corresponding  face  value  of  these  notes.  Furthermore,  law 
enforcement measures resulted in the identification of nine clandestine print shops and one 
mint,  together  with  raw  materials,  tools  and  machinery  used  by  counterfeiters  for  the 
forgery  of  euro  Over  the  last  years,  an  increasing  number  of  deceptive  counterfeit 
banknotes have been found, with security features (such as holograms) from China. Digital 
printing  techniques  were  growing,  as  well  as  altered  design  banknotes,  presumably 
produced in China (e.g. ’movie money’) or Türkiye.  

The total number of counterfeit euro coins removed from circulation in 2024 was 48 8190 
pieces,  an  increase  of  1.6  %  compared  to  2023.  The  quality  of  the  counterfeit  coins 
remained high. In this respect, 23 new classes and variants were created, out of which 9 
had good electromagnetic properties.  

When compared to 2023, 2024 marks an increase in 2 euro denomination counterfeits. In 
particular,  2  euro  denomination  counterfeits  increased  by  2.95%,  1  euro  denomination 
counterfeits  decreased  by  16.50  %  and  50  cent  denomination  counterfeits  increased  by 
25% in comparison to 2023. Furthermore, in 2024 the 1 euro denomination maintains the 
second position, from a quantity point of view (3.23 % of the total). The 2 euro remains by 
far the most counterfeited denomination, constituting 97.95% in terms  of value (almost 
stable compared to 2023).   

The  statistics  for  the  year  2024  confirm  the  increasing  trend  of  counterfeit  euro  coins 
removed from circulation of the last five years. Projections for 2025, based on information 
received from Member States, confirm that the increasing trend is expected to continue. 

5  For more information: https://www.ecb.europa.eu/press/pr/date/2025/html/ecb.pr250221~c0d1113d2c.en.html    
6  For example, in 2017 694.000 counterfeit euro banknotes were withdrawn from circulation, see    
https://www.ecb.europa.eu/press/pr/date/2018/html/ecb.pr180126.en.html  
7  Annual Report on euro counterfeiting 2023, Document Reference #1408866, The Hague 08/08/2024 

3 

 
 
Overall, 4 561 109 counterfeit euro coins have been removed from circulation since the 
introduction of euro coins in 2002.  

With respect to the criminal phenomenon of counterfeiting, the long-term view held by 
Europol, Member State national experts, the Commission and the European Central Bank, 
confirms  the  growing  interest  in  euro  counterfeiting  of  organised  crime  groups  located 
outside EU. The involvement of organised crime groups continues to be a characteristic of 
this crime and contributes to the maintenance of a high-level criminal threat. Moreover, 
Europol states that 2023 saw a significant revitalization of the distribution of counterfeit 
euro  banknotes  and  coins.  Online  distribution  continues  to  use  diverse  platforms,  in 
particular encrypted peer-to-peer communication and to a lesser extent the Darknet8. 

Interaction with other instruments/programmes 

The  Pericles  IV  interim  evaluation9  concluded  that  Pericles’  distinct  transnational  and 
multidisciplinary approach, as well as its emphasis on capacity building and its thematic 
focus on euro anti-counterfeiting  sets the programme apart from other EU programmes 
such as the Internal Security Fund (ISF), the technical assistance and information exchange 
(TAIEX)10,  twinning  instruments,  and  international  initiatives,  which  rarely  display  the 
same features simultaneously.  

The Police instrument of the Internal Security Fund (ISF Police) covers the prevention 
of  and  fight  against  crime  in  general,  but  only  includes  (indirect)  efforts  to  prevent  or 
combat euro (or currency) counterfeiting if linked to other types of crimes prioritised by 
the instrument (namely terrorism, organised crime, cybercrime, and environmental crime).  

Furthermore, the  Technical Assistance and Information Exchange (TAIEX) instrument 
has supported activities related to euro counterfeiting, but these activities are of a different 
scale,  duration  and  nature  compared  to  Pericles  IV  actions  and  are  often  in  support  of 
accession negotiations. Several CNAs and non-EU authorities have been involved in other 
programmes  but,  as  stated  in  the  stakeholder  interviews,  they  regard  the  Pericles  IV 
programme as unique, complementing other initiatives effectively11.  

The  interim  evaluation  also  highlights  the  close  effective  cooperation  between  the 
Commission, the ECB and Europol in the protection of the euro and the fight against euro 
counterfeiting. In particular, the activities organised by the ECB are of a technical nature 
and provide new insights into the technical aspects of counterfeit production. To this end, 
the ECB’s activities are mostly relevant to national central banks, while those carried out 
by the ECB’s Counterfeit Analysis Centre supplement the activities carried out under the 
Pericles umbrella.  

8 Annual Report on euro counterfeiting 2023, Document Reference #1408866, The Hague 08/08/2024. 
9  Commission  Staff  Working  Document  on  the  interim  evaluation  of  the  ‘Pericles  IV’  programme  accompanying  the  document 
Communication  from  the  Commission  to  the  European  Parliament,  the  Council  and  the  European  Central  Bank  on  the  interim 
evaluation of the ‘Pericles IV’ programme (SWD (2025) 44 final; COM(2025)54 final). 

10  Information  about  the  ISF  is  available  here;  information  about  the  TAIEX  instrument  is  available  here;  information  about  the 

Twinning instrument is available here.  

11 Stakeholder consultation as part of the Pericles IV interim evaluation, see (SWD (2025) 44 final. 

4 

 
 
 
Europol  (in particular through the European multidisciplinary platform against criminal 
threats (EMPACT)12 also seeks to provide training and contribute to the capacity building 
of law enforcement. Given the complementary objectives between Pericles and EMPACT, 
the Commission is closely coordinating with the EMPACT driver in order to maximize the 
complementarity  between  the  two  sources  of  financing.  For  this  reason,  Europol 
(EMPACT) and DG ECFIN agreed that, given its specialisation and interdisciplinarity, the 
Pericles programme would take the initiative in this regard and allow EMPACT to put its 
additional brand on the most relevant Pericles initiatives. This would enable Europol to 
focus its activities on operational support. 

1.2.  Lessons learned from previous programmes 

Interim evaluation of the Pericles IV programme 

An interim evaluation of the programme was carried out by an independent contractor on 
the  basis  of  Art  13  of  Regulation  (EU)  No  2021/840.  The  Commission  adopted 
Communication  COM(2017)  741  to  the  European  Parliament,  the  Council  and  the 
European Central Bank on the results of the interim evaluation of the programme on 20 
February 2025, in which it shares the independent study’s conclusion that the programme 
has  effectively  contributed  to  preventing  and  combating  euro  counterfeiting,  thereby 
preserving the integrity of euro banknotes and coins. Pericles has fostered cooperation and 
increased the capacity to protect the euro among institutions in Member States and non-
EU countries. The interim evaluation concludes that the programme should continue until 
its natural expiry in 2027 and supports the continuation of the programme as a stand-alone 
programme beyond 2027 given its EU added value, long-term impact and sustainability. 

The overall assessment from the evaluation of the Pericles IV programme13 was positive. 
In particular, the evaluation concludes that:14 

•  The programme is effectively meeting its objectives as outlined in Article 2 of the 
Regulation. It has successfully improved cooperation and capacity to protect the 
euro among institutions in Member States and non-EU countries while its actions 
have  also  facilitated  critical  contacts  and  information  exchange,  significantly 
improving institutional and operational capabilities. 

•  The  programme’s  success  is  largely  due  to  its  design,  which  reflects  its  unique 
focus and allows for close cooperation between Member States and the European 
Commission through DG ECFIN. As Pericles IV is a stand-alone programme, the 
Commission department managing it acts as an operational business unit, integral 
to strategy development, planning and implementation of actions. This ensures that 

12 EMPACT fosters multidisciplinary and multiagency operational cooperation to fight organised crime at EU level. More     information 

on EMPACT is available here. 

13 Communication COM(2025) 54 final - Communication from the Commission to European Parliament, the Council and the European 
Central Bank on the interim evaluation of the Programme for exchange, assistance and training for the protection of the euro against 
counterfeiting ('Pericles IV' Programme),26 February 2025. 

14 Commission Staff Working Document SWD(2025) 44 final Accompanying the document Communication from the Commission to 
European Parliament, the Council and the European Central Bank on the interim evaluation of the Programme for exchange, assistance 
and training for the protection of the euro against counterfeiting ('Pericles IV' Programme), 20 February 2025. 

5 

 
 
 
the  programme  remains  aligned  with  the  needs  of  Member  States  and  action 
participants,  bringing  added  value  and  effectiveness.  The  Commission  has 
previously assessed that a merger with other EU programmes is not legally feasible 
given the programme’s two unique legal bases in the Treaty  (Article 133 TFEU 
(ordinary  legislative  procedure)  and  Article  352  TFEU  (special  legislative 
procedure)15. 

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

•  The  Pericles  IV  programme’s  coordination,  management  and  administrative 
structures are adequate, ensuring efficient use of resources. DG ECFIN’s prompt 
support is highly appreciated, and partner institutions such as the ECB and Europol 
positively assess their cooperation with DG ECFIN. While management costs are 
comparatively  high  in  relative  terms  compared  to  similar  programmes,  this  is 
mainly due to the limited overall budget of the Programme. Their overall share is 
also declining due to digitalisation, indicating overall efficiency gains. The close 
involvement of DG ECFIN in action coordination and implementation, including 
by  chairing  ECEG  meetings,  ensures  Member  State  buy-in  and  effective 
monitoring.  The  programme  undergoes  full  interim  and  ex-post  evaluations, 
although  its  small  size  raises  questions  about  the  proportionality  of  these 
requirements.  

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

•  On the budgets for individual grants, a difference can be noted between forecast 
and final costs. This is due mainly to changes in cost elements such as travel and 
subsistence.  The  current  co-financing  arrangement  of  75%  (the  standard  co-
financing rate) and 90% (the exceptional co-financing rate) is appropriate, with an 
average co-financing rate of 81%. Although the programme’s budget is considered 
generally  appropriate,  a  decrease  in  funding  has  meant  that  fewer  actions  were 
implemented and fewer participants trained. 

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

6 

 
 
 
• 

• 

In  terms  of  coherence,  the  programme  operates  within  a  landscape  of  EU  and 
national initiatives, each with its own focus and objectives. Actions organised by 
other European Commission Directorates-General are aligned with the programme, 
minimising  any  overlap  of  activities.  This  complementarity  extends  to  actions 
implemented  by  other  EU  institutions,  such  as  the  ECB,  and  agencies,  such  as 
Europol. The ECB focuses on sharing information to combat euro counterfeiting, 
primarily targeting national banks, whereas Pericles IV includes law enforcement 
agencies. Europol’s operational activities complement the programme’s emphasis 
on training, relationship-building and the sharing of information. 
 At Member State level, initiatives are limited in scope. The programme fills this 
gap  by  offering  actions  that  provide  expertise  and  foster  the  building  of 
relationships among Member States and with non-EU countries. 

•  The  programme  provides  significant  EU  added  value  by  establishing  and 
improving  relationships  among  Member  States  and  with  non-EU  countries,  EU 
institutions and international organisations that go beyond the scope of individual 
national authorities. These relationships ensure that national authorities have clear 
points  of  contact  for  information,  knowledge  sharing  and  cooperation.  The 
programme also plays a crucial role in disseminating information about emerging 
trends in euro counterfeiting.   
 Pericles IV addresses a critical gap in many Member States, where resources for 
organising international and multidisciplinary training on euro counterfeiting are 
often limited. By providing targeted support, the programme strengthens the EU’s 
capacity  to  combat  euro  counterfeiting  and  supports  the  development  of  new 
relationships, networks and transnational cooperation efforts. 

• 

•  Applications  predominantly  come  from  a  limited  number  of  countries,  although 
participation in the actions of the programme is more diversified16. In the first three 
years  of  implementation  of  Pericles  IV,  applications  were  received  from  Italy, 
Spain,  Germany,  Portugal  and  Croatia.  These  countries,  together  with  France, 
account  for  approximately  three-quarters  of  all  counterfeit  euros  detected  in 
circulation  and therefore regard the problem  of euro counterfeiting  as  of greater 
concern than other Member States.  Interviews  with  non-applicants  revealed that 
financial resources, understaffing and capacity limits remain the main barriers to 
involvement  of  these  countries.  Even  if  the  relevant  authority  would  receive 
funding from Pericles IV, internal procedures often pose a challenge in ensuring 
the  required  financial  resources 
the  co-financed  amount. 
Furthermore, for some non-applicant countries, euro counterfeiting is not seen as a 
high-level priority given the low amounts of detected counterfeits in circulation in 
their territory.17 

to  supplement 

•  The  programme  remains  crucial  even  though  the  average  number  of  annually 
detected counterfeit banknotes during this programme period is lower than in the 

16 COM(2017) 345 final, Report from the Commission to the European Parliament and the Council concerning the implementation and 

the results of the Pericles 2020 programme for the protection of the euro against counterfeiting in 2016, 29 June 2017. 

17 Mid-term evaluation of the Pericles IV programme – final report, annexed to Commission Staff Working Document SWD(2025) 44 

final. 

7 

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

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

Lessons learned in the interim evaluation 

•  Maintaining the balance between the different types of action funded through the 
programme will be key throughout the remainder of the programming period. This 
can be achieved by encouraging specific types of action, such as studies and the 
purchase of equipment for non-EU countries, through the annual Pericles strategy 
papers and the meetings of the Euro Counterfeiting Experts Group (ECEG). 
•  Extending the length of the ECEG meetings to two days would allow for more in-
depth discussion. It might also be worth encouraging the representatives of judicial 
authorities to get more involved in the meetings (and the Pericles IV programme in 
general).  

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

and future threats. 

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

proportionality could be applied to evaluation requirements 

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

•  The  fight  against  euro  counterfeiting  is  most  effective  when  all  relevant 
stakeholders  in  detection, investigation and prosecution are involved. Continued 
active involvement of the judiciary, customs and parcel and delivery services in 
programme actions would thus be relevant, especially given the need to counter 
recent threats such as methods of distribution over the internet and altered-design 
banknotes. 

•  Taking  sufficient  follow-up  actions  and  providing  regular  training  sessions  can 
help correctly apply and reinforce learning outcomes. It also ensures that updates 
on current trends and developments are shared widely by continuing to highlight 

8 

 
 
the threat posed by euro counterfeiting. This need also continues to evolve due to 
the constantly changing nature of the threats posed by counterfeiting. Therefore, in 
order to keep abreast of  developments  in  counterfeiting  and to account  for staff 
turnover, it is necessary for training to be repeated every 2-3 years. 

Evaluation of the previous programme 
The final evaluation report of the Pericles 2020 programme was adopted in July 202218 
under Article 13(6) of Regulation (EU) No 331/2014 of the European Parliament and of 
the  Council  of  11  March  2014.  The  evaluation  positively  assessed  the  programme's 
implementation. It stated that the Programme has achieved its objectives in an efficient and 
effective way, since it has been successful in delivering all the envisaged diverse types of 
activities with respect to the protection of the euro and also since it took into account the 
multidisciplinary  aspects  of  the  fight  against  counterfeiting.  It  also  recognised  the 
Programme’s European and overall added value and its complementarity and coherence 
with other existing activities at Member State and European level. As for suggestions for 
improvement, the evaluation noted that  

•  While  the  problem  of  counterfeiting  evolves  with  new  tools  and  methods,  it  is 
important to carry out a continuous strategic and operational needs assessment and 
to ensure the relevance of the Programme; 

•  There  are  indications  of  the  expansion  of  the  scope  of  anti-counterfeiting 
authorities to cover also digital currencies, including the digital euro, if introduced. 
•  Based  on  the  stakeholders’  feedback,  it  can  be  concluded  that  the  face-to-face 
aspect of the Pericles actions is a crucial factor for the success of the Programme. 
•  The  higher  co-financing  rate  of  90%  in  duly  justified  cases19  was  useful  in 

• 

• 

extending the geography of participation; 
It  is  important  to  maintain  a  regular  coordination  with  relevant  DGs  and  other 
institutions  as  a  way  of  ensuring  complementarity  and  avoiding  overlaps  on 
counterfeit-related projects; 
It  can  be  concluded  that  keeping  the  focus  on  increased  cooperation  with  third 
countries continues to be a valid objective of the Programme. The evaluation also 
concluded that Pericles is seen as the only programme that supports, on an EU and 
global level, the enhancement of the operational capacity of stakeholders involved 
in  the  protection  of  the euro,  dissemination  of  best  practices  regarding  the  fight 
against  counterfeiting,  and  essentially  building  trust  between  institutions  across 
countries and regions. Therefore, and due to the ever-evolving threats to the euro 
that counterfeiting poses, there is a continued need for Pericles actions. 

18 Commission Staff Working Document Evaluation report on the final evaluation of the Pericles 2020 Programme SWD (2022) 207 

final, 28.7.2022.    

19 The standard co-financing rate is fixed at 75% for both the Pericles 2020 and Pericles IV generations of the programme. 

9 

 
 
 
 
2.  EU ADDED VALUE AND LEGAL BASIS 

EU added value and legal basis 

The protection of the European single currency as a public good has a clear transnational 
dimension, and therefore euro protection goes beyond the interest and the responsibility of 
individual EU Member States. Considering the cross-border circulation of the euro and the 
deep involvement of international organised crime in euro counterfeiting (production and 
distribution), national protection frameworks need to be complemented by an EU initiative 
to  ensure  homogeneous  national  and  international  cooperation,  and  to  face  possible 
emerging transnational risks. 

According  to  the  interim  evaluation  of  the  Pericles  IV  programme,  the  programme 
addresses  a  critical  gap  in  many  Member  States,  where  resources  for  organising 
international and multidisciplinary trainings on euro counterfeiting are often limited. By 
providing targeted support, the Programme strengthens the EU’s capacity to combat euro 
counterfeiting. An absence of the Programme would impact ongoing initiatives and hinder 
the development of new relationships and networks, impeding transnational cooperation 
efforts and would thus weaken the protection of the euro. Indeed, the Programme offers 
significant EU added value by establishing and enhancing relationships and cooperation 
among Member States, third countries, Union institutions, and international organisations 
that  are  beyond  the  reach  of  individual  national  authorities,  such  as  establishing  a 
coordinated  relationship  with  the  Chinese  authorities  to  counter  threats  such  as  the 
distribution  of  counterfeit  euro  holograms,  and  encouraging  a  common  EU  strategy  to 
counter the threats posed by altered design banknotes.The Pericles programme for euro-
area Member States will be based on Article 133 Treaty on the Functioning of the European 
Union (TFEU), as it lays down measures necessary for the use of the euro as the single 
currency. The application of the Pericles programme will be extended to the Member States 
that have not adopted the euro as their single currency, through a proposal for a parallel 
Regulation based on Article 352 TFEU. 

3.  POLICY AND MANAGEMENT OBJECTIVES 

The threat  to  the  euro from  counterfeiting  continues to  evolve.  Recently the number of 
counterfeit euros has been increasing, more sophisticated classes of counterfeiting have 
been developed and new means of counterfeit distribution have emerged. The transnational 
dimension of this phenomenon of euro counterfeiting and the involvement of organised 
crime  in  producing  and  distributing  counterfeit  euros  require  a  coordinated  European 
dimension  of  countermeasures  to  ensure  homogeneous  national  and  international 
cooperation, and to face possible emerging transnational risks. 

To address the needs identified, the following general and specific objectives have been 
developed: 

General objective 

10 

 
 
The general objective of the Programme is to prevent and combat counterfeiting and 
counterfeiting-related  fraud  and  preserve  the  integrity  of  the  euro,  thereby 
strengthening  the  trust  of  citizens  and  businesses  in  the  genuineness  of  the  euro  and 
contributing  to  ensuring  the  effective  functioning  of  the  euro,  safeguarding  fiscal  and 
financial stability  in the Union and fostering the international  use of the euro for trade, 
financial services and investment.    

Specific objective 

This  general  objective translates into one specific objective:  to protect  the euro against 
counterfeiting  and counterfeiting-related  fraud, taking  also  into  account  potential future 
developments,  such  as  potential  threats  to  the  future  digital  euro,  and  potential  threats 
posed by and investigational opportunities offered by Artificial Intelligence. It does so by 
supporting and supplementing the measures undertaken by Member States and assisting 
the competent national and Union authorities in their efforts to develop among themselves 
and with the Commission a close and regular cooperation and an exchange of best practice, 
where appropriate including third countries and international organisations.  

4.  KEY IMPLEMENTATION ELEMENTS OF THE PROGRAMME 

Continuing threats and priorities 
With the use of an annual Pericles strategy paper, identifying both emerging and recurrent 
threats and priorities, the programme continues to respond to these threats and priorities in 
a flexible  and effective  way. Current  threats  (based on the Pericles strategy for 202520) 
which the future programme will need to address include the distribution of counterfeits 
and high-quality components on the internet/darknet, as well as countering ‘movie money’ 
and ‘prop copy’ products (including altered design notes). As there is a significant risk of 
euro counterfeiting in certain third countries as well, the programme should also ensure 
high  participation  from  third  country  authorities  in  its  actions.  Through  the  Pericles 
strategy  paper,  the  programme  shall  also  identify  priority  'hotspots'  and  threats  coming 
from outside the EU, such as the South-East of Europe including Türkiye, China, Colombia 
and  Peru.  The  relevance  of  the  Programme  can  be  further  enhanced  by  focusing  on 
addressing  current  and  preparing  for  the  upcoming  and  evolving  threats. These  include 
potential threats relating to the future digital euro and the impact of Artificial Intelligence 
on counterfeit currency production and identification.  The Pericles Programme might need 
to attract specific expertise to address these threats in the future. 

Actions to be funded 
In line with its predecessor, and taking into account the upcoming threats and technological 
developments  identified  by  the  evaluation,  the  Pericles  V  programme  should  provide 
financial support for the following actions:  

20 C(2025) 972 final, Commission Decision of 18.2.2025 on the financing of the Pericles IV Programme and the adoption of the annual 

work programme for 2025 – ANNEX-PART 2/2 update of the Pericles IV strategy priority action points. 

11 

 
 
 
 
 
a. 

exchange  and  dissemination  of  information,  in  particular  through  organising 
workshops,  meetings  and seminars, including  training, targeted placements  and 
exchanges of staff of competent national authorities and other similar actions. The 
exchange of information should, among others, be targeted at:  

— best practices in preventing counterfeiting and counterfeiting-related 
fraud relating to the euro, including potential threats to the future 
digital euro, 

—  methodologies  for  monitoring  and  analysing  the  economic  and 

financial impact of counterfeiting, 

— operation of databases and early warning systems,  

— use of detection tools, including with computer back-up,  

— enquiry and investigation methods,  

—  scientific  assistance,  including  monitoring  of  new  developments, 
also  with  regard  to  potential  threats  posed  by  and  investigational 
opportunities offered by Artificial Intelligence, 

— protection of the euro outside the Union,  

— research actions,  

— provision of specific operational expertise;  

(b) technical, scientific and operational assistance, as appears necessary as 

part of the Pericles IV programme, including in particular:  

—  any  appropriate  measure  which  establishes  teaching  resources  at 
Union level, such as  a handbook of Union legislation, information 
bulletins,  practical  manuals,  glossaries  and  lexicons,  databases, 
especially in the area of scientific assistance or technology watch, or 
computer  support  applications,  such  as  software  and  Artificial 
Intelligence tools,  

—  relevant  studies  with  a  multidisciplinary  and 

transnational 

dimension, including research on innovative security features,  

—  development  of  technical  support  instruments  and  methods  to 

facilitate detection actions at Union level,  

— support for cooperation in operations involving at least two countries 
when such support cannot be made available from other programmes 
of Union institutions and bodies;  

(c) the purchase of equipment to be used by specialised anti-counterfeiting 
authorities  of  third  countries  for  protecting  the  euro  against 
counterfeiting.  For  this  type  of  action,  exclusively  implemented 
through  grants,  the  purchase  of  equipment  should  not  be  the  sole 
component of the grant agreement. 

Beneficiaries 

Potential  applicants  to  the  Pericles  programme  are  limited  to  the  Competent  National 
Authorities  of  the  Member  States,  including  law  enforcement  authorities,  judicial 

12 

 
 
authorities, national central banks and mints, for whom the implementation of a Pericles 
action is subsidiary to their professional tasks. They are officially appointed by Member 
States' governments and are included in the list of Competent National Authorities which 
is published in the Official Journal of the European Union21. Together with representatives 
of the ECB and Europol, they are members of the Euro Counterfeiting Experts' Group 
(ECEG),  managed  by  the  Commission.  The  group  endorses  a  Pericles  strategy  on  an 
annual  basis  (which  includes  the  identification  of  emerging  threats  and  priorities), 
discusses  possible  future  Pericles  applications  and  analyses  the  results  of  the  Pericles 
events. The ECEG represents a key tool to coordinate the implementation of the Pericles 
strategy, to avoid duplications and to identify unaddressed priorities/threats.  

In addition to Article 168(2) and (3) of Regulation (EU, Euratom) 2024/2509, associated 
third  countries  may,  where  relevant,  participate  in  and  benefit  from  any  procurement 
mechanisms  set  Article  168(2)  and  (3)  of  Regulation  (EU,  Euratom)  2024/2509.  Rules 
applicable to Member States shall be applied, mutatis mutandis, to participating associated 
third countries.    

In cases where the programme is opened to the participation of third countries through full 
or  partial  association,  those  authorities  shall  be  appointed  as  the  competent  national 
authorities as defined in point (b) of Article 2 of Regulation (EC) No 1338/2001 by those 
third countries shall also be considered eligible for funding. 

Delivery mechanisms 
Due to the limited and public nature of potential beneficiaries, delivery mechanisms such 
as interest subsidies, guarantees, loans and financial instruments are not applicable.   
Financial support under the current programme for eligible actions take the form of either:  
(a) grants (‘Competent National Authority-implemented actions’), or  
(b) public procurement (‘direct actions’). 

The Commission makes use of procurement ('direct actions') with an aim to complement 
the grant actions and therefore meet the highest number of emerging threats and priorities. 
The annual work programme indicates the budgetary allocation between grants and public 
procurement on an annual basis. 

Simplification 

The interim evaluation of Pericles IV underlines that Pericles undergoes full interim and 
ex-post evaluations, although its small size raises questions about the proportionality of 
these  requirements.  This  issue  will  be  addressed  in  the  performance  framework  for  the 
post-2027 budget, which is examined in a separate impact assessment. The performance 
framework provides for an implementation report during the implementation phase of the 
programme,  as  well  as  a  retrospective  evaluation  to  be  carried  out  in  accordance  with 
Article 34(3) of Regulation (EU, Euratom) 2024/2509. This would result in a decrease of 

21 See Notice 2015/C 264/02 in the Official Journal: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52015XC0812(01 ).   

13 

 
 
 
 
 
burdens  for  beneficiaries,  participants  and  stakeholders  participating  in  the  evaluation 
exercises. 

The Programme also states that funding may be provided in the form of actual eligible cost 
reimbursement only where the objectives of an action cannot be achieved otherwise. This 
increases the possibility to use simplified cost options for grants and therefore simplifies 
the application and final reporting exercises. 

Encouraging diversification 

The  interim  evaluation  of  the  Pericles  IV  programme  underlines  the  importance  for 
diversification in terms of actions and participants. In particular, the Programme should 
further  incentivise  those  actions  focusing  on  connecting  countries  that  are  specifically 
relevant to the issue at hand in order to ensure actions that   are  as  effective  and  relevant 
as possible. The Programme should also ensure a balance between the different types of 
actions  funded.  In  terms  of  participants,  the  fight  against  euro  counterfeiting  is  most 
effective  when  all  relevant  stakeholders  in  detection,  investigation,  and  prosecution  are 
involved.  The  active  involvement  of  the  judiciary,  customs,  and  parcel  and  delivery 
services in Programme actions would therefore be relevant, especially given the need to 
counter  recent  threats  like  distribution  methods  over  the  internet  and  altered  design 
banknotes. This can be achieved by encouraging specific types of actions, such as studies 
and  the  purchase  of  equipment  for  third  countries,  through  the  annual  Pericles  strategy 
papers and the meetings of the Euro Counterfeiting Experts Group (ECEG). 

5.  AVAILABLE POLICY OPTIONS 

To achieve the policy objective outlined in section 3, the following three policy options 
are considered:  

Policy option 1: (The baseline). The continuation of the Programme to deliver a similar 
number of actions to a similar number of participants as the Pericles IV Programme. 

Policy option 2: discontinuation of the Programme.  

Policy option 3: The continuation of the Programme with an increased number of actions 
and an increased number of participants compared to the Pericles IV Programme. 

Under policy option 1 there would be no policy change. The Programme would continue 
with the same envelope and maintain its unique focus, reflected in its legal basis in Article 
133 of TFEU, which along with its transnationality and multi-disciplinarity make it stand 
out in relation to other EU programmes and national modes of action. This would assure 
its  high-level  of  EU-added  value.  Furthermore,  the  Commission  /  DG  ECFIN  being  in 
charge  of  both  the  direct  management  of  the  programme  and  the  designing  and 
implementation  of  EU  policy  and  legislation  for  the  protection  of  the  euro,  covering 
prevention, enforcement and cooperation, allows achieving an optimal degree of synergy. 

14 

 
 
 
This guarantees the effective achievement of the objectives of the programme, since it links 
legislation  and  policy  with  the  implementation  of  the  programme.  Participation  of  the 
Commission  in  nearly  every  action  supports  preparation  and  presentation  of  the  EU 
legislative and policy dimensions.  

According to the interim evaluation of the Programme22, while the budget of Pericles IV 
can be considered overall appropriate to allow the Programme to fulfil its objectives, the 
budget  cut  faced  in  the  current  programming  period  (2021-2027)  was  reflected  in  a 
decreased  number  of  implemented  actions  and  number  of  action  participants  when 
compared  to  the  previous  Pericles  Programme.  During  its  first  and  second  year  of 
implementation,  the  predecessor  programme  (Pericles  2020)  funded  10  and  12  actions, 
respectively.  With  Pericles  IV,  a  total  of  10  actions  were  financed  in  the  first  two 
implementation years, five in 2021 and five in 2022. This represents more than a 50% drop 
when  compared  to  the  previous  programming  period.  Furthermore,  the  number  of 
participants in Pericles IV has decreased by almost a hundred compared to the Pericles 
2020  Programme.  According  to  the  Programme  statement23  prepared  by  the  European 
Commission, this decrease can be attributed to the lower budget in the current multiannual 
financial framework and the increase in inflation rates. Therefore, it can be expected that 
continuing  the Programme with  the same  envelope would maintain  the  current level  of 
implementation with a risk of decrease due to the impact of possible future inflation. 

Under policy option 2 the Commission would discontinue the Programme. Although this 
would lead to a cost saving amounting to the programme’s budget (EUR 6.6 million for 
Pericles IV) many Member States, where resources are often limited, would not be able to 
organise international  and multidisciplinary  trainings  to  combat euro counterfeiting.  An 
absence of the Programme would impact ongoing initiatives and hinder the development 
of new relationships and networks, impeding transnational cooperation efforts. Indeed, the 
Programme offers significant EU added value by establishing and enhancing relationships 
and  cooperation  among  Member  States,  third  countries,  Union  institutions,  and 
international organisations that are beyond the reach of individual national authorities. The 
discontinuation of the Programme would impede the maintenance of an effective and well-
trained anti-counterfeiting network of experts that is needed to counter the continuing and 
upcoming  threats  involving  organised  crime  at  international  level,  such  as  new 
sophisticated counterfeits and their distribution on internet/ darknet. 

Under policy option 3, the Commission would propose the continuation of the Programme 
with an increased envelope taking into account the decrease in the envelope of the Pericles 
IV programme compared to the predecessor Pericles 2020 programme due to three main 
external factors: inflationary pressures, the budget cut faced in the current programming 
period (2021-2027) and the use of the operational budget for conducting the evaluations 
of the Programme. 

22 Mid-term evaluation of the Pericles IV programme – final report, annexed to Commission Staff Working Document SWD(2025) 44 

final. 

23 Data extracted from Programme statements, European Commission, website accessible here.  

15 

 
 
The evolution of the Pericles IV budget, as expressed in 2020 constant prices, shows that, 
due  to  the  abovementioned  factors,  the  budget  decrease  in  real  terms  stands  at  32%. 
Implementers  of  Pericles  IV  actions  were  largely  of  the  opinion  that  the  budget  is  not 
sufficient and that it results in a more limited set of implemented actions, as organisers 
have  to  choose  between  different  action  types.  Survey  responses  pointed  out  that  an 
increase of the Pericles Programme budget would be beneficial for eligible participants as 
it would allow them to implement more actions. Specifically, an increased budget would 
likely  expand,  and  restore  to  previous  levels,  the  number  of  actions  implemented  and 
participants trained. Interviews with several authorities of the Southeastern Europe region 
stressed the importance of the outreach that Pericles IV actions have. Overall, there is a 
need  to  involve  a  larger  number  of  expertsin  Pericles  actions  for  which  the  budget  is 
insufficient.  

The continuation of the current programme with an increased envelope would ensure its 
targeted  Commission  direct  actions 
continued  effectiveness,  also  by  ensuring 
complementing  Member  States'  actions,  and  would  sustain  the  long-term  effects  of  the 
programme  as  confirmed  by  its  interim  evaluation.    The  increased  budget  would  likely 
result in an increased number of implemented actions and number of action participants 
compared to the current Pericles IV programme. 

The increasing  popularity  of social media,  communication platforms, as well as market 
places  on  the  internet  and  darknet  have  made  new  distribution  channels  available  for 
distributing  counterfeit  euros.  These  means  of  distribution  make  it  more  attractive  for 
organised crime located in third countries, in some cases far away from the territory of the 
Union  (e.g.  China),  to  produce  counterfeit  euros  and  ship  them  to  the  euro  area.  These 
developments trigger the need for the Programme to make an extra effort to expand the 
anti-counterfeiting network in order to guarantee an appropriate worldwide protection of 
the  euro.  At  the  same  time,  the  development  of  Artificial  Intelligence  represents  an 
additional tool for organised crime to become more aggressive, as well as an opportunity 
for anti-counterfeiting agencies to further develop their technical and operational capacity. 
Finally, as mentioned above, the future introduction of the digital euro, could, depending 
on its architecture, expand the scope of the Programme to include the protection against 
counterfeiting, or counterfeiting related fraud, of this new type of currency. 

Against this background, the Commission concludes that policy option 3 is the preferred 
option  for  the  following  reason:  it  would  assure  the  fulfilment  of  the  objectives  of  the 
Programme  by  protecting  the  euro,  ensuring  up-to-date  framework  to  detect  euro 
counterfeiting,  establish  and  sustain  an  effective  and  well-trained  anti-counterfeiting 
network of experts and suppress counterfeit-related activities and fraud. 

16 

 
 
 
6.  RESULTS AND IMPACTS 

The preferred policy solution is to continue the programme in line with the current MFF 
programme with an increased number of actions and an increased number of participants 
compared to the Pericles IV Programme 24.  

In terms of expected results and impacts, the Pericles programme will help the beneficiaries 
– the competent authorities of Member States – in their work protecting the euro against 
counterfeiting and counterfeiting-related fraud through training, exchange of best practice 
and awareness raising. Target groups for the action of the programme will be all staff in 
public and private sector related to the protection of the euro. 

7.  MONITORING AND EVALUATION 

This initiative will be monitored through the rules defined in the performance framework 
for  the  post-2027  budget,  which  is  covered  in  a  separate  impact  assessment.  The 
performance framework provides for an implementation report during the implementation 
phase  of  the  programme,  as  well  as  a  retrospective  evaluation  to  be  carried  out  in 
accordance with  Article  34(3) of Regulation  (EU, Euratom) 2024/2509.  The evaluation 
shall be conducted in accordance with the Commission's Better Regulation Guidelines and 
will be based on indicators relevant to the objectives of the programme.  

24 This is on the basis of the current implementation rate of the programme which approaches a 100% consumption of its annual budget, 
reflecting a high demand for the programme, see Annual Activity Reports. 

17