COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the European Union Agency for Law Enforcement Cooperation (Europol), amending Regulation (EU) 2018/1726 and Regulation (EU) 2024/982, and repealing Regulation (EU) 2016/794
Date: 2026-06-24
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: Europol, fight against crime, operation of the Institutions, police cooperation, terrorism

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.6.2026  SWD(2026) 580 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT    Accompanying the document Proposal for a  REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the European Union Agency for Law Enforcement Cooperation (Europol), amending Regulation (EU) 2018/1726 and Regulation (EU) 2024/982, and repealing Regulation (EU) 2016/794 {COM(2026) 580 final} - {SEC(2026) 580 final} - {SWD(2026) 581 final} - {SWD(2026) 582 final}  
 
 
Table of contents 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................. 6 
1. 
2. 
PROBLEM DEFINITION ...................................................................................................... 9 
3.  WHY SHOULD THE EU ACT? .......................................................................................... 20 
4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 22 
5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ...................................................... 24 
6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 37 
HOW DO THE OPTIONS COMPARE? .............................................................................. 44 
7 
8 
PREFERRED OPTION ........................................................................................................ 47 
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ......................... 52 
ANNEX 1: PROCEDURAL INFORMATION .............................................................................. 53 
LEAD DG, DECIDE PLANNING/CWP REFERENCES ............................................................. 53 
ORGANISATION AND TIMING ................................................................................................. 53 
CONSULTATION OF THE RSB .................................................................................................. 54 
EVIDENCE, SOURCES AND QUALITY .................................................................................... 54 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................. 55 
ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................................ 71 
PRACTICAL IMPLICATIONS OF THE INITIATIVE....................................................... 71 
1. 
SUMMARY OF COSTS AND BENEFITS ......................................................................... 72 
2. 
3. 
RELEVANT SUSTAINABLE DEVELOPMENT GOALS ................................................. 92 
ANNEX 4: ANALYTICAL METHODS ....................................................................................... 93 
1.  METHODOLOGICAL APPROACH ................................................................................... 93 
COSTING METHODOLOGIES .......................................................................................... 94 
2. 
3. 
CAVEATS AND LIMITATIONS ........................................................................................ 96 
ANNEX 5: THE PREFERRED POLICY MEASURES ................................................................ 98 

ANNEX  6:  MONITORING  AND  EVALUATION  FRAMEWORK  FOR  THE  PREFERRED 
POLICY MEASURES ........................................................................................................ 106 

ANNEX 7: EVALUATION OF THE EXISTING POLICY AND LEGISLATIVE FRAMEWORK
 ............................................................................................................................................ 111 

ANNEX  8:  INVENTORY  OF  EXISTING  INFORMATION  SYSTEMS  AND  TOOLS  AT 
EUROPOL .......................................................................................................................... 148 
ANNEX 9: DNA MATCHING SERVICE ................................................................................... 151 
ANNEX 10: IMPACTS OF POLICY OPTIONS ......................................................................... 153 

 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AIRPOL 

Law enforcement network in the European aviation sector 

AMLA 

Authority  for  Anti-Money  Laundering  and  Countering  the 
Financing of Terrorism 

AP 

Analysis Project 

ATLAS 

European Cybersecurity Atlas 

CAAR 

Consolidated Annual Activity Report 

CEPOL 

European Union Agency for Law Enforcement Training 

CODIS 

Combined DNA Index System 

COSI 

Standing  Committee  on  Operational  Cooperation  on  Internal 
Security 

DSC 

Data Subject Categorisation 

EAS 

Europol Analysis System 

 EBCG Regulation 

 Regulation (EU) 2019/1896 on the European Border and Coast 
Guard Agency 

ECB  

European Central Bank 

ECCC 

European Cybersecurity Competence Centre  

EDPS 

European Data Protection Supervisor 

EEAS 

European External Action Service 

2 

 
 
 
EFECC 

European Financial and Economic Crime Centre 

EIFS 

European In-Flight Security Officer Network 

EIGE 

European Institute for Gender Equality 

EIS 

Europol Information System 

ELA 

European Labour Authority 

EMPACT 

European Multidisciplinary Platform Against Criminal Threats 

ENISA 

European Union Agency for Cybersecurity 

ENU 

Europol National Unit 

EPPO 

European Public Prosecutor’s Office 

EPRIS 

European Police Records Index System 

 ER 

Regulation (EU) 2016/794 (“Europol Regulation”)  

EUAA 

European Union Agency for Asylum 

EUCARIS 

European Car and Driving Licence Information System  

EUDA 

European Union Drugs Agency 

EU-SOCTA 

European  Union  Serious  and  Organised  Crime  Threat 
Assessment 

Eurojust 

European Union Agency for Criminal Justice Cooperation 

 Eurojust Regulation 

 Regulation (EU) 2018/1727 

Europol 

European Union Agency for Law Enforcement Cooperation 

3 

 
 
Europol Regulation  Regulation (EU) 2016/794 

eu-LISA 

European  Union  Agency  for  the  Operational  Management  of 
Large-Scale IT Systems in the Area of Freedom, Security and 
Justice 

FEPORT 

Federation of European Private Port Companies and Terminals 

FRA 

European Union Agency for Fundamental Rights 

Frontex 

European Border and Coast Guard Agency 

HRSN 

High Risk Security Network 

Interpol 

International Criminal Police Organization 

IOCTA 

 Internet Organised Crime Threat Assessment 

JAD 

Joint Action Days 

JHA 

Justice and Home Affairs 

JIT 

Joint Investigation Team 

JOAC 

Joint Operational Analysis Case Platform 

LED 

Law Enforcement Directive 

LEWP 

Law Enforcement Working Party 

MAOC (N) 

Maritime Analysis and Operations Centre (Narcotics) 

OLAF 

European Anti-Fraud Office 

OSINT  

 Open-Source Intelligence 

4 

 
 
OTF 

Operational Task Forces 

PD 

Programming Document 

QUEST 

Querying Europol Systems 

RAILPOL 

European Association of Railway Police Forces 

REFIT 

Commission’s Regulatory Fitness and Performance Programme 

SDG 

Sustainable Development Goal 

SIENA 

Secure Information Exchange Network Application 

SPoC 

Single Points of Contact  

TEU 

Treaty on European Union 

TFEU 

Treaty on the Functioning of the European Union 

UMF 

Unform Messaging Format 

5 

 
 
 
 
 
1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

The  EU  is  entering  a  new  security  era  marked  by  rapid  and  lasting  change.  The 
assumptions  that  shaped  Europe’s  internal  security  framework  even  a  decade  ago  are 
increasingly  being  overtaken  by  a  reality  in  which  threats  evolve  faster,  operate  across 
borders by default, and unfold across highly interconnected digital, economic, and societal 
systems. At the same time, serious and organised crime, terrorism, cybercrime, and hybrid 
threats  increasingly  converge,  combining  criminal  activity,  cybercrime  operations,  and 
economic interference. Their effects ripple across the EU, threatening economic stability, 
straining  institutional  resilience,  and  eroding  public  trust.  Geopolitical  instability, 
including Russia’s war of aggression against Ukraine, has further amplified these risks. 

As emphasised by the European Council in June 2025, “serious and organised crime, and 
terrorism, radicalisation and violent extremism, both online and offline, represent a major 
threat  to  European  citizens  and  the  security  of  Member  States”1,  requiring  the 
mobilisation  of  all  relevant  instruments  at  both  national  and  Union  level.  Their  impact 
reaches beyond security alone,  affecting  citizens’ sense of safety  and  confidence in  the 
EU’s ability to protect them. This concern is tangible, with 64% of EU citizens saying they 
are worried about the EU’s security in the coming years2. 

This evolving threat landscape unfolds within an area without internal frontiers, where free 
movement is a defining strength of the EU and where preparedness must match the scale 
and fluidity of cross-border threats. In such a space, security cannot be ensured by Member 
States  acting  alone.  Europe’s  security  architecture  therefore  combines  action  within 
national jurisdictions with coordination at Union level, where information can be brought 
together,  cross-border  connections  identified,  and  common  responses  enabled3.  This 
allows  threats  to  be  addressed  more  effectively  and  at  the  right  scale.  This  architecture 
relies on a broader ecosystem of EU bodies and agencies operating across different stages 
of  the  security  and  criminal  justice  chain.  Within  this  framework,  Europol  supports 
criminal intelligence analysis, operational coordination and information exchange between 
law  enforcement  authorities.  Eurojust  facilitates  judicial  cooperation  and  coordination 
between  prosecutors  and  judicial  authorities.  The  EPPO  investigates  and  prosecutes 
criminal  offences  affecting  the  financial  interests  of  the  Union,  while  OLAF  conducts 
administrative investigations into fraud, corruption and other irregularities affecting the 
EU budget. Frontex supports border management and contributes to situational awareness 
at the external borders, including in relation to cross-border crime. Europol increasingly 
operates  in  close  interaction  with  these  actors,  notably  through  information  exchange, 
analytical support, operational coordination and cross-system cooperation. 

These dynamics are reflected in Europol’s 2025 EU Serious and Organised Crime Threat 
Assessment4, which identifies a  fundamental transformation in the nature of  crime. 
Criminal networks5 are more resilient, technologically enabled, and transnational than ever 

1 European Council, Conclusions, 26-27 June 2025, EUCO 12/25, para. 41. 
2 Flash Eurobarometer FL550: EU Challenges and Priorities. 
3  Articles  67(3),  87(1),  and  88(1)  TFEU  establish  the  Union’s  competence  to  support  and  strengthen 
cooperation between Member States’ law enforcement authorities, including through Europol. 
4 Europol (2025) European Union Serious and Organised Crime Threat Assessment (EU-SOCTA).  
5 Europol (2024), Decoding the EU’s most threatening criminal networks. 

6 

 
 
 
before. They operate simultaneously across multiple jurisdictions and rely extensively on 
digital  infrastructures,  encryption,  financial  systems,  and  emerging  technologies  (for 
example cryptocurrencies or anonymisation tools) to organise, expand, and conceal their 
activities. Digitalisation has accelerated the scale, reach, and operational sophistication of 
criminal  and  terrorist  actors.  For  example,  organised  crime  groups  increasingly  use 
encrypted  communication  platforms,  online  marketplaces  and  digital  payments  to 
coordinate activities across borders. At the same time, the growing convergence between 
cybercrime6, financial crime7, and terrorism8 further increases the complexity of the threat 
environment. 

This  transformation  is  driving  a  change  in  how  security  is  organised  across  the  EU. 
Member  States  are  modernising  their  frameworks  and  deepening  cooperation9.  More 
fundamentally, 
law 
enforcement authorities and on the Union’s collective capacity to act. No single authority 
can  fully  capture  or  address  threats  that  develop  simultaneously  across  multiple 
jurisdictions and operational domains.  

these  developments  are  reshaping  expectations  placed  on 

In response and recognising that internal security is a shared European responsibility, the 
EU  has  articulated  an  ambitious  political  vision  to  strengthen  its  collective  security, 
notably through ProtectEU – a European Internal Security Strategy10. At the centre of 
this vision stands Europol, a key instrument of European cooperation in internal security. 
Established  two  decades  ago  to  support  cooperation  between  national  law  enforcement 
authorities, the agency has progressively evolved into a key operational and analytical hub. 
By enabling information exchange, criminal intelligence analysis and coordinated action 
against  cross-border  crime,  Europol  helps  Member  States  detect  criminal  networks, 
connect intelligence and act collectively against threats that no single  national authority 
could  address  alone.  Over  the  past  26  years,  Europol  has  evolved  from  a  coordination 
platform  into  a  central  operational  and  analytical  hub  at  the  heart  of  Europe’s  law 
enforcement architecture. By supporting thousands of operations each year and enabling 
millions  of  information  exchanges,  Europol  has  helped  transform  fragmented  national 
efforts into a more connected European response.11 

Europol  is  today  a  force  multiplier  for  European  security,  reflecting  a  shift  from 
cooperation  as an option to  cooperation as a necessity. This  level  of integration, once 
unimaginable,  has  been  enabled  through  successive  legal  reinforcements,12  building  on 
Member States’ willingness to pool expertise and capabilities to step up the fight against 
serious crime and terrorism. In doing so, it gives practical effect to the Treaties’ objective 
of ensuring a high level of security for the EU and its citizens in an area without internal 

6 Europol (2024), Internet Organised Crime Threat Assessment (IOCTA) 2024.  

ENISA (2025), ENISA Threat Landscape October 2025. 

7 Europol (2023), European Financial and Economic Crime Threat Assessment 2023. 
8 Europol (2025), European Union Terrorism Situation & Trend Report. 
9 For instance, the Netherlands, Belgium, Germany, France, Italy, Spain, Sweden have formed the European 
coalition to fight Organised crime. 
10 COM (2025) 148 final. 
11 In 2024 alone, Europol supported more than 3 300 operations, enabled over 2 million secure information 
exchanges, and provided access to its databases nearly 15 million times. 
12 Regulation (EU) 2016/794 was amended in 2022 by Regulation (EU) 2022/991 to address new security 
threats and in 2025 by Regulation (EU) 2025/2611 to effectively counter migrant smuggling. 

7 

 
 
 
frontiers13. As its mandate and tools have evolved, Europol has become a central pillar of 
a more integrated and operational European security architecture.  

Yet Europol’s success has also raised expectations about what European cooperation can 
deliver.  It  has  shown  that  collective  action  and  EU  support  can  extend  the  reach  and 
effectiveness of national authorities. In particular, the 2022 reform14 marked a decisive 
strengthening of Europol’s mandate, addressing urgent operational and legal constraints 
identified  at  that  time,  notably  concerning  large  datasets  and  cooperation  with  private 
parties.  However,  the  operational  and  technological  environment  has  evolved  at  a 
significantly  faster  pace  than  anticipated  at  the  time  of  the  2022  reform,  with  an 
exponential  increase  in  multi-source  data,  growing  expectations  regarding  proactive 
operational support, and the emergence of more integrated EU security frameworks and 
cooperation  models.  Threats  that  once  appeared  at  the  periphery  have  moved  to  the 
forefront, redefining the scale and intensity of the challenges facing the Union15. These 
developments have revealed structural limitations in the current mandate which go beyond 
the targeted adjustments introduced in 2022. 

This acceleration calls for safeguarding Europol’s ability to operate effectively in the face 
of new threats.  This  ambition  lies at  the heart of the Union’s political  priorities.  In her 
Political  Guidelines,  President  von  der  Leyen  called  for  making  Europol  “a  truly 
operational  police  agency”,  signalling  a  clear  commitment  to  equip  the  Union  with  the 
capabilities required to respond to a rapidly evolving threat environment. 

This impact assessment therefore examines how Europol’s legal framework, capabilities 
and resources need to evolve to ensure the Union remains able to address emerging security 
challenges  effectively,  with  a  stronger  focus  on  speed,  integration,  and  operational 
effectiveness. As technology redefines the nature of security itself, it is essential to put in 
place a  robust and future-proof  framework that  enables Europol  to  respond to  evolving 
threats, in close coordination with all relevant Union bodies and agencies, while remaining 
firmly grounded in the Union’s values and trusted by its citizens, including by maintaining 
a high level of data protection at Europol. 

This assessment takes place within a broader effort to strengthen the Union’s overall 
security  architecture  as  outlined  in  ProtectEU.  In  this  context,  several  legislative  and 
policy  initiatives  are  being  advanced  to  reinforce  the  EU’s  response  to  serious  and 
organised crime and terrorism. These include the recently adopted proposal establishing 
EU-wide  rules  against  the  trafficking  of  illicit  firearms16  and  the  forthcoming  proposal 
establishing  new  EU  rules  to  fight  organised  crime17.  At  the  same  time,  a  number  of 
operational and strategic initiatives have been put forward to support Member States in 

13 Article 88 TFEU defines Europol’s mission to support and strengthen cooperation between Member States’ 
law enforcement authorities in preventing and combating serious cross-border crime and terrorism. 
14 Regulation (EU) 2022/991 amending Regulation (EU) 2016/794. 
15 The prominence of technology-related drivers has increased significantly in Europol threat assessments. 
While references to AI and digital technologies in Europol’s EU-SOCTA 2021 were largely forward-looking, 
Europol’s EU-SOCTA 2025 places these technologies at the core of its analysis across multiple threat areas. 
16 2026/0059 (COD). 
17 Commission work programme 2026 – COM (2025) 870 final. 

8 

 
 
 
addressing evolving threats, including the new EU Drug Strategy18 and Action Plan against 
drug trafficking19, and the Agenda to prevent and counter terrorism20. 

It  also  contributes  to  improving  the  effectiveness  of  the  EU’s  unique  ecosystem  of 
specialised bodies and agencies, whose mandates are being revised21 to reflect evolving 
operational demands. Frontex22, Europol, Eurojust23, and the EPPO24 each fulfil distinct 
but  complementary  roles  across  the  security  and  criminal  justice  continuum.  Ensuring 
seamless  cooperation  and  information  exchange  between  them  is  essential  for  a  more 
integrated  and  effective  European  response.  In  practice,  these  interactions  increasingly 
require continuous operational coordination and interoperable information flows across the 
different  stages  of  detection,  intelligence  development,  investigation,  prosecution  and 
operational follow-up. This includes, for example, Europol’s analytical support to cross-
border  investigations  coordinated  by  Eurojust,  cooperation  with  the  EPPO  in  complex 
financial and organised crime investigations, exchanges with OLAF in relation to fraud 
patterns affecting the EU budget and support to Frontex regarding criminal intelligence 
linked to migrant smuggling, trafficking in human beings and other cross-border criminal 
activities. Closer cooperation and information exchange between relevant EU bodies and 
agencies  is  also  an  integral  part  of  the  comprehensive  review  of  the  EU's  anti-fraud 
architecture (AFA) to strengthen oversight and accountability25. 

The  revision  of  Europol’s  framework  also  takes  place  in  parallel  with  the  revision  of 
Chapter IX of the EU legal framework on data protection for EU institutions, bodies, 
offices and agencies (EUDPR)26. This provides an opportunity to ensure full coherence 
and alignment between Europol’s evolving operational mandate and the EU data protection 
framework27.  

In this evolving landscape, ensuring that Europol remains capable of supporting a strong 
and integrated European response to security threats remains strategically important for 
the Union. It  also  provides  an opportunity  to  ensure greater legal  coherence across the 
broader EU internal security framework, including ongoing reforms affecting information 

18 COM(2025) 743 final. 
19 COM (2025) 744 final. 
20 COM(2026) 101 final. 
21 In accordance with the Commission work programme 2026. 
22 The European Border and Coast Guard Agency (EBCGA), established by Regulation (EU) 2019/1896, is 
responsible for the implementation of European Integrated Border Management at the EU’s external borders. 
23 The EU Agency for Criminal Justice Cooperation (Eurojust), established by Regulation (EU) 2018/1727, 
provides support to prosecutors and judges, notably by supporting Joint Investigation Teams and facilitating 
cases involving a European Investigation Order.  
24 The European Public Prosecutor’s Office (the EPPO), established by Council Regulation (EU) 2017/1939, 
is the independent office responsible for investigating and prosecuting crimes against the financial interests 
of the EU. 
25  The  Commission  work  programme  2026  announced  a  comprehensive  review  of  the  EU's  anti-fraud 
architecture, building on the July 2025 Commission White Paper (COM(2025) 546 final). 
26 In particular, Chapter IX of Regulation 2018/1725. 
27 The objective is to streamline procedures and clarify roles, while fully maintaining a high level of data 
protection  in  line  with  EU  standards.  In  doing  so,  the  overall  reform  does  not  merely  preserve  existing 
standards but also simplifies the data protection framework by removing fragmentation, which should ensure 
a  unified  regime  across  EU  law  enforcement  and  criminal  justice  authorities  and  facilitate  information 
sharing between them. 

9 

 
 
 
exchange, interoperability, anti-fraud cooperation and operational  coordination between 
Union bodies and agencies. 

2.  PROBLEM DEFINITION 

In  today’s  security  environment,  effective  cooperation  between  law  enforcement 
authorities and strong EU-level coordination have become essential to complement and 
reinforce Member States’ efforts. 

The importance of strong European cooperation is reflected in the European Police Chiefs 
Convention  of 202328 and the joint  call  by European  Police  Chiefs29 in  2025 to  further 
strengthen Europol’s role. 

Despite its strengthened mandate, Europol is not fully equipped to fulfil its mission in 
this evolving environment. As highlighted in the Commission report pursuant to Article 
68(3) of the Europol Regulation30 and in the evaluation of Europol31, the Agency faces 
legal,  operational,  and  structural  constraints  that  limit  its  ability  to  provide  timely, 
comprehensive, and actionable support to Member States. Persistent information gaps 
hinder the development of a complete criminal intelligence picture of cross-border threats. 
Uneven and fragmented operational cooperation and coordination with Member States 
limit  the  added  value  of  Europol’s  support  for  the  action  of  national  authorities  on  the 
ground.  Limitations  in  technical  capabilities,  specialised  expertise,  and  preparedness 
reduce the ability to respond effectively to increasingly sophisticated and technologically 
enabled  criminal  activity.  Together,  these  constraints  reduce  Europol’s  operational 
effectiveness and its capacity to deliver its full added value.  

As  a  result,  a  structural  gap  is  widening  between  the  Union’s  security  ambitions  and 
Europol’s  ability  to  fully  deliver  on  its  mission  in  practice.  The  scale,  speed,  and 
sophistication  of  emerging  threats  are  placing  demands  on  Europol  that  its  current 
framework struggles to meet. When criminal intelligence cannot be fully connected and 
operational responses cannot be coordinated in time, critical opportunities to detect and 
disrupt cross-border criminal activity are lost, weakening the EU’s ability to respond. 

2.1.  What are the problems? 

2.1.1 Problem 1: Europol and national authorities face persistent information gaps 
when investigating cross-border crimes and identifying threats. 

28 Future of policing main focus as police chiefs meet at Europol | Europol. 
29  European  Police  Chiefs  (20  April  2025)  Joint  Statement  by  the  European  Police  Chiefs  on  the  Future 
Development of Europol, Kraków. 
30 COM(2025) 752 final. 
31 See Annex 7.  

10 

 
 
 
 
Serious  and  organised  crime,  terrorism  and  hybrid  threats  increasingly  operate  across 
jurisdictions  and  digital  environments.  Effective  investigations  therefore  depend  on  the 
ability of national authorities and Europol to access and connect relevant information. 

However, Member States’ law enforcement agencies do not share sufficient relevant data 
with  Europol.  Therefore,  information  available  at  EU  level  remains  uneven  and 
incomplete32, affecting Europol’s analytical capabilities and leaving investigators without 
a  complete  picture  of  criminal  networks  operating  across  borders.  As  a  result,  parallel 
investigations may take place without awareness of related cases in other Member States, 
and links between suspects, criminal activities or financial flows may remain undetected. 
This reduces the effectiveness of cross-border investigations and limits Europol’s ability 
to  identify  connections  between  cases,  delaying  the  detection  of  organised  crime 
structures and weakening the capacity to anticipate evolving criminal threats. 
Data contributions via the Secure Information Exchange Network Application33 (SIENA) 
and the Europol Information System34 (EIS) vary significantly, with a limited number of 
Member States providing a disproportionate share of operational data, while contributions 
from other Member States are limited. This uneven distribution creates structural blind 
spots that can be exploited by cross-border criminal networks. In addition, even where data 
are shared, they are often incomplete or lack key identifiers, that is, are not provided in 
the structured format that would allow automatic comparison of records for reliable cross-
matching35. Investigators are often confronted with inconsistent data quality, or with data 
that is collected or stored in different formats from their own and hence cannot be used in 
the  investigators’  own  case  management  systems  without  manual  processing.  These 
differences cost time and reduce usability, directly affecting national investigations. 

Moreover, Europol faces operational constraints in processing large datasets relevant 
for  cross-border 
the  application  of  Data  Subject 
Categorisation  (DSC)  under  the  Europol  Regulation36  delays  the  intake  and  analysis  of 
large volumes of data, as the categorisation of large or unstructured datasets often requires 
manual  intervention  and  additional  proportionality  assessments.  In  time-sensitive 

investigations.  In  particular, 

32  Key  data  relating  to  suspects,  financial  flows,  communication  identifiers,  travel  movements  or  digital 
accounts may be held by different Member States without being connected at EU level. 
33 In 2025, the share of SIENA messages exchanged by Member States where Europol was involved varied 
from 24% to 56% across Member States. For more information on SIENA, see Annex 8. 
34 As of 31 December 2025, around 90% of the objects stored in the EIS had been introduced by Member 
States representing around 25% of the EU population, while Member States representing more than 50% of 
the  EU  population  contributed  to  less  than  5%  of  the  objects  shared  by  EU  Member  States.  For  more 
information on the EIS, see Annex 8. 
35 In 2025, overall, 18% of messages received by Europol contained structured information, varying across 
Member States from 0.1% to 21%. For more information on cross-checking, see Annex 8. 
36 Under Union law, both Europol and Member States must perform DSC for their own processing of personal 
data  in  criminal  investigations,  regardless  of  whether  the  data  are  subsequently  transferred  to  Europol. 
However, the legal requirements applicable to Europol differ from those applied by Member States, Eurojust 
or the EPPO. Under the Europol Regulation, Europol must classify individuals whose personal data appear 
in  a  dataset  into  categories  defined  in  Annex  II  of  that  Regulation  (e.g.  suspects,  associates,  victims  or 
witnesses) before the data can be fully processed. 

11 

 
 
 
investigations,  this  limits  Europol’s  ability  to  rapidly  identify  links  between  suspects, 
detect emerging criminal networks and provide timely operational support37.  

2.1.2 Problem 2: Europol’s operational support remains limited and fragmented 

Crime  is  borderless  and  the  most  threatening  criminal  networks  in  the  EU  affect  all 
Member States38.  Despite  its  central  role in  enabling a  necessary  cross-border response 
through EU-level law enforcement cooperation, Europol’s operational support to Member 
States – including through cooperation with partners, in particular EU bodies and agencies 
– remains limited, fragmented and uneven.  

In particular, cooperation between Europol and other EU bodies and agencies is marked 
by  weak  information  exchange  and  insufficient  institutionalisation,  which  limits  the 
potential for timely and comprehensive EU-level responses to cross-border crime. 
Across  Member  States,  engagement  with  Europol39  varies  significantly  in  terms  of  the 
frequency of operational requests, participation in analytical projects and operational task 
forces, and use of Europol’s information systems40. The efficient and comprehensive use 
of  Europol’s  support  often  depends  on  national  law  enforcement  agencies’  knowledge 
about the available services and their possible added value for a given investigation. As a 
result, Europol’s operational support, including analytical products, criminal intelligence 
development and operational coordination, is not always utilised in a consistent and timely 
manner  in  ongoing  investigations41.  The  Agency’s  capabilities  are  therefore  not  always 
deployed to their full potential in support of national authorities dealing with serious and 
organised  crime  with  a  cross-border  dimension.  This  significantly  affects  the  overall 
effectiveness of EU-level support for complex cross-border investigations. 

At the same time, national law enforcement authorities across the Union remain unevenly 
equipped  with  the  advanced  specialised  and  technical  expertise  required  to  address 
increasingly  technology-enabled  forms  of  crime.  While  Member  States  continue  to 

37  Section  (3)  on  criminal  investigations  of  the  Commission  report  evaluating  the  operational  impact  of 
Regulation (EU) 2022/991, adopted pursuant to Article 68(3) of Regulation (EU) 2016/794 highlights that 
Europol “cannot process, nor even store, the personal data of individuals who do not fall under [the relevant] 
categories”.  This  requirement  creates  a  significant  administrative  and  analytical  burden  in  practice, 
particularly when handling large or unstructured datasets originating from multiple sources. Such data often 
do not easily correspond to predefined categories, complicating the identification of relevant data subjects 
and potentially slowing the progress of investigations. As a result, the intake and analysis of large datasets 
may  be  delayed  at  critical  early  stages  of  investigations,  limiting  Europol’s  ability  to  identify  relevant 
individuals, detect connections between cases and conduct analytical work on bulk data, including at the 
request of Member States. 
38 Europol (2024) Decoding the EU’s most threatening criminal networks, p. 44. 
39 For instance, only one of 23 Europol Member States which responded to the targeted survey for national 
law enforcement authorities reported having received more than five requests by Europol to initiate, conduct 
or coordinate a criminal investigation under Article 6 ER. See Annex [No], Study supporting the evaluation 
and the impact assessment of the Europol Regulation. 
40 In 2025, more than 90% of the searches carried by EU Member States in Europol data had been carried 
out by Member States representing less than 20% of the EU population. 
41 ICF (March 2026), Draft Final Report of the Study supporting the evaluation and the impact assessment 
of the Europol Regulation, Figure 35 and Questions 60-69 dedicated to Europol’s operational centres. 

12 

 
 
 
 
strengthen their capabilities, tackling these threats increasingly requires highly specialised 
tools, expertise and analytical capacities that are costly to develop and maintain at national 
level.  This  has  led  to  growing  reliance  on  Europol’s  specialised  technical42  and 
innovation43 support, including training and operational assistance in areas such as digital 
forensics,  artificial  intelligence,  and  cryptocurrency  investigations44.  Demand  for  such 
support  continues  to  grow  faster  than  Europol’s  current  ability  to  provide  it,  limiting 
Europol’s ability to respond effectively to the operational needs across the Union45. As a 
result,  Europol  cannot  always  scale  its  support  in  line  with  the  increasing  operational 
demands from Member States, leaving capability gaps at EU level in areas where collective 
support would be most efficient. 

Operational support limitations also stem from and extend to cooperation with relevant 
EU  bodies  and  agencies  responsible  for  preventing  and  combating  cross-border  crime 
within their respective mandates. 
Since the European Public Prosecutor’s Office (EPPO)46 became operational in 2021, 
Europol  and the EPPO have significantly strengthened their operational  cooperation  on 
complex cross-border investigations affecting the Union’s financial interests.47 Over recent 
years, the growing scale and complexity of EPPO investigations have increased demand 
for  Europol’s  analytical  support,  including  cross-checking  operational  data  against 
Europol  databases,  identifying  links  across  cases,  and  enriching  them48.  However,  the 
current  legal  framework  governing  the  exchange  and  use  of  operational  information 
between  Europol  and  the  EPPO  limits  the  extent  of  the  support  Europol  can  provide, 
including by analysing relevant datasets49 and identifying connections between cases. At 

for 

they 

the  digital 

infrastructures 

rely  on.  See, 

42 ICF (March 2026) Draft Final Report of the Study supporting the evaluation and the impact assessment of 
the Europol Regulation, interviews with national authorities and Europol .  
43  For  example,  the  number  of  operations  supported  by  the  Europol  Innovation  Lab  more  than  doubled 
between 2024 and 2025.  
44 Cybersecurity skills shortages further lead to enhanced cyber inequity, creating systemic exposure for law 
enforcement  authorities  and 
instance, 
WEF_Global_Cybersecurity_Outlook_2026.pdf. 
45 87% of respondents mentioned specialised technical skills as an area where Europol should play a stronger 
role  in  training  and  capacity  building.  See  Figure  70,  Study  supporting  the  evaluation  and  the  impact 
assessment  of  the  Europol  Regulation.  Furthermore,  86%  of  respondents  indicated  there are  areas  where 
Europol’s training offer dedicated to specialised skills should be expanded, see Figure 71, ibid. 
46 In accordance with the Council Regulation (EU) 2017/1939 of 12 October 2017 implementing enhanced 
cooperation on the establishment of the [EPPO], the EPPO is responsible for investigating, prosecuting and 
bringing  to  judgment  the  perpetrators  of,  and  accomplices  to,  criminal  offences  affecting  the  financial 
interests of the Union which are provided for in Directive (EU) 2017/1371. 
47 Article 20a(2) of the Europol Regulation provides that “Europol shall support the investigations of the 
EPPO and cooperate with it, by providing information and analytical support”. Europol supported six EPPO 
cases in 2021, 28 cases in 2022, 47 cases in 2023 and 83 cases in 2024. 
48  Europol’s  European  Financial  and  Economic  Crime  Centre  (EFECC)  provides  specialised  analytical 
support. EPPO estimates for the period 2028-2034 foresee substantial support needs from Europol, including 
data  cross-checks  against  Europol  databases  (600-1200  cases),  operational  analytical  support  (500-1200 
investigations),  digital  forensics  support  (80-150  cases),  and  operational  deployments  (100-250 
investigations). 
49 In this context, it may be noted that the Commission proposal to amend Regulation (EU) No 904/2010 on 
administrative cooperation in the field of VAT envisages facilitating access for the EPPO and the European 

13 

 
 
 
 
the same time, large volumes of operational data held by the EPPO50 cannot always be 
effectively  used  by  Europol  for  its  activities  due  to  mandate  limitations.  This  reduces 
Europol’s  ability  to  support  the  investigations  conducted  by  national  law  enforcement 
authorities and provide them with comprehensive analytical support. 

Cooperation between Europol and Eurojust also remains limited in practice, particularly 
due to the very limited exchange of operational information between the two agencies51. 
As a result, Europol receives only a very limited amount of information from Eurojust, 
constraining its ability to detect links between cases handled by judicial authorities and 
those  analysed  within  Europol’s  operational  and  analytical  activities.  In  addition,  gaps 
persist in the EU-level support available to national authorities seeking to obtain electronic 
evidence in investigations today,52 as there is currently no stable and structured EU-level 
framework for operational cooperation between Europol and Eurojust to support Member 
States in this regard53.  

More  broadly,  structured  EU-level  cooperation  in  support  of  investigations  into  cross-
border crime remains uneven across the EU’s internal security architecture. Exchanges of 
information between Europol and other relevant EU actors, including Frontex in the areas 
of  migrant  smuggling  and  trafficking  in  human  beings,54  the  Anti-Money  Laundering 
Authority  (AMLA)  in  financial  crime55,  and  EU  cybersecurity  actors,  such  as  the  EU 
Agency  for  Cybersecurity  (ENISA),56  CERT-EU  and  the  European  Cybersecurity 

Anti-Fraud Office (OLAF) to certain VAT information for the purposes of investigating offences affecting 
the  Union’s  financial  interests  (Proposal  for  a  Council  Regulation,  COM(2025)  685  final).  In  light  of 
Europol’s strengthened role in supporting EPPO investigations, the possible extension of access  to similar 
information for Europol could also be considered. 
50  The  EPPO’s  Case  Management  System  contains  rapidly  increasing  volumes  of  operational  data.  For 
example, approximately 1 406 terabytes of data are stored in relation to three investigations alone, illustrating 
the scale of data potentially relevant for operational analysis and cross-case link detection. 
51 Both the Europol Regulation (Article 21) and the Eurojust Regulation  (Article 49) provide for indirect 
information exchange between the two agencies on the basis of a hit/no-hit system. In practice, exchanges 
have  remained  minimal.  Between  May  2023  and  August  2025,  Europol  sent  108  SIENA  messages  to 
Eurojust containing 2 081 entities for link detection, resulting in eight hits at Eurojust, none of operational 
relevance to Europol. 
52 According to the European Commission, “more than half of all investigations today involve a cross-border 
request to access electronic evidence”, i.e., “data  in electronic form that are relevant  in investigating and 
prosecuting  criminal  offences”.  Notably,  “electronic  evidence  is  needed  in  around  85%  of  criminal 
investigations, and in two-thirds of these investigations there is a need to request evidence from online service 
providers based in another jurisdiction. The number of requests to the main online service providers grew by 
70% in the period between 2013 and 2016”, Frequently Asked Questions: New EU rules to obtain electronic 
evidence Brussels, 17 April 2018. 
53 Since 2017, Europol and Eurojust have jointly supported EU law enforcement and judicial authorities in 
obtaining  electronic  evidence  from  service  providers  located  in  other  jurisdictions  through  the  SIRIUS 
Project. The initiative provided operational guidance, specialised training, investigative tools and a platform 
facilitating exchanges between authorities and service providers. The SIRIUS Project has been funded by 
the European Commission’s Service for Foreign Policy Instruments (FPI). 
54 Improvements in the exchange of operational information between Europol and Frontex are addressed in 
the impact assessment for the upcoming revision of the EBCG Regulation. 
55 Reciprocal exchange of operational information between AMLA and Europol is currently not foreseen. 
56 ENISA is established under Regulation (EU) 2019/881 (Cybersecurity Act) and plays a central role in EU 
cybersecurity cooperation. Its mandate was further expanded by Directive (EU) 2022/2555 (NIS2 Directive), 
which assigns the Agency key tasks in supporting operational cooperation and situational awareness across 
the Union’s cybersecurity architecture. 

14 

 
 
 
Competence  Centre  (ECCC)57,  remain  limited,  reducing  the  potential  for  coordinated 
responses to cross-border and cyber-enabled crime. 

2.2.  What are the problem drivers? 

2.2.1 Problem 1: Europol and national authorities face persistent information gaps 
when investigating cross-border crimes and identifying threats. 

Driver  1.1:  Regulatory,  legal  and  procedural  constraints  affecting  information 
sharing 

Divergent national criminal procedure laws and differing interpretations of necessity and 
proportionality  drive  selective  and  inconsistent  information  sharing  between  Member 
States  and  Europol.  Political  sensitivities,  historical  cooperation  patterns  and  varying 
levels  of  trust  in  Europol’s  handling  of  sensitive  data  (e.g.  terrorism,  minors,  financial 
crime or migration cases) further reinforce conservative practices among Member States. 

As a result, information exchange remains uneven and incomplete, with Member States 
sometimes limiting or delaying transmission of operational data, even where cooperation 
would  be  legally  possible  and  operationally  justified.  This  is  reflected  in  significant 
variations in Member States’ contributions to Europol systems and in the uneven use of 
information exchange channels. 

Driver 1.2: Operational and technical limitations in data automation, integration and 
standardisation hampering information exchange 

Member States’ law enforcement IT systems differ significantly in terms of automation, 
connectivity, and their ability to produce structured, interoperable data. Only a few operate 
automated data loaders to transmit data to Europol58, while others rely on manual processes 
or,  in  some  cases,  bypass  EU  channels  altogether.  Europol’s  core  systems  remain 
underutilised59,  reducing  cross-border  visibility  and  EU-level  situational  awareness. 
Therefore, the available statistics point to significant disparities in connectivity and data 
transmission practices across Member States. 

Even  where  connectivity  exists,  most  operational  information  is  transmitted  in 
unstructured  formats  requiring  manual  processing.  The  lack  of  common  data  models, 
standardised  templates  and  automated  workflows  slows  ingestion,  cross-checking  and 
analysis. These technical limitations reduce scalability and prevent near-real-time criminal 
intelligence  production,  including  for  biometric  and  multimedia  data,  thereby  limiting 
Europol’s analytical capacity and operational added value. 

Driver 1.3: Regulatory, legal and procedural constraints affecting data processing 

57 SWD(2026) 11 final. 
58 In 2025, only 14 Member States operated data loaders. 
59 For example, in 2025, only 15 Member States allowed their users to perform direct searches in Europol 
data via a technical application called QUEST. For more information on QUEST, see Annex 8. 

15 

 
 
 
Compliance requirements related to data protection rules, in particular regarding DSC60, 
operate in practice as structural constraints on information processing. 

The requirement to apply DSC ex ante, combined with intensive procedural safeguards, 
slows down or in some cases prevents the timely processing and further handling of data, 
particularly in fast-moving or data-intensive investigations. Europol experience indicates 
that the application of DSC to large datasets can require significant time and specialised 
resources before operational analysis can begin. 

While legally robust, these procedural requirements reduce operational agility and delay 
access to cross-border intelligence. As a consequence, Europol and Member States may 
face constraints in fully exploiting lawfully available data, even where processing would 
be operationally necessary and proportionate. 

Driver  1.4:  Structural  and  operational  shift  in  the  criminal  data  and  information 
environment 

The digital transformation of crime has fundamentally changed the nature and volume of 
information  relevant  to  criminal  investigations.  Criminal  networks  increasingly  operate 
across  digital  platforms,  financial  systems  and  communication  infrastructures  spanning 
several  jurisdictions,  generating  large  volumes  of  fragmented  operational  data  held  by 
different authorities. The growing use of technologies such as artificial intelligence further 
increases the speed, scale and complexity of criminal activity61.  

As a result, effective responses to serious and organised crime increasingly depend on the 
rapid  exchange,  correlation  and  analysis  of  information  across  national  and  EU-level 
systems. In practice, key elements of an investigation are often dispersed across several 
Member  States  and  authorities,  making  it  necessary  to  connect  different  pieces  of 
information – such as suspects, communication data or financial transactions – in order to 
detect  cross-border  criminal  networks.  However,  existing 
information-sharing 
mechanisms were largely designed for more limited data volumes and slower operational 
cycles.  They  rely  mainly  on  message-based  exchanges  between  authorities,  where 
information is shared case by case rather than analysed collectively across systems. This 
can  make  it  harder  to  identify  links  between  investigations  and  to  build  a  timely  and 
comprehensive EU-level criminal intelligence picture. 

2.2.2 Problem 2: Europol’s operational support remains limited and fragmented 

60 Data Subject Categorisation (DSC) refers to the requirement under the Europol Regulation to assign each 
personal data record processed by Europol to a specific category of data subject (such as suspects, convicted 
persons,  potential  future  offenders,  victims,  witnesses  or  other  contacts  and  associates),  together  with 
corresponding conditions governing the processing and retention of such data. This categorisation aims to 
ensure compliance with EU data protection rules but can limit the ability to process certain datasets where 
the status of individuals cannot be clearly determined at the time the data are received. 
61 The 2025 European Union serious and organised crime threat assessment, (EU-SOCTA 2025). 

16 

 
 
 
Driver 2.1: Operational limited awareness of Europol’s operational support 

Awareness among Member States of the full range of Europol’s operational tools, services 
and capabilities remains uneven62. As the use of Europol’s operational support is voluntary 
and initiated at  national  level63, national  authorities may not  always consider Europol’s 
involvement at an early stage of investigations.64 This results in delayed engagement with 
the Agency and limits the timely exchange of information, the early identification of cross-
border links, and the effective use of Europol’s capabilities to support coordinated EU-
level  responses  to  serious  and  organised  crime.65  Available  operational  data  show 
important differences between Member States in the frequency and timing of requests for 
Europol operational support. 

Driver  2.2:  Operational  and  capability-related  constraints  limiting  the  tailoring  of 
Europol’s support to national investigative needs 

While Europol provides operational support to Member States, the support provided is not 
always  sufficiently  tailored  to  the  specific  needs66,  legal  frameworks  and  evidentiary 
requirements of national investigations. As a result, the analytical outputs or information 
provided by Europol may not always be directly usable in national proceedings. In some 
cases, national authorities must repeat investigative or analytical steps to produce evidence 
that complies with national procedural requirements. This creates inefficiencies, increases 
the  workload  for  national  investigators  and  reduces  the  overall  effectiveness  of  the 
operational support provided by Europol.  

At the same time, the rapid digitalisation of crime requires investigators to use increasingly 
specialised  tools,  technologies  and  skills,  including  in  areas  such  as  digital  forensics, 
artificial  intelligence  and  cryptocurrency  investigations.  Europol’s  current  framework 
limits its ability to develop and provide such tools and specialised training at scale across 
the Union, constraining its capacity to support technology-enabled investigations. Demand 
for  specialised  operational  support  and  advanced  analytical  capabilities  has  increased 
significantly in recent years 

62 ICF (March 2026), Draft Final Report of the Study supporting the evaluation and the impact assessment 
of the Europol Regulation, Annex 10.3.1. 
63 Under  the Europol Regulation, Europol may support investigations, coordinate operational actions and 
participate in Joint Investigation Teams, but it cannot initiate investigations or conduct operational activities 
without the agreement of the Member States concerned. 
64  Evaluation  evidence,  from  the  study  supporting  the  evaluation  and  impact  assessment  of  the  Europol 
Regulation, indicates that Europol’s operational support is often mobilised only at a relatively advanced stage 
of national investigations. 
65 “Case study evidence on Europol’s operational centres confirms that the agency’s support often focuses 
on strengthening ongoing investigations rather than shaping investigative strategies from the outset”, ibid. 
66 ICF (March 2026) Study supporting the evaluation and the impact assessment of the Europol Regulation 
- “Limited timeliness of replies via SIENA” is mentioned as a barrier by 40% of respondents, Figure A7.27, 
Annex 7. Interviews with national authorities highlighted the time required to obtain analytical outputs from 
Europol can be significant in cases involving large or technically complex datasets. 

17 

 
 
 
Driver  2.3:  Limited  capacity  for  systemic  modernisation  of  law  enforcement 
capabilities 

In  many  Member  States,  organisational,  legal,  and  procurement  constraints  limit  the 
systematic  uptake  and  scaling  of  innovation,  resulting  in  fragmented  development  and 
uneven  deployment  of  modern  investigative  tools.  Barriers  include  overlapping 
responsibilities across national, regional and local authorities, slow procurement processes, 
and rigid administrative procedures. As a result, innovative solutions are often developed 
within  short-term  projects  or  pilot  initiatives  but  struggle  to  transition  into  sustainable 
operational  capabilities  deployed  at  EU  level67.  This  creates  disparities  in  operational 
capabilities across the Union and even stronger reliance on Europol to provide specialised 
expertise  and  technical  support  in  cross-border  investigations.  .  Despite  the  growing 
demand68,  Europol’s  role  in  supporting  innovation  and  specialised  capabilities  remains 
limited in scale, constraining its ability to systematically strengthen operational capabilities 
across Member States69. This includes limitations linked to available specialised expertise, 
technical capacity and scalable operational support resources. 

Driver  2.4:  Regulatory,  legal  and  operational  constraints  on  information  sharing 
between Europol and the EPPO 

The current  legal  framework does not  provide a sufficiently robust basis for systematic 
operational cooperation between Europol and the EPPO70. As a result, cooperation largely 
relies  on  ad  hoc  requests  and  case-by-case  arrangements,  limiting  the  systematic 
mobilisation of Europol’s analytical support for EPPO investigations and preventing the 
full  exploitation  of  complementarities  between  Europol  and  the  EPPO71.  In  addition, 
Europol cannot share relevant operational information directly with the EPPO without the 

67 Comparative analysis shows that scaling occurs only where an EU actor combines a clear legal mandate 
with an operational or coordinating role and sufficient convening power. Where such a mandate is absent, 
innovation  remains  locked  at  pilot  level  by  design,  regardless  of  technical  maturity  or  demonstrated 
usefulness. Study on strengthening EU-funded security research and innovation – 20 years of EU-Funded 
Civil Security R&I (DG HOME, 2025)  
68 See Joint Statement by the European Police Chiefs on the Future Development of Europol. Moreover, the 
results of the public consultation show strong support for enhancing Europol’s technological and innovation 
capabilities,  see  the  factual  summary  report  registered  under  Ares(2026)2806442  and  published  at 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14638-Law-enforcement-
cooperation-new-Europol-regulation-proposal-/public-consultation_en. 
69 For instance, Europol’s Innovation Lab and EU-funded projects run “sandboxes” to experiment with AI 
algorithms; however, due to data protection constraints, these activities cannot rely on real operational crime 
data. 
70  The  EPPO  (November  2025),  Note  [to  DG  HOME  of  the  European  Commission]  on  improving  the 
cooperation between the EPPO and Europol. See also ICF (March 2026), Draft Final Report of the Study 
supporting  the  evaluation  and  impact  assessment  of  the  Europol  Regulation,  sub-driver  2.5.3  ‘Legal  and 
mandate limitations hinder cooperation with EPPO’. 
71 ibid.  

18 

 
 
 
consent of the Member State that provided the data72, which significantly delays access to 
information relevant for EPPO investigations73. 

Driver  2.5:  Weak 
cooperation between Europol and other EU bodies and agencies 

information  exchange  and 

insufficiently 

institutionalised 

Despite  the  growing  need  for  seamless  cooperation  across  the  EU’s  internal  security 
architecture74,  crucial  information  exchange  between  Europol  and  other  relevant  EU 
bodies  and  agencies,  including  Frontex75,  AMLA76,  Eurojust,77  and  OLAF,78  remains 
weak. Existing exchanges remain uneven and are often dependent on ad hoc arrangements. 
This affects the completeness of the EU-level criminal intelligence picture that Europol 
can  provide  in  support  of  Member  State  national  authorities.  Moreover,  broader 
cooperation  between  Europol  and  other  relevant  EU  bodies  and  agencies,  such  as 
Eurojust79 and ENISA80, is obstructed by insufficient institutionalisation. This hinders the 
scope,  foreseeability  and  sustainability  of  coordinated  support  benefiting  the  national 
authorities of EU Member States.81  

72 In accordance with the data ownership principle established in Article 19 ER. 
73 Although the EPPO may obtain the same information directly from the Member State concerned under 
Regulation  (EU)  2017/1939,  this  indirect  route  duplicates  exchanges  and  may  delay  access  to  relevant 
information,  in  some  cases  by  up  to  two  months,  as  indicated  by  the  EPPO  at  the  third  thematic  expert 
workshop on the future of Europol, see Annex II. 
74 Communication from the Commission to the European Parliament, the Council, The European economic 
and social committee and the Committee of the regions on ProtectEU: a European Internal Security Strategy 
COM(2025) 148 final. 
75 The data on the debriefing interview reports sent by Frontex to Europol, which amounted only to 40 in 
2025, exemplifies  the overly limited  exchange of operational  information between the two  agencies.  The 
Commission has analysed the problem driver in the impact assessment for the revision of Frontex and may 
accordingly propose to address the identified shortcomings in Article 90 of the ECBGA Regulation and its 
implementation through the upcoming legislative initiative on Frontex. 
76 The recent reform of the EU anti-money laundering framework created a new institutional architecture 
centred on AMLA, but Europol currently lacks a formal interface to exchange operational information with 
AMLA, which in turn contributes to the fragmentation of the EU financial intelligence landscape. See sub-
driver 2.5.4 ‘Unclear division of roles and weak operational integration between Europol and AMLA’, Study 
supporting the evaluation and impact assessment of the Europol Regulation, interim report, January 2026. 
77 See footnote 51 on the implementation of indirect information exchange on the basis of a hit/no-hit system; 
‘Implementation challenges’ and the box summarising the results of the targeted survey for EU bodies and 
agencies in Annex 2 of the Impact Assessment for the revision of Eurojust. 
78  See,  for  instance,  European  Court  of  Auditors,  Special  Report  26/2025  ‘EU  bodies  fighting  fraud’, 
concluding  that,  “while  the  mandates  of  OLAF,  the  EPPO,  Eurojust  and  Europol  are  clearly  defined, 
weaknesses  remain  in  terms  of  exchange  of  information”.  The  Commission  may  propose  to  strengthen 
information exchange between OLAF, the EPPO, Eurojust and Europol as part of the upcoming AFA review. 
79 See also the impact assessment for the revision of Eurojust. 
80 The Commission has proposed closer cooperation between Europol and ENISA to improve cybersecurity 
preparedness and response to ransomware incidents as part of the Cybersecurity Act 2 (COM(2026) 11 final). 
81 For instance, SIRIUS remains a project in nature and thus its mission and sustainability are varying and 
uncertain as they depend on the types and timings of available EU funding. Notably, further to a change of 
the funding source (Contribution agreement NDICI THREATS FPI/2024/OPSYS CT NR 700002618 as of 
1 January 2025), the beneficiaries of the Project are now the national law enforcement and judicial authorities 
of  third  countries,  while  the  dire  need  expressed  by  the  national  authorities  of  the  EU  Member  States  to 

19 

 
 
 
 
2.3.  How likely is the problem to persist? 

The overall problem is structural and likely to persist, as it is driven by long-term trends 
in the scale, complexity, and digitalisation of serious and organised crime. This will require 
more timely criminal intelligence, closer operational coordination across Member States 
and  Europol,  and  access  to  advanced  analytical  and  technical  capabilities.  At  the  same 
time,  Europol’s  ability  to  respond  effectively  will  continue  to  be  shaped  by  its  legal 
framework,  technical  infrastructure,  and  available  expertise,  which  cannot  evolve 
automatically in line with operational needs. As cooperation increasingly involves a wider 
range of actors, including EU bodies and agencies, the need for effective coordination and 
specialised support at European level will further grow. Without adaptation, these trends 
are likely to widen the gap between operational needs and Europol’s capacity to support 
Member States effectively. 

First, data-related challenges are expected to intensify sharply as the volume, speed, 
and  complexity  of  operational  data  continue  to  accelerate.  Criminal  investigations  are 
increasingly  driven  by  digital  evidence,  encrypted  communications,  and  data  dispersed 
across multiple jurisdictions and platforms, generating vast and fragmented datasets. At 
the  same 
limited 
in 
interoperability, and constraints in processing large and complex datasets will continue to 
hinder Europol’s ability to fully integrate and exploit this information. Without addressing 
these structural data gaps, Europol risks falling behind the scale and pace at which criminal 
networks  operate,  limiting  its  capacity  to  generate  a  complete  and  timely  European 
criminal intelligence picture and to detect critical cross-border links. 

information  sharing  practices, 

time,  persistent  differences 

At the same time, Europol’s role as an information hub is expected to expand significantly, 
with increasing volumes of operational data being transmitted from Member States and 
partners. If existing legal, technical and resource constraints regarding data processing by 
Europol  are not  addressed, these growing  data flows will place  mounting pressure on 
Europol’s  systems  and  resources,  creating  structural  bottlenecks.  In  such  a  scenario, 
efforts to improve information sharing and close existing data gaps may yield only limited 
operational  benefit,  as  the  Agency’s  ability  to  translate  greater  data  availability  into 
actionable criminal intelligence would remain constrained by existing legal and resource 
limitations.  Rather  than  strengthening  Europol’s  operational  impact,  the  growing  data 
flows could deepen existing bottlenecks, increasing the burden on the Agency and limiting 
its ability to deliver timely  and effective support in  an increasingly demanding security 
environment. 

continue relying on the project’s knowledge and expertise to successfully obtain critical electronic evidence 
for criminal investigations and prosecutions (n 53) has remained unmet. 

20 

 
 
 
Second, operational demands on Europol are expected to increase significantly82 as 
the criminal landscape becomes more complex, connected and transnational,83 requiring 
faster,  more  coordinated  responses  across  jurisdictions  and  actors.  Effective  action 
increasingly  depends  on  the  ability  to  rapidly  connect  information,  provide  timely 
analytical and operational support, and facilitate coordinated action across jurisdictions. 
However, Europol’s ability to expand and adapt its operational support is shaped by the 
scope and modalities defined in its legal framework, which cannot automatically evolve in 
line with operational needs. 

Furthermore,  the  need  for  closer  cooperation  and  complementarity  between  EU  bodies 
and agencies will become more critical.84 Fragmentation and duplication  of EU efforts 
would  reduce  effectiveness  and  efficiency,  limiting  the  Union’s  ability  to  deliver  a 
coherent and effective operational response to increasingly complex cross-border crime. 

Third, capability gaps are also expected to persist and widen due to the rapid pace of 
technological change, including developments in artificial intelligence, digital forensics, 
and advanced analytics.85 Criminal networks are early adopters of new technologies, and 
law enforcement authorities require specialised expertise, advanced analytical tools, and 
scalable  technical  infrastructure  to  respond  effectively.  However,  national  innovation 
capacities and training systems are expected to evolve unevenly due to differing priorities, 
resources, and organisational constraints. In addition, parallel innovation and development 
ties  up  scarce  resources.  Without  stronger  coordination  at  EU  level,  inefficiencies, 
disparities in skills86, technical capabilities, and preparedness across Member States are 
likely to persist or deepen, limiting the effectiveness of the collective European response. 

Taken together, these dynamics suggest  that,  without intervention, the gap between the 
complexity of criminal threats and the capacity of Europol and law enforcement authorities 
to  address  them  effectively  will  widen,  with  continued  implications  for  the  quality  of 
national  investigations,  the  effectiveness  of  cross-border  cooperation  and  the  overall 
capacity of the Union to respond coherently to serious and organised crime. 

82  Even  today,  there  would  be  thousands  more  cases  where  Member  States  ask  for  Europol’s  support  if 
Europol had the capacity to provide that according to the Deputy Director of Europol for Governance, Jürgen 
Ebner, at “The future of Europol”, The Europol Podcast, 18 December 2025. Demand for Europol’s services 
exceeds Europol’s current capacity also according to the Study supporting the evaluation and the impact 
assessment of the Europol Regulation, draft final report, March 2026.  
83 Retooling the police is a priority for a strategic response against the future evolution of organised crime 
according to the Global Initiative against Transnational Organized Crime (GI-TOC), Intersections: Building 
blocks  of  a  global  strategy  against  organized  crime,  p  88.  Increasing  crime  threats  and  a  limited  budget 
decisively contribute to make Europol unable to optimally fulfil its supporting role for the Member States 
according to the European Police Chiefs. 
84 For instance, in the area of financial crime, while this impact assessment report considers the relationship 
between Europol and AMLA, GI-TOC has suggested the creation of a global financial crime intelligence 
centre as a priority action to counter the future evolution of organised crime, ibid, pp. 80-81. 
85 See the problem definition by the Study supporting the evaluation and the impact assessment of the Europol 
Regulation, draft final report, March 2026, namely driver 2.2. 
86 Feasibility study on law enforcement training in the EU to  strengthen a  common EU law  enforcement 
culture, interim report, January 2026. 

21 

 
 
 
3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis  

The  legal  basis  of  this  initiative  is  Article  88  of  the  Treaty  on  the  Functioning  of  the 
European Union (TFEU), which establishes Europol’s mission. In particular, it stipulates 
that  the  Agency  shall  ‘support  and  strengthen  action  by  the  Member  States'  police 
authorities and other law enforcement services and their mutual cooperation in preventing 
and combating serious crime affecting two or more Member States, terrorism and forms 
of crime which affect a common interest covered by a Union policy’.  

Article  88(2)  TFEU  empowers  the  European  Parliament  and  the  Council,  acting  in 
accordance with the ordinary legislative procedure by means of regulations, to determine 
Europol’s structure, operation, field of action, and tasks. 

3.2. 

Subsidiarity: Necessity of EU action 

According to the subsidiarity principle laid down in Article 5(3) TFEU, action at EU level 
should be taken only when the aims envisaged cannot be achieved sufficiently by Member 
States alone and can therefore, by reason of the scale or effects of the proposed action, be 
better achieved by the EU. 

Europol’s mandate is to support and strengthen cooperation between Member States’ law 
enforcement authorities in addressing serious and organised crime and terrorism. These 
threats  increasingly  operate  across  borders,  jurisdictions,  and  digital  environments, 
requiring coordinated action and the timely exchange and analysis of information at Union 
level. Member States acting alone cannot ensure the necessary level of coordination, nor 
can they establish a comprehensive criminal intelligence picture across the Union. 

Union  action  is  therefore  necessary  to  provide  a  common  legal  framework  enabling 
Europol to effectively support Member States, facilitate cooperation, and strengthen the 
exchange and analysis of operational information. Moreover, as Europol is a Union agency 
established by Regulation (EU) 2016/794, any modification of its mandate or functioning 
can  only  be  achieved  through  Union  legislation.  The  objectives  of  this  initiative  can 
therefore be better achieved at Union level, in accordance with the principle of subsidiarity. 

3.3. 

Subsidiarity: Added value of EU action 

The evaluation of the Europol Regulation (Annex 7) has confirmed that Europol plays a 
unique and indispensable role in supporting Member States in preventing and combating 
serious and organised crime and terrorism, in particular where these threats have a cross-
border  dimension.  Through  its  criminal  intelligence  analysis,  operational  and  technical 
support  to  investigations,  coordination  of  cross-border  law  enforcement  actions,  and 
support  to  joint  investigation  teams,  Europol  expands  the  reach,  speed,  and 
effectiveness  of  national  investigations.  It  enables  authorities  to  detect  connections 
between criminal activities across multiple Member States, identify priority targets, and 
coordinate  operational  responses,  thereby  significantly  strengthening  the  Union’s 
collective ability to disrupt criminal networks. 

22 

 
 
Europol also provides specialised capabilities, expertise, and technological infrastructure 
that individual Member States could not develop or maintain efficiently on their own.87 
This includes advanced analytical and forensic capacities, the ability to process and analyse 
very large and complex datasets, and innovation and technical support to address evolving 
threats.  By  centralising  high-value  expertise,  tools,  and  infrastructure  at  Union  level, 
Europol generates substantial economies of scale, reduces duplication of investment, and 
ensures that all Member States benefit from cutting-edge capabilities, regardless of their 
size or national resources. 

A common Union legal framework ensures that Europol can perform its tasks consistently, 
effectively, and with full respect for Member States’ competences and responsibilities for 
law enforcement. It also guarantees coherent governance, accountability, and safeguards, 
including a high level of protection of personal data, thereby strengthening mutual trust 
and enabling effective operational cooperation. This contributes to ensuring a high level 
of  security  across  the  Union  and  to  protecting  the  integrity  of  its  internal  market88, 
democratic institutions, and digital and economic infrastructure. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The  general  objective  of  this  initiative  is  to  improve  the  effectiveness  of  EU-level  law 
enforcement  cooperation  in  preventing  and  combating  serious  and  organised  crime  and 
terrorism, in order to contribute to a high level of internal security in the EU.  

In  particular,  the  aim  is  to  enhance  Europol’s  capacity  to  enable  a  more  complete  and 
timely understanding of criminal threats across the Union and to support their effective 
detection, disruption and prevention, thereby contributing to the protection of citizens and 
victims. 

4.2. 

Specific objective 

4.2.1 Reinforce Europol’s role as an information hub for law enforcement 

This objective aims to strengthen Europol’s capacity to collect, process, analyse and share 
high-quality criminal information across borders. It focuses on:  

• 

improving the timeliness and completeness of information exchange, including 
reducing delays and gaps in cross-border data sharing; 

•  ensuring that  relevant information is  available and accessible  across  Member 
States  and  relevant  EU  bodies  and  agencies  in  a  consistent  and  interoperable 
manner; 

87 See Annex 7: Evaluation of the existing policy and legislative framework pages 120, 124. 
88  https://www.europol.europa.eu/sites/default/files/documents/Europol_report_-_Leveraging_legitimacy_-
_How_the_EU_most_threatening_crim_networks_abuse_legal_business_structures.pdf 

23 

 
 
 
• 

improving the usability of information for operational purposes, including its 
structuring, analysis and sharing in an actionable format.  

By addressing fragmentation and the under-utilisation of existing tools, this objective will 
enable the systematic identification of cross-border links between cases, individuals 
and  criminal  networks,  including  emerging  threats,  and  support  more  effective 
operational  action,  while  maintaining  robust  data  protection  and  fundamental  rights 
safeguards. 

4.2.2. Strengthening Europol’s capacity to support law enforcement operational action 

This  objective  aims  to  ensure  that  Europol  can  provide  timely,  coordinated  and 
operationally  relevant  support  to  cross-border  investigations  into  serious  and 
organised crime and terrorism. It focuses on: 

•  enabling earlier and more consistent involvement of Europol  in cross-border 

• 

investigations; 
improving  the  translation  of  criminal  intelligence  into  concrete  operational 
results, including support to coordinated measures; 

•  strengthening operational coordination and cooperation with Member States 
and Union bodies and agencies, in particular the EPPO, including through a 
more continuous use of EU-level capabilities. 

This  will  support  faster,  more  coherent  and  effective  investigations,  and  ensure  a  more 
continuous  EU-level  support  across  the  operational  lifecycle,  from  intelligence  to 
investigation and prosecution. 

Figure 1: Intervention Logic 

24 

 
 
 
 
5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

The  baseline  scenario  reflects  the  continuation  of  the  current  legal,  governance,  and 
operational framework established by Regulation (EU) 2016/794, as amended. 

Under this scenario, Europol would continue to support cross-border cooperation, provide 
criminal intelligence analysis, and contribute to coordinated operational responses, playing 
a key role in enabling collective action against serious and organised crime and terrorism89. 

Over  the  period  2027-2037,  the  operational  environment  is  expected  to  transform 
fundamentally,  with  criminal  networks  leveraging  advanced  technologies,  scaling  their 
activities across borders  with unprecedented speed, and producing volumes of data that 
challenge  the  ability  of  authorities  to  detect,  analyse,  and  respond  effectively90. 
Operational cooperation at Union level will become indispensable, requiring faster, deeper, 
and more continuous coordination to match the speed, complexity, and reach of evolving 
threats. 

In this evolving environment, Europol would remain a central pillar of the Union’s internal 
security  architecture,  but  the  fact  that  its  operational  model  was  conceived  for  a 
fundamentally different  era would become increasingly evident. As threats  grow faster, 
more  data-driven,  and  more  interconnected,  Europol’s  ability  to  keep  pace  would  be 
progressively constrained by the limits of its current legal, technical, and organisational 
framework. While Europol would continue to adapt incrementally, its capacity to operate 
at the scale and tempo required by the evolving threat environment would remain shaped 
by the limits of its existing legal, technical, and organisational framework. 

In terms of information and criminal intelligence, Europol would remain the Union’s 
central  hub  for  receiving  and  analysing  criminal  data,  but  the  scale  and  complexity  of 
incoming  information  would  grow  far  faster  than  Europol’s  capacity  to  fully  exploit  it. 
Despite  ongoing  initiatives  to  improve  connectivity91  and  expand  data  exchange92, 
information flows would remain uneven and incomplete, reflecting persistent disparities 
in national capabilities and system integration. At the same time, the exponential growth 
of  digital  evidence  and  data-intensive  investigations  would  place  mounting  pressure  on 
Europol’s  infrastructure  and  analytical  environment.  Increasingly,  resources  would  be 
absorbed by maintaining and stabilising existing systems, limiting the Agency’s ability to 
scale processing capacity and deploy advanced analytical tools. Without structural change, 
Europol would face growing difficulty in transforming expanding data volumes into timely 

89 See Annex 7, which presents the evaluation of the Europol Regulation and shows a consistent upward 
trend. 
90  EU-SOCTA  and  IOCTA  highlight  that  criminal  networks  are  increasingly  digitalised,  technologically 
enabled  and  transnational,  generating  growing  volumes  of  data  and  requiring  stronger  cross-border 
operational cooperation. 
91 Examples of Europol’s ongoing modernisation efforts include the Information Management and Analysis 
Capability (IMAC), aimed at strengthening the processing and analysis of criminal information, and the Joint 
Operational Analysis Capability (JOAC), which enables real-time analytical support to operational activities, 
including joint investigation teams, operational task forces, and coordinated cross-border investigations.  
92 Considering the EU JHA interoperability roadmap and other developments related to travel information. 

25 

 
 
 
and operational criminal intelligence, weakening the Union’s ability to detect and disrupt 
cross-border threats. 

Europol’s operational support would also continue to expand within its existing mandate. 
Europol  would continue to  support investigations and coordinated operational  activities 
through analytical contributions, technical expertise, and coordination functions, including 
support to joint investigation teams, operational task forces, and cooperation with Union 
bodies and agencies. Europol would also continue to play an important role in facilitating 
cooperation with international partners, including through closer partnerships with specific 
countries. However, as operational demands increase in scale and complexity, Europol’s 
ability  to  provide  timely  and  comprehensive  support  across  all  relevant  investigations 
would  remain  limited  by  structural  factors,  including  legal  and  procedural  constraints, 
uneven  Member  State  participation,  and  limits  in  the  scalability  of  its  analytical  and 
coordination  functions.  As  a  result,  Europol’s  operational  engagement  would  remain 
selective,  contributing  to  uneven levels  of operational support across the  Union. At the 
same time, as the mandates and operational activities of other Union actors, notably the 
EPPO,  expand,  Europol  would  be  increasingly  expected  to  provide  analytical  and 
coordination support, with cooperation continuing to deepen, while remaining hampered 
by fragmented mandates. 

Europol would also continue to provide specialised expertise and advanced capabilities, 
including  in  digital  forensics,  decryption,  and  large-scale  data  analysis93,  without 
duplicating those provided by other EU bodies and agencies. Europol’s technological role 
in supporting the Union’s response to online threats is also expected to continue expanding 
in  line  with  existing  policy  frameworks,  including  the  Digital  Services  Act94  and 
developments under the Cybersecurity Act95. This work increasingly involves structured 
cooperation  with  private  sector  actors,  including  online  platforms,  financial  service 
providers  and  technology  companies,  which  play  an  important  role  in  detecting  and 
reporting criminal activity in the digital environment. These initiatives increasingly rely 
on Europol’s technical and analytical expertise to support the identification and assessment 
of online risks, including those linked to serious and organised crime, terrorism and illegal 
content online96. Furthermore, the work of Europol’s Innovation Lab97 and the European 

93  For  instance,  the  recommendations  of  the  High-Level  Group  on  access  to  data  and  the  Commission’s 
roadmap for lawful and effective access to data for law enforcement identify Europol as a key actor in the 
areas of digital forensics.  At the same time,  Europol Programming Document 2024-2026 establishes that 
‘Europol seeks to be at the forefront of law enforcement innovation and research and through its Innovation 
Lab, it facilitates innovation in the law enforcement community and addresses the risks and opportunities of 
emerging technologies’, which is strategic objective 5 in that document. 
94 Regulation (EU) 2022/2065. 
95 Regulation (EU) 2019/881. 
96 In particular, Europol’s role under Article 18 of Regulation (EU) 2022/2065. 
97  Europol’s  Innovation  Lab,  established  in  2019,  is  a  collaborative  platform  within  Europol  that  brings 
together  law  enforcement  authorities,  researchers,  technology  experts,  and  industry  partners  to  explore, 
develop,  and  test  innovative  tools,  technologies,  and  methods  that  help  law  enforcement  agencies  across 
Europe anticipate, prevent, and combat emerging criminal and security threats in an increasingly digital and 
complex  environment.  The  number  of  supported  operations  by  the  Europol  Innovation  Lab  more  than 
doubled between 2024 and 2025. 

26 

 
 
 
Clearing  Board98,  and  technological  developments  would  contribute  to  incremental 
improvements, and Europol would remain a key provider of specialised capabilities that 
many Member States would not be able to sustain independently. However, the pace of 
technological change and the increasing sophistication of criminal methodologies would 
continue to raise operational requirements. Europol’s ability to scale advanced capabilities 
and operationalise emerging technologies would remain shaped by structural constraints, 
including ICT infrastructure limitations, governance and legal requirements, procurement 
timelines,  and  compliance  obligations.  Legal  and  procedural  safeguards,  including 
narrowly defined mandates governing the use of publicly available information, biometric 
data,  and  artificial  intelligence  tools,  would  continue  to  shape  the  pace  and  scope  of 
deploying new analytical techniques99. In particular, the growing importance of publicly 
available  information  and  open-source  intelligence  (OSINT)  in  criminal  investigations 
would further increase analytical demands on Europol to exploit such data. 

In financial terms, the baseline scenario assumes the continuation of Europol’s current 
budgetary trajectory under the existing Multiannual Financial Framework, reflecting a no-
policy-change scenario. Europol’s budget has grown steadily in recent years, increasing 
from  approximately  EUR  169  million  in  2021  to  around  EUR  235  million  in  2025, 
reflecting the Agency’s gradual expansion of its operational responsibilities and analytical 
capabilities.  Based  on  this  trend,  the  cumulative  Europol  budget  over  the  current  MFF 
(2021-2027)  is  estimated  at  around  EUR  1.5  billion.  For  the  purposes  of  this  impact 
assessment, baseline projections assume that Europol’s budget would continue to evolve 
broadly in line with historical trends, resulting in a projected envelope of approximately 
EUR 2.3-2.9 billion over the following MFF period (2028-2034), depending on whether 
linear growth or a constant growth rate is assumed100. These projections exclude the costs 
associated  with  the  policy  options  assessed  in  this  impact  assessment  and  reflect 
expenditure  that  would  likely  be  incurred  irrespective  of  the  initiative.  The  budgetary 
impact  of the  preferred option should therefore  be assessed in  addition  to  the projected 
baseline envelope. 

5.2.  Description of the policy options 

This  Impact  Assessment  examines  two  policy  options,  focusing  on  the  main  strategic 
directions  for strengthening  Europol’s role within  the Union’s  security  architecture and 
presenting  those  measures  contained  in  the  two  options  that  would  have  the  most 
significant  implications.  These  options  are  structured  around  two  distinct  policy 
directions both reflecting an ambitious strengthening of Europol’s role. 

Policy Option 1 strengthens Europol’s existing mandate and operational model through 
targeted structural improvements and expanded capabilities, enabling more effective and 
scalable operations while preserving the current framework. 

98 The  European Clearing Board is a Europol-coordinated forum where EU Member States and agencies 
align operational needs and guide the development of innovative law-enforcement technologies. 
99 ICF (March 2026), Draft Final Report of the Study supporting the evaluation and the impact assessment 
of the Europol Regulation, p.31. 
100 See Annex 3 cost of the preferred option, for more details on the calculation. 

27 

 
 
 
Policy Option 2, by contrast, explores a more fundamental evolution of Europol’s role, 
positioning the Agency as an essential Union-level capability for coordinating operations 
and  generating  criminal  intelligence  in  response  to  increasingly  complex  cross-border 
threats. 

Each policy option comprises a coherent, but not exhaustive, set of measures addressing 
the  specific  objectives  of  strengthening  Europol.  Some  measures  represent  progressive 
improvements that could be implemented cumulatively, with Policy Option 2 building on 
and going beyond elements of Policy Option 1. However, other measures reflect alternative 
approaches that are specific to each option and are not cumulative. 

The policy measures have been designed to address the two identified problem areas in a 
complementary manner. Measures under Sub-policy Options 1.1, 2.1, 2.2 and 2.4 primarily 
address  the persistent  information gaps that hinder the development  of a complete EU-
wide criminal intelligence picture. Measures under Sub-policy Options 1.3, 1.4, 2.3 and 
2.4 primarily address the fragmented and uneven use of Europol's operational support and 
specialised capabilities. Together, the measures seek to improve both the availability of 
operational information and Europol's ability to provide timely, effective and operationally 
embedded support to Member States and other relevant EU actors. 

28 

 
 
 
Policy Options (table): 

Specific Objective 1: Reinforce Europol’s role as 
an information hub for law enforcement 

a)  closing information gaps 

b)  addressing data subject categorisation 

Specific Objective 2: Strengthening Europol’s 
capacity to support law enforcement operational 
action 

a)  inter-agency cooperation 

b)  bringing Europol’s support to the ground 

Policy Option 1: Reinforcing Europol’s 
existing model 

Policy Option 2: Designing a new model for 
Europol 

Sub policy option 1.1: strengthened data 
availability, processing and service 

Sub policy option 2.1: Europol as an 
operational service provider and information 
hub for law enforcement 

Sub policy option 1.2: enhanced 
mitigating measures to address the 
obstacles of Data Subject Categorisation 

Sub policy option 2.2: simplified rules to 
reduce the administrative burden of data 
subject categorisation 

Sub policy option 1.3: reinforced 
cooperation with the EU bodies and 
agencies for internal security  

Sub policy option 1.4: Europol digital 
platforms embedded in national 
investigations 

Sub policy option 2.3: Europol to provide 
analytical support to the EPPO 

Sub policy option 2.4: EU Digital Police 
Cloud and Europol support offices 

 
 
 
 
 
 
 
 
 
4.1.1. Specific Objective 1: Reinforce Europol’s role as the EU operational information 
hub for law enforcement 

Policy Option 1: Reinforcing Europol’s existing model 

Sub-policy option 1.1: Strengthened data availability, processing and service 

 

Improving  data  availability 
obligations 

through 

targeted  and 

incremental  data-sharing 

  Upgrading Europol systems and services to deliver stronger operational returns 

This  sub-policy  option  aims  to  strengthen  Europol’s  ability  to  support  Member  State 
investigations  by  improving  the  availability,  timeliness  and  operational  use  of  data, 
while ensuring that enhanced cooperation delivers clear operational returns to Member 
States. It  addresses  the  main technical,  organisational and practical  barriers to  effective 
information  exchange  without  introducing  automatic  or  bulk  data  transfers,  and 
without altering the fundamental data-ownership model or Europol’s mandate. 

The  option  focuses  on  priority  crime  areas  identified  in  the  Europol  Regulation  (e.g., 
terrorism and child sexual exploitation) where EU added value is clear. Member States 
would  have  limited,  progressive  duties  to  make  relevant  data  available  to  Europol, 
building on existing cooperation practices. 

A key measure is the mandatory deployment of technical data-loader solutions, enabling 
automated and timely data uploads while preserving full Member State control over 
shared  data.  Experience  shows  such  tools  reduce  administrative  burden,  increase 
timeliness, and support more systematic information sharing. If all Member States were to 
contribute at levels comparable (per capita) to Member States equipped with data loaders 
(such  as  Germany  and  the  Netherlands),  the  overall  EIS  content  could potentially 
increase by  50%  in  the  short  term,  providing  a  more  comprehensive  threat  intelligence 
picture and a greater chance of identifying interconnected cases. 

This approach does not alter the possibility left to Member States to decide not to supply 
information to Europol under Article 7(7) of the Europol Regulation, nor does it confer 
autonomous  data  collection  powers  on  Europol.  The  focus  is  on  technical  readiness, 
predictability and consistency, supported by transparency measures such as monitoring 
of  response  times,  feedback  loops  to  national  units  and  aggregated  reporting  on 
responsiveness. 

A  central  component  is  a  major  upgrade  of  Europol’s  ICT  infrastructure  and  core 
systems  (including  SIENA,  EIS,  EAS  and  QUEST/QUEST+)101,  improving  scalability, 
automation,  usability  and  performance.  This  ensures  that  increased  data  availability 
translates  into  tangible  benefits  for  Member  States.  Where  appropriate,  proven  EU 
technologies  from  EU  large-scale  systems  provided  by  eu-LISA  could  be  reused  to 

101 See Annex 8 for more details. 

 
 
 
enhance interoperability and resilience systems102. This increase in capacity would enable 
systematic and automated cross-check against relevant EU information systems103. 

Europol’s  role  in  maintaining  common  technical  and  data  standards,  notably  the 
Universal  Messaging  Format  (UMF),  would  be  reinforced  to  reduce  fragmentation, 
mapping costs and duplication, while supporting automation and data quality. The option 
also  consolidates  Europol’s  OSINT  capacity104,  including  the  application  and 
deployment of AI-assisted tools. 

To reduce implementation costs, Europol could support joint procurement of technical 
components  (e.g.,  data-loaders  and  interfaces),  promoting  economies  of  scale  and 
interoperability. Crucially, the option strengthens Europol’s service and assistance role 
through a dedicated pool of ICT and data-management experts supporting Member States 
with  deployment,  troubleshooting,  standards  compliance  and  training.  This  ensures 
consistent uptake and practical operational benefits. 

Overall, this sub-policy option enhances the availability, quality, and operational use of 
data while fully respecting national autonomy and data ownership, functioning as both 
a standalone upgrade and a key enabler for broader reform measures. 

Sub policy option 1.2: Mitigating measures to address the obstacles of Data Subject 
Categorisation 

  Smarter and faster implementation of Data Subject Categorisation 

This  sub-policy  option  aims  to  improve  the  efficiency  of  DSC  at  Europol  without 
changing  the  existing  legal  framework.  It  focuses  on  mitigating  the  resource-intensive 
nature  of  current  requirements  by  strengthening  Europol’s  operational  procedures  and 
technological capabilities. 

In  particular,  Europol  would  deploy  advanced  analytical  tools  and  update  internal 
guidelines  to  support  faster  and  more  consistent  DSC.  This  could  include  operational 
manuals  and  standardised  procedures  for  handling  specific  datasets,  such  as 
telecommunications data, open-source intelligence or financial information. The objective 
would  be  to  streamline  the  process,  enhance  legal  certainty  and  reduce  the  operational 
burden. The option would also strengthen cooperation with Member States to facilitate the 
efficient processing of complex datasets and support timely investigations. 

102 For instance, technology used by the shared biometric matching service (sBMS) for upgrading Europol’s 
biometric capabilities. 
103 In 2024, Europol carried out 13 704 manual and 194 792 batch searches directly in EIS and generated 
13 409 Cross Match Reports and SIENA hit notifications. If each case-triggered intake (manual or batch) 
were systematically accompanied by proportionate consultations of relevant EU information systems (SIS, 
VIS, EURODAC, EES, ETIAS, ECRIS-TCN), this could imply in the order of 200 000 additional structured, 
logged queries annually at EU level. 
104 This would entail scaling up Europol’s ability to collect and analyse publicly available online information 
relevant to criminal investigations. It would involve specialised tools, analytical methods and dedicated staff 
to systematically integrate OSINT into Europol’s intelligence workflows. 

31 

 
 
 
 
Policy Option 2: Designing a new model for Europol  

Sub policy option 2.1: Europol as an operational service provider and information 
hub for law enforcement 

  Authorised Europol access to national data 

  Europol as a provider of operational services 

This  sub  policy  option  strengthens  Europol’s  role  as  an  operational  service  provider 
acting  on  behalf  of  Member  States,  by  improving  its  ability  to  access,  process  and 
operationally  exploit  relevant  information,  while  fully  preserving  Member  State  data 
ownership, investigative autonomy and existing decentralised architectures. It builds 
on existing EU frameworks, notably Prüm II105, and focuses on targeted extensions where 
clear EU added value and operational necessity are demonstrated. 

Under this option, Europol would be allowed, with the explicit authorisation of the data-
owning  Member  State(s),  to  query  national  databases  already  connected  under  EU 
information  exchange  mechanisms,  in  particular  the  Prüm  II  framework.  This  would 
include national biometric databases (DNA profiles, fingerprints and facial images), police 
record indexes (EPRIS) and vehicle registration data (EUCARIS). 

The key change would be to remove the current restriction linked to the origin of the 
data to be used by Europol when launching queries, allowing Europol to use authorised 
national  data in  addition to  third country-sourced data106. Europol  would act  strictly on 
behalf of and within the scope defined by the authorising Member State(s)107. 

For  non-biometric  data,  this  represents  a  proportionate  extension  of  Europol’s  existing 
analytical role, removing an artificial constraint that limits operational effectiveness. For 
biometric  data,  Europol  would  function  as  a  technical  and  forensic  service  provider, 
supporting Member States by launching authorised queries, handling complex matches and 
providing expert analysis, particularly in time-critical or large-scale cases (e.g., terrorist 
attacks or mass casualty events). Authorisations could be granted on a standing or ad-hoc 
basis. 

Beyond data access, this option would also position Europol as a provider of shared EU-
level  operational  and  technical  services,  reducing  fragmentation,  dependencies,  and 
costs.  These  services  would  be  optional,  demand-driven  and  subject  to  strong  Member 

105 The Prüm II framework, established by Regulation (EU) 2024/982, is currently in the implementation 
phase, with the start of operations expected by 2027. 
106 Europol currently hosts roughly 17 600 fingerprints sets and 5 300 latent prints, around 450 DNA profiles, 
and about 3 500 facial images in  the  EIS. Extending the mandate  to allow Europol to run Prüm II cross-
checks not only on third-country biometrics but also on biometric data submitted by Member States would 
significantly enhance effectiveness. Instead of limiting queries to externally sourced datasets, Europol could 
systematically deconflict and crossmatch Member State-contributed biometric traces (e.g. latent prints from 
serious crime scenes) across the full Prüm network. 
107 This would not modify the Prüm II hit/no-hit architecture, nor grant Europol autonomous access rights. 

32 

 
 
 
State oversight. A key example is an EU DNA matching service108, as Member States 
currently rely on different technologies, including third-country tools. An EU-level service 
facilitated  by  Europol  would  support  Prüm  II  implementation,  reduce  external 
dependencies  and  ensure  interoperability,  while  reducing  dependency  on  third-country 
tools. 

Sub policy option 2.2: Simplified rules to reduce the administrative burden of Data 
Subject Categorisation 

  Aligning the rules with already existing legal frameworks 

This sub-policy option would entail a legislative overhaul, aligning the Europol Regulation 
with  the  EU  Data  Protection  Regulation  (EUDPR)  and  the  Law  Enforcement  Directive 
(LED), to establish an appropriate legal framework for Europol, simplifying the rules for 
data processing and improving Europol’s operational flexibility, while maintaining a high 
level of data protection. 

Under this approach, DSC would be required “where applicable and as far as possible”, 
rather than as a strict ex ante condition for accepting and processing all data. Categorisation 
would  instead  take  place  when  data  is  operationally  used,  allowing  Europol  to  process 
larger  and  more  complex  datasets  while  ensuring  proportionate  and  meaningful 
classification. 

This  framework  would  provide  greater  legal  clarity,  support  the  use  of  advanced 
analytical tools and machine learning by enabling more consistent processing and analysis 
of  large  and  complex  datasets,  and  reduce  operational  bottlenecks.  Oversight  by  the 
European Data Protection Supervisor (EDPS) would remain.  The alignment would also 
enhance consistency across EU data protection instruments, providing simplification and 
reducing fragmentation. 

4.5.2.  Specific  objective  2:  Reinforce  Europol’s  role  in  providing  operational 
support to investigations 

Policy Option 1: Reinforcing Europol’s existing model 

Sub policy option 1.3: enhanced EU inter-agency information  

  Reinforced operational support to the EPPO 

  Strengthened Europol-Eurojust operational continuum 

  Enhanced information sharing between Europol and AMLA 

108 DNA matching services are necessary tools to allow existing systems using DNA technology to work. 
Implementation  would  be  progressive  and  evidence-based,  starting  with  pilots  and  clear  governance 
arrangements, preserving flexibility and trust. For more details on the EU DNA matching service, see Annex 
9. 

33 

 
 
 
 
This  option  strengthens  operational  information  exchange  and  cooperation  between 
Europol  and  key  EU  bodies  and  agencies,  notably  the  EPPO,  Eurojust  and  AMLA,  to 
ensure more coherent and effective EU-level support for national authorities in tackling 
cross-border crime.  

Reinforced Europol support to the EPPO 

This component would strengthen Europol’s support to the EPPO while maintaining the 
current  institutional  framework.  Europol  would  enhance  its  analytical  support  to  EPPO 
investigations, ensuring more systematic and timely cooperation to be able to match the 
growing  needs  of  the  EPPO.  This  could  involve  allocating  additional  specialised  staff 
within Europol, including the creation of a dedicated team focusing on EPPO-related 
cases. Such a team would deepen expertise, improve operational coordination and enable 
more  structured  planning  of  resources.  The  option  would  also  strengthen  operational 
interaction through enhanced coordination between liaison officers stationed at Europol 
and the EPPO. 

These  measures  would  require  targeted  legislative  amendments  but  would  not  alter  the 
respective  mandates  of  Europol  and  the  EPPO  or  the  fundamental  nature  of  their 
relationship. 

Strengthened Europol-Eurojust operational continuum 

This  component  would  strengthen  complementarity  between  Europol  and  Eurojust, 
ensuring  a  seamless  continuum  between  law  enforcement  and  judicial  cooperation  and 
enabling  more 
investigations. 
Operationally, this would support a more continuous transition between the intelligence, 
investigation and prosecution phases of cross-border cases, while avoiding duplication of 
efforts between authorities. 

throughout  cross-border 

integrated  EU  support 

A first  element of this measure would be to enhance information sharing by improving 
indirect  access  to  information  between  Europol  and  Eurojust  through  the  practical 
implementation of the hit/no-hit system provided for in the mandate of both agencies109. 
Under this system, each agency would be able to query limited reference data held by the 
other  agency  in  order  to  identify  whether  potentially  relevant  operational  or  judicial 
information exists, without obtaining direct access to the underlying files. Operationally, 
this would involve upgrading the current mechanism through the implementation of more 
automated  processes,  thereby  enabling  faster  and  more  efficient  exchanges  of  relevant 
information between the two agencies. 

A  second  element  would  establish  specialised  EU-level  support  within  Europol  for 
national authorities seeking to obtain electronic evidence from online service providers. 
This support would complement the judicial coordination role of Eurojust by focusing on 
the  operational  and  technical  dimensions  of  cross-border  access  to  electronic  evidence. 
This would include operational guidance on legal procedures, practical tools and technical 
expertise for requesting and handling electronic evidence, as well as structured channels 
for  interaction  with  service  providers.  Europol’s  role  would  focus  on  facilitating 
operational  coordination,  technical  assistance  and  information  exchange,  while  judicial 

109 This solution would also be expanded to other EU bodies and agencies, ensuring a semi-automated and 
asymmetrical hit/no-hit system. 

34 

 
 
 
authorisations and prosecutorial decisions would remain the responsibility of competent 
national authorities and judicial actors. Europol could also maintain dedicated resources 
facilitating  exchanges  between  competent  authorities  and  providers,  supporting  the 
preservation,  production  and  handling  of  electronic  evidence 
in  cross-border 
investigations.  This  would  enable  more  consistent  and  predictable  EU-level  support  in 
cases involving digital evidence and strengthen operational coordination between Europol 
and Eurojust. 

Enhanced information sharing between Europol and the AMLA  

This  component  would  strengthen  cooperation  between  Europol  and  the  AMLA  by 
enabling  structured  information  exchanges  between  the  two  bodies.  In  particular,  it 
would provide AMLA with indirect access to information stored by Europol through the 
hit/no-hit system. This would allow AMLA to identify potential links between financial 
intelligence and Europol’s operational information on serious and organised crime. 

Sub  policy  option  1.4:  Embedding  Europol  tools  and  systems  in  national 
investigations 

  Connect national case management systems 

  Targeted obligation to consult Europol systems 

This  option  would  bring  Europol’s  analytical  capabilities  closer  to  the  daily  work  of 
investigators by integrating Europol tools directly into national case management systems. 
Instead of relying  mainly  on reactive exchanges of information, investigators would be 
able to access Europol’s analytical support as part of their normal investigative workflow, 
allowing  earlier  identification  of  cross-border  links  and  stronger  analytical  support 
throughout investigations. 

Member States would progressively connect their national case management systems - 
to be established under Directive (EU) 2024/977 - with Europol systems through secure 
interfaces  and  common  data  standards.  Investigators  would  be  able  to  consult  Europol 
systems automatically at predefined stages of an investigation, receive cross-checks and 
analytical feedback directly within their case files, and transmit relevant case information 
to Europol. 

This approach would enable largely automated exchanges, allowing Europol to function 
as a shared analytical backbone by providing automated cross-checks and identification of 
cross-border connections in support of national investigations. 

The option would also  introduce a  targeted obligation to consult Europol  systems  in 
serious and organised crime investigations with a cross-border dimension. Where relevant 
links are identified, this could trigger conditional sharing of case data with Europol, while 
fully  respecting  the  principles  of  necessity  and  proportionality.  Embedded  consultation 
would support earlier detection of cross-border connections and help avoid investigative 
overlaps, complementing existing information exchange channels. 

Implementation  would  depend  on  the  development  of  fast,  scalable  and  reliable  digital 
infrastructure as envisaged under Sub policy option 1.1. 

35 

 
 
Policy Option 2: A new model for Europol 

Sub  policy  option  2.3:  Europol  as  structural  provider  of  information,  analytical 
support and capabilities to the EPPO110 

 

Integrated and systematic framework of operational and analytical support 

This option would introduce a structural shift in Europol’s support to the EPPO, moving 
from the current request-based model to a systematic framework for analytical support. 
Europol would act as a structural provider of analytical capabilities to the EPPO, ensuring 
that  the  Union’s  central  law  enforcement  expertise  is  mobilised  consistently  in 
investigations affecting the Union’s financial interests. 

A  key  element  would  be  the  establishment  of  a  structured  framework  through  which 
Europol’s analytical and technical capabilities are systematically deployed in support of 
EPPO  investigations.  This  would  include  a  dedicated  capability  within  Europol 
composed  of  specialised  staff  focusing  on  EPPO-related  cases,  enabling  deeper 
expertise and more predictable operational support. 

Under this model, the EPPO would be able to guide and prioritise the analytical support 
provided by Europol, ensuring alignment with investigative needs and timelines and that 
analytical  tasks  and  operational  activities  of  a  non-coercive  nature  are  carried  out  by 
Europol  on  behalf  of  the  EPPO.  Europol  would  provide  analytical  support  during 
operational  phases  of  investigations,  technical  assistance  in  processing  seized  data,  and 
intelligence products supporting investigative strategies. This would allow the EPPO to 
benefit  more  systematically  from  Europol’s  expertise  in  large-scale  data  analysis  and 
criminal intelligence development in complex cross-border financial crime cases. 

The option would also strengthen information exchange between Europol and the EPPO 
within the EPPO’s mandate. The Europol Regulation could mirror the logic of the EPPO 
Regulation by allowing the EPPO to access relevant information held by Europol when 
this falls within its competence. Faster and more systematic data exchange would enable 
both  bodies  to  identify  cross-border  criminal  links  more  effectively  and  strengthen 
investigations affecting the Union’s financial interests. Clear arrangements would govern 
the control and use of exchanged data, without fundamentally altering the existing data-
ownership model or Europol’s mandate. 

Sub  policy  option  2.4:  Operational  integration  of  Europol  into  national 
investigations 

•  EU Police Cloud 

•  Europol Support Offices 

110 Policy Option 2 does not include a comparable operational support model for Eurojust, as the agency does 
not exercise investigative powers or conduct operational law enforcement activities.  

36 

 
 
 
 
This sub-option would transform the way Europol supports investigations by embedding 
its analytical, technical and coordination capabilities directly within national operational 
environments. Through a shared EU law enforcement platform (“EU Police Cloud”) and 
reinforced operational presence in Member States, Europol would evolve from a central 
hub  into  an  operational  capability  integrated  into  the  day-to-day  work  of  investigators 
across the Union. 

EU Police Cloud 

The EU Police Cloud would provide investigators in Member States with direct access to 
Europol’s  analytical  tools,  collaborative  environments  and  data-processing  capabilities 
through a secure digital platform. Rather than relying primarily on request-based support, 
investigators  would  be  able  to  use  Europol  tools  directly  during  investigations.  Access 
would  be granted only  to authorised users designated by competent  national  authorities 
and  Europol,  based  on  role-based  permissions  and  investigation-specific  access  rights. 
Authentication could rely on the EU Police Digital Identity, allowing national authorities 
to issue, manage and revoke credentials while ensuring a harmonised and trusted access 
framework across the Union. 

The  platform  would  remove  technical  barriers  that  currently  limit  the  use  of  Europol’s 
digital  tools  and  progressively  become  accessible  to  a  broad  community  of  law 
enforcement users across the Union (up to 380 000 by 2035111). Designed as a modular 
online platform, it would allow investigators to access specialised tools and shared data in 
real time, enabling more timely and operationally embedded collaboration with Europol. 
In  practice,  investigators  participating  in  the  same  join  operational  case  could  securely 
collaborate  within  dedicated  digital  workspaces,  exchange  operational  information, 
perform analytical queries and coordinate investigative actions in near real time. The EU 
Police Cloud would bring together, through a single digital environment, the analytical 
and  operational  tools  currently  available  at  Europol’s  headquarters  and  make  them 
accessible to national investigators across the Union. 

A  core  function  would  be  the  ability  to  upload,  store  and  analyse  large  volumes  of 
investigative  data,  including  structured  data  (police  records,  administrative  data)  and 
unstructured data (digital extractions, seized devices, operational material). Data uploaded 
to the platform would remain logically separated according to the relevant investigation, 
operational task or access authorisation. Data would remain subject to strict access control, 
compartmentalisation by investigation, and robust security safeguards, ensuring that only 
authorised personnel can access relevant datasets. All data-processing activities would be 
logged  and  auditable,  enabling  ex  post  verification  of  compliance  with  access  rights, 
investigation  mandates  and  data-protection  requirements.  Advanced  forensic  and 
analytical  modules,  including  AI-based  tools  and  biometric  capabilities,  would  enable 
targeted cross-checks within joint investigations. 

Other modules would automate searches and requests across information available for 
law enforcement purposes under Union or national law, including police records (EIS and 
national  records  via  the  Prüm  II  framework),  investigative  records,  interoperability 

111 Estimation based on the assumption that (i) 20% of law enforcement officers have criminal investigation 
skills,  and  (ii)  the  size  of  the  European  police  workforce  reported  by  Eurostat  (2023):  1,537,588  police 
officers. Police, court and prison personnel statistics - Statistics Explained - Eurostat. 

37 

 
 
 
databases,  national  administrative  records  (see  policy  option  1.1),  OSINT,  referrals, 
information provided by third countries or private parties to Europol.  Queries would be 
taking place in accordance with applicable access rights and legal bases, ensuring that users 
only obtain access to information they are authorised to consult.  To improve reactivity, 
regular repeated searches and alerts would be implemented.  

As collaboration builds upon a continuum  of exchanges from the more technical  to  the 
more communicational, this platform would provide online integrated collaboration tools 
building on existing Europol tools112 such as messaging, mail and video conference. These 
functionalities would support operational coordination between investigators and analysts. 

To  handle  increasing  data,  processing  and  users,  the  platform  would  use  multi-cloud 
infrastructure (private and sovereign), allowing differentiated treatment of sensitive areas 
like  terrorism.  Sensitive  operational  environments  could  be  hosted  within  dedicated 
secured infrastructures with reinforced access restrictions and cybersecurity measures. It 
would  be  accessible  as  a  standalone  web/mobile  application  and  via  Application 
Programming Interfaces (APIs)113 for integration with national case management systems, 
supporting  Europol’s  standardisation  role.  Security  would  rely  on  a  harmonised  EU 
Police  Digital  Identity  based  on  the  EU  Digital  Identity  Framework  at  high  assurance 
level  granting  secure  and  trusted  access  across  the  Union.  The  platform  would  be 
developed  according 
security-by-default  principles. 
include  multi-factor  authentication,  encryption, 
Cybersecurity  safeguards  would 
continuous security monitoring, incident detection and response capabilities, audit trails 
and  resilience  measures  against  unauthorised  access,  data  breaches  or  cyberattacks. 
Sensitive  operational  environments  could  be  subject  to  enhanced  security  requirements 
depending on the nature of the data processed. Successful implementation would depend 
on  the  simplification  of  the  DSC  under  Sub  policy  option  2.2  to  allow  for  Europol  to 
process data even if the DSC has not yet been carried out. 

security-by-design  and 

to 

Europol support offices 

Europol  support  offices  would  strengthen  Europol’s  operational  presence  in  Member 
States and serve as interfaces with national authorities, helping investigators integrate 
Europol’s tools, analysis and expertise into ongoing investigations. They could build on 
the existing Europol National Units in each Member State. 

The model would rely on staffing arrangements that combine expertise on Europol and its 
tools with strong familiarity with national investigative environments. This would allow 
Europol’s  support  to  be  better  aligned  with  national  legal  frameworks,  procedural 
requirements and investigative workflows. 

Through this approach, Europol support offices would act as operational multipliers within 
national  investigative  ecosystems.  They  would  provide  investigators  with  immediate 
operational  access  to  Europol’s  analytical  tools,  specialist  expertise  and  technical 
capabilities,  enhancing  awareness  of  Europol’s  support  and  effectively  embedding  that 
support within investigations. By enabling the early mobilisation of Europol capabilities, 

112 Including SIENA, Videoconference for Operational Purposes (VCOP) and Virtual Command Post (VCP). 
113 APIs are sets of rules and protocols that allows different software applications or systems to communicate 
and exchange data with each other. 

38 

 
 
 
they would ensure that analytical outputs and technical support are produced in forms that 
can  be  directly  integrated  into  national  investigative  processes  and,  where  relevant, 
relied upon in judicial proceedings. 

The support offices would also provide a stable operational interface for the deployment 
of specialised Europol capabilities, including digital forensic expertise, data analysis and 
other technical support. This model would complement the Agency’s strong central model 
while bringing Europol’s capabilities closer to investigators on the ground. It would also 
support a more circular exchange of expertise between Europol and national authorities, 
strengthening operational cooperation and the practical use of Europol capabilities across 
the Union. 

5.3.  Options discarded at an early stage 

5.3.1. 
Non-legislative action and targeted changes to Europol’s legal framework 

Non-legislative  measures,  including  operational  arrangements,  guidance,  and  technical 
improvements within the existing legal framework, were considered but found insufficient 
to  address  the  structural  limitations  identified.  While  such  measures  could  deliver 
incremental  improvements,  they  would  not  enable  Europol  to  access,  process,  and 
operationally exploit  information at  the scale required, nor to  strengthen its operational 
support, capabilities, and governance in a systematic and sustainable manner. 

Similarly,  more  limited  and  isolated  amendments  to  the  Europol  Regulation  were 
considered but discarded, as they would not provide the comprehensive and future-proof 
framework  needed  to  enable  Europol  to  operate  effectively  in  a  rapidly  evolving  and 
increasingly  complex  security  environment114.  Targeted  legislative  adjustments  may 
address specific issues, but, on their own, would not fully address the broader structural 
challenges identified. 

5.3.2. 
Turning Europol into an autonomous agency with executive powers 

The  option  of  transforming  Europol  into  an  autonomous  agency  with  executive  law 
enforcement  powers,  including  the  ability  to  conduct  investigations  or  take  coercive 
measures independently of Member State authorities, was considered115 but discarded at 
an early stage. Such an approach would represent a fundamental departure from the current 
role of Europol as a support and coordination agency operating in close cooperation with 
national authorities in line with Article 88 TFEU. 

114 The Commission’s report pursuant to Article 68(3) of the Europol Regulation (COM(2025) 752 final) 
illustrates that limited changes risk to perpetuate existing shortcomings.  
115  Some  stakeholders,  including  the  European  People’s  Party  and  Renew  Europe,  have  called  for 
strengthening  Europol’s  operational 
to  grant  enforcement  powers. 
https://www.epp.eu/files/uploads/2025/01/EPP-Retreat-Priorities-2025-statement.pdf 

including  proposals 

role, 

39 

 
 
 
 
 
This  option  would  raise  significant  legal,  operational  and  governance  complexities. 
Consequently, this option will not be available in short- to mid-term to address the pressing 
security needs identified in Section 2. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section assesses the expected impacts of the policy options described in Section 5. 
The analysis evaluates the extent to which the options would contribute to achieving the 
objectives identified in Section 4, compared with the baseline scenario described in Section 
5.3. The impacts are assessed on a scale ranging from ‘very positive impact’ (++) to ‘very 
negative  impact’  (--),  with  intermediate  scores:  ‘positive  impact’  (+),  ‘neutral’  (0)  and 
‘negative impact’ (-). 

The assessment draws on the evidence collected through the study supporting this Impact 
Assessment,  including,  where  possible,  the  quantification  and  monetisation  of  impacts. 
Where  sufficient  data  was  available,  impacts  were  quantified  based  on  existing 
assessments  or  modelling;  where  this  was  not  possible,  a  qualitative  assessment  was 
carried out. Further details on the methodology and underlying estimates are provided in 
Annex 10. 

6.1 Financial impacts116 

Impact on EU institutions and agencies 

Policy Option 1 (+/-) entails  additional financial  and human resource requirements for 
Europol. Over the 2028–2034 Multiannual Financial Framework (MFF) period,  one-off 
adjustment costs are estimated at approximately EUR 61 million117, mainly associated 
with  upgrades  of  ICT  infrastructure  including  the  EIS,  the  EAS,  SIENA,  QUEST  and 
analytical tools supporting operational information exchange and analysis. Europol would 
also  incur  recurring  annual  adjustment  costs  of  around  EUR  12.2  million118 
(corresponding  to  approximately  EUR  85.4  million  cumulatively  over  the  2028–2034 
period) related to staff, system maintenance, infrastructure operation and technical support 
to Member States119.  

Additional costs related to mitigating measures on DSC are expected to remain limited, as 
they mainly concern the development of internal guidance, analytical tools and training 
materials120. 

Policy  Option  1  also  includes  measures  reinforcing  operational  cooperation  between 
Europol and other EU bodies and agencies. In particular, strengthening Europol’s support 
to  the  EPPO  would  require  the  establishment  of  a  dedicated  analytical  and  operational 
support capacity within Europol. The recurring annual operational cost of this reinforced 

116 Detailed information is provided in Annex 3. 
117 See costs section of Annex 3. 
118 See costs section of Annex 3. 
119  These  costs  relate  mainly  to  the  upgrade  and  scaling  of  Europol’s  core  systems  and  the  provision  of 
technical support to Member States. These costs include the staff needed to provide the services. 
120  Costs  mainly  concern  the  development  of  internal  operational  guidance,  analytical  tools  and  training 
activities aimed at improving the efficiency of data subject categorisation processes. 

40 

 
 
 
support is estimated at approximately EUR 10 million121 (corresponding to approximately 
EUR  70  million  cumulatively  over  the  2028–2034  period).  Furthermore,  measures 
strengthening  the  operational  continuum  between  Europol  and  Eurojust  would  generate 
limited additional EU-level financial costs, estimated at approximately EUR 2 million 
in one-off costs and EUR 1 million in recurring annual adjustment cost (corresponding 
to approximately EUR 7 million cumulatively over the 2028–2034 period), mainly related 
to system adaptations and operational coordination122. 

Finally, the integration of Europol analytical tools and systems into national investigative 
environments  would  require  additional  investment  at  Europol  level,  with  one-off 
adjustment costs estimated at approximately EUR 50 million and recurring annual 
adjustment cost of around EUR 8 million123 (corresponding to approximately EUR 56 
million cumulatively over the 2028–2034 period). 

Under Policy Option 2, the financial impact  on EU institutions and agencies would be 
more significant (+).  

For Europol,  one-off adjustment  costs are estimated at  approximately  EUR 11 million, 
mainly  linked  to  system  adaptations,  reinforced  data-management  capacity  and  the 
development  of  an  EU  DNA  matching  service.  Europol  would  also  incur  recurring 
annual adjustment cost  of around EUR  5.3 million (corresponding to approximately 
EUR  37.1  million  cumulatively  over  the  2028–2034  period),  primarily  related  to 
specialised  staff,  system  maintenance  and  operational  support  associated  with  these 
services124.  However,  these  investments  could  generate  efficiency  gains  at  EU  level  by 
reducing fragmentation, avoiding duplication of technical solutions across Member States 
and providing shared operational services at scale. 

Furthermore, additional financial effects would arise from the simplification of the rules 
on  DSC.  While  this  policy  option  would  significantly  improve  Europol’s  operational 
flexibility and capacity to process information, it would not require substantial financial 
investment, as it mainly involves legislative alignment and simplification of existing rules. 
On  the  contrary,  the  simplification  of  the  current  framework  is  expected  to  generate 
administrative savings and efficiency gains, as resources currently devoted to the labour-
intensive process  of  DSC could  be redeployed to operational  analysis and investigative 
support.  Overall,  the  measure  is  therefore  expected  to  have  a  very  positive  financial 
impact,  primarily  through  efficiency  gains  rather  than  additional  expenditure,  although 
these gains remain difficult to quantify precisely at this stage due to limited comparable 
operational data. 

121 Costs relate primarily to specialised staff within a dedicated Europol support capacity responsible  for 
operational analysis, cross-checks of operational data and digital forensic support for EPPO investigations. 
52 additional officers would be required in 2026, gradually increasing to 66 officers by 2033, to meet the growing 
demand for support. The total annual cost of employing these additional officers is estimated to rise from €8.2 
million in 2026 to €10.4 million by 2033. 
122  These  costs  relate  to  further  development  of  the  Europol-Eurojust  hit/no-hit  information  exchange 
mechanism and the consolidation of EU-level support for accessing electronic evidence. 
123 See costs section of Annex 3. 
124  Costs  relate  mainly  to  system  adaptations  enabling  authorised  access  to  national  databases  connected 
under EU frameworks, reinforced data management capacity and the development and operation of an EU 
DNA matching capability. 

41 

 
 
 
The  development  of  the  EU  Police  Cloud  would  entail  one-off  adjustment  costs  for 
Europol  estimated  at  approximately  EUR  143.3  million  and  recurring  annual 
adjustment cost of around EUR 39.8 million125 (corresponding to approximately EUR 
278.6 million cumulatively over the 2028–2034 period). While the initial investment in 
digital infrastructure is significant, the use of a common EU-level platform is expected to 
generate efficiency gains over time by reducing fragmentation between national systems 
and enabling more efficient processing and analysis of operational data126. 

Additional  costs  would  arise  from  the  deployment  of  Europol  support  offices  in 
Member States, with recurring annual adjustment cost of up to EUR 6.5 million127 
(corresponding  to  approximately  EUR  45.5  million  cumulatively  over  the  2028–2034 
period).  

Establishing Europol as a structural provider of analytical and operational support to the 
EPPO would generate additional adjustment recurring cost at EU level estimated at 
approximately  EUR  11  million  per  year128  (corresponding  to  approximately  EUR  77 
million cumulatively over the 2028–2034 period). These costs relate mainly to the creation 
and operation of a dedicated Europol support capacity composed of specialised analysts 
and operational staff supporting EPPO investigations129. No separate one-off adjustment 
costs are expected130. 

Impact on Member States 

Under Policy Option 1 (+), Member States would incur moderate implementation costs, 
mainly related to improving data exchange with Europol and integrating Europol analytical 
capabilities into national investigative environments. 

One-off costs are estimated at approximately EUR 81 million in total (around EUR 3 
million per Member State on average), primarily linked to the deployment of automated 
data-loader solutions and the technical adjustments required to connect national systems 
with upgraded Europol platforms. Recurring annual costs are estimated at approximately 
EUR 16.2 million (corresponding to approximately EUR 113.4 million cumulatively over 
the 2028–2034 period), mainly related to maintenance of data loader infrastructure, system 
interfaces and operational support. 

Further  costs  would  arise  from  the  integration  of  EIS  and  EAS  into  national 
investigative environments, including updates to national case management systems, the 
adoption  of  common  data  standards  and  training  of  personnel.  These  investments  are 
estimated at  approximately  EUR 105 million in one-off costs and EUR 20 million in 

125 Costs relate mainly to infrastructure development, system integration, data migration and the operation of 
the EU Police Cloud platform, as well as the establishment of a secure EU Police Digital Identity framework 
for law enforcement users. 
126 See benefits section of Annex 3. 
127See costs section of Annex 3. 
128 See costs section of Annex 3. 
129 Costs primarily reflect the establishment of a dedicated EPPO support team within Europol responsible 
for  operational  analysis,  cross-checks  of  operational  data,  digital  forensic  support  and  coordination  of 
analytical activities supporting EPPO investigations. 
130 The necessary infrastructure and onboarding requirements are already covered.  

42 

 
 
 
 
annual recurring costs (corresponding to approximately EUR 140 million cumulatively 
over the 2028–2034 period). 

At  the  same  time,  Policy  Option  1  is  expected  to  generate  significant  operational 
efficiencies  for  national  authorities131.  Automated  data  loaders  would  reduce  manual 
processing  and  delays  in  information  sharing,  while  improved  Europol  systems  and 
embedded  analytical  services  would  allow  investigators  to  benefit  more  systematically 
from EU-level analytical capabilities. Measures addressing obstacles linked to DSC would 
not  generate  additional  costs  for  Member  States,  as  they  mainly  concern  internal 
procedures within Europol. 

Under  Policy  Option  2  (+/-),  the  economic  impact  on  Member  States  would  vary 
depending on the operational capabilities developed at EU level. 

For  measures  enabling  Europol  to  act  as  an  operational  service  provider  and 
information  hub,  Member  State  costs  are  expected  to  remain  very  limited,  as  the 
approach relies primarily on existing EU information exchange mechanisms, such as the 
Prüm II framework. One-off costs are estimated at approximately EUR 0.05 million per 
Member  State132,  reflecting  minor  technical  adjustments  required  to  enable  authorised 
queries through existing infrastructure. Recurring costs are expected to remain negligible. 

More substantial  costs would  arise from the  deployment of the EU Police Cloud and 
related  digital  infrastructure,  which  would  require  adjustments  to  national  systems, 
integration with the EU Police Digital ID framework, training and data migration. These 
investments are estimated at approximately EUR 67.5 million in one-off costs and EUR 
11.4  million  in  annual  recurring  costs133  (corresponding  to  approximately  EUR  79.8 
million cumulatively over the 2028–2034 period). 

Overall, although Policy Option 2 involves high implementation costs for Member States 
in relation to digital infrastructure, these investments are expected to generate long-term 
efficiency gains by enabling access to shared analytical tools and operational services at 
EU  level,  reducing  fragmentation  of  national  solutions  and  supporting  more  effective 
cross-border investigations. 

6.2 Social impacts 

6.2.1 Impacts on security and EU citizens 

Policy  Option  1  (+)  is  expected  to  have  a  positive  impact  on  internal  security  by 
strengthening the ability of national authorities and EU bodies to detect  and investigate 
cross-border criminal activity. Improved data availability and upgraded Europol systems 
would  enable  more  systematic  cross-checks  and  faster  analytical  support,  helping 
investigators identify cross-border links earlier and coordinate more effectively. 

Reinforced  cooperation  with  the  EPPO  would  reinforce  investigations  affecting  the 
Union’s financial interests, while stronger coordination with Eurojust would facilitate the 

131 See benefits section of Annex 3. 
132 See costs section of Annex 3 
133 See costs section of Annex 3 

43 

 
 
 
judicial  handling  of  complex  cross-border  cases,  including  those  involving  electronic 
evidence.  Embedding  Europol  analytical  tools  within  national  investigative  workflows 
would further reduce the risk of undetected cross-border criminal connections, ultimately 
contributing to a higher level of security for EU citizens. 

Policy  Option  2  (++)  is  expected  to  have  a  very  strong  positive  impact  on  security  by 
significantly strengthening the Union’s ability to detect, investigate and disrupt serious and 
organised crime. Faster and more systematic cross-checks across national databases under 
the  Prüm  II  framework  would  enable  investigators  to  identify  cross-border  criminal 
networks  earlier  and  act  more  quickly.  Shared  EU-level  operational  capabilities  and 
simplified data processing rules would substantially increase Europol’s analytical capacity, 
allowing  authorities  to  exploit  large  datasets  and  detect  criminal  patterns  that  would 
otherwise remain unnoticed.  

By making Europol’s capabilities directly accessible to investigators through shared digital 
infrastructure and strengthened operational presence in Member States, the option would 
enable faster, more coordinated and intelligence-driven investigations across the Union. 
Overall, this option would markedly improve the EU’s ability to prevent and disrupt cross-
border crime and terrorism, delivering tangible security benefits for EU citizens. 

6.2.2 Administrative impacts on national authorities 

Policy Option 1 (+) is expected to have a positive impact on the administrative efficiency 
of national law enforcement authorities by streamlining cross-border information exchange 
and  improving  the  operational  returns  of  cooperation  with  Europol.  Improved  data 
availability and automated data-sharing tools would reduce manual  administrative tasks 
and  delays,  while  upgraded  Europol  systems  would  provide  faster  cross-checks  and 
analytical support. Additional efficiency gains would arise from clearer guidance on DSC 
and  strengthened  cooperation  with  EU  bodies  and  agencies.  Embedding  Europol  tools 
more directly into national investigative workflows would further reduce administrative 
friction and improve the systematic use of EU-level information in investigations. 

Policy Option 2 (++) would result in strong administrative efficiency gains by simplifying 
procedures  and  expanding  EU-level  operational  support.  Allowing  Europol,  when 
authorised by Member States, to query national databases under the Prüm II framework 
would reduce administrative workload in cross-border investigations and enable Europol 
to  carry out  complex analytical  and forensic tasks on behalf of Member States. Further 
gains would arise from establishing Europol as a structural provider of analytical support 
to the EPPO to avoid multiple requests for information. The EU Police Cloud and Europol 
support offices would also facilitate easier access to Europol tools and expertise, improving 
operational interaction and reducing coordination burdens for national authorities. 

6.2.3 Youth impacts 

Both policy options (0) are not expected to have direct impacts specifically targeting young 
people. However, by strengthening the Union’s capacity to prevent and combat serious and 
organised crime, including offences that particularly affect minors, such as child sexual 

44 

 
 
exploitation or cyber-enabled crime, the measures may have indirect positive effects on 
young people. 

6.2.4 SMEs 

Both  policy  options  concern  the  operational  framework,  governance  and  cooperation 
mechanisms of Europol and competent public authorities. It does not introduce regulatory 
obligations, compliance requirements or direct operational impacts for SMEs. Both policy 
options are therefore not expected to have direct impacts for SMEs. 

6.3 Fundamental rights impacts 

The  two  policy  options  assessed  in  this  Impact  Assessment  involve  the  processing  of 
personal  data  in  the  context  of  law  enforcement  cooperation.  They  therefore  relate 
primarily to the fundamental rights to respect for private and family life (Article 7) and 
protection  of  personal  data  (Article  8)  of  the  Charter  of  Fundamental  Rights  of  the 
European Union. The analysis below assesses whether any interference with these rights 
is  necessary  and  proportionate  to  the  objective  of  general  interest  consisting  in  the 
prevention, detection and investigation of serious and organised crime and terrorism. 

6.3.1 Objective of general interest 

Policy Option 1 (++) 

Policy Option 1 contributes to the objective of general interest consisting in the prevention, 
detection and investigation of serious and organised crime and terrorism. By improving 
the  availability,  quality  and  timeliness  of  operational  data  exchanged  between  Member 
States and Europol, the option would strengthen the analytical capacity of law enforcement 
authorities  and  support  earlier  identification  of  cross-border  criminal  links.  Upgrading 
Europol’s systems and improving data exchange with other EU bodies and agencies would 
allow authorities to exploit operational information more effectively. 

Policy Option 2 (++) 

Objective of general interest 

Policy  Option  2  would  further  strengthen  the  Union’s  capacity  to  prevent,  detect  and 
investigate serious and organised crime and terrorism by significantly improving the ability 
of  law  enforcement  authorities  to  access,  process  and  analyse  operational  data  across 
borders. By enabling faster cross-checks across databases, expanding EU-level analytical 
capabilities and simplifying data processing rules, the option would allow authorities to 
exploit  large  and  complex  datasets  more  effectively  in  support  of  investigations.  This 
would enhance the detection of criminal networks, strengthen cross-border investigations 
and improve the overall effectiveness of EU action against serious and organised crime. 

6.3.2 Protection of personal data 

Policy Option 1 (0) 

Necessity 

The measures included in Policy Option 1 aim to address operational inefficiencies in the 
current framework for information exchange and analysis. In particular, fragmented and 

45 

 
 
largely manual data-sharing processes limit the ability of Europol and Member States to 
analyse operational information effectively and identify cross-border criminal connections. 
Improving data availability through automated tools and upgrading Europol systems would 
ensure  that  lawfully  shareable  information  can  be  processed  more  efficiently  and  used 
more systematically in criminal investigations. 

At  the  same  time,  the  option  does  not  introduce  new  categories  of  personal  data,  new 
processing  purposes,  or  additional  access  rights.  The  measures  primarily  concern 
improvements to the functioning of existing systems and procedures and therefore operate 
within the current legal framework governing the processing of personal data by Europol 
and national authorities. 

While  the  option  does  not  substantially  alter  the  existing  data-protection  framework, 
increased automation and interoperability may nevertheless increase certain risks related 
to erroneous data propagation, unauthorised access or wider dissemination of inaccurate 
information if safeguards are not effectively implemented. 

Proportionality 

The option preserves the existing safeguards governing the processing of personal data. 
Member States would retain control over the data they share with Europol and existing 
rules  on  purpose  limitation,  access  conditions  and  retention  periods  would  remain 
to  data  subject 
unchanged.  Measures  addressing  operational  challenges  related 
categorisation would focus on improving procedures and guidance rather than modifying 
the underlying legal obligations. 

Operational safeguards would continue to include role-based access controls, logging and 
traceability of access to operational data, differentiated handling codes defined by the data 
owner,  data-quality  verification  mechanisms,  and  supervision  by  the  Europol  Data 
Protection  Officer  and  the  European  Data  Protection  Supervisor  (EDPS).  Europol’s 
existing  information-security  framework,  including  encryption,  network  segmentation, 
secure authentication mechanisms and continuous security monitoring, would continue to 
apply to upgraded systems and automated exchange tools. 

In practice, automated data-loading solutions would not bypass Member State control over 
operational data. Member States would remain responsible for defining which categories 
of  information  may  be  shared  automatically,  under  which  conditions,  and  with  which 
handling restrictions. Automated exchanges would therefore remain subject to predefined 
operational parameters, auditability and ex post verification mechanisms. 

Conclusion 

Overall,  Policy  Option  1  respects  the  principles  of  necessity  and  proportionality  while 
maintaining the existing level of data protection safeguards. Its impact on the protection of 
personal data is therefore assessed as neutral (0). Although certain operational risks linked 
to increased automation remain, these are considered limited and manageable within the 
existing EU data protection, cybersecurity and supervisory framework. 

Policy Option 2 (-) 

Necessity 

46 

 
 
The  measures  address  operational 
limitations  currently  affecting  cross-border 
investigations,  particularly  delays  and  fragmentation  in  accessing  and  analysing 
operational  data.  Allowing  Europol,  when  authorised  by  Member  States,  to  perform 
queries in national databases connected under existing EU frameworks would enable faster 
identification  of  cross-border  links  in  complex  or  time-critical  investigations.  Shared 
services,  such  as  a  potential  EU  DNA  matching  service,  would  strengthen  forensic 
cooperation and reduce reliance on fragmented technical solutions. 

In  addition,  the  EU  Police  Cloud  would  provide  the  scalable  infrastructure  required  to 
process  large  and  complex  datasets  used  in  cross-border  investigations,  while  the 
simplification  of  DSC  rules  would  allow  lawfully  collected  data  to  be  processed  more 
efficiently. These measures are therefore necessary to ensure that operational information 
can be effectively used to combat increasingly digital and transnational forms of crime. 

At  the  same  time,  these  measures  increase  the  scale,  speed  and  interconnectedness  of 
operational  data  processing,  thereby  creating  heightened  risks  relating  to  cybersecurity, 
unlawful access, function creep, excessive data availability, potential re-use of data beyond 
the  original  operational  context,  and  the  processing  of  inaccurate  or  insufficiently 
categorised  data.  The  EU  Police  Cloud  in  particular  would  create  a  more  integrated 
operational  environment  with  a  significantly larger  user  base  and  increased  volumes  of 
sensitive law-enforcement information processed digitally across borders. 

Proportionality 

The interference with fundamental rights remains proportionate. Europol would act only 
on the basis of Member State authorisation and within its mandate, without centralising 
national  databases  or  altering  Member  State  ownership  of  data.  The  measures  do  not 
introduce fundamentally new categories of personal data or new processing purposes but 
improve  the  operational  use  of  data  already  lawfully  collected  for  law  enforcement 
purposes. 

Processing would remain subject to the safeguards provided under the Europol Regulation, 
the  Law  Enforcement  Directive  and  the  EUDPR,  including  purpose  limitation,  access 
controls  and  independent  supervision.  Technical  infrastructures  such  as  the  EU  Police 
Cloud would incorporate security-by-design features, strong authentication and traceable 
access management to ensure accountability. 

More specifically, the EU Police Cloud would rely on a multi-layered security architecture 
combining organisational, technical and legal safeguards. These would include end-to-end 
encryption of data in transit and at rest, strict compartmentalisation of operational datasets, 
role-based and attribute-based access controls, multi-factor authentication through the EU 
Police Digital Identity framework, continuous security monitoring, penetration testing and 
detailed audit logs enabling full traceability of user actions. 

Access  to  operational  environments  and  datasets  would  remain  limited  to  specifically 
authorised users acting within defined operational mandates and on a need-to-know basis. 
Different investigations and operational projects would remain logically separated through 
compartmentalised  access  environments,  preventing  unrestricted  cross-access 
to 
operational information. 

The processing of sensitive operational datasets would also remain subject to differentiated 
handling  codes,  retention  periods  and  supervisory  controls.  Europol’s  Data  Protection 

47 

 
 
Function and the EDPS would continue exercising oversight over compliance with data-
protection obligations, including in relation to large datasets, automated analytical tools 
and the use of artificial intelligence-supported functionalities. 

Regarding the simplification of DSC rules, safeguards would continue to require Europol 
to  assess  the  relevance,  reliability  and  necessity  of  operational  data  within  defined 
timeframes. The simplification would therefore not eliminate data-protection obligations, 
but rather adapt the sequencing and operational handling of categorisation requirements to 
avoid  unnecessary  delays  in  time-sensitive  investigations,  therefore  aligning  it  with  the 
EUDPR.  

Cybersecurity risks associated with the EU Police Cloud would furthermore be mitigated 
through compliance with the EU cybersecurity framework applicable to Union institutions 
and  bodies,  including  high  common  cybersecurity  standards,  incident  reporting 
obligations,  business  continuity  measures,  security  accreditation  procedures  and 
continuous  vulnerability  management.  Given  the  sensitivity  of  the  data  processed, 
implementation would likely require phased deployment, independent security testing and 
reinforced operational-security governance arrangements. 

Conclusion 

Overall, Policy Option 2 would increase the operational processing of personal data within 
EU  law  enforcement  cooperation  and  therefore  has  a  negative  impact  (-)  on  the 
protection of personal data compared with the baseline. Nevertheless, the interference 
with  fundamental  rights  remains  justified  by  the  objective  of  combating  serious  and 
organised  crime  and  terrorism,  and  the  measures  are  necessary  and  proportionate, 
while  maintaining  the  safeguards  and  oversight  mechanisms  provided  by  the  EU  data 
protection framework. 

Although  residual  risks  related  to  cybersecurity,  data  concentration  and  broader 
operational  access  cannot  be  fully  eliminated,  these  risks  are  expected  to  be  mitigated 
through a combination of legal limitations, technical safeguards, operational controls and 
independent supervision. The overall impact on fundamental rights is therefore considered 
proportionate in light of the security objectives pursued and the safeguards accompanying 
implementation. 

6.4 Environmental impacts 

Both  policy  options  are  not  expected  to  have  direct  environmental  impacts  (0),  as  they 
concern the organisation of law enforcement cooperation and the analytical and operational 
support provided by Europol. However, the options could have indirect positive effects on 
the environment.  Environmental  crime is  included among  the areas of criminal  activity 
listed  in  Annex  I  of  the  Europol  Regulation.  By  strengthening  Europol’s  analytical 
capabilities, operational support and cooperation with national authorities, Policy Options 
1  and  2  could  contribute  to  more  effective  detection  and  investigation  of 
environmental crime, such as illegal waste trafficking or wildlife trafficking. 

48 

 
 
7  HOW DO THE OPTIONS COMPARE? 

This  section  compares  the  policy  options  presented  in  Section  5  against  the  baseline 
scenario described in Section 5.3 and assesses their relative effectiveness in achieving the 
objectives identified in Section 4.  

Overall, both policy options would improve Europol’s capacity to support Member States 
in preventing and combating serious and organised crime and terrorism. However, they 
differ in the scale of change introduced, the level of investment required and the extent to 
which  Europol’s  operational  role  within  the  EU  internal  security  architecture  would 
evolve.  Policy  Option  1  focuses  on  reinforcing  and  modernising  the  existing 
cooperation model, whereas Policy Option 2 introduces a more integrated operational 
model with stronger EU-level capabilities. 

7.1. Addressing information gaps 

Both policy options address two closely linked aspects of the problem: the availability 
of operational information shared with Europol and the conditions under which Europol 
can process and that information. 

Policy Option 1 (Sub policy options 1.1 and 1.2) focuses on improving the functioning 
of  the  existing  information  exchange  model,  notably  through  automated  data  loaders, 
targeted data-sharing obligations and upgrades to Europol’s core information systems. 

In terms  of effectiveness, these measures  would significantly improve the availability, 
quality  and  timeliness  of  operational  information  available  to  Europol,  thereby 
strengthening its analytical support to Member States. However, the option would not fully 
address structural constraints affecting Europol’s capacity to process large and complex 
datasets, as the current framework for data subject categorisation would remain unchanged. 
At  the  same  time,  information  sharing  would  continue  to  rely  largely  on  voluntary 
contributions by Member States. 

In terms of efficiency, the option requires investment in digital infrastructure and system 
upgrades  but  largely  builds  on  existing  systems  and  cooperation  mechanisms.  These 
investments  are  expected  to  generate  operational  efficiencies  through  improved 
automation and interoperability. 

Regarding  coherence,  the  option  fully  preserves  the  current  decentralised  model  of 
information exchange and maintains Member States’ control over operational data. 

In  terms  of  fundamental  rights,  the  option  improves  data-sharing  efficiency  within 
existing safeguards and does not introduce new data, purposes or access rights. 

Policy  Option  2  (Sub  policy  options  2.1  and  2.2)  introduces  an  integrated  model  by 
allowing Europol, where authorised by Member States, to query certain national databases 
connected under EU frameworks and by simplifying the rules governing the processing of 
operational data by reforming data subject categorisation. 

In terms of effectiveness, these measures would significantly improve Europol’s ability 
to identify cross-border links and process large operational datasets, thereby enabling more 
systematic use of advanced analytical tools. 

In  terms  of  efficiency,  the  option  involves  higher  implementation  costs,  particularly 
related  to  the  development  of  shared  operational  capabilities  and  digital  infrastructure. 

49 

 
 
However, it may also generate long-term efficiency gains by reducing fragmentation of 
analytical tools across the Union. 

Regarding  coherence,  the  option  represents  a  more  significant  evolution  of  Europol’s 
operational role, but remains compatible with the EU legal framework, as Europol would 
continue to act in support of Member States. 

In terms of fundamental rights, the option would increase the operational processing of 
personal  data  compared  with  the  baseline.  Such  processing  would  nevertheless  remain 
subject  to  the safeguards and oversight  mechanisms provided under EU data protection 
law. 

Criterion 

Baseline 

Policy option 1 

Policy option 2 

Effectiveness 

Efficiency 

Coherence 

Fundamental 
rights 

0 

0 

0 

0 

7.2. Addressing operational gaps 

+ 

+ 

+ 

0 

++ 

+ 

+ 

- 

Both  policy  options  addressing  this  problem  concern  Europol’s  capacity  to  provide 
operational support to investigations across the Union. These limitations relate both to the 
level  of operational  support  provided to  Member  States and  to the coordination of EU-
level support between Europol and other EU actors involved in combatting cross-border 
crime. 

Policy  Option  1  (Sub  policy  options  1.3  and  1.4)  focuses  on  reinforcing  the  existing 
operational cooperation model by strengthening coordination between Europol and other 
EU actors and by bringing Europol’s capabilities closer to national investigators. 

In  terms  of  effectiveness,  these  measures  would  improve  the  overall  EU  support 
architecture  for  cross-border  investigations.  Embedding  Europol  tools  into  national 
investigative  workflows  would  support  earlier  identification  of  cross-border  links  and 
allow  Europol’s  analytical  capabilities  to  be  used  more  systematically  by  national 
authorities. Strengthened cooperation between Europol, the EPPO and Eurojust would also 
facilitate more efficient handling of complex cases. However, the option would primarily 
reinforce  the  current  cooperation  model  and  would  not  fundamentally  transform  how 
Europol’s capabilities are accessed and used by investigators. 

In terms of efficiency, the option requires significant investment in system integration and 
digital  infrastructure,  particularly  to  embed  Europol  analytical  tools  into  national  case 
management systems. At the same time, these investments build on existing cooperation 
structures and are expected to generate operational efficiencies by reducing administrative 

50 

 
 
 
burdens associated with manual information exchange and by improving the timeliness of 
analytical support. 

Regarding coherence, the option preserves the existing institutional balance within the 
EU internal security architecture. Europol would continue to operate as a support agency 
acting in close cooperation with national authorities and other EU actors. 

Policy Option 2 (Sub policy options 2.3 and 2.4) introduces a more integrated operational 
model aimed at bringing Europol’s capabilities closer to investigators and strengthening 
its role as a provider of operational services at EU level. 

investigators 

In  terms  of  effectiveness,  these  measures  would  significantly  enhance  Europol’s 
operational support to investigations. The EU Police Cloud and Europol support offices 
tools,  collaborative 
would  enable 
environments  and  technical  capabilities  more  directly  during  investigations,  facilitating 
large-scale  collaborative  investigations  and  more  effective  use  of  advanced  analytical 
tools.  At  the  same  time,  establishing  Europol  as  a  structural  provider  of  analytical 
capabilities to  the EPPO would ensure  a  more systematic use of Europol’s expertise in 
complex cross-border cases. 

to  access  Europol’s  analytical 

In terms of efficiency, the option involves substantial investment in digital infrastructure 
and operational capacity, particularly for the development of the EU Police Cloud and the 
deployment  of  support  offices  in  Member  States.  However,  the  use  of  shared  EU-level 
analytical tools and collaborative environments could generate long-term efficiency gains 
by reducing fragmentation of national solutions and enabling more efficient cross-border 
investigations. 

Regarding  coherence,  the  option  represents  a  more  significant  evolution  of  Europol’s 
operational role within the EU internal security architecture. The measures would remain 
compatible with the existing institutional framework for EU law enforcement cooperation. 

In  terms  of  fundamental  rights,  the  option  could  lead  to  a  moderate  increase  in  the 
operational  processing  of  personal  data  compared  with  the  baseline,  notably  due  to  the 
more systematic and collaborative use of Europol’s analytical tools within the EU Police 
Cloud. In addition, the simplification of the DSC framework would expand the categories 
of personal data that Europol may process for operational analysis in certain cases, where 
the DSC is not immediately possible and must be carried out as far as feasible and as early 
as possible. This may increase the volume of personal data processed compared with the 
baseline.  At  the  same  time,  the  use  of  a  common  EU-level  infrastructure  could  also 
strengthen safeguards by enabling more consistent security standards, access controls and 
audit mechanisms across the Union. In any event, such processing would remain subject 
to the safeguards and oversight mechanisms provided under EU data protection law. 

Criterion 

Baseline 

Policy option 1 

Policy option 2 

Effectiveness 

0 

+ 

++ 

51 

 
 
Efficiency 

Coherence 

Fundamental 
rights 

0 

0 

0 

8  PREFERRED OPTION 

+ 

+ 

0 

+ 

+ 

- 

Based on the comparison of policy options in Section 7 and the impacts assessed in Section 
6, the preferred approach consists of a package  of measures  combining elements from 
Policy  Options  1  and  2.  This  approach  addresses  both  the  information  gaps  affecting 
Europol’s role as an information hub and the operational limitations that constrain timely 
and effective support to investigations, with advanced capabilities acting as a cross-cutting 
enabler. 

Specific objective 

Policy option 

Main measure 

Information exchange 

Policy Option 1 (Sub 
policy option 1.1) 

Information exchange and 
advanced capabilities 

Policy Option 2 (Sub 
policy option 2.1) 

Strengthened data 
availability, processing and 
service 

Extension of Europol 
access to relevant data via 
the Prüm II framework 

Information exchange 

Policy Option 2 (Sub 
policy option 2.2) 

Reform of Data Subject 
Categorisation  

Operational support 

Policy Option 1 (Sub 
policy option 1.3) 

Enhanced EU inter-agency 
cooperation with Eurojust, 
AMLA 

Operational support 

Policy Option 2 (Sub 
policy option 2.3) 

Structural Europol-EPPO 
partnership 

Operational support 

Policy Option 1 (Sub 
policy option 1.4) 

Operational support and 
advanced capabilities 

Policy Option 2 (Sub 
policy option 2.4) 

Embedding Europol tools 
and systems in national 
investigations 

Operational integration of 
Europol into national 
investigations (EU Cloud, 
Europol support offices) 

Taken together, these measures form a coherent and mutually reinforcing reform of the 
EU law enforcement information architecture. 

52 

 
 
Options not retained 

Several  elements  considered  during  the  assessment  were  not  retained  in  the  preferred 
package.  In  particular,  Sub  policy  option  1.2  was  not  retained,  as  the  targeted 
improvements in data availability and automation provided under Sub policy options 1.1, 
1.4  and  2.4,  combined  with  the  structural  reform  of  data  subject  categorisation 
introduced  under  Sub  policy  option  2.2,  provide  a  more  effective  and  coherent 
framework for operational data processing. At the same, Sub policy option 1.3 is also not 
retained  because  exploiting  the  full  potential  between  Europol  and  the  EPPO  requires 
substantial reinforcements. 

8.1. Impacts of the preferred option 

Cumulative impact of the preferred package 

The preferred package generates cumulative impacts by combining measures that address 
different  but  interrelated  drivers  of  the  problem.  Taken  together,  these  measures 
strengthen  Europol’s  ability  to  combat  cross-border  crime  more  effectively  than  any 
individual measure alone. 

First, improvements in data availability and usability (Sub policy options 1.1, 2.1, 2.2 and 
1.4) enhance Europol’s capacity to receive, process and analyse operational information. 
This strengthens the analytical basis for cross-border investigations and improves the 
quality and timeliness of criminal intelligence products provided to Member States. 

Second,  reinforced  cooperation  with  EU  actors,  notably  Eurojust  and  the  EPPO  (Sub 
policy  options  1.3  and  2.3),  improves  the  coordination  between  operational  and 
prosecutorial  support  at  EU  level.  This  facilitates  more  effective  follow-up  of 
operational criminal intelligence and strengthens the overall EU response to serious and 
organised crime. 

Finally,  the  EU  Police  Cloud  and  related  operational  integration  measures,  including 
Europol  support  offices  (Sub  policy  option  2.4),  provide  the  scalable  digital  and 
operational  infrastructure  needed  to  support  more  advanced  data  analysis  and  closer 
day-to-day operational cooperation between Europol and national authorities, including in 
support of ongoing investigations. 

By combining  these elements, the preferred package improves the flow  of information, 
strengthens  operational  coordination  and  provides  the  technical  capabilities  needed  to 
support more integrated EU law enforcement cooperation. 

8.1.1 Financial impacts (+) 

The preferred package entails cumulative investments at both Member State and EU level 
while generating important efficiencies through synergies between the selected measures. 

In  particular,  overlaps  between  Sub  policy  options  1.1  and  1.4  generate  economies  of 
scale.  As  some  infrastructure  and  implementation  costs  are  shared,  the  combined 
implementation reduces costs by an estimated EUR 30 million in one-off expenditure and 
EUR  6  million  in  recurring  annual  costs  (corresponding  to  approximately  EUR  42 

53 

 
 
million  over  the  2028–2034  MFF  period)  compared  with  a  scenario  where  the  options 
would be implemented separately. 

The total estimated costs134 are: 

Costs 

Member States 

Europol 

One-off costs 

EUR 254.85 million 

EUR 239.8 million 

Annual recurring costs 

EUR 47.9 million 

EUR 78.4 million 

Recurring costs 
cumulative 2028-2034 

Total costs over 2028–
2034 (one-off + 
recurring) 

EUR 335.3 million 

EUR 548.8 million 

EUR 590.15 million 

EUR 788.6 million 

8.1.2. Social impacts 

Impact on security and EU citizens (++) 

Each  of  the  preferred  Sub  policy  options  contributes  individually  to  strengthening  EU 
internal security. When implemented together, their effects are cumulative and mutually 
reinforcing  because  they  address  successive  steps  of  cross-border  law  enforcement 
cooperation. Improved access to and usability of data (Sub policy options 1.1, 2.1, 2.2, 1.4) 
strengthens  the  information  base  for  investigations.  Stronger  cooperation  between  EU 
actors (Sub policy options 1.3, 2.3) ensures that this information can be operationally used 
and followed up at EU level. Modern digital tools and infrastructure (Sub policy option 
2.4) enable this information sharing and cooperation to take place efficiently at scale. 

Administrative impacts on national authorities (++) 

While  some  adjustments  and  implementation  efforts  will  be  required,  the  preferred 
package is expected to reduce administrative burden over time by simplifying information 
exchange,  improving  legal  clarity  and  enabling  more  efficient  operational  cooperation. 
This  contributes  to  greater  operational  effectiveness  and  strengthens  the  capacity  of 
national authorities to address increasingly complex and digitalised criminal threats. 

Youth impacts (0) 

The preferred option is not expected to have direct impacts  specifically targeting young 
people. However, by strengthening the Union’s  capacity to  prevent  and  combat serious 
crime, including offences that particularly affect minors, such as child sexual exploitation 

134 For more details see Annex 3. 

54 

 
 
 
and cyber-enabled crime, the measures may have indirect positive effects on the protection 
and safety of young people across the Union. 

8.1.3 Fundamental rights impacts 

Objective of general interest (++) 

The preferred package makes a significant contribution to the objective of general interest 
of preventing, detecting and investigating serious and organised crime and terrorism in the 
Union. By enabling earlier identification of cross-border criminal activities and facilitating 
more effective operational responses, the measures strengthen the Union’s overall capacity 
to protect citizens and address evolving security threats. 

Protection of personal data (0) 

Necessity 

Some elements of the preferred package increase Europol’s ability to query and analyse 
operational data in support of cross-border investigations (notably Sub policy options 2.1 
and 2.4), which may lead to a greater operational use of personal data. At the same time, 
the reform of data subject categorisation (Sub policy option 2.2) is necessary to address 
operational  inefficiencies  that  currently  limit  the  effective  use  of  lawfully  collected 
information. Together, these measures enable more timely and effective analysis of data 
relevant to serious and organised crime and terrorism. 

Proportionality 

The  impact  on  data  protection  remains  limited  and  proportionate.  The  measures  do  not 
introduce  new  categories  of  personal  data.  Processing  would  remain  subject  to  the 
safeguards  provided  under  the  EU  data  protection  framework,  including  purpose 
limitation, access controls and independent supervision. 

Conclusion 

Overall, the preferred package enhances Europol’s analytical capabilities while remaining 
within existing data protection safeguards. Its impact on personal data is therefore limited 
and proportionate.  

8.1.4 Environmental impacts (0) 

The preferred option is not expected to have direct environmental impacts. However, by 
strengthening  the  operational  capabilities  of  law  enforcement  authorities  to  investigate 
environmental  crime,  the  package  may  indirectly  contribute  to  the  protection  of  the 
environment. 

8.1.5 Feasibility (+) 

55 

 
 
All preferred measures are technically feasible as they build on existing legal frameworks, 
operational practices and IT infrastructure at EU and national level135. 

From  a  technical  perspective,  the  reform  primarily  relies  on  upgrading  and  integrating 
existing systems rather than creating entirely new architectures. Synergies with established 
EU  technological  frameworks,  including  those  developed  by  eu-LISA,  further  enhance 
feasibility by leveraging proven interoperability standards and secure digital infrastructure. 

From a political perspective, the preferred package remains proportionate and compatible 
with the current distribution of competences between the Union and the Member States. 

8.1.6 Impact on digitalisation (++) 

The preferred option strongly supports the digital transformation of EU law enforcement 
cooperation. 

Improved  data  availability  and  harmonised  rules  enhance  information  exchange  and 
operational analysis, while the EU Police Cloud provides the scalable digital infrastructure 
necessary  for  advanced  analytical  capabilities  and  secure  collaboration  across  Member 
States. 

8.2.REFIT (simplification and improved efficiency) 

In line with the Commission’s Regulatory Fitness and Performance Programme (REFIT), 
revisions  of  existing  EU  legislation  aim  to  simplify  rules  and  reduce  unnecessary 
administrative burden. In this context, the revision of the Europol legal framework seeks 
to streamline procedures and improve the efficiency of EU law enforcement cooperation. 

While  the  preferred  option  may  require  additional  engagement  from  Member  States, 
notably  in  authorising  Europol  to  query  certain  national  databases  and  ensuring 
connectivity to shared services, these efforts are offset by improved operational support, 
faster  cross-border  investigations  and  more  efficient  use  of  EU-level  analytical 
capabilities. In particular, the simplification of DSC (Sub policy option 2.2) will directly 
contribute to reducing administrative burden by introducing clearer procedures and more 
proportionate safeguards. Additional measures, such as technical guidance, training and 
centralised support provided by Europol, will further facilitate implementation. 

8.3.Application of the ‘one in, one out’ approach  

This initiative does not impose administrative costs on businesses and therefore does 
not trigger the ‘one in, one out’ adjustment mechanism. The measures primarily concern 
public  authorities  involved  in  law  enforcement  cooperation  and  do  not  introduce  new 
regulatory  obligations  for  the  private  sector.  As  a  result,  the  initiative  does  not  entail 
administrative  costs  or  savings  for  businesses  and  does  not  generate  direct  costs  for 
citizens. Any adjustment costs associated with the implementation of the preferred option 
will mainly concern public authorities, notably in relation to the adaptation of information 
systems and operational procedures. 

135 For example, the Prüm II framework. 

56 

 
 
 
At  the  same  time,  the  initiative  is  expected  to  generate  significant  public  benefits  by 
strengthening the Union’s capacity to prevent and combat serious and organised crime. 

9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The  Commission  will  monitor  the  impacts  of  the  preferred  option  through  the  existing 
evaluation  and  reporting  framework  under  Article  68  of  the  Europol  Regulation, 
which  provides  for  periodic  assessments  of  Europol’s  effectiveness,  efficiency  and  EU 
added value. To ensure coherence and avoid duplication, monitoring will rely primarily on 
Europol’s  established  reporting  tools136,  complemented  where  necessary  by  indicators 
aligned with the objectives of this initiative. 

Monitoring will cover outputs, results and broader impacts, including improvements 
in information exchange, operational support to cross-border investigations, including the 
provision of modern capabilities, and inter-agency cooperation. Particular attention will be 
given to data protection compliance, proportionality and fundamental rights safeguards, 
including supervision by the EDPS. Indicators will be collected annually from the entry 
into force of the revised Regulation.  

In  line  with  Article  68  of  the  Europol  Regulation,  the  Commission  will  carry  out  an 
evaluation  four  years  after  the  entry  into  force  of  the  revised  Regulation  to  assess  its 
effectiveness,  efficiency,  coherence,  relevance  and  EU  added  value,  and  to  inform  any 
future revision. Detailed monitoring indicators are set out in Annex 6. 

136 Including the Consolidated Annual Activity Report, SIENA and EIS reporting, reporting on Member State 
contributions under Article 7(11) of Europol’s Regulation, and Management Board performance indicators. 

57 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The lead DG is the Directorate-General for Migration and Home Affairs (DG HOME). The 
agenda  planning  (Decide)  reference  for  the  Proposal  for  a  Regulation  on  Europol  is 
PLAN/2025/524. 

ORGANISATION AND TIMING 

The initiative is planned for Q2 2026 by the Commission Work Programme 2026.  

The Interservice Steering Group (ISSG) on the Revision of Europol co-chaired by SG and 
HOME  was  composed  of  the  following  further  services:  SJ,  BUDG,  CNECT,  EEAS, 
ENEST,  FISMA,  FPI,  HR,  IAS,  INTPA,  JRC,  JUST,  MARE,  MENA,  OLAF, 
RTD,TAXUD. 

The ISSG on the Revision of Europol met four times to discuss the preparations for the 
upcoming initiative, namely on 11 April 2025, 11 December 2025, 11 February 2026 and 
10 March 2026.  

At the meeting of 11 April 2025, the ISSG discussed about the upcoming initiative and the 
terms  of  reference  for  an  external  study  supporting  the  back-to-back  evaluation  of  the 
Europol Regulation and the impact assessment for its revision. 

At the meeting of 11 December 2025, after the draft interim report of the external ’Study 
supporting  the  evaluation  and  the  impact  assessment  of  the  Europol  Regulation’  was 
presented by the contractor, focusing on the findings of the evaluation, the ISSG discussed 
the Commission report delivered pursuant to Article 68(3) of the Europol Regulation and 
the draft intervention logic for the upcoming legislative initiative prepared by DG HOME. 

At  the  meeting  of  11  February  2026,  the  ISSG  discussed  a  very  preliminary  draft  of 
sections 1-5 of this Impact Assessment report (SWD) to allow the Commission services to 
discuss and  agree on the problem definition, objectives and policy options. DG HOME 
later shared a  consolidated  version  of the draft SWD to  allow  the  ISSG to  comment  in 
writing by 4 March 2026. 

At  the  meeting  of  10  March  2026,  after  the  draft  final  report  of  the  external  ’Study 
supporting  the  evaluation  and  the  impact  assessment  of  the  Europol  Regulation’  was 
presented by the contractor, the draft SWD was discussed by the ISSG. 

Throughout the process, the ISSG was involved in all key intermediate steps: e.g., Call for 
Evidence,  consultation  strategy,  public  consultation  questionnaire,  targeted  surveys, 
inception report of the external study, etc.  

CONSULTATION OF THE RSB 

DG HOME has prepared this draft SWD for submission to the Regulatory Scrutiny Board 
(RSB) on 18 March 2026 with a view to the meeting with the RSB scheduled for 15 April 
2026. 

 
 
 
An upstream meeting with the RSB took place on 9 January 2026 to discuss the preparation 
of  the  impact  assessment  accompanying  the  revision  of  the  Europol  Regulation.  The 
discussion  focused  in  particular  on  the  problem  definition  and  evidence  base,  the 
distinction between problem drivers and consequences, the operationalisation of objectives 
in SMART terms, and the design and comparison of policy options. Particular attention 
was given to fundamental rights and data protection impacts, the coherence of Europol’s 
role  within  the  broader  EU  security  and  justice  architecture,  and  the  need  for  robust 
observational  data  and  cost-benefit  analysis.  The  RSB  also  provided  guidance  on 
strengthening the intervention logic, monitoring framework and overall reader-friendliness 
of the report. 

In  line  with  the  recommendations  contained  in  the  RSB's  positive  opinion  with 
reservations,  the  report  has  been  revised  to  address  all  shortcomings  identified  by  the 
Board. The table below summarises the recommendations made by the RSB and the actions 
taken to reflect them in the revised Impact Assessment report: 

RSB recommendation 

Changes introduced in the revised IA report 

1. 
Improve  assessment  of 
impacts on fundamental rights, 
and 
protection 
data 
cybersecurity. 
Clarify 
safeguards 
and  mitigation 
measures. 

2. Better explain Europol's legal 
and  operational  environment 
and  justify  the  need  for  a  new 
the  2022 
reform 
reform. 

following 

The section on fundamental rights was substantially 
revised. The assessment  now explains in  practical 
terms  how  safeguards  would  operate  for  each 
relevant  measure,  including  purpose  limitation, 
access  controls,  role-based  access  management, 
logging,  audit 
trails,  retention  periods,  prior 
Member State authorisation, EDPS supervision and 
judicial  remedies.  A  dedicated  assessment  of 
cybersecurity risks  linked to  the EU Police Cloud 
was  added,  covering  risks  such  as  unauthorised 
access, data breaches, insider threats, supply-chain 
vulnerabilities  and  cloud  concentration  risks, 
together  with  mitigation  measures 
including 
zero-trust 
security-by-design, 
architecture,  multi-cloud  deployment,  continuous 
monitoring, and incident response mechanisms. 

encryption, 

The problem definition and baseline sections were 
strengthened  to  provide  a  clearer  overview  of 
Europol's  position  within  the  EU  internal  security 
architecture and its interaction with Member States, 
Eurojust,  EPPO,  OLAF  and  other  EU  actors. 
Additional  explanation  was  added  to  demonstrate 
that  many  operational  challenges  stem  from 
developments that occurred after the adoption of the 
2022  reform,  including  the  rapid  increase  in  data 
volumes,  digitalisation  of  crime,  operational 
experience with the amended mandate, emergence 
of  new  technologies  and  implementation  lessons 
learned since entry into force. 

59 

 
 
3. Better distinguish regulatory, 
resource-
and 
operational 
related  drivers  and  strengthen 
evidence base. 

Reformulate 

specific 
4. 
objectives in SMART terms and 
strengthen 
to  policy 
links 
options. 

define 

Better 

policy 
5. 
measures, 
including 
cooperation  with  Eurojust  and 
the EU Police Cloud. 

6. Improve cost assessment and 
ensure  consistency  across  the 
report. 

and 

limitations 

operational 

he  problem  tree  and  problem  description  were 
revised  to  clearly  distinguish  between  regulatory 
constraints, 
and 
resource/capacity-related  challenges.  Additional 
examples  were 
evidence 
operational 
including 
incorporated 
Europol operational statistics, SIENA and Europol 
information system usage data, EPPO cooperation 
indicators  and 
figures, 
stakeholder 
findings 
consultations. 

information  exchange 

the  report, 

evaluations 

throughout 

from 

and 

The  specific  objectives  were  revised  following 
SMART principles. Objectives are now formulated 
in a more measurable and operational manner. The 
intervention  logic  was  strengthened  by  clarifying 
the  link  between  identified  problems,  specific 
objectives,  operational  objectives 
the 
corresponding  sub-policy  options.  Explanations 
were added throughout the policy options chapter to 
demonstrate  how  each  measure  contributes  to 
achieving the objectives. 

and 

For 

Additional  operational  detail  was  introduced  for 
several  measures. 
Europol-Eurojust 
cooperation,  the  report  now  explains  how  the 
enhanced  hit/no-hit  mechanism  would  function  in 
practice,  including  automation  and  information 
flows.  The  EU  Police  Cloud  description  was 
substantially  expanded, 
including  architecture, 
access  model,  data  processing  environment, 
analytical  tools,  interoperability  features,  cloud 
infrastructure, digital identity framework, APIs and 
operational safeguards. 

the  2028-2034  MFF.  Cost 

The  costing  methodology  was 
revised  and 
harmonised  across  the  report  and  annexes.  The 
assessment  now  clearly  identifies  the  reference 
tables 
period  as 
distinguish one-off and recurrent costs and present 
cumulative costs over the MFF period. Explanatory 
text  was  updated 
to 
consistently  refer  to  annual  and  cumulative  costs. 
as 
clarified 
The 
than 
implementation/adjustment 
rather 
and 
administrative  burden.  Cross-references 
calculations were aligned between the main report 
and Annex 3. 

costs  was 
costs 

throughout 

nature 

report 

the 

of 

60 

 
 
7.  Strengthen  monitoring  and 
evaluation  framework  and  link 
objectives 
indicators, 
to 
outputs, outcomes and impacts. 

The  monitoring  framework  was  comprehensively 
revised.  Indicators  are  now  explicitly  linked  to 
specific objectives and operational objectives. The 
framework  distinguishes  outputs,  outcomes  and 
impacts  and  introduces  measurable  performance 
indicators  were  added 
indicators.  Additional 
covering 
exchange,  operational 
information 
support, cooperation with EU agencies, deployment 
of  capabilities,  uptake  of  systems  and  user 
satisfaction. Targets  and measurement  approaches 
were  clarified  to  facilitate  future  evaluation  of 
effectiveness, efficiency and impact. 

EVIDENCE, SOURCES AND QUALITY 

The  impact  assessment  is  based  on  the  results  of  an  inclusive  and  comprehensive 
consultation of all relevant stakeholders (Annex 2), which equally informed the evaluation 
of the Europol Regulation (Annex 7). The consultation included scientific expertise, for 
instance  through  four  expert  workshops137.  Consultations138  and  desk  research  were 
conducted  also  in  the  context  of  the  ‘Study  supporting  the  evaluation  and  the  impact 
assessment  of  the  Europol  Regulation’,  which  contributed  to  the  evidence  base  for  this 
back-to-back  evaluation  and  impact  assessment139.  Observational  data  complement 
stakeholder views, reinforcing the evidence base. 

137 See Annex 2. 
138 Ibid. 
139 The draft final report of March 2026 was submitted to the RSB together with the draft of this SWD.  

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
62 

 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

1.  Introduction 

The preparation for the upcoming legislative proposal on Europol has been anchored in an 
inclusive  and  comprehensive  consultation  of  relevant  stakeholders  to  ensure  that  the 
proposal  reflects  both  the  political  ambition to  reinforce  Europol140  and  the  operational 
needs of the Member States.141 

In  line  with  the  Better  Regulation  Guidelines  and  Toolbox,  this  annex  provides  an 
overview  of  the  stakeholder  consultation  activities  undertaken  in  preparation  for  the 
initiative.  It  summarises  the  consultation  strategy,  the  stakeholders  consulted,  the 
consultation  methods  used,  the  main  views  expressed,  and  how  these  views  have  been 
taken into account in the preparation of the impact assessment. 

2.  Consultation strategy 

The consultation strategy followed three main phases. The first phase served to discuss 
extensively with the Member States at policy and senior official level to adequately scope 
their operational needs (May – June 2025). The second phase served to gather in-depth 
feedback and evidence from all relevant stakeholders, including on both the evaluation of 
the Europol Regulation and all the elements of the impact assessment, ranging from the 
definitions  of  the  problems  and  objectives  to  the  analysis  of  the  impacts  of  the  policy 
options and the comparison of policy measures (July 2025  – February 2026). The third 
phase served for discussions at political level (March 2026). 

3.  Consultation activities  

3.1  Phase  1:  extensive  consultations  with  the  Member  States  at  policy  and 
senior official level  

Scoping discussions with the Member States were held in multiple fora, notably:  

- the EU Council Standing Committee on Internal Security (COSI); 

- the High-Level Forum on the Future of EU Criminal Justice;  

- the Management Board of Europol;  

- the consultation kick-off meeting organised by DG HOME at senior official level;  

- the EU Council Law Enforcement Working Party (LEWP).  

140 See Political Guidelines for the Next European Commission 2024-2029 & ProtectEU. 
141 Joint Statement by the European Police Chiefs on the Future Development of Europol. 

63 

 
 
 
 
Regarding the outcomes of these consultations, Council discussions in COSI and LEWP 
showed Member States  broadly support reinforcing Europol’s operational role within 
the current treaty limits, while strongly rejecting the idea of a “European FBI” and being 
concerned about including hybrid threats as a crime area for which Europol is competent. 
At the High-Level Forum on EU Criminal Justice of 21 May 2025, judicial authorities 
also  expressed  support  for  strengthening  Europol’s  core  tasks,  particularly  data 
exchange and support for the EPPO. At the consultation kick-off meeting organised by 
DG  HOME  on  20  June  2025,  Member  States  expressed  consensus  on  increasing 
Europol’s  operational  effectiveness  without  transforming  it  into  an  executive  or 
intelligence  agency.  They  prioritised  faster,  more  flexible  support  for  national 
investigations. They cautioned against centralising expertise at the EU level alone. The 
dedicated discussion in the Management Board of Europol on 25 June 2025 revealed 
Member States’ support for reinforcing Europol’s role as the EU criminal information 
hub, improving processing of large data sets and addressing legal and technical obstacles 
in the data protection framework. 

3.2 Phase 2: In-depth evidence gathering 

3.2.1 Call for evidence  

The Commission published a call for evidence on the ‘Have your say’ web portal from 3 
July 2025 to 31 July 2025. Seventeen valid responses were received. Six position papers 
were  submitted  by  business  associations,  non-governmental  organisations  (NGOs)  and 
academia.  

Table – Responses to the call for evidence by stakeholder group and country of origin 

Stakeholder group 

Country of origin 

Number of responses  

Academic/research 
organisation 

Romania 

Business association 

Belgium 

Company/business 

Austria, Italy 

EU citizen 

Belgium,  Bulgaria,  Finland, 
Germany, Lithuania, Slovakia  

Non-EU citizen 

Mexico 

Non-governmental 
organisation (NGO) 

Belgium, United Kingdom 

Trade Union 

Belgium, Luxembourg 

1 

3 

2 

6 

1 

2 

2 

64 

 
 
 
Total 

17 

The main points raised by the respondents to the call for evidence: 

-  General  support  for  strengthening  Europol’s  mandate,  particularly  to  address 
emerging  threats,  with  many  calling  for  enhanced  operational  capabilities, 
specialised units, and a stronger coordinating role at EU level. 

-  Concerns regarding fundamental  rights  raised mainly by a digital rights NGO 

and some EU citizens. 

-  Emphasis  on  the  need  to  support  frontline  policing,  with  police  trade  unions 
stressing that any mandate changes should be accompanied by investments. 
-  Diverging views on the extent of Europol’s operational autonomy, with business 
associations and an environmental NGO favouring stronger operational powers 
to  serve  sectoral  priorities,  while  other  stakeholders  believe  Europol  should 
remain primarily a coordination and support body. 

3.2.2 Public consultation 

The Commission conducted a public consultation on ‘Law enforcement cooperation – new 
Europol regulation (proposed)’ via its ‘Have Your Say’ web portal for 12 weeks, between 
27 October 2025 and 15 January 2026. The public consultation aimed to gather insights 
on:  (i)  the  implementation  of  the  Europol  Regulation,  focusing  specifically  on  its 
effectiveness, efficiency, relevance, coherence, EU added value and impact; (ii) existing 
needs  and  gaps;  (iii)  quantitative  and  qualitative  inputs  to  support  the  Commission  in 
identifying possible policy measures to support Member States; and (iv) the effectiveness 
and  operational  functioning  of  existing  EU  tools.  The  consultation  received  33  valid 
replies. No coordinated campaigns were identified. Eight position papers were submitted 
by  three  NGOs,  one  EU  citizen,  one  public  authority,  one  business  association,  one 
company/business, and one stakeholder that identified as “other”.  

Table – Responses to the public consultation by stakeholder group and country of origin 

Stakeholder group 

Country of origin 

EU citizen 

Business association 

France,  Germany, 
United Kingdom 
Belgium 

Ireland, 

Italy, 

Company/business 

Belgium, Ireland, United States 

Consumer organisation 

Italy 

Non-governmental 
organisation (NGO) 

Belgium, United Kingdom 

of 

Number 
responses 
6 

1 

3 

1 

4 

65 

 
 
 
 
 
Public authority 

Other (not specified) 

Total 

Ireland, 

Croatia,  Cyprus, 
Italy, 
Germany,  Netherlands,  Norway, 
Spain, Switzerland 
Germany, Italy, Latvia 

13 

5 

33 

The main points raised by stakeholders in the public consultation were as follows:142 

▪  Overall effectiveness is assessed positively, with strong performance in core 
analytical  and  coordination  functions.  Respondents  generally  viewed 
Europol’s performance under the current Regulation as effective, particularly its 
role  as  the  EU  criminal  information  hub,  its  analytical  outputs  (e.g.  threat 
assessments  and  situation  reports),  and  its  coordination  of  investigative  and 
operational  actions.  At  the  same  time,  uncertainty  remained  higher  for 
cooperation  with  the  private  sector  and  for  the  development  of  centres  of 
expertise, and legal factors were most often identified as obstacles to effective 
implementation. 

▪  The  Regulation  is  considered  relevant  to  and  aligned  with  EU  priorities, 
with  high  satisfaction  for  operational  and  technological  support.  Most 
respondents judged Europol’s objectives and activities to be highly relevant or 
relevant to EU law enforcement and security priorities. Europol’s focus on key 
crime areas was seen as broadly aligned with EU priorities, and satisfaction was 
particularly high regarding operational investigative support and technological 
expertise  (including  digital  forensics,  AI-based  data  analysis  and  biometrics). 
There was limited appetite, or uncertainty, about expanding Europol’s focus to 
additional crime areas. 

▪  EU  added  value  is  widely  recognised.  An  overwhelming  majority  of 
respondents  rated  Europol’s  EU  added  value  positively,  and  more  than  half 
observed  positive  changes  attributable  to  the  Regulation.  In  the  absence  of 
Europol,  respondents  considered  that  Member  States  would  only  be  able  to 
conduct  comparable  investigations  and  information  exchanges  to  a  limited 
extent. 

▪  Implementation  challenges  relate  mainly  to  resources,  governance  and 
legal–technical  constraints.  While  respondents  generally  considered  that  the 
current Regulation enables Europol to fulfil its mandate, governance, oversight, 
and  resources  received  the  lowest  positive  ratings.  More  broadly,  legal  and 
procedural uncertainties (notably regarding access to data and admissibility of 
evidence),  technological  and  legal  disparities  between  Member  States,  and 
rapidly  evolving  digital  criminal  methods  were  identified  as  significant 
constraints on effective implementation.  

▪  Preferred pathways for revision favour non‑legislative measures and targeted 

142  For  further  information,  see  the  factual  summary  report  of  the  public  consultation  registered  under 
Ares(2026)2806442 
https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/14638-Law-enforcement-cooperation-new-Europol-regulation-proposal-/public-
consultation_en. 

published 

and 

at 

66 

 
 
 
 
 
amendments rather than a full mandate overhaul. 

3.2.3 Four thematic workshops on the future of Europol  

DG HOME organised four thematic workshops on the future of Europol to gather feedback 
at  technical  level  notably  from  Member  States’  experts.  Europol  participated  in  all 
workshops and the EPPO participated in the agenda point on Europol-EPPO cooperation. 
Each workshop was attended by around 100 experts. Overall, nineteen agenda topics were 
addressed and around a dozen written contributions by Member States were received by 
the Commission as a follow-up to the discussions. 

The  first  two  workshops  were  held  on  6  and  7  November  and  were  dedicated  to 
“Optimising  Europol’s  data  ecosystem  and  strengthening  Europol’s  role  as  the  EU’s 
operational  information  hub”  and  “Developing  EU-level  specialised  law  enforcement 
expertise  and  operational  innovation  within  Europol,  and  reinforcing  Europol’s  role  in 
tackling  persistent  and  emerging  security  threats,  including  within  the  EMPACT 
framework”.  The  third  and  fourth  thematic  expert  workshops  were  held  on  18  and  19 
December  and  were  respectively  dedicated  to  “inter-agency  cooperation,  notably 
strengthening law enforcement and judicial cooperation with the EPPO” and “resources, 
Europol’s human resources model, governance and data protection”.  

On optimising Europol’s data ecosystem and strengthening Europol’s role as the EU’s 
operational information hub, experts agreed on the need to upload, securely share and 
jointly analyse large sets of data in real-time. They stressed the need to have joint and 
simultaneous data analysis, paving the way towards a collaborative EU law enforcement 
digital space, as  a one-stop-shop working environment. They emphasised the need to 
bolster Europol’s capacities to cooperate with private parties. Experts expressed varying 
degrees of openness to a more active role for Europol in accessing existing information 
at both national and EU levels.  

On  strengthening  Europol’s  operational  role  in  coordinating  support  to  counter 
persistent  threats,  a  majority  of  experts  considered  that  the  operational  mechanisms 
already in  place  (OTFs,  EMPACT) work well and require only  additional funding to 
respond to their needs. Experts did not consider medium or long-term deployment of 
Europol  staff  (e.g.  the  European  Operational  Team  Costa  del  Sol)  necessary,  but 
supported targeted and flexible deployments, if required, and upon request by Member 
States. 

On  enhancing  EU-level  specialised  expertise  in  fighting  online  crime,  experts 
emphasised  the  operational  need  to  enhance  Europol’s  supportive  role  in  the  “digital 
space”.  They  underlined  the  benefit  of  technical  standardisation  and  discussed  on  an 
enhanced role for Europol in case the national authority cannot be identified.  

On reinforcing Europol’s support role in countering emerging criminal threats, experts 

67 

 
 
agreed that Europol’s capabilities should focus on the criminal law component. They 
did not propose adding hybrid threats as part of the forms of crime for which Europol is 
competent, noting that the current list of crimes already provides sufficient scope for 
requesting Europol’s support in response to their operational needs.  

On strengthening EPPO-Europol cooperation for greater operational impact, discussions 
highlighted  the  growing  demand  for  Europol  support  to  EPPO  investigations.  EPPO 
called  on  moving  from  constrained  information  sharing  toward  full  bidirectional 
information  exchange,  reinforced  analytical  capacities  at  Europol,  possible  dedicated 
structures  for  EPPO-related  crime  areas,  and  operational  support  on  the  ground  with 
Member States’ consent. While Member States broadly supported stronger operational 
cooperation, views diverged on creating dedicated Europol units and on legal changes. 
Many  experts  favoured  fully  exploiting  the  existing  legal  framework,  stressing  data 
ownership principles and better coordination.  

On building a stronger EU law enforcement-judicial cooperation continuum, there was 
a broad agreement on the added value of OTFs and JITs and on the need for enhanced 
Europol  support,  including  training,  coordination,  and  deconfliction.  Member  States 
called for simplified procedures and increased financial resources. Strong support was 
expressed  for  the  EU-funded  SIRIUS  project  and  for  establishing  a  permanent  joint 
Eurojust-Europol platform, notably for asset recovery, including crypto assets.  

On enhancing information sharing and aligned information management, Member States 
reaffirmed SIENA as the core secure communication channel and underlined the need 
to  harmonise  the  inter-agency  legal  framework  to  avoid  duplication,  particularly 
between Europol and Frontex. Some supported broader information exchange with other 
EU  actors,  including  AMLA,  ENISA,  the  ECB  (on  terrorism)  and  MAOC-N  (on 
maritime drug trafficking). 

On joining forces in digital services and cloud solutions, there was broad support for 
developing a secure, future-proof EU cloud solution to enhance data management and 
joint processing. Different options were discussed, ranging from a private Europol cloud 
provided  by  a  European  supplier  to  a  common  eu-LISA-hosted  infrastructure  for  the 
JHA domain. Experts agreed on the strong operational  need and on the necessity  for 
further reflection on the most appropriate model.  

On  Europol’s  data  protection  framework,  Member  States  widely  considered  data 
protection  rules,  as  currently  interpreted,  to  be  a  major  operational  constraint.  Many 
supported a review of Europol’s data processing powers, notably for uncategorised data, 
with  a  shift  towards  a  case-based  approach  aligned  with  national  practices,  while 
maintaining a high level of protection. Simplification of procedures and a review of data 
retention  periods  were  also  advocated,  particularly  in  light  of  the  EDPS’  strict 
interpretation. 

68 

 
 
On  strengthening  Member  States’  role  in  Europol  governance,  experts  agreed  on 
reviewing the functioning of the Europol National Units (ENUs) and strengthening their 
role  as  the  key  interface  between  Europol  and  national  authorities.  ENUs  should  be 
empowered  act  as  a  national  “mirror”  of  Europol,  enhancing  awareness,  trust  and 
effective use of the Agency’s tools. 

3.2.3 Targeted consultations in the context of the external supporting study 

An external study was commissioned to support the preparation of the initiative. It started 
in July 2025. The contractor carried out extensive consultation activities until March 2026. 
Notably,  these included  six  targeted surveys, more than 135 stakeholder  interviews (12 
exploratory interviews followed by more than 123 targeted interviews), six field visits, and 
three focus group meetings.  

The targeted surveys were developed for the following stakeholder groups: 

1.  National law enforcement authorities of the EU Member States. 
2.  National law enforcement authorities of third countries.  
3.  Law enforcement networks.  
4.  EU agencies, bodies and offices (BOAs). 
5.  Private parties- companies.  
6.  Non-governmental, civil society and research organisations.  

Interviews were conducted with: 

-  national authorities of the EU Member States, including Denmark (56); 
-  Europol staff members, including managers and senior managers (35); 
-  European Commission services (14); 
-  EU agencies143 (8); 
-  EU bodies and offices144 (4), 
- 
-  MAOC-N; 
- 
- 
- 

third countries146 (4) 
international organisations147(1); 
the private sector148 (2) 

law enforcement networks145(6); 

143 CEPOL, EIGE, EUDA, eu-LISA, Eurojust, Frontex. 
144 EEAS, EPPO, OLAF, EDPS. 
145 AIRPOL, ATLAS, EIFS, ESG, HRSN, RAILPOL. 
146 Australia, Brazil, Switzerland, Türkiye. 
147 Interpol. 
148 European Banking Federation; FEPORT. 

69 

 
 
 
 
-  youth organisations149 (1). 

The field visits took place in Europol and five Europol Member States.150 

The three focus group meetings were dedicated to:  

1.  national authorities of the EU Member States, including Denmark; 
2.  EU agencies and bodies for internal security, in line with ProtectEU; 
3.  Europol. 

The targeted survey for the national law enforcement authorities of the EU Member 
States received 109 responses from 24 out of 25 Europol Member States and can thus be 
considered as highly representative151. Most responses were received from Germany (50), 
Finland  (7),  Belgium  and  Italy  (6).  Responses  were  received  mostly  from  international 
police cooperation units (61%) and home affairs ministries (48%).  

The main points raised by survey respondents:152 

▪  Key evaluation findings: Europol is widely assessed as effective, relevant, and 
providing  strong  EU  added  value,  particularly  in  supporting  cross-border 
information  exchange,  operational  coordination,  and  investigations,  though 
relevance  is  more  mixed  in  areas  such  as  training,  innovation,  and  certain 
emerging domains. 

▪  Implementation  challenges:  Key  challenges  include  legal  and  procedural 
constraints  on  information  sharing,  uneven  data  contributions  and  follow‑up 
among Member States, limited automation and interoperability between Europol 
systems  and  national  databases,  resource  constraints,  administrative  and 
financial burdens, and variable awareness or uptake of certain Europol tools and 
innovation outputs. 

▪  Pathways  for  revision:  Forward‑looking  preferences  prioritise  increased 
resources, improved data sharing and interoperability, enhanced analytical and 
technical  capacity,  stronger  training  and  capacity  building,  and  clearer 
coordination with other EU agencies. Support for legislative changes is cautious 
and  focusing  mainly  on  expanded  analytical  and  data‑processing  capabilities 
rather than broad mandate expansion. 

149 Missing Children Europe. 
150 Austria, Italy, The Netherlands, Slovenia, Sweden. 
151  Germany,  Finland,  Belgium,  Italy,  Hungary,  Bulgaria,  Czechia,  Latvia,  Austria,  Romania,  Estonia, 
Portugal, Slovenia, Croatia, Cyprus, France, Ireland, Lithuania, Luxembourg, Malta, Netherlands, Poland, 
Slovakia, Sweden, noting the 109th response from the 24th Europol Member State was received much later 
than the deadline for replies and has therefore still to be included in the report produced by the contractor.   
152 Due to the large number of responses from Germany (50) and as several other countries also provided 
multiple replies, the data was cleaned and collated at a country level to provide a single aggregated response 
per Member State. For each country, averages or sums were calculated across all the quantitative questions, 
and if any options in a multiple-choice question were selected this counted as a response. 

70 

 
 
 
The targeted survey for EU BOAs received 13 responses, namely from all the EU justice 
and home affairs agencies concerned153, “EU agencies and bodies for internal security” of 
direct relevance to the implementation of ProtectEU154, and two more155. 

The main points raised by survey respondents: 

▪  Key evaluation findings: Cooperation with EU Agencies is generally seen as 
strategically  effective  and  aligned  with  EU  security  objectives.  Europol’s 
activities  are  broadly  relevant  to  agency  mandates,  particularly  for  EU-level 
coordination, but vary in operational impact depending on mandates and working 
arrangements. Overall, Europol provides strong EU added value as a central hub 
for information, analysis, and cross-border support, complementing the roles of 
other EU Agencies. 

▪  Implementation challenges: Key challenges include gaps in the timeliness and 

completeness of information sharing (notably with Eurojust). 

▪  Pathways for revision: Forward‑looking considerations prioritise strengthening 
and updating existing  cooperation frameworks rather than structural  overhaul, 
with emphasis on more systematic information sharing, enhanced analytical and 
operational  capacity,  improved  resourcing,  streamlined  contact  points,  and 
expanded  joint  work,  including  through  the  EU  Innovation  Hub  for  Internal 
Security. 

The  targeted  survey  for  national  law  enforcement  authorities  of  third  countries 
received 22 individual responses156. 

The main points raised by survey respondents: 

•  Key  evaluation  findings:  Cooperation  with  third-country  authorities  is 
generally  seen  as  effective,  particularly  in  cybercrime,  drug  trafficking, 
operational  analysis,  SIENA-enabled  information  exchange,  joint  operations, 
and training, with strong recognition of Europol’s role in addressing evolving 
criminal methods. Europol’s support is broadly aligned with third country needs, 
although  relevance  is  weaker  in  terrorism-related  cooperation  and  some 
innovation  areas.  Overall,  Europol  delivers clear EU added value by enabling 
cooperation with Member States, strengthening cross-border data exchange and 
analysis, and providing coordination and intelligence capabilities that would be 
difficult to achieve independently. 

•  Implementation challenges: Key challenges include legal and data protection 
constraints  on  information  sharing,  limited  or  absent  direct  access  to  Europol 
data  and  systems  (notably  for  Schengen  Associated  Countries),  operational 
needs falling outside the scope of existing agreements, resource constraints, and 
occasional delays in feedback or request processing. 

153 CEPOL, EIGE, eu-LISA, EUAA, EUDA, Eurojust, FRA, Frontex. 
154 ENISA, EPPO, OLAF. 
155 ELA, EMSA. 
156 From Albania, Australia, Bosnia and Herzegovina, Brazil, Colombia, Ecuador, Georgia, Iceland, Japan, 
Kosovo, Moldova, North Macedonia, Norway, Switzerland, Türkiye, UK, Ukraine, USA. 

71 

 
 
 
•  Pathways  for  revision:  Forward‑looking  preferences  prioritise  more  flexible 
and inclusive cooperation arrangements, including improved access to Europol 
systems and operational data, broader participation in analysis projects, JITs and 
OTFs, strengthened analytical and training capacities, and targeted adjustments 
to  cooperation  frameworks  to  address  emerging  threats  and  close  operational 
gaps for associated and partner countries. 

The targeted survey for law enforcement networks received 20 individual responses. 

The main points raised by survey respondents: 

•  Key  evaluation  findings:  Cooperation  with  Europol  is  generally  seen  as 
effective, particularly in coordination and support through information sharing, 
analysis,  and  innovation  tools,  although  some  note  greater  operational 
coordination is expected. Europol’s activities are broadly relevant to European 
law enforcement networks, especially in analysis, coordination, and innovation, 
but  vary  depending  on  mandate  fit  and  operational  needs.  Overall,  Europol 
provides  strong  EU  added  value  as  a  central  hub  for  intelligence,  secure 
information  exchange,  analytical  capacity,  innovation,  and  cross-border 
coordination. 

•  Implementation  challenges:  Key  challenges  include  legal  and  procedural 
barriers  to  information  sharing,  delays  or  gaps  in  operational  data  exchange, 
limited  analytical  and  technical  capacity,  resource  and  funding  constraints, 
administrative burdens. 

•  Pathways  for  revision:  Forward‑looking  preferences  prioritise  strengthening 
practical  support  rather 
including  simplified 
administrative  and  funding  procedures,  improved  information‑sharing  tools, 
enhanced  analytical  and  operational  capacity,  clearer  mandate  alignment  with 
network  needs,  and  more  structured,  long‑term  support,  with  mixed  views  on 
mandate expansion balanced against preserving network autonomy. 

than  wholesale  redesign, 

The  targeted  survey  for  private  parties-  companies  received  20  responses,  almost 
entirely from companies which are known to cooperate with Europol. 

The main points raised by survey respondents: 

▪  Key evaluation findings: From the private sector perspective, cooperation with 
Europol  is  generally effective, particularly in  information sharing, operational 
collaboration, and established public–private partnerships, though effectiveness 
is  less  clear  in  research  and  innovation  activities.  Europol’s  engagement  is 
broadly  relevant,  especially  in  financial  services  and  cybersecurity,  but  varies 
across  sectors  due  to  uneven  awareness  and  involvement.  Overall,  Europol 
provides strong EU added value as a central hub for cross-border coordination, 
intelligence,  and  public–private  cooperation,  delivering  capabilities  and  scale 
beyond national efforts. 

72 

 
 
 
 
▪  Implementation  challenges:  Key  challenges  include  legal  constraints  on 
information sharing, limited clarity on Europol’s specific intelligence needs and 
feedback  mechanisms,  fragmentation  and  technical  limitations  of  information 
sharing platforms. 

▪  Pathways  for  revision:  Forward‑looking  preferences  focus  on  strengthening 
and  scaling  existing  cooperation  models  rather  than  structural  overhaul,  with 
emphasis on clearer guidance and legal certainty, more specialised and secure 
information‑sharing platforms, enhanced operational collaboration and feedback 
loops,  improved  resourcing  of  successful  partnerships,  and  governance 
arrangements that ensure transparency and standardisation. 

The targeted survey for non-governmental, civil society and research organisations 
received responses from 14 organisations157. 

The main points raised by survey respondents: 

▪  Key evaluation findings: Europol’s engagement with civil society is effective 
mainly  in  targeted,  project-based  and  research-driven  areas,  while  overall 
effectiveness  is  harder  to  assess  due  to  limited  interaction.  Its  activities  are 
generally  seen  as  relevant  and  coherent  with  civil  society  priorities  on  cross-
border crime and analysis, though gaps remain in prevention, victim support, and 
integrating human and digital rights. 

▪  Implementation  challenges:  Key  challenges 

limited 
transparency and accessibility of engagement mechanisms, uneven awareness of 
cooperation  opportunities,  administrative  barriers,  and  concerns  regarding 
governance, accountability, and the fundamental rights implications of expanded 
data processing and AI‑based analysis. 

identified 

include 

▪  Pathways  for  revision:  Forward‑looking  preferences  emphasise  establishing 
structured  and  inclusive  engagement  with  NGOs  and  civil  society,  clearer 
contact  points  and  advisory  mechanisms,  strengthened  transparency  and 
oversight, and reinforced safeguards for fundamental rights. 

Field visits to Member States aimed at gathering qualitative, context-specific evidence on 
Europol’s cooperation with Member States. 

The main points raised by the interviewees during the field visits to Member States: 

▪  National  authorities  highly  value  Europol’s  role  in  facilitating  cross-border 
information  exchange,  analytical  support  and  operational  coordination. 
However, investigative responsibility and judicial accountability must remain at 
national level, with Europol acting in a supportive and complementary capacity. 
Information  exchange  is  functional  but  constrained  by  legal,  technical  and 
organisational  barriers.  Limited  interoperability  between  national  systems  and 

▪ 

157  The  14th  response  was  received  much  later  than  the  deadline  for  replies  and  has  therefore  still  to  be 
included in the report produced by the contractor. 

73 

 
 
 
 
 
Europol  tools,  reliance  on  manual  uploads  and  lack  of  automation  create 
administrative burdens.  

▪  Strict  interpretation  of  data  protection  provisions  is  viewed  as  increasingly 
burdensome  in  fast-moving  operational  contexts,  limiting  actionable  criminal 
intelligence delivery.  

▪  Europol’s strength lies in filtering, contextualising and prioritising information. 
Proactive  identification  of  cross-border  links,  emerging  phenomena  and 
structured analytical coordination across crime areas were cited as areas where 
Europol delivers clear EU added value. 

▪  Duplication  of  analysis  across  Member  States  is  a  as  source  of  inefficiency. 
There is broad support for stronger interoperability and smarter automation. At 
the  same  time,  any  expansion  of  access  to  sensitive  data  would  require 
mechanisms to maintain trust among Member States. 

4. Main horizontal findings of the consultation 

4.1 Problem definition 

There was broad agreement among stakeholders that Europol and national authorities face 
persistent information gaps when investigating cross-border crimes and identifying threats, 
and  that  Europol’s  operational  support  remains  limited,  including  cooperation  with  EU 
agencies and EPPO. Information gaps reduce effectiveness in the EU-level fight against 
serious  crime,  while  operational  cooperation  faces  legal  and  practical  constraints.  The 
current mandate limits Europol’s ability to provide optimal support in certain areas. 

4.2 Views on strengthening Europol’s role 

All  stakeholder  groups  recognise  Europol’s  clear  EU  added  value  as  a  central  hub  for 
cross‑border information exchange, analysis, and coordination that cannot be replicated at 
national  level.  Across groups, there  is  also  convergence around the nature of Europol’s 
coordination role as the EU’s criminal intelligence hub and as a provider of specialised 
expertise and analytical support, rather than as an entity replacing national authorities. This 
includes  support  for  stronger  cooperation  with  partners.  Member  States  are  eager  to 
enhance Europol’s capacity to support complex cross-border investigations provided that 
national competences remain respected, clear safeguards for trust-based cooperation are 
maintained  (starting  with  the  data  ownership  principle)  and  proportionality  is  ensured. 
Conversely,  stakeholder  views  diverged  on  the  extent  and  modalities  of  the  structural 
changes required.  

5. How stakeholder views have been taken into account 

Stakeholders’ views informed the initiative throughout the process in several ways. Most 
importantly,  the  problem  definition  and  the  objectives  were  refined  to  reflect  the 
operational  needs  of  the  Member  States.  For  instance,  the  focus  group  with  Europol 
confirmed information gaps as a primary constraint for the effectiveness of investigations, 
with  Europol’s  support  capacity  being  limited  mainly  by  uneven  and  insufficient  data 

74 

 
 
 
contributions from Member States, and voluntary information sharing approaches having 
widely reached their limits. 

The policy options “reinforcing Europol’s existing model” and “a new model for Europol” 
were  tested  with  the  main  stakeholders,  especially  through  the  focus  group  meetings, 
proving effective to capture a wide range of desirable policy measures. Implementation 
considerations  were  reflected  in  the  sequencing  and  design  of  policy  measures.  Where 
views  diverged,  the  impact  assessment  presents  a  balanced  analysis  grounded  in 
proportionality, feasibility and EU added value. 

How have stakeholder views been taken into account? A prominent example  

Targeted survey for the EU Member States’ national law enforcement authorities 
– Figure 10 – Question 10: Are there, in your view, any criminal or security threats 
or offences that should be added or removed from Europol’s mandate to better address 
current and emerging security challenges? 

16 Europol Member States opposed making Europol competent for new forms of crime, 
while 8 Europol Member States (7 + 1 late respondent) suggested broadening Europol’s 
mandate by adding new forms of crime to Annex I, especially hybrid threats, but also 
tax crime and others, or by removing the list altogether. 

The Commission services took note of Member State experts’ position expressed at the 
thematic workshops that Europol can already provide support to counter the criminal 
law dimension of hybrid threats insofar as they materialise in any of the several forms 
of crime for which Europol is competent. Notably, Europol can support crime detection 
and  analysis  and  coordinate  law  enforcement  responses,  which  it  must  do  without 
interfering with the competences of national intelligence agencies. 

75 

 
 
 
The Commission services also took note of Member State law enforcement agencies’ 
position expressed over bilateral discussions that, while hybrid threats are transversal in 
nature, Europol’s support against hybrid threats has in practice been provided mostly 
through a counter-terrorism angle, without fully mobilising Europol’s capabilities across 
all its various operational centres. Europol could instead mobilise the capabilities of all 
its operational centres to respond to requests from national law enforcement authorities 
and fully support national investigations, exploiting all its supportive potential under the 
current mandate, by deploying its entire toolbox in the most relevant crime areas. 

This does not require changes to Europol’s mandate and has thus been excluded by the 
impact assessment report. 

7. Conclusion 

The extensive consultation process confirmed the centrality of the identified problems and 
the need to adapt Europol’s support to evolving security challenges. While stakeholders 
expressed  different  levels  of  ambition  regarding  structural  changes,  there  was  broad 
recognition  of  the  need  to  strengthen  Europol’s  support  to  Member  States  in  tackling 
serious and organised crime, cybercrime and terrorism. The impact assessment reflects the 
evidence  gathered  and  seeks  to  strike  a  balance  between  ambition,  operational 
effectiveness, legal certainty and political feasibility. 

76 

 
 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

1.1 EU citizens 

All  preferred  options  aim  to  improve  the  prevention,  detection,  investigation,  and 
prosecution of serious and organised crime, directly benefiting citizens. By enhancing 
the availability, structure, and usability of law enforcement data, the package supports: 

•  Earlier detection of cross-border criminal networks. 
•  Faster  identification  of  suspects  and  links  between  cases  in  multiple  Member 

States. 
Improved asset tracking and coordinated operational responses. 

• 
•  Stronger protection in both physical and digital environments. 

Citizens benefit from a higher level of security while safeguards on data protection and 
fundamental rights remain fully respected. 

1.2 National authorities 

a.  Law enforcement officers 

The initiative equips officers with enhanced operational tools, including: 

•  Better tools to query data stored in the Europol systems. 
•  Structured  and  semi-automated  data  exchange  through  integrated  national  case 

management systems and the EU Police Cloud. 

•  Europol  support  in  data  processing,  analytics  and  operational  coordination, 

including cross-border investigative leads. 

•  Clearer  and  standardised  procedures  for  inter-agency  cooperation  with  Eurojust 

and the EPPO. 

These  improvements  reduce  delays,  avoid  duplication,  and  strengthen  the  quality  and 
timeliness of cross-border investigations. 

b.  IT organization in Member States 

IT teams are affected primarily during initial implementation: 

• 

Initial investment to connect national CMS to Europol platforms and the EU Police 
Cloud. 

•  Simplified maintenance and upgrades due to centralised integration, reducing long-

term operational burden. 

•  Streamlined interoperability and harmonised data standards across national and EU 

systems. 

77 

 
 
 
1.3 EU level 

a.  Europol 

•  Acts  as  the  central  analytical  and  operational  hub  for  EU  internal  security, 

integrating national and EU-level datasets. 

•  Provides structured operational support to Member States, including intelligence 
analysis,  cross-border  link  detection,  advanced  biometric  matching  and  case 
prioritisation. 

•  Supports real-time coordination and structured exchange between Member States, 

EPPO and Eurojust. 

•  Ensures that national CMS integration and the EU Police Cloud facilitate faster, 

automated and reliable access to actionable information. 

•  Delivers  scalable  technical,  digital,  and  forensic  capacity  without  centralising 

national data or replacing national investigative powers. 

Europol’s reinforced role allows for more proactive, timely and consistent support across 
complex  investigations,  increasing  operational  efficiency  and  EU-wide  situational 
awareness. 

b.  Eurojust 

•  Gains access to more structured, reliable, and timely information from Europol to 
support judicial cooperation and coordination of cross-border prosecutions which 
facilitates  the  work  of  joint  investigation  teams  (JITs)  as  well  as  mutual  legal 
assistance requests. 

•  Benefits from more efficient workflows with Europol information systems. 
•  Enhanced information quality and timeliness enables more efficient coordination 
in  serious  and  organised  crime  cases,  strengthening  legal  certainty  and 
effectiveness of judicial processes. 

c.  EPPO 

•  Gains  streamlined  access  to  operational  data  and  analytical  outputs  provided  by 

Europol, enabling quicker decision-making in cross-border prosecutions. 

•  Strengthened structural partnership with Europol ensures that EPPO investigative 

needs are systematically integrated into EU-level operational workflows. 

•  Receives  coordinated 

including 
prioritisation  of  cases,  operational  insights,  and  access  to  enhanced  analytical 
products. 

in  cross-border 

investigations, 

support 

•  The  partnership  improves  the  quality,  consistency,  and  speed  of  EPPO-led 
prosecutions,  reinforcing  EU-level  enforcement  capacity  while  maintaining 
national procedural autonomy. 

2.  SUMMARY OF COSTS AND BENEFITS 

Cost of the baseline scenario 

Unless  otherwise indicated, all cost  estimates presented in  this section are expressed in 
current prices (2026 EUR) and cover the period 2028–2034, corresponding to the duration 
of 
to 
the  next  Multiannual  Financial  Framework  (MFF).  One-off  costs  refer 
implementation  and  deployment  expenditure  incurred  during  the  roll-out  phase  of  the 

78 

 
 
measures, while recurrent costs refer to average annual operational expenditure over the 
same  period.  The  same  methodological  assumptions  and  calculation  basis  are  used 
throughout the main report and the supporting annexes. 

In  financial  terms,  the  baseline  scenario  assumes  the  continuation  of  Europol’s  current 
funding trajectory without the additional investments associated with the policy options 
assessed  in  this  impact  assessment.  Baseline  projections  are  based  on  the  historical 
evolution of Europol’s annual adopted budget between 2017 and 2025 and extrapolated 
over the 2028–2034 MFF period.. 

Two projection approaches were considered in order to reflect possible future expenditure 
patterns. 

First, a linear growth scenario assumes that Europol’s budget continues to increase by 
approximately EUR 15 million per year, corresponding to the average annual increase 
observed between 2017 and 2025. Under this assumption, Europol’s total budget over the 
next Multiannual Financial Framework (MFF 2028–2034) would amount to approximately 
EUR 2.28 billion. 

Second, a constant growth rate scenario assumes that the historical growth rate observed 
between 2017 and 2025 continues over the projection period. This corresponds to an annual 
growth  rate  of  approximately  9.41%,  resulting  in  a  projected  budget  of  approximately 
EUR 2.87 billion over the same MFF period. 

For  the  purposes  of  the  impact  assessment,  the  linear  growth  scenario  is  used  as  the 
conservative  baseline,  while  the  constant  growth  scenario  illustrates  a  possible  upper-
bound trajectory reflecting the increasing operational demand on Europol. 

These projections provide a range for the expected evolution of Europol’s budget under 
the  baseline  scenario.  They  reflect  the  continued  expansion  of  Europol’s  operational 
responsibilities and analytical support functions, while assuming no structural changes to 
its  mandate,  operational  model,  or  technological  infrastructure  beyond  incremental 
adaptations within the current framework. 

For the purpose of this impact assessment, the baseline therefore assumes a total Europol 
budget  envelope  in  the  range  of  EUR  2.3–2.9  billion  for  the  period  2028–2034  (as 
compared to the current EUR 1.53 billion), reflecting the continuation of current trends 
without  the  additional  investments  associated  with  the  policy  options  assessed  in  the 
following section. 

79 

 
 
Cost of the preferred option 

The table below presents the costs associated with the preferred option (in million EUR). 
One-off costs are presented as cumulative implementation costs over the deployment phase 
of the preferred option,  while recurrent  costs  cover the cumulated annual  average  costs 
during the 2028–2034 period. 

No costs are identified for citizens/ consumers and businesses given the costs associated 
with the policy measures are directed at EU-level or national public administrations. 

II. Overview of costs – Preferred option 

Citizens/ 
Consumers 

One-off/ 
Recurrent 

Businesses 

Administrations 

One-off/ 
Recurrent 

One-off 

Recurrent  

Sub policy option 
1.1 -  

Data loaders 

Sub policy option 
1.1 -  

Upgrade of 
systems and tools 

Direct costs 

N/A 

N/A 

Direct costs 

N/A 

N/A 

54 (Member 
States) 

75.6 (Member 
States) 

5 (Europol) 

7 (Europol) 

27 (Member 
States) 

37.8 (Member 
States) 

56 (Europol) 

78.4 (Europol) 

80 

 
 
 
 
Sub policy option 
1.3 -  

Automation of the 
Europol-Eurojust 
hit/ no hit 
mechanism 

Sub policy option 
1.3 - 

Institutionalisation 
of SIRIUS  

Sub policy option 
1.4 -  

Europol digital 
platforms 
embedded in 
national 
investigations 

Sub policy option 
2.1 -  

Access to national 
databases 

Sub policy option 
2.1 -  

DNA matcher 

Sub policy option 
2.2 -  

Simplified rules to 
reduce the 
administrative 
burden of data 
subject 
categorisation 

Sub policy option 
2.3 -  

Europol as 
structural provider 
of information, 

Direct costs 

N/A 

N/A 

Direct costs 

N/A 

N/A 

Direct costs 

N/A 

N/A 

Direct costs 

N/A 

N/A 

Direct costs 

N/A 

N/A 

0 (Member 
States) 

0 (Member 
States) 

2 (Europol) 

7 (Europol) 

0 (Member 
States) 

0 (Member 
States) 

0 (Europol) 

1 (Europol) 

105 (Member 
States) 

140 (Member 
States) 

50 (Europol) 

56 (Europol) 

0 (Member 
States) 

0 (Member 
States) 

6 (Europol) 

30.1 (Europol) 

1.35 (Member 
States) 

2.1 (Member 
States) 

5 (Europol) 

14 (Europol) 

Direct costs 

N/A 

N/A 

0 

0 

Direct costs 

N/A 

N/A 

0 

0 (Member 
States) 

77.7 (Europol) 

81 

 
 
 
 
 
 
 
analytical support 
and capabilities to 
the EPPO  

Sub policy option 
2.4 -  

EU Police Cloud  

Sub policy option 
2.4 - 

EU Police Digital 
ID 

Sub policy option 
2.4 -  

Europol support 
offices 

Direct costs 

N/A 

N/A 

Direct costs 

N/A 

N/A 

13.5 (Member 
States) 

4.2 (Member 
States) 

143.7 (Europol) 

278.6 (Europol) 

54 (Member 
States) 

75.6 (Member 
States) 

2.5 (Europol) 

3.5 (Europol) 

Direct costs 

N/A 

N/A 

0 

0 (Member 
States) 

45.5 
(Europol) 

All  one-off and recurrent  costs are implementation costs. No regulatory charges, hassle 
costs, administrative costs or indirect costs were identified and therefore are not quantified. 
These are all provisional estimates that would need to be confirmed, including how the 
costs are split between the different Member States. As a result, the confidence margin of 
cost estimates cannot be better than 20-25% at this early stage in a project. What is stable 
is  how  the  costs  of  the  various  measures  compare  with  each  other.  Where  precise 
operational  expenditure  data  were  not  available,  recurring  costs  were  estimated  using 
standard  lifecycle  costing  assumptions  derived  from  comparable  EU  large-scale  IT 
systems and agency operational expenditure patterns. Unless otherwise specified, annual 
maintenance and support costs are estimated at approximately 20% of initial deployment 
costs. 

Sub policy option 1.1: Strengthened data availability, processing and service 

This option entails upfront investment at both Member State and Europol level, primarily 
driven  by  data  loaders  as  well  as  system  and  tools  (including  enhance  use  of 
interoperability tools). 

For Member States, one-off costs (EUR 81 million aggregated, approx. EUR 3 million 
per Member State) relate mainly to: 

a)  Deployment of automated data-loader solutions; 
b)  Adaptation of national systems to interface with upgraded Europol tools; 
c)  Integration, testing and limited workflow adjustments; 
d)  Training of end-users. 

The deployment of data-loaders is estimated to range between EUR 1 million and EUR 3 
million per Member State depending on the size of the Member States’ databases and their 
level of existing integration. An average of EUR 2 million was therefore taken as a basis. 

82 

 
 
 
 
 
 
 
 
 
The remaining EUR 1 million results from the point b) to d). The basis was similar projects 
in the past where Member States had to integrate workflow adjustments. 

Recurring costs (EUR 16.2 million annually, approx. EUR 600 000 per Member State), 
corresponding  to  approximately  EUR  113.4  million  cumulatively  over  the  2028–2034 
MFF period. These costs reflect maintenance, system support and continued operational 
use. It is calculated as a standard 20% rate of the one-off costs based on similar simulations 
and building on past experience. Costs remain moderate as the option does  not require 
entirely new national systems, but builds on existing infrastructure and voluntary uptake 
of EU-level services. 

For Europol, one-off costs (EUR 61 million) are driven by: 

•  Major upgrades of core ICT systems (SIENA, EIS, EAS, QUEST+); 
•  Development  of  centralised  interoperability  solutions  and  harmonised  data 

models (UMF); 

•  Design and deployment of standardised data loaders; 
•  Joint procurement structures and specialised ICT recruitment. 

The  costs  are  inspired  by  similar  costs  incurred  by  EU  Agencies  that  built  similar 
technologies. For instance, the cost of building the shared Biometric Matching Service by 
eu-LISA for the Interoperability Regulations15820. The cost figure has been updated from 
the original 2018 estimate to account for inflation between 2018 and 2026, ensuring that 
the values reflect current price levels and purchasing power. 

Recurring  costs  are  estimated  at  EUR  11.2  million  annually,  corresponding  to 
approximately  EUR  78.4  million  cumulatively  over  the  2028–2034  MFF  period.  These 
costs cover maintenance, cybersecurity, governance, operational support, and reinforced 
technical and analytical staff. It is calculated as a standard 20% rate of the one-off costs159. 

Although the option requires significant initial investment, it is expected to generate long-
term efficiencies through: 

•  Economies of scale via joint procurement; 
•  Reduced duplication of national developments; 
•  Europol-supported optimisation and harmonisation of systems. 

The  financial  effort  therefore  reflects  a  structural  modernisation  of  the  EU  law 
enforcement  information  architecture,  with  medium-  to  long-term  savings  and 
operational gains. 

Sub policy option 1.3: Measure 1 for a reinforced Europol’s support to the EPPO 

One‑off  costs  for  Member  States  are  expected  to  be  negligible  or  very  limited,  as  the 
measure  concerns  the  creation  of  new  Europol‑level  capacities  (including  a  dedicated 
support unit and time‑bound Task Forces) and does not entail structural changes to national 

158 Regulation (EU) 2019/817 & Regulation (EU) 2019/818. 
159 As for instance in the impact assessment accompanying the JITs Collaboration platform – development 
cost: €8.4 million; annual maintenance and operation: €1.7 million. Ratio: 1.7/8.4≈20% 

83 

 
 
 
systems,  procedures  or  staffing.  All  direct  operational,  staffing,  training  and  equipment 
costs are expected to arise at EU level (Europol and, where relevant, EPPO). Any potential 
impacts on Member States would be indirect and implementation‑specific, and no material 
national cost drivers have been identified. 

Recurring costs for Member States are expected to be negligible or very limited, as the 
measure establishes new capacities at EU level (Europol and EPPO) and does not entail 
new obligations for national authorities. In particular, the measure does not introduce new 
duties, workflows, reporting requirements or compliance obligations for Member States, 
nor  does  it  require  contributions  of  staff,  procedural  adaptations  or  the  maintenance  of 
additional  processes  at  national  level.  Any  potential  impacts  on  Member  States  would 
therefore be indirect and implementation‑specific, and no material recurring cost drivers 
have been identified at this stage. 

No separate one‑off costs are calculated for Europol, because the costing approach already 
captures them within the annual cost estimates. Indeed, the annual costs are based on the 
average  resources  allocated  to  Europol  officers  –  a  benchmark  that  already  includes 
salaries, onboarding, training, equipment, and other personnel‑related expenses. 

The recurrent costs to Europol stem from establishing a dedicated Support Team for EPPO 
investigations, which requires the long‑term employment of additional specialised officers. 
These  staff  carry  out  operational  analysis,  cross‑checks,  and  digital  forensics,  and  their 
salaries and related personnel expenses form the ongoing cost driver. Based on projected 
staffing needs, recurrent costs are estimated to range from EUR 8.7 million in 2028 to EUR 
11.8  million  in  2034,  with  an  annual  average  of  EUR  10  million,  corresponding  to  an 
estimated  cumulative  cost  of  approximately  EUR  70  million  over  the  2028–2034  MFF 
period. 

Sub policy option 1.3: Measures 2 and 3 for a strengthened continuum of EU-level 
support to law enforcement cooperation through Europol and judicial cooperation 
through Eurojust 

Both the one‑off costs for Member States and the recurring costs for Member States are 
expected  to  be  negligible,  as  the  measures  regard  cooperation  between  Europol  and 
Eurojust and the support they provide to Member States in return. 

The  measures  would  largely  build  on  existing  technical  infrastructure  and  operational 
arrangements  between  Europol  and  Eurojust.  For  the  hit/no-hit  mechanism,  precise 
estimation  of direct  one-off costs is  challenging, as  these would depend on the level  of 
technical ambition chosen for automation and the extent of system integration pursued. A 
light-touch  approach  focused  on  enhancing  existing  interfaces  would  entail  minimal 
additional expenditure, while more advanced automation solutions could involve moderate 
investment  in  system  configuration  and  security.  For  the  SIRIUS  Project,  the 
institutionalisation within both the Europol and Eurojust Regulations would not require the 
creation of new infrastructure – SIRIUS is currently operational and supported by existing 
systems,  workflows  and  personnel  –  but  rather  organisational  adjustments,  procedural 
alignment and limited technical refinement. 

84 

 
 
The  automation  of  the  hit/no-hit  mechanism  is  expected  to  reduce  the  staff-intensive 
manual  exchanges  currently  required  under  the  baseline,  generating  administrative 
efficiency  gains.  The  recurring  costs  for  SIRIUS  are  expected  to  broadly  follow  the 
baseline  level  of  resources  already  devoted  to  the  project,  with  adjustments  reflecting 
demand  and  operational  scope.  This  corresponds  to  estimated  recurrent  costs  of 
approximately EUR 1 million annually for Europol, or around EUR 7 million cumulatively 
over the 2028–2034 MFF period. 

The institutionalisation of SIRIUS and the upgrading of the Europol–Eurojust hit/no-hit 
mechanism are expected to generate a minimal positive impact on efficiency compared to 
the baseline. Under SIRIUS Phase II (2021–2025), the total project budget amounted to 
approximately EUR 3.49 million over four years (EUR 2.16 million for Europol; EUR 1.33 
million for Eurojust), with 7 contract agents supporting its activities at Europol and 4 at 
Eurojust.  Institutionalisation  would  not  necessarily  require  a  substantial  increase  in 
resources  beyond  this  envelope  but  would  shift  funding  from  a  contribution-agreement 
model to stable internal budget lines within Europol (and Eurojust), potentially requiring 
the  conversion  of  contract  agents  into  temporary  agents  and  modest  additional 
administrative overhead.  

Regarding  the  hit/no-hit  mechanism,  the  current  manual  and  template-based  model  has 
proven  highly  burdensome  and  operationally  ineffective,  requiring  extensive  manual 
verification and layered authorisations for minimal operational output. Of the two possible 
implementation modes, the person-to-system approach is likely to be more proportionate 
and  immediately  feasible  from  an  efficiency  perspective,  as  it  limits  large-scale  data 
transfers  while  reducing  manual  workload  and  preserving  data  ownership.  The  more 
ambitious system-to-system model could generate higher long-term analytical gains but 
would entail greater upfront IT development and legal alignment costs. Even if the volume 
of  meaningful  hits  remains  modest,  a  more  automated  and  scalable  mechanism  would 
reduce  transaction  costs,  improve  timeliness  and  increase  the  likelihood  of  detecting 
genuinely relevant cross-case links at an earlier stage. 

Sub  policy  option  1.4:  Europol’s  digital  platforms  embedded 
investigations 

in  national 

Member  States:  One-off  costs  are  estimated  at  EUR  105  million,  reflecting  the 
implementation of new criminal information strategies that integrate both national and EU-
level  investigative  lifecycles.  This  includes  updating  national  systems  supporting  law 
enforcement procedures, such as CMS, Single Point of Contact CMS and corresponding 
police  records,  mapping  existing  data  and  workflows  to  the  UMF  standard.  National 
workflows  will  be  adapted  to  integrate  systematic  use  of  QUEST+  and  data  loaders, 
alongside  associated  training  and  change  management  for  staff  to  ensure  proper 
adoption. Recurring  costs are estimated at  EUR  20 million per year, corresponding to 
around EUR 140 million cumulatively over the 2028–2034 MFF period, covering ongoing 
operational adjustments, refresher training and maintenance of updated national workflows 
and IT systems. 

85 

 
 
Europol: One-off costs are estimated at EUR 50 million, covering the upgrade of central 
data ingestion components, including extending Europol Case Management Systems and 
other databases (e.g. Europol Information System) to handle EU-wide object identifiers 
and scaling up processing capacities. Costs also include reinforcement of the dedicated 
team  responsible  for  facilitating  integration  between  Europol  and  national  systems, 
ensuring  smooth  operational  collaboration.  Additionally,  costs  cover  standardisation 
efforts, including the development of guidance documents supporting Member States’ new 
criminal information lifecycle strategies. Recurring costs are estimated at EUR 8 million 
per year, corresponding to around EUR 56 million cumulatively over the 2028–2034 MFF 
period,  reflecting  ongoing  support  to  Member  States,  continued  maintenance  and 
monitoring  of  upgraded  systems  and  operational  assistance  to  ensure  effective 
implementation of new workflows and interoperability practices. 

Sub policy option 2.1: Europol as an operational service provider and information 
hub 

The first part of the cost assessment focuses exclusively on access via the existing Prüm 
framework. Under Prüm, Member States’ costs remain negligible, as the measure builds 
on the existing legal and technical architecture and does not  require new large-scale IT 
systems  for  simple  query-only  access.  According  to  the Prüm  II  Impact  Assessment160, 
establishing technical connectivity (e.g. for DNA matching) has been estimated at around 
EUR 300 000 per Member State for DNA and similar biometric exchange functionality, 
reflecting moderate one-off investments for automated integration with existing systems. 
Consequently, the incremental costs for Member States under  Sub policy option 2.1 are 
considered limited, and estimated to EUR 50 000 per Member State as this option does 
not  introduce  additional  legal  access  rights  nor  require  complete  redesign  of  national 
infrastructures. 

For Europol, costs linked to access to national databases are primarily driven by: 

•  Additional  forensic  experts  and  operational  staff  to  follow  up  on  matches, 
consistent  with  estimates  in  the  legislative  financial  statement  accompanying 
proposal  for  a  Prüm  II  Regulation161  which  foresee  staff  costs  for  search 
verification by EU agencies; 

•  Reinforcement  of  information  management  capacities  to  ensure  secure  and 

efficient data flows; 

•  Limited system adaptations to handle increased volumes. 

The estimated costs for the EU DNA matcher are informed by operational cost estimates 
developed by forensic authorities in the context of preparatory work for a pilot project. In 
particular, a budget proposal prepared by the Netherlands Forensic Institute (NFI) for a 
two-year  pilot  project  foresees  a  dedicated  project  team  including  forensic  experts,  IT 
developers  and  project  management  staff,  supported  by  technical  infrastructure  and 

160 SWD(2021) 379. 

161 COM (2021) 784 final 

86 

 
 
 
 
 
operational overhead. The budget calculations rely on standard governmental salary scales 
and include an overhead rate of approximately 25 %, consistent with typical EU project 
financing structures.  

The  pilot  proposal  assumes  that  most  personnel  would  be  employed  directly  by  the 
participating  forensic  institute,  although  additional  costs  could  arise  if  specialised  IT 
expertise  needs  to  be  sourced  through  subcontracting.  Such  subcontracting  could 
potentially double certain personnel costs, illustrating the importance of relying on existing 
institutional capacities where possible. Those costs would be shifted towards Europol in 
line with sub policy option 2.1. The estimations consider that 75% of the recurring EUR 2 
million  annual  adjustment  costs  (corresponding  to  approximately  EUR  14  million 
cumulatively  over  the  2028–2034  MFF  period)  would  represent  HR  costs.  With  the 
remaining being divided between travel, equipment and other goods and services costs.  

These operational estimates confirm that developing and testing a shared EU-level DNA 
matching  capability  requires  a  relatively  limited  recurring  adjustment  cost  notably 
covering HR costs. The cost assumptions used for Policy Option 2.1 therefore reflect a 
realistic implementation scenario based on existing forensic cooperation initiatives. 

The  baseline  for  this  assessment  is  not  zero,  as  many  Member  States  already  rely  on 
third-country based matching solutions managed outside the EU framework. Over time, 
Union-level costs under this option are expected to be offset by: 

•  Reduced  duplication  of  national  efforts  in  forensic  matching  and  follow-up 

work; 

•  Economies of scale from shared EU-run services rather than multiple national or 

external systems; 

•  Avoidance of third-country dependency costs associated with non-EU provider 

solutions. 

The investment therefore represents not only operational reinforcement but also a  long-
term strategic consolidation of EU capabilities. 

Sub policy option 2.2: Simplified rules to reduce the administrative burden of data 
subject categorisation 

Policy option 2.2 on DSC would significantly enhance Europol’s operational flexibility 
and  its  capacity  to  process  and  analyse  information  in  a  timely  manner,  while  not 
requiring  substantial  initial  financial  investment.  The  measure  primarily  entails 
legislative alignment, clarification and simplification of the existing framework, rather 
than  the  development  of  new  IT  systems  or  structural  reorganisation.  As  such, 
implementation  costs  would  be  limited  and  largely  confined  to  internal  adjustments, 
updated guidance and targeted training. 

Importantly,  the  option  would  reduce  or  eliminate  the  resource-intensive  procedures 
linked to data subject categorisation under the current framework. Staff time currently 
devoted to ex ante categorisation, verification and corrective compliance actions could 
instead  be  redirected  towards  operational  analysis  and  investigative  support.  This 
reallocation  of  resources  is  expected  to  generate  tangible  administrative  savings  and 

87 

 
 
efficiency  gains  over  time.  Overall,  the  combination  of  limited  (to  no)  upfront 
investment  and  sustained  operational  efficiencies  justifies  a  very  positive  cost 
assessment, although precise quantification of these efficiency gains remains subject to 
uncertainty at this stage due to limited comparable operational data. 

Sub  policy  option  2.3:  Europol  as  structural  provider  of  information,  analytical 
support and capacities to the EPPO 

The one-off costs for Member States are expected to be negligible or very limited, as the 
measure  does  not  require  them  to  provide  additional  staff,  adapt  national  systems,  or 
assume  operational  expenditures.  The  initiative  is  designed  to  operate  at  EU  level,  and 
therefore  does  not  generate  structural  investment  needs  at  national  level.  Likewise,  no 
significant  recurring  costs  are  anticipated  for  Member  States,  as  they  would  neither 
contribute personnel nor cover ongoing operational, administrative or compliance-related 
expenses linked to the reinforced cooperation framework. 

For Europol, no separate fixed start-up costs are identified, since the costing methodology 
is  based  on  the  average  annual  cost  per  staff  member,  which  already  incorporates 
salaries, onboarding, training, equipment, IT access and other personnel-related overheads. 
As a result, initial implementation costs are embedded within the overall annual resource 
envelope. 

The  recurrent  costs  for  Europol  arise  primarily  from  the  establishment  of  a  dedicated 
Support  Team  for  EPPO  investigations,  requiring  the  long-term  employment  of 
additional specialised officers. These staff members would carry out operational analysis, 
cross-checks, digital forensic support and structured case coordination, with an estimated 
annual  average  cost  of  EUR  10.1  million,  corresponding  to  around  EUR  70.7  million 
cumulatively  over  the  2028–2034  MFF  period.  In  addition,  permanent  cooperation 
mechanisms, including reinforced coordination structures and liaison arrangements, would 
entail further staffing needs, with estimated additional annual costs of less than EUR 1 
million (less than EUR 7 million cumulatively over the 2028–2034 MFF period). Overall, 
the financial impact is concentrated at EU level and reflects a structural reinforcement of 
analytical and prosecutorial support capacities. 

Sub policy option 2.4: Measure 1 on the EU Police Cloud 

The  initial  investment  costs  associated  with  the  deployment  of  the  EU  Digital  Police 
Cloud  and  the  EU  Police  Digital  ID  are  substantial,  reflecting  the  scale  and  strategic 
nature of the infrastructure.  

For Member States, one-off costs are estimated at EUR 13.5 million for the EU Police 
Cloud,  EUR  0.5  million  per  Member  State  to  bring  national  law  enforcement  ICT 
infrastructure and criminal  investigators’ endpoints (laptops, tablets  and smartphone) in 
line  with  a  set  of  harmonized  rules  for  the  technical  interoperability  and  security  of 
applications and digital services, notably when provided on classified networks, and EUR 
54 million for the EU Police Digital ID (i.e. EUR 2 million per Member State for stepping 
up the national digital identity scheme for criminal investigators based on a Digital Identity 
wallet  level  high,  for exhaustively  issuing  such credentials,  and integrating the national 
police identity scheme within the wider EU digital police scheme). Recurring costs of EUR 

88 

 
 
0.6 million per year for the Cloud (approximately EUR 4.2 million cumulatively over 
the 2028–2034 MFF period) to maintain the national law enforcement ICT architecture up 
to  the evolving common standards  and EUR 10.8 million per year for the Digital ID 
(approximately EUR 75.6 million cumulatively over the 2028–2034 MFF period) for the 
Digital ID to insure the level of authentication against the Police Cloud is maintained over 
time up to the latest standards and is kept available to the evolving investigators’ staff. 

For Europol, one-off investments amount to EUR 143.7 million for the EU Police Cloud 
which  account  for  the  extensive  migration  of  operational  data  processing  operated  by 
Europol to a platform based self-service architecture, (applications such as EIS, analysis 
projects,  biometric  identification,  crypto  asset  tracing,  OSINT,  digital  forensics  and 
especially  those  limited  to  Europol’s  analysts)  for  the  establishment  of  harmonized 
technical rules applicable to national ICT infrastructures, and for the initial set-up costs of 
Cloud Services, particularly for classified information and EUR 2.5 million for the EU 
Police  Digital  ID  for  renovating  Europol’s  identity  and  access  management  (IAM) 
platform  and  establishing  harmonized  rules  for  national  authorities  issuing  such  IDs. 
Recurring costs are estimated at EUR 39.8 million annually for the Cloud, corresponding 
to around EUR 278.6 million cumulatively over the 2028–2034 MFF period, to maintain 
and develop  the portfolio of online applications  and most importantly  for operating the 
online service and EUR 0.5 million per year for the Digital ID (around EUR 3.5 million 
cumulatively over the 2028-2034 MFF period) for maintaining both the IAM platform and 
stirring the evolution of common standards on a Police Digital Identity at EU level. These 
costs cover infrastructure development, secure hosting environments, identity and access 
management solutions, system integration, data migration, cybersecurity safeguards, and 
ongoing technical management. 

Despite  the  scale  of  the  initial  expenditure,  these  investments  represent  a  structural 
modernisation  of  EU  law  enforcement  digital  capabilities.  By  consolidating  processing 
environments,  standardising  secure  access  through  a  common  Digital  ID,  and  reducing 
fragmentation  across  disparate  national  systems,  the  initiative  is  expected  to  generate 
significant long-term efficiencies. Cost savings will stem from economies of scale, reduced 
duplication of infrastructure, lower maintenance overhead, and streamlined cross-border 
data exchange. Member States benefit from significant cost efficiencies, including reduced 
investments in hardware, software licenses, maintenance and IT staffing, with indicative 
savings  estimated  at  15-30 %  compared  to  independent  deployments.  Operationally, 
national authorities gain faster access to cross-border data, harmonised analytical outputs, 
and  real-time  collaboration  capabilities,  while  reducing  duplication  of  effort  and 
inconsistencies between systems. 

Over time, the enhanced processing capacity and secure digital architecture will enable 
faster  analytics,  improved  operational  coordination,  and  more  automated  workflows. 
These efficiencies allow both Europol and Member States to reallocate resources toward 
strategic and operational priorities, strengthening collective investigative capabilities while 
ensuring  a  scalable,  secure,  and  future-proof  digital  backbone  for  EU  internal  security 
cooperation. 

89 

 
 
Sub policy option 2.4: Measure 2 on Europol support offices 

Taking into account standard EU employment costs, including salaries, social security 
contributions, expatriation and household allowances where applicable, as well as limited 
operational expenditure such as secure IT connectivity, encrypted communications, basic 
office equipment and essential coordination travel, a modest Europol support office would 
be expected to generate EU-level costs in the range of approximately EUR 400,000 to 
EUR 650,000 per year. This estimate assumes a small footprint structure, composed of a 
limited  number  of  specialised  staff  embedded  in  or  co-located  with  relevant  national 
counterparts, without requiring significant infrastructure investment. 

Under a limited rollout scenario of five to ten Europol support offices, annual EU-level 
costs would therefore likely range between approximately EUR 2 million and EUR 6.5 
million,  corresponding  to  approximately  EUR  14  million  to  EUR  45.5  million 
cumulatively over the 2028–2034 MFF period, depending on staffing levels, host-country 
conditions  and  the  intensity  of  operational  engagement.  These  estimates  remain 
proportionate,  as  they  reflect  a  light  and  scalable  deployment  model  focused  on 
coordination,  facilitation  and  analytical  support  rather  than  autonomous  operational 
structures. Over time, such offices could generate indirect efficiency gains by improving 
information flows, accelerating case coordination and reducing transaction costs linked to 
cross-border cooperation. 

III. Contribution to the administrative burden reduction targets 

Administrative costs 

New recurrent 
costs (INs) 

Removed 
recurrent 
costs (OUTs) 

Net cost (Ins 
– OUTs) 

New one-
off costs 
(Ins) 

All businesses 

in which SMEs 

Public administrations 

Citizens 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Removed 
one-off 
costs 
(OUTs) 

n/a 

n/a 

n/a 

n/a 

IV. Overview of relevant Sustainable Development Goals 

Sustainable Development Goals 

Expected progress towards the goal 

No. 16: Peace, justice, and strong 
institutions 

The initiative is expected to strengthen the rule of law and enhance 
security within the EU by reinforcing the operational effectiveness  
of Europol. 

Clarifying and, where appropriate, reinforcing the role of Europol in 
supporting  Member  States  in  the  fight  against  cross-border  and 
serious organised crime will enhance the Agency’s contribution to 

90 

 
 
 
 
tackling  transnational  threats,  including  terrorism,  cybercrime  and 
other forms of serious crime, thereby supporting broader EU security 
objectives. 

Improved  coordination,  information  exchange  and  operational 
cooperation  among  Member  States,  facilitated  by  Europol,  are 
expected to lead to more effective law enforcement outcomes. This, 
in  turn,  may  contribute  to  increased  public  trust  in  national 
authorities and EU institutions, particularly in the EU’s capacity to 
address complex and evolving security challenges. 

Benefits of the preferred option 

The table below presents the overview of benefits for the preferred option.  

I. Overview of Benefits (total for all provisions) – Preferred Option 

Description 

Amount 

Direct benefits 

Strengthened 
data 
availability,  processing 
and service. 

requests 

reduced  ad-hoc 

The implementation of this policy options will lead 
for 
to  significantly 
information, as Member States gain access to more 
complete  and  structured  datasets.  This  will  enable 
faster access to relevant data for investigations and 
provide  more  reliable  information  for  operational 
analysis and cross-border cases, improving both the 
quality and timeliness of investigative outputs. 

Comments  
(main recipients of the 
benefits) 

National  law  enforcement 
the  EU 
authorities  of 
Member States, Europol. 

At EU level, these improvements will allow Europol 
to  deliver  better  analytical  outputs  and  more 
effectively  support  EU-wide  operations,  ensuring 
that law enforcement and judicial authorities across 
the Union can act on accurate, comprehensive, and 
actionable information. 

Strengthened continuum 
of  EU-level  support  to 
enforcement 
law 
through 
cooperation 
judicial 
Europol  and 
cooperation 
through 
Eurojust. 

By  effectively  exchanging  relevant  operational 
information,  Europol  and  Eurojust  will  be  able  to 
better support national law enforcement and judicial 
authorities in line with their respective mandates (for 
instance, thanks to earlier detection of links between 
cases).  For  Europol,  this  includes  the  ability  to 
produce  a  more  complete  EU-level  criminal 
intelligence picture. 

National  law  enforcement 
and  judicial  authorities  of 
the  EU  Member  States, 
Europol,  Eurojust,  private 
parties. 

National authorities of the EU will be able to rely in 
a  stable  and  foreseeable  long-term  manner  on 
jointly 
specialised  knowledge  and  expertise 
provided  by  Europol  and  Eurojust  to  successfully 
obtain  critical  electronic  evidence  for  criminal 

91 

 
 
 
 
 
 
 
Europol 
digital 
platforms  embedded  in 
national investigations. 

investigations  and  prosecutions, 
partnership with private parties  

including 

in 

Upgrading and integrating national and EU systems 
allows  for  more  efficient  queries,  automated 
workflows,  and  standardised  data  processing.  This 
reduces  repetitive  manual  tasks  and  improves  the 
speed and reliability of investigative outputs. 

National  law  enforcement 
authorities  of 
the  EU 
Member States, Europol. 

Member  States  benefit  from  long-term  operational 
savings,  as 
integrated  systems  facilitate  more 
effective  searches,  increased  detection  of  relevant 
data 
cross-border 
investigations,  reinforcing  both  national  and  EU-
wide law enforcement capabilities. 

stronger 

leads, 

and 

and 

as 

Europol 
operational 
provider 
information hub 

an 
service 
and 

effectively, 

information 

This  option  enhances  Europol’s  ability  to  use 
available 
providing 
dedicated  forensic  experts  and  operational  staff  to 
handle  queries  and  analyse  data.  Member  States 
benefit  directly  by  reducing  the  need  to  perform 
time-consuming  searches  themselves,  saving  both 
personnel time and operational costs. 

National  law  enforcement 
authorities  of 
the  EU 
Member States, Europol. 

that 

At the EU level, the improved operational capacity 
ensures 
EU-wide 
cross-border 
investigations  are  supported  with  more  accurate, 
timely,  and  actionable  intelligence,  reinforcing  the 
overall  law  enforcement  response  and  delivering 
tangible efficiency gains across the Union. 

and 

rules 

Simplified 
to 
the 
reduce 
administrative burden of 
data 
subject 
categorisation (DSC) 

This  option  will  reduce  the  administrative  burden 
associated with the management of DSC procedures, 
lowering  the  personnel  resources  required  to  carry 
out 
tasks.  By 
simplifying  these  processes,  it  will  allow  both 
Member  States  and  Europol  to  allocate  staff  time 
more efficiently to operational activities. 

labour-intensive  administrative 

National  law  enforcement 
the  EU 
authorities  of 
Member States, Europol. 

At the same time, Europol will benefit from greater 
flexibility in the use of certain categories of data that 
were  previously  subject 
to  stricter  procedural 
limitations.  This  will  increase  the  volume  and 
operational  relevance  of  information  available  for 
analysis, thereby strengthening Europol’s analytical 
capabilities. 

Member  States  and  Europol  will  therefore  realise 
efficiency gains through reduced staff time devoted 
to  DSC-related  administrative  procedures,  while 
maintaining  a  robust  legal  framework.  Alignment 
with the EUDPR and the LED, to the extent required 
to establish an appropriate framework for Europol, 
will ensure legal certainty and consistency with the 
EU data protection acquis. 

Overall,  the  streamlined  approach  will  facilitate 

92 

 
 
more efficient information handling and intelligence 
analysis, supporting cross-border investigations and 
sharing 
enabling  more  effective 
between Member States and Europol. 

information 

Europol  as  structural 
provider of information, 
analytical  support  and 
capacities to the EPPO 

The financial interests of the EU will be protected as 
the EPPO will be able to fulfil its mission effectively 
(thanks 
to  Europol’s  reinforced  support)  and 
efficiently  (thanks  to  direct  access  to  information 
stored  by  Europol  and  hierarchal  arrangements 
between EPPO and Europol). For Europol, structural 
cooperation with the EPPO will lead to the ability to 
produce  a  more  complete  EU-level  criminal 
intelligence picture and thus better support national 
law enforcement authorities.  

national 

EPPO, 
law 
enforcement authorities of 
the  EU  Member  States, 
Europol. 

EU Digital Police Cloud  The EU Police Cloud provides scalable storage and 
processing power for law enforcement applications, 
generating  economies  of  scale  that  prevent  each 
Member  State  from 
in 
expensive digital infrastructure. This ensures faster, 
more secure and harmonised access to critical tools 
and datasets. 

individually 

investing 

National  law  enforcement 
authorities  of 
the  EU 
Member States, Europol. 

Member States save resources and gain operational 
efficiency by leveraging shared infrastructure, while 
Europol  benefits 
from  centralised  processing, 
enhanced  analytical  capacity,  and  support  for  EU-
wide operations, delivering tangible long-term gains 
in both cost and effectiveness. 

Europol support offices  By  significantly  improving  the  practical  uptake  of 
Europol’s  support  (analytical,  operational,  and 
strategic products) by national authorities thanks to 
swifter,  faster  and  more  systematic  access,  this 
measure strengthens the effectiveness and efficiency 
of national investigations, as well as and the quality 
and timeliness of the EU-wide criminal intelligence 
picture provided by Europol. 

National  law  enforcement 
authorities  of 
the  EU 
Member States, Europol. 

None identified 

Indirect benefits 

The preferred option clearly identifies two areas where the direct benefits could result in 
substantial figures. Those are:  

•  Potential efficiency gains from joint procurement in EU internal security 
•  Potential gains due to the EU Police Cloud 

93 

 
 
 
 
 
Potential efficiency gains from joint procurement in EU internal security 

According to Eurostat statistics on government expenditure by function, expenditure by 
EU Member States on public order and safety amounted to approximately  1.7% of EU 
GDP  in  2023162.  This  category  includes  expenditure  related  to  police  services,  fire 
protection services, law courts, prisons and related research and development. 

On the basis of the current  size of the EU economy,  this corresponds  to  approximately 
€270–290  billion  annually  across  the  Union.  Within  this  category,  police  services 
account for around 0.9% of EU GDP, representing the largest component of public order 
and safety expenditure. 

This  spending  supports  a  wide  range  of  operational  capabilities,  including  personnel, 
infrastructure, and operational equipment used by law enforcement authorities. In recent 
years,  the  technological  component  of  law  enforcement  capabilities  has  increased 
significantly, reflecting the growing role of digital evidence, cyber investigations, use of 
biometric  technology  and  data-driven  policing  in  combating  organised  crime  and 
terrorism. 

Procurement  of  law  enforcement  equipment  and  technologies  is  largely  carried  out  at 
national, and in some cases regional or local, level. As a result, procurement markets for 
law  enforcement  technologies  in  the  Union  are  characterised  by  a  high  degree  of 
fragmentation. 

Fragmentation can lead to a number of inefficiencies, including: 

•  duplication of procurement procedures across Member States; 
• 
• 

reduced purchasing volumes for similar technologies; 
limited  interoperability  between  equipment  and  systems  used  by  different 
authorities; 

•  weaker bargaining power vis-à-vis suppliers. 

These issues are particularly relevant in areas where technologies are widely used by law 
enforcement  authorities  across  the  Union,  including  digital  investigation  tools,  forensic 
technologies and data-analysis capabilities. 

Similar challenges related to fragmentation of procurement markets have been identified 
in the defence sector. In its analysis of defence capability development, the Commission 
has  highlighted  that  fragmentation  of  procurement  across  Member  States  may  lead  to 
higher costs and reduced efficiency. In this context, the Commission has estimated that 
joint procurement of defence equipment could generate savings of around 10% on 
the value of equipment procured jointly, notably through economies of scale, stronger 
bargaining power, and reduced duplication of procurement processes163. 

162 Eurostat (March 2025), Government expenditure on public order and safety, accessible at: Government 
expenditure on public order and safety - Statistics Explained - Eurostat  
163 SWD (2025) 820 final. 

94 

 
 
 
This analysis suggests that the aggregation of demand across Member States can generate 
efficiency  gains  in  markets  characterised  by  multiple  national  buyers  and  relatively 
concentrated supplier bases. 

Although the operational contexts differ, procurement markets for certain law enforcement 
technologies  display  characteristics  similar  to  those  observed  in  the  defence  sector, 
including: 

• 
• 
• 
• 

a large number of public buyers across the Union; 
relatively limited numbers of specialised suppliers; 
increasing reliance on complex technological systems; 
the need for interoperability between national authorities. 

These  features  are  particularly  visible  in  areas  such  as  digital  forensic  tools,  cyber-
investigation  technologies,  biometric  identification  systems,  case  management  systems, 
and data-analysis platforms used in criminal investigations. 

In such areas, voluntary joint procurement mechanisms at Union level via Europol could 
allow participating Member States to aggregate demand for commonly used technologies. 
This  could  contribute  to  improved  purchasing  conditions,  facilitate  interoperability  of 
systems  used  by  law  enforcement  authorities  and  reduce  duplication  of  procurement 
efforts. 

While the magnitude of potential efficiency gains would depend on the scope and level of 
participation in joint procurement arrangements, experience from other sectors indicates 
that aggregation of demand may generate both financial and operational benefits. 

Potential advantages include: 

economies of scale, resulting from larger procurement volumes; 
improved bargaining power vis-à-vis technology suppliers; 
reduced administrative costs associated with procurement procedures; 

• 
• 
• 
•  greater  interoperability  of  technological  systems  used  by  law  enforcement 

authorities; 
faster deployment of new capabilities across Member States. 

• 

Such  mechanisms  could  complement  existing  Union-level 
initiatives  aimed  at 
strengthening  operational  cooperation  between  law  enforcement  authorities,  including 
those supported by Europol. 

If  we  considered  the  above,  by  leveraging  economies  of  scale,  reducing  duplicated 
administrative effort, and increasing bargaining power, joint procurement could achieve 
conservative savings of 10% compared to each Member State conducting procurement 
individually. For example, a total estimated cost of EUR 200 million across 20 Member 
States  could  be  reduced  to  approximately  EUR  180  million  under  a  joint  procurement 
approach. These savings reflect both lower unit prices and reduced administrative burdens, 
while  maintaining  compliance  with  EU  procurement  rules  and  ensuring  harmonised 
quality standards. 

95 

 
 
Given  the  scale  of  public  expenditure  on  public  order  and  safety  in  the  Union  and  the 
increasing  importance  of  technological  capabilities  in  law  enforcement  activities,  the 
aggregation of demand through voluntary joint procurement mechanisms could contribute 
to improving the efficiency of public spending in this area. 

Experience  in  other  sectors,  including  defence,  indicates  that  joint  procurement  may 
generate  significant  efficiency  gains  where  procurement  markets  are  fragmented  and 
characterised  by  multiple  public  buyers.  Similar  mechanisms  could  therefore  offer 
potential benefits in specific areas of law enforcement technology procurement, while also 
supporting greater interoperability and operational cooperation between Member States. 

Potential gains due to the EU Police Cloud 

In the absence of concrete figures, this section aims to explain the logic behind the potential 
gains due to the EU Police Cloud. The EU Police Cloud would provide scalable storage 
and  processing  capacity  for  law  enforcement  applications  at  Union  level.  By  pooling 
digital  infrastructure,  it  would  generate  economies  of  scale  compared  to  multiple 
independent national deployments. 

The volume of digital evidence processed by law enforcement authorities is increasing 
rapidly,  driven  by  the  growing  use  of  online  communications,  encrypted  messaging 
services, digital devices  and data-intensive investigations.  This  trend requires  expanded 
storage capacity and advanced computing capabilities to process large datasets, including 
for  digital  forensics,  cybercrime  investigations  and  data  analytics.  Shared  infrastructure 
can address these growing needs more efficiently than multiple smaller national systems, 
enabling  law  enforcement  authorities  to  access  scalable  and  adaptable  computing 
resources. 

In the absence of a shared platform, Member States would need to invest individually in 
digital infrastructure, including data-storage systems, computing capacity, cybersecurity 
services  and  software  licences,  notably  for  EU  classified  infrastructure.  A  shared  EU 
platform would lower the minimum cost of entry to highly specialized infrastructure and 
shared tools, avoid duplication of such investments and allow participating authorities to 
benefit from common infrastructure and services. 

While the investment costs for cloud infrastructure itself are relatively limited compared 
with  the  broader  operational  costs  of  analytical  capabilities,  economies  of  scale  can  be 
achieved through several mechanisms. First, a shared platform would reduce duplication 
in data collection and processing, as the same datasets, including those obtained through 
open-source intelligence tools or specialised licences, would not need to be collected and 
analysed  separately  by  multiple  authorities.  Second,  computing  resources  could  be 
allocated  dynamically  across  participating  users,  allowing  processing  power  to  be 
distributed more efficiently depending on operational needs. This type of shared resource 
management  can  generate  significant  efficiency  gains,  with  potential  reductions  in 
processing requirements estimated in the range of 50–70% compared with fragmented 
national deployments. 

In  addition,  the  shared  platform  would  significantly  lower  the  cost  of  access  to  highly 
specialised  capabilities,  including  infrastructure  compliant  with  EU  RESTRICTED 

96 

 
 
classification  requirements  and  advanced  analytical  services.  For  many  national 
authorities,  developing  such  capacities  individually  would  require  substantial  upfront 
investment and specialised expertise, which can be more efficiently provided through a 
common EU-level platform. 

Member  States  could  therefore  reduce  costs  related  to  hardware  procurement,  software 
licensing,  system  maintenance  and  IT  staffing,  while  gaining  access  to  more  advanced 
analytical capabilities than might be available through smaller national deployments. The 
use of a common infrastructure for public data, such as Child Sexual Abuse (CSA) material 
from the Internet or the dark web and joint investigative data will a minima halve the cost 
of storage and processing, as well as the cost of the collection of public data including from 
the dark web. The dedicated processing capacities (GPUs) made available by the EU Police 
Cloud would be allocated over more law enforcement authorities and more users, allowing 
a more efficient use of such capacities, by evening out over time the Member States instant 
peaks. Note that this economy of scale could not be reached at national level with other 
governmental authorities for sensitivity and confidentiality reasons.  

Europol would also benefit from centralised processing capacity, facilitating the analysis 
of large datasets and supporting EU-wide operational activities. 

Overall, the use of shared digital infrastructure could generate significant efficiencies over 
time  by  spreading  infrastructure  costs  across  multiple  users  and  avoiding  parallel 
investments by individual Member States. 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

IV. Overview of relevant Sustainable Development Goals – Preferred Option(s) 

Relevant SDG 

Expected  progress  towards  the 
Goal 

Comments 

SDG 16 – peace, justice and strong 
institutions 

and 

identification 

Faster 
joint 
analysis  of  cross‑border  criminal 
activities enable investigations to be 
carried  out  earlier  and  better, 
empowering  effective  responses  by 
national  law  enforcement  agencies 
and 
thus  strengthening  effective 
institutions and rule of law. 

and 

Stronger 
between 
cooperation 
Europol  and  Eurojust  as  well  as 
the  EPPO  will 
Europol 
strengthen the EU-level fight against 
organised crime and thus the rule of 
law  within  the  EU  and  its  Member 
States, including better protecting the 
financial interest of the EU.  

97 

 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1.  METHODOLOGICAL APPROACH 

This Impact Assessment has been prepared by the Commission services in accordance with 
the Better Regulation  Guidelines and Toolbox. The analytical  framework structures the 
assessment  of  problems,  objectives,  policy  options  and  impacts  in  a  consistent  and 
traceable manner. An external study supported the evidence base and analytical work.  

The intervention logic links identified problems and their drivers to specific objectives and 
to  the  measures  included  under  each  policy  option.  Coherence  is  ensured  between  the 
evaluation  findings  (Annex  7),  the  problem  definition  in  the  main  report,  and  the 
comparative assessment  of impacts.  Each option was assessed  against a clearly defined 
baseline  scenario  reflecting  the  continuation  of  the  current  legal  and  operational 
framework. The baseline scenario reflects the continuation of the current legal mandate, 
including  already  programmed 
governance 
developments.  It  does  not  assume  structural  mandate  changes  beyond  the  current 
framework. This counterfactual ensures that impacts attributed to the initiative represent 
incremental effects compared to the status quo. 

structure  and  operational  model, 

Three core assessment criteria guided the analysis: 

-  Effectiveness: the extent to which the option is expected to achieve the initiative’s 

objectives. 

-  Efficiency:  the  relationship  between  the  resources  required  and  the  results 

expected, including distributional effects. 

-  Coherence:  the  internal  consistency  of  the  option  and  its  alignment  with  other 

relevant EU legislation and policy objectives. 

The analysis also considers proportionality and EU added value. 

1.1 Methodology for assessment of impacts 

Effectiveness  

Effectiveness was assessed by examining the extent to which each policy option addresses 
the identified problems and contributes to the initiative’s specific and general objectives. 
The  analysis  draws  on  evaluation  findings,  operational  data,  stakeholder  feedback  and 
expert  judgement.  Where  available,  quantitative  indicators  informed  the  assessment.  In 
areas where quantitative indicators were not available, structured qualitative analysis was 
applied. 

The assessment considers not only formal legal changes but also implementation feasibility 
and operational practicality. 

98 

 
 
 
 
 
Efficiency  

Efficiency was evaluated by analysing the proportionality between expected benefits and 
the resources required under each policy option. The analysis covers: 

Implementation efforts at EU and national level where relevant; 

•  Financial costs at EU level; 
• 
•  Administrative burden and compliance implications; 
•  Social impacts and potential effects on fundamental rights; 
•  Distribution of costs and benefits across stakeholders. 

Costs  and  benefits  were  assessed  both  in  quantitative  and  qualitative  terms.  Where 
monetisation was not feasible, impacts were characterised in terms of expected magnitude 
and  operational  significance.  The  analysis  explicitly  distinguishes  between  one-off 
implementation costs and recurring operational costs. 

The proportionality principle guided the assessment: resource implications were evaluated 
against  expected  operational 
including  enhanced  coordination, 
strengthened  analytical  capacity,  improved  information  exchange  and  reduction  of 
fragmentation. 

improvements, 

Coherence 

Coherence  was  examined  by  assessing  the  consistency  of  each  option  with  related  EU 
legislation,  in  particular  the  ProtectEU  Strategy,  existing  institutional  mandates  and 
broader policy objectives. The analysis identifies potential overlaps, complementarities or 
tensions with other instruments at EU and national level. 

2.  COSTING METHODOLOGIES 

The costing exercise provides indicative ex ante estimates of the financial and operational 
implications of the policy options. Given the varying degree of specification of measures 
and differences in data availability, a mixed-method approach combining quantitative and 
qualitative evidence was applied. 

Quantification  was  undertaken  only  where  sufficiently  reliable  and  granular  data  were 
available. Where implementation  parameters remain dependent  on future operational  or 
technical  decisions,  impacts  were  assessed  qualitatively  in  order  to  avoid  artificial 
quantification. 

2.1 Evidence base for quantification  

Quantitative analysis relied primarily on Europol’s annual budget, establishment plans and 
Single Programming Documents. These sources enabled: 

•  estimation of unit costs per full-time equivalent (FTE); 
•  allocation of costs between operational and enabling functions; 
•  modelling of scaling effects for analytical, operational and compliance capacities; 
•  differentiation between capital expenditure and recurring expenditure. 

For selected measures involving regulatory and compliance functions, quantitative inputs 
were  drawn  from  Commission  Staff  Working  Documents  and  administrative  reporting, 
including  cost  modelling  related  to  temporary  data  processing  under  Article  18  of  the 
Europol Regulation and reporting to the Joint Parliamentary Scrutiny Group. 

99 

 
 
Publicly  available  remuneration  benchmarks  were  used,  where  relevant,  to  estimate 
staffing costs for potential new organisational structures. 

2.2 Benchmarking and modelling 

Where direct measurement was not feasible, project-level financial data from comparable 
EU-level initiatives were used as benchmarks. These include platforms such as the SIRIUS 
project  and  the  Joint  Operational  Analysis  Case  (JOAC)  platform.  These  benchmarks 
provided  reference  points  for  development  costs,  staffing  structures  and  operational 
expenditure. 

For infrastructure-intensive or digital measures, including the EU  Digital  Police Cloud, 
scenario-based modelling was applied over a multi-annual horizon. Financial projections 
incorporated known technical constraints, including projected data volume growth, system 
performance  requirements,  data-centre  capacity  limits,  and  expected  system  usage 
intensity. 

Alternative scenarios reflected varying levels of technical ambition and investment scale. 
Costs were systematically differentiated between one-off implementation expenditure and 
recurring adjustment costs related to maintenance, licences, managed services and ongoing 
support. 

2.3 Human resources 

Human  resource  impacts  were  explicitly  quantified  where  measures  implied  structural 
expansion  of  analytical,  operational  or  compliance  functions.  Quantification  relied  on 
activity-based  costing,  operational  workload  benchmarks  and  scenario-based  scaling  of 
staffing needs. 

Where  quantitative  operational  data  were  insufficient  to  support  monetisation,  staffing 
impacts were assessed qualitatively and characterised conservatively. 

2.4 ICT and interoperability 

ICT-related  costs  were  identified  for  measures  that  explicitly  require  IT  infrastructure, 
system  development  or  integration,  data-processing  platforms,  large-scale  information 
exchange  mechanisms,  or  a  material  expansion  of  Europol’s  digital  and  analytical 
environment. For a substantial share of measures, ICT impacts were assessed as negligible 
or limited, on the assumption that they build on existing Europol systems, interoperability 
frameworks  and  national  infrastructures  without  requiring  major  upgrades.  The 
quantification  and  qualitative  assessment  of  ICT  costs  followed  three  approaches 
depending on the nature of the measure and data availability: incremental adjustment of 
existing  systems;  proportional  scaling  of  enabling  ICT  capacity  alongside  operational 
expansion;  and  scenario-based  modelling  for  large  digital  platforms  and  collaborative 
environments. 

The  latter  approach  was  applied  in  particular  to  the  EU  Police  Cloud.  In  these  cases, 
financial  projections  were  developed  over  a  multi-annual  period,  incorporating  known 
technical constraints such as projected data volume growth, existing data-centre capacity 
limits,  legal  restrictions  affecting  outsourcing,  and  the  scale  and  duration  of  large  ICT 
programmes.  Alternative  scenarios  were  used  to  reflect  varying  levels  of  investment 
ambition and technical capability, ranging from limited system upgrades to more advanced 
configurations  involving  cloud  solutions,  enhanced  security  features,  automation  and 
therefore  differentiated  between  one-off 
advanced  analytics. 

ICT  costs  were 

100 

 
 
implementation  costs  and  recurring  adjustment  costs  related  to  maintenance,  licences, 
managed services and ongoing support. 

For measures involving data exchange with other EU agencies,  ICT costs are primarily 
driven by interoperability requirements and workload-dependent demand. In these cases, 
the analysis assumes that core systems are already in place and that additional costs mainly 
relate  to  integration,  logging  and  auditing  configurations,  capacity  management  and 
maintenance.  Benchmarks  from  comparable  projects  were  used  where  relevant  to 
approximate development and operating costs, with low and high-bound estimates applied 
to  reflect  uncertainty  regarding  future  data  volumes,  query  intensity  and  participation 
levels. 

2.5 Infrastructure  

Infrastructure  costs  include  premises,  secure  facilities,  equipment  and  organisational 
support services required to accommodate operational expansion. As such costs are highly 
dependent on future implementation choices and location-specific factors, they could not 
be  estimated  ex  ante  with  sufficient  reliability  and  were  therefore  not  monetised.  Their 
potential impact is described qualitatively. 

3.  CAVEATS AND LIMITATIONS 

Uncertainty  in  cost  projections  was  addressed  through  scenario  analysis  and  the  use  of 
lower- and upper-bound estimates where appropriate. Key variables subject to sensitivity 
considerations  include  staffing  levels,  data  volumes,  ICT  scaling  requirements  and 
participation rates. 

Where  impacts  could  not  be  reliably  monetised,  qualitative  assessment  was  applied. 
Conservative  assumptions  were  used  in  order  to  avoid  overstating  benefits  or 
underestimating costs. 

Certain limitations are inherent to ex ante assessments of complex institutional reforms. 
Some  implementation  parameters  depend  on  future  operational  decisions,  legislative 
negotiations  or  technological  developments.  In  such  cases,  impacts  are  presented 
proportionately and transparently, ensuring analytical robustness without over-precision. 

Despite these limitations, the consistent comparative framework applied across policy 
options ensures that the relative differences between options are analytically sound and 
that conclusions are evidence-based and proportionate. 

101 

 
 
 
ANNEX 5: THE PREFERRED POLICY MEASURES 

The combined effect operates along three mutually dependent pillars: data availability, 
legal usability and technical-operational capacity. The contribution of each measure to 
the operational objectives will be reported under the section on the preferred policy option. 

Legal enabler: Data Subject Categorisation 

The  reform  of  Data  Subject  Categorisation  (DSC)  of  policy  option  2.2  constitutes  a 
horizontal  enabler  for  the  entire  package.  By  streamlining  and  aligning  the  DSC 
framework, it removes structural constraints affecting the timely processing of large and 
complex datasets. 

This directly strengthens the effectiveness of: 

•  Sub policy option 1.1, by facilitating faster and more consistent data uploads; 
•  Sub  policy  option  2.1,  by  enabling  more  efficient  cross-border  exploitation  of 

shared data; 

•  Sub  policy  option  1.4,  by  ensuring  that  systematic  consultation  mechanisms 

function without procedural bottlenecks; 

•  Sub  policy  option  2.4,  by  providing  legal  clarity  for  scalable  cloud-based 

analytics. 

Data availability and systematic use 

Options 1.1 and 2.1 improve the quantity, quality and cross-border use of data, within 
proportionate  limits.  Automated  data  loaders  and  structured  workflows  ensure  more 
consistent  contributions  from  Member  States.  Option  1.4  embeds  Europol  systems  into 
national workflows and makes cross-border checks systematic. 

More information at Europol strengthens the EU intelligence picture and directly enhances 
cooperation  with  EPPO  and  Eurojust.  Conversely,  structured  data  inflows  from  EPPO, 
Eurojust and other EU actors increase the analytical value of Europol datasets by enabling 
broader cross-checks and correlation. 

Together, these measures will contribute to the operational objectives of: 

• 

Improving  information  exchange  by  increasing  the  volume  and  reliability  of 
operational data at EU level and reducing fragmentation and uneven participation; 
•  Reducing delays and increasing actionable intelligence by ensuring that shared data 

is systematically queried and exploited. 

Structural enablers 

Sub policy options 1.3 and 2.3 reinforce the institutional architecture at EU level: 

• 

Institutionalisation of SIRIUS ensures sustainable support to national authorities in 
accessing electronic evidence. 

102 

 
 
•  Upgrading  and  automating  the  Europol–Eurojust  hit/no-hit  mechanism,  and 
extending indirect access, enhances structured inter-agency information exchange. 
•  A reinforced partnership with the EPPO,  including a dedicated team at Europol, 

ensures predictable, specialised and high-quality analytical support. 

Processing capacity and scalability 

The  EU  Police  Cloud  (Sub  policy  option  2.4)  provides  the  scalable  infrastructure 
necessary  to  absorb  and  analyse  increased  data  flows.  It  enables  secure  storage, 
advanced  analytics  and  structured  collaboration  at  scale.  Enhanced  analytical  tools 
(including  those  under  Sub  policy  options  1.1,  1.3  and  2.1)  and  strengthened  Europol–
EPPO cooperation  (Sub  policy option 2.3) ensure that increased data volumes translate 
into operational results rather than administrative burden. 

The  combined  dynamic  is  cumulative:  More  structured  data  →  improved  analytics  → 
stronger operational insights → more effective cross-border cooperation. 

Financial coherence and cost synergies 

Certain investments under Sub policy options 1.1 and 1.4 overlap, particularly in relation 
to  system  upgrades  and  integration  components.  Implemented  together,  these  elements 
avoid duplication, meaning that the combined investment remains broadly aligned with the 
previously estimated envelope (approximately EUR 30 million in system modernisation), 
rather than accumulating mechanically. 

Economies  of  scale,  reduced  duplication  and  structured  EU-level  coordination  further 
enhance cost-efficiency. 

Overall assessment 

Taken together, the preferred options form a coherent, cumulative and scalable reform 
package: 

•  Sub policy option 2.2 removes legal bottlenecks; 
•  Sub policy options 1.1 and 2.1 increase data availability and cross-border use; 
•  Sub policy option 1.3 strengthens inter-agency cooperation and information 

exchange; 

•  Sub policy option 2.3 anchors Europol as a structural analytical partner of 

the EPPO; 

•  Sub policy option 1.4 ensures systematic operational embedding; 
•  Sub policy option 2.4 provides the digital backbone and scalability. 

Their combined implementation directly supports the operational objectives identified in 
this  Impact  Assessment  and  will  be  subject  to  structured  monitoring  and  evaluation  to 
ensure measurable improvements in information exchange, analytical capacity and cross-
border operational effectiveness. 

The package therefore delivers a proportionate and mutually reinforcing response to the 
evolving digital and transnational nature of serious and organised crime. 

103 

 
 
The preferred package combines Sub policy options 1.1 + 2.1 (limited to Prüm II and 
without broader interoperability), Sub policy option 2.2 (Data Subject Categorisation 
reform),  Sub  policy  option  1.3  (enhanced  EU  inter-agency  cooperation  limited  to 
Eurojust),  Sub  policy  option  2.3  (structural  Europol–EPPO  partnership)  and  Sub 
policy options 1.4 + 2.4 (structural integration and EU Police Cloud). Together, these 
measures  form  a  coherent  and  mutually  reinforcing  reform  of  the  EU  law  enforcement 
information architecture. 

Preferred policy option 1.1 + 
1.3 + 1.4 + 2.1+ 2.2 +2.3+ 2.4 

assessment criteria 

1) Impact on citizens 

2) Impact on national authorities 

3) Objective of general interest 

4) Data protection 

5) Costs 

6) Feasibility 

7) Impact on digitalisation 

a. Impact on citizens (++) 

++ 

++ 

++ 

0 

+ 

+ 

++ 

Each  of  the  preferred  options  individually  contributes  to  strengthening  EU  internal 
security; combined, their impact is cumulative and mutually reinforcing. By improving 
the availability, quality and usability of data (1.1, 1.4, 2.1, 2.2), enhancing structured inter-
agency  and  prosecutorial  cooperation  (1.3,  2.3),  and  providing  scalable  digital  and 
analytical capacity (2.4), the package directly addresses the three core problems identified: 
persistent  information  gaps  in  cross-border  investigations,  fragmented  and  uneven 
operational coordination, and structural resource and capability constraints at EU level. 

In  practical  terms,  this  translates  into  earlier  detection  of  criminal  networks,  faster 
identification  of  cross-border  links,  improved  asset  tracing,  and  more  coordinated 
operational  action  across  Member  States.  Strengthened  analytical  capabilities  and 
streamlined information flows reduce delays, minimise duplication of efforts and increase 
the likelihood that criminal activities are detected before harm escalates. At the same time, 
reinforced  cooperation  with  EU  partners  and  prosecutorial  authorities  supports  stronger 
case-building and higher-quality evidence, contributing to more effective prosecutions. 

Overall, the combined measures significantly enhance the capacity of Europol and national 
authorities to prevent, investigate and disrupt serious and organised crime, including 

104 

 
 
 
 
 
in the digital domain, thereby delivering a substantially higher level of protection for 
citizens  in  both  physical  and  online  environments,  while  operating  within  a  robust 
framework of data protection and fundamental rights safeguards. 

b. Impact on national authorities (++) 

Each  of  the  preferred  options  individually  strengthens  national  authorities’  operational 
capacities; taken together, their impact is systemic and mutually reinforcing. By closing 
information gaps and improving structured data exchange (1.1, 1.4, 2.1, 2.2), reinforcing 
EU-level  coordination  and  prosecutorial  cooperation  (1.3,  2.3),  and  providing  scalable 
digital  infrastructure  and  advanced  analytical  tools  (2.4),  the  package  directly  tackles 
fragmented cross-border information flows, uneven coordination and structural constraints 
in resources and technical capabilities. 

In practical terms, national authorities benefit from faster access to relevant intelligence, 
improved  cross-border  link  detection,  stronger  analytical  support  and  more 
predictable  cooperation  channels.  Streamlined  procedures  and  clearer  frameworks 
enhance  legal  certainty  and  reduce  operational  friction,  while  shared  digital  tools  and 
specialised  expertise  help  address  capacity  gaps,  particularly  in  complex  areas  such  as 
cybercrime,  financial  investigations  and  large  datasets.  Overall,  the  measures  reinforce 
Member States’ ability to  act  effectively,  cooperate  efficiently and rely on sustained 
EU-level support, strengthening both day-to-day operational performance and long-term 
resilience against increasingly sophisticated and digitalised criminal threats. 

c. Impact on fundamental rights 

Objective of general interest (++) 

Each of the preferred options contributes individually to strengthening the Union’s Area 
of Freedom, Security and Justice; combined, they create a more coherent, resilient and 
future-proof  internal  security  framework.  By  reinforcing  structured  information 
exchange,  operational  coordination  and  digital  capabilities,  the  package  enhances  the 
Union’s  collective  capacity  to  prevent  and  combat  serious  and  organised  crime  in  an 
increasingly cross-border and digitalised threat environment. 

The measures also strengthen mutual trust and solidarity among Member States, ensure 
more effective interaction between EU bodies, notably Europol, the EPPO and Eurojust 
and reduce fragmentation in the EU security architecture. By investing in  shared digital 
and analytical capacities, the Union advances its strategic autonomy in law enforcement 
technologies and expertise, reducing reliance on external tools while maintaining high 
standards.  Overall,  the  initiative  supports  the  objective  of  delivering  a  high  level  of 
security across the EU, firmly anchored in respect for fundamental rights, data protection 
and the rule of law. 

Impact on data protection (0) 

The impact of the preferred package on data protection is considered overall neutral, as 
all  retained  options  have  successfully  passed  both  the  necessity  and  proportionality 
assessments. 

105 

 
 
Necessity.  The  measures  respond  to  clearly  identified  structural  problems,  persistent 
information gaps, fragmented cross-border exchanges and inefficiencies in data handling, 
which cannot be effectively addressed by Member States acting alone. The initiative does 
not  introduce  new  categories  of  personal  data  nor  expand  the  purposes  of  processing. 
Instead,  it  seeks  to  improve  the  relevance,  structure  and  operational  usability  of  data 
already lawfully processed within the existing legal framework. By optimising information 
flows and clarifying procedural conditions, the package ensures that processing remains 
strictly linked to operational needs in combating serious and organised crime. 

Proportionality.  The  preferred  options  are  limited  to  what  is  necessary  to  achieve  the 
identified  objectives  and  avoid  excessive  or  unjustified  data  processing.  They  build  on 
existing  systems  and legal  bases, refrain  from creating parallel  databases or duplicative 
storage, and maintain decentralised responsibilities where appropriate. Safeguards relating 
to  purpose  limitation,  access  control,  oversight  and  data  subject  rights  remain  fully 
applicable.  Particular  attention  has  been  paid  to  ensuring  that  enhanced  analytical 
capacities  and  improved  interoperability  do  not  alter  the  balance  between  operational 
effectiveness and fundamental rights protection. 

The reform of Data Subject Categorisation (Option 2.2) simplifies an existing safeguard 
to  remove structural  inefficiencies and reduce administrative burden, while maintaining 
the core protective logic of differentiated data handling. This adjustment strengthens legal 
clarity  and  aligns  more  closely  with  the  framework  of  the  EUDPR  and  the  Law 
Enforcement Directive, without lowering the level of protection. 

Overall, the combined measures preserve a high level of data protection, while enhancing 
coherence,  transparency  and  accountability  in  EU  law  enforcement  information 
processing. 

e)  Cost (+) 

Direct costs 

Member States  

Europol 

Expected one-off costs (in million EUR) 

254.85 

267.3 

-  Policy option 1.1 
-  Policy option 1.3 
-  Policy option 1.4 
-  Policy option 2.1 
-  Policy option 2.2 
-  Policy option 2.3 
-  Policy option 2.4 

Expected 
(in million EUR) 

yearly 

-  Policy option 1.1 
-  Policy option 1.3 
-  Policy option 1.4 
-  Policy option 2.1 

-  81 
-  0 
-  105 
-  1.35 
-  0 
-  0 
-  67.5 

-  61* 
-  2 
-  50* 
-  11 
-  0 
-  0 
-  143.3 

recurring 

costs 

47.9 

77.3 

-  16.2 
-  0 
-  20 
-  0.3 

-  12.2 
-  1 
-  8 
-  5.3 

106 

 
 
 
 
 
 
 
 
-  Policy option 2.2 
-  Policy option 2.3 
-  Policy option 2.4 

-  0 
-  0 
-  11.4 

-  0 
-  11 
-  39.8 

The  combined  package  entails  cumulative  investments  at  both  Member  State  and  EU 
level,  while  generating  important  efficiencies  through  synergies  and  rationalised 
implementation.  In  particular,  overlaps  between  Policy  Options  1.1  (strengthening 
information  exchange)  and  1.4  (CMS  integration  and  workflow  embedding)  create 
economies  of  scale  estimated  at  approximately  EUR  30  million,  reducing  overall 
expenditure compared to a purely additive approach. 

The one-off costs reflect initial investments in system upgrades, deployment of technical 
infrastructure, training, and integration of digital and analytical tools. For Member States, 
these are estimated at EUR 254.85 million, while for Europol they amount to EUR 237.3 
million.  Recurring  annual  costs  cover  ongoing  maintenance,  operational  support, 
staffing, and continuous improvements to systems and services, amounting to EUR 47.9 
million for Member States and EUR 77.3 million for Europol. 

These figures represent a consolidated and optimised implementation of the preferred 
options,  ensuring  that  operational  impact  is  maximised  while  financial  burdens  are 
contained.  Importantly,  the  investments  are  expected  to  generate  significant  efficiency 
gains:  improved  interoperability,  automation  of  data  flows,  and  enhanced  analytical 
capacity will reduce time and resources needed for cross-border investigations. Over time, 
these operational efficiencies are likely to offset a portion of the recurring costs, while also 
increasing  the  overall  return  on  investment  in  terms  of  faster  investigations,  better 
intelligence, and improved EU internal security outcomes. 

Overall,  the  cost  estimates  demonstrate  that  the  package  is  financially  feasible, 
proportionate,  and  justified  by  the  expected  operational  and  strategic  benefits  for  both 
Member States and Europol. 

f)  Feasibility (+) 

All preferred options are individually technically feasible, as they build on existing legal 
frameworks, operational practices, and IT infrastructures at both EU and national level. 
When combined, they form a reinforced and coherent technical package: increased data 
availability  and  streamlined  categorisation  (1.1,  2.1,  2.2,  1.4)  feed  directly  into 
strengthened inter-agency and prosecutorial  cooperation (1.3, 2.3), while  the EU Police 
Cloud (2.4) provides the scalable digital infrastructure necessary to support expanded 
analytical use, advanced data matching, and secure cross-border workflows. The approach 
relies  primarily  on  upgrading  and  integrating  existing  systems,  rather  than  creating 
entirely  new  architectures,  ensuring  continuity,  manageability,  and 
reduced 
implementation risk. Synergies with established EU technological frameworks, including 
those  developed  by  eu-LISA,  further  enhance  feasibility  by  leveraging  proven 
interoperability  standards,  secure  authentication  mechanisms,  and  shared  infrastructure 
components. Collectively, these measures generate cumulative efficiencies, enabling the 
package to deliver greater operational impact than the sum of individual options. 

107 

 
 
 
 
From  a  political  feasibility  perspective,  each  option  is  achievable  when  considered 
individually,  as  all  are  anchored  in  existing  cooperation  frameworks  and  respect  the 
division of competences between the Union and Member States. Certain elements, notably 
strengthened  EU-level  coordination,  DSC  reform  and  the  structural  reinforcement  of 
Europol’s  role  vis-à-vis  the  EPPO,  may  encounter  reservations  from  stakeholders 
the  package  remains 
traditionally  cautious  about  deeper 
proportionate  and  firmly  rooted  in  operational  needs  identified  by  Member  States 
themselves,  and  its  design  emphasizes  support  rather  than  substitution  of  national 
responsibilities. Taken together, the measures form a balanced and pragmatic reform: 
they enhance EU-level support, strengthen operational effectiveness and provide scalable 
and resilient tools while preserving Member State decision-making and oversight. 

integration.  However, 

By improving the efficiency and coherence of cross-border investigations, enabling better 
use of shared intelligence, and embedding upgraded technical infrastructure, the combined 
package  is  technically  achievable,  politically  realistic,  and  institutionally  well 
grounded. It ensures high data protection standards, maintains Member State control over 
operational decisions, and creates a sustainable foundation for future-proof EU internal 
security cooperation. 

g) 

Impact on digitalisation (++) 

All  preferred  options  with  a  digital  dimension  have  a  positive  impact  on  the  digital 
transformation of EU law enforcement cooperation, as they modernise data exchange, 
streamline  digital  processing  frameworks,  and  strengthen  analytical  and  cloud-based 
capacities. By improving the automation, standardisation, and interoperability of existing 
systems, these options reduce manual workflows, accelerate the timeliness of cross-border 
intelligence  sharing,  and  enhance  the  reliability  and  usability  of  operational  data. 
Combined,  their  effect  is  mutually  reinforcing:  improved  data  availability  and 
harmonised rules feed directly into stronger inter-agency and prosecutorial cooperation, 
while the EU Police Cloud provides a  scalable, secure and resilient digital backbone 
capable  of  supporting  advanced  analytics,  AI-assisted  processing  and  structured  cross-
border workflows. In addition, the integration of national Case Management Systems with 
EU-level  platforms  further  embeds  digital  tools  into  everyday  investigative  processes, 
ensuring that information flows efficiently and systematically without creating new access 
rights or duplicating datasets. Together, the package accelerates a coherent and future-
proof digitalisation of EU internal security, enhancing operational effectiveness, fostering 
standardised digital practices across Member States, and creating a sustainable foundation 
for next-generation law enforcement capabilities. 

108 

 
 
 
 
 
 
 
ANNEX 6: MONITORING AND EVALUATION FRAMEWORK FOR 
THE PREFERRED POLICY MEASURES 

Putting in place a structured framework for monitoring and evaluation will help ensure that 
the  strengthened  mandate  under  the  preferred  policy  option  translates  into  measurable 
operational,  strategic  and  systemic  benefits.  The  framework  will  establish  clear  links 
between the general and specific objectives, operational outputs, expected outcomes and 
broader impacts, supported by measurable indicators and, where feasible, baselines and 
targets. Monitoring arrangements will build on the mechanisms already established under 
Article 68 of the Europol  Regulation,  which foresees periodic evaluations  of Europol’s 
impact,  effectiveness  and  efficiency.  These  mechanisms  will  be  complemented  by  a 
refined  indicator  framework  aligned  with  the  specific  and  operational  objectives  of  the 
preferred option. 

Monitoring  will  focus  on  outputs  (e.g.  volume  and  quality  of  information  exchange, 
operational  support  delivered),  results  (e.g.  improved  cross-border  linkages  identified, 
investigative  acceleration),  and  broader  impacts  (e.g.  strengthened  EU-level  situational 
awareness,  reduced  fragmentation  in  operational  coordination).  The  framework  will 
distinguish  more  clearly  between  outputs  (activities  and  services  delivered),  outcomes 
(changes  in  operational  cooperation  and  investigative  effectiveness)  and  impacts 
(contribution  to  EU  internal  security  objectives).  Attention  will  be  given  to  monitoring 
data-protection compliance, proportionality and fundamental rights safeguards, especially 
in relation to large and complex datasets and advanced analytical tools. 

Core  indicators  will  be  drawn  from  a  range  of  sources,  including  Europol’s  existing 
reporting  instruments,  including  the  Consolidated  Annual  Activity  Report  (CAAR); 
Article  7(11)  reporting  on  Member  State  information  contributions;  EDPS  supervisory 
findings and data protection reporting; SIENA Annual Reports; EIS Annual Reports; and 
Management  Board  performance  indicators.  Where  possible,  indicators  will  include 
baseline values and measurable targets to support the assessment of progress over time. 

The  Commission  will  monitor  implementation  through  its  representation  on  the 
Management  Board,  structured  exchanges  with  Member  States  and  Europol,  and 
consultation  with  oversight  bodies,  including  the  EDPS.  Data  will  also  be  drawn  from 
SOCTA  cycles,  EMPACT  performance  reporting  and,  where  appropriate,  targeted 
stakeholder surveys. 

Monitoring will begin from the entry into force of the revised Regulation. Indicators will 
be collected annually. A structured evaluation should be undertaken four years after entry 
into force, allowing sufficient time for operational maturation while ensuring that findings 
can  inform  any  future  legislative  revision.  The  evaluation  will  assess  effectiveness, 
efficiency, coherence, relevance and EU added value, including the extent to which the 
initiative  has  achieved  the  specific  objectives  and  contributed  to  the  overall  objective. 
Where  relevant,  interim  reviews  may  assess  implementation  bottlenecks,  including 
technical  interoperability  and  data-protection  compliance  burdens,  in  line  with  REFIT 
principles. 

The monitoring framework below summarises the operational objectives and  associated 
indicators per specific objective. It also identifies the corresponding outputs, outcomes and 
expected impacts to facilitate the assessment of operational success over time. 

109 

 
 
Specific objective 

Operational objective 

Indicator description 

Data source 

Targets / frequency 

SO1: Reinforce Europol’s 
role  as  an  information 
hub 

Strengthen Europol’s 
capacity to collect, 
process, analyse and 
exchange criminal 
intelligence with Member 
States and improve the 
timeliness, interoperability 
and usability of 
information exchanges 

Strengthening 
SO2: 
to 
capacity 
Europol’s 
support  law  enforcement 
operational action 

Optimally integrate human 
resources between Europol 
and Member States 

• % of Member States 
technically integrated with 
Europol data-ingestion 
tools 
• % of operational data 
flows transmitted through 
automated channels 
• Average time between 
receipt of information by 
Europol and dissemination 
of operational leads 
• % of Europol-supported 
investigations relying on 
data from at least two 
Member States 
• Number of cross-system 
matches generating 
operational follow-up 
• Satisfaction score from 
Member States regarding 
Europol analytical support 

• Number of operational 
deployments and 
embedded Europol support 
arrangements 
• Average time-to-
deployment following 
Member State request 

Annual monitoring; target 
increases to be defined in 
Programming Documents 
and Management Board 
KPIs 

SIENA and EIS 
transaction logs;  

CAAR;  

Article 7(11) reporting; 

Europol operational 
workflow logs;  

Europol user surveys 

Europol HR and 
deployment records; 

ENU coordination records; 

Annual monitoring; 
deployment and training 
targets to be reviewed 
every two years 

 
 
Ensure direct and 
proactive operational 
support by Europol to 
Member States and EPPO 
investigations 

 operational support office 
reporting 

Annual monitoring with 
mid-term review after four 
years 

CAAR; 

operational reporting; 

EMPACT reporting; 

EPPO cooperation 
reporting; 

targeted stakeholder 
surveys 

• Number of specialised 
experts deployed in 
operational cases 
• Number of national 
officers trained in 
specialised investigative 
fields 
• Share of priority cases 
supported by specialised 
expertise 

• Number and share of 
cross-border investigations 
supported operationally by 
Europol 
• Number and share of 
EMPACT and EPPO cases 
receiving Europol support 
• Number of proactive 
support offers initiated by 
Europol and accepted by 
Member States/EPPO 
• Share of cases where 
Europol support 
contributed to operational 
outcomes 
• Feedback score from 

111 

 
 
Joint operational activity 
registers;  

SIRIUS platform metrics;  

Annual monitoring; 
operational coordination 
targets to be reviewed in 
evaluation cycle 

cooperation logs;  

case-management systems 

Enhance coordination and 
complementarity between 
Europol and relevant EU 
entities to reinforce 
synergies and ensure 
efficient resource use 

Member States and EPPO 
on operational usefulness 

• Number of joint 
operational activities with 
Eurojust, EPPO and other 
EU entities 
• Number of SIRIUS 
requests handled and 
median response time 
• Share of Europol-
supported cases involving 
coordinated cooperation 
channels with Eurojust or 
EPPO 
• Number of structured 
information exchanges 
through hit/no-hit systems 

112 

 
 
 
ANNEX 7: EVALUATION OF THE EXISTING POLICY AND 
LEGISLATIVE FRAMEWORK 

1.  Introduction 

1.1. Purpose and scope 

This  evaluation  assesses the performance of Regulation  (EU)  2016/794,  as  amended by 
Regulation  (EU)  2022/991,  establishing  the  legal  framework  governing  the  European 
Union Agency for Law Enforcement Cooperation (Europol).  

The evaluation is conducted in line with the European Commission’s Better Regulation 
Guidelines and  applies  the  standard  evaluation  criteria  of effectiveness,  efficiency, 
relevance, coherence, and EU added value. In this context, the analysis examines the 
extent to which the intervention has achieved its intended objectives, whether it has done 
so  in  a  proportionate  and  resource-efficient  manner,  and  whether  the  underlying  policy 
rationale remains valid in light of the evolving security landscape in the European Union.  

The  evaluation  covers  the  period 2017-2024,  corresponding  to  the  implementation  of 
Regulation  (EU)  2016/794  and  the  initial  application  of  the  amendments  introduced  by 
Regulation  (EU)  2022/991.  The  analysis  therefore  assesses  both  the  functioning  of  the 
original regulatory framework and the initial impacts of the 2022 legislative changes.  

The scope of the evaluation focuses on Europol’s core tasks as defined in the Regulation, in 
particular its  role  in  facilitating  information  exchange,  providing  criminal  intelligence 
analysis,  supporting  operational  coordination  between  Member  States,  developing 
specialised  expertise  through  dedicated  operational  centres,  and  cooperating  with  EU 
institutions, agencies, third countries, and private actors. Particular attention is given to the 
extent  to  which  the  Regulation  has  enabled  Europol  to  respond  to  the  increasingly 
transnational,  digitalised,  and  technologically  sophisticated  nature  of  serious  crime  and 
terrorism.  

In  addition  to  assessing  operational  performance,  the  evaluation  examines  whether  the 
current legal framework provides Europol with the necessary tools to address emerging 
challenges.  These  include  the  increasing  volume  and  complexity  of  data  relevant  to 
criminal investigations, and the need for law enforcement authorities to develop advanced 
technological capabilities, including in the areas of digital forensics, and data analytics. 
The  analysis  therefore  considers  whether  the  Regulation  remains  adequate  to  support 
Europol’s evolving role within the EU’s internal security architecture.  

The  evaluation  also takes  into  account the  broader  policy  context  in  which  Europol 
operates,  including  the  EU’s  internal  security  strategies  and  operational  cooperation 
frameworks, such as the ProtectEU Internal Security Strategy. These policy initiatives 
shape  Europol’s  operational  priorities  and  provide  an  important  reference  point  for 
assessing the continued relevance of the existing regulatory framework.  

The findings of the evaluation contribute to the accompanying impact assessment, which 
examines potential policy options for revising Europol’s mandate. The evaluation therefore 
provides the analytical basis for identifying possible shortcomings in the current legislative 

 
 
 
framework and for assessing whether further policy or legislative action at EU level may 
be necessary.  

1.2. Methodology 

The  evaluation  draws  on  a  broad  range  of  qualitative  and  quantitative  evidence 
sources in order to ensure a comprehensive assessment of the functioning of Regulation 
(EU) 2016/794, as amended by Regulation (EU) 2022/991. 

The main evidence base for the evaluation was generated through an external study 
commissioned by the European Commission. The study supported the analytical work 
underpinning  the  evaluation,  including  evidence  collection,  stakeholder  consultations, 
data analysis and the development of thematic case studies.  

The  external  study  supporting  this  evaluation  was  carried  out  by ICF S.A under 
Framework Contract 330302019 between July 2025 and March 2026.  

The  external  study  included  extensive  stakeholder  consultations,  public surveys and 
targeted  interviews  with  relevant  stakeholders.  These  consultations  involved  law 
enforcement  officials  from  Member  States,  Europol  officers  directly  involved  in 
operational  activities,  and  representatives  of  relevant  EU  institutions  and  agencies.  The 
purpose  of  these  consultations  was  to  gather  practical  insights  into  how the  Regulation 
functions  in  practice,  including  operational  experiences,  perceived  added  value  of 
Europol’s  support,  and  potential  challenges  related  to  the  implementation  of  the  legal 
framework.  

In  total, 135  stakeholder  interviews  were  held,  including  12  explanatory  interviews 
followed by 123 targeted interviews. They were conducted with national authorities of the 
EU Member States, including Denmark (56), Europol staff managers including managers 
and  senior  managers  (35), European  Commission  services  (14), EU  agencies  (8), EU 
bodies  and  offices  (4), law  enforcement  networks  (6), MAOC-N, third  countries  (5), 
international organisations (1), the private sector (2) and youth organisations (1).  

specific 

operational 

The  external  study  also  included  thematic  case  studies  illustrating  Europol’s  role  in 
case 
activities 
supporting 
studies provide qualitative insight into how Europol’s analytical capabilities, coordination 
functions and operational support contribute to concrete law enforcement outcomes at EU 
level.  Field  visits  to  Europol  and  five  Member  States164,  which  also  included  further 
interviews, were conducted in order to gather qualitative and context specific evidence on 
Europol’s cooperation with Member States. 

investigations.  These 

and 

In addition to the evidence generated through the external study, the Commission carried 
out  complementary  evidence-gathering  activities in  order  to further  inform  the 
evaluation.  These 
included thematic  workshops  with  relevant  stakeholders, 
which provided an opportunity to discuss specific operational and policy issues related to 
Europol’s mandate and its future development.  

The first two workshops were held on 6 and 7 November 2025, focusing on optimising 
Europol’s data ecosystem and reinforcing its role as the EU’s central operational hub and 
developing EU-level  specialised  law  enforcement  expertise  and  operational  innovation 

164 Austria, Italy, The Netherlands, Slovenia, Sweden. 

114 

 
 
 
within Europol and reinforcing Europol’s role in tackling persistent and emerging threats 
including  within  the  EMPACT  framework  respectively. The  third  and  fourth  thematic 
expert  workshops  were  held  on  18  and  19  December  2025,  with  a  focus  on  enhancing 
coordination and complementarily between Europol and relevant EU entities to reinforce 
synergies, ensure efficient resource  use,  and  consolidate Europol’s  central  role  in  the 
third  workshop and on strengthening 
the 
EU internal 
the steering  and  oversights of  Europol  to  ensure  effective  governance  in  line  with  its 
growing operational tasks, budget and staff, while optimally integrating human resources 
between Europol and Member States for the fourth workshop.  

security infrastructure for 

Furthermore, the  Commission  conducted  targeted  bilateral  outreach  to  Member 
States’ authorities, as well as exchanges with institutional stakeholders, including the 
Council,  in  the  context  of  COSI  and  the  Law  Enforcement  Working  Party,  and  the 
European Parliament, including the Joint Parliamentary Scrutiny Group. These exchanges 
helped  gather additional perspectives  on  the  implementation  of  the  Europol  Regulation, 
the  practical  functioning  of  Europol’s  mandate,  and possible  areas where  the  current 
legislative framework could be further strengthened.165 

The evaluation also relies on quantitative data analysis, including operational statistics 
and performance indicators relating to Europol’s activities and the use of its information 
systems  and  operational  support  tools.  This  analysis  includes  trend  analysis  of  relevant 
indicators  over  the  evaluation  period in  order  to identify developments  in  Europol’s 
operational  role  and  the  use  of  its  services  by  Member  States. Data  sources  used 
predominantly include Europol Annual Reports, SIENA statistics and annual reports, EIS 
annual reports, operational support statistics, Europol’s annual budget, establishment plans 
and Single Programming Documents. 

The combination of these sources enables the triangulation of evidence, allowing findings 
to be validated across multiple data sources and perspectives. Quantitative operational data 
are therefore assessed alongside stakeholder input and qualitative operational examples in 
order 
the 
to identify both  measurable  outcomes  and  structural  challenges 
implementation of the Regulation.  

in 

Nevertheless, certain  methodological  limitations should  be taken  into  account when 
interpreting  the  findings  of  this  evaluation.  First,  the  availability  and  comparability  of 
operational  data  across  the  evaluation  period  may  be  affected  by  changes  in  reporting 
practices, evolving performance indicators, and the progressive development of Europol’s 
operational tools and systems. As a result, some trend analyses rely on partially comparable 
datasets or proxy indicators.  

Second, evidence collected through stakeholder consultations and interviews reflects the 
perspectives of participating stakeholders and may therefore be subject to response bias or 
differences in national operational practices. While efforts were made to ensure balanced 
representation  across  Member  States  and  stakeholder  groups,  the  consultation  results 
cannot be considered fully statistically representative of all users of Europol’s services.  

Third, given the evolving nature of criminal threats and technological developments, it is 
not 
the 
intervention. Europol operates within  a  broader  and  constantly  evolving  security 

outcomes 

observed 

attribute 

possible 

always 

solely 

to 

to 

165 More detailed information can be found in Annex 2 of the Staff Working Document. 

115 

 
 
 
environment  shaped  by  multiple  external  factors,  including  developments  in  criminal 
activity,  technological  change,  and  variations  in  national  law  enforcement  capacities. 
These  external  developments  may  influence  observed  outcomes,  making  it  difficult  in 
some cases to isolate the specific effects of the Regulation from broader contextual trends. 

Where such limitations arise, the evaluation relies on the triangulation of multiple evidence 
sources in  order  to ensure  that  conclusions remain proportionate  and  robust.  Further 
methodological details are provided in Annex 4.  

2.  What was the expected outcome of the intervention 

2.1. Description of the intervention and its objective 

Europol was founded under the 1995 Europol Convention as a European Police Office 
to facilitate cooperation among national law enforcement authorities in combating serious 
cross-border crime. The Convention came into force 1 October 1998 and Europol became 
fully  operational  1  July  1999.  Initially,  Europol  focused  on  supporting  information 
exchange  between  Member  States  through  national  contact  points,  analysing  criminal 
intelligence, 
organised 
criminal networks and maintaining centralised data systems.  From its inception, Europol 
was designed to  act  as a hub for criminal intelligence sharing among Member States in 
order  to address  transnational  crime  phenomena  such  as  terrorism,  drug  trafficking, 
trafficking in human beings, cybercrime and other forms of serious organised crime.  

investigations 

supporting 

into 

operational 

The Agency’s legal framework evolved significantly with the Council Decision of 6 April 
Europol’s 
clarified 
broadened 
2009,  which 
its objectives, competences and 
requirement 
tasks.  The  Decision 
to identify organised crime groups before action could be taken and expanded Europol’s 
responsibilities  to additional crime  areas,  including  money  laundering,  trafficking  in 
human  beings,  trafficking  of  cultural  goods,  racism  and  xenophobia  and  environmental 
crime. It also strengthened Europol’s operational role by enabling it to request the initiation 
of  investigations,  support  Joint  Investigation  Teams  (JITs)  and  produce  strategic  threat 
assessments.  

scope 
removed 

and 

the 

Council Framework Decision of 13 June 2002 established the legal framework for Joint 
Investigation Teams to facilitate cross-border investigations and judicial cooperation. The 
2009  Council  Decision subsequently authorised  Europol  staff  to participate in  JITs, 
allowing the Agency to support investigations directly within its mandate.  

Regulation (EU) 2016/794 replaced the 2009 Council Decision and strengthened Europol’s 
legal  framework  as  the  EU  agency  for  law  enforcement  cooperation.  The  Regulation 
introduced enhanced governance and accountability mechanisms, including scrutiny by the 
European Parliament and national parliaments, as well as supervision of Europol’s data 
processing activities by the European Data Protection Supervisor (EDPS). It also clarified 
and  expanded  Europol’s  mandate  and established the  legal  basis  for  specialised  centres 
within Europol providing targeted expertise in specific crime areas.  

The  overall objective of  the  Regulation  is  to  strengthen  cooperation  between  Member 
States’  law  enforcement  authorities  in  preventing  and  combating  serious  cross-border 
crime  and  terrorism  by  improving  information  exchange,  analytical capabilities and 
operational coordination at EU level.  

116 

 
 
In 2022, Regulation (EU) 2022/991 introduced further amendments aimed at addressing 
emerging  operational  and  technological  challenges.  These  amendments  strengthened 
cooperation between law enforcement authorities and private parties, enabled Europol to 
process large and complex datasets for criminal analysis, and enhanced the Agency’s role 
in research and innovation related to security technologies. They also clarified Europol’s 
ability to support investigations concerning crimes affecting a Union interest, even where 
a  clear  cross-border  dimension  is  not  initially  established,  and  empowered  Europol  to 
propose the introduction of information alerts in the Schengen Information System (SIS) 
regarding third-country nationals involved in terrorism and serious crime.  

The  amended  framework  also  strengthened  cooperation  between  Europol  and  the 
European Public Prosecutor’s Office (EPPO), operational since 2021. Europol’s activities 
are  organised  around  specialised  centres  focusing  on  specific  crime  areas,  providing 
targeted operational and analytical support to Member States.  

These  developments  progressively  strengthened  Europol’s  mandate  and  operational 
capabilities, positioning the Agency as the EU’s central hub for criminal intelligence and 
operational coordination in the fight against serious cross-border crime and terrorism.  

Figure 1: The evolution of Europol’s mandate  

the 

time, 

same 

they  make 

extensive  use  of  digital 

Europol operates in  a rapidly  evolving  security  environment.  Criminal  networks 
increasingly operate across  borders,  exploiting  differences  between  national 
legal 
frameworks, jurisdictional limits and gaps in  information exchange between authorities. 
technologies, 
At 
encrypted communications and  global  financial  systems  to facilitate and  conceal  their 
activities. These developments create significant challenges for national law enforcement 
authorities, which often face difficulties in obtaining timely cross-border information and 
coordinating investigations. In this context, Europol supports Member States in preventing 
and  combating  serious  and  organised  crime, terrorism and  other  forms  of  cross-border 
criminal  activity  by  providing  analytical  support, facilitating information  exchange and 
supporting the coordination of cross-border investigations. Europol also contributes to the 
implementation of EU security priorities, as reflected in the ProtectEU Internal Security 
Strategy, including operational cooperation frameworks such as EMPACT.  

logic 

underlying 

Regulation 

intervention 

The 
and 
its subsequent amendment by Regulation (EU) 2022/991 is based on the recognition that 
serious and organised crime and terrorism increasingly operate across national borders and 
require  coordinated  responses  at  EU  level.  By  strengthening  Europol’s  mandate, 
improving mechanisms for information exchange and criminal intelligence analysis, and 
enhancing  operational  coordination  between  national  law  enforcement  authorities,  the 
Regulation aims to increase the effectiveness of cross-border investigations and support 
Member  States  in  addressing  complex  transnational  crime  threats.  The  intervention  is 

2016/794 

(EU) 

117 

 
 
  
therefore expected to contribute to improved operational cooperation, more efficient use 
of law enforcement resources, and enhanced situational awareness at EU level, ultimately 
strengthening the  Union’s  capacity  to  prevent  and  combat  serious  crime  and  terrorism 
while ensuring respect for fundamental rights.  

This evaluation therefore examines the extent to which the existing legal framework has 
enabled  Europol  to  fulfil  these objectives, in  particular  by strengthening  information 
exchange, analytical support and operational coordination between Member States in the 
fight against serious cross-border crime and terrorism.  

118 

 
 
 
Figure 2: Intervention logic  

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
 
 
2.2. Points of comparison 

This  section explains the points of comparison  used to  assess the impact of Regulation 
(EU) 2016/794 and its amendment by Regulation (EU) 2022/991 on Europol’s functioning. 
The evaluation relies primarily on temporal comparisons between the situation prior to 
the adoption of the Regulation and developments observed during its implementation. 

The  main  baseline  for  the  evaluation  is  the  situation  before  the  entry  into  force  of 
Regulation (EU) 2016/794, when Europol operated under the legal framework established 
by the 2009 Council Decision. This baseline provides a reference point for assessing how 
the 2016 Regulation strengthened Europol’s governance framework, operational mandate 
and analytical capabilities. 

The  evaluation  then  examines  developments  during  the  implementation  period  of  the 
Regulation,  from  its  entry  into  force  in  2017  to  2024.  Within  this  period,  particular 
attention  is  given  to  developments  following  the  entry  into  force  of  Regulation  (EU) 
2022/991. This allows the evaluation to assess both the longer-term effects of the 2016 
Regulation and the early impacts of the 2022 amendment. 

To structure the analysis, the evaluation examines developments across six core activity 
areas  reflecting  Europol’s  main  operational  functions:  information  management, 
operational support, strategic analysis, specialised expertise through operational centres, 
cooperation  with  private  sector  entities  and  external  cooperation  with  international 
partners.  These  activity  areas  serve  as  analytical  benchmarks  for  assessing  changes  in 
Europol’s operational output, use of information systems and support to Member States 
over the evaluation period. 

In  addition  to  temporal  comparisons,  the  evaluation  also  considers  contextual 
benchmarks in order to better understand Europol’s role within the broader EU security 
architecture.  This  includes  comparisons  with  other  EU  bodies  involved  in  combatting 
cross-border crime, such as Frontex and the European Public Prosecutor’s Office, as well 
as  reference  to  international  cooperation  mechanisms,  notably  Interpol,  in  order  to 
contextualise Europol’s position as an EU-level criminal intelligence hub. 

Finally, thematic comparisons are used to assess how Europol’s activities have evolved 
in response to emerging crime threats. This includes examining developments in areas such 
as  cybercrime,  terrorism,  human  trafficking  and  financial  crime,  in  order  to  determine 
whether  the  regulatory  framework  has  enabled  Europol  to  adapt  its  operational  and 
analytical support to the evolving security environment. 

Taken  together,  these  points  of  comparison  allow  the  evaluation  to  assess  whether  the 
current legal framework has strengthened Europol’s operational effectiveness, improved 
information exchange and analytical support to Member States, and enhanced cooperation 
with relevant partners at EU and international level. 

3.  What was the expected outcome of the intervention? 

The intervention evaluated in this report is Regulation (EU) 2016/794, which entered into 
force in May 2017 and established the current legal framework governing Europol. The 
Regulation  replaced  the  framework  established  by  Council  Decision  2009/371/JHA, 
under which Europol had operated since 2010. The reform responded to the growing cross-
border  dimension  of  serious  and  organised  crime  and  terrorism,  which  increasingly 
required  more  effective  mechanisms  for  information  exchange,  criminal  intelligence 

 
 
analysis  and  operational  coordination  between  Member  States166.  The  need  for  the 
intervention was linked to limitations identified in the previous legal framework, including 
restrictions  on  Europol’s  ability  to  process  operational  data,  support  investigations  and 
cooperate effectively with other EU bodies and external partners. 

The  general  objective  of  the  Regulation  was  to  enhance  cooperation  between  law-
enforcement  authorities  in  the  Union  and  to  strengthen  support  to  Member  States  in 
preventing and combating serious and organised crime and terrorism affecting two or more 
Member States167. To achieve this objective, the Regulation clarified Europol’s tasks and 
intelligence  analysis,  operational 
strengthened 
coordination  and  specialised  support  to  investigations,  as  well  as  to  manage  EU-level 
information systems used for law-enforcement cooperation168. 

to  provide  criminal 

its  mandate 

The intervention logic underlying  the Regulation  expected that strengthening  Europol’s 
mandate and analytical capabilities would lead to increased use of Europol’s information 
systems,  greater  analytical  and  operational  support  provided  to  Member  States’ 
investigations and stronger coordination of cross-border law-enforcement actions. These 
outputs  were  expected  to  improve  the  identification  of  links  between  criminal 
investigations  conducted  in  different  Member  States  and  facilitate  coordinated 
investigations  targeting  organised  criminal  networks  operating  across  jurisdictions169. 
Ultimately, the intervention was expected to contribute to strengthening the EU’s capacity 
to combat serious and organised crime and terrorism with a cross-border dimension and to 
improve  the  effectiveness  of  law-enforcement  cooperation  across  the  Union.  These 
objectives  are  also  consistent  with  broader  EU  policy  goals  on  internal  security170  and 
contribute indirectly to SDG 16 (peace, justice and strong institutions), particularly targets 
relating to combating organised crime and strengthening institutional capacity171.  

The  evaluation  therefore  assesses  whether  these  expected  outputs,  results  and  impacts 
materialised during the evaluation period 2017-2024 compared with the baseline situation 
under the previous legal framework between 2014 and 2016. 

4.  How has the situation evolved over the evaluation period? 

4.1. Current state of play 

This section describes how Europol’s activities and operational capacity evolved during 
the  evaluation  period  2017-2024  following  the  entry  into  force  of  Regulation  (EU) 
2016/794. Developments are compared with the baseline period 2014-2016, when Europol 
operated under the legal framework established by the 2009 Council Decision. 

166 European Commission, Proposal for a Regulation on the European Union Agency for Law Enforcement 
Cooperation  (Europol),  COM(2013)  173  final,  27.3.2013,  explanatory  memorandum;  European 
Commission, Impact Assessment accompanying the proposal for a Regulation on Europol, SWD(2013) 98 
final, 27.3.2013; Recitals 1-6 of Regulation (EU) 2016/794. 
167 Article 3 of Regulation (EU) 2016/794. 
168 Articles 4-7 and Articles 17-21 of Regulation (EU) 2016/794. 
169 SWD(2013) 98 final,  
170 European Commission, The EU Internal Security Strategy in Action, COM(2010) 673 final. 
171 A/RES/70/1, 2015. 

121 

 
 
 
During  the  evaluation  period,  Europol’s  activities  developed  across  three  main  areas: 
information management, operational support and analytical capabilities, and cooperation 
with operational partners. 

Information management 

Europol acts as a hub for criminal intelligence exchange between EU law enforcement 
authorities. Secure operational communication is primarily conducted through the Secure 
Information  Exchange  Network  Application  (SIENA),  supported  by  the  Europol 
Information System (EIS) and the Querying Europol Systems (QUEST) interface. These 
systems enable national authorities to exchange operational messages, query data stored in 
Europol systems and identify links between investigations. 

During  the  evaluation  period,  the  volume  of  operational  exchanges  conducted  through 
SIENA  increased  steadily,  and  its  use  also  contributed  to  a  rise  in  the  number  of 
operational cases. During the same period, the number of competent authorities connected 
to  SIENA  expanded 
to  include  national  law  enforcement  authorities,  customs 
administrations, and Police and Customs Cooperation Centres (PCCCs)172. 

SIENA 

Year 

Messages exchanged 

Creation of 
operational cases 

Connected 
authorities  

2016 

2017 

2020 

2023 

2024 

869 858 

~1 million 

~1.3 million 

~1.8 million 

~2 million 

46 437 

66 113 

88 748 

151 318 

169 500 

757 

1 100 

2 239 

2 950 

3 500 

Source: Europol operational statistics; Europol annual reports 2017-2024. 

The expansion of SIENA connectivity took place in a broader EU policy context aimed 
at strengthening law enforcement information exchange173. During the evaluation period, 
the  Union  adopted  new  legislative  measures  in  this  area,  including  the  Information 

172  The  extent  and  timing  of  this  integration  varied  across  Member  States.  Member  States  with  direct 
connections between national case-management systems and SIENA recorded higher volumes of automated 
exchanges, while others continued to rely primarily on manual message entry through central contact points 
or Europol National Units (External evaluation study, 2026). 
173  During  the  evaluation  period,  the  Union  adopted  or  developed  several  instruments  relevant  to  police 
information  exchange,  including  the  Information  Exchange  Directive,  Prüm  II,  the  interoperability 
framework for EU information systems and the Digital Services Act, each of which created new interfaces 
or  implementation  tasks  relevant  to  Europol’s  information-management  and  ICT  environment.  These 
developments affected the technical and organisational environment in which SIENA, EIS and related tools 
operated during the period under evaluation. 

122 

 
 
 
Exchange Directive174, which provides for the mandatory use of SIENA by national Single 
Points  of  Contact  and  foresees  the  integration  of  SIENA  into  national  police  case-
management  systems.  As  the  Directive  was  adopted  towards  the  end  of  the  evaluation 
period,  its  implementation  had  only  started  in  several  Member  States  by  2024  and  the 
transitional arrangements for its application extend beyond the evaluation period. During 
the period covered by this evaluation, SIENA therefore remained one of several channels 
used by national authorities for cross-border law enforcement information exchange. 

The operation of Europol’s information-management environment during the evaluation 
period was also shaped by developments relating to data standardisation, large datasets and 
data protection. A large share of SIENA traffic continued to be transmitted in unstructured 
formats,  including  narrative  text,  PDFs,  screenshots,  scans  and  extracted  device  data, 
requiring manual handling before these data could be cross-checked or analysed175. The 
UMF initiative did not progress to full operational implementation during the evaluation 
period176. 

In  addition  to  secure  communication  through  SIENA,  Europol  maintains  centralised 
criminal  intelligence  databases  accessible  to  national  authorities  through  the  Europol 
Information System (EIS) and the QUEST search interface177, which enables searches 
across  multiple  Europol  datasets.  This  system  allows  national  authorities  to  query 
operational  data  stored  at  Europol  and  identify  potential  links  between  criminal 
investigations conducted in different jurisdictions. 

During the evaluation period, both the volume of searches conducted in Europol systems 
and the number of data objects stored in the EIS evolved as follows: 

Year 

2015 

2016 

2017 

2020 

2023 

EIS searches 

EIS objects 

633 639 

1 436 838  

2 478 825 

10 231 771 

14 238 667 

295 374 

395 357 

1 062 236 

1 337 089 

1 572 837 

174 Directive (EU) 2023/977 of the European Parliament and of the Council of 10 May 2023 on the exchange 
of information between law enforcement authorities of Member States and repealing Council Framework 
Decision 2006/960/JHA. 
175 External evaluation study supporting the evaluation and impact assessment of Regulation (EU) 2016/794, 
2026. 
176 External evaluation study supporting the evaluation and impact assessment of Regulation (EU) 2016/794, 
2026. 
177 The development and use of EIS and QUEST during the evaluation period depended on how national 
authorities  connected  their  domestic  systems  to  Europol’s  tools.  Many  Member  States  continued  to  use 
SIENA to request EIS cross-checks, as QUEST or other automated loaders had not yet been implemented. 
Data provision to EIS also remained uneven, with structured uploads, automated ingestion, and common 
formats not uniformly implemented across the Union. (External evaluation study, 2026). 

123 

 
 
 
2024 

12 795 330 

Source: Europol 

1 693 143 

Europol  also  performs  automated  cross-matching  of  operational  data  received  from 
Member  States  in  order  to  identify  potential  links  between  criminal  investigations 
conducted in different jurisdictions. This process generates crossmatch reports and SIENA 
hit notifications that are transmitted to the relevant national authorities when matches are 
detected between datasets stored in Europol systems.  

During  the  evaluation  period,  the  number  of  crossmatch  reports  and  hit  notifications 
generated by Europol evolved as follows: 7 372 in 2017, 6 824 in 2018, 7 806 in 2019, 9 
559  in  2020,  14  413  in  2021,  14  737  in  2022,  and  14  407  crossmatch  reports  in  2023, 
followed by 13 409 reports in 2024178.  

A  key  development  affecting  information  management  during  the  evaluation  period 
concerned the handling of large and complex datasets. Regulation (EU) 2022/991 clarified 
Europol’s  legal  framework  for  processing  personal  data  received  without  data-subject 
categorisation  for  the  purpose  of  completing  categorisation  and  supporting  ongoing 
investigations.  Under Article 18(6a), such data may be processed for up to  18 months, 
extendable  to  36  months  in  justified  cases,  solely  for  completing  data-subject 
categorisation. Article 18a introduced a derogation allowing Europol to process personal 
data  from  competent  authorities,  the  EPPO  or  Eurojust,  where  necessary  to  support 
ongoing criminal investigations, including through operational analysis and, in exceptional 
and duly justified cases, cross-checking. These amendments required the development of 
internal procedures and data-governance arrangements for the management of large and 
complex datasets. 

Operational support and analytical capabilities  

Europol provides operational support to Member States in cross-border investigations and 
operational  actions  through  analytical  support,  operational  coordination  and  specialised 
technical  expertise.  Under  Regulation  (EU)  2016/794,  Europol  supports  national 
authorities by providing criminal intelligence analysis, coordinating operational activities 
and  deploying  specialised  capabilities  during  investigations.  These  activities  include 
support  to  operational  investigations,  participation  in  Joint  Investigation  Teams  (JITs), 
organisation  of  operational  meetings,  support  to  Operational  Task  Forces  (OTFs), 
coordination  of  Joint  Action  Days  (JADs)  and  the  deployment  of  mobile  offices  and 
specialised staff during operational actions. 

During the baseline period (2014-2016), Europol already provided operational analytical 
support to Member States primarily through Analytical Work Files (AWFs), operational 
meetings  and  participation  in  Joint  Investigation  Teams  (JITs).  AWFs  were  the  main 
analytical structures used by Europol to analyse operational data and support cross-border 
investigations179.  Europol  also  facilitated  coordination  between  national  authorities 

178 Europol Consolidated annual activity reports. 
179 Council Decision 2009/371/JHA establishing the European Police Office (Europol), OJ L 121, 15.5.2009, 
Articles 10-14. 

124 

 
 
 
through  operational  meetings  and  analytical  support  to  investigations180.  According  to 
Europol operational statistics, the Agency produced around 5 300 operational reports in 
2016,  reflecting  the  analytical  support  provided  to  national  investigations  during  this 
period181. Operational support during the baseline period was therefore primarily focused 
on providing criminal intelligence analysis and facilitating coordination between national 
authorities involved in cross-border investigations.182 

Following  the  entry  into  force  of  Regulation  (EU)  2016/794  in  2017,  Europol’s 
operational  support  was  progressively  expanded  and  became  increasingly  structured 
around  intelligence-led  investigations  targeting  organised  criminal  networks  operating 
across  several  Member  States.  This  reflected  the  strengthened  mandate  of  Europol  to 
provide analytical support, operational coordination and specialised expertise to national 
authorities  in  cross-border  investigation.  During  the  evaluation  period,  operational 
coordination increasingly relied on structures such as Operational Task Forces (OTFs)183 
and Europol’s participation in Joint Investigation Teams (JITs)184, which bring together 
investigators  and  analysts  from  several  Member  States  to  support  intelligence-led 
investigations  targeting  priority  criminal  networks.  Europol  also  supports  coordinated 
operational  actions  between  Member  States  through  the  organisation  of  Joint  Action 
Days185. The number of JADs has increased throughout the evaluation period, with a total 
of 7 taking place in 2017, 10 in 2023 and 11 in 2024.186 

Year 

Cross-border 
investigations 
supported by Europol 

Joint Investigation 
Teams  

Operational 
Task Forces  

2014-2016 
(baseline annual 
average) 

2017 

2020 

~1 000 

38 JITs 

1496 

837 

61 JITs 

57 JITs (including 
15 newly signed) 

- 

- 

11 

180 Europol, Annual General Report 2015, The Hague, 2016. 
181 Europol, Consolidated Annual Activity Report 2016, The Hague, 2017, p. 12. 
182 Europol, Consolidated Annual Activity Report 2016, pp. 11–14. 
183 Operational Task Forces are operational coordination structures supported by Europol that bring together 
investigators  and  analysts  from  several  Member  States  to  target  priority  criminal  networks  and  conduct 
intelligence-led investigations. 
184 Joint Investigation Teams are cooperation mechanisms enabling competent authorities from two or more 
countries to conduct joint criminal investigations for a specific purpose and limited period. Europol supports 
JITs by providing analytical, operational and coordination assistance. 
185 These operations involve coordinated law enforcement activities carried out simultaneously in several 
Member States and supported by Europol through operational coordination, criminal intelligence analysis 
and mobile office deployment. They take place in the framework of EMPACT. 
186 Europol, Consolidated Annual Activity Reports 2017, 2023, 2024. 

125 

 
 
 
2023 

3155 

2024 

3 324 

33 JITs (including 
21 newly initiated 
teams) 

49 JITs (including 
36 newly 
established). 

27 

65187 

Source: Europol operational statistics 

In  parallel  with  the  increase  in  investigations  supported,  Europol’s  analytical  output 
expanded  considerably  during  the  evaluation  period.  Operational  reports  produced  in 
direct support of investigations increased from 5 330 in 2016 to 23 012 in 2023 and 21 281 
in 2024. Europol also continued to produce strategic analysis188 on emerging crime threats 
and supporting EU operational frameworks such as EMPACT. In 2024, Europol produced 
29  strategic  analysis  reports  and  366  operational  analysis  reports,  compared  with  44 
strategic reports and 332 operational reports in 2017. 

At the same time, the speed of operational analytical responses improved substantially 
over  the  evaluation  period.  Europol  operational  data  indicate  that  the  average  response 
time  to  analytical  requests  from  Member  States  decreased  from  27.5  days  in  2016  to  a 
range of 3-4 days between 2021 and 2024. In 2024, the average turnaround time for 80% 
of first-line analysis requests was 3.2 days, compared with 4.2 days in 2023. 

A further component of Europol’s operational support consists of on-the-spot operational 
deployments,  primarily  through  the  use  of  mobile  offices189  and  the  deployment  of 
specialised  operational  staff.  During  the  baseline  period  (2014-2016),  Europol  already 
provided  such  support  during  investigations  and  operational  actions.  In  2016,  Europol 
recorded 159 short-term mobile office deployments, 56 long-term deployments and 6 
permanent  deployments  supporting  operational  activities190.  Mobile  offices  were  also 
deployed during major investigations, for example to support operations in Belgium and 
France following the 2015-2016 terrorist attacks191.  

During the evaluation period, the number of deployments increased significantly, reaching 
339 in 2017, 370 in 2018 and 353 in 2019192. While reporting categories changed slightly 
over time, the figures indicate a substantial increase in the use of mobile offices to provide 
on-the-spot analytical support during operational actions.  

187  In  2024,  Europol  also  introduced  a  new  internal  management  and  monitoring  framework  for  OTFs 
(OTF.360), although the operational impact of this new framework falls largely beyond the evaluation period. 
188 Europol’s analytical products include the Serious and Organised Crime Threat Assessment (SOCTA), the 
Internet Organised Crime Threat Assessment (IOCTA), the EU Terrorism Situation and Trend Report (TE-
SAT) and the European Financial and Economic Crime Threat Assessment (EFECTA). 
189 Mobile offices allow investigators to access Europol databases and analytical tools in real time during 
operational actions and enable the immediate cross-checking of operational data against information stored 
in Europol systems. 
190 Europol Consolidated Annual Activity Report 2016. 
191 Europol Review 2016-2017. 
192 Europol,  Consolidated Annual Activity Reports 2017–2019. Mobile offices were also used to support 
major  international  security  events  requiring  enhanced  operational  coordination.  In  2024,  for  example, 
Europol provided operational support during UEFA EURO 2024 and the Paris 2024 Olympic and Paralympic 
Games, including the deployment of staff and coordination support. 

126 

 
 
 
During  the  evaluation  period  (2017-2024),  Europol  further  expanded  its  specialised 
operational  structures  to  address  evolving  crime  threats193.  The  European  Counter 
Terrorism Centre (ECTC), launched in 2016, strengthened operational coordination and 
information  exchange  between  Member  States  in  terrorism  investigations.  In  2020, 
Europol established the European Financial and Economic Crime Centre (EFECC) to 
enhance  support  for  investigations  related  to  financial  and  economic  crime,  including 
fraud, corruption, money laundering and asset recovery.  

Technological  developments  increasingly  shaped  Europol’s  operational  capabilities 
during the evaluation  period, reflecting the growing  importance of digital evidence  and 
large datasets in  criminal investigations. While Europol already used analytical tools to 
support investigations during the baseline period, it did not yet have dedicated innovation 
structures  or  programmes  to  develop  new  technological  capabilities.  The  expansion  of 
cybercrime,  online  fraud,  encrypted  communications  and  cryptocurrency-related  crime 
therefore led to growing demand from Member States for advanced data-analysis tools, 
prompting Europol to progressively strengthen its technological capacities and establish 
dedicated innovation structures. 

In this context, Europol created the Europol Innovation Lab in 2020 to develop and test 
new  technologies  relevant  for  law  enforcement,  including  artificial  intelligence,  data 
mining and advanced analytics applied to large operational datasets194. In 2024, Europol 
further strengthened these capabilities with the launch of the Research and Innovation 
Sandbox,  which  allows  the  development  and  testing  of  AI  models  using  operational 
datasets under controlled conditions. These developments illustrate a broader shift during 
the  evaluation  period  towards  data-driven  investigations,  in  which  large  volumes  of 
digital  evidence  and  financial  data  increasingly  require  specialised  analytical  tools  and 
technological expertise to support cross-border investigations. 

In  addition  to  supporting  Member  States  directly,  Europol  provides  operational  and 
analytical  support  within  the  broader  EU  internal  security  architecture  through 
cooperation  with  EU  agencies  and  bodies  involved  in  law-enforcement,  border 
management and judicial cooperation. 

During  the baseline period (2014-2016), operational  cooperation between Europol  and 
other  EU  actors  already  existed195,  particularly  with  Eurojust  in  the  context  of  Joint 
Investigation Teams (JITs). In 2016, 50 operational cases supported by Europol involved 
Eurojust, reflecting the complementary analytical and judicial support provided by the two 
agencies  in  cross-border  criminal  investigations196.  Cooperation  also  took  place  with 
Frontex,  particularly  in  investigations  related  to  migrant  smuggling  and  cross-border 

193 Some of these structures were already operational during the baseline period (2014-2016). The European 
Cybercrime Centre (EC3), established in 2013, supports investigations related to cybercrime, online fraud 
and child sexual exploitation and provides specialised capabilities such as digital forensics, malware analysis 
and cryptocurrency tracing. In 2016, Europol created the European Migrant Smuggling Centre (EMSC) to 
strengthen support to Member States in investigations targeting migrant smuggling networks. 
194  By  2023,  the  Innovation  Lab  had  supported  dozens  of  innovation  projects  and  research  initiatives 
involving law enforcement authorities, EU agencies, research institutions and private-sector partners, and 
contributed  to  the  development  and  testing  of  analytical  tools  made  available  to  the  European  policing 
community through Europol’s tool repository, which hosts more than 30 investigative tools. 
195  Cooperation  was  primarily  based  on  operational  coordination,  participation  in  joint  meetings  and 
information exchange through Europol systems.  
196 Europol, Consolidated Annual Activity Report 2016. 

127 

 
 
 
organised  crime.  In  2016,  Europol  deployed  officers  to  migration  hotspot  locations  in 
Greece and Italy to support operations coordinated by Frontex and assist Member States 
in identifying criminal networks involved in migrant smuggling197.  

During the evaluation period (2017-2024), this cooperation expanded as the EU internal 
security  architecture  evolved  and  new  actors  were  created.  Europol  increasingly 
contributed  analytical  support,  operational  coordination  and  information  exchange  to 
multi-agency investigations and EU-level operational frameworks.  

One important development was the establishment of the European Public Prosecutor’s 
Office (EPPO)198, operational since 2021, which investigates crimes affecting the EU’s 
financial  interests.  Europol  provides  analytical  support  and  intelligence  cross-checks  in 
investigations  related  to  fraud,  corruption  and  other  financial  crimes  affecting  the  EU 
budget.  Europol  contributes  to  a  subset  of  these  investigations  by  providing  analytical 
support, cross-matching of operational data and intelligence analysis, particularly in 
complex cases involving organised fraud schemes, corruption and cross-border VAT fraud 
affecting the EU budget. Europol supported six EPPO cases in 2021, 28 cases in 2022, 47 
cases in 2023 and 83 cases in 2024. Cooperation with EPPO increased gradually during 
the  latter  part  of  the  evaluation  period  as  operational  arrangements  between  the  two 
organisations were implemented. 

Europol also contributed to training and knowledge-sharing activities for law enforcement 
authorities. During the evaluation period, Europol cooperated with the European Union 
Agency  for  Law  Enforcement  Training  (CEPOL)  to  deliver  training  programmes 
addressing priority crime areas such as cybercrime, financial crime and counterterrorism. 
In  2024,  more  than  800  law  enforcement  officers  participated  in  Europol-supported 
training activities. 

The implementation of this support to EU agencies and EU-level frameworks developed 
progressively  during  the  evaluation  period  and  was  influenced  by  differences  in 
institutional  mandates, data access  conditions  and the maturity of inter-agency working 
arrangements. The focus group with EU agencies and bodies noted that cooperation is often 
operationally close, but that data protection arrangements, mandate boundaries and data 
ownership principles continue to shape how information can be exchanged and used across 
institutional actors. These factors formed part of the operational context in which Europol’s 
support functions evolved over the period.  

External cooperation 

Cooperation with external partners strengthened over the evaluation period, reflecting the 
increasing international dimension of serious and organised crime and the operational 
needs of Member States to cooperate with partners outside the EU.  

During  the  baseline  period  (2014-2016),  Europol  already  maintained  cooperation 
agreements  with  around  25  third  countries  and  international  organisations  and  hosted 
around 200 liaison officers at it headquarter. 

During the evaluation period, Europol further expanded its external cooperation network. 
The Agency concluded additional working arrangements with third countries and partners, 

197 Europol, Consolidated Annual Activity Report 2016. 
198 Regulation (EU) 2017/1939. 

128 

 
 
 
including Singapore in 2020 and India in 2023, and strengthened operational cooperation 
with international organisations such as INTERPOL and International Criminal Court. 
In  parallel,  Europol  increasingly  cooperated  with  private-sector  partners,  particularly  in 
cybercrime and online fraud investigations. By the early 2020s, Europol was working with 
a  large  number  of  private-sector  partners,  including  technology  companies  and 
financial  institutions,  in  public-private  partnerships  supporting  investigations  related  to 
cybercrime and illicit financial flows. 

The  pace  of  developments  in  external  cooperation  during  the  evaluation  period  was 
influenced  by  several  factors.  The  growing  transnational  nature  of  criminal  networks 
created increased demand from Member States for cooperation with third countries and 
international  partners.  At  the  same  time,  the  development  of  formal  cooperation 
frameworks  depends  on  the  existence  of  an  appropriate  legal  basis  under  the  Europol 
Regulation,  including  international  agreements  between  the  EU  and  partner  countries 
where the exchange of personal data is envisaged. The negotiation and adoption of such 
agreements require compliance with EU data protection standards and fundamental rights 
safeguards and may therefore take time. In addition, broader EU external security priorities 
and the strategic importance of certain partner countries also shaped the development of 
Europol’s external cooperation network. 

5.  Evaluation findings 

5.1. To what extent was the intervention successful and why? 

The success of the intervention is assessed in terms of the extent to which the Regulation 
strengthened  cooperation  between  Member  States’  law  enforcement  authorities  in 
preventing and combating serious cross-border crime and terrorism, and whether this was 
achieved effectively, efficiently and in a coherent manner within the EU internal security 
framework. 

Effectiveness 

Effectiveness  concerns  the  extent  to  which  the  objectives  of  the  Regulation  have  been 
achieved. 

The  expected  outcome  of  the  intervention  was  to  strengthen  operational  cooperation 
between  Member  States  through  improved  information  exchange,  enhanced  analytical 
capabilities  and  stronger  operational  coordination  at  EU  level.  Evidence  presented  in 
Section 2 indicates that these objectives have been largely achieved during the evaluation 
period. 
Operational  data199  show  a  substantial  increase  in  the  use  of  Europol’s  information 
exchange  infrastructure.  The  volume  of  operational  exchanges  through  the  Secure 
Information Exchange Network Application (SIENA) increased significantly during the 
evaluation period, reaching approximately two million messages in 2024. Similarly, the 
number of searches  conducted in Europol’s information systems increased substantially 
over  the  same  period.  These  developments  suggest  that  national  law  enforcement 
authorities increasingly rely on Europol’s systems to support cross-border investigations.  

199 Europol Annual Reports 2017-2024. 

129 

 
 
 
Evidence  from  stakeholder  consultations  supports  this  finding.  Respondents  to  the 
Commission’s public consultation200 consistently identified Europol’s role in facilitating 
cross-border information exchange and operational coordination as one of the Agency’s 
most  important  contributions  to  EU  law  enforcement  cooperation.  Focus  group 
discussions  with  Member  State  authorities201  similarly  emphasised  the  operational 
importance  of  Europol’s  information  exchange  systems  and  analytical  support. 
Participants indicated that Europol’s analytical capabilities frequently enable investigators 
to identify links between criminal cases conducted in different jurisdictions and facilitate 
coordinated operational actions across Member States. 

Operational  support  provided  by  Europol  has  also  expanded  significantly  during  the 
evaluation  period.  The  number  of  cross-border  investigations  supported  by  Europol 
increased substantially, reaching approximately 3 324 investigations supported in 2024202. 
Case studies analysed during the external evaluation203 study demonstrate that Europol’s 
analytical  capabilities  frequently  enable  investigators  to  identify  links  between 
criminal  cases  in  different  Member  States  and  facilitate  coordinated  operational  action 
against transnational criminal networks. 

The development of specialised operational centres within Europol also contributed to 
strengthening operational effectiveness. Centres such as the European Cybercrime Centre 
(EC3), the European Counter Terrorism Centre (ECTC) and the European Financial and 
Economic Crime Centre (EFECC) provide specialised expertise in  areas  such as digital 
intelligence  analysis204. 
forensics,  financial 
Stakeholder  consultations205  indicate  that  these  specialised  capabilities  are  particularly 
valuable for Member States with more limited technical resources. 

investigations  and  counter-terrorism 

Despite  these  positive  developments,  the  evaluation  identified  several  factors  that  may 
affect the full effectiveness of the intervention. 
First,  evidence  collected  through  focus  group  discussions206  indicates  that  information 
sharing practices remain uneven across Member States. Some Member States contribute 
significantly  larger  volumes  of  operational  data  than  others,  which  may  affect  the 
completeness of operational datasets available to Europol for analytical purposes. 
Second, stakeholders207 highlighted operational challenges related to the processing of 
large  and  complex  datasets,  particularly  in  cases  involving  digital  evidence  and 
encrypted communications. 

Third,  consultations 
to  data  protection 
identified  procedural  constraints  related 
requirements and data ownership principles that may affect Europol’s ability to process 
certain datasets or share information across institutional boundaries (EU agencies focus 
group, January 2026). 

200 Public consultation summary report, 2026. 
201 Member States focus group, January 2026. 
202 Europol Annual Reports 2017-2024. 
203 External evaluation study, 2026. 
204 Europol Annual Reports 2017-2024. 
205 Public consultation summary report, 2026. 
206 Member States focus group, January 2026. 
207 EU agencies focus group, January 2026. 

130 

 
 
 
Overall, the available evidence indicates that the Regulation has significantly strengthened 
operational cooperation between Member States and enhanced Europol’s role as the EU’s 
central criminal intelligence hub. 

Efficiency 

Efficiency assesses whether the objectives of the intervention were achieved at reasonable 
cost and whether the available resources were used proportionately to the results obtained. 

Europol provides several centralised services at EU level, including secure communication 
systems, analytical platforms and specialised forensic capabilities. These services allow 
Member States to pool resources and avoid duplicating similar infrastructure at national 
level. 

The expansion of Europol’s operational activities during the evaluation period occurred 
alongside increases in the Agency’s financial and human resources. Overall, the available 
evidence indicates that Europol’s operational outputs have increased broadly in line with 
the growth in available resources208. 

Year 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

2024 

Budget 

Staff 

€104.9 million 

€129.9 million 

€136.1 million 

€138.3 million 

€143.6 million 

€168.8 million 

€192.4 million 

€200 million 

€217 million 

655 

684 

859 

893 

871 

960 

992 

911 

941 

Evidence  from  stakeholder  consultations209  suggests  that  Europol’s  centralised  services 
generate economies of scale by providing specialised analytical and technical capabilities 
that would be costly for individual Member States to develop independently. 
Focus  group  discussions  with  Member  States210  indicate  that  measures  aimed  at 
strengthening  automated  data  exchange  and  systematic  use  of  Europol  systems  could 
generate significant operational benefits while involving moderate implementation costs. 

At the same time, consultations indicate that increasing demand for Europol’s services may 
place pressure on the Agency’s analytical capacity and operational resources211. 

208 Europol Annual Reports 2017-2024. 
209 Public consultation summary report, 2026. 
210 Member States focus group, January 2026. 
211 External evaluation study, 2026. 

131 

 
 
 
Stakeholders212 also identified opportunities to improve efficiency by simplifying certain 
operational  procedures,  strengthening  interoperability  between  information  systems  and 
improving digital tools supporting operational cooperation. 

Overall, the evaluation indicates that Europol’s services contribute to more efficient use of 
law enforcement resources across the Union, although growing operational demand may 
require additional resources to maintain this level of efficiency. 

Coherence 

Coherence  assesses  whether  the  intervention  is  consistent  with  other  EU  policies  and 
instruments  and  whether  it  interacts  effectively  with  the  broader  EU  internal  security 
framework. 

Europol  operates  within  a  broader  EU  security  architecture  that  includes  several  actors 
involved in law enforcement cooperation and judicial coordination, including Eurojust, the 
European Public Prosecutor’s Office (EPPO), Frontex and CEPOL. 
Evidence collected during the evaluation213 indicates that Europol’s activities generally 
complement  those  of  these  actors,  particularly  through  its  role  in  providing  criminal 
intelligence  analysis  and  facilitating  information  exchange  between  national  authorities 
and other EU Agencies, bodies and offices. In particular, Europol plays an important role 
in  supporting  the  European  Multidisciplinary  Platform  Against  Criminal  Threats 
(EMPACT),  which  coordinates  operational  actions  against  priority  crime  threats  at  EU 
level. 
At  the  same  time,  consultations  with  EU  agencies214  highlighted  certain  operational 
challenges  related  to  the  interaction  between  different  institutional  mandates  and  legal 
frameworks.  In  particular,  stakeholders  noted  that  differences  in  data  protection 
frameworks and institutional mandates may affect the efficiency of information exchange 
between EU bodies. 

Nevertheless, the evaluation did not identify major inconsistencies between the Europol 
Regulation and other EU legal instruments. 

5.2. How did the EU intervention make a difference? 

This section assesses the EU added value of the intervention. EU added value refers to 
the  benefits  generated  by  EU-level  intervention  that  would  not  have  been  achieved,  or 
would have been achieved less effectively, by Member States acting individually. 

The evaluation finds that Europol generates substantial EU added value by enabling the 
integration of criminal intelligence and operational coordination across multiple Member 
States. 

Europol’s centralised information exchange infrastructure enables national authorities to 
share  operational  information  simultaneously  with  multiple  partners,  facilitating  the 
identification  of  links  between  criminal  investigations  conducted  in  different  Member 

212 EU agencies focus group, January 2026. 
213 External evaluation study, 2026. 
214 EU agencies focus group, January 2026. 

132 

 
 
 
States 215. Without EU-level coordination mechanisms such as those provided by Europol, 
cooperation  between  national  authorities  would  rely  primarily  on  bilateral  exchanges, 
which  may  be  slower  and  less  effective  in  addressing  complex  transnational  criminal 
networks. Stakeholder consultations216 indicate that Europol’s analytical and coordination 
capabilities  significantly  enhance  the  effectiveness  of  cross-border  investigations 
compared with bilateral cooperation mechanisms. 

Europol  also  centralises  specialised  analytical  and  technical  capabilities  at  EU  level, 
including advanced digital forensic tools, financial intelligence analysis and cybercrime 
investigation  support.  By  pooling  these  capabilities,  Europol  allows  Member  States  to 
benefit  from  economies  of  scale  and  reduces  the  need  for  duplicative  investment  in 
specialised infrastructure217. 

These capabilities are particularly valuable for smaller or resource-constrained Member 
States218. 
Operational case studies analysed during the evaluation219 show that Europol’s analytical 
and coordination capabilities can play a decisive role in complex investigations targeting 
criminal networks operating across several jurisdictions. 

Europol  also  facilitates  cooperation  between  EU  law  enforcement  authorities  and 
international  partners.  Consultations  with  external  stakeholders  indicate  that  Europol 
serves  as  an important  gateway  for  cooperation with  the European Union, reducing  the 
need for multiple bilateral contacts with individual Member States220. 
High-level  stakeholders221  also  emphasised  Europol’s  central  role  in  facilitating 
information exchange and analytical cooperation across the Union. 

Overall, the evaluation concludes that the intervention provides clear EU added value by 
enabling coordinated operational responses to cross-border criminal threats that would be 
significantly  more  difficult  to  achieve  through  national  or  bilateral  cooperation 
mechanisms alone. 

5.3. Is the intervention still relevant? 

The  relevance  criterion  assesses  whether  the  objectives  of  the  intervention  remain 
appropriate in the context of evolving crime threats and operational needs. 
Evidence  from  Europol  threat  assessments222  indicates  that  organised  crime  groups 
increasingly  operate  across  national  borders  and  rely  heavily  on  digital  technologies, 
encrypted communication services and global financial systems to conduct illicit activities. 

215 Europol Annual Reports 2017-2024. 
216 Public consultation summary report, 2026. 
217 External evaluation study, 2026. 
218 Public consultation summary report, 2026. 
219 External evaluation study, 2026. 
220 External evaluation study, 2026. 
221 Joint Statement by the European Police Chiefs on the Future Development of Europol. 
222 SOCTA, 2025. 

133 

 
 
 
Stakeholder consultations conducted during the evaluation223 indicate strong support for 
Europol’s role in facilitating cross-border operational cooperation and providing analytical 
support to Member States. In particular, respondents to the public consultation and call for 
evidence  emphasised  the  growing  importance  of  EU-level  coordination  mechanisms  in 
addressing technologically sophisticated forms of criminal activity, including cybercrime 
and online financial fraud224. 
Focus  group  discussions  with  Member  States  and  EU  agencies225  highlighted  the 
increasing 
in  addressing 
technologically sophisticated forms of criminal activity, including cybercrime and online 
financial fraud. Focus group discussions226 similarly highlighted the increasing complexity 
of  criminal  investigations  involving  digital  evidence,  large  datasets  and  cross-border 
financial flows. 

importance  of  EU-level  coordination  mechanisms 

At  the  same  time,  stakeholders  identified  areas  where  evolving  operational  needs  may 
require further adaptation of the legal framework. These include: 

• 

• 

• 

• 

the increasing volume of digital evidence in criminal investigations 

the need to process large and complex datasets 

the growing importance of cooperation with private sector actors 

the rapid technological evolution of criminal methods. 

Overall, the evaluation  finds that  the objectives of Regulation (EU) 2016/794  remain 
highly  relevant,  as  the  increasingly  transnational  and  digital  nature  of  serious  crime 
continues  to  require  strong  EU-level  mechanisms  supporting  operational  cooperation 
between Member States. 

6.  What are the conclusions and lessons learned 

6.1. Conclusions 

The evaluation concludes that Regulation (EU) 2016/794 has substantially strengthened 
the European Union’s capacity to  prevent  and  combat serious  and organised crime and 
terrorism  with  a  cross-border  dimension.  Europol  has  consolidated  its  role  as  a  central 
operational  and  analytical  hub  within  the  EU’s  internal  security  architecture,  providing 
clear added value to Member States’ law enforcement cooperation.  

The  evidence  presented  in  Sections  3  and  4  indicates  that  the  intervention  has  largely 
achieved its objectives. Europol has enhanced the quality, scale and intensity of cross-
border  information  exchange  and  operational  coordination  among  Member  States.  The 
growing  use  of  Europol’s  information  systems,  notably  SIENA  and  the  Europol 
Information System, illustrates the increasing reliance of national authorities on Europol 
as a platform for secure information exchange and analytical support. Europol’s strategic 
threat assessments, including SOCTA, IOCTA and TE-SAT, have become key tools for 
identifying EU crime priorities and informing operational planning at EU level. 

223 Public consultation summary report, 2026. 
224 Public Consultation Factual Summary Report, 2026; Call for Evidence Factual Summary Report, 2026. 
225 Member States focus group, January 2026; EU agencies focus group, January 2026. 
226 EU Agencies Focus Group Summary, February 2026. 

134 

 
 
 
Europol’s  specialised  centres,  such  as  the  European  Cybercrime  Centre  (EC3)  and  the 
European Counter Terrorism Centre (ECTC), have strengthened the Union’s capacity to 
address emerging and technically complex threats by providing specialised expertise and 
analytical  capabilities  that  many  Member  States  could  not  sustain  independently.  In 
addition, Europol’s operational support to mechanisms such as Joint Investigation Teams 
(JITs),  Joint  Action  Days  (JADs)  and  Operational  Task  Forces  (OTFs)  has  facilitated 
coordinated enforcement actions, accelerated evidence collection and reduced duplication 
of investigative efforts across jurisdictions. 

The evaluation also finds that Europol operates efficiently by centralising specialised ICT 
systems,  analytical  capabilities  and  operational  coordination  at  EU  level,  generating 
economies  of  scale  that  individual  Member  States  would  struggle  to  achieve  alone. 
Increased resources have enabled Europol to expand its outputs, particularly in information 
exchange and operational support. However, the continued growth in operational demand 
and  the  increasing  complexity  of  transnational  crime  create  pressures  on  Europol’s 
resources and risk shifting the balance towards reactive operational support at the expense 
of strategic foresight. 

The evaluation also finds that the intervention contributed to strengthening Europol’s role 
within the EU internal security architecture. Cooperation between Europol and other EU 
actors, including Eurojust, Frontex, European Public Prosecutor’s Office and CEPOL, 
expanded  during  the  evaluation  period.  Europol  also  increased  its  engagement  with 
international  partners  and  private-sector  actors  in  areas  such  as  cybercrime  and  online 
fraud. 

The Regulation remains highly relevant to the evolving security landscape. Serious and 
organised  crime  and  terrorism  continue  to  operate  increasingly  across  borders,  with 
digitalisation  further  expanding  the  scale  and  reach  of  criminal  activities.  Europol’s 
mandate remains broadly aligned with these challenges, although emerging threats such as 
large-scale cyber-enabled fraud and the use of artificial intelligence in criminal activities 
may require further adaptation of the legal framework. 

The evaluation finds that the Regulation is coherent both internally and with the broader 
EU legal framework governing police cooperation. Europol’s mandate complements other 
EU  instruments  and  agencies,  contributing  to  a  more  integrated  European  security 
architecture while maintaining safeguards for fundamental rights. 

Finally,  the  evaluation  confirms  that  Europol  generates  clear  EU  added  value.  By 
providing  EU-wide  criminal  intelligence,  facilitating  operational  coordination  and 
enabling cooperation with private sector partners and third countries, Europol supports a 
more coherent and effective European response to transnational crime. These benefits are 
particularly significant for smaller Member States that may lack the capacity to develop 
comparable  capabilities  at  national  level.  At  the  same  time,  Europol’s  effectiveness 
continues to depend on the timely and comprehensive sharing of information by Member 
States,  highlighting  the  importance  of  sustained  engagement  across  the  EU  law 
enforcement community. 

6.2. Lessons learned  

Several lessons emerge from the evaluation. 

135 

 
 
First,  the  evaluation  confirms  the  continued  importance  of  EU-level  mechanisms  for 
criminal intelligence exchange and operational coordination. The transnational nature 
of  serious  and  organised  crime  means  that  effective  investigations  increasingly  require 
structured  cooperation  between  multiple  jurisdictions.  Europol’s  systems  and  analytical 
capabilities play a central role in enabling such cooperation. 

Second,  the  evaluation  highlights  the  growing  importance  of  advanced  analytical 
capabilities and technological tools in criminal investigations. The increasing volume of 
digital evidence and the use of encrypted communications by criminal networks require 
specialised  expertise  and  technological  capabilities.  The  development  of  innovation-
related initiatives within Europol during the evaluation period reflects the need to adapt 
operational support to these technological developments. 

Third, the evaluation underlines the importance of consistent and systematic information 
sharing  between  Member  States.  Differences  in  data-sharing  practices  may  reduce  the 
completeness  of  operational  datasets  and  limit  the  effectiveness  of  analytical  support. 
Stakeholders emphasised that more systematic use of Europol systems and automated data 
exchange could further improve operational cooperation. 

Fourth,  the  evaluation  highlights  the  importance  of  coherence  across  the  EU  internal 
security framework. Effective cooperation between Europol and other EU actors depends 
on clear mandates, compatible data-protection frameworks and efficient mechanisms for 
information  exchange.  While  cooperation  between  agencies  is  generally  effective, 
stakeholders noted that differences in legal frameworks may sometimes affect operational 
coordination. 

Finally, from a REFIT perspective, the evaluation suggests that simplifying operational 
procedures and improving interoperability between information systems could reduce 
administrative  burden  and  increase  efficiency.  Stakeholders  identified  opportunities  to 
streamline  certain  operational  processes  and  strengthen  digital  tools  supporting 
information exchange and analytical cooperation. 

Overall,  the  evaluation  indicates  that  the  legal  framework  established  by  the  Europol 
Regulation  continues  to  provide  a  relevant  basis  for  supporting  Member  States  in 
addressing serious and organised crime and terrorism with a cross-border dimension. The 
lessons  identified  in  this  evaluation  may  inform  future  reflections  on  how  EU-level 
mechanisms for law-enforcement cooperation can continue to adapt to evolving security 
threats and operational needs. 

136 

 
 
 
 
 
Table 1: Evaluation Matrix 

Evaluation questions 

A 

Effectiveness: To what extent has Europol progressed positively towards achieving the objectives under its mandate? 

Sub-questions 

Judgment criteria 

Indicators 

Data collection tools and 
methods 

Based on data and in the views 
of ‘stakeholders’227 

1 

contributed 

To  what  extent  have  Europol's 
activities 
to 
achieving  the  objectives  under 
its  regulatory  framework 
to 
support and strengthen action 
by  the  competent  authorities 
of  the  Member  States  and 
their  mutual  cooperation  in 
preventing  and  combating 
serious  crime  affecting  two  or 
more  Member  States,  terrorism 
and forms of crime which affect 
a common interest covered by a 

serious 

contribution 

to 
Europol’s 
ending  ongoing  or  preventing 
cross-border 
and 
organised  crime  and  terrorism 
terms  of 
is  significant 
successful police interventions 
and operational results. 

in 

Europol  and  Member  States 
Law  Enforcement  Authorities 
(LEAs) 
is 
effective 

cooperation 

Qualitative: 

Alignment  of  Europol’s  operations 
and 
its  policy 
objectives and priorities. 

activities  with 

Opinion based: 

Stakeholders’  satisfaction  level  with 
Europol's activities and objectives. 

of 

research:  Data 
serious 

on 
Desk 
evolution 
and 
organised  crime  and  terrorism 
and  successful  operations  with 
the  support  of  Europol,  place 
into context crime areas in focus 
(Annex 1 Europol Reg). 

Interviews: 
Europol  MB, 
Member  States  Ministry  of 
Interior 
level); 
(political 
network  of  national  parliament 
representatives reviewing report 

227 Unless otherwise specified, the term stakeholders indicate all categories consulted as indicated in the last column. 

 
 
 
 
 
 
 
 
policy 

Union 
ensure 
security in the Area of Freedom, 
Security and Justice?  

and 

Resources allocated to Europol 
and  their  employment  by  the 
Agency meets the needs of MS 
and  allows  to  swiftly  address 
all  requests  for  support  by 
Member 
law 
enforcement authorities. 

States 

Stakeholders’  perception  of 
pertinence  of 
objectives and related priorities. 

the 
the  EU  policy 

from 
(Joint 
Europol 
Parliamentary  Scrutiny  Group 
(JPSG)). 

Member  States 
authorities’ 
satisfaction 
responsiveness of Europol. 

law  enforcement 
with 

Survey:  Member  States  law 
enforcement 
authorities, 
General  public,  COM  and  EU 
agencies and bodies 

is  satisfaction  with 

There 
Europol’s support 

Quantitative:  

Overview of statistics on criminality 
in  focus  (Eurostat,  UN  survey  of 
crime threads, JRC counter-terrorism 
knowledge  hub,  EU  database  of 
etc)  where 
terrorist 
information  of 
available  (limited 
cross-border 
from 
SIENA reports. 

crime),  data 

offenders 

Qualitative: 

Alignment  of  EU  operations  with 
policy objectives and priorities. 

Opinion based: 

2 

To what extent have Europol's 
activities supported relevant EU 
policy objectives and priorities 
related 
the  Area  of 
Freedom, Security and Justice 
(specifically TFEU Art 67 (3); 
Art  87,  88)?  (ER  Art.  4.1  (j), 
(l); (u); (z); 4.2; 4.3; 4.4) 

to 

of 

contributions 

Europol’s 
Evolution 
to 
strategic 
police 
cross-border 
for 
cooperation, 
judicial 
and 
combatting  serious  crime  and 
terrorism. 

support 
collaboration, 

138 

research: 

Desk 
Europol 
strategic reports on evolution of 
crime, 
policy 
development. 

input 

to 

Commission 
Interviews: 
representatives 
of  Europol 
Management  Board,  Member 

 
 
 
 
Stakeholders’ satisfaction levels with 
Europol's activities and objectives. 

Stakeholders’  perception  of  EU 
policy 
related 
priorities. 

objectives 

and 

Quantitative: 

and 

crime 

against 

Statistical data to measure operational 
in 
success 
supporting  security  –  using  EU-
SOCTA, 
iOCTA,  TE-SAT  data, 
EMPACT  reporting  and  specific 
early  warning  notifications,  SIENA 
data 

level), 

States,  Ministries  of  Interior 
(political 
JSPG, 
Commission services, including 
SG,  DG  HOME,  DG  JUST 
coordination unit, Police Chiefs, 
HENU. 

Survey:  Member  State 
law 
enforcement  authorities,  EU 
agencies  and  bodies;  General 
public (public consultation). 

Comparative analysis: with the 
operational records of other EU 
agencies,  Member  State  law 
enforcement  authorities  and 
INTERPOL. 

Measurement 
of 
improvements  in  the  speed, 
efficiency, and success rates of 
joint  operations,  intelligence 
coordination 
sharing, 
among  Member 
States 
(Article. 4.2). 

and 

Cooperation  between  Europol 
law 
and  Member  State 
is 
enforcement 
considered effective 

authorities 

concrete 
of 
Evidence 
outcomes, such as dismantling 
criminal  networks,  successful 
initiatives, 
counterterrorism 
security 
and 
measures. 

enhanced 

Europol 
successfully 
cooperation 
facilitated 
between  law  enforcement  and 
judicial 
across 
authorities 
Member States 

139 

 
 
 
 
Europol’s input into EU policy 
development through strategic 
analysis  a,  recommendation, 
and  dissemination  of  good 
practices to Member States and 
EU agencies. 

is  satisfaction  with 
the  EU 
in 

There 
Europol’s  role 
architecture. 

between 

Consistency 
the 
priorities and objectives across 
multi-annual 
the 
programming,  annual  work 
programmes,  and  Europol’s 
legal  mandate  and  obligations 
resulting from other legal acts. 

Alignment of the programmes’ 
the  overarching 
goals  with 
strategic  goals  of  the  Agency 
and  the  evolving  political  and 
legislative landscape. 

3 

To  what  extent  did  Europol’s 
priorities  and  objectives  set 
the  multi-
respectively  by 
annual  programming  and  the 
annual  work  programmes 
adopted 
Europol 
by 
(MB) 
Management  Board 
between 2017-2024 reflect over 
time  the  overall  priorities  and 
objectives of the Agency under 
its legal mandate? (Article. 3) 

Qualitative: 

initiatives  or 
Evidence  of  main 
projects  within  the  multi-annual  and 
annual  programmes  adopted  by  the 
MB to illustrate how they contribute 
to  the  Agency’s  objectives  under  its 
legal mandate. 

consistencies 

or 
Identified 
discrepancies  in  the  stated  priorities 
and objectives. 

Opinion based: 

Desk research: Review of grey 
literature  (notably,  Europol’s 
operational  documents  such  as 
SPDs  and  CAARs);  mapping 
priorities against Annex 1 listed 
crimes 

Interviews:  Member  States 
Ministries  of  Interior/political 
level, JSPG, COM strategic staff 
JHA policy, Europol MB 

Survey:  Member  State 
law 
enforcement  authorities,  EU 
agencies  and  bodies;  General 
public (public consultation) 

140 

 
 
 
 
 
 
Effectiveness  of 
the  multi-annual 
programming  and  the  annual  work 
programmes adopted by Europol MB 
in  meeting  the  Agency’s  objectives 
under its legal mandate. 

Quantitative: 

Review  of  performance  indicators 
and  data  and  progress  reports  to 
and 
measure 
achievements  over  the  evaluation 
period (2017-2024). 

progress 

the 

4 

To  what  extent  and  how  have 
external 
(COVID, 
factors 
development  of  AI  and  other 
security 
technology; 
developments)  influenced  the 
effectiveness of Europol? 

global 

External  factors  had  limited 
impact on Europol’s objectives 
and tasks. 

External  factors  had  limited 
impact on the effectiveness of 
Europol’s working methods. 

Qualitative: 

Identification  and  assessment  of 
external  factors  impacting  Europol’s 
operational effectiveness. 

Opinion-based: 

Perceptions  of  Europol  staff,  law 
enforcement  authorities,  EU  policy 
makers,  other  experts  on  impact  of 

research:  Academic 
Desk 
papers, 
literature, 
Europol’s  operational  support 
documents 

grey 

Interviews: 
JSPG,  Member 
States  Ministries  of  Interior 
(political  level),  COM  strategic 
policy 
staff,  Europol  MB, 
Academia  and  other  experts, 
NGOs 

141 

 
 
 
 
Survey:  Member  States  law 
enforcement  authorities,  EU 
agencies  and  bodies;  General 
public (public consultation) 

external  factors  (e.g.  on  Europol’s 
effectiveness. 

Perceptions about the development of 
technology for LEA purposes. 

Perceptions  about  developments  of 
use  of 
for  criminal 
purposes. 

technology 

Quantitative: 

of 

number 

Evolution 
of 
the 
stakeholders  with  which  Europol  is 
expected to cooperate and of its areas 
of activity. 

5 

of 

To  what  extent  does  Europol 
and 
effective 
make 
proportionate 
the 
use 
different  task  domains (6 core 
information 
areas: 
management, 
operational 
support,  strategic  analysis, 
specialised  expertise  (expert 
support 
private 
centres), 
sector  cooperation,  external 

domains 

Europol’s  makes  satisfactory 
and  proportionate  use  of  all 
task 
tools 
entrusted  to  it  to  achieve  its 
objectives and tasks as set out 
in its legal mandate. 

and 

Qualitative: 

Impact  of  development  of  tools  and 
task domains on crime and terrorism. 

Opinion-based: 

There is clear complementarity 
between 
the  use  made  by 
Europol  of  its  task  domains 

Europol  staff  views  on  the  use  of 
different powers and tools as set out 

142 

research:  Europol’s 
Desk 
documents, 
operational 
academic 
research,  National 
information  on  ENUs  and  their 
impact. 

Interviews: 
JSPG,  Member 
States  Ministries  of  Interior 
(political  level),  COM  strategic 

 
 
 
cooperation) - and tools (EIS, 
SIS,  EAS,  SIENA,  Big  data 
processing, 
system  with 
EPPO)  under  the  current  legal 
framework? 

and  tools  and  Member  State 
law  enforcement  authorities’ 
activities. 

in the legal mandate and likely impact 
on crime/ deterrent effect. 

policy  staff  JHA  area,  Europol 
MB. 

The  mere  fact  that  Europol 
disposes  of  certain  tasks  and 
tools  has  already  a  deterrent 
effect 
and 
terrorists regardless of its use.  

criminals 

for 

Public and academic experts – on use 
of Europol of its powers and tools and 
possible  impact  on  crime  /  deterrent 
effect. 

law 
Survey:  Member  State 
authorities, 
enforcement 
General 
(public 
public 
consultation),  EU  institutions, 
agencies and bodies. 

Quantitative: 

Statistical information on the use and 
costs of the various tools such as EIS, 
SIENA,  EAS,  big  data  processing, 
system with EPPO. 

B 

Efficiency: How well did Europol use resources relative to the changes achieved? 

Sub-questions 

Judgment criteria 

Indicators 

6 

What  are  the  overall  direct  and 
indirect  costs  and  benefits  of 
Europol’s  core  task  domains 
(six  core  areas:  information 
management, 
operational 
support,  strategic  analysis, 

The overall costs of Europol’s 
activities  are  proportionate  to 
their impact  and outweigh the 
benefits generated. 

Qualitative: 

Resource  allocation  is  proportionate 
to operations and support provided by 
Europol. 

Data collection tools and 
method 

Desk research: Review of grey 
literature 
operational 
and 
reports,  including  COM  review 
68(3)  ER, 
under  Article 
CAARs,  Europol  Survey  on 
number of staff. 

143 

 
 
 
 
 
 
specialised  expertise  (expert 
support 
private 
centres), 
sector  cooperation,  external 
cooperation)  and  how  have 
they  evolved  since  2017?  Are 
efficiency  gains  expected  or 
possible  in  the  short  or  long 
term? 

The  activities  of  Europol  do 
not  cause  significant  costs  for 
Member 
law 
enforcement authorities. 

State 

The  current  organization  and 
working  methods  are  highly 
efficient and there is no scope 
for savings or room to achieve 
the  same  results  in  a  more 
efficient way. 

The  activities  of  Europol 
balance) 
(on 
generate 
efficiencies  gains  for  Member 
State 
enforcement 
authorities. 

law 

Opinion-based: 

Europol  staff,  EU  policy  makers  on 
perceived levels of cost  and benefits 
of Europol’s activities. 

Perspective  of  strengths  and  gaps  or 
cost-intensiveness. 

Quantitative: 

Statistics  on  resources  by  year  and 
their  evolution  and  employment  by 
the Agency. 

Allocation  of  resources  per  core 
areas. 

Interviews: JSPG, Europol MB, 
Member  States  Ministries  of 
Interior (political level), ECA. 

Survey:  Member  State 
law 
enforcement authorities and EU 
agencies  and  bodies,  general 
public (public consultation). 

studies:  Review  of 
Case 
specific  operations  and  their 
costs  and  benefits,  collecting 
deep insights,  drawing on good 
practices. 

C 

Relevance: To what extent do the objectives of the Regulation continue to align with current needs within the EU and among stakeholders? 

Sub-questions 

Judgment criteria 

Indicators 

Data collection tools and 
method 

144 

 
 
 
 
 
 
  
  
 
7 

To  what  extent  do  Europol’s 
objectives  and  activities  (core 
task  domains)  under  its  legal 
framework  correspond  to  the 
evolving  needs  within  the  EU 
and 
affected 
stakeholders? 

among 

objectives 

Europol’s 
and 
activities are well aligned with 
Regulations and corresponding 
to  needs  of  affected  key 
stakeholders. 

Qualitative: 

Needs  of  Member  States 
law 
authorities,  Europol 
enforcement 
staff, EC, European Parliament, JHA 
agencies. 

activities 

and 
Europol’s 
objectives  are  well  aligned 
framework 
with 
legal 
setting 
and 
Member State needs. 

up  Europol 

the 

framework 

Regulatory 
is 
adapted  to  evolving  needs  of 
its 
the 
stakeholders. 

Agency 

and 

Coherence 
Europol’s objectives and 
with  Regulation 
amended by Regulation 2022/991. 

of 
activities 
as 

2016/794 

Trends of crime and development of 
criminal  activities,  broader  trends  of 
technology  development,  needs  in 
terms  of  data  sharing,  trends  for 
cooperation with third countries. 

Opinion-based: 

Desk research: Review of grey 
literature 
operational 
and 
reports, stakeholder reports  

Interviews: 
JSPG,  COM, 
Member  States  Ministries  of 
level), 
(political 
Interior 
strategic  policy  staff  JHA  area, 
Europol  MB, 
academia, 
networks. 

Survey:  Member  State 
law 
enforcement  authorities,  COM 
and 
and 
bodies staff, general public  

agencies 

EU 

on 

alignment 

Perspectives 
of 
Europol’s objectives and activities as 
stated  in  amended  Regulation  with 
affected 
evolving 
stakeholders 
Europol 
collaborators. 

needs 

and 

of 

145 

 
 
  
D 

8 

Views  on  needs  of  adaptation  of 
regulatory  framework  applicable  to 
Europol 

Quantitative: 

SOCTA reports 

Coherence: 
internal coherence - to what extent Europol various components or interventions achieve together the overall Europol objectives? 
External coherence - how well different interventions of Europol work with other EU policy interventions, other EU agency interventions or 
international ones - as well as national/ regional local level interventions? 

Sub-questions 

Judgment criteria 

Indicators 

To  what  extent  are  Europol's 
objectives  and  activities  (core 
task  domains)  under  its  legal 
framework  coherent  with  other 
relevant 
policy 
EU 
developments,  in  the  fields  of 
law  enforcement  cooperation 
including  with 
and  security, 
ProtectEU, 
European 
the 
Internal Security Strategy? 

objectives 

and 
Europol’s 
activities as set out under legal 
framework  are  coherent  and 
aligned to EU polices related to 
law  enforcement  cooperation 
and security. 
Europol's 
and 
activities  as  set  out  under  its 
legal 
created 
framework 
synergies  with  other  EU 

objectives 

Qualitative: 

Evidence  that  Europol's  objectives 
and  activities  worked  in  coherence 
with  other  EU 
law  enforcement 
cooperation and security policies. 

Evidence 
contradictions, synergies and gaps. 

indications 

or 

of 

Data collection tools and 
method 

Desk research: Review of grey 
literature 
operational 
and 
reports,  including  COM  review 
the 
under  Article  68(3)  of 
Europol Regulation. 
Interviews: 
JSPG,  COM, 
COSI, strategic policy staff JHA 
area,  Member  States  Ministries 
of 
level), 
Interior 
Europol MB. 

(political 

146 

 
 
 
Opinion-based: 

Stakeholders’  views  on  existence  of 
coherence, 
gaps, 
synergies, 
contradictions and overlaps. 

Survey:  Member  States  law 
enforcement authorities and EU 
agencies  and  bodies,  general 
publics (public consultation). 

Europol 

policies  in  the  field  of  law 
enforcement  cooperation  and 
security 
No  evidence  of  contradictions 
between 
legal 
framework  and  other  EU 
policies  on  law  enforcement 
cooperation and security. 
There  was  no  evidence  of 
overlaps  between  Europol's 
framework  and  EU 
legal 
policies  on  law  enforcement 
cooperation and security. 

E 

EU Added value 

Sub-questions  

Judgment criteria  

Indicators  

9 

Europol, 

Without 
how 
effectively could Member States 
conduct 
exchange 
and 
investigations  and  information 
at their current scale? 

carry 

Member States do not have the 
out 
to 
possibility 
investigations and information 
exchange 
in  a  comparable 
scale  and  manner  without  the 
support  of  Europol 
the 
current context. 

in 

Qualitative: 

Baseline 
exchanges. 

of 

current 

scale 

of 

specific 
Evidence  on  cases  or 
requests,  activities  where  Europol 

Data collection tools and 
method  

Desk research: Review of grey 
and operational 
literature 
reports  

JSPG, 

COM 
Interviews: 
strategic  policy  staff  JHA  area, 
Member  States  Ministries  of 

147 

 
 
 
  
Interior 
level), 
(political 
Europol  MB,  Europol  Police 
Chiefs. 

Survey:  Member  States  law 
enforcement authorities and EU 
agencies  and  bodies,  general 
public (public consultation). 

Case  studies:  specific  cases  of 
investigations 
cross-border 
conducted  with  and  without 
Europol’s 
involvement, 
understand  effectiveness  and 
challenges 
both 
faced 
scenarios. 

in 

Member  States  clearly  relied 
on  Europol's  activities  and 
knowledge. 

had  key  role  in  investigation  or 
sharing of knowledge. 

Evidence on existing Member States 
practices  on 
and 
exchanges of information. 

investigations 

Absence  of  indications  that  Member 
States could have achieved the same 
results without Europol’s expertise in 
investigations and knowledge. 

Opinion-based: 

Stakeholders’  perspectives  on  the 
ability of Member States to carry out 
the 
and 
exchanges of information, pointing to 
clear cases, instances. 

investigations 

same 

Quantitative: 

EIS  information,  use  of  EAS  and 
SIENA. 

148 

 
 
 
  
 
 
 
ANNEX 8: INVENTORY OF EXISTING INFORMATION SYSTEMS 
AND TOOLS AT EUROPOL 

This inventory provides an overview of Europol’s main information systems and tools to 
support Member States in preventing and combating serious international and organised 
crime, cybercrime and terrorism.  

It  is  aimed  at  facilitating  navigation  through  the  Agency’s  operational  environment  by 
presenting  core  systems,  information  exchange  tools,  operational  support  tools  and 
coordination mechanisms.  

1.  Core Operational Systems 

Store, process and analyse operational criminal data shared by Member States 

Europol Information System (EIS) 

Europol’s central criminal information system. It contains information related to suspected 
and convicted persons, criminal networks and structures, offences and criminal activities, 
objects used to commit crimes (e.g. vehicles, communication devices, financial accounts).  

Data can be inserted into the EIS manually through a specific Europol’s web application, 
or  automatically  through  a  data  loader  solution.  Newly  inserted  data  is  automatically 
compared with existing information in the system to identify potential matches. 

The EIS user community includes officials in the Member State Europol National Units 
(ENUs),  Member  State  liaison  officers  at  Europol,  as  well  as  Europol  officials  and 
seconded national experts (SNEs). 

Europol Analysis System (EAS) 

Operational  information  system  hosting  data  contributed  by  Member  States  and  Third 
Parties.  It  supports  Europol  analysts  in  their  operational  and  strategic  analysis  of  data 
provided by Europol’s stakeholders and enables information to be managed centrally. 

Analysis Projects (APs) 

Operational data processed in the EAS is organised in Analysis Projects. As intelligence 
platforms supporting criminal investigations related to specific crime areas, they enable 
Europol  and  Member  States  to  collect  and  analyse  operational  data,  identify  criminal 
networks  and  links  between  investigations,  support  international  investigations  through 
analytical products.  

They  focus  on  certain  crime  areas  from  commodity-based,  thematic  or  regional  angles 
(e.g., drugs trafficking, Islamist terrorism, Italian organised crime). 

2.  Information Access and Exchange Tools 

Exchange operational information and securely access Europol data systems 

Secure Information Exchange Network Application (SIENA) 

 
 
The Agency’s main platform for the secure exchange of operational and strategic crime-
related information. It enables communication between Europol, EU Member States, EU 
agencies, Third Parties and international partners with cooperation agreements.  

The  application  allows  the  exchange  of  information  on  three  classification  levels:  EU 
Confidential (EU-C), EU Restricted (EU-R), and Basic Protection Level (BPL). 

SIENA  can  be  used  by  liaison  officers,  Europol  officials,  ENU  personnel  and  other 
designated law enforcement authorities. Third Parties with whom Europol has cooperation 
agreements are also connected to SIENA. 

Querying Europol Systems (QUEST) 

Web service integrated in national system interface(s) of Europol Member States. It allows 
law enforcement authorities to query Europol data directly from their national interfaces. 

It enables searches in the EIS and APs and allows queries concerning persons, firearms, 
identity documents, means of communication, means of transportation, financial accounts 
and means of payment. 

Large File Exchange 

System  allowing  the  secure  exchange  of  large  volumes  of  data  that  exceed  the  size 
limitation  of  file  attachment  in  SIENA.  It  is  used  to  exchange  large  datasets  related  to 
criminal investigations, such as digital evidence or extensive operational datasets. 

It can also be used for bilateral exchanges of large data volumes. 

3.  Operational Coordination Mechanisms 

Support  the  coordination  of  international  investigations  and  operational  responses 
involving multiple Member States. 

24/7 Operational Centre 

By ensuring continuous operational support for Member States and Europol partners, it 
monitors operational and non-operational information exchange through SIENA, provides 
first-level response on a 24/7 basis to law enforcement authorities’ requests and supports 
urgent cross-border investigations. 

Joint Cybercrime Action Taskforce (J-CAT) 

24/7 permanent taskforce operating from Europol headquarters together with the European 
Cybercrime Centre (EC3). It coordinates intelligence-led coordinated actions against key 
cybercrime threats and targets. It also facilitates between law enforcement agencies from 
different countries. 

Governed by a Board composed of at least one senior law enforcement representative per 
participating agency. 

150 

 
 
Operational Task Force (OTF) 

Established by EU Member States and operational partners to target a High Value Target 
involved in serious and organised crime or terrorism, it temporarily brings investigators 
and analysts from the relevant countries to enhance coordination, intelligence sharing and 
operational  cooperation  during  cross-border  cooperation.  Europol  offers  analytical  and 
operational support. 

151 

 
 
 
 
 
ANNEX 9: DNA MATCHING SERVICE 

DNA is currently the most widely used biometric modality in the European Union for the 
identification of individuals and the resolution of criminal investigations. 

Within  the  EU,  DNA  profiles  are  always  generated  by  accredited  national  forensic 
laboratories.  These  certified  laboratories  analyse  DNA  samples,  either  collected  from  a 
known individual (typically through a buccal swab) or recovered as biological traces from 
a crime scene. The analysis involves a series of complex biological, chemical and physical 
processes  that  ultimately  produce  a  standardised  DNA  profile  suitable  for  forensic 
comparison. 

Once generated, each DNA profile is stored in a national DNA database, where it can be 
compared against other  profiles to  identify potential  matches. Such matches may occur 
between a crime scene trace and the profile of a known individual, or between crime scene 
traces originating from different investigations, thereby helping to establish links between 
criminal cases. 

Currently, 23 out of the 27 EU Member States use the  Combined DNA Index System 
(CODIS)  as  the  software  application  for  managing  national  DNA  databases  and 
performing DNA profile comparisons. CODIS is owned, developed and maintained by the 
Federal Bureau of Investigation (FBI) of the United States. Under the existing Prüm 
framework, national CODIS systems are interconnected, enabling automated cross-border 
DNA comparisons between Member States. 

While the process of DNA matching itself is computationally straightforward compared to 
other biometric modalities, it is governed by a set of highly specific and rigorous biological 
rules that must be applied consistently. Unlike facial recognition or fingerprint matching 
systems, DNA profile matching does not rely on artificial intelligence or machine learning 
techniques,  but  instead  on  deterministic  comparison  algorithms  based  on  established 
forensic standards. 

The Prüm II Regulation228 and its implementing act229 introduce important changes to 
the  DNA  profile  comparison  framework.  In  particular,  DNA  profile  exchanges  will  be 

228 Regulation (EU) 2024/982 
229  [Note  to  publication  colleagues,  link  to  be  updated  in  June  when  the  IA  is  published  with  the  right 
reference] 

152 

CODISDNAMatcherCODISDNAMatcherFBIbuiltForensicLabForensicLabCurrent PrümI situationFBIbuiltPrümIBilateral connections 
 
 
 
routed  through  a  centralised  technical  router  operated  by  eu-LISA,  and  updated 
matching  rules  will  apply.  Implementing  these  changes  requires  modifications  to  the 
CODIS  software  currently  used  by  Member  States.  As  CODIS  is  proprietary  software 
owned and maintained by the FBI, such changes can only be carried out  by the United 
States authorities. 

This situation creates a structural technological dependency of the EU on a third country 
for  a  core  component  of  its  law  enforcement  infrastructure.  In  the  current  geopolitical 
context, reducing such dependencies has become an increasingly important objective for 
the Union, particularly in sensitive areas related to internal security and law enforcement 
cooperation. 

To address this dependency, the EU could develop, deploy and maintain its own European 
DNA  matching  service  capable  of  performing  the  same  core  functionalities  currently 
provided  by  CODIS.  Such  an  EU-developed  application  would  implement  equivalent 
DNA profile comparison rules and database management capabilities, while being fully 
aligned with EU legal and operational requirements. Member States would progressively 
migrate  their  existing  DNA  profiles  from  CODIS  to  the  new  EU  system,  after  which 
CODIS would no longer be required for national DNA profile database management or 
cross-border comparisons. 

Developing  an  EU-controlled  DNA  matching  service  would  enhance  the  Union’s 
technological  sovereignty  in  a  critical  area  of  forensic  cooperation,  while  ensuring  full 
operational continuity for national authorities and supporting the long-term sustainability 
of the Prüm II framework. 

153 

ForensicLabForensicLabEUDNAMatcherEUDNAMatcherEUbuiltEUbuiltPrümIIRouterFuture foreseen PrümII situation 
 
 
 
 
 
 
ANNEX 10: IMPACTS OF POLICY OPTIONS 

The information presented in this annex aims to enhance transparency and provide further 
evidence  underpinning  the  conclusions  of  the  impact  assessment.  The  annex  should 
therefore  be  read  in  conjunction  with  the  main  impact  assessment,  as  it  provides  the 
technical background and detailed results that support the overall evaluation of the policy 
options. 

Environmental impact: None, as the options do not involve environmental aspects. 

Economic impact: Limited to EU and Member State investment in Europol human and 
technical resources; no direct effects on private operators or SMEs are expected. 

As certain options involve the exchange of personal data, particular attention is given to 
fundamental rights, in line with the EU Charter. Any interference must be necessary and 
proportionate (Articles 51–52), balancing security objectives with protection of personal 
data  (Articles  7–8)  and  privacy.  The  options  aim  to  improve  law  enforcement 
effectiveness,  supporting  public  security  and  preventing  serious  crimes  such  as  human 
trafficking (Articles 2 and 5 of the Charter). 

Data  protection  is  safeguarded  by  the  Europol  Regulation,  the  Law  Enforcement 
Directive,  and  the  EU  Data  Protection  Regulation,  ensuring  legality,  necessity,  and 
proportionality  of processing.  Limitations on rights  are targeted, strictly  within existing 
law  enforcement  mandates.  Each  option  pursues  the  general  interest  of  EU  internal 
security, and the assessment focuses on necessity and proportionality.  

The  impacts  are  assessed  on  a  scale  ranging  from  ‘very  positive  impact’  (++)  to  ‘very 
negative  impact’  (--),  with  intermediate  scores:  ‘positive  impact’  (+),  ‘neutral’  (0)  and 
‘negative impact’ (-).Reinforcing Europol’s existing model 

1.1 Sub policy option 1.1: Strengthened data availability, processing and service 

a.  Impact on citizens (+) 

This  option  protects  EU  citizens  by  enabling  Europol  to  cross-check  and  analyse 
lawfully  available  data,  allowing  earlier  detection  of  criminal  networks,  faster 
Member  State  coordination,  and  more  targeted  law  enforcement,  while  focusing  on 
priority crimes and preserving Member State control and fundamental rights. 

b.  Impact on national authorities (++) 

This  policy  option  has  a  very  positive  impact  on  national  authorities  by  addressing 
operational, technical and resource constraints and improving the returns of cooperation 
with Europol. Member States gain: 

•  Automated data-loaders, reducing manual uploads and delays; 
•  Systematic cross-checks by Europol, enhancing intelligence quality; 

154 

 
 
•  Upgraded systems (SIENA, EIS, EAS, QUEST/QUEST+), enabling faster and 

more actionable analysis; 

•  Dedicated technical support, including specialised teams for integration and 

optimisation; 

•  Joint procurement, reducing costs and promoting interoperability. 

Overall,  the  option  improves  the  cost–benefit  of  sharing  data,  encourages  systematic 
engagement, and strengthens mutual trust and EU-level law enforcement effectiveness. 

c.  Impact on fundamental rights 

i.  Objective of general interest (+) 

This option supports the prevention, detection, and investigation of serious crime and 
terrorism by improving the efficiency, quality, and timeliness of information exchange. 
Automated  data-loading  and  proportionate  cross-checks  by  Europol  enhance 
intelligence accuracy and reduce delays and duplication. Upgraded systems (SIENA, EIS, 
EAS,  QUEST/QUEST+)  provide  faster  queries,  stronger  analytics,  and  traceable 
processing, while technical support and joint procurement promote interoperability, data 
quality, and compliance. Overall, it fosters a systematic, accountable, and transparent 
use of shared information. 

ii.  Impact on data protection (0) 

Overall, the policy option has a neutral to slightly positive impact on data protection. 

Necessity 

The measures tackle inefficiencies in current cooperation, such as fragmented and manual 
data-sharing. Automated data-loaders ensure that lawfully shareable data are complete, 
accurate, and consistently used. System upgrades and technical support make existing 
tools  function  effectively  and  comply  with  EU  data  protection  standards,  without 
changing retention, access rights, or processing purposes. We therefore conclude that the 
policy option respects the principle of necessity. 

Proportionality 

The option preserves full Member State control over shared data, with purpose limits. 
System upgrades improve architecture, reliability, and safeguards without changing the 
legal balance. Overall, measures focus on enhancing lawful processing while respecting 
existing safeguards and oversight. We therefore conclude that the policy option respects 
the principle of proportionality. 

d.  Costs (0) 

Direct costs 

Member 
States 

Europol 

155 

 
 
 
 
 
 
 
Expected one-off costs (in million EUR) 

81 (3 per MS) 

61 

1)  Data loaders 

2)  Upgrade of systems and tools 

Expected yearly recurring costs (in million EUR per 
annum) 

1)  Data loaders 

2)  Upgrade of systems and tools  

1)  54 

2)  27 

1)  5 

2)  56 

16.2 

12.2 

1)  10.8 

1)  1 

2)  5.4 

2)  11.2 

This option entails upfront investment at both Member State and Europol level, primarily 
driven  by  data  loaders  as  well  as  system  and  tools  (including  enhance  use  of 
interoperability tools). The financial effort reflects a structural modernisation of the EU 
law  enforcement  information  architecture,  with  medium  to  long-term  savings  and 
operational gains. For more details on the costs of this policy option see Annex 3. 

e.  Feasibility (+) 

Technical  feasibility 
is  high.  The  main  components,  automated  data-loaders, 
interoperability  tools  and  Europol  systems  (SIENA,  EIS,  EAS,  QUEST/QUEST+),  are 
already operational. The option focuses on scaling and upgrading existing capabilities, 
not creating new infrastructures. Europol’s in-house expertise and eu-LISA’s experience 
with  large-scale  EU  systems  further  reduce  implementation  risks  and  support  secure, 
infrastructure, 
coherent  deployment.  Where  relevant,  synergies  with  eu-LISA’s 
interoperability architecture and technical standards can support secure implementation, 
ensure consistency across EU information systems and reduce duplication of effort. This 
institutional ecosystem significantly mitigates implementation risks. 

Political feasibility is positive. The option preserves Member State control and does not 
expand  Europol’s  mandate  or  introduce  indiscriminate  data  transfers.  By  delivering 
tangible  operational  benefits  –  stronger  analytical  support  and  reduced  administrative 
burden – it aligns EU-level improvements with national interests. 

Overall, the measure is feasible from a technical, operational and political perspective. 

f.  Impact on digitalisation (++) 

This option has a very positive impact because it advances the digital transformation of 
EU  law  enforcement  by  introducing  automated  data-loaders,  enabling  faster,  more 
reliable, and systematic information exchange. It automates existing processes, reduces 
administrative  burden,  and  supports  near  real-time  cross-border  flow.  Standardised 
data models and guidance foster interoperability across Member States, while timely, 
structured  data  feeding  enhances  analytical  capabilities  and  real-time  intelligence 
services.  The  infrastructure  also  lays  the  foundation  for  future  digital  initiatives, 
embedding the ‘digital by default’ principle without creating new legal obligations. 

156 

 
 
 
1.2 Policy  option  1.2:  enhanced  mitigating  measures  to  address  the  obstacles  of  data 

subject categorisation 

a.  Impact on citizens (0) 

This policy option has a neutral impact on citizens (0). It does not constitute any significant 
changes,  as  the  obligation  to  carry  out  the  categorisation  of  data  subjects  remains 
unchanged. Instead, the measures of this option aim at improving the situation for national 
authorities by facilitating the overall process. 

b.  Impact on national authorities (+) 

The  option  has  a  positive  impact  on  national  authorities  as  it  would  result  in  more 
streamlined processing of complex and large datasets. Due to the detailed internal guidance 
and tools (checklists, templates, standard scenarios) that would be developed as part of this 
option, there would be reduced operational delays and fewer inconsistencies, resulting in 
the overall positive impact on national  authorities. Greater legal certainty and clarity in 
applying DSC rules would also reduce the risk of errors and subsequent corrective actions. 

c.  Impact on fundamental rights (0) 

i.  Objective of general interest (+) 

This  option  makes  a  positive  contribution  to  an  objective  of  general  interest  (+),  as  it 
constitutes a measure to facilitate the overall fight  against serious and organised crime. 
Improving and harmonising the practical application of the rules governing data subject 
categorisation and the subsequent improvement would lead to more consistent and reliable 
data processing, facilitating the work of both national authorities and Europol, resulting in 
faster operational results and investigations. 

ii.  Impact on data protection (0) 

Necessity 

The flaws and obstacles of the current DSC framework have been highlighted both by the 
national authorities of the Member States as well as by the Commission, as underlined by 
the report pursuant to article 68(3) of the ER230, resulting in the necessity for a change to 
such rules and the operational capabilities.  

By utilising current tools and methodologies to reduce errors and inconsistencies in data 
categorisation, the overall level of data protection is maintained and strengthened through 
improved  compliance  and  consistency.  We  therefore  conclude  that  the  policy  option 
respects the principle of necessity. 

230 COM(2025) 752 final, 11.12.2025. 

157 

 
 
 
Proportionality  

The policy option of addressing the obstacles of DSC by introducing mitigation measures 
is fully proportionate as it would aim to harmonise and streamline currently existing rules 
rather  than  introduce  new  ones.  Standardising  the  process  of  DSC  while increasing  the 
legal  certainty and simultaneously making it more efficient and less resource-intensive, 
demonstrates the proportionality of this option. No new categories of data, new processing 
purposes or expanded access rights are introduced. We therefore conclude that the policy 
option respects the principle of proportionality. 

d.  Cost (+) 

The overall cost of this option is difficult to estimate. The option will require small initial 
investments related to the development of internal guidance, tools and training materials. 
In the long-term, however, the initial cost of labour needs would be offset by the overall 
benefit of clarifying and improving the framework on DSC, reducing inefficiencies and 
corrective workload. 

e.  Feasibility (++) 

This policy option has very positive feasibility as it would be easily put into place. The 
technical feasibility would not require developing an entirely new framework for DSC but 
rather improving and further developing a set of rules already in place. 

The  political  feasibility  would  be  equally  as  positive  (++)  as  national  authorities  have 
underlined the need for  further  clarifications  and guidelines, as well as the necessity  to 
reform the overall process of DSC. This policy option should therefore face little to no 
political opposition. 

f.  Impact on digitalisation (0) 

The option has an overall neutral impact on digitalisation. While it relies on existing digital 
infrastructures, it does not fundamentally transform the digital architecture of the process 
of  data  subject  categorisation.  Subsequently  putting  in  place  mitigating  measures  to 
address the obstacles of DSC serves as an enabler for Europol to process and analyse data 
rather than being a driver of structural change. Meaning that Europol’s overall usage of 
data would be (further) consolidated, which has no impact on digitalisation as such. 

1.3 Policy option 1.3 - Measure 1 on reinforced Europol’s support to the EPPO 

EPPO  Support  Unit:  a  reinforced,  dedicated  unit  within  Europol’s  Financial  and 
Economic Crime Centre (EFECC), composed of specialised staff assigned exclusively to 
EPPO-related cases, replacing and reinforcing the current small team handling these. The 
organisation of the unit would not change compared to what is currently in place with the 
current small team except in terms of staff, which would however grow significantly. The 
unit’s staff will need to be specialised in VAT fraud, customs fraud, excise fraud, and 
trade-based  money  laundering,  and  should  have  familiarity  with  the  complex  multi-
criminal behaviours of modern organised crime groups (MTIC schemes). Four different 

158 

 
 
types of support tasks would be handled by the unit: cross-checks of EPPO data against 
Europol database (hit/no-hit), digital forensics (in particular making information in seized 
devices  available  for  operation  analysis),  operational  analysis  (making  sense  of  data 
gathered  in  EPPO  cases),  and  operational  support  (e.g.  assets  tracing,  preparatory 
activities for action days, manning virtual command posts). The Europol-EPPO Working 
Arrangement would be updated accordingly. 

a.  Impact on citizens (+) 

This measure would reinforce the protection of EU citizens against the crimes for which 
the EPPO is  competent and the criminal  actors involved. Therefore, this measure has  a 
positive impact on citizens. 

b.  Impact on national authorities (+) 

Europol’s reinforced support to the EPPO will help further extract criminal proceeds from 
criminal  actors. Therefore, this measure has  a  positive impact on national  authorities 
(+). 

c.  Impact on fundamental rights (+) 

This  measure  would  have  a  positive  impact  on  fundamental  rights  insofar  as  it  would 
ultimately  help  strengthen  the  EU  Member  States’  statehood  against  criminal  threats, 
prompting  Member  States’  concrete  ability  to  respect,  promote  and  fulfil  human  rights 
under international and EU law. 

i.  Objective of general interest (+) 

This  measure  makes  a  positive  contribution  to  an  objective  of  general  interest  (+), 
namely  the  protection  of  the  financial  interests  of  the  EU,  by  allowing  the  EPPO  to 
effectively carry out its mission vis-a-vis sharply increasing need for support from Europol. 

ii.  Data protection (0) 

Necessity and proportionality 

The current Europol staff allocated to support the EPPO (8-9 officers) is not sufficient. 
This measure is necessary to meet the minimum level of the EPPO’s sharply increasingly 
needs and thus allow it to effectively protect the financial interests of the EU. It does not 
interfere with current data protection levels. Therefore, this policy measure respects the 
principles of necessity and proportionality. 

d.  Costs (+) 

Direct costs 

Member States activities 

EU activities 

159 

 
 
 
 
 
 
Expected one-off costs (in 
million EUR) 

Expected  yearly  recurring 
costs (in million EUR) 

0 

0 

0 

10 

One-off costs for Member States are negligible, as  the measure focuses  on establishing 
new Europol-level capacities, without requiring structural changes, staff contributions, or 
procedural adaptations at national level. Recurrent costs arise mainly at Europol, reflecting 
the long-term employment of specialised officers in the dedicated EPPO Support Team, 
responsible for operational analysis, cross-checks, and digital forensics, with an average 
annual cost of approximately EUR 10 million. 

e.  Feasibility (+) 

Technical feasibility 

The measure is legally feasible. Establishing the EPPO Support Unit at Europol would not 
alter  the  respective  mandates  or  the  fundamental  nature  of  the  relationship  between 
Europol and the EPPO. It would not require amending the Europol Regulation. Amending 
the  Europol-EPPO  Working  Arrangement  would  suffice.  From  an  organisational 
perspective, the measure would build on existing organisational and technological set-ups 
(e.g.  EFECC,  JIT  model,  case-handling  processes),  but  would  require  enhanced 
operational  capacity  in  terms  of  staff  (e.g.  capability  to  support  investigations  and  run 
analytical tasks, expertise in defined areas [VAT fraud, customs fraud, MTIC]). For this 
reason, the option is technically feasible (++). 

Political feasibility 

The  consultation  activities  have  revealed  that  both  Europol  and  the  EPPO  would  fully 
support this measure,231 while Member States would widely support it232. However, several 
Member  States  have  also  emphasised  their  preference  that  Europol’s  support  remain 
essentially focused on the operational needs of the Member States233. Overall, the measure 
is politically feasible (+). 

f.  Impact on digitalisation (0) 

This measure would have no to positive impacts on digitalisation depending on whether 
implementation maintains the current level or increases the digital delivery of services. 

231 Interview, focus groups, targeted survey with agencies. 
232 The responses to the targeted survey for the EU Member States’ national law enforcement authorities 
show support for the update of the working arrangement 
233 As discussed in the COSI meeting of February 2026. 

160 

 
 
 
1.4 Policy  option  1.3  -  Measures  2  and  3  for  a  strengthened  continuum  of  EU-level 
support to law enforcement cooperation through Europol and judicial cooperation 
through Eurojust  

a.  Impact on citizens (+) 

These measures would overall reinforce the protection of EU citizens against organised 
crime, albeit moderately. 

b.  Impact on national authorities (+) 

These  measures  would  overall  reinforce  the  information  at  disposal  of  Europol  and 
Eurojust and thus the support they can provide to national authorities, albeit moderately. 
The  national  authorities  of  EU  Member  States  would  be  able  to  continue  relying  on 
SIRIUS’ knowledge and expertise to successfully obtain critical electronic evidence for 
criminal investigations and prosecutions, namely in a permanent manner.  

c.  Impact on fundamental rights (+) 

These measures would have a positive impact on fundamental rights insofar as it would 
ultimately  help  strengthen  the  EU  Member  States’  statehood  against  criminal  threats, 
prompting  Member  States’  concrete  ability  to  respect,  promote  and  fulfil  human  rights 
under international and EU law. 

i.  Objective of general interest (+) 

These measures make a positive contribution to an objective of general interest (+), namely 
the  EU-level  fight  against  organised  crime  and  cybercrime,  by  strengthening  the 
continuum of EU-level support through Europol and judicial cooperation through Eurojust. 

ii.  Data protection (0) 

Necessity and proportionality 

These measures are necessary to strengthen the continuum of EU-level support through 
Europol  and  judicial  cooperation  through  Eurojust.  Upgrading  the  existing  hit/no-hit 
mechanism  through  the  introduction  of  automated  processes  is  necessary  to  improve 
indirect 
Introducing 
Institutionalising  the  mission  of  the  SIRIUS  project  within  the  Europol  Regulation  is 
necessary to ensure the long-term financial sustainability and permanent support for the 
national authorities of the EU Member States according to their needs. Therefore, these 
measures respect the principles of necessity and proportionality. 

exchange  between  Europol 

and  Eurojust. 

information 

d.  Costs (+) 

Direct costs 

Member States activities 

EU activities 

161 

 
 
 
 
 
Expected one-off costs (in 
million EUR) 

Expected  yearly  recurring 
costs (in million EUR) 

0 

0 

2 

1 

One-off  and  recurring  costs  for  Member  States  are  expected  to  be  negligible,  as  the 
measures  focus  on  Europol–Eurojust  cooperation  and  build  on  existing  infrastructure, 
workflows, and personnel. Costs at EU level reflect Europol and Eurojust staffing for the 
SIRIUS  project  and 
the  hit/no-hit  mechanism,  with  modest  adjustments  for 
institutionalisation and light automation, generating efficiency gains by reducing manual 
exchanges and improving operational timeliness. 

e.  Feasibility (+) 

Technical feasibility 

From a legal perspective, the institutionalisation of SIRIUS would require amending the 
Europol  and  Eurojust  Regulations  regarding  their  tasks.  Article  4  of  the  Europol 
Regulation  already  provides  a  broad  mandate  for  Europol  to  support  Member  States 
through expertise, training, operational coordination and facilitation of cooperation with 
private  parties.  A  legislative  clarification  explicitly  mandating  Europol  to  provide 
structured support on cross-border access to electronic evidence, including cooperation 
with Eurojust, service providers and third countries, would provide legal certainty, stable 
governance and budgetary predictability. For the hit/no-hit automation component, both 
Regulations  foresee  indirect  access  to  information  on  a  hit/no-hit  basis.  The  current 
limitations  are  related  to  implementation  modalities.  From  a  technical  perspective, 
feasibility remains strong. 

Political feasibility 

From  a  political  perspective,  feasibility  is  high.  The  SIRIUS  EU  Electronic  Evidence 
Situation Report 2024 confirms sustained and growing operational demand for EU-level 
support  in  accessing  electronic  evidence.234  In  2023  alone,  competent  authorities 
submitted  266,855  cross-border  data  disclosure  requests  to  major  online  service 
providers, representing a 22% increase compared to 2022, demonstrating the scale and 
structural  nature  of  demand.235  Feedback  collected  in  the  2024  report  from  law 
enforcement, judicial authorities and service providers highlights the value of centralised 
expertise,  Single  Points  of  Contact  (SPoCs)  and  structured  dialogue  with  private 
companies.236  Service  providers  also  emphasised  the  importance  of  predictable 
engagement and harmonised practices, indicating that institutionalisation would enhance 

234 Europol (2025) SIRIUS Electronic Evidence Situation Report 2024. 
235 Europol (2025) SIRIUS EU Electronic Evidence Situation Report 2024 – Factsheets (Law Enforcement, 
Judicial Authorities, Service Providers). 
236 ibid. 

162 

 
 
 
 
 
legal certainty rather than create new burdens.237 These stakeholder views demonstrate 
broad operational acceptance and support across law enforcement, judiciary and private 
sector  actors,  reinforcing  the  political  feasibility  of  embedding  SIRIUS  permanently 
within the Europol and Eurojust mandates.  

f.  Impact on digitalisation (0) 

This measure would have no to positive impacts on digitalisation depending on whether 
implementation maintains the current level or increases the digital delivery of services. 

1.5 Policy option 1.4: Europol digital platforms embedded in national investigations 

a.  Impact on citizens (++) 

This option has a very positive impact on citizens by reducing the risk of undetected 
cross-border  criminal  links.  Integrating  national  CMS  with  Europol  platforms  and 
requiring targeted consultation in serious cases embeds checks into everyday workflows, 
enabling  earlier  detection,  reducing  blind  spots,  and  improving  Member  State 
coordination, thereby enhancing overall citizen security. 

b.  Impact on national authorities (+) 

This  option  benefits  national  authorities  by  embedding  Europol  support  directly  into 
CMS  workflows,  allowing  investigators  to  consult  platforms  and  receive  analytical 
feedback within their national environment. Targeted consultation in serious cross-border 
cases  ensures  EU-level  information  is  systematically  used,  preventing  missed  links  and 
supporting  early  de-confliction.  National  authorities  retain  full  control  while  gaining 
enhanced situational awareness and more consistent analytical support. 

c.  Impact on fundamental rights  

i.  Objective of general interest (++) 

This option makes a strong positive contribution to an objective of general interest, i.e. 
the prevention and combating of serious crime and terrorism, by embedding Europol 
platforms  into  national  workflows  and  requiring  targeted  consultation  in  cross-border 
cases,  ensuring  EU-level  information  is  systematically  used,  reducing  fragmentation, 
closing information gaps, and strengthening early detection of criminal networks. 

ii.  Data protection (0) 

Necessity 

The  integration  of  national  CMS  with  Europol  systems  improves  workflows  and 
interfaces without creating new data categories, access rights, or processing purposes. A 
targeted obligation to systematically consult EIS in serious cross-border cases addresses 

237 Europol (2025) SIRIUS EU Electronic Evidence Situation Report 2024 – Factsheets (Law Enforcement, 
Judicial Authorities, Service Providers). 

163 

 
 
 
 
operational  gaps,  ensuring  lawfully  available  information  is  effectively  used.  By 
embedding consultation as a structured, proportionate step, the measure reduces blind 
spots, prevents information gaps, and ensures existing data-sharing mechanisms function 
as  intended.  We  therefore  conclude  that  the  policy  option  respects  the  principle  of 
necessity. 

Proportionality 

This  option  does  not  create  new  data  categories,  databases,  or  purposes;  it  structures 
existing lawful access to Europol systems, notably EIS, within national CMS. A targeted 
obligation to consult EIS in serious cross-border cases ensures that lawfully available data 
is consistently and effectively used, without expanding Europol’s mandate. Embedded 
consultation reduces missed links and fragmentation while preserving national control, 
purpose  limitation,  and  data  ownership,  ensuring  interference  with  data  protection 
rights is proportionate. 

We therefore conclude that the policy option respects the principle of proportionality. 

d.  Costs (0) 

Direct costs 

Member 
States 

Europol 

Expected one-off costs (in million EUR) 

105 

Expected yearly recurring costs (in million EUR per 
annum) 

20 

50 

8 

One-off  costs  for  Member  States  (EUR  105  million)  cover  new  criminal  information 
strategies,  updates  to  case  management  systems,  integration  with  UMF  standards,  and 
training,  with  recurring  costs  (EUR  20  million/year)  for  ongoing  maintenance.  Europol 
one-off costs (EUR 50 million) include upgrades to data ingestion, scaling of databases, 
and support to Member States, with recurring costs (EUR 8 million/year) for continued 
operational and integration support. 

Technical feasibility 

Integrating national CMS with Europol systems requires secure APIs, harmonised data 
models,  workflow  adjustments,  and  increased  capacity,  but  builds  on  existing  SIENA 
connectivity  rather  than  creating  a  new  digital  ecosystem.  Implementation  will  need 
substantial  EU  and  national  resources,  including  development,  testing,  training,  and 
change management, with Europol providing central support through toolkits, reference 
architectures, and on-site assistance. Systematic consultation is technically feasible only if 
Europol  systems  are  robust,  scalable,  and  able  to  handle  increased  queries  while 
delivering timely responses. 

164 

 
 
 
 
 
 
 
 
 
For this reason, the option is  technically feasible (+) only in conjunction with Policy 
Option  1.1,  which  upgrades  Europol’s  ICT  infrastructure,  performance  and  service 
delivery. Without Option 1.1, embedding systematic consultation into national workflows 
would  risk  system  overload,  latency  and  reduced  reliability,  making  overall  feasibility 
negative (–). 

Political feasibility 

Political feasibility is ambitious, as embedding Europol systems into national CMS and 
introducing  systematic  consultation  represents  a  major  shift  for  Member  States.  While 
benefits  are  clear,  faster  detection,  improved  situational  awareness,  and  better 
analytical support, authorities may resist changing established workflows. Feasibility is 
higher with phased implementation, pilot projects, peer exchanges, and strong Europol 
support to build trust. Rapid, large-scale deployment without engagement and resources 
is unlikely to succeed. Overall, the option is  politically feasible but facing significant 
obstacles (-). 

e.  Impact on digitalisation (+) 

This option advances the digitalisation of EU law enforcement by integrating national 
CMS  with  Europol  systems  and  enabling  systematic  consultation  of  EIS/EAS.  It 
replaces  manual,  ad  hoc  processes  with  automated  workflow  checks,  standardises 
information  exchange,  and  delivers  timely,  actionable  analytical  outputs,  improving 
usability, automation, and effectiveness of existing systems while reinforcing the ‘digital 
by default’ principle’. 

1.  Designing a new model for Europol  

2.1 Policy option 2.1: Europol as an operational service provider and information hub 

a.  Impact on citizens (+) 

Overall, this policy option has a positive impact on citizens (+), by enhancing the EU’s 
capacity to prevent and combat serious crime while preserving  Member State control. 
Europol,  when  authorised,  could  query  national  databases  under  Prüm  II  (DNA, 
fingerprints, facial images), police indexes, and vehicle records, acting strictly on behalf 
of Member States. In time-critical or large-scale cases, Europol’s technical and forensic 
support enables faster cross-border link detection. An EU DNA matching service would 
strengthen forensic cooperation, reduce reliance on third-country tools, and improve the 
speed and reliability of cross-border investigations. 

b.  Impact on national authorities (++) 

This  option  strongly  benefits  national  authorities,  especially  investigators  handling 
complex  or  cross-border  cases,  by  allowing  Europol,  strictly  on  behalf  of  and  with 
explicit authorization, to query national databases under Prüm II. Authorities gain faster 
handling of biometric and non-biometric queries, technical and forensic support in 
high-volume cases,  and  improved  analytical  coherence  across jurisdictions. Real-time 
alerts and subscription-based notifications reduce fragmentation and ensure that relevant 

165 

 
 
 
developments  are  not  missed,  without  creating  automatic  data  transfers.  Political 
acceptability relies on strict safeguards, authorisation, and clear governance. 

The  optional  EU  DNA  matching  service  would  provide  shared  forensic  capabilities, 
reduce  dependency  on  third-country  tools  and  align  with  Prüm  II  standards.  Member 
States  would  benefit  from  faster  adaptation  to  evolving  requirements,  operational 
continuity,  and  support  for  smaller  forensic  authorities,  while  maintaining  national 
ownership  of  data  and  investigative  decisions.  The  service  strengthens  strategic 
autonomy and technical resilience in cross-border investigations. 

c.  Impact on fundamental rights 

i.  Objective of general interest (+) 

This option makes a positive contribution to an objective of general interest (+), namely 
the prevention and combating of serious crime and terrorism. By combining authorised 
Europol  access  to  national  data  under  Prüm  II,  improved  system  interoperability,  and 
shared services such as a potential EU DNA matching service, this option strengthens the 
speed, coherence, and reliability of cross-border investigations. It reduces fragmentation, 
enables earlier detection of cross-system links, and enhances forensic cooperation in 
complex  or  time-critical  cases,  while  Europol  acts  strictly  within  its  mandate  and  on 
Member State authorisation, without centralising data. Overall, it reinforces EU internal 
security and delivers clear EU added value. 

ii.  Impact on data protection (0) 

Necessity 

Allowing Europol, with explicit Member State authorisation, to query national databases 
under EU frameworks addresses operational gaps that currently cause delays and blind 
spots.  Anchored  in  the  Prüm  II  hit/no-hit  architecture  and  maintaining  full  national 
control, Europol acts as a technical and analytical service provider without new data 
categories or autonomous access rights, ensuring more effective cross-border cooperation, 
particularly in complex or time-critical cases. 

A  shared  EU  DNA  matching  service  enhances  operational  resilience,  aligns  with 
evolving Prüm II standards, and reduces reliance on third-country tools. Developed with 
Member States and forensic authorities, it is  optional and fully governed by Member 
States,  providing  a  common  solution  for  lawfully  collected  data  while  preventing 
fragmentation and ensuring consistent application of EU data protection standards. Both 
measures  are  necessary  and  targeted,  addressing  identified  operational  gaps  without 
expanding Europol’s mandate or data scope. 

This policy option passes the necessity test.  

Proportionality 

Europol  access  strictly  limited  to  Prüm  II  and  under  Member  State  authorisation  is 
proportionate, preserving the hit/no-hit architecture, national control, case-based use, 

166 

 
 
and data ownership, without expanding data categories or retention. This supports cross-
border investigations without exceeding what is necessary, while any access beyond Prüm 
II is not proportionate and excluded from option comparisons. 

A shared EU DNA matching service, developed with Member States and aligned with 
Prüm II, is proportionate. It does not create new data categories, remains optional and 
Member  State–governed,  and  preserves  decentralised  storage  and  ownership, 
providing  common  infrastructure  for  lawfully  exchanged  DNA  data.  Its  benefits  – 
enhanced  effectiveness  and  EU  strategic  autonomy  –  outweigh  the  limited,  controlled 
impact on data processing. We therefore conclude that the option respects the principle 
of proportionality. 

d.  Costs (+/--) 

Direct costs 

Member States  Europol 

Expected one-off costs (in million EUR) 

1.35  (0.05  per 
MS) 

11 

1)  Access to national databases 

2)  DNA matcher 

Expected yearly recurring costs (in million EUR per 
annum) 

0.3 

1)  Access to national databases 

2)  DNA matcher 

1)   0 

2)  1.35 

1)  6 

2)  5 

5.3* 

1)  0 

1)  4.3 

2)  0.3 

2)  1 

Under  the  Prüm-based  approach,  Member  States’  costs  remain  negligible,  with  only 
limited  technical  adjustments  and  a  small  one-off  cost  (around  EUR  0.05  million  per 
Member State). Europol bears moderate initial and limited recurring costs for additional 
staff,  reinforced  data  management  and  minor  system  upgrades,  including  the  EU  DNA 
matcher.  While  EU-level  expenditure  increases,  overall  Union  costs  are  expected  to 
decrease  over  time  through  economies  of  scale  and  reduced  reliance  on  third-country 
solutions. 

e.  Feasibility (+) 

Technical feasibility 

Technical  feasibility  is  high  for  Prüm  II–based  authorised  access,  as  the  necessary 
hit/no-hit  infrastructure,  secure  channels,  and  biometric  matching  are  already  in  place, 
requiring mainly workflow and configuration adjustments. A shared EU DNA matching 
service is more complex but feasible, building on existing forensic standards, technologies, 

167 

 
 
 
 
 
 
 
 
 
 
and Prüm frameworks, and requiring  robust  security, governance, and Member State 
cooperation. With phased implementation, both measures are technically feasible, giving 
an overall positive feasibility assessment (+). 

Political feasibility  

The  policy  option  in  politically  feasible  (+).  Prüm  II-based  authorised  access  is 
challenging, as it shifts Europol’s role to querying Member State data, but is acceptable 
when Europol acts strictly on Member State request. Any access beyond Prüm II would 
likely face strong opposition. The EU DNA matching service is politically feasible, as it 
enhances  strategic  autonomy,  reduces  reliance  on  third-country  tools,  and  remains 
optional and Member State-governed.  

f.  Impact on digitalisation (0) 

The option has a neutral impact on digitalisation, relying on existing infrastructures like 
Prüm  II  and  forensic  technologies  without  fundamentally  transforming  EU  law 
enforcement’s digital architecture. Prüm II access builds on established frameworks, and 
the optional EU DNA matching service consolidates existing capabilities. Digital tools 
primarily enable operational support rather than driving structural digital transformation. 

2.2 Policy  option  2.2:  Simplified  rules  to  reduce  the  administrative  burden  of  data 

subject categorisation 

a.  Impact on citizens (+) 

As this policy option would allow both Europol and the EU Member States to use data 
more effectively and consistently, there would be a direct, positive impact on Europol’s 
ability to fight serious and organised crime and terrorism. By reducing operational delays 
and increasing  legal  clarity, investigations could  progress  more efficiently,  leading  to  a 
positive impact on citizens and strengthening overall security. 

b.  Impact on national authorities (++) 

The option would significantly change and simplify the process of Member States sharing 
data.  It would  lead to  harmonisation  of rules applicable to  Member States and Europol 
alike, by aligning the Europol Regulation with the Law Enforcement Directive (LED) and 
the EU Data Protection Regulation (EUDPR), resulting in clearer and more coherent rules 
for national authorities. 

In addition, the overall harmonisation would lead to a decrease in bureaucracy, constituting 
another  very  positive  impact  on  national  authorities.  Greater  legal  certainty  would  also 
reduce the risk of divergent interpretations and corrective actions. 

168 

 
 
c.  Impact on fundamental rights (+) 

i.  Objective of general interest (+) 

This policy option would have a clear positive impact as regards the objective of general 
interest.  A  simplified  and  harmonised  framework  for  data  subject  categorisation  would 
enhance Europol’s operational effectiveness positively contributes to the ability of Europol 
to fight against serious and organised crime and terrorism by lessening operational burden 
on Europol and eliminating operational delays currently faced. 

ii.  Impact on data protection (-) 

Necessity 

This policy option proves to be of a high necessity as it would positively impact the way 
data  would  be  analysed  and  used  by  Europol.  Whereas  currently  data  may  remain 
underused due to the complex framework governing data subject categorisation, the option 
would allow for data to be processed and analysed more efficiently, within a clearer and 
legally  aligned  structure.  This  ensures  that  data  already  lawfully  collected  can  be 
effectively used for its intended law enforcement purpose. We therefore conclude that the 
policy option respects the principle of necessity. 

Proportionality 

The  option  is  proportionate  in  that  it  does  not  introduce  new  categories  of  data,  new 
processing purposes, or expanded access rights. However, the removal and simplification 
of  the  Data  Subject  Categorisation  (DSC)  entail  a  moderate  negative  impact  on  data 
protection,  as  some  of  the  procedural  safeguards  that  previously  limited  operational 
processing are reduced. The measure aligns existing rules with the LED and the EUDPR 
and  reduces  procedural  constraints,  thereby  enhancing  operational  coherence  and 
effectiveness. By maintaining the core safeguards and limiting the scope of processing to 
operationally necessary cases, the option seeks an appropriate balance between efficiency 
and fundamental rights. We therefore conclude that, while there is a negative impact on 
data  protection,  the  policy  option  remains  proportionate  in  relation  to  the  objectives 
pursued. 

d.  Cost (++) 
Even  though  the  policy  option  would  significantly  improve  Europol’s  operational 
flexibility  and  capacity  to  process  information,  it  would  not  require  substantial  initial 
investment, as it primarily concerns legislative alignment and simplification. Moreover, 
this policy option would likely free up resources that are currently deployed to specifically 
engage  in  the  burdensome  procedure  of  data  subject  categorisation  under  the  current 
framework.  

Administrative savings and efficiency gains are therefore expected, justifying the very 
positive cost assessment. 

169 

 
 
e.  Feasibility (+) 

The technical feasibility of this option is to be assessed as very positive (++), as it would 
not require substantial changes to be put in place or require the development of an entirely 
new legal framework for DSC. Instead, the framework would be aligned to that of the LED 
and the EUDPR.  

The alignment with already existing legislation would constitute a positive assessment as 
regards  political  feasibility  (+).  Overall,  this  harmonisation  would  be  well-received  by 
Europol and the Member States aligned, as underlined by the recent report under article 
68(3)  of  the  ER  and  further  consultation  of  Member  States’  experts  at  technical  level. 
However, as this option could potentially offset complexities as regards data ownership 
and sovereignty, the impact is assessed only as positive and not as very positive.  

f.  Impact on digitalisation (0) 

The  option  has  an  overall  neutral  impact  on  digitalisation.  By  aligning  existing  legal 
frameworks  and  procedures,  the  digital  architecture  of  the  process  of  data  subject 
categorisation  is  not  fundamentally  transformed.  Subsequently  address  the  obstacles  of 
DSC serves as an enabler for Europol to process and analyse data rather than being a driver 
of  structural  change.  Meaning  that  Europol’s  overall  usage  of  data  would  be  (further) 
consolidated, which has no impact on digitalisation as such. 

2.3 Policy option 2.3: Europol as structural provider of information, analytical support 

and capacities to the EPPO 

a.  Impact on citizens (++) 

The positive impacts on citizens mentioned for policy option 1 would increase thanks to 
efficiency  gains  deriving  from  the  introduction  of  both  hierarchical  arrangements  and 
direct  information  exchange  between  Europol  and  EPPO.  Citizens  would  also  benefit 
indirectly from Europol having access to further information stored by the EPPO.  

b.  Impact on national authorities (++) 

The positive impacts on national authorities mentioned for policy option 1 would increase 
thanks  to  efficiency  gains  deriving  from  the  introduction  of  both  hierarchical 
arrangements  and  direct  information  exchange  between  Europol  and  EPPO.  Law 
enforcement  authorities  would  also  benefit  indirectly  from  Europol  having  access  to 
further information stored by the EPPO, as this would strengthen Europol’s support and 
coordination abilities. 

c.  Impact on fundamental rights (++) 

This measure would have a very positive impact on fundamental rights insofar as it would 
ultimately help strengthen the EU Member States’ statehood against criminal threats in an 
efficient manner, prompting Member States’ concrete ability to respect, promote and fulfil 
human rights under international and EU law. 

170 

 
 
 
i.  Objective of general interest (++) 

This measure makes a very positive contribution to an objective of general  interest (+), 
namely  the  protection  of  the  financial  interests  of  the  EU,  by  allowing  the  EPPO  to 
effectively  and  efficiently  carry  out  its  mission.  The  same  goes  for  the  EU-level  fight 
against  serious  and  organised  crime,  cybercrime  and  terrorism,  by  allowing  Europol  to 
develop  specialised  skills  and  have  access  to  a  huge  amount  of  relevant  information  to 
ultimately more effectively support the Member States.  

ii.  Impact on data protection (0) 

Necessity and proportionality 

This measure is necessary to efficiently meet the EPPO’s sharply increasingly needs and 
allow it to maximally protect the financial interests of the EU. It does not interfere with 
current data protection levels. Therefore, this policy measure respects the principles of 
necessity and proportionality. 

d.  Costs (++) 

Direct costs 

Expected one-off costs (in 
million EUR) 

Expected  yearly  recurring 
costs (in million EUR) 

Member States activities 

EU activities 

0 

0 

0 

11.1 

One-off and recurring costs for Member States are negligible, as the measure operates at 
EU level and does not require national staff contributions or operational expenditure. For 
Europol, no separate start-up costs are identified, since onboarding and infrastructure needs 
are already captured in the average annual staff cost methodology. Recurrent costs stem 
mainly from establishing a dedicated EPPO Support Team (around EUR 10.1 million 
annually) and additional permanent cooperation mechanisms (less than  EUR 1 million 
per year). 

e.  Feasibility (+) 

Technical feasibility 

The measure is legally feasible. Besides establishing the EPPO Support Unit, which was 
analysed  for  policy  option  1,  turning  Europol  into  a  structural  provider  of  information, 
analytical  support  and  capacities  to  the  EPPO  would  require  amending  the  Europol 
Regulation  regarding  Europol’s  tasks.  Introducing  the  possibility  for  hierarchical 
arrangements  and  direct  information  exchange  between  Europol  and  EPPO  when 
information falls within the EPPO’s competence would also require amending the Europol 
Regulation regarding relations between Europol and EPPO. 

171 

 
 
 
 
 
Political feasibility 

The  consultation  activities  have  revealed  that  the  EPPO  would  fully  support  this 
measure,238  while  both  Europol  and  several  Member  States  remain  reluctant  toward 
introducing  the  possibility  for  information  exchanges  in  derogation  from  the  “data 
ownership  principle”239.  Overall,  the  measure  remains  politically  feasible,  albeit  with 
difficulties. 

f.  Impact on digitalisation (0) 

This measure would have no to positive impacts on digitalisation depending on whether 
implementation maintains the current level or increases the digital delivery of services. 

2.4 Policy option 2.4: EU Police Cloud and Europol support offices 

a.  Impact on citizens (+) 

The  continued  rise  of  digitally  enabled  and  AI-facilitated  crime,  combined  with 
increased cross-border mobility, has led to a more diverse and complex threat landscape. 
Criminal activities increasingly span EU internal borders and affect citizens both directly 
and  indirectly.  This  trend  is  expected  to  intensify  as  a  growing  share  of  citizens’  daily 
activities takes place in digital environments. 

Ensuring  a  safer  physical  and  online  environment  therefore  requires  enhanced  cross-
border  cooperation,  improved  information  exchange  among  Member  States,  and 
analytical  capacities  capable  of  processing  large  and  complex  datasets.  The  EU  Police 
Cloud  would  support  the  deployment  of  interoperable  digital  investigative  tools  and 
scalable  processing  capabilities,  enabling  law  enforcement  authorities  to  respond  more 
effectively  to  evolving  forms  of  criminality.  Overall,  the  initiative  is  expected  to 
strengthen EU internal security by supporting law enforcement adaptation to the digital 
transformation of crime, thereby delivering tangible benefits for citizens in terms of safer 
physical and online environments. 

By strengthening the operational link between Europol and the Member States, through 
reinforced  Europol  National  Units  complemented  by  Europol  Support  Offices,  this 
measure would establish a more integrated,  efficient and operationally driven model of 
cross-border  law-enforcement  cooperation.  It  is  expected  to  deliver  tangible  security 
outcomes  for  citizens,  including  more  effective  disruption  of  cross-border  criminal 
networks,  earlier  detection  of  cross-border  dimensions  in  criminal  investigations,  faster 
operational  responses,  and  improved  coordination  of  operational  and  investigative 

238 As stated by the EPPO in the interview carried out by ICF in the context of the study supporting the 
evaluation and impact assessment of the Europol Regulation, as well as during  the third workshop on the 
future  of  Europol  and  in  its  Note  to  DG  HOME  on  improving  the  cooperation  between  the  EPPO  and 
Europol.  
239 As  stated  by  Europol,  during  the  focus  groups  carried  out  in  the  context  of  the  study  supporting  the 
evaluation  and  impact  assessment  of  the  Europol  Regulation,  and  by  Member  States  during  the  fourth 
workshop on the future of Europol and during the COSI meeting of February 2026.  

172 

 
 
 
activities. Over time, this enhanced effectiveness is likely to contribute to a higher level of 
security within the Union and to reinforce citizens’ trust in the EU’s capacity to combat 
serious and organised crime. 

b.  Impact on national authorities (++) 

The EU Police Cloud would provide criminal investigators across the Union with scalable 
storage  and  on-demand  computing  capacity,  enabling  them  to  manage  expanding 
datasets  and  peak  workloads  more  effectively.  National  authorities  would  benefit  from 
enhanced  analytical  tools,  including  AI-supported  pattern  detection,  network  and 
multimedia analysis, and decryption capabilities. These functionalities would support more 
precise and near real-time data processing, thereby strengthening investigative and crime-
prevention capacities. 

The  initiative  would  also  foster  secure  and  trust-based  cross-border  information 
sharing. Through harmonised authentication mechanisms and common security standards 
across  Member  States,  the  Police  Cloud  would  offer  a  unified  environment  for  joint 
analysis  and  cooperation.  National  authorities  would  retain  control  over  their  data 
throughout  its  lifecycle,  while  benefiting  from  reduced  fragmentation  and  improved 
interoperability, thus reinforcing mutual trust and operational cooperation. 

By  enabling  the  processing  of  sensitive  law  enforcement  data  within  a  sovereign 
European  framework,  the  transition  would  contribute  to  resilience  and  strategic 
autonomy. Moving beyond constraints linked to traditional infrastructure would facilitate 
more  efficient  data  handling  and  timely  operational  responses,  in  line  with  EU  digital 
sovereignty objectives. Overall, the EU Police Cloud is expected to enhance operational 
effectiveness, efficiency and cooperation among national authorities, supporting strategic 
law enforcement objectives at Union level. 

Europol Support Offices would have a significant operational impact on national law-
enforcement  authorities.  They  would  provide  more  systematic  and  easier  access  to 
Europol’s  analytical,  operational,  and  strategic  products,  while  reducing  administrative 
and coordination burdens through locally embedded expertise familiar with both national 
procedures  and  Europol  systems.  The  offices  would  also  strengthen  trust  and  mutual 
understanding  between  national  services  and  Europol  and  support  capacity-building 
through specialised training. Evidence shows that Europol support is often mobilised late 
in investigations, limiting its impact; these Europol support offices would facilitate earlier 
engagement,  improve  uptake  of  Europol  products  in  national  proceedings,  and,  in  the 
medium term, increase operational efficiency while reducing duplication of efforts.  

c.  Impact on fundamental rights (+) 

i.  Objective of general interest (+) 

The proposal aligns firmly with the EU’s overarching interest in promoting security, peace, 
and the well-being of citizens through a unified law enforcement framework. In supporting 
Europol’s  capabilities,  the  measure  seeks  to  uphold  the  collective  security  interests  of 
Member States, ensuring a harmonised approach to combating serious crime. 

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ii.  Impact on data protection (0) 

Necessity  

The EU Police Cloud would provide the scalable storage and processing infrastructure 
required to support an expanding range of EU criminal information-sharing and analytical 
tools.  It  would  enable  seamless  deployment  within  national  environments  and  ensure  a 
high and harmonised  level  of security,  notably through an EU Digital  Police identity 
framework. 

The initiative would not introduce new personal data or new processing operations, 
but  would  serve  as  the  secure  technical  backbone  for  existing  and  future  applications 
requiring significant computing capacity. 

Its necessity arises from the need to process large, complex and cross-border datasets 
that cannot be efficiently handled through decentralised infrastructures alone. Certain joint 
analytical and communication-based applications inherently require centralised capacity 
due  to  volume  and  operational  constraints.  Joint  cross-border  analysis  of  information 
shared by Member States, including extensions of JOAC and Europol Analytical Projects, 
requires  centralised  storage  and  processing,  as  the  data  volumes  involved  exceed  the 
practical  transfer  capacities  between  national  data  centres.  Similarly,  communication-
based  tools  such  as  SIENA,  the  Large  File  Exchange  (LFE)  system,  and  multilateral 
operational  cooperation  mechanisms  rely  on  central  processing  infrastructure  to 
function effectively. 

The EU Police Cloud is therefore considered a necessary enabling measure to maintain 
effective and secure EU law enforcement cooperation in the digital environment. 

Proportionality 

The  EU  Police  Cloud  being  only  a  technical  platform  for  hosting  law  enforcement 
applications does not entail per se any possible consequence on the persons’ rights and 
freedom.  Such  hosted  data  processing  being  however  susceptible  by  the  size  and  the 
processing power to augment the risks  of potential infringements, EU police cloud will 
accordingly provide by default build-in safeguards ensuring that a first unconditional line 
of guarantees will be available to limit the hosted application to essential purposes in law 
enforcement:  along  with  harmonized  digital  police  environment,  will  a  common  police 
digital ID scheme, based on EU Digital Identity with insurance level high be the ground 
stone for insuring traceability, accountability and strong role-based access to such sensitive 
investigative data and to the corresponding tools.  

In that way will the EU Police Cloud contribute to safeguarding individual privacy rights 
for all potential storage and processing of data while maximising operational efficacy. The 
approach ensures a balanced application of processing power without overextending the 
access to or usage of personal data. 

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d.  Cost (0) 

Direct costs 

Member States  

Europol 

Expected one-off costs (in million EUR) 

67,5 

145.8 

-  EU Police Cloud 

-  13,5 

-  143.3 

-  EU Police Digital ID 

-  Europol Support offices 

-  54 

-  0 

-  2,5 

-  0 

Expected 
(in million EUR) 

yearly 

recurring 

costs 

11,4 

46.8 

-  EU Police Cloud 

-  EU Police Digital ID 

-  Europol Support offices 

-  0,6 

-  10,8 

-  0 

-  39.8 

-  0,5 

-  6,5 

The initial investment costs associated with the deployment of the EU Digital Police Cloud 
are  substantial,  encompassing  infrastructure  development,  data  migration,  and  ongoing 
system  management. Nevertheless, these investments  are  counterbalanced by long-term 
savings  arising  from  enhanced  processing  efficiencies  and  reduced  overhead  linked  to 
disparate national law enforcement systems.  

A modest Europol support office would generate approximately EUR 400,000 to EUR 
650,000  per  year,  covering  staff  costs,  secure  IT  connectivity,  equipment  and  limited 
coordination travel. Under a rollout of five to ten antenna offices, total annual EU-level 
costs would range between EUR 2 million and EUR 6.5 million, reflecting a scalable and 
proportionate deployment model. 

e.  Feasibility (+) 

From a technical perspective, the deployment of the EU Digital Police Cloud is feasible, 
supported  by  robust  advancements  in  cloud  computing  and  data  analytics  technologies, 
and notably via a more robust market offering including under sovereignty aspects. The 
initiative benefits from a solid foundation of Europol’s existing expertise in secure data 
processing  and  with  IT  resilience  across  JHA  agencies,  ensuring  that  the  infrastructure 
meets the high demands of law enforcement applications. 

From a political perspective, there is broad support for the proposal given its alignment 
with  EU  objectives  relating  to  enhanced  security,  digital  sovereignty,  and  collaborative 
law enforcement. While recognising the strategic importance of unified crime prevention 
capabilities across the Union, sovereignty, security and data ownership, will be essential 
criteria  to  be  met  to  comfort  MS  readiness  to  cooperate  in  implementing  shared 
infrastructure. 

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The  Europol  Support  Offices  are  operationally  feasible,  as  they  build  on  existing 
structures  (Europol  National  Units),  leverage  Europol’s  current  practice  of  temporarily 
deploying staff to support investigations and can make use of the Agency’s secure IT and 
forensic environments, which could be extended to support this model.  

From a  legal perspective, the measure would require a targeted legislative amendment 
introducing  an  explicit  legal  basis  for  the  establishment  of  Europol  support  offices  in 
Member States limiting to support, coordination and technical functions, for the purpose 
of facilitating and strengthening operational support. 

From  a  political  perspective,  the  establishment  of  support  offices  would  be  demand-
driven and voluntary, based on an invitation or agreement with the host Member State. The 
exact size, number, location and duration of Europol support offices would remain flexible 
and subject to periodic review. 

f.  Impact on digitalisation (++) 

Digitalisation brought about by the EU Digital Police Cloud facilitates superior analytical 
capabilities, enabling Europol to process increasingly complex and voluminous datasets 
with  greater  precision  and  speed.  This  transformation  accelerates  the  timeliness  and 
accuracy of operative activity, promoting proactive threat identification and intervention 
strategies. 

The  cloud's  sophisticated  data  handling  and  integration  capacities  afford  Europol  and 
national law enforcement authorities the opportunity to harness machine learning and AI-
enhanced  insights,  fostering  innovative  approaches  in  combating  organised  crime  and 
terrorism. Through these technological advancements, Europol and national authorities are 
better equipped to adapt to evolving criminal modalities, ensuring resilient and forward-
thinking security strategies. 

Europol Support Offices would enhance the digitalisation of law-enforcement cooperation 
by enabling earlier and  more effective use of Europol’s platforms and tools, improving 
data  quality  and  interoperability,  facilitating  faster  digital  information  exchange,  and 
supporting  the  deployment  of  mobile  digital  tools  during  operations.  By  embedding 
expertise at national level, the option bridges the gap between technical capabilities and 
operational  use,  complementing  EU  efforts  on  interoperability,  secure  information 
exchange, and digital transformation. 

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ANNEX 11: COMPETITIVENESS CHECK 

1.  Overview of impacts on competitiveness  

Dimensions 
Competitiveness 

of 

Impact of the initiative 
(++ / + / 0 / - / -- / n.a.) 

References  to  sub-sections  of  the 
main report or annexes 

Cost and price competitiveness  n.a. 

International competitiveness  

n.a. 

Capacity to innovate 

SME competitiveness 

n.a. 

n.a. 

2.  SYNTHETIC ASSESSMENT  

Main  report  –  sections  on  economic 
affected 
impacts 
(initiative targets public authorities) 

stakeholders 

/ 

Main  report  –  sections  on  economic 
impacts / stakeholders affected 

Main  report  –  sections  on  economic 
impacts / stakeholders affected 

Main report – “Application of the ‘one 
in, one out’ approach” (no admin costs 
for private sector) 

Overall, this initiative aims to address challenges related to the efficiency of Europol and 
to  strengthen  the  implementation  and  further  development  of  EU  law  enforcement 
cooperation.  The  measures  under  consideration  primarily  concern  the  organisation, 
planning, governance, operational cooperation and internal capacities of public authorities 
(Europol  and  Member  States’  competent  law  enforcement  authorities).  They  do  not 
introduce regulatory obligations for economic operators, do not set product requirements, 
and do not alter market access conditions or the rules governing competition in the internal 
market. 

Accordingly, no direct impacts on competitiveness are expected across the four dimensions 
(cost/price competitiveness, international competitiveness, capacity to innovate and SME 
competitiveness). For the purposes of the competitiveness check, the initiative is therefore 
assessed as not applicable. 

While the implementation of some measures may entail public procurement by Europol or 
Member  States  (e.g.  for  technical  equipment  and  related  services,  including  IT 
components,  data  processing  tools,  integration,  maintenance,  training  or  other  support 
services), this reflects how public authorities may operationalise the measures, rather than 
an impact stemming from new requirements on undertakings. Such procurement would be 
conducted under the applicable EU and national public procurement rules and would not, 
in  itself,  constitute  a  competitiveness  effect  attributable  to  the  initiative  (no  new 
compliance burden or market constraint is created for operators, including SMEs). 

Stakeholder input from economic operators received during the Call for Evidence does not 
alter  this  conclusion,  as  the  initiative  remains  focused  on  public-sector  operational 
capacity,  information  exchange  and  governance  in  the  area  of  law  enforcement 
cooperation, rather than on regulating private-sector activity. 

177