REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 37th Annual Report on the protection of the European Union’s financial interests and the fight against fraud – 2025
Date: 2026-07-28
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU strategy, activity report, corruption, digitisation, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.7.2026  COM(2026) 411 final  REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 37th Annual Report on the protection of the European Union’s financial interests and the fight against fraud – 2025 {SWD(2026) 245 final} - {SWD(2026) 246 final} - {SWD(2026) 247 final} - {SWD(2026) 248 final} - {SWD(2026) 249 final} - {SWD(2026) 250 final} - {SWD(2026) 251 final}  
 
 
Contents 

EXECUTIVE SUMMARY ............................................................................................................ 2 

1. 
Introduction ......................................................................................................................... 4 
1.1.  The EU’s financial interests and their protection .................................................................. 4 
1.2.  Methodological approach ...................................................................................................... 5 
A systemic approach to the anti-fraud cycle ........................................................ 5 
Prevention ............................................................................................................ 6 
Detection .............................................................................................................. 6 
Investigation and prosecution .............................................................................. 7 
Recovery and sanctioning .................................................................................... 7 
Reporting and monitoring .................................................................................... 7 
1.3.  Data sources .......................................................................................................................... 7 
Special boxes for key points ............................................................................................... 11 
1.4. 

1.2.1. 
1.2.2. 
1.2.3. 
1.2.4. 
1.2.5. 
1.2.6. 

2. 
2.1. 

Main developments in the protection of the EU’s financial interests in 2025 .............. 13 
Strengthening the legal framework ..................................................................................... 13 
The legislative proposal for the next MFF ......................................................... 13 
2.1.1. 
2.1.2. 
Review of the anti-fraud architecture ................................................................. 14 
2.1.2.1.  Key priorities identified in the White Paper ....................................................... 14 
2.1.2.2.  Sources informing the review ............................................................................ 14 
2.1.3. 
The anti-corruption package .............................................................................. 15 
2.1.3.1.  Directive on combating corruption .................................................................... 15 
2.1.3.2.  EU network against corruption .......................................................................... 16 
2.1.3.3.  The EU anti-corruption strategy ......................................................................... 16 
2.2.  Overview of national measures adopted in 2025 ................................................................ 16 
Strengthening the governance and coordination of the fight against fraud ......................... 19 
2.3. 
2.3.1. 
Implementation  of  the  action  plan  accompanying  the  Commission  anti-fraud 
strategy ............................................................................................................... 19 
National anti-fraud strategies ............................................................................. 19 
2.4.  Enhancing anti-fraud frameworks: A review of member states’ progress on reporting and 
digitalisation........................................................................................................................ 22 
2.4.1.  Member State actions: follow-up to the recommendation in the 2024 PIF report
    ......................................................................................................................... 22 
Improved reporting and more effective communication channels ..................... 23 
2.4.1.1. 
2.4.1.2.  Digitalisation and AI .......................................................................................... 25 
Implementation of the EU anti-fraud programme ............................................................... 27 

2.3.2. 

2.5. 

A holistic view of the fight against fraud affecting the EU’s financial interests .......... 28 
3. 
3.1.  The protection of the EU’s financial interests through the anti-fraud cycle ....................... 28 
Detection ............................................................................................................ 28 
3.1.1. 
Prevention (early detection) ............................................................................... 32 
3.1.2. 
Investigation and prosecution ............................................................................ 34 
3.1.3. 
3.1.4. 
Recovery and sanctioning .................................................................................. 36 
3.1.4.1.  Recovery ............................................................................................................ 36 
3.1.4.2.  Sanctioning ........................................................................................................ 38 
3.2.  Main findings by budgetary sector ...................................................................................... 39 

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Revenue – traditional own resources ................................................................. 39 
3.2.1. 
Expenditure ........................................................................................................ 41 
3.2.2. 
3.2.2.1.  Shared management ........................................................................................... 41 
3.2.2.2. 
Indirect management – Neighbourhood and the world ...................................... 45 
3.2.2.3.  Direct management ............................................................................................ 45 
Recovery and resilience facility ......................................................................... 46 
3.2.3. 
Fraud enablers against the EU budget ................................................................................. 47 
Organised crime ................................................................................................. 47 
3.3.1. 
Corruption .......................................................................................................... 47 
3.3.2. 
Conflicts of interest ............................................................................................ 48 
3.3.3. 

3.3. 

Conclusions and recommendations ................................................................................. 49 
4. 
Prevention ........................................................................................................................... 49 
4.1. 
4.2.  Detection ............................................................................................................................. 49 
4.3. 
Investigation and prosecution ............................................................................................. 50 
4.4.  Recovery and sanctioning ................................................................................................... 50 

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EXECUTIVE SUMMARY 

This year’s annual report on the protection of the EU’s financial interests (PIF report) presents the 
first comprehensive overview of efforts to combat fraud and financial irregularities affecting the 
Union’s  financial  interests,  structured  around  the  concept  of  the  anti-fraud  cycle.  It  marks  the 
beginning of a refined EU reporting framework, consolidating data from all relevant actors into a 
single PIF report. The aim is to increase transparency and accountability, as proposed in the White 
Paper on the anti-fraud architecture (AFA) review . 

To this end, several new indicators have been identified to measure the activities  of and results 
achieved by EU and national AFA actors in prevention, detection, investigation and prosecution, 
recovery and sanctioning. 

The report also provides an overview of the key measures adopted at both EU and national levels 
to  strengthen  the  protection  of  the  EU’s  financial  interests.  At  EU  level,  the  Commission  has 
proposed a legislative package for the next multiannual financial framework (MFF), based on a 
performance-focused delivery model that incorporates lessons from the Recovery and Resilience 
Facility (RRF) into future spending programmes. The proposal includes mandatory requirements 
for Member States to report detected fraud and irregularities, and to adopt comprehensive national 
anti-fraud strategies. 

The legislative package was accompanied by the publication of White Paper for the AFA review, 
which is expected to lead to a Commission communication, to be adopted by the end of 2026. This 
may result in legislative proposals amending the key legal acts governing EU AFA actors. Political 
agreement on the Directive on combating corruption was reached at the end of 2025, and the legal 
act entered into force on 31 May 2026. It will be underpinned by the EU’s first anti-corruption 
strategy. 

Prevention is the stage of the anti-fraud cycle where there has been most improvement, thanks to a 
sustained  focus  on  preventive  measures,  such  as  early  detection  and  exclusion  mechanisms, 
capacity  building  and  improved  information-sharing  among  authorities.  Early  detection  of 
suspected fraud has increased, reducing the need for costly recovery proceedings and minimising 
the risks associated with failed fund retrieval. It is crucial that national authorities systematically 
refer these cases to prosecution services and report them to the Commission in a timely manner. 

Detection has remained relatively stable over the past five years, except for a sizeable increase in 
fraud cases reported in 2024 and fluctuations in specific budgetary areas. The financial amounts at 
stake have risen since 2023, which may reflect a greater focus on high-value cases. An analysis of 
detection  methods  reveals  untapped  potential  in  risk-based  approaches,  IT  tools,  and 
whistleblowing, particularly for fraud identification. In 2025, a total of 13 010 irregularities (-7.6% 
on  2024),  amounting  to  EUR 2.1  billion  (+12.8%  on  2024)  were  recorded.  Of  these,  986  were 
classified as fraudulent cases (-32% on 2024) amounting to EUR 274.3 million in 2025 (-49.2% 
on 2024). 

Investigation and prosecution are often lengthy and complex, with many cases taking years to lead 
to a final judgment. The AFA review will examine ways to improve coordination and cooperation 
between key EU actors, especially OLAF and the European Public Prosecutor’s Office (EPPO), to 
streamline  these  processes.  Ongoing  cooperation  and  support  from  national  services  remain 
essential. 

Recovery and sanctioning continue to be areas requiring further improvement. Closer cooperation 
and coordination between investigative, prosecutorial, judicial, and administrative bodies would 
boost recovery rates and provide better data on the outcomes of judicial actions, including sanctions 
and penalties imposed. 

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LIST OF ABBREVIATIONS 

AFA 
AFIS 
AI 

Anti-fraud architecture 
Anti-Fraud Information System 
Artificial intelligence 
Authority for Anti-Money Laundering and Countering the Financing of 
Terrorism 
Anti-Fraud Coordination Services 
Commission anti-fraud strategy 
Common agricultural policy 
Committee on Budgetary Control 
CAP strategic plan 
European Court of Auditors 
Early Detection and Exclusion System 
European Public Prosecutor’s Office 
European Regional and Development Fund 
European Social Fund 
European Union 
Fund for European Aid to the Most Deprived 
Fraud Prevention and Detection Network 
Institutions, bodies, offices and agencies 
Irregularity Management System 
Instrument for Pre-Accession 
Information technology 
Joint customs operation 
Just Transition Fund 
Multiannual financial framework 
National anti-fraud strategies 
European Anti-Fraud Office 
Protection of financial interests 

AMLA 
AFCOS 
CAFS 
CAP 
CONT 
CSP 
ECA 
EDES 
EPPO 
ERDF 
ESF 
EU 
FEAD 
FPDNet 
IBOA 
IMS 
IPA 
IT 
JCO 
JTF 
MFF 
NAFS 
OLAF 
PIF 
PFIU audits  Audits on the protection of the financial interests of the Union 
RRF 
RRP 
TFEU 
TOR 
UAFP 
VAT 
YEI 

Recovery and Resilience Facility 
National recovery and resilience plan 
Treaty on the Functioning of the European Union  
Traditional own resources 
Union anti-fraud programme 
Value added tax 
Youth employment initiative 

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1.  INTRODUCTION 

1.1.  The EU’s financial interests and their protection 

The  EU’s  2025  budget  amounts  to  EUR 199.4  billion  in  commitment  appropriations  and 
EUR 155.2  billion  in  payment  appropriations.  The  2021-2027  MFF  amounts  to  EUR  1 202.8 
billion (1). Additional resources come from NextGeneration EU, the EU’s post-COVID economic 
recovery package under which EUR 750 billion (2) is to be spent between 2021 and 2026. 

These  financial  resources  enable  the  EU  to  finance  its  policies  and  promote  its  objectives  and 
values. 

EU Member States manage the largest share of EU expenditure and collect VAT and traditional 
own resources (TOR), the latter mainly taking the form of customs duties. 

In accordance with Article 325 of the Treaty on the Functioning of the European Union (TFEU), 
the EU and its Member States must counter fraud and any other illegal activities  that affect the 
EU’s  financial  interests.  Under  paragraph  5  of  that  Article,  each  year  the  Commission,  in 
cooperation  with  the  Member  States,  must  submit  a report  to the  European  Parliament  and  the 
Council on the measures taken to implement the Article. This report, also known as the PIF report, 
meets that obligation for 2025 (3). It is accompanied by seven working documents (4).  

On  6 May  2025,  the  European  Parliament  adopted  its  resolution  on  the  protection  of  the  EU’s 
financial interests for 2023 (5). Parliament reiterated its call for the PIF report to become a tool to 
improve the  governance  of  the  EU’s anti-fraud  architecture (AFA)  and  for the report’s  holistic 
approach to be expanded. In line with this and previous requests, the 2025 PIF report is based on 
the concept of the anti-fraud cycle to give a more comprehensive overview of the key measures 
taken in 2025 and the main results achieved by AFA actors in countering fraud and irregularities. 

Section 2 covers the main developments of the AFA at European and national level. It looks at the 
legal  framework,  the  consolidation  of  governance,  major  developments  in  digitalising  the  fight 
against fraud and the support offered by the Commission in this area through the Union anti-fraud 
programme (UAFP). Section 3 presents data on the fight against fraud from the four perspectives 
corresponding to the stages of the anti-fraud cycle and on specific enablers to which the EU budget 

(1)  Multiannual financial framework ceilings in million EUR, at current prices. Source:   OJ L, 2025/31, 

27.2.2025 

(2)   In 2021 prices. 

(3)   Article 310(6) TFEU. 

(4)   The seven Commission staff working documents are: 

a)  National anti-fraud strategies (NAFS) - state of play; 
b)  Measures adopted by Member States to protect the EU’s financial interests– Implementation 

of article 325 TFEU; 

c)  Follow-up by Member States to the recommendations of the PIF Report 2024; 
d)  Statistical evaluation of irregularities reported for own resources, agriculture, cohesion and 

fisheries policies, pre-accession and direct expenditure; 

e)  Commission anti-fraud strategy (CAFS) action plan implementation monitoring: state-of-play 

31 May 2026; 

f)  Early Detection and Exclusion System (EDES) – Panel referred to in Article 143 of the 

Financial Regulation; 

g)  Annual overview with information on the results of the Union anti-fraud programme in 2025. 

(5)   Procedure file 2024/2083(INI). 

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is exposed: corruption, organised crime and conflicts of interest. Section 4 provides conclusions 
and recommendations. 

1.2.  Methodological approach 

1.2.1.   A systemic approach to the anti-fraud cycle 

Following  calls  from  the  European  Parliament  to  enhance  the  PIF  report’s  holistic 
approach and the Commission’s commitment to develop it accordingly, this year’s report 
adopts a  systemic perspective, supplementing  the traditional focus on detection with  a 
broader analysis of the entire anti-fraud cycle (see Figure 1). This approach ensures a 
comprehensive assessment of efforts to protect the EU’s financial interests. 

Figure 1: The anti-fraud cycle 

Prevention

Detection

Recovery 
and 
sanctioning

Investigation 
and 
prosecution

The anti-fraud cycle comprises four interlinked stages and an additional key element: 

1.  Prevention – limiting opportunities for fraud and irregularities. 

2.  Detection – identifying and addressing cases of fraud or irregularities. 

3.  Investigation  –  gathering  evidence  to  confirm  fraud  and  irregularities  and  identify 

perpetrators. 

4.  Recovery  and  sanctioning  –  recovering  funds  and  applying  corrective  measures  (e.g., 

judicial proceedings, disciplinary action). 

5.  Reporting – supplying data to analyse performance and inform policy adjustments. 

Member States must report detected irregularities and fraud to comply with sectoral obligations, 
while  EU  anti-fraud  actors  (e.g.,  OLAF,  EPPO)  provide  investigative  data.  This  reporting  is 
critical: it enables the cycle’s effectiveness to be analysed and supports evidence-based feedback 
to improve all stages. 

The stages of the cycle are interdependent, as changes in one area affect others. Multiple EU and 
national actors operate across these stages, and  it is essential for them to coordinate with each 

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other.  To  strengthen  this  collaboration,  the  Commission  has  long  advocated  for  national  anti-
fraud strategies. 

This  new  approach  also  aligns  with  repeated  calls  from  the  European  Parliament for the  PIF 
report to provide a fuller picture of anti-fraud efforts and measure the performance of all actors 
at EU and national level. 

1.2.2.  Prevention 

Preventive  measures  aim  to  minimise  the  occurrence  of  irregularities  and  fraud.  They  may 
include: 

• 

• 

• 

• 

legislative action (e.g. stricter rules); 

institutional frameworks (e.g. specialised bodies, robust procedures); 

transparency and accountability mechanisms; 

staff training and awareness-raising; and 

•  organisational culture (e.g. zero-tolerance policies). 

A well-designed management and control system can deter fraud by reducing opportunities 
and enable early detection, before funds are fully disbursed. 

Effective prevention reduces the burden on detection, investigation and correction. 

This report examines prevention through two lenses: 

1.  Policy and legislative measures adopted by the Commission (6) and Member States (7) 

to strengthen the protection of EU financial interests. 

2.  Early detection of fraud and irregularities that prevents funds being unduly spent in full 

or in part (8). 

1.2.3.  Detection 

Robust detection capacity is vital to identify and correct irregularities and fraud. Low detection 
rates do not necessarily reflect lower levels of fraud. On the contrary, they may indicate  weak 
controls,  insufficient  administrative  capacity  or  poor  compliance  with  the  reporting  obligation. 
Conversely, high detection rates can act as a deterrent. Detection data helps refine preventive 
policies.  If  detection  fails,  fraudulent  cases  may  go  uninvestigated,  hindering  recovery  and 
corrective action.  

In this report detection is looked at from different angles: from a qualitative point of view, through 
national and EU-level measures and, from a quantitative point of view, through data received in 
the  Irregularity  Management  System  (IMS)  and  the  OWNRES  database  (reported  by  Member 
States), and data published in the OLAF and EPPO annual reports. 

(6)   See the staff working document accompanying this report, ‘Commission Anti-Fraud Strategy (CAFS) 

Action plan implementation monitoring: state of play 31 May 2026’. 

(7)   See the SWDs accompanying this report ‘Measures adopted by the Member States to protect the EU’s 
financial interests’ and ‘Follow-up by Member States to the recommendations of the PIF Report 2024’. 

(8)   See Section 3.1.2. 

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1.2.4.  Investigation and prosecution 

Once a potential case of fraud is detected, thorough investigations are required to confirm the facts, 
identify the perpetrators and enable corrective action.  

Investigations seek to gather evidence for prosecutions and trials and could generate insights to 
improve prevention and detection. In the EU, administrative and criminal investigations are carried 
out  either  by  national  authorities,  or  by  OLAF  (administrative  investigations)  and  the  EPPO 
(criminal investigations), in accordance with their respective mandates. 

This  report  incorporates  information  on  investigations  based  on  information  from  national 
authorities  (IMS  and  OWNRES),  OLAF  and  the  EPPO  (respective  annual  reports  and  data 
provided by the two bodies). 

1.2.5.  Recovery and sanctioning 

Successful  investigation  lead  to  judicial  proceedings  or  corrective  measures,  such  as  financial 
recovery of sums due to the EU budget, disciplinary action or administrative reforms to address 
and  mitigate  the  risks  identified.  These  outcomes  strengthen  prevention,  either  by  deterring 
potential fraudsters or increasing fraud-proofing. 

This  PIF  report  includes  metrics  on  recovery  and  sanctions  based  on  an  analysis  of  IMS  and 
OWNRES  data,  the  Commission’s  annual  management  and  performance  report  (AMPR),  and 
OLAF and the EPPO reports. 

1.2.6.  Reporting and monitoring 

Risk analysis underpins effective policy responses at every stage of the anti-fraud cycle. Reliable, 
comparable  data are  essential  to  identify  necessary  measures  and  evaluate their  success.  Data 
availability  depends  on  reporting,  hence  the  Commission’s  emphasis  on  Member  States’ 
compliance with the irregularity and fraud reporting obligation. 

1.3.  Data sources 

This report is based on information provided by the Member States via dedicated questionnaires (9). 
Section 3 draws on  

• 
• 
• 

irregularities detected and reported by the Member States (10); 
irregularities detected and reported by pre-accession assistance beneficiary countries (11); 
recovery orders extracted from the Commission accounting system. 

Sectoral  regulations  on  traditional  own  resources,  shared  management  funds  and  pre-accession 
instruments  set  out  the  conditions  under  which  Member  States  and  pre-accession  assistance 
beneficiary  countries  must  report  detected  irregularities.  Reporting  is  subject  to  certain 
limitations (12). 

(9)  The  questionnaires  are  on  the  measures  taken  by  the  Member  States  to  protect  the  EU’s  financial 

interests and to follow-up the recommendations in the 2024 PIF report.  

(10)  See, in particular, Box 2 of the 2021 PIF Report, Section 6.1, p. 31. 

(11)  Reported to the Commission via the Irregularity Management System (IMS). 

(12)  For a description of these limitations, see Box 3 in the 2021 PIF report, Section 6.1, p. 32. 

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This report categorises the cases reported by the Member States and beneficiary countries into two 
broad types: fraudulent irregularities (13) and non-fraudulent irregularities (14). 

The PIF report refers to the results of investigations by OLAF and the EPPO. Data are sourced 
from the respective annual reports (15) or obtained directly from these bodies (16). 

These data sources have some significant underlying differences in nature, scope, budgetary areas 
covered and timelines (17). 

Figure 2 below illustrates how each data source provides information for each specific stage of the 
anti-fraud cycle. 

Figure 2: How the various data sources feed into the anti-fraud cycle analysis 

Stage of AF cycle 

Data source 

Prevention 

Detection 

Investigation and 
prosecution 

Recovery and 
sanctioning 

Scope 

Policy 

Data on 
results 

Policy 

Data on 
results 

Policy 

Data on 
results 

Policy 

Data on 
results 

Questionnaires  on 
measures  adopted 
by MS and follow-up 
given  to  PIF  reports 
recommendations 

 IMS 

OWNRES 

EPPO 
reports 

annual 

Data  notified  by  the 
EPPO 
the 
to 
Commission 

OLAF annual reports 

Commission 
data 
(SUMMA  and  other 
sources) 

(13)  ‘Fraudulent  irregularities’  are  those  the  reporting  country  has  classified  as  fraud  in  traditional  own 
resources, suspected or established fraud in relation to funds managed under shared  management and 
pre-accession instruments. 

(14)  All irregularities that have not been classified as fraudulent are considered to be non-fraudulent. 

(15)  The OLAF 2025 annual report and the EPPO 2025 annual report differ significantly in nature and scope 
from the PIF report. These differences were extensively explained in Section 1.2 of the 2023 PIF report. 

(16)  In such cases, the source is cited as: ‘Commission calculation based on data provided by OLAF/EPPO’. 

(17)   The reporting workflow from the Member  States and, ultimately, the availability of complete data to 
prepare this report depend heavily on information from the authorities detecting and investigating the 
irregularity or fraud. Reporting bodies in the Member States (mainly managing authorities or paying 
agencies for shared management and customs authorities for traditional own resources) can report on 
criminal investigations only when the relevant judicial or law enforcement authorities provide them with 
the authorisation and the necessary information. This means that, while the EPPO, OLAF or national 
law enforcement are actively investigating a case, the bodies responsible for reporting irregularities and 
fraud to the Commission might not be able to do so in certain cases due to investigations possibly being 
confidential.  In  such  cases,  this  information  will  only  become  available  when  the  investigation  is 
completed and will only be included in the PIF report once this has happened.  

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This year’s report broadens the scope of data by introducing new or more granular indicators. These 
indicators aim to measure the performance of the EU anti-fraud architecture across all stages of the 
anti-fraud  cycle.  Figure  3  lists  and  defines  the  indicators  used  for  each  stage,  along  with  the 
underlying data sources. 

Figure 3: Indicators used in this report by stage of the anti-fraud cycle 

Name of the indicator 

Description of the indicator 

Type of indicator 

Data source 

Number of cases with 
irregular amounts 
prevented from being 
spent 

In a reference period, the total number 
of cases for which a part or the entirety 
of the irregular amounts has not been 
paid (partial or full prevention) 

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

[A.1] 

[A.2] 

[A.3] 

n
o
i
t
n
e
v
e
r
P

Percentage of cases 
with prevention on 
total number of cases 

Calculated dividing indicator [A.1] by the 
total number of cases reported [B.1] in 
the same reference period 

Financial amounts 
prevented from being 
spent 

In a reference period, the total irregular 
financial amounts which have not been 
paid 

[A.4] 

Prevention rate 

Calculated dividing indicator [A.3] on 
total irregular financial amounts [B.2] in 
the same reference period 

[A.5] 

Amount 
recommended for 
prevention 

Total amount recommended for 
prevention as result of OLAF 
investigations 

[A.6] 

Amount prevented  

Same as [A.3] but related to OLAF 
recommendations [A.5] 

[A.7] 

Establishment rate for 
prevention 

Calculated dividing indicator [A.5] on 
indicator [A.6] 

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

Multiannual (reference period 
indicated) 
Sectoral 
Multiannual (reference period 
indicated) 
Sectoral 

Multiannual (reference period 
indicated) 
Sectoral 

IMS 

IMS 

IMS 

IMS 
OLAF / 
Commission 

OLAF / 
Commission 

OLAF / 
Commission 

OLAF / 
Commission 

Name of the indicator 

Description of the indicator 

Type of indicator 

Data source 

[B.1] 

Number of cases of 
irregularities 

In a reference period, the number of 
cases of detected irregularities reported 
by national authorities  

Annual/Multiannual (specified) 
Sectoral 
Total/Fraudulent/non-fraudulent 

OWNRES 
IMS 

[B.2] 

Irregular financial 
amounts 

In a reference period, the irregular 
financial amounts related to the cases 
reported [B.1] 

Annual/Multiannual (specified) 
Sectoral 
Total/Fraudulent/non-fraudulent 

OWNRES 
IMS 

Total detection rate, calculated 
dividing indicator [B.2] on total 
commitment appropriations/payments 
(specified) 

Fraud detection rate, calculated 
dividing indicator [B.2] (referred 
exclusively to fraudulent irregularities) 
on total commitment 
appropriations/payments (specified) 
Irregularity detection rate, calculated 
dividing indicator [B.2] (referred 
exclusively to non-fraudulent 
irregularities) on total commitment 
appropriations/payments (specified) 

Fraud frequency level, calculated 
dividing the number of fraudulent 
irregularities on the total number of 
reported irregularities [B.1] 

Fraud amount level, calculated 
dividing the financial amounts linked to 
fraudulent irregularities on the total 
irregular financial amounts [B.2] 

Annual/Multiannual (specified) 
Sectoral 
Total 

OWNRES 
IMS 

Annual/Multiannual (specified) 
Sectoral 
Fraudulent 

OWNRES 
IMS 

Annual/Multiannual (specified) 
Sectoral 
Non-fraudulent 

OWNRES 
IMS 

Annual/Multiannual (specified) 
Sectoral 
Fraudulent 

OWNRES 
IMS 

Annual/Multiannual (specified) 
Sectoral 
Fraudulent 

OWNRES 
IMS 

[B.3] 

TDR 

n
o
i
t
c
e
t
e
D

[B.4] 

FDR 

[B.5] 

IDR 

[B.6] 

FFL 

[B.7] 

FAL 

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[B.8] 

Number of 
investigations opened 

Number of investigations opened in the 
reporting year by budgetary sector 

Annual 
Sectoral 

[B.9] 

Source of information 
leading to opening 
investigations 

Number of investigations opened in the 
reporting year by type of source of 
information 

Annual 

OLAF 
EPPO 

OLAF 
EPPO 

Name of the indicator 

[C.1] 

Number of ongoing 
investigations/open 
cases 

[C.2] 

Percentage of 
fraudulent cases 
finalised 

[C.3] 

Percentage of closed 
fraudulent cases 
dismissed 

Description of the indicator 
In the reference period, the number of 
investigations ongoing (for the EPPO 
and OLAF) and cases of suspected 
fraud (IRQ3 classification in IMS) 
reported by national authorities still 
open 
Calculated dividing the number of 
fraudulent cases completed (meaning 
dismissed or with established fraud) on 
the total number of cases that have 
been classified (dismissals) or are still 
classified as fraud (suspected or 
established fraud) 

Calculated dividing the number of 
fraudulent cases dismissed on the total 
number of fraudulent cases completed 
(meaning dismissed or with established 
fraud) 

Type of indicator 

Data source 

Multiannual (reference period 
indicated) 
Sectoral 
Fraudulent 

IMS 
OLAF 
EPPO 

Multiannual (reference period 
indicated) 
Sectoral 
Fraudulent 

Multiannual (reference period 
indicated) 
Sectoral 
Fraudulent 

[C.4] 

Percentage of closed 
fraudulent cases 
concluded with 
conviction 

Calculated dividing the number of 
fraudulent cases with established fraud 
on the total number of fraudulent cases 
completed (meaning dismissed or with 
established fraud) 

Multiannual (reference period 
indicated) 
Sectoral 
Fraudulent 

[C.5] 

Number of indictments 

Number of indictments in the reporting 
year 

Annual 
Fraudulent 

[C.6] 

Dismissals 

Number of dismissals in the reporting 
year 

Annual 
Fraudulent 

[C.7] 

[C.8] 

[C.9] 

Simplified prosecution 
procedures 

Number of simplified prosecution 
procedures in the reporting year 

Annual 
Fraudulent 

Number of closed 
investigations 

Number of closed investigations in the 
reporting year 

Annual 
Total 

Number of financial 
recommendations 

[C.10] 

Number of judicial 
recommendations 

Number of financial recommendations 
resulting from closed investigations 
[C.8] in the reporting year 
Number of judicial recommendations 
resulting from closed investigations 
[C.8] in the reporting year 

Annual 
Fraudulent 

Annual 
Fraudulent 

Name of the indicator 

Description of the indicator 

Type of indicator 

Data source 

[D.1] 

Number of closed 
cases with recovery 

[D.2] 

Percentage of total 
number of cases 

[D.3] 

Financial amounts 
recovered 

[D.4] 

Recovery rate 

In the reference period, the number of 
irregularities reported by the Member 
States, closed with financial recovery 
information 

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

Calculated dividing indicator [D.1] by 
the total number of cases reported in 
the same reference period with 
amounts to recover 

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

With reference to cases included in 
[D.1], the total irregular financial 
amounts which have been recovered, or 
withdrawn or corrected 

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

Calculated dividing [D.3] by the total 
amount to be recovered as reported by 
national authorities with reference to 
cases included in [D.1] 
Calculated dividing [D.3] by [D.6] in the 
case of OLAF's financial 
recommendations  

Multiannual (reference period 
indicated) 
Sectoral 
Total/Fraudulent/Non-fraudulent 

IMS 

IMS 

IMS 
OLAF 

IMS 
OLAF 

IMS 

IMS 

IMS 

EPPO 

EPPO 

EPPO 

OLAF 

OLAF 

OLAF 

n
o
i
t
u
c
e
s
o
r
p
d
n
a
n
o
i
t
a
g
i
t
s
e
v
n

I

i

g
n
n
o
i
t
c
n
a
s
d
n
a

y
r
e
v
o
c
e
R

Page 10 

 
  
  
 
 
 
  
  
 
 
 
[D.5] 

Amount recommended 
for recovery 

Financial amount recommended for 
recovery, following OLAF investigations 

[D.6] 

FAER 

Financial amounts established for 
recovery, following Commission action 
based on OLAF financial 
recommendations 

[D.7] 

Number of cases with 
sanctions 

In the reference period, the number of 
irregularities reported by the Member 
States, closed with sanctions imposed 

[D.8] 

[D.9] 

Percentage of 
fraudulent cases with 
sanctions 

Number of specific 
administrative 
recommendations 

Calculated dividing the number of cases 
closed with sanctions [D.7] on the total 
number of cases closed by the Member 
States 

Number of specific administrative 
recommendations aimed at excluding 
economic operators from access to EU 
financing 

Multiannual (reference period 
indicated) 
Sectoral 

Multiannual (reference period 
indicated) 
Sectoral 

Multiannual (reference period 
indicated) 
Sectoral 
Fraudulent/Non-fraudulent 

OLAF / 
Commission 

OLAF / 
Commission 

IMS 

Multiannual 

OLAF / 
Commission 

[D.10] 

Number of final court 
decisions 

Number of cases with a non-appealable 
court decision 

Annual 

[D.11] 

Number of convictions 

Number of cases with a non-appealable 
court decision concluded with conviction 

Annual 

EPPO 

EPPO 

1.4.  Special boxes for key points 

This document uses four types of text box to highlight specific aspects. They are illustrated in 
Figure 4. 

Figure 4: Types of text box used to highlight key aspects 

Methodological 
note

Focus point

Recommendation

Snapshot

Methodological notes explain specific aspects of the dataset underpinning the indicators presented 
in a given section. 

Focus points highlight key findings or implications arising from the preceding analysis. They may 
also indicate potential future action by the Commission. 

Page 11 

 
  
  
 
Snapshots provide supplementary information on a specific topic linked to the section in which 
they appear.  

Recommendations are included in the final section of the report and are addressed to Member 
States, based on the preceding conclusions. 

Page 12 

 
 
 
2.  MAIN  DEVELOPMENTS  IN  THE  PROTECTION  OF  THE  EU’S  FINANCIAL 

INTERESTS IN 2025 

2.1.  Strengthening the legal framework 

2.1.1.  The legislative proposal for the next MFF 

On 16 July 2025, the Commission adopted its first set of legislative proposals for the 2028-2034 
multiannual  financial  framework  (MFF),  followed  by  a  second  set  of  sectoral  proposals  on 
3 September 2025. Together, these proposals create the strategic basis for the EU’s future financial 
programming and prioritisation over the next seven-year budget period. 

The MFF proposal represents an ambitious reform of EU funding, with a budget of nearly EUR 2 
trillion in current prices. The Commission aims to make the framework simpler, more flexible and 
better aligned with local and regional needs. It also introduces a shift towards performance-based 
funding, building on aspects of the Recovery and Resilience Facility (RRF), where Member States 
receive funds subject to achieving predefined milestones and targets set out in their national and 
regional partnership plans. This marks a departure from traditional cost-based funding in favour of 
a result-oriented approach. In addition, the single audit principle places the effective functioning 
of  Member  States’  management  and  control  systems  in  the  center  of  the  protection  of  the  EU 
financial interests. 

The new structure is designed to be more flexible, with the number of budget headings reduced 
from  seven  to  four  and  numerous  existing  programmes  merged  into  larger,  integrated  funds  to 
improve  efficiency  and  synergies.  This  streamlined  and  flexible  approach  should  ease 
administrative burdens, strengthen internal controls, and reduce vulnerabilities.  

The new MFF aims to support reforms that strengthen the rule of law in the Member States and 
requires comprehensive reporting on the final beneficiaries of EU funds. The national and regional 
partnership  plans  align  EU  investments  with  broader  national  reform  agendas,  enhancing 
management,  transparency,  and  sustainability.  The  proposal  supplements  this  approach  with 
mandatory requirements for Member States to report any suspected fraud, corruption, irregularities, 
conflicts of interest or double funding, while adopting comprehensive national anti-fraud strategies, 
based on risk assessments. 

Focus point 1: Need for enhanced administrative capacity and coordination 

The proposal for the regulation establishing the European Fund for economic, social and territorial 
cohesion,  agriculture  and  rural,  fisheries  and  maritime,  prosperity  and  security,  shifts  the 
responsibility for controlling EU funds managed by the Member States to national authorities. The 
performance-based delivery model will require stronger administrative capacity at national level 
and close coordination between the EU and national anti-fraud bodies. 

Page 13 

 
2.1.2.  Review of the anti-fraud architecture 

In July 2025, while presenting the first set of proposals for the next MFF, the Commission adopted 
a White Paper for the anti-fraud architecture (AFA) review (18). The review aims to help increase 
the  coherence,  resilience  and  effectiveness  of  the  EU’s  anti-fraud  framework,  thereby 
strengthening the protection of EU revenue and expenditure. 

The AFA review seeks to modernise the EU anti-fraud landscape in response to key developments, 
including: 

• 

• 

• 

the shift towards performance-based models in the next MFF; 

the  reference  to  the  Anti-Money  Laundering  Authority  (AMLA) (19)  and  the  future 
European  Union  Customs  Authority (20),  as  potential  anti-fraud  actors  within  the  AFA 
alongside existing actors (OLAF, the EPPO, Eurojust and Europol); 

the  evolving  role  of  national  anti-fraud  authorities,  and  authorising  officers  in  the  EU 
institutions in safeguarding the EU budget.  

2.1.2.1.  Key priorities identified in the White Paper 

The review is both timely and necessary given the growing threats posed by organised crime and 
fraudsters exploiting emerging technologies such as artificial intelligence and cryptocurrencies. 

The  White  Paper  outlines  six  priority  themes:  (i)  enhancing  cooperation  and  coordination;  (ii) 
strengthening fraud prevention; (iii) improving detection; (iv) ensuring higher-quality reporting; 
(v) improving investigation and prosecution capabilities; and (vi) streamlining recovery processes. 

A particular focus is placed on harnessing modern technologies, including artificial intelligence, 
across  the  entire  anti-fraud  cycle.  Additionally,  the  review  emphasises  the  need  for  better 
information-sharing, data-sharing and system operability among anti-fraud bodies. 

2.1.2.2.  Sources informing the review 

The review process draws on multiple inputs, including: 

• 

findings from ongoing evaluations of the key legislative acts underpinning EU anti-fraud 
work (21); 

(18) COM (2025) 546 final, 16.07.2025. 

(19)  Regulation (EU) 2024/1620 of the European Parliament and of the Council of 31 May 2024 establishing 
the  Authority for Anti-Money Laundering and Countering the Financing of Terrorism and amending 
Regulations  (EU)  No  1093/2010,  (EU)  No  1094/2010  and  (EU)  No  1095/2010,  OJ  L,  2024/1620, 
19.6.2024. Following the adoption of the AMLA’s regulation on 31 May 2024, the authority was legally 
established on 26 June 2024 and will be fully operational as of 1 January 2028. 

(20)  COM(2023) 258 final. 

(21)  e.g. the founding Regulations of the EPPO and OLAF and the PIF directive. 

Page 14 

 
 
•  positions expressed by the European Parliament and the Council (22); 

• 

• 

reports from the European Court of Auditors (23); 

consultations with EU anti-fraud actors, to gather practical insights into prevention and 
enforcement to protect the EU’s financial interests. 

The  review  process  is  expected  to  culminate  in  a  Commission  communication  by  late  2026, 
potentially accompanied by legislative proposals to amend key acts, including the EPPO and OLAF 
Regulations and the PIF Directive.  

These measures aim to strengthen the EU’s anti-fraud framework in time for the next MFF. 

Snapshot 1: European Court of Auditors’ special report on EU’s anti-fraud bodies 

In 2025, the European Court of Auditors (ECA) published its special report 26/2025 on EU bodies 
fighting fraud, which assessed the key actors involved in the EU anti-fraud architecture, including 
the  EPPO  and  OLAF,  and  how  they  cooperate  in  investigating  fraud.  The  ECA  found  that  the 
responsibilities  of  these  bodies  are  clearly  set  out,  but  the  architecture  would  benefit  from 
improvements  in  terms  of  information  exchange  between  the  EPPO  and  OLAF,  as  well  as  the 
Commission’s  wider  role  in  protecting  the  EU  budget.  The  ECA  recommended  that  the 
Commission to: i) set up a new system to simplify the handling of allegations and investigations; 
ii) analyse variations in the level of fraud reported across the EU; and (iii) measure the impact of 
fraud investigations, including amounts recovered to the EU budget. 

2.1.3.  The anti-corruption package 

2.1.3.1.  Directive on combating corruption 

In December 2025, the Council and the European Parliament reached political agreement on the 
Directive  on  combating  corruption (24),  following  trilogue  negotiations  that  began  in  January 
2025. The Directive was formally adopted in spring 2026 with Member States required to transpose 
it into national law within two years. It introduces three key changes to how corruption offences 
will be addressed across the EU:  

1.  Harmonised  definitions: 

including  bribery, 
misappropriation,  trading  in  influence,  (at  least  certain  serious  violations  involving) 

it  aligns  definitions  of  offences 

(22)   e.g. Report on the protection of the EU’s financial interests  – combating fraud – annual report 2023, 

1 April 2025, European Parliament, Committee on Budgetary Control.  

(23)   e.g. Special report 7/2024 on the Commission’s systems for recovering irregular EU expenditure and 

special report 26/2025 on EU bodies fighting fraud. 

(24)  Directive  (EU)  2026/1021  of  the  European  Parliament  and  of  the  Council  of  29  April  2026  on 
combatting corruption, replacing Council Framework Decision 2003/568/JHA and the Convention on 
the  fight against corruption involving officials of the  European Communities or officials of Member 
States of the European Union and amending Directive (EU) 2017/1371 of the European Parliament and 
of the Council. OJ L, 2026/1021, 11.5.2026. 

Page 15 

 
 
unlawful exercise of public functions, enrichment and concealment, as well as obstruction 
of justice related to corruption offences.  

2.  Stronger penalties and procedural rules: it sets minimum levels of criminal penalties 
(including  imprisonment)  for  natural  and  legal  persons  and  lays  down  minimum  time 
frames for investigating and prosecuting corruption offences, tailored to the gravity of each 
offence, to ensure sufficient time for effective enforcement.  

3. 

 A  stronger  preventive framework:  it  reflects  joint efforts  by  Member  States and  the 
Commission  to  adopt  concrete  measures  to  prevent  corruption  across  the  EU,  such  as 
national anti-corruption strategies.  

The Directive on the fight against fraud to the EU's financial interests by means of criminal law (25) 
has also been amended to align it with this new instrument, particularly on penalties and limitation 
periods and may be further aligned.  

2.1.3.2.  EU network against corruption 

In 2025, the EU network against corruption (26) continued its activities, including: 

• 

• 

a workshop on corruption mitigation measures (June 2025);  

its  third  plenary  meeting  (November  2025),  which  explored  the  link  between 
competitiveness  – a key Commission  priority  – and anti-corruption efforts. Discussions 
focused  on  how  EU  anti-corruption  policy  could  foster  a  more  competitive  business 
environment, attract investment, and promote sustainable economic growth across the EU.  

2.1.3.3.  The EU anti-corruption strategy 

In October 2025, the adoption of the first EU anti-corruption strategy was announced as part of 
the 2026 Commission work programme. The strategy aims to strengthen independent and effective 
judicial systems and to protect and uphold democracy and the rule of law in the EU. 

2.2.  Overview of national measures adopted in 2025 

In  2025,  Member  States  reported  72  measures  to  strengthen  their  anti-fraud  frameworks  and 
protect EU funds. Each country had been asked to report up to three measures, which could be 
legislative, administrative, organisational, or operational in nature. Of the measures reported, 
25  were  packages  of  measures  (12  of  which  combined  multiple  types  of  action),  while  the 
remaining 47 were single measures. Packages of measures consist of multiple measures adopted 
simultaneously having the same objective. 

The measures reported cover all stages of the anti-fraud cycle. As in previous years, the focus in 
2025 remained on the first two stages of the cycle, as shown in Figure 5. 

(25)  Directive (EU) 2017/1371, OJ L198/29, 28.7.2017. 

(26)  https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/democracy-

eu-citizenship-anti-corruption/anti-corruption/eu-network-against-corruption_en. 

Page 16 

 
 
Figure 5: Measures reported by Member States by stage of the anti-fraud cycle addressed 

• 57 

measures 
(79%)

• 48 

measures 
(67%)

Prevention

Detection

Recovery 
and 
sactioning

Investigation 
and 
prosecution

• 21 

measures 
(29%)

• 26 

measures 
(36%)

Note: a measure can target more than one stage. Out of 72 measures reported, 18 targeted one 
stage, 36 two stages, 10 three stages, and 8 all four stages of the anti-fraud cycle. 

The measures also targeted fraud risks in different vulnerable areas, with some addressing several 
areas at once. The most frequently targeted area in 2025 was ‘shared management and control 
of  the  EU  funds’  (mentioned  in  37  measures).  Around  one  in  three  measures  also  addressed 
‘conflicts of interest’ or ‘antifraud and anticorruption strategies’ (see Figure 6). 

Figure 6: Areas targeted in 2025 

 Shared Management and Control of the EU Funds
 Conflict of Interest
 Antifraud or Anticorruption Strategy
 Public Procurement
 Corruption
 Financial Crime (Including Money Laundering)
 Organised Crime
 Whistleblower
 Other
 Fraud Definition
 AFCOS
 Customs/Tor/Illicit Trade

36

26

24

22

21
21

16

11
11

9

7

6

0

5

10

15

20

25

30

35

40

Number of mentions (total=210)

Note: one measure may target multiple areas. Of 72 measures reported, 22 targeted one area, 17 two areas, 
13 three areas, 9 four areas, 1 five areas, 6 six areas, 1 seven areas, 1 eight areas and 1 nine areas, and 2 
ten areas. 

Measures may apply horizontally (across all EU budget sectors) or sectorally (targeting specific 
sectors). Member States reported measures in both categories. 

Page 17 

 
  
 
Based on Member States’ input, two key trends emerged in 2025: early detection and exclusion 
and capacity-building activities. These trends reinforced the continued emphasis on prevention 
and detection.   

Snapshot 2: Focus areas enhancing fraud prevention and detection 

Member States reported 17 measures targeting (i) early detection and exclusion; and (ii) capacity 
building (27). These measures place strong emphasis on prevention.  

(i) Early detection and exclusion 

Member States reported multiple measures focusing on early detection of ‘unreliable’ entities and 
their exclusion from further procedures. This might include counterparts previously  involved in 
fraudulent or irregular activities or failing to disclose conflicts of interest. Beyond reducing fraud 
risks, this approach optimises resource allocation. An overview of these measures is provided in 
Table 1 of Annex 3. 

(ii) Training and capacity building 

Member States continued efforts to raise awareness and  improve skills among staff involved in 
anti-fraud actions. Through training and guidelines, they ensure that staff are familiar with current 
fraud  risks,  systems  and  procedures,  so that  they  can  respond  effectively  to  cases  of  fraud  and 
irregularities  (see  Table  2  of  Annex  3).  Additional  measures  include  IT  systems  training  and 
technical guidelines. 

A third focus area in 2025 was information exchange management, with measures to streamline 
information and data flows and harmonise reporting practices. 

Snapshot 3: Focus area – Information exchange management 

Member  States  reported  15  measures  in  this  area (28).  Effective  data  management  remains  a 
priority,  with  approaches  varying  but  sharing  a  common  goal:  improving  data  processing  and 
accessibility.  

Measures shown in Table 3 of Annex 3 include: (i) guidelines, checklists and common reporting 
standards;  (ii)  designating  dedicated  bodies  and  reallocating  fraud-related  responsibilities;  (iii) 
updating and upgrading data systems; and (iv) creating dedicated databases. 

Accessibility and quality of collected data are key for robust analytical work. Common practices 
in data collection and data formats help improve data quality and increase data usability. In 2025, 
many Member States reported taking measures to improve the quality of and access to data, thereby 
strengthening their other anti-fraud efforts. 

Additionally,  five  Member  States  reported  on  changes  to  administrative  structures  to  facilitate 
information  flows  and  more  clearly  divide  responsibilities  in  the  anti-fraud  domain.  Reported 
examples  (see  Table  4  of  Annex  3)  show  new  bodies  or  units  to  being  created  to  consolidate 
powers  in  various  anti-fraud  fields and  dedicated  responsible  bodies  being  set  up  to  streamline 
communication with other national and EU-level counterparts and benefit from the knowledge of 
highly specialised staff. 

(27)  For a description of the related measures, see Sections 1.1 and .1.3 of the SWD ‘Measures adopted by 
Member  States  to  protect  the  EU’s  financial  interests  -  implementation  of  Article 325  TFEU’, 
accompanying this report. 

(28)  See Section 1.2 of the SWD ‘Measures adopted by Member States to protect the EU’s financial interests 

- implementation of Article 325 TFEU’, accompanying this report. 

Page 18 

 
 
2.3.  Strengthening the governance and coordination of the fight against fraud 

2.3.1.  Implementation of the action plan accompanying the Commission anti-fraud 

strategy 

A  key  instrument  for  the  Commission’s  sustained  approach  to  fraud  prevention,  detection  and 
correction – the Commission anti-fraud strategy (CAFS) and its 2023 accompanying action plan 
– continued to be actively implemented throughout 2025. The plan includes 44 actions under seven 
themes  that  cover  the  Commission’s  priorities  in  fighting  fraud. OLAF,  as  the  lead  service, 
monitored and coordinated the implementation of the plan (29).  

Themes 2 (Support Member States to reinforce the protection of the RRF, cohesion, agriculture 
and fisheries funds), 5 (Reinforce the anti-fraud architecture) and 6 (Reinforce the Commission's 
anti-fraud governance) mainly help strengthen the governance and coordination of the fight against 
fraud. 

Under the second theme, the Commission continued to provide targeted support to Member States 
on anti-fraud topics. The revised Handbook on reporting irregularities was adopted in September 
2025, following discussions with Member States. 

To reinforce the EU anti-fraud architecture (fifth theme) the Commission stepped up cooperation 
with the EPPO on the administrative follow-up of the EPPO cases. OLAF has continued to deliver 
training courses and presentations on ethics and anti-fraud matters to decentralised agencies and 
joint undertakings.  

On cooperation among Commission departments and executive agencies (sixth theme), in 2025, 
OLAF reviewed 15 service-level strategies and continued sharing the latest developments in anti-
fraud policy within the fraud prevention and detection network. 

The action plan is expected to be implemented until end of 2026. OLAF will evaluate the results 
and assess the need for a new anti-fraud strategy or action plan, and possible changes in the way 
the Commission and the EU deal with fraud risks. This process of reflection will notably consider 
the results of the review of the EU’s anti-fraud architecture and the ECA special report 18/2026 of 
18 June 2026 on the CAFS. 

2.3.2.  National anti-fraud strategies 

Another  key  element  of  governance  is  the  adoption  of  dedicated  strategies  to  counter  fraud 
affecting the EU’s financial interests. Over the years, the Commission has supported the adoption 
of national anti-fraud strategies (NAFS)devised by the key national level of the AFA. Currently, 
there is no legal obligation for Member States to have a NAFS. However, the Commission included 
the adoption of comprehensive NAFS, based on a risk assessment, among the key requirements for 
Member  States’  management,  control  and  audit  systems  in  the  proposal  for  the  regulation 
establishing the European Fund for economic, social and territorial cohesion, agriculture and rural, 
fisheries and maritime, prosperity and security for the period 2028-2034 (30). 

(29)  See the ‘Commission anti-fraud strategy (CAFS) action plan implementation monitoring: state-of-play 

31 May 2026’, accompanying this report. 

(30)  COM(2025) 565 final, Annex IV. Last year’s report reiterated the recommendation to Member States to 

have in place NAFS. 

Page 19 

 
 
In 2025, 25 Member States indicated that they had anti-fraud strategies in place for the protection 
of the EU’s financial interests. The approach taken by the Member States varied widely though as 
regards the scope of these strategies. 

A total of 10 Member States indicated that they have a NAFS in place addressing at least fraud 
against EU funds (31) and 8 Member States (32) are in the process of adopting one. However,  9 
Member  States (33)  declared  having  neither  a  national  anti-fraud  strategy  to  protect  the  EU’s 
financial interests nor an ongoing procedure to adopt one (Figure 7).  

No Member State adopted new NAFS in 2025. 

Figure 7: Overview of the NAFS reported by Member States (34) 

Year when NAFS 
was adopted 

Period covered by 
current NAFS 

Date of last 
update to NAFS 

NAFS is 'planned' 
or 'ongoing' 

(31)  These are the same NAFS reported in 2024, therefore the qualitative assessment in the 2024 PIF report 

(SWD(2025)229 final) remains valid. Cyprus adopted its NAFS on 29 May 2026. 

(32)  Belgium, Denmark, Germany, Ireland, Spain, Cyprus, Luxembourg and Netherlands. Cyprus adopted 

its NAFS on 29 May 2026. 

(33)  Estonia, Greece, Croatia, Lithuania, Austria, Poland, Slovenia, Finland and Sweden. 

(34)  The period covered by Malta’ NAFS was extended to 2026. Slovakia is currently updating its NAFS, 

which was initially set up for the 2014-2020 period. 

Page 20 

ATBE2020BGHRCY20082024CZDKEEFI20222025FRDEEL20222024HUIE2024IT2024LVLTLU20212023MTNLPL20232025PT2023RO20152019SKSIESSE|------|200820092010-20142015201620272017201820192020202120222023202420252026 
 
   
   
   
 
22 out of 27 Member States indicated that they had other types of anti-fraud strategy in place to 
protect the EU’s financial interests, as presented in Figure 8. Of the other 5 Member States, 3 have 
a NAFS in place, while the remaining 2 (35) did not declare having any anti-fraud strategy. 

Figure 8: Overview of other types of anti-fraud strategy reported by Member States 

AT 

BE 

BG 

HR 

CY 

CZ 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

Regional AFS 

Sectoral 
national 
strategy 

Sectoral 
regional AFS + 
anti-corruption 
strategy 

Authority level 
AFS 

Programme level 
AFS 

Other 

The main reason for adopting a NAFS cited by Member States was the legal obligation to protect 
the EU’s financial interests under Article 325 TFEU. One Member State (36) developed its NAFS 
specifically  as  part  of  commitments  under  the  EU’s  conditionality  procedure.  Other  reasons 
mentioned included: (i) the need for a coherent and coordinated policy framework to combat fraud 
affecting the EU budget; (ii) strengthening cooperation among national authorities responsible for 
managing EU funds; and (iii) creating structured mechanisms to address systemic risks. 

(35)  Lithuania and Sweden. 

(36)  Hungary. 

Page 21 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
Member States identified several key benefits of NAFS:  

•  better cooperation, communication and coordination among national anti-fraud actors; 
• 
consolidation of the anti-fraud architecture, particularly within the AFCOS network; 
•  better governance by clearly setting out responsibilities and procedures; 
• 
• 
• 
•  greater  transparency  of  anti-fraud  efforts  and  accountability  in  fund  management 

clearer legal and regulatory framework; 
a more structured and systematic approach to fraud prevention and detection;  
effective and coordinated implementation of anti-fraud measures; 

processes; 
stronger institutional capacities through targeted capacity-building measures. 

• 

By contrast, the reasons for not adopting a NAFS mentioned by some Member States included 
having  key  anti-fraud  elements  already  embedded  in  existing  national  systems,  procedures  and 
other anti-fraud strategies in place at national level, lack of added value or lack of political decision. 
Three Member States (37) reported legislative barriers as the main obstacle to adopting a NAFS, 
while two (38) cited resource-related issues and one (39) mentioned institutional factors. 

2.4.  Enhancing anti-fraud frameworks: A review of member states’ progress 

on reporting and digitalisation 

2.4.1.  Member  State  actions:  follow-up  to  the  recommendation  in  the  2024  PIF 

report 

The  2024  PIF  report contained  four recommendations (40).  The  first two  were  on  strengthening 
reporting and communication channels, specifically by: (i) reducing the reporting gap in relation 
to suspected fraud and irregularities; and (ii) setting up more effective communication channels, 
by identifying and addressing existing loopholes in the information flow for suspected fraud cases, 
from  initial  reporting  to  the  Commission  through  to  follow-up.  The  third  recommendation 
concerned the adoption of national anti-fraud strategies (already covered in  Section 2.3.2). The 
fourth  recommendation  addressed  digitalisation  as  a  pillar  of  the  NAFS  with  the  aim  of:  (a) 
assessing the level of threat posed to the EU budget by the rise in cybercrime and in the use of AI 
and other innovative technologies, in particular by organised crime groups; (b) identifying Member 
States’ knowledge and skills gaps in relation to the deploying, developing and using innovative 
technologies to combat fraud more effectively; and (c) identifying the measures needed to mitigate 
those threats and vulnerabilities. 

(37)  Greece, Lithuania and Slovenia. 

(38)  Finland and Sweden. 

(39)  Slovenia. 

(40)  See  2024 PIF report, Section 5. The replies  from  Member States to recommendations 1, 2 and 4  are 
included in the SWD ‘Follow-up on recommendations to the Commission report on the protection of the 
EU’s  financial  interests  and  the  fight  against  fraud  –  2024’.  The  replies  to  recommendation  3  are 
included in the SWD ‘National anti-fraud strategies (NAFS) state of play and assessment’. 

Page 22 

 
 
2.4.1.1. 

 Improved reporting and more effective communication channels 

Improved reporting 

Member  States  show  greater  confidence  in  their  anti-fraud  reporting  systems.  In  2024  11 
Member States identified no significant gaps in their reporting, while their number rose to 18 in 
2025,  a  trend  that  may  reflect  improvements  in  national  reporting  mechanisms,  heightened 
awareness of obligations, or increased trust in existing systems. Nevertheless, caution is warranted, 
as these findings are based on Member States’ self-assessments. 

Prevention  remains  the  primary  focus  of  national  anti-fraud  efforts,  followed  by  detection. 
Twenty-four  Member  States  prioritised  prevention,  while  the  remaining  three (41)  focused  on 
detection. 

On  staff  knowledge  and training  on the  Irregularity Management  System (IMS),  most Member 
States rely on OLAF or Commission materials (22 Member States), regular training sessions (20), 
liaison officers or trainers in contact with OLAF (18), and national guidance or manuals (17). 

Overall, responses indicate a strong commitment to anti-fraud reporting, characterised by: (i) a 
prevention-led approach, (ii) extensive use of training, (iii) growing reliance on risk assessment, 
and (iv) better  coordination through AFCOS and IMS support structures.  However, closing the 
reporting  gap  depends  not  only  on  legal  obligations,  but  also  on  operational  consistency,  staff 
capacity, inter-agency coordination, and systematic quality control of reporting data. 

Snapshot 4: Best practices to improve reporting 

The most transferable best practices mentioned by Member States include:  

• 

• 

• 

regular fraud risk self-assessment; 

comprehensive staff training and onboarding for IMS reporting; 

clear allocation of tasks and referral pathways; 

•  use of red flags, data tools and integrated checks; 

•  national coordination mechanisms and working groups; 

• 

effectiveness measurement combining audits, risks, cases and recoveries. 

Key  takeaway:  closing  the  reporting  gap  requires  more  than  legal  compliance.  It  demands 
operational consistency, staff skills, coordination and systematic data-quality checks. 

Information flow and communication channels 

Most Member States have formal or semi-formal arrangements to facilitate information-sharing 
between reporting and judicial authorities, including: 

central contact points or single points of contact;  
reporting guidelines and manuals; 
cooperation protocols or memoranda of understanding; 
regular inter-agency meetings; 

• 
• 
• 
• 
•  direct email exchanges; and  
•  dedicated AFCOS coordination structures. 

Regular meetings are the most widely used coordination method (reported by 25 Member States). 
IMS is also widely used as a coordination tool, with 22 Member States referring to its use in this 
context. Encrypted email is used by 15 Member States. Among the 16 Member States using secure 

(41)  Bulgaria, Denmark and Luxembourg. 

Page 23 

 
 
online  platforms  or  shared  case-management  systems,  14  rely  on  them  as  their  primary 
communication tool. 

Operational weaknesses 

The  main  challenge  identified  is  timely  access  to  information  from  investigative  and  judicial 
authorities  (e.g.  prosecutors,  police,  the  EPPO  or  courts),  in  particular  on  updates  on  ongoing 
criminal  proceedings  (especially  where  criminal  proceedings  are  prolonged  or  subject  to 
confidentiality  requirements)  and  final  judicial  outcomes.  Member  States  repeatedly  reported 
difficulties in obtaining the information needed to complete or update IMS entries, especially for 
sanctions,  fraud  classification,  modus  operandi,  recovery  amounts,  and  judicial  status  and 
outcomes. 

Several Member States also referred to structural limitations linked to the EPPO Regulation, where 
AFCOS does not always receive operational information directly, confirming a pattern previously 
identified in the 2024 PIF report. 

Cooperation with national administrative bodies appears to function relatively smoothly, with 24 
Member States reporting no issues. Cooperation with investigative bodies was assessed to be less 
uniform: 18 Member States reported no issues, 7 reported minor issues and 2 (42) reported serious 
issues. This suggests that the principal challenge lies not in administrative coordination as such, 
but in access to follow-up information from investigative and judicial authorities once a case enters 
the criminal justice chain. 

Conclusion 

The  effectiveness  of  communication  channels  depends  less  on  creating  new  reporting  channels 
than  on  structured  governance,  routine  coordination  and  reliable  mechanisms  for  follow-up, 
particularly  between  administrative  and  judicial  actors.  The  core  challenge  remains  ensuring 
continuous  information  flow  after  a  case  reaches  the  courts,  so  that  administrative  reporting 
remains timely, complete and accurate. 

Snapshot 5:Best practices for effective communication channels 

The most transferable best practices mentioned by Member States include:  

• 

• 

• 

formal cooperation agreements and written referral/update procedures,  

regular multi-authority meetings and AFCOS-led coordination,  

clear case ownership and periodic follow-up reviews,  

•  national case-management systems feeding into IMS,  

•  pragmatic confidentiality arrangements (e.g. need-to-know access and staged reporting),  

•  designated contact points and liaison structures, and  

• 

continuous quality control of IMS data.  

Key takeaway: improving communication is less about creating one new channel and more about 
ensuring that information continues to flow seamlessly, even after a case enters the judicial phase, 
to maintain timely, complete and accurate reporting. 

(42)  Spain and Cyprus. 

Page 24 

 
 
2.4.1.2.  Digitalisation and AI 

Digitalisation  remains  a  key  component  of  anti-fraud  efforts  across  Member  States,  though 
implementation varies significantly and is often approached cautiously.  

Use of AI  

Most Member States (21) reported not using AI tools in their anti-fraud strategies. Three Member 
States (43) confirmed AI was integrated into their national anti-fraud strategy, while 6 (44) use it in 
other anti-fraud frameworks. 

Where applied, AI is primarily used for anomaly detection and predictive analytics, aligning with 
the broader prevention and detection focus within the anti-fraud cycle.  

The  examples  provided  by  Member  States  include:  (i)  machine-learning  tools  for  anomaly 
detection and risk analysis in agriculture and customs; (ii) tools supporting audits and the prediction 
of  irregularities;  (iii)  text-processing  and transcription  assistance;  (iv)  risk  scoring  and  network 
analysis applications; and (v) automated invoice verification. 

Overall, AI adoption remains at an exploratory stage and is often sector-specific rather than fully 
integrated into national systems. 

Assessment of cyber-threats and AI-related threats 

Progress in this area has been limited: 

•  3 Member States (45) conducted a comprehensive assessment in 2025; 

•  8 (46) performed a partial assessment;  

•  15 reported no assessment and no plans to conduct one; 

•  1 indicated that an assessment was planned.  

This  suggests  that  the  recommendation  to  assess  cyberthreats  and  AI-related  threats  is  only 
beginning to be reflected in national practice. 

Future digitalisation priorities 

Member States intend to focus on: 

• 

• 

• 

stronger interoperability between systems; 

 expanded use of Arachne and the future Arachne+; 

improved risk-analysis tools; 

•  better data integration; 

•  possible use of AI applications (e.g. for anomaly detection or complaint analysis); and 

•  digital platforms to support transparency and case management. 

(43)  Czechia, Italy and Portugal. 

(44)  Belgium, Spain, France, Italy, Hungary and Slovenia. 

(45)  Czechia, Luxembourg and Sweden. 

(46)  Belgium, Estonia, Ireland, Spain, Latvia, Malta, Austria and Slovakia. 

Page 25 

 
 
Snapshot 6: Best practices in digitalisation 

Member  States  increasingly  recognise  digitalisation  as  essential  to  anti-fraud  policy,  but 
implementation  remains  uneven,  fragmented  and  hindered  by  interoperability  issues,  legal 
uncertainty and budget constraints.  

Most easily transferable best practices include: 

•  embedding digitalisation in anti-fraud strategies; 

• 

improving interoperability between national systems and EU tools; 

•  deploying AI in a targeted, secure and risk-based manner; 

•  combining digital outputs with human analysis and operational follow-up; 

•  clarifying legal and data protection frameworks; and  

• 

investing in training and technical support. 

Key takeaway: Digitalisation is most effective when supported by: (i) usable, high-quality data; 
(ii)  interoperable  systems;  (iii)  legal  certainty;  (iv)  skilled  staff;  and  (v)  integration  into  daily 
control workflows. 

Use of Arachne by the Member States – state of play 

In 2024, 22 Member States used Arachne as part of their anti-fraud strategies; this increased slightly 
to 23 in 2025. However, usage varies significantly. The tool is not simply ‘used’ or ‘not used’, but 
often only partially integrated. For example, data may cover only certain funds, uploads may be 
manual or provided only to a limited extent. Thus, while uptake is broad, depth and quality of use 
differ considerably. 

The reasons for partial implementation are: (i) technical limitations (8 Member States), (ii) strategic 
decisions to provide only the minimum dataset (7 Member States), and (iii)  egal constraints (6 
Member States). This suggests that partial integration is often a  pragmatic compromise rather 
than a rejection of the tool itself. 

Interoperability  with  national  data-analysis  tools  remains  limited.  Where  it  exists, 
interoperability is generally assessed as medium to high, but few Member States have achieved it. 
In  practice,  many  systems  still  rely  on  XML  exports,  manual  uploads,  or  data  extraction  from 
national systems into Arachne, rather than on automated interoperability. 

Snapshot 7: Barriers to digitalisation 

The  2024  analysis  identified  interoperability  problems,  legal  barriers,  and  data-protection  or 
security  concerns  as  the  main  obstacles  to  digitalisation.  This  year’s  responses  confirm  these 
findings,  with  the  three  most  significant  barriers  being  interoperability  challenges  (19  Member 
States), budget constraints (16 Member States), and data protection concerns or other legal issues 
(12 Member States). 

These results indicate that the primary obstacles are structural and organisational, rather than 
conceptual.  Qualitative  responses  confirm  this  conclusion,  highlighting:  (i)  poor  system 
compatibility;  (ii)  uneven  data  quality  and  access;  (iii)  fragmented  institutional  arrangements 
slowing digital progress; (iv) legal and privacy frameworks complicating automated data use; and 
(v) rigid and costly legacy applications. 

Member  States  that  are  more  advanced  in  this  area  emphasised  the  need  for  interoperability, 
common data standards, and stronger support from the Commission and OLAF. 

Page 26 

 
2.5.  Implementation of the EU anti-fraud programme 

The Union anti-fraud programme (UAFP), with a budget of EUR 181.7 million for the 2021-2027 
programming period, serves as a strategic financial instrument designed to increase the integrity of 
the EU’s budget through its three components (47): 

(i) protection of the EU’s financial interests by Member States (‘anti-fraud measures’);  
(ii) organisation of mutual administrative assistance and cooperation in customs and agricultural 
matters (Anti-Fraud Information System – AFIS); and  
(iii) development and maintenance of the IMS for the reporting of irregularities by Member States. 

The 2025 financing decision allocated EUR 17.6 million to the first component, EUR 8.7 million 
to the AFIS component and over EUR 1 million to the IMS component. The available funds for 
2025 were successfully implemented using the various financing instruments available, such as 
grants and procurement.  

For  the  first  component,  the  focus  was  on  financing  projects  (through  grants)  linked  to  the 
expenditure side of the EU budget and on digitalisation, IT development and the integration of AI 
in the fight against fraud by Member States. The two calls for proposals that were launched in 2025 
(with a total budget of EUR 12.4 million) saw a high demand for financing (over four times higher 
than  the  available  budget) and  participation  by  most Member  States  (151  applications  from  16 
Member  States  and  2  applications  from  Ukraine,  the  only  third  country  associated  to  the 
programme so far). Notably, around 25% of all received proposals targeted the financing of data 
analytics technology and IT tools.  

Procured activities under the 2025 budget of the programme, totalling around EUR 3.9 million, 
focused  on  enhancing  the  technical  capabilities  of  Member  State  authorities.  Key  deliverables 
included specialised anti-fraud conferences, digital forensic analyst training, and the provision of 
access to data from commercial databases and to customs analysis tools.  

(47)  For  a full description  of  the  implementation  of  the  UAFP  in  2025  see  SWD  ‘Annual  overview  with 

information on the results of the Union anti-fraud programme in 2025’. 

Page 27 

 
 
 
 
3.  A  HOLISTIC  VIEW  OF  THE  FIGHT  AGAINST  FRAUD  AFFECTING  THE  EU’S 

FINANCIAL INTERESTS 

Section 1.2 outlined the anti-fraud cycle and the importance of addressing its four stages to ensure 
an adequate protection of the EU’s financial interests. This section builds on new analyses and data 
to present specific indicators for measuring the results of the measures taken by AFA actors at 
both EU and national level. 

It begins with an overall assessment of the different stages of the anti-fraud cycle, providing a 
comprehensive overview of the protection of the EU financial interests.  The second part of the 
section offers a narrative analysis relating to the various EU budget areas. 

Methodological note 1: Data availability to cover all indicators 

In line with the holistic approach, intended to cover the entire anti-fraud cycle, the Commission 
aims to present specific metrics to assess the impact of different actors and track progress. This 
year’s report marks a first step in this direction and helps identify data needs and gaps. 

The subsections below do not follow the traditional sequence of the anti-fraud cycle (prevention, 
detection, investigation and prosecution, recovery and sanctioning), as  no data exist on ‘pure’ 
prevention. The available data instead allow ‘early detection’ to be measured, which is therefore 
presented after the ‘detection’ stage. 

A  second  consideration  is  that  data  or  analyses  do  not  cover  all  budgetary  areas  uniformly. 
Consequently, the level of granularity in the data and analysis may vary across subsections. 

3.1.  The protection of the EU’s financial interests through the anti-fraud cycle 

3.1.1.  Detection 

The ability of management and control systems to detect irregularities and fraud affecting the 
EU’s financial interests is crucial to ensuring an adequate level of protection. Detection enables 
necessary  follow-up  measures,  including  referring  suspected  fraud  cases  to  the  competent 
authorities (prosecution services and law enforcement) and initiating administrative procedures to 
establish amounts for financial corrections or recoveries. 

Methodological note 2: Defining and measuring detection 

Sector-specific regulations require national authorities (in customs, shared management and pre-
accession) to report to the Commission ‘irregularities that have been the subject of a first written 
assessment by a competent authority, either administrative or judicial, which has concluded on the 
basis of specific facts that an irregularity has been committed’ and ‘irregularities that give rise to 
the initiation of administrative or judicial proceedings at national level in order to establish the 
presence of fraud or other criminal offences […]’(48). 

Data  on  detected  irregularities  (both  fraudulent  and  non-fraudulent)  are  reported  by  national 
authorities via IMS and OWNRES. They do not capture all detection activities because of specific 
derogations in the sectoral regulations (49). 

(48)  The quoted text is from Annex XII of Regulation (EU) 2021/1060. Similar provisions are contained in 

the different sectoral regulations on the reporting of irregularities to the Commission. 

(49)  First of all, the threshold of EUR 10 000 of EU funds applies. Additional derogations are presented in 

methodological note 3. 

Page 28 

 
 
Furthermore, detected cases in relation to the RRF and VAT-fraud are not subject to mandatory 
reporting to the Commission (50) (see Sections 3.2.3 and 3.3.1).  

In  2025,  a  total  of  13 010  irregularities  (both  fraudulent  and  non-fraudulent),  amounting  to 
EUR 2.1 billion were recorded (51). Compared with 2024, this represents a slight decrease in the 
number  of  reported  irregularities  (-7.6%),  while  the  related  irregular  amounts  increased 
(+12.8%) (52). The number of fraudulent irregularities remained relatively stable between 2020 and 
2023 but significantly increased in 2024 to 1 456 and fell to 986 in 2025 (-32% on 2024). This 
represents  7.6%  of  the  total  number  of  reported  irregularities.  There  was  more  variation  in  the 
financial amounts linked to these cases due to a few individual cases with high financial impact. 
The figure fell to EUR 274.3 million in 2025 (-49.2% on 2024), confirming the volatility of this 
indicator.  

Figure 9: Irregularities reported and related financial amounts – 2021-2025 (OWNRES, IMS 
and the Commission’s accounting system) 

s
n
o

i
l
l
i

M

11.283

11.989

12.752

12.625

12.024

14.000

12.000

10.000

8.000

6.000

4.000

s
e
s
a
c

f
o
°
N

2.000

1.077

1.129

1.101

1.456

986

0

2021

2022

2023

2024

2025

2.500

2.000

1.500

1.000

500

0

s
t
n
u
o
m
a
r
a
u
g
e
r
r
I

l

Fraudulent - Irregular amounts (in EUR million)

Non-fradulent - Irregular amounts (in EUR million)

Fraudulent - N° of cases

Non-fraudulent - N° of cases

By contrast, non-fraudulent irregularities followed an upward trend from 2020 to 2023, in line with 
the  expected  spending  programme  cycles.  After  stabilising  in  2024,  the  number  of  these 
irregularities decreased slightly in 2025 with 12 024 cases reported (-4.8% on 2024). However, the 
financial  amounts  involved  increased  to  EUR 1.82  billion  (+38.2%  on  2024).  Compared  to  the 
average for the last five years, the number of non-fraudulent irregularities reported in 2025 was 1% 
lower, while the financial value was 28.2% higher. 

(50)  Member States remain under the obligation to report suspected fraud cases to the competent investigative 
authorities,  such  as  the  EPPO  and  OLAF  and  to  keep  relevant  records  for  five  years,  as  per  Article 
11(1)(d) of the RRF financing agreement. 

(51)  Irregularities relating to expenditure were reported by Member States and non-EU countries in IMS and 
irregularities  relating  to  traditional  own  resources  in  OWNRES.  Irregularities  related  to  direct 
management are extracted from the Commission’s accounting system. 

(52)  This increase is mainly due to non-fraudulent irregularities reported in traditional own resources. For 

most expenditure sectors there was a decrease, except agriculture and internal policies.  

Page 29 

 
 
 
 
 
Figure 10: Summary indicators for detection - 2025 

Cases detected and reported - 2025 

Total irregularities 
EUR 
(million) 
824.7 
1 271.1 

N 
4 390 
8 620 

TDR 
2.68% 
0.72% 

7 821 

1 174 

0.90% 

4 272 

3 489 

60 

358 

441 

264.5 

899.2 

10.1 

11.0 

86.3 

0.46% 

1.37% 

0.13% 

0.07% 

0.28% 

Fraudulent irregularities 
EUR 
(million) 
85.4 
188.8 

FAL 
10.4% 
14.9% 

FFL 
6.5% 
8.1% 

Non-fraudulent 
irregularities 
EUR 
(million) 
N 
4 105 
739.3 
7 919  1 082.3 

IDR 
2.41% 
0.61% 

FDR 
0.28% 
0.11% 

183 

8.2% 

15.6% 

0.14% 

7 181 

991 

0.76% 

21.8 

160.6 

0.3 

0.6 

5.5 

6.9% 

9.7% 

13.3% 

8.1% 

7.3% 

8.2% 

17.9% 

3.2% 

5.4% 

6.4% 

0.04% 

0.24% 

3 977 

3 152 

0.004% 

52 

0.00% 

0.02% 

329 

409 

242.7 

738.6 

9.8 

10.4 

80.8 

0.42% 

1.13% 

0.13% 

0.06% 

0.26% 

N 
285 
701 

640 

295 

337 

8 

29 

32 

NB: TDR, FDR and IDR are calculated on the relevant commitment appropriations as 
indicated in the overview table of the MFF ceilings of the 2025 budget published on OJ L 
2025/31, 27.2.2025, p. 14. For the full description and definition of the various indicators, 
see section 1.2, Figure 2. 

Budgetary sector 

Revenue (TOR) 
Expenditure 

Shared management 

Agriculture 

Cohesion and Fisheries 

Other shared management 

Indirect management - Neighbourhood and the World 

Direct expenditure 

Data sources 

Data from OWNRES 
Data from IMS 
Data from the Commission's accounting system 

Page 30 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
 
EU investigative bodies also contribute to the detection efforts shown in Figures 10 and 11. They 
rely on reports and information from third parties (public or private) to initiate their investigations 
but can also open investigations on their own initiative. This was also the practice before the EPPO 
began to operate, when national prosecution services and law enforcement were the addressees of 
these reports and information.  

Figure 11: Investigations opened by EU bodies in 2025 by budgetary sector 

Budgetary Sector 
Customs (own resources) 

Shared management 

Indirect management 

Direct management 

Recovery and resilience facility 

Other 

Unidentified 

TOTAL 

Investigations opened in 2025 

OLAF* 

EPPO** 

58 

66 

24 

47 

31 

33 

180 

465 

13 

38 

264 

194 

586 

254 

1 740 

* Source: OLAF annual report 2025 - The sum may not correspond to the total, as one investigation may relate to more than one budgetary sector 

** Commission calculation on data provided by the EPPO. 290 VAT investigations by the EPPO are not included in the table.'Other' in the EPPO 
column includes 13 cases related to RRF and shared management 

If VAT and RRF as reported by the EPPO are excluded from the analysis, for the main budgetary 
sectors,  the  number  of  investigations  opened  by  the EPPO  in  2025  is  similar  to  the  number  of 
fraudulent cases shown in Figure 9. 

As already mentioned, suspected RRF and VAT fraud are not part of the mandatory reporting for 
the Member States (53) - see Sections 3.2.3 and 3.3.1. 

Figure 12: Investigations opened by EU bodies in 2025 by source of information 

Sources of information 

Investigations opened in 2025 
OLAF  

EPPO* 

IBOAs 
National authorities 
Private parties 
Own initiative/ex officio 
Other 
TOTAL 

* The total in Figure 12 differs from the total in Figure 11 as it includes VAT investigations. 

89 
5 
79 
65 
16 
254 

102 
1 661 
208 
59 

2 030 

(53)  For  RRF,  it  does  not  exist  for  Member  States  the  obligation  to  inform  the  Commission  of  detected 
irregularities and fraud, as in shared management. However, Member States remain under the obligation 
to report suspected fraud cases to the competent authorities, such as the EPPO and OLAF, and to keep 
records for five years, as per Article 11(1)(d) of the RRF financing agreement. 

 
 
  
  
 
Focus point 2: Overall detection is stable with sectoral differences 

Overall, detection was fairly stable and continual over time (see Figure 9), with relatively small 
variations. When looking at individual budgetary areas, however, the situation is more complex. 
This  is  because  other  factors  come  into  play,  such  as  the  multiannual  nature  of  spending 
programming cycles or specific situations (for example, the COVID-19 crisis hampered on-the-
spot  checks  and  significantly  affected  trade  in  the  relevant  period).  Furthermore,  certain  legal 
constraints, such as the lack of available data from the Member States on RRF (54) and VAT fraud, 
mean that a complete picture cannot be presented and the data reported by the Member States, the 
EPPO and OLAF are not fully comparable.  

3.1.2.  Prevention (early detection) 

Methodological note 3: How prevention is measured in this report and what sectors are covered 
in this section 

Prevention is the first step of the anti-fraud cycle. For the purposes of this report (55), prevention 
refers to early detection, i.e. identifying irregularities and fraud detected before financial amounts 
are  disbursed  to the  beneficiary.  Early  detection may  prevent  payment to  the  beneficiary  of  all 
financial amounts involved (full prevention) or just part of them, with some funds already having 
been disbursed before detection (partial prevention). 

This section mainly focuses on expenditure under shared management, based on data provided by 
Member States via the IMS. For non-fraudulent irregularities, the data in IMS do not capture the 
full scope of prevention activities, as Member States are not required to report cases detected before 
expenditure is declared in a statement submitted to the Commission. This limitation does not apply 
to fraudulent irregularities. 

To assess progress, comparisons have been made between different reference periods: 

• 

• 

for agricultural policy, preventive activities over the last five years (2021-2025) are compared 
with the previous five-year period (2016-2020).  

for cohesion policy, the comparison covers full programming periods (2007-2013, 2014-2020, 
2021-2027). 

Additional data in this section cover indirect management (pre-accession) and direct expenditure, 
based on funds prevented from being spent based on OLAF investigations (56). 

Figure 13 shows the main prevention results of early detection activities as reported by the Member 
States in the  areas  of  shared  management.  The  impact  of  early  detection  on the  non-fraudulent 
irregularities is less representative of the prevention efforts, given that the data capture in particular 
partial prevention (which is anyhow improving compared to previous periods). The continuous 
focus on fraud prevention, as consistently reported in the PIF reports in recent years, has yielded 
tangible results in all areas measured, both in absolute and relative terms. 

In the period covered in Figure 13 (57), prevention efforts reported by Member States in shared 
management account for more than EUR 579 million. 

(54)  See footnote 53. 

(55)  See also Sections 1.2.2 and 1.3 and methodological note 1, p. 30. 

(56)  For information about funds prevented from being spent on the basis of  the EPPO notifications to the 

Commission, see snapshot 8. 

(57)  Since 2014 for the cohesion policy and since 2016 for agriculture. 

Page 32 

 
 
Figure 13: Prevention results as reported by the Member States 

Reference 
period 

Fraudulent irregularities 

Non-fraudulent irregularities 

Years 

N 

% of  
total 

EUR  
(million) 

% of  
total 

% of  
total 

EUR  
(million) 

% of  
total 

N 

2016-20 

151 

24.6% 

18.0 

17.2% 

538 

6.0% 

21.3  4.6% 

2021-25 

255 

31.2% 

22.4 

25.1% 

1 202 

9.0% 

30.8  4.8% 

2016-20 

39 

6.0% 

1.9 

1.9% 

203 

4.6% 

4.9  1.5% 

2021-25 

79 

10.8% 

2.2 

5.5% 

162 

4.3% 

4.8  1.6% 

2014-20 

129 

34.3% 

42.3 

30.7% 

979  23.0% 

136.1  15.0% 

2021-25 

263 

23.4% 

100.8 

13.8% 

1 575  12.8% 

177.7  7.0% 

2021-25 

31 

59.6% 

12.7 

50.7% 

44  11.9% 

2.9  6.2% 

Budgetary sector 

Agriculture 

Rural development 

Support to agriculture 

Cohesion policy 

Programming period 2014-
2020 

Programming period 2021-
2027 

Applying the same logic, thanks to early detection as a result of its administrative investigations, 
OLAF can issue financial recommendations to prevent sums from being unduly spent, across all 
expenditure  management  modes.  Following  these  recommendations,  the  Commission  may 
consider withholding additional funding. Over the last 10 years, the results show that OLAF’s and 
the Commission’s combined efforts have prevented more than EUR 658 million from being unduly 
spent, as shown in Figure 14. This is more than the prevention amounts initially recommended by 
OLAF, which underlines the importance of focusing  as early as possible on matters or areas of 
concern when suspected irregularities and fraud are first detected.  

Figure 14: Prevented amounts as a result of OLAF’s financial recommendations – 2016-2025 

Amount 
recommended 
for prevention 

Amount to be 
prevented from 
undue spending = 
Amount prevented 

Establishment 
rate for prevention 

EUR 

590 166 737 

361 139 436 
140 216 080 
88 811 221 

EUR 

658 080 808 

368 812 810 
200 789 193 
88 478 805 

% 

112% 

102% 
143% 
100% 

Expenditure mode 

Expenditure 

Shared management 
Indirect management 
Direct management 

Focus point 3: Prevention measures show results 

The  comparison  between  the  reference  periods indicates an improvement,  which  is  particularly 
visible  in  fraud  prevention  .  The  situation  for  non-fraudulent  irregularities  is  stable,  but  the 
derogations to the reporting obligation do not allow this aspect of early detection to be measured 
properly (as in relation to OLAF’s cases). 

Page 33 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
The results are consistent with the continuous focus on prevention by national authorities and EU 
bodies and institutions. 

3.1.3.  Investigation and prosecution 

This section provides an overview of ongoing investigations at EU and national level (58).  

Methodological note 4: What is measured under ‘Investigation and prosecution’ 

This section outlines the main efforts of investigative bodies at EU and national level. The ongoing 
efforts are presented as follows: 

•  For national authorities, the number of ‘open cases’ of fraudulent irregularities (59) as reported 
in IMS and OWNRES for 2021-2025. IMS data do not allow to identify precisely whether an 
‘open  case’  means  an  investigation  is  still  ongoing  or  the  case  has  been  brought  to  trial. 
Additionally, case dismissals can only be inferred by comparing case histories in IMS. These 
are limitations of the datasets that must be considered.  

•  For EU bodies (OLAF and EPPO), the number of ongoing investigations at the end of 2025. 

In terms of results, the section presents: 

• 

• 
• 

for national authorities, the percentage of fraudulent cases marked as completed (dismissed or 
established fraud) of the total number of fraudulent cases reported in the reference period; 
for OLAF, the number of investigations completed in 2025; 
for the EPPO, the number of indictments, dismissals and simplified prosecution procedures in 
2025. 

Figure 15: Ongoing investigations and prosecutions (2021-2025) 

Budgetary area - sector 

Revenue - TOR 

Shared management 

Agriculture 

Cohesion policy and fishery 

Other shared management 

Indirect management - Neighbourhood and the 
World 

Direct management - not RRF 

SUBTOTAL 

Direct management - RRF 

Other expenditure (not specified) 

Other 

TOTAL 

Open cases / ongoing investigations 

National 
authorities* 

EPPO** 

OLAF*** 

738 

2 341 

1 211 

1 120 

10 

79 

n/a 

3 158 

n/a 

333 

1 462 

541 

908 

13 

23 

137 

1 818 

512 

478 

3 158 

2 945 

83 

120 

26 

89 

9 

42 

87 

245 

40 

52 

424 

* For the limitations concerning data from national authorities, please see methodological note 4. 
738 Revenue - TOR cases include all open fraudulent cases for which either the investigation or the financial follow-up is ongoing. 

(58)  When referring to national authorities, the data presented in Figure 16 may also cover investigations by 
national  authorities  from  third  countries,  like  the  United  Kingdom  (in  both  areas  of  customs  and 
expenditure) and candidate countries (for pre-accession). However, these cases represent a very small 
percentage of the numbers presented. 

(59)  Cases classified as ‘suspected fraud’ (IRQ3) and with ‘OPEN’ status in IMS. 

Page 34 

 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
  
  
 
 
  
  
  
  
 
 
 
** Source: Commission calculation on data provided by the EPPO. 648 investigations into VAT have not been included for 
comparability reasons. For another 478 investigations, the types of programmes concerned were not specified.  
*** Source: OLAF annual report 2025 and data provided by OLAF. Sum of individual entries does not correspond to TOTAL, as one 
investigation may refer to more than one area 

Data from national authorities, the EPPO and OLAF cover areas that are only partially overlapping.  

1.  A significant part of ongoing EPPO and OLAF investigations are unlikely to have been 
disclosed to  national authorities and therefore already reported via IMS.  However, they 
indicate potential future cases that will be reported in the coming years, depending on their 
outcome. 

2.  Member  States  are  required  to  report  irregularities  and  fraud  in  IMS  only  in  shared 
management and, to a limited extent, in relation to European Neighbourhood programmes 
(ENI)  with  participating third  countries.  Candidate  countries  are also required to  report 
irregularities  and  fraud  in  IMS  in  relation  to  pre-accession  instruments  (indirect 
management). 

3.  EPPO data cover only participating Member States. 

4.  Limitations in the way data are captured in IMS may result in the number of ongoing cases 
being overestimated, as the data may also include cases already at the trial stage rather than 
under active investigation. 

5.  Investigations  from  the  EPPO  into  VAT  fraud  are  omitted  in  Figure  15  to  increase 

comparability. 

Despite  these differences and keeping in mind the specific data  characteristics, the  data offer a 
comprehensive view of ongoing investigative efforts to protect the EU’s financial interests. 

Figure 16: Results of investigations and prosecution 

Results of investigations 

Number of 
fraudulent 
cases 
finalised 

% on total 
fraudulent 
cases 

Number 
of 
finalised 
cases 
dismissed 

% on 
fraudulent 
cases 
finalised 

Number of 
finalised 
cases with 
fraud 
established 

% on 
fraudulent 
cases 
finalised 

1 319 

396 

1 207 

288 

31% 

22% 

35% 

20% 

515 

107 

628 

93 

39% 

27% 

52% 

32% 

804 

289 

579 

195 

61% 

73% 

48% 

68% 

Shared management 
sector (data reported 
by Member States 
from 2014 to 2025) 
Agriculture (2014-
2025) 
Agriculture (2021-
2025) 
Cohesion policy and 
fisheries (2014-2025) 
Cohesion policy and 
fisheries (2021-2025) 

Estimated damage notified to the 
Commission and the IBOAs  

Number of 
cases 

N 

Expenditure 
fraud  
EUR million 

Revenue fraud 
EUR million 

275 
292 
99 
168 
159 

162.7 
- 
8.6 
- 
- 

1 180 
- 
11.8 
- 
- 

EPPO (2025)* 
Indictments 
Dismissals 
Simplified prosecution procedures 
Final court decisions 
Convictions 

Page 35 

 
 
 
 
 
  
  
* Source: EPPO annual report 2025 - may include RRF fraud cases. Revenue fraud cases refer 
almost exclusively to VAT fraud (estimated damage to national budgets). See Snapshot 8. 

Number 
N 

Financial recommandations 

For recovery 
EUR million 

for prevention 
EUR million 

- 
597 
- 

- 
18 
- 

OLAF (2025)** 
Investigations concluded 
Financial recommendations 
Judicial recommendations 
Source: OLAF annual report 2025 - may include RRF 
cases 

209 
141 
11 

Focus point 4: Future improvements in data capturing 

The comparability of the data presented in this section is limited for the reasons outlined above. 
Further work is needed to improve data collection. 

The  Commission/OLAF  has  already  launched  a  revision  of  how  data  on  criminal  and 
administrative proceedings are captured in IMS. The planned changes will apply from June 2026 
for all irregularities related to the 2021-2027 programming period and beyond. 

In OWNRES, new features will include a dedicated field to indicate whether a case is linked to an 
EPPO investigation. 

3.1.4.  Recovery and sanctioning 

3.1.4.1.  Recovery 

Methodological note 5: Scope of data on recoveries 

Recovery is a key element of the anti-fraud cycle.  

For  expenditure,  it  represents  the  point  at  which  anti-fraud  efforts  succeed  in  ensuring  that 
misappropriated  funds  are  returned  to  finance  legitimate  operations  or  are  reinstated  in  the  EU 
budget.  Protecting  the  EU’s  financial  interests  on  the  expenditure side is  complex  and  depends 
largely on the management mode. 

When, for example, funds are directly managed by the Commission or other IBOAs, they can be 
effectively recovered. However, under shared or indirect management, only a fraction of the total 
amounts  is actually  recovered,  depending  on  specific  circumstances.  In most cases,  the  bulk  of 
these resources undergoes financial corrections, meaning that the projects affected by irregularities 
are excluded from EU financing and replaced by other projects. In practice, a project affected by 
irregularities becomes financed by other sources of funding (national or other) and it is for the new 
‘creditor’ to recover the debt. 

For this reason, especially in relation to shared management irregularities reported by the Member 
States, the protection of the EU’s financial interests can take the form of recovery or withdrawal. 
In this section, both measures are considered as recovery (60). 

(60)  For detailed data on withdrawals and recoveries in shared management, see Sections 3.5.1 and 4.5.1 of 
the  SWD  ‘Statistical  evaluation  of  irregularities  reported  by  the  Member  States’,  accompanying  this 
report. 

Page 36 

 
  
  
  
  
  
  
  
  
  
  
  
 
For revenue, customs fraud can lead to shortfalls in own resources collection. Member States are 
financially  responsible  for  an  effective  establishment  and  collection  of  the  customs  duties  due. 
Customs duties recovered by national authorities are made available to the EU budget as traditional 
own resources. For customs duties irrecoverable from the economic operators, the Commission 
verifies  if  national  authorities  carried  out  their  obligations  effectively.  If  that  is  not  confirmed, 
Member  States  are  requested  to  compensate  the  EU  budget  for  the  losses  of  traditional  own 
resources.  

As regards VAT (national revenue),  fraud affects the collection of tax revenue for the Member 
States. There is no direct impact on the VAT-based own resource and the EU budget, as the VAT 
base relevant for the calculation of that own resource is determined by the VAT collected by the 
Member States. However, any VAT recoveries by national authorities are added to the VAT base 
used to calculate the corresponding own resource, resulting in higher VAT-based own resources 
being called. 

Figure 17 presents the main indicators on recoveries based on data reported by the Member States 
in the areas of traditional own resources and shared management. 

Figure 17: Recovery rates for TOR and shared management 

Fraudulent irregularities 

Non-fraudulent irregularities 

Amounts 
recovered 
(EUR 
million) 

% of 
total 

Recovery 
rate 

Amounts 
recovered 
(EUR 
million) 

% of 
total 

Recovery 
rate 

Budgetary 
sector 
Traditional 
own 
resources* 

Reference 
period 

2025 

1989-2022 

N 

- 

- 

N 

- 

- 

- 

- 

19.9 

- 

28% 

71% 

54% 

- 

- 

602.6 

- 

82% 

91% 

91% 

Agriculture** 

2015-2025  

274 

10% 

17.7 

12 397 

37% 

560.9 

Rural 

development 
Support to 

agriculture 
Cohesion and 
fisheries*** 

2015-2025 

174 

14% 

12.0 

81% 

8 532 

35% 

387.3 

91% 

2015-2025 

100 

7% 

5.7 

32% 

3 865 

44% 

173.6 

92% 

2015-2025 

430 

19% 

162.2 

96% 

24 726 

62% 

4 297.9 

99% 

* For additional information on recoveries in TOR, see Section 3.2.1. 
** For additional information on recoveries in agriculture, see Section 3.2.2.1. 
*** For additional information on recoveries in cohesion policy, see Section 3.2.2.2. 

Figure 18 presents the recovered amounts resulting from OLAF’s financial recommendations for 
which follow-up was completed. Table 5 of Annex 4 details results for each year from 2016 until 
2025. Monitoring of additional 639 financial recommendations is still ongoing, but it has already 
yielded results amounting to EUR 570 million. Additional details on these recoveries are presented 
in Table 6 of Annex 4. 

Figure 18: Recovery with follow-up completed based on OLAF’s financial recommendations by 
area and management mode – 2016-2025 

Number of 
recom-
mendations 

Amount 
recom-
mended for 
recovery 

Amount 
established 
to be 
recovered 
(FAER) 

Establish-
ment rate 
for recovery 

Amount 
recovered 

Recovery 
rate 

N 

600 

EUR million 

EUR million 

% 

EUR 
million 

% 

4 178.5 

4 704.1 

113% 

4 534.5 

96% 

Budgetary area 

Revenue 

Page 37 

 
  
 
Expenditure 

Shared management 

Indirect management 

Direct management 

569 

242 

121 

206 

1 129.7 

941.1 

110.6 

78.0 

854.9 

743.8 

46.8 

76% 

79% 

42% 

824.9 

737 

41.1 

64.3 

82% 

46.7 

96% 

99% 

88% 

73% 

Focus point 5: Recovery from fraudsters is the most difficult phase 

The data on all the sectors analysed highlight the inherent difficulties in recovering funds linked to 
fraud cases.  

The  data  reported  by  Member  States  indicate  that  only  a  few  criminal  proceedings  result  in 
successful  recovery  of  funds.  From  2015  to  2025,  this  amounted  to  about  EUR 180  million  in 
shared management. 

By contrast, administrative proceedings yield better results, as they allow for swifter resolution of 
the financial aspects related to irregularities. From 2015 to 2025, Member States reported that about 
EUR 5 billion had been recovered in shared management. 

Over  the  same  period,  joint  efforts  of  OLAF  and  the  Commission  resulted  in  almost  EUR 825 
million  recovered  across  all  management  modes,  following  financial  recommendations  from 
OLAF. 

Snapshot 8: Recovery following the EPPO notifications 

The  Commission  is  streamlining its  procedures to  follow  up  on  notifications received  from the 
EPPO.  

The  2025  monitoring  exercise  covered  588  EPPO  notifications  (it  being  noted  that  several 
notifications may stem from a single investigation). This figure also includes notifications sent in 
previous years. 

On revenue, the EPPO notified the Commission of estimated damage of EUR 1.7 billion, almost 
exclusively related to VAT and thus primarily affecting national budgets (61). 

On  the  expenditure  side,  the  financial  damage  amounts  stated  by  the  EPPO  relating  to  its 
investigations amounts to EUR 900 million. Over 72% of this estimated amount refers to ongoing 
EPPO investigations, meaning the figure is likely to change as cases are concluded in the coming 
years.  The  Commission  has  established  the  damage  at  EUR 190  million.  EUR 30  million  have 
already been recovered and EUR 15 million prevented from being unduly spent. 

The consolidation of these figures in the years ahead will offer a more complete picture of the 
situation. 

When investigations or criminal proceedings are completed, with the support of adequate evidence 
proving  fraudulent  or  irregular  behaviour,  the  Commission  can  successfully  proceed  to  the 
adoption of precautionary measures and the protection of the affected funds.  

3.1.4.2.  Sanctioning 

Recovering  the  sums  unduly  paid  or  evaded  restores  the  financial  damage  of  fraud  and 
irregularities. However, imposing criminal penalties is also critical for crime deterrence, because 

(61)  See Section 3.3.1. 

Page 38 

 
 
 
 
the threat of negative consequences can dissuade both potential offenders (general deterrence) and 
the specific individual punished (specific deterrence) from committing future crimes. 

Figure 16 presents data on the number of cases concluded with established fraud as reported by 
the  Member  States  in  shared  management  (over  the  period  2016-2025)  and  the  number  of 
convictions following the EPPO’s investigations (in 2025). 

IMS data offer additional details on the types of penalties imposed.  Information about imposed 
sanctions have been provided for about half of the closed fraudulent irregularities reported during 
2015-2025 in shared management. In some cases, these were just administrative sanctions. Most 
criminal sanctions involved imprisonment or proportional fines. Different categories of penalties 
were not frequently combined. Imprisonment was rarely accompanied by other penalties to protect 
the EU’s financial interests, such as exclusion from future subsidies. Criminal and administrative 
penalties were rarely combined. 

3.2.  Main findings by budgetary sector 

This  section  examines  the  key  budgetary  areas,  highlighting  the  most  significant  findings  and 
specific features associated with them. Indicators already presented in Section 3.1 are not repeated 
here.  However,  some  may  be  explored  in  greater  depth  where  specific  aspects  require  further 
analysis. 

3.2.1.  Revenue – traditional own resources  

This subsection presents data on fraud and irregularities detected and reported by Member States 
in the area of traditional own resources (TOR) (62).  

Methodological note 6: Data on traditional own resources 

The statistics are based on fraudulent and non-fraudulent irregularities reported by the Member 
States via OWNRES, with a cut-off date of 2 March 2026. 

The data cover both open and closed cases. The figures reflect the total estimated and established 
amounts of TOR, while recovery statistics are based solely on established amounts.   

Between 2021 and 2025, the Member States reported an average of 5 042 cases of fraudulent and 
non-fraudulent irregularities related to traditional own resources per year. In 2025, they reported 
4 390 cases, i.e. 13% lower than the five-year average. However, the total estimated and established 
amount  of  TOR  (EUR 824.7  million)  was  26%  higher  than  the  five-year  average  (EUR 656 
million). 

Member States detected 285 cases of fraudulent irregularities involving a total financial amount 
of EUR 85.4 million. Compared with 2021-2025, the number of fraudulent cases fell by 40%, while 
the corresponding  amount of TOR decreased by 25%. In 2025, only 6.5% of all reported cases 
were  classified  as  fraudulent,  accounting  for  10%  of  the  TOR  amount  involved.  However,  the 
average  amount  per  fraudulent  case  (EUR 299 536)  was  significantly  higher  than  for  non-
fraudulent cases (EUR 180 106).   

(62)  For a detailed analysis of irregularities reported by the Member States in relation to TOR, see Section 2 
of SWD ‘Statistical evaluation of irregularities reported for own resources, natural resources, cohesion 
policy, pre-accession assistance and direct expenditure in 2025’, accompanying this report. 

Page 39 

 
 
The number of non-fraudulent irregularities also declined by 10% compared with 2021-2025, 
with  4 105  cases  reported  in  2025.  Despite  this,  the  estimated  and  established  amount  of  TOR 
increased by more than 36% reaching EUR 739.3 million. 

Figure 19: Irregularities detected and reported in traditional own resources – 2021-2025 

6.000

5.000

4.569

s
e
s
a
c

f
o
r
e
b
m
u
N

5.619

5.447

5.183

4.390

4.000

3.000

2.000

1.000

0

R
U
E

n
o

i
l
l
i

m
n

i

s
t
n
u
o
m
A

900

800

700

600

500

400

300

200

100

0

2021

2022

2023

2024

2025

  Estimated and established amount

   Number of cases

Snapshot 9: Detected fraud and irregularities in traditional own resources 

In fraudulent cases, the primary modus operandi in terms of financial impact was incorrect value 
(37 cases, EUR 22.7 million), followed by incorrect origin or country of dispatching (44 cases, 
EUR 21 million). However,  smuggling (seized and confiscated goods) was the most frequently 
reported  type (72  cases,  EUR 11.4  million)  followed  by incorrect classification/misdescription 
(47 cases, EUR 14.7 million). 

cases, 

the  most 

non-fraudulent 

incorrect 
For 
classification/misdescription  (1 765  cases,  EUR 156  million).  However,  incorrect  value 
dominated in terms of financial impact (871 cases, EUR 398 million). Sports footwear was the 
most affected type of goods in terms of value. The top three countries of origin of goods affected 
by irregularities were China, the United States and India. 

remained 

violation 

common 

Release  for  free  circulation  remained  the  most  affected  customs  procedure  with  3 812  cases 
involving an overall estimated and established amount of EUR 746.3 million (87% of all cases 
and 90% of the total amounts reported for 2025, regardless of whether they are fraudulent or non-
fraudulent). In 2025, the registered amounts of TOR for fraud cases decreased significantly across 
all customs procedures except for release for free circulation and other, which increased. As in 
2024, the second most impacted customs procedure by TOR amount for non-fraudulent cases was 
inward processing followed by customs warehousing. 

Inspections by anti-fraud services played a crucial role in detecting fraudulent cases in 2025 (37% 
of cases and 74% of amounts). Non-fraudulent irregularities were primarily detected through post-
release  controls  (51%  of  cases  and  75%  of  amounts).  Release  controls  were  also  an  effective 
method of detecting both fraudulent and non-fraudulent irregularities. 

Page 40 

 
 
 
 
 
 
 
Snapshot 10: OLAF’s investigations in customs 

In 2025, in the context of its investigations, OLAF issued financial recommendations to customs 
authorities  of  the  Member  States  in  relation  to  the  evasion  of  import  duties  for  an  amount  of 
EUR 351.1  million.  OLAF  also  issued  requests  to  take  precautionary  measures  to  customs 
authorities of Member States for an amount of EUR 397.4 million (63).  

In 2025, 12 Member States reported 75 cases of smuggled cigarettes with nearly EUR 13 million 
in  estimated  TOR  involved.  Lithuania  reported  the  highest  number  of  cases  (16)  followed  by 
Estonia (15). The highest amount of TOR (EUR 3.3 million) was reported by Italy. Compared 
with 2024, 9 Member States continued to report cigarettes smuggling cases exceeding EUR 10 000 
in TOR (64) while some Member States have re-appeared in the statistics. (65) 

The recovery rate for fraudulent and non-fraudulent irregularities detected in 2025 was 77% (66), 
overall, a positive outcome. For fraudulent cases, the recovery rate of 28% decreased compared to 
the previous year, while for non-fraudulent cases, it remained similar to 2024, at 82%, though the 
recovered amount was almost double that of the previous year.  

The historical recovery rate (67) rose from 84% to 86% (71% for fraudulent cases and 91% for 
non-fraudulent cases).  

Recovery  is  an  ongoing  process  with  amounts  increasing  over  time  as  EU,  national  and  other 
administrative  appeals  are  finalised  and  decisions  become  definitive.  Furthermore,  usually  the 
financial responsibility of Member States is assessed after the recovery actions taken by national 
authorities as regards the economic operators are concluded. 

3.2.2.  Expenditure 

3.2.2.1.  Shared management 

3.2.2.1.1.  Agriculture 

Methodological note 6: differences between CAP pillars  

When analysing the indicators shown in Figures 13 and 17, the following should be taken into 
account: 

•  Support to agriculture (SA): accounts for the largest share of agricultural spending (about 
70%) and consists mainly of direct payments to farmers. These are annual payments based on 
entitlements. Many of these payments are below EUR 10 000 and thus are more likely to fall 
under the de minimis derogation (see methodological note 1). Some of these payments involve 
market measures, which follow a reimbursement-of-costs approach. 

•  Rural  development  (RD):  represents  about  30%  of  agricultural  spending.  Some  of  the 
payments in RD are based on reimbursements of costs and follow a multiannual approach. 

(63)  Member States report in OWNRES the reference of OLAF investigation to facilitate the identification 

of these cases. Many of the amounts reported in OWNRES relate to OLAF investigations. 

(64)  Belgium, Bulgaria, Estonia, Greece, France, Croatia, Lithuania, Poland, and Romania.   

(65)  Germany, Italy, Austria. 

(66)  The recovery rate includes both amounts recovered from the economic operators and amounts funded 

by the Member States. 

(67)  Only closed cases are taken into account. Cases from 2023 onwards are excluded.  

Page 41 

 
 
As from 2023, each EU Member State has a CAP strategic plan (CSP), combining interventions in 
the  form  of  support  to  agriculture  (direct  payments  and  sectoral  interventions)  and  rural 
development. 

As shown in Figure 13, fraud prevention in agriculture has improved over time, particularly in 
rural  development.  These  results  stem  largely  from  routine  controls,  which  may  indicate  that 
management  and  control  systems  have  consistently  prioritised  prevention.  For  both  rural 
development and support to agriculture, most fraud prevention was in cases involving less than 
EUR 100 000 . 

In  terms  of  detection,  in  2024-2025  20%  of  fraudulent  irregularities  related  to  support  to 
agriculture involved expenditure under CSPs reported by few Member States. These cases mostly 
involved direct payments to farmers, often for small financial amounts. For rural development, this 
figure was 5%. 

Focus point 6: Fraud detection under CSP 

The low level of fraud detection for both support to agriculture and rural development may reflect 
the early stage of CSP implementation. However, it also highlights the need to closely monitor 
whether management and control systems can effectively detect fraudulent irregularities affecting 
expenditure under CSP. 

In  general,  detection  of  irregularities  is  concentrated  in  a  few  Member  States,  in  particular  for 
fraudulent  irregularities,  where  the  top  five  Member  States (68)  in  terms  of  number  of  cases 
accounted for about 69% of all irregularities reported as fraudulent in the last five years. For non-
fraudulent irregularities the share of the top five Member States (69) is 58%. 

Snapshot 11 – Measures affected by fraud in the common agricultural policy 

Fraudulent  irregularities  related  to  direct  payments  to  farmers  mainly  concerned  false 
documentary proof or false requests. Under the 2023-2027 CAP, risks related to respect of good 
agricultural  and  environmental  conditions  and  support  to  environmental  commitments  may 
increase.  However,  the  reporting  of  irregularities  affecting  these  ‘environmental’  payments  is 
concentrated in a few Member States. In addition, analysis suggests that most of these irregularities 
may not be specifically related to controls on respect of agricultural practice. 

Infringements related to the falsification of documentary proof or requests were the most frequent 
in relation to market measures. In previous years, most of the fraudulent irregularities concerned 
the  wine-growing  sector, the  fruit and vegetables  sector  or  promotion.  During  2025,  fraudulent 
irregularities mainly concerned the wine sector and beekeeping. 

More  than  half  of  the  fraudulent  irregularities  related  to  rural  development  concerned  the 
documentary  proof  or  the  request,  where  falsified  proofs  were  the  most  frequent  fraud  pattern 
encountered. Violations concerning the implementation of the action accounted for a significant 
share of the financial amounts involved in fraud in rural development. 

Risk analysis, tips from informants and information published in the media still only marginally 
contributed to detecting fraud. The exception was  market measures, where a significant share of 
detections  resulted from  scrutiny  of  transactions,  with  undertakings  being  selected  based  on  an 
analysis of risk factors. However, the actual contribution of risk analysis to detection in market 
measures largely depends on how this requirement has been translated in practice, going beyond 

(68)  Romania, France, Estonia, Italy and Poland. 

(69)  Poland, Spain, Romania, Greece and Hungary. 

Page 42 

 
 
criteria  such  as  new  beneficiaries,  time  elapsed  since  the  previous  control  and  amount  of  the 
operation. 

The indicators presented in Figure 18 underline that successful recovery in the case of fraud is 
more difficult, as criminal proceedings may be lengthy and complex. In general, once proceedings 
are completed, the protection of the EU’s financial interests is effective. Recovery in relation to 
non-fraudulent  irregularities  yields  far  better  results,  with  about  40%  of  closed  cases  over  the 
period 2015-2025 resulting in almost EUR 561 million recovered. 

3.2.2.1.2.  Cohesion policy 

Methodological note 8: Reporting of irregularities and fraud in relation to cohesion policy 

Cohesion  policy  funds  multiannual  programmes,  the  rules  for  which  are  set  for  each  MFF.  As 
project implementation often extends beyond the programming period, control and audits may take 
place throughout the project life cycle. Consequently, in 2025 most irregularities and fraud cases 
reported  by  national  authorities  related  to  the  2014-2020  programming  period;  with  some  still 
linked to 2007-2013.  

Due to the slow start of 2021-2027 programme implementation, reporting of related irregularities 
and fraud only began in 2024. Even in 2025, only 10% of the total number of irregularities reported 
for cohesion policy related to the 2021-2027 programmes. 

Cohesion policy supports diverse strategic goals, such as green energy, research, social inclusion, 
and regional development, adding complexity to the data analysis. 

Prevention  improved  significantly  from  the  2007-2013  programming  period  to  2014-2020 
programming period.  This is showed by an increase in the number of fraudulent and non-fraudulent 
cases where more than half of the irregular or fraudulent disbursements were prevented. In fact, 
for  non-fraudulent irregularities,  the  overall  drop in  reporting (70)  stemmed  from a  reduction in 
cases  without  prevention,  while  the  reporting  of  irregularities  where  full,  or  at  least  partial, 
prevention occurred, increased. This suggests improved prevention measures. However, it may 
also reflect a shift in national management and control systems, with a focus on processing pending 
requests for reimbursements, and move away from targeted ex post controls on past transactions. 

Despite  their  low  numbers,  the  first  two  years  of  2021-2027  reporting,  show  further  fraud 
prevention improvements and stable trends for non-fraudulent irregularities. 

Focus  point  7:  Progress  in  prevention  measures  in  cohesion  policy  from  one  programming 
period to another 

The  comparison  between  the  three  programming  periods  shows  a  continuous  improvement, 
particularly in  relation  to  early  fraud  detection.  However,  data  on  the  2021-2027  programming 
period  remain  limited  and  may  evolve.  Trends  in  prevention  for  non-fraudulent  irregularities 
appear stable. 

The Commission will closely monitor these trends over time. 

Routine controls underpin a large share of prevention cases (23% of fraudulent irregularities and 
66% of non-fraudulent irregularities with prevention). Fraud prevention also relies on ‘tips from 
informants’, ‘existing doubts’ and, to a lesser extent, ‘information published in the media’. 

(70)  Highlighted in previous PIF reports, see for example the 2021 PIF report, Snapshot 17, p. 38 

Page 43 

 
 
 
The  first  detections  related  to  the  2021-2027  programming  period  confirm  previous 
findings on the areas of cohesion policy most vulnerable to fraud. To date, a noticeable 
share of reported fraudulent irregularities relates to digitalisation of SMEs, investment in 
energy  efficiency,  research  and  innovation.  In  terms  of  financial  amounts  involved  in 
fraudulent irregularities, business development and internationalisation of SMEs and the 
provision of water for human consumption come to notice. 

Snapshot 12 – Most frequently detected infringements in cohesion policy 

With  regard  to  fraudulent  irregularities,  the  most  frequent  infringements  during  the  2014-2020 
programming  period  involved  supporting  documents.  Fraudulent  infringements  of  contract 
provisions/rules ranked second and were often related to non-implementation of the funded action. 
Infringements  of  public  procurement  rules  were  the  second  most  reported  non-fraudulent 
irregularity (after infringements of contract provisions/rules), but they rarely led to a suspicion of 
fraud. 

Most fraudulent infringements concerning ethics and integrity were related to conflicts of interest.  

Risk analysis continues to play only a marginal role in detecting fraud, while information from 
civil  society,  though  declining,  remains  more  significant.  For  non-fraudulent  irregularities, 
detection from risk analysis may have increased, but information from civil society continues to 
provide a negligible contribution to detection. Detection may improve by strengthening ex post risk 
analysis, with a view to carrying out tailored checks.  

Figure 20: Cohesion policy – detection rates by programming period 

Indicator 
Fraud detection rate (FDR) 
Irregularities detection rate (IDR) 
Total detection rate (TDR) 

Programming periods 

2007-2013 

2014-2020 

2021-2027 

0.42% 
2.50% 
2.92% 

0.22% 
0.89% 
1.11% 

0.05% 
0.09% 
0.14% 

The  FDR  and  IDR  for  2021-2027  remain  very  low,  even  considering  that  pre-financing  is 
frontloaded.  In  addition,  for  all  these  programming  periods,  there  are  significant  differences  in 
reporting from different Member States. 

As  shown  in  Figure  16,  only  19%  of  fraudulent  irregularities  reported  during  2015-2025  were 
closed  (with  all  proceedings,  including  recovery,  finalised).  In  contrast,  62%  of  non-fraudulent 
irregularities were closed over the same period.  

Once  proceedings  are  concluded,  the  EU’s  financial  interests  are  effectively  protected,  via 
recovery, deduction or writing-off, with a ‘recovery rate’ above 95%. 

3.2.2.1.3.  Other shared management  

In terms of funding for other internal policies, the first fraudulent irregularities relating to the 2021-
2027 programming period were reported in 2025. During 2021-2025, most of the financial amounts 
were involved in fraud concerning the Asylum, Migration and Integration Fund. The reporting of 
non-fraudulent irregularities relating to the  2021-2027 programming period accelerated in 2025 
(especially for the Just Transition Fund), when it represented already 65% of reporting. During 
2021-2025, most of the financial amounts involved concerned the Youth Employment Initiative 
(also because of one large case) and the Fund for European aid to the most deprived (the fund with 
the highest number of non-fraudulent irregularities). 

Page 44 

 
  
3.2.2.2.  Indirect management – Neighbourhood and the world 

Since  2007,  the  EU  has  provided  financial  and  technical  assistance  to  support  reforms  in 
enlargement countries (71) through the Instrument for Pre-Accession Assistance (IPA). In 2025, 
irregularities mostly concerned IPA II and IPA III.  

The number of non-fraudulent irregularities in IPA II increased markedly in 2022 and has since 
fluctuated around 270 irregularities per year on average. The reporting of fraud dropped in 2025: 
only 2 fraudulent irregularities were reported, with just EUR 5 000 involved. During 2021-2025, 
irregularities were reported by nine countries, mostly Türkiye and, to a lesser extent, Albania and 
North  Macedonia.  The  highest  number  of  irregularities  and  the  highest  financial  amounts 
concerned agriculture and rural development. The financial amounts involved in irregularities in 
this policy area increased significantly in 2024, also because of an OLAF investigation in Albania.  

With  regard  to  IPA  III  (2021-2027),  four  beneficiary  countries  reported  51  irregularities.  The 
number of non-fraudulent irregularities accelerated in 2025. However, the reporting of fraud is still 
rare, with just 3 cases communicated so far. 

Concerning cross-border cooperation under the European neighbourhood instrument (CBC-
ENI),  during  2021-2025,  after  nearly  no  reporting  until  2022,  a  few  irregularities  started  being 
communicated  from  2023.  These  irregularities  were  reported  only  by  Romania,  Poland  and 
Estonia. The highest number of irregularities concerned expenditure to address common challenges 
in environment, public health, safety and security.  

In  2025,  Ukraine  got  access  to  the  Irregularities  Management  System  (IMS)  and  reported  24 
fraudulent irregularities and 7 non-fraudulent irregularities related to the Ukraine Facility. More 
than 75% of these irregularities concerned the provision of access to safe and quality education. 
Most  of  the  irregularities  involved  false  or  falsified  documents,  with  falsification  was  about 
inaccurate  information  reported  in  certificates  of  completion  of  works,  which  led  to  excessive 
payments or the overstatement of the cost of works.  

Focus point 8: Expanding the scope of IMS reporting in relation to candidate countries 

The  mandatory  reporting  via  IMS  of  detected  irregularities  and  fraud  is  foreseen  for  all  new 
instruments  supporting  candidate  countries  (the  Reform  and  Growth  Facility (72),  the  Moldova 
Facility and the Ukraine Facility).  

In the case of Ukraine all necessary preparatory conditions have already been met, and its reporting 
authorities  have  successfully  started  using  the  system.  Preparations  are  ongoing  for  the  other 
candidate countries. 

3.2.2.3.  Direct management 

In 2025, excluding RRF grants, EUR 49 025 million was disbursed under ‘direct management’. 
The  Commission  recorded  441  recovery  items  classified  as  irregularities,  for  a  total  value  of 
EUR 86.34 million. Among these recovery items, 32 were indicated as fraudulent irregularities, 
totalling EUR 5.52 million. 

(71)  There are currently nine candidate  countries for EU membership:  Albania, Bosnia and Herzegovina, 
Georgia, Moldova, Montenegro, North Macedonia, Serbia, Türkiye, and Ukraine. Kosovo is recognised 
as a potential candidate. 

(72)  The beneficiary countries of this facility are Albania, Bosnia and Herzegovina, Kosovo, Montenegro, 

North Macedonia and Serbia. 

Page 45 

 
 
During 2021-2025, the average fraud detection rate was 0.04%. This ratio peaked in 2024 at 0.12%. 
The average irregularity detection rate was about 0.15%. 

In 2025, the highest number of recovery items qualified as non-fraudulent irregularities (269) came 
under the budget heading ‘Single market, innovation and digital’, which also recorded the highest 
irregular amounts (EUR 76.3 million). 

During  2021-2025,  77.7%  of  recovery  items  qualified  as  fraudulent  (by  number)  and  91%  (by 
amount)  involved  legal  entities  resident  in  the  EU-27.  For  non-fraudulent  irregularities,  these 
shares were 75.5% (by number) and 81.9% (by amount). 

3.2.3.  Recovery and resilience facility 

In 2025, the Commission continued to support Member States in amending their national recovery 
and resilience plans (RRPs). It disbursed 34 payments to 24 Member States  totalling EUR 87.3 
billion (including EUR 47.2 billion in loans), bringing cumulative disbursements by year-end to 
EUR 393.4 billion (including EUR 155.9 billion in loans).  

The Commission maintained a dynamic audit and control framework, incorporating feedback from 
its own audits, the Internal Audit Service, the European Court of Auditors, the Council of the EU 
and the European Parliament. 

By February 2026, the Commission had conducted 121 audits, covering 442 milestones and targets, 
with 443 auditees, resulting in 701 findings.  

Member  States  have  implemented  most  of  the  audit  recommendations  (91%),  with  audit  and 
control milestones accelerating the implementation of audit recommendations in some cases. The 
Commission continues to monitor rigorously the implementation of audit recommendations by the 
Member States, including during the final phase and closure of the RRF.  

Snapshot 13: Cooperation between the Commission, OLAF and the EPPO to fight fraud and 
irregularities in the RRF 

RRF funds are disbursed once milestones and targets have been met satisfactorily.  

Throughout the process, including through dedicated system audits, the Commission verifies that 
Member States have the necessary control systems in place to protect the EU’s financial interests 
and, to that end, it cooperates with national authorities, OLAF and the EPPO.  

By the end of February 2026, the Commission had reported 38 potential irregularities to OLAF 
(identified  via  ex post  audits  or  from  open  sources).  OLAF  informed  the  Commission  of  an 
additional 50 cases (for a total of 88).  

The  EPPO  sent  to  the  Commission  137  notifications  (101  active  cases  in  court  proceedings  or 
ongoing investigations. 68% of the ongoing cases notified by the EPPO to the Commission related 
to one measure in a single Member State) for an estimated damage of EUR 77 million. In its 2025 
annual report, the EPPO reported 512 ongoing investigations into RRF, with estimated damage 
amounting to about EUR 5 billion (73). 

Once it receives OLAF recommendations, the Commission liaises with Member States to request 
the correction of amounts unduly paid or misused. If Member States do not fulfil their obligations, 

(73)  The  difference  between  the  number  of  ongoing  investigations  by  the  EPPO  and  the  number  of 
notifications sent to the Commission stems from the fact that it is the EPPO that decides when to inform 
the Commission about its cases. This is unlikely to happen in the early stages of its investigations. As 
indicated in the EPPO annual report, in 2025, 293 new investigations were related to the RRF (p. 70). 

Page 46 

 
 
the Commission can take corrective measures in cases of fraud, corruption, conflict of interests or 
double funding that has not been corrected by the Member States.  

3.3.  Fraud enablers against the EU budget 

3.3.1.  Organised crime  

According to Europol’s latest EU serious organised crime threat assessment (74), criminal networks 
exploit crises, such as natural disasters or health emergencies, to make companies or individuals 
eligible for funding. Advances in AI will also provide new tools for generating text and images 
which can be misused to create fake identities or convincing false documentation at low cost.  

Fraud schemes targeting the financial interests of Member States and the EU vary in sophistication. 
Missing trader intra-Community (MTIC) fraud in particular inherently relies on complex networks 
of  companies  to  obscure  connections  between  participants,  often  culminating  in  contra-trading 
schemes. The systematic misuse of legal business structures is a key feature of VAT and MTIC 
fraud. Shell or buffer companies, whether infiltrated or newly established, facilitate the exploitation 
of cross-border VAT systems and VAT refund processes. 

The EPPO’s annual reports underline the involvement of organised crime groups including in VAT 
and customs fraud. In its 2025 annual report, the EPPO reported 529 active investigations at the 
end  of  2025  (14.7%  of  the  total  active  investigations)  in  which  participation  in  criminal 
organisations was among the investigated offences.  

By  the  end  of  2025,  the  EPPO  had  648  VAT-related  active  investigations (75),  with  estimated 
financial damage of EUR 43.84 billion mostly impacting on national budgets. This represents about 
18% of the EPPO’s 3 602 active investigations and almost 65% of the estimated financial damage. 

3.3.2.  Corruption 

Corruption  is  a  critical  enabler  of  organised  crime,  allowing  criminal  networks  to  infiltrate 
institutions,  evade  law  enforcement,  and  expand  their  influence across  political,  economic,  and 
social spheres. It undermines the rule of law, weakens governance structures, and distorts economic 
systems, creating an environment conducive to illicit activities. The intersection of corruption and 
organised crime presents several significant threats to societal stability and security (76) 

The EPPO reported 169 active investigations (4.7% of the total) involving corruption among the 
offences investigated up to the end of 2025.  

From 2021 to 2025, 40 corruption cases were reported to the Commission via IMS by 12 countries. 
Of these, 36 were reported by 8 Member States. In view of the EPPO’s investigations, these data 
appear incomplete and may reflect specific difficulties in detecting and investigating corruption 
offences.  

(74)  Europol, Serious organised crime threat assessment, 2025.  

(75)  Data provided by the EPPO. 

(76)  Europol, Serious organised crime threat assessment, 2025, cit. p.28. 

Page 47 

 
 
3.3.3.  Conflicts of interest 

Between 2021 and 2025, national authorities from 26 countries (21 Member States, 4 candidate 
countries  and  the  United  Kingdom)  reported  562  irregularities  involving  conflicts  of  interest 
totalling over EUR 240 million in the areas of shared management and pre-accession assistance. 
Of these, 157 cases (28%) were classified as fraudulent by the reporting authorities, amounting to 
more than EUR 100 million (42% of the total irregular amounts). The majority (over 80%) of the 
reported cases and related amounts fell under cohesion policy. 

The conflicts of interest detected primarily occurred during the implementation phase of projects 
(in almost 90% of cases), i.e. between the beneficiary of the funding (mostly private entities, but 
also NGOs and public bodies) and their contractors or subcontractors. 

Page 48 

 
 
 
4.  CONCLUSIONS AND RECOMMENDATIONS 

For the first time, this report provides a comprehensive and holistic view of efforts to combat 
fraud  and  irregularities  affecting  the  EU’s  financial  interests.  It  structures  data  from  multiple 
sources around the anti-fraud cycle’s key conceptual framework to analyse progress in this area. 

The report marks the first step in improving the EU’s reporting framework by incorporating results 
from  all  components  of  the  anti-fraud  architecture  into  the  PIF  report.  This  will  enhance 
transparency and accountability, in line with the proposals set out in the White Paper for the anti-
fraud  architecture  review.  The  results  of  the  AFA  review  will  be  presented  in  a  Commission 
communication planned for the end of 2026. 

To this end, the report proposes a number of indicators and assesses the suitability of existing data 
sources to populate them adequately. Some data gaps have already been identified, but the findings 
will help shape future actions to address them. 

4.1. Prevention  

Recent PIF reports consistently highlight that prevention remains the most prioritised phase of the 
anti-fraud  cycle  for  Member  States.  This  focus  is  justified:  early  detection  or  prevention  of 
irregularities and fraud improve the cost-effectiveness of protective measures, reducing the need 
for lengthy and costly recovery proceedings while mitigating risks linked to failed fund retrieval.  

However,  effective  prevention,  particularly  in  cases  of  suspected  fraud,  must  extend  beyond 
financial safeguards. It should be followed by thorough investigation and prosecution to ensure 
that perpetrators face appropriate sanctions and are excluded from future access to EU and public 
funding. 

Focus point 9: Ensuring robust monitoring of prevention data 

Given  the  limitations  arising  from  the  existing  regulatory  framework,  the  Commission  will 
continue to monitor the quality of data submitted and support national authorities. 

Recommendation 1: Ensure that cases of attempted fraud  detected at an early stage are duly 
referred to competent prosecution services 

Member States authorities are invited to pay particular attention to cases detected at an early stage, 
before  funding  has  been  disbursed  to  beneficiaries,  in  particular  if  attempted  fraud  might  be 
involved. Authorities should ensure that these cases are duly referred to the competent prosecution 
services,  including  the  EPPO,  and  reported  to  the  Commission  in  compliance  with  sectoral 
regulations even when the prevention of financial damage was successful thanks to early detection. 

4.2. Detection 

Over  recent  years,  the  detection  of  fraud  and  irregularities  has  remained  largely  stable,  though 
variations persist across specific budgetary areas.  

The number of cases detected has stayed broadly constant – apart from a notable spike in fraudulent 
irregularities in 2024 – but the financial amounts involved have increased over the past two years. 
This  shift  toward  targeting  higher-impact  cases  could  be  further  strengthened  through  as  yet 
untapped  potential  in  risk-based  analysis,  IT  tools  and  whistleblowing,  particularly  for  fraud 
identification. 

Page 49 

 
Focus point 10: Arachne+ developments 

The Commission is committed to continued development of Arachne+ in line with the current plans 
to provide national authorities with a modern, comprehensive and efficient tool to support their 
prevention and detection efforts. 

Recommendation 2: Enhance detection through risk analysis and IT tools 

Member States should strengthen detection of fraud and irregularities through enhanced use of risk 
analysis and IT tools such as Arachne+. 

The  resulting  control  approaches  should  include  ex post  controls  on  sets  of  past  transactions 
identified via risk analysis and IT tools. 

4.3.  Investigation and prosecution 

Investigations  and  prosecutions  largely  depend  on  frontline  detection  (by  IBOAs  and  national 
authorities) and third-party complaints. OLAF adds value by providing specialised investigative 
capacities, prioritising the protection of the EU’s financial interests and enabling streamlined cross-
border cooperation. 

The EPPO has the power to investigate and prosecute fraud and other criminal offences affecting 
the EU’s financial interests and has already improved criminal proceedings, reducing investigation 
times  (particularly  for  cross-border  cases),  minimising  time-barred  dismissals,  and  increasing 
indictment and conviction rates. 

Complementary activities by OLAF can  support prosecution with swift administrative action in 
accordance with existing rules. 

Full cooperation by national services is necessary. 

Focus point 11: Strengthening coordination and cooperation among AFA actors 

The  AFA  review  will  look,  amongst  other,  at  how  cooperation  and coordination  between  AFA 
actors  can  be  enhanced  to  ensure  effective  investigation  and  prosecution  of  PIF  offences, 
harnessing new technologies. 

Recommendation 3: Ensure full support for OLAF and the EPPO  

Competent  authorities  must  fully  cooperate  with  OLAF  and  the  EPPO,  including  by  reporting 
without  delay  suspected  criminal  offences  and  granting  timely  access  to  data  collected  for 
implementing funds or the collecting revenue relevant to the EU budget. 

4.4.  Recovery and sanctioning 

Recovery is an area of the anti-fraud cycle where progress has been made but further improvements 
are needed, particularly for fraud cases.  

Effective protection of EU funding requires close cooperation between investigative bodies and 
authorities in charge of recoveries. The long-standing collaboration between the Commission and 
OLAF demonstrates the value of shared procedures and practices. 

Page 50 

 
Focus point 12: Monitoring the EPPO notifications 

The Commission has established a monitoring mechanism, similar to the one in place for OLAF’s 
financial  recommendations,  to  ensure  that  the  actual  damage  established  in  the  EPPO  cases  is  
correctly quantified and appropriate follow-up action is taken.  

The Commission will be reporting on progress in this area in future PIF reports.  

Data  on  sanctions  reported  by  national  authorities  remain  largely  incomplete  and  should  be 
improved  to  provide  a  clearer  overview  of  the  penalties  applied  following  criminal  and 
administrative proceedings. 

Recommendation 4: Boost cooperation between administrative and judicial services.  

Member States should: 

• 

• 

set up mechanisms to improve cooperation and information exchange between investigative 
and administrative services, boosting financial recovery.  

strengthen reporting on sanctions and penalties imposed after final judicial and administrative 
decisions. 

Page 51 

 
ANNEX 1 - Irregularities reported as fraudulent in 2025 (77) 
The number of irregularities reported as fraudulent measures the results of Member States' work to counter fraud and other illegal activities affecting the EU's financial interests. Therefore, the 
figures should not be interpreted as indicating the level of fraud in the Member States territories. Annex for the PIF Report does not include third countries (pre-accession), the UK and direct 
expenditure. 

Member States 

Agriculture 

Cohesion policy and 
Fisheries 

Other internal 
policies 

Pre accession & 
Neighbourhood (78) 

TOTAL EXPENDITURE 

REVENUE 

Belgique/België 
Bulgaria 
Ceská republika 
Danmark 
Deutschland 
Eesti 
Éire/Ireland 
Ellada 
España 
France 
Hrvatska 
Italia 
Kypros 
Latvija 
Lietuva 
Luxembourg 
Magyarország 
Malta 
Nederland 
Österreich 
Polska 
Portugal 
Romania 
Slovenija 
Slovensko 
Suomi/Finland 
Sverige 

TOTAL EU27 

N 

EUR 

N 

0 
4 
7 
15 
10 
21 
0 
0 
5 
9 
0 
10 
0 
2 
15 
0 
9 
0 
83 
0 
21 
5 
74 
2 
3 
0 
0 
295 

0 
1 220 578 
1 410 581 
605 625 
646 596 
1 463 863 
0 
0 
623 420 
512 973 
0 
1 058 725 
0 
75 232 
946 157 
0 
5 437 498 
0 
940 979 
0 
1 247 526 
1 163 334 
4 393 150 
82 599 
11 414 
0 
0 
21 840 250 

3 
3 
64 
1 
52 
2 
0 
3 
8 
3 
4 
4 
0 
2 
0 
0 
18 
0 
0 
2 
12 
27 
100 
1 
21 
3 
1 
334 

EUR 
1 404 886 
238 894 
42 442 320 
33 347 
4 182 519 
286 615 
0 
242 515 
1 923 627 
1 333 629 
657 624 
727 293 
0 
59 878 
0 
0 
3 451 147 
0 
0 
1 049 835 
5 111 570 
11 064 944 
54 230 295 
28 671 
31 617 764 
179 000 
59 399 
160 325 772 

N 

EUR 

N 

EUR 

N 

0 
0 
0 
0 
4 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
4 
0 
0 
0 
0 
8 

0 
0 
0 
0 
326 004 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
326 004 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
0 
0 
0 
1 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
23 771 
0 
0 
0 
0 
23 771 

EUR 
1 404 886 
1 459 472 
43 852 902 
638 972 
5 155 119 
1 750 477 
0 
242 515 
2 547 047 
1 846 602 
657 624 
1 786 018 
0 
135 110 
946 157 
0 
8 888 645 
0 
940 979 
1 049 835 
6 359 096 
12 228 278 
58 647 216 
111 270 
31 629 177 
179 000 
59 399 
182 515 796 

3 
7 
71 
16 
66 
23 
0 
3 
13 
12 
4 
14 
0 
4 
15 
0 
27 
0 
83 
2 
33 
32 
179 
3 
24 
3 
1 
638 

N 

29 
23 
0 
2 
22 
15 
0 
26 
6 
62 
6 
19 
7 
0 
18 
0 
3 
0 
0 
8 
16 
2 
11 
1 
0 
2 
7 
285 

EUR 
24 655 630 
2 500 070 
0 
56 641 
1 216 031 
2 748 159 
0 
2 918 814 
799 036 
25 443 268 
628 115 
7 171 687 
188 692 
0 
2 470 847 
0 
394 768 
0 
0 
1 479 396 
11 657 102 
273 562 
360 667 
20 779 
0 
163 234 
221 238 
85 367 735 

(77)  Based on data in the Irregularity Management System (IMS) as of 8/3/2026 (for expenditure) and on data from the OWNRES application as of 2/3/2026 (for revenue). 

(78)  The irregularity reported by Romania is related to the European neighbourhood Instrument. 

Page 52 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 2 - Irregularities not reported as fraudulent in 2025 (79) 
It does not include third countries (pre-accession), the UK and direct expenditure 

Member States 

Agriculture 

Cohesion policy and 
Fisheries 

Other internal policies 

Pre accession & 
Neighbourhood (80) 

TOTAL EXPENDITURE 

REVENUE 

Belgique/België 
Bulgaria 
Ceská republika 
Danmark 
Deutschland 
Eesti 
Éire/Ireland 

Ellada 

España 
France 
Hrvatska 
Italia 
Kypros 
Latvija 
Lietuva 
Luxembourg 
Magyarország 
Malta 
Nederland 
Österreich 
Polska 
Portugal 
Romania 
Slovenija 
Slovensko 
Suomi/Finland 
Sverige 

TOTAL EU27 

N 

27 
48 
60 
41 
171 
31 
0 

182 
442 
301 
200 
288 
1 
23 
74 
3 
307 
2 
10 
10 
832 
309 
507 
11 
44 
24 
29 
3 977 

EUR 

786 940 
2 701 441 
1 067 477 
1 498 377 
5 057 601 
2 610 274 
0 

3 464 111 
75 418 916 
14 630 586 
19 006 249 
15 628 133 
298 480 
414 171 
2 771 386 
27 026 
17 507 822 
56 735 
388 933 
631 093 
21 466 966 
13 039 199 
39 246 198 
265 754 
3 219 314 
720 017 
770 940 
242 694 139 

N 

7 
75 
270 
11 
102 
45 
6 

212 
777 
50 
45 
196 
1 
5 
21 
0 
272 
4 
5 
15 
402 
105 
317 
5 
85 
3 
31 
3 067 

EUR 
1 228 350 
8 525 940 
41 368 828 
593 772 
10 885 306 
2 285 527 
3 737 811 

87 006 201 
179 652 472 
6 925 617 
4 634 327 
23 300 999 
2 495 072 
283 763 
10 050 387 
0 
32 144 615 
95 515 
407 359 
1 454 681 
110 030 450 
9 061 128 
81 438 423 
679 460 
66 969 648 
202 855 
2 198 914 
687 657 420 

N 

EUR 

N 

EUR 

N 

0 
0 
4 
0 
3 
9 
1 

12 
0 
4 
0 
0 
0 
1 
0 
0 
1 
0 
0 
2 
6 
2 
6 
0 
0 
1 
0 
52 

0 
0 
114 034 
0 
60 486 
218 145 
3 543 161 

1 934 108 
0 
899 613 
0 
0 
0 
30 815 
0 
0 
11 392 
0 
0 
116 160 
289 424 
69 719 
2 463 174 
0 
0 
10 967 
0 
9 761 198 

0 
0 
0 
0 
0 
0 
0 

4 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
3 
0 
0 
0 
0 
8 

0 
0 
0 
0 
0 
0 
0 

189 308 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
87 193 
0 
302 438 
0 
0 
0 
0 
578 939 

34 
123 
334 
52 
276 
85 
7 

410 
1 219 
355 
245 
484 
2 
29 
95 
3 
580 
6 
15 
27 
1 241 
416 
833 
16 
129 
28 
60 
7 104 

EUR 
2 015 290 
11 227 381 
42 550 339 
2 092 150 
16 003 393 
5 113 945 
7 280 972 

92 593 728 
255 071 388 
22 455 816 
23 640 576 
38 929 132 
2 793 552 
728 748 
12 821 772 
27 026 
49 663 828 
152 250 
796 291 
2 201 934 
131 874 034 
22 170 046 
123 450 233 
945 214 
70 188 962 
933 840 
2 969 854 
940 691 694 

N 

367 
1 
59 
109 
1 612 
5 
45 

7 
480 
344 
9 
68 
4 
31 
11 
5 
30 
0 
351 
51 
113 
0 
61 
25 
19 
58 
240 
4 105 

EUR 
294 779 485 
26 081 
3 994 884 
15 412 614 
167 011 186 
384 048 
3 139 053 

543 980 
72 983 869 
60 224 996 
192 275 
4 854 689 
483 523 
1 675 724 
516 283 
86 297 
2 984 576 
0 
41 674 315 
9 196 840 
7 134 818 
0 
5 907 103 
1 242 393 
1 204 238 
5 586 025 
38 095 480 
739 334 773 

(79)  Based on data in the Irregularity Management System (IMS) as of 8/3/2026 (for expenditure) and on data from the OWNRES application as of 2/3/2026 (for revenue). 

(80)  Data in this column includes 4 irregularities (1 PL, 3 RO) related to the European neighbourhood Instrument. 

Page 53 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 3: Overview of measures taken by the Member States to target specific topics 

Table 1: Early-detection and exclusion 

Early-stage risk identification and exclusion 

Member 
State 

Belgium  

Bulgaria  

Target 

Identifying 
potential 
conflicts of 
interest 

Excluding 
unreliable 
economic 
operators 

Type of 
measure 

Administrative 

Legislative 

Cyprus 

Identifying red 
flags  

Administrative 

Description 

Before  evaluating  project  proposal 
evaluators tick the declaration of honour. 
A  sample  of  statements  is  verified  via 
Arachne.  

exclusion 

award 
Mandatory 
procedures  of  persons  convicted  of 
certain offences.  

from 

Changes  to  the  e-procurement  system 
include automated workflows, role-based 
access and  time-stamped  records which 
reduce discretion and conflicts of interest. 
Contract-management 
functions 
(milestones, variations, payments, alerts) 
help 
irregular 
amendments and non-performance early. 

overpricing, 

detect 

Hungary 

Excluding 
fraudulent 
taxpayers 

Operational 

Post-release controls are used to identify 
and  exclude  fraudulent  taxpayers,  for 
example by cancelling their tax number.   

Ireland  

Performing 
eligibility and 
compliance 
checks 

Poland  

Identifying 
potential 
conflict of 
interest 

Administrative 

Organisational 

Operational 

Operational 

Embedding  eligibility  and  compliance 
checks into the implementation of the Just 
Transition  Fund  from  the  outset.  The 
measure also ensures accountability and 
traceability  of  Just  Transition  Fund 
spending.  

the 
the  project  selection  stage, 
At 
SAMPLER tool is used to verify conflicts 
of 
the 
subsequent procedures. 

interest,  which 

simplifies 

 
 
 
 
 
 
 
Table 2: Training and capacity-building activities reported by Member States in 2025 

Member State 

Type of measure 

Description 

Trainings and capacity-building activities 

Belgium 

Organisational 

Mandatory  e-learning  on  combating 
managers and project managers. 

fraud 

for 

top 

Administrative 

Training on the importance of transparency of lobbying 
activities  and  requirements  for  registration  and  public 
disclosure of meetings.  

Cyprus 

Administrative 

Training  and  guidance  for  all  bodies  working  with  EU 
funds to set common standards.  

Administrative 

Targeted  training  programme  covering  key  PIF  areas 
given  by  the  Treasury  of  the  Republic  of  Cyprus  for 
officials from all authorities working with EU funds.  

Czechia 

Organisational 

Internal training action for staff of the managing authority 
for the Employment+ operational programme. 

Finland 

Administrative 

Training on good administrative practices  to harmonise 
approaches. Increasing awareness within organisations.  

Germany 

 Administrative 

Guideline document on prevention of conflict of interest. 

Hungary  

Operational 

Hungarian  public  procurement  authority  updated 
low  prices, 
guidelines  on  examining  exceptionally 
dynamic  purchasing  systems,  provided  online  training 
and organised conferences focused on conflict of interest 
and integrity issues.  

Ireland  

Administrative 

for 

Development 

The  Northern  and  Western  Regional  Assembly,  a 
the  European 
managing  authority  responsible 
Regional 
an 
Fund 
administrative measure to bolster capacity building. They 
increased  initiatives  to  boost  staff  awareness  with  anti-
fraud training on governance and control of funds. This 
covered  many  areas  including  public  procurement, 
conflicts of interest, State aid, integrity and transparency. 

introduced 

Latvia 

Organisational 

Lithuania 

Organisational 

The Latvian  Procurement  Monitoring  Bureau  organised 
several webinars and workshops, independently and in 
cooperation with the State  Chancellery and the Latvian 
School of Public Administration, to strengthen knowledge 
and practice in public procurement processes. 

Training on transparency and the fight against corruption 
and  fraud  for  institutions  working  with  EU  Structural 
Funds. 

Page 55 

 
Malta  

Administrative 

Communication  campaign  raising  awareness  among 
public service and public sector employees. 

Slovakia 

Organisational 

the  EU’s 

focused  on  protecting 

Training 
financial 
interests on both the expenditure and revenue sides of 
fraud,  money 
the  EU  budget  (tax  and  customs 
laundering, irregularities, and financial corrections, etc.). 
The  training  is  for  law  enforcement  authorities  and 
employees of managing and intermediary bodies, audit 
and control bodies and employees working on traditional 
own resources. 

Spain  

Operational 

to 
The  Conflict-of-Interest  Advisory  Unit  continued 
spread good practices. The Spanish AFCOS continued 
its  intensive  training  work  on  preventing  and  fighting 
fraud against the EU’s financial interests. 

Table 3: Information exchange management 

Managing the flow of information: enhancement of systems and data collection 

Member State 

Type of 
measure 

Description 

Croatia 

Operational 

Cyprus  

Administrative 

Implementation of a new system (eKohezija) which 
stores  all  project  information  and  is  used  for 
management  purposes 
the  project 
cycle.   

throughout 

Update  of  an e-procurement system standardising 
procedures  and  documentation,  centralising  data, 
recording  time-stamped  actions  across  the  whole 
contract lifecycle.   

Finland 

Administrative 

Guidelines  on  the  use  of  the  administrative  and 
control system.   

Italy  

Portugal  

Administrative 

Integration of systems with the Arachne/SAS model 
strengthening  early  detection  of 
fraud  and 
irregularities.  

Operational 

Computerisation  of  the  serious  irregularities  case 
register to allow constant flow of information.   

Administrative 

Dashboards sharing risk monitoring information with 
managing authorities.  

Operational 

Development of a new customs anti-fraud database 
that is interoperable with EU and national systems. 

Slovakia 

Operational 

New IT functionality in ITMS21+ (the IT system for 
the Programme Slovakia for the 2021-2027 period), 
including  export  and  import  of  data  between  the 
ITMS21+ and the IMS. 

Page 56 

 
 
Slovenia 

Operational 

Introduction  of  automatic  verification  of  double 
financing via a new tab in the system.  

Managing the flow of information: quality of reporting 

Member State 

Type of 
measure 

Description 

Cyprus 

Administrative 

Among other courses, training on using the IMS and 
EDES systems.  

Denmark  

Administrative 

Guidelines  on  proper  reporting  of  irregularities 
clarifying ambiguities identified.  

Germany 

Administrative 

Workshop dedicated to the IMS system. 

Luxembourg 

Administrative 

Organisational 

Issuance  of  guidelines  to  be  applied  in  cases  of 
the 
fraud  or 
irregularities  being  detected, 
the 
corresponding  corrective  procedures,  and 
notification and monitoring of those irregularities. 

Poland 

Operational 

Framework  checklist  harmonising  the  approach  of 
various  institutions  in  selecting  aspects  to  verify 
during checks on public procurement and State aid. 

Slovakia  

Legislative 

Administrative 

Manual  on  reporting  irregularities  (AFCOS);  new 
internal  audit  guidelines  were  issued  due  to  the 
adoption of an amendment to the legislation.  

Page 57 

 
 
 
 
 
 
Table  4:  Measures  creating  new  bodies  or  transferring  powers  (including  streamlining 
communication with other national and EU-level counterparts) 

Managing the flow of information: Dedicated bodies/functions 

Member State 

Type of 
measure 

Description 

Estonia 

Organisational 

Designation of a new position of personal income tax 
manager. 

Legislative 

Administrative 

Organisational 

Greece 

Operational 

Transfer of responsibilities, staff and services to the 
Independent  Authority 
to 
consolidate  control  and  prosecution  mechanisms, 
integrate information systems, and avoid duplication 
of responsibilities.  

for  Public  Revenue 

Legislative 

Creation  of  a  register  of  public  procurement 
professionals, with the main objective of simplifying, 
transparency, 
streamlining  and  enhancing 
integrity  and  efficiency  of  public  procurement 
procedures (Law 5218/2025). 

the 

Organisational 

Latvia  

Transformation  of  the  Tax  and  Customs  Police 
Department 
direct 
administration  institution  -  the  Tax  and  Customs 
Police to separate and transfer responsibilities. 

independent 

into 

an 

Organisational 

Creation of the Customs Audit Division at the State 
Revenue Service. 

Legislative 

Slovakia 

Administrative 

Organisational 

Setting-up  of  a  cross-cutting  working  group  within 
the  Agricultural  Paying  Agency  focused  on  project 
assessment, public procurement, conflicts of interest 
and control of EU funds. 

Spain  

Administrative 

Creation  of  the  State  Independent  Whistleblower 
Protection Authority. 

Organisational 

Setting-up of an operational group dedicated to the 
EPPO cases.   

Page 58 

 
 
 
 
ANNEX 4 –OLAF’s financial recommendations 

Table  5:  Financial  recoveries  following  OLAF’s  financial  recommendations  with  finalised 
follow-up per area, management mode and year 

Recom-
mendations 

AREA - 
Management 
mode / Year 

Amount 
recom-
mended to 
be 
recovered 

Amount to 
be 
recovered 
FAER 

Establish-
ment rate 
for 
recovery 

N 

EUR million 

EUR million 

% 

Amount 
recovered 

Recovery 
rate 

EUR 
million 

% 

600 

4 178.5 

4 704.1 

113% 

4 534.6 

96% 

REVENUE 
customs 
2016 
2017 
2018 
2019 
2020 
2021 
2022 
2023 
2024 
2025 

EXPENDITURE 
Direct 
management 

2016 
2017 
2018 
2019 
2020 
2021 
2022 
2023 
2024 
2025 

71 
88 
83 
64 
97 
90 
28 
32 
29 
18 

206 

41 
27 
28 
26 
32 
20 
15 
8 
8 
1 

104.7 
2 530.5 
58.2 
288.6 
123.2 
286.2 
81.9 
688.5 
11.0 
5.6 

78.0 

12.4 
13.6 
7.3 
6.3 
14.2 
9.4 
1.6 
13.0 
0.3 
0.0 

EXPENDITURE 
Indirect 
management 

121 

110.6 

2016 
2017 
2018 
2019 
2020 
2021 
2022 
2023 
2024 

Page 59 

33 
11 
12 
9 
19 
11 
12 
9 
5 

28.3 
6.5 
18.5 
5.1 
26.8 
2.0 
20.2 
3.0 
0.2 

64.9 
3 777.0 
40.6 
201.1 
95.1 
68.5 
93.6 
343.7 
12.1 
7.4 

64.3 

10.9 
7.1 
3.6 
5.3 
10.5 
9.8 
1.3 
15.8 
0.0 
0.0 

46.8 

19.1 
1.1 
6.3 
1.1 
4.1 
1.6 
10.1 
2.7 
0.7 

62% 
149% 
70% 
70% 
77% 
24% 
114% 
50% 
110% 
132% 

23.6 
3 735.8 
20.4 
200.2 
53.6 
48.5 
89.1 
343.7 
12.1 
7.3 

36% 
99% 
50% 
100% 
56% 
71% 
95% 
100% 
100% 
100% 

82% 

46.7 

73% 

88% 
52% 
49% 
85% 
74% 
104% 
80% 
122% 
18% 
76% 

4.0 
4.0 
1.8 
2.5 
10.4 
7.0 
1.1 
15.8 
0.0 
0.0 

37% 
56% 
52% 
48% 
99% 
72% 
85% 
100% 
100% 
100% 

42% 

41.1 

88% 

67% 
16% 
34% 
22% 
15% 
79% 
50% 
92% 
316% 

16.6 
0.9 
6.3 
1.1 
1.7 
0.9 
10.1 
2.7 
0.7 

87% 
89% 
100% 
100% 
41% 
56% 
100% 
100% 
100% 

 
EXPENDITURE 
Shared 
management 

2016 
2017 
2018 
2019 
2020 
2021 
2022 
2023 
2024 
2025 
TOTAL 
(REVENUE + 
EXPENDITURE) 

242 

941.1 

743.8 

79% 

737.0 

99% 

46 
42 
27 
29 
19 
20 
27 
22 
9 
1 

193.6 
379.0 
59.0 
137.4 
37.8 
21.8 
67.1 
20.6 
23.6 
1.0 

103.1 
356.8 
135.5 
27.9 
32.1 
10.4 
40.6 
13.7 
22.7 
1.0 

53% 
94% 
229% 
20% 
85% 
48% 
60% 
67% 
97% 
100% 

102.9 
355.9 
135.5 
27.9 
32.0 
10.4 
35.5 
13.2 
22.7 
1.0 

100% 
100% 
100% 
100% 
100% 
99% 
88% 
96% 
100% 
100% 

1169 

5 308.2 

5 559.0 

105% 

5 359.4 

96% 

Table 6: Recommendations issued 2016-2025, by budget area – provisional results on ongoing 
cases 

Number of 
recom-
mendations 

N 

Amount 
recom-
mended 
for 
recovery 
EUR 
million 

Amount 
established 
to be 
recovered 
(FAER) 

Amount 
recovered 

Amount 
recom-
mended for 
prevention 

Amount 
prevented 

EUR million  EUR million  EUR million  EUR million 

197 

442 

241 

48 

153 

1 126.7 

1 917.8 

596.5 

628.1 

402.5 

167.5 

N/A 

283.2 

N/A 

239.7 

1 098.3 

390.2 

94.4 

34.4 

0.0 

98.7 

71.6 

6.1 

113.4 

113.4 

720.8 

166.3 

67.0 

135.4 

126.2 

BUDGETARY 
AREA 
Revenue 

Expenditure 
Shared 
management 
Indirect 
management 
Direct 
management 

Page 60