COMMISSION STAFF WORKING DOCUMENT Statistical evaluation of irregularities reported for 2025: own resources, agriculture, cohesion and fisheries policies, pre-accession and direct expenditure Accompanying the document 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  SWD(2026) 251 final  COMMISSION STAFF WORKING DOCUMENT Statistical evaluation of irregularities reported for 2025: own resources, agriculture, cohesion and fisheries policies, pre-accession and direct expenditure Accompanying the document 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 {COM(2026) 411 final} - {SWD(2026) 245 final} - {SWD(2026) 246 final} - {SWD(2026) 247 final} - {SWD(2026) 248 final} - {SWD(2026) 249 final} - {SWD(2026) 250 final}  
 
 
CONTENTS 

LIST OF ABBREVIATIONS ............................................................................................. 3 

EXECUTIVE SUMMARY ................................................................................................. 4 

1. 

INTRODUCTION ..................................................................................................... 11 

1.1.  Scope of the document .................................................................................... 11 
1.1.  Structure of the document ............................................................................... 11 

2.  TRADITIONAL OWN RESOURCES (TOR) ......................................................... 12 

2.1. 
Introduction ..................................................................................................... 12 
2.2.  General trend ................................................................................................... 12 
2.3.  Prevention ........................................................................................................ 14 
2.4.  Detection and investigation ............................................................................. 15 
2.4.1.  Types of infringement and modus operandi ...................................... 15 
2.4.2.  Detection of irregularities by Member State ..................................... 16 
2.5.  Recovery .......................................................................................................... 19 
2.6.  Other      ........................................................................................................... 20 
2.6.1.  Commission’s inspections ................................................................. 20 
2.6.2.  Examination of write-off reports ....................................................... 21 

3.  COMMON AGRICULTURAL POLICY ................................................................. 22 

3.1. 
Introduction ..................................................................................................... 22 
3.2.  General trend ................................................................................................... 22 
3.3.  Prevention ........................................................................................................ 27 
3.4.  Detection and investigation ............................................................................. 31 
3.4.1.  Types of infringement and modus operandi ...................................... 31 
3.4.2.  Risk analysis and spontaneous reporting ........................................... 34 
3.4.3.  Duration of irregularities ................................................................... 34 
3.4.4.  Detections and reporting by Member State ....................................... 35 
3.4.5.  Follow-up to supected fraud .............................................................. 39 
3.5.  Recovery and sanctions ................................................................................... 41 
3.5.1.  Recovery ............................................................................................ 41 
3.5.2.  Sanctions ........................................................................................... 46 

4.  COHESION AND FISHERIES POLICIES .............................................................. 48 

4.1. 
Introduction ..................................................................................................... 48 
4.2.  General trend ................................................................................................... 48 
4.3.  Prevention ........................................................................................................ 53 
4.4.  Detection and Investigation ............................................................................. 58 
Irregularities by area of the cohesion policy ..................................... 58 
4.4.1. 
4.4.2.  Types of infringement and modus operandi ...................................... 60 
4.4.3.  Risk analysis and spontaneous reporting ........................................... 63 

 
 
 
  
4.4.4.  Duration of irregularities ................................................................... 64 
4.4.5.  Detection and reporting by Member State ........................................ 65 
4.4.6.  Follow-up to suspected fraud ............................................................ 71 
4.5.  Recovery and Sanctions .................................................................................. 73 
4.5.1.  Recovery ............................................................................................ 73 
4.5.2.  Sanctions ........................................................................................... 77 
4.6.  Other internal policies ..................................................................................... 78 

5.  NEIGHBOURHOOD POLICY ................................................................................ 80 

5.1. 

Introduction ..................................................................................................... 80 
Instruments for Pre-accession Assistance ......................................... 80 
5.1.1. 
5.1.2.  Cross-border  cooperation  under  European  Neighbourhood 

Instrument .......................................................................................... 81 
5.1.3.  Ukraine facility .................................................................................. 82 
5.2.  Pre-accession Assistance ................................................................................. 82 
5.2.1.  General analysis ................................................................................ 82 
Instrument for Pre-accession Assistance II (IPA II 2014-2020) ....... 83 
5.2.2. 
Instrument for Pre-accession Assistance III (IPA III 2021-2027) .... 87 
5.2.3. 
5.3.  Cross-border Cooperation under ENI.............................................................. 88 
5.4.  Ukraine Facility ............................................................................................... 89 

6.  DIRECT MANAGEMENT ....................................................................................... 90 

6.1. 
Introduction ..................................................................................................... 90 
6.2.  General overview ............................................................................................ 90 
6.3.  General five-year analysis for 2021-2025 ....................................................... 91 
6.4.  Specific analysis .............................................................................................. 92 
6.4.1.  Recoveries by budget headings ......................................................... 92 
6.4.2.  Recoveries by legal entity residence ................................................. 93 

COUNTRY FACTSHEETS .............................................................................................. 94 

Belgium - Belgique/België ........................................................................................ 95 
Bulgaria – България ................................................................................................. 96 
Czech Republic - Česká republika ............................................................................ 97 
Denmark – Danmark ................................................................................................. 98 
Germany – Deutschland ............................................................................................ 99 
Estonia – Eesti ......................................................................................................... 100 
Ireland – Éire ........................................................................................................... 101 
Greece – Ελλάδα ..................................................................................................... 102 
Spain – España ........................................................................................................ 103 
France ...................................................................................................................... 104 
Croatia – Hrvatska ................................................................................................... 105 
Italy – Italia ............................................................................................................. 106 
Cyprus – Κύπρος ..................................................................................................... 107 
Latvia – Latvija ....................................................................................................... 108 
Lithuania – Lietuva ................................................................................................. 109 

 
 
Luxembourg ............................................................................................................ 110 
Hungary - Magyarország ......................................................................................... 111 
Malta  ....................................................................................................................... 112 
Netherlands - Nederland .......................................................................................... 113 
Austria – Österreich ................................................................................................ 114 
Poland – Polska ....................................................................................................... 115 
Portugal ................................................................................................................... 116 
Romania – România ................................................................................................ 117 
Slovenia – Slovenija ................................................................................................ 118 
Slovakia – Slovensko .............................................................................................. 119 
Finland – Suomi-Finland ......................................................................................... 120 
Sweden – Sverige .................................................................................................... 121 

ANNEXES ...................................................................................................................... 122 

 
 
 
 
LIST OF ABBREVIATIONS 

AMIF 
CAP 
CARDS 
CBC 
CF 
DA 
EAFRD 
EAGF 
EAGGF 
EFF 
EGF 
EMFF 
ERDF 
ESF 
ESIF 
FAL 
FDR 
FEAD 
FFL 
GUID 
HRD 
IDR 
IMS 
IPA 
IPARD 
ISF 
ISPA 
MM 
PAA 
PHARE 
PP 
RD 
REGD 
SA 
SAPARD 
TAIB 
TIPAA 
TOR 
YEI 

Asylum, Migration and Integration Fund 
Common Agricultural Policy 
Community Assistance for Reconstruction, Development and Stabilisation 
Cross-Border Cooperation 
Cohesion Fund 
Direct payments to farmers 
European Agricultural Fund for Rural Development 
European Agricultural Guarantee Fund 
European Agricultural Guidance and Guarantee Fund 
European Fisheries Fund 
European Globalisation Adjustment Fund 
European Maritime and Fisheries Fund 
European Regional Development Fund 
European Social Fund 
European Structural and Investment Funds 
Fraud Amount Level 
Fraud Detection Rate 
Fund for European Aid to the Most Deprived 
Fraud Frequency Level 
European Agricultural Guarantee and Guidance Fund – Section Guidance 
Pre-accession, Human Resources Development component 
Irregularities Detection Rate 
Irregularity Management System 
Instrument for Pre-accession Assistance 
Instrument for Pre-Accession Assistance for Rural Development 
Internal Security Fund 
Instrument for Structural Policies for Pre-Accession 
Market Support Measures 
Pre-Accession Assistance 2000-2006 
Pre-accession assistance programme 
Programming period 
Rural Development 
Pre-accession, Regional Development component 
Direct Support to Agriculture 
Special Accession Programme for Agricultural and Rural Development 
Transition Assistance and Institution Building 
Turkey Instrument for Pre-accession Assistance 
Traditional Own Resources 
Youth Employment Initiative 

3 

 
 
EXECUTIVE SUMMARY 

EXECUTIVE SUMMARY 

Revenue – traditional own resources (TOR) 

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 (TOR) per year. In 2025, 
the Member States reported 4 390 cases, i.e. 13% below 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).  

The Member States detected 285 cases of fraudulent irregularities involving a total financial 
amount of EUR 85.4 million. Compared to the 2021-2025 period, the number of fraudulent 
cases decreased by 40% and the respective amount of TOR decreased by 25%. In 2025, only 
6.5% of all reported cases were classified as fraudulent, accounting for 10% of the amount of 
TOR involved. However, the average amount per fraudulent case (EUR 299 536) was much 
higher than per non-fraudulent case (EUR 180 106). Compared to the 2021-2025 period, the 
number  of  non-fraudulent  irregularities  decreased  by  10%.  In  2025,  the  Member  States 
reported 4 105 cases. Despite this, the estimated and established amount of TOR increased by 
more than 36% to EUR 739.3 million. 

In  fraudulent  cases,  incorrect  value  became  the  primary  modus  operandi  as  regards  the 
amount, with 37 cases involving EUR 22.7 million of TOR, followed by incorrect origin or 
country  of  dispatching  (44  cases  totalling  EUR  21  million).  However,  the  Member  States 
reported  more  cases  of  smuggling  –  seized  and  confiscated  goods  and  incorrect 
classification/misdescription (72 cases for EUR 11.4 million and 47 cases for 14.7 million). 
For  non-fraudulent  cases, 
incorrect 
classification/misdescription  (1  765  cases  totalling  EUR  156  million)  but  in  terms  of  TOR 
amounts, incorrect value dominated in 2025 (871 cases totalling EUR 398 million).  

type  of  violation  remains 

the  most  common 

Sports footwear became the most affected type of goods in terms of value. China, the United 
States and India ranked as the top three countries of origin of goods affected by irregularities. 

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

In  2025,  inspections  by  anti-fraud  services  (37%  of  cases  and  74%  of  amounts)  played  a 
crucial  role  in  detecting  fraudulent  cases.  Non-fraudulent  instances  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. 

In  2025,  twelve  Member  States  reported  75  cases  of  smuggled  cigarettes  with  nearly 
EUR 13 million  of  the  estimated  amount  of  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 to 2024, nine Member States continued 
to report cigarettes smuggling cases exceeding EUR 10 000 in TOR whereas some Member 
States have re-appeared in the statistics.   

The recovery rate concerning fraudulent and non-fraudulent irregularities in TOR detected in 
2025  was  very  positive,  at  77%.  For  fraudulent  cases,  the  recovery  rate  of  28%  shows  a 

4 

 
 
EXECUTIVE SUMMARY 

decrease compared to the previous year. For non-fraudulent cases, the percentage was similar 
to 2024, resulting in a recovery rate of 82%, although the recovered amount was almost two 
times higher in 2025. The historical recovery rate went up from 84% and currently stands at 
86% (71% for fraudulent cases and 91% for non-fraudulent cases).  

Recovery is  a  constantly ongoing  process with  amounts growing  over time as EU, national 
and  other  administrative  appeal  processes  are  finalised  and  decisions  become  definitive. 
Furthermore, usually the financial 
is assessed after 
the recovery  actions  taken  by  national  authorities  as  regards  the  economic  operators are 
concluded. 

responsibility of  Member  States 

Expenditure - common agricultural policy 

EU  funding  granted  to  projects  or  operations  (partially)  affected  by  fraud  during  the  years 
2021-2025  is  about  EUR 156 million,  of  which about  EUR 132 million  were  the  fraudulent 
financial  amounts  involved  in  these  operations  during  2021-2025.  The  detection  of  these 
irregularities was  concentrated in  few Member States,  which is  not  justified by  the level  of 
concentration of payments. 

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. In 2024-2025, just 20% of the fraudulent irregularities 
related to support to agriculture concerned expenditure under CSP, being reported by a small 
minority  of  Member  States,  most  of  the  time  concerning  direct  payments  to  farmers,  often 
with small financial amounts involved. This percentage was 5% for rural development. This 
suggests the need for monitoring closely the capability of national management and control 
systems to detect fradulent irregularities affecting expenditure under CSP.       

For  rural  development,  during  2021-2025,  prevention  featured  in  31%  of  fraudulent 
irregularities and represented 25% of the financial amounts involved in fraud.  Mostly fraud 
prevention in rural development was the result of routine controls, but where prevention was 
partial,  higher  shares  of  prevented  amounts  were  due  to  few  cases  following  tips  from 
informants  or  existing  doubts.  Fraud  prevention  outcomes  were  much  lower  for  support  to 
agriculture,  where  routine  checks  accounted  for  most  of  prevention,  in  particular  for  direct 
payments to farmers, and partial prevention was rare. For both rural development and support 
to agriculture, most of fraud prevention concerned cases where less than EUR 100 000 were 
involved.  This  could  point  to  the  need  for  better  targeting  of  larger  beneficiaries  or  larger 
fraud  schemes,  especially  if  this  prevalence  of  small  cases  is  not  justified  by  the  general 
distribution of payments. 

Fraudulent  irregularities  related  to  direct  payments  to  farmers  mainly  concerned  false  
documentary  proof  or  false  requests.  Under  the  CAP  2023-2027,  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  the 
majority of these irregularities may not be related to non-respect of agricultural practices (but 
just  the  consequence  of  other  infringements)  or,  at  least,  they  may  have  not  been  reported 
because of controls on these practices. This points to the need for improving national control 
systems on actual agricultural practices. This is relevant both for the basic payments and for 
the new eco-schemes. 

Infringements  related  to  the  falsification  of  documentary  proof  or  requests  were  the  most 
frequent  in  relation  to  market  measures.  Past  analysis  suggests  that  most  of  the  fraudulent 

5 

 
 
EXECUTIVE SUMMARY 

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,  which  most  of  the  time  were  falsified.  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. A significant share of detections related to market 
measures followed the scrutiny of transactions, where the selection of undertakings should be 
based  on  the  analysis  of  risk  factors.  However,  actual  contribution  of  risk  analysis 
significantly depends on how this requirement has been translated in practice, going beyond 
criteria such as new beneficiaries, time from previous control or amount of the operation. 

Considering  the  years  2014-2025,  for  about  19%  of  the  irregularities  with  a  suspicion  of 
fraud,  the  suspicion  was  then  confirmed  as  established  fraud,  while  for  12%  the  suspicion 
was  dismissed.  Most  of  the  irregularities  where  there  was  a  suspicion  of  fraud  are  still 
classified  as  suspected  fraud,  even  if  several  years  have  elapsed  since  the  initial  reporting. 
Significant differences between Member States can be found.  

Considering the fraudulent irregularities reported during 2015-2025 that are now closed (so 
that the recovery process is complete), in rural development more than 75% of the relevant 
amounts have been recovered. For support to agriculture, recovery was even higher during all 
years of the period 2015-2025, with the exception of 2015, due to one large case related to 
market measures where significant amounts have not been recovered. However, both for rural 
development and support to agriculture, this assessment of recovery is heavily influenced by 
the fact  that about  90% of fradulent irregularities  with  amounts to  be recovered  reported  in 
2015-2025 are still open and they have not been included in the analysis, because recovery 
may still be ongoing. This high percentage may be due to the long time needed for closing 
fraudulent irregularities. However, this percentage is high also for earlier years. 

Sanctions have been imposed for half of the fraudulent irregularities (reported during 2015-
2025  and  that  are  now  closed)  and  unexpectedly  often  they  were  just  administrative 
sanctions.  Most  of  penal  sanctions  concerned  imprisonment  or  proportional  fines.  The 
combination  of  different  categories  of  penalties  was  not  frequent.  Imprisonment  was  rarely 
accompanied by other penalties to protect the EU financial interests, such as exclusion from 
future subsidies. Penal and administrative penalties were rarely combined.   

Expenditure - cohesion and fisheries policies 

In  relation  to  the  cohesion  and  fisheries  policies,  the  EU  funding  granted  to  operations 
(partly)  affected  by  fraud  during  the  years  2021-2025  is  EUR  7.6  billion,  of  which 
EUR 0.9 billion  were  the  fraudulent  financial  amounts  involved  in  these  operations  during 
2021-2025.  Where  just  part  of  expenditure  is  considered  fraudulent,  there  may  be  risks  of 
persistent funding to fraudsters, which warrants targeted controls of other final recipients or 
contractors. 

After an increase from  programming  period (PP) 2007-2013 to PP 2014-2020, the Member 
States  are  reporting  far  less  fraudulent  irregularities  during  PP  2021-2027.  There  is  also  a 
strong  decrease  in  the  reporting  of  non-fraudulent  irregularities,  which  follows  the  drop 
already experienced  during PP 2014-2020. The implementation of PP 2021-2027 seems to be 

6 

 
 
EXECUTIVE SUMMARY 

lagging  behind  and  this  might  temporarily  contribute  to  explain  part  of  the  decrease. 
However, this happened also for PP 2014-2020 and later the gap was not filled in. 

Fraud prevention can play a role during the whole programming period and cycle, even if it 
can  be  expected  to  decrease  as  the  operations  approach  finalisation.  For  PP  2021-2027, 
prevention features in about 60% of cases of fraud and represents about half of the financial 
amounts involved  in  fraud.  For PP 2014-2020,  during the years 2021-2025,  prevention still 
features  in  about  one  fourth  of  cases  of  fraud  and  represents  14%  of  the  financial  amounts 
involved  in  fraud  (13%  and  7%,  respectively,  for  non-fraudulent  irregularities).  Routine 
controls  were  more  prevalent  in  prevention  related  to  non-fraudulent  irregularities, 
contributing to a flatter trend across time than fraud prevention. Fraud prevention relied more 
also on other sources, including tips from informants or suspicions. 

From  PP  2007-2013  to  PP  2014-2020,  prevention  has  improved,  in  terms  of  number  of 
irregularities  where  more  than  half  of  irregular  or  fraudulent  disbursements  have  been 
prevented.  Actually,  for  non-fraudulent  irregularities,  the  above  mentioned  overall  drop  in 
reporting was due to the decrease of irregularities with no prevention, while the reporting of 
irregularities where at least part of the irregular disbursements were prevented increased. This 
may  support  the  hypothesis  that  prevention  improved,  contributing  to  some  extent  to  the 
overall drop in reporting of non-fraudulent irregularities. However, this may also be the result 
of  the  national  management  and  control  systems  excessively  shifting  focus  away  from 
targeted  controls  covering  past  transactions.  Finally,  most  of  prevention  concerned 
irregularities or fraud where less than EUR 1 million were involved. This could point to the 
need  for  better  targeting  of  larger  projects  or  larger  fraud  schemes,  especially  if  this 
prevalence of smaller cases is not justified by the general distribution of payments. 

The  first  detections  related  to  PP  2021-2027  seem  to  confirm  previous  findings  about  the 
areas  of  the  cohesion  policy  most  vulnerable  to  fraud.  So  far,  a  noticeable  share  of  the 
reported fraudulent irregularities concerned the digitalisation of SMEs, investment in energy 
efficiency,  research  and  innovation.  In  terms  of  financial  amounts  involved  in  fraudulent 
irregularities,  also  the  business  development  and  internationalisation  of  SMEs  and  the 
provision of water for human consumption come to notice. 

With  regard  to  fraudulent  irregularities,  during  PP  2014-2020,  the  most  frequent 
infringements  concerned  the  supporting  documents.  Fraudulent  infringements  of  contract 
provisions/rules  ranked  second  and  often  consisted  in  non-implementation  of  the  funded 
action.  Infringements  of  public  procurement  rules  were  the  second  most  reported  non-
fraudulent irregularities (after infringements of contract provisions/rules), but they rarely led 
to  a  suspicion  of  fraud.    Fraud  detection  seems  to  be  improving  with  the  start  of  reporting 
related  to  PP 2021-2027,  as  in  about  18%  of  the  public  procurement  infringements  a 
suspicion  of  fraud  was  reported.  However,  this  is  mainly  due  to  reporting  by  one  Member 
State.  Most  of  fraudulent  infringements  concerning  ethics  and  integrity  were  related  to 
conflict of interests.  

Risk analysis still only marginally contributes to detecting fraud, while information from civil 
society plays a larger role, but  decreasing.  On non-fraudulent irregularities, there may have 
been an improvement in risk analysis, 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.  

In relation to PP 2014-2020, the Fraud Detection Rate (FDR) is 0.22%, which is lower than 
the  FDR  recorded  for  the  PP  2007-2013  (0.42%).  For  PP  2021-2027,  the  FDR  is  still  just 

7 

 
 
EXECUTIVE SUMMARY 

0.05%.  There  is  a  similar  trend  for  the  indicator  related  to  non-fradulent  irregularities:  for 
PP 2021-2027, the Irregularities Detection Rate (IDR) is still just 0.09%, which is lower than 
the IDR for PP 2014-2020 (0.89%), which in turn is lower than the IDR for the PP 2007-2013 
(2.5%). The indicators for PP 2021-2027 are very low, even considering that pre-financing is 
frontloaded. In addition, in all these programming periods, there are significant differences in 
the reporting from different Member States. 

With  reference  to  irregularities  reported  during  the  years  2014-2025,  for  about  17%  of  the 
irregularities with a suspicion of fraud, the suspicion was then confirmed as established fraud. 
For 18%, the suspicion  was  instead dismissed. Most of the irregularities where there was a 
suspicion  of  fraud  are  still  classified  as  suspected  fraud,  even  if  several  years  have  elapsed 
since  the  initial  reporting.  This  is  no  clear  pattern  across  time.  Significant  differences 
between Member States can be found.  

During 2015-2025, for closed fraudulent irregularities, about 69% of the amounts to recover 
have  been  deducted  or  written  off,  27%  have  been  actually  recovered  and  4%  are  not 
recovered.    Nearly  all  the  amounts  deducted  or  written  off  are  related  to  fraudulent 
irregularities where this was the only form of recovery, with nearly all amounts fully charged 
to national budget. The fraudulent irregularities with no amounts deducted or written off were 
smaller and for them 87% of the amounts were actually recovered. However,  about 80% of 
fraudulent irregularities reported during 2015-2025 are not included in this analysis, because 
they are still open.  For closed non-fraudulent irregularities, findings are the opposite: more 
than 70% of the amounts to recover have been actually recovered, 28% have been deducted 
or written off and 1% are not recovered. About 30% of non-fraudulent irregularities are not 
included in this analysis, because they are still open. 

During  2015-2025,  sanctions  have  been  imposed  for  about  half  of  the  closed  fraudulent 
irregularities  and  just  3%  of  the  closed  non-fraudulent  irregularities.  For  some  of  the 
fraudulent  irregularities  the  sanctions  were  just  administrative.  Most  of  penal  sanctions 
concerned  imprisonment  or  national  proportional  fines.  The  combination  of  different 
categories of penalties was not frequent. In particular, imprisonment was rarely accompanied 
with  other  penalties  to  protect  the  EU  financial  interests,  such  as  exclusion  from  future 
subsidies. In addition, penal and administrative penalties were rarely combined.  

Concerning the funding  of other internal policies, the first fradulent irregularities related to 
PP  2021-2027  were  reported  in  2025.    During  the  years  2021-2025,  most  of  the  financial 
amounts  involved  in  fraud  concerned  AMIF.  The  reporting  of  non-fradulent  irregularities 
related to PP 2021-2027 accelerated in 2025 (especially for JTF), when it represented already 
65%  of  reporting.  During  the  years  2021-2025,  most  of  the  financial  amounts  involved 
concerned YEI (also because of one large case) and FEAD (the fund with the highest number 
of non-fraudulent irregularities).  

Expenditure – Neighbourhood policy 

The  irregularities  concerning  pre-accession  during  the  years  2021-2025  mostly  occurred  in 
connection with funds distributed under IPA I (2007-2013), IPA II (2014-2020) and IPA III 
(2021-2027). From 2021 to 2022, while the number of fraudulent irregularities decreased, the 
number  of  non-fraudulent  irregularities  experienced  an  exceptional  raise.  However,  the 
average financial amounts involved in non-fraudulent irregularities dropped. During the years 
2021-2024, the average financial amounts involved in fraudulent irregularities have increased 
and they have constantly been higher than those involved in non-fraudulent irregularities.  

8 

 
 
EXECUTIVE SUMMARY 

In 2025, irregularities mostly concerned just IPA II and IPA III. With regard to IPA II during 
the past 5 years, the number of non-fraudulent irregularities increased markedly in 2022 and 
since then it has been fluctuating around an average of about 270 irregularities per year. The 
reporting  of  fraud  dropped  in  2025.  Just  2  fraudulent  irregularities  were  reported,  with  just 
EUR 5 000  involved.  With  regard  to  IPA  III  (2021-2027)  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  IPA  II  during  the  years  2021-2025,  irregularities  were  reported  by  9  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  related  to  this  policy  area  increased 
significantly  in  2024,  also  because  of  an  OLAF  investigation  in  Albania.  The  financial 
amounts  involved  in  ‘Socio-economic  and  regional  development’  were  lower  than  those 
involved  in  the  other  areas.  With  regards  to  IPA  III,  4  beneficiary  countries  reported  51 
irregularities.  The  highest  number  of  irregularities  concerned  competitiveness  and  inclusive 
growth, mostly reported by Türkiye.  

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.  

Mandatory  reporting  of  detected  irregularities  and  fraud  through 
the  Irregularities 
Management  System  (IMS)  is  foreseen  for  all  new  instruments  supporting  candidate 
countries,  namely  the  Reform  and  Growth  Facility,  the  Moldova  Facility  and  the  Ukraine 
Facility.  

Ukraine  is  currently  the  only  country  for  which  all  necessary  preparatory  conditions  have 
been met, and its reporting authorities have already started using the system. Preparations for 
all other countries are still ongoing.  

In  2025,  Ukraine  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  irregularities  concerned  false  or  falsified 
documents.  Most  of  the  time,  falsification  was  about  inaccurate  information  reported  in 
certificates of completion of the works, which led to excessive payments or the overstatement 
of the cost of works.    

Expenditure - direct management 

In  the  2025  financial  year,  excluding  RRF  grants,  EUR 49  025  million  were  disbursed  in 
‘direct  management’  mode  and  the  Commission  recorded  441  recovery  items  classified  as 
irregularities, for a total value of EUR 86.34 million. Among these recovery items, 32 were 
reported as fraudulent irregularities, totalling EUR 5.52 million. 

During  2021-2025,  the  average  annual  ratio  of  financial  amounts  involved  in  fraudulent 
irregularities to total expenditure under direct management was 0.04%. This ratio peaked in 
2024  at  0.12%.  The  ratio  of  financial  amounts  involved  in  non-fraudulent  irregularities  to 
total expenditure under direct management was about 0.15%. 

In the 2025 financial year, the highest number of recovery items qualified as non-fraudulent 
irregularities was related to the budget heading ‘Single market, innovation and digital’ (269 

9 

 
 
EXECUTIVE SUMMARY 

items). The highest irregular (non-fraudulent) amounts registered (EUR 76.35 million) were 
also in this heading. 

During  2021-2025,  77.7%  of  the  total  number  of  recovery  items  qualified  as  fraudulent 
irregularities  and  91%  of  the  related  recovery  amounts  concerned  legal  entities  that  were 
resident in the EU-27. For non-fraudulent irregularities, this percentage is slightly lower for 
the number of items (75.5%) and much lower for the related recovery amounts (81.9%). 

10 

 
 
INTRODUCTION  

1. 

INTRODUCTION 

1.1. Scope of the document 

This document1 presents a statistical evaluation of the irregularities and fraud detected by the 
Member States during 2025, in the context of past years and relevant programming periods 
(PP).  It  covers  both  the  revenue  and  expenditure  sides  of  the  EU  budget.  This  analysis  is 
based  on  the  notifications  provided  by  national  authorities  of  cases  of  irregularities  and 
suspected or established fraud. Their reporting is performed in fulfilment of a legal obligation 
enshrined  in  sectoral  European  legislation.  The  document  accompanies  the  Annual  Report 
adopted  on  the  basis  of  Article 325(5)  of  the  Treaty  on  the  Functioning  of  the  European 
Union  (TFEU),  according  to  which  “The  Commission,  in  cooperation  with  Member  States, 
shall  each  year  submit  to  the  European  Parliament  and  to  the  Council  a  report  on  the 
measures  taken  for  the  implementation  of  this  article”.  Therefore,  this  document  should  be 
regarded as an analysis of the achievements of the Member States, in terms of detection and 
reporting. 

The methodology (including the definition of terms and indicators), the data sources and the 
data  capture  systems  are  explained  in  detail  in  the  Commission  Staff  Working  Document  – 
Methodology for the Statistical Evaluation of Irregularities accompanying the Annual Report 
on the Protection of the EU financial interests (the ‘PIF report’) for the year 20152. 

1.1. 

Structure of the document 

The  present  document  is  divided  in  five  parts.  The  first  part  includes  an  analysis  of  the 
irregularities reported in the area of traditional own resources (revenue). The four subsequent 
parts of the document are dedicated to irregularities reported in the area of expenditure (i) for 
the common agricultural policy; (ii) for cohesion policy, fisheries and other internal policies; 
(iii) for pre-accession and neighbourhood policies and (iv) under direct management. 

The  document  is  completed  by  27  country  factsheets,  which,  for  each  Member  State,  
summarise the main indicators and information on the detection of irregularities and fraud. 

Several  annexes  complement  the  information  and  data,  providing  a  global  overview  of  the 
irregularities reported according to the relevant sectoral regulations. Annexes 1 to 12 concern 
traditional  own  resources.  Annex  13  cover  all  the  expenditure  sectors  for  which  Member 
States and beneficiary countries have a reporting obligation. 

1 This document does not represent an official position of the Commission. 
2 SWD(2016)237final 
https://anti-fraud.ec.europa.eu/about-us/reports/annual-reports-protection-eus-financial-interests-pif-report_en 

11 

 
 
 
 
TRADITIONAL OWN RESOURCES 

2.  TRADITIONAL OWN RESOURCES (TOR) 

2.1. 

Introduction 

This section presents a statistical evaluation of fraud and irregularities detected by the Member 
States  in  2025  related  to  revenue  under  the  Traditional  Own  Resources  (TOR).  It  places  these 
detections  in  the  context  of  past  years.  The  statistics  are  based  on  the  total  estimated  and 
established  TOR  amounts  as  reported  by  the  Member  States  in  the  OWNRES  application.3 
Figures on recovery are based solely on established amounts. The OWNRES application enables 
the  Member  States  to  report  cases  of  fraud  or  irregularity  involving  TOR  of  more  than 
EUR 10 000, as required by Article 5(1) of Regulation No 2021/768 laying down implementing 
measures for the system of own resources of the European Union. For the sake of comparability 
with previous years, the analysis uses data for the European Union comprising 27 Member States 
(EU-27). The United Kingdom’s figures can nevertheless be found in the annexes. 

The  collection  of  TOR  is  delegated  to  the  Member  States  under  EU  law.  They  must make  the 
traditional own resources (which they have themselves established and collected) available to the 
EU  budget.4  The  Commission  must  be  assured  that  Member  States  are  complying  with  their 
responsibilities  for  collecting  and  making  the  corresponding  TOR  available.  Therefore,  the 
Commission retains considerable inspection powers with respect to TOR.  

2.2.  General trend 

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,  the 
Member States reported 4 390 cases which represents a decrease of 13% compared to this five-
year average. However, the total estimated and established amount of TOR (EUR 824.7 million) 
increased by almost 26% compared to the five-year average (EUR 656 million).5  

Graph TOR1 illustrates that the total number of cases (both fraudulent and non-fraudulent) rose 
steadily  until  2023,  before  decreasing  in  2024  and  2025.  Regarding  the  reported  amounts,  the 
figures  for  2022  and  2025  were  significantly  influenced  by  3  major  non-fraudulent 
irregularities reported by Belgium (involving more than EUR 480 million). 

3 This analysis is based on the OWNRES data extracted as of the cut-off date, 2 March 2026. For conversion from 
national currencies to EUR, the InforEuro exchange rate effective on 2 March 2026 was used. 
4 During the reporting period, the Commission received 75% of the customs duties collected, while Member States 
retained 25% as collection costs. 
5 See Annex 1. 

12 

 
 
TRADITIONAL OWN RESOURCES 

Graph TOR1: Total number of OWNRES cases and the related estimated and established amount (2021-2025) 

s
e
s
a
c

f
o
r
e
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6.000

5.000

4.000

3.000

2.000

1.000

0

R
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n
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A

900

800

700

600

500

400

300

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100

0

2021

2022

2023

2024

2025

  Estimated and established amount

   Number of cases

In 2025, the average amount  per case was EUR 187 859 compared to  the  five-year average of 
EUR 130 133. Germany reported by far the highest number of cases (1 634), followed by Spain 
(486)  and  France  (406).  Belgium  reported  the  highest  amount  of  TOR  involved  (more  than 
EUR 319 million). The second highest amount was reported by Germany (EUR 168 million) but 
no other country reported irregularities exceeding EUR 100 million of TOR.  

Irregularities reported as fraudulent 

The Member States  detected 285 cases of  fraudulent irregularities  involving  a total  financial 
amount  of  EUR  85.4  million.6  Compared  to  the  2021-2025  period,  the  number  of  fraudulent 
cases  decreased  by  40%  and  the  respective  amount  of  TOR  decreased  by  25%  (see  Graph 
TOR2).  However,  the  average  amount  per  fraudulent  case  in  2025  (EUR  299  536)  was  higher 
than the five-year average (EUR 240 367). Overall, the proportion of fraudulent cases has been 
relatively low. In 2025, only 6.5% of all reported cases were classified as fraudulent, accounting 
for 10% of the estimated and established amount of TOR involved. 

Graph TOR2: OWNRES cases reported as fraudulent and related estimated and established amount (2021-2025) 

s
e
s
a
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f
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6.000

5.000

4.000

3.000

2.000

1.000

0

R
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E

n
o

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600

500

400

300

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0

2021

2022

2023

2024

2025

  Estimated and established amount

   Number of cases

6 See Annex 2. 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
TRADITIONAL OWN RESOURCES 

In 2025, 7 Member States did not report any fraudulent case exceeding EUR 10 000, namely the 
Czech Republic, Ireland, Latvia, Luxembourg, Malta, the Netherlands, and Slovakia. Moreover, 
Luxembourg  and  Malta  did  not  report  fraudulent  cases  during  the  past  5  years.  On  the  other 
hand, certain Member States reported more than 50% of their cases as fraudulent (Bulgaria 96%, 
Estonia 75%, Greece 79%, Cyprus 64%, Lithuania 62%, and Portugal 100%).  

Irregularities not reported as fraudulent 

Compared to the 2021-2025 period, the number of non-fraudulent irregularities decreased by 
10% (see Graph TOR3). In 2025, the Member States reported 4 105 cases whereas the five-year 
average  stands  at  4 568  cases.  Despite  this,  the  estimated  and  established  amount  of  TOR 
increased  by  more  than  36%  to  EUR  739.3  million  compared  to  the  five-year  average  of 
EUR 542.2 million.7 In 2025, nearly 93.5% of cases were not classified as fraudulent, accounting 
for 90% of the estimated and established amount of TOR involved. 

Graph TOR3: OWNRES cases reported as non-fraudulent and related estimated and established amount (2021-2025) 

s
e
s
a
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f
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6.000

5.000

4.000

3.000

2.000

1.000

0

R
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n
o

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A

800

700

600

500

400

300

200

100

0

2021

2022

2023

2024

2025

  Estimated and established amount

   Number of cases

Malta  and  Portugal  did  not  report  any  non-fraudulent  irregularities  exceeding  EUR 10 000  in 
2025.  The  average  amount  per  non-fraudulent  case  in  2025  was  EUR  180  106  which  is 
significantly  lower  than  per  fraudulent  case.  The  five-year  average  for  2021-2025  stands  at 
EUR 118 699  per  non-fraudulent  case.  The  notable  differences  in  how  Member  States  qualify 
cases  as fraudulent or non-fraudulent  may be partly due to  their  classification practices,  which 
can impact comparisons of the amounts involved in reported cases. 

2.3.  Prevention 

The Member States are required to carry out customs checks and to report the findings of these 
checks  to  the Commission. Together with the Commission’s inspections they  support ensuring 
the effective functioning of the Customs Union, the protection of EU producers, and the uniform 
application of EU rules. They also contribute to identifying and eliminating loopholes that make 
it possible for fraudsters to abuse the system or evade paying the applicable duties. 

One  general  conclusion  drawn  from  the  Commission’s  TOR  inspections  in  the  Member  States 
remains  that  a  timely  and  proactive  approach  in  assessing  and  monitoring  risks  is 
indispensable  for  an  effective  protection  of  the  EU’s  financial  interests.  This  means  using  all 
available  sources  of  information  (including  RIF  and  AM  communications),  exchanging 
information  among  services  involved  and  giving  prompt  feedback  on  actions  taken.  Such 

7 See Annex 3. 

14 

 
 
 
 
 
 
 
 
TRADITIONAL OWN RESOURCES 

permanent  assessment,  exchange  of  information  and  monitoring  of  risks,  fraud  trends  and 
feedback is required for fine-tuning the measures to be taken and thus for better protection of the 
EU’s financial interests. 

2.4.  Detection and investigation 

2.4.1.  Types of infringement and modus operandi 

In fraudulent cases, incorrect value became the primary modus operandi as regards the amount, 
with 37 cases involving  EUR 22.7 million of TOR, followed by incorrect origin or country of 
dispatching  (44  cases  totalling  EUR  21  million).  However,  the  Member  States  reported  more 
cases  of  smuggling  –  seized  and  confiscated  goods  and  incorrect  classification/misdescription 
(72 cases for EUR 11.4 million and 47 cases for 14.7 million).  

For  non-fraudulent  cases,  the  most  common  type  of  violation  remains  incorrect  classification/ 
misdescription (1 765 cases totalling EUR 156 million) but in terms of TOR amounts, incorrect 
value dominated in 2025 (871 cases totalling EUR 398 million). 

Considering  all  cases  combined,  incorrect  value  recorded  the  highest  financial  amounts 
involved  (EUR  421  million  for  908  cases).  The  analysis  suggests  that  more  than  half  of  these 
cases (accounting for EUR 354 million) related to goods of Chinese origin. 

2.4.1.1.Goods affected by irregularities 

In 2025, sports footwear became the most affected goods in terms of value followed by electric 
bikes.  Some  products,  such  as  fish  fillets,  have  newly  appeared  in  the  statistics.  Electrical 
machinery and equipment,  cigarettes, inedible mixtures of fats  and oils, aluminium,  machinery 
and mechanical appliances (for example fort-lift trucks), textiles, articles of plastics, articles of 
iron or steel also ranked high in the statistics.  

China,  the  United  States,  and  India  were  the  most  frequently  reported  countries  of  origin  for 
goods affected by irregularities in 2025. These countries were also linked to the highest volume 
of TOR. Meanwhile, the United Kingdom  remained prominently ranked  in  the statistics, while 
cases involving Russia and Morocco saw a significant increase compared with 2024. 
The  Member  States  also  reported  75  cases  of  smuggled  cigarettes  in  OWNRES8.  Only  cases 
with reported type of fraud  smuggling were taken into account. The estimated amount of TOR 
involved  was  almost  EUR  13  million  (with  an  average  amount  per  case  EUR 172  480).  As 
shown in Table TOR1 below, 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 to 
2024, 9 Member States continued to report cigarettes smuggling cases exceeding EUR 10 000 in 
TOR9  whereas  some  Member  States  have  re-appeared  in  the  statistics after  a  break.10  Fifteen 
Member States did not report any case of cigarettes smuggling in 2025.11  

8 CN code 2402 2090. See Annex 12.  
9 Belgium, Bulgaria, Estonia, Greece, France, Croatia, Lithuania, Poland, and Romania.   
10 Germany, Italy, Austria. 
11  Czech  Republic,  Denmark,  Ireland,  Spain,  Cyprus,  Latvia,  Luxembourg,  Hungary,  Malta,  the  Netherlands, 
Portugal, Slovenia, Slovakia, Finland, and Sweden. 

15 

 
 
TRADITIONAL OWN RESOURCES 

Table TOR1: Cases of smuggled cigarettes in 2025 

Over  the  period  2021-2025,  the  Member  States  reported  504  cases  of  smuggled  cigarettes, 
accounting for almost EUR 132 million. Throughout this period, Lithuania reported the highest 
number of cases (136) and Belgium reported the highest amounts of TOR (EUR 59 million). 

2.4.1.2.Customs procedures affected by irregularities 

The statistical  evaluation  covers the following customs procedures:  release for free circulation, 
transit, customs warehousing, inward processing and other.12 Customs procedure release for free 
circulation remains the most affected customs procedure with 3 812 cases involving an overall 
estimated and established amount of EUR 746.3 million. This represents  87% of all cases and 
90%  of  the  amounts  reported  for  2025,  regardless  of  whether  they  are  fraudulent  or  non-
fraudulent. 

For fraudulent cases, the number of cases involving release for free circulation decreased from 
462  in  2024  to  202  in  2025.  A  similar  trend  can  be  observed  for  customs  warehousing  which 
decreased  from  16  to  8  cases,  although  the  reported  amount  stayed  almost  the  same  (around 
EUR 2  million).  In  2025,  the  registered  amounts  of  TOR  for  fraud  decreased  for  all  customs 
procedures  (especially  for  transit)  except  for  release  for  free  circulation  and  other  which 
increased.  

For  non-fraudulent  cases,  91%  of  the  estimated  and  established  amount  for  all  customs 
procedures  is  linked  to  release  for  free  circulation  (EUR  673  million).  In  monetary  terms,  the 
second  most  affected  customs  procedure  in  2025  was  inward  processing  (EUR  37.5  million) 
followed by customs warehousing (almost EUR 14 million). For transit, the number of reported 
cases increased (from 189 to 253) as well as the estimated and established amount of TOR (from 
EUR 2.5 million to about EUR 8 million). 

2.4.2.  Detection of irregularities by Member State 

Based  on  OWNRES  data,  Member  States  have  established  or  estimated  approximately 
EUR 824.7  million  related  to  reported  fraudulent  or  non-fraudulent  irregularities  where  the 
amount  exceeds  EUR  10 000.  In  2025,  the  total  established  amount  of  TOR  was  about 

12 See Annex 6 and 7. 

16 

CasesEstimated and established amountNEURBE3716,184BG6248,483DE116,786EE152,748,159EL101,755,683FR13854,852HR5600,919IT23,313,440LT162,442,743AT143,276PL2107,883RO187,600EU-277512,936,008MS 
 
 
TRADITIONAL OWN RESOURCES 

EUR 31.5 billion  (gross)  and  more  than  97%  was  duly  recovered  and  made  available  to  the 
Commission via the A-account.13  

OWNRES cases accounted for 2.68% of the total collected TOR (gross) amount in 2025. This 
detection  rate  marks  an  increase  from  2024,  when  it  was  1.83%.14  A  detection  rate  of  2.68% 
means  that  out  of  every  EUR  100  of  TOR  (gross)  established  and  collected,  EUR  2.68  is 
registered in OWNRES as irregular (fraudulent or non-fraudulent). 

The percentage varies across Member States, with countries like Belgium, Denmark, Germany, 
Estonia,  France,  Austria,  Finland,  and  Sweden  reporting  above-average  rates.  There  is  also  a 
difference  in  the  financial  impact  of  fraudulent  cases  and  non-fraudulent  cases;  the  average 
detection  rate  for  fraudulent  cases  is  considerably  lower  at  0.28%,  compared  to  2.41%  for 
non-fraudulent cases.15    

Furthermore, individual larger cases detected in a specific year may affect annual rates. Factors 
such as the type of traffic, type of trade, the level of compliance of the economic operators,  or 
the location of a Member State can influence these rates significantly. Additionally, the Member 
States’ customs control strategies to target high-risk imports and detect TOR-related fraud and 
irregularities can also impact the incidence rates. 

Detection of fraud 
In 2025, there has been a shift in the methods of detecting fraud compared to the previous year.16 
As  shown  in  Graph  TOR4  below,  the  majority  of  fraudulent  cases  were  discovered  through 
inspections  by  anti-fraud  services  (37%;  105  cases)  instead  of  post-release  controls,  which 
became the third most successful method of detecting fraud (23%; 65 cases). Customs controls 
carried out at the time of release of the goods came second with 36% (103 cases).  

Graph TOR4: Method of detection 2025 – Cases reported as fraudulent (by number of cases) 

these 

terms, 

In  monetary 
three  detection  methods  collectively  accounted  for  almost 
EUR 84 million,  representing  98%  of  the  estimated  and  established  amount  of  TOR  in 
fraudulent  cases.  When  compared  to  2024,  this  share  remained  nearly  unchanged.  In  2025, 
inspections by anti-fraud services came first with 74%, followed by post-release controls (14%) 
and release controls (10%) as shown in Graph TOR5 below. The remaining methods of detection 
have only a marginal impact.  

13 These are provisional figures for EU-27 available as of 15 March 2026. In the period 2021-2027, Member States 
retain 25% of the collected customs duties. This not only covers collection costs but also serves as an incentive to 
ensure a diligent collection of the amounts due. 
14 On the cut-off date for the 2024 PIF report, i.e., 15 March 2025. 
15 See Annex 4. 
16 See Annex 8 and 9.  

17 

 
 
 
TRADITIONAL OWN RESOURCES 

Graph TOR5: Method of detection 2025 – Cases reported as fraudulent (by estimated and established amount) 

Detection of irregularities 

In  2025,  the  majority  of  non-fraudulent  cases  were  detected  during  post-release  controls 
(51%;  2 096  cases)  which  is  a  continuous  trend.  Other  frequent  methods  of  detection  were 
release controls (23%; 962 cases) and voluntary admission (11%; 443 cases) which replaced tax 
audit in the third place (see Graph TOR6 below).  

Graph TOR6: Method of detection 2025 – Cases not reported as fraudulent (by number of cases) 

Concerning the estimated and established amount of TOR in non-fraudulent cases, in 2025, the 
for 
most  effective  detection  method  was  post-release  controls 
EUR 554 million  (see  Graph  TOR7  below).  Both  tax  audits  (7%)  and  release  controls  (7%) 
account for EUR 51.5 million.  

(75%)  accounting 

18 

 
 
 
TRADITIONAL OWN RESOURCES 

Graph TOR7: Method of detection 2025 – Cases not reported as fraudulent (by estimated and established amounts) 

2.5.  Recovery 

The  fraud  and  irregularity  cases  detected  in  2025  and  reported  via  OWNRES  account  for  an 
established  amount  of  EUR 804.6  million,  of  which  EUR  622.5  million  have  been  made 
available  by  the  27  Member  States,  resulting  in  a  recovery  rate  of  77%.17  This  is  a  positive 
outcome  given  that  recovery  is  typically  a  lengthy  process  which  evolves  over  time  and  is 
expected to further increase in the future.  

For an accurate comparison between 2025 and 2024, the recovery rate of 77% for the year 2025 
should  be  compared  to  the  recovery  rate  of  80%  for  the  year  2024  as  reported  in  past  year’s 
Statistical  Evaluation.18  Graph TOR8  below  shows  the  updated  annual  recovery  rate  (as  of  2 
March  2026)  for  all  cases  reported  between  2021  and  2025.  The  recovery  rate  has  fluctuated 
between 65% and 91% over the past five years.  

Graph TOR8: Annual recovery rate (2021-2025) 

100%

80%

60%

40%

20%

0%

2021

2022

2023

2024

2025

The  recovery  rate  for  2025  varies  across  the  Member  States.  In  absolute  terms,  Belgium 
recovered  the  highest  amount  (EUR  291  million).  Four  Member  States  (Estonia,  Latvia, 
Luxembourg, and Portugal) recovered 100%, i.e., the entire established amount has already been 
recovered for the EU budget. In 8 Member States, the recovery rate is above 90% (Belgium 92%, 
Czech Republic 98%, Denmark 98%, Ireland 95%, Lithuania 96%, Austria 95%, Finland 95%, 
Sweden 96%).  

For fraudulent cases, the recovery rate of 28% shows a decrease compared to the previous year. 
For  non-fraudulent  cases,  the  percentage  was  similar  to  2024,  resulting  in  a  recovery  rate  of 
in  2025 
82%,  although 

recovered  amount  was  almost 

times  higher 

two 

the 

17  The  recovery  rate  includes  both  amounts  recovered  from  the  economic  operators  and  amounts  funded  by  the 
Member States. 
18 Section 2.2.3 of ‘Statistical evaluation of irregularities reported for 2024’, SWD(2025) 230 final 

19 

 
 
 
 
TRADITIONAL OWN RESOURCES 

(EUR 602.6 million).19  Member  States  continue  to  be  more  successful  in  recovering  non-
fraudulent amounts, which is a consistent trend. OWNRES data confirms that the recovery rate 
for  fraudulent  cases  is  overall  much  lower  than  for  non-fraudulent  cases,  as  shown  in  Table 
TOR2 below.  

 Table TOR2: Historical recovery rate (HRR) 

The  historical  recovery  rate  (HRR)  went  up  from  84%  and  currently  stands  at  86%.  The 
historical recovery rate accounts for the recovery results of both complex and easy cases. Only 
closed cases are taken into account. Therefore, cases from 2023 onwards  are excluded because 
these  are  predominantly  easy  cases  (complex  cases  typically  cannot  be  closed  within  3  years). 
Recovery is a constantly ongoing process with amounts growing over time as  the EU, national 
and other administrative appeal processes are finalised and final decisions made.  

The Commission examines the measures taken by the Member States concerning the recovery of 
TOR,  including  the  timely  notification  of  the  customs  debt  and  the  necessary  enforcement 
procedures.  Based  on  the  inspection  findings  (see  below),  the  Commission  assesses  the 
effectiveness  and  diligence  of  the  Member  States  in  this  area.  The  Commission  requests 
measures  to  be  taken  to  remedy  any  shortcomings.  If  TOR  are  not  established  or  recovered 
because of an administrative error by a Member State, the Commission applies the principle of 
financial liability, making individual Member States responsible for the error. However, those 
recoveries are not always recorded in OWNRES. 

2.6.  Other 

2.6.1.  Commission’s inspections 

The  Commission  services20  scrutinise  the  way  in  which  the  Member  States  discharge  their 
responsibility  for  collecting  TOR.  The  inspections  carried  out  for  this  purpose  are  based  on 
Council  Regulation  2021/768  and  have  these  main  objectives:  (i)  to  protect  the  financial 
interests of the EU and ensure that the burden of financing the EU expenditure is fairly shared 
among  the  Member  States,  (ii)  to  maintain  a  level  playing  field  for  economic  operators,  and 
(iii) to keep the budgetary authority and the European Court of Auditors properly informed.  

The  TOR  inspections  are  carried  out  either  as  regular  inspections  on  the  spot  in  the  Member 
States (or remotely if necessary) or as desk audits. In 2025, the Commission focused its regular 
on-the-spot inspections in the Member States on (i) the control strategy for tariff quotas, (ii) 
the reliability of the normal and separate account statements, and (iii) the separate account 
cases and the corrections of the normal account  (as a second topic in  all inspected Member 
States).  Furthermore,  the  Commission  also  continued  its  close  monitoring  of  Member  States’ 
actions  and  followed  up  on  previously  initiated  desk  audits  and  observations  made  during  its 
inspections. 

19 See Annex 10. The estimated amounts are excluded. 
20 Directorate-General for Budget. While DG Budget has the operational responsibility within the Commission for 
implementing  inspections  covering  the  collection  of  TOR,  other  Commission  services  (e.g.  DG  TAXUD)  are 
regularly invited to take part in these inspections to provide specific technical expertise. 

20 

IrregularitiesHRR 1989-2022Reported as fraudulent71.13 %Reported as non-fraudulent90.81 %Total85.73 % 
 
 
TRADITIONAL OWN RESOURCES 

As regards the errors detected and findings made (systematic and one-off), DG Budget is taking 
appropriate action on the financial aspect, asking for unpaid amounts to be made available and 
for  interest  to  be  paid,  where  appropriate.  Shortcomings  with  potential  legislative  implications 
are forwarded to DG TAXUD, for further assessment. Where systematic shortcomings have been 
identified, the national authorities have been requested to take appropriate action to strengthen 
their national systems.  

2.6.2.  Examination of write-off reports 

Under  Article  13(3)  of  Council  Regulation  No 609/2014,  the  Member  States  are  obliged  to 
inform  the  Commission  about  cases  where  amounts  of  traditional  own  resources  exceeding 
EUR 100 000 have been written-off from the separate account (and thus  not made available to 
the  EU  budget)  because  they  were  declared  or  deemed  irrecoverable.  For  amounts  below  the 
reporting  threshold,  the Commission  routinely  assesses  samples  of  cases  during  its  on-the-spot 
inspections. The purpose of the Commission’s examination of the write-off reports is to  assess 
the degree of diligence shown by the Member States in fulfilling their autonomous responsibility 
to establish and recover from the economic operators the customs duties representing TOR. 

In 2025, 16 Member States submitted to  the Commission  services  for  assessment 68 write-off 
reports totalling EUR 116.2 million.21 For 20 write-off reports, the Commission concluded that 
the  Member  States  satisfactorily  demonstrated  that  traditional  own  resources  were  lost  for 
reasons  not  imputable  to  the  Member  States.  However,  in  28  cases,  amounting  to 
EUR 80.1 million, the Commission considered that this was not the case, and the Member States 
were financially responsible for the loss. 

21 See Annex 11. 

21 

 
 
 
 
 
Common Agricultural Policy 

3.  COMMON AGRICULTURAL POLICY  

3.1. 

Introduction 

This  section  presents  a  statistical  evaluation  of  irregularities  and  fraud  reported  by  the 
Member  States  in  2025  in  expenditure  under  the  common  agricultural  policy  (CAP).  It 
provides context to these detections by looking at past years.  

Nearly  all  expenditure  under  the  CAP  is  disbursed  by  the  Member  States  under  shared 
management. As from 2023, each Member State has a CAP Strategic Plan (CSP), combining 
interventions  in  the  form  of  direct  payments,  rural  development,  and  sectoral  interventions. 
The  Member  States  must  report  irregularities  and  fraud  to  the  Commission  through  the 
Irregularity Management System (IMS).  

In  this  section,  when  reference  is  made  to  fraud,  this  includes  both  suspected  fraud  and 
established fraud22. Non-fraudulent irregularities must be reported in IMS only when they are 
detected  after  the  expenditure  has  been  introduced  in  a  statement  submitted  to  the 
Commission.  Fraudulent  irregularities  must  always  be  reported  in  IMS.  Unless  specified 
otherwise, when reference is made to financial amounts involved in irregularities, this means 
the  EU-share  of  these  financial  amounts.  Both  fraudulent  and  non-fraudulent  irregularities 
must  be  reported  when  involving  financial  amounts  above  EUR 10 000. Several  Member 
States  also  reported  some  irregularities  under  this  threshold.  These  irregularities  might  be 
inter-linked, bringing the total financial amounts involved above the threshold. 

For the purpose of communicating the following findings, CAP is split into two main parts: 
(i) support to agriculture (SA), which includes direct aid to farmers (DA) and measures 
to  regulate  the  market  (market  measures  or  sectoral  interventions)  (MM);  (ii)  rural 
development (RD). In general, the following findings refer to EU-27.23   

3.2.  General trend 

Graph  NR1  below  provides  an  overview  of  the  number  of  irregularities  reported  as 
fraudulent, broken down by year and type of support, for the  years 2021-2025. Graph NR2 
shows the financial amounts involved in these irregularities. 

22 Suspected fraud means an irregularity that gives rise to the initiation of administrative or judicial proceedings 
at national level in order to establish the presence of intentional behaviour, in particular fraud, as referred to in 
Article 1(1)(a) of the Convention drawn up on the basis of Article K.3 of the Treaty on European Union, on the 
protection  of  the  European  Communities’  financial  interests.  Regardless  of  the  approach  adopted  by  each 
Member State, ratification of the 1995 Convention has equipped every country with a basis for prosecuting and 
possibly imposing penalties for specific conducts. Then the Directive (EU) 2017/1371 (so-called PIF Directive) 
defines  what  the  Member  States  are  requested  to  regard  as  fraud  affecting  the  EU’s  financial  interests.  If 
following a criminal proceeding a guilty verdict is issued and is not appealed against, the case can be considered 
established fraud. If following an administrative proceeding, the deciding body establishes the intentionality of 
the  irregular  conduct,  this  is  also  considered  established  fraud.  See  ‘Handbook  on  reporting  irregularities  in 
shared management’ (2025). 
23 For the methodology to identify the irregularities related to direct payments to farmers, market measures and 
rural development, please see Annex 12 to the  ‘Statistical evaluation of  irregularities reported for 2021: own 
resources, agriculture, cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2022)307. 

 
 
 
Common Agricultural Policy 

In 2024 and 2025, fraudulent irregularities related to expenditure under CSP represented: 

•  20%  of  fraudulent  irregularities  related  to  support  to  agriculture  (just  15%  in  terms  of 

financial amounts involved), most of the time for direct payments to farmers; 

•  5% of fraudulent irregularities related to rural development (just 1% in terms of financial 

amounts involved). 

The  fraudulent  irregularities  reported  in  IMS  so  far  do  not  include  yet  the  outcome  of  an 
investigation  of  the  European  Public  Prosecutor’s  Office  (EPPO)  about  a  large-scale 
agricultural funding fraud in Greece (see Box NR1 below)  

Box NR1: EPPO is investigating fraud involving agricultural funds in Greece. 

In  the  2025  Annual  Report,  the  EPPO  published  the  following  information  about  an ongoing  investigation  in 
Greece related to large-scale agricultural funding fraud: 

“In an investigation led by the EPPO in Athens (Greece), an organised criminal group, allegedly involved in a systematic 
large-scale  subsidy  fraud  scheme  and  money-laundering  activities,  has  been  identified.  On  22  October  2025,  37  suspects 
were arrested, and searches were carried out throughout the country. The investigation revealed that, since at least 2018, 
the  group  is  believed  to  have  been  operating  across  Greece,  with  a  clear  hierarchical  structure  and  distinct  roles.  They 
allegedly  exploited  procedural  gaps  in  the  submission  of  Single  Aid  Applications  under  the  EU’s  Common  Agricultural 
Policy  (CAP),  using  falsified  or  misleading  documents  to  claim  agricultural  subsidies  from  the  Hellenic  Payment  and 
Control Agency for Guidance and Guarantee Community Aid (O.P.E.K.E.P.E.). The members of the organised crime group 
were  also  suspected  of fraudulently  declaring agricultural  land  and pastures  that did  not  belong  to  them or  did not  meet 
eligibility  criteria.  They  allegedly  inflated  livestock  numbers  to  increase  their  subsidy  entitlements.  To  conceal  the  illicit 

23 

10423713316817514714723018611411679626239037036329505010015020025030035040045020212022202320242025Graph NR1: CAP -number of irregularities reported as fraudulent by type of support (EU27)Support to agriculture (SA)Rural development (RD)SA/RDTOTAL CAP EU2714.76.86.36.66.716.912.420.624.314.90.70.30.20.60.332.319.627.131.521.80510152025303520212022202320242025MillionsGraph NR2: CAP -amounts involved in irregularities reported as fraudulent by type of support (EU27)Support to agriculture (SA)Rural development (RD)SA/RDTOTAL CAP EU27 
 
 
Common Agricultural Policy 

origin of the proceeds, the suspects were believed to have issued fictitious invoices, routed the funds through multiple bank 
accounts, and mixed them with legitimate income. Part of the misappropriated money was allegedly spent on luxury goods, 
travel,  and  vehicles,  to  disguise  the  funds as  lawful assets.  In  the  course of  the  preliminary  investigation, 324  individuals 
were identified as subsidy recipients, causing an estimated damage of more than €19.6 million to the EU budget. Of these, 
42 were believed to be involved in this case and were considered current members of the organised crime group. Most of 
them appear to have no actual connection to farming, suggesting that their participation served solely to facilitate the fraud. 
All persons concerned are presumed innocent until proven guilty in the competent Greek courts of law.” 

https://www.eppo.europa.eu/assets/annual-report-2025/pdfs/EPPO_Annual_Report_2025_en.pdf 

In general, funding from the EU budget to a project or operation is accompanied by funding 
from  the  national  budget  (co-financing).  The  financial  amounts  mentioned  above  are  the 
EU-share directly involved in the reported irregularities. Available data provide information 
also  on  the  total  financial  amounts  directly  involved  in  the  irregularities  (EU-share  plus 
national share = public contribution share). Irregularities affect projects or operations that are 
not necessarily considered totally irregular. Part of the funding to these projects might still be 
considered regular. Available data provide information also on the EU-share and total value 
of the public contribution granted to the projects or operations affected by the irregularities. 
As shown by Graph NR3, the funding (EU-share) granted to projects or operations affected 
by 
is  about 
EUR 156 million,  of  which  about  EUR 132 million  were  the  fraudulent  financial 
amounts (EU-share) involved in these projects or operations in 2021-2025 (85%). In terms of 
total  public  contribution,  the  funding  granted  to  projects  or  operations  affected  by 
irregularities reported as fraudulent during the years 2021-2025 is about EUR 195 million, of 
which  about  EUR 167 million  were  the  fraudulent  financial  amounts  involved  in  these 
projects or operations in 2021-2025 (86%). 24  

the  years  2021-2025 

fraudulent  during 

reported  as 

irregularities 

24 A project/operation can be affected by more than one irregularity. So while summing up the funding to the 
operations associated to each relevant irregularity, there is a risk of  considering the same operation more than 
once. To reduce this risk, an analysis has been carried out to identify the operations/projects affected by more 
than one irregularity. Through the automatic Excel function ‘remove duplicates’, the exact match of operational 
programme (CCI), project name, project number and funding (EU-share and total public contribution) has been 
considered  as  pointing  to  the  same  project/operation.  However,  for  a  significant  share  of  the  relevant 
irregularities,  CCI,  project  name  and  number  are  blank.  This  means  that  it  was  enough  that  the  values  of  the 
contribution (EU-share and total public) and the Member State were the same to consider that the irregularities 
were referring to the same project/operation. For all duplicates, the project name and number were empty. So all 
duplicates were such because of the values of the contributions and the CCI or just because of the values of the 
contribution  (in  case  also  the  CCI  was  empty).  However,  this  could  be  wrong  and  might  be  due  to  support 
schemes resulting in some sort of standardised contribution to beneficiaries. This would mean that the values of 
operations  in  Graph  NR3  have  been  excessively  reduced.  However,  at  EU-27  level,  the  reduction  that  is  just 
based on the values of the contribution represents about 0.5% of the total values, so the findings of the analysis 
can still be considered as valid. 

24 

 
 
Common Agricultural Policy 

Graph  NR4  below  provides  an  overview  of  the  number  of  irregularities  not  reported  as 
fraudulent by the Member States. Graph NR5 focuses on the financial amounts. The irregular 
financial amounts fluctuated strongly, mainly due to the reporting in some years, where few 
cases relating to market measures  or rural development involved exceptional amounts. 

Non-fraudulent  irregularities  related  to  support  to  agriculture  under  CSP  started  being 
reported in 2024. In 2025, they more than doubled with respect to 2024 and got to represent 

25 

4189213252995156451192167571335195050100150200250SARDMIXTotal CAPMillionsGraph NR3: Irregularities reported as fraudulent 2021-2025Financial amounts involved in irregularitiesand total value of public contribution in affected operationsIrregularity (EU-share)Value operations (EU-share)Irregularity (public contrib.)Value operations (public contrib.)9818536797356032,2142,5672,9092,4083,327313779159473,2263,4573,6673,3023,97705001,0001,5002,0002,5003,0003,5004,0004,50020212022202320242025Graph NR4: CAP -number of irregularities not reported as fraudulent by type of support (EU27)Support to agriculture (SA)Rural development (RD)SA/RDTOTAL CAP EU2710284413433828816010720625473185.8177.1203.6148.1242.705010015020025030020212022202320242025MillionsGraph NR5: CAP -amounts involved in irregularities not reported as fraudulent by type of support (EU27)Support to agriculture (SA)Rural development (RD)SA/RDTOTAL CAP EU27 
  
 
 
 
Common Agricultural Policy 

about 44% of the non-fraudulent irregularities related to support to agriculture in this year, 
but  just  23%  in  terms  of  financial  amounts  involved.    Mostly,  the  reported  CSP 
irregularities were related to direct payments to farmers. However, in 2025, the number of 
non-fraudulent  irregularities  related  to  market  measures  under  CSP  represented  more  than 
10% of those related to support to agriculture under CSP.  

In  2024-2025,  non-fraudulent  irregularities  related  to  rural  development  under  CSP 
represented just 2% of non-fraudulent irregularities related to rural development.  

As  shown  in  Graphs  NR2  and  NR4  above,  several  irregularities  concerned  both  rural 
development and support to agriculture (SA/RD), basically always  rural development and 
direct aid to farmers.  

The detection of irregularities was concentrated in a few Member States. During the years 
2021-2025, the fraudulent irregularities notified by the top five Member States in terms of 
number of cases accounted for about 69% of all irregularities reported as fraudulent (60% of 
the financial amounts for the top five Member States in terms of financial amounts). In 2025, 
this  concentration  was  even  higher  at  73%,  in  terms  of  number  of  irregularities  (64%,  in 
terms  of  financial  amounts).  In  terms  of  non-fraudulent  irregularities,  during  the  years 
2021-2025,  the  top  five  Member  States  reported  58%  of  all  non-fraudulent  irregularities 
(69% of financial amounts for the top five Member States in terms of financial amounts). In 
2025, this concentration was even higher at 60%, in terms of number of irregularities (71%, 
in  terms  of  financial  amounts).  A  deeper  analysis  of  concentration  is  referred  to  in 
Section 3.4.4.  

Different  CAP  areas  cannot  be  simply  compared  on  the  basis  of  the  financial  amounts 
involved in irregularities, because this metric is influenced by the total amount of payments 
received by the Member States. For example, these payments are much higher for direct aid 
than  rural  development.  A  better  comparison  can  be  based  on  the  fraud  (FDR)  and 
irregularity (IDR) detection rates. These are ratios between the financial amounts involved 
in  the  relevant  irregularities  (fraudulent  for  FDR  and  non-fraudulent  for  IDR)  during 
2021-2025 and the relevant payments received by the Member States during the same period. 
These rates are shown in Table NR1 below. 

Detection rates for support to agriculture were much lower than for rural development. 
However,  one  part  of  support  to  agriculture,  interventions  in  agricultural  markets, 
accounted for a FDR that is similar to rural development and for the highest IDR.  

26 

FDR IDRDirect payments (DA) (3)0.02%0.05%Intervention in agricultural markets (MM) (4)0.10%1.51%Support to agriculture (SA) (2)0.02%0.14%Rural development (RD) (1)0.12%0.85%Total CAP0.05%0.34%(2) SA: it does not include the financial amounts involved in SA/RD irregularities. Should they be added, FDR would still be 0.02% and IDR would be 0.15% (3) DA: it includes also the financial amounts involved in irregularities with both direct payments and rural development infringements. Should these 'mixed' irregularities be excluded, FDR would be 0.01% and IDR would be 0.04% (4) MM: it includes also the financial amounts involved in irregularities with both market measures and rural development infringements. Should these 'mixed' irregularities be excluded, FDR would still be 0.10% and IDR would be 1.50% Table NR1: FDR and IDR by type of CAP expenditure - EU27Type of expenditureIrregularities detected and reported 2021-2025 / Payments 2021-2025Total1.61%0.39%0.97%(1) RD: it does not include the financial amounts involved in SA/RD irregularities. Should they be added, FDR would still be 0.12% and IDR would be 0.88% 0.07%0.16% 
 
Common Agricultural Policy 

3.3. 

Prevention 

Prevention is the first step of the anti-fraud cycle. This analysis being based on IMS data, 
prevention means early detection so that financial amounts involved in an irregularity or in a 
case of fraud are not  paid to  the beneficiary. Early  detection may avoid  the payment to  the 
beneficiary of all financial amounts involved (total prevention) or just part of them, because 
part of the payments related to the irregularity or to the case of fraud have already been made 
before detection (partial prevention).  

For  non-fraudulent  irregularities,  data  in  IMS  cannot  be  used  to  capture  the  full 
outcome  of  prevention  activities.  This  limitation  does  not  apply  to  fraudulent 
irregularities.  There  is  no  obligation  for  the  Member  States  to  report  non-fraudulent 
irregularities detected before expenditure has been introduced in a statement submitted to the 
Commission. In this respect, IMS data can only be used to measure the effect of prevention 
for irregularities that, at the same time, are related to both (i) items of expenditure that have 
not been paid (as a consequence of early detection) and (ii) items of expenditure included in a 
statement to the Commission (which triggers the obligation to report in IMS). The derogation 
to reporting in IMS is more likely to apply to ‘total prevention’ non-fraudulent irregularities, 
but  it  cannot  be  excluded  that  there  are  ‘partial  prevention’  non-fraudulent  irregularities 
where  the  expenditure  already  paid  out  has  not  been  include  in  a  statement  to  the 
Commission yet. This limitation does not apply to fraudulent irregularities, because they must 
be  reported  in  IMS  also  where  no  payments  have  been  made  yet.  So,  for  fraudulent 
irregularities, IMS data can be used to assess the full outcome of prevention activities. 

to  rural  development  prevented 

Graph NR6a  below  shows  that,  during  2021-2025,  the  early  detection  of  fraudulent 
irregularities  related 
the  disbursement  of  about 
EUR 22 million,  which  is  about  25%  of  the  financial  amounts  involved  in  fraud  during 
these 5 years. Graph NR6a also shows that this prevention effect featured in about 31% of 
fraudulent  irregularities.  During  2021-2025,  for  about  one  fifth  of  the  fraudulent 
irregularities related to rural development there was total prevention and the number of 
fraudulent  irregularities  with  partial  prevention  increased  with  respect  to  the  years  2016-
2020. Consequently, the share of irregularities with  no prevention decreased from 75% in 
2016-2020  to  69%  in  2021-2025.  Most  of  prevention  in  fraud  related  to  rural 
development  concerned  cases  where  less  than  EUR 100  000  were  involved.  However, 
with respect to 2016-2020, there was an increasing number of cases above this value, which 
accounted  for  most  of  the  financial  amounts  related  to  fraud  in  rural  development  during 
2021-2025.  A  general  distribution  of  the  payments  in  rural  development  by  value  that  was 
skewed  toward  values  below  EUR 100 000  may  contribute  to  explain  this  prevalence  of 
financial  amounts  below  EUR  100 000  involved  in  detected  fraud.  However,  should  the 
distribution  of  the  amounts  involved  in  reported  fraudulent  irregularities  be  significantly 
more  skewed  towards  values  below  EUR 100 000  than  the  general  distribution  of  relevant 
payments, this could point to a need for more targeting of larger beneficiaries or larger 
fraud schemes. This cannot be tested, because the general distribution of payments was not 
available for this analysis. 

27 

 
Common Agricultural Policy 

‘partial  prevention’  non-fraudulent 

For  non-fraudulent  irregularities  related  to  rural  development,  prevention  measurable 
through IMS in 2021-2025 was very low (see Graph NR6b below). During 2021-2025, the 
number  of 
to  rural 
development increased with respect to 2016-2020, mainly with prevented amounts between 
10%  and  50%  of  the  total  amounts  involved  in  the  irregularity.  ‘Total  prevention’ 
irregularities decreased instead, but overall the number of irregularities with a prevention 
component  increased  by  about  120%.  As  mentioned,  data  on  ‘total  prevention’  is  more 
likely to be incomplete, because of the aforementioned derogation to reporting in IMS. For 
nearly  all  non-fraudulent  irregularities  featuring  prevention,  less  than  EUR  100  000 
were involved, even if there was an increase also for classes above EUR 100 000 from the 
years 2016-2020 to the years 2021-2025.  

irregularities  related 

28 

86.812.89.015.317.711.966.718.04.13.45.26.63.022.424.6%21.2%32.7%32.3%31.0%40.4%31.2%17.2%24.1%27.7%25.4%27.2%20.3%25.1%0.0%5.0%10.0%15.0%20.0%25.0%30.0%35.0%40.0%45.0%0.020.040.060.080.0100.0120.02016-2020202120222023202420252021-2025MillionsGRaph NR6a: rural development prevention and fraudulent irregularities: cases and financial amountsPaidPrevented% irregularities with prevention% financial amounts prevented 
 
 
 
Common Agricultural Policy 

Most of prevention in rural development was based on routine controls. However, where 
prevention was partial also other factors played a role: (i) for fraudulent irregularities, the few 
cases  that  were  started  because  of  tips  from  informants  or  suspicions  accounted  for  higher 
shares of the ‘partially prevented’ amounts; (ii) many non-fraudulent irregularities followed 
administrative enquiries and they accounted from most of the ‘partially prevented’ amounts.     

Fraud prevention outcomes are much lower for support to agriculture, where just 5% of 
the  fraudulent  financial  amounts  were  prevented  and  prevention  concerned  just  11%  of 
fraudulent irregularities (see Graph NR7a below)25. During 2021-2025, for about 10% of the 
fraudulent irregularities there was total prevention, which represents an increase from the 
years 2016-2020. Fraudulent irregularities with partial prevention were rare. Consequently, 
the  share  of  irregularities  with  no  prevention  decreased  from  the  years  2016-2020  to  the 
years 2021-2025 (from 94% to 89%). Nearly all prevention in fraud related to support to 
agriculture concerned cases where less than EUR 100 000 were involved and there is no 
change from 2016-2020 to 2021-2025. See above about the comparison with the distribution 
of  number  of  payments  by  value  to  test  the  hypothesis  about  a  need  for  more  targeting  of 
larger beneficiaries or larger fraud schemes. 

25 The significant difference in the amounts already paid out (see Graph NR7a: from about EUR 100 million in 
2016-2020  to  EUR  38  million  in  2021-2025)  is  due  to  2  large  ‘no  prevention’  fraudulent  irregularities, 
accounting together for about EUR 50 million. These 2 irregularities concerned market measures. 

29 

438.381.486.9152.597.3194.2612.321.31.01.57.09.911.330.86.0%4.2%5.2%10.7%12.1%11.4%9.0%4.6%1.2%1.7%4.4%9.3%5.5%4.8%0.0%2.0%4.0%6.0%8.0%10.0%12.0%14.0%0.0100.0200.0300.0400.0500.0600.0700.02016-2020202120222023202420252021-2025MillionsGRaph NR6b: rural development prevention and non-fraudulent irregularities: cases and financial amountsPaidPrevented% irregularities with prevention% financial amounts prevented 
 
 
 
Common Agricultural Policy 

For non-fraudulent irregularities related to support to agriculture, prevention measurable 
through IMS in 2021-2025 was even lower (see Graph NR7b below). During 2021-2025, the 
number of ‘no prevention’ and ‘total prevention’ non-fraudulent irregularities related to 
support  to  agriculture  decreased  with  respect  to  2016-2020,  while  partial  prevention 
remained stable. As mentioned, data on ‘total prevention’ is  more likely  to be incomplete, 
because of the derogation to reporting in IMS. For nearly all non-fraudulent irregularities 
featuring prevention less than EUR 100 000 were involved. 

Routine checks accounted for most of prevention in support to agriculture, in particular 
for direct payments to farmers. In relation to market measures (i) also risk analysis played 
a  role  in  prevention,  especially  for  fraudulent  irregularities;  (ii)  for  most  of  non-fraudulent 
irregularities with prevention, control had been started because of administrative enquiries.  

30 

100.114.46.46.15.75.338.01.90.30.40.20.90.42.26.0%2.9%9.7%2.3%21.4%15.2%10.8%1.9%2.3%6.1%3.5%13.1%6.9%5.5%0.0%5.0%10.0%15.0%20.0%25.0%0.020.040.060.080.0100.0120.02016-2020202120222023202420252021-2025MillionsGRaph NR7a: support to agricultureprevention and fraudulent irregularities: cases and financial amountsPaidPrevented% irregularities with prevention% financial amounts prevented310.8101.782.839.832.032.0288.34.90.21.30.81.70.74.84.6%1.9%4.5%5.2%6.1%4.4%4.3%1.5%0.2%1.6%2.1%4.9%2.2%1.6%0.0%1.0%2.0%3.0%4.0%5.0%6.0%7.0%0.050.0100.0150.0200.0250.0300.0350.02016-2020202120222023202420252021-2025MillionsGRaph NR7b: support to agricultureprevention and non-fraudulent irregularities: cases financial amountsPaidPrevented% irregularities with prevention% financial amounts prevented 
 
 
 
 
Common Agricultural Policy 

3.4.  Detection and investigation 

3.4.1.  Types of infringement and modus operandi 

3.4.1.1.Direct payments to farmers 

During  the  years  2021-2025,  fraudulent  irregularities  related  to  direct  payments  to  farmers 
mainly concerned the falsification of documentary proof or of the request for aid, followed by  
irregularities  concerning  the  beneficiary,  most  of  the  time  not  having  the  required  quality. 
The  Member  States  detected  also  a  noticeable  number  of  fraudulent  cases  related  to  the 
category ‘product, species and/or land’, most of the time concerning overdeclaration and/or 
declaration of fictitious product, species and/or land.  

Focus on payments for agricultural practices beneficial to the climate and the enviroment 

Based on IMS data until 2024 included, an analysis was carried out about the types of CAP 
payments affected by fraud.26  One of the findings of this analysis was that about 40% of the 
fraudulent irregularities reported during the years 2020-2024 in relation to direct payments to 
farmers  concerned  payments  for  agricultural  practices  beneficial  to  the  climate  and  the 
environment (APCE).27 

Under  the  CAP  2023-2027,  risks  related  to  respect  of  good  agricultural  and  environmental 
conditions and support to environmental commitments may increase. Certain conditions are 
more stringent and apply to all payments while there is also increased support for voluntary 
environmental commitments. In particular, 25% of the direct payments must be allocated to 
eco-schemes,  providing  stronger  incentives  for  climate  and  environment-friendly  farming 
practices.  So  additional  analysis  has  been  carried  out  on  these  2020-2024  irregularities,  to 
better understand the actual reasons behind the reporting of irregularities related to payments 
for APCE.28 

The  first  finding  is  that  the  reporting  of  these  irregularities  is  concentrated  in  a  few 
Member  States.  Fraudulent  irregularities  related  to  payments  for  APCE  alone  or  together 
with  other  payments  have  been  reported  by  just  12  Member  States,  with  4  Member  States 
reporting  about  84%  of  them.  Non-fraudulent  irregularities  related  to  payments  for  APCE 
alone  have  been  reported  by  16  Member  States.  This  number  raises  to  21  if  also  the 
irregularities  related  to  APCE  payments  together  with  other  payments  are  considered. 
However,  many  of  these  Member  States  reported  just  one  or  two  non-fraudulent 
irregularities.  

In  addition,  this  analysis  suggests  that  the  majority  of  these  irregularities  may  not  be 
actually related to non-respect of agricultural practices or, at least, they may have not 
been reported because of controls on these practices.  The reduction of the payments for 
APCE  may  be  the  consequence  of  ineligibility  with  respect  to  other  payments,  such  as  the 

26 The types of CAP payments affected by fraud  were identified on the basis of the budget lines associated to 
each fraudulent irregularity. See ‘Statistical Evaluation of irregularities reported for 2024’ (SWD(2025)230 final 
on 25/7/2025) and the report ‘Analysis of irregularities reported by the Member States – Common Agricultural 
Policy 2024’ (ARES(2025)8499414 on 7/10/2025). 
27  For  the  purpose  of  that  analysis  APCE  refers  both  to  payment  for  agricultural  practices  beneficial  for  the 
climate and the environment (referred as ‘greening’ – CAP programming period 2014-2022) and to schemes for 
the climate and the environment (referred as ‘eco-schemes’ – CAP programming period 2023-2027). 
28 The main limitations of this analysis are (i) the actual link with relevant agricultural practices is assessed on 
the basis of the description of the modus operandi, which is often short and unclear, requiring varying degrees of 
interpretation;  (ii)  cases  where  less  than  EUR  10 000  were  involved  cannot  be  included  because  of  the 
derogation to reporting these cases in IMS. 

31 

 
 
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Basic Payment System, for example because the beneficiary does not have required qualities, 
does not have the right to use the land, does not use the land for agricutural purposes at all, 
because of the splitting of farms, etc. In other words, The high share of reported irregularities 
related  to  payments  for  APCE  does  not  seem  to  be  the  result  of  effective  management  and 
control systems focused on the actual agricultural practices of farmers, but mainly the result 
of other types of controls more focused on detecting non-farmers, applications with no right 
to use the land, non-respect of eligibility conditions, etc. 

This  may  point  to  the  need  for  improving  national  control  systems  on  actual 
agricultural practices. This is relevant both for the basic payments and for the new eco-
schemes. This requires adequate investment in specific methods, resources and skills.  Need 
for  controlling  these  agricultural  practices  is  even  higher  than  before  the  CAP  2023-2027, 
because  many  aspects  of  the  agricultural  practices  beneficial  to  the  climate  and  the 
environment  have  become  compulsory,  as  part  of  GAECs  and  because  25%  of  the  direct 
payments  must  be  allocated  to  eco-schemes,  providing  stronger  incentives  for  climate  and 
environment-friendly farming practices. 

The introduction of the CAP Strategic Plans (CSP)  

As  from  the  financial  year  2024,  nearly  all  expenditure  for  direct  payments  to  farmers  has 
been claimed under new CAP within CSP. It is important to monitor the capability of national 
management and control systems to detect fradulent irregularities.  

In  2024-2025,  the  first  fraudulent  irregularities  related  to  direct  payments  to  farmers 
under  CSP  were  reported,  but  only  by  7  Member  States.  During  2024-2025,  payments 
related  to  CSP  were  involved  in  about  21%  of  the  fraudulent  irregularities  related  to  direct 
payments. It may be early for an assessment about this level of fraud detection in relation to 
CSP, also because there  is  usually a delay between the irregularity and the detection of the 
irregularity. However, (i) the cases of fraud have been detected by just 7 Member States and 
2 of them accounted for nearly 80% of them; (ii) one third of these  fraudulent irregularities 
were below EUR 10 000. This suggests the need to monitor closely the capability of national 
management and control systems to detect fradulent irregularities in direct payments.       

3.4.1.2.Market measures 

Infringements related to the falsification of documentary proof or requests were the most 
frequent in relation to market measures. During the years 2021-2025, more than 70% of 
the  fraudulent  irregularities  related  to  market  measures  were  just  about  the  documentary 
proof or the request for aid. Most of them were about false or falsified documentary proof.  

Types of market measures 

Analysis  carried  out  last  year  suggests  that,  during  the  period  2015-2024,  most  of  the 
fraudulent  irregularities  concerned  the  wine-growing  sector,  the  fruit  and  vegetables 
sector  or  promotion.  For  the  wine-growing  sector,  the  funding  for  investment,  the 
promotion in third countries and the restructuring and conversion of vineyards were the most 
affected measures. For the fruit and vegetables sector, the most affected measure was the aid 
to  producer’s  cooperation,  both  in  the  form  of  aid  to  investment  and  aid  to  formation  and 
administrative operations.29   

29  See  ‘Statistical  Evaluation  of  irregularities  reported  for  2024’  (SWD(2025)230  final on  25/7/2025)  and  the 
report  ‘Analysis  of  irregularities  reported  by  the  Member  States  –  Common  Agricultural  Policy  2024’ 
(ARES(2025)8499414 on 7/10/2025). 

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During 2025, fraudulent irregularities related to market measures mainly concerned the 
wine  sector  and  beekeeping.  The  wine  sector  accounted  for  10  of  the  22  fraudulent 
irregularities  related  to  market  measures.  Specific  aid  for  beekeeping  was  concerned  by  6 
fraudulent irregularities.   

The introduction of the CAP Strategic Plans (CSP)  

So  far,  the  Member  States  have  reported  just  4  fraudulent  irregularities  concerning 
expenditure for market measures under CSP. In the financial year 2023, just about 7% of 
expenditure  for  market  measures  has  been  claimed  under  new  CAP  within  CSP. In  the 
financial years 2024 and 2025, this percentage has increased to 34% and 57%, respectively. It 
may  be  early  for  an  assessment  about  this  level  of  fraud  detection  in  relation  to  CSP,  also 
because there is usually a delay between the irregularity and the detection of the irregularity. 
However, just 4 fraudulent irregularities detected and 24 Member States without one single 
detection  suggests  the  need  to  monitor  closely  the  capability  of  national  management  and 
control systems to detect fradulent irregularities related to market measures.  

3.4.1.3.Rural development 

During  2021-2025,  more  than  half  of  the  fraudulent  irregularities  related  to  rural 
development  concerned  the  documentary  proof  or  the  request,  which  most  of  the  time 
were  falsified.  The  category  ‘(non-)action’  accounted  for  about  16%  of  the  fraudulent 
irregularities  related  to  rural  development,  but  for  26%  of  the  financial  amounts  involved. 
Most of these fraudulent irregularities concerned action not implemented or not completed. 
The category ‘beneficiary’ accounted for about 20% of the fraudulent irregularities related to 
rural  development,  but  for  just  14%  of  the  financial  amounts  involved.  In  particular,  they 
concerned  beneficiaries  not  having  the  required  quality,  alone  or  in  combination  with 
other infringements, in particular false documentary proof and falsification of the request for 
aid.  During  the  period  2021-2025,  4  irregularities  were  reported  as  corruption  and  1  as 
conflict of interest.  

Types of rural development measures   

fraudulent 

Analysis carried out last year suggests that, during the period 2020-2024, the majority 
of 
irregularities  concerned  reimbursement-based  or  project-based 
measures. Most of these irregularities seem to concern investment in agricultural holdings, in 
particular  investments  in  physical  assets,  and  farm  and  business  development.  Most  of  the 
remaining  reimbursement-based  infrigements  were  about  diversification  in  rural  areas, 
support for local development or about setting up young and new farmers. Also in the context 
of forestry, most of the fraudulent irregularities seem to concern project-based measures. 30  

The  same  analysis  suggests  also  that  another  significant  share  of  fraudulent  irregularities 
concerned  payments  that  should  have  been  granted  only  where  certain  conditions  were 
satisfied.  Most of these irregularities seem to concern agro-enviroment payments related to 
rural  development.  Most  of  the  remaining  condition-based  fraudulent  irregularities  were 
about payments to farmers in areas facing natural or other constraints.  

The introduction of the CAP Strategic Plans (CSP)  

So  far  (in  2024  and  2025),  the  Member  States  have  reported  just  14  fraudulent 
irregularities  concerning  expenditure  for  rural  development  under  CSP.  These 

30  See  ‘Statistical  Evaluation  of  irregularities  reported  for  2024’  (SWD(2025)230  final on  25/7/2025)  and  the 
report  ‘Analysis  of  irregularities  reported  by  the  Member  States  –  Common  Agricultural  Policy  2024’ 
(ARES(2025)8499414 on 7/10/2025). 

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fraudulent  irregularities  have  been  reported  by  4  Member  States.  It  may  be  early  for  any 
assessment about this level of fraud detection in relation to CAP Strategic Plans, also because 
projects may still be at an early stage of implementation and because there is usually a delay 
between  the  irregularity  and  the  detection  of  the  irregularity.  However,  just  14  fraudulent 
irregularities detected and 23 Member States without one single detection suggests the need 
to  monitor  closely  the  capability  of  national  management  and  control  systems  to  detect 
fradulent irregularities related to rural development.  

3.4.2.  Risk analysis and spontaneous reporting 

Detection  capacity  is  a  key  feature  of  the  anti-fraud  cycle,  which  contributes  to  the 
effectiveness and efficiency of the system for the protection of the EU budget. In the 2017 
PIF  Report,  to  boost  the  capacity  to  detect  irregularities,  the  Commission  recommended  to 
the Member States to improve risk analysis and the use of spontaneous reporting of potential 
irregularities and strengthening the protection of whistle-blowers that are also a crucial source 
for investigative journalism.31  

During  2021-2025,  risk  analysis  still  only  marginally  contributed  to  detecting  fraud  in 
rural  development  and  direct  payments  to  farmers.  In  market  measures,  risk  analysis  may 
have  played  a  stronger  role,  because  several  irregularities  were  detected  because  of  the 
scrutiny of commercial documents. In principle, the selection of the undertakings for scrutiny 
should be based on risk factors. However, it significantly depends on how the requirement of 
considering the risk factors has been translated into practice. For example, if the selection for 
scrutiny is based on criteria such as new beneficiaries, time from previous control, amount of 
the operation, these checks cannot be considered as based on risk analysis as recommended 
above.  The  share  of  fraud  detections  based  on  tips  from  informants  and  whistle-blowers 
was low, between 2% for direct payments and 4% for rural development or market measures. 
Information  published  in  the  media  was  never  a  source  of  fraud  detection,  apart  from  one 
case related to direct payments to farmers.  

Concerning  non-fraudulent  irregularities  patterns  for  risk  analysis  are  similar  to  those 
mentioned  for  fraud.  However,  for  direct  payments,  the  contribution  to  detection  of  risk 
analysis is stronger than for fraudulent irregularities, reaching 3.5% of irregularities detected 
during  2021-2025  (7.5%,  considering  also  the  reason  ‘comparison  of  data’,  which  is  very 
generic, but might mean some form of risk analysis). The share of detections based on  tips 
from  informants  and  whistle-blowers  or  information  published  in  the  media  was 
negligible. However, for direct payments, the contribution to detection of tips from informant 
is  about  4%,  similar  to  the  highest  contribution  in  relations  to  fraudulent  irregularities  for 
rural development and market measures (see above). 

3.4.3.  Duration of irregularities 

During 2016-2025, it took on average more than 4 years from the start of the irregularity 
to come to a suspicion that a fraudulent  irregularity had been committed and about 3 years 
to close the case after reporting to the Commission (see Graph NR8 below). These durations 
are  shorter  for  non-fraudulent  irregularities  (see  Graph  NR9).  The  intentional  nature  of 
fraudulent  irregularities  may  contribute  to  explain  the  longer  duration  from  perpetration  to 
suspicion. Fraudsters may go to great lenghts to hide their behaviour. 

31 Section 9.2 of ‘29th Annual Report on the Protection of the EU’s financial interests  – Fight against fraud – 
2017’,  COM(2018)553  final  and  ‘Statistical  evaluation  of  irregularities  reported  for  2017:  own  resources, 
agriculture, cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2018)386 final.  

34 

 
 
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3.4.4.  Detections and reporting by Member State 

The  tables  included  in  this  section  show,  for  each  CAP  sector,  the  fraudulent  and 
non-fraudulent  irregularities  reported  by  each  Member  State,  together  with  the  financial 
amounts  (EU-share)  involved,  the  payments  received  during  the  same  period  and  the 
calculation of the FDR and IDR. 

Table NR2 concerns irregularities related to rural development. 

35 

0.020.040.060.080.0100.0120.0Reporting to case closureDetection to reportingSuspicion to detectionIrregularity to suspicionGraph NR8: Average times from  irregularity to case closure 2016-2025; irregularities reported as fraudulentAvg. duration in months51 months8 months10 monthsNumber of irregularities at the basis of these averagetimes From irregularityto suspicion: 2 888  From suspicionto detection: 2 803From detection to reporting: 2 978From reporting to case closure: 4100.010.020.030.040.050.060.070.080.090.0Reporting to case closureDetection to reportingSuspicion to detectionIrregularity to suspicionGraph NR9: Average times from  irregularity to case closure 2016-2025; irregularities not reported as fraudulentAvg. duration in months34 months30 months7 months6 monthsNumber of irregularities at the basis of these averagetimes From irregularityto suspicion: 30 011From suspicionto detection: 30 263From detection to reporting: 30 920From reporting to case closure:9 47434 months 
 
 
Common Agricultural Policy 

Table NR3 focuses on irregularities related to market measures. 

36 

Financial amounts involved (EU-share)Financial amounts involved (EU-share)PaymentsFDR  (3)IDR (3)NEUREUR%%AT1188,60514832,0202,895,460,7420.010.03BE00581,314,226541,492,4800.000.24BG182,545,82840624,700,3511,592,945,7520.161.55CY3866,92400133,129,3840.650.00CZ192,054,0332116,148,7611,437,258,5640.140.43DE16902,7532928,191,3788,032,211,3980.010.10DK694,837,823782,536,515698,295,3270.690.36EE12112,815,008985,197,663518,006,8892.471.00ES157,444,5651,371138,188,4446,901,529,5020.112.00FI133,624823,306,9661,639,532,5810.000.20FR43640,67071424,949,59210,060,677,0140.010.25GR11,019,3791,21618,704,8373,883,430,3020.030.48HR113,190,44460443,219,9781,725,764,7170.182.50HU3912,349,2441,51656,319,4422,937,869,1530.421.92IE00001,627,927,9770.000.00IT356,528,88156633,537,0958,932,035,3930.070.38LT824,249,55438511,316,4271,280,512,6550.330.88LU00579,755104,867,4670.000.08LV233,637,489782,704,895581,441,1970.630.47MT4354,101311,803,250106,710,6970.331.69NL0014806,588948,067,5430.000.09PL592,940,8492,28951,253,3097,331,429,9710.040.70PT81,297,3821,16638,822,3072,515,938,3370.051.54RO23015,486,8751,884141,756,5105,656,546,9730.272.51SE21,000,868681,990,7911,318,718,6970.080.15SI395,94943944,557699,902,4620.010.13SK214,590,40523624,875,4551,175,883,1110.392.12TOTAL EU2782489,071,25113,425643,501,11475,277,586,2870.120.85UK (2)12193,3101816,394,7091,254,364,7670.020.51Table NR2: Rural development 2021-2025: number of irregularities, financial amounts (EU-share) involved and detection rates by Member State (1)Irregularities not reported as fraudulent 2021-25Irregularities reported as fraudulent 2021-25Member State(2) As of 1 February 2020, the UK is no longer part of the EU (3) FDR are calculated based on the financial amounts (EU-share) involved in irrregularities reported as fraudulent (third column). IDR are calculated based on the financial amounts (EU-share) involved in irrregularities not reported as fraudulent (fifth column). 2021-2025(1) Only irregularities exclusively concerning rural development 
   
 
Common Agricultural Policy 

Table NR4 concerns irregularities related to direct payments to farmers. 

37 

Financial amounts involved (EU-share)Financial amounts involved (EU-share)PaymentsFDR (2)IDR (2)NEUREUR%%AT41,156,097490,769135,262,8360.850.07BE005502,884355,165,1040.000.14BG117,340215,549,970162,625,4160.013.41CY001298,48031,029,6720.000.96CZ008352,757130,597,6790.000.27DE1554,140225,045,416744,551,9930.070.68DK002310,90177,483,9770.000.40EE000014,326,0440.000.00ES343,73142624,385,1853,206,434,1310.000.76FI000054,993,8920.000.00FR141,066,53927519,823,8942,953,831,6020.040.67GR12,543,01725781,682349,779,2850.730.22HR11,315,45581,242,60269,555,1701.891.79HU1115,238434,360,370228,515,6660.051.91IE129,8360076,334,0480.040.00IT2625,39225723,912,0543,444,949,0230.020.69LT004524,94436,440,2250.001.44LU00003,503,0690.000.00LV000029,944,7430.000.00MT00001,344,0660.000.00NL444,57915383,916480,552,1140.010.08PL64,961,40455110,506,425340,317,8751.4632.47PT5661,2161295,534,629542,029,4750.121.02RO12586,178707,946,193375,964,9110.162.11SE00379,77383,116,7910.000.10SI005120,49145,347,1610.000.27SK00116,71971,927,5970.000.02TOTAL EU275613,720,1621,379211,770,05414,045,923,5620.101.51Table NR3: Market measures 2021-2025: number of irregularities, financial amounts (EU-share) involved and detection rates by Member State (1)Member StateIrregularities reported as fraudulent 2021-25Irregularities not reported as fraudulent 2021-25(2) FDR are calculated based on the financial amounts (EU-share) involved in irrregularities reported as fraudulent (third column). IDR are calculated based on the financial amounts (EU-share) involved in irrregularities not reported as fraudulent (fifth column).  2021-2025(1) One fraudulent irregularity concerned also direct payments and rural development. Four non-fraudulent irregularities concerned also direct payments to farmers and three of these four also rural development. 
 
 
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The  detection  of  irregularities  was  concentrated  in  a  few  Member  States.  A  deeper 
analysis of concentration was included in the 2018 PIF Report.32 That analysis found that the 
concentration  of  detections  went  beyond  what  could  be  expected  given  the  level  of 
concentration of payments. This could be due to many different factors, including different 
underlying  levels  of  irregularities  and  fraud,  differences  in  the  quality  of  the  prevention  or 
detection  work.  The  concentration  of  detections  was  more  accentuated  for  fraudulent 
rather than for non-fraudulent irregularities. This suggests that different approaches to 
criminal investigation and prosecution could have been an additional and significant factor 
giving rise to these different levels of detection across the Member States. Different practices 
concerning the stage of the procedure when potentially fraudulent irregularities are reported 
may also play a role. 

32  Section  3.4.3  of  ‘Statistical  evaluation  of  irregularities  reported  for  2018:  own  resources,  agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2019)365 final. 

38 

Financial amounts involved (EU-share)Financial amounts involved (EU-share)PaymentsFDR  (3)IDR (3)NEURN%%AT006197,7193,398,318,5880.000.01BE0042966,4152,411,593,8930.000.04BG006108,7684,052,214,0480.000.00CY13,10200236,337,6150.000.00CZ337,54733904,7084,186,472,5490.000.02DE12613,3681883,804,88922,484,721,8560.000.02DK00862,590,6864,039,562,0600.000.06EE39739,187114,367941,406,2580.080.00ES13515,43360514,956,86825,290,732,4220.000.06FI00002,596,981,0810.000.00FR1583,447,77724509,23934,205,824,7230.010.00GR7171,8594186,805,0619,500,677,3990.000.07HR365,52432614,2841,859,581,8490.000.03HU1011421,9566,521,656,3480.000.01IE129,836005,887,913,4450.000.00IT817,084,34152635,339,37917,497,228,2250.040.20LT477,6281072,559,8732,841,620,7950.000.09LU0000163,696,9770.000.00LV0014249,7861,589,146,7160.000.02MT000034,017,9030.000.00NL821,227,18531538,4343,093,420,4640.040.02PL412,246,0431288,524,80816,958,278,0710.010.05PT26,406621,398,6183,857,714,5290.000.04RO32412,818,32818613,595,6619,470,287,3430.140.14SE118,7117111,1233,413,458,2850.000.00SI00347,535654,447,3170.000.01SK8147,2932456,711,5381,979,481,2240.010.34TOTAL EU2778129,249,5682,761100,971,715189,166,791,9840.020.05UK (2)0014340,516(2) As of 1 February 2020, the UK is no longer part of the EU (3) FDR are calculated based on the financial amounts (EU-share) involved in irrregularities reported as fraudulent (third column). IDR are calculated based on the financial amounts (EU-share) involved in irrregularities not reported as fraudulent (fifth column).   Table NR4: Direct payments to farmers 2021-2025: number of irregularities, financial amounts (EU-share) involved and detection rates by Member State (1)Member StateIrregularities reported as fraudulent 2021-25Irregularities not reported as fraudulent 2021-252021-2025(1) A number of irregularities concerned both direct payments to farmers and other CAP areas (mostly rural development) 
 
 
 
Common Agricultural Policy 

3.4.5.  Follow-up to supected fraud 

The  Member  States  may  report  irregularities  as  non-fraudulent  (just  administrative 
irregularities)  or  as  fraudulent  (suspected  or  established  fraud)  and  they  may  change  this 
classification  during  the  lifetime  of  the  irregularities.  The  following  analysis  provides 
intelligence on how the Member States followed up suspected fraud they detected during the 
period  2014-2025.33  The  irregularities  that  have  been  cancelled  are  excluded  from  this 
analysis, because once an irregularity is cancelled the information needed for the analysis is 
not present in IMS anymore. This implies an underestimation of dismissals.   

As shown in Graph NR10 below, for about 19% of the irregularities with a suspicion of 
fraud, the suspicion was then confirmed as established fraud. The best results in terms of 
established  fraud  are  between  25%  and  28%  (in  2015,  2018  and  2020),  but  with  no  clear 
pattern, because they are not all related to earlier years. The worst years are 2014 and 2022.  

For 12% of the irregularities with a suspicion of fraud, the suspicion was then dismissed 
(see Graph NR10 below). The dismissal ratio was higher during 2014-2017 than during the 
following years, in line with expectations. 

Most  of  the  irregularities  where  there  was  a  suspicion  of  fraud  are  still  classified  as 
suspected  fraud,  even  if  several  years  have  elapsed  since  the  initial  reporting  (see 
Graph NR10 below). This percentage changes year on year, but is very high also for  earlier 
years. 

33 To include an irregularity in this analysis, the relevant year is the year to which the Member State allocate the 
irregularity in IMS (reporting year). Changes to the classification of the irregularities until 8/3/2026 (date of the 
download of IMS data for this analysis) are considered. 

39 

 
 
Common Agricultural Policy 

Focusing on the irregularities that were initially reported during 2014-2018, significant 
differences between Member States can be found (see Table NR5 below). Focusing on this 
period means focusing on irregularities that have been reported between 7 and 12 years ago. 

In  many  Member  States,  the  percentage  of  irregularities  still  classified  as  suspected 
fraud is high. This may suggest that the judicial authorities do not give proper follow-up to 
these suspicions, including because they may not have sufficient resources. Alternatively, it 
could  be  that  there  are  no  proper  communication  channels  from  judicial  to  reporting 
authorities. This high percentage of irregularities still classified as suspected fraud could also 
be due to persistent suspicions of the paying agencies, while criminal proceedings were not 
started, were prevented by the statute of limitations or did not lead to enough evidence about 
fraud. 

40 

 
 
Common Agricultural Policy 

3.5.  Recovery and sanctions 

3.5.1.  Recovery 

Data from IMS can be used to measure certain aspects of recovery. For each irregularity, 
the Member States are requested to report the financial amounts involved and then split them 
in  amounts  prevented  and  amounts  already  paid  out.  The  latter  are  considered  financial 
amounts  to  be  recovered.  Then,  the  Member  States  can  follow  up  the  amounts  to  be 
recovered and specify: (i) the amounts that do not have to be recovered due, for instance, to a 
deduction  during  interim  or  final  payment  or  a  write  off;  (ii)  the  amounts  that  have  been 
recovered; (iii) the amounts that still need to be recovered (outstanding debt). 

The  following  analysis  is  based  on  the  above  mentioned  information  and  focuses  on  the 
irregularities that have been initially reported during 2015-2025 and are now closed, because 
for 
the  recovery  process  should  have  been  finalised. For  13  011  closed 
irregularities (accounting  for  about  EUR   658 million),  there  were  amounts  to  be  recovered 
and the Member States provided information about the recovery.34 

them 

For  rural  development,  the  analysis  covers  174  closed  fraudulent  irregularities  (accounting 
for  about  EUR  14.5  million  to  recover).  As  shown  in  Graph  NR11a,  in  relation  to  rural 
development for the years 2015-2025, closed irregularities considered in this analysis are 

34  There  were  amounts  to  recover  for  13  954  closed  irregularities  (accounting  for  about  EUR  694  million  to 
recover). However, for 943 of these irregularities (accounting for about EUR 36 million), there were amounts to 
recover,  but  the  Member  States  have  not  provided  any  information  about  the  recovery,  so  they  are  not 
considered in the analysis of the recovery. They are considered in the total number of cases with amounts to be 
recovered. 

41 

Pending suspected fraudN.%N.%N.%AT150%00%150%BE00%1100%00%BG2837%1621%3141%CY00%00%6100%CZ38%3793%00%DE2061%824%515%DK427%533%640%EE13%1138%1759%ES3170%00%1330%FI0NA0NA0NAFR1422%1219%3859%GR00%00%17100%HR531%744%425%HU3716%188%17476%IE13%39%3189%IT3815%104%20581%LT00%00%40100%LU00%00%1100%LV39%722%2269%MT00%00%1100%NL939%1461%00%PL13334%5113%21053%PT13%621%2276%RO214%17535%30060%SE00%00%2100%SI00%218%982%SK412%26%2882%EU-2735418%38520%1,18362%Table NR5: CAP: follow-up to suspected fraud by Member State - Irregularities initially reported during 2014-2018 (1)Member StateDismissalEstablished fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
Common Agricultural Policy 

a  small  percentage  (14%)  of  total  fraudulent  irregularities  (open  and  closed)  with 
amounts to be recovered. This  is  also  due to the fact  that closing a fraudulent irregularity 
takes time. However, a higher percentage of closed irregularities would be expected at least 
for earlier years, but data do not show such a pattern (see Graph NR11a). More than 75% of 
the amounts have actually been recovered, 19% are not recovered   and 5% have been 
deducted  or  written  off  (see  Graph  NR11b).  As  shown  in  Graph  NR11c,  the  recovery 
percentage is  above 70% for  all  years, with  the exception of irregularities reported in  2025 
(recent irregularities), 2017, 2019 and 2020. So there is no clear pattern.  

For support to agriculture, the analysis covers 100 closed fraudulent irregularities (accounting 
for about EUR 17.5 million to recover). As shown in Graph NR12a, in relation to support to 
agriculture for the years 2015-2025, closed irregularities considered in this analysis are a 
small percentage (7%) of total fraudulent irregularities (open and closed) with amounts 
to  be  recovered.  Less  than  30%  of  the  amounts  have  actually  been  recovered,  more  than 
65%  are  not  recovered 
 (see 
Graph NR12b). As  shown  in  Graph  NR12c,  the  recovery  percentage  is  above  85%  for 
most years, reaching 100% in 2018-2022. The recovery percentage is lower in 2023 and 
especially in 2015, when 87% of the relevant amounts are not recovered. This is the year 
where most of the amounts to recover were concentrated (see Graph NR12b). This is due to 
one  single  case  related  to  market  measures  with  about  EUR 12  million  that  are  not 
recovered.  

 and  about  3%  have  been  deducted  or  written  off 

42 

 
Common Agricultural Policy 

(1) Closed irregularities includes irregularities with amounts to be recovered and information about recovery. Total irregularities includes closed and open irregularities with amounts to be recovered. 703,24511,328,2842,825,114-500,0001,500,0003,500,0005,500,0007,500,0009,500,00011,500,00013,500,00015,500,00017,500,000GraphNR11b: Rural Developmentfraudulent irregularitiesRecovery of paid out irregular amounts Amount deducted, written off etcAmount recoveredBalance to recover3%23%0%0%7%13%0%8%3%0%0%79%71%46%100%46%59%96%86%97%97%56%18%6%54%0%47%27%4%6%0%3%44%0%10%20%30%40%50%60%70%80%90%100%20152016201720182019202020212022202320242025Graph NR11c: Rural Developmentfraudulent irregularitiesRecovery: year by year distribution Amount deducted, written off etcAmount recoveredBalance to recover557,5195,137,88511,975,839-500,0001,500,0003,500,0005,500,0007,500,0009,500,00011,500,00013,500,00015,500,00017,500,00019,500,000Graph NR12b: Support to agriculturefraudulent irregularitiesRecovery of paid out irregular amounts -Amount deducted, written off etcAmount recoveredBalance to recover4%3%14%0%0%0%0%0%0%0%9%97%86%100%100%100%100%100%73%100%87%0%0%0%0%0%0%0%27%0%0%10%20%30%40%50%60%70%80%90%100%2015201620172018201920202021202220232024Graph NR12c: Support to agriculturefraudulent irregularitiesRecovery: year by year distribution -Amount deducted, written off etcAmount recoveredBalance to recover14412089848610912311518613985121926716152520151188%16%29%8%19%14%20%17%8%8%9%0204060801001201401601802000%5%10%15%20%25%30%35%20152016201720182019202020212022202320242025Graph NR11a: Rural Developmentfraudulent irregularitiesClosed irregularities vs all irregularities (1)Total irregularities (including open)Closed irregularities% closed over total126951011311651251002181291328018161413654987014%17%14%10%4%4%4%4%6%5%0%0501001502002500%2%4%6%8%10%12%14%16%18%20152016201720182019202020212022202320242025Graph NR12a: Support to agriculturefraudulent irregularitiesClosed irregularities vs all irregularities (1)Total irregularities (including open)Closed irregularities% closed over total 
 
 
 
 
Common Agricultural Policy 

For  rural  development,  the  analysis  covers  8 532  closed  non-fraudulent  irregularities 
(accounting for about EUR 427 million to recover). As shown in Graph NR13a, in relation to 
rural development for the years 2015-2025, closed irregularities considered in this analysis 
are about one third (35%) of total non-fraudulent irregularities (open and closed) with 
amounts to be recovered. About 75% of the amounts have actually been recovered, 9% 
are not recovered and 16% have been deducted or written off  (see Graph NR13b).   As 
shown  in  Graph  NR13c,  the  recovery  percentage  is  above  80%  for  most  years,  with  the 
notable  exception  of  irregularities  reported  in  2025.  This  is  because  of  an  exceptional 
percentage of amounts deducted or written off (65%), due to 2 large irregularities accounting 
together for about 50 million.  

For  support  to  agriculture,  the  analysis  covers  3 865  closed  non-fraudulent  irregularities 
(accounting for about EUR 190 million to recover). As shown in Graph NR14a, in relation to 
support  to  agriculture  for  the  years  2015-2025,  closed  irregularities  considered  in  this 
analysis  are  about  44%  of  total  non-fraudulent  irregularities  (open  and  closed)  with 
amounts to be recovered. About 80% of the amounts have actually been recovered, 8% 
are not recovered  and 11% have been deducted or written off  (see Graph NR14b).  As 
shown  in  Graph  NR14c,  the  recovery  percentage  is  above  80%  for  most  years,  with  the  
exception of irregularities reported in 2015 and 2020. In 2015, 28% of the relevant amounts 
are not recovered, mainly because of a large irregularity related to market measures. In 2020, 
26% of the relevant amounts were deducted or written off.  

For  an  in-depth  analysis  of  recovery  and  financial  corrections  in  the  CAP,  see  the 
DG AGRI’s  2025  Annual  Activity  Report  and  the  2025  Annual  Management  and 
Performance Report for the EU Budget.35 

35 See also the Communication from the Commission to the Parliament, the Council and the Court of Auditors 
on the Protection of the EU budget – COM(2016)486 on 18/7/2016. 

 
 
 
Common Agricultural Policy 

(1) Closed irregularities includes irregularities with amounts to be recovered and information about recovery. Total irregularities includes closed and open irregularities with amounts to be recovered. 68,479,241318,802,49837,925,337-500,00049,500,00099,500,000149,500,000199,500,000249,500,000299,500,000349,500,000399,500,000449,500,000Graph NR13b: Rural Developmentnon-fraudulent irregularitiesRecovery of paid out irregular amountsAmount deducted, written off etcAmount recoveredBalance to recover21,344,394152,222,70315,662,368-500,00019,500,00039,500,00059,500,00079,500,00099,500,000119,500,000139,500,000159,500,000179,500,000199,500,000Graph NR14b: Support to agriculturenon-fraudulent irregularitiesRecovery of paid out irregular amountsAmount deducted, written off etcAmount recoveredBalance to recover7%4%7%5%6%5%5%3%3%2%65%80%84%78%83%71%88%86%93%87%96%34%13%12%15%12%23%7%9%4%10%2%1%0%10%20%30%40%50%60%70%80%90%100%20152016201720182019202020212022202320242025Graph NR13c: Rural Developmentnon-fraudulent irregularitiesRecovery: year by year distribution Amount deducted, written off etcAmount recoveredBalance to recover13%12%15%13%14%26%3%19%9%15%5%59%85%74%84%81%70%97%80%87%84%94%28%3%11%3%6%5%0%1%4%1%1%0%10%20%30%40%50%60%70%80%90%100%20152016201720182019202020212022202320242025Graph NR14c: Support to agriculturenon-fraudulent irregularitiesRecovery: year by year distributionAmount deducted, written off etcAmount recoveredBalance to recover255720961606160914911908218525292875237132311,42978555859262369779686690469458856%37%35%37%42%37%36%34%31%29%18%05001000150020002500300035000%10%20%30%40%50%60%20152016201720182019202020212022202320242025Graph NR13a: Rural Developmentnon-fraudulent irregularitiesClosed irregularities vs all irregularities (1)Total irregularities (including open)Closed irregularities% closed over total90380499079182082996882764568757251937842128339235832235636230017457%47%43%36%48%43%33%43%56%44%30%0200400600800100012000%10%20%30%40%50%60%70%20152016201720182019202020212022202320242025Graph NR14a: Support to agriculture non-fraudulent irregularitiesClosed irregularities vs total irregularities (1)Total irregularities (including open)Closed irregularities% closed over total 
 
 
 
COMMON AGRICULTURAL POLICY 

3.5.2.  Sanctions 

For each irregularity, the Member States must specify whether sanctions have actually been 
imposed.  Sanctions  have  been  imposed  for  277  out  of  the  534  fraudulent  irregularities 
(about  52%)  reported  during  2015-2025  that  are  now  closed.  As  shown  in  Table  NR6 
below,  in  about  42%  of  cases,  these  sactions  were  just  administrative,  which  is  not 
expected for fraudulent irregularities. Sanctions have been applied to 1 275 out of 14 217 
closed non-fraudulent irregularities (about 9%).36 

Table NR7 below shows the specific type of sanction that has been imposed, separately for 
fraudulent  and  non-fraudulent  irregularities.  Each  specific  type  can  be  administrative  or 
penal,  with  the  exception  of  imprisonment,  which  can  be  only  penal.  For  each  irregularity, 
more than one specific type of sanction may have been imposed.  

For the purpose of this analysis, the specific types of sanction listed in Table NR7 above have 
been  grouped  as  the  categories  fines,  imprisonment,  exclusion  from  future  subsidies, 
limitation  in  access  to  public  procurement,  loss  of  subsidies  and  other.  Table  NR8  below 
shows  how  these  categories  were  combined.  First  of  all,  the  combination  of  different 
categories  of  penalty  was  not  frequent.  For  45  of  the  277  fraudulent  irregularities  where 
sanctions were applied, imprisonment was imposed together with a fine. Imprisonment was 
rarely accompanied by other penalties that may protect future public funding, such as 
exclusion  from  future  subsidies  or  limited  access  to  public  procurement.  Table  NR9 
shows  that  for  55  of  the  1 274  non-fraudulent  irregularities  where  sanctions  were  applied, 

36 There were 6 additional fraudulent and 55 additional non-fraudulent irregularities were the  IMS field about 
sanctions imposed was filled in. However, for these irregularities, the IMS field ‘Procedure to impose penalties’ 
was  filled  in  with  ‘Decision:  no  sanction’ or  the  IMS  ‘Status  of  the  procedure’  was  ‘abandoned’.  Because  of 
these inconsistencies, these irregularities have not been included as irregularities where a sanction was imposed. 

46 

Type of sanction appliedN. irregularities%Type of sanction appliedN. irregularities%admin11542%admin1,272100%admin and penal3914%admin and penal20%penal12344%penal10%Grand Total277Grand Total1,275Table NR6: Common Agricultural PolicyIrregularities reported during 2015-2025 and closedFraudulentNon-fraudulentType of sanctionAdministrative sanctionPenal sanctionBoth administrative and penalAdministrative sanctionPenal sanctionBoth administrative and penalNational fine - proportional255492911National fine - non-proportional81535National fine - flat rate5195National subsidies - loss of subsidies28National subsidies - exclusion from future subsidies14356Limitation of access to public procurement3EU-fine - proportional101371EU-fine - non-proportional861EU-fine - flat rate111EU-subsidies - loss of subsidies143311EU-subsidies - exclusion from future subsidies692107Imprisonment2Imprisonment under 1 year381Imprisonment between 1 year and 4 years35Imprisonment over 4 years4Other3241881FraudulentNon-fraudulentMore than one type of sanction is possible for one irregularityTable NR7: Common Agricultural PolicyIrregularities reported during 2015-2025 and closed 
 
 
 
COMMON AGRICULTURAL POLICY 

fines were accompanied with exclusion from future subsidies. The latter is also accompanied 
with other non-specified penalties. 

There  were  just  39  out  of  277  fradulent  irregularities  where  penal  sanction  were 
accompanied  by  administrative  sanctions  (14%).  Table  NR10  explores  the  interplay 
between penal sanctions and administrative sanctions. Most of the time, it is a combination of 
imprisonment  with  administrative  fines  or  a  combination  of  penal  and  administrative  fines. 
There  are  also  a  few  cases  where  imprisonment  or  penal  fines  were  combined  with  the 
exclusion  from  future  subsidies  as  administrative  sanction.  This  means  that  most  of  the 
administrative exclusions reported in Table NR7 above for fraudulent irregularities were not 
combined with a penal sanction. 

47 

Category of sanctionProp., non-prop., flat  fineImprisonmentExclusion from future subsidiesLimitation access to public procurementLoss of subsidiesOtherProp., non-prop., flat  fineImprisonment45Exclusion from future subsidies87Limitation access to public procurement120Loss of subsidies7230Other41301Table NR8: Common Agricultural PolicyFraudulent Irregularities reported during 2015-2025 and closedCategory of sanctionProp., non-prop., flat  fineImprisonmentExclusion from future subsidiesLimitation access to public procurementLoss of subsidiesOtherProp., non-prop., flat  fineImprisonment0Exclusion from future subsidies550Limitation access to public procurement000Loss of subsidies2110Other002001Table NR9: Common Agricultural PolicyNon-fraudulent Irregularities reported during 2015-2025 and closedPenal SanctionsProp., non-prop., flat  fineExclusion from future subsidiesLimitation access to public procurementLoss of subsidiesOtherProp., non-prop., flat  fine125061Imprisonment125010Exclusion from future subsidies00000Limitation access to public procurement00000Loss of subsidies00000Other13010Table NR10: Common Agricultural Policy - fraudulent Irregularities reported during 2015-2025 and closedInterplay penal - administrative penaltiesAdministrative Sanctions 
 
 
 
 
 
 
 
   
4.  COHESION AND FISHERIES POLICIES  

4.1. 

Introduction 

This  section  presents  a  statistical  evaluation  of  irregularities  and  fraud  reported  by  the 
Member  States  during  2025,  with  reference  to  the  cohesion  and  fishery  policies.  It  places 
these detections in the context of past years and relevant programming periods (PP). 

Expenditure  under  the  cohesion  and  fisheries  policies  is  disbursed  by  the  Member  States 
under  shared  management.  The  Member  States  must  report  irregularities  and    fraud  to  the 
Commission through the Irregularity Management System (IMS).  

In  this  section,  when  reference  is  made  to  fraud,  this  includes  both  suspected  fraud  and 
established fraud37. Non-fraudulent irregularities must be reported in IMS only when they are 
detected  after  the  expenditure  has  been  introduced  in  a  statement  submitted  to  the 
Commission.  Fraudulent  irregularities  must  always  be  reported  in  IMS.  Unless  specified 
otherwise, when reference is made to financial amounts involved in irregularities, this means 
the  EU-share  of  these  financial  amounts.  Both  fraudulent  and  non-fraudulent  irregularities 
must  be  reported  when  involving  financial  amounts  above  EUR 10 000. Several  Member 
States  also  reported  some  irregularities  under  this  threshold.  These  irregularities  might  be 
inter-linked, bringing the total financial amounts involved above the threshold.  

4.2.  General trend 

Table  CP1 38  below  provides  an  overview  by  programming  period  and  by  Fund  of  the 
irregularities  reported  as  fraudulent  in  the  past  5  years  in  relation  to  the  cohesion  and 
fisheries policies (years 2021-2025). 

Fraudulent  irregularities  related  to  PP  2007-2013  peaked  in  2015,  before  gradually 
decreasing  in  the  following  years.  In  2018  they  were  overtaken  by  those  related  to 
PP 2014-2020.  The  number  of  fraudulent  irregularities  related  to  PP  2014-2020  has  been 
increasing until 2024, then in 2025 it started decreasing.These trends are in line with known 
trends  and  patterns  in  the  detection  and  reporting  of  irregularities  and  is  linked  to  the 
implementation  cycles  of  programming  periods39.  The  reporting  related  to  PP    2021-2027 
started in 2024. 

37 Suspected fraud means an irregularity that gives rise to the initiation of administrative or judicial proceedings 
at national level in order to establish the presence of intentional behaviour, in particular fraud, as referred to in 
Article 1(1)(a) of the Convention drawn up on the basis of Article K.3 of the Treaty on European Union, on the 
protection  of  the  European  Communities’  financial  interests.  Regardless  of  the  approach  adopted  by  each 
Member State, ratification of the 1995 Convention has equipped every country with a basis for prosecuting and 
possibly imposing penalties for specific conducts. Then the Directive (EU) 2017/1371 (so-called PIF Directive) 
defines  what  the  Member  States  are  requested  to  regard  as  fraud  affecting  the  EU’s  financial  interests.  If 
following a criminal proceeding a guilty verdict is issued and is not appealed against, the case can be considered 
established fraud (IRQ5 in IMS). If following an administrative proceeding, the deciding body establishes the 
intentionality  of  the  irregular  conduct,  this  can  also  be  considered  established  fraud  (IRQ4  in  IMS).  See 
‘Handbook on reporting irregularities in shared management’ (2025). 
38 ESF+ is the successor of ESF for the PP 2021-2027. It brings together the ESF, FEAD and YEI. This is why 
in  Table  CP1  also  FEAD  and  YEI  are  reported.  This  increases  comparability.  However,  FEAD  and  YEI  are 
covered by Section 4.6, on the other internal policies. 
39 When support is based on multiannual programmes, the number of irregularities can be expected  to increase 
around  the  end  of  the  eligibility  period  and  decrease  afterwards,  when  routine  controls  are  less  intense.  In 
general, increases in the number of reported irregularities can be influenced by Member States’ building up their 
capacity to detect fraudulent irregularities. 

48 

 
 
 
Table CP2 below provides an overview by programming period and by Fund of the financial 
amounts involved in cases reported as fraudulent. The financial amounts involved tend to 
fluctuate  more  than  the  number  of  irregularities,  due  to  the  possibility  of  individual  cases 
involving  extremely  high  amounts.  For  PP  2014-2020,  the  financial  amounts  have 
significantly  increased  in  2024.  This  increase  is  due  to  the  Cohesion  Fund  and,  to  a  lesser 
extent, to the ERDF (see Table CP2). About half of the increase related to the Cohesion Fund 
is due to 7 cases reported by Romania, each of them with more the EUR 10 million involved. 
All  of  these  cases  concern  the  provision  of  water  for  human  consumption  (extraction, 
treatment, storage and distribution infrastructure). The increase related to the ERDF is mainly 
due to one irregularity reported by Portugal, where about EUR 40 million are involved.      

49 

202120222023202420252021-2025NNNNNNProgramming Period 2021-2027000193756CF000011ERDF000152843ESF+0004812Programming Period 2014-201341632493512821,179CF1310261151ERDF8291139198163673ESF47608111585388EMFF492122350FEAD003003YEI00140014Programming Period 2007-134320372415139CF5013110ERDF251230171094ESF9021315EFF4843120Programming Period 2000-06010001ERDF010001TOTAL EU271771842863943341,375UK(1)101136(1) As of 1 February 2020, the UK is no longer part of the EU Table CP1: Number of fraudulent irregularities by programming period and Fund - Cohesion and Fisheries PoliciesPROGRAMMING PERIOD / FUNDIrregularities reported as fraudulent202120222023202420252021-2025EUREUREUREUREUREURProgramming Period 2021-202700014,943,18110,141,56525,084,746CF0000201,316201,316ERDF00014,639,6939,352,41923,992,112ESF+000303,488587,830891,318Programming Period 2014-2079,360,562100,819,265101,554,103306,731,884144,407,581732,873,395CF631,97811,362,8152,433,780163,239,21646,183,300223,851,089ERDF68,412,96481,607,21988,732,020127,793,71782,258,978448,804,898ESF9,826,0266,861,87110,285,61813,742,95812,274,52552,990,998EMFF489,594987,36064,0551,955,9933,690,7787,187,780FEAD0015,8080015,808YEI0022,8220022,822Programming Period 2007-1325,753,00831,561,61126,772,93912,195,1275,776,623102,059,308CF9,573,8780156,7321,487,277148,80311,366,690ERDF13,508,62612,938,36623,429,63010,255,5465,276,61265,408,780ESF1,669,729089,8003,394208,1891,971,112EFF1,000,77518,623,2453,096,777448,910143,01923,312,726Programming Period 2000-060455,675000455,675ERDF0455,675000455,675TOTAL EU27105,113,570132,836,551128,327,042333,870,192160,325,769860,473,124UK(1)00133,327379,418307,653820,398Table CP2: Financial amounts involved in fraudulent irregularities by programming period and Fund - Cohesion and Fisheries PoliciesPROGRAMMING PERIOD / FUNDIrregularities reported as fraudulent(1) As of 1 February 2020, the UK is no longer part of the EU  
 
 
 
In general, funding from the EU budget to a project or operation is accompanied by funding 
from  the  national  budget  (co-financing).  The  financial  amounts  mentioned  above  are  the 
EU-share of the financial amounts directly involved in the reported irregularities. Available 
data  provide  information  also  on  the  total  financial  amounts  directly  involved  in  the 
irregularities  (EU-share  plus  national  share  =  public  contribution  share).  Irregularities 
affect projects or operations that are not necessarily considered totally irregular. Part of the 
funding  to  these  projects  or  operations  might  still  be  considered  regular.  Available  data 
provide  information  also  on  the  EU-share  and  total  value  of  the  public  contribution 
granted to the projects or operations affected by the reported irregularities. As shown 
by  Graph  CP1,  in  relation  to  the  cohesion  and  fisheries  policies,  the  funding  (EU-share) 
granted to  projects  or operations affected by irregularities reported as  fraudulent  during the 
years  2021-2025  is  about  EUR  7.6  billion,  of  which  about  EUR 0.9 billion  were  the 
fraudulent financial amounts (EU-share) involved in these projects or operations in 2021-
2025.  In  terms  of  total  public  contribution,  the  funding  granted  to  projects  or  operations 
affected  by  irregularities  reported  as  fraudulent  during  the  years  2021-2025  is  about 
EUR 9 billion,  of  which  about  EUR  1  billion  were  the  fraudulent  financial  amounts 
involved in these projects or operations in 2021-2025.40 

The difference between the financial amounts directly involved in the irregularities and 
the public contribution to the affected operations is significant (see Graph CP1). This is 
influenced also by few large operations. This may also be due to the type of operations or 
projects, where the discovery that a transaction is fraudulent does not automatically put into 
question  other  transactions  under  the  same  operation  or  larger  project.41  Actually,  29 

40 A project/operation can be affected by more than one irregularity. So while summing up the funding to the 
operations associated to each relevant irregularity, there is a risk of considering the same operation more than 
once. To reduce this risk, an analysis has been carried out to identify the operations/projects affected by more 
than one irregularity. As a first step, through the automatic Excel function ‘remove duplicates’, the exact match 
of  operational  programme,  project  number  and  funding  (EU-share  and  total  public  contribution)  has  been 
considered as pointing to the same project/operation. Then a number of other hypotheses have been formulated 
about other irregularities that could be related to the same projects/operations, despite the absence of the exact 
match. These hypotheses have been checked with the Member States. This brought to the values in Graph CP1. 
41 For example, there may be projects where the beneficiary is the Ministry of Labour, which redistributed the 
funds to the final recipients. Another similar example may be operations that during the COVID crisis provided 
financial support for SMEs affected by the pandemic. In such cases, the fraudulent irregularities related to one 

50 

235539563186030263466411,0433,2332,8511,460327,5763,9393,3441,690439,01601,0002,0003,0004,0005,0006,0007,0008,0009,00010,000CFERDFESFFisheriesTot Cohesion andFisheriesEUR millionGraph CP1: Irregularities reported as fraudulent 2021-2025Financial amounts involved in irregularities and value of public contribution in affected operationsIrregularity (EU-share)Irregularity (public contr.)Value operations (EU-share)Value operations (pub. contr.) 
 
 
 
operations  or  projects  where  the  expenditure  (EU-share)  is  more  than  EUR 50 million  each 
accounted together for EUR 5.6 billion of expenditure, so about 75% of the ‘value operations 
(EU-share)’ reported in Graph CP1. For these 29 operations or projects, the ratio between the 
fraudulent amounts (in Graph CP1, ‘irregularity (EU-share)’) and their expenditure (in Graph 
CP1, ‘value operations (EU-share)’) is just about 2%.  

In  general,  projects  or  operations  where  just  part  of  the  expenditure  is  considered  as 
fraudulent  may  imply  risks  of  persistent  funding  to  fraudsters.  Targeted  ex  post 
controls  of  other  final  recipients  or  other  contractors  may  be  warranted  once  the 
detected  irregularities  led  to  identify  risks  and  vulnerabilities  that  could  apply  also  to 
them.  In  this  situation,  there  is  fraud  (or  a  suspicion  of  fraud),  but  the  relevant  authorities 
assess that this  concerns just part of the operation/project,  while the remaining part is  legal 
and regular and funding is confirmed. While it depends on the type of operation/project and 
on  the  type  and  specific  circumstances  of  the  detected  fraudulent  practice,  adequate  checks 
should be put in place to get reasonable assurance that the remaining funding to the affected 
operation/project  is  actually  free  from  fraud  (for  example,  other  contracts  under  the  same 
project or subsidies to other final recipients under the same operation managed by the same 
authority or intermediate body).  

So  far,  the  Member  States  reported  far  less  fraudulent  irregularities  during  PP  2021-
2027 than during previous programming periods. Table CP3 below compares the number 
of fraudulent irregularities in the first 12 years from the start of PP 2007-13 (from year 2007 
to year 2018) and PP 2014-2020 (from year 2014 to year 2025). Table CP3 compares also the 
first 5 years of PP 2007-2013, PP 2014-2020 and PP 2021-27. 

Table  CP4  below  provides  an  overview  by  programming  period  and  by  Fund  of  the 
irregularities  not  reported  as  fraudulent  in  the  past  5  years.  Table  CP5  below  shows  the 
financial amounts involved in these irregularities.  

final recipient may be isolated and negligible when compared to the value of the overall operation managed by 
the  public  Authority.  Another  example  may  concern  large  infrastructure  projects,  such  as  the  development  of 
water and wastewater infrastructure in a County. Fraud may affect just one of the many contracts to implement 
the  project  in  the  County,  but  the  Member  State  may  have  indicated  to  whole  expenditure  involved  in  the 
project. 

51 

PP2007-13200720082009201020112007-1120122013201420152016201720182007-18N00423186159111192145329250147951,428EUR00125,369,56212,880,319112,533,479250,783,360164,331,92991,992,22487,393,825185,867,815167,311,83996,849,595104,819,5631,149,350,1502014-20201420152016201720182014-1820192020202120222023202420252014-25N011181181381001561341632493512821,573EUR0150,672368,0399,504,56269,896,44279,919,71521,445,91844,274,24979,360,562100,819,265101,554,104306,731,884144,407,582878,513,2792021-27202120222023202420252021-25N000193756EUR00014,943,18110,141,56525,084,746REPORTING YEARTable CP3: Irregularities reported as fraudulent: number and financial amounts (EU-share) involved - Cohesion and fisheries policies (EU27) (1)(1) CF, ERDF, ESF, ESF+, FEAD, YEI, EMFAF, EMFF, EFF 
 
 
 
 
In  practice,  reporting  related  to  PP  2014-2020  began  in  2016.  Since  then,  these  detections 
and  irregular  financial  amounts  have  been  increasing  until  2024.  Year  2025  is  the  first 
year  with  a  decrease.  Table  CP6  below  compares  the  number  of  non-fraudulent 
irregularities in the first 12 years from the start of PP 2007-13 (from year 2007 to year 2018) 
and PP 2014-2020 (from year 2014 to year 2025). This comparison shows the drop in the 
number  of  non-fraudulent  irregularities  from  PP  2007-2023  to  PP  2014-2020  (-52%). 
Already  based  on  data  until  2020  included,  a  specific  analysis  had  showed  that  this  strong 

52 

202120222023202420252021-2025NNNNNNProgramming Period 2021-2700087285372CF00012122ERDF00078197275ESF+00086472EMFAF000011FEAD000022Programming Period 2014-202,0582,3002,4762,9272,75812,519CF120157211258125871ERDF1,2691,5311,5951,8852,0418,321ESF5755095386944952,811EMFF61831007784405FEAD2619148269YEI711851142Programming Period 2007-1317892636039432CF2417913972ERDF13060442427285ESF13863030EFF117420345Programming Period 2000-0652411022CF001001ERDF3029014ESF211004GUID010203TOTAL EU272,2412,3942,5433,0853,08213,345UK(1)34929636585591(1) As of 1 February 2020, the UK is no longer part of the EU Table CP4: Number of irregularities not reported as fraudulent by programming period and Fund - Cohesion and Fisheries PoliciesPROGRAMMING PERIOD/ FUNDIrregularities not reported as fraudulent202120222023202420252021-2025NNNNNNProgramming Period 2021-270006,213,50841,097,40647,310,914CF00011,4244,149,9754,161,399ERDF0006,055,68332,241,83838,297,521ESF+000146,4014,576,9574,723,358EMFAF000012,47612,476FEAD0000116,160116,160Programming Period 2014-20436,761,120417,503,111521,581,008576,933,251643,968,4112,596,746,901CF45,948,846101,016,683119,057,288101,593,59254,939,993422,556,402ERDF195,510,107268,715,348296,588,422391,306,490514,717,5721,666,837,939ESF185,342,97736,377,75577,173,39372,696,98363,352,264434,943,372EMFF6,283,4518,172,3186,374,9268,751,5406,789,64036,371,875FEAD1,927,3243,201,1087,553,814711,5622,273,49515,667,304YEI1,748,41519,89914,833,1651,873,0841,895,44720,370,009Programming Period 2007-13157,930,83115,821,32226,630,97437,052,3006,876,704244,312,132CF90,924,4461,439,2123,142,8196,403,1252,255,743104,165,345ERDF61,961,71312,831,58822,096,52825,245,6314,329,502126,464,963ESF4,014,145776,602143,943624,06605,558,756EFF1,030,527773,9201,247,6844,779,478291,4598,123,068Programming Period 2000-061,209,531214,9644,870,6473,625,29809,920,441CF004,268,125004,268,125ERDF178,5960564,4883,174,60303,917,688ESF1,030,935125,00038,034001,193,969GUID089,9640450,6950540,659TOTAL EU27595,901,482433,539,397553,082,629623,824,357691,942,5212,898,290,388UK(1)10,547,3451,605,5595,409,45514,065,95350,899,68382,527,995Table CP5: financial amounts involved in irregularities not reported as fraudulent by programming period and Fund - Cohesion and Fisheries PoliciesPROGRAMMING PERIOD/ FUNDIrregularities not reported as fraudulent 
 
 
 
 
decrease  was  building  up.  This  analysis  was  disseminated  to  all  Member  States42,  with  a 
recommendation  to  assess  the  extent  to  which  the  potential  explanations  identified  by  that 
analysis  and  other  possible  explanations  actually  applied  to  their  operational  programmes, 
with the aim of implementing corrective measures in case the decrease could be due to less 
effective detection or reporting. Table CP6 compares also the first 5 years of PP 2007-2013, 
PP 2014-2020  and  PP 2021-27.  The  decrease  of  reported  non-fraudulent  irregularities 
seems  to  continue:  during  PP  2021-27  there  is  a  decrease  of  65%  from  PP  2014-2020 
and  of  87%  from  2007-2013.  Based  on  the  amounts  of  payments  received  so  far  by  the 
Member  States,  Table  CP6  shows  that  the  implementation  of  PP  2021-2027  seems  to  be 
lagging  behind  when  compared  with  PP  2014-2020.  This  might  temporarily  contribute  to 
explain part of the decrease. However, this happened also for PP 2014-2020 and later the gap 
was not filled in. Once again, the Member States are invited to analyse this decrease and to 
implement  corrective  measures  in  case  the  decrease  is  due  to  less  effective  detection  or 
reporting of irregularities.    

4.3. 

Prevention 

Prevention is the first step of the anti-fraud cycle. This analysis being based on IMS data, 
prevention means early detection so that financial amounts involved in an irregularity or in a 
case of fraud are not  paid to  the beneficiary. Early  detection may avoid  the payment to  the 
beneficiary of all financial amounts involved (total prevention) or just part of them, because 
part of the payments related to the irregularity or to the case of fraud have already been made 
before detection (partial prevention). 

For  non-fraudulent  irregularities,  data  in  IMS  cannot  be  used  to  capture  the  full 
outcome  of  these  prevention  activities.  This  limitation  does  not  apply  to  fraudulent 
irregularities.  There  is  no  obligation  for  the  Member  States  to  report  non-fraudulent 
irregularities detected before expenditure has been introduced in a statement submitted to the 
Commission. In this respect, IMS data can only be used to measure the effect of prevention 
for irregularities that, at the same time, are related to both (i) items of expenditure that have 
not been paid (as a consequence of early detection) and (ii) items of expenditure included in a 
statement to the Commission (which trigger the obligation to report in IMS). The derogation 
to reporting in IMS is more likely to apply to ‘total prevention’ non-fraudulent irregularities, 
but  it  cannot  be  excluded  that  there  are  ‘partial  prevention’  non-fraudulent  irregularities 

42  ‘Analysis  of  the  decline  in  non-fraudulent  irregularities  from  programming  period  2007-2013  to 
programming period 2014-2020’ (OLAF, May 2022). The resulting hypotheses have been mentioned also in the 
2021 report on the protection of the EU financial interests. 

53 

PP2007-13200720082009201020112007-112007-18N071089331,8312,87935,389Amounts of irregularities096,61530,708,297113,323,876334,580,882478,709,6707,845,862,2662014-20201420152016201720182014-182014-25N01172008501,06816,843Amounts of irregularities015,8724,818,31566,692,453223,679,313295,205,9533,515,274,047Cumulative Net payments1,281,029,5038,101,007,21225,448,981,17546,665,542,86782,589,438,3302021-27202120222023202420252021-25N00087285372Amounts of irregularities0006,213,50841,097,40647,310,914Cumulative Net payments05,498,573,45810,924,371,32319,596,984,92453,463,984,615Table CP6: Irregularities not reported as fraudulent: number and financial amounts (EU-share) involved - Cohesion and fisheries policies (EU27)REPORTING YEAR 
 
  
 
where  the  expenditure  already  paid  out  has  not  been  include  in  a  statement  to  the 
Commission yet. This limitation does not apply to fraudulent irregularities, because they must 
be  reported  in  IMS  also  where  no  payments  have  been  made  yet.  So,  for  fraudulent 
irregularities, IMS data can be used to assess the full outcome of prevention activities. 

Fraud prevention can play a role during the whole programming period and cycle, even 
if it can be expected to decrease as the operations approach finalisation and most of the 
support has already been paid out. Fraud can hit at different stages of the implementation, 
such as the selection of projects that are going to get support, procedures to procure goods, 
works or services, interim and final requests for reimbursement, actual use of funded assets 
after reimbursement. In addition, not all operations start at the beginning of the programming 
period.  

Focusing on PP 2014-2020, Graph CP2a shows that, during the years 2021-2025, the early 
detection of fraudulent irregularities prevented the disbursement of about EUR 101 million, 
which  is  about  14%  of  the  financial  amounts  involved  in  fraud  during  the  same  5  years. 
Graph CP2a  also  shows  that  this  prevention  effect  featured  in  about  23.5%  of  fraudulent 
irregularities.  The  comparison  between  the  years  2014-2020  and  the  years  2021-2025 
highlights the decrease in the percentage related to the financial amounts (from 31% during 
the years 2014-2020 to the aforementioned 14% in the years 2021-2025) and to the share of 
cases  (from  34%  to  the  aforementioned  23.5%).  This  trend  may  be  linked  to  the  fact  that 
during the years 2014-2020, more projects related to PP 2014-2020 could be just starting and 
the detection of fraud at an early stage may have allowed preventing a significant share of the 
expenditure.  Actually,  for  PP  2021-2027,  for  which  detection  of  fraud  has  recently  started, 
prevention  features  in  about  60%  of  cases  of  fraud  and  represents  about  half  of  the 
financial amounts involved in fraud (see Graph CP2c).   

54 

(1) CF, ERDF, ESF, EMFF95.370.882.870.7274.1131.9630.342.38.618.030.432.611.2100.834.3%30.3%35.8%37.5%15.4%10.8%23.4%30.7%10.8%17.9%30.1%10.6%7.8%13.8%0.0%5.0%10.0%15.0%20.0%25.0%30.0%35.0%40.0%0.0100.0200.0300.0400.0500.0600.0700.0800.02014-2020202120222023202420252021-2025% of irregularities and financial amounts EUR millionGraph CP2a: PP 2014-2020 -prevention in fraudulent irregularities: cases and financial amounts(1)PaidPrevented% irregularities with prevention% financial amounts prevented770.8402.9367.5458.8542.3574.12,345.6136.130.146.640.431.629.0177.723.0%16.7%18.3%17.5%11.1%2.6%12.8%15.0%7.0%11.2%8.1%5.5%4.8%7.0%0.0%5.0%10.0%15.0%20.0%25.0%0.0500.01,000.01,500.02,000.02,500.03,000.02014-2020202120222023202420252021-2025% of irregularities and financial amounts EUR millionGraph CP2b: PP 2014-2020 -prevention in non-fraudulent irregularities: cases and financial amounts(1)PaidPrevented% of irregularities with prevention% financial amounts prevented 
 
 
 
Graph  CP2b  focuses  on  non-fraudulent  irregularities  related  to  PP  2014-2020.  During  the 
years  2021-2025,  the  early  detection  of  non-fraudulent  irregularities  prevented  the 
disbursement of about EUR 178 million, which is 7% of the financial amounts involved in 
non-fraudulent irregularities during the same 5 years. This prevention effect featured in about 
13%  of  non-fraudulent  irregularities.  The  comparison  between  the  years  2014-2020  and 
the years 2021-2025 highlights a decrease in the share of cases with prevention (from 23% 
during the years 2014-2020 to the aforementioned 13% in the years 2021-2025) and a similar 
decrease in the percentage related to the financial amounts (from 15% to the aforementioned 
7%).  For  PP 2021-2027,  for  the  first  2  years  of  reporting  (years  2024-2025),  prevention 
features  in  about  12%  of  non-fraudulent  irregularities  and  represents  about  6%  of  the 
financial amounts involved (see Graph CP2d).   

In  relation  to  PP  2014-2020,  during  the  years  2014-2025,  for  about  23%  of  the  fraudulent 
irregularities  with  partial  or  total  prevention  (accounting  for  about  19%  of  the  prevented 
amounts)  the  control  had  been  started  because  of  routine.  For  non-fraudulent  irregularities, 
this percentage increases to about 66% (accounting for about 51% of the prevented amounts). 
This  stronger  role  of  routine  in  prevention  for  non-fraudulent  irregularities  may 
contribute to explain the flatter trend highlighted in Graph CP2b above, in comparison to 
fraudulent irregularities (Graph CP2a above). Fraud prevention relied on a wider range of 
sources. For fraudulent irregularities, the reasons ‘tips from informants’ and ‘existing doubts’ 
both accounted for about 15% of cases and the reason ‘suspicious conduct’ for about 14% of 
the  prevented  amounts.  Information  published  in  the  media  contributed  to  the  start  of  the 
control  for  just  few  cases  (3%),  but  these  cases  accounted  for  about  9%  of  the  prevented 
amounts. Information published in the media contributed to about 11% of prevented amounts 

55 

Some prev32112,559,7676.028809No prev2658939,899,15393.97119(1) CF, ERDF, ESF+, EMFAF3.68.71211.31.41384.2%45.5%59.6%75.7%13.9%50.7%0.0%10.0%20.0%30.0%40.0%50.0%60.0%70.0%80.0%90.0%0.05.010.015.020.025.030.0202420252024-2025% of irregularities and financial amounts EUR millionGraph CP2c: PP 2021-20207-prevention in fraudulent irregularities: cases and financial amounts(1)PaidPrevented% irregularities with prevention% financial amounts prevented6.038.2440.22.735.7%13.8%11.9%2.7%6.7%6.2%0.0%2.0%4.0%6.0%8.0%10.0%12.0%14.0%16.0%0.05.010.015.020.025.030.035.040.045.050.0202420252024-2025% of irregularities and financial amounts EUR millionGraph CP2d: PP 2021-20207-prevention in non-fraudulent irregularities: cases and financial amounts(1)PaidPrevented% irregularities with prevention% financial amounts prevented 
 
 
 
also in relation to non-fraudulent irregularities, mainly due to 2 cases where all amounts were 
prevented, accounting together for EUR 33 million.      

For  fraudulent  irregularities,  from  PP  2007-2013  to  PP  2014-2020,  analysis  suggests 
that  prevention  in  terms  of  early  detection  has  improved.  Graph  CP3  below  shows  the 
distribution  of  fraudulent  irregularities  by  the  ratio  between  prevented  amount  and  total 
amount involved in the irregularity, separately for the first 12 years of PP 2014-2020 (years 
2014-2025) and the same number of years after the start of PP 2007-2013 (years 2007-2018). 
Graphs CP3a and CP3b shows that the number of fraudulent irregularities where all irregular 
amounts  had  been  paid  out  (‘no  prevention’  irregularities)  was  remarkably  stable  from 
PP 2007-2013 to PP 2014-2020. Many more irregularities where all fraudulent disbursements 
have been prevented (‘total prevention’ irregularities) were instead reported during PP 2014-
2020 (+109%). There was also a significant increase in the number of irregularities where the 
disbursement of more than half of the fraudulent amounts were prevented (see Graphs CP3a 
and CP3b below).  

in  the  detection  and  reporting  of  non-fraudulent 
While  the  strong  decrease 
irregularities  raises  concerns,  there  are  elements  supporting  the  hypothesis  that  this 
may  be  partly  due  to  some  improvement  of  prevention.  As  already  mentioned,  the  total 
number  of  the  non-fraudulent  irregularities  detected  during  the  first  12  years  of  the  2 
programming  periods  strongly  decreased  from  PP  2007-2013  to  PP 2014-2020.  The 
hypothesis  may  be  made  that  this  may  partly  be  due  to  improvements  in  detecting  non-
fraudulent irregularities before irregular expenditure is sent to the Commission (because then 
these irregularities are not reported in IMS). On the one hand, the evolution across time of the 
error  rates,  as  estimated  by  the  European  Court  of  Auditors,  does  not  show  a  clear  pattern 

56 

 
 
 
supporting this hypothesis.43 On the other hand, as shown by Graphs CP4a and CP4b below: 
(i) the decrease was stronger in terms of ‘no prevention’ irregularities (-51%) and less strong 
for  the  ‘total  prevention’  irregularities  (-27%);  (ii)  there  was  a  significant  increase  in  the 
number of non-fraudulent irregularities where more than half of the amounts were prevented. 
These  can  be  taken  as  elements  supporting  the  hypothesis  that  prevention  may  have 
improved.    

However,  there  are  also  signs  that  the  analysis  for  ex-post  detection  of  irregularities 
should  be  strengthened.  Actually,  the  overall  drop  in  the  detection  and  reporting  of  non-
fraudulent irregularities is due to the decrease of ‘no prevention’ irregularities (which halved 
from PP 2007-2013 to PP 2014-2020), while non-fraudulent irregularities where there was at 
least  partial  prevention  have  more  than  doubled  from  PP 2007-2013  to  PP  2014-2020  (see 
Table CP7 below and Graphs CP4a and CP4b above). The hypothesis can be made that the 
‘no prevention’ irregularities are irregularities that have not been detected while processing a 
request  for  payment,  but  thanks  to  controls  that  took  place  at  a  later  stage.  From  PP  2007-
2013 to PP 2014-2020, the national management and control systems may have excessively 
shifted  focus  away  from  this  type  of  controls  that  cover  past  transactions.  Another 

43 Most likely error rate in ‘Cohesion’, from 2007 to 2009: >5%. Most likely error rate in ‘Cohesion, energy and 
transport’  in  2010:  7.7%.  Most  likely  error  in  ‘Regional  policy,  transport  and  energy’  and  ‘Employment  and 
social  affair’,  respectively,  from  2011  to  2013:  6%,  2.2%  (2011),  6.8%,  3.2%  (2012),  6.9%,  3.1%  (2013). 
Estimated level of error of ‘economic, social and territorial cohesion’, from 2014 to 2019:  5.7%, 5.2%, 4.8%, 
3%, 5%, 4.4%. Estimated level of error of ‘cohesion, resilience and values’, from 2020 to 2024: 3.5%, 3.6%, 
6.4%,  9.3%,  5.7%  (Source:  European  Court  of  Auditors:  Annual  reports  on  the  implementation  of  the  EU 
budget for the 2007-2024 financial years). 

57 

 
 
 
 
 
explanation might be shortcomings in the reporting of irregularities detected in relation 
to  expenditure  that  was  excluded  from  the  annual  accounts  due  to  an  ongoing 
assessment  about  legality  and  regularity.  These  irregularities  are  not  covered  by  any 
derogation for reporting in IMS. Even if expenditure was excluded from the annual accounts, 
the  irregularity  should  be  reported,  because  it  was  detected  after  previous  inclusion  of  the 
expenditure  concerned  in  a  payment  application  to  the  Commission  (i.e.  the  original 
application for interim payment).   

involved 

Most  of  prevention  concerned  cases  where  less  than  EUR 1 million  were  involved.  A 
general  distribution  of  the  number  of  grants  that  was  skewed  toward  values  below 
EUR 1 million  might  contribute  to  explain  this  prevalence  of  financial  amounts  below 
EUR 1 million 
the 
distributions  in  terms  of  value  of  the  amounts  involved  in  fraud  or  irregularities  be 
significantly more skewed towards values below EUR 1 million than the general distribution 
of  grants,  this  could  point  to  the  need  for  more  targeting  of  larger  projects  or  larger  fraud 
schemes. This cannot be tested, because the general distribution of grants is not available for 
this analysis.  

irregularities.  However,  should 

in  detected  fraud  and 

4.4.  Detection and Investigation 

4.4.1.  Irregularities by area of the cohesion policy 

The operational programmes financed under the EU cohesion policy are implemented along 
identified intervention fields. In relation to PP 2014-2020, an analysis of the irregularities by 
intervention field has been carried out during 2024, based on data until 2023 included.44 

The first detections related to PP 2021-2027 seem to confirm previous findings. It is early 
to  attempt  a  similar  analysis  with  reference  to  PP  2021-2027.  However,  Table  CP8  below 
already shows the number of fraudulents irregularities (at the level of priority – higher level - 
and theme – lower level) and non-fraudulent irregularities (at the level of priority only) that 
have  been  reported  so  far  in  relation  to  PP  2021-2027.  A  noticeable  share  of  the  reported 
fraudulent  irregularities  concerned  the  digitalisation  of  SMEs  (16  fraudulent  irregularities), 
investment  in  energy  efficiency  (7),  research  and  innovation  (4).  In  terms  of  financial 
amounts 
the  business  development  and 
irregularities,  also 
internationalisation  of  SMEs  and  the  provision  of  water  for  human  consumption  come  to 
notice.  

in  fraudulent 

involved 

44 OLAF, ‘Fraud and irregularities by areas of the cohesion policy – comparing risks - 2023’, 24 July 2024. A 
summary of  the  findings  has been  published  also  under  Section  4.4  of  ‘Statistical  evaluation  of  irregularities 
reported  for  2023:  own  resources,  agriculture,  cohesion  and  fisheries  policies,  pre-accession  and  direct 
expenditure’, SWD(2024) 193 final, 25/7/2024.  

58 

N.EURwhere all financial amounts involved were already paid out28,6757,112,585,667where at least part of the financial amounts were prevented1,131303,372,640where all financial amounts involved were already paid out14,0472,869,896,221where at least part of the financial amounts were prevented2,554560,398,116PP 2007-2023until 2018PP 2014-2020until 2025Irregularities not reported as fraudulent (1)(1) CF, ERDF, ESF, EFF, EMFFTable CP7 
 
 
 
A closer look at European territorial cooperation 

An analysis has been carried out of the irregularities reported until 2024 under PP 2014-2020 
concerning  ERDF  funding  in  relation  to  European  Territorial  Cooperation  (ETC) 
programmes.  The  EU  promotes  cooperation  between  regions  and  countries  to  help  their 
economic and social development  and tackle the  obstacle of borders. Under PP 2014-2020, 
this European Territorial Cooperation (Interreg V) was organised under multiple strands: (i) 
cross-border  cooperation  in  the  EU  (Interreg  V-A);  (ii)  cross-border  cooperation  at  EU 
external  borders,  including  candidate  and  neighbouring  countries;  (ii)  trans-national 
cooperation  (Interreg  V-B),  covering  larger  areas;  (iii)  interregional  cooperation  and 
networking programmes (Interreg V-C).45 The analysis focused on Interreg V-A, Interreg V-
B and Interreg V-C. 

45  Inforegio - Interreg : European Territorial Co-operation ; Inforegio - 2014-2020 period – Interreg V 

59 

Financial amountsFinancial amountsNEURNNEUR161,461,717Digitising SMEs (including e-Commerce, e-Business and networked business processes, digital innovation hubs, living labs, web entrepreneurs and ICT start-ups, B2B)2264,710Investment in fixed assets, including research infrastructure, in micro enterprises directly linked to research and innovation activities27,535,680SME business development and internationalisation, including productive investments42,989,027Energy efficiency renovation of existing housing stock, demonstration projects and supporting measures compliant with energy efficiency criteria2920,048Energy efficiency renovation or energy efficiency measures regarding public infrastructure, demonstration projects and supporting measures compliant with energy efficiency criteria14,312,020Energy efficiency and demonstration projects in SMEs and supporting measures22,826,413Provision of water for human consumption (extraction, treatment, storage and distribution infrastructure, efficiency measures, drinking water supply)10Provision of water for human consumption (extraction, treatment, storage and distribution infrastructure, efficiency measures, drinking water supply) compliant with efficiency criteria1201,316Waste water collection and treatmentA more connected Europe by enhancing mobility1710,331,0921218,482Infrastructure for tertiary education154,772Infrastructure for vocational education and training and adult learning224,033Measures to improve access to employment29,370Support for adult education (excluding infrastructure)1422,721Measures to promote equal opportunities and active participation in society1217,825Pathways to integration and re-entry into employment for disadvantaged people161,354Measures to enhancing the equal and timely access to quality, sustainable and affordable services365,177undefinedA Europe closer to citizens by fostering the sustainable and integrated development of all types of territories and local initiatives6119,226332,557,267Protection, development and promotion of cultural heritage and cultural servicesTechnical assistance112,388,831Research and technological development (R&TD), innovation and entrepreneurship (4) 13812,329,06122128,363Other measures to stimulate research and innovation and entrepreneurship in SMEs (6)Productive investment (5)114,449Development of endogenous potential (5)1137,499Energy1116,585Renewable energy: wind (6)undefined5384,61377797,865UndefinedTotal number of irregularities EU 2736947,182,2795625,084,745Detail about the themes only related to the irregularities reported as fraudulent (3)(5) This is a priority related to PP 2014-2020 that has been wrongly used for PP 2021-2027.(6) This is a theme related to PP 2007-2013 that has been wrongly used for PP 2021-2027.(2) In this Table, the priorities refer to both fraudulent and non-fraudulent irregularities(3) The themes in this colums refer only to the fraudulent irregularities. The themes related to the non-fraudulent are not specified and could be other themes included in the same priority(1) This Table provides information at the level of priority for the non-fradulent irregularities and both at the level of priority and at the level of theme for the fraudulent irregularities. While the themes for which fraudulent irregularities have been reported sofar are 19, those related to non-fraudulent irregularities are already 74. A more competitive and smarter Europe by promoting innovative and smart economic transformation and regional ICT connectivityA greener, low-carbon transitioning towards a net zero carbon economy and resilient Europe by promoting clean and fair energy transition, green and blue investment, the circular economy, climate change mitigation and adaptation, risk prevention and management, and sustainable urban mobilityA more social and inclusive Europe implementing the European Pillar of Social Rights20579,621,59611Priorities (2)Irregularities not reported as fraudulentTable CP8: Categories of irregularity - Cohesion policy (PP 2021-2027 - CF, ERDF, ESF+) (1)865,145,642476,710,27012Irregularities reported as fraudulent(4) This is a priority related to PP 2007-2013 that has been wrongly used for PP 2021-2027. 
 
 
 
Thirteen out of the 76 territorial cooperation programmes (17%) were affected by fraudulent 
irregularities. The overall financial impact of reported fraud over the payments received by 
these  76  programmes  (the  FDR46)  was  lower  than  for  other  operational  programmes.  The 
overall  frequency  of  fraud  among  the  irregularities  reported  for  territorial  cooperation  in 
general  (the  FFL 47)  was  also  lower  than  for  other  operational  programmes.  However,  this 
frequency  of  fraud  was  high  when  focusing  just  on  trans-national  and  interregional 
cooperation.  Actually,  this  frequency  was  high  for  almost  all  programmes  affected  by 
fraud, meaning that, when fraudulent irregularities were detected in relation to an ETC 
programme,  they  represented  a  significant  share  of  all  irregularities  detected  for  that 
programme. 

Sixty-two of the 76 programmes (82%) were affected by non-fraudulent irregularities. The 
overall  financial  impact  of  these  irregularities  (the  IDR48)  was  lower  than  for  other 
operational programmes. It was very low for trans-national and interregional cooperation. On 
average, ETC programmes were eight times smaller than the other operational programmes, 
which  could  lead  to  higher  frequency  of  irregularities  below  the  reporting  threshold 
(EUR 10 000).  Because  of  their  smaller  size,  these  programmes  might  also  be  easier  to 
manage and control and so less at risk of unintentional irregularities. However, for several 
territorial  cooperation  programmes,  analysis  suggested  that  this  could  also  be  due  to 
low performance in detection and reporting of irregularities through the IMS.  

to  public  procurement  concerned  conflict  of 

The majority of the irregularities were related to violations of the public procurement rules, 
but  they  were  rarely  reported  as  fraudulent.  The  few  fraudulent  irregularities  reported  in 
interest,  artificial  splitting, 
relation 
discriminatory  selection  criteria  and  modification  of  the  contract  elements  specified  in  the 
tender documents.  Most of non-fraudulent irregularities in public procurement concerned the 
pre-tendering  phase,  but  also  the  evaluation  of  tenders  and  the  post-tendering  phase  were 
affected. 

For  fraudulent  irregularities,  the  most  frequent  type  of  violation  was  conflict  of  interest. 
Both  for  fraudulent  and  non-fraudulent  irregularities,  the  second  most  reported  category  of 
violations was that related to the supporting documents. 

4.4.2.  Types of infringement and modus operandi 

Table  CP9  below  provides  an  overview  of  the  categories  of  irregularities  reported  in 
connection  with  the  cohesion  policy  during  PP  2014-2020. Table  CP10  shows  the  same 
information in relation to PP 2021-2027.49 The same irregularity may be associated to several 
categories of infringement. That is why the row of totals does not result from summing up the 
figures  in  the  respective  columns  of  Tables  CP9  and  CP10:  it  would  result  in  multiple 
counting of the same notification of irregularity.  

46  FDR  is  the  ratio  between  the  amounts  involved  in  cases  reported  as  fraudulent  during  a  certain  period  in 
relation to one or more operational programmes and the payments received by the same operational programmes 
during the same period.  
47 FFL is the ratio between the number of fraudulent irregularities reported during a certain period and the total 
number of irregularities (fraudulent and non-fraudulent) reported during the same period. 
48  IDR  is  the  ratio  between  the  amounts  involved  in  irregularities  not  reported  as  fraudulent  during  a  certain 
period  in relation to  one or more operational programmes and the payments received by the same operational 
programmes during the same period.  
49  For  details  about  the  content  of  the  categories  of  irregularities  listed  in  Tables  CP9  and  CP10,  please  see 
Annex  13  to  ‘Statistical  evaluation  of  irregularities  reported  for  2021:  own  resources,  agriculture,  cohesion 
and fisheries policies, pre-accession and direct expenditure’, SWD(2022)307 final. 

60 

 
 
 
With  regard  to  fraudulent  irregularities,  during  PP  2014-2020  the  most  frequent 
infringements  concerned  the  supporting  documents.  Most  of  the  time,  false  or  falsified 
documents were used.   

Fraudulent  infringements  of  contract  provisions/rules  ranked  second  during  PP  2014-
2020  and  often  consisted  in  non-implementation  of  the  funded  action.  Considering  both 
fraudulent  and  non-fraudulent  irregularities  related  to  PP  2021-2027,  the  infringement  of 
contract provisions is again the most reported violation (see Table CP10). Most of the time, it 
was about failure to respect deadlines, but this may be due to a specific situation that does not 
represent  an  emerging  pattern,  also  because  nearly  all  of  these  non-fraudulent  irregularities 
have been reported by one Member State.   

In relation to PP 2014-2020, despite in only 4% of the public procurement infringements 
fraud was suspected, these cases represent 12% of the financial amounts involved in public 
procurement  infringements  (see  Table  CP9).  Analysis  based  on  data  until  2024  related  to 

61 

NEUREUR/avgFFL (2)%FAL (3)%NEUREUR/avgIncorrect, missing, false or falsified supporting documents651251,543,932386,39623412,140358,050,700167,313Infringement of contract provisions/rules368126,307,563343,2277135,223852,880,645163,293Infringement of public procurement rules196187,972,302959,0424125,0301,342,758,821266,950Ethics and integrity136170,620,5291,254,563367424459,269,198242,907Eligibility / Legitimacy of expenditure/measure4344,770,2731,041,1694201,181184,594,571156,304Infringements concerning the request13036,850,319283,464343325776,111,046296,152Violations/breaches by the operator8023,241,699290,5211518468104,224,488222,702Incorrect, absent, falsified accounts7322,260,801304,942815833126,894,255152,334Product, species and/or land5412,467,463230,879131936351,495,650141,861Multiple financing163,126,543195,4092944393,944,292101,136Bankruptcy185,645,280313,627111615129,768,364197,141State aid162,554,615159,6633548947,266,14396,659Movement14,6124,61240221,557,87870,813Money laundering1188,149188,14950271501,483501,483Other198248,364,9991,254,36911291,587595,964,972375,529blank195,597,915294,6275636983,389,162225,987Total number of irregularities EU 27 (1)1,480861,837,498582,32382016,1803,423,444,944211,585(1) CF, ERDF, ESF. This is not the sum of the figures above, because one irregularity can refer to more than one category(2) FFL (Fraud Fequency level): ratio between the number of fraudulent irregularities and the total number of irregularities (fraudulent and non-fraudulent)(3) FAL: ratio between the amounts involved in fraudulent irregularities and the total amounts involved in irregularities (fraudulent and non-fraudulent)Irregularities not reported as fraudulentTable CP9: Categories of irregularity - Cohesion policy (PP 2014-2020) Categories of irregularitiesIrregularities reported as fraudulentFinancial amountsFinancial amountsNEUREUR/avgFFL (2)%FAL (3)%NEUREUR/avgIncorrect, missing, false or falsified supporting documents155,476,502365,1001745736,763,90192,656Infringement of contract provisions/rules5148,17229,6343113916,399,406117,981Infringement of public procurement rules192,980,202156,85318138720,112,451231,178Ethics and integrity1110,810,708982,7927399478,64919,662Eligibility / Legitimacy of expenditure/measure2119,28559,64343503,819,12176,382Infringements concerning the request483,51020,878112313,724,707120,152Violations/breaches by the operator372,03524,012152174,572,032268,943Incorrect, absent, falsified accounts261,35430,6778723817,70035,552Product, species and/or land259,99729,99929352,106,074421,215Multiple financing0000181,20881,208State aid1583,047583,0473394240,48720,244Other85,816,417727,05253957301,75643,108blank133,34733,34710010000Total number of irregularities EU 27 (1)5625,084,746447,942133536947,182,278127,865(3) FAL: ratio between the amounts involved in fraudulent irregularities and the total amounts involved in irregularities (fraudulent and non-fraudulent)(1) CF, ERDF, ESF+. This is not the sum of the figures above, because one irregularity can refer to more than one category(2) FFL (Fraud Fequency level): ratio between the number of fraudulent irregularities and the total number of irregularities (fraudulent and non-fraudulent)Table CP10: Categories of irregularity - Cohesion policy (PP 2021-2027) Categories of irregularitiesIrregularities reported as fraudulentIrregularities not reported as Financial amounts Financial amounts (EU-share) 
 
 
 
 
PP 2014-2020 50 suggested that, where the suspicion of fraud was specified, the most reported 
infringements  were  (i)  bid-rigging;  (ii)  conflict  of  interests  (iii)  use  of  discriminatory, 
unrelated  or  disproportionate  criteria  or  technical  specification.  The  low  frequency  of 
fraudulent  cases  against  the  background  of  so  many    infringements  suggests  a  need  for 
improvement either in fraud detection concerning public procurement or in the administrative 
capability of contracting authorities. Fraud detection seems to be improving with the start of 
reporting related to PP 2021-2027, as in about 18% of the public procurement infringements 
a suspicion of fraud was reported (see Table CP10). However, this is mainly due to reporting 
by  one  Member  State.  So  far,  for  PP  2021-2027  the  most  reported  fraudulent  public 
procurement infringements were conflict of interest, lack of transparency or equal treatment 
during the evaluation, bid rigging and illegal prior involvement.  

In relation to PP 2014-2020, about four out of ten infringements and  seven out of ten Euro 
concerning ethics and integrity were fraudulent. For reporting related to PP 2021-2027, these 
values  are  even  higher  (see  Table  CP10).  About  two  third  of  the  fraudulent  ethics  and 
integrity infringements related to PP 2014-2020 concerned conflict of interest 51 and less than 
20%  corruption  or  bribery.  An  analysis  has  been  recently  carried  out  of  the  cases  of 
corruption  perpetrated  by  public  officials  reported  between  the  years  2007  and  2023  in 
relation to PP  2007-2013 and PP 2014-2020 (see Box CP1).  

Box CP1: Corruption and fraud in the cohesion policy 

This analysis explored the relation between corruption and fraud to the detriment of the EU’s financial interests, focusing on 
corruption  perpetrated  by  public  officials.  The  analysis  covered  all  irregularities  (i)  reported  by  the  Member  States  as 
related to corruption in IMS (based on a specific IMS structured field about the type of violation); (ii) concerning the cohesion 
policy (meaning CF, ERDF and ESF); (iii) under the programming periods 2007-2013 and 2014-2020.  

Just 20 cases have been assessed as relevant for the analysis. This number of reported cases is excessively low, bearing in 
mind the time-span covered by this analysis, the amount of expenditure of reference (about EUR 680 billion) and information 
from other sources. 

About  20%  of  these  cases  of  corruption  followed  a  control  started  because  of  tips  from  informants  or  information 
published in the media. About 25% of the irregularities were instead detected because of a control that started in the absence 
of specific allegations or suspicions. This means that the detection of the corruptive behaviour was due to chance or similar, 
rather  than  to  risk  analysis.  Actually, detecting  a hidden phenomenon  like  corruption  through  risk  analysis  is  a  challenging 
task. 

The relevant irregularities reported by the Member States were mostly about bribery, with financial benefits received 
or  promised  to  the  public  officials  involved.  In  one  case,  the  system  included  consultancy  contracts  with  a  colluded 
company  of  professionals.  In  another  case,  the  bribe  was  to  be  paid  through  the  invoicing  of  fictitious  services  from 
companies  related  to  the  briber  to  the  company  that  was  promised  the  award  of  the  contract  during  a  public  procurement 
procedure.  

Most  of  the  reported  irregularities  concerned  corruption  in  public  procurement  procedures.  This  means  that  the  public 
officials  involved  were  on  the  side  of  the  beneficiary,  acting  as  contracting  authority.  Sometimes  corruption  concerned 
simplified  or  restricted  public procurement  procedures,  where  the  contracting  authority has  more  leeway  in  influencing 
who  will  participate  in  the  procedure.  This  may  facilitate  bid-rigging  or  result  in  single  bidding.  Sometimes  corruption 
concerned  open  public  procurement  procedures.  In  these  cases,  public  officials  mostly  favoured  the  briber  in  the 
pre-tendering  phase,  but  also  the  evaluation  of  bids  happened  to  be  affected  by  corruption.  High  public  officials 
(managers) were also targeted by bribers. Managers played key roles, either because they had the overview of the upcoming 
and ongoing public procurement procedures or because they were the intermediary between the winning contractors and the 
evaluation committees. External experts may also be involved in corruption in relation to the public procurement procedures 
they manage for the contracting authority. They can also make use of their links with other companies for bid-rigging or for 
the payment of the bribe. 

Available data does not allow identifying a ‘most affected by corruption’ sector. However, there is some confirmation about 

50 ‘Statistical evaluation of irregularities reported for 2024: own resources, agriculture, cohesion and fisheries 
policies, pre-accession and direct expenditure’, SWD(2025)  230final, 25/7/2025.  
51  59  additional  fraudulent  irregularities  concerned  conflict  of  interest  in  public  procurement.  They  are 
considered under infringements of public procurement rules. 

62 

 
 
 
 
the vulnerability of sectors mentioned in other studies. Considering the limited number of cases, corruption touched upon a 
wide  range  of  sectors.  These  sectors  include  education  infrastructure,  Research  and  Technology  Development  (RTD), 
transport, waste management and waste water management. 

4.4.3.  Risk analysis and spontaneous reporting 

In  the  antifraud  cycle,  the  capacity  of  a  system  to  detect  fraud  and  irregularities  is  a  key 
feature that helps making the system effective and efficient in protecting the EU budget.  In 
the  2017  PIF  Report,  to  boost  the  capability  to  detect  irregularities,  the  Commission 
recommended  to  the  Member  States  to  improve  risk  analysis  and  the  use  of  spontaneous 
reporting  of  potential  irregularities  and  to  strengthen  the  protection  of  whistle-blowers  that 
are also a crucial source for investigative journalism52. 

The percentage of fraudulent irregularities detected following risk analysis during the past 
5 years  was still very low with no improvement  from  the previous years 2016-2020  (see 
Table  CP11  below).  During  the  past  5  years,  about  12%  of  the  irregularities  have  been 
detected following tips from informants, but there was a decreased from previous 5 years. 
Only a few detections followed information published in the media (1%).   

On non-fraudulent irregularities, there may have been an improvement in risk analysis, if 
the  Member  States  that  reported  ‘comparison  of  data’  meant  some  form  of  risk  analysis. 
Information  from  civil  society  continued  to  provide  a  negligible  contribution  to 
detection (see Table CP12 below). 

52 Section 4.3 of the ‘29th Annual Report on the Protection of the EU’s financial interests – Fight against fraud 
–  2017’,  COM(2018)553  final  and  ‘Statistical  evaluation  of  irregularities  reported  for  2017:  own  resources, 
agriculture, cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2018)386 final.  

63 

N.%EUR (2)N.%EUR (2)Risk analysis181.97,198,123161.22,751,888Comparison of data161.74,576,276282.28,677,159Probability checks80.82,984,41470.5397,913Statistical analysis10.1218,482Tip from informant, whistle-blower etc.17618.5103,727,76115412.087,991,444Information published in the media262.740,037,297151.211,770,184Total951543,647,6481,287829,478,313(2) Financial amounts (EU-share) involved in irregularitiesTable CP11 - Reasons for performing the controls that led to detection of irregularities reported as fraudulent (Cohesion policy - EU27) (1)(1) CF, ERDF, ESF, ESF+Irregularities reported as fraudulent - Cohesion policyProgramming periods 2007-2013, 2014-2020 and 2021-20272016-2020Reason for performing control2021-2025N.%EUR (2)N.%EUR (2)Risk analysis4002.361,629,0314773.760,247,612Comparison of data1160.722,122,7468236.5130,590,401Probability checks840.515,555,5022912.355,131,435Statistical analysis160.13,995,169170.11,980,746Tip from informant, whistle-blower etc.2591.540,640,9411531.244,962,126Information published in the media680.465,661,302430.311,658,194Total17,5243,962,605,51212,7592,807,709,056Table CP12 - Reasons for performing the controls that led to detection of irregularities not reported as fraudulent (Cohesion policy - EU27) (1)Irregularities not reported as fraudulent - Cohesion policy Programming periods 2007-2013, 2014-2020 and 2021-2027(2) Financial amounts (EU-share) involved in irregularities(1) CF, ERDF, ESF, ESF+Reason for performing control2016-20202020-2024 
 
 
 
  
 
 
The  low  share  of  irregularities  detected  following  risk  analysis  suggests  room  for 
improvement in this domain. It is true that risk analysis might have had a more important 
role in detecting irregularities before expenditure is introduced in a request for reimbursement 
to the Commission. These detections, where referring to non-fraudulent irregularities, do not 
have  to  be  reported  in  IMS.  However,  this  is  valid  only  for  non-fraudulent  irregularities. 
Fraudulent  irregularities  must  always  be  reported  in  IMS  (where  above  the  EUR  10 000 
threshold).  Detection  of  fraud  and  irregularities  could  improve  by  adding  to  existing 
preventive  management  verifications  and  audits  of  operations  also  ex post  thematic  risk 
analysis  projects  focusing  on  groups  of  past  transactions,  with  a  view  to  carrying  out 
targeted ex post controls.  

During  the  programming  period  2021-2027,  management  verifications  are  risk-based 
and  proportionate  to  the  risks  identified.  Until  PP  2014-2020  included,  administrative 
verifications  covered  instead  100%  of  the  payment  applications  for  reimbursement  by 
beneficiaries. In this new context, it is even more important that the approach to management 
verifications includes an adequate policy about ex post checks.  

National  anti-fraud  strategies  should  consider  strengthening  the  national  anti-fraud 
landscape through the systematic involvement of bodies that are (i) external to management 
and  control  system  specific  to  the  use  of  EU  funds  and  (ii)  endowed  with  the  necessary 
powers, information and resources.  

4.4.4.  Duration of irregularities  

With regard to PP 2014-2020, for fraudulent irregularities, on average, it took 27 months to 
suspect that an irregularity had been or was being perpetrated. Once the suspicion arose, the 
Member  States  detected  the  fraudulent  irregularity  in  5  months.  Then  the  fraudulent 
irregularity  was  reported  to  the  Commission  9  months  after  detection.  The  average  time 
from the reporting to the Commission to the case closure was more than 2 years and a 
half. For the non-fraudulent irregularities this took 20 months (see Graphs CP5 and CP6 
below).  This  delay  in  closing  fraudulent  cases  is  consistent  with  the  need  to  rely  on 
specialised,  more  limited  resources  to  investigate  fraud  and  the  longer  duration  of  criminal 
proceedings. 

64 

 
 
4.4.5.  Detection and reporting by Member State  

Given  the  multiannual  nature  of  cohesion  and  fisheries  programmes,  focus  is  on  the  whole 
programming  periods.  The  fraud  detection  rate  (FDR)  and  the  irregularities  detection  rate 
(IDR)  compare  the  results  obtained  by  Member  States  in  the  fight  against  fraud    and 
irregularities with the payments they received.53 

Tables CP13 and CP14 below show data on fraud detection in the Member States in relation 
to  PP 2014-2020  and  PP  2021-2027,  respectively.  Tables  CP15  and  CP16  below  show  the 
financial amounts involved in the irregularities included in Tables CP13 and CP14.  

53 FDR is the ratio between the amounts involved in cases reported as fraudulent and the payments  received by 
the  Member State. The Member States have the obligation to report  also irregularities for which payment and 
inclusion of the expenditure concerned in a statement of expenditure submitted to the European Commission did 
not occur yet. As a consequence, the FDR covers both the ‘preventive’ and the 'repressive' side of the anti-fraud 
cycle. IDR is a similar ratio, but based on the amounts involved in cases not reported as fraudulent.  

65 

0.010.020.030.040.050.060.070.080.0Reporting to case closureDetection to reportingSuspicion to detectionIrregularity to suspicionGraph CP5: Average times from  irregularity to case closure Cohesion and Fisheries policies; PP 2014-2020; irregularities reported as fraudulentAvg. duration in months27 months5 months9 monthsNumber of irregularities at the basis of these averagetimes From irregularityto suspicion: 1 490From suspicionto detection: 1 474From detection to reporting: 1 499From reporting to case closure: 1460.010.020.030.040.050.060.070.0Reporting to case closureDetection to reportingSuspicion to detectionIrregularity to suspicionGraph CP6: Average times from  irregularity to case closure Cohesion and Fisheries policies; PP 2014-2020; irregularities not reported as fraudulentAvg. duration in months20 months27 months3 months8 monthsNumber of irregularities at the basis of these averagetimes From irregularityto suspicion: 15 855From suspicionto detection: 15 809From detection to reporting: 16 116From reporting to case closure:6 40032 months 
 
 
 
 
66 

CFERDFESFEMFFCF, ERDF, ESF, EMFFNNNNNAT03407BE1710018BG0622028CY04004CZ31071495264DE065550120DK04004EE22521039ES0110011FI00011FR0204125GR381012HR2153020HU1198141214IE00000IT0180119LT057315LU00000LV5536468MT11002NL00101PL367964170PT153443101RO281677324292SE014611SI6106022SK144714075TOTAL EU2770895515631543UK (1)059115(1) As of 1 February 2020, the UK is no longer part of the EUTable CP13: Number of fraudulent irregularities by Member State - Cohesion and Fisheries policies - Programming period 2014-20Member StateIrregularities reported as fraudulent PP 2014-20CFERDFESF+EMFAFCF, ERDF, ESF, EMFAFNNNNNBE11CZ134DE5510DK11EE55FI22FR11HU22LV33PT22RO23124SK11TOTAL EU2714312056Table CP14: Number of fraudulent irregularities by Member State - Cohesion and Fisheries policies - Programming period 2021-27Member StateProgramming period 2021-2027 - Cohesion and Fisheries policiesIrregularities reported as fraudulent PP 2021-27 
 
 
 
 
In relation to PP 2014-2020, the FDR is 0.22% (see Table CP15 below), which is lower than 
the  FDR  recorded  for  the  PP  2007-2013  (0.42%).54 The  highest  FDRs  were  recorded  by 
Romania  (about  1.43%)  and  Slovakia  (about  0.78%).  Besides  these  2  Member  States,  the 
FDR  exceeded  0.2%  only  in  Austria,  Czechia,  Hungary,  Latvia  and  Portugal.  In  the  other 
Member States, the FDR was still lower, often close to zero (see Table CP15 below). 

For PP 2021-2027, the FDR is still just 0.05% (see Table CP16 below). This is very low, 
even considering that pre-financing is frontloaded. During a comparable period of time after 
the start of the programming period, during PP 2014-2020, the FDR was about 0.86%. This 
was heavily influenced by 2 large irregularities. Even without these outliers, the FDR would 
have been about three times the FDR during PP 2021-2027. 

54  Considering  data  until  2021  included  (Section  4.5.3  of  ‘Statistical  evaluation  of  irregularities  reported  for 
2021:  own  resources,  agriculture,  cohesion  and  fisheries  policies,  pre-accession  and  direct  expenditure’, 
SWD(2022)307 final) 

67 

CFERDFESFEMFFEUREUREUREUREUREU payments (1)FDR %AT02,953,83588,43203,042,2671,256,195,8690.24BE44,3022,645,873320,41203,010,5862,201,514,0840.14BG0377,4101,202,40001,579,8107,851,590,5050.02CY0414,86000414,860884,394,0230.05CZ23,273,32755,086,0878,895,080507,23787,761,73122,677,889,8550.39DE08,211,4067,265,031015,476,43720,653,910,3040.07DK0245,65500245,655832,837,8500.03EE616,1036,203,18074,970493,5897,387,8433,799,288,3970.19ES02,024,341002,024,34142,716,563,5650.00FI000132,888132,8881,555,315,7660.01FR011,304,602575,16356,25011,936,01518,081,335,0090.07GR6,117,703960,06941,40007,119,17118,217,220,2990.04HR10,470,9666,469,895236,661017,177,5229,131,616,1000.19HU1,288,80849,650,8541,574,345876,85953,390,86622,401,868,3800.24IE000001,173,538,2940.00IT05,127,636082,2935,209,92946,363,619,1090.01LT03,784,500471,90498,6184,355,0237,029,259,2060.06LU00000182,134,1340.00LV1,654,04823,902,427545,166654,87926,756,5194,721,225,3280.57MT214,69560,14900274,844844,499,1410.03NL000001,670,720,9520.00PL4,062,40242,715,17117,831,778955,78965,565,13978,750,001,1350.08PT192,54989,670,55610,035,333490,574100,389,01223,458,738,6460.43RO167,804,558154,817,07415,576,7343,380,997341,579,36323,920,112,2001.43SE021,659437,134875,6221,334,4151,985,539,6360.07SI756,7312,712,553733,57604,202,8593,338,781,3980.13SK33,660,12271,099,2775,316,6010110,076,00014,099,394,5900.78EU27250,156,313540,459,06871,222,1178,605,596870,443,094389,094,368,2140.22UK (2)0803,0741,811,02817,3242,631,42610,717,216,3360.02Table CP15: Financial amounts (EU-share) involved in fraudulent irregularities and fraud detection rate by Member State - Cohesion and Fisheries policies - Programming period 2014-20Member StateFinancial amounts (EU-share) involved in Irregularities reported as fraudulent PP 2014-2020CF, ERDF, ESF, EMFF(1) Net payments until 2025 from CF, ERDF, ESF, EMFF. Total includes payments related to cross border cooperation(2) As of 1 February 2020, the UK is no longer part of the EU 
 
 
 
Tables  CP17-20  below  show  data  on  irregularity  detection  in  the  Member  States  for 
PP 2014-2020 and PP 2021-2027. In relation to PP 2014-2020, the IDR is 0.89%, which is 
much lower than the IDR recorded for the PP 2007-2013 (2.5%)55. This is not surprising, 
given the striking drop in the number of non-fraudulent irregularities reported by the Member 
States (see Section 4.2)   

55  Considering  data  until  2021  included  (Section  4.5.4  of  ‘Statistical  evaluation  of  irregularities  reported  for 
2021:  own  resources,  agriculture,  cohesion  and  fisheries  policies,  pre-accession  and  direct  expenditure’, 
SWD(2022)307 final) 

68 

CFERDFESF+EMFAFEUREUREUREUREUREU payments (1)FDR %BE016,585016,585200,197,8910.01CZ201,316094,757296,0734,824,483,6430.01DE0115,497676,611792,1082,087,489,6660.04DK033,347033,34798,820,6280.03EE02,989,02702,989,027580,248,9270.52FI046,112046,112277,258,5910.02FR0583,0470583,0472,643,934,2430.02HU0128,3630128,3633,241,463,9590.00LV0065,17765,177856,517,8630.01PT07,535,68007,535,6802,752,838,6000.27RO012,452,27054,77212,507,0426,487,641,2890.19SK092,185092,1851,544,986,4940.01EU27201,31623,992,113891,317025,084,74653,463,984,6140.05Member StateProgramming period 2021-2027 - Cohesion and Fisheries policiesFinancial amounts (EU-share) involved in Irregularities reported as fraudulent CF, ERDF, ESF, EMFAF(1) Net payments until 2025 from CF, ERDF, ESF+, EMFAF. Total includes payments related to cross border cooperationTable CP16: Financial amounts (EU-share) involved in fraudulent irregularities and fraud detection rate by Member State - Cohesion and Fisheries policies - Programming period 2021-27 
 
 
 
 
For  PP  2014-2020,  Slovakia  recorded  the  highest  IDR,  at  3.72%.  In  line  with  the  general 
significant decrease in non-fraudulent irregularities reported, the IDR is above 1% only 
in Austria, Bulgaria, Estonia, Greece and Romania. In many Member States, IDR is below 
0.5% (see Table CP19 below).  

69 

CFERDFESFEMFFCF, ERDF, ESF, EMFFNNNNNAT0125201146BE075390114BG714106643590CY1066325CZ2291,047277201,573DE051020210722DK0982138EE172377297585ES01,031192461,269FI04516869FR037013230532GR414412068696HR238213626267HU46878297151,236IE01947066IT06661602828LT110468335616LU01001LV201011710148MT2177430NL1774385PL1852,6611,221224,089PT4424112479488RO169745554731,541SE0413247120SI74819074SK1364741057722TOTAL EU271,26610,9653,94949016,670UK (1)0918687301,635(1) As of 1 February 2020, the UK is no longer part of the EUTable CP17: Number of irregularities not reported as fraudulent by Member State - Cohesion and Fisheries policies - Programming period 2014-20Member StateIrregularities  not reported as fraudulent PP 2014-20CFERDFESF+EMFAFCF, ERDF, ESF+, EMFAFNNNNNBG02406CZ142210046DE03609EE3115019FI00011GR05005HR00101HU114520148IE00404IT04004LV10001MT10001PL04428072PT00101RO0266032SE03104SI01001SK294015TOTAL EU2722275721370Table CP18: Number of irregularities not reported as fraudulent by Member State - Cohesion and Fisheries policies - Programming period 2021-27Member StateProgramming period 2021-2027 - Cohesion and Fisheries policiesIrregularities  not reported as fraudulent PP 2021-27 
 
   
  
  
For PP 2021-2027, the IDR is still just 0.09%. This is very low, even considering that pre-
financing  is  frontloaded.  During  a  comparable  period  of  time  after  the  start  of  the 
programming period, during PP 2014-2020, the IDR was about 0.34%. 

70 

CFERDFESFEMFFEUREUREUREUREUREU payments (1)IDR %AT012,959,841885,74381,94313,927,5271,256,195,8691.11BE04,223,1533,472,29207,695,4452,201,514,0840.35BG66,996,69559,501,0664,097,0423,249,188133,843,9917,851,590,5051.70CY4,150,336407,308351,439243,8575,152,940884,394,0230.58CZ55,186,621123,055,80820,769,6591,295,978200,308,06622,677,889,8550.88DE066,571,16314,284,9531,676,11582,532,23120,653,910,3040.40DK0407,464615,060933,4501,955,974832,837,8500.23EE23,080,41526,898,1092,852,566268,83153,099,9213,799,288,3971.40ES0241,461,60750,894,1523,432,569295,788,32842,716,563,5650.69FI02,794,914344,685310,0263,449,6251,555,315,7660.22FR049,463,54911,137,8333,413,31264,014,69418,081,335,0090.35GR43,723,659137,032,313165,544,858567,696346,868,52618,217,220,2991.90HR9,234,62516,901,03424,029,6912,321,22652,486,5769,131,616,1000.57HU18,203,122130,011,97435,962,5233,040,989187,218,60822,401,868,3800.84IE0549,8536,381,22106,931,0741,173,538,2940.59IT0132,131,03819,379,69649,220151,559,95446,363,619,1090.33LT14,865,23848,347,0862,195,47193,61465,501,4097,029,259,2060.93LU014,2590014,259182,134,1340.01LV7,051,76421,359,428822,671766,66430,000,5274,721,225,3280.64MT913,5181,462,529616,77296,7103,089,529844,499,1410.37NL42,2754,831,393199,16440,4265,113,2581,670,720,9520.31PL34,842,724536,176,846112,845,6992,710,182686,575,45178,750,001,1350.87PT5,929,68328,228,6847,493,5585,903,54847,555,47323,458,738,6460.20RO169,985,927262,996,34040,632,0328,243,616481,857,91523,920,112,2002.01SE01,499,0391,321,3154,324,4527,144,8061,985,539,6360.36SI1,954,8076,521,5391,251,62709,727,9733,338,781,3980.29SK237,046,556254,564,22431,483,6971,141,465524,235,94214,099,394,5903.72TOTAL EU27693,207,9652,170,371,561559,865,41944,205,0773,467,650,022389,094,368,2140.89UK (2)072,769,42731,134,9413,088,969106,993,33710,717,216,3361.00Table CP19: Financial amounts (EU-share) involved in irregularities not reported as fraudulent and irregularity detection rate by Member State - Cohesion and Fisheries policies - Programming period 2014-20(2) As of 1 February 2020, the UK is no longer part of the EUMember StateCF, ERDF, ESF, EMFFIrregularities  not reported as fraudulent PP 2014-20(1) Net payments until 2025 from CF, ERDF, ESF, EMFF. Total includes payments related to cross border cooperationCFERDFESF+EMFAFEUREUREUREUREUREU payments (1)IDR %BG025,9300144,629170,5591,186,125,9030.01CZ941,699830,1270508,0542,279,8804,824,483,6430.05DE0217,8030190,456408,2592,087,489,6660.02EE89,276246,8750114,380450,531580,248,9270.08FI0012,476012,476277,258,5910.00GR01,946,963001,946,9633,809,621,4670.05HR00023,26523,265989,877,5350.00HU951,19112,666,39601,258,50914,876,0963,241,463,9590.46IE000159,536159,536142,979,3280.11IT0150,41700150,4174,937,849,9020.00LV32,87400032,874856,517,8630.00MT23,27400023,27484,994,0860.03PL010,127,54401,684,37511,811,91910,372,289,0990.11PT00048,06948,0692,752,838,6000.00RO06,793,1110243,5007,036,6116,487,641,2890.11SE060,885024,36085,245341,546,0430.02SI019,8720019,872300,449,0920.01SK2,123,0855,211,5980324,2257,658,9081,544,986,4940.50TOTAL EU274,161,39938,297,52112,4764,723,35847,194,75453,463,984,6140.09(1) Net payments until 2025 from CF, ERDF, ESF+, EMFAF. Total includes payments related to cross border cooperationTable CP20: Financial amounts (EU-share) involved in irregularities not reported as fraudulent and irregularity detection rate by Member State - Cohesion and Fisheries policies - Programming period 2021-27Member StateIrregularities  not reported as fraudulent PP 2021-27CF, ERDF, ESF, EMFAFProgramming period 2021-2027 - Cohesion and Fisheries policies 
 
 
 
Past analysis based on PP 2007-2013 suggested that the concentration of detections is not 
fully explained by the concentration of payments 56. There was little correlation between 
the amounts paid and the number of detections. This analysis was quite solid, as it was based 
on operational programmes closed several years before. This finding seems to be confirmed 
by the differences in fraud detection related to PP 2014-2020 (see above, Tables CP13, CP15, 
CP17,  CP19).  The  outcome  of  that  analysis  based  on  PP  2007-2013  could  be  due  to  many 
different factors, including different underlying levels of irregularities and fraud, differences 
in the quality of prevention or detection work, different approaches to criminal investigation 
and prosecution to protect the EU budget or to the classification of irregularities as suspected 
fraud in IMS. 

4.4.6.  Follow-up to suspected fraud 

The  Member  States  may  report  irregularities  as  non-fraudulent  (just  administrative 
irregularities)  or  as  fraudulent  (suspected  or  established  fraud)  and  they  may  change  this 
classification  during  the  lifetime  of  the  irregularities.  The  following  analysis  provides 
intelligence on how the Member States followed-up suspected fraud they detected during the 
years  2014-2025.57  The  irregularities  that  have  been  cancelled  are  excluded  from  this 
analysis, because once an irregularity is cancelled the information needed for the analysis is 
not present in IMS anymore. This implies an underestimation of dismissals.   

As shown in Graph CP7 below, for about 17% of the irregularities with a suspicion of 
fraud, the suspicion was then confirmed as established fraud. The best results in terms of 
established fraud are around 20%, with a peak at 33% in 2019. This is no clear pattern across 
time,  because  these  best  results  are  not  all  related  to  earlier  years.  The  worst  years  include 
also 2015, 2017 and 2018.  

For 18% of the irregularities with a suspicion of fraud, the suspicion was then dismissed 
(see  Graph  CP7  below).  The  dismissal  ratio  was  higher  during  2014-2020  than  during  the 
following years, in line with expectations.  

Most  of  the  irregularities  where  there  was  a  suspicion  of  fraud  are  still  classified  as 
suspected  fraud,  even  if  several  years  have  elapsed  since  the  initial  reporting  (see  Graph 
CP7 below). 

56  Section  4.4.2  of  ‘Statistical  evaluation  of  irregularities  reported  for  2018:  own  resources,  agriculture, 
cohesion and fisheries policies, pre-accession and direct expenditure’, SWD(2019)365 final 
57 To include an irregularity in this analysis, the relevant year is the year to which the Member State allocate the 
irregularity in IMS (reporting year). Changes to the classification of the irregularities until 8/3/2026 (date of the 
download of IMS data for this analysis) are considered. 

71 

 
 
 
Focusing on the irregularities that were initially reported during 2014-2018, significant 
differences  between  Member  States  can  be  found  (see  Table  CP21  below).  Focusing  on 
this period means focusing on irregularities that have been reported between 7 and 12 years 
ago. 

In  many  Member  States,  the  percentage  of  irregularities  still  classified  as  suspected 
fraud is high. This may suggest that the judicial authorities do not give proper follow-up to 
these suspicions, including because they may not have sufficient resources.  Alternatively, it 
could  be  that  there  are  no  proper  communication  channels  from  judicial  to  reporting 
authorities. This high percentage of irregularities still classified as suspected fraud could also 
be  due  to  persistent  suspicions  of  the  national  authorities,  while  criminal  proceedings  were 
not  started, were prevented by the statute of limitations or did  not  lead to  enough evidence 
about fraud. 

72 

 
 
 
4.5.  Recovery and Sanctions 

4.5.1.  Recovery 

Data from IMS can be used to measure certain aspects of recovery. For each irregularity, 
the Member States are requested to report the financial amounts involved and then split them 
in  amounts  prevented  and  amounts  already  paid  out.  The  latter  are  considered  financial 
amounts  to  be  recovered.  Then,  the  Member  States  can  follow  up  the  amounts  to  be 
recovered and specify: (i) the amounts that do not have to be recovered due, for instance, to a 
deduction  during  interim  or  final  payment  or  a  write  off;  (ii)  the  amounts  that  have  been 
recovered; (iii) the amounts that still need to be recovered (outstanding debt). 

The  following  analysis  is  based  on  the  above  mentioned  information  and  focuses  on  the 
irregularities that have been initially reported during 2015-2025 and are now closed, because 
for  them  the  recovery  process  should  have  been  finalised.  In  relation  to  the  cohesion  and 
fisheries  policies  at  EU  27  level,  for  25 156  closed  irregularities   (accounting  for  about 
EUR 4.5 billion ), there were amounts to recover.58  

58  There  were  amounts  to  recover  (IMS  field  9.3)  for  27 822  closed  irregularities  (accounting  for  about 
EUR 5 billion  to  recover).  However,  for  2 666  of  these  irregularities  (about  10%,  accounting  for  about 
EUR 570 million), the Member States have not reported any follow-up, so they have been excluded from this 
analysis. However, they are considered in the total number of cases with amounts to be recovered (see below). 
These 2 666 irregularities were fraudulent (55) and non-fraudulent (2 611). About 75% and 16% of the excluded 
irregularities  have  been  reported  by  2  Member  States.  About  81%  concerned  decertified  expenditure.  With 
specific reference to the excluded fraudulent irregularities, about 87% are reported as established fraud. 

73 

N.%N.%N.%AT133%00%267%BE00%00%6100%BG650%217%433%CY00%120%480%CZ4227%8051%3422%DE6335%3922%7743%DK233%117%350%EE00%1045%1255%ES2518%00%11282%FI125%00%375%FR00%00%12100%GR712%12%4986%HR00%250%250%HU5138%54%7758%IE0NA0NA0NAIT1831%58%3661%LT113%563%225%LU0NA0NA0NALV924%1334%1642%MT00%00%2100%NL531%744%425%PL9731%6019%15950%PT00%00%49100%RO7337%84%11859%SE120%00%480%SI741%212%847%SK1915%3325%7860%EU-2742827%27417%87355%Table CP21: Cohesion and Fisheries policies  Follow-up to suspected fraud by Member State - Irregularities initially reported during 2014-2018 (1)Member StateDismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
The analysis covers 430 fraudulent irregularities (accounting for about EUR 169 million to be 
recovered). 59  As  shown  in  Graph  NR8a,  in  relation  to  cohesion  and  fisheries  for  the  years 
2015-2025, closed irregularities considered in this analysis are a small percentage (19%) 
of  total  fraudulent  irregularities  (open  and  closed)  with  amounts  to  be  recovered60.  As 
mentioned, closing a fraudulent irregularity takes time (see Section 4.4.4). However, there is 
no clear pattern with significantly higher percentages of closed irregularities for earlier years 
(see Graph CP8a). About 69% of the amounts to recover have been deducted or written 
off, 27% have been  actually  recovered and 4% are not recovered.  As shown in  Graph 
CP8c,  there  were  years  where  most  of  the  amounts  were  deducted  or  written  off,  such  as 
2015,  2016,  2021  and  2024,  and  years  where  most  of  the  amounts  have  been  actually 
recovered, such as 2019, 2020, 2023 and 2025. In 2020 and 2022, percentages of the amounts 
not  recovered  were  higher,  around  30%.  This  is  mostly  due  to  2  irregularities  accounting 
together for more that 95% of the EUR 5 million not recovered in 2020 and 2022. 

In relation  to fraudulent irregularities,  nearly all the amounts deducted or written off 
are  related  to  irregularities  where  this  was  the  only  form  of  recovery,  with  nearly  all 
amounts  fully  charged  to  national  budget61.  The  fraudulent  irregularities  with  actual 
recovery and no amounts deducted or written off were smaller62 and for them 87% of 
the amounts were actually recovered. Fraudulent irregularities with both amounts deducted 
or written off and amounts actually recovered or fraudulent irregularities with neither of them 
were rare.  

irregularities 

The  analysis  covers  24 726  non-fraudulent 
for  about 
EUR 4.3 billion to  recover).63 As shown in  Graph  NR9a below, in  relation to  cohesion  and 
fisheries for the years 2015-2025, closed irregularities considered in this analysis are 62% 
of  total  non-fraudulent  irregularities  (open  and  closed)  with  amounts  to  be  recovered64. 
More than 70% of the amounts to recover have been actually recovered, 28% have been 
deducted or written off and 1% are not recovered.  As shown in Graph CP9c, for most of 
the years, about 75% of the amounts to recover  have been  actually  recovered.  In 2018, the 
percentage of amounts deducted or written off was particularly high, at 53%.  

(accounting 

Nearly  all  the  amounts  actually  recovered  are  related  to  non-fraudulent  irregularities 
where there are no amounts deducted or written off.  For these irregularities, the average 
amount to recover is about EUR 172 000. Most of the amounts deducted or written off are 
related  to  irregularities  where  this  was  the  only  form  of  recovery,  with  most  of  the 

59  About  40% of  them  have been  reported  in 2015.  The  majority  of  these fraudulent  irregularities  reported  in 
2015 were from Spain and related to PP 2007-2013. 
60 As mentioned, closed cases considered in the analysis does not include irregularities with amounts to recover, 
but  for  which  the  Member  States  have  not  provided  any  information  about  the  recovery.  However,  these 
irregularities  are  included  in  the  total.  The  percentage  would  be  16%,  considering  in  the  total  also  the 
irregularities without amounts to be recovered.   
61 Based on the value of the IMS field ‘Financial status’. 
62 The average amounts to recover for these fraudulent irregularities (about EUR 184 000) is much lower than 
the  average related to the above mentioned fraudulent irregularities with just amounts deducted or written off 
(EUR 820 000). 
63  About  31% of  them have been  reported  in 2015.  The  majority  of  these fraudulent  irregularities  reported  in 
2015 are related to PP 2007-2013 and are due to Spain that at that time cleared a significant reporting backlog. 
64 As mentioned, closed cases considered in the analysis does not include irregularities with amounts to recover, 
but  for  which  the  Member  States  have  not  provided  any  information  about  the  recovery.  However,  these 
irregularities  are  included  in  the  total  and  they  are  about  7%  of  it.  The  percentage  of  closed  irregularities 
considered in this analysis would be 60%, considering in the total also the irregularities without amounts to be 
recovered.   

74 

 
 
 
expenditure fully charged to national budget65. For these irregularities, the average amount 
to recover is about EUR 178 000. Non-fraudulent irregularities with both amounts deducted 
or written off and amounts actually recovered or non-fraudulent irregularities with neither of 
them were rare. 

65 Based on the value of the IMS field ‘Financial status’. 

75 

 
 
 
 
76 

117457020406080100120140160180MillionsGraph CP8b: Recovery of paid out irregular amounts fraudulent irregularitiesAmount deducted, written off etcAmount recoveredBalance to recover81%96%62%58%20%2%78%45%6%86%33%69%18%4%33%41%80%67%22%25%93%13%67%27%1%0%6%0%0%31%0%30%1%2%0%4%0%10%20%30%40%50%60%70%80%90%100%Graph CP8c: Recovery -year by year distributionfraudulent irregularitiesAmount deducted, written off etcAmount recoveredBalance to recover315232144179141172153152204335278169362433342326253219954%16%17%18%24%13%17%16%16%6%3%0%10%20%30%40%50%60%05010015020025030035040020152016201720182019202020212022202320242025Graph CP8a: Closed irregularities vs all irregularitiesfraudulent irregularitiesTotal irregularities (including open)Closed irregularities% closed over total1,2063,0924905001,0001,5002,0002,5003,0003,5004,0004,5005,000MillionsGraph CP9b: Recovery of paid out irregular amounts non-fraudulent irregularitiesAmount deducted, written off etcAmount recoveredBalance to recover23%23%33%53%23%27%26%22%23%34%37%28%76%76%65%47%75%73%74%78%76%65%63%71%1%1%2%1%1%0%0%0%1%2%0%1%0%10%20%30%40%50%60%70%80%90%100%Graph CP9c: Recovery -year by year distributionnon-fraudulent irregularitiesAmount deducted, written off etcAmount recoveredBalance to recover929675894675171916232175214922932406303129967,6684,4202,9588929111,2071,1531,2301,3421,4711,47482%58%63%52%56%55%54%54%56%49%49%0%10%20%30%40%50%60%70%80%90%01000200030004000500060007000800090001000020152016201720182019202020212022202320242025Graph CP9a: Closed irregularities vs all irregularitiesnon-fraudulent irregularitiesTotal irregularities (including open)Closed irregularities% closed over total 
 
 
 
 
COHESION AND FISHERIES 

4.5.2.  Sanctions 

For each irregularity, the Member States must specify whether sanctions have actually been 
imposed.  Sanctions  have  been  imposed  for  291  out  of  the  556  fraudulent  irregularities 
reported  during  2015-2025  that  are  now  closed  (about  52%).  As  shown  in  Table  CP22 
below, in about 9% of cases, these sactions were just administrative, which is not expected 
for fraudulent irregularities. Sanctions have been applied to 896 out of 28 094 closed non-
fraudulent irregularities (about 3%).66 

Table CP23 below shows the specific type of sanction that has been imposed, separately for 
fraudulent  and  non-fraudulent  irregularities.  Each  specific  type  can  be  administrative  or 
penal,  with  the  exception  of  imprisonment,  which  can  be  only  penal.  For  each  irregularity, 
more than one specific type of sanction may have been imposed.  

The  combination  of  different  categories  of  sanctions  was  not  frequent.  Imprisonment 
was rarely accompanied with other penalties to protect the EU financial interests, such 
as  exclusion  from  future  subsidies.  For  the  purpose  of  this  analysis,  the  specific  types  of 
sanction listed in Table CP23 above have been grouped as the categories fines, imprisonment, 
exclusion from future subsidies, limitation in access to public procurement, loss of subsidies 
and  other.  Table  CP24  below  shows  how  these  categories  were  combined  in  the  same 
irregularities. For 46 and 19 of the 291 fraudulent irregularities where sanctions were applied, 

66 There were 2 additional fraudulent and 697 additional non-fraudulent irregularities were the IMS field about 
sanctions imposed was fill in. However, for these irregularities, the IMS field ‘Procedure to impose penalties’ 
was  filled  in  with  ‘Decision:  no  sanction’ or  the  IMS  ‘Status  of  the  procedure’  was  ‘abandoned’.  Because  of 
these inconsistencies, these irregularities have been excluded from the analysis. In particular, one Member State 
reported sanctions for 666 non-fraudulent irregularities where the IMS field ‘Procedure to impose penalties’ was 
filled in with ‘Decision: no sanction’. For all of these 666 irregularities, there are just proportional national fines 
mentioned,  which  are  then  not  included  in  the  analysis.  For  570  of  these  666  irregularities,  there  is  no 
information about type and status of procedure.  

77 

Type of sanction appliedN. irregularities%Type of sanction appliedN. irregularities%admin269%admin87898%admin and penal165%admin and penal10%penal24986%penal172%Grand Total291Grand Total896Table CP22: Cohesion and Fisheries policies (1)Irregularities reported during 2015-2025 and closedFraudulentNon-fraudulent(1) CF, ERDF, ESF, ESF+, EFF, EMFF, EMFAF, FIFG, GUIDType of sanctionAdministrative sanctionPenal sanctionBoth administrative and penalAdministrative sanctionPenal sanctionBoth administrative and penalNational fine - proportional96713232National fine - non-proportional118101National fine - flat rate12341National subsidies - loss of subsidies4671National subsidies - exclusion from future subsidies11855Limitation of access to public procurementEU-fine - proportional1421EU-fine - non-proportional6EU-fine - flat rate1EU-subsidies - loss of subsidies46204EU-subsidies - exclusion from future subsidies1117137Imprisonment8Imprisonment under 1 year33Imprisonment between 1 year and 4 years701Imprisonment over 4 years14Other7945813Table CP23: Cohesion and Fisheries policies (1)Irregularities reported during 2015-2025 and closedFraudulentNon-fraudulentMore than one type of sanction is possible for one irregularity(1) CF, ERDF, ESF, ESF+, EFF, EMFF, EMFAF, FIFG, GUID 
 
 
 
 
COHESION AND FISHERIES 

imprisonment  was  imposed  together  with,  respectively,  a  fine  or  exclusion  from  future 
subsidies.  In  16  fraudulent  irregularities,  fines  and  exclusion  from  future  subsidies  were 
combined.  For  non-fraudulent  irregularities  different  categories  of  sanctions  were 
basically never combined. 

For fraudulent irregularities, penal and administrative penalties were rarely combined. 
Table  CP25  below  explores  the  interplay  between  penal  sanctions  and  administrative 
sanctions. Most of the time, for the very few cases where administrative sanctions were added 
to the penal sanctions, it was (i) a combination of imprisonment with administrative exclusion 
from future subsidies or (ii) a combination of penal fines with administrative exclusion from 
future subsidies.  

4.6.  Other internal policies 

Other  funds  are  used  under  shared  management  to  finance  other  internal  policies.  Tables 
CP26  and  CP27  show  the  number  of  and  financial  amounts  involved  in  fraudulent  and 
non-fraudulent irregularities concerning AMIF, FEAD, EGF, JTF, ISF, BMVI and YEI.   

Most  of  the  fraudulent  irregularities  reported  during  the  years  2021-2025  concerned 
PP 2014-2020,  but  during  2025  the  first  irregularities  concerning  PP  2021-2027  have 
been  reported  (7  fraudulent  irregularities,  related  to  AMIF  and  JTF)  (see  Table  CP26 
above). During 2023, an outstanding number of YEI irregularities with small but interlinked 
financial  amounts  involved  were  reported  by  Czechia  as  fraudulent.  In  relation  to  FEAD, 
financial amounts  involved in  fraudulent irregularities before the year 2021 tend to  be high 

78 

Category of sanctionProp., non-prop., flat fineImprisonmentExclusion from future subsidiesLimitation access to public procurementLoss of subsidiesOtherProp., non-prop., flat fineImprisonment46Exclusion from future subsidies1619Limitation access to public procurement000Loss of subsidies7600Other10141402(1) CF, ERDF, ESF, ESF+, EFF, EMFF, EMFAF, FIFG, GUIDTable CP24 Cohesion and Fisheries policies (1)Fraudulent Irregularities reported during 2015-2025 and closedPenal SanctionsProp., non-prop., flat fineExclusion from future subsidiesLimitation access to public procurementLoss of subsidiesOtherProp., non-prop., flat fine27020Imprisonment47010Exclusion from future subsidies00000Limitation access to public procurement00000Loss of subsidies00000Other10010(1) CF, ERDF, ESF, ESF+, EFF, EMFF, EMFAF, FIFG, GUIDTable CP25: Cohesion and Fisheries policies (1) fraudulent Irregularities reported during 2015-2025 and closedInterplay penal - administrative penaltiesAdministrative SanctionsNEURNEURNEURNEURNEURNEURNEURAMIF142,455002120,14900198,0864326,0047544,239FEAD87,915,2250000315,8080000315,808ISF00000000173,52100173,521JTF00000000004040YEI5116,329001422,82200001422,822TOTAL EU27148,074,009002120,1491738,6302171,6078326,00429656,390Table CP26: Number of irregularities and financial amounts (EU-share) reported as fraudulent by the Member States -  AMIF, FEAD, EGF, JTF, ISF, BMVI and YEIFUNDREPORTING YEAR2016-2020202120222023202420252021-2025 
 
 
 
COHESION AND FISHERIES 

and  represented  nearly  98%  of  the  total  financial  amounts  involved  in  fraud  under  these 
internal  policies.  This  pattern  is  not  replicating  during  the  years  2021-2025,  when  the 
financial amounts involved in the FEAD fraudulent irregularities are small. During the years 
2021-2025, more than 80% of the financial amounts are involved in AMIF cases.  

The reporting of non-fraudulent irregularities related to PP 2021-2027 started in 2024 
and  accelerated  in  2025,  especially  for  JTF  (see  Table  CP27  above).  During  the  years 
2021-2025,  non-fraudulent  irregularities  related  to  FEAD  were  the  most  frequent  and 
accounted for most of the financial amounts involved in fraud. This is different from previous 
years, when the highest number of non-fraudulent irregularities concerned AMIF. AMIF still 
ranks second in terms of number of non-fraudulent irregularities during the years 2021-2025. 
During this period, the highest financial amounts are involved in non-fraudulent irregularities 
related to YEI, also because of an irregularity accounting for about EUR 8 million. 

79 

NEURNEURNEURNEURNEURNEURNEURAMIF743,312,6405114,25813357,375251,54918608,8738191,917461,323,972FEAD364,217,837261,927,324193,201,108147,553,8148711,56242,389,6557115,783,463EGF147,124000000000000JTF00000000267,12424836,03526903,159ISF8902,0128462,535288,3772100,2106402,62734,388,047215,441,796BMVI00000000139,728260,097399,825YEI267,368,87671,748,415119,8991814,833,16551,873,084111,895,4474220,370,010TOTAL EU2714515,848,489464,252,532353,666,7593622,538,738403,702,998529,761,19820943,922,225UK (1)362,0604181,2223175,285362,060(1) As of 1 February 2020, the UK is no longer part of the EU. The irregularites reported in this Table with reference to UK concern AMIF under PP 2014-2020. Table CP27: Number of irregularities and financial amounts (EU-share)  not reported as fraudulent by the Member States -  AMIF, FEAD, EGF, ISF and YEIFUNDREPORTING YEAR2016-2020202120222023202420252021-2025 
 
 
PRE-ACCESSION 

5.  NEIGHBOURHOOD POLICY  

5.1. 

Introduction 

This  section  presents  a  statistical  evaluation  of  irregularities  and  fraud  reported  by  the 
beneficiary  countries  during  2025  with  reference  to  the  pre-accession  policy,  the  cross-
border cooperation under the European Neighbourhood Instrument (CBC-ENI) and the 
Ukraine  Facility.67  It  places  these  detections  in  the  context  of  past  years  and  relevant 
multiannual financial frameworks. 

The  beneficiary  countries  must  report  fraudulent  and  non-fraudulent  irregularities  to  the 
Commission  through  the  Irregularity  Management  System  (IMS)68.  When  reference  is 
made to fraud or fraudulent, this includes both suspected and established fraud.69 Differently 
from the Common Agricultural Policy (CAP) and the Cohesion and Fisheries policies, there 
are no exceptions to reporting in IMS. Irregularities must always be reported in IMS, (i) also 
when  they  are  detected  and  corrected  before  the  expenditure  is  introduced  in  a  statement 
submitted to the Commission; (ii) also when the financial amounts are below EUR 10 000. In 
this section, when reference is made to the financial amounts involved in irregularities, it is 
always the EU-share of these financial amounts. 70 

5.1.1.  Instruments for Pre-accession Assistance  

As  from  2007,  the  EU  provides  pre-accession  assistance  through  the  Instrument  for  Pre-
accession  Assistance  (IPA).  IPA  aims  to  support  candidate  countries  and  potential 
candidates for EU membership in meeting the accession criteria and to bring their institutions 
and  standards  in  line  with  the  EU  acquis.  For  the  multiannual  financial  framework  period 
2014-2020, IPA II was allocated EUR 12.8 billion. For the following period 2021-2027, the 
IPA  III  budgetary  envelope  is  EUR  14.2  billion.  The  current  beneficiaries  are:  Albania, 
Bosnia  and  Herzegovina,  Kosovo71,  Montenegro,  North  Macedonia,  Serbia,  and  Türkiye. 
Assistance is also provided through multi-country/regional programmes.72 

67  Reporting  in  relation  to  the  Reform  and  Growth  Facility  and  the  Moldova  Facility  has  not  started  yet  (see 
below). 
68  Mandatory  reporting  covers  pre-accession  assistance,  CBC-ENI,  the  Reform  and  Growth  Facility,  the 
Moldova  Facility  and  the  Ukraine  Facility.  In  relation  to  pre-accession  assistance  and  CBC-ENI,  Bosnia 
Herzegovina and Kosovo are not using IMS. In relation to the three facilities, preparations for reporting have 
only been completed by Ukraine that is successfully using the system since September 2025. 
69 Suspected fraud means an irregularity that gives rise to the initiation of administrative or judicial proceedings 
at national level in order to establish the presence of intentional behaviour, in particular fraud, as referred to in 
Article 1(1)(a) of the Convention drawn up on the basis of Article K.3 of the Treaty on European Union, on the 
protection  of  the  European  Communities’  financial  interests.  Regardless  of  the  approach  adopted  by  each 
Member State, ratification of the 1995 Convention has equipped every country with a basis for prosecuting and 
possibly imposing penalties for specific conducts. Then the Directive (EU) 2017/1371 (so-called PIF Directive) 
defines  what  the  Member  States  are  requested  to  regard  as  fraud  affecting  the  EU’s  financial  interests.  If 
following a criminal proceeding a guilty verdict is issued and is not appealed against, the case can be considered 
established fraud (IRQ5 in IMS). If following an administrative proceeding, the deciding body establishes the 
intentionality of the irregular conduct, this can also be considered established fraud (IRQ4 in IMS).  
70 Data for this analysis have been download from IMS on 8/3/2026.   
71 This designation is without prejudice to positions on status, and is in line with UNSCR 1244/1999 and the ICJ 
Opinion on the Kosovo declaration of independence.  
72 https://ec.europa.eu/neighbourhood-enlargement/instruments/overview_en 

80 

 
 
PRE-ACCESSION 

IPA  II  (2014-2020)  built  on  the  results  achieved  under  IPA  I  (2007-2013)  and  set  a  new 
framework for providing pre-accession assistance. The primary innovation of IPA II was its 
strategic focus  on specific objectives.73  The IPA  II Regulation limits  financial assistance to 
five policy areas: (i) reforms in preparation for EU membership and related institution- and 
capacity-building; (ii) socio-economic and regional development; (iii) employment, social 
policies,  education,  promotion  of  gender  equality,  and  human  resources  development; 
(iv) agriculture and rural development; and (v) regional and territorial cooperation.74 

The general objective of the IPA III instrument (2021-2027) is to support the beneficiaries in 
adopting  and  implementing  the  political,  institutional,  legal,  administrative,  social  and 
economic  reforms  required  by  those  beneficiaries  to  comply  with  Union  values  and  to 
progressively  align  to  Union  rules,  standards,  policies  and  practices  with  a  view  to  Union 
membership.  The  IPA  III  Programming  Framework 75  represents  the  overarching  European 
Commission's strategic document for the use of EU funds assisting the IPA III beneficiaries. 
This  document  identifies  five  thematic  windows,  which  mirror  the  clusters  of  negotiating 
chapters as per the revised enlargement methodology:76 

•  Window 1: Rule of law, fundamental rights and democracy; 
•  Window  2:  Good  governance,  EU  acquis  alignment,  good  neighbourly  relations 

and strategic communication; 

•  Window 3: Green agenda and sustainable connectivity; 
•  Window 4: Competitiveness and inclusive growth; 
•  Window 5: Territorial and cross border cooperation. 

5.1.2.  Cross-border cooperation under European Neighbourhood Instrument 

For the multiannual financial framework period 2014-2020, the European Neighbourhood 
Instrument (ENI) was established through Regulation  232/2014  of 11 March 2021, with  a 
view  to  advancing  further  towards  an  area  of  shared  prosperity  and  good  neighbourliness 
involving the Union and a number of countries and territories.77 

Funding for cross-border cooperation under ENI (CBC-ENI) follows five main priorities: 
(i)  CBC-ENI-A:  to  promote  economic  and  social  development  in  regions  on  both  sides  of 
common  borders;  (ii)  CBC-ENI-B:  to  address  common  challenges  in  environment,  public 
health,  safety  and  security;  (iii)  CBC-ENI-C:  for  promotion  of  better  conditions  and 
modalities  for  ensuring  the  mobility  of  persons,  goods  and  capital;  CBC-ENI-D:  cross-
cutting areas; CBC-ENI-E: other. 

73 See Regulation (EU) 231/2014 of the European Parliament and of the Council of 11 March 2014 establishing 
an Instrument for Pre-accession Assistance (IPA II), OJ L 77, 15.3.2014, p. 11–26 and  
https://ec.europa.eu/neighbourhood-enlargement/instruments/overview_en.  
74 Article 3, paragraph 1, of Regulation (EU) No 231/2014 of the European Parliament and the Council of 11 
March 2014 establishing an Instrument for Pre-accession Assistance (IPA II) 
75  Commission  Implementing  decision  of  10/12/2021  adopting  the  Instrument  for  Pre-Accession  Assistance 
(IPA III) Programming Framework for the period 2021-2027. 
76 https://ec.europa.eu/neighbourhood-enlargement/instruments/overview_en   
77 See Inforegio - European Neighbourhood Instrument CBC programmes (ENI CBC) 2014-2020 

81 

 
 
PRE-ACCESSION 

5.1.3.  Ukraine facility 

The  Ukraine  Facility  provides  up  to  EUR 50  billion  in  grants  and  loans  for  the  period 
2024-2027  to  support  Ukraine's  efforts  to  sustain  macro-financial  stability,  promote  short-
term recovery as well as rebuild and modernise the country whilst implementing key reforms 
on  its  EU  accession  track.  It  supports  the  transition  towards  green,  digital  and  inclusive 
economy that is progressively aligned with EU rules and standards.78 

5.2. 

Pre-accession Assistance 

5.2.1.  General analysis 

Table NE1 below  (and  related graph) shows all fraudulent and non-fraudulent irregularities 
reported  by  the  beneficiary  countries  during  the  years  2021-2025  under  pre-accession 
programmes. These irregularities mostly occurred in connection with funds distributed under 
IPA I, IPA II and IPA III.79   

From  2021  to  2022,  while  the  number  of  fraudulent  irregularities  decreased,  the 
number of non-fraudulent irregularities experienced an exceptional increase. However, 
the average financial amounts involved in the latter dropped (see Table NE1). While the 
number  of  non-fraudulent  irregularities  increased  by  180%,  the  financial  amounts  involved 
increased  by  just  80%,  translating  in  a  significantly  lower  average  amount  in  2022  (about 
EUR 29 000)  than  in  2021  (about  EUR  46 000).  This  trend  continued  in  2023,  when  the 
average  amount  involved  in  non-fraudulent  irregularities  decreased  further  to  about 
EUR 26 000.  

In 2024, both fraudulent and non-fraudulent irregularities significantly increased. Also 
the  average  financial  amounts  involved  in  non-fraudulent  irregularities  increased  to  about 
EUR 68 000  in  2024.  The  average  financial  amounts  involved  in  fraudulent  irregularities 
were higher and increasing, from about EUR 55 000 in 2021 to about EUR 154 000 in 2024. 
The  peak  of  the  financial  amounts  in  2023  was  due  to  one  large  fraudulent  irregularity 
reported  by  Türkiye  in  relation  to  IPA  II  (socio-economic  and  regional  development). 
Without this large irregularity, the average financial amounts for 2023 would have been about 
EUR 154 000, similar to 2024.  

About  4%  of  the  irregularities  were  reported  as  fraudulent.  This  percentage  (the  fraud 
frequency level – FFL) changed over time, being higher in 2021 (15%), lower in 2022-2024 
(around 3-5%) and very low in 2025 (about 1%). 

78 Ukraine - Enlargement and Eastern Neighbourhood - European Commission 
79  Just  3  non-fraudulent  irregularities  (with  about  EUR  0.5  million  involved)  concerned  instead  pre-accession 
related  to  the  programming  period  2000-2006:  2  TIPAA  irregularities  and  1  PHARE  irregularity.  Türkiye 
received  assistance  under  the  specific  pre-accession-oriented  framework  of  the  Pre  accession  Financial 
Assistance  for  Türkiye  (TIPAA).  The  PHARE  programme  provided  support  for  institution-building  measures 
and  associated  investment,  as  well  as  funding  measures  to  promote  economic  and  social  cohesion  and  cross 
border cooperation. 

82 

 
 
 
 
 
 
 
PRE-ACCESSION 

As the irregularities reported during 2025 mostly refer to IPA II and IPA III, this is separately 
analysed in the following sections.80  

5.2.2.  Instrument for Pre-accession Assistance II (IPA II 2014-2020) 

5.2.2.1. Recent trends 

Table NE2 below  (and related graph) shows all fraudulent and non-fraudulent irregularities 
reported by the beneficiary countries during the years 2021-2025 under IPA II.  

The number of non-fraudulent irregularities increased markedly in 2022 and since then 
it  has  been  fluctuating  around  an  average  of  about  270  irregularities  per  year.  The 

80 In 2025, in relation to IPA I, the beneficiary countries reported just 3 irregularities (with about EUR 155 000 
involved)  concerning  IPARD  (1  fraudulent  irregularity)  and  TAIB  (2  non-fraudulent  irregularities).  TAIB 
concerns transition assistance and institution building. IPARD concerns rural development. 
For  an  exhaustive  analysis  of  irregularities  under  IPA  I,  see  ‘Statistical  Evaluation  of  irregularities  report  in 
2024’, SWD(2025)230 final, on 25/7/2025 

83 

NEURNEURNEUR202118984,4421004,562,5171185,546,9592022101,087,8052808,227,9922909,315,79720231019,345,9772456,260,37625525,606,3532024162,465,48132522,151,20234124,616,6832025415,5153189,227,2603229,242,775TOTAL5823,899,2201,26850,429,3471,32674,328,567Table NE1 - Pre-accession: reported irregularities, 2021-2025YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTAL 
 
 
 
 
 
 
 
PRE-ACCESSION 

average  financial  amounts  involved  in  the  non-fraudulent  irregularities  reported  during  the 
years 2021-2025 ranged between EUR 25 000 and EUR  29 000, with the exception of 2024 
when it peaked to about EUR 60 000.  

The reporting of fraud dropped in 2025. Just 2 fraudulent irregularities were reported, 
with  just  EUR 5 000  involved.  The  number  of  fraudulent  irregularities  ranged  between  9 
and 16, during 2021-2024. The total financial amounts fluctuated around EUR 1 million, with 
the exception of 2024. However, net of one large fraudulent irregularity reported by Türkiye 
in relation to IPA II also the financial amounts reported in 2024 were about EUR 0.8 million. 
This  translates  into  average  financial  amounts  ranging  from  EUR 92 000  to  EUR 109 000 
during 2022-2024 (excluding the aforementioned outlier). Fraud reporting in  2025 is  out  of 
this pattern.  

During the years 2021-2025, the FFL was 4%, but in 2025 it dropped below 1%. FFL was 
very high in 2021 (19%) and then it was around 4% during 2022-2024. In 2025, FFL was just 
0.7%.  

Table NE3 below shows that irregularities related to IPA II concerned all policy areas. The 
highest  number  of  cases  and  the  highest  financial  amounts  concerned  agriculture  and 
rural  development.  The  financial  amounts  involved  in  irregularities  related  to  this  policy 
area  increased  significantly  in  2024,  also  because  of  irregularities  related  to  an  OLAF 
investigation in Albania (see Box NE1 below). The same investigation is linked also to 7 of 

84 

NEURNEURNEUR202116900,791681,847,405842,748,1962022101,087,8052737,973,9912839,061,7972023918,745,3182416,017,14825024,762,4662024131,192,89529117,411,78530418,604,680202525,2602707,272,2322727,277,492TOTAL5021,932,0691,14340,522,5611,19362,454,631YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTALTable NE2 - Pre-accession: reported irregularities (IPA II), 2021-2025 
 
 
PRE-ACCESSION 

the  18  irregularities  (and  most  of  the  financial  amounts)  reported  in  2024,  for  which  the 
beneficiary countries did not specify the policy area (see ‘Not specified’ in Table NE3). 

Box NE1: Serious misuse of EU pre-accession agricultural funds 
OLAF investigated  serious  allegations  involving  the  misuse  of EU funds  from  IPA  II  for  rural  development 
(IPARD II) in Albania. One allegation was that applicants for these funds were obliged to pay a large percentage 
of their grant to ‘pre-selected’ consultancy companies, which would then facilitate contracts with the Albanian 
Agency for Rural Development and Agriculture (ARDA), which distributed the funds. 
After  a  series  of  complex  investigative  steps,  OLAF uncovered  several  serious  irregularities  during  the 
grant-awarding phase and the implementation of several projects. These irregularities included: 

•  Applicants being requested to pay a sizeable part of their grant to a local consultancy company; 

•  Contracts  being  awarded  without  competition,  or  through  a  rigged  competition  (with  fake  offers  being 

submitted); 

•  Inflated prices and breaches of contractual rules. 

See also ‘The OLAF report 2023’: 
https://ec.europa.eu/olaf-report/2023/investigative-activities/preventing-undue-expenditure_en.html#serious-misuse-of-eu-pre-accession-
agricultural-funds 

The  policy  areas  ‘Regional  and  territorial  cooperation’,  ‘Socio-economic  and  regional 
development’  and  ‘Institution-  and  capacity-building’  recorded  similar  reporting. 
However, the financial amounts involved in ‘Socio-economic and regional development’ 
were  lower  than  those  involved  in  the  other  areas.  The  number  of  irregularities  ranged 
from 76 to 87 and the average financial amounts involved from EUR 35 000 to EUR 50 000. 
The  financial  amounts  involved  in  ‘Socio-economic  and  regional  development’  were 
apparently  higher,  but  this  was  because  of  the  aforementioned  irregularity  reported  by 
Türkiye. Net of this outlier, the average financial amounts would be just EUR 9 000.   

Table  NE4  below  shows  that  irregularities  related  to  IPA  II  were  reported  by  9  countries. 
The  main  contributor  to  detection  was  Türkiye,  which  reported  about  58%  of 
irregularities,  followed  by  Albania  (17%)  and  North  Macedonia  (11%).  Most  of  the 
financial  amounts  were  involved  in  irregularities  reported  by  Türkiye,  also  because  of  the 
aforementioned  large  irregularity.  In  relation  to  non-EU  beneficiary  countries,  the  average 
financial amounts ranged from about EUR 31 000 in Montenegro81 to EUR 76 000 in Serbia. 

81  Net  of  the  aforementioned  large  irregularity,  the  average  financial  amount  for  Türkiye  would  be  lower,  at 
about EUR 22 000. 

85 

NEURNEURNEURNEURNEURNEUR202111377,97268,99800561,942,39111418,83500202230428,91225225,8921255,0002157,130,769121,021,22400202328880,1511018,044,15614175,8921634,548,109351,114,158002024312,23020211,97015679,48622314,797,653251,671,351181,231,990202541,514,66516135,52916483,6282174,677,9284159,58615306,156TOTAL763,213,9297718,626,545461,594,00687433,096,849874,385,155331,538,146Table NE3 - Pre-accession: reported irregularities (IPA II) by component, 2021-2025Not specifiedPolicy area (1)(1) For the full description of the policy areas, see Section 5.1.1.Regional and territorial cooperationYearInstitution anc capacity buildingSocio-economic and regional developmentHuman resources developmentAgriculture and rural development 
 
 
 
PRE-ACCESSION 

5.2.2.2. Trends since the start of IPA II, by beneficiary country and policy area 

Table NE5 below (and related graph) shows the number of irregularities and related financial 
amounts concerning IPA II since 2014, by beneficiary country and component. 

Since 2014, the same 9 beneficiary countries reported 1 338 irregularities related to 5 policy 
areas (see Table NE5 and related graph). The highest number of irregularities concerned 
agriculture and rural development, mostly reported by Türkiye (63%), North Macedonia 
(18%) and Albania (13%). Only two other countries, Montenegro and Serbia, reported cases 
related to agriculture and rural development.  

A  broader  range  of  countries  reported  irregularities  concerning  regional  and  territorial 
cooperation, the second most affected policy area.  Most of the cooperation irregularities 
were reported by Serbia and Bulgaria (75%).  

third  highest  number  of 

The 
capacity-building’ and reporting was mostly from Albania (66%). 

irregularities 

concerned 

‘Institution-  and 

The  fourth  highest  number  of  irregularities  concerned  ‘socio-economic  and  regional 
development’ and reporting was mostly from Türkiye (80%).  Türkiye reported also 81% of 
irregularities concerning 'Human resources development’. 

86 

NEURNEURNEURNEURNEURNEURNEURNEUR2021842,8116324,5481338,46814731,132411,532,472114,8630000163,902202258581,5895324,838822,732,297141,975,9251213,361,088386,0580000002023541,444,41111199,657357,702231,809,11714120,768,67315428,557242,810111,539002024647,250,84014312,475326,041,245231,483,5881653,292,507132,0035192,02000002025141,082,4689233,438290,016211,266,8432224,415,418004189,3080000TOTAL19810,402,119451,394,9561328,959,728957,266,60569033,370,15820561,48111424,138111,539163,902(1) The irregularities reported by the Member States mentioned in this table are related to IPA cross-border programmes and they may also be related to operations taking place in the cooperating non-Member StateTable NE4 - Pre-accession: reported irregularities (IPA II) by country, 2021-2025 (1)YearALBGGRITMEMKRORSTR 
 
 
 
 
 
 
 
 
 
PRE-ACCESSION 

5.2.3.  Instrument for Pre-accession Assistance III (IPA III 2021-2027) 

Table NE6 below  (and related graph) shows all fraudulent and non-fraudulent irregularities 
reported  by  the  beneficiary  countries  during  the  years  2021-2025  under  IPA III,  meaning 
since the start of the programming period.  

The  number  of  non-fraudulent  irregularities  accelerated  in  2025.  Reporting  started  in 
2023,  but  it  was  negligible  until  2024.  The  average  financial  amounts  involved  in  the  non-
fraudulent irregularities is about EUR 38 000. The reporting of fraud is still rare, with just 
3 cases communicated so far.  

87 

NEURNEURNEURNEURNEURNEURAL1257,524,81831,283,33355369,82400115,263181,267,849BG0027679,07500000000GR0010394,38900129,7500000IT00111,53900000000ME371,069,817516,88434,90029,1175345,22400MK1829,390,8530023,31281,0930000RO00163,90200000000RS263,769,401462,046,570101,226,809513,26033,52710233,279TR62513,962,16547,058132,325,1776618,573,324391,229,992537,017TOTAL99535,717,054974,502,750833,930,0228218,626,544481,594,006331,538,145Policy area (1)Table NE5 - Pre-accession:  irregularities reported under IPA II components since 2014(1) For the full description of the policy areas, see Section 5.1.1.Not specifiedAgriculture and rural developmentRegional and territorial cooperationInstitution anc capacity buildingSocio-economic and regional developmentHuman resources developmentNEURNEURNEUR2023001010202421,272,16315,73731,277,900202510461,810,186471,810,186TOTAL31,272,163481,815,924513,088,087Table NE6 - Pre-accession: reported irregularities (IPA III), 2021-2025YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTAL 
 
 
 
PRE-ACCESSION 

Four  beneficiary  countries  reported  51  irregularities  related  to  two  thematic  windows  (see 
Table  NE7  and  related  graph).  The  highest  number  of  irregularities  concerned 
competitiveness  and  inclusive  growth,  mostly  reported  by  Türkiye  (94%).  Just  one 
irregularity  was  reported  in  relation  to  the  green  agenda  and  sustainable  connectivity  by 
Montenegro. For the rest of the reported irregularities, the window was not specified. 

5.3.  Cross-border Cooperation under ENI 

Table NE8 below  (and related graph) shows all fraudulent and non-fraudulent irregularities 
reported by the beneficiary countries during the years 2021-2025 in relation to cross-border 
cooperation under ENI. 

After  nearly  no  reporting  during  2021-2022,  a  few  irregularities  started  being 
communicated from 2023. However, since 2024, the number of these irregularities has been 
decreasing.  The  FFL  is  24%,  but  this  is  based  on  few  irregularities.  All  irregularities  were 
related to the multiannual financial framework 2014-2020.82 

82 However, for one irregularity, a priority related to the financial framework 2021-2027 has been indicated. See 
also Table NE9  

88 

NEURNEURNEURME001000MK0000151,521,562RS21,272,1630000TR32288,6240015,737TOTAL341,560,78710161,527,299Thematic windowTable NE7 - Pre-accession:  irregularities reported under IPA III components since 2021Competitiveness and inclusive growthGreen agenda and sustainable connectivityNot specified 
 
 
 
PRE-ACCESSION 

Irregularities  concerning  CBC-ENI  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  (CBC-ENI-B). 
This  is  due  to  reporting  by  Romania  and  Poland.  The  other  priorities  were  affected  by  the 
same  lower  number  of  irregularities.  Expenditure  for  cross-cutting  areas  was  the  least 
affected, with just one irregularity reported by Romania.  

5.4.  Ukraine Facility 

In 2025, Ukraine got access to IMS and reported the first irregularities concerning the 
Ukraine  Facility,  most  of  them  as  suspected  fraud.  Ukraine  reported  24  irregularities  as 
fraudulent  (with  about  EUR 550 000  involved)  and  7  irregularities  as  not  fraudulent  (with 
about EUR 800 000 involved). 

More  than  75%  of  these  irregularities  concerned  the  provision  of  access  to  safe  and 
quality  education.  Most  of  the  time,  these  irregularities  about  education  concerned 
expenditure  for  quality  nutrition  or,  to  a  lesser  extent,  shelters  and  safe  conditions  in 
educational establishments. The remaining irregularities concerned investments in healthcare 
or the provision of housing for vulnerable groups of the population.  

Detection  always  followed  routine  controls.  The  method  for  the  detection  was  always  ex 
post control. 

Most  of  these  irregularities  concerned  false  or  falsified  documents.  Most  of  the  time, 
falsification  was  about  inaccurate  information  reported  in  certificates  of  completion  of  the 
works, which led to excessive payments or the overstatement of the cost of works. In some of 
these  cases,  it  is  also  specified  that  works  had  not  actually  been  performed.  In  one  case, 
falsification concerned the purchase of equipment that did not meet the requirements.  

89 

NEURNEURNEUR202100135,527135,52720220000002023313,2145622,1458635,3592024148,4906207,2717255,7622025123,7714389,6315413,402TOTAL585,475161,254,574211,340,050Table NE8 - Cross-border cooperation under European Neighbourhood Instrument (CBC-ENI), 2021-2025YearIrregularities reported as fraudulentIrregularities not reported as fraudulentTOTALNEURNEURNEURNEURNEUREE135,52700000000PL004180,8262100,836004524,647RO3152,046484,6592132,6931128,81700TOTAL4187,5738265,4854233,5291128,8174524,647(1) It includes 1 irregularity related to the programming period 2014-2020, but with priority CBC-ENI-B related to prpgramming period 2021-2027Table NE9 - CBC-ENI 2021-2025 - Irregularities by reporting beneficiary country and prioritypromote economic and social development in regions on both sides of common bordersCBC-ENI-Aaddress common challenges in environment, public health, safety and securityCBC-ENI-B (1)promotion of better conditions and modalities for ensuring the mobility of persons, goods and capitalCBC-ENI-C cross-cutting areasCBC-ENI-DOtherCBC-ENI-EPriority  
 
 
 
DIRECT MANAGEMENT 

6.  DIRECT MANAGEMENT 

6.1. 

Introduction 

This  section  contains  a  descriptive  analysis  of  the  data  on  recovery  orders  issued  by  the 
Commission in relation to expenditure managed in direct management mode, one of the three 
modes the Commission uses to implement the EU budget. 

Under  the  Financial  Regulation,  the  Commission  implements  the  budget  directly  (‘direct 
management’) as set out in Articles 125 to 156, through its departments, including its staff in 
EU  delegations  under  the  authority  of  their  respective  heads  of  delegation,  in  line  with 
Article 60(2), or through executive agencies as referred to in Article 6983. 

6.2.  General overview 

In  the  2025  financial  year,  a  total  of  EUR 89  103  million84  was  disbursed  under  direct 
management85. 
Table DM1 below presents the actual payments by budget heading86. Compared to previous 
years, the actual payments are lower. 

Table DM1 – Payments made in the 2025 financial year by budget heading 

Table DM2 below  presents  RRF grants  paid  per country in  202587. These grants accounted 
for  EUR 40 078 million88,  which  is  smaller  than  the  rest  of  direct  management  spending 
(EUR 49 025 million)89. 
Overall,  24  Member  States  received  RRF  grants90.  Italy  received  the  biggest  amount  (over 
EUR 7  638  million),  followed  by  Spain  and  Greece  with  EUR 7  129  million  and 

83 Regulation (EU, Euratom) 2024/2509 of the European Parliament and of  the Council of 23 September 2024 
on  the  financial  rules  applicable  to  the  general  budget  of  the  Union  (recast)  PE/99/2023/REV/1  OJ  L, 
2024/2509. 
84 Calculation based on SUMMA data extracted in March and reassessed in April 2026. 
85 This amount includes RRF grants. 
86 For the RRF, see Table DM2. 
87 Data provided by DG ECFIN at the end of March 2026. 
88 The total amount of EUR 40 078 million in grants, corresponds to the 2025 payments from two budget items: 
‘Recovery  and  Resilience  Facility  -  Non-repayable  support’  [06 02 01]  and  ‘Contribution  from  the  Brexit 
Adjustment Reserve’ [16 02 04]. 
89 As no single irregularity related to the RRF was reported until the end of 2025 in SUMMA and the presence 
of RRF payments in the analysis would significantly distort the percentages, RRF has been excluded from this 
analysis. 

90 

Million EUR%1. Single market, innovation and digital20 25241.32. Cohesion, resilience and values7 28914.93. Natural resources and environment355                  0.74. Migration and border management208                  0.45. Security and defence872                  1.86. Neighbourhood and the world11 16322.87. European public administration8 88718.1Total direct management (DM) excluding RRF49 025100.0Multiannual financial framework (MFF) headingPayments in 2025 
 
 
DIRECT MANAGEMENT 

EUR 3 455 million, respectively. Germany, Hungary and Lithuania did not receive any RRF 
grants. 

Table DM2 – RRF payments per Member State made in the 2025 financial year  

6.3.  General five-year analysis for 2021-2025 

In  the  2025  financial  year,  the  Commission  recorded  441  recovery  items91  in  the  SUMMA 
system92 that were qualified as irregularities, which amounted to EUR 86.34 million. Among 
these recovery items, 32 were reported as fraudulent, involving a total of EUR 5.52 million. 

The  following  analysis  gives  an  overview  of  recovery  data  recorded  by  the  Commission  in 
ABAC and SUMMA in the last five years. 

On  average,  between  2021  and  2025,  there  were  41  recovery  items  per  year  qualified  as 
fraudulent irregularities. The ratio of financial amounts involved in these irregularities to total 

90 Apart from grants, the RRF consists of loans, which in 2025 accounted for EUR 47 218 million. RRF loans 
are not part of direct management; therefore, they are not part of this analysis. 
91 Recovery items mean ‘recovery context’ elements in SUMMA. There can be more recovery context elements 
associated to one recovery order issued. As of 2023, they also include cancellations. 
92  SUMMA  is the  European  Commission's  new  corporate  financial  and  accounting  system,  launched  on 
January 1, 2025,  to  replace  the  outdated  ABAC  system.  It  is a  transversal,  transactional  information  system 
allowing for the execution and monitoring of all budgetary and accounting operations by the Commission, an 
agency or institution. 

91 

Million EUR%Austria2 1385.3Belgium1 4633.7Bulgaria1 9044.8Croatia1 0412.6Cyprus1900.5Czechia1 7514.4Denmark1280.3Estonia1220.3Finland6231.6France3 2628.1Germany00.0Greece3 4558.6Hungary00.0Ireland3560.9Italy7 63819.1Latvia2930.7Lithuania00.0Luxembourg580.1Malta490.1Netherlands1 1853.0Poland2 2165.5Portugal1 9164.8Romania6221.6Slovakia4921.2Slovenia4001.0Spain7 12917.8Sweden1 6464.1Total RRF grants40 078100.0CountryGrants paid out in 2025 
 
 
DIRECT MANAGEMENT 

expenditure  under  direct  management  in  2021-2025  was  very  low  (0.04%).  Figures  are 
presented in Table DM3 below. 

Table DM3 – Irregularities reported as fraudulent and related amounts, 2021-2025 financial years  

During  2021-2025,  there  were  a  total  of  3  816  recovery  items  registered  as  non-fraudulent 
irregularities  (on  average  763  items  per  year),  with  a  total  recovery  amount  of 
EUR 295.92 million.  The  ratio  of  these  aggregate  irregular  amounts  to  payments  in  2021-
2025  was  0.15%  and  remained  very  stable  in  the  last  five  years.  Figures  are  presented  in 
Table DM4 below. 

Table DM4 – Irregularities reported as non-fraudulent and related amounts, 2021-2025 financial years  

6.4. 

Specific analysis 

6.4.1.  Recoveries by budget headings 

Table DM5 below provides an overview of irregularities by budget heading in 2025.93 

In 2025, the highest number of recovery items qualified as non-fraudulent irregularities was 
recorded  in  the  ‘Single  market,  innovation  and  digital’  budget  heading  (269  items).  The 
highest irregular amounts registered (EUR 76.35 million) were also in this heading. 

In  the  same  year,  32  recovery  items  were  registered  as  fraudulent  irregularities.  The  two 
budget  headings  with  the  highest  number  of  reported  fraudulent  irregularities  were  ‘Single 
market,  innovation  and  digital’  and  ‘Neighbourhood  and  the  world’,  with  17  and  9  items, 
respectively. The total value of fraudulent irregularities was EUR 5.52 million, out of which 
58.5% (EUR 3.23 million) was related to the ‘Single market, innovation and digital’ budget 
heading.  

93  In  the  case  of  MFF  heading  ‘Cohesion,  resilience  and  values’,  the  reported  fraudulent  amount  is  slightly 
negative,  due  to  two  cancellations  recovery  orders  (RO  type  IC),  which  exceeded  the  other  recovery  orders 
issued in 2025. 

92 

Million EURNoMillion EUR%202121 711547.040.03202232 892375.670.02202342 340201.870.00202450 1726362.440.12202549 025325.520.01Total196 14020682.540.04YearPaymentsIrregularities  reported as fraudulentIrregular amounts/ paymentsMillion EURNoMillion EUR%202121 71182535.850.17202232 89273355.610.17202342 34087250.680.12202450 17297772.960.15202549 02540980.820.16Total196 1403 816295.920.15YearPaymentsIrregularities not reported as fraudulentIrregular amounts/ Payments 
 
 
 
 
DIRECT MANAGEMENT 

Table DM5 – Irregularities reported by budget heading and related amounts, 2025 

6.4.2.  Recoveries by legal entity residence 

Table DM6 below summarises the total recoveries made  in the past five years according to 
the country of residence of the legal entity, to which the payment was unduly made. 

During 2021-2025, 75.5% of non-fraudulent irregularities and 81.9% of the related recovery 
amounts  concerned  legal  entities  that  were  resident  in  the  EU-2794.  For  fraudulent 
irregularities,  this  percentage  is  slightly  higher  for  the  number  of  items  (77.7%)  and  much 
higher for the related recovery amounts (91%). 

Table DM6 – Recoveries per country of residence of the legal entity, 2021-2025 

94 The residence of the legal entity and the residence of the beneficiary are not necessarily the same. 

93 

Million EURMillion EURNoMillion EURNo1. Single market, innovation and digital20 25276.352693.23172. Cohesion, resilience and values7 2892.0370-0.0153. Natural resources and environment355               0.0000.0004. Migration and border management208               0.0230.0005. Security and defence872               0.0000.0006. Neighbourhood and the world11 1632.28622.3097. European public administration8 8870.1450.011Total DM excluding RRF49 02580.824095.5232Irregularities reported as fraudulentMFF headingPayments 2025Irregularities not reported as fraudulentNoMillion EURNoMillion EURAustria814.9110.15Belgium33111.00101.46Bulgaria373.2850.83Croatia243.5900.00Cyprus1368.2020.04Czechia210.2610.02Denmark1014.4740.10Estonia161.0930.16Finland536.7900.00France37317.65274.53Germany37017.8571.73Greece11014.9940.36Hungary300.381154.09Ireland653.0340.15Italy28422.27291.71Latvia141.0800.00Lithuania290.7400.00Luxembourg140.4010.11Malta120.0400.00Netherlands31817.96123.80Poland505.2331.82Portugal601.6200.00Romania321.2020.56Slovakia274.5520.05Slovenia140.0910.04Spain32625.76293.04Sweden763.9020.33Total EU 272881242.3516075.09United Kingdom36215.61161.09Total other countries57337.95306.37Grand total3816295.9120682.55Irregularities not reported as fraudulentIrregularities reported as fraudulentLE country 
 
  
 
COUNTRY FACTSHEETS 

Introduction 

For TOR, the factsheet shows the number of (and the estimated and established amounts involved in) 
fraudulent and not fraudulent irregularities reported in relation to 2025. The estimated and established 
amounts  are compared  with  the amount  of  gross  TOR  collected in relation  to  2025  (‘estimated  and 
established amounts’ / ‘gross TOR’). 

For  the  Common  Agricultural  Policy,  the  factsheet  shows  the  number  of  (and  the  EU-share  of  the 
financial amounts involved in) fraudulent and not fraudulent irregularities reported in relation to 2025 
and the past five years. Data is separately shown for support to agriculture (direct payments to farmers 
and  market  measures)  and  rural  development.  The  financial  amounts  (EU-share)  involved  are 
compared with the payments received, through the indicators FDR and IDR. 

For the Cohesion and Fisheries Policies, the factsheet shows the number of (and the EU-share of the 
financial amounts involved in) fraudulent and not fraudulent irregularities reported in relation to the 
programming  period  2014-2020  (in  relation  to  2025  and  cumulative  since  the  start  of  the 
programming  period)  and  the  programming  period  2021-2027.  The  financial  amounts  (EU-share) 
involved  in  irregularities  related  to  the  programming  period  2014-2020  and  those  related  to  the 
programming  period  2021-2027  are  compared  with  the  relevant  payments  received,  through  the 
indicators FDR and IDR. 

Finally,  the  factsheet  includes  data  and  indicators  on  the  follow-up  the  Member  States  give  to 
suspected fraud. For an explanation of these data and indicators, please make reference to the relevant 
sections in this Statistical Evaluation attached to the 2025 PIF Report. 

94 

 
 
 
Belgium - Belgique/België 

95 

OWNRES / gross TORNEURNEUR%Established and estimated2924,655,630367294,779,4858.63%FDRIDRNEURNEUR%%Support to agriculture (SA)0010322,6400.000.06Rural Development (RD)0011344,5910.000.29SA/RD006119,709TOTAL0027786,9400.000.12FDRIDRNEURNEUR%%Support to agriculture (SA)00401,339,8540.000.05Rural Development (RD)00581,314,2260.000.24SA/RD008156,950TOTAL001062,811,0300.000.08Period / FundFDRIDRNEURNEUR%%Year 202521,388,30271,228,350CF144,30200ERDF11,344,0005432,359ESF002795,991Cumulative from start of the programming period 183,010,5861147,695,4450.140.35CF144,30200ERDF72,645,873754,223,1530.250.40ESF10320,412393,472,2920.030.31Period / FundYears 2024-2025116,585000.010.00ERDF116,585000.020.001. Traditional Own ResourcesFundReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported as fraudulentIrregularities reported in 20252. Natural ResourcesIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities not reported as fraudulentIrregularities reported as fraudulentN.%N.%N.%BE00%1100%00%N.%N.%N.%BE00%00%6100%4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraudFor further explanations about these data, please see the PIF Report 2025(1) The irregularities that were reported and then cancelled are not included in this analysis4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud 
 
 
 
 
 
Bulgaria – България 

96 

OWNRES / gross TORNEURNEUR%Established and estimated232,500,070126,0811.30%FDRIDRNEURNEUR%%Support to agriculture (SA)0051,114,7360.000.13Rural Development (RD)41,220,578431,586,7050.320.42TOTAL41,220,578482,701,4410.100.22FDRIDRNEURNEUR%%Support to agriculture (SA)117,340275,679,9430.000.13Rural Development (RD)182,545,82840624,700,3510.161.55SA/RD00110,335TOTAL192,563,16843430,390,6290.040.52Period / FundFDRIDRNEURNEUR%%Year 20253238,894707,825,015CF0091,568,161ERDF127,377455,752,393ESF2211,51713352,002EMFF003152,459Cumulative from start of the programming period 281,579,810590133,843,9900.021.70CF007166,996,6950.003.06ERDF6377,41041059,501,0660.011.54ESF221,202,400664,097,0420.070.24EMFF00433,249,1880.004.47Period / FundYears 2024-2025006170,5590.000.01ERDF00225,9300.000.00ESF+004144,6290.000.03Irregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported 2021-2025Fund1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%BG2837%1621%3141%N.%N.%N.%BG650%217%433%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
Czech Republic - Česká republika 

97 

OWNRES / gross TORNEURNEUR%Established and estimated00593,994,8840.80%FDRIDRNEURNEUR%%Support to agriculture (SA)0017174,9920.000.02Rural Development (RD)71,410,58143892,4850.720.45TOTAL71,410,581601,067,4770.130.10FDRIDRNEURNEUR%%Support to agriculture (SA)337,547411,257,4640.000.03Rural Development (RD)192,054,0332116,148,7610.140.43TOTAL222,091,5802527,406,2260.040.13Period / FundFDRIDRNEURNEUR%%Year 20255338,677,86921437,953,816CF323,273,327444,149,706ERDF1912,852,31713022,795,781ESF262,044,9884011,008,329EMFF5507,23700Cumulative from start of the programming period 26487,761,7311,573200,308,0660.390.88CF323,273,32722955,186,6210.380.90ERDF10755,086,0871,047123,055,8080.430.96ESF1498,895,08027720,769,6590.240.57EMFF5507,237201,295,9781.634.17Period / FundYears 2024-20254296,073462,279,8800.010.05CF1201,31614941,6990.010.04ERDF0022830,1270.000.05ESF+394,75710508,0540.020.10Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported 2021-2025Fund1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%CZ38%3793%00%N.%N.%N.%CZ4227%8051%3422%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
Denmark – Danmark 

98 

OWNRES / gross TORNEURNEUR%Established and estimated256,64110915,412,6142.88%FDRIDRNEURNEUR%%Support to agriculture (SA)0020713,8430.000.09Rural Development (RD)15605,62521784,5340.310.40TOTAL15605,625411,498,3770.060.15FDRIDRNEURNEUR%%Support to agriculture (SA)00882,901,5870.000.07Rural Development (RD)694,837,823782,536,5150.690.36TOTAL694,837,8231665,438,1030.100.11Period / FundFDRIDRNEURNEUR%%Year 20250011593,772EMFF0011593,772Cumulative from start of the programming period 4245,655381,955,9740.030.23ERDF4245,6559407,4640.070.11ESF008615,0600.000.23EMFF0021933,4500.000.46Period / FundYears 2024-2025133,347000.030.00ERDF133,347000.100.00Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%DK427%533%640%N.%N.%N.%DK233%117%350%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
 
 
 
 
 
Germany – Deutschland 

99 

OWNRES / gross TORNEURNEUR%Established and estimated221,216,0311,612167,011,1862.86%FDRIDRNEURNEUR%%Support to agriculture (SA)228,997692,473,1740.000.05Rural Development (RD)6459,8321012,565,7060.030.14SA/RD2157,767118,722TOTAL10646,5961715,057,6010.010.08FDRIDRNEURNEUR%%Support to agriculture (SA)121,030,7752109,095,0090.000.04Rural Development (RD)16902,7532928,191,3780.010.10SA/RD2157,767118,722TOTAL302,091,29550317,305,1100.010.06Period / FundFDRIDRNEURNEUR%%Year 2025433,608,236928,898,213ERDF403,034,851687,610,635ESF3573,385241,287,578Cumulative from start of the programming period 12015,476,43772282,532,2310.070.40ERDF658,211,40651066,571,1630.070.54ESF557,265,03120214,284,9530.090.17EMFF00101,676,1150.000.76Period / FundYears 2024-202510792,1099408,2590.040.02ERDF5115,4973217,8030.010.02ESF+5676,6116190,4560.080.02Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-20254. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as Irregularities not reported N.%N.%N.%DE2061%824%515%N.%N.%N.%DE6335%3922%7743%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
 
 
Estonia – Eesti 

100 

OWNRES / gross TORNEURNEUR%Established and estimated152,748,1595384,0486.42%FDRIDRNEURNEUR%%Support to agriculture (SA)9195,603000.100.00Rural Development (RD)121,268,260312,610,2741.422.92TOTAL211,463,863312,610,2740.500.89FDRIDRNEURNEUR%%Support to agriculture (SA)39739,187114,3670.080.00Rural Development (RD)12112,815,008985,197,6632.471.00TOTAL16013,554,195995,212,0300.920.35Period / FundFDRIDRNEURNEUR%%Year 20251286,615291,886,540CF003196,055ERDF1286,615261,690,485Cumulative from start of the programming period 397,387,84358553,099,9210.191.40CF2616,10317223,080,4150.062.17ERDF256,203,18037726,898,1090.301.31ESF274,970292,852,5660.010.49EMFF10493,5897268,8310.490.27Period / FundYears 2024-202552,989,02719450,5300.520.08CF00389,2760.000.03ERDF52,989,02711246,8751.530.13ESF+005114,3800.000.12Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-20201. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-20254. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulentFundIrregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%EE13%1138%1759%N.%N.%N.%EE00%1045%1255%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
 
Ireland – Éire 

101 

OWNRES / gross TORNEURNEUR%Established and estimated00453,139,0530.50%FDRIDRNEURNEUR%%SA/RD129,83600TOTAL129,83600Period / FundFDRIDRNEURNEUR%%Year 20250023,578,275ESF0023,578,275Cumulative from start of the programming period 00666,931,0740.000.59ERDF0019549853.330.000.12ESF00476381220.940.001.15Period / FundYears 2024-2025004159,5360.000.11ESF+004159,5360.000.24Irregularities reported 2021-20253. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as Irregularities not reported as 1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulentFundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%IE13%39%3189%N.%N.%N.%IE0NA0NA0NAFor further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
Greece – Ελλάδα 

102 

OWNRES / gross TORNEURNEUR%Established and estimated262,918,8147543,9800.86%FDRIDRNEURNEUR%%Support to agriculture (SA)006223,9570.000.01Rural Development (RD)001763,240,1550.000.41TOTAL001823,464,1110.000.13FDRIDRNEURNEUR%%Support to agriculture (SA)82,714,8764457,640,7430.030.08Rural Development (RD)11,019,3791,21618,704,8370.030.48TOTAL93,734,2551,66126,345,5800.030.19Period / FundFDRIDRNEURNEUR%%Year 20253242,51520785,059,237CF00918,299,505ERDF3242,51514060,267,216ESF00586,492,516Cumulative from start of the programming period 127,119,171696346,868,5260.041.90CF36,117,7034143,723,6590.221.58ERDF8960,069441137,032,3130.011.25ESF141,400206165,544,8580.004.06EMFF008567,6960.000.15Period / FundYears 2024-20250051,946,9630.000.05ERDF0051,946,9630.000.101. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-20254. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%GR00%00%17100%N.%N.%N.%GR712%12%4986%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
Spain – España 

103 

OWNRES / gross TORNEURNEUR%Established and estimated6799,03648072,983,8692.54%FDRIDRNEURNEUR%%Support to agriculture (SA)4613,6131077,261,9550.010.13Rural Development (RD)19,80733568,156,9610.004.14TOTAL5623,42044275,418,9160.011.02FDRIDRNEURNEUR%%Support to agriculture (SA)171,129,0461,03239,356,5980.000.14Rural Development (RD)157,444,5651,371138,188,4440.112.00TOTAL328,573,6112,403177,545,0410.020.50Period / FundFDRIDRNEURNEUR%%Year 202581,923,627777179,652,472ERDF81,923,627766178,101,675ESF00111,550,796Cumulative from start of the programming period 112,024,3411,269295,788,3280.000.69ERDF112,024,3411,031241,461,6070.010.83ESF0019250,894,1520.000.40EMFF00463,432,5690.000.35Irregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020N.%N.%N.%ES3170%00%1330%N.%N.%N.%ES2518%00%11282%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
France 

104 

OWNRES / gross TORNEURNEUR%Established and estimated6225,443,26834460,224,9963.01%FDRIDRNEURNEUR%%Support to agriculture (SA)9512,973422,206,2300.010.03Rural Development (RD)0025812,392,1240.000.58SA/RD00132,232TOTAL9512,97330114,630,5860.010.15FDRIDRNEURNEUR%%Support to agriculture (SA)1724,514,31629820,300,9000.010.05Rural Development (RD)43640,67071424,949,5920.010.25SA/RD00132,232TOTAL2155,154,9851,01345,282,7240.010.10Period / FundFDRIDRNEURNEUR%%Year 20252750,582506,925,617ERDF1385,096416,706,872ESF1365,4866117,252EMFF003101,493Cumulative from start of the programming period 2511,936,01553264,014,6940.070.35ERDF2011,304,60237049,463,5490.100.45ESF4575,16313211,137,8330.010.17EMFF156,250303,413,3120.010.63Period / FundYears 2024-20251583,047000.020.00ERDF1583,047000.040.00Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-20254. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as Irregularities not reported FundIrregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%FR1422%1219%3859%N.%N.%N.%FR00%00%12100%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
Croatia – Hrvatska 

105 

OWNRES / gross TORNEURNEUR%Established and estimated6628,1159192,2750.88%FDRIDRNEURNEUR%%Support to agriculture (SA)0011407,3020.000.10Rural Development (RD)0018918,598,9480.005.63TOTAL0020019,006,2490.002.64FDRIDRNEURNEUR%%Support to agriculture (SA)41,380,979401,856,8860.070.10Rural Development (RD)113,190,44460443,219,9780.182.50TOTAL154,571,42464445,076,8640.131.23Period / FundFDRIDRNEURNEUR%%Year 20254657,624434,518,113ERDF2633719.68122979776.72ESF223904.72311538336.45Cumulative from start of the programming period 2017,177,52226752,486,5750.190.57CF210,470,966239,234,6250.490.43ERDF156,469,8958216,901,0340.130.35ESF3236,66113624,029,6910.011.23EMFF00262,321,2260.001.03Period / FundYears 2024-202500123,2650.000.00ESF+00123,2650.000.041. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%HR531%744%425%N.%N.%N.%HR00%250%250%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Italy – Italia 

106 

OWNRES / gross TORNEURNEUR%Established and estimated197,171,687684,854,6890.37%FDRIDRNEURNEUR%%Support to agriculture (SA)7881,4261117,186,9040.020.17Rural Development (RD)230,2811535,863,0770.000.26SA/RD1147,017242,578,152TOTAL101,058,72528815,628,1330.020.24FDRIDRNEURNEUR%%Support to agriculture (SA)615,480,72466344,072,4430.030.21Rural Development (RD)356,528,88156633,537,0950.070.38SA/RD201,603,61711713,699,314TOTAL11613,613,2221,34691,308,8520.050.31Period / FundFDRIDRNEURNEUR%%Year 20253352,29318822,598,699ERDF2270,00015919,587,551ESF00272,961,929EMFF182,293249,220Cumulative from start of the programming period 195,209,929828151,559,9540.010.33ERDF185,127,636666132,131,0380.020.48ESF0016019,379,6960.000.11EMFF182,293249,2200.020.01Period / FundYears 2024-2025004150,4170.000.00ERDF004150,4170.000.00Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%IT3815%104%20581%N.%N.%N.%IT1831%58%3661%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
Cyprus – Κύπρος 

107 

OWNRES / gross TORNEURNEUR%Established and estimated7188,6924483,5231.05%FDRIDRNEURNEUR%%Support to agriculture (SA)001298,4800.000.53TOTAL001298,4800.000.31FDRIDRNEURNEUR%%Support to agriculture (SA)001298,4800.000.11Rural Development (RD)3866,924000.650.00SA/RD13,10200TOTAL4870,0261298,4800.220.07Period / FundFDRIDRNEURNEUR%%Year 20250012,495,072CF0012,495,072Cumulative from start of the programming period 4414,860255,152,9410.050.58CF00104,150,3360.001.60ERDF4414,8606407,3080.110.11ESF006351,4390.000.16EMFF003243,8570.000.61Irregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentN.%N.%N.%CY00%00%6100%N.%N.%N.%CY00%120%480%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
 
 
 
 
Latvia – Latvija 

108 

OWNRES / gross TORNEURNEUR%Established and estimated00311,675,7242.51%FDRIDRNEURNEUR%%Support to agriculture (SA)006100,2180.000.03Rural Development (RD)275,23217313,9530.110.45TOTAL275,23223414,1710.020.10FDRIDRNEURNEUR%%Support to agriculture (SA)0014249,7860.000.02Rural Development (RD)233,637,489782,704,8950.630.47TOTAL233,637,489922,954,6810.170.13Period / FundFDRIDRNEURNEUR%%Year 2025156,3304250,888CF00193,184ERDF156,3303157,705Cumulative from start of the programming period 6826,756,51914830,000,5270.570.64CF51,654,048207,051,7640.130.57ERDF5323,902,42710121,359,4280.900.80ESF6545,16617822,6710.080.12EMFF4654,87910766,6640.470.55Period / FundYears 2024-2025365,177132,8740.010.00CF00132,8740.000.02ESF+365,177000.100.00Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-20253. Cohesion and Fisheries Policy - Programming period 2014-2020FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as Irregularities not reported Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%LV39%722%2269%N.%N.%N.%LV924%1334%1642%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Lithuania – Lietuva 

109 

OWNRES / gross TORNEURNEUR%Established and estimated182,470,84711516,2832.01%FDRIDRNEURNEUR%%Support to agriculture (SA)0014504,0470.000.08Rural Development (RD)15946,157602,267,3380.270.65TOTAL15946,157742,771,3860.100.29FDRIDRNEURNEUR%%Support to agriculture (SA)477,6281153,143,7260.000.11Rural Development (RD)824,249,55438511,316,4270.330.88TOTAL864,327,18250014,460,1530.100.35Period / FundFDRIDRNEURNEUR%%Year 2025002110,050,387CF001481,625ERDF00189,496,010ESF00158,478EMFF00114,274Cumulative from start of the programming period 154,355,02361665,501,4090.060.93CF0011014,865,2380.000.73ERDF53,784,50046848,347,0860.101.31ESF7471,904332,195,4710.040.18EMFF398,618593,6140.160.15Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%LT00%00%40100%N.%N.%N.%LT113%563%2225%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Luxembourg 

110 

OWNRES / gross TORNEURNEUR%Established and estimated00586,2970.48%FDRIDRNEURNEUR%%Rural Development (RD)00327,0260.000.06TOTAL00327,0260.000.04FDRIDRNEURNEUR%%Rural Development (RD)00579,7550.000.08TOTAL00579,7550.000.03Period / FundFDRIDRNEURNEUR%%Cumulative from start of the programming period 00114,2590.000.01ERDF00114,2590.000.022. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported in 20251. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%LU00%00%1100%N.%N.%N.%LU0NA0NA0NAFor further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Hungary - Magyarország 

111 

OWNRES / gross TORNEURNEUR%Established and estimated3394,768302,984,5760.94%FDRIDRNEURNEUR%%Support to agriculture (SA)1115,238151,716,3340.010.12Rural Development (RD)85,322,26029215,791,4881.654.89TOTAL95,437,49830717,507,8220.311.01FDRIDRNEURNEUR%%Support to agriculture (SA)2115,238544,782,3260.000.07Rural Development (RD)3912,349,2441,51656,319,4420.421.92TOTAL4112,464,482157061,101,7680.130.63Period / FundFDRIDRNEURNEUR%%Year 2025173,430,03118722,824,009CF00113,998ERDF152,464,79113118,813,729ESF188,381532,896,376EMFF1876,85921,099,906Cumulative from start of the programming period 21453,390,8661,236187,218,6080.240.84CF11,288,8084618,203,1220.020.30ERDF19849,650,854878130,011,9740.441.14ESF141,574,34529735,962,5230.030.72EMFF1876,859153,040,9892.578.92Period / FundYears 2024-20252128,36314814,876,0970.000.46CF001951,1910.000.44ERDF2128,36314512,666,3960.010.88ESF+0021,258,5090.000.081. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%HU3716%188%17476%N.%N.%N.%HU5138%54%7758%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
 
Malta 

112 

OWNRES / gross TORNEURNEUR%Established and estimated00000.00%FDRIDRNEURNEUR%%Rural Development (RD)00256,7350.000.13TOTAL00256,7350.000.11FDRIDRNEURNEUR%%Rural Development (RD)4354,101311,803,2500.331.69TOTAL4354,101311,803,2500.251.27Period / FundFDRIDRNEURNEUR%%Year 202500372,241ERDF00248,136ESF00124,105Cumulative from start of the programming period 2274,844303,089,5300.323.63CF1214,6952913,5180.100.45ERDF160,149171,462,5290.020.39ESF007616,7720.000.25EMFF00496,7100.000.43Period / FundYears 2024-202500123,2740.000.03CF00123,2740.000.21Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-20253. Cohesion and Fisheries Policy - Programming period 2014-2020FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as Irregularities not reported Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%MT00%00%1100%N.%N.%N.%MT00%00%2100%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Netherlands - Nederland 

113 

OWNRES / gross TORNEURNEUR%Established and estimated0035141,674,3150.92%FDRIDRNEURNEUR%%Support to agriculture (SA)83940,979349,5930.130.01Rural Development (RD)007339,3390.000.12TOTAL83940,97910388,9330.090.04FDRIDRNEURNEUR%%Support to agriculture (SA)971,428,55146922,3490.040.03Rural Development (RD)0014806,5880.000.09TOTAL971,428,551601,728,9380.030.04Period / FundFDRIDRNEURNEUR%%Year 2025005407,359ERDF005407,359Cumulative from start of the programming period 10855,113,2590.000.31CF00142,275ERDF00774,831,3930.000.62ESF104199,1640.000.03EMFF00340,4260.000.04Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-2025Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020FundIrregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%NL939%1461%00%N.%N.%N.%NL531%744%425%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Austria – Österreich 

114 

OWNRES / gross TORNEURNEUR%Established and estimated81,479,396519,196,8403.38%FDRIDRNEURNEUR%%Support to agriculture (SA)004147,4380.000.02Rural Development (RD)006483,6550.000.10TOTAL0010631,0930.000.05FDRIDRNEURNEUR%%Support to agriculture (SA)41,156,09710288,4880.030.01Rural Development (RD)1188,60514832,0200.010.03TOTAL51,344,701241,120,5080.020.02Period / FundFDRIDRNEURNEUR%%Year 202521,049,835151,454,681ERDF21,049,835141,413,462ESF00141,219Cumulative from start of the programming period 73,042,26714613,927,5260.241.11ERDF32,953,83512512,959,8410.431.87ESF488,43220885,7430.020.16EMFF00181,9430.001.18Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-2025Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020FundIrregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%AT150%00%150%N.%N.%N.%AT133%00%267%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Poland – Polska 

115 

OWNRES / gross TORNEURNEUR%Established and estimated1611,657,1021137,134,8181.04%FDRIDRNEURNEUR%%Support to agriculture (SA)9646,502282,883,4070.020.08Rural Development (RD)12601,02480018,294,7090.031.06SA/RD004288,851TOTAL211,247,52683221,466,9660.020.40FDRIDRNEURNEUR%%Support to agriculture (SA)457,110,787180119,027,5350.040.69Rural Development (RD)592,940,8492,28951,253,3090.040.70SA/RD296,6606497,963TOTAL10610,148,2962,475170,778,8060.040.69Period / FundFDRIDRNEURNEUR%%Year 2025103,644,33933196,270,921CF0025,579,304ERDF11,471,62620869,097,323ESF81,926,74211520,150,453EMFF1245,97261,443,841Cumulative from start of the programming period 17065,565,1394,089686,575,4500.080.87CF34,062,40218534,842,7240.020.15ERDF6742,715,1712,661536,176,8460.101.27ESF9617,831,7781,221112,845,6990.140.87EMFF4955,789222,710,1820.180.51Period / FundYears 2024-2025007211,811,9190.000.11ERDF004410,127,5440.000.14ESF+00281,684,3750.000.101. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%PL13334%5113%21053%N.%N.%N.%PL9731%6019%15950%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Portugal 

116 

OWNRES / gross TORNEURNEUR%Established and estimated2273,562000.07%FDRIDRNEURNEUR%%Support to agriculture (SA)3413,146651,905,2960.050.21Rural Development (RD)2750,18824411,133,9020.243.57TOTAL51,163,33430913,039,1990.101.07FDRIDRNEURNEUR%%Support to agriculture (SA)7667,6231926,948,6700.020.16Rural Development (RD)81,297,3821,16638,822,3070.051.54TOTAL151,965,0041,35845,770,9770.030.66Period / FundFDRIDRNEURNEUR%%Year 20252711,064,9441049,013,059CF00223,582,960ERDF2110,715,102453,624,518ESF6349,842271,301,216EMFF0010504,366Cumulative from start of the programming period 101100,389,01248847,555,4730.430.20CF1192,549445,929,6830.010.21ERDF5389,670,55624128,228,6840.710.22ESF4410,035,3331247,493,5580.130.10EMFF3490,574795,903,5480.121.50Period / FundYears 2024-202527,535,680148,0690.270.00ERDF27,535,680000.720.00ESF+00148,0690.000.00FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025N.%N.%N.%PT13%621%2276%N.%N.%N.%PT00%00%49100%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
Romania – România 

117 

OWNRES / gross TORNEURNEUR%Established and estimated11360,667615,907,1031.27%FDRIDRNEURNEUR%%Support to agriculture (SA)482,308,272522,917,8630.120.15Rural Development (RD)262,084,87845536,328,3350.183.16TOTAL744,393,15050739,246,1980.141.26FDRIDRNEURNEUR%%Support to agriculture (SA)33813,470,42126421,917,4470.140.22Rural Development (RD)23015,486,8751,884141,756,5100.272.51SA/RD137,96700TOTAL56928,995,2622148163,673,9570.191.06Period / FundFDRIDRNEURNEUR%%Year 20258045,289,01128374,194,237CF301911,852,907ERDF3736,853,83316452,349,743ESF276,649,048809,131,737EMFF131,786,13120859,850Cumulative from start of the programming period 292341,579,3631,541481,857,9141.432.01CF28167,804,558169169,985,9272.572.60ERDF167154,817,074745262,996,3401.252.13ESF7315,576,73455440,632,0320.320.83EMFF243,380,997738,243,6162.536.17Period / FundYears 2024-20252412,507,042327,036,6120.190.11ERDF2312,452,270266,793,1110.310.17ESF+154,7726243,5000.010.02Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-20201. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural Resources4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%RO214%17535%30060%N.%N.%N.%RO7337%84%11859%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Slovenia – Slovenija 

118 

OWNRES / gross TORNEURNEUR%Established and estimated120,779251,242,3930.46%FDRIDRNEURNEUR%%Rural Development (RD)282,59911265,7540.060.20TOTAL282,59911265,7540.030.10FDRIDRNEURNEUR%%Support to agriculture (SA)008168,0260.000.02Rural Development (RD)395,94943944,5570.010.13TOTAL395,949511,112,5830.010.08Period / FundFDRIDRNEURNEUR%%Year 2025128,6714659,588ERDF004659,588ESF128,67100Cumulative from start of the programming period 224,202,859749,727,9730.130.29CF6756,73171,954,8070.080.21ERDF102,712,553486,521,5390.160.39ESF6733,576191,251,6270.100.17Period / FundYears 2024-202500119,8720.000.01ERDF00119,8720.000.011. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%SI00%218%982%N.%N.%N.%SI741%212%847%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Slovakia – Slovensko 

119 

OWNRES / gross TORNEURNEUR%Established and estimated00191,204,2380.66%FDRIDRNEURNEUR%%Support to agriculture (SA)005381,9220.000.09Rural Development (RD)00282,524,4100.000.50SA/RD311,41411312,982TOTAL311,414443,219,3140.000.35FDRIDRNEURNEUR%%Support to agriculture (SA)117,72831936,2720.000.05Rural Development (RD)214,590,40523624,875,4550.392.12SA/RD9129,5652155,791,985TOTAL314,737,69848231,603,7120.150.98Period / FundFDRIDRNEURNEUR%%Year 20252031,525,5796659,056,812CF422,865,671136,627,518ERDF88,647,3465052,363,618ESF812,561365,676Cumulative from start of the programming period 75110,076,000722524,235,9420.783.72CF1433,660,122136237,046,5560.845.94ERDF4771,099,277474254,564,2240.993.56ESF145,316,60110531,483,6970.181.07EMFF0071,141,4650.0023.05Period / FundYears 2024-2025192,185157,658,9090.010.50CF0022,123,0850.000.82ERDF192,18595,211,5980.010.71ESF+004324,2250.000.06Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesFundIrregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-20254. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%SK412%26%2882%N.%N.%N.%SK1915%3325%7860%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Finland – Suomi-Finland 

120 

OWNRES / gross TORNEURNEUR%Established and estimated2163,234585,586,0253.03%FDRIDRNEURNEUR%%Support to agriculture (SA)007115,3160.000.02Rural Development (RD)0017604,7010.000.21TOTAL0024720,0170.000.09FDRIDRNEURNEUR%%Support to agriculture (SA)10381,027,3770.000.04Rural Development (RD)133,624823,306,9660.000.20SA/RD327,458357,778TOTAL561,0821234,392,1200.000.10Period / FundFDRIDRNEURNEUR%%Year 20251132,8882190,380ERDF002190379.85EMFF1132887.6400Cumulative from start of the programming period 1132,888693,449,6250.010.22ERDF00452,794,9140.000.31ESF0016344,6850.000.06EMFF1132,8888310,0260.180.42Period / FundYears 2024-2025246,112112,4760.020.00ERDF246,112000.030.00EMFAF00112,4760.000.09Irregularities reported as Irregularities not reported 3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural Resources4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as Irregularities not reported Irregularities reported in 2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%FI0NA0NA0NAN.%N.%N.%FI125%00%375%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
Sweden – Sverige 

121 

OWNRES / gross TORNEURNEUR%Established and estimated7221,23824038,095,4804.54%FDRIDRNEURNEUR%%Support to agriculture (SA)00586,9380.000.01Rural Development (RD)0024684,0010.000.31TOTAL0029770,9400.000.08FDRIDRNEURNEUR%%Support to agriculture (SA)118,71113227,3080.000.01Rural Development (RD)21,000,868681,990,7910.080.15SA/RD00122,203TOTAL31,019,579822,240,3030.020.05Period / FundFDRIDRNEURNEUR%%Year 2025159,399292,141,715ERDF003171257.34EMFF159398.73261970458.12Cumulative from start of the programming period 111,334,4151207,144,8070.070.36ERDF121,659411,499,0390.000.15ESF4437,134321,321,3150.050.15EMFF6875,622474,324,4520.894.41Period / FundYears 2024-202500485,2440.000.02ERDF00360,8850.000.03ESF+00124,3600.000.10Irregularities not reported as fraudulentIrregularities reported as fraudulent1. Traditional Own ResourcesReporting Year 2025Irregularities reported as fraudulentIrregularities not reported as fraudulentIrregularities reported 2021-2025FundIrregularities reported as fraudulentIrregularities not reported as fraudulent2. Natural ResourcesIrregularities reported in 2025Fund4. Cohesion and Fisheries Policy - Programming period 2021-2027Irregularities reported as fraudulentIrregularities not reported as fraudulent3. Cohesion and Fisheries Policy - Programming period 2014-2020Irregularities reported as fraudulentIrregularities not reported as fraudulentN.%N.%N.%SE00%00%2100%N.%N.%N.%SE120%00%480%For further explanations about these data, please see the PIF Report 20254: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Common Agricultural Policy)(1)DismissalEstablished fraudPending suspected fraud4: Follow-up to suspected fraud - Irregularities initially reported during 2014-2018 (Cohesion and Fisheries Policy) (1)DismissalEstablished fraudPending suspected fraud(1) The irregularities that were reported and then cancelled are not included in this analysis 
 
 
 
 
 
 
ANNEXES 

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Annex 1 

123 

NEURNEURNEURNEURNEURBE595                     115,330,849      557                     457,419,558      440                     45,630,886        310                     50,540,283        396                     319,435,115      BG29                        2,491,371          12                        1,852,452          20                        1,340,759          19                        4,534,492          24                        2,526,151          CZ65                        3,097,226          84                        7,459,102          103                     6,645,648          91                        6,783,752          59                        3,994,884          DK102                     4,358,591          100                     3,839,145          157                     6,550,509          97                        5,706,031          111                     15,469,255        DE1,573                  84,677,562        1,939                  139,966,248      2,371                  207,947,750      2,518                  144,614,053      1,634                  168,227,217      EE9                          1,053,524          4                          314,252              9                          279,506              8                          3,167,555          20                        3,132,207          IE27                        1,446,990          22                        2,265,975          59                        8,016,806          100                     12,627,322        45                        3,139,053          EL37                        12,717,668        55                        9,536,676          48                        7,562,643          32                        17,129,530        33                        3,462,794          ES491                     55,574,434        532                     33,626,312        485                     52,967,312        423                     70,767,692        486                     73,782,905        FR363                     59,505,089        398                     32,447,273        494                     44,359,650        390                     46,487,268        406                     85,668,264        HR8                          944,363              24                        3,860,549          16                        1,214,961          17                        946,332              15                        820,390              IT101                     18,799,837        111                     22,290,728        169                     27,672,512        153                     19,912,638        87                        12,026,376        CY1                          13,590                5                          160,662              6                          251,416              10                        306,369              11                        672,214              LV44                        3,858,643          39                        3,811,000          17                        885,274              25                        1,191,601          31                        1,675,724          LT68                        5,157,425          56                        3,730,125          60                        7,050,814          39                        1,888,618          29                        2,987,130          LU1                          43,171                3                          182,475              5                          86,297                HU31                        2,064,718          25                        2,546,011          28                        1,950,834          37                        3,011,636          33                        3,379,343          MT4                          483,018              2                          44,438                2                          110,246              3                          95,379                NL493                     167,970,423      601                     70,775,846        400                     18,702,477        541                     86,192,069        351                     41,674,315        AT61                        6,642,690          76                        3,570,430          72                        4,307,732          61                        4,534,436          59                        10,676,236        PL135                     9,915,891          152                     14,980,863        159                     13,134,859        138                     19,831,755        129                     18,791,920        PT24                        2,900,653          41                        3,362,891          46                        1,554,415          10                        6,162,980          2                          273,562              RO42                        2,202,079          41                        3,696,390          63                        8,218,206          46                        3,841,806          72                        6,267,770          SI13                        1,135,392          18                        465,159              29                        1,383,263          29                        3,365,977          26                        1,263,172          SK8                          884,116              6                          435,742              14                        253,423              18                        848,792              19                        1,204,238          FI50                        12,720,222        37                        3,360,331          69                        6,568,452          81                        7,678,249          60                        5,749,259          SE194                     10,130,873        246                     11,262,784        283                     13,463,972        248                     22,110,591        247                     38,316,718        EU-274,569586,120,4105,183837,080,9425,619488,024,3265,447544,459,6814,390824,702,507UK42648,116,86134040,011,4009310,075,383487,018Total4,995634,237,2715,523877,092,3435,712498,099,7085,451544,546,7004,390824,702,507* Cut-off date 02/03/2026** Amounts are roundedTOR: Total number of fraudulent and non-fraudulent cases with the related estimated and established amount (2021 - 2025)                                                                      MS20212022202320242025 
 
 Annex 2 

124 

NEURNEURNEURNEURNEURBE187100,539,07512355,264,806489,022,930          3730,265,5412924,655,630BG282,491,371101,753,87716927,124              184,229,401232,500,070CZ116,615DK6349,7293113,6523219,952256,641DE604,265,030514,626,392242,648,162          31816,460,678221,216,031EE81,033,8103267,8059279,506              83,167,555152,748,159IE1100,366EL1310,706,085458,677,543467,522,484          2616,622,555262,918,814ES3718,932,592242,820,562357,277,089          221,974,3776799,036FR8628,226,3428611,751,645793,669,109          737,076,1266225,443,268HR228,514113,521,0166557,220              3145,8366628,115IT1713,221,370316,633,5645716,691,373        4910,120,120197,171,687CY113,5902112,6024225,747              6202,1207188,692LV91,043,536398,255228,604                LT463,837,216332,812,294306,351,805          191,505,074182,470,847LUHU1158,6144198,637126,313                2155,0393394,768MTNL514,406,9432295,846AT44,203,383459,7195215,150              118,40381,479,396PL271,547,786444,518,363272,680,822          149,931,4501611,657,102PT41,003,662152,148,4612357,509              53,644,3222273,562RO10591,26252,017,9067124,551              5114,33511360,667SI1565,8214694,523              173,204120,779SK337,131136,241312,442                2184,378FI119,828186,1874101,359              33,277,9862163,234SE1105,1257221,238EU-27558207,339,669501107,815,37340959,413,823616109,493,57728585,367,735UK24,450,974Total560211,790,643501107,815,37340959,413,823616109,493,57728585,367,735* Cut-off date 02/03/2026** Amounts are roundedTOR: Total number of fraudulent cases with the related estimated and established amount (2021 - 2025)                                              MS20212022202320242025 
 
 
Annex 3 

125 

NEURNEURNEURNEURNEURBE40814,791,774434402,154,75239236,607,95627320,274,742367294,779,485BG10298,5754413,6351305,091126,081CZ643,080,611847,459,1021036,645,648916,783,752593,994,884DK964,008,863973,725,4921576,550,509945,486,07810915,412,614DE1,51380,412,5321,888135,339,8562,347205,299,5882,200128,153,3751,612167,011,186EE119,714146,4475384,048IE261,346,624222,265,975598,016,80610012,627,322453,139,053EL242,011,58310859,134240,1596506,9757543,980ES45436,641,84250830,805,75045045,690,22340168,793,31548072,983,869FR27731,278,74731220,695,62841540,690,54131739,411,14234460,224,996HR6915,85013339,53310657,74114800,4969192,275IT845,578,4688015,657,16411210,981,1391049,792,518684,854,689CY348,060225,6684104,2494483,523LV352,815,108363,712,74515856,669251,191,601311,675,724LT221,320,20923917,83130699,00920383,54411516,283LU143,1713182,475586,297HU301,906,104212,347,374271,924,521352,856,597302,984,576MT4483,018244,4382110,246395,379NL488153,563,48059970,480,00040018,702,47754186,192,06935141,674,315AT572,439,307723,510,711674,092,582604,516,033519,196,840PL1088,368,10510810,462,49913210,454,0371249,900,3051137,134,818PT201,896,991261,214,430441,196,90552,518,657RO321,610,817361,678,485568,093,655413,727,471615,907,103SI12569,57118465,15925688,740283,292,773251,242,393SK5846,9855399,50111240,98216664,414191,204,238FI4912,700,394363,274,143656,467,093784,400,263585,586,025SE19410,130,87324611,262,78428313,463,97224722,005,46624038,095,480EU-274,011378,780,7424,682729,265,5695,210428,610,5034,831434,966,1044,105739,334,773UK42443,665,88734040,011,4009310,075,383487,018Total4,435422,446,6295,022769,276,9705,303438,685,8854,835435,053,1234,105739,334,773* Cut-off date 02/03/2026** Amounts are roundedTOR: Total number of non-fraudulent cases with the related estimated and established amount (2021 - 2025)                                                MS20212022202320242025 
 
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126 

OWNRES established and estimated amountOWNRES established and estimated amount as a % in amount gross TOR collectedOWNRES established and estimated amountOWNRES established and estimated amount as a % in amount gross TOR collectedOWNRES established and estimated amountOWNRES established and estimated amount as a % in amount gross TOR collectedEUR%EUR%EUR%BE319,435,115                         8.63%24,655,6300.67%294,779,4857.97%BG2,526,151                              1.30%2,500,0701.28%26,0810.01%CZ3,994,884                              0.80%0.00%3,994,8840.80%DK15,469,255                           2.88%56,6410.01%15,412,6142.87%DE168,227,217                         2.86%1,216,0310.02%167,011,1862.84%EE3,132,207                              6.42%2,748,1595.64%384,0480.79%IE3,139,053                              0.50%0.00%3,139,0530.50%EL3,462,794                              0.86%2,918,8140.73%543,9800.14%ES73,782,905                           2.54%799,0360.03%72,983,8692.52%FR85,668,264                           3.01%25,443,2680.90%60,224,9962.12%HR820,390                                 0.88%628,1150.67%192,2750.21%IT12,026,376                           0.37%7,171,6870.22%4,854,6890.15%CY672,214                                 1.05%188,6920.29%483,5230.76%LV1,675,724                              2.51%0.00%1,675,7242.51%LT2,987,130                              2.01%2,470,8471.66%516,2830.35%LU86,297                                   0.48%0.00%86,2970.48%HU3,379,343                              0.94%394,7680.11%2,984,5760.83%MT0.00%0.00%0.00%NL41,674,315                           0.92%0.00%41,674,3150.92%AT10,676,236                           3.38%1,479,3960.47%9,196,8402.91%PL18,791,920                           1.04%11,657,1020.64%7,134,8180.39%PT273,562                                 0.07%273,5620.07%0.00%RO6,267,770                              1.27%360,6670.07%5,907,1031.20%SI1,263,172                              0.46%20,7790.01%1,242,3930.45%SK1,204,238                              0.66%0.00%1,204,2380.66%FI5,749,259                              3.03%163,2340.09%5,586,0252.95%SE38,316,718                           4.54%221,2380.03%38,095,4804.52%EU-27824,702,5072.68%85,367,7350.28%739,334,7732.41%UKTotal824,702,5072.68%85,367,7350.28%739,334,7732.41%* Cut-off date 02/03/2026** Amounts are rounded    TOR: Percentage of the financial impact of OWNRES cases to the collected and made available TOR (gross) in 2025 per Member StateMSAllFraudulentNon-fraudulent 
 
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Established amountRecovered amountRREstablished amountRecovered amountRREUREUR%EUREUR%BE18,081,81315,717,64687%316,398,851291,283,24192%BG4,305,098803,62619%2,277,668758,03633%CZ6,783,7526,699,74299%3,994,8843,920,09698%DK5,706,0315,366,19294%15,469,25515,130,32098%DE144,570,935134,431,35793%168,227,217100,399,98560%EE384,048384,048100%IE12,627,3226,654,44953%3,139,0532,997,41095%EL12,938,685673,4865%1,053,873247,74924%ES70,086,51163,299,42690%73,782,90559,353,95180%FR45,528,96040,092,22388%84,813,41247,078,06056%HR800,496789,71699%219,472192,27588%IT19,781,8445,355,34427%8,712,9363,039,63635%CY306,369163,48753%672,214543,75481%LV1,191,6011,191,601100%1,675,7241,675,724100%LT637,560351,24755%544,387522,10896%LU182,475182,475100%86,29786,297100%HU3,011,6361,408,34647%3,379,343797,12424%MT95,37995,379100%NL86,016,46056,021,25565%41,521,57327,161,40965%AT4,534,4364,506,96499%10,676,23610,140,32595%PL17,565,68616,071,94491%14,667,2637,809,30053%PT6,162,9802,694,83744%273,562273,562100%RO3,841,8063,639,44395%6,267,7705,070,13081%SI3,292,7733,292,773100%1,263,1721,014,58380%SK848,792664,41478%1,204,238708,97759%FI7,678,2494,560,57559%5,749,2595,469,50395%SE22,005,46621,048,87796%38,122,13636,448,76996%EU-27498,583,114395,776,82879%804,576,747622,506,37277%UK87,01887,018100%Total498,670,133395,863,84779%804,576,747622,506,37277%* Cut-off date 02/03/2026** Amounts are roundedTOR: Recovery rates (RR) per cut-off date MS20242025 
 
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Release for free circulationTransitCustoms warehousingInward processingOtherRelease for free circulationTransitCustoms warehousingInward processingOtherBE24,622,00920,05213,570                282,151,9261,103,649          11,410,081113,829BG2,185,994314,07626,081CZ3,994,884DK44,40912,23215,243,93510,808                36,86131,95389,057DE1,216,031159,805,485611,115              1,325,8905,130,803137,893EE2,748,159          384,048IE2,652,772354,300131,981EL499,44639,905663,6851,715,778          543,980ES799,03660,908,39335,942                24,95812,014,576FR24,012,20244,8931,386,173          51,995,8093,338,386          55,7871,637,9053,197,109HR45,710181,797400,608192,275IT5,341,4471,830,240          4,399,05716,672438,960CY188,692483,523LV1,655,88419,839LT28,104760,3951,682,348          473,20822,279                20,796LU86,297HU394,7682,865,741118,834MTNL31,316,6522,703,361          943,5416,633,54977,212AT1,479,3969,118,77814,819                63,243PL11,465,79383,426107,8837,099,83834,979PT273,562RO336,72123,9465,891,88215,221SI20,7791,242,393SK1,193,22111,017FI163,2345,397,146172,66416,215SE221,23823,849,29169,315                10,65811,340,8802,825,337EU-2773,338,568700,2761,932,57220,0529,376,268672,972,4997,909,67413,828,57337,506,9547,117,073UKTotal73,338,568700,2761,932,57220,0529,376,268672,972,4997,909,67413,828,57337,506,9547,117,073* Cut-off date 02/03/2026** Amounts are roundedTOR: Estimated and established amount per customs procedure per Member State (2025)MSFraudulentNon-fraudulent 
 
 
Annex 7 

129 

Release for free circulationTransitCustoms warehousingInward processingOtherRelease for free circulationTransitCustoms warehousingInward processingOtherBE271129452138                          BG1671CZ59DK111031212                          DE221,5283019323                          EE155IE3942                          EL141297ES64263150FR4321728242479                          HR2319IT1816512                          CY74LV301LT2313911LU5HU3291MTNL17811921294                          AT84812                          PL11321112PT2RO101601                          SI125SK181                          FI25521                          SE722041141                          EU-272021881563,6102536214436UKTotal2021881563,6102536214436* Cut-off date 02/03/2026TOR: Customs procedure by number of cases per Member State (2025)MSFraudulentNon-fraudulent 
 
 
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AllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherAllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherBE396291151213671911259438BG242368911CZ595914414DK111211109801829DE1,634222108111,612117105897926188EE2015141541IE4545282663EL3326171627511ES4866122148011715215156337FR4066231141613441768172141HR1564119522IT87192896816291751CY11715144LV313111191LT29181171111LU555HU3333301254MT0NL351351144146160AT5982651434175PL129164471113510116PT222RO721138614561SI2611254174SK191921511FI60225811416SE24776124081159EU-274,390285103651052194,1059622,096187261443156UKTotal4,390285103651052194,1059622,096187261443156* Cut-off date 02/03/2026TOR: Method of detection by number of cases per Member State (2025)MSNFraudulentNon-fraudulent 
 
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131 

AllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherAllRelease controlsPost-release controlsInspections by anti-fraud servicesTax auditVoluntary admissionOtherBE396291151213671911259438BG242368911CZ595914414DK111211109801829DE1,634222108111,612117105897926188EE2015141541IE4545282663EL3326171627511ES4866122148011715215156337FR4066231141613441768172141HR1564119522IT87192896816291751CY11715144LV313111191LT29181171111LU555HU3333301254MT0NL351351144146160AT5982651434175PL129164471113510116PT222RO721138614561SI2611254174SK191921511FI60225811416SE24776124081159EU-274,390285103651052194,1059622,096187261443156UKTotal4,390285103651052194,1059622,096187261443156* Cut-off date 02/03/2026TOR: Method of detection by number of cases per Member State (2025)MSNFraudulentNon-fraudulent 
 
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Established amount, EURRecovered amount, EURRR, %Established amount, EURRecovered amount, EURRR, %BE22,578,2237,126,30732%293,820,628284,156,93497%BG2,251,587758,03634%26,08100%CZ3,994,8843,920,09698%DK56,64156,641100%15,412,61415,073,68098%DE1,216,031832,41568%167,011,18699,567,57060%EE384,048384,048100%IE3,139,0532,997,41095%EL509,89490,18718%543,980157,56229%ES799,036544,63168%72,983,86958,809,32081%FR24,588,4163,181,26013%60,224,99643,896,80073%HR27,19600%192,275192,275100%IT3,858,247476,49112%4,854,6892,563,14653%CY188,692166,08288%483,523377,67278%LV1,675,7241,675,724100%LT28,10428,104100%516,283494,00496%LU86,29786,297100%HU394,76852,81113%2,984,576744,31325%MTNL41,521,57327,161,40965%AT1,479,3961,229,85183%9,196,8408,910,47497%PL11,217,3464,919,56444%3,449,9172,889,73584%PT273,562273,562100%RO360,667124,96535%5,907,1034,945,16584%SI20,77920,779100%1,242,393993,80380%SK1,204,238708,97759%FI163,23410,2476%5,586,0255,459,25698%SE26,65626,656100%38,095,48036,422,11496%EU-2770,038,47319,918,58928%734,538,274602,587,78382%UKTotal70,038,47319,918,58928%734,538,274602,587,78382%* Cut-off date 02/03/2026** Amounts are roundedTOR: Recovery rates (RR) per Member State in 2025MSFraudulentNon-fraudulent 
 
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Total cases** Cases assessed twice (AI)  Total (amounts not counted twice) N*EURNEURNEURNEURNNEURBG2                          670,594              2                          2                          670,594              CZ1                          305,937              1                          125,559              1                          222,294              3                          1                          653,789              DK1                          165,038              1                          1                          165,038              DE212,455              1                          436,573              1                          649,028              EL2                          1,458,118          1                          2,492,362          3                          1                          3,950,480          ES12                        6,510,961          7                          3,740,158          1                          312,570              20                        2                          10,563,689        FR 1                          12,129,456        1                          12,129,456        IT4                          1,291,007          7                          71,463,025        11                        5                          72,754,032        LT1                          1,172,149          1                          1,172,149          HU 7                          7,360,421          7                          7,360,421          MT 1                          315,314              1                          315,314              NL5                          1,569,049          1                          183,120              6                          1,752,168          AT1                          1,061,225          2                          701,198              3                          1,762,423          RO1                          1,060,059          35,901                4                          816,309              1                          66,463                6                          1,978,732          SI1                          185,164              1                          185,164              FI 1                          170,412              1                          170,412              EU-272011,613,794 2880,113,803 1824,002,258 2503,036 6812116,232,891 UK2370,91922370,919Total2011,613,794 3080,484,722 1824,002,258 2503,036 7014116,603,810 * Number of cases** Cases assessed twice are not includedTOR: Examination of write-off cases in 2025MS Acceptance  Reference to Article 13.2 considered not justified  Additional information request (AI)  Not appropriate  
 
 
 
 
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CasesEstimated and established amountNEURBE3716,184BG6248,483DE116,786EE152,748,159EL101,755,683FR13854,852HR5600,919IT23,313,440LT162,442,743AT143,276PL2107,883RO187,600EU-277512,936,008* CN code 2402 2090* Cut-off date 02/03/2026TOR: Cases of smuggled cigarettes* in 2025MS 
 
ANNEX 13 

List of abbreviations 

SA: Support to Agriculture 

RD: Rural Development 

SA/RD: Support to Agriculture/ Rural Development 

GUID: European Agricultural Guarantee and Guidance Fund – Section Guidance 

EFF: European Fisheries Fund 

EMFF: European Maritime and Fisheries Fund 

CF: Cohesion Fund 

ERDF: European Regional and Development Fund 

ESF: European Social Fund 

AMIF: Asylum, Migration and Integration Fund 

FEAD: Fund for European Aid to the most Deprived 

ISF: Internal Security Fund 

CBC: pre-accession, Cross-Border Cooperation component 

IPA: Instrument for Pre-accession Assistance 

HRD: pre-accession, Human Resources Development component 

IPARD: Instrument for Pre-Accession for Rural Development 

REGD: pre-accession, Regional Development component 

TAIB: Transition Assistance and Institution Building 

ENI: European Neighbourhood Instrument 

TIPAA: Turkey Instrument for Pre-accession Assistance 

UA: Ukraine Facility 

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 number of irregularities reported 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 Countries’ territories.Annex to the Statistical Evaluation -Irregularities reported as fraudulent by Member States and Beneficiary Countries in 2025 (1)(1) Based on data in the Irregularity Management System(IMS) as of 8/3/2026FUNDS/TYPE OF EXPENDITURE 
 
 
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COUNTRIESSARDSA/RDEFFEMFFCFERDFESFESF+AMIFJTFIPARDIPAIIIPAIIIUFCBC-ENIAT0000001,049,835000000000BE0000044,3021,360,585000000000BG01,220,578000027,377211,51700000000CY0000000000000000CZ01,410,58100507,23723,623,44715,987,7362,253,17770,7240000000DE28,997459,832157,7670003,150,348573,385458,786326,004000000DK0605,625000033,347000000000EE195,6031,268,2600000286,615000000000ES613,6139,80700001,923,627000000000FI0000132,888046,112000000000FR512,97300000968,143365,48600000000GR000000242,515000000000HR000000633,72023,90500000000HU115,2385,322,26000876,85902,485,90688,38100000000IE0000000000000000IT881,42630,281147,017082,2930645,000000000000LT0946,15700000000000000LU0000000000000000LV075,232000056,33003,5480000000MT0000000000000000NL940,979000000000000000PL646,502601,02400245,97202,938,8571,926,74200000000PT413,146750,188000010,715,102349,84200000000RO2,308,2722,084,8780143,0191,786,131045,597,3266,649,04854,77200000023,771SE000059,39900000000000SI082,5990000028,67100000000SK0011,4140022,865,6718,739,53112,56100000000UK000017,3240290,329000000000AL0000000000000000ME0000000000000000MK0000000000000000RS0000000000000000TR0000000000010,2555,260000UA00000000000000556,8900TOTAL6,656,75014,867,302316,197143,0193,708,10246,533,42097,178,33912,482,714587,830326,004010,2555,2600556,89023,771(1) Based on data in the Irregularity Management System(IMS) as of 8/3/2026FUNDS/TYPE OF EXPENDITUREAnnex to the Statistical Evaluation - Irregular amounts related to irregularities reported as fraudulent by Member States and Beneficiary Countries in 2025 (1) 
 
 
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nnex to the Statistical Evaluation -Irregularities not reported as fraudulent by Member States and Beneficiary Countries in 2025  (1)The number of irregularities reported 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 Countries’ territories.(1) Based on data in the Management System(IMS) as of 8/3/2026 
 
 
 
 
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COUNTRIESSARDSA/RDEFFEMFFEMFAFCFERDFESFESF+YEIFEADAMIFISFJTFBMVITAIBIPAIIIPAIIIUFCBC-ENIAT147,438483,655000001,413,46241,21900116,160000000000BE322,640344,591119,7090000432,359795,991000000000000BG1,114,7361,586,705016,037152,45902,156,0765,778,322352,00271,04200000000000CY298,480000002,495,07200000000000000CZ174,992892,48500005,468,24224,394,46311,008,329497,7940010,6440103,390000000DE2,473,1742,565,70618,72200009,424,1941,287,578173,5340060,48600000000DK713,843784,53400593,7720000000000000000EE02,610,2740000285,3311,897,1450103,0510000200,36917,77600000ES7,261,95568,156,96100000178,101,6751,550,796000000000000FI115,316604,70100012,4760190,38000000010,967000000FR2,206,23012,392,12432,2320101,493006,706,872117,252012,40600844,886042,32100000GR223,9573,240,155000018,299,50562,214,1806,492,51601,883,041051,0680000189,308000HR407,30218,598,948000003,072,7261,538,33623,26500000000000HU1,716,33415,791,488001,099,9060965,18925,924,6342,896,3761,258,509000011,392000000IE000000003,578,275159,5360003,543,1610000000IT7,186,9045,863,0772,578,152049,2200020,289,8502,961,929000000000000LT504,0472,267,3380014,2740481,6259,496,01058,478000000000000LU027,0260000000000000000000LV100,218313,9530000126,058157,70500000030,815000000MT056,735000023,27448,13624,105000000000000NL49,593339,33900000407,3590000000000000PL2,883,40718,294,709288,85101,443,84106,844,46079,941,62520,150,4531,650,0710000289,4240000087,193PT1,905,29611,133,90200504,36603,582,9603,624,5181,301,21648,0690069,71900000000RO2,917,86336,328,3350275,422859,850011,867,31759,060,5979,131,737243,50002,273,49500189,67900000302,438SE86,938684,001001,970,45800204,096024,36000000000000SI0265,75400000679,4600000000000000SK381,9222,524,410312,9820008,750,60357,829,14465,676324,22500000000000UK00001,925,1280045,626,5303,348,025000000000000AL000000000000000001,082,468000ME00000000000000000233,438000MK0000000000000000090,0161,521,56200RS000000000000000001,266,843000TR0000000000000000144,8424,410,159288,62400UA0000000000000000000804,8230TOTAL33,192,584206,150,9063,350,648291,4598,714,76812,47661,345,711596,915,44266,700,2894,576,9571,895,4472,389,655191,9174,388,047836,03560,097144,8427,272,2321,810,186804,823389,631FUNDS/TYPE OF EXPENDITUREAnnex to the Statistical Evaluation - Irregular amounts related to irregularities not reported as fraudulent by Member States and Beneficiary Countries in 2025  (1)(1) Based on data in the Irregularity Management System(IMS) as of 8/3/2026