COMMISSION STAFF WORKING DOCUMENT National anti-fraud strategies (NAFS): state of play 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) 250 final  COMMISSION STAFF WORKING DOCUMENT National anti-fraud strategies (NAFS): state of play  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) 251 final}  
 
 
TABLE OF CONTENTS 

INTRODUCTION ......................................................................................................................................... 3 

OVERVIEW OF NATIONAL ANTI-FRAUD STRATEGIES ..................................................... 3 
1. 
1.1. Main reason for establishing a NAFS and resulting benefits ................................................................... 6 
1.2. Fraud risk assessment informing the NAFS ............................................................................................. 7 
1.3. Challenges and lessons learned ................................................................................................................ 7 
1.4. Reasons for not adopting a NAFS ............................................................................................................ 8 
1.5. AFCOS Network ...................................................................................................................................... 9 

2. 

FOLLOW-UP TO RECOMMENDATION 3 OF THE 2024 PIF REPORT - RESPONSES 
FROM THE MEMBER STATES .................................................................................................. 12 

Q.3.1 Do you have in place a National Anti-Fraud Strategy (NAFS) for the protection of the EU's financial 

interests? ............................................................................................................................................ 12 
Q.3.2 Date of adoption (year). ...................................................................................................................... 12 
Q.3.3 Date of the latest update (year), if applicable. ..................................................................................... 12 
Q.3.4 Period covered. .................................................................................................................................... 13 
Q.3.5 Fields/Areas covered by NAFS. .......................................................................................................... 13 
Q.3.6 Please specify "Other" field(s)/area(s) concerned by the NAFS. ........................................................ 14 
Q.3.7 What were the main reasons for establishing a NAFS? ...................................................................... 14 
Q.3.8 If you adopted a new NAFS or updated your existing one in 2025: What are the lessons learned? ... 16 
Q.3.9 What benefits have you noticed since establishing a NAFS? .............................................................. 16 
Q.3.10 Has a nation-wide fraud risk assessment been conducted to inform the NAFS? .............................. 18 
Q.3.11 Who were the stakeholders involved? ............................................................................................... 18 
Q.3.12  What  type  of  challenges  have  you  encountered  in  the  process  of  elaboration/adoption  of  the 

NAFS? ............................................................................................................................................... 19 
Q.3.13 Are you planning to adopt a NAFS? ................................................................................................. 20 
Q.3.14 Which is the stage of the ongoing procedure for adopting a NAFS? ................................................ 20 
Q.3.15 What are the reasons for not having/planning to adopt a NAFS? ..................................................... 20 
Q.3.16 Are there any obstacles preventing you from adopting a NAFS? ..................................................... 21 
Q.3.17 What type of support from the European Commission would help you progress towards adopting 

a NAFS? ............................................................................................................................................ 22 

Q.3.18  Do  you  have  in  place  any  other  anti-fraud  strategy/ies  (AFS)  for  the  protection  of  the  EU's 

financial interests? ............................................................................................................................. 23 
Q.3.19 What other anti-fraud strategy(ies) have you adopted? ..................................................................... 23 
Q.3.20 Please specify the period and areas covered by the regional cross-cutting AFS (i.e., cohesion funds, 

agricultural funds, RRF, customs, VAT, other). ............................................................................... 24 

Q.3.21 Please specify the period and areas covered by the sectoral national AFS (i.e., cohesion funds, 

agricultural funds, RRF, customs, VAT, other). ............................................................................... 24 

Q.3.22 Please specify the period and areas covered by the sectoral regional AFS (i.e., cohesion funds, 

agricultural funds, RRF, customs, VAT, other). ............................................................................... 26 
Q.3.23 Please specify the authority concerned and the period covered by the authority level AFS. ............ 27 
Q.3.24 Please specify the programme concerned and the period covered by the programme level AFS. .... 29 
Q.3.25 Please specify "Other" types of strategy adopted, including period and areas covered. ................... 30 
Q.3.26 Is there a national anti-fraud network in your Member State? .......................................................... 32 
Q.3.27 How has your national anti-fraud network evolved in terms of structure and/or involvement since 

its establishment? .............................................................................................................................. 32 
Q.3.28 Does AFCOS have a key role in your national anti-fraud network? ................................................. 35 
Q.3.29 Please specify the role of the AFCOS in your anti-fraud network. ................................................... 36 

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Q.3.30 Has/How has the national anti-fraud network contributed to the elaboration of the NAFS? ............ 39 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

INTRODUCTION 

While having a national anti-fraud strategy (NAFS) in place is not a legal obligation for the Member 
States, the Commission (1), European Parliament (2) and European Court of Auditors (3) have actively 
encouraged Member States to adopt national anti-fraud strategies. Moreover, the European Parliament 
has called for the Commission to ‘assess the NAFS that have been adopted, to examine why Member 
States are lagging behind in adopting them, and to push the remaining Member States to progress with 
the adoption’ (4). 

The state of play on the NAFS has been presented in the Annual Report on the Protection of the European 
Union’s financial interests and the Fight against fraud (‘PIF Report’). This overview is based on the 
Member States’ replies to the dedicated questionnaire. 

To  address  the  request  for  analysis  of  the  adopted  NAFS,  in  the  2023  and  2024  PIF  Reports,  the 
Commission conducted a qualitative assessment that extends beyond the self-assessment provided in 
the responses to the PIF questionnaire. This assessment is based on criteria derived from the guidelines 
on national anti-fraud strategies (5). 

Since  no  new  NAFS  was  adopted  in  2025,  the  qualitative  assessment  accompanying  the  2024  PIF 
Report (6) remains valid. Consequently, it has not been reproduced in this document. 

The 2024 PIF Report included a recommendation on NAFS. 

Recommendation 3 – Adoption of a National Anti-Fraud Strategy 

The Commission reiterates its recommendation that the Member States which have not yet adopted a 
NAFS should do so. 

National anti-fraud networks have been developing in several Member States, often with the national 
Anti-Fraud  Coordination  Service  (AFCOS)  playing  a  key  role.  These  networks  provide  the  ideal 
structure  for  conducting  nation-wide  fraud  risk  assessment  and  consequently  developing  national 
strategies. 

The Commission supports and encourages this process. 

This  SWD  contains  an  overview  of the  national  and  other anti-fraud  strategies  in  place  in the 
Member States and the follow-up given by the Member States to Recommendation 3 of the 2024 
PIF Report. 

1. OVERVIEW OF NATIONAL ANTI-FRAUD STRATEGIES 

In 2025, 25 Member States indicated that they have anti-fraud strategies in place for the protection of 
the EU’s financial interests (7). The approach taken by the Member States varied widely. 

(1)Annual Report on the Protection of the European Union’s financial interests and the Fight against fraud (‘PIF Report’) - 
2017, 2018, 2020, 2022, 2023, 2024. 
(2)European Parliament resolutions on the protection of the European Union’s financial interests – combating fraud – 
annual reports 2016-2024. 
(3)Special Report No 6/2019 Tackling fraud in EU cohesion spending: managing authorities need to strengthen detection, 
response and coordination. 
(4)European Parliament Resolution of 7 July 2022 on the protection of the European Union’s financial interests – combating 
fraud – annual report 2020 (2021/2234(INI)). 
(5)Guidelines for the elaboration of a national anti-fraud strategy (NAFS) 
(6)SWD(2025) 229 final. 
(7)The information was gathered via a dedicated questionnaire. 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
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A  total  of  10  Member  States  indicated  they  have  a  national  anti-fraud  strategy  (NAFS)  in  place 
addressing at least fraud against EU funds. These are the same NAFS reported in 2024, therefore the 
qualitative assessment in the 2024 PIF Report (8) remains valid. 

7 out of the 10 NAFS cover both EU expenditure and revenue, the remaining 3 (9) NAFS cover only EU 
expenditure. 

8 of the 17 Member States who do not have a national anti-fraud strategy for the protection of EU’s 
financial interests, are in the process of adopting one. 3 (10) Member States are in the preliminary stage 
(i.e.  defining  the  legal  and  institutional  framework  and  the  scope  of  the  strategy),  1 (11)  is  in  the 
preparatory  phase  (i.e. state  of  play and fraud risk assessment)  and  4 (12)  are in the  formal  approval 
phase. 

9 (13) Member States declared neither having a national anti-fraud strategy for the protection of EU’s 
financial interests nor an ongoing procedure to adopt one. 

Figure 1 – Overview of the NAFS reported by Member States (14) 

22 out of 27 Member States indicated that they have other types of anti-fraud strategy for the protection 
of  EU’s  financial  interests  in  place:  regional  cross-cutting,  sectoral  national,  sectoral  regional,  anti-
corruption (covering also  the  EU’s financial interests),  authority/programme  level. Most  of  these 22 
Member States have more than one anti-fraud strategy for the protection of EU’s financial interests in 
place. Of the remaining 5, 3 (15) have a NAFS in place, while the remaining 2 (16) did not declare having 
any anti-fraud strategy. 

(8) SWD(2025) 229 final. 
(9) Hungary, Malta, Portugal 
(10) Belgium, Denmark, Germany 
(11) Luxembourg 
(12) Cyprus, Ireland, Netherlands, Spain 
(13) Austria, Croatia, Estonia, Finland, Greece, Lithuania, Poland, Slovenia, Sweden 
(14) The figure is based on the Member States’ replies to the 2023, 2024 and 2025 dedicated questionnaires. 
(15) Bulgaria, France, Hungary 
(16) Lithuania, Sweden 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Table 1 – Overview of other types of anti-fraud strategies reported by Member States 

Regional AFS 

Sectoral national 
strategy 

Sectoral regional 
AFS + Anti-
corruption strategy 

Authority level AFS 

Programme level AFS 

Other 

T
A

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
E

S
E

I

F

R
F

R
H

U
H

E

I

T

I

T
L

U
L

V
L

T
M

L
N

L
P

T
P

O
R

E
S

I

S

K
S

Member States 

Not Used 

Used 

A  specific  questionnaire  was  sent  to  the  Member  States  to  gather  information  on  how  they  have 
implemented the recommendations in the 2024 PIF Report. Their responses to Recommendation 3 are 
analysed below. In Section 2, the Commission provides an overview and analysis of these responses, 
while Section 3 sets out the detailed replies to each question in the survey. 

FOLLOW-UP TO RECOMMENDATION 3 OF THE 2024 PIF REPORT - OVERVIEW OF 

(1) 
MEMBER STATES’ REPLIES 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

1.1. Main reason for establishing a NAFS and resulting benefits 

For the Member States with a NAFS in place, the main reason for its adoption is the obligation to protect 
the  EU’s  financial  interests,  as  stipulated  under  Article  325  of  the  Treaty  on  the  Functioning  of  the 
European Union. One Member State (17) developed its NAFS specifically as part of commitments under 
the EU’s conditionality procedure. 

In addition to legal obligations, the following reasons were cited: 

•  the need for a coherent, coordinated policy framework to combat fraud affecting the 

EU budget; 

•  strengthening  cooperation  among  national  authorities  responsible  for  managing  EU 

funds; 

•  establishing a structured mechanism to address systemic risks; 

•  securing budgetary resources for the AFCOS. 

Member States have identified several key benefits resulting from the implementation of a NAFS, which 
can be grouped into the following categories: 

•  strengthened  cooperation,  communication  and  coordination  among  national  anti-

fraud actors; 

•  consolidation of the anti-fraud architecture, particularly within the AFCOS network; 

•  better governance by clearly defining responsibilities and procedures; 

•  improved clarity of legal and regulatory framework; 

•  a more structured and systematic approach to fraud prevention and detection; 

•  effective and coordinated implementation of anti-fraud actions; 

•  greater  transparency  regarding  anti-fraud  efforts  and  accountability 

in  fund 

management processes; 

•  strengthened  institutional  capacities  through  targeted  capacity-building  measures 

included in the NAFS. 

(17) Hungary 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

1.2. Fraud risk assessment informing the NAFS 

6 out of 10 Member States that have a NAFS in place have performed a nation-wide risk assessment to 
inform the strategy. 

Figure 2 - Nation-wide fraud risk assessment 

A  wide  range  of  stakeholders  was  involved  in  the  nation-wide  fraud  risk  assessment:  all  national 
authorities involved in the AFCOS network (2 (18)), all national authorities with competencies in the 
protection of EU’s financial interests (3 (19)), managing authorities (1 (20)). 

1.3. Challenges and lessons learned 

Member States reported several challenges encountered during the developments and adoption of their 
NAFS, including: 

•  Institutional/governance challenges such as political instability; insufficient political 
support; absence of a designated authority with clear responsibility for elaborating the 
strategy; differences in understanding the roles of various anti-fraud actors; and inter-
institutional coordination of anti-fraud actors. 

•  Operational  challenges  such  as  lack  of  a  standardised  methodology  for  assessing 
fraud risks; defining effective anti-fraud actions and measurable, realistic indicators; 
integrating evolving commitments (e.g., under EU conditionality and the Recovery and 
Resilience Facility); balancing fraud prevention needs with the administrative burden; 
resource  and  capacity  constraints  (financial,  human,  technical);  and  lengthy 
elaboration and approval processes. 

(18) Bulgaria, Latvia 
(19) France, Italy, Portugal 
(20) Hungary 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Among  the  lessons  learned  in  the  process  of  elaborating  and  adopting  a  NAFS,  Member  States 
highlighted the need to: 

•  ensure flexibility, to allow adapting the strategy to evolving risks and changes in the 

regulatory framework; 

•  integrate preventive, detection and corrective measures in a consistent manner; 

•  systematise fraud risk assessment at national level; 

•  update the strategy / action plan based on the evaluation of previous one to  reflect 

progress and emerging needs; 

•  continuously strengthen inter-institutional coordination; 

•  ensure structured information sharing between the different administrative levels and 

maintain clear communication with all stakeholders; 

continuous staff training and digitalisation of the anti-fraud processes. 

1.4. Reasons for not adopting a NAFS 

For some (21) of the 9 Member States that declared neither having a NAFS nor an ongoing procedure to 
adopt one, the reason is that key anti-fraud elements are already embedded in existing national systems, 
procedures and other anti-fraud strategies in place at national level. Setting up a NAFS has been however 
considered  by  Finland  and  Greece.  Slovenia  mentioned  the  lack  of  political  decision  for  adopting  a 
NAFS. Sweden indicated that having a NAFS would not bring added value. 

Most Member States reported legislative barriers as the main obstacle to adopting a NAFS, while two 
of them cited resource-related issues and one mentioned institutional factors. 

Figure 3 – Obstacles preventing the adoption of NAFS 

Regarding the type of support needed from the European Commission to help Member States progress 
towards  adopting  a  NAFS,  most  Member  States  emphasised  the  need  for  updated  guidelines,  while 
technical  assistance,  mandatory  NAFS,  financial  support,  and  tailored  advice  were  each  equally 
mentioned but less frequently. 

(21) Croatia, Estonia, Finland, Poland 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Figure 4 - Type of support needed from the European Commission

1.5. AFCOS Network 

23 Member States have an AFCOS network in place. In 19 of them AFCOS plays a key role. 

The role of AFCOS in AFCOS network varies across Member States, ranging from only being a member 
to presiding over the network. In many cases AFCOS serves as a coordinating body for the AFCOS 
network, and in some Member States (22) it acts as the central coordination service for all matters related 
to the protection of EU’s financial interests at national level. Other key functions of AFCOS include: 

•  coordinating the elaboration, adoption, implementation of NAFS; 

•  information and knowledge sharing; 

•  elaborating methodologies, guidelines, trainings, awareness campaigns on anti-fraud 

issues; 

•  assisting OLAF during on-the-spot checks and inspections; 

•  reporting irregularities to the Commission. 

(22) Bulgaria, Finland, Latvia, Romania, Slovakia 

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23222TAILORED ADVICEUPDATED GUIDELINESFINANCIAL SUPPORTMANDATORY NAFSTECHNICAL ASSISTANCE SUPPORT FROM THE COMMISSION  
 
 
 
 
 
Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Figure 5 - AFCOS Network 

Out  of  the  10  Member  States  that  have  a  NAFS  in  place,  AFCOS  networks  was  involved  in  the 
elaboration/update in 9 of them. The remaining one (23) does not have an AFCOS network in place. In 
addition, in all 4 Member Stated that are currently in the formal procedure for adopting the NAFS the 
AFCOS networks was involved in the elaboration. 

Regarding  the  evolution  of  the  AFCOS  network  since  its  establishment,  two  trends  can  be  noticed: 
expansion in membership, with an increasing number of authorities joining the AFCOS network, and 
enhanced cooperation. Higher frequency and deeper engagement were also reported. 

(23) Portugal 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

2.  FOLLOW-UP  TO  RECOMMENDATION  3  OF  THE  2024  PIF  REPORT  -

RESPONSES FROM THE MEMBER STATES 

Q.3.1 Do you have in place a National Anti-Fraud Strategy (NAFS) for the 
protection of the EU's financial interests? 

Response 

Frequency  Member States 

10 

BG,  CZ,  FR, 
HU, IT, LV,  MT, 
PT, RO, SK 

17 

AT, BE, CY, DE, 
DK, EE, EL, ES, 
FI,  HR,  IE,  LT, 
LU, NL, PL, SE, 
SI 

Yes 

No 

Q.3.2 Date of adoption (year). 

Member 
State 

Response 

BG 

CZ 

FR 

HU 

IT 

LV 

MT 

PT 

RO 

SK 

2020 

2008 

2022 

2022 

2024 

2024 

2021 

2023 

2023 

2015 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Q.3.3 Date of the latest update (year), if applicable. 

Member 
State 

Response 

CZ 

FR 

HU 

PT 

SK 

2024 

2025 

2024 

2025 

2019 

Q.3.4 Period covered. 

Member 
State 

Response 

BG 

CZ 

FR 

HU 

IT 

LV 

MT 

PT 

RO 

SK 

2021 - 2027 

2008 - present 

2022 - 2027. A first roadmap for 2022 to 2025 was subject to an interim report. Following 
this report, a second roadmap was drawn up for 2025 to 2027. 

2022 - 2027 

2024 - 2027 

2024 - 2026 

2021 - 2026 

2023 - 2027 

2023 - 2027 

2014  –  2020.  The  current  version  was  prepared  to  reflect  the  framework  of  the 
programming period 2014-2020, but its main elements are still applicable to the present 
landscape. The preparation of the update of the NAFS in the Slovak Republic is currently 
taking place at the level of the Working Group under Article 325 TFEU, which has been 
established under the Steering Committee for the Protection of the Financial Interests of 
the EU in the Slovak Republic. 

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Report 2024 

Q.3.5 Fields/Areas covered by NAFS. 

Response 

Frequency  Member States 

EU expenditure (EU funds) 

EU revenue (TOR) 

Other (please specify) 

9 

BG,  CZ,  FR, 
HU,  IT,  LV,  PT, 
RO, SK 

7 

BG, CZ, FR, IT, 
LV, RO, SK 

1  MT 

Q.3.6 Please specify "Other" field(s)/area(s) concerned by the NAFS. 

Member 
State 

Response 

MT 

Public  funds,  including  funds  that  Malta  is  required  to  manage  under  its  international 
obligations. 

Q.3.7 What were the main reasons for establishing a NAFS? 

Member 
State 

Response 

the  programming  period  2014-2020  Bulgarian  citizens  and 

During 
institutions 
demonstrated an increasingly strong commitment to countering fraud, corruption and any 
other illegal activity affecting Bulgaria’s national budget and the budget of the European 
Union. The national strategy sets out the goals of the Bulgarian competent authorities in 
the field of preventing and combating irregularities and fraud affecting the EU’s financial 
interests over the period 2021-2027. 

The main reason for developing the NAFS was to ensure the requirement for consistent 
protection of the EU's financial interests in all EU Member States, based in particular on 
Articles 310 and 325 of the Treaty on the Functioning of the European Union, and to ensure 
the most effective protection of funds provided to the Czech Republic from the EU budget 
in individual programming periods. 

The  Member  States  are  expected  to  help  protect  the  EU’s  financial  interests  and  to 
coordinate their actions internally in order to better combat fraud affecting the EU budget. 

Given  the  increasingly  sophisticated  fraud  techniques,  the  EU  and  the  Member  States 
must constantly adapt and strengthen their methods of combating fraud. 

The government adopted the NAFS in 2022, in line with the commitment made under the 
conditionality procedure. Prior to that, the NAFS was an institutional strategy issued by the 
coordinating body. 

BG 

CZ 

FR 

HU 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Member 
State 

Response 

The Italian NAFS, originally included in the Annual Report to Parliament (provided for in 
Article  54  of  Law  No  234/2012),  has  been  updated,  revised  and  extended  into  a  new 
standalone, comprehensive document. The NAFS is structured in full compliance with the 
guidelines of the European Commission (set out in document ARES(2016)6943965 of 13 
December 2016, entitled ‘Guidelines on national anti-fraud strategies’) and the other EU 
institutions.  It  has  been  adapted  to  meet  Italy’s  specific  regulatory  and  organisational 
conditions  and  aims  to  ensure  the  highest  level  of  protection  for  the  EU’s  financial 
interests,  in  full  compliance  with  the  general  principles  contained  in  the  Treaty  on  the 
Functioning  of  the  EU  and  the  Financial  Regulation,  as  well  as  to  implement  fully  and 
effectively  the  Commission’s  recommendations.  The  Italian  Anti-Fraud  Strategy  – 
accompanied  by  a  specific  ‘Action  Plan  (AP)’,  with  strategic  objectives,  indicators  and 
timetables for implementation – aims to cover in full the four phases of the anti-fraud cycle 
set out in the aforementioned Commission document: prevention, detection, investigation 
and prosecution, and recovery and sanctions. 

NAFS was adopted: 

•  To ensure a coherent, coordinated policy for preventing, detecting, and combating fraud 

affecting the EU budget. 

•  To improve cooperation among national authorities involved in EU funds management, 

law enforcement, audit, and prosecution. 

•  To  provide  a  structured  mechanism  to  address  systemic  risks  identified  during  risk 

assessment. 

•  To reserve funds for the AFCOS activities in the state budget. 

The  Maltese  National  Anti-Fraud  and  Corruption  Strategy  (NAFCS)  has  four  main 
objectives: (1) Capacity building; (2) Communication strategy; (3) Maximization of national 
co-operation; and (4) Maximization of EU and international co-operation. 

In terms of defining, developing and implementing the various frameworks and financial 
instruments  of  the  EU  budget,  it  was  vital  –  not  least  because  of  the  large  amounts  of 
funding allocated to Portugal – to implement a robust policy on the prevention, detection, 
correction and investigation of irregularities and on combating fraud. 

The NAFS establishes a framework and guidelines for drawing up individual action plans 
containing  effective  and  proportionate  anti-fraud  measures  to  protect  the  EU’s  financial 
interests, making it a powerful tool for combating fraud, since it is designed to enable the 
bodies  involved  in  managing  and  auditing  EU  funds  to  join  forces  and  take  concerted 
action in this area. 

The need to develop a national anti-fraud strategy derives from Romania’s fundamental 
obligation to protect the financial interests of the European Union, as required by Article 
325 of the Treaty on the Functioning of the European Union. The importance of a national 
anti-fraud  public  policy  has  also  been  consistently  underlined  by  the  EU  institutions  at 
working meetings and through public documents. 

Under Article 10(d) of Government Decision No 738/2011 approving the Regulation on the 
organisation  and  functioning  of  the  Romanian  Anti-Fraud  Department  (DLAF),  the 
Department is responsible for developing the national anti-fraud strategy and coordinating 
its implementation. 

NAFS  is  a  comprehensive  strategy  for  coordinating  the  protection  of  the  EU’s  financial 
interests in the Slovak Republic, developed with the aim of improving the protection of the 
EU's financial interests in the Slovak Republic, pursuant to Article 325 TFEU. It applies to 

IT 

LV 

MT 

PT 

RO 

SK 

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Report 2024 

Member 
State 

Response 

both the revenue and expenditure side of the budget and covers all phases of the anti-
fraud cycle. It also defines the roles of the bodies involved in the AFCOS network in relation 
to  the  protection  of  the  EU's  financial  interests.  The  main  reason  is  to  improve  the 
protection of financial interests of  EU in cooperation  with all partners  -  members of the 
AFCOS network. 

Q.3.8 If you adopted a new NAFS or updated your existing one in 2025: What 
are the lessons learned? 

Member 
State 

Response 

Bulgaria  faces  challenges  in  implementing  and  monitoring  strategic  and  operational 
objectives.  These  challenges  are  largely  due  to  the  lack  of  assessment  of  whether 
specific  activities  or  measures  have  contributed  to  the  achievement  of  the  operational 
and strategic objectives set out in the NAFS. 

While  specific  activities  include  performance  indicators,  there  are  no  predefined  result 
indicators  and  target  values  at  the  operational  objective  level,  which  means  that  the 
current  monitoring  of  strategy  implementation  does  not  take  into  account  progress 
towards achieving strategic priorities. 

BG 

Furthermore, regarding the current Rules for the preparation, monitoring, and reporting 
of the NAFS, the annual implementation plan does not require annual assessments of 
the achievement  of operational objectives and actions, which means that there are no 
specific  rules  established,  including  indicators  by  which  objectives  are  defined  as 
“completed”. 

The new 2025-2027 three-year roadmap, which builds on previous measures, is intended 
to be both ambitious and pragmatic. It comes at a time of growing challenges. On the one 
hand, the financial amounts at stake have never been so large, and on the other hand, 
fraud  techniques  are  evolving  rapidly,  with  the  methods  used  by  often  transnational 
criminal networks becoming increasingly sophisticated. To address these challenges, the 
new 2025-2027 roadmap incorporates the lessons learned from previous years and the 
recommendations made in the PIF reports for 2022 and 2023. 

Given that the Italian NAFS was only formally adopted recently, there has not yet been a 
need  to  update  it.  However,  the  importance  of  further  strengthening  inter-institutional 
coordination  and  structured  information  sharing  between  the  different  administrative 
levels has been noted. We have also identified the need to invest continuously in staff 
training, risk analysis and the digitisation of anti-fraud processes. Another lesson learnt 
was the need to  make the strategy flexible so that  it  could  be adapted to the evolving 
risks and regulatory framework. 

Pursuant to point 5 of National Order No 7833/2023, the original indicators, targets and 
deadlines of the NAFS were updated in 2025. The main lessons learned include the need 
to: strengthen coordination between national authorities and AFCOS; systematise fraud 
risk  assessment  at  national  level;  integrate  prevention,  detection  and  correction 

FR 

IT 

PT 

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Member 
State 

Response 

measures consistently; and maintain constant, clear communication with all stakeholders 
to ensure that the NAFS is effective. 

Q.3.9 What benefits have you noticed since establishing a NAFS?   

Member 
State 

Response 

BG 

CZ 

FR 

As  a  result  of  implementing  the  measures  set  out  in  the  NAFS,  there  has  been  a 
strengthening of institutional cooperation, transparency for the public regarding anti-fraud 
efforts, as well as inter-institutional cooperation and coordination to jointly solve common 
problems. 

Improved  communication  among  the  anti-fraud  actors  leading  to  more  efficient 
cooperation. 

The  NAFS  ensures  the  effective  and  coordinated  implementation  of  actions  in  order  to 
better protect the EU’s financial interests. Indeed, the establishment of such a strategy has 
created greater clarity around the actions carried out in the framework of the dedicated 
roadmaps covering the period of specific actions. The consolidation of an interim report on 
the first roadmap (2022-2025) provided the opportunity to check that the planned actions 
had  been  properly  implemented.  It  also  made  it  possible  to  identify  new  actions  which 
needed to be taken. 

HU 

The  adoption  of  the  NAFS  by  the  government  has  increased  its  visibility,  which  aids 
monitoring activities. 

IT 

The recent adoption of the NAFS has reinforced our advanced model for protecting the 
EU’s  financial  interests,  which  places  national  governance  frameworks  at  the  core  of  a 
system for preventing and combating irregularities and fraud affecting the EU budget. In 
this context, the implementation of Article 3 of Decree-Law No 19/2024 has brought about 
a  significant  change  through  the  expanded  membership  of  COLAF  (Committee  for 
Combatting Fraud against the European Union), thus strengthening operational synergy 
between central institutions, local administrations and control bodies. 

Benefits of NAFS include: 

•  Stronger, more coordinated national anti‑fraud system and better cooperation between 

authorities from the AFCOS network. 

LV 

• 

Improved  legal  and  regulatory  clarity  -  within  NAFS  a  systematic  assessment  was 
carried out in order to improve Latvia’s legal framework, including compliance with the 
PIF Directive and identification of gaps in criminal‑law provisions. 

•  Strengthened  institutional  capacities  and  expertise,  as  NAFS  includes  targeted 

capacity‑building measures. 

More  coordination  and  cooperation  between  national  authorities  combating  fraud  and 
corruption. In addition, the NAFCS provides for a normative, institutional and operational 
framework  for  the  effective  and  efficient  fight  against  fraud  and  corruption  in  Malta, 
reflecting local requirements, EU and other international obligations. 

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MT 

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Report 2024 

Member 
State 

Response 

Among the benefits we have obtained from setting up a NAFS, we would highlight: 

• 

improved coordination and cooperation between the national bodies that form part of 
the EU funds’ ecosystem; 

•  a more structured and systematic approach to fraud prevention and detection; 

•  better risk assessment and risk mitigation; 

•  greater transparency and accountability in the process of handing funds; 

PT 

•  more robust financial protection: less misappropriation and less improper use of funds 

from the Union's budget; 

•  greater  integrity:  more  rigorous  handling  and  implementation  of  funds,  focusing  on 

ethics and compliance; 

• 

improved  governance,  with  the  clear  definition  of  responsibilities  and  procedures  for 
dealing with fraud risks; and 

•  greater  trust  through  increased  transparency  and  accountability,  essential  for  the 

credibility and image of the institutions in the eyes of the public. 

RO 

Interinstitutional cooperation in fraud prevention and detection has been strengthened. 

SK 

In view of the obligations arising from the applicable NAFS, AFCOS partners fulfil ongoing 
tasks  and  take  measures  within  each  phase  of  the  anti-fraud  cycle.  These  are 
subsequently  analysed  and  evaluated,  which  contributes  to  the  adoption  of  further 
necessary measures. 

Q.3.10 Has a nation-wide fraud risk assessment been conducted to inform the 
NAFS?  

Response 

Yes 

No 

Frequency  Member States 

6 

BG, FR, HU, IT, 
LV, PT 

4  CZ, MT, RO, SK 

Q.3.11 Who were the stakeholders involved? 

Member 
State 

Response 

BG 

FR 

      -       

All competent authorities in Bulgaria that are members of the AFCOS Council. 

The  national  administrations,  in  cooperation  with  the  managing,  audit  and  control 
authorities for European funds, and the administrative and judicial investigation services 

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Member 
State 

Response 

coordinated  by  the  MICAF.  The  French  delegation  of  the  EPPO  is  also  an  important 
partner, alongside OLAF. 

Under  the  strategy,  the  managing  authorities  carried  out  a  fraud  risk  assessment  in 
accordance with Commission document EGESIF_14-0021-00. 

All  national  institutions  and  administrations  concerned  with  the  protection  of  the  EU’s 
financial interests that are part of COLAF were involved in the development of the National 
Anti-Fraud Strategy. 

HU 

IT 

LV 

All the authorities involved in the AFCOS network. 

PT 

The national bodies responsible for handling and monitoring the funds from the  general 
budget of the Union are responsible for implementing the NAFS. The General Inspectorate 
of Finance's (Inspeção-Geral de Finanças - IGF) audit authority, in its role as AFCOS and 
in conjunction with the coordinating bodies, is responsible for monitoring, assessing and 
publishing the results of the strategy. 

Q.3.12  What  type  of  challenges  have  you  encountered  in  the  process  of 
elaboration/adoption of the NAFS? 

Member 
State 

Response 

BG 

CZ 

FR 

HU 

IT 

LV 

Lack  of  a  responsible  institution  at  the  national  level  with  competences  for  governing, 
elaborating and assessment of the NAFS. 

In some cases, there were slight differences in the understanding of the role of diverse 
anti-fraud actors. 

No particular obstacles. 

Hungary made various commitments related to the conditionality procedure and the RRF 
that  fall  under  the  scope  of  the  NAFS.  The  challenge  was  to  ensure  that  these 
continuously advancing measures were reflected in the strategy in an accurate and timely 
manner. 

The  drafting  and  adoption  of  the  NAFS  in  Italy,  coordinated  by  the  Committee  for 
Combating Fraud against the European Union (COLAF), has faced several challenges. 
One of the main challenges was harmonising the activities of a multitude of stakeholders, 
with  the  aim  of  making  the  NAFS  an  operational  and  cross-cutting  document  within  a 
complex  administrative  system.  An  additional  challenge  was  that  of  defining  a  shared 
methodology for fraud risk assessment and identifying implementation indicators capable 
of measuring actual effectiveness. 

•  Ensuring  effective  inter‑institutional  coordination  -  challenge  to  coordinate  efforts  of 

more than 20 authorities during preparations of the NAFS. 

•  Balancing prevention and administrative burden - challenge to design fraud‑prevention 
measures that are effective but do not overburden beneficiaries or create unnecessary 
complexity in EU funds management. 

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Member 
State 

Response 

•  Achieving political consensus and ensuring prioritization - high‑level political support is 

needed to adopt a NAFS. 

•  Resource and capacity constraints - developing, implementing, and monitoring a NAFS 

requires financial, human, and technical resources. 

•  Establishing measurable and realistic indicators  - challenge to balance ambition with 

feasibility and ensure data availability for monitoring. 

MT 

PT 

RO 

SK 

Information gathering. 

Assessing the risk and effectiveness of the anti-fraud measures put in place. 

Developments in the political situation at national level have slowed down the adoption 
of the strategy. During the approval period, changes occurred both in the management 
of the co-initiating institution and in the Cabinet of Ministers. 

This is a lengthy process of preparing a strategic document, in the preparation of which 
a large number of entities are involved, it goes through a commenting procedure at the 
levels of the working group, members of the Steering Committee and the government of 
the Slovak Republic. At the same time, a major challenge is the allocation of sufficient 
financial resources for the implementation of the measures. 

Q.3.13 Are you planning to adopt a NAFS? 

Response 

Frequency  Member States 

No, there is currently no procedure for adopting a NAFS 

Yes, the procedure for adopting a NAFS is ongoing 

9 

8 

AT,  EE,  EL,  FI, 
HR, LT, PL, SE, 
SI 

BE,  CY,  DE, 
DK,  ES,  IE,  LU, 
NL 

Q.3.14  Which is  the  stage  of  the  ongoing  procedure  for  adopting  a  NAFS? 

Response 

Frequency  Member States 

Formal approval of the strategy 

Preliminary stage - defining the legal and institutional  framework 
and the scope of the strategy 

4  CY, ES, IE, NL 

3  BE, DE, DK 

Preparatory phase - state of play and fraud risk assessment 

1  LU 

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Q.3.15  What  are  the  reasons  for  not  having/planning  to  adopt  a  NAFS? 

Member 
State 

Response 

Estonia has not adopted a standalone NAFS because the key elements normally covered 
by  a  NAFS  are  already  embedded  in  existing  national  systems,  procedures,  and 
sector‑specific  regulations.  Anti‑fraud  responsibilities  are  clearly  allocated  between 
authorities,  and  prevention,  detection,  investigation,  and  reporting  processes  are 
governed  by  established  legal  acts  and  internal  control  frameworks.  As  a  result,  the 
functions  of  a  NAFS  are  fulfilled  through  these  existing  structures,  and  a  separate 
overarching  strategy  has  not  been  deemed  necessary.  All  authorities  involved  in  the 
protection  of  the  EU’s  financial  interests  regularly  assess  and  mitigate  the  risks  within 
their  respective  areas.  Where  relevant,  they  share  their  findings  with  other  bodies  to 
ensure that risks are addressed quickly, effectively, and with minimal impact. 

Sectoral strategies exist for operations co-financed by the Structural Funds, for Recovery 
and  Resilience  Fund  projects,  and  for  revenue.  In  addition,  sectoral  strategies  for  the 
agricultural  funds  and  the  Asylum  and  Migration  Fund  are  currently  being  drafted. 
Furthermore, the National Transparency Authority has prepared a national anti-corruption 
action  plan  for  2022-2025.  We  do,  however,  intend  to  discuss  a  national  anti-fraud 
strategy. 

Anti-fraud strategies and plans are in place for EU-funded programmes and funds and 
for the Recovery and Resilience Facility (RRF). No immediate need for a national anti-
fraud strategy has been identified. The drafting of the strategy has been the subject  of 
preliminary discussions for the next financial framework period. 

The  Republic  of  Croatia  has  adopted  two  NAFS  related  to  the  protection  of  the  EU´s 
financial interests so far and they were both communicated to OLAF. One covered the 
period 2010-2012 (adopted 14/01/2010) while the other covered the period 2014-2016 
(adopted 23/01/2014), and both strategies were fully implemented. 

Considering that the anti-fraud coordination system in the Republic of Croatia has been 
established,  fully  operational,  and  no  major  weaknesses  were  identified,  no  new  anti-
fraud strategies for the protection of EU’s financial interests have been adopted, neither 
updates of the existing ones have been made. Yet, AFCOS system in the Republic of 
Croatia  has  been  constantly  fine-tuned  through  softer  measures  (e.g.  Irregularity 
management guidelines, fraud risk assessments at the level of operational programmes, 
etc.). 

Poland has not adopted a NAFS. Current EU provisions do not impose a requirement to 
adopt a NAFS and this is still a non-binding Commission recommendation. 

The obligation to protect the financial interests of the EU (including the fight against fraud) 
stems directly from the Treaties, in particular Article 325 TFEU, and is properly complied 
with in Poland. This is demonstrated, for example, by the statistics presenting the number 
of irregularities, including fraud, detected and reported to the Commission; these confirm 
the effectiveness of the approaches that have been implemented and are in place. Even 
though these approaches do not constitute a single national strategy, they are effective 
and produce satisfactory results. 

We do not currently see any added value. 

No political and interinstitutional decision has been discussed yet. 

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EE 

EL 

FI 

HR 

PL 

SE 

SI 

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Member 
State 

Response 

Due to the absence of  a national strategy for  ESI funds, the Ministry of Cohesion and 
Regional Development (as Managing Authority) has prepared a sectoral strategy for ESI 
funds  in  Slovenia,  at  the  level  of  the  programme  for  the  implementation  of  European 
cohesion policy funds.  

Q.3.16 Are there any obstacles preventing you from adopting a NAFS? 

Response 

Legislative 

Resource-related 

Institutional 

Other (please specify) 

No 

Frequency  Member States 

3  EL, LT, SI 

2  FI, SE 

1  SI 

1  EE 

2  HR, PL 

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Please specify "Other" obstacles. 

Member 
State 

Response 

EE 

Estonia does not face specific obstacles to adopting a NAFS. As a small country, we rely 
on close inter-institutional cooperation, which functions efficiently and allows issues to be 
addressed  flexibly  based  on  current  needs  and  available  resources.  The  roles  and 
responsibilities  related  to  fraud  prevention,  detection,  and  reporting  are  already  clearly 
established in existing national systems, so a separate overarching strategy has not been 
considered necessary. 

Q.3.17 What type of support from the European Commission would help you 
progress towards adopting a NAFS? 

Member 
State 

Response 

BE 

CY 

DE 

DK 

EE 

EL 

ES 

HR 

IE 

Belgian AFCOS: A dedicated experienced staff member which helps us in the realisation 
of such a strategy. Also, clear input on areas of improvement to ensure a smooth progress 
of the installation of such strategies. 

The next MFF should mandate the adoption of a NAFS. 

At this stage, we do not need the support of the European Commission, but we will come 
back to you in due course with a request for support. 

General  guidance  and  feedback  during  the  process  of  preparing  and  elaborating  the 
strategy. 

Estonia does not currently plan to adopt a NAFS, as the functions of such a strategy are 
already  covered  by  existing  national  systems,  procedures,  and  inter‑institutional 
cooperation  mechanisms.  Given  the  size  of  the  country  and  the  efficiency  of  existing 
structures, a separate strategy has not been considered necessary. 

If the adoption of a NAFS becomes mandatory at EU level, Estonia would require financial 
support to  develop  and  implement  it,  as this would entail additional administrative and 
analytical work beyond current capacities. Any future strategies would also need to be 
designed  in  an  innovative,  IT‑driven  manner  and  reflect  the  actual  operational 
environment,  ensuring  that  systems  remain  modern,  data‑based,  and  responsive  to 
emerging risks. 

Updated guidelines from the European Commission. 

Making it a legal requirement to have a NAFS would be extremely useful. 

Technical  (financial)  support  from  different  EU  sources  would  be  beneficial  (e.g. 
Technical Support Instrument, TAIEX). 

AFCOS  has  appreciated  the  support  from  OLAF  in  progressing  its  AFCOS  network 
Handbook  in 2025. Guidance on NAFS from 2016  being updated would be a support, 
which we note is on the agenda for the next COCOLAF expert group. 

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Member 
State 

Response 

NL 

None at present. 

PL 

As there is no work on a NAFS, there is no expectation of support from the Commission. 
There are already Commission/OLAF guidelines on how to draw up such a strategy and 
on  the  themes  and  the  areas  to  be  regulated.  If  work  does  begin  on  a  NAFS,  the 
guidelines should suffice to create a strategy that meets the Commission’s requirements. 

Q.3.18 Do you have in place any other anti-fraud strategy/ies (AFS) for the 
protection of the EU's financial interests? 

Response 

Frequency  Member States 

Yes 

No 

22 

AT, BE, CY, CZ, 
DE, DK, EE, EL, 
ES,  FI,  HR,  IE, 
IT,  LU,  LV,  MT, 
NL, PL, PT, RO, 
SI, SK 

5 

BG, FR, HU, LT, 
SE 

Q.3.19 What other anti-fraud strategy(ies) have you adopted? 

Response 

Frequency  Member States 

Authority level AFS 

Programme level AFS 

14 

14 

Sectoral national strategy (covering the whole national territory) 

14 

BE, CZ, DE, DK, 
EE, ES, HR, IE, 
IT,  LU,  LV,  PL, 
RO, SI 

AT, BE, DE, DK, 
EE,  ES,  FI,  IE, 
IT,  LU,  LV,  PL, 
RO, SI 

AT, CY, DK, EE, 
EL,  ES,  FI,  IT, 
LV, MT, NL, PT, 
SI, SK 

Regional AFS (cross-cutting covering the EU's financial interests) 

4  BE, DE, ES, IT 

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Response 

Frequency  Member States 

Sectoral regional AFS Anti-corruption strategy (covering also the 
EU's financial interests) 

Other (please specify) 

3  DE, EE, HR 

7 

BE, CZ, DE, ES, 
FI, IE, IT 

Q.3.20  Please  specify  the  period  and  areas  covered  by  the  regional  cross-
cutting  AFS  (i.e.,  cohesion  funds,  agricultural  funds,  RRF,  customs,  VAT, 
other).   

Member 
State 

Response 

•  Public service of Wallonia (PSW) ERDF Wallonia: All issues managed by the PSW as 
regional administration are covered by the regional strategy adopted in December 2023 
and updated in 2025 by the new COSTRA (Strategic Committee). It covers all periods 
since that date. 

BE 

•  ESF Agency: On 9 September 2024, the Managing Committee of the MFWB (Ministry of 
the Wallonia-Brussels Federation) adopted an anti-fraud policy for the entire Ministry (not 
just European funds). A working group was set up to draft an action plan to put this policy 
into practice, coordinate it and monitor it. The cohesion policy and RRF funds managed 
by the MFWB are also covered. 

•  ESF  Agency  Wallonia:  The  Fédération  Wallonie-Bruxelles  (FWB)  anti-fraud  strategy 
which  covers  all  the  responsibilities  of  the  French  Community,  including  the  cohesion 
funds. 

•  The  Lower  Saxony  ERDF  managing  authority:  The  2021–2027  programming  period  – 

cohesion fund. 

•  The Bremen ERDF managing authority: An anti-fraud and anti-corruption strategy (risk 
management) was drawn up in the context of establishing the management and control 
systems for the 2021–2027 Bremen ERDF programme, based on  the experience from 
the 2014–2020 funding period. 

•  The  Brandenburg  ERDF  managing  authority:  Anti-fraud  strategy  in  the  2021–2027 
Brandenburg  operational  programme  for  the  ERDF/JTF;  description  of  measures  to 
combat and prevent fraud, corruption, money laundering and conflicts of interest. 

Consello de Contas de Galicia: Strategy for the prevention of corruption 2024. 

Scope: Administration of the Autonomous Community of Galicia. Period: 2023-2028. 

The following sectors were covered by the Customs and Monopolies Agency from 2025 
onwards: VAT, customs, tobacco and duties. Risk analyses were carried out at local and 
central level using the information contained in the platforms used. 

DE 

ES 

IT 

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Q.3.21 Please specify the period and areas covered by  the sectoral national 
AFS  (i.e.,  cohesion  funds,  agricultural  funds,  RRF,  customs,  VAT,  other).

Member 
State 

Response 

AT 

Cohesion funds, agricultural funds, fisheries, since 15 December 2020. ESF. 

AFS  for  revenue,  adopted  in  2023  for  the  period  2023-2028.  With  scarce  human  and 
financial resources, the AFS was adopted to set priorities and use a targeted approach 
to  achieve  the  greatest  possible  effect,  to  protect  tax  revenues.  Having  a  transparent 
strategy  is  key  to  successful  financial  administration.  It  provides  a  clear  guidance 
framework,  provides  a  basis  for  further  action  and  promotes  a  more  efficient  use  of 
resources. 

CY 

Agricultural funds. 

DK 

EE 

Denmark  has  four  sectoral  national  anti-fraud  strategies:  i)  The  Danish  Business 
Authority's anti-fraud strategy for the cohesion policy funds; ii) The Danish Agricultural 
Agency's strategy on anti-fraud for agricultural funds; iii) The Danish Fisheries Agency's 
strategy on anti-fraud for fisheries funds; iv) The strategy on the Recovery and Resilience 
Facility. 

The RRF anti-fraud strategy was implemented in November 2023. The strategy on anti-
fraud for agricultural funds since 2014. 

The sectoral AFS elements in Estonia are reflected in several national strategic documents 
covering different periods and policy areas: 

•  Financial  Crime  Prevention  and  Public  Awareness  Action  Plan  2025–2026  –  focuses  on 

preventing financial crimes and raising public awareness. 

•  Police  and  Border  Guard  Board  Services  Action  and  Development  Plan  2024–2027  – 

includes prevention of threats and offences, including fraud and financial crime. 

• 

• 

• 

Internal Security Development Plan “Shaping a Preventive and Safe Living Environment” 
2025–2028  –  addresses  prevention  of  offences,  property  damage,  fraud  and  financial 
crime. 

“Estonia 2035” – strengthens rule of law and transparency, prevents cybercrime, enhances 
financial  supervision,  promotes  financial  and  digital  literacy,  and  supports  EU‑level 
cooperation. 

“Sustainable  Estonia 21”  – emphasises anti‑corruption, ethical standards, cyber‑security, 
financial  transparency,  public  awareness,  and  international  cooperation  (cross‑cutting 
relevance across all major policy areas). 

Special  Service  for  Institutional  Support  and  Information  Systems  (EYTHYPS)  is 
implementing a national sectoral strategy for the Structural Funds for 2021-2027. 

EL 

Recovery and Resilience Facility Special Coordination Service (EYSTA) has drawn up and 
implemented  an  anti-fraud  strategy  for  Recovery  Fund  actions  for  the  period  up  to  the 
completion of the National Recovery and Resilience Plan. 

Furthermore, there is the Independent Authority for Public Revenue’s 2022-2025 national 
anti-corruption strategy.’ 

ES 

•  Resolution of 27 February 2025, of the Directorate-General of the State Tax Administration 
Agency,  approving  the  general  guidelines  of  the  2025  Annual  Tax  and  Customs  Control 

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Member 
State 

Response 

Plan.  Scope:  tax  control  (VAT,  personal  income  tax,  etc.)  and  customs  control.  Period: 
2025. 

•  Strategic Plan of the Tax Agency. Scope: State tax system and customs system. Period: 

2024-2027. 

•  Ministry of Health: Strategy for the fight against corruption in the health sector. 

•  Scope: public health (specific funds: others). Period: indefinite. 

EU regional and structural policy anti-fraud plan 2021-2027, EU EAFRD and EAGF anti-
fraud strategy 2023-2027, European Maritime, Fisheries and Aquaculture Fund anti-fraud 
plan  2021-2027,  EU  Home  Affairs  Funds  irregularity  strategy  2021-2027,  Risk 
management and anti-fraud strategy – Finland’s recovery and resilience plan 2020-2026. 

The General Anti-Fraud  Strategy for  the implementation of the National Recovery and 
Resilience Plan, drawn up by the Ministry of Economic Affairs and Finance,  covers the 
entire period of the NRRP, i.e. from 2021 to 2026, and is not limited to a single economic 
sector, but covers all the measures financed by the plan, focusing on the prevention of 
four  main  risks  (defined  as  ‘the  four  financial  interests  of  the  EU’):  fraud;  corruption; 
conflict of interests; double funding. 

The Ministry of Economic Affairs and Finance – General National Accounts Department 
is  the  competent  authority  for  the  Recovery  and  Resilience  Facility,  covered  by  the 
national AFS for the period 2021-2026. 

FI 

IT 

LV 

EU Funds 2021-2027, RRF. 

MT 

NL 

The sectoral national AFS covers all European Funds availed of by Malta. The document 
is being revised on a regular basis depending on the  needs and future developments, 
especially when there are major amendments to EU and/or national legislation. 

Shared  management  funds  by  MFF  period.  In  addition,  the  anti-fraud  strategy  comes 
under  the  responsibility  of  Customs  regarding  import  duties.  Customs  has  an 
enforcement plan for this. 

PT 

Annual strategic plan to combat fraud in the area of tax and customs evasion. 

SI 

In  the  absence  of  a  national  strategy,  the  Ministry  of  Cohesion  and  Regional 
Development,  in  its  role  as  Managing  Authority  for  ESI  funds  in  Slovenia  (the  only 
Managing  Authority  in  Slovenia  for  Objective  1)  has  drawn  up  a  sectoral  anti-fraud 
strategy (with a corresponding action plan) for ESI funds, at the level of the programme 
for implementation  of ESI funds during the 2021-2027 period. The strategy covers the 
2021-2027 ESI programme (incorporating lessons learned from the past) and relates to 
ERDF, Cohesion Fund, ESF+ and JTF (Just Transition Fund). At programme level, the 
AFS covers the period of the 2021-2027 ESI programme. 

SK 

National Strategy for Combating Money Laundering (AML), Financing of Terrorism (CFT) 
and Proliferation of Weapons of Mass Destruction. Period: 2025-2030. 

Q.3.22 Please specify the period and areas covered by the sectoral regional 
AFS  (i.e.,  cohesion  funds,  agricultural  funds,  RRF,  customs,  VAT,  other).

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Member 
State 

Response 

•  The Lower Saxony ERDF managing authority: The 2021–2027 programming period – 

cohesion fund. 

•  The EU Paying Agency for Lower Saxony, Bremen and Hamburg: The strategy has been 
in place since 2015 and covers fraud prevention in Lower Saxony in relation to the EAGF 
and the EAFRD. 

DE 

•  The  Brandenburg  ERDF  managing  authority:  Anti-fraud  strategy  in  the  2021–2027 
Brandenburg  operational  programme  for  the  ERDF/JTF;  description  of  measures  to 
combat and prevent fraud, corruption, money laundering and conflicts of interest. 

EE 

HR 

EAFRD, EMFAF, RRF and EAGF 2021–2027: EU‑fund‑specific frameworks for the 2021–
2027 period, incorporating cross‑cutting anti‑fraud requirements. These frameworks are 
implemented at national level by PRIA (Agricultural Register and Information Board), which 
ensures compliance and applies the relevant control and prevention measures. 

Contribution from Ministry of Justice, Public Administration and Digital Transformation (in 
relation to the national Anti-Corruption Strategy): The current Strategy for the Prevention 
of Corruption adopted by the Parliament is in force and applies to the period from 2021 to 
2030.  The  Strategy  generally  focuses  on  the  prevention  of  corruption,  through 
strengthening  the  institutional  and  legislative  framework  for  the  fight  against  corruption, 
strengthening  the  transparency  and  openness  of  public  authorities,  and  improving  the 
system  of  integrity  and  conflict  of  interest  management  in  public  administration.  The 
strategy is implemented through the implementation of Action Plans for the period from 
2022 to 2024, from 2025 to 2027 and 2028 to 2030. The Strategy includes measure to 
strengthen the framework for preventing irregularities and fraud in the institutional use of 
ESI funds. To further strengthen the framework for preventing irregularities and fraud in 
the  institutional  framework  for  the  use  of  funds  from  ESI  funds,  the  rules  of  the  set 
framework  are  implemented  by  holding  meetings,  issuing  instructions  and  conducting 
training within the established Network of Coordinators in the field of public procurement, 
state aid and management of irregularities. 

Q.3.23 Please specify the authority concerned and the period covered by the 
authority level AFS.  

Member 
State 

Response 

•  Public service of Wallonia (PSW) ERDF Wallonia: All issues managed by the PSW as 
regional administration are covered by the regional strategy adopted in December 2023 
and updated in 2025 by the new COSTRA (Strategic  Committee). It covers all periods 
since that date. 

•  ESF Agency: On 9 September 2024, the Managing Committee of the MFWB (Ministry of 
the Wallonia-Brussels Federation) adopted an antifraud policy for the entire Ministry (not 
just European funds). A working group was set up to draft an action plan to put this policy 
into practice, coordinate it and monitor it. The cohesion policy and RRF funds managed 
by the MFWB are also covered. 

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BE 

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Response 

•  The paying agency (the State Agricultural Intervention Fund - SZIF), from the Common 

CZ 

Agricultural Policy 2014 onwards. 

•  The MA of the Ministry of Labour and Social Affairs, 2014 onwards. 

•  The  Rhineland-Palatinate  ERDF  managing 

authority:  Rhineland-Palatinate 
Administrative Regulation of 22 January 2019 on the  prevention of corruption in public 
administration (ref. FM – 0308-0004-0401 415, Rhineland-Palatinate Ministerial Gazette 
2019, p. 14). 

•  The Lower Saxony ERDF managing authority: The Lower Saxony ERDF/ESF+ managing 

authority. 

•  The EU Paying Agency for Lower Saxony, Bremen and Hamburg: The EU Paying Agency 
for Lower Saxony, Bremen and Hamburg along with the Lower Saxony Ministry of Food, 
Agriculture and Consumer Protection and subordinate authorities. 

DE 

•  The AMIF managing authority: For the 2021–2027 funding period, the AMIF managing 
authority  has  in  place  its  own  anti-fraud  strategy,  guidelines  and  a  management  and 
control system. 

•  The  Thuringia  ERDF  managing  authority:  The  Thuringia  ERDF  managing  authority, 

funding period 2021–2027 (2021–2029). 

•  The  Brandenburg  ERDF  managing  authority:  ERDF/JTF  managing  authority, 
Investitionsbank des Landes Brandenburg (ILB) as an intermediate body (for grants), the 
‘start-ups and business financing’ department of the Brandenburg Ministry of Economic 
Affairs,  Labour,  Energy  and  Climate  Action  as  an  intermediary  body  (for  financial 
instruments). 

DK 

Authority: The Danish Business Authority. Period: 2021-2027. 

Our implementing bodies have institution‑level fraud‑prevention  guidelines  and plans in 
place.  These  documents  are  regularly  updated  and  refined  based  on  ongoing  risk 
assessments,  ensuring  that  controls  remain  relevant  and  effective.  They  also  set  out 
cooperation  procedures  within  Estonia’s  national  anti‑fraud  network,  enabling  smooth 
information  exchange  and  the  sharing  of  good  practices  among  domestic  authorities. 
Where necessary, this national cooperation framework supports interaction with partners 
in the wider EU anti‑fraud community. 

Tax and Customs Board 2024-2027. 

Spanish Agricultural Guarantee Fund (FEGA): Strategy for the prevention, detection and 
combating of fraud and conflicts of interest. Scope: agricultural funds, affects all units of 
the  FEGA  paying  agency,  the  General  Secretariat,  the  Sub-Directorate  General  for 
Agricultural  Funds  and  those  units  outside  the  organisation  that  participate  (through 
delegation or joint action agreements) in the management and/or control of the measures 
and interventions concerned. Period: indefinite (updated in 2025). 

Contribution from the Ministry of Agriculture, Forestry and Fisheries (Paying Agency for 
Agriculture, Fisheries and Rural Development): The Paying Agency has adopted an Anti-
fraud strategy for the period 2023-2027.  

The Department of Agriculture, Food and the Marine, period covered is ongoing and will 
be as long as they are involved in EU funding. 

The Ministry of Economic Affairs and Finance – General National Accounts Department is 
the competent authority for the Recovery and Resilience Facility for the period 2021-2026. 

EE 

ES 

HR 

IE 

IT 

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State 

Response 

LU 

LV 

PL 

RO 

SI 

The Anti-Fraud Directorate of the Customs and Monopolies Agency is responsible for TOR 
from 2025 onwards. 

ERDF, ESF+ 

Corruption Prevention and Combating Bureau has adopted the Corruption Prevention and 
Combating Action Plan 2023–2025. 

The Agency for Restructuring and Modernisation of Agriculture (ARiMR, paying agency): 

The AFS covers all support programmes handled by ARiMR (agricultural funds, fisheries 
funds, the RRF and national programmes). 

Cohesion funds Anti-Fraud Strategy - Managing Authority for the 2021-2027 South-West 
Oltenia Regional Programme. 

As the coordinating body for implementation of the recovery and resilience plan (RRP), 
the Office of the Republic of Slovenia for Recovery and Resilience (URSOO) has adopted 
the anti-fraud strategy of the coordinating body of the Recovery and Resilience Facility for 
the  2021-2026  period,  i.e.  the  implementation  period  of  the  RRP.  Similarly,  all 
implementing bodies have adopted their anti-fraud strategies for the RRP implementation 
period.  For  the  AKTRP:  The  authority  is  the  Agency  of  the  Republic  of  Slovenia  for 
Agricultural Markets and Rural Development (AKTRP). The strategy relates to the current 
CAP programming period. 

Q.3.24 Please specify the programme concerned and the  period covered by 
the programme level AFS.  

Member 
State 

Response 

Public  service  of  Wallonia  (PSW)  ERDF  Wallonia:  The  Anti-Fraud  Statement  for  the 
ERDF/JTF programme ‘Wallonia 2021-2027’. 

BE 

Note: The RRF is covered by the regional AFS. 

•  The Rhineland-Palatinate ERDF managing authority: ERDF, 2021–2027. 

•  The EU Paying Agency for Lower Saxony, Bremen and Hamburg: EAFRD and EAGF, 

funding periods 2020-2024 and 2023–2027. 

DE 

•  The  ESF  Plus  Federal  Programme,  led  by  the  Federal  Ministry  of  Labour  and  Social 
Affairs (BMAS): The ESF Plus Federal Programme for the 2021–2027 funding period. 

•  The Bremen ERDF managing authority: The Bremen ERDF programme as of the 2021–

2027 funding period. 

•  The Brandenburg ERDF managing authority: The 2021–2027 funding period. 

DK 

EE 

      -       

EMFF 2014-2020 and EMFAF 2021-2027. 

EAFRD, EMFAF, RRF and EAGF 2021 - 2027: EU-fund-specific frameworks for the 2021-
2027 period, incorporating cross-cutting anti-fraud requirements. These frameworks are 

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Member 
State 

Response 

implemented at national level by PRIA (Agricultural Register and Information Board), which 
ensures compliance and applies the relevant control and prevention measures. 

•  Anti-fraud  strategy  for  Asylum,  Migration  and  Integration  Fund  (AMIF).  Period:  2021-

2027. 

•  Anti-fraud strategy for European Maritime, Fisheries and Aquaculture Fund (EMFAF). 

•  Period: 2021-2027. 

EU regional and structural policy anti-fraud plan 2021-2027, EU EAFRD and EAGF anti-
fraud strategy 2023-2027, European Maritime, Fisheries and Aquaculture Fund anti-fraud 
plan  2021-2027,  EU  Home  Affairs  Funds 
irregularity  strategy  2021-2027,  Risk 
management and anti-fraud strategy - Finland’s recovery and resilience plan 2020-2026. 

In  respect  of  ERDF,  this  is  relevant  for  the  managing  authorities.  For  example,  SEM 
Regional Programme 2021-2027 (Southern Regional Assembly). 

NRRP (2021-2026); TOR (2025 onwards). 

ERDF (yearly), ESF+ (2021-2027). 

Programme-level  strategies  cover  programming  periods  and  sectoral  funds  under  the 
responsibility of the Ministry of Agriculture (EAFRD, EAGF, EMFAF). 

The various cohesion policy programmes for the 2021-2027 financial perspective. 

•  Ministry  of  Development,  Public  Works  and  Administration:  Interreg  programmes.  The 
period covered is the implementation period + the project durability period for V-A 2014 
(5 years from completion of the last project) and VI-A 2021 (5 years from completion of 
the last project). 

•  Managing  Authority  for  the  South-West  Oltenia  Regional  Programme:  Cohesion  funds 

anti-fraud strategy. 

ES 

FI 

IE 

IT 

LU 

LV 

PL 

RO 

SI 

The 2021-2027 Cohesion Policy programme. 

Q.3.25 Please specify "Other" types of strategy adopted, including period and 
areas covered. 

Member 
State 

Response 

For Flanders, when drawing up an anti-fraud strategy, it is mainly envisaged to continue 
working on the basis of, on the one hand, the already existing parts of anti-fraud within 
Flemish  Government  (e.g.  whistle-blower  regulation,  deontological  codes,  …)  and  the 
anti-fraud strategies that (have to) be set up in the context of RRF and ESIF. 

•  National Coordination Authority - A strategy to fight fraud and corruption within EU funds, 
focusing on Cohesion Policy Funds and the entire programming period 2014-2020 and 
2021-2027. 

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BE 

CZ 

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Member 
State 

Response 

•  Ministry of Transport - Anti-fraud policy of the Ministry of Transport responds to the need 
to strengthen the prevention, detection and management of fraud within the activities of 
the Ministry, especially in the management of public funds, including EU funds. It focuses 
on setting uniform rules and procedures that support the principle of zero tolerance for 
fraud,  preventing  its  occurrence,  investigating  suspicions  and  taking  corrective 
measures. The policy applies to all organisational units of the Ministry of Transport and 
its employees. The Ministry of Transport adopted the Anti-Fraud Policy after 2018, as 
this  policy  explicitly  follows  on  from  Regulation  (EU)  2018/1046  of  the  European 
Parliament and of the Council of 18 July 2018. 

DE 

The AMIF managing authority has, for example, a management and control system, a 
risk management plan, fraud risk management, a funding manual, internal guidelines and 
audit documentation, and established reporting channels. They are all valid for the entire 
2021–2027 funding period. 

•  The National Police Strategic Plan 2022-2025 and the Civil Guard Strategic Plan 2021-
2024 set out specific objectives related to the prosecution of different forms of corruption, 
whose measurement indicators are based mainly on the number of operations carried 
out and the number of people arrested or investigated for public corruption offences. 

•  Order  PJC/327/2024  published  the  Agreement  of  the  National  Security  Council 
approving a new National Strategy against Organised Crime and Serious Crime, which 
aim  to  help  minimise  the  negative  consequences  associated  with  this  threat,  where 
corruption  phenomena  fit  in,  bring  criminals  to  justice,  dismantle  existing  groups  and 
prevent  the  emergence  of  new  ones.  The  published  Agreement  includes  an 
implementation guideline stating that the strategy will be aligned with EU priorities and 
international initiatives on the matter, where international cooperation and collaboration 
with European authorities will undoubtedly play a prominent role in the definition of this 
strategic document. 

• 

‘Strategic  Plan  to  Combat  Illicit  Enrichment  by  Criminal  Organisations  and  Offenders 
PELCEIL 2023-2025’, which aims to promote national schemes among the institutions 
involved  in  the  prevention  and  investigation  of  illicit  enrichment  and  its  associated 
activities, optimising coordination and interoperability through appropriate channels and 
tools, facilitating the exchange of information and adapting the corresponding regulatory 
framework for this purpose, both nationally and internationally, and strengthening in this 
regard the protection of the State against corruption. 

Government Resolution on the National Anti-Corruption Strategy and Action Plan 2025-
2027. 

Anti-Fraud strategies are adopted for each Government Department. These are updated 
by each Department periodically/ when necessary. 

The Mission Unit for the implementation of the NRRP (established under the Minister’s 
Private  Office  at  the  Ministry  of  Justice,  although  functionally  independent)  adopted  a 
dedicated  anti-fraud  strategy  aimed  at  preventing  and  combating  fraud,  serious 
irregularities,  corruption,  conflicts  of  interest  and  double  funding,  with  anti-money 
laundering checks on beneficial ownership and the transposition of the NRRP General 
Anti-Fraud  Strategy  (Circular  MEF-RGS  No  35/2023).  Further  strategies  include  the 
creation  of  an  on-going  service  for  reporting  anomalies,  with  the  aim  of  uncovering 
potentially  fraudulent  behavioural  patterns  by  involving  affected  communities  and 
relevant  stakeholders.  In  addition,  a  multiannual  environmental  monitoring  project  has 
been launched, aimed at detecting and preventing environmental crimes that could have 

ES 

FI 

IE 

IT 

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State 

Response 

a potential impact on the financial interests of the European Union. Both initiatives help 
to  strengthen  our  ability  to  detect  risks  early  and  complement  the  anti-fraud  system’s 
preventive approach. 

Q.3.26  Is  there  a  national  anti-fraud  network  in  your  Member  State? 

Response 

Frequency  Member States 

Yes 

No 

23 

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

4  DE, LT, PT, SI 

Q.3.27  How  has  your  national  anti-fraud  network  evolved  in  terms  of 
structure and/or involvement since its establishment? 

Member 
State 

Response 

BE 

BG 

CY 

CZ 

DK 

Through a complex process involving the institutional landscape. There are difficulties in 
implementing it, particularly due to a lack of resources. 

There  is  an  increase  in  cooperation  and  information  sharing  between  the  national  anti-
fraud  institutions.  There  is  also  an  improvement  in  cooperation  and  exchange  of 
information  regarding  the  follow-up  actions  taken  by  the  Prosecutor's  Office  of  the 
Republic of Bulgaria, including in relation to the status of cases in the pre-trial phase. 

Was established in 2002 under a Council of Ministers decision and codified into law in May 
2024. There are plans to further enhance/update the legislation to incorporate the aims of 
the NAFS. 

With the start of National Recovery Plan, relevant bodies (Component owners, Delivery 
unit) were added to the network. With the start of operation of EPPO, the involvement of 
the Police of the Czech Republic increased instead of the Prosecutor General’s Office. 

Following the adoption of the OLAF Regulation in 2013, the Danish AFCOS Network was 
established  in  order  to  ensure  coordination  between  relevant  competent  authorities  in 
Denmark.  Besides  the  Ministry  of  Finance,  the  network  consists  of  the  authorities  that 
manage  EU  spending  programmes  under  shared  management,  those  that  collect  the 
Danish  own  resource  contribution  (customs),  and  those  that  investigate  and  prosecute 
criminal cases of fraud involving EU funds. Several cooperative agreements have been 

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State 

Response 

made between the network-authorities. These ensure cooperation on the control against 
double  financing  in  EU-funded  projects.  Also,  they  aim  at  enhancing  the  authorities’ 
cooperation on antifraud matters in general. The AFCOS Network meet at least once a 
year or as required. 

Estonia’s national anti‑fraud network has been operating since 2003 and currently brings 
together 15 institutions involved in protecting the EU’s financial interests. 

The  structure  has  remained  stable,  and  cooperation  has  deepened  over  time  through 
regular  information  exchange  and  coordinated  approaches  to  fraud  prevention  and 
reporting.  In  recent  years,  cooperation  has  become  more  needs‑based,  and  in‑person 
meetings  have  taken  place  less  frequently,  although  the  network  continues  to  function 
effectively due to Estonia’s small size and strong inter‑institutional cooperation culture. 

In accordance with Article 28 of Law 4914/2022, an internal cooperation network between 
the Managing Authorities of the, coordinated by EYTHYPS, has been set up to prevent 
and combat fraud for the 2021-2027 programming period. 

According  to  Article  49  of  the  same  Law,  the  Anti-Fraud  Internal  Cooperation  Network 
between  the  Managing  Authorities  of  the  ESPA  programmes  supports  the  work  of  the 
competent Managing Authorities to ensure the implementation of anti-fraud measures and 
assess their effectiveness. The Network aims to develop a common understanding on the 
prevention  and  combating  of  fraud,  and  to  exchange  knowledge,  experience  and  good 
practice on how to apply the relevant prescribed procedures, problem-solve, and further 
improve  and  adapt.  The  exchange  of  information  and  transfer  of  expertise  between 
members  of  the  Anti-Fraud  Internal  Cooperation  Network  will  take  place  on  the 
Management Organisation Unit of Development Programmes’ intranet (‘DIAVLOS’). 

With  regard  to  the  AFCOS  network,  the  Advisory  Council  for  the  Prevention  and 
Combating of Fraud against the Financial Interests of the European Union is a collegiate 
body  that  provides  advice  and  support  to  AFCOS,  in  which  the  bodies,  entities  and 
institutions  with  competences  in  the  management,  control,  prevention  and  fight  against 
fraud are broadly represented and which, therefore, participate in one way or another in 
the  adoption  and  implementation  of  such  measures  and  actions.  The  structure  has 
remained stable since its creation in 2019. 

On the other hand, the Network of Anti-Fraud Offices and Agencies of the Spanish State, 
established  in  2018  by  the  anti-fraud  offices  and  agencies  existing  at  that  time,  has 
considerably increased its membership, as other public institutions, administrations and 
public entities have been created and assigned functions in these areas since that date. 
The purpose of this network is to share experiences and knowledge in order to improve 
the performance of its functions and the achievement of objectives of common interest, as 
well  as  to  establish  coordination  systems  and  a  platform  for  cooperation,  information 
exchange  and  the  development  of  proposals  for  the  effective  fight  against  fraud  and 
corruption. 

The network includes all ministries managing EU-funded programmes and funds (Ministry 
of  Finance,  Ministry  of  Economic  Affairs  and  Employment,  Ministry  of  Agriculture  and 
Forestry, Ministry of the Interior), the Finnish Food  Authority as the  paying authority for 
agriculture  and  rural  development  and  market  support,  and  the  State  Treasury  as  the 
authority  responsible  for  financial  monitoring,  reporting  and  control  of  the  RRF.  The 
network includes representatives from Finnish Customs, Police and the National Bureau 
of Investigation. In total the network is made up of around 60 civil servants. It  also has 
links to the audit and certifying authority, to OLAF and to the EPPO. The national AFCOS 
contact point is responsible for network activities. 

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EE 

EL 

ES 

FI 

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Member 
State 

Response 

FR 

The  national  anti-fraud  network  is  constantly  being  strengthened  through  the  specific 
measures taken as part of the strategy, most of which require major coordination between 
stakeholders. 

The AFCOS Network has been established in 2008 and has been the same since the very 
beginning. It consists of administrative and criminal bodies, namely: 

•  Ministry of Justice, Public Administration and Digital Transformation 

HR 

HU 

IE 

IT 

•  Ministry of the Interior 

•  Ministry of Finance – Tax Administration 

•  Ministry of Finance – Customs Administration 

•  Ministry of Finance – Anti-Money Laundering Office 

•  Ministry of Finance – Sector for Financial and Budgetary Supervision 

•  Ministry  of  the  Economy  –  Directorate  for  Public  Procurement  Policy,  Sector  for 

Implementation of Public Procurement Policy 

•  State Attorney's Office of the Republic of Croatia and 

•  Agency for the Audit of the European Union Programme Implementation System. 

Institutions  with  responsibilities  and  powers  in  the  field  of  the  protection  of  the  EU’s 
financial interests delegate experts to the European interdepartmental committee’s OLAF 
expert group. The working group monitors domestic institutional changes through changes 
in the members delegated. 

The anti-fraud network, called the AFCOS network, has evolved both in terms of the size 
of the group and the more regular meetings. The group includes all reporting authorities 
and key stakeholders in Ireland, with the colleagues responsible for the upcoming Social 
Climate  Fund  attending  for  the  first  time  in  2025.  The  meetings  are  quarterly,  or  as 
required. 

The Network of NRRP Anti-Fraud Contact Persons was established by Decision No 57 of 
9 March 2022 of the State General Accounting Department, alongside the Committee for 
Reporting and Control, with the task of supporting central administrations responsible for 
NRRP measures and  the implementing bodies involved  in  fraud risk management. It is 
chaired by  a senior official of the Inspectorate General  for the NRRP (IGPNRR) and  is 
made up of officials from the Ministry of Economic Affairs and Finance, officers from the 
Guardia di Finanza, as well as officials from the Anti-Fraud Directorate of the Customs and 
Monopolies  Agency  and  other  anti-fraud  contact  persons  designated  by  each  central 
administration responsible for NRRP measures and COLAF duties. 

LU 

There is an anti-fraud committee in place.  

Since 2007, the Latvian AFCOS Council has evolved from a small coordination mechanism 
into  a  comprehensive,  multi‑agency  national  anti‑fraud  network.  In  2014,  the  Council’s 
structure and mandate were formalized through Government Regulation, which defined its 
tasks,  rights,  and  working  procedures.  This  increased  institutional  clarity  and  broadened 
working  scope.  Over  time,  the  AFCOS  Council  widened  its  membership  significantly. 
Today, it includes 22 different authorities: 

- Managing authorities; 

- Law‑enforcement institutions (State Police, Prosecutor’s Office, EPPO); 

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Response 

- Control and oversight bodies (State Audit Office, SRS, KNAB); 

- Line ministries; 

- Permanent experts from specialised agencies and NGOs. 

A major development occurred in 2017, when the Government approved the first AFCOS 
Operational  Strategy  (NAFS),  strengthening  cooperation  mechanisms  and  establishing 
shared goals across institutions. Since that time 3 NAFS were adopted and implemented. 

Increasing  frequency  and  depth  of  engagement  -  the  Council,  which  must  meet  at  least 
twice  per  year,  has  evolved  to  hold:  more  frequent  thematic  meetings;  targeted  expert 
discussions; follow‑up sessions on suspected fraud cases. 

The structure of the network has remained the same. In addition, the implementation of 
the  NAFCS  Action  Plan  contributed  to  more  involvement  amongst  the  members  of  the 
network. 

All relevant parties have joined the anti-fraud network. There are regular meetings at which 
current developments and case studies are discussed. 

Poland  does  not  have  a  formalised  national  anti-fraud  network.  However,  in  cohesion 
policy, for example, there is anti-fraud cooperation (based on agreements and contracts) 
with institutions outside the management and control system. In 2025, steps were taken 
to  broaden  the  network:  an  agreement  is  currently  being  prepared  on  the  electronic 
transmission  to  the  organisational  units  of  the  Police  of  information  collected  in  the 
CST2021 IT system, which supports programme implementation. 

Following  the  adoption  of  the  strategy,  all  the  networks  and  working  groups  within  the 
national anti-fraud system became operational. During the two years of implementation of 
the strategy, these groups underwent structural changes to adapt to the specific activities 
outlined in the strategy’s action plan. Over time, the work has become more substantial in 
terms of both quality and quantity in order to adapt to the working methods, procedures 
and activities to be implemented. 

MT 

NL 

PL 

RO 

SE 

Linked to RRF, the number of authorities included in the network has increased. 

(2)  The  National  Anti-Fraud  Network  is  a  system  of  authorities  and  institutions  of  the 
Slovak Republic, the main objective of which is cooperation in the performance of tasks in 
the field of protection of the interests of the European Union. It consists mainly of authorities 
and institutions: 
•  which provide EU funds and otherwise manage these funds, 

•  which control the management of these funds, 

SK 

•  with the authority to perform tasks related to the protection of the EU's financial interests. 

This network has been expanded since its establishment due to new tasks arising from EU 
and  Slovak  legislation  (e.g.  NICA  for  RRF  implementation,  CSIRT  -  government  unit  in 
relation to cyber threats, AMLA contact point- Financial Intelligence Unit of the Presidium of 
the Police Force as part of the Ministry of the Interior of the Slovak Republic., etc.). The 
network currently has 22 partners. 

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Q.3.28  Does  AFCOS  have  a  key  role  in  your  national  anti-fraud  network? 

Response 

Frequency  Member States 

Yes 

No 

19 

BE,  BG,  CY, 
CZ, DK, EE, EL, 
ES, FI, FR, HU, 
IE,  IT,  LV,  MT, 
NL, RO, SE, SK 

4  AT, HR, LU, PL 

Q.3.29  Please  specify  the  role  of  the  AFCOS  in  your  anti-fraud  network. 

Member 
State 

Response 

BE 

BG 

CY 

The AFCOS network is presided by the Secretariat which is housed at the Fraud Control 
Department of the Directorate General Economic Inspection. The role of the BE AFCOS 
Secretariat has heavily increased since 2021 and the installation of the RRF fund. Since 
then, they developed their role as the Belgian Anti-fraud Knowledge Centre where they 
have  trained  the  all  BE  AFCOS  stakeholders  on  Fraud,  Risk  Management  and  How  to 
organise  an  on-the-spot-check.  Also,  on  an  international  scale  the  Secretariat  of  BE 
AFCOS is seen as a valued partner in the development of new anti-fraud technologies and 
a welcome knowledge centre for the training of other Member States. 

The  AFCOS  Directorate  in  Bulgaria  carries  out  control,  information  and  coordination 
activities related to the protection of the EU's financial interests, and acts as a coordination 
service for combating fraud in the implementation of the NAFS. The AFCOS Council took 
a decision to designate the AFCOS Directorate as a structure responsible for governing 
the processes of planning, monitoring and reporting the NAFS. 

AFCOS is the national anti-fraud network as it is a coalition of public authorities that deal 
with EU funded projects and/or fraud investigations. 

•  Coordination of administrative investigation and on-the-spot controls by OLAF. 

•  Ensures the submission of regular and extraordinary reports on irregularities detected in 
the  implementation  of  European  funds  in  individual  programming  periods  and  in  the 
implementation of the Recovery and Resilience Facility, while the input data is provided 
by the relevant bodies within the network. 

CZ 

•  Based on the analyses carried out, compiles a typology of irregularities that have occurred 
in the context of regular reporting of irregularities at the external level, in the context of 
the implementation of the RRF 

• 

Is  responsible  for  elaboration  and  regular  updates  of  the  National  Strategy  for  the 
Protection of the EU's Financial Interests and of the Methodological Guideline regulating 
the  methodology  for  reporting  irregularities  at  the  external  level  to  OLAF,  or  the 
methodology regulating the area of irregularities in the implementation of the RRF. 

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Report 2024 

Member 
State 

Response 

DK 

EE 

EL 

ES 

FI 

FR 

The role as AFCOS is placed with the Danish Ministry of Finance who acts as the head of 
and  coordinator  of  the  AFCOS  Network.  The  Ministry  of  Finance  has  no  investigative 
function.  The  responsibility  for  the  fight  against  fraud  is  decentralised  to  the  competent 
authorities of the network. 

AFCOS  maintains  direct  contact  with  representatives  of  all  institutions  in  the  national 
anti‑fraud network. The level of involvement varies: some partners are more active due to 
their operational role, while others participate more passively. 

AFCOS  shares  relevant  information  with  network  members  —  including  updates  on 
meetings, audits and Commission activities — and involves them in Commission working 
groups  and  discussions.  AFCOS  also  organises  meetings  and  coordinates  cooperation 
between the institutions as needed. 

In the context of the national anti-corruption action plan for 2022-2025, the AFCOS played 
a key role in drawing up sectoral anti-fraud strategies for the Asylum, Migration and Home 
Affairs Fund and the agricultural funds. The AFCOS is also part of the ESPA Secretariat-
General’s anti-fraud network and has a website (afcos.aead.gr) on which 58 accredited 
competent anti-fraud bodies that protect the EU’s financial interests are registered. 

In the case of the Advisory Council for the Prevention and Combating of Fraud against the 
Financial Interests of the European Union, this is an advisory body to AFCOS, which holds 
its vice-presidency and secretariat. 

The Government Financial Contoller´s function of the Ministry of Finance was designated 
as the national anti-fraud contact point in 2014. This function helps cooperation between 
OLAF  and  EU  Member  States’  authorities,  maintains  and  develops  contacts  between 
OLAF  and  national  competent  authorities,  coordinates  national  cooperation  and  the 
promotion  of  anti-fraud  awareness,  and  responds  and  coordinates  OLAF’s  requests  for 
information. 

It has been strengthened in particular in the fight against fraud involving public aid, notably 
aid financed through the NRPP. In order to take a systematic approach to the proliferation 
of large-scale fraud involving national and European public aid, a decision was made to 
set up a new specific interministerial mechanism for monitoring and analysing fraud risks. 
This mechanism is intended to identify and appraise as early as possible the potential risks 
of fraud linked to the establishment of national and European public aid schemes and to 
organise a rapid and concerted institutional response. To this end, Decree No 2023-663 
of 26 July 2023 instructed the MICAF to set up an interministerial unit to monitor public aid 
fraud, bringing together all the administrations and competent administrative investigation 
services as well as the specialised judicial investigation services. 

HU 

AFCOS is responsible for coordinating the tasks of the working group set out in point 3.27. 

IE 

IT 

      -       

AFCOS  hosts  the  meeting  (i.e.  it  takes  place  in  the  Department  of  Finance,  AFCOS 
coordinates attendance and sets the initial agenda), For many items, AFCOS will chair but 
take input from all members to ensure that the meeting adds as much value as possible. 

Pursuant to Article 3(3) of the Decision of 9 March 2022 of the State General Accounting 
Department,  the  meetings  of  the  Network  are  to  be  attended  by  experts  and/or 
representatives  (determined  by  the  issues  to  be  dealt  with)  from  the  Committee  for 
Combating  Fraud  against  the  European  Union  (COLAF  –  Italian  AFCOS),  established 

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Member 
State 

Response 

pursuant to Article 54 of Law No 234 of 24 December 2012 at the Department for European 
Affairs of the Prime Minister’s Office. 

•  AFCOS  acts  as  Latvia’s  central  coordination  service  for  all  matters  related  to  the 
protection  of  the  EU  budget,  ensuring  implementation  of  a  unified  national  policy.  It 
coordinates  between  managing  authorities,  law‑enforcement  bodies,  supervisory 
institutions, and EU bodies. 

•  Official Contact Point for cooperation with OLAF  - AFCOS is the nationally designated 
contact  institution  for  cooperation  with  OLAF.  It  evaluates  OLAF  information  requests, 
helps determine competent national authorities, and supports OLAF during on‑the‑spot 
checks. 

LV 

•  Secretariat and lead institution of the AFCOS Council (National Anti‑Fraud Network) - the 
EU  Funds  Audit  Department  of  the  Ministry  of  Finance  as  AFCOS  serves  as  the 
secretariat of the AFCOS Council, organising meetings, preparing agendas, coordinating 
follow‑up actions, and ensuring continuous information flow between institutions. 

•  Coordinates the development and implementation of NAFS - AFCOS is responsible for 
coordination of preparation of NAFS, submits NAFS to the Government for adoption, as 
well as coordinates the implementation of the NAFS and Action Plan. 

•  AFCOS maintains its social awareness campaign "Fraud Off" and coordinates AFCOS 

network activities held within this campaign. 

MT 

NL 

RO 

The Financial Investigations Directorate (FID), in its role as the Maltese AFCOS, is one of 
the members of the anti-fraud network. 

The  AFCOS  is  responsible  for  coordinating  the  anti-fraud  network,  acts  as  the  contact 
point for the European authorities (including for requested reporting) and provides support 
for fraud reports (where necessary). 

DLAF  (AFCOS  Romania)  is  the  institution  responsible  for  liaising  with  OLAF  and 
coordinating the fight against fraud at national level, to ensure that Romania’s obligations 
under Article 325 of the Treaty on the Functioning of the European Union are met. In its 
capacity  as  AFCOS,  DLAF  coordinates  the  implementation,  updating  and  evaluation  of 
the strategy. 

The instrument through which the strategy is implemented is the action plan, which sets 
out  objectives,  measures  and  deadlines  for  implementing  those  measures,  and  the 
institutions responsible for that implementation. 

SE 

Calls meetings and organises working groups. 

institutions  and 

AFCOS performs tasks related to ensuring the protection of the EU's financial interests in 
the  Slovak  Republic  through  coordination  of  the  preparation  and  implementation  of 
legislative, administrative and operational activities and cooperation between all interested 
national 
the  necessary 
the  European  Commission, 
communication and educational activities. Its task is to ensure effective cooperation and 
exchange of information with OLAF, including information of an operational nature. One of 
the important tasks of the AFCOS is to receive and monitor all irregularities detected and 
revealed  violations  of  the  rules  in  the  use  of  EU  funds,  as  well  as  suspicions  of  their 
violation (i.e. irregularities and suspicions of irregularities), subsequently analyse them and 
report them to the OLAF/European Commission. Another important task of the AFCOS is 

including 

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SK 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Member 
State 

Response 

performing  control  activities  and  dealing  with  allegations/notifications  submitted  by  the 
public for the purpose of protecting the EU's financial interests in the Slovak Republic. 

Q.3.30  Has/How  has  the  national  anti-fraud  network  contributed  to  the 
elaboration of the NAFS?   

Member 
State 

Response 

BG 

CY 

To effectively update the NAFS, a working group has been formed with the participation 
of all national competent  institutions. The working group is actively involved in the mid-
term evaluation and update of the NAFS. 

All members participated in the process through interviews and workshops and provided 
feedback  on  the  draft  NAFS  and  the  relevant  KPIs.  In  addition,  we  asked  for  the 
contribution of non-AFCOS members, such as EPPO, the Ministry of Justice and the Anti-
corruption Authority. 

CZ 

The members of the network contributed to the content of the NAFS and its updates. 

EE 

The  national  anti‑fraud  network  has  not  contributed  to  the  elaboration  of  a  NAFS,  as 
Estonia  has  not  developed  a  standalone  national  anti‑fraud  strategy.  The  functions 
normally covered by a NAFS are addressed through existing sector‑specific strategies and 
established inter‑institutional cooperation mechanisms. 

EL 

There is no national anti-fraud strategy. 

ES 

FI 

A  specific  commission  was  set  up  within  the  Advisory  Council  for  the  Prevention  and 
Combating of Fraud against the Financial Interests of the European Union to draw up the 
NAFS.  It  was  made  up  of  15  members,  including  a  representative  from  the  Spanish 
Network of Anti-Fraud Offices and Agencies. 

Preliminary discussions on the development of a national anti-fraud strategy for the next 
financial framework period have taken place in the network. 

FR 

Yes. 

HR 

HU 

IE 

IT 

      -       

Every AFCOS Network authority contributed to the elaboration of the strategy within their 
scope of work. 

Several members of the working group mentioned in  the answer to question  3.27 were 
involved in developing the NAFS and are currently involved in implementing and updating 
it. 

Any elaboration of a NAFS will incorporate involvement of the AFCOS Network. 

In accordance with Article 3 of Decree-Law No 19/2024, the Chair of the Network of NRRP 
Anti-Fraud  Contact  Persons  was  included  among  the  members  of  COLAF  (Italian 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the PIF 
Report 2024 

Member 
State 

Response 

AFCOS), and thus actively participated in the drafting of the National Anti-Fraud Strategy 
(NAFS). 

LU 

The audit authority is verifying and checking the existing AFS on a regular basis. 

LV 

MT 

NL 

PL 

RO 

All the authorities from the AFCOS network participated in the elaboration of NAFS, jointly 
they carried out fraud risk assessment, defined strategic goals and activities to be included 
in the NAFS. 

Through, amongst others, knowledge sharing and the provision of information, both during 
meetings and written procedure. 

The NAFS was drawn up in consultation with the national anti-fraud network. All parties 
thus contributed to the content of the NAFS. 

Poland has not adopted a NAFS. 

Since  April  2022,  to  facilitate  communication,  DLAF  has  coordinated  the  designation  by 
national institutions involved in protecting the EU’s financial interests in Romania of persons 
responsible for the strategy. 
DLAF  has  coordinated  and  centralised  the  institutions’  contributions,  which  highlighted 
elements of anti-fraud activity specific to each institution. These contributions include: 
•  a description of the legislative and institutional context, including the main applicable laws 
and  regulations,  and  the  institution’s  role  in  the  management  and  control  of  European 
funds,  in  preventing,  detecting,  investigating  or  prosecuting  irregularities  or  crimes 
affecting  the  financial  interests  of  the  European  Union  in  Romania,  and  in  recovering 
related budgetary claims, as appropriate; 

•  a  SWOT  analysis  reflecting  the  institution’s  current  anti-fraud  position,  including  its 

strengths, areas for improvement, opportunities and risks/vulnerabilities; 

• 

results of  the risk analysis  conducted at institutional level on fraud  involving European 
funds; 

•  main  issues  identified,  along  with  possible  solutions  to  remedy  them,  which  could  be 

included among the strategy’s objectives. 

SE 

There is no national anti-fraud strategy. 

SK 

Submission of supporting documents, expert input and proposals for measures for specific 
protections of financial interests relating to both the revenue and expenditure parts of the 
EU budget. 

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