COMMISSION STAFF WORKING DOCUMENT Commission Anti-Fraud Strategy (CAFS) Action Plan Implementation monitoring: state of play 31 May 2026 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) 246 final  COMMISSION STAFF WORKING DOCUMENT Commission Anti-Fraud Strategy (CAFS) Action Plan     Implementation monitoring: state of play 31 May 2026 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) 247 final} - {SWD(2026) 248 final} - {SWD(2026) 249 final} - {SWD(2026) 250 final} - {SWD(2026) 251 final}  
 
 
LIST OF ABBREVIATIONS  

AFCOS  

Anti-Fraud Coordination Service  

AFIS  

CAFS 

CAP  

Anti-Fraud Information System  

Commission Anti-Fraud Strategy 

Common Agricultural Policy  

COCOLAF 

Advisory Committee for the Coordination of Fraud Prevention 

CBAM  

Carbon Border Adjustment Mechanism 

DAC 

DG 

ECA 

Common Audit Directorate of DG REGIO and DG EMPL 

Directorate-General 

European Court of Auditors 

EMFAF 

European Maritime, Fisheries and Aquaculture Fund 

EDES 

EEAS 

EIPA 

Early Detection and Exclusion System 

European External Action Service 

European Institute of Public Administration 

EMPACT 

European Multidisciplinary Platform Against Criminal Threats 

EPPO    

European Public Prosecutors’ Office  

EPSO 

ETS 

EUCI 

European Personnel Selection Office 

Emissions Trading System 

EU classified information 

FPDNet 

Fraud Prevention and Detection Network 

GETI 

GIPs 

IDOC 

IMS 

JRC 

MFF  

NAFS    

OLAF    

PIF  

RRF  

Get Intelligence system 

Guidelines on Investigative Procedures 

Investigation and Disciplinary Office 

Irregularity Management System  

Joint Research Centre 

Multiannual Financial Framework  

National Anti-Fraud Strategy  

European Anti-Fraud Office  

Protection of the EU’s Financial Interests  

Recovery and Resilience Facility  

SOCTA 

Serious and Organised Crime Threat Assessment 

TSI 

Technical Support Instrument 

UAFP   

Union Anti-Fraud programme 

UNCAC 

United Nations Convention against Corruption 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
INTRODUCTION 

On 11 July 2023, the Commission adopted its revised Commission Anti-Fraud Strategy (CAFS) action 
plan1. It includes 44 actions under seven themes that cover the Commission’s priorities in fighting fraud. 

This  document  presents  the  state-of-play  of  the  individual  actions  of  the  plan  and  is  part  of  the 
monitoring  of  the  CAFS  action  plan  implementation.  It  has  been  prepared  in  consultation  with 
Commission departments and Executive agencies to accompany the 2025 Report on the protection of 
the European Union’s financial interests, the so-called PIF report. 

The text in blue represents the actions as published in July 2023, while the remaining text reflects the 
state-of-play of the implementation of the actions on 31 May 2026.  

1 COM(2023) 405 final and SWD(2023) 245 final. 

1 

 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
1 

Further develop, promote and increase the use of the current Arachne system in the Commission and in Member 
States notably by increasing user-friendliness and exploring possibilities for interoperability and synergies with 
other corporate IT tools as well as national databases. 

Due date 
2023 and 
continuous 

Lead 
DAC, EMPL: 
lead 
Shared 
management 
DGs, JRC: 
support 

State-of-play May 2026 

Arachne+2 is currently being progressively deployed, with onboarding activities started after service activation of 28 April 2026 and currently ongoing across 
the Commission and Member States, while the decommissioning of the current Arachne solution is foreseen after the completion of the onboarding activities. 
Since 2024, the Commission has been strongly promoting Arachne with Member States. The number of users increased by 56,31% between 1 January 2024 
and 1 May 2026, reaching the total of 26,084 users. 

Currently, 23 Member States are using Arachne+ on a voluntary basis and at different level of intensity, among which 18 for CAP3 and 19 for RRF4 purposes. 
The migration from Arachne to Arachne+ will start for all Member States to be implemented by 30 June 2026. DG BUDG has also reinforced the resources 
dedicated to the project to ensure it is fully operational for all management modes for the next MFF by 1 January 2028. Feeding Arachne+ with data will be 
compulsory from 1 January 2028. To this end, the Commission is providing technical support and training to Member States. 

2 Arachne+ is a risk-scoring and data-mining tool, built up on the previously existing legacy Arachne, which is being developed to bring several important changes, e.g. cover 
  all management modes. 

3 Belgium, Croatia, Cyprus, Denmark, Estonia, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Netherlands, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden. 

4 Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Finland, Greece, Hungary, Ireland, Italy, Latvia, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, 
  Slovenia. 

2 

 
 
 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
2 

Continue developing the envisaged single integrated IT system (corporate Arachne) for data 
mining  and  risk  scoring,  in  line  with  the  Interinstitutional  Agreement  and  the  RRF 
Regulation5,  with  a  view  to  extend  its  use  to  all  Member  States  and  to  all  management 
modes. 

Lead 
BUDG, DAC, EMPL: lead 
Spending DGs, OLAF, DIGIT, 
JRC: support 

Due date 
2023 and 
continuous 

State-of-play May 2026 

While the Commission proposed the mandatory use of the integrated IT system ‘Arachne+’, the Regulation (EU, Euratom) 2024/2509 on the financial rules 
applicable to the general budget of the Union  does not make its use obligatory. Nevertheless, all texts (including the Inter-institutional Agreement – ‘IIA’) 
contain  a  commitment  by the  Commission to  provide  Member  States  with  a single  data-mining  tool that  they  can  voluntarily  use  for  control  and  audit 
purposes, with a view to a generalised application by Member States. The Commission will keep doing its utmost to encourage the Member States to use this 
data-mining tool. A joint statement annexed to the Regulation underscores the Commission's commitment to evaluate the tool's readiness by 2027, with the 
aim to potentially reopen negotiations on its compulsory use. 

The transition to the new tool reached an important milestone with Service Activation on 27 April 2026, in spite of some delays, which have been duly 
reported and acted upon. Significant improvements have been achieved in several areas of the project, in particular in relation to its governance, as a follow 
up to this audit. Following Service Activation, Phase 3 of the project has commenced and will deliver the governance, data, interoperability, risk analysis, 
and AI-related capabilities needed to make the system operationally ready and compliant. 

At the same time, to foster cooperation between the Commission and Member States in developing the tool and preparing for its readiness assessment by the 
end of 2027, the Commission will keep on organising the regular Expert Group meetings throughout 2026, focusing on risk indicators, interoperability, 
artificial intelligence, and data protection. So far, a meeting on data protection took place on 19 February 2026, and a meeting on risk indicators is foreseen 
for 2 June 2026. Three more Expert Group meetings are planned for the year.  

So far, 19 Member States use Arachne+ for RRF6 purposes, including two Member States with dedicated milestones in their RRPs (PL, HU). Other Member 
States use alternative systems.  

5 Regulation (EU) 2021/241. 

6 Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Finland, Greece, Hungary, Ireland, Italy, Latvia, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, 
  Slovenia. 

3 

 
 
 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
3 

Further develop and increase use of EDES in the Commission and in Member States based on user feedback, in view of its 
possible extension to shared management, notably by: 

Lead 
BUDG 

Due date 
2023 and 
continuous 

increasing the user-friendliness of the database; 

a. 
b.  exploring possibilities for interoperability and synergies with other corporate IT tools as well as national databases; 
c.  enhancing  dialogue  on  EDES  among  Commission  departments  and  Executive  agencies,  other  EU  institutions, 

Member States and implementing partners. 

State-of-play May 2026 

The Commission has continuously stressed the importance and benefits of the Early Detection and Exclusion System (EDES) in protecting the Union budget, 
notably for the prevention and detection effects on fraud and unreliable behaviours, and for ensuring effective sanctions. 

a. The Commission has made several improvements to enhance the user-friendliness of the EDES Database, including the introduction of a new feature 
allowing users to create a case by importing a Business Partner (BP) number from SUMMA. To ensure consistency with the use of SUMMA, a popup 
warning now appears when sending a case for validation in the EDES database to confirm the absence of BP number. In addition, as of October 2026, two 
factor authentication will be required to access to EDES also for accounts external to the EU Institutions.  

b. The Commission is continuously improving the connection between the EDES database and ECFIN, the new corporate financial system lauched in February 
2025 by integrating in the EDES database new search features using the BP number. The efforts in connecting the EDES database to other Corporate tools 
are progressing. After the development of a new web service that would allow external organisations (including Member States authorities) to connect to 
EDES database, the corporate application eSubmission was connected to EDES search Web Service. A survey on the EDES-IMS interface has been circulated 
among EDES users, the results of the survey were presented at the FDPNet in November 2025. 

c. The Commission maintains and fosters internal dialogue and with partners by further developing guidance and training on EDES. Over the reporting 
period, in addition to five regular EDES courses, the EDES experts’ platforms were organised in July and November 2025. In September and October 2025, 
two ad hoc training sessions on EDES were dedicated to EP staff including one for trainers’ capacity building. The script for a video capsule on EDES titled 
‘Who should be afraid of EDES? Navigating EDES: Preparing an effective EDES file and knowing when to approach the EDES panel’ is in preparation and 
the filming will be done in the second half of 2026. This video will guide the Authorising Officers in the use of EDES, when making referrals to the EDES 
Panel. In addition, the video tutorial on how to use the EDES database is also under development. The update of the guidelines on ‘effects of an exclusion 
on ongoing legal commitments’ and a Vademecum on EDES is in the final stages and the guidelines will be published in the second half of 2026. 

4 

 
 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
4 

Explore the possibility to strengthen the anti-fraud functionalities in SUMMA, notably by: 

a.  considering the creation of a dashboard on unusual patterns in transactions to detect potential 

irregularities and provide analysis to DGs; 

b.  considering,  after  the  SUMMA  go-live,  a  screening  of  other  databases  such  as  Arachne  and 
commercial  databases  via  the  SUMMA  Business  Partner  Integrity  Screening,  similar  to  the 
envisaged screening of EDES and the Financial Sanctions Database, and exploring if and how 
these anti-fraud functionalities could be used in the Commission and beyond; 

Lead 

Due date 

BUDG: lead 
OLAF, spending DGs: 
support 
BUDG: lead 
DAC, EMPL: support 

2025 

2025 

c.  considering additional controls of business partners (legal entities). 

BUDG 

2025 

State-of-play May 2026 

Following the exploratory phase carried out in 2025, DG BUDG has further progressed on its path to strengthening of anti-fraud functionalities related to 
Business Partner data in SUMMA. 

A  Project  Initiation  Request  (PIR)  for  a  Business  Partner  Compliance  &  Risk  Intelligence  Hub  was  submitted  and  acknowledged  by  the  
Information Technology and Cybersecurity Board  (ITCB) on 21 April 2026. The initiative aims to further develop the Business Partner framework and 
assess options to embed fraud risk indicators and screening functionalities within financial workflows. The proposed initiative foresees: 

a. A meeting was held on 21 November 2025 with OLAF to further clarify the definition and scope of  ‘unusual’ patterns.  DG BUDG has indicated its 
intention to enhance the data warehouse with any additional financial or budgetary data deemed necessary, which could subsequently be explored through 
appropriate data mining tools. In parallel, discussions are ongoing with DIGIT and OLAF regarding OLAF’s potential level of access to Arachne+ and the 
new business requirements that may arise, should Arachne+ be selected as the preferred tool for such analytical purposes. 

b.  Strenghtening the  interoperability  of  SUMMA  with  systems  such as  Arachne+,  IMS and  external  databases  (e.g.  ORBIS). The initiative foresees  the 
progressive integration of fraud risk indicators and screening functionalities within Business Partner processes. 

c.  The  implementation  of  solutions  to  enhance  data  quality  and  reliability,  including  Optical  Character  Recognition  (OCR)  and  Intelligent  Document 
Processing technologies. These elements aim to introduce automated data enrichment, validation and screening functionalities. 

The next step foreseen is the preparation of a Project Charter by the end of 2026. Further developments, including implementation (2027–2028), remain 
subject to governance approval and detailed planning. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
5 

Increase  the  user-friendliness  of  the  Irregularity  Management  System  (IMS)  for Member  States  authorities and  relevant 
Commission staff, the use of the system and therefore the completeness and accuracy of the data in the system, notably by: 

Lead 
OLAF 

Due date 
2023 and 
continuous 

a.  upgrading the system technically; 
b.  exploring the possibilities for interoperability with other Commission and national systems dedicated to protecting 

the EU’s financial interests. 

State-of-play May 2026 

IMS is the system through which Member States report on irregularities and fraud affecting the EU budget to the Commission, allowing the Commission to 
analyse for example trends and modus operandi. It has potential for greater interoperability with other corporate tools of the Commission, such as Arachne+ 
and EDES, and with digital tools in Member States. OLAF, which runs the IMS on behalf of the Commission, is continuosuly working on improving its user 
friendliness. 

a.  In  July  2025,  an improvement  was implemented  in  IMS  concerning  the  field  ‘Initiating authority  –  complete  name’.  This  field  is now  automatically 
populated  based  on  the  authority  creating the case.  This  enhancement  helps ensure more  consistent data  entry and reduces  the  risk of  incorrect manual 
changes. Previously, in some cases, the name of the initiating authority was modified directly in IMS through field 1.5, instead of being updated in URT, the 
dedicated application for managing users and authorities. In April 2026, work resumed on revising several dropdown lists (codelists) for the 2021–2027 
programming period to strengthen data collection and improve data quality, with implementation planned for Q2 2026. This includes a new codelist on the 
functions and roles of the authorities, enabling more precise data collection. The stages of proceedings were also revised to better align with national practices. 

Further improvements were also introduced to support the reporting of irregularities under new instruments. In 2025, competence for the Ukraine Facility 
was established in IMS, and the Ukrainian authorities began reporting irregularities. In September 2025, the CLIMATE competence was created in IMS to 
enable  the  reporting  of  irregularities  related  to  the  Social  Climate  Fund.  In  February  2026,  the  Reform  and  Growth  Facility  for  the  Western  Balkans 
competence was created in IMS to enable the reporting of irregularities related to that Facility. 

b. As regards interoperability and links with other Commission systems, an EDES survey was launched in February 2025. The results were discussed with 
DG BUDG, and possible corrective measures identified through the survey were taken into account. 

6 

 
 
 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
6 

Explore options to improve the efficiency and accuracy of financial and administrative monitoring of follow-up of 
OLAF cases, notably by increasing data interaction possibilities between OLAF and Commission departments and 
where appropriate monitoring of the follow-up of EPPO cases based on information received from the EPPO.  

Lead 
OLAF, SG, BUDG 

Due date 
2024 

State-of-play May 2026 

This action has been completed end of 2024. 

7 

 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
7 

Explore options to improve internal communication on cases of fraud and irregularities by: 

a.  exploring  the  possibilities  of  developing  IT  solutions  for  communication  between  OLAF,  Commission 
departments and Executive agencies along the full life cycle of a case - from communicating suspicions of fraud 
to OLAF, through selection and investigation, to follow-up and monitoring (including on information received 
from the EPPO, where appropriate) - to make such communication more regular and efficient, while respecting 
the confidentiality of investigations; 

Lead 

Due date 

OLAF: lead 
SG: support 

2025 

b.  updating Commission departments and Executive agencies bilaterally, as well as the Secretariat-General where 

OLAF 

2024 

appropriate, on the status of OLAF cases every six months in the meantime 

State-of-play May 2026 

Communication with other Commission departments and Executive agencies on OLAF investigations will be facilitated by an increased use of digital tools. 

a.  An OLAF internal study on cases-related exchanges between OLAF and other stakeholders was finalised in May 2024. Any further study and related 

development of IT solutions will depend on the outcome of ongoing discussions related to the EU anti-fraud architecture. 

b. This sub action has been completed in 2024. 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
8 

Set up a working group to explore available and possible future options for strengthening digital control against plagiarism, 
also for 'external' plagiarism comparing not only documents prepared for the Commission but also other documents. 

Due date 
2024 

Lead 
OLAF: 
lead 
All DGs: 
support 

State-of-play May 2026 

This action has been completed. 

9 

 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
9 

Develop a  matrix  of  risk  indicators  in  GETI  (Get  Intelligence  system)  to  contribute to  fraud  prevention  and  to  pro-actively 
identify  high  risk  projects  and  entities,  targeting  aspects  such  as  unusual  behaviour,  financial  information  and  contractual 
patterns. 

Lead  Due date 
OLAF  2026 

State-of-play May 2026 

GETI is an OLAF data analytical tool used for simultaneously searching in multiple data stacks of structured and unstructured data in multiple different 
languages. GETI finds information quicker and more efficiently, by bringing together data from different sources. 

OLAF has gathered and implemented various risk indicators with the aim to pro-actively detect irregularities. By May 2026, six analytical reports flagging 
potential irregularities for further investigation were delivered to the investigative units. Work on a pilot to integrate the identified risk indicators into a 
generative AI based tool, complementing GETI dashboards was conducted throughout 2025. 

10 

 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
10 

Set up a working group to explore available and possible future options for strengthening digital control of external service 
providers and experts, notably checking that they do not claim reimbursement for the same hours from several sources. 

Due date 
2024 

Lead 
OLAF: 
lead 
All DGs: 
support 

State-of-play May 2026 

This action has been completed. 

11 

 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
11 

Further strengthen the Commission's IT and information security to respond quickly and effectively to evolving 
cyber-security threats, including the threat of cyber-fraud, and minimise potential impacts, notably by:  

a.  regularly revising the IT security strategy and, as applicable, the IT security plans based on comprehensive 

risk assessments that take the possibility of cyber-fraud into account; 

b.  ensuring  close  cooperation  on  information  security  between  EU  institutions  and  bodies,  notably  on 
investigations of leaks of information, on common rules and tools to securely exchange information. 

Lead 

Due date 

DIGIT: lead 
strategy 
All DGs: lead 
plans 
OLAF: support 
HR: lead 
OLAF: support 

2023 and 
continuous 

2023 and 
continuous 

State-of-play May 2026 

Cybersecurity threats are constantly evolving. The Commission is committed to ensuring the safety and security of its digital assets and reputation, as well 
as maintaining the continuity of its operations. 

a.  DIGIT regularly monitors and reports on the cybersecurity posture of the Commission via the IT Security and Risk Report (ITSRR). The release of the 
4th quarterly 2025 ITSRR took place in February 2026. The report provides a snapshot on the Commission’s IT security risk posture, including updates and 
key developments in relation to the threat landscape, proactive and reactive cybersecurity and capability development. It also encompasses the assessment of 
the implementation of the actions planned under the 2025-2026 strategy for the second half of 2025, which showed good progress. 

b. HR.DS remains committed to ensuring the Commission has the critical capabilities required to address the escalating complexity of security threats and 
protect its operational resources. HR.DS continued to defend in Council and the European Parliament its proposal to harmonise information security rules 
among EU institutions, agencies and bodies. Notably, the draft report was presented in September 2025 to the LIBE Committee (Committee on Civil Liberties, 
Justice and Home Affairs of the European Parliament), while the proposal was discussed at every meeting of the Council Security Committee throughout the 
year.  The  new  Framework  Agreement  with  the  European  Parliament  modernises  the  exchange  of  sensitive  and  classified  information  between  the  two 
Institutions.  Negotiations  were  successfully  concluded  in  September  2025.  Negotiations  on  an  Annex  governing  the  exchange  of  classified  information 
continued until the end of 2025. The new Framework Agreement was published in the Official Journal on 12 May 2026. HR.DS has also increased the 
availability of tools to exchange classified information, in particular by rolling out a new tool (SUE) to securely exchange classified information with EU 
entities and Member States (ministries and permanent representations). 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
Foster digitalisation and the use of IT tools to fight fraud  

Nr  Action 
12  Encourage  Member  States,  notably  through  available  funding  programmes,  to  digitalise  as  appropriate  fraud 
prevention, detection and investigation by supporting the development and use of IT tools for data collection and 
analysis using advanced data mining, machine learning technologies and forensics, as well as the exploration of 
emerging technologies such as artificial intelligence, block chain technology and biometrics.  

Lead 
All DGs providing 
such funding 

Due date 
2023 and 
continuous 

State-of-play May 2026 

The Union anti-fraud programme (through its Calls for proposals under the ‘anti-fraud measures’ component), included in 2025 opportunities for Member 
States and Ukraine for the financing of projects related to the digitalisation of fraud preventive actions, the detection and the investigation of irregularities or 
fraud against the EU budget. Under the 2025 operational budget, five projects out of the 20 selected for technical assistance funding, were related to this 
digitalisation process (mostly data collection and data analysis). 

SG REFORM is implementing a project with the Hungarian Integrity Authority to develop an AI-supported tool. This tool will use a data-driven approach 
to perform risk analysis and thus identify irregular patterns in procurement and other EU co-funded projects. The goal is to enable risk-based investigations.  
The project with the Lithuanian Special Investigation Service (STT) has been completed in February 2026 resulting in a tailored AI-supported model that the 
STT will further refine and develop to inform its corruption risk analysis and investigations. 

Beyond the funding opportunities, DG ECFIN is assessing the IT systems put in place by Member States to collect data on the implementation of the Recovery 
and Resilience Plan and to monitor the achievement of milestones and targets. 

13 

 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds 

Nr  Action 
13 

Further improve the prevention and detection of fraud to the RRF, notably by: 

a.  developing risk indicators on fraud, corruption, conflict of interest and double funding, for the purposes of 
auditing and identifying potential cases to be transmitted to OLAF for possible investigation or transmission 
to the EPPO; 

b.  carrying  out  system  audits  on  the  protection  of  the  EU's  financial  interests  focusing  on  high-risk  areas 

identified in risk assessments; 

c.  continuing anti-fraud awareness raising and training; 
d.  encouraging Member States to make use of IMS to report irregularities related to the RRF in line with an 

ECA recommendation. 

State-of-play May 2026 

Lead 
ECFIN: lead 
OLAF: support 

Due date 
2023 and 
continuous 

With the large amounts involved in the RRF, the Commission is closely monitoring and taking action to address risks and instances of fraud, corruption, 
double funding and conflict of interest. 

a. No updates took place in relation to this sub-action since last year’s reporting. 

b. DG ECFIN has carried out at least one audit on the protection of EU’s financial interests in each Member States. Targeted audits on the protection of EU’s 
financial interests are conducted where particular needs have been identified, such as for specific topics, measures, regions or authorities. To ensure that risks 
are adequately monitored and addressed throughout the life of RRF, DG ECFIN has continued to conduct its annual risk assessment methodology to select 
Member States for further system audits on the protection of the financial interests of the Union (PFIU). DG ECFIN has undertaken further audit work in 
2025 in 5 Member States based on the risk assessment updated in January 2025. For 2026, given that RRF has entered the final phase of implementation, the 
focus of the 2026 risk assessment shifted towards more targeted PFIU selection, combining PFIU audits with other type of audits for an efficient use of 
resources. 

c. The Technical Working Meeting with National Audit Bodies on the Recovery and Resilience Facility (RRF) was held in Brussels on 12-13 February 2026, 
with a focus groups session dedicated to the continued detection capacity of fraud, conflict of interest, corruption and double funding at the time of RRF final 
phase, closure and beyond. In addition, DG ECFIN’s presentations included guidance on continued detection and reporting obligations. 

d. Specifically concerning the use of IMS (which is not mandatory under the RRF Regulation), the Member States’ audit authorities for RRF have been made 
aware of the advantages of using IMS for reporting irregularities during the bilateral meetings organised by DG ECFIN, as well as during the abovementioned 
Technical Working Meeting. 

14 

 
 
 
 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds 

Nr  Action 
14 

Encourage Member States to put in place effective and proportionate anti-fraud measures, such as strategies 
at  national,  plan,  programme  or  authority  level  and,  as  applicable,  provide  guidance  and  support  in  this 
respect. 

Lead 
ECFIN, shared 
management DGs 
and OLAF  

Due date 
2023 and 
continuous 

State-of-play May 2026 

The Member States are responsible for putting in place effective and proportionate anti-fraud measures to protect the financial interests of the Union. An 
appropriate framework for developing such measures are national anti-fraud strategies (NAFS), and the Commission, European Parliament and European 
Court of Auditors have therefore actively encouraged Member States to adopt such strategies. 

As of February 2026, OLAF has set up a temporary ad hoc working group of national experts to update the 2016  ‘Guidelines on National Anti-Fraud 
Strategies’. 17 national experts from 13 Member States are part of the working group. The kick-off meeting was held on 26 March.  

DG MARE has encouraged Member States authorities to consider putting in place NAFS whenever Key Requirement 7 (KR7) was within the scope of audit 
missions. Between July 2024 and April 2026, nine such audit missions have been carried out, which has brought the Member States covered to 23. A related 
question in the checklist for KR7 audit assignments under the European Maritime, Fisheries and Aquaculture Fund was included in the beginning of 2026. 

DG ECFIN has encouraged the adoption of National Anti Fraud Strategy in the context of its RRF audits on the protection of the EU financial’s interests. 
Where  necessary, audit and  control milestones  requiring Member  States to  put in  place  dedicated  national  anti-fraud strategies  were added in  national 
Recovery and Resilience Plans (RRPs). DG ECFIN also updated its two guidance documents on internal control and summary of  audits in response to 
European Court of Auditors Special report 06/2026, which addressed best practices on fraud reporting in relation to the reporting of fraud and suspected 
fraud cases. 

DG REGIO, with the cooperation of the European Institute of Public Administration, delivered three seminars  in June and October 2025, and January 2026 
on ’Identifying  and  preventing  fraud  and  corruption  in  Structural  and  Cohesion  Funds  2021-2027’. All  three  seminars  included  a  module 
on NAFS explaining the importance of having such strategies in place. 

15 

 
 
 
 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds 

Nr 
15 

Action 
Provide,  as  relevant,  regular  training,  awareness  raising  and  exchanges  of  best  practice  examples  with 
Member State authorities, either dedicated to or including as an important element anti-fraud matters, such 
as prevention, detection and handling of irregularities, as well as reporting in the IMS. 

Lead 
ECFIN, shared 
management 
DGs and OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2026 

The Commission provided the Member States authorities with anti-fraud training, awareness raising and exchanges of best practices in several fora in 2025. 

The  shared  management  DGs  (REGIO,  EMPL,  MARE  and  AGRI)  continued  to  provide  training  and  raise  awareness  of  anti-fraud  matters,  as  well  as 
exchanging best practice, in various instances such as meetings with Audit Authorities or anti-fraud seminars for programme authorities. Notably, 26 Annual 
Coordination meetings with the Audit Authorities (ACMs) included an OLAF presentation on double funding in EU funded projects.  

DG  REGIO,  with  the  cooperation  of  the  European  Institute  of  Public  Administration,  delivered three seminars on  ‘Identifying  and  preventing  fraud  and 
corruption in  Structural  and  Cohesion  Funds  2021-2027’  in June and  October 2025,  and in  January  2026. DG  REGIO  provided in  June, September and 
October 2025 three training courses on the ’Implementation of Integrity Pacts (IP) in selected public procurement projects financed by EU cohesion funds’.  
On 26 January 2026, DG REGIO provided a seminar on ‘TSI 2024 Multicounty Project BG, CY, EL on Anti-Fraud - EC Fraud Risk Assessment and Scoring 
Methodologies’ for almost 400 participants. 

DG AGRI delivered six seminars on anti-fraud topics in 2025. OLAF has participated in such seminars, notably by delivering presentations to the Online 
Workshop on Anti-Fraud activities, organised by the Paying Agency for Agriculture of Croatia (June 2025) and to the Seminar on Fraud Risks and Prevention 
in IPARD implementation (Albania, September 2025). In November 2025, OLAF participated to the anti-fraud seminar in Finland. In March 2026, OLAF 
participated  to  a  workshop  in  Irland  (organised together  with  DG  AGRI)  and  presented  the reporting of irregularities  in  the  IMS.  In May  2026,  OLAF 
delivered a presentation on the key role of reporting irregularites and fraud, to an anti-fraud seminar in Greece on protecting the EU budget in the common 
agricultural policy. The topic of antifraud in CAP was covered in the 57th Conference of Directors of EU Paying Agencies (Poland, May 2025), and in the 
59th Conference of Directors of EU Paying Agencies (Cyprus, May 2026). 

In cooperation with the European Institute of Public Administration, OLAF has delivered two seminars on fraud prevention in the European Structural and 
Investment Fund and Recovery and Resilience Facility. The seminars were delivered for the Members States managing and audit authorities. OLAF has also 
delivered several training sessions related to the Irregularity Management System (IMS), with the aim of improving reporting quality and enhancing the use 
of the tool. In October 2025, OLAF delivered a full IMS training to the Irish authorities. In November 2025, OLAF participated in a training for users in 
Greece, Cyprus and Bulgaria organised by the OECD on the European Commission’s fraud risk assessment and scoring methodology. In May 2026, OLAF 
delivered further training to users from the Irish agriculture department, focusing on how to report a case in the system. 

For the RRF, DG ECFIN raised such topics in the annual conference with national audit authorities, as well as bilateral meetings with national audit authorities 
that take place on a yearly basis. 

16 

 
 
 
  
 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds 

Nr  Action 
16 

Promote sharing of best practice and provide guidance for Member States on preventing, 
detecting, handling and reporting conflict of interest situations. 

Lead 
BUDG: lead 
ECFIN, shared management DGs: 
support 

Due date 
2024 and 
continuous 

State-of-play May 2026 

Member States have the obligation, when implementing the EU budget in shared management, to take the necessary measures to avoid conflicts of interest. 
The Commission has stepped up its efforts to provide guidance and allow the Member States to share their experiences with each other. 

Following the dissemination by the Commission of a consolidated document on best practices to relevant Member States authorities in April 2025, for the 
RRF, DG ECFIN invited Member States to share best practices on conflict of interest situations in annual conference with National Audit Bodies. In the 2026 
edition, one of the focus groups sessions was dedicated to the continued detection capacity in terms of conflict of interest, corruption, double funding and 
fraud at the time of RRF final phase, closure and beyond. 

17 

 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds 

Nr  Action 
17 

Promote  and  support  the  use  of  IMS  by  Commission  auditors  for  fraud  risk  assessment  purposes,  notably  by  providing 
training. 

Lead 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2026 

OLAF  continuously  strives  to  make  IMS  accessible  to  relevant  Commission staff.  IMS  can  for  example support  auditors  with their risk  analysis in  the 
planning of an audit. 

In March 2026, a short training session on ‘How to search in IMS’ was provided to IMS users in DG EMPL. A further session on the same topic is planned 
for June 2026 for users from DG ECFIN, DG AGRI, DG HOME and REGIO/EMPL/DAC. 

These sessions aim to improve users’ ability to retrieve and interpret IMS data, thereby supporting the use of the system for audit-related analysis and fraud 
risk assessment. 

18 

 
 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds 

Nr  Action 
18  Verify, as relevant, that the work done by audit authorities and certification bodies includes checking on the existence of 
adequate procedures for timely and accurate reporting of detected irregularities, their handling, follow-up and transmission 
of  information  to  the  competent  investigative  bodies.  This  might  include  cases  where  the  irregular  expenditure  is 
withdrawn from EU funding or, in the case of the RRF, corrected and recovered from the final recipients.  

Lead 
ECFIN, 
shared 
management 
DGs 

Due date 
2023 and 
continuous 

State-of-play May 2026 

To ensure that the EU’s financial interests are protected, it is important that Member States have procedures in place for following up on detected fraud and 
irregularities. Audit authorities and certification bodies play an important role in verifying that this is the case. 

For the RRF, DG ECFIN reviewed management declarations and audit reports received with all payment requests and issued recommendations following 
audits on the protection of EU’s financial interests. The work done on the protection of the EU’s financial interests and the follow up of reported irregularities 
are discussed during the bilateral annual meetings with the audit authorities. In addition, during the Annual Conference with National Audit Bodies held on 
12 and 13 February 2026, the participants discussed how to carry out targeted checks on PFIU at the time of RRF final phase, closure and beyond. Moreover, 
as audit authorities play an important role in the internal control system, DG ECFIN also carries out compliance audits to assess the reliability of the work 
performed at national level. Since the start of the RRF, DG ECFIN has conducted 23 compliance audits or combined audits with compliance elements. 

By April 2026, DG MARE conducted 23 audit missions on KR 7 using the checklist updated in 2024. 

DG  AGRI  updated  the  specific  guidance  n.  5  for  Paying  Agencies  regarding  debt  management.  The  Guidance  was  discussed  in  the  Agriculture  Funds 
Committees and Expert Group Meetings. On 16-17 June 2025 and 17-18 November 2025, presentations on debt management were delivered (with focus on 
recoveries targeting persons responsible for the irregularities). 

19 

 
 
 
 
 
 
 
 
Support Member States to reinforce the protection of the Recovery and Resilience Facility, cohesion, agricultural and fisheries funds 

Nr  Action 
19 

Support Member State authorities to improve the quantity and quality of irregularity reporting to 
the Commission via the IMS, notably by: 

Lead 

Due date 

a.  developing and updating guidance on reporting, for example, the IMS handbook, including 

on issues related to conflicts of interest; 

OLAF: lead 
Shared management DGs: support 

2024 

b.  reminding  Member  State  authorities  in  the  communication  on  the  outcome  of  a 
Commission  audit  or  an  investigation  on  the  obligation  to  report  in  IMS  irregularities 
above the threshold, also when identified during a Commission audit or an investigation, 
and  to  confirm  explicitly  their  reporting  of  those  irregularities  to  allow  for  their  exact 
identification. 

State-of-play May 2026 

Shared management DGs: lead 
OLAF: support 

2023 and 
continuous 

For the EU to have a complete and correct picture of the irregularities and fraud against EU funding, the Member States need  to report them in IMS. To 
support the Member States, OLAF issued guidance on reporting. 

a. The Handbook on the reporting of irregularities was adopted in September 2025. It includes guidance on issues related to conflict of interest.  

b. Following shared management DGs reminder to Member States authorities about the obligation to report in IMS irregularities above the threshold, Member 
States started using the new procedure and OLAF is monitoring it. 

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area  

Nr  Action 
20  Develop a joint ethics and anti-fraud training plan with the EEAS, to ensure that specialised training is delivered 

consistently for targeted groups of staff notably in the Representations, Delegations and Missions. 

Lead 
External action DGs: 
lead 
OLAF, HR: support 

Due date 
2024 

State-of-play May 2026 

This action has been completed. Further streams of work deriving from this action were carried out throughout 2025.  

The learning path on ‘Fraud prevention, awareness raising, and OLAF investigations’ prepared by DG INTPA is available on EU Learn since May 2025. It 
has been further enhanced through the inclusion of new e-learning training courses in 2025 and 2026, such as the one developed by DG COMP (with the 
support of DG BUDG) entitled ‘Detecting bid rigging: what is bid rigging and how can we fight it together?’. Additionally, a dedicated e-learning course on 
conflict  of  interest,  developed  by  DG  BUDG,  has  been  made  available  on  the  learning  path  on  ‘Fraud  prevention,  awareness  raising,  and  OLAF 
investigations’ to raise awareness about instances leading to conflict of interest situations in direct and indirect management and to provide staff members 
working in RELEX DGs with hands-on information about the prevention and mitigation of conflict of interests.  

The learning path on ‘Fraud Prevention, Awareness Raising, and OLAF Investigations’ on EU Learn has been consistently promoted through the anti-fraud 
intranets of external action Commission services, anti-fraud newsletters, as well as through jointly organised anti-fraud training sessions by DG INTPA, DG 
FPI, DG MENA, DG ENEST and OLAF, which take place four times a year. This participation is crucial for ensuring that staff receive comprehensive 
training on ethics and anti-fraud issues. 

As part of its efforts to strengthen anti-fraud measures, DG ENEST successfully organised a comprehensive anti-fraud training session for the European 
Union Delegation in Bosnia and Herzegovina on 3 March 2026, with approximately 140 participants attending, and featuring presentations from experts from 
OLAF, DG ENEST, and EEAS on fraud prevention, investigations, and guidelines, providing staff with the necessary knowledge and skills to prevent and 
combat fraud. 

21 

 
 
 
 
 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area  

Nr  Action 
21  Raise awareness of pillar-assessed partners in the field of external action on their obligation to notify the 

Lead 

Commission of cases of detected irregularities, fraud and exclusion situations, notably by: 

a.  providing the partners with guidance on the information to be shared with the Commission when 

notifying cases; 

b. 

inviting OLAF to participate in relevant meetings with major recipients of EU funding. 

INTPA: lead 
External action DGs, OLAF, 
BUDG: support 
External action DGs: lead 
OLAF: support 

Due date 

2024 

2023 and 
continuous 

State-of-play May 2026 

The  Commission  may  delegate  the  implementation  of  EU-funded  projects  to  partner  organisations  in  indirect  management.  To  ensure  that  the  partner 
organisation’s internal rules and procedures guarantee a high level of protection of EU funds, the organisation must pass a pillar assessment. Pillar-assessed 
partners have an obligation to notify the Commission of cases of detected irregularities, fraud and exclusion situations. 

a.  On 29 October 2025, the revised Contribution Agreement Manual (‘CA Manual’) was published on DG INTPA Intranet page (as Annex e2f13 to the 
Companion v.16)  and on DG INTPA Internet page Working with partner organisations - European Commission. DG INTPA’s main partners – notably 
those  with  whom  there  is a  Financial  Framework  Partnership  Agreement  (a  long-term  strategic  agreement)  as  well  as  those  with  whom  there is  an 
arrangement  for  submitting  a  global Management  Declaration  -  have  been  informed accordingly  about the  updated  version  of  the  CA  Manual.  The 
changes introduced reflect exchanges with OLAF about the list of a minima information to be provided by the Organisation to the European Commission 
and the Contracting Authority in case of established fraud, irregularities or a suspected case of fraud, corruption or any other illegal activity affecting the 
financial interests of the Union. In addition, the updated version of the CA Manual also reflects OLAF’s interpretative guidance on the term 'suspected 
cases' in response to partners’ requests for clarification as regards  the obligation under Article 158(7) of the 2024 Financial Regulation (‘FR’) for entities 
implementing EU funds under indirect management to ‘notify the Commission without delay of cases of established fraud and irregularities and their 
follow-up, as well as any information relating to suspected cases of fraud, corruption or any other illegal activity affecting the financial interests of the 
Union’. These updates were also introduced in the Contribution Agreement for Financial Instruments Manual (‘CAFI Manual’ - Annex e3c10 to the 
Companion v.16).  

DG ECHO sent a notification to all pilar-assessed humanitarian partners specifying fraud reporting obligations on 15 December 2025. 

b.  Between March 2025 and April 2026, DG INTPA facilitated dialogue between OLAF and key international partners to clarify and reinforce reporting 
obligations under the EU’s anti-fraud framework. A recurring theme was the interpretation of the newly introduced terminology ‘suspected cases’ of 
fraud or corruption in the Contribution Agreement (CA) template, a point emphasised in meetings with the OECD (March 2025), UN partners (May and 
June 2025), EBRD (July 2025), and the African Development Bank (February 2026). OLAF’s presentations, such as those delivered to the EU-UN FAFA 
Working Group and the Joint Technical Reference Group (JTRG), underscored the need for proactive disclosure.  

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area  

Nr 
22 

Action 
Develop common lines of action with the EEAS to reduce the risks associated with local agents who remain 
in the same post for a long period of time in the Delegations. 

Lead 
External action 
DGs: lead 
OLAF, HR: support 

Due date 
2024 

State-of-play May 2026 

This action has been completed. Further streams of work deriving from this action were carried out throughout 2025. An action plan to reduce the risks 
associated with local agents who remain in the same post for a long period of time in the Delegations was adopted and sent out to respective Commission 
services and EEAS on 20 May 2025.  

Throughout 2025, DG INTPA continued the implementation of the Action Plan through its supervision missions to 12 EU Delegations. The following aspects 
have been raised with the EU Ambassadors and other staff members: (i) Identification of colleagues dealing with the same portfolio/projects since more than 
6 years and assessment of their roles, functions and responsibilities, (ii) alignment between job descriptions and work actually implemented by local agents, 
(iii)  expatriate  staff  supervising  every  stage  of  visa  circuits  for  local  agents  participating  in  a  project/programme  and  (iv)  restriction  of  access  to  the 
Delegation premises to local agents while expatriate staff is absent. 

On 21 October 2025, DG INTPA issued a note on ‘Ethics standards, reporting irregularities, alleged fraud and corruption, and disclosure of information by 
staff’ to all INTPA staff, aiming to ensure that all staff members are aware of the professional ethics standards, the importance of fraud prevention and 
detection, as well as the rules and guidelines for disclosure of information and the security of sensitive non-classified information in AI systems. The note 
includes an annex with all exsting trainings on ethics and anti-fraud, which are regularly promoted also via DG INTPA’s anti-fraud newsletter and/or DG 
INTPA’s Anti-Fraud Policy webpage (point 4 – Learning and Development). On top of that, ethics training has been structured and promoted via the learning 
path on ‘Fraud prevention, awareness raising and OLAF investigations’. DG TRADE issued a similar note on ‘Ethics standards, reporting irregularities, 
alleged fraud and corruption, and disclosure of information by staff’ to all TRADE staff on 17 December 2025. DG ENEST sent an annual reminder to staff 
on ethics and anti-fraud as well as on compulsory attendance to anti-fraud trainings and/or information sessions in the last three years. DG ENEST has 
included risk assessment points in supervision missions, focusing on confirmation of local agents' tasks aligning with updated job descriptions, surveillance 
of local agents by expatriate staff in project/programme stages and access restrictions to Delegations for local agents when expatriate staff are not present. 

DG MENA included a specific question on local staff attendance at ethics and anti-fraud training in its questionnaire for Supervision Missions. 

In close cooperation with the EEAS and the COMDEL members (RELEX and central services), an updated policy on local agent contracts (fixed-term 
contracts) was put in place in 2025.   

23 

 
 
 
 
 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area  

Nr  Action 
23 

Improve the use of IMS in candidate countries, notably by: 

a.  developing guidance on irregularity reporting in IMS; 

b.  providing training to relevant national authorities; 

c.  raising awareness among relevant authorities on the need to report irregularities in IMS in a complete and 

correct manner. 

State-of-play May 2026 

Lead 

Due date 

OLAF: lead 
NEAR: support 
OLAF: lead 
NEAR: support 
NEAR, OLAF 

2024 

2023 and 
continuous 
2024 and 
continuous 

Under indirect management, the countries benefitting from pre-accession assistance (IPA) must report irregularities and fraud to the Commission, and keep 
the Commission informed about the progress of administrative and legal proceedings in relation to such irregularities. Such reporting is to be done through 
IMS. To ensure correct reporting, the Commission provides guidance and training to the candidate countries. 

a.  This sub-action has been completed end of 2024. 

b. In April 2025, OLAF delivered a training on the practical use of IMS in a Workshop for Ministry of Finance of Serbia. In October 2025, DG ENEST and 
OLAF  participated  in  the  regional  online  workshop  on  irregularities,  together  with  representatives  from  national  authorities  from  Western  Balkans  and 
Türkiye to discuss best practices in reporting and managing irregularities. DG ENEST participated to the AFCOS Seminar in Tirana, Albania, organised by 
OLAF in October 2025, which provided a platform for exchanging experiences and strengthening cooperation among national authorities and EU Delegations 
in the Enlargement and Eastern Neighbourhood region. In the same event, OLAF delivered a training on strengthening the role of national authorities in 
preventing detecting and monitoring irregularities and on the reporting of irregularities in IMS and needs for simplification.  

c. DG ENEST assigned Irregularity Officers in the EU Delegations in order to liaise with the national authorities and follow up on the irregularities reporting. 
National authorities continue to report quarterly on follow-up of irregularities to DG ENEST as requested. To support DG ENEST in better identifying the 
programmes used in pre-accession countries, new programme codes have been introduced in the IMS system. 

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area  

Nr  Action 
24  Develop guidance and exchange of best practice on addressing the risks to spending in emergency situations 

(follow-up to 2019 CAFS action 29), focusing on conflict of interest. 

Lead 
ECHO, FPI, HOME: lead 
OLAF, BUDG: support 

Due date 
2024 

State-of-play May 2026 

This action has been completed in April 2025. 

25 

 
 
 
 
 
Reinforce the protection of funds under indirect management and in the external relations area  

Nr  Action 
25  Cooperate with Ukraine authorities, international donors and their anti-fraud services to protect EU funding from fraud and 

Lead 
OLAF  

corruption, notably by: 

Due date 
2023 and 
continuous  

a.  strengthening national anti-fraud structures through capacity building, in particular by: 

i. 
ii. 

providing targeted anti-fraud support to national authorities, e.g. through training and exchange of expertise; 
supporting accession to the Union Anti-Fraud Programme; 

b.  collaborating on possible cases affecting the EU’s financial interests, including through exchange of information. 

State-of-play May 2026 

The EU is spending large sums of money to support Ukraine in meeting present and future challenges. All players involved must do their utmost to ensure 
that the funds reach their intended recipients. Throughout 2025, OLAF continued its engagement to protect the EU’s financial interest with regard to funding 
to support Ukraine. 

a. In 2025, the Union Anti-fraud programme financed the training of staff members of the Ukrainian law enforcement authorities, who participated in OLAF 
conferences and training events, such as the conference of the national Anti-Fraud Coordination Services (AFCOS) of candidate countries and potential 
candidates (which took place on 8-9th October 2025 in Tirana, Albania). In addition, six Ukrainian law enforcement agents participated in the two Digital 
Forensics  and  Analysts’  Training  (DFAT)  sessions  (November  2025),  funded  through  the  Union  anti-fraud  programme  in  2025.  Three  Ukrainian 
representatives attended the Anti-Fraud Intelligence Analysis (AFIA) training of June 2025, delivered by OLAF and CEPOL.  

OLAF coooperated with the Ukrainian Ministry of Finance providing advice and know-how in elaborating the Ukrainian anti-fraud strategy. The national 
anti-fraud strategy should considerably improve the protection of the EU funds and increase detection rate for irregularities and fraud cases. As the Ukraine 
Facility competence was set up in the IMS, OLAF provided support to AFCOS Ukraine in establishing its reporting structure and in reporting its first cases 
in the system. 

b. OLAF investigative units continued to intensify their cooperation with Ukrainian authorities for cases of fraud or irregularity allegations. OLAF also 
increased the dialogue with relevant counterparts, such as Ukrainian civil society organisations, Ukrainian AFCOS, the Audit Board and the EU Delegation 
in Kyiv, to raise awareness about reporting fraud allegations to OLAF. 

26 

 
 
 
 
 
 
 
Reinforce the EU's capacity to fight customs fraud and protect EU revenues  

Nr  Action 
26 

Strengthen the Commission’s and Member States’ analytical capacities in the customs anti-fraud area by 
developing  data  analysis  tools  and  increasing  exchange  of  and  access  to  relevant  data  for  anti-fraud 
purposes, to improve the prevention and detection of customs fraud. 

Lead 
OLAF, JRC, 
TAXUD, BUDG: 
lead 

Due date 
2023 and 
continuous 

State-of-play May 2026 

Analytical tools and data sharing play an important role in boosting the EU's capacity to effectively tackle customs fraud. 

The Anti-Fraud Information System (AFIS) analytical platform (FraudAP) is fully operational. Between June 2025-May 2026, various applications and 
intelligence reports were produced using the FraudAP. The B2B interface tool between the CIS and Member State national systems was released to Member 
States on 25 November 2025 and an online training on the implementation of the CIS B2B mechanism was provided to Member State customs authorities 
on the same day. Since February 2026, the FraudAP4All, which consists of an integrated infrastructure and includes a number of tools for the conduct of data 
analysis, is available to OLAF investigators. 

Over the past year, the Customs Anti-Fraud Enabling Technologies 2024-2027 (CAFET-2) has primarily focused on defining the transition from monthly 
aggregates  (Comext)  to  disaggregated  import  data  (Surveillance)  as  inputs  for  price  calculations,  alongside  the  implementation  of  related  procedural 
adjustments. Additionally, substantial attention was given to pre-filtering outliers from the new data source, involving a comparative assessment of multiple 
methodological approaches. 

27 

 
 
 
 
 
 
 
 
Reinforce the EU's capacity to fight customs fraud and protect EU revenues  

Nr  Action 
27 

Ensure effective complementarity between customs risk management and anti-fraud activities, notably 
by: 

Lead 
TAXUD: lead 
OLAF, BUDG: support 

Due date 
2024 

a.  strengthening data sharing in the Customs Risk Management System; 
b.  developing and better defining risk indicators related to anti-dumping and undervaluation in the 

new Financial Risk Criteria Decision; 

c.  developing new common risk criteria for intellectual property rights at import. 

State-of-play May 2026 

Sub-action a. has been completed in Q1 2025; sub action b. has been completed in 2024. 

c. The Commission established a Subgroup of the Customs Expert Group on Customs Controls and Risk Management to assess the need to develop Common 
Risk Criteria (CRC) for IPR, and to check if their implementation would be efficient and effective. Based on the results of the work performed, the Subgroup 
came to the conclusion that it would be premature to go forward with the introduction of binding CRC for the time being. Nevertheless, Member States 
recognised the need to enhance the risk management at European level and will develop an alternative solution. This solution will be a temporary one until 
the enhanced common risk approach by the customs datahub under the ongoing customs reform comes in place. 

28 

 
 
 
 
 
 
 
Reinforce the EU's capacity to fight customs fraud and protect EU revenues  

Nr 
28  

Action 
Define an anti-fraud strategy for new own resources and identify and implement mitigating measures on fraud risks 
concerning  the  Carbon  Border  Adjustment  Mechanism,  the  EU  Emissions  Trading  System  and  other  new  own 
resources. 

Lead 
OLAF, 
BUDG, 
TAXUD, 
CLIMA 

Due date 
Within two 
years of 
adoption 

State-of-play May 2026 

The Commission presented in June 2023 an adjusted proposal for a next generation of own resources that covered the Carbon Border Adjustment Mechanism 
(CBAM)  and  an  extension  of  the  Emission  Trading  System  (ETS).  CBAM  was  included  in  the  July  2025  proposal  for  new  own  resources  (OR)  in  the 
framework of the next MFF. The whole package is still to be adopted by the co-legislators and approved by the national Parliaments. However, Member 
States have started collecting CBAM amounts as from 1 January 2026 (though the price of the certificates has been fixed only in April). These amounts, for 
the time being, accrue exclusively to the national budgets and only as from 2028 they will constitute OR. Work on the anti-fraud strategy is therefore in an 
early stage and will have to take account of the experience made and possible problems reported by Member States in the collection of the CBAM amounts. 
Nevertheless, there will be important synergies between the work on the anti-circumvention strategy and the anti-fraud strategy. 

On  16  December  2025,  the  Commission  made  a  proposal  to  extend  the  scope  of  CBAM  to  certain  downstream  products,  including  additional  anti-
circumvention measures. The review report was also published, alongside the Impact Assessment. The CBAM anti-circumvention measures is an inherent 
part of the rationale of the proposal that is now with the co-legislators. The work of the Risk Management Network was complemented by two surveys 
addressed to the Risk Management Network and a number of bilateral technical meetings to cover specific points (some risks identified and/or data quality). 

Workshops for the elaboration of high level business requirements for the creation of a CBAM Risk Management Module were finalised. A second phase of 
more detailed and operational elaboration requirements is now ongoing. The workstream is on track. 

29 

 
 
 
  
 
 
 
Reinforce the EU's capacity to fight customs fraud and protect EU revenues  

Nr 
29 

Action 
Minimise the potential fraud risks associated with the EU Emissions Trading System (ETS), notably by: 

Lead 

implementing and enhancing security measures; 

a. 
b.  exploring  alternative  operating  models  for  the  ETS  Union  Registry,  and  conducting  an  in-depth 
feasibility assessment and cost–benefit analysis to inform the decision on a potentially new operating 
model. 

CLIMA 
CLIMA: lead 
SG, BUDG, DIGIT,  
TAXUD: support 

Due date 

2023 and 
continuous 
2024 

State-of-play May 2026 

The EU Emissions Trading System (ETS) is the world's first major carbon market and remains the biggest one. With a market value of around EUR 770 
billion and a revenue of more than EUR 7 billion generated for the EU in 2023, it is vulnerable to cyberfraud. The Commission is therefore enhancing its 
security measures. 

a.  The external risk assessment of 2024 resulted in eight new security measures of which one was closed in 2025 while the remaining ones are ongoing. 

b.  Throughout 2025, an interservice group led by DG CLIMA, comprising SG, DG BUDG, DIGIT, DG FISMA and DG TAXUD continued to work on an 
alternative operating model of the Union Registry. The follow-up on this work was presented in the first quarter of 2026 to the Corporate Management 
Board, who supported the initiative presented by DG CLIMA for the development of such new enhanced operating model. 

30 

 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture  

Nr  Action 
30 

Ensure  effective  cooperation  between  the  Commission  and  the  European  Public 
Prosecutor’s Office (EPPO), notably by: 

Lead 

a.  providing guidance to Commission departments and Executive agencies; 
b.  establishing Commission wide cooperation on EDES and on the application of the 

Central services as appropriate  

Conditionality Regulation; 

c.  assessing potential compliance issues with the Member States’ transposition and 

implementation of the PIF Directive. 

BUDG 

JUST: lead 
OLAF: support 

Due date 

2024 and 
continuous 
2023 and 
continuous 
2023 and 
continuous 

State-of-play May 2026 

The Commission and the EPPO have a shared interest in fostering an effective and cooperative relationship for the purpose of  protecting EU’s financial 
interests. 

a. The revised Commission-EPPO Agreement was signed in November 2024. The third phase of its implementation, i.e. the deployment of the EPPO Box in 
the Commission Services, is ongoing. In particular, EPPO Boxes were set up by EPPO with the OLAF assistance in the priority DGs, i.e. the ones receiving 
most of the communications/notifications from the EPPO. The EPPO held training sessions with each of the DGs where the EPPO Box was set-up. For the 
implementation of the internal workflow, OLAF has organised a dedicated training session for the priority DGs, delivered jointly with the Commission 
Secretariat-General  (Ares  registration  and  tasks  assignment).  OLAF  has  also  facilitated  the  organisation  of  the  EPPO  training  (EPPO  operational 
communication guide for the use of the Commission Services). 

OLAF continues to update the Commission’s register of EPPO contact points and has created in spring 2026 a dedicated repository of various resources at 
disposal of the relevant Commission Services. OLAF will continue to act as contact point/dispatcher of the communications between the EPPO and the other 
DGs until the full deployment of the EPPO Box in all the other DGs. OLAF provides support to the DGs in their day-to-day implementation of the Agreement 
as required. OLAF will continue to provide guidance to Commission departments and Executive agencies as required, also after the deployment of the EPPO. 

b. The Commission has maintained and fostered its cooperation with the EPPO for what concerns the administrative follow-up of EPPO cases. Practice is 
evolving and it is expected to settle with more EDES cases stemming from EPPO investigations. Furthermore, the Commission has kept analysing information 
provided by the EPPO, both as part of input for the preparation of the annual Rule of Law Report, and on an ad hoc basis. 

c. The Commission has issued three Reasoned Opinions against Member States for non-compliance of national legislation with the PIF Directive. One case 
has been closed, and further closures are expected in the next cycles. In total, five cases remain open. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture  

Nr  Action 
31 

Strengthen the support to Decentralised agencies and Joint Undertakings7 in their effort to fight fraud, notably 
in establishing a coherent anti-fraud framework across agencies by: 

a.  providing training on ethics and anti-fraud matters; 

b.  providing methodology and advice on anti-fraud strategies; 
c.  sharing knowledge, allowing the agencies to publish relevant information on the inter-agency website; 
d.  regularly  participating  in  relevant  meetings  of  the  EU  Agencies  Network  to  inform  on  anti-fraud 

matters. 

State-of-play May 2026 

Lead 

Due date 

OLAF: lead 
HR: support 
OLAF 
OLAF 

2023 and continuous 

2023 and continuous 
2023 and continuous 

OLAF 

2023 and continuous 

The  EU  Decentralised  agencies  and  Joint  Undertakings  are  autonomous  bodies  with  own  legal  personality,  established  by  a  founding  regulation.  They 
contribute to the implementation of various EU policies, sometimes with an important budget. While they have different governance structures, mandates 
and tasks, they are all bound to follow financial rules similar to those of the European institutions and to prevent fraud and irregularities. 

a. Throughout 2025 and in the first quarter of 2026, upon request, OLAF delivered 14 tailored-made training courses and presentations on ethics and anti-
fraud matters to the Decentralised agencies and Joint Undertakings and their cooperation networks dealing with anti-fraud matters. 

b. OLAF provided guidance for anti-fraud strategies to Decentralised agencies and Joint Undertakings, based on the 2024 dedicated methodology.  

c. OLAF provided advice on anti-fraud matters to the Decentralised agencies and Joint Undertakings, and shared relevant material to be published by inter-
agency networks or on local websites of agencies. 

d. OLAF regularly participated in relevant meetings of the EU Agencies Network working groups related to anti-fraud. On 9 October 2025, in the context of 
the meeting of the Network of the Commission Representatives on Agencies’ Boards, OLAF presented conclusions after one year of implementation of the 
new anti-fraud strategy methodology by the agencies. 

7 Bodies set up under the Treaty on the Functioning of the European Union and Euratom Treaty and referred to in Articles 70 and 71 of Regulation (EU, Euratom) 2018/1046. 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture  

Nr  Action 
32 

Protect and empower investigative journalists as an important source of information on suspected fraud, 
notably by ensuring that appropriate EU legislation is in place including on SLAPP (strategic lawsuit 
against public participation) and on media freedom (European Media Freedom Act), and that Member 
States take appropriate measures to put in practice the Commission Recommendation on SLAPP and 
that on the safety of journalists, while funding projects in support of investigative journalism. 

State-of-play May 2026 

Lead 
CNECT, 
JUST 

Due date 
2023 and continuous 

The Commission adopted the European Democracy Shield in November 2025. It includes reinforced financial support for independent and local journalism 
to be provided under the new Media Resilience Programme, an Update of the Commission’s Recommendation on the Safety of Journalists and step up action 
to support the EU’s existing framework to combat abusive lawsuits against public participation (SLAPPs). 

The Anti-SLAPP Directive entered into force on 6 May 2024 and the transposition deadline for Member States was 7 May 2026. The Commission held three 
transposition  workshops  in  November  2024,  May  2025  and  November  2025  with  Member  States  and  supported  them  in  the  transposition  process  with 
clarifications and replies to their questions. 

To intensify its efforts to protect journalists against undue pressure, threats and attacks, the Commission will update its Recommendation on the safety of 
journalists to support a stronger safety and enabling environment for journalists and for quality news reporting (primary source journalism) in society in April 
2027. In April 2026, the Commission has renewed the mandate and composition of the expert group against SLAPPs to foster support for victims. In April-
May 2026, the Commission collected feedback through a public survey and, on 7-8 May, organised a high-level event on combating SLAPPs to support the 
review  of  the  Anti-SLAPP  Recommendation.  In  addition,  several  focus  groups  with  relevant  stakeholders  are  foreseen  for  June  2026,  to  support  the 
aforementioned review. 

Furthermore, to promote safe harbours for journalists, researchers and civil society organisations active in analysing the information environment and its 
evolutions (e.g. the impact of AI), the Commission will adopt guidelines to support the implementation of relevant EU rules, such as the Digital Services Act 
(DSA), the Regulation on political advertising or the AI Act. 

The financial support to media sectors of special relevance to democracy (including investigative journalism) under the cross-sectoral strand of Creative 
Europe since 2023 continues with support of around €5-7 million per year. 

33 

 
 
 
 
 
 
 
 
 
Reinforce the EU anti-fraud architecture  

Nr  Action 
33 

Enhance the involvement of civil society in the Commission’s anti-fraud efforts, notably by exploring the possibility to 
work with civil society organisations to increase whistleblowing and reporting of suspicions of fraud. 

Lead 
OLAF, DGs as 
appropriate 

Due date 
2024 

State-of-play May 2026 

This action has been completed in 2025. 

34 

 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
34  Maintain a high level of coordination and cooperation on anti-fraud matters between Commission departments and Executive 

Lead 
OLAF 

agencies through the Fraud Prevention and Detection Network (FPDNet) and its subgroups.  

Due date 
2023 and 
continuous 

State-of-play May 2026 

OLAF Correspondents and other anti-fraud professionals in Commission departments and Executive agencies meet in the Fraud Prevention and Detection 
Network (FPDNetwork) and its subgroups. These meetings are organised and chaired by OLAF, and a forum to share the latest developments on anti-fraud 
policy, develop such policy and exchange experiences. The FPDNet is involved in the coordination and monitoring of the implementation of the CAFS 
Action Plan. 

35 

 
 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
35  Regularly include aspects of the Commission’s anti-fraud policy on the agenda of the Corporate Management Board 

meetings, for example: 

a. 
the follow-up to OLAF's recommendations and – where applicable – information received from the EPPO; 
b.  overall progress in the implementation of the Commission's anti-fraud strategy and its accompanying action 

Lead 
SG, OLAF: lead 
All DGs: support 

Due date 
2023 and 
continuous 

plan. 

State-of-play May 2026 

The Commission’s Corporate Management Board (CMB) provides coordination, oversight, advice and strategic orientations on corporate management issues, 
including anti-fraud policy matters. OLAF’s Director-General is regularly invited to present aspects of the Commission’s anti-fraud policy. 

a.  In October 2025, OLAF was invited to the CMB meeting to discuss the follow-up of OLAF recommendations and information received from the EPPO.  
b.  In the same meeting, the CMB also discussed the state of play of the implementation of the CAFS action plan. Further, the CMB was briefed on the 

launch of the anti-fraud architecture review. 

In September 2025, the CMB was briefed about the audit of the European Court of Auditors’ (ECA) on cooperation between EU bodies fighting fraud. 

In December 2025, the CMB took note of the ECA’s Special report on tackling fraud in the Recovery and Resilience Facility. In March 2026, the CMB was 
updated on the ECA’s ongoing audit on the Commission’s anti-fraud strategy. 

36 

 
 
 
 
 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
36 

Improve continuously service-level anti-fraud strategies and their implementation, notably by: 
a.  updating such strategies and fraud risk assessments in principle every three years8; 
b.  seeking OLAF's advice at an early stage in the development of such a strategy or update, submitting the drafts 
for OLAF's mandatory review and to peer review, and justifying in writing when OLAF’s recommendations 
on the anti-fraud strategy have not been followed. Any issues that cannot be resolved between OLAF and the 
Commission department concerned may be discussed in suitable fora or be brought to the attention of the 
Corporate Management Board. 

State-of-play May 2026 

Lead 
All DGs and 
executive 
agencies: lead 
OLAF: support 

Due date 
2023 and 
continuous 

Service-level anti-fraud strategies help tailor anti-fraud measures to different policy areas and operations, thus increasing their effectiveness and efficiency. 
OLAF provides support for the elaboration of service-level anti-fraud strategies through methodological guidance elaborated in consultation with FPDNet, 
through training and tailor-made advice. 

a. In 2025, OLAF reviewed and approved the service-level anti-fraud strategies together with their fraud risk assessments of fifteen Commission departments 
and Executive agencies, in line with OLAF anti-fraud strategy methodology of June 2021. 

b. OLAF reviewed all anti-fraud strategies submitted in 2025 and early 2026. Since early 2024, all service-level anti-fraud strategies are subject to peer 
review. A great majority of departments and agencies follow the guidance of OLAF and no systemic issues in this regard were brought to the attention of the 
Corporate Management Board in 2025. 

8 In line with the 2019 CAFS and the anti-fraud strategy methodology of June 2021, ref. Ares(2021)4589215. 

37 

 
 
 
 
 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
37  Make  use  of  OLAF’s  investigative  experience  in  the  Commission’s  work  with  individual  Member  States,  notably  in  the 

Lead 
OLAF 

European Semester and in the Rule of Law processes where appropriate. 

Due date 
2024 and 
continuous 

State-of-play May 2026 

OLAF’s knowledge and experience from working in Member States with national authorities can be of relevance to the European Semester and the Rule of 
Law processes. 

As regards the European Semester process, OLAF participated in a number of meetings in 2025 and spring 2026 to better assess where OLAF’s contribution 
would be appropriate. 

As regards Rule of Law, OLAF contributed to the 2026 Rule of Law package and regularly participates in the discussions on individual Member States. 
OLAF continued to record potential Rule of Law issues in a dedicated module in its case management system. 

38 

 
 
 
 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr 
38 

Action 
In  implementing  the  EU’s  anti-corruption  policy9,  exploit  the  synergies  between  anti-fraud  and  anti-corruption 
policies, notably by identifying common areas of high risk and measures to address such risks. 

Lead 
HOME, 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2026 

In 2025, following a Commission reorganisation, the Anti-Corruption team joined DG JUST from DG HOME. As a result, action 38 is now also co-lead by 
DG JUST.  

At theThird Plenary Meeting of the EU Network Against Corruption (October 2025), OLAF presented its analysis on the relation between corruption and 
fraud to the detriment of the EU’s financial interests. 

Throughout 2025, DG JUST pursued negotiations with the co-legislators on a Directive on combating corruption and a provisional political agreement was 
reached between the European Parliament and the Council in December 2025. A study on Mitigating High-Risk Corruption in EU Member States will be 
finalised by DG JUST in the second quarter of 2026. 

Currently, the study on national anti-corruption strategies is being carried out. DG JUST also organised the Third Plenary Meeting of the EU Network Against 
Corruption and held other activities under this banner, including a number of national workshops in Member States. The EU Anti-Corruption Strategy is 
currently in preparation and is scheduled for adoption in Q4 2026. It will complement several other recent or ongoing initiatives, including the review of the 
EU Anti-Fraud Architecture (AFA). 

9 See the Anti-corruption package adopted by the Commission on 3 May 2023. 

39 

 
 
 
 
 
 
 
 
 
 
Reinforce the Commission's anti-fraud governance and maintain a high level of coordination and cooperation among Commission departments and Executive 
agencies  

Nr  Action 
39 

Exploit the synergies between policies against organised crime, fraud and corruption, notably by identifying sectors at risk of 
fraud and corruption by organised crime, and of its infiltration in the legal economy, and measures to address such risks. 

Lead 
HOME, 
OLAF 

Due date 
2023 and 
continuous 

State-of-play May 2026 

Fraud, corruption and organised crime are often interlinked. These interlinkages need to be better understood to allow for the development of holistic policies. 

On 16-17 October 2025, DG HOME organised a meeting with Member States and EU Agencies and bodies. The objective of the meeting was to prepare for 
the modernised rules to combat organised crime (as listed in the Commission Work Programme 2026), with a short session on criminal infiltration. 

OLAF is involved in EMPACT Operational Action OA 2.4, which focuses on fraud involving EU funds. OLAF contributed to a survey aimed at national 
judicial police responsible for investigating criminal fraud against the EU budget. The collection and analysis of survey results provided insights into how 
organised crime exploits EU funding mechanisms and could feed into future strategic responses. 

Part of the same EMPACT Operational Action OA 2.4, at the invitation of the Portuguese co-driver, in November 2025, OLAF also attended and delivered 
two presentations during the Capacity Building meeting on Strategy and Investigative Techniques on Fraud Involving EU Funds. The presentations focused 
on the Office mandate, structure and cooperation framework but also delivered a thorough overview of OLAF tools repository including AI developments, 
highlighted different analytical techniques and presented OLAF facilitated trainings (Anti-Fraud Intelligence Analysis - AFIA and Digital Forensics and 
Analysts - DFAT). 

40 

 
 
 
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
40  Map, enhance and promote existing ethics and anti-fraud training and awareness raising for staff at all levels across 
the Commission, and reinforce the existing financial learning activities with additional messages on ethics and anti-
fraud matters. 

Lead 
OLAF, HR, SG, 
BUDG: lead 
All DG’s: support 

Due date 
2024 

State-of-play May 2026 

This action has been completed. Further streams of work deriving from this action were carried out throughout 2025.  

DG BUDG continued to disseminate its training video on conflict of interest in the management of EU budget and to strengthen its messages on the protection 
of the EU financial interests through its regular BUDG training sessions. 18 training sessions took place between June 2025 and May 2026. The development 
of a new training video on EDES with focus on exclusion cases with engagement of the EDES panel is in progress. Additionally, BUDG continued to promote 
other (non-BUDG) anti-fraud and ethics training events in its financial learning paths (i.e. fraud and bid rigging). 

DG HR redesigned the ethics e-learning module. It will be delivered in September 2026 and include a specific anti-fraud section. 

OLAF  delivered  in  November  2025  the  ‘Customisable  anti-fraud  training  modules’  available  to  Commission  services  to  be  further  tailored  to  their 
specificities. 

41 

 
 
 
 
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
41 

Promote awareness on Members’ ethical obligations among Members of the Commission and Cabinets through 
the  Network  of  Ethics  and  Transparency  Contact  Points  and  through  targeted  information  for  Members  at  the 
beginning and end of their mandates. 

Lead 
SG: lead 
OLAF, HR: support 

Due date 
2023 and 
continuous 

State-of-play May 2026 

The EU Treaties and the Code of Conduct for the Members of the European Commission lay down the rules on how Members should perform their duties. 
They shall observe the highest standards of ethical conduct. 

In 2020, the Commission established a Network of Ethics and Transparency Contact Points composed of correspondents in the Cabinets of the Members of 
the Commission. The aim is to raise awareness on the Members’ obligations in the areas of ethics and transparency. The Network serves as a regular platform 
for the exchange of information, and meetings are organised on routine basis. 

In 2025, three meetings of the Network of Ethics and Transparency Contact Points took place, including one dedicated to updates of the Members’ declarations 
of interests. Furthermore, information sessions were held for both outgoing and incoming Members of the Commission, aiming to raise awareness as regards 
the ethical obligations applicable to them under the Treaty and the Code of Conduct. 

42 

 
 
 
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
42 

Provide  corporate  training  and  guidance  on  grants  and  procurement,  including  on  simplified  forms  of  reimbursement  for 
grants, while ensuring that the training and guidance contain relevant anti-fraud elements.  

Lead 
BUDG 

Due date 
2024 and 
continuous 

State-of-play May 2026 

Direct expenditure, primarily in the form of grants and procurement, accounts for a substantial portion of the Union’s budget. Simplified funding mechanisms 
- such as simplified cost options (SCOs), including lump sums and flat rates - offer significant potential to reduce administrative burden and lower error rates. 
As a result, their use in EU grant funding is increasingly widespread. 

Throughout 2025, seven workshops were held on grants, featuring practical exercises on simplified cost options, while  14 procurement-focused sessions 
addressed anti-fraud measures, conflicts of interest, and professional conflicting interests. The training video on conflicts of interest remained accessible on 
BUDGpedia. The video explains what constitutes a conflict of interest in EU budget management, how to identify, prevent, and address such conflicts, and 
how to safeguard the budget’s integrity—including in procurement-related professional conflicts. 

The BUDGpedia page dedicated to simplified cost options is updated regularly, and the video on conflicts of interest is incorporated into standard BUDG 
training courses to enhance dissemination. 

EDES state of play is regularly presented at the RUF meetings and EDES-related elements were discussed in the Procurement Experts Platform (PEP) in July 
2025, as well as in February 2026. EDES corporate trainings are held throughout the year: six regular trainings per year plus several ad hoc sessions and/or 
workshops tailored for target audience (specific institutions, agencies or expert groups). 

43 

 
 
 
 
 
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
43  Based on identified needs and priorities of Commission departments and Member States, perform and disseminate 

strategic analysis and guidance, notably to: 

Lead 
OLAF: lead 
All DGs: support 

Due date 
2023 and 
continuous 

a.  feed into training and awareness raising, fraud risk assessments, and other prevention and detection activities 

b. 

of Commission departments, agencies, Member States and other anti-fraud partners; 
translate audit results and experience from investigations into concrete advice on fraud risks, fraud patterns 
and red flags, for example, in the form of case compendia. 

State-of-play May 2026 

To increase the anti-fraud knowledge of the Commission, partner organisations and Member States, notably on fraud risks, trends and modus operandi, 
OLAF has established a strategic analysis function within its Anti-Fraud Knowledge Centre. 

In 2025, OLAF updated and disseminated two strategic analysis reports on agriculture and cohesion policy to relevant Commission services and Member 
States, to feed into their fraud risk assessments. Updated versions of these reports will be disseminated in 2026. 

OLAF also carried out an analyis of fraud and irregularities that concerned payments for agricultural practices beneficial to the climate and the environment, 
to better understand the actual reasons behind the reporting of these irregularities. Concerning the cohesion policy, fraud and irregularities that concerned 
ERDF funding in relation to European Territorial Cooperation were scrutinised. The main findings fed into the Statistical Evaluation accompanying the 2025 
PIF Report.  

In addition, OLAF has significantly expended the analysis of fraud and irregularities to cover the whole anti-fraud cycle, including prevention, recovery and 
sanctioning. This holistic approach to the analysis of fraud and irregularities feeds into new indicators about the functioning of the management and control 
systems. 

44 

 
 
 
 
  
 
 
 
Strengthen the culture of ethics and anti-fraud in the Commission  

Nr  Action 
44  Consider  anti-fraud  aspects  when  reviewing  the  recruitment  process  in  the  context  of  the  implementation  of  the 
Commission's  new  HR  strategy,  notably  in  the  behavioural  assessments  and  in  the  training  of  selection  panels,  and 
reinforce the checks of originals of qualifications and certificates of candidates. 

Lead 
HR: lead 
OLAF: 
support 

Due date 
2023  

State-of-play May 2026 

The action has been completed in 2025. 

45