COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of Article 325 TFEU 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

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   EUROPEAN COMMISSION  Brussels, 28.7.2026  SWD(2026) 249 final  COMMISSION STAFF WORKING DOCUMENT Measures adopted by the Member States to protect the EU's financial interests - Implementation of Article 325 TFEU 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) 250 final} - {SWD(2026) 251 final}  
 
 
CONTENTS 
List of abbreviations ............................................................................................................... 6 

Introduction ........................................................................................................................... 7 

Overview of findings ............................................................................................................... 8 

Common topics and trends in 2025 ....................................................................................... 12 

1.1 Early-stage risk identification and exclusion..................................................................... 12 

1.2 Managing the flow of information ..................................................................................... 13 

1.3 Trainings, raising awareness, capacity-building ............................................................... 16 

1.4 Trends in legislative measures: higher penalties, new sanctions ....................................... 17 

Follow-up on the 2024 and 2023 topics ................................................................................. 18 

1.5 Conflict of interest .......................................................................................................... 18 

1.6 Digitalisation .................................................................................................................. 20 

1.7 Cooperation and information exchange ........................................................................... 20 

1.8 Whistleblowers ............................................................................................................... 21 

LIST OF MEASURES WITH A 

COMPONENT ................................................................... 22 

LIST OF MEASURES WITH AN 

 COMPONENT ........................................................... 23 

LIST OF MEASURES WITH AN 

COMPONENT ......................................................... 24 

LIST OF MEASURES WITH AN 

 COMPONENT ............................................................... 25 

How to read this report ......................................................................................................... 27 

Member States ..................................................................................................................... 29 

Austria .............................................................................................................................. 29 

2.1 Frequent verifications ..................................................................................................... 29 

Belgium ............................................................................................................................. 30 

2.2 Mandatory anti-fraud trainings ........................................................................................ 30 

2.3 Ex-ante use of Arachne for conflict of interest .................................................................. 32 

2.4 Declarations of internal and external evaluators .............................................................. 32 

2.5 Additional measures reported by Belgium in 2025 ............................................................ 33 

Bulgaria ............................................................................................................................. 34 

2.6 Amendment of the Administrative Violations and Penalties Act ........................................ 34 

2.7 Amendment of the Protection of Persons Whistleblowing or Publicly Disclosing Information 
on Violations Act (ZZLPSPOIN) .............................................................................................. 35 

2.8 Amendment to the Public Procurement Act (ZOP) ............................................................ 36 

Croatia .............................................................................................................................. 36 

2.9 Amendment of the Criminal Procedure Act ...................................................................... 37 

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2.10 Amendments to the Criminal Code ................................................................................ 38 

2.11 Full implementation of management information system “eKohezija” ............................ 39 

Cyprus .............................................................................................................................. 39 

2.12 Registration of lobbyists and disclosure of meetings – trainings ...................................... 39 

2.13 Code of Conduct for Public Officials – update and targeted training ................................ 41 

2.14 Reform of the e-procurement system of the Treasury of the Republic .............................. 41 

2.15 Additional measures reported by Cyprus in 2025 ............................................................ 43 

Czech Republic ................................................................................................................. 43 

2.16 Ending tax confidentiality in respect of labour inspection bodies .................................... 44 

2.17 Structured cooperation with taxi service providers via e-platforms (Uber and Bolt) .......... 44 

2.18 Internal training action .................................................................................................. 45 

Denmark ........................................................................................................................... 46 

2.19 Implementation of a new whistleblower system ............................................................. 46 

2.20 Fine-tuning of the guidelines for reporting financial irregularities through IMS ................. 46 

Estonia .............................................................................................................................. 47 

2.21 Legislative amendments tightening the framework for customs‑ and sanctions‑ related 
misdemeanours ................................................................................................................... 47 

2.22 Introduction of personal income tax risk managers ........................................................ 48 

2.23 Fraud-prevention plan under a unified system................................................................ 48 

2.24 Additional measures reported by Estonia in 2025 ........................................................... 49 

Finland .............................................................................................................................. 50 

2.25 Update and organisational rollout of the guidelines on the administrative and control 
system. ................................................................................................................................ 50 

2.26 Training on good administrative practices ...................................................................... 50 

2.27 Targeted control measures in IOSS assets ..................................................................... 51 

France ............................................................................................................................... 51 

2.28 Improving administrative and judicial cooperation ......................................................... 52 

Germany ........................................................................................................................... 52 

2.29 Prevention and detection of conflicts of interest in the agricultural/fisheries sector. ........ 52 

2.30 A guidance document on the prevention of conflicts of interest (State of Rhineland-
Palatinate) ........................................................................................................................... 53 

2.31 Increased number of on-site inspections (State of Schleswig-Holstein) .......................... 54 

2.32 Additional measures reported by Germany in 2025 ........................................................ 54 

Greece .............................................................................................................................. 54 

2.33 Transfer to the Independent Authority for Public Revenue ............................................... 54 

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2.34 Interventions in the institutional framework of public procurement – law reform ............. 57 

2.35 Development of a system for supervising the implementation of the management and 
control system – project implementation .............................................................................. 59 

Hungary............................................................................................................................. 61 

2.36 Support activities and guidance from the Public Procurement Authority.......................... 61 

2.37 Ensuring integrity of staff at the National Development Centre ....................................... 62 

2.38 Post-release controls for preventive purposes ............................................................... 63 

Ireland ............................................................................................................................... 64 

2.39 Revision of the Department of Agriculture, Food and the Marine Fraud Policy .................. 64 

2.40 Enhanced management and control systems for Just Transition Fund ............................. 65 

2.41 Regular updates of Fraud Risk Profile of PEACEPLUS fund .............................................. 66 

2.42 Additional measures reported by Ireland in 2025 ............................................................ 68 

Italy ................................................................................................................................... 69 

2.43 Introducing criminal and administrative sanctions for the violation of EU restrictive 
measures ............................................................................................................................. 69 

2.44 Systematic integration and strengthening of Arachne/SAS model ................................... 70 

2.45 Digitalisation of the register on cases of serious irregularities ......................................... 71 

2.46 Additional measures reported by Italy ............................................................................ 73 

Latvia ................................................................................................................................ 74 

2.47 Establishment of the Tax and Customs Police as a separate institution ........................... 74 

2.48 Annual AFCOS Discussions on Emerging Fraud Risks and the Impact of EU Case Law on EU 
Funds Management .............................................................................................................. 75 

2.49 Capacity‑building activities in public procurement processes ........................................ 75 

2.50 Additional measures reported by Latvia in 2025 ............................................................. 77 

Lithuania ........................................................................................................................... 78 

2.51Trainings strengthening competencies of institutions managing EU Structural funds ........ 78 

2.52 Infringements in agriculture sector – amendments to legal acts ...................................... 78 

Luxembourg ...................................................................................................................... 79 

2.53 Update of control and monitoring system for the national implementation of the RRF ..... 79 

2.54 Guidelines on ESF+ procedural matters ......................................................................... 80 

2.55 Adding a new feature – a whistleblower button ............................................................... 81 

Malta ................................................................................................................................. 82 

2.56 Communications campaign against fraud and misuse of public funds ............................ 82 

Netherlands ...................................................................................................................... 82 

2.57 Annual self-declaration of absence of a potential conflict of interest .............................. 83 

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2.58 Complete revision of the Interreg Meuse-Rhine antifraud policy programme ................... 83 

2.59 Legislative amendment against misuse of legal exception rules ...................................... 84 

Poland ............................................................................................................................... 84 

2.60 Strengthening selection of projects with potential conflict of interests ............................ 85 

2.61 Verification of declarations of impartiality ...................................................................... 85 

2.62 Guidelines for controls under the development plan co-financed by the RRF .................. 86 

Portugal............................................................................................................................. 87 

2.63 Implementation of measures set out in the National Anti-Fraud Strategy (NAFS) ............. 87 

2.64 Updating of mechanisms to support risk assessment, analysis and management when 
implementing EU funding ...................................................................................................... 88 

2.65 Development of a new customs anti-fraud database ...................................................... 89 

Romania ............................................................................................................................ 89 

2.66 Strengthening the legal framework to prevent and combat corruption of foreign public 
officials ................................................................................................................................ 90 

2.67 Strengthening the operational capacity of the National Anti-Corruption Directorate ........ 91 

2.68 Strengthening customs control and supervision mechanisms ........................................ 92 

2.69 Additional measures reported by Romania in 2025 ......................................................... 93 

Slovakia............................................................................................................................. 94 

2.70 Improving reporting and strengthening communication channels ................................... 94 

2.71 Strengthening control and audit system of public financial resources ............................. 95 

2.72 Strengthening the protection of the EU’s financial interests within the framework of the CAP
 ............................................................................................................................................ 97 

Slovenia ............................................................................................................................ 99 

2.73 Automatic verification of double co-financing ................................................................ 99 

2.74 Exchange of information between national police and EPPO ......................................... 100 

2.75 Amendment of money laundering prevention legal act ................................................. 101 

Spain ............................................................................................................................... 102 

2.76 Approval of the State Plan to Combat Corruption ......................................................... 103 

2.77 Establishment of the State Independent Whistleblower Protection Authority ................ 105 

2.78 Creation of an operational group dedicated to EPPO cases .......................................... 106 

2.79 Additional measures reported by Spain in 2025 ............................................................ 107 

Sweden ........................................................................................................................... 108 

2.80 Strengthening of penalties for certain offences ............................................................ 108 

2.81 Report on the conditions for reducing the risk of double funding ................................... 109 

Case studies ...................................................................................................................... 110 

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Case study 1. The case of a missing trader company, reported by Italy ............................... 111 

Case study 2. The case of an attempted cigarettes smuggling, reported by Croatia ............ 112 

Case study 3. The case of imports from third countries and fictitious movement of goods 
between EU countries, reported by Czech Republic .......................................................... 112 

Case study 4. The case of waffle factory funded with ERDF, reported by Belgium ............... 113 

Case study 5. The case of nineteen identical applications, reported by Slovakia ................ 114 

Case study 6. The case of inflated costs of beekeeping equipment, reported by Romania ... 115 

Case study 7. The case of conflict of interest (family connections), reported by Hungary .... 116 

Case study 8. The case of conflict of interest (professional ties with both the beneficiary and 
the contractor), reported by Bulgaria ................................................................................ 117 

Case study 9. The case of targeted operation against food fraud, reported by Greece ......... 118 

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List of abbreviations 
AFCOS  
CAP 
EAFRD   
EAGF 
EDES 
EPPO  
ERDF  
ESF  
ESF+ 
EU  
FEAD  
IMS 
NAFS  
OECD 
OLAF  
PIF  
RRF  
RRP  
TEU 
TFEU 
VAT  

Anti-Fraud Coordination Service  

Common Agricultural Policy  

European Agricultural Fund for Rural Development  

European Agricultural Guarantee Fund  

Early Detection and Exclusion System  
European Public Prosecutors’ Office  

European Regional Development Fund  

European Social Fund EU European Union  

European Social Fund Plus  

European Union  

Fund for European Aid to the Most Deprived  

Irregularity Management System 

National Anti-Fraud Strategy  

Organisation for Economic Cooperation and Development 
European Anti-Fraud Office  

Protection of the EU’s Financial Interests  

Recovery and Resilience Facility  

Recovery and Resilience Plan  

Treaty on European Union  

Treaty on the Functioning of the European Union 

Value Added Tax 

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Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

Introduction 
Article 325(2) of the Treaty on the Functioning of the European Union (TFEU) obliges Member 
States to take the same measures to counter fraud affecting the EU’s financial interests as those 
used  to  protect  their  own  financial  interests.  Paragraph  5  adds  that  the  Commission,  in 
cooperation with Member States, should submit a report to the European Parliament and the 
Council each year on the measures taken to implement this Article.  

The Commission asked the Member States to report on up to three measures adopted in 2025 
they considered most important for the protection of the EU’s financial interests. This report 
shows common trends as well as includes detailed information provided by each Member State 
on their country measures.  

The data presented in this report comes from Member States responses collected with the PIF 
Questionnaire  2025.  The  survey  collected  both  structured  and  unstructured  (free  text) 
information. The report first presents an overview of the measures reported in 2025, followed 
by lists of all measures, divided by the type of action, and then covers in detail each measure 
reported  by  each  Member  State. The  last  part  includes  9  case  studies  provided  by  Member 
States.  

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Overview of findings  
In  2025,  Member  States  reported  72  measures  aimed  at  strengthening  their  anti-fraud 
architecture and protection of the EU funds. Each country could  report up to  3 measures of 
type of 
action. Out of 72 total, 25 package measures were reported, with 12 of those covering more 
than one type of action. Package measures consist of multiple actions adopted simultaneously 
to achieve the same objective. The rest were 47 single measures.      

, or 

, 

, 

Reported  measures  concern  all  stages  of  the  anti-fraud  cycle,  from  prevention,  through 
detection, investigation and prosecution, to recovery and sanction. In 2025, the focus was on 
the first two stages of the cycle: over 79% (57) of all measures addressing the prevention stage 
and nearly 67% (48) the detection stage.  

79% (57) 

67% (48) 

Prevention

Detection

Recovery 
and 
Sanction

Investigation 
and 
Prosecution

29% (21) 

36% (26) 

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

Each of the reported measures  can be classified  according to  the type of action it entails. A 
type  of  action  refers  to  legal  acts  adopted  or  amended  to  enforce  legal 

obligations.   

In  2025,  Member  States  reported  20  measures  which  had  a  legislative  component, 
including 7 new legislations and 16 amendments (in 3 cases it was both). In the case of 
9 measures, the aim was to clarify or consolidate existing rules or remedy flaws. Another 
4 measures aimed to enforce the rules in line with developments in EU law. The remaining 
ones had multiple objectives. 

Four measures were related to criminal sanctions, either introducing new ones (2) or 
strengthening  the  existing  ones  (2).  In  one  case,  new  legislation  introduced  criminal 
sanctions and extended the time barring.  

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Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

measures  concern  legal  acts  adopted  by  an  administrative  body  that 
implement actions provided by legislative acts. Measures may apply across multiple services 
and bodies (cross-cutting measures). 

Member States reported 26 measures in 2025, which had an administrative component, 
including  11 new  and 19 updated  measures  (in 4 cases  it was both).  Those include:  3 
decisions/resolutions,  3 
instructions, 
guidelines, or manuals, 3 action plans, and 3 others (for example trainings). Majority, 21 
measures,  aimed  to  clarify  or  consolidate  existing  rules  or  enhance  them.  In  total,  11 
measures impact more than one agency (cross-cutting measures).  

recommendations,  14  Circulaire/circular, 

Another type of action is 
meaning decisions or any other non-legislative 
action taken to change the organisational framework of an administration or body whose tasks 
and activities relate to the protection of the EU’s financial interests.  

In 2025, Member States reported 20  measures  which had an organisational  component, 
including 12 new and 9 updated measures (in 1 case it was both). In terms of expected 
results  on  resource  use,  13  measures  were  neutral  on  resources,  and  for  7  measures  an 
increased  use  of  resources  was  reported.  No  measure  reported  in  2025  was  linked  to  a 
decreased resource use.  

Finally, 
measures concern any action with a direct impact on its operations, 
undertaken by an administration or body whose tasks and activities relate to the protection of 
the EU’s financial interests.  

In  2025,  Member  States  reported  26  measures  which  had  an  operational  component, 
including 16 new and 12 updated measures (in 2 cases it was both). For most measures 
(21/26), multiple expected results were mentioned: 18 mentioned effects on targeting of 
checks,  16  enhanced  information  flow,  13  enhanced  ex-ante  controls,  12  enhanced 
coordination, 11 enhanced cooperation, 10 enhanced ex post controls, and 8 targeting of 
investigations.  

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Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
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Measures  adopted  by  Member  States  address  fraud  risks  in  different  areas  vulnerable  to 
irregularities or misconduct. It is possible for a measure to target more than one area. In 2025, 
the most frequently targeted area was “Shared Management and Control of the EU funds”, 
with 36 mentions across 72 measures (17.1% of all mentions). Roughly 1 in 3 measures also 
mentioned  “Conflict  of  Interest”  (12.4%  of  all  mentions)  or  “Antifraud  and Anticorruption 
Strategy” (nearly 11.4% of all mentions). 

Areas targeted in 2025

 Shared Management and Control of the EU Funds

 Conflict of Interest

 Antifraud or Anticorruption Strategy

 Public Procurement

 Corruption

 Financial Crime (Including Money Laundering)

 Organised Crime

 Whistleblower

 Other

 Fraud Definition

 AFCOS

 Customs/Tor/Illicit Trade

0

5

10

15

20

25

30

35

40

Number of mentions (total=210)

Note: One measure can target multiple areas. Out of 72 measures reported, 22 target one area, 17 target two 
areas, 13 target three areas, 9 target four areas, 1 target five areas, 5 target six areas, 1 target seven, eight and 
nine areas, respectively, and 2 target 10 areas.  

“Other” areas include fraud and duplication of funding, irregularity reporting and investigation, 
protection of persons reporting regulatory violations, transparency and integrity, and internal 
audits.  

An anti-fraud measure may affect all sectors of the EU budget (horizontal measure) or target 
specific sectors (sectoral measure). Across all types of measures, Member States report some 
level of horizontal and sectoral activity. It is visible that 
measures tend to 
concern specific sectors.   

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Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

Sectoral  Horizontal 

Total 

Single 
Package 
Single 
Package 
Single 
Package 
Single 
Package 

Total single: 
Total packageNote: 
Total: 

5 
3 
4 
9 
6 
7 
12 
10 
27 
14 
41 

9 
3 
7 
6 
2 
5 
2 
2 
20 
11 
31 

14 
6 
11 
15 
8 
12 
14 
12 
47 
25 
72 

   20 

26 

20 

26 

72 measures & 
92 types of action 
mentioned  

Note: Package measures may cover more than one type of action. This affects the total number of mentions of each 
measure type. There were 25 package measures reported in 2025, which mentioned 45 types of actions.  

Sectoral measures target at least one of the sectors in the Revenue or the Expenditure domain. 
This  means that one measure may target  more than one sectors. In 2025, out  of 41 sectoral 
measures, 25 targeted one sector, 13 targeted two, 1 targeted four, 1 targeted six, and 1 targeted 
eight sectors.  

The following graph presents the number of mentions of each sector by the type of measure. 
The  most  frequently  targeted  sector  in  2025  was  the  Expenditure  side  of  Cohesion  Policy 
funds.  

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Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

Sectors targeted in 2025

Revenue: Customs

Revenue: Tax Fraud

4

4

Expenditure: Agriculture

Expenditure: Fisheries

Expenditure: Cohesion Policy

Expenditure: Centralised Direct Management

Expenditure: Fund For The Most Deprived

Expenditure: Globalisation Fund

Expenditure: Migration And Asylum

Expenditure: Recovery And Resilience Facility

2

2

2

2

2

2

1

1

0

2

3

5

1

3

2

1

1

1

2

6

4

5

5

3

3

3

1

6

10

4

10

15

20

25

Number of mentions (total=88)

LEGISLATIVE

ADMINISTRATIVE

ORGANISATIONAL

OPERATIONAL

Note: There are 14 sectoral package measures, which include components of multiple types of action and target 
multiple sectors, resulting in the number of mentions equal to 88. 

Common topics and trends in 2025 

Measures reported by Member States in 2025 address various aspects of fraud, target multiple 
areas  and  sectors  and  affect  all  stages  of  the  anti-fraud  cycle.  Upon  closer  analysis,  it  was 
possible to identify common topics, across the Member States’ responses in 2025’s responses. 
Those  include  focus  on  early-stage  risk  identification  and  exclusion,  managing  the  flow  of 
information and capacity-building activities.  

1.1 Early-stage risk identification and exclusion  

The clear focus on the prevention and detection of stages of the anti-fraud cycle is visible across 
all reported measures. In 2025, Member States reported multiple measures that focus on early 
detection of ‘unreliable’ counterparts and their exclusion from further procedures. This might 
include  counterparts  previously  engaged  in  fraudulent  or  irregular  activities  or  those  not 
properly disclosing conflict of interest. On top of mitigating risks of fraud, early detection and 
exclusion facilitates effective and targeted use of resources.  

Member State 

Target 

Type of measure 

Description 

Early-stage risk identification and exclusion 

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financial interests 

Belgium  

Identifying 
potential conflict 
of interest 

Administrative 

Prior to the evaluation of project proposal evaluators 
tick declaration of honour. A sample of statements is 
verified via Arachne.  

Bulgaria  

Excluding 
unreliable 
economic 
operators 

Legislative 

Mandatory exclusion from award procedures of 
persons convicted of certain offences.  

Cyprus 

Identifying red 
flags  

Administrative 

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

Hungary 

Excluding 
fraudulent 
taxpayers 

Operational 

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

Ireland  

Performing 
eligibility and 
compliance 
checks 

Administrative 

Organisational 

Operational 

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

Poland  

Identifying 
potential conflict 
of interest 

Operational 

At the stage of selecting projects, using SAMPLER 
tool to verify conflict of interest, which simplifies the 
subsequent procedures.  

1.2 Managing the flow of information 

In 2025, Member States frequently reported measures focused on streamlining information flow 
as well as harmonising approach and reporting practices. It seems that managing large amounts 
of  data  is  one  of  key  priorities. Approaches  vary  between  Member  States,  but  a  common 
objective  emerges  –  being  able  to  effectively  process  and  access  the  data.  Examples  show 
measures  introducing  guidelines,  checklists,  or  common  reporting  standards,  designating 
dedicated bodies and transferring fraud-related responsibilities, updating and adding features to 
data systems, and creating dedicated databases.  

Accessibility  and  quality  of  the  collected  data  is  key  for  robust  analytical  work.  Common 
practices  regarding  data  collection  means  and  data  formats  help  improve  data  quality  and 

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Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

enhance  data  usability.  In  2025,  many  Member  States  reported  measures  taken  to  improve 
quality and access to the data, simultaneously strengthening their other anti-fraud efforts.  

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

Member State 

Type of measure 

Description 

Croatia 

Operational 

Cyprus  

Administrative 

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

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

Finland 

Administrative 

Guidelines on the use of administrative and control system.   

Italy  

Portugal  

Administrative 

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

Operational 

Computerisation of register of cases of serious irregularities to 
allow constant flow of information.   

Administrative 

Dashboards sharing risk monitoring information with 
managing authorities.  

Operational 

Development of a new customs anti-fraud database with 
interoperability with EU and national systems. 

Slovakia 

Operational 

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

Slovenia 

Operational 

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

Member State 

Type of measure 

Description 

Managing the flow of information: Quality of reporting 

Cyprus 

Administrative 

Among others, trainings on using IMS and EDES systems.  

Denmark  

Administrative 

Guidelines on proper reporting of irregularities clarifying 
identified ambiguities.  

Germany 

Administrative 

Workshop dedicated to IMS system. 

Luxembourg 

Administrative 

Organisational 

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

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Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
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Poland 

Operational 

Administrative 

Slovakia  

Organisational 

Operational 

Framework checklist harmonising approach of various 
institutions in selecting elements for verification during checks 
on public procurement and state aid. 

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

In  2025,  Member  States  reported  on  changes  to  the  administrative  structures  aimed  at 
facilitating information flow and clearer division of responsibilities in the anti-fraud domain. 
Reported examples show, that new institutions, or units within existing ones, have been created 
to  consolidate  competencies  in  various  anti-fraud  aspects.  Establishment  of  dedicated 
responsible bodies additionally streamlines communication with other national and EU-level 
counterparts and benefits from knowledge of highly specialised staff.  

Member State 

Managing the flow of information: Dedicated bodies/functions 
Type of measure 

Description 

Estonia 

Organisational 

Designation of a new position of personal income tax manager. 

Legislative 

Administrative 

Organisational 

Greece 

Operational 

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

Legislative 

Establishment of a Register of Public Procurement 
Professionals, with the main objective of simplifying, 
streamlining and enhancing the transparency, integrity and 
efficiency of public procurement procedures (Law 5218/2025). 

Organisational 

Latvia  

Transformation of Tax and Customs Police Department into an 
independent direct administration institution - the Tax and 
Customs Police aimed at separating and transferring 
responsibilities. 

Organisational 

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

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Legislative 

Slovakia 

Administrative 

Organisational 

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

Spain  

Administrative 

Establishment of the State Independent Whistleblower 
Protection Authority. 

Organisational 

Establishment of an operational group dedicated to EPPO 
cases.   

1.3 Trainings, raising awareness, capacity-building  

Member States report continuous efforts to raise awareness and enhance knowledge and skills 
of individuals engaged in anti-fraud actions. Through trainings and guidelines Member States 
ensure relevant staff is familiar with current fraud risks as well as systems and procedures and 
therefore  able  to  adequately  address  fraud  and  irregularities  Additional  measures,  not 
mentioned in the table, may include trainings on specific IT systems or technical guidelines.  

Member State 

Type of measure 

Description 

Trainings and capacity-building activities 

Belgium 

Organisational 

Mandatory e-learning on combating fraud from top managers and 
project managers. 

Administrative 

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

Cyprus 

Administrative 

Trainings and guidance to all bodies involved with EU funds aimed at 
setting common standards.  

Administrative 

Targeted training program covering key PIF-areas by the Treasury of 
the Republic of Cyprus for officials from all authorities involved with 
EU funds.  

Czech 
Republic 

Organisational 

Internal training action for staff of the managing authority of 
Operational Programme Employment+. 

Finland 

Administrative 

Training on good administrative practices aimed at harmonising 
approaches. Increasing awareness within organisation.  

Germany 

 Administrative 

Guideline document on prevention of conflict of interest. 

Hungary  

Operational 

Hungarian Public Procurement Authority updated guidelines on 
examination of exceptionally low prices, dynamic purchasing system, 

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provided online training and organised conferences focused on 
conflict of interest and integrity issues.  

The Northern and Western Regional Assembly, a Managing Authority 
responsible for the European Regional Development Fund introduced 
an administrative measure to bolster capacity building. They increased 
initiatives to boost staff awareness with anti-fraud training for 
governance and control of funds. This has been in many areas 
including public procurement, conflicts of interest, state aid, integrity 
and transparency. 

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

Trainings in the area of transparency and the fight against corruption 
and fraud addressed at institutions involved with the European Union 
Structural Funds. 

Ireland  

Administrative 

Latvia 

Organisational 

Lithuania 

Organisational 

Malta  

Administrative 

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

Slovakia 

Organisational 

Spain  

Operational 

Training focused on protection of financial interests of EU in both the 
expenditure and revenue sides of the EU budget (tax and customs 
fraud, money laundering, irregularities, and financial corrections, etc.), 
targeting law enforcement authorities and employees of managing and 
intermediary bodies, audit and control bodies, as well as employees 
working in the area of traditional own resources. 

The Conflict of Interest Advisory Unit continued dissemination of 
good practices. The Spanish AFCOS continued its intensive training 
work on the prevention and fight against fraud to the EU's financial 
interests.  

1.4 Trends in legislative measures: higher penalties, new sanctions 

Legislative changes adopted in 2025 revised and sanctioned new offences, for example related 
to bribing of representatives. Regarding penalties and sanctions, relevant legislative measures 
favour a stricter approach, increasing the existing criminal sanctions and introducing new ones 
as well as extending time barring for recognised offences.  

Member State  

Target 

Description  

Trends in legislative measures 

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Bulgaria 

A legal person that has 
benefited or would benefit 
from a criminal offence 

In addition to pecuniary sanctions, new sanctions 
were introduced, including a temporary ban on 
participation in funding procedures and public 
disclosure of decision. 

Croatia 

Inclusion of all acts of passive 
and active bribery  

Revised and broadened definition of bribery of 
representatives.   

Czech 
Republic 

Illegal employment and tax 
evasion 

New provision allows exchange of information 
between labour inspection bodies and law 
enforcement. 

Estonia 

Legal and natural persons in 
customs cases 

Maximum penalty amount was increased, and 
misdemeanour fine unit was doubled. 

Italy  

Romania 

Sweden 

Violation of EU restrictive 
measures (asset freezes, 
embargos etc.) 

Introducing criminal and administrative sanctions 
and assets confiscation. Longer time barring and 
enhanced sanctions.  

Foreign public officials in 
international economic 
operations  

Aggravated fraud related 
offences, bribery and 
aggravated bribery offences 

Strengthening frameworks and introducing new 
criminal sanctions. 

Proposal to increase minimum penalties. 

Follow-up on the 2024 and 2023 topics  

This section follows up on the topics popular in the last two years and shows how measures 
reported 2025 continue efforts from previous years. The common topics of previous two years 
include:  conflict  of  interest  (2024),  digitalisation  and  new  technologies  (2024  and  2023), 
cooperation and information exchange (2024), and whistleblowers (2023).   

1.5 Conflict of interest  

Similarly  to  2024,  identifying  and  addressing  situations  where  conflict  of  interest  occurs 
remains at interest of the Member States, with 26 measures targeting this area in 2025. Member 
States  use  different  tools  to  address  the  issue,  relying  on  staff  declarations,  building 
organisational culture of integrity, or verifications of said declarations, often with the help of 
IT systems.  

Selected measures addressing conflict of interest 

Tool used 

Target 

Description  

Member State  

Type of 
measure 

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Administrative  

IT tool for 
verification 

Operational 

Declarations 

Administrative  Code of conduct 

Conflict of 
interest 

Conflict of 
interest  

Extended use of Arachne for conflict of 
interest verification of all funds. Sample 
of declarations will be verified.    

Conflict of interest analyses and updated 
manuals of the ESF+, ERDF and RRF 
programmes including declarations of 
internal and external evaluators.  

Conflict of 
interest,  
Integrity of staff 

Revised document sets enforceable 
standards on integrity, impartiality and 
conflicts of interest for officials 
managing EU funds.  

Belgium  

Cyprus 

Administrative 

IT tool for 
verification 

Conflict of 
interest 

Germany 

Administrative 

Declarations 

Conflict of 
interest 

Automated workflows, role-based access 
and time-stamped records reduce 
discretion and conflicts of interest. 

Guidance document on prevention was 
issued for all entities involved, which are 
now expected to draw up and sign 
conflict of interest declarations.  

Legislative 

Hungary 

Organisational 

Operational 

Cross-
verification of 
data 

Integrity of staff 

Checks on data retrieval from EU tender 
systems.   

Netherlands 

Operational 

Declarations 

Integrity of staff 

Annual declarations confirming absence 
of conflicts of interest must be signed by 
all persons involved in projects requiring 
assessment.  

Operational 

IT tool for 
verification 

Conflict of 
interest 

Conflict of interest verification procedure 
in the SAMPLER tool.  

Poland 

Operational 

Declarations 

Conflict of 
interest  

Verification of the declarations of the 
members of the evaluation committee by 
an independent organisational unit in the 
managing authority.  

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1.6 Digitalisation  

Digitalisation and the use of IT tools to fight fraud is essential for timely and effective response. 
While  digitalisation  remains  an  important  objective,  it  seems  that  the  focus  has  shifted  to 
making use of the available data, streamlining its flow, and ensuring quality and harmonisation. 
A summary of the measures falling into this topic is covered in section 1.2 Managing the flow 
of information. Nevertheless, new systems are being introduced, and new digital databases are 
being created. In 2025, 13 operational measures concerned the use of IT tools.   

1.7 Cooperation and information exchange  

Strengthening cooperation and information exchange is an ongoing effort reported by Member 
States, both in the previous years and in 2025. On the national level there are various agencies 
that  have  access  to  data  relevant  for  combating  fraud  and  the  cooperation  between  them  is 
crucial  for  the  effectiveness  of  the  national  anti-fraud  system.  Part  of  the  measures  cover 
establishing contact points and responsible bodies, which was already covered in the report (see 
1.2 Managing  the flow of information). At the same time, Member States undertake actions 
aimed at broader cooperation with external partners, including EU institutions (EPPO, OLAF) 
or business entities.  

Selected measures addressing cooperation and information exchange 

Type of measure 

Partners 

Description   

Member 
State  

Cyprus 

Administrative 

Lobbyists  

Mandatory registration of lobbyists and disclosure of 
meetings for increased transparency.  

Czech 
Republic 

Operational 

Taxi service 
providers (Uber and 
Bolt)  

Memorandums of cooperation have been agreed under 
which there will be regular monthly transmission of 
information.  

Estonia 

Operational  

International (Latvia, 
Lithuania, Poland, 
Finland and Sweden) 

Organising a forum for participating investigators to share 
information on recent tax and excise crime trends, discuss 
case examples, and strengthen operational contacts. 

France  

Legislative 

Internal agencies  

Establishment of an interministerial anti-fraud watch unit 
for national and European public aid within the 
Interministerial Anti-Fraud Coordination Office. 

Latvia   

Organisational 

National authorities, 
managing 
institutions, and 
law‑enforcement 
bodies 

Conducting two thematic discussions within the AFCOS 
Council to strengthen a common understanding of risks, 
harmonize approaches, and improve coordinated 
preventive and corrective actions across the EU funds 
management system.  

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Slovakia  

Administrative 

Organisational 

Operational 

OLAF, 

Internal agencies 

Among others, establishment of contact points at regional 
prosecutors' offices of the General Prosecutor´s Office of 
the Slovak Republic for OLAF investigators. 

Cooperation agreement between Government Office of 
the Slovak Republic (AFCOS) and the Office for the Fight 
against Organised Crime of the Ministry of the Interior of 
the Slovak Republic. 

Slovenia  

Operational  

EPPO 

Links and exchange of information between the managing 
authority, the EPPO, and the police through regular 
cooperation and reporting on cases.  

Spain  

Organisational  

EPPO  

Establishment of an operational group dedicated to EPPO 
cases.   

1.8 Whistleblowers  

The topic of whistleblowers protection and measures undertaken to encourage them to report 
wrongdoings  was  popular  in  2023.  In  2025,  10  measures  addressed  area  of  whistleblowers 
addressing the issue during trainings (Belgium,  Cyprus, Czech Republic) or in revised anti-
fraud  policies  and  program  frameworks  (Ireland,  Netherlands,  Slovakia,  Spain).  Selected 
measures are summarised in the table below.   

Member State  

Selected measures addressing whistleblower protection 
Description  

Type of measure 

Austria 

Administrative 

Establishment of an internal body as a whistleblower 
system at the federal level: Federal Disciplinary Authority.  

Bulgaria 

Legislative 

Legislative amendment improves the protection of 
persons who report breaches of EU law. 

Denmark 

Operational 

A new whistleblower scheme allowing anonymous 
submissions of suspicions of fraud anonymously. 
Previously it was not possible to make a report 
anonymously. 

Luxembourg 

Operational  

A new button which redirects to guidance for 
whistleblowers was added to the website and program 
platform. 

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Spain 

Administrative 

Establishment of an independent institution - The State 
Independent Whistleblower Protection Authority - which 
ensures protection of informants. 

List of measures with a 

component 

MEASURE 

2.6 Amendment of the Administrative Violations and Penalties Act 
2.7 Amendment of the Protection of Persons Whistleblowing or Publicly Disclosing 
Information on Violations Act (ZZLPSPOIN) 

2.8 Amendment to the Public Procurement Act (ZOP) 
2.9 Amendment of the Criminal Procedure Act 
2.10 Amendments to the Criminal Code 
2.16 Ending tax confidentiality in respect of labour inspection bodies 
2.21 Legislative amendments tightening the framework for customs‑ and sanctions‑ 
related misdemeanours 
2.28 Improving administrative and judicial cooperation 
2.33 Transfer to the Independent Authority for Public Revenue  
2.34 Interventions in the institutional framework of public procurement – law reform 
2.37 Ensuring integrity of staff at the National Development Centre 
2.43 Introducing criminal and administrative sanctions for the violation of EU restrictive 
measures 
2.52 Infringements in agriculture sector – amendments to legal acts 
2.59 Legislative amendment against misuse of legal exception rules 
2.66 Strengthening the legal framework to prevent and combat corruption of foreign 
public officials 
2.68 Strengthening customs control and supervision mechanisms 
2.71 Strengthening control and audit system of public financial resources 
2.72 Strengthening the protection of the EU’s financial interests within the framework of 
the CAP 
2.76 Approval of the State Plan to Combat Corruption 
2.80 Strengthening of penalties for certain offences 

COUNTRY 

Bulgaria 

Croatia 

Czech Republic 

Estonia 

France 

Greece 

Hungary 

Italy 

Lithuania 
Netherlands 

Romania 

Slovakia 

Spain 
Sweden 

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List of measures with an 

 component  

2.1 Frequent verifications 

MEASURE 

2.3 Ex-ante use of Arachne for conflict of interest 
2.12 Registration of lobbyists and disclosure of meetings – trainings  
2.13 Code of Conduct for Public Officials – update and targeted training 
2.14 Reform of the e-procurement system of the Treasury of the Republic 
2.20 Fine-tuning of the guidelines for reporting financial irregularities through IMS 
2.25 Update and organisational rollout of the guidelines on the administrative and control 
system 
2.26 Training on good administrative practices 
2.29 Prevention and detection of conflicts of interest in the agricultural/fisheries sector 
2.30 A guidance document on the prevention of conflicts of interest (State of Rhineland-
Palatinate) 
2.33 Transfer to the Independent Authority for Public Revenue  
2.35 Development of a system for supervising the implementation of the management and 
control system – project implementation 
2.40 Enhanced management and control systems for Just Transition Fund 
2.41 Regular updates of Fraud Risk Profile of PEACEPLUS fund 
2.44 Systematic integration and strengthening of Arachne/SAS model 
2.54 Guidelines on ESF+ procedural matters 
2.56 Communications campaign against fraud and misuse of public funds 
2.58 Complete revision of the Interreg Meuse-Rhine antifraud policy programme 
2.64 Updating of mechanisms to support risk assessment, analysis and management when 
implementing EU funding 
2.67 Strengthening the operational capacity of the National Anti-Corruption Directorate 
2.70 Improving reporting and strengthening communication channels 
2.71 Strengthening control and audit system of public financial resources 
2.72 Strengthening the protection of the EU’s financial interests within the framework of 
the CAP 
2.76 Approval of the State Plan to Combat Corruption 
2.77 Establishment of the State Independent Whistleblower Protection Authority 

23 

COUNTRY 
Austria 

Belgium 

Cyprus 

Denmark 

Finland 

Germany 

Greece 

Ireland 

Italy 
Luxembourg 
Malta 
Netherlands 

Portugal 

Romania 

Slovakia 

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2.81 Report on the conditions for reducing the risk of double funding 

Sweden 

List of measures with an 

component 

MEASURE 

2.1 Frequent verifications 
2.2 Mandatory anti-fraud trainings 
2.18 Internal training action 
2.22 Introduction of personal income tax risk managers 
2.23 Fraud-prevention plan under a unified system 

2.33 Transfer to the Independent Authority for Public Revenue  

2.37 Ensuring integrity of staff at the National Development Centre 

2.39 Revision of the Department of Agriculture, Food and the Marine Fraud Policy 

2.40 Enhanced management and control systems for Just Transition Fund 

2.41 Regular updates of Fraud Risk Profile of PEACEPLUS fund 

2.47 Establishment of the Tax and Customs Police as a separate institution 

2.48 Annual AFCOS Discussions on Emerging Fraud Risks and the Impact of EU Case 
Law on EU Funds Management 
2.49 Capacity‑building activities in public procurement processes 

2.51Trainings strengthening competencies of institutions managing EU Structural funds 

2.54 Guidelines on ESF+ procedural matters 

2.67 Strengthening the operational capacity of the National Anti-Corruption Directorate 

2.70 Improving reporting and strengthening communication channels 

2.72 Strengthening the protection of the EU’s financial interests within the framework of 
the CAP 
2.75 Amendment of money laundering prevention legal act 

2.78 Creation of an operational group dedicated to EPPO cases 

COUNTRY 
Austria 
Belgium 
Czech Republic 

Estonia 

Greece 

Hungary 

Ireland 

Latvia 

Lithuania 

Luxembourg 

Romania 

Slovakia 

Slovenia 

Spain 

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List of measures with an 

 component  

MEASURE 

2.1 Frequent verifications 
2.4 Declarations of internal and external evaluators 
2.11 Full implementation of management information system “eKohezija” 

2.17 Structured cooperation with taxi service providers via e-platforms (Uber and Bolt) 

2.19 Implementation of a new whistleblower system 
2.27 Targeted control measures in IOSS assets 
2.31 Increased number of on-site inspections (State of Schleswig-Holstein) 

2.33 Transfer to the Independent Authority for Public Revenue  
2.35 Development of a system for supervising the implementation of the management and 
control system – project implementation 
2.36 Support activities and guidance from the Public Procurement Authority 
2.37 Ensuring integrity of staff at the National Development Centre 
2.38 Post-release controls for preventive purposes 
2.40 Enhanced management and control systems for Just Transition Fund  

2.45 Digitalisation of the register on cases of serious irregularities 
2.53 Update of control and monitoring system for the national implementation of the RFF 

2.55 Adding a new feature – a whistleblower button 

2.57 Annual self-declaration of absence of a potential conflict of interest 

2.60 Strengthening selection of projects with potential conflict of interests 
2.61 Verification of declarations of impartiality 
2.62 Guidelines for controls under the development plan co-financed by the RRF 

2.63 Implementation of measures set out in the National Anti-Fraud Strategy (NAFS) 

2.65 Development of a new customs anti-fraud database 
2.67 Strengthening the operational capacity of the National Anti-Corruption Directorate 

2.70 Improving reporting and strengthening communication channels 

COUNTRY 
Austria 
Belgium 

Croatia 

Czech Republic 

Denmark 
Finland 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Luxembourg 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

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2.73 Automatic verification of double co-financing 
2.74 Exchange of information between national police and EPPO 

Slovenia 

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How to read this report 
Member States could report up to 3 measures through a dedicated and structured questionnaire. 
Upon reporting the third and last one, a respondent was presented with a possibility to provide 
information on any additional measures they wish to report. This information was recorded in 
a free format and cannot be structured.  

Information  about  each  measure  was  populated  into  the  table  template,  as  presented  below. 
,  and 
Types  of  measures, 

, 

, 

 were colour-coded in a consistent manner throughout the report.  

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 #2 #3 taken by MS in 2025  

Legislative  

Administrative 

Prevention

Detection 

Organisational  

Operational 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Each measure  was  classified by the Member State as a  New measure/New legislation  or an 
Update/Amendment. Targeted stages of the anti-fraud cycle are highlighted in dark blue. In the 
example above, the Prevention stage is selected.  

For each measure, an anti-fraud cycle graph reflects the stages targeted with the measures. The 
dark blue colour indicates that the stage was targeted whereas light blue indicates, that it was 
not. 

Areas targeted by each measure are the same for all types of measures. Possible areas include 
Public  Procurement,  Financial  Crime  (Including  Money  Laundering),  Organised  Crime, 
Corruption, Conflict of Interest, Fraud Definition, AFCOS, Whistleblower, Customs/Tor/Illicit 
Trade, Shared Management and Control of the EU Funds, Antifraud or Anticorruption Strategy, 
and Other.  

For  measures  targeting  Corruption,  Member  States  were  asked  to  indicate  whether  the  anti-
corruption measure is related to the Public sector (including political sphere) or to the Private 
sector. They then selected the scope of the anti-corruption measure, from the list visible in the 
table below, and had a possibility to elaborate in the comments.  

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
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Public / 
Private sector 

Public sector  
(including political sphere) 

Private sector 

Corruption within public procurement – MS #1 #2 #3 

Fight against corruption in public procurement 

Comment 

Measures addressing transparency in public procurement, Measures to improve the 
effectiveness of management of the public procurement, Measures to prevent 
corruption amongst personnel, including management, Measures addressing 
transparency of companies participating in public procurement, Measures to 
improve the effectiveness of control and audit, Other measures preventing 
corruption in public procurement 

For Sectoral measures, respondents were asked to specify sectors affected by a given measure. 
Available  options  include  Revenue  (Customs,  Tax  Fraud)  and  Expenditure  (Agriculture, 
Fisheries,  Cohesion  Policy,  Centralised  Direct  Management,  Fund  for  the  Most  Deprived, 
Globalisation  Fund,  Migration  and Asylum,  Recovery  and  Resilience  Facility)  categories  or 
Other. No further specification was required for Horizontal measures as those, by definition, 
cover all areas of the EU budget.  

Scope of the measure and expected results vary between measure types, as shown below.  

Type of measure 

Scope 

Expected results 

Competences, Powers, Definition of a 
specific topic, Recovery, Financial 
penalties, Other administrative penalties, 
Criminal sanctions, Time barring, Other 

To clarify and consolidate existing 
rules, To remedy flaws, To enforce the 
rules in line with developments in EU 
law, Other 

Eligibility criteria, Management of funds, 
Monitoring/desk checks, On the spot 
checks, 
Audit checklist, Investigation, Irregularities 
reporting, Penalty, Recovery, Other 

To clarify or consolidate existing rules, 
To enhance existing measure, Cross-
cutting measure, multi-agency 
measure/measure with impact on 
various bodies, Other 

Reorganisation of existing bodies, 
Competence, 

Inter-agency cooperation, General trainings, 
Fraud awareness trainings, Simplification of 
procedures, Other 

IT tools ("IT data feeding", "Other IT"), 
Web reporting/Hotline, Flagging practice, 
Risk indicators, Increased number of 
checks, Structured cooperation with law 
enforcement, 

Structured cooperation with judicial 
authorities, Other 

Neutral on resources, Increased 
resources 

Enhanced coordination, Enhanced 
cooperation, Enhanced information 
flow, Targeting of checks, Targeting of 
investigations, Enhanced ex-ante 
controls, Enhanced ex-post controls, 
Other 

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Member States  

Austria 

Austria  reported  one  package  measure  in  2025,  with  administrative,  organisational  and 
operational components, which include frequent verifications of the beneficiaries, covering up 
to the full awarded amount.  

2.1 Frequent verifications  

To prevent irregularities, frequent verifications are carried out pursuant to 2021-2027 funding 
period, in line with Article 74(1)(f) of Regulation 2021/1060. The verification procedure allows 
the administrative bodies to check 100% of the expenditure submitted by the beneficiary. 

This measure is intended to prevent irregularities through (*): 

•  checks in  order to  ensure that funds are used properly and that  any irregularities are 

reported, 

•  Whistleblower  Protection  Act  (HSchG)  in  implementation  of  Regulation  (EU) 

2019/1937, 

•  an  establishment  of  an  internal  body  as  a  whistleblower  system  at  the  federal  level: 

Federal Disciplinary Authority, 

•  establishment of an external body: Federal Office for the Prevention of and Fight against 

Corruption at the Federal Ministry of the Interior. 

The  formal  requirements  in  the  national  eligibility  rules  as  well  as  requirements  in  the 
management  and  control  system  are  intended  to  increase  efficiency.  Standardised  forms 
(checklists) increase the quality of the invoices submitted (**). 

An  operational  update  includes  mapping  of  the  entire  funding  process,  including  the  billing 
process,  in  a  central  database.  In  addition,  the Arachne  data  mining  tool,  provided  by  the 
European Commission, is used for risk assessment and risk analysis (***). 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Austria in 2025  

Public 
procurement  

Conflict of 
interest 

Shared 
management and 
control of EU 
funds 

Antifraud or 
anticorruption 
strategy 

Eligibility criteria 

Management of 
funds 

On the spot checks 

Audit checklist 

Irregularities 
reporting  

Recovery  

Reorganisation of 
existing bodies 

Inter- agency 
cooperation 

Fraud awareness 
trainings 

Simplification of 
procedures 

IT tools ('IT data 
feeding', 'Other 
IT') 

Other*** 

Cross-
cutting 
measure, 
multi-
agency 
measure/ 
measure 
with impact 
on various 
bodies** 

Other* 

Neutral on 
resources  

Enhanced 
information 
flow 

Targeting of 
checks 

Administrative 
Circulaire/Circular, 
Instructions, 
Guidelines, Manuals 

Update 

E
G
A
K
C
A
P

Organisational  
01/01/2026 

Update  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure - 
Cohesion 
policy 

Operational 
22/11/2022 

 Update 

Belgium 

Belgium reported three measures in 2025: one package measure concerning declarations and 
potential conflict of interest and two single measures regarding mandatory anti-fraud trainings 
and ex-ante use of Arachne system.  

2.2 Mandatory anti-fraud trainings  

A compulsory e-learning course on the fight against fraud was launched in October 2025 and 
is to be taken by all staff of the Public Service of Wallonia (PSW) and of the French Community 
(CF). It is also open to staff of the Walloon public interest bodies. Compulsory training courses 
30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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for the NRRP managers and project managers of the PSW were organised in December 2025 
on  the  subject  of  combating  fraud,  both  in  person  and  remotely  (accessible  via  the  Ecole 
d’administration publique for PSW and CF staff members). 

The  training  provided  aims  to  empower  top  management  and  project  managers  linked  to 
European funds, while strengthening their role as exemplars. E-learning makes all staff aware 
of the fight against fraud. It strengthens the skills of actors and strengthens a culture of integrity 
and prevention. 

Training is given, via the Ecole d’administration publique, in collaboration with the Ministere 
De  La  Federation  Wallonie-Bruxelles  The  aim  of  the  compulsory  e-learning  course  and 
specialised  training  is  to  raise  staff  awareness  and  train  staff  in  combating  fraud,  including 
corruption. (*) 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Belgium in 2025  

E
L
G
N
I
S

Organisational  
04/12/2025 

New 
measure 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

Public 
Procurement  

Financial Crime 
(Including Money 
Laundering) 

Corruption 

Conflict Of 
Interest 

Fraud Definition 

SECTORAL  

Expenditure – 
Agriculture 

Expenditure – 
Fisheries  

Expenditure – 
Cohesion policy  

AFCOS 

Expenditure – 
Recovery and 
Resilience 
Facility  

Whistleblower 

Shared 
Management and 
Control of The Eu 
Funds 

Antifraud Or 
Anticorruption 
Strategy 

Competence  

Inter-agency 
cooperation  

General 
trainings  

Fraud 
awareness 
trainings  

Other*  

Neutral on 
resources  

Public / 
Private sector 

Corruption within public procurement – Belgium #1 

Fight against corruption in public procurement 

Comment 

Public sector  
(including political sphere) 

Measures to prevent corruption amongst 
personnel, including management 

Compulsory e-learning and specialised training 
aim to raise awareness and train staff in the fight 
against fraud, including corruption. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
   
 
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2.3 Ex-ante use of Arachne for conflict of interest  

This measure extends the use of Arachne system for assessment of potential conflict of interest 
to all funds. Prior to the evaluation of a project proposal, both the internal and external evaluator 
should tick the following declaration on honour in PLATOS (MS’s application). An evaluation 
of a project proposal can only be started if the above declaration on honour has been ticked. 
Statements on honour will be sampled. A possible conflict of interest of the sample population 
will be checked off through Arachne. The same analysis on the conflict of interest was carried 
out in the context of the renewal process of the ESF+ Wallonia-Brussels. 

In  accordance  with Article  74(1)(c)  of  Regulation  1060/2021,  the  Managing Authority  shall 
ensure  effective  and  proportionate  anti-fraud  measures  and  procedures  based  on  the  risks 
identified. Ex-ante use of Arachne to detect a conflict of interest through data analysis is seen 
as a measure to detect fraud. (*) 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Belgium in 2025  

E
L
G
N
I
S

Administrative 
Recommendation 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Fraud Definition 

Antifraud or 
Anticorruption 
Strategy 

Monitoring/ 
desk checks 

On the spot 
checks  

Other* 

2.4 Declarations of internal and external evaluators  

Under  the  management  and  control  systems  and  manuals  of  the  ESF+,  ERDF  and  RRF 
programmes, clear procedures have been put in place for the prevention, control and detection 
of  irregularities.  Conflict  of  interest  risk  analyses  have  also  been  carried  out,  and  the  RRF 
manual  was  updated  in  July  2025.  Checks  are  also  carried  out  at  project  level  under  these 
programmes to ensure correct implementation of the established rules.  

These control measures and conflict of interest risk analyses have been put in place as part of 
the improvement of procedures to combat fraud, and to prevent, control and detect irregularities. 
They have also made it possible to raise awareness among the various stakeholders. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Belgium in 2025  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

32 

 
 
 
 
 
 
 
 
 
 
 
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financial interests 

E
G
A
K
C
A
P

Operational 
01/09/2025 

Update   

SECTORAL 

Conflict of 
Interest 

Expenditure – 
Cohesion policy  

Shared 
Management and 
Control of the 
EU Funds 

IT tools ('IT 
data feeding', 
'Other IT') 

Increased 
number of 
checks  

Enhanced  
ex-ante 
controls  

2.5 Additional measures reported by Belgium in 2025 

Belgium reported several additional measures undertaken in 2025, which include:  

•  Adoption of an OPW anti-fraud procedure focused on reporting and handling of these 

reports, by PSW Agriculture, natural resources and the environment, 

•  Drafting of a procedure for processing and correcting fraud in PSW General Secretariat. 
The  PSW  is  working  on  the  procedure  of  improving  relations  between  the 
administration and the judicial authorities.  

•  Establishment  of  the  integrity  adviser  (cf.  Order  of  the  Walloon  Government  of 
13/10/2022 on reporting information on a suspected irregularity), providing a reliable 
point  of  contact  for  reporting  any  irregularity,  while  ensuring  the  protection  of 
whistleblowers, by the Agency for Quality of Life (AVIQ) 

•  Adopting a guide to internal procedures and monitoring under the Walloon 2023-2027 
CAP Strategic Plan (approved on 22 April 2025). This guide concerns projects falling 
within the remit of AVIQ in measure 356 ‘Aid for investments in health infrastructure 
in rural areas’, Intervention 371 ‘LEADER’ and Intervention 373 ‘Cooperation in the 
field of health’, by AVIQ 

•  Adopting  additional  measures  by  PSW,  such  as  a  procedure  for  handling  internal 
irregularities by the integrity adviser (project sent for validation to the Minister in June 
2025), which aims to ensure rigorous, impartial and confidential management of any 
report concerning a breach of ethics or professional standards, for example checking the 
admissibility  of  the  report,  drawing  up  recommendations  proportionate  to  the 
seriousness of the facts, sending it to the competent authority 

•  Adopting additional measures by ESF Flanders, such as performing in-depth control on 
double  financing  for  random  sample  of  ESF+  projects  and  quarterly  upload  ESF+ 
projects via Arachne. 

•  Adopting additional measures updating its management and control procedures by RRF 

Flanders, including:  

1)  Fraud risk assessments carried out by all implementing bodies. 
2)  Publication  of  anti-fraud  policies  by  the  Flemish  Government  and  each 

implementing body. 

3)  Enhanced  anti-fraud  procedures,  such  as  assurance  for  signatories  of 
management  declarations;  functional  internal  and  external  whistleblowing 

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

channels; enhanced verification of compliance with EU and national law (public 
procurement, State aid). 

4)  Enforcement procedure to ensure correction of irregularities and apply sanctions 

for non-compliance. 

•  Adopting additional measures by ESF-Asylum, Migration and Integration Fund (AMIF) 
Wallonia-Brussels, concerning an ESF Agency that initiated an update of its analysis of 
fraud and financial risks related to co-financed beneficiaries (via Arachne). 

Bulgaria 

Bulgaria reported three single measures in 2025, all concerning amendments to various existing 
legislative acts, introducing new sanctions, protecting whistleblowers, and excluding unreliable 
operators from future contracts.  

2.6 Amendment of the Administrative Violations and Penalties Act  

The  Administrative  Violations  and  Penalties  Act  (ZANN)  provides  new  penalties  directly 
related to  the protection of the EU’s  financial interests and the fight against fraud. The new 
sanctions  concern  a  legal  person  that  has  enriched  or  would  enrich  itself  from  a  criminal 
offence. 

Brief description of the legislation: in addition to a financial penalty for a legal person that has 
enriched or would enrich from a criminal offence, the ZANN provides new penalties, namely: 

•  a temporary prohibition on participation in public procurement procedures, 
•  a temporary prohibition on participation in concession award procedures, 
•  a temporary prohibition on participation in procedures for the award of EU funds, 
•  a  temporary  prohibition  to  receive  subsidies  and  grants  from  the  EU,  the  state  or 

municipal budgets, 

•  and a public disclosure of the decision. 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Bulgaria in 2025  

E
L
G
N
I
S

Legislative  
29/07/2025 

Amendment 

Prevention

Detection

HORIZONTAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Financial Crime 
(Including 
Money 
Laundering) 

Organised Crime 

Corruption 

Conflict Of 
Interest 

Other 
administrative 
penalties  

To remedy 
flaws 

 Law/Act: ZANN - amended and supplemented State Gazette No 61 of 2025, suppl. - SG No 115 of 2025 

34 

 
 
 
 
 
 
 
 
 
 
 
 
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financial interests 

Corruption within public procurement – Bulgaria #1 

Public / 
Private sector 

Public sector  
(including political sphere) 

Fight against corruption in public 
procurement 

- 

Comment 

- 

2.7 Amendment of the Protection of Persons Whistleblowing or Publicly 
Disclosing Information on Violations Act (ZZLPSPOIN) 

This measure improves the protection of whistleblowers and fully aligns it with Directive (EU) 
2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection 
of  persons  who  report  breaches  of  Union  law.  The  amendments  aim  to  ensure  effective 
protection of a much wider range of whistleblowers. 

Brief description of the legislation: the amendments are intended to provide full and correct 
transposition of Directive (EU) 2019/1937. The main amendments include the reduction of the 
scope of the exception under Article 4(3) of the ZZLPSPOIN, increasing the scope of protection 
under Article 5(2)(6) and (7), removing the limitation of the temporal scope of an infringement 
as an obstacle to initiating proceedings for the verification of an alert. 

35 

 
 
 
 
 
 
 
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financial interests 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Bulgaria in 2025  

E
L
G
N
I
S

Legislative  
05/09/2025 

Amendment 

Prevention

Detection

HORIZONTAL 

Whistleblower 

Definition of a 
specific topic  

To remedy 
flaws 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Law/Act: Act amending the Protection of Persons Whistleblowing or Publicly Disclosing Information on Violations 
Act, promulgated in State Gazette No 38 of 9 May 2025. 

2.8 Amendment to the Public Procurement Act (ZOP) 

This measure covers amendments of Articles 54(1) and 157(1)(1) of ZOP in connection with 
the mandatory exclusion of a participant convicted of an offence under Chapter One (a) of the 
Criminal  Code, trafficking in  human beings,  offences against labour rights, offences  against 
property, holdings and the tax system, EU funds, bribery, etc. of the Criminal Code.  

This  measure  is  important  because  it  aims  to  prevent  possible  criminal  offences  and 
irregularities, as well as future cases of misconduct, by excluding unreliable economic operators 
from award procedures. 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #3 taken by Bulgaria in 2025  

E
L
G
N
I
S

Legislative  
29/07/2025 

Amendment 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

Organised 
Crime 

Shared 
Management 
and Control of 
The EU Funds 

Competences  

Powers  

To enforce the 
rules in line 
with 
developments 
in EU law 

Law/Act: New § 54 of the Act amending the Criminal Code, promulgated in State Gazette №61/29.07.2025, in 
force since 31.01.2026 regarding the Public Procurement Act. 

Croatia 

In  2025,  Croatia  reported  three  single  measures  including  two  amendments  to  the  existing 
legislative  acts  on  bribery  and  an  operational  measure  targeting  new  use  of  IT  tools  across 
different sectors.  

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financial interests 

2.9 Amendment of the Criminal Procedure Act  

The Act amending the Criminal Procedure Act extended the catalogue of criminal offences for 
which special evidentiary measures referred to in Article 332(1) of the Criminal Procedure Act 
may  be  ordered  in  such  a  way  that  it  also  includes  the  criminal  offence  of  bribing  a 
representative. 

Brief description of the legislation: The inclusion of the crime of bribery of a representative in 
the  catalogue  of  crimes  referred  to  in Article 334  of  the  Criminal  Procedure Act,  for  which 
special evidence-gathering work may be ordered, will make it possible to conduct inquiries by 
ordering special evidence-gathering work for that crime when inquiries could not be carried out 
in another way or only with disproportionate difficulty. 

The giving of bribes to a public official within the meaning of Article 4(4) of Directive (EU) 
2017/1371 on the fight against fraud to the Union's financial interests by means of criminal law, 
or  the  taking  of  such  bribes,  constitutes  an  offence  under  that  Directive,  which  has  been 
transposed into Croatian national law by, inter alia, the crime of bribery of a representative as 
referred to in Article 339 of the Criminal Code (Kazneni zakon). 

As part of the accession process of the Republic of Croatia to the OECD, in December 2024 
the Working Group on Bribery in International Business Transactions adopted a report of the 
second  phase  of  the  evaluation  of  the  Republic  of  Croatia.  That  report  contained  the 
recommendation, regarding the crime of bribery of a representative as referred to in Article 339 
of the Criminal Code, that that offence be included in the catalogue of crimes for which special 
evidence-gathering work may be ordered. (*) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Croatia in 2025  

E
L
G
N
I
S

Legislative 
30/04/2025  

Amendment  

Prevention

Detection

HORIZONTAL 

Corruption 

Powers 

Other* 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Law/Act: The Act amending the Criminal Procedure Act was published in Narodne Novine (NN; Official Gazette 
of the Republic of Croatia) No 72/25. It entered into force on 30 April 2025 

Public / 
Private sector 

Public sector  
(including political sphere) 

Corruption within public procurement – Croatia #1 

Fight against corruption in public procurement 

Comment 

- 

- 

37 

 
 
 
 
 
 
 
 
 
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

2.10 Amendments to the Criminal Code  

The Act on Amendments to the Criminal Code reworded the legal description of the criminal 
offence of bribery of representatives in such a way that all acts of active and passive bribery of 
representatives at the centralised and decentralised level, at the level of the EU level, and at the 
level of international public organisations are given legal continuity in this offence. 

Brief description of the legislation: The criminal offence of bribing a representative (Article 339 
of the Criminal Code) has been reworded – in terms of both active and passive bribery – as 
regards acts and omissions by a representative for which a bribe is given, offered or promised, 
in order to explicitly criminalise the bribery of representatives so that they perform any type of 
act of voting or other types of act unrelated to voting. Namely, the official acts of active and 
passive bribery of domestic and foreign representatives, different from the act of voting, have 
been criminalized by Articles 293 (Receiving a bribe) and 294 (Giving a bribe) of the Criminal 
Code even prior to the amendments on the Criminal Code (Official Gazette No. 136/25). 

The giving of bribes to a public official within the meaning of Article 4(4) of Directive (EU) 
2017/1371 on the fight against fraud to the Union's financial interests by means of criminal law, 
or  the  taking  of  such  bribes,  constitutes  an  offence  under  that  Directive,  which  has  been 
transposed  into  Croatian  national  law  by,  inter  alia,  the  criminal  offence  of  bribery  of  a 
representative referred to in Article 339 of the Criminal Code. 

As part of the accession process of the Republic of Croatia to the OECD, the Working Party on 
Bribery in International Business Transactions adopted in December 2024. Report of the second 
phase of the evaluation of the Republic of Croatia. That report contained the recommendation 
that the crime of bribing a representative be amended and supplemented to explicitly criminalise 
the  giving  of  bribes  to  a  foreign  representative  so  that  they  perform  acts  other  than  voting, 
including  abstaining  or  refraining  from  voting,  and  making  certain  statements  in  legislative 
discussions or refraining from doing so. (*) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Croatia in 2025  

E
L
G
N
I
S

Legislative 
13/11/2025  

Amendment 

Prevention

Detection

HORIZONTAL 

Corruption 

Definition of a 
specific topic 

Other* 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Law/Act: The Act on Amendments to the Criminal Code was published in the Official Gazette No. 136/25. It 
entered into force on 13 November 2025. 

Public / 
Private sector 

Public sector  
(including political sphere) 

38 

Corruption within public procurement – Croatia #2 

Fight against corruption in public procurement 

Comment 

- 

- 

 
 
 
 
 
 
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

2.11 Full implementation of management information system “eKohezija” 

The  Managing  Authority  for  ESF+  Programme  (the  Ministry  of  Labour,  Pension  System, 
Family  and  Social  Policy)  has  successfully  implemented  management  information  system 
“eKohezija” for monitoring implementation of ESF+ funded projects which follows the whole 
cycle  of  project  management:  preparation  and  publication  of  Calls  for  Proposals,  receiving 
project applications, projects selection, contracting and full project implementation. 

This  measure is  important  since it allows better  and more timely management verifications. 
Also, the information system “eKohezija” serves as a unique storage point for all documentation 
related to the project implementation. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Croatia in 2025  

E
L
G
N
I
S

Operational 
01/06/2025 

 New 
measure  

Prevention

Detection

Recovery 
and sanction 

Investigation
and 
prosecution 

HORIZONTAL 

Public 
procurement  

Conflict of 
interest 

Shared 
management and 
control of EU 
funds 

IT tools (“IT 
data feeding”, 
“Other IT”) 

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

Targeting of 
checks 

Targeting of 
investigations 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

Cyprus 

Cyprus reported three single administrative measures in 2025, pointing to new developments 
and updates to the existing solutions. The measures focus on areas of corruption, conflict of 
interest  and  anti-fraud  and  anti-corruption  strategy  and  include  awareness-raising  activities, 
trainings and digitalisation.  

2.12 Registration of lobbyists and disclosure of meetings – trainings 

Trainings,  provision  of  guidance  and  daily  monitoring  and  review  of  relevant  registers  and 
records by the Independent Authority Against Corruption (IAAC) falling within the scope of 
the "Transparency in Public Decision-Making Processes and Related Matters Law of 2022 (L. 

39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

20(I)/2022)". The purpose of the implementation of the said Law is to prevent corruption, to 
promote  transparency,  integrity,  and  accountability,  and  to  safeguard  the  lawfulness  and 
credibility of public decision-making processes. Lobbying constitutes an effort to ensure that 
public  decision-making  processes  are  conducted  with  transparency,  thereby  fostering  public 
confidence and trust in such processes. 

Lobbying activities contribute directly to the prevention of fraud and corruption by ensuring 
that  interactions  between  public  officials  and  representatives  of  a  special  interest  group,  are 
conducted  openly,  documented  appropriately  and  are  subject  to  oversight.  By  requiring  the 
registration  of  lobbyists  and  the  disclosure  of  these  meetings,  the  Law  mitigates  undue 
influence, enhances accountability, and promotes compliance with ethical and legal obligations. 
These  measures  strengthen  public  confidence  in  decision-making  processes  and  reduce 
opportunities for illicit or improper conduct. 

The  Independent Authority Against  Corruption,  during  2025,  conducted  extensive,  targeted 
awareness-raising presentations and training seminars, in order to inform  the persons falling 
within the scope of the Law of their obligations under the Law. Specifically, presentations and 
seminars  were  made  by  the Authority  to  a  wide  range  of  entities. These  activities  aimed  at 
raising awareness, promoting compliance and focused on ensuring transparency, integrity, and 
accountability in public decision-making. (*) 

Single / 
Package  

Type  

E
L
G
N
I
S

Administrative 
Implementation of 
action plan, 
guidance, training 
and monitoring. 

New / 
Update/ 
Amendment 

New 
measure 

Anti-Fraud Measure #1 taken by Cyprus in 2025  

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Corruption 

Conflict of 
Interest 

Antifraud or 
Anticorruption 
Strategy 

Other* 

To enhance 
existing 
measure  

Public / 
Private sector 

Fight against corruption in public 
procurement 

Comment 

Corruption within public procurement – Cyprus #1 

Public sector  
(including political sphere) 
Private sector  

Other measures preventing corruption in 
public procurement 

40 

The IAAC conducted extensive, targeted awareness-
raising presentations and training seminars, to inform the 
persons falling within the scope of the Law of their 
obligations under the Law. Specifically, presentations and 
seminars were made by the Authority to a wide range of 
entities. These activities aimed at raising awareness, 
promoting compliance and focused on ensuring 
transparency, integrity, and accountability in public 
decision-making. In parallel, continuous guidance was 
provided, while daily monitoring and review of relevant 
registers and records were carried out. 

 
 
 
 
 
 
 
 
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

2.13 Code of Conduct for Public Officials – update and targeted training  

Revising  Cyprus’  Civil  Service  Code  of  Conduct  strengthens  protection  of  EU  financial 
interests by setting clear, enforceable standards on integrity, impartiality and conflicts of interest 
for officials managing EU funds. It addresses gaps highlighted by EU audits, supports effective 
prevention/detection of fraud and corruption, and is embedded through guidance, training and 
practical verification tools (e.g., Arachne and registry cross-checks), improving transparency 
and traceability in procurement and grants. 

It is cross-cutting because it applies horizontally across the public service and affects all bodies 
involved  in  the  EU-funds  cycle  (selection,  procurement,  payments,  monitoring,  audit).  It 
requires  coordinated  implementation  via  common  rules  on  integrity/conflict  of  interest, 
guidance and training, and shared verification tools (e.g., Arachne and registry cross-checks). 
Findings can trigger multi-body follow-up (reporting, disciplinary action, exclusion/recovery, 
and referrals). 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #2 taken by Cyprus in 2025  

E
L
G
N
I
S

Administrative 
Trainings and 
awareness 

New 
measure  

Update  

Prevention

Detection

HORIZONTAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Corruption 

Conflict of 
Interest 

Whistleblower 

Antifraud or 
Anticorruption 
Strategy 

Management 
of funds 

Monitoring/ 
desk checks 

On the spot 
checks 

Audit checklist 

Reason / 
Expected Result  

To enhance 
existing 
measure 

Cross-cutting 
measure, multi-
agency 
measure/ 
measure with 
impact on 
various bodies 

Public / 
Private sector 

Corruption within public procurement – Cyprus #2 

Fight against corruption in public procurement 

Comment 

Public sector  
(including political sphere) 

Measures to prevent corruption amongst personnel, 
including management 

- 

2.14 Reform of the e-procurement system of the Treasury of the Republic 

The  new  eProcurement  reform  protects  the  EU’s  financial  interests  by  digitalising  the  full 
public-procurement  cycle  end-to-end,  creating  a  complete  audit 
trail  and  stronger 
transparency/competition. Automated workflows, role-based access and time-stamped records 
reduce  discretion  and  conflicts  of  interest.  Contract-management  functions  (milestones, 

41 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

variations,  payments,  alerts)  help  detect  overpricing,  irregular  amendments  and  non-
performance  early.  Central  data  and  analytics  enable  risk-based  controls  and  faster 
corrections/recovery. 

A  single  national  eProcurement  platform  used  by  all  contracting  authorities  and  economic 
operators. It standardises procedures and documentation, records time-stamped actions across 
the whole contract lifecycle, and centralises data for control/audit bodies. The same workflows 
and analytics support prevention, detection and correction for all programmes, including EU-
funded procurement. 

Measure  implemented  in  the  public  sector:  rollout  of  an  end-to-end  national  eProcurement 
platform plus a public procurement-data analytics/statistics tool. It digitalises tendering through 
award  and  links  contract  execution  (amendments,  payments)  in  one  system,  enabling  full 
traceability,  public  scrutiny  and  risk-based  controls/audit.  Interoperability  with  Tax 
Dept/Registrar supports verification of economic operators. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Cyprus in 2025  

E
L
G
N
I
S

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

New 
measure 

Update 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

Corruption 

Conflict of Interest 

Shared 
Management and 
Control of The EU 
Funds 

Antifraud or 
Anticorruption 
Strategy 

Other - Integrity 
and transparency 

Management of 
funds 

Monitoring/ 
desk checks 

On the spot 
checks 

Audit checklist 

Investigation 

Irregularities 
reporting 

Penalty 

Recovery 

Other* 

To enhance 
existing 
measure 

Cross-cutting 
measure, multi-
agency 
measure/ 
measure with 
impact on 
various bodies 

Corruption within public procurement – Cyprus #3 

Fight against corruption in public procurement 

Comment 

Public / 
Private sector 

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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financial interests 

Public sector  
(including political sphere) 

Measures addressing transparency in public 
procurement. 

Measures to improve the effectiveness of 
management of the public procurement. 

Measures addressing transparency of companies 
participating in public procurement 

Measures to improve the effectiveness of control 
and audit 

Measure implemented in the public sector: rollout 
of an end-to-end national eProcurement platform 
plus a public procurement-data analytics/statistics 
tool. It digitalises tendering through award and 
links contract execution (amendments, payments) 
in one system, enabling full traceability, public 
scrutiny and risk-based controls/audit. 
Interoperability with Tax Dept/Registrar supports 
verification of economic operators. 

2.15 Additional measures reported by Cyprus in 2025  

Cyprus reported several  additional measures undertaken in  2025, which focused on training 
activities related to the Protection of the Financial Interests of the Union (PIF) – 2025. Overall, 
the  2025  training  activities  contributed  to  improved  awareness,  harmonised  practices  across 
authorities and strengthened administrative capacity to safeguard the financial interests of the 
European Union, in particular:  

•  During 2025, the Directorate of Financial Control of EU Funds of the Treasury of the 
Republic of Cyprus implemented a targeted training programme aimed at strengthening 
the prevention, detection and correction of irregularities, fraud and conflicts of interest 
affecting the financial interests of the European Union. 

•  A total of seven training actions were organised, with the participation of approximately 
615  officials,  including  staff  of  the Treasury  of  the  Republic  of  Cyprus.  Participants 
represented all authorities involved in the management and control of EU funds under 
shared  management,  including  managing  authorities,  intermediate  bodies,  audit  and 
control bodies, contracting authorities and bodies implementing grant schemes, as well 
as other relevant stakeholders involved in programme implementation. 

•  The  training  programme  covered  key  PIF-related  areas,  including  administrative 
verifications and management checks; prevention and detection of conflicts of interest; 
public procurement procedures  and compliance;  State aid  rules applicable to  EU co-
financed grant schemes; ethical standards and the Code of Conduct for public officials; 
and fraud risk management and fraud prevention measures. 

Particular emphasis was placed on EU anti-fraud tools and methodologies, including the EU 
Fraud  Risk  Assessment  methodology  and  fraud  risk  scoring,  the  Irregularity  Management 
System, and the Early Detection and Exclusion System, as well as the application of risk-based 
approaches to reinforce preventive controls. In November 2025, a specialised training session 
was  delivered  on  the  EU  fraud  risk  assessment  methodology,  irregularity  reporting  and 
exclusion mechanisms, further enhancing the capacity of national authorities to identify, report 
and address fraud and serious irregularities in a timely and effective manner. 

Czech Republic 

In 2025, Czech Republic reported three sectoral measures, with two of them addressing the risk 
tax fraud on the revenue side, focusing on the area of financial crime and organised crime. The 
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financial interests 

third measure targeted the expenditure side of the Cohesion Policy funds with broad training 
action.  

2.16 Ending tax confidentiality in respect of labour inspection bodies 

The  labour  market  of  the  Czech  Republic  is  greatly  harmed  by  illegal  employment,  which 
causes  significant  losses  in  income  tax,  value  added  tax  and  compulsory  social  insurance 
contributions. 

Brief  description  of  the  legislation:  Until  now  tax  confidentiality  of  the  Financial 
Administration (Finanční správa – FS) has not been waived with respect to labour inspection 
authorities. Under the new  provision  of Section 40 of Act  No 435/2004  on employment, FS 
bodies  will  be  authorised  to  provide,  upon  request,  information  required  to  perform  tasks 
targeting  illegal  employment.  Lifting  the  confidentiality  will  result  in  more  effective 
cooperation  between  labour  inspection  offices  and  the  FS,  leading  to  a  more  effective 
crackdown on illegal employment as well as improved collection of direct and indirect taxes. 
In the area of VAT, this involves not only protecting the financial interests of the Czech Republic 
but also improving the protection of the EU’s financial interests. 

Under the reworded legislative provision, labour inspection bodies can transmit information to 
law enforcement authorities for the purposes of investigating the criminal offence of the illegal 
employment of foreign nationals, an offence described in Section 342 of the Criminal Code. 
This provision also lifted the confidentiality in tax matters as regards criminal investigations 
into illegal employment, a situation which had not been lifted until now. (*) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #1 taken by Czech Republic in 2025  

E
L
G
N
I
S

Legislative  
18/12/2024 

Amendment 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Revenue: Tax 
Fraud 

Financial Crime 
(Including Money 
Laundering) 

Organised Crime 

Powers 

Financial 
penalties  

Criminal 
sanctions 
(new) 

Reason / 
Expected Result  

To clarify and 
consolidate 
existing rules 

To remedy 
flaws  

Other* 

Law/Act: Act No 470/2024 amending Act No 435/2004 on employment, as amended. Legislation was adopted to 
reword Section 40. The measure has been effective since 1/01/2025. 

2.17 Structured cooperation with taxi service providers via e-platforms 
(Uber and Bolt) 

The operation of taxi services via the Uber and Bolt electronic platforms in the Czech Republic 
is associated with large-scale tax fraud on income tax and value added tax. Organized groups 
originating  in  the  countries  of  the  former  Soviet  Union,  Asia  and  the  Czech  Republic 
systematically evade taxes through vehicle fleet companies operating taxi services in the Czech 
Republic. The tax losses are estimated around CZK 4 billion per year (approximately EUR 165 
million). 

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Structured  cooperation  with  private  law  bodies  was  initiated.  Memorandums  of  cooperation 
have been  agreed under  which there will be  regular monthly  transmission of information  to 
transport providers; this will bring about a significant improvement in the information available 
to the financial authorities. Using the data received, it will be possible to carry out effective risk 
analysis and to apply checks at a significantly greater frequency than has been possible under 
current conditions (once per year). (*) 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / Expected 
Result  

Anti-Fraud Measure #2 taken by Czech Republic in 2025  

E
L
G
N
I
S

Operational 
29/09/2025 

 New 
measure 

Prevention

Detection 

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Revenue: Tax 
Fraud 

Financial Crime 
(Including 
Money 
Laundering) 

Organised Crime 

Other* 

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

Targeting of 
checks 

Enhanced ex-
ante controls 

2.18 Internal training action  

The internal training initiative ‘Subsidy fraud in OPE/OPE+’ for staff of the managing authority 
of the Operational Programme Employment+ (OPE+); the aim of this training course was to 
provide participants with a fundamental and comprehensive overview of the issue of fraudulent 
behaviour,  from  the  filing  of  a  criminal  complaint  to  the  final  legal  ruling  (and  consequent 
recovery of compensation for damage) or the dismissal of the case.  

Making all staff in various positions at the managing authority aware of the issue of fraud and 
the entire process connected to it will ensure that proper procedural practices are followed and 
will minimise the risk of underestimation or of procedural error. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Anti-Fraud Measure #3 taken by Czech Republic in 2025  
Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Prevention

Detection

Recovery
and sanction 

Investigation 
and 
prosecution 

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E
L
G
N
I
S

Organisational 
22/10/2025 

New 
measure 

Denmark 

Fraud Definition 

SECTORAL 

Whistleblower 

Expenditure: 
Cohesion Policy 

Shared 
Management and 
Control of the 
EU Funds 

Fraud 
awareness 
trainings  

Neutral on 
resources 

In  2025,  Denmark  reported  two  measures,  focusing  on  whistleblower  protection  (ensuring 
anonymity) and on accuracy of reporting data. 

2.19 Implementation of a new whistleblower system 

Implemented  a  new  whistleblower  scheme  where  it  is  possible  to  report  suspicion  of  fraud 
anonymously. Previously it was not possible to make a report anonymously.  

This measure aims at securing anonymity of whistleblowers (*), and is believed to encourage 
anyone who is in doubt if they want to make a report, to make the report because it is possible 
to do it anonymously.  

Single / 
Package  

Type  

E
L
G
N
I
S

Operational 
01/01/2025 

New / 
Update/ 
Amendment 

New 
measure  

Update  

Anti-Fraud Measure #1 taken by Denmark in 2025  

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Prevention

Detection

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Cohesion Policy 

Whistleblower 

Other* 

Targeting of 
investigations 

2.20 Fine-tuning of the guidelines for reporting financial irregularities 
through IMS 

Following feedback from the Danish Agency for Green Transition and Aquatic Environment, 
the Danish IMS country officer, the Danish Agriculture and Fisheries Agency have updated its 
guidelines  in  regard  to  the  reporting  of  financial  irregularities.  Previous  ambiguous 
understandings  of  reporting-categories  have  thus  been  specified  and  updated  in  internal 
guidelines.  

This should ensure a more detailed reporting of potential irregularities, with a higher accuracy 
in the provided information. In addition, this more streamlined and accurate process also allows 
personnel-resources to be directed towards more critical tasks in the anti-fraud cycle. 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Denmark in 2025  

E
L
G
N
I
S

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

Update 

Prevention

Detection 

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Fisheries 

Shared 
Management and 
Control of the 
EU Funds 

Irregularities 
reporting 

To clarify or 
consolidate 
existing rules 

Estonia 

Estonia  reported  three  measures  in  2025,  including:  legislative  amendments  increasing 
pecuniary  penalties  and  extending  investigative  powers  of  authorities  in  customs-  and 
sanctions-related  misdemeanours;  introducing  personal  income  tax  risk  managers;  and 
integrating institutional organisational frameworks.  

2.21 Legislative amendments tightening the framework for customs‑ and 
sanctions‑ related misdemeanours 

Three legislative amendments were adopted. Two of them entered into force on 1 January 2025 
under both the Customs Act and the Penal Code:  

• 

• 

the maximum misdemeanour penalty for legal persons in customs cases was raised from 
3,200 to 100,000 euros, and  
the misdemeanour fine unit for natural persons doubled from 4 to 8 euros, increasing 
the overall deterrent effect of financial sanctions.  

The third amendment, effective 27 May 2025, granted customs authorities investigative powers 
for violations related to international sanctions, significantly expanding their role in detecting 
and  handling  such  offences.  Together,  these  changes  strengthened  enforcement  capacity, 
harmonised  offence  definitions,  and  ensured  a  more  proportionate  response  to  serious 
infringements. 

Three measures were adopted, with the objectives that:  

1)  penalties must be effective, proportionate and dissuasive, allowing fines that neutralize 

the financial gain from infringements,  

2)  fine rates were increased to strengthen prevention and improve legal compliance;  
3)  the Estonian Tax and Customs Board was authorised to process small‑scale sanctions 
violations  as  misdemeanours,  with  customs  handling  misdemeanours  and  the 
Investigation Department handling criminal cases. 

Brief description of the legislation Three separate amendments were adopted:  

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1)  the maximum misdemeanour penalty for legal persons in customs cases was increased 

from 3,200 to 100,000 EUR;  

2)  the misdemeanour fine unit for natural persons was doubled from 4 to 8 EUR; and  
3)  customs authorities were granted investigative powers for sanction‑related violations. 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Estonia in 2025  

E
L
G
N
I
S

Legislative  
27/04/2025 

Amendment 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Revenue: 
Customs 

Customs/Tor/ 
Illicit Trade 

Competences  

Other 
administrative 
penalties  

To clarify and 
consolidate 
existing rules 

Law/Act: RT 1 12.12.2024, 6; RT 1 30.12.2024, 18 and RT 1 17.04.2025, 4. 

2.22 Introduction of personal income tax risk managers  

A  position  of  personal  income  tax  risk  manager  was  created.  The  risk  manager  maps  and 
maintains  an  overview  of  personal  income  tax  risks,  develops  and  manages  tax  loss 
methodologies  and  risk  models,  and  ensures  that  cases  referred  to  the  audit  department  are 
selected in a targeted manner. 

Mapping and maintaining an overview of personal income tax risks, developing and managing 
tax loss methodologies and risk models, and ensuring targeted selection of cases for audit will 
help detect tax fraud and make tax evasion more complex, burdensome and costly. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Estonia in 2025  

E
L
G
N
I
S

Organisational  
01/10/2025 

New 
measure 

Prevention

Detection

SECTORAL 

Revenue: Tax 
Fraud 

Fraud Definition 

Competence 

Neutral on 
resources 

Recovery 
and sanction 

Investigation 
and 
prosecution 

2.23 Fraud-prevention plan under a unified system  

In November 2025, the Police and Border Guard Board (PPA) approved a fraud‑prevention plan 
establishing  an  integrated  framework  where  activities,  units  and  stakeholders  operate  as  a 
unified system. The approach strengthens the prevention, detection and handling of fraud, and 
a dedicated unit is planned to become operational by 1 April 2026. 

The measure is reported because the PPA is taking independent steps to enhance its fight against 
fraud 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Estonia in 2025  

E
G
A
K
C
A
P

Organisational  
01/04/2026 

New 
measure 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement 

Financial Crime 
(Including Money 
Laundering) 

Organised Crime 

Shared 
Management and 
Control of the EU 
Funds 

Antifraud or 
Anticorruption 
Strategy 

Reorganisation 
of existing 
bodies  

Competence 

Inter-agency 
cooperation  

General trainings  

Fraud awareness 
trainings  

Simplification of 
procedures  

Increased 
resources 

2.24 Additional measures reported by Estonia in 2025  

Estonia  reported  several  additional  measures  undertaken  in  2025,  including  the  following 
actions and amendments:  

•  For several years Estonian Tax and Customs Board have been running an international 
cooperation  project  —  annual  meetings  for  tax  (including  Missing  Trader  Intra-
Community (MTIC)) and excise investigators. This initiative is carried out together with 
Estonia,  Latvia,  Lithuania,  Poland,  Finland  and  Sweden,  under  the  umbrella  of 
EMPACT.  During  these  meetings,  participating  investigators  share  information  on 
recent tax and excise crime trends, discuss case examples, and strengthen operational 
contacts  between  officers.  This  measure  supports  and  facilitates  international 
cooperation in cross‑border tax (including MTIC) and excise investigations.  

•  The  Public  Procurement Act  was  amended  to  address  issues  related  to  background 
checks  of  foreign  companies  in  defence  and  security  procurements  involving  state 
secrets or classified information. Under the amendment, background checks on foreign 
companies  will  be  carried  out  by  the  Foreign  Intelligence  Service  instead  of  the 
contracting authority, ensuring that such checks are conducted correctly and efficiently 
through official international channels. The amendment (PPA § 178 subsections 3¹–5) 
entered into force on 1 September 2025.  

•  Our implementing authorities (RTK, KIK, EIS, PRIA, SIM) continuously develop and 
refine their procedures. They have upgraded their systems and guidelines, strengthened 

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analytical and risk‑assessment processes, and provided ongoing training to staff to better 
prevent and combat fraud. These improvements are part of a broader effort to ensure 
that operational tools, supervisory methods, and internal procedures remain up to date 
and effective. Risk assessment is consistently based on identified findings, ensuring that 
measures  and  controls  are  targeted,  evidence‑driven,  and  proportionate  to  the  risks 
detected.   

Finland 

In 2025, Finland reported three measures: two administrative measures focusing on increasing 
awareness  of  fraud  risks  and  relevant  trainings,  and  one  operational  measure  targeting  the 
undervaluation of imports in the Import One Stop Shop (IOSS) system.  

2.25 Update and organisational rollout of the guidelines on the 
administrative and control system. 

Increase  control  awareness  within  the  organisation,  in  particular  regarding  fraud  risks.  The 
guidance has also assessed aid offences based on national legislation. The guidance is a follow-
up to the anti-fraud plan of the European Maritime, Fisheries and Aquaculture Fund in 2024. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Finland in 2025  

E
G
A
K
C
A
P

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

Update 

Prevention

Detection

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Fisheries 

Management 
of funds 

Other – Integrity 
and transparency 

Monitoring/ 
desk checks 

To enhance 
existing 
measure 

Irregularities 
reporting 

2.26 Training on good administrative practices 

A two-part training on good administrative procedures organised by the managing authority to 
support the activities of the intermediary bodies. Training also provided for aid beneficiaries. 

A  harmonised  administrative  procedure  strengthens  citizens'  and  stakeholders'  trust  in 
authorities and reduces fraud risks. Clear procedures reduce human error, increase transparency 
and  facilitate  the  identification  of  suspicious  transactions.  Clear  division  of  responsibilities, 
effective controls and documented processes prevent abuses and enhance accountability. The 
objectives are supported by the regular updating of risk analysis, the management of risks of 
double funding and the development of checklists and public procurement risk management. 

Anti-Fraud Measure #2 taken by Finland in 2025  

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle 

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

E
G
A
K
C
A
P

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

New 
measure  

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Cohesion Policy 

Expenditure: 
Migration And 
Asylum 

Other – 
Transparency 
and 
accountability 

Other – 
Administrative 
practices 

To clarify or 
consolidate 
existing rules 

2.27 Targeted control measures in IOSS assets  

This measure addresses misuse and undervaluation of IOSS codes in imports. A control project 
aimed at IOSS codes was launched in early 2025. The project features targeted control measures 
based on the selection criterion defined in the customs clearance system, including interception 
of consignments, inspection of products and verification of the correctness of the value of the 
goods by means of additional information requested from the recipients. Control measures will 
continue in line with the OLAF letter (AM/2025/046). 

There are grounds for suspicion and, based on the available evidence, it can be concluded that 
IOSS  codes  are  being  misused,  and  the  values  of  the  products  are  being  deliberately 
undervalued. In addition to errors in the declaration and payment of VAT, the procedure allows 
customs duties to be avoided if the value of the goods is declared below the EUR 150 threshold. 
Although the values of individual IOSS imports are generally low, large volumes mean that 
misreporting may have a significant impact on the accumulation of customs duties. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #3 taken by Finland in 2025  

E
G
A
K
C
A
P

Operational 
04/02/2025 

New 
measure  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Revenue: 
Customs 

Revenue: Tax 
Fraud 

Financial Crime 
(Including 
Money 
Laundering) 

Shared 
Management and 
Control of the 
EU Funds 

Increased 
number of 
checks 

Reason / 
Expected Result  

Enhanced 
cooperation 

Targeting of 
checks 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

France 

In 2025, France reported one legislative package measure addressing the pursue and sanction 
of fraud with enhanced inter-ministerial cooperation.  

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2.28 Improving administrative and judicial cooperation 

The establishment of an interministerial anti-fraud watch unit for national and European public 
aid  within  the  Interministerial  Anti-Fraud  Coordination  Office  (MICAF)  is  a  mechanism 
designed to identify and assess 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.  It  brings  together  all  the  competent  administrations  and 
administrative investigation services as well as the specialized judicial investigation services. 

The MICAF consolidated the interministerial work on the law of 30 June 2025 ‘combating all 
fraud  involving  public  aid’  and  proposed  measures  to  enable  the  exchange  of  data  between 
partners  and  the  suspension/rejection  of  applications  in  the  event  of  suspected  fraud. These 
measures will be useful for energy renovation fraud and learning fraud partly financed by the 
RRF. This law also contains many other useful provisions on energy renovation fraud. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by France in 2025  

E
G
A
K
C
A
P

Legislative  
26/07/2023 

New 
legislation 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

Organised Crime 

Conflict of 
Interest 

Fraud Definition 

AFCOS 

Antifraud or 
Anticorruption 
Strategy 

Competences   

To clarify and 
consolidate 
existing rules 

Decree: No 2023-663 of 26 July 2023 and Law No 2025-594 of 30 June 2025 

Germany 

Germany reported three measures in 2025, including: two administrative measures addressing 
the potential conflict of interests, and an increased number of on-the-spot inspections.  

2.29 Prevention and detection of conflicts of interest in the 
agricultural/fisheries sector. 

Federal  Ministry  of Agriculture,  Food  and  Regional  Identity  implemented  an  administrative 
measure following a policy paper on prevention and detection of conflicts of interest by the 
competent authorities in the agricultural/fisheries sector (*). 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Germany in 2025  

E
L
G
N
I
S

Administrative 
Recommendation 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Conflict of 
Interest 

Monitoring/ 
desk checks 

Irregularities 
reporting 

Other* 

To enhance 
existing 
measure 

2.30 A guidance document on the prevention of conflicts of interest (State 
of Rhineland-Palatinate) 

State of Rhineland-Palatinate (RLP) ERDF Managing Authority prepared a guidance document 
on the prevention of conflicts of interest for the ERDF in RLP and made available to all entities 
involved in the resolution. All parties are expected to draw up and sign a declaration on the 
existence or otherwise of conflict of interest. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Germany in 2025  

E
L
G
N
I
S

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

Prevention

Detection 

SECTORAL 

Public 
Procurement  

Management 
of funds 

Eligibility 
criteria  

Update 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Cohesion Policy 

Corruption 

Conflict of 
Interest 

To clarify or 
consolidate 
existing rules 

Monitoring/ 
desk checks 

On the spot 
checks 

Audit checklist 

Public / 
Private sector 

Corruption within public procurement – Germany #2 

Fight against corruption in public procurement 

Comment 

Public sector  
(including political sphere) 

Measures to prevent corruption amongst personnel, 
including management 

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2.31 Increased number of on-site inspections (State of Schleswig-Holstein) 

A  risk  analysis  was  carried  out.  As  a  result,  the  number  of  on-site  inspections  increased. 
Increasing the number of on-the-spot checks will help to better achieve the goal of protecting 
the financial interests of the EU. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Germany in 2025  

E
G
A
K
C
A
P

Operational 
30/12/2025 

 Update 

Prevention

Detection

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Cohesion Policy 

Shared 
Management and 
Control of the 
EU Funds 

Increased 
number of 
checks 

Targeting of 
checks 

Enhanced ex-
post controls 

2.32 Additional measures reported by Germany in 2025 

AFCOS, located in the Federal Ministry of Finance organised two IMS Workshops (presence / 
hybrid)  on 18 and 24 of September 2025 with the IMS users to improve the reporting quality 
for Germany.    

Greece 

Greece reported three measures in 2025, including a comprehensive package measure focused 
on transfer of responsibilities to consolidate control and prosecution mechanisms and increase 
their  transparency  and  accountability,  a  legislative  measure  addressing  public  procurement 
procedures and relevant vocational trainings of officials involved in those procedures, and an 
introduction of a system for case management.  

2.33 Transfer to the Independent Authority for Public Revenue  

Transfer  of  responsibilities  and  services  to  the  Independent  Authority  for  Public  Revenue 
(AADE), including the Directorate-General of the Financial and Economic Crime Unit (SDOE) 
at  the  Ministry  of  Economic Affairs  and  Finance;  and  the  Payment  and  Control Agency  for 
Guidance and Guarantee Community Aid (OPEKEPE). 

In particular: 

•  Pursuant to Article 254 of Law Ν.5222/2025 (Government Gazette, Series I, No 134) 
and  Decision  No  Δ.ΟΡΓ.Α  248060  ΕΞ  2025  of  the  Governor  of  the  Independent 
Authority for Public Revenue (Government Gazette, Series II, No 5302), as of 6 October 
2025 the Directorate-General of the SDOE (DG SDOE) was transferred in its entirety, 
including remit, business units, posts, staff, archives, assets and logistical equipment, to 
the Independent Authority for Public Revenue.  

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The  transfer  of  the  responsibilities  of  the  SDOE  to  the  AADE  aims  to  unify  the  tax 
administration’s control and enforcement mechanisms. At the same time, the aim is to make the 
country’s control and enforcement mechanisms more effective, as part of a modern organization 
that is in line with European standards. 

•  Part  C  of  Law  Ν.5264/2025  (Government  Gazette,  Series  I,  No  239)  and  Decision 
Δ.ΟΡΓ.Α  471379  ΕΞ  2025  of  the  Governor  of  the  Independent Authority  for  Public 
Revenue (Government Gazette, Series II, No 7110) amended the AADE’s organisation 
as a result of the transfer to the AADE of the remit, business units and organisational 
posts of the former OPEKEPE. 

The purpose of Part C is to enhance the transparency, accountability and technical reliability of 
the agricultural aid payment system and to ensure the sound financial management of EU funds.

Brief description of the legislation: Article 254 of Law Ν.5222/2025 provided for the transfer 
of DG SDOE in its entirety, including remit, business units, posts, staff, archives, assets and 
logistical equipment, to the Independent Authority for Public Revenue. The purpose of Part C 
of Law 5264/2025 is to transfer the remit of the Payment and Control Agency for Guidance and 
Guarantee Community Aid to the Independent Authority for Public Revenue. 

The transfer of the responsibilities of the SDOE to the AADE was designed to consolidate the 
control  and  enforcement  mechanisms  of  the  tax administration,  with  a  view  to  coordinating 
them more effectively and enhancing their operational independence. The aim is also to make 
these mechanisms more effect as part of a modern organization that is in line with European 
standards. Part C concerns the transfer of OPEKEPE’s remit to the AADE and the resolution of 
organisational, financial and operational issues arising from the transfer. (*) 

From  an  administrative  perspective,  those  changes  aim  to  operational  capacity  of  control 
mechanisms through the integration of IT systems, direct access to tax and customs data, the 
avoidance of remit overlap and the faster completion of control procedures, thereby enhancing 
the number, effectiveness and efficiency of controls carried out. Addressing shortcomings in 
the  management  of  European  funds  in  agriculture.  Compliance  with  recommendations  and 
audit findings of European institutions. (**) 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Greece in 2025  

Legislative  
28/07/2025 

New 
legislation 

Administrative 
Decision/ 
Resolution 

Update 

Prevention

Detection

SECTORAL 

Revenue: 
Customs 

Organisational 
19/12/2025  

Update 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Revenue: Tax 
Fraud 

E
G
A
K
C
A
P

Financial 
Crime 
(Including 
Money 
Laundering) 

Organised 
Crime 

Corruption 

Operational 
28/07/2025 

 Update 

56 

Competences  

Powers 

Recovery  

Financial 
penalties  

Other 
administrative 
penalties 

Management of 
funds 

On the spot 
checks 

Investigation 

Reorganisation 
of existing 
bodies  

Competence 

Inter-agency 
cooperation  

Simplification of 
procedures  

Increased 
number of 
checks 

Other** 

To clarify and 
consolidate 
existing rules 

To remedy 
flaws  

Other* 

Neutral on 
resources 

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

Targeting of 
checks 

Targeting of 
investigations 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Law/Act: Article 254 of Law Ν.5222/2025 (Government Gazette, Series I, No 134) and Part C of Law 
Ν.5264/2025 (Government Gazette, Series I, No 239). 

Public / 
Private sector 

Corruption within public procurement – Greece #1 

Fight against corruption in public procurement 

Comment 

Measures addressing transparency in public 
procurement. 

Measures to improve the effectiveness of 
management of the public procurement. 

Public sector  
(including political sphere) 

Measures to prevent corruption amongst personnel, 
including management 

Measures addressing transparency of companies 
participating in public procurement 

Measures to improve the effectiveness of control 
and audit 

2.34 Interventions in the institutional framework of public procurement – 
law reform 

This measure concerns a publication of Law 5218/2025 (Government Gazette, Series I, No 125) 
entitled:  ‘Reform  of  the  framework  for  the  vocational  training  of  officials  handling  public 
contracts, the framework for the preparation and award of public contracts and legal protection 
in  the  field  of  public  contracts,  the  framework  for  national  quality  infrastructure  and  the 
framework for the establishment, extension and modernisation of manufacturing activities in 
the Region of Attica and other provisions’. 

The provisions of Law 5218/2025 amended the institutional framework for public contracts, 
with  the  main  objective  of  simplifying  and  streamlining  it,  and  enhancing  the  transparency, 
integrity and effectiveness of public procurement procedures. 

Part A  establishes  a  Register  of  public  procurement  professionals  with  a  view  to  promoting 
professional  specialisation  and  enhancing  the  integrity  of  staff  involved  in  public  contract 
procedures.  Officials  on  the  register  are  required,  inter  alia,  to  declare  their  assets,  disclose 
conflicts of interest and comply with guarantees of impartiality. In this context, the National 
Centre for Public Administration and Local  Government  (EKDDA), in  cooperation with  the 
Hellenic  Single  Public  Procurement  Authority  (EADHSY)  and  other  bodies,  implements 
certification  programmes  to  which  its  staff  contribute  as  educators,  also  with  a  focus  on 
corruption-related issues. 

Brief description of the legislation: Reform of multiple frameworks governing the following: 
the  vocational  training  of  officials  handling  public  contracts,  the  preparation  and  award  of 
public  contracts  and  legal  protection  in  the  field  of  public  procurement,  national  quality 
infrastructure and the establishment, extension and modernisation of manufacturing activities 
in the Region of Attica and other provisions. 

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Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Greece in 2025  

E
L
G
N
I
S

Legislative  
14/07/2025 

Amendment 

Prevention

Detection 

HORIZONTAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Public 
Procurement 

Corruption 

Competences  

Powers  

To clarify and 
consolidate 
existing rules 

Law/Act: Ν. 5218/2025 (Α 125) 

Public / 
Private sector 

Corruption within public procurement – Greece #2 

Fight against corruption in public procurement 

Comment 

Public sector  
(including political sphere) 

Measures to prevent corruption amongst personnel, 
including management 

2.35 Development of a system for supervising the implementation of the 
management and control system – project implementation 

A contract was signed between the Special Managing Authority for the Strategic Planning of 
the CAP of the Ministry of Rural Development and Food, and the Contractor on 18/07/2025. 
As a result, a system for supervision of the Management and Control System (MCS) for CAP 
Strategic  Planning  by  the  Intermediate  Management  Bodies  (IBOs)  was  implemented.  This 
project aims to deliver: 

•  Manual of the System for Supervision of the Implementation of the Management and 

Control System of the CAP Strategic Plan by the IBOs (Receipt – 11/09/2025). 

•  Detailed documents (documents and instructions) on the implementation of supervisory 
checks for the IBOs in respect of all the measures coming under the CFP Strategic Plan 
(Receipt – 08/12/2025). 

The Special Managing Authority for the Strategic Planning of the CAP at the Ministry of Rural 
Development and Food is the competent authority for supervising the correct implementation 
of the Management and Control System. 

Where the responsibility for carrying  out  tasks is  delegated to  an  Intermediate Management 
Body,  the  Special  Managing  Authority  for  the  Strategic  Planning  of  the  CAP  retains  full 
responsibility  for  the  efficiency  and  integrity  of  the  management  and  performance  of  those 
tasks. Consequently, the subject of this project was the preparation of the Surveillance System 
for the implementation of the Management and Control System. 

Supervisory checks by the Special Managing Authority for the Strategic Planning of the CAP 
at the Ministry of Rural Development and Food on the Intermediate Management Bodies, to 
which the responsibility for implementing the Control Management System (MCS) has been 
delegated. (*) 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #3 taken by Greece in 2025  

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

New 
measure 

E
G
A
K
C
A
P

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Agriculture 

Shared 
Management and 
Control of the 
EU Funds 

Monitoring/ 
desk checks 

On the spot 
checks 

Audit checklist 

Reason / 
Expected Result  

To clarify or 
consolidate 
existing rules 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies* 

Operational 
08/12/2025 

 New 
measure 

Risk indicators 

Targeting of 
checks 

Hungary 

In 2025, Hungary reported three measures: an operational measure undertaken by the Public 
Procurement  Authority  in  order  to  support  law  enforcement  in  their  activities,  a  measure 
introducing checks on integrity and conflict of interest of National Development Centre staff, 
and organised post-release controls as a preventive measure against abuse of VAT deductions.  

2.36 Support activities and guidance from the Public Procurement Authority 

The Public Procurement Authority (PPA) engaged in support activities, including: 

• 

to  increase  the  level  of  competition  in  public  procurement,  and  in  the  light  of  the 
experience gained in applying legislation, the PPA updated its guidance on the correct 
examination of disproportionately low prices;  

•  PPA updated its has updated its guidance on the dynamic purchasing system;  
•  as  part  of  the  programme  to  promote  cooperation  between  smaller  contracting 
authorities,  the  PPA  provided  access  to  online  learning  materials  for  all  interested 
parties; 

•  and  at  its  conferences,  the  PPA  focused  on  the  issue  of  conflicts  of  interest  and  the 

enhancement of integrity. 

Importance of this measure stems from an appropriate support for those applying the legislation 
in  how  to  correctly  examine  disproportionately  low  prices,  thus  providing  a  clearer 
understanding  of  the  dynamic  purchasing  system,  and  a  programme  supporting  cooperation 
between  smaller  contracting  authorities  can  play  an  effective  role  in  increasing  the  level  of 
competition in public procurement, in accordance with Government Decision No 1082/2024 of 
28 March 2024. The Public Procurement Authority’s conferences and training courses provide 
an opportunity to raise awareness, among those applying the legislation, of situations giving 
rise to conflicts of interest and the importance of enhancing integrity. 
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The Authority’s  activities  in  support  of  the  application  of  public  procurement  legislation,  in 
particular  the  publication  of  the  guidance  highlighted  above  and  of  publicly  available 
presentations,  promote  the  legality  of  public  procurement  procedures  with  a  view  to  the 
transparent  and  proper  use  of  public  funds.  Presentations  focusing  on  supporting  and 
strengthening the integrity of public procurement and promoting the correct application of the 
legislation, in particular audit updates and the topic of conflicts of interest, continued to feature 
prominently in the training courses and knowledge-sharing events of the Public Procurement 
Authority in 2025. (*) 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Hungary in 2025  

E
G
A
K
C
A
P

Operational 
28/03/2024 

Update  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

Corruption 

Conflict of 
Interest  

Antifraud or 
Anticorruption 
Strategy 

Risk indicators 

Other* 

Enhanced 
information 
flow 

Targeting of 
checks 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

Public / 
Private sector 

Corruption within public procurement – Hungary #1 

Fight against corruption in public procurement 

Comment 

Public sector  
(including political sphere) 

Private sector 

Measures addressing transparency in public 
procurement. 

Measures to improve the effectiveness of 
management of the public procurement. 

Measures to prevent corruption amongst personnel, 
including management 

Measures addressing transparency of companies 
participating in public procurement 

Measures to improve the effectiveness of control 
and audit 

2.37 Ensuring integrity of staff at the National Development Centre 

Effective supervision of all positions in the staff of the Hungarian Development Centre (NFK) 
and  of  state  project  evaluators  from  an  organisational  security  point  of  view.  The  measure 
contributes  to  compliance  with  the  commitments  made  in  relation  to  the  conditionality 
procedure and the RRF to protect EU’s financial interests, supplementing the measures for staff 
in sensitive positions in all managing authorities. 

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Brief  description  of  the  legislation:  The  Directorate  for  Internal  Audit  and  Integrity  was 
authorised  by  law  to  conduct  checks  on  persons  connected  to  the  Hungarian  Development 
Centre and state project evaluators, including certain issues related to their integrity, and, in that 
context, to collect data from criminal records, educational records and records kept by the state 
tax and customs authorities. 

During  the Hungarian Development  Centre’s investigations, not  only  its Conflict  of Interest 
Department but also its Security Department (both operating under the Directorate for Internal 
Audit  and  Integrity)  conduct  checks  to  detect  unjustified  and  unauthorised  employee  data 
retrieval from the EU tender databases, thereby preventing potential abuses of this kind. (*) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #2 taken by Hungary in 2025  

Legislative  
01/11/2024 

Amendment 

E
G
A
K
C
A
P

Organisational  
21/02/2025 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

Operational 
01/12/2024 

New measure  

SECTORAL 

Expenditure: 
Cohesion 
Policy 

Expenditure: 
Recovery 
And 
Resilience 
Facility 

Financial 
Crime 
(Including 
Money 
Laundering) 

Organised 
Crime 

Conflict of 
Interest 

Reason / 
Expected Result  

To enforce the 
rules in line 
with 
developments 
in EU law 

Competences  

Powers 

Competence 

Inter-agency 
cooperation  

Increased 
resources  

IT tools ("IT 
data feeding", 
"Other IT") 

Other* 

Law/Act: Act XVIII of 2023 and Act XLI of 2024 

2.38 Post-release controls for preventive purposes 

The customs division of the National Tax and Customs Administration (NAV) took measures 
to assign and implement the post-release control task in 2025 and the annual control task to the 
local authorities. Organised post-release controls, coordinated at central level around the risks 
involved, contribute significantly to  the protection of the financial interests  of the European 
Union and to the fight against fraud, with their preventive effect.  

As a result of the amendment of the VAT deduction rules, there are fewer high-risk clients with 
indirect  representatives,  so  emphasis  has  also  been  placed  on  checking  release  for  free 
circulation in accordance with VAT regulations in the case of economic operators who present 
tax risks. Strengthening information exchange and operational cooperation to detect and prevent 
illegal activities. The aim is also to phase out and eliminate fraudulent taxpayers as early as 
possible (cancellation of the tax number, invalidation of the EORI number) to  prevent  them 
from continuing their illegal activities in other Member States. 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Hungary in 2025  

E
L
G
N
I
S

Operational 
23/12/2024 

 Update 

Prevention

Detection

Recovery
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Revenue: 
Customs 

Revenue: Tax 
Fraud 

Shared 
Management and 
Control of the 
EU Funds 

Web reporting/ 
Hotline 

Risk indicators 

Antifraud or 
Anticorruption 
Strategy 

Increased 
number of 
checks 

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

Targeting of 
checks 

Targeting of 
investigations 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

Ireland 

Ireland  reported  three  measures  in  2025,  including  a  revision  of  internal  fraud  policy, 
strengthening management and control systems to detect fraud at an early stage, and assessment 
and  regular  updates  of  a  Fraud  Risk  Profile  of  PEACEPLUS  fund,  which  is  used to  inform 
strategy and response to emerging risks.  

2.39 Revision of the Department of Agriculture, Food and the Marine Fraud 
Policy 

Revision of the Department of Agriculture, Food and the Marine Fraud Policy (DAFM), which 
is responsible for the CAP and fisheries funds in Ireland. These receipts represent the largest 
component of Ireland’s drawdown from the EU budget. The revision of the anti-fraud strategy 
was  a  key  strategic  and  oversight  mechanism 
the  potential 
irregularities/fraud,  consequently  aiming  to  further  enhance  the  protections  of  the  EU’s 
financial interests. 

to  combat 

in  order 

DAFM is responsible for approximately €1.5 billion payments annually in respect of EAGF 
and  EAFRD  funds. Appropriate  anti-fraud  measures  and  procedures  are  vital  to  detect  and 
prevent fraud to reduce the risk of the funds. 

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Anti-Fraud Measure #1 taken by Ireland in 2025  

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

E
L
G
N
I
S

Organisational  
17/11/2025 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal / 
Sectoral  

SECTORAL 

Expenditure: 
Agriculture 

Expenditure: 
Fisheries 

Area  

Scope  

Reason / 
Expected Result  

Shared 
Management and 
Control of the 
EU Funds 

Antifraud or 
Anticorruption 
Strategy 

Inter-agency 
cooperation  

Neutral on 
resources  

2.40 Enhanced management and control systems for Just Transition Fund  

The Just Transition Fund (JTF) Managing Authority continued to strengthen the management 
and control systems for the implementation of the JTF, with a particular focus on safeguarding 
EU financial interests. Clear administrative and financial verification procedures were applied 
to JTF-supported operations, including checks on eligibility, expenditure and compliance with 
EU rules. These measures were designed to prevent and detect irregularities and fraud at  an 
early stage and to ensure sound financial management of JTF resources. 

This  measure  is  important  because  robust  management  and  control  systems  are  the  primary 
means of preventing and detecting irregularities and fraud affecting EU-funded expenditure. By 
embedding  and  enhancing  clear  verification,  eligibility  and  compliance  checks  into  the 
implementation of the Just Transition Fund from the outset, the risk of ineligible expenditure, 
mismanagement  or  misuse  of  EU  funds  is  significantly  reduced.  The  measure  also  ensures 
accountability  and  traceability  of  JTF  spending,  providing  assurance  that  EU  resources  are 
managed in accordance with applicable rules. 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Ireland in 2025  

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

Update 

E
G
A
K
C
A
P

Organisational  
30/01/2025 

Update 

Prevention

Detection 

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Cohesion Policy 

Shared 
Management 
and Control of 
the EU Funds 

Antifraud or 
Anticorruption 
Strategy 

Operational 
30/01/2025 

Update  

Eligibility 
criteria  

Management 
of funds 

Monitoring/ 
desk checks 

Audit 
checklist 

Competence 

General 
trainings  

Fraud 
awareness 
trainings  

Simplification 
of procedures  

Other 

IT tools ("IT 
data feeding", 
"Other IT") 

Risk indicators 

Increased 
number of 
checks 

Structured 
cooperation 
with judicial 
authorities 

To clarify or 
consolidate 
existing rules 

To enhance 
existing 
measure 

Increased 
resources  

Enhanced 
information 
flow 

Targeting of 
checks 

Targeting of 
investigations 

2.41 Regular updates of Fraud Risk Profile of PEACEPLUS fund  

Fraud Risk Assessment and Policy Framework by the Special EU Programming Body, involved 
in  the  PEACEPLUS  fund. A  Fraud  Risk  Profile  has  been  developed,  which  identifies  and 
assesses fraud risks associated with each key organisational objective. This profile is reviewed 
regularly to ensure emerging risks are identified and that mitigation measures remain effective. 

In alignment with the assessed level of fraud risk, an Anti-Fraud Policy and a Fraud Response 
Plan  have  been  developed.  These  instruments  set  out  the  principles,  responsibilities,  and 
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procedures  for  preventing,  detecting,  reporting,  and  responding  to  suspected  fraud.  Both 
documents  are designed  to  be proportionate to  the level of  risk identified in  the Fraud Risk 
Profile and are updated as necessary to reflect changes in the organisation’s risk environment 
and regulatory requirements. 

•  Fraud Response Plan – Updated 07/2025 
•  Anti-Fraud Policy – Updated 23/07/2025 
•  Conflict of Interest Policy – Updated 10/11/2025 

It  is  essential  because  a  regularly  updated  Fraud  Risk  Profile  ensures  early  identification  of 
vulnerabilities, while a proportionate Anti-Fraud Policy and Fraud Response Plan provide the 
structured governance required for effective prevention, detection, and follow-up of suspected 
fraud. The  European  Commission  emphasise  that  improving  fraud  detection,  reporting,  and 
governance  is  fundamental  to  protecting  EU  funds,  and  that  organisations  must  maintain 
effective,  risk-based  anti-fraud  systems  aligned  with  their  management  and  control 
responsibilities. 

The administrative update covered developing of a fraud risk profile and undertaking a 
regular review of the fraud risks associated with each of the key organizational objectives (*), 
through: 

•  effective anti-fraud policy and Fraud Response Plan, commensurate to the level of 

fraud risk identified in the fraud profile; 

•  designing an effective control environment to prevent fraud commensurate with the 

fraud risk profile; 

•  coordinating assurances about the effectiveness of anti-fraud policies to support the 

Governance Statement; 

•  usage of IT tools and open-source resources, e.g. Arachne; 
•  and, reporting mechanisms to key bodies. 

The  measure  additionally  covers  trainings  attendance  from  this  ‘Managing  authority  at 
Arachne’ training in March 2025, IMS training in October 2025 and interdepartmental meetings 
throughout the year. (**) 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Ireland in 2025  

Administrative 
Action plan 

Update 

E
G
A
K
C
A
P

Organisational  
23/07/2025 

Update 

Public 
Procurement  

Financial Crime 
(Including Money 
Laundering) 

SECTORAL 

Prevention

Detection

Expenditure: 
Cohesion Policy 

Conflict of 
Interest 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Recovery And 
Resilience 
Facility 

Whistleblower 

Antifraud or 
Anticorruption 
Strategy 

Other – 
Irregularity 
reporting  

To clarify or 
consolidate 
existing rules 

To enhance 
existing 
measure 

Increased 
resources  

Management 
of funds 

Investigation 

Irregularities 
reporting 

Recovery 

Other* 

Inter-agency 
cooperation  

General 
trainings  

Fraud 
awareness 
trainings  

Simplification 
of procedures  

Other**  

2.42 Additional measures reported by Ireland in 2025 

The  Irish  Revenue  authorities  provided  information  on  the  indicative  measures  being 
undertaken, continuing from previous years into 2025: 

•  Excise fraud - tackling the illicit trades in tobacco, oil, and alcohol products; 
•  Missing Trader Intra Community Fraud– identifying and investigating the theft of Value 

Added Tax through the exploitation of EU VAT rules; 

•  Targeting undervaluation and misclassification; 
• 
• 

Identifying and addressing fraudulent claims for repayment of VAT and Customs Duty; 
Identifying  instances  of  infringements  of  intellectual  property  rights  and  taking 
appropriate action; 

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• 

Investigating irregularities involving evasion of duty on imports into the EU, namely, 
common customs tariff, anti-dumping duty and countervailing duty, and quantification, 
assessment and pursuit of civil liability identified by investigations into the suspected 
fraud; 

•  Where appropriate, investigating with a view to criminal prosecution, those involved in 

suspected fraud; 

Several other additional measures were adopted by relevant bodies:  

•  The  Department  of  Justice,  the  Managing Authority  for  the Asylum  Migration  and 
Integration  Fund  (AMIF)  introduced  a  risk-based  verification  process  of  expenditure 
and participants at the end of 2024. This has been progressing during 2025 with a first 
assurance package audit expected in 2026. A review of anti-fraud procedures will take 
place based off the recommendations of this. 

•  The Northern and Western Regional Assembly, a Managing Authority responsible for 
the  European  Regional  Development  Fund  introduced  an  administrative  measure  in 
order to bolster capacity building. They increased initiatives to boost staff awareness 
with  anti-fraud  training  for  governance  and  control  of  funds. This  has  been  in  many 
areas  including  public  procurement,  conflicts  of  interest,  state  aid,  integrity  and 
transparency. 

•  The Southern Regional Assembly (ERDF) reported a review of fraud risk assessments 
in place for schemes. It allows for an annual check in with scheme managers with  a 
specific focus on Anti- Fraud. It ensures that any issues identified in the previous review 
have been addressed and for robust measures. 

•  The  Department  of  Housing  reported  on  improvements  made  to  their  Public  Utility 
Policy  setting  out  necessary  anti-fraud  policies  to  bolster  measures  in  the  fraud 
prevention  and  detection  stages  of  the  anti-fraud  cycle.  Training  was  undertaken 
throughout the year to align with this rollout of enhanced company policies in order to 
solidify compliance and enforcement. 

Italy 

Italy reported three single measures covering legislative, administrative, and operational types 
of action. In 2025, Italy: introduced criminal and administrative sanctions for those who violate 
restrictive measures, in line with EU Decision, systematically integrated its data systems and 
trained staff on their effective use, and computerisation of case records system.  

2.43 Introducing criminal and administrative sanctions for the violation of 
EU restrictive measures 

Legislative  Decree  No  211  of  30  December  2025  implements  Directive  (EU)  2024/1226, 
introducing criminal and administrative sanctions for the violation of EU restrictive measures 
(such as freezing funds, embargoes and travel bans). In light of Article 29 TEU and Article 215 
TFEU,  the  decree  seeks  to  strengthen  the  Common  Foreign  and  Security  Policy  (CFSP), 

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ensuring  the  protection  of  democratic  values  and  the  rule  of  law  and  the  maintenance  of 
international peace, through an effective and dissuasive punitive system. 

The  Directive  is  derived  from  Decision  (EU)  2022/2332,  which  classified  the  violation  of 
restrictive measures as an ‘area of crime’ within the meaning of the second subparagraph [sic] 
of Article 83(1) TFEU, requiring Member States to ensure minimum harmonisation with regard 
to  offences  and  sanctions.  Given  the  financial  and  cross-border  nature  of  the  conduct,  the 
legislation focuses on asset confiscation as a deterrent and a means of resource recovery. This 
approach  could  be  said  to  continue  on  from  the  fight  against  crimes  affecting  the  Union's 
financial interests. 

Anti-Fraud Measure #1 taken by Italy in 2025  

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

E
L
G
N
I
S

Legislative  
09/01/2026 

New 
legislation 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal / 
Sectoral  

SECTORAL 

Revenue: 
Customs 

Revenue: Tax 
Fraud 

Expenditure: 
Agriculture 

Expenditure: 
Fisheries 

Expenditure: 
Cohesion Policy 

Expenditure: 
Recovery And 
Resilience 
Facility 

Area  

Scope  

Reason / 
Expected Result  

Public 
Procurement  

Financial Crime 
(Including 
Money 
Laundering) 

Organised Crime 

Corruption 

Customs/Tor/ 
Illicit Trade 

Shared 
Management and 
Control of the 
EU Funds 

Recovery  

Financial 
penalties  

Criminal 
sanctions 
(more) 

Time barring 
(more)  

To enforce the 
rules in line 
with 
developments 
in EU law 

Decree: No. 211 

Public / 
Private sector 

Corruption within public procurement – Italy #1 

Fight against corruption in public procurement 

Comment 

Public sector  
(including political sphere) 

Measures addressing transparency in public 
procurement. 

Private sector 

Measures addressing transparency of companies 
participating in public procurement 

2.44 Systematic integration and strengthening of Arachne/SAS model 

In the course of 2025, the operational implementation of the Arachne/SAS model within Italian 
Agricultural Payments Agency’s (AGEA) anti-fraud strategy and operational framework was 
further  stepped  up  as  a  central  instrument  supporting  activities  aimed  at  the  prevention  and 
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detection of fraud affecting the EU funds. The measure provided for the systematic integration 
of the model into management, inspection and audit procedures, as well as training for staff 
involved in risk analysis. 

The  measure  is  relevant  as  it  significantly  strengthens  the  prevention  and  early  detection  of 
fraud  and  irregularities  affecting  EU  funds. The  implementation  of  the Arachne/SAS  model 
enables  a  systematic  and  risk-based  analysis  of  operations  and  beneficiaries,  improving  the 
targeting of controls, the efficiency of verifications and the ability of competent authorities to 
act in a timely manner, thus contributing to a more effective protection of the financial interests 
of the European Union. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Italy in 2025  

E
L
G
N
I
S

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Agriculture 

Conflict Of 
Interest 

Fraud Definition 

Shared 
Management and 
Control of the 
EU Funds 

Antifraud or 
Anticorruption 
Strategy 

Eligibility 
criteria  

Management 
of funds 

Monitoring/ 
desk checks 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies 

2.45 Digitalisation of the register on cases of serious irregularities 

Digitisation of the ‘Summary of irregularities concerning NRRP procedures/spending’ register 
for cases of serious irregularities (fraud, corruption, conflicts of interest and double funding). 
This register includes the information that the Inspectorate-General of the NRRP sends to the 
Commission along with Italy’s management declaration. Also worth noting are:  

•  updates  to  the  ‘Monitoraggio  dei  Contratti  Pubblici’  (‘Public  Contract  Monitoring’) 
platform, known as ‘Mo.Co.P.2’, which is used to combat irregularities related to public 
procurement. 
the ‘Cruscotto Analisi PNRR’ (‘NRRP Analysis Dashboard’) application, an operational 
tool used to protect public spending, procurement contracts and incentives.  

• 

The digitisation of the register makes it possible to  establish a constant  flow of information 
(details of the measure/project, type of serious irregularity, impact on performance, corrective 
action and undue payments that need to be, or have already been, recovered) between the central 
bodies  responsible  for  NRRP  measures,  the  Inspectorate-General  of  the  NRRP  and  the 
European  Commission.  The  ‘Mo.Co.P.2’  and  ‘Cruscotto  Analisi  PNRR’  applications  are 

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helping operational units of the Guardia di Finanza to target their enforcement efforts on public 
spending, including EU funds. 

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Single / 
Package  

Type  

Anti-Fraud Measure #3 taken by Italy in 2025  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

E
L
G
N
I
S

Operational 
01/01/2025 

New 
measure  

Update  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Recovery And 
Resilience 
Facility 

Public 
Procurement  

Corruption 

Conflict of 
Interest 

Other - Fraud 
and Double 
Financing 

IT tools ("IT 
data feeding", 
"Other IT") 

Risk 
indicators 

Reason / 
Expected Result  

Enhanced 
coordination 

Enhanced 
information 
flow 

Targeting of 
checks 

Targeting of 
investigations 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

Public / 
Private sector 

Corruption within public procurement – Italy #3 

Fight against corruption in public procurement 

Comment 

Public sector  
(including political sphere) 

Measures to improve the effectiveness of control 
and audit 

- 

2.46 Additional measures reported by Italy  

The administrative measures are aimed at preventing and combating fraud and evasion linked 
to the role of tax representative and the possibility for non-residents to operate under the VAT 
Information Exchange System (VIES system).  

Those measures derive from the implementation of Article 4, paragraph 1, letters (a) and (b) of 
Legislative  Decree  No  13  of  12  February  2024,  which  made  amendments  to  Article  17, 
paragraph  3,  and Article  35  of  Presidential  Decree  No  633  of  26  October  1972. Article  35, 
paragraph  7-quater  provides  that,  for  entities  which  are  not  residents  of  a  European  Union 
Member State or a State belonging to the European Economic Area and which fulfil their value 
added tax obligations through a tax representative, inclusion in the database of taxable persons 
conducting intra-Community transactions (VIES) is subject to the provision of an appropriate 
guarantee. Article 17, paragraph 3 has been supplemented and stipulates that, in order to become 
a tax representative, individuals must meet the requirements set out in Article 8, paragraph 1, 
letters  (a),  (b),  (c)  and  (d)  of  Ministerial  Degree  No  164  of  31  May  1999  and  provide  an 
appropriate  guarantee,  to  be  calculated  based  on  the  number  of  entities  they  represent.  The 
Ministerial  Decrees  of  4  December  2024  and  9  December  2024  set  out  the  criteria  and 
procedures for issuing these guarantees, entrusting the Director of the Revenue Agency with 
the  issue  of  specific  implementing  provisions  setting  out  the  operational  procedures  for 

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submitting  guarantees  to  the  Revenue  Agency  offices.  Following  the  adoption  of  these 
provisions, specific operational guidelines were issued to the offices regarding the management 
of the procedures required to implement the regulatory framework. 

Latvia 

In  2025,  Latvia  reported  three  organisational  measures,  including:  an  establishment  of  a 
dedicated  institution  for  investigation  of  financial  and  tax  crimes,  organisation  of  thematic 
sessions within AFCOS Council, and engagement in capacity-building activities.  

2.47 Establishment of the Tax and Customs Police as a separate institution 

In  2025,  Latvia  adopted  a  major  structural  reform  within  the  State  Revenue  Service  (SRS), 
leading to the transformation of its Tax and Customs Police Department into an independent 
direct administration institution - the Tax and Customs Police - effective from 1 January 2026. 
The reform removed the investigative function from the SRS and placed it under the Ministry 
of the Interior to strengthen specialization, improve investigative independence, and enhance 
operational efficiency.  

The  new  institution  maintains  responsibility  for  investigating  tax  crimes,  customs  fraud, 
smuggling,  and  offences  affecting  the  EU’s  financial  interests. The  reorganization  improves 
coordination  with  law‑enforcement  bodies,  ensures  clearer  separation  of  functions  between 
control  and  investigation,  and  supports  a  more  robust  national  framework  for  addressing 
complex financial and customs‑related crimes 

This  reform  substantially  strengthens  Latvia’s  capacity  to  detect  and  investigate  crimes 
affecting the EU budget. By establishing the Tax and Customs Police as a dedicated institution 
within  the  Ministry  of  the  Interior,  Latvia  enhances  investigative  independence,  improves 
cooperation with law‑enforcement partners, and increases the effectiveness of actions against 
tax fraud, customs fraud, smuggling, and misuse of EU funds. The measure directly contributes 
to safeguarding EU financial interests. 

Anti-Fraud Measure #1 taken by Latvia in 2025  

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

E
L
G
N
I
S

Organisational  
01/01/2026 

New 
measure 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal / 
Sectoral  

SECTORAL 

Revenue: 
Customs 

Revenue: Tax 
Fraud 

Area  

Scope  

Reason / 
Expected Result  

Financial Crime 
(Including Money 
Laundering) 

Customs/Tor/ 
Illicit Trade 

Reorganisation 
of existing 
bodies 

Neutral on 
resources 

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2.48 Annual AFCOS Discussions on Emerging Fraud Risks and the Impact of 
EU Case Law on EU Funds Management 

In 2025, Latvia organized two thematic discussions within the AFCOS Council (Coordination 
Council for the Protection of the EU’s Financial Interests) as part of the annual AFCOS network 
activities. The first discussion focused on fraud risks related to IT project implementation and 
VAT  fraud,  covering  typical  schemes,  preventive  measures,  and  detection  challenges.  The 
second discussion addressed the assessment of potential irregularities in EU‑funded projects in 
light of the Court of Justice judgment of 10 October 2024 in case C‑175/23. The discussions 
brought  together  national  authorities,  managing  institutions,  and  law‑enforcement  bodies  to 
strengthen a common understanding of risks, harmonize approaches, and improve coordinated 
preventive and corrective actions across the EU funds management system. 

These discussions enhance Latvia’s ability to prevent and detect fraud affecting the EU budget 
by improving risk awareness, aligning interpretations of EU case law, and supporting consistent 
treatment  of irregularities. They strengthen  cooperation between institutions involved in  EU 
funds management and law enforcement, promote early identification of vulnerabilities, and 
contribute to more effective protection of the EU’s financial interests. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Latvia in 2025  

E
G
A
K
C
A
P

Organisational  
16/101/2025 

New 
measure 

Prevention

Detection 

HORIZONTAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Public 
Procurement  

AFCOS 

Shared 
Management and 
Control of the 
EU Funds 

Antifraud or 
Anticorruption 
Strategy 

General 
trainings  

Neutral on 
resources 

2.49 Capacity‑building activities in public procurement processes 

In  2025,  the  Procurement  Monitoring  Bureau  organized  several  webinars  and  workshops, 
independently and in cooperation with the State Chancellery and the Latvian School of Public 
Administration,  to  strengthen  knowledge  and  practice  in  public  procurement  processes. The 
activities  covered  key  topics  such  as  procurement  planning,  the  application  of  exclusion 
grounds,  and  the  most  common  procurement  errors  identified  in  EU‑funded  projects. These 
events  targeted  contracting  authorities,  procurement  specialists,  and  EU  funds  management 
institutions,  providing  practical  guidance,  clarifying  legal  requirements,  and  promoting 
consistent application of procurement rules. The measure aimed to enhance understanding of 

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risk  areas,  reduce  errors,  and  support  compliant  and  transparent  procurement  procedures  in 
projects financed from EU funds. 

The  trainings  help  prevent  procurement‑related  irregularities  and  fraud  risks  in  EU‑funded 
projects  by  improving  the  competence  of  contracting  authorities  and  strengthening  uniform 
application of procurement rules. By addressing common mistakes and clarifying complex legal 
provisions,  the  measure  reduces  vulnerabilities  in  EU  funds  management,  supports  early 
detection of risks, and contributes directly to safeguarding the EU’s financial interests. 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Latvia in 2025  

E
G
A
K
C
A
P

Organisational  
06/01/2025 

New 
measure 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

General 
trainings  

Neutral on 
resources 

2.50 Additional measures reported by Latvia in 2025 

Lativia reported several additional measures undertaken in 2025, which include: 

•  Establishment of the Customs Audit Division at the SRS. This is an additional measure 
complementing the SRS reorganization.  The creation of the Customs Audit Division  
strengthens the detection of financial irregularities and sanctions violations. In 2025, the 
Division’s  working  environment  and  regulatory  framework  were  established,  and 
risk‑management coordination was ensured. The measure enhances the effectiveness of 
customs  controls,  supports  compliance  with  EU  requirements,  and  improves  the 
identification of risks relevant to the protection of the EU’s financial interests. 
Internal Regulatory Measures of the Prosecutor’s Office Supporting the Protection of 
EU Financial Interests. In 2025–2026, The Prosecutor’s Office adopted several internal 
acts  reinforcing  prioritization  and  supervision  of  criminal  cases  related  to  EU  funds. 
These measures improve investigation quality and institutional accountability regarding 
offences affecting the EU budget, and include: 

• 

1)  Order from 28/01/2025: designated fraud and embezzlement causing damage to 

the state or involving EU or foreign financial assistance as priority cases. 

2)  Order  from  04/03/2025:  strengthened  supervision,  information  exchange  and 
control  mechanisms  for  priority  criminal  cases,  including  those  affecting  EU 
financial interests. 

3)  Order  from  07/01/2026:  introduced  revised  rules  for  evaluating  prosecutors’ 
performance, listing cases of fraud, computer fraud and embezzlement involving 
EU or foreign financial assistance as priority indicators. 

•  Amendments to Article 10(10) of the Road Traffic Law. In 2025, the Ministry of Finance 
initiated  amendments  to  strengthen  controls  related  to  intra‑EU  vehicle  acquisitions, 
addressing risks relevant to VAT fraud schemes. The amendments introduce a ban on 
alienation  for  15  days  (legal  persons)  or  30  days  (natural  persons),  extendable  if  an 
inspection is initiated, for certain M1/M1G and N1/N1G vehicles newly registered or 
re‑registered after purchase in another EU Member State. The Law “Amendments to the 
Road Traffic  Law”  was  adopted  on  6  November  2025  and  entered  into  force  on  22 

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November 2025. The measure enhances traceability of intra‑EU vehicle movements and 
contributes to mitigating VAT‑related risks. 

Lithuania 

Lithuania reported two measures in 2025, covering trainings against corruption and fraud as 
part of capacity-building organisational efforts and legal amendments aimed at investigations 
of irregularities and information sharing between authorities.  

2.51Trainings strengthening competencies of institutions managing EU 
Structural funds 

The  Managing Authority  organized  trainings  in  order  to  strengthen  the  competences  of  the 
institutions managing the European Union Structural Funds in the area of transparency and the 
fight against corruption and fraud. The Managing Authority continuously evaluates the training 
needs of the administrations of the European Union Structural Funds in the field of transparency 
and the fight against corruption and fraud. 

Capacity building is crucial in order to protect EU financial interests and improve measures of 
fight against fraud. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Lithuania in 2025  

E
L
G
N
I
S

Organisational 
01/01/2025  

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Corruption 

Conflict of 
Interest 

General 
trainings  

Fraud 
awareness 
trainings 

Neutral on 
resources  

Public / 
Private sector 

Public sector  
(including political sphere) 

Corruption within public procurement – Lithuania #1 

Fight against corruption in public procurement 

Comment 

Measures addressing transparency in public 
procurement. 

Measures to improve the effectiveness of control 
and audit 

- 

2.52 Infringements in agriculture sector – amendments to legal acts  

This measure includes three orders of the Minister of Agriculture of the Republic of Lithuania, 
specifically:   

•  No  3D-80  of  14  February  2023  "On  the  Approval  of  the  Methodology  for  the 
Application  of  Sanctions  for  Infringements  of  the  Provisions  of  Legal  Acts  in  the 

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Implementation of the Intervention Measures of the Strategic Plan of Agricultural and 
Rural Development of Lithuania 2023-2027",  

•  No 3D-80 of 5 February 2010 "On the Approval of the Rules for the Administration of 
Infringements of Legal Provisions in Connection with the Implementation of Measures 
of the European Agricultural Guarantee Fund, the European Agricultural Fund for Rural 
Development and the European Fisheries Fund" (Last amended in 10/09/2024),  

•  No 3D-929 of 4 December 2014 "On Approval of the Methodology for the Application 
of Sanctions for Infringements of the Provisions of Legal Acts in the Implementation of 
the  Measures  of  the  Rural  Development  Programme  2014-2020  in  Lithuania"  (Last 
amended in 16/09/2024). 

Brief  description  of  the  legislation:  the  amendments  are  related  to  investigating  a  suspected 
infringement,  sharing  information  with  other  authorities,  decision-making,  information, 
sanction methodology, etc.  

Changes are expected to facilitate conducting investigations into irregularities, protecting the 
financial interests of the EU and the Republic of Lithuania. (*) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #2 taken by Lithuania in 2025  

E
L
G
N
I
S

Legislative  
16/09/2024 

New 
legislation 

Amendment  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Fisheries 

Other – 
Investigations of 
irregularities 

Definition of a 
specific topic 

Recovery   

Reason / 
Expected Result  

To enforce the 
rules in line 
with 
developments 
in EU law 

Other*  

Regional  law/decree/order:  Order  of  the  Minister  of  Agriculture  of  the  Republic  of  Lithuania  No  3D-80  of  5 
February  2010  "On  the Approval  of  the  Rules  for  the  Administration  of  Infringements  of  Legal  Provisions  in 
Connection with the Implementation of Measures of the European Agricultural Guarantee Fund, the European 
Agricultural Fund for Rural Development and the European Fisheries Fund  

Luxembourg 

2.53 Update of control and monitoring system for the national 
implementation of the RRF 

The protection of the financial interests of the Union is particularly important for the national 
implementation  of  EU  funds. As  part  of  NextGenerationEU,  the  Recovery  and  Resilience 
Facility is a centrepiece of the EU's pan to emerge stronger and more resilient from the current 
crisis.  Member  States  are  responsible  for  the  successful  implementation  of  their  national 
Recovery and Resilience Plan. 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Luxembourg in 2025  

E
G
A
K
C
A
P

Operational 
19/12/2025 

Update  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Recovery And 
Resilience 
Facility 

Shared 
Management and 
Control of the 
EU Funds 

IT tools ("IT 
data feeding", 
"Other IT") 

Increased 
number of 
checks 

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

Targeting of 
checks 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

2.54 Guidelines on ESF+ procedural matters  

The managing authority of the ESF+ has prepared a Summary outlining the organisation and 
management of the programme, as well as the procedures to be followed in all matters related 
to its operation. In particular, it includes guidelines to be applied in cases of detected fraud or 
irregularities, the corresponding corrective procedures, and the notification and monitoring of 
such irregularities. 

This measure provides a guideline that explains the procedure to follow, step by step, in various 
situations to protect the financial interests of the EU. It therefore reduces the error rate and also 
decreases the likelihood that irregularities will go unnoticed 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Luxembourg in 2025  

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

New 
measure  

Update 

E
G
A
K
C
A
P

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Shared 
Management and 
Control of the EU 
Funds 

Antifraud or 
Anticorruption 
Strategy 

Organisational  
01/12/2025 

New 
measure  

Update 

Eligibility 
criteria  

Management 
of funds 

Monitoring/ 
desk checks 

On the spot 
checks 

Audit checklist 

Irregularities 
reporting 

Recovery 

To clarify or 
consolidate 
existing rules 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies 

Competence  

Simplification 
of procedures 

Neutral on 
resources  

2.55 Adding a new feature – a whistleblower button  

We  have  added  a  whistleblower  button  that  redirects  users  to  the  national  whistleblower 
platform, both on the ESF+ platform and on our website. It also includes a brief explanation of 
whistleblowing,  the  protection  and  anonymity  afforded  to  whistleblowers,  and  the  different 
types of cases that may arise. 

The  whistleblower  button  is  intended  to  provide  actors  with  an  additional  means  of 
anonymously reporting fraudulent activities. By communicating the introduction of this new 
tool, we aim to strengthen an anti‑fraud culture, thereby reducing the opportunity to commit 
fraud and increasing overall awareness 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Luxembourg in 2025  

Operational 
01/01/2026 

New 
measure  

Prevention

Detection

HORIZONTAL 

Whistleblower 

Recovery 
and sanction 

Investigation 
and 
prosecution 

IT tools ("IT 
data feeding", 
"Other IT") 

Web 
reporting/ 
Hotline 

Enhanced 
cooperation 

Enhanced 
information 
flow 

E
L
G
N
I
S

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Malta 

Malta  reported  one  administrative  measure  in  2025,  covering  a  campaign  against  fraud  and 
misuse of public funds, which raised awareness and pointed to the reporting infrastructure. This 
campaign targeted public service and public sector employees.  

2.56 Communications campaign against fraud and misuse of public funds 

In 2025, Malta initiated the process to implement a communications campaign against fraud 
and  misuse  of  public  funds  (including  EU  funds  that  Malta  is  required  to  manage  under  its 
international obligations), in response to Action Points 9 and 10 of the National Anti-Fraud and 
Corruption Strategy. A desktop message was devised, which reached over 54,000 employees 
working within the Public Service and Public Sector. The message directed employees to report 
the above-mentioned irregularities through the Report Suspected Fraud/Irregularities button on 
the website of the Internal Audit and Investigations Department. The campaign was launched 
during the second week of 2026 upon the lapse of the festive season. 

This measure involves a communications campaign addressed to employees within the Public 
Service and Public Sector to raise awareness about the incidence of fraud and misuse of public 
funds. The campaign also highlights the infrastructure that is in place to assist public employees 
to report suspected cases of fraud and misuse of public funds in a secure manner. Increased 
awareness to safeguard public funds and a straightforward reporting system are considered as 
very  strong  measures  in  the  protection  of  national  and  EU  financial  interests  and  the  fight 
against fraud. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Malta in 2025  

E
L
G
N
I
S

Administrative 
Action plan 

New 
measure 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

Conflict of 
Interest 

Shared 
Management and 
Control of the 
EU Funds 

Antifraud or 
Anticorruption 
Strategy 

Irregularities 
reporting 

To clarify or 
consolidate 
existing rules 

Netherlands 

In  2025,  the  Netherlands  reported  three  measures,  including:  an  operational  measure 
introducing annual declaration on absence of the conflict of interest, an administrative measure 

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covering  a  comprehensive  update  of  a  program  anti-fraud  strategy,  and  an  amendment  of  a 
money-laundering prevention act.  

2.57 Annual self-declaration of absence of a potential conflict of interest 

With regard to the recommendation of the European Commission and the observations made 
by the national audit service on the risk of conflict of interest of the Paying Agency's in-house 
staff (beyond the swearing of an oath the managing authorities’ integrity policies), it has been 
agreed that for anyone working on a project for which an assessment has to be done, a list will 
be drawn up each year and signed to confirm absence of conflicts of interest. 

When they take up their post, in-house staff swear an oath. There is also an integrity policy at 
the organisation. The organisation considered these two measures sufficient to prevent conflicts 
of interest affecting in-house staff. With the European Commission’s recent recommendation 
and the comments from the national audit service on the risk of conflicts of interest affecting 
in-house staff of the managing authority, it has been agreed that, for anyone working on a project 
in which for which an assessment has to be done, a list will be drawn up each year and signed 
to confirm absence of conflict of interest. (*) 

Anti-Fraud Measure #1 taken by the Netherlands in 2025  

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

E
L
G
N
I
S

Operational 
01/07/2025 

New 
measure  

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Horizontal / 
Sectoral  

SECTORAL 

Area  

Scope  

Reason / 
Expected Result  

Expenditure: 
Cohesion Policy 

Conflict of 
Interest 

Risk indicators  Other* 

2.58 Complete revision of the Interreg Meuse-Rhine antifraud policy 
programme 

A new policy applies to the entire programme. The policy reflects the programme’s commitment 
to protecting EU and public funds, in line with legal, ethical and moral rules. The programme 
adheres to the principles of integrity, objectivity and fairness. There is a zero-tolerance policy 
on fraud and corruption. 

All the various authorities, including EU ones, concerned with the programme can be involved 
in prosecuting fraud. (*) 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #2 taken by the Netherlands in 2025  

E
G
A
K
C
A
P

Administrative 
Decision/ Resolution 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Fraud Definition 

Whistleblower 

Antifraud Or 
Anticorruption 
Strategy 

Eligibility 
criteria  

Management 
of funds 

Monitoring/ 
desk checks 

Investigation 

Recovery 

Reason / 
Expected Result  

To clarify or 
consolidate 
existing rules 

To enhance 
existing 
measure 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies (*) 

2.59 Legislative amendment against misuse of legal exception rules  

An amendment to Regulation of the Minister of Agriculture, Fisheries, Food Security and 
Nature of 18 December 2024, to Article 5 of the CAP 2023 Implementing Regulation. 

The paying agency wants to prevent large companies being able to make use of the exception 
under Article 5. 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by the Netherlands in 2025  

E
L
G
N
I
S

Legislative  
18/12/2024 

Prevention

Detection 

Amendment  

HORIZONTAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Shared 
Management and 
Control of the 
EU Funds 

Definition of a 
specific topic  

To clarify and 
consolidate 
existing rules 

Decision: An amendment to Regulation of the Minister of Agriculture, Fisheries, Food Security and Nature of 18 
December 2024, to Article 5 of the CAP 2023 Implementing Regulation. 

Poland 

Poland reported three single operational measures in 2025, all of which focused on stages of 
fraud prevention and fraud detection. Specifically, those include: updated mechanisms for co-
financed  projects  verification  regarding  conflict  of  interest;  verification  of  impartiality 
declaration  at  the  stage  of  selecting  beneficiaries;  and,  a  checklist  for  monitoring  the 
implementation and verification of expenditure in the field of public procurement and public 
aid.  

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2.60 Strengthening selection of projects with potential conflict of interests 

This  measure  is  related  to  strengthening  control  mechanisms  and  tools  for  monitoring  the 
process  of selecting projects  to  be cofinanced under EU funds, using the conflict  of interest 
verification procedure in the SAMPLER tool.   

The  procedure  was  adopted  in  January  2025  and  updated  in  December  2025.  The  updated 
version of the procedure includes, inter alia, detailed rules for verifying when selecting projects 
for cofinancing, conflicts of interest between members of project evaluation committees and 
beneficiaries whose projects are selected for cofinancing under the relevant call. 

Applying  the  mechanism  simplifies  the  procedures  for  verifying  entities  and  individuals, 
including  personal  and  capital  links  between  them.  It  allows  comprehensive  and  targeted 
verification of entities and individuals when projects  are being  selected  for cofinancing,  the 
implementation  of  a  structured  process  of  examining  the  risk  of  conflicts  of  interest  and  an 
improved  information  flow.  The  introduction  of  this  measure  constitutes  an  action  under 
Article 325  TFEU  and  fulfils  the  obligations  laid  down  in  Article 74(1)(c)  and  (d)  of 
Regulation (EU) 2021/1060 and Article 61 of Regulation (EU, Euratom) 2024/2509). 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Poland in 2025  

E
L
G
N
I
S

Operational 
09/01/2025 

New 
measure  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Cohesion Policy 

Conflict of 
Interest 

Shared 
Management and 
Control of the 
EU Funds 

IT tools ("IT 
data feeding", 
"Other IT") 

Risk 
indicators 

Enhanced 
coordination 

Enhanced 
information 
flow 

Targeting of 
checks 

2.61 Verification of declarations of impartiality  

Instructions for verifying declarations of impartiality and confidentiality during the work of the 
tender  evaluation  committees  in  the  selection  of  beneficiaries-partner  organisations  with  a 
nationwide or supraregional scope for the European Food Aid Funds 2021-2027 programme 
under the ESF+. 

The tool aims to address conflicts of interest. It is part of the description of the management 
and control system in place in the institutions involved in the implementation of the European 
Funds for Food Aid 2021-2027 Programme. 

The  tool  aims  to  prevent  conflicts  of  interest  at  the  stage  of  selecting  beneficiaries-partner 
organisations of nationwide or supraregional for the European Funds for Food Aid programme 
(FEPŻ). The verification of the declarations of the members of the evaluation committee by an 
independent organisational unit in the managing authority is intended to confirm the correctness 

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financial interests 

of  the  declarations  submitted  and  prevent  conflicts  of  interest  when  beneficiaries  with 
nationwide  or  supraregional  reach  are  being  selected.  This  instrument  has  been  adopted  to 
implement  the  recommendation  made  by  the  audit  authority  in  the  system  audit  for  the 
European Funds for Food Aid programme for financial year 2024/2025. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Poland in 2025  

E
L
G
N
I
S

Operational 
19/03/2025 

New 
measure  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Fund For the 
Most Deprived 

Conflict of 
Interest 

Risk indicators 

Shared 
Management and 
Control of the 
EU Funds 

Increased 
number of 
checks 

Enhanced 
information 
flow 

Targeting of 
checks 

Enhanced ex-
ante controls 

2.62 Guidelines for controls under the development plan co-financed by 
the RRF 

The guidelines have been supplemented by an additional annex, namely a framework checklist 
for  checking  the  implementation  and  verification  of  expenditure  in  the  field  of  public 
procurement  and  state  aid. The  mechanism  can  contribute  to  a  more  effective  combating  of 
fraud and other illegal activities affecting the financial interests of the EU. 

The  rationale  for  introducing  the  framework  checklist  was  to  indicate  to  the  institutions  the 
system  for  implementing  the  National  Recovery  and  Resilience  Plan,  i.e. institutions 
responsible for reforms / institutions responsible for investments / support units – the essential 
elements underpinning verifications during checks on public procurement and state aid. This 
harmonises the approach of the individual institutions in this area and ensures that checks are 
more  effective.  The  introduction  of  the  checklist  constitutes  implementation  of  one  of  the 
Commission’s recommendations. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Poland in 2025  

Operational 
08/05/2025 

 New 
measure 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Public 
Procurement  

Expenditure: 
Recovery And 
Resilience 
Facility 

Shared 
Management and 
Control of the 
EU Funds 

Risk indicators 

Enhanced 
coordination 

Targeting of 
checks 

E
L
G
N
I
S

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Portugal 

Portugal  reported  three  measures  focused  on  fraud  prevention  and  detection  stages  in  2025. 
Those  include  awareness,  computerisation  and  organising  focus  groups,  as  set  out  in  the 
National Anti-Fraud Strategy, providing access to risk dashboards for Managing Authorities, 
and development of a new customs database.  

2.63 Implementation of measures set out in the National Anti-Fraud 
Strategy (NAFS) 

The implemented measures focus on the continuity of fraud awareness activities, the conclusion 
of coordination agreements, the development of IT systems to detect double funding (Recovery 
and Resilience Plan, RRP) and participation in working groups to deal with matters related to 
fraud prevention and detection (Agricultural Funds). 

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. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Portugal in 2025  

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E
L
G
N
I
S

Operational 
31/12/2025 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Agriculture 

Expenditure: 
Fisheries 

Expenditure: 
Cohesion Policy 

Expenditure: 
Centralised 
Direct 
Management 

Expenditure: 
Fund For the 
Most Deprived 

Expenditure: 
Globalisation 
Fund 

Expenditure: 
Migration And 
Asylum 

Expenditure: 
Recovery And 
Resilience 
Facility 

AFCOS 

Shared 
Management and 
Control of the 
EU Funds 

Antifraud or 
Anticorruption 
Strategy 

IT tools ("IT 
data feeding", 
"Other IT") 

Risk indicators 

Structured 
cooperation 
with judicial 
authorities 

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

Targeting of 
checks 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

2.64 Updating of mechanisms to support risk assessment, analysis and 
management when implementing EU funding 

In 2025, the Agency for Development and Cohesion, as the certifying authority, made available 
to  the  managing  authorities,  for  monitoring  risk  and  error  categories  (combination  of 
beneficiary and operation) and the impact category for payment claims. The dashboards are in 
a specific risk-assessment area on a dedicated platform. 

The purpose of this measure is to make the management of funds from the EU budget more 
effective by allowing managing authorities to identify, prevent and mitigate situations involving 
fraud  or  mismanagement;  at  the  same  time,  this  enhances  transparency  and  integrity  when 
funding is disbursed and in their implementation. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Portugal in 2025  

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E
L
G
N
I
S

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Cohesion Policy 

Shared 
Management and 
Control of the 
EU Funds 

Expenditure: 
Migration And 
Asylum 

Antifraud or 
Anticorruption 
Strategy 

Management 
of funds 

Monitoring/ 
desk checks 

On the spot 
checks 

To enhance 
existing 
measure 

2.65 Development of a new customs anti-fraud database 

The  measure  was  implemented  with  the  aim  of  improving  data  collection  and  processing, 
enhancing risk management and profiling, with a focus on interoperability with EU and national 
systems, as well as providing analytical information. 

The  new  customs  anti-fraud  database  will  improve  data  quality  and  integrity,  enable  the 
application of data analytics and artificial intelligence tools, and ensure interoperability with 
EU and national systems. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

nti-Fraud Measure #3 taken by Portugal in 2025  

E
L
G
N
I
S

Operational 
31/12/2025 

New 
measure  

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Revenue: 
Customs 

Revenue: Tax 
Fraud 

Financial Crime 
(Including 
Money 
Laundering) 

Organised Crime 

Customs/Tor/ 
Illicit Trade 

IT tools ("IT 
data feeding", 
"Other IT") 

Risk indicators 

Increased 
number of 
checks 

Structured 
cooperation 
with law 
enforcement 

Enhanced 
coordination 

Enhanced 
cooperation 

Targeting of 
checks 

Enhanced ex-
ante controls 

Romania 

 In 2025, Romania reported three measures, all targeting corruption, among other related areas. 
Specifically,  a  legislative  measure  addressing  corruption  of  foreign  public  officials,  an 
establishment  of  a  dedicated  fund  supporting  anti-corruption  investigation  and  surveillance 
efforts, and an amendment to the legal framework allowing for the use of new technologies in 
customs operations.  

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2.66 Strengthening the legal framework to prevent and combat corruption 
of foreign public officials 

This measure concerns the Law No 156 of 16 October 2025 amending Law No 319/2024 laying 
down  measures  implementing  the  Convention  on  Combating  Bribery  of  Foreign  Public 
Officials in International Business Transactions, adopted in Paris on 21 November 1997, and 
supplementing Law No 302/2004 on international judicial cooperation in criminal matters. Law 
No 156/2025 strengthens the legal framework for preventing and combating bribery of foreign 
public officials, which is a significant component of the fight against fraud. 

Brief  description  of  the  legislation:  Law  No 156/2025  introduces  significant  amendments  to 
both  criminal  law  and  legislation  on  international  judicial  cooperation,  with  the  aim  of 
strengthening the legal framework for preventing and combating the bribery of foreign public 
officials. Legislative act in its scope regulates the criminal framework for offences involving 
the bribery of foreign public officials in the context of international business transactions. (*) 

The adoption of the legislative act forms part of Romania’s accession process to the OECD. 
(**) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #1 taken by Romania in 2025  

Reason / 
Expected Result  

To clarify and 
consolidate 
existing rules 

Competences  

Powers 

Definition of a 
specific topic 

To remedy 
flaws  

Recovery  

Criminal 
sanctions  

Other*  

To enforce the 
rules in line 
with 
developments 
in EU law 

Other**  

E
L
G
N
I
S

Legislative  
16/10/2025 

New 
legislation 

Amendment  

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Financial Crime 
(Including 
Money 
Laundering) 

HORIZONTAL 

Corruption 

Other - Integrity 
and transparency 
measures 

Law/Act: No.156 

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Public / 
Private sector 

Public sector  
(including political sphere) 
Private sector 

Corruption within public procurement – Romania #1 

Fight against corruption in public procurement 

Comment 

Measures to prevent corruption amongst personnel, 
including management 

2.67 Strengthening the operational capacity of the National Anti-Corruption 
Directorate 

A  special  fund  for  operational  expenses,  amounting  to  3,000,000  LEI,  equivalent  to 
approximately  600,000  EUR  annually  was  established  in  2025.  Under  Government  Order 
No 10  of  1 February  2025,  the  National  Anti-Corruption  Directorate  (Direcția  Națională 
Anticorupție, DNA) became the beneficiary of this fund. The Order sets up the legal framework 
for the creation of an annual fund intended for the planning and conduct of operations aimed at 
detecting corruption offences as they are being committed, and of a special fund for operational 
expenditure under the authority of the Directorate’s chief prosecutor. 

The management and use of the special fund for operational expenditure were regulated at DNA 
level by Order No 44 of 14 April 2025 of the chief prosecutor. This Order sets out the fund’s 
designated  uses,  primarily  covering  the  implementation  of  technical  surveillance  measures, 
procurement of technical means and necessary equipment, and expenses incurred through the 
use of undercover investigators, investigators acting under their real identity and collaborators. 
This special fund has significantly strengthened the operational capacity of the DNA. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Romania in 2025  

Investigation 

Penalty 

Recovery 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Revenue: 
Customs 

Corruption 

Competence 

To enhance 
existing 
measure 

Increased 
resources  

IT tools ("IT 
data feeding", 
"Other IT") 

Enhanced 
information 
flow 

Increased 
number of 
checks 

Targeting of 
investigations 

Administrative 
Decision/ 
Resolution 

New 
measure 

Organisational 
01/02/2025  

New 
measure 

Operational 
14/04/2025 

New 
measure  

E
G
A
K
C
A
P

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Public / 
Private sector 

Public sector  
(including political sphere) 
Private sector 

Corruption within public procurement – Romania #2 

Fight against corruption in public procurement 

Comment 

Measures to improve the effectiveness of control 
and audit 

2.68 Strengthening customs control and supervision mechanisms 

This measure concerns the Law No 239/2025 of 15 December 2025 laying down measures for 
the recovery and efficient use of public resources and amending certain legislative acts amended 
Law No 86/2006 (the Romanian Customs Code) by introducing a new Article 20^1 on the use 
of photo-audio-video equipment by customs personnel in the course of specific customs control 
and supervision activities. 

The measure is intended to enhance the framework for protecting the financial interests of the 
European  Union  by  strengthening  customs  control  and  supervision  mechanisms  for  goods 
imported  into  the  EU  customs  territory.  The  measure  aims  to  prevent  and  combat  tax  and 
customs  fraud  by  creating  a  unified,  coherent  and  stable  legal  framework  that  is  adapted  to 
social realities and ongoing technological developments. 

Brief description of the legislation: The measure involves amending Law No 86/2006 (through 
the adoption of Law No 239/2025 of 15 December 2025) by introducing Article 20^1, which 
relates  to  the  use  of  photo-audio-video  equipment  by  designated  customs  personnel  in  the 
course of customs control and supervision activities. The new article contains six paragraphs 
and  lays  down  the  general  criteria  and  conditions  governing  the  use  of  body-worn  camera 
systems (including recording, capture, storage and access), with the detailed implementing rules 
to be laid down by order of the President of the Romanian Customs Authority. 

The  measure  establishes  a  legal  framework  for  the  effective  operation  and  use  of  available 
technical  resources,  with  the  aim  of  increasing  integrity  among  customs  personnel  and 
enhancing public trust in the customs administration. The measure is designed to prevent the 
commission  of  unlawful  acts,  particularly  corruption  offences,  and  to  deter  activities  and 
conduct that breach the customs code of conduct. Its purpose is to strengthen the prevention 
and detection of tax and customs (*) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Romania in 2025  

E
L
G
N
I
S

Legislative  
15/12/2025 

New 
legislation 

Amendment 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

92 

SECTORAL 

Corruption 

Revenue: 
Customs 

Customs/Tor/ 
Illicit Trade 

Revenue: Tax 
Fraud 

Antifraud or 
Anticorruption 
Strategy 

Competences  

Other 
administrative 
penalties  

Other*  

 
 
 
  
 
 
 
 
 
 
 
 
 
  
  
 
 
Commission Staff Working Document - Measures adopted by the Member States to protect the EU’s 
financial interests 

Law/Act: No. 239 

Public / 
Private sector 

Public sector  
(including political sphere) 
Private sector 

Corruption within public procurement – Romania #3 

Fight against corruption in public procurement 

Comment 

Measures to improve the effectiveness of control 
and audit 

2.69 Additional measures reported by Romania in 2025 

Romania  reported  also  additional  measures  undertaken  in  2025,  which  are  related  to  the 
operations  of  the  National  Office  for  the  Prevention  and  Combating  of  Money  Laundering 
(ONPCSB), and include:  

•  updating the national legislative framework in the field of preventing and combating 
money  laundering  (AML)  and  terrorist  financing  (CFT).  Law  No 129/2019  on  the 
prevention  and  combating  of  money  laundering  and  terrorist  financing  has  been 
amended by Government  Emergency Order No 10 of 13 March 2025, Law No 86 of 
22 May 2025, Law No 164 of 23 October 2025 and Law No 224 of 12 December 2025. 
The aim of these amendments is to adapt the legislative framework to new European 
and international requirements. 

The main objectives of these legislative amendments are to align national legislation with 
EU law, to remedy the shortcomings identified in the Moneyval Evaluation Report, and to 
strengthen internal mechanisms for preventing, detecting and sanctioning money laundering 
and terrorist financing  activities. Specifically, among  other things, the amendments  have 
clarified  reporting  entities’  obligations;  strengthened  customer  due  diligence  measures; 
streamlined  the  supervisory  regime  and  updated  the  sanctions  framework;  strengthened 
ONPCSB’s  role  in  coordinating  risk  assessments;  and  improved  customer  due  diligence 
requirements, staff training and statistical reporting. 

•  updating  legislation  on  the  enforcement  of  international  sanctions  by  adopting  Law 
No 151 of 13 October 2025, Government Emergency Order No 66 of 2 December 2025, 
and  Law  No 224  of  12 December  2025. These  legislative  acts  have  strengthened  the 
institutional and procedural framework for enforcing international financial sanctions, 
including those adopted at EU level. 

Through these legislative measures, Romania has sought to ensure a consistent and efficient 
regulatory  framework  that  is  adapted  to  recent  developments  and  thereby  strengthen  the 
national system for preventing and combating money laundering and terrorist financing and for 
enforcing international sanctions. 

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Slovakia 

In 2025, Slovakia reported three package measures addressing: the strengthening of a common 
standard and the digitalisation of irregularities reporting across multiple involved entities, the 
strengthening of the system of financial control and internal audit through an amendment to the 
Act on Financial Control and Audit and the issuance of a methodological guideline on internal 
audit, and the application of preventive and corrective measures within the CAP fund through 
legal amendments, guidelines, and a new anti-fraud strategy in this domain. 

2.70 Improving reporting and strengthening communication channels 

This set of measures aimed to improve the reporting of irregularities and suspicions of fraud 
and to strengthen communication channels includes:  

1)  Manual on Reporting Irregularities (AFCOS),  
2)  New  IT  system  ITMS21+  functionalities  for  the  administration  of  irregularities, 
reporting  irregularities  to  OLAF  and  data  exchange  with  the  IMS  system  for  the 
Programme Slovakia 2021-2027 (AFCOS+MF SR),  

3)  Cooperation agreement between Government Office of the Slovak Republic (AFCOS) 
and the Office for the Fight against Organised Crime of the Ministry of the Interior of 
the Slovak Republic,  

4)  Establishment  of  contact  points  at  regional  prosecutors'  offices  of  the  General 

Prosecutor´s Office of the Slovak Republic for OLAF investigators. 

The set of measures directly responds to the European Commission’s recommendations in the 
36th  PIF  Report.  It  standardises  and  digitalises  the  reporting  of  irregularities  and  suspected 
fraud, improves the quality, completeness and timeliness of data and reduces the risk of errors. 
By  strengthening  cooperation  between  AFCOS,  law  enforcement,  prosecutors  and  OLAF 
through  updated  agreements  and  designated  contact  points,  it  contributes  to  more  effective 
protection of the European Union’s financial interests. 

Updating  the  rules  for  reporting  irregularities  and  suspected  fraud  (Manual  on  Reporting 
Irregularities) and their application across entities involved in the external reporting system to 
the EC/OLAF, aims to eliminate reporting deficiencies, ensuring consistency of procedures and 
increasing the quality, completeness and timeliness of data reported through the IMS. Manual 
on Reporting Irregularities covers PP 2004-2006, 2007-2013, 2014-2020, 2021-2027 and for 
EAGF, EAFRD, AMIF, ISF, CF, EGF, ERDF, ESF, ESF+,EFF, ENRF, FEAD,CBC-ENP.(*) 

The  IT  systems  ITMS21+  and  IMS  are  interconnected  through  automated  data  export  and 
import for monthly and quarterly reports, improving data quality and efficiency in relation to 
OLAF. 

In addition, the cooperation agreement between the Government Office of the Slovak Republic 
(AFCOS) and the Office for the Fight against Organised Crime of the Ministry of the Interior 
of  the  Slovak  Republic,  together  with  the  establishment  of  contact  points  at  regional 
prosecutors’ offices of the General Prosecutor’s Office of the Slovak Republic for cooperation 
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with OLAF investigators(**), strengthen cooperation and communication within the system for 
the  protection  of  the  EU’s  financial  interests,  particularly  in  the  new  institutional  setting 
following the abolition of the Special Prosecutor’s Office and the National Criminal Agency in 
2024. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Anti-Fraud Measure #1 taken by Slovakia in 2025  

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Administrative 
Circulaire/Circular, 
Instructions, 
Guidelines, Manuals 

Update 

E
G
A
K
C
A
P

Prevention

Detection

HORIZONTAL 

Organisational  
18/12/2025 

New 
measure 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Operational 
10/11/2025 

 New 
measure 

Financial 
Crime 
(Including 
Money 
Laundering) 

Organised 
Crime 

AFCOS 

Other 

Irregularities 
reporting 

Reorganisation of 
existing bodies  

Competence 

Inter-agency 
cooperation  

Other**  

IT tools ("IT data 
feeding", "Other 
IT") 

Reason / 
Expected Result  

To clarify or 
consolidate 
existing rules 

To enhance 
existing 
measure 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies* 

Neutral on 
resources  

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

2.71 Strengthening control and audit system of public financial resources 

A set of measures to strengthen the system of control and audit of public financial resources 
was adopted, including: 

1)  amendment  to  Act  No.  357/2015  Coll.  on  financial  control  and  auditing  and  on 
amendments  to  certain  laws;  amendment  to  the  law  enhances  the  performance  of 

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financial interests 

financial  control  across  the  entire  public  administration.  It  strengthens  the  internal 
control system of public administration bodies, including sound financial management. 
2)  methodological guidance of the Audit and Control Section of the Ministry of Finance 
of the Slovak Republic on the performance of internal audits, effective from January 1, 
2026 (Ministry of Finance of the Slovak Republic); New internal audit guidelines were 
adopted due to the adoption of an amendment to the Act on Financial Control and Audit. 
The  methodological  guidelines  for  the  performance  of  internal  audits  regulate  the 
performance of internal audits in accordance with that act.” 

Brief description of the legislation: The key elements of the internal control system were 
established. They are based on the generally accepted and recommended COSO model. In 
connection with the design of the internal control system, the competences for internal audit 
were adjusted, including reporting obligations regarding the internal control system. The 
financial  control  system  was  simplified  in  order  to  reduce  the  administrative  burden  on 
public authorities as much as possible. 

The  methodological  guideline  regulates  the  basic  rules,  objectives,  and  method  of 
performing internal audits for public administration bodies that perform internal audits. The 
methodological  guidelines  have  been  developed  in  accordance  with  internationally 
recognized  auditing  standards,  in  particular  the  Global  Standards  for  Internal  Auditing 
issued  by  the  Institute  of  Internal Auditors,  which  came  into  effect  on  January  9,  2025.  
Internal auditors perform internal audits in accordance with the Standards. (*) 

Anti-Fraud Measure #2 taken by Slovakia in 2025  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Prevention

Detection

HORIZONTAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Shared 
Management and 
Control of The 
EU Funds 

Other – Internal 
audit 

Legislative  
21/10/2025 

Amendment 

Administrative 
Circulaire/Circular, 
Instructions, 
Guidelines, Manuals 

New measure 

96 

Competences  

Powers 

Definition of a 
specific topic 

Financial 
penalties  

Other- 
Financial 
control, 
Internal control 
system, audit  

To clarify and 
consolidate 
existing rules 

To remedy 
flaws  

Monitoring/ 
desk checks 

Other – 
Internal audit 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies* 

Singl
e / 
Packa
ge  

E
G
A
K
C
A
P

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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financial interests 

Law/Act: Act no. 294/2025 Coll. Amending the Act no. 357/2015 Coll. on financial control and auditing and on 
amendments to certain laws. 

Public / 
Private sector 

Public sector  
(including political sphere) 
Private sector 

Corruption within public procurement – Slovakia #2 

Fight against corruption in public procurement 

Comment 

Measures to prevent corruption amongst personnel, 
including management 

Measures to improve the effectiveness of control 
and audit 

2.72 Strengthening the protection of the EU’s financial interests within the 
framework of the CAP 

Set of measures has been adopted to strengthen the protection of the EU’s financial interests 
within the framework of the CAP, with:   

•  Act No. 316/2025 Coll., amending Act No. 280/2017 Coll. on the provision of support 
and  subsidies  in  agriculture  and  rural  development,  Act  No.  292/2014  Coll.  on 
contributions from the European Structural and Investment Funds and Act No. 247/2024 
Coll. on contributions from the European Agricultural Fund for Rural Development;  
•  Methodological  Guideline  of  the  Managing  Authority,  particularly  regarding  the 
handling  of  irregularities,  controls,  payment  applications,  and  rules  on  public 
procurement and procurement;  

•  a new Anti-Fraud Policy of the Agricultural Paying Agency (APA);   
• 

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

Set of measures to strengthen the prevention, detection and correction of irregularities and fraud 
in  the  use  of  EU  funds  under  the  CAP  for  the  years  2023-2027.  It  responds  to  the  new 
requirements  of Regulations (EU) 2021/2115 and 2021/2116 and to  the shortcomings of the 
previous  national  framework.  The  measures  align  preventive  and  corrective  measures  with 
eligibility  conditions,  strengthen  legal  certainty  and  reduce  the  risk  of  irregular  payments, 
thereby protecting the financial interests of the EU. 

Brief description of the legislation: Act No. 316/2025 Coll., on contributions from the European 
Agricultural Fund for Rural Development, introduces a specific legal framework for control 
procedures, powers and obligations related to administrative checks, on-the-spot checks, remote 
sensing and the area monitoring system. The amendment addresses the specificities of direct 
payments and sectoral interventions, clarifies the status and powers of body responsible for the 
protection of the EU’s financial interests (AFCOS), and regulates procedures for dealing with 
irregularities, suspected fraud and the recovery of undue payments. 

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Non-legislative  measures  supporting  the  package  include  the  adoption  of  a  new Anti-Fraud 
Policy and its publication on the website of the APA, establishing a framework for preventing, 
detecting and tackling fraud and defining the responsibilities of staff, beneficiaries and third 
parties. The methodological guideline for the Managing Authority was adopted, specifying the 
procedures for handling irregularities, controls, payment claims and public procurement and 
strengthening the protection of the EU's financial interests before and after the payment from 
the EAFRD.(*) 

Creation of a working group for project support as a cross-cutting unit within the APA, which 
is  tasked  with  assessing  selected  projects  and  deciding  on  the  further  course  of  the APA.  It 
mainly concerns the areas of public procurement, conflict of interest and control of EU funds. 
This measure is also expected to reduce the likelihood of irregularities within the CAP, more 
effective  and  faster  cooperation  between  the  involved  APA  departments  in  resolving 
irregularities,  increased  emphasis  on  resolving  cases  investigated  by  OLAF  and  the  use  of 
experience in new projects. (**) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #3 taken by Slovakia in 2025  

E
G
A
K
C
A
P

Legislative 
21/11/2025 

Amendment 

Public 
Procurement  

SECTORAL 

Expenditure: 
Agriculture 

Financial Crime 
(Including Money 
Laundering) 

Competences  

Powers 

Organised Crime 

Recovery  

Corruption 

Conflict of 
Interest 

Financial 
penalties   

Reason / 
Expected Result  

To clarify and 
consolidate 
existing rules 

To remedy 
flaws  

To enforce the 
rules in line 
with 
developments 
in EU law 

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AFCOS 

Whistleblower 

Shared 
Management and 
Control of the EU 
Funds 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

Administrative 
Circulaire/circular, 
Instructions, 
Guidelines, Manuals 

New measure 

Eligibility 
criteria  

Management 
of funds 

Monitoring/ 
desk checks 

On the spot 
checks 

Audit checklist 

Investigation 

Irregularities 
reporting 

Penalty 

Recovery 

Other* 

To clarify or 
consolidate 
existing rules 

To enhance 
existing 
measure 

Organisational  
20/03/2025 

New measure 

Other**  

Neutral on 
resources  

Law/Act:  Act  No.  316/2025  Coll.  This  is  an  act  amending  and  supplementing  Act  No.  280/2017  Coll.  on  the 
provision of support and subsidies in agriculture and rural development and amending Act No. 292/2014 Coll. on 
the contribution provided from the European Structural and Investment Funds and on the amendment of certain 
acts, as amended, as amended and supplementing Act No. 247/2024 Coll. on the contributions provided from the 
European Agricultural Fund for Rural Development and on the amendment of certain acts. 

Slovenia 

In 2025, Slovenia reported three sectoral measures, including: an introduction of a new feature 
aimed at spotting double financing in the application system, enhanced information exchange 
between authorities and amendment of money-laundering prevention legislation.  

2.73 Automatic verification of double co-financing  

Inclusion  of  automatic  application  verification  of  double  co-financing  at  the  level  of  an 
individual application or payment claims was done by the Agency for Agricultural Markets and 
Rural  Development  (ARSKTRP).  Inclusion  of  a  new  ‘double  co-financing’  tab  in  the 
application for processing applications and payment claims. Data are entered in this tab if the 
applicant/beneficiary  has  already  received  appropriations  from  the  paying  agency  and  other 
grantors of aid which could overlap in content with the supported project.   

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In accordance with Article 36 of Regulation 2021/2116/EU of the European Parliament and of 
the Council of 2 December 2021 on the financing, management and monitoring of the common 
agricultural policy and repealing Regulation (EU) No 1306/2013, the ARSKTRP ensures that 
expenditure financed by the EAGF or the EAFRD does not receive any other financing from 
the Union budget. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Slovenia in 2025  

E
L
G
N
I
S

Operational 
01/07/2025 

Update  

Prevention

Detection

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Agriculture 

Shared 
Management and 
Control of the 
EU Funds 

IT tools ("IT 
data feeding", 
"Other IT") 

Enhanced ex-
ante controls 

Enhanced ex-
post controls 

2.74 Exchange of information between national police and EPPO 

Ministry of Cohesion and Regional Development established links and exchange of information 
between  the  managing  authority,  the  EPPO,  and  the  police  through  regular  cooperation  and 
reporting on cases, such as indictments, and joint training using examples from the practice of 
all bodies concerned. 

Because if authorities are better informed and information flows between them are improved, 
this fosters better implementation of the European Cohesion Policy, which results in a better 
protection of financial interests and early detection, which in turn contributes to a more effective 
system of protection of the EU's financial interests. 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Slovenia in 2025  

E
L
G
N
I
S

Operational 
20/11/2025 

New 
measure  

Prevention

Detection

SECTORAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Expenditure: 
Cohesion Policy 

Shared 
Management and 
Control of the 
EU Funds 

Structured 
cooperation 
with law 
enforcement 

Enhanced 
coordination 

Enhanced 
cooperation 

Enhanced 
information 
flow 

Targeting of 
checks 

Targeting of 
investigations 

2.75 Amendment of money laundering prevention legal act 

Office for Money Laundering Prevention adopted a legislative measure – an act amending The 
Prevention of Money Laundering and Terrorist Financing Act (Official Gazette of the Republic 
of Slovenia, No. 17/25 - ZPPDFT-2B);   

The  European  Funds  Service  of  the  Ministry  of  the  Interior,  in  its  capacity  of  Managing 
Authority (MA) for the Internal Security Funds and Implementing Body for the Resilience and 
Recovery  Plan,  also  carries  out  work  to  prevent  fraud,  specifically  awareness-raising, 
participation in training, monitoring of the fraud risk indicators, identification of conflicts of 
interest  and  risks  in  public  procurement  procedures  and  the  implementation  of  contracts.  In 
2025 an additional measure was introduced to determine whether there were any conflicts of 
interest  between 
and 
tenderers/contractors.   

in  public  procurement  procedures 

individuals 

involved 

 As  regards  OLAF  and  the  Office  for  Money  Laundering  Prevention  as  competent  national 
authority, new Article 116a has been added in Prevention of Money Laundering and Terrorist 
Financing  Act.  This  article  relates  to  effective  cooperation  between  OLAF  and  the  Office 
regarding requests relating to matters under investigation in Art.3 and 4 of Reg.883 MNZ: The 
measure we report on is key to strengthening the ethical behaviour of individuals, improving 
risk management, ensuring an effective system and supervision and controls, thus strengthening 
the protection of the EU's financial interests, including detection and prevention of interests. 

The managing authority reports quarterly to AFCOS on detected irregularities in the use of EU 
funds under the Internal Security Funds. In 2025, an irregularity was detected in one case, which 
was reported to the MA of the Ministry of the Interior and reported to the competent authorities. 
An irregularity could also constitute a potential conflict of interest. Further irregularities have 
been rectified during the implementation of the operation, which is why the operation continues. 

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In  connection  with  the  provision  laid  down  in  Regulation  2023/2223/EU  concerning 
cooperation between OLAF and the Office as the competent national authority, a new Art. 116a 
has  been  added  in  The  Prevention  of  Money  Laundering  and  Terrorist  Financing Act.  This 
article relates cooperation between OLAF and the Office regarding requests relating to matters 
under investigation referred to in Articles 3 and 4 of Regulation 883/2013/EU (*) 

In  addition  to  the  fraud  indicators  already  included  in  the  checklists  for  management 
verifications,  with  an  emphasis  on  the  detection  of  conflicts  of  interest  and  risks  in  public 
procurement  procedures  and  in  the  implementation  of  contracts,  additional  activities  were 
introduced  for  checking  interest-based  connections  between  the  participants  in  the  public 
procurement  procedure  and  the  selected  tenderers/contractors.  A  declaration  by  persons 
involved  has  been  introduced  regarding  their  lack  of  connections  to  tenderers,  plus  further 
checking of this declaration (firstly only at the management verification stage, then at the public 
procurement implementation stage following the audits carried out by the Audit Authority). (**) 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Slovenia in 2025  

E
L
G
N
I
S

Organisational  
03/01/2025 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

SECTORAL 

Expenditure: 
Migration And 
Asylum 

Expenditure: 
Recovery And 
Resilience 
Facility 

Public 
Procurement  

Financial Crime 
(Including Money 
Laundering) 

Conflict of 
Interest 

Shared 
Management and 
Control of the EU 
Funds 

Antifraud or 
Anticorruption 
Strategy 

Other* 

Fraud 
awareness 
trainings  

Other**  

Increased 
resources  

Spain 

Spain reported three horizontal measures in 2025, which include an approval of the statewide 
anti-corruption  plan  and  its  five  areas  of  action,  an  establishment  of  a  dedicated  body  for 
whistleblower  protection,  and  creation  of  a  working  group  dedicated  to  collaboration  with 
EPPO.  

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2.76 Approval of the State Plan to Combat Corruption 

Approval by the Council of Ministers on 26 August 2025 of the State Plan to Combat Corruption 
and the creation of an interministerial commission to implement, promote and monitor the plan 
(Royal Decree 711/2025 of 26 August). 

This plan deploys a strategy for action in the areas of transparency, good governance of public 
administrations and the fight against corruption, based on the recommendations of the Council 
of  Europe's  Group  of  States  against  Corruption  (GRECO),  the  OECD  and  the  European 
Commission, and incorporating contributions from civil society.  

The Plan includes five areas of action: 

1)  Risk  prevention  and  governance  in  the  fight  against  corruption  and  control  of 

corruption. 

2)  Protection of whistleblowers. 
3)  Combating corruption: investigating, prosecuting and punishing corruption. 
4)  Recovery of assets derived from corrupt activities. 
5)  Promotion of a culture of anti-corruption and integrity among citizens 

The  State  Plan  to  Combat  Corruption,  which  will  be  implemented  through  an  organic  law 
currently  being  drafted,  includes  five  areas  of  action  that  will  contribute  to  improving  the 
protection of the EU's financial interests, in addition to national interests. 

Brief  description:  Royal  Decree  711/2025,  of  August  26,  creating  the  Interministerial 
Commission  for the Promotion  of the State Plan to  Combat Corruption, and establishing  its 
composition  and  functioning. The  Commission  is  chaired  by  the  First Vice  President  of  the 
Government and Minister of Finance. 

For the implementation of the Plan, it is planned to approve the Organic Law on Public Integrity, 
subject to prior public consultation in September 2025, which is currently being drafted, as well 
as other regulatory amendments. The State Plan to Combat Corruption establishes a roadmap 
that allows to continue moving toward a more honest and transparent administration. It contains 
new measures to combat corruption in different areas. (*) 

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Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Anti-Fraud Measure #1 taken by Spain in 2025  

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Public 
Procurement  

Financial Crime 
(Including Money 
Laundering) 

Organised Crime 

Corruption 

Conflict of 
Interest 

Prevention

Detection

HORIZONTAL 

Fraud Definition 

Legislative 
26/08/2025  

New 
legislation 

E
G
A
K
C
A
P

Recovery 
and sanction 

Investigation 
and 
prosecution 

Administrative 
Action plan 

New 
measure 

AFCOS 

Whistleblower 

Shared 
Management and 
Control of the EU 
Funds 

Antifraud or 
Anticorruption 
Strategy 

Reason / 
Expected Result  

To clarify and 
consolidate 
existing rules 

To remedy 
flaws  

To enforce the 
rules in line 
with 
developments 
in EU law 

To clarify or 
consolidate 
existing rules 

To enhance 
existing 
measure 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies* 

Competences  

Powers 

Definition of a 
specific topic 

Recovery   

Management 
of funds 

Monitoring/ 
desk checks 

Investigation 

Penalty 

Recovery 

Decree: Royal Decree 711/2025 

Public / 
Private sector 

Corruption within public procurement – Spain #1 

Fight against corruption in public procurement 

Comment 

Measures addressing transparency in public 
procurement. 

Public sector  
(including political sphere) 

Measures to improve the effectiveness of 
management of the public procurement. 

Measures to prevent corruption amongst personnel, 
including management 

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Measures addressing transparency of companies 
participating in public procurement 

Measures to improve the effectiveness of control 
and audit 

2.77 Establishment of the State Independent Whistleblower Protection 
Authority  

The  State  Independent  Whistleblower  Protection Authority  was  established  on  1  September 
2025 (Order PJC/908/2025, of August 8, determining the date of commencement of operations 
of the Independent Whistleblower Protection Authority).  

The purpose of this Independent Authority for the Protection of the Informant is to guarantee 
the protection of the informant, to serve as an institutional pillar in the prevention and fight 
against  fraud  and  corruption,  and  in  guaranteeing  the  integrity  of  the  administrations  and 
personnel in the service of the public sector. 

This Authority  is  also  in  charge  of  an  external  reporting  channel  whose  scope  includes  the 
protection of EU´s financial interests. 

The material scope of Law 2/2023 on the protection of persons who report regulatory violations 
and the fight against fraud covers, in addition to the scope of the Directive (EU) 2019/1937, 
actions or omissions that may constitute a serious or very serious criminal or administrative 
offense. (*) 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #2 taken by Spain in 2025  

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E
L
G
N
I
S

Administrative 
Other - Ministerial 
Order (Ministry of 
Justice, Office of the 
President, and Court 
Relations) 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

Financial Crime 
(Including Money 
Laundering) 

Organised Crime 

Corruption 

Conflict of 
Interest 

Fraud Definition 

Whistleblower 

Shared 
Management and 
Control of the EU 
Funds 

Antifraud or 
Anticorruption 
Strategy 

Other* 

Other - 
Reporting 
channel and 
whistleblower 
protection 

To clarify or 
consolidate 
existing rules 

Public / 
Private sector 

Public sector  
(including political sphere) 
Private sector 

Corruption within public procurement – Spain #2 

Fight against corruption in public procurement 

Comment 

Measures to prevent corruption amongst personnel, 
including management 

Other measures preventing corruption in public 
procurement 

The scope of the external reporting channel 
includes breaches of public procurement.  

Protection of whistleblowers. 

2.78 Creation of an operational group dedicated to EPPO cases 

Creation within the Economic and Fiscal Crime Unit of the National Police of a new operational 
group dedicated exclusively to investigating and enforcing requirements in relation to crimes 
falling within the jurisdiction of the European Public Prosecutor's Office. 

The existence of a new group attached to the European Public Prosecutor's Office, physically 
located at the headquarters of the Spanish delegation of the aforementioned Office, significantly 
improves  cooperation  with  this  body  and,  therefore,  the  protection  of  the  EU's  financial 
interests. 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #3 taken by Spain in 2025  

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E
L
G
N
I
S

Organisational  
01/02/2025 

New 
measure 

Prevention

Detection 

Recovery 
and sanction 

Investigation 
and 
prosecution 

HORIZONTAL 

Public 
Procurement  

Financial Crime 
(Including Money 
Laundering) 

Organised Crime 

Corruption 

Conflict of 
Interest 

Customs/Tor/ 
Illicit Trade 

Shared 
Management and 
Control of the EU 
Funds 

Reorganisation 
of existing 
bodies  

Inter-agency 
cooperation  

General 
trainings 

Increased 
resources  

Public / 
Private sector 
Public sector  
(including political sphere) 

Private sector 

Corruption within public procurement – Spain #3 

Fight against corruption in public procurement 

Comment 

Other measures preventing corruption in 
public procurement 

Investigation and prosecution of crimes in 
public procurement funded by European funds. 

2.79 Additional measures reported by Spain in 2025 

Spain reported additional measures undertaken in 2025, including:  

• 

In  2025,  the  process  of  filling  the  posts  assigned  to  the Support  Unit  of  the  General 
Intervention of the State Administration (IGAE) for the European Public Prosecutor's 
Office continued, a unit that depends organically on the IGAE and functionally on the 
EPPO. All four positions are currently filled. 

Likewise, in January 2025, the Civil Guard significantly increased the number of support staff 
assigned to the EPPO. 

•  As a development of Law 7/2024 and the VAT amendment to tackle hydrocarbon fraud 
in relation to the concepts of reliable operator and guarantee management, Orders of the 
Ministry of Finance nº 1495, 1496, and 1497 of 2025 have been published, with the new 
system  coming  into  effect  on  January  1,  2026,  for  applications  for  reliable  operator 
status and on February 1, 2026, for guaranteed extractions. 

•  Development by the ERDF managing authority of verification and control instruments 
that  encompass  both  strategies  and  checklists,  which  form  part  of  the  management 

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verification  system,  ensuring  that  co-financed  expenditure  complies  with  the 
regulations, is reviewed using risk-based criteria, and is documented objectively. 

•  Update  of  the  Strategy  for  the  prevention,  detection,  and  combating  of  fraud  and 
conflicts  of  interest  within  the  agency  (FEGA,  Spanish Agricultural  Guarantee  Fund 
Agency). 

•  The Conflict of Interest Advisory Unit, created in 2023 at the IGAE in the context of 
the Recovery, Transformation and Resilience Plan, has continued  its work in 2025 to 
disseminate  good  practices  to  avoid  and  prevent  conflicts  of  interest,  through  the 
publication of the document ‘Ethical and Integrity Commitments’ aimed at participants 
in public procurement procedures (tenderers, contractors and subcontractors). 

•  The Spanish AFCOS has continued its intensive training work on the prevention and 
fight against fraud to the EU's financial interests, both in general terms in these matters, 
and in more specific training in the framework of the implementation of the Recovery, 
Transformation  and  Resilience  Plan.  Other  entities  also  organised  trainings  e.g.  the 
FEGA, or the Civil  Guard to  provide training to national  investigators specialised in 
economic and financial investigations to increase their knowledge of frauds that may 
affect  the  EU's  financial  interests  in  order  to  facilitate  the  detection  of  possible 
fraudulent conduct during their investigative activities. 

Sweden 

Sweden  reported  two  horizontal  measures  in  2025,  including  a  legislative  amendment 
strengthening penalties for offences related to high risk of damaging confidence in the public 
and  trust  in  authorities  and  an  administrative  measure  related  to  a  report  on  possibilities  to 
reduce double financing risks.  

2.80 Strengthening of penalties for certain offences 

The Government’s bill introducing more severe penalties for certain offences relevant to the 
criminal offences set out in Articles 3 and 4 of the SEFI Directive. The bill provides for higher 
penalties that better reflect the gravity of the offences. 

Brief  description  of  the  legislation:  It  is  proposed  to  increase  the  minimum  penalty  from 
imprisonment  of  six  months  to  imprisonment  of  one year  for  the  following  offences:  gross 
fraud, gross misappropriation of subsidies, gross embezzlement, gross breach of trust, gross tax 
offence, gross customs offence and gross money laundering. The minimum penalty for bribery 
(taking or giving a bribe) is to be increased from a fine to imprisonment of minimum one month. 
The  minimum  penalty  for  gross  bribery  (taking  or  giving  a  bribe)  is  to  be  increased  from 
imprisonment of six months to imprisonment of 18 months. The maximum penalties for the 
above offences will remain unchanged. 

The legislative measure is proposed as part of a broader review of penalty scales under criminal 
law,  some  of  including  for  offences  related  to  those  criminalised  under  the  SEFI  Directive. 
Among other things, it was considered that those offences should be met with a more forceful 

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reaction than is currently the case and that they are of such a nature that they risk undermining 
trust in public authorities and other central institutions. (*) 

Single / 
Package  

Type  

New / Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Reason / 
Expected Result  

Anti-Fraud Measure #1 taken by Sweden in 2025  

E
L
G
N
I
S

Legislative 
15/01/2026  

Amendment  

Prevention

Detection 

HORIZONTAL 

Recovery 
and sanction 

Investigation 
and 
prosecution 

Financial 
Crime 
(Including 
Money 
Laundering) 

Criminal 
sanctions  
(more)  

Other*  

Law/Act: Referral to the Council on Legislation Dual punishment for crimes in criminal networks and stricter 
penalty scales, decided by the Government on 15 January 2026. 

2.81 Report on the conditions for reducing the risk of double funding 

Report  on  the  conditions  for  countering  fraud  and  other  irregularities  through  checks  by 
authorities  managing,  administering  and  disbursing  EU  funds  to  recipients  in  Sweden.  The 
reports have been produced together with several managing authorities under the SEFI Council. 
This provides increased support and knowledge in how these issues should be addressed. 

Indicative reports have been drawn up that can be used at a cross-cutting level by all managing 
authorities. (*) 

Single / 
Package  

Type  

New / 
Update/ 
Amendment 

Stage in Anti-Fraud Cycle  

Horizontal / 
Sectoral  

Area  

Scope  

Anti-Fraud Measure #2 taken by Sweden in 2025  

E
G
A
K
C
A
P

Administrative 
Recommendation 

Update 

Prevention

Detection

Recovery 
and sanction 

Investigation 
and 
prosecution 

Financial Crime 
(Including Money 
Laundering) 

HORIZONTAL 

Organised Crime 

Monitoring/ 
desk checks 

Shared 
Management and 
Control of the EU 
Funds 

Reason / 
Expected Result  

To clarify or 
consolidate 
existing rules 

Cross-cutting 
measure, multi-
agency 
measure/measu
re with impact 
on various 
bodies* 

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Case studies  
In 2025, nine Member States voluntarily submitted a case study in the PIF Questionnaire. The 
cases are related to different irregularity types, both on the revenue and expenditure side, or 
include  conflict  of  interest  or  counterfeit  goods  scenarios.  The  following  table  summarises 
information  on  the  reporting  country,  type  of  irregularity  detected,  and,  in  most  cases,  the 
amount affected by the irregularity.  

Italy 
Cross-border VAT fraud 

Approx. 34 million EUR 

Croatia 
Misclassification of 
goods/smuggling 

Czech Republic 
VAT fraud/tax evasion 

400,608.00 EUR amount 
due was recovered 

Approx. 187 million EUR 

Belgium 
Misuse of investment 
premiums 

3,360,000.00 EUR 

Slovakia 
False statements and 
documentation 

Romania 
False documentation 

More than 5.6 million EUR, 
financial damage avoided 

More than 240,000 EUR 
(1,224,832 RON) 

Hungary 
Conflict of interest 

Bulgaria 
Conflict of interest, false declaration 

No subsequent financial damage found 

N/A 

Greece  
Counterfeit food products 

Approx. 95 million EUR in seized goods  

E
U
N
E
V
E
R

E
R
U
T
I
D
N
E
P
X
E

F
O
T
C
I
L
F
N
O
C

T
S
E
R
E
T
N
I

I
E
F
R
E
T
N
U
O
C

S
D
O
O
G
T

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Case study 1. The case of a missing trader company, reported by Italy   

Reporting country: 

Italy  

Irregularity type: 

Cross-border VAT fraud  

Amount affected: 

Approx. 34 million EUR 

Industry/Product: 

Wholesale of cleaning products  

Suspicion:  

Abnormal financial flows from Italian companies to a local 
company operating in the financial sector 

The Verona Economic and Financial Police Unit, in the context of an investigation coordinated 
by the European Public Prosecutor’s Office, identified a criminal association engaged in cross-
border VAT fraud in the wholesale trade in cleaning products. 

The investigative activities, which also involved international judicial cooperation mechanisms, 
uncovered a fraudulent system built on ‘shell’ and ‘buffer’ companies, which are used to evade 
VAT.  In  short,  companies  purportedly  resident  abroad  purchased  household  cleaning  and 
personal  hygiene products  from  Italian wholesalers (VAT-free) and then sold  them  – though 
only on paper – to missing traders in Italy who then supplied the goods to buffer companies 
without paying any tax. 

On 26 November 2025, the aforementioned unit, together with other units of the Guardia di 
Finanza, issued an order for the precautionary seizure, also by equivalent value, of assets and 
financial  resources  worth  approximately  EUR  34  million.  They  also  called  7  leaders  of  the 
criminal organisation and 27 of their associates in for questioning prior to the implementation 
of the precautionary measures. Simultaneous operations took place in Croatia, resulting in the 
arrest of a number of suspects, and in northern Italy, where searches and seizures were carried 
out at the request of the Croatian judicial authorities. 

A Central European Financial Intelligence Unit (FIU) reported abnormal cash flows from Italian 
companies to a local company operating in the financial sector, on the suspicion that they were 
purchasing  false guarantees. The company had been the subject of  criminal  proceedings  for 
offences  related  to  money  laundering  and  fraud  and  had  also  been  suspected  of  conducting 
unauthorised banking activities. The FIU's analysis initially focused on suspicious transaction 
reports concerning the Italian companies (which had previously been involved in various illegal 
activities).  Subsequently,  through  consulting  the  national  public  procurement  database  and 
based on close cooperation with the National Anti-Corruption Authority, the Unit found that 
two of the aforementioned companies had been awarded multiple tenders and then gone on to 
sign the related public contracts, which were financed by EU NRRP funds. However, the actual 
use  and  submission  of  the  guarantees  in  question  in  the  tender  documentation  were  not 

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specifically assessed. In this regard, the FIU has conducted a thorough and effective financial 
analysis, enhanced its capacity to access external information assets and implemented effective 
best practices for both national and international cooperation.  

Case study 2. The case of an attempted cigarettes smuggling, reported 
by Croatia  

Reporting country: 

Croatia  

Irregularity type: 

Misclassification of goods/smuggling  

Amount affected: 

400,608.00 EUR – amount due was recovered 

Industry/Product: 

Cigarettes  

Suspicion:  

Shape of transported goods did not match the description  

On October 16, 2025, in Bregana, customs officers of Mobile Unit Zagreb stopped and singled 
out  for  inspection  a  truck  with  goods  declared  for  transit  –  plastic  film,  with  gross  weight 
15,317.00 kg. The vehicle was transported to Department of Mobile Unit Zagreb in Bregana. 
The  control  revealed  shapes  that  did  not  match  with  the  description  of  the  declared  goods. 
Cardboard boxes containing cigarettes were discovered – 13,910,000 pieces of various brands 
of cigarettes. As means of committing the crime, set of vehicles and goods were temporarily 
confiscated. Customs duty was collected in the amount of 400,608.00 EUR. 

Case study 3. The case of imports from third countries and fictitious 
movement of goods between EU countries, reported by Czech 
Republic  

Reporting country: 

Czech Republic   

Irregularity type: 

VAT fraud/tax evasion  

Amount affected: 

Approx. 187 million EUR 

Industry/Product: 

Electronic goods  

Suspicion:  

Targeted action against an organised group importing goods 
from third countries and engaging in fictitious trade 
transactions 

The  case,  codenamed  ‘Záblesk’  (‘Flash’),  targeted  a  group  of  individuals  suspected  to  be 
involved in a long-term criminal scheme consisting of the importation of electronic devices into 
the European Union from third countries (including Hong Kong, the United Arab Emirates and 

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the  United  States)  through  companies  based  in  Czechia.  These  companies  subsequently 
declared  intra-Community  supplies  of  goods  to  entities  registered  in  Hungary,  Poland  and 
Slovakia. However, these foreign entities did not engage in any real economic activity, did not 
take  delivery  of  the  goods  and  did  not  pay  anything. The  electronic  equipment  was  instead 
delivered to other recipients that have yet to be identified.  

The  losses  caused  by  this  fraudulent  scheme  are  estimated  to  exceed  CZK 4.7 billion 
(approximately EUR 187 million), making it one of the largest cases of VAT fraud in Czechia’s 
history. A total of ten people were arrested, seven of whom have been formally charged with 
the  serious  crime  of  tax  fraud,  specifically  tax  evasion,  and  the  illegal  underpayment  of 
compulsory payments. The court decided to place six of the accused in pre-trial detention; in 
the case of one individual, pre-trial detention was replaced by conditional supervision and a 
prohibition on leaving the country. If convicted, the individuals will face custodial sentences of 
between five and ten years. Three properties, luxury watches and cash were seized during house 
searches,  and  bank  accounts  holding  a 
(approximately 
EUR 1.6 million) were frozen. 

total  of  CZK 42 million 

Case study 4. The case of waffle factory funded with ERDF, reported by 
Belgium  

Reporting country: 

Belgium   

Irregularity type: 

Misuse of investment premiums  

Amount affected: 

3,360,000.00 EUR 

Industry/Product: 

ERDF funds/factory construction  

Suspicion:  

A check conducted on company premises revealed existence 
of a private apartment 

In 2019, company X was granted an investment premium of 28% on an investment programme 
worth EUR 12 000 000 with a budgetary impact of EUR 3 360 000. The investment was for the 
construction of a new waffle factory. The company undertook to employ at least 44.79 workers 
from  1 April  2023  to  31  March  2027. The  employment  condition  was  met  in  the  reference 
quarter with 48.25 FTEs. The premium was therefore paid in full (two instalments in 2020 and 
the balance in 2021).  

In 2024, an own initiative a check on the company’s premises was carried out by the competent 
administration, which discovered the existence of a private apartment occupied by the director 
and the director’s spouse and children. The director had never informed the administration of 
the existence of this residence. The administration considered that the director of company X 
had knowingly provided incorrect or incomplete information with a view to obtaining the grant. 
In 2025, the administration then planned to request the full recovery of the investment premium, 

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i.e. EUR 3 360 000 (40% from the ERDF). For the infringement ‘Has KNOWINGLY provided 
incorrect or incomplete information with a view to obtaining a grant’, a criminal report was also 
sent  to  the  competent  public  prosecutor  for  misappropriation  of  subsidies,  fraud  and  use  of 
forgery.  

Case study 5. The case of nineteen identical applications, reported by 
Slovakia   

Reporting country: 

Slovakia 

Irregularity type: 

False statements and documentation 

Amount affected: 

More than 5.6 million EUR, financial damage avoided 

Industry/Product: 

ESF+ fund, non-refundable subsidies for adult education 

Suspicion:  

Multiple (19) applications originating form one organisation 
included identical references of previous experience and 
requested the same amount of a non-refundable financial 
contribution.  

On  2  October  2024,  The  Ministry  of  Education,  Research,  Development  and Youth  of  the 
Slovak  Republic,  as  the  intermediary  body  for  the  Programme  Slovakia  (the  Ministry  of 
Education)  announced  a  call  for  applications  for  a  non-refundable  financial  contribution 
(application)  entitled  "Development  of  basic  adult  skills  -  the  path  to  inclusion  and 
employability"  call  code  PSK-MSVVM-019-2024-DV-ESF+  (call).  The  condition  for 
providing a contribution (eligibility of the applicant) is that the organization meets the following 
on  the  day  of  submitting  the  application:  the  organization  demonstrates  at  least  2  years  of 
experience (cumulative) with the implementation of activities in accordance with the focus of 
the call for eligible target groups of the call.  

When  fulfilling  and  demonstrating  experience  with  the  implementation  of  activities  and  the 
target group, 19 applicants who applied for the provision by registering for the call submitted 
references, where 1 person acts as a guarantor. After reviewing these references, the ministry of 
Education found that the references in the title of the training are identical. This means that each 
of the 19 applicants should have implemented the same set of training courses. The applicants 
were unable to refute the doubts even after being asked to supplement or explain the doubts and 

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ambiguities. For this reason, reasonable doubt arose about the truthfulness of these references. 
At the same time, the relevant applications have the same amount of the requested financial 
contribution.  

The  Ministry  of  Education  rejected  all  19  applications  in  the  approval  process,  because  the 
relevant  condition  for providing the contribution was not  met. Subsequently the Ministry of 
Education submitted a motion to the General Prosecutor’s Office of the Slovak Republic on 14 
May 2025 pursuant to Section 196 of Act No. 301/2005 Coll. on the Criminal Code (Criminal 
Code) against an unknown offender on suspicion of committing the crime of damage to the 
financial interests of the EU at the stage of attempt pursuant to Section 261, paragraph 1 of the 
Criminal  Code.  If  grant  agreements  for  a  non-repayable  financial  contribution  had  been 
concluded with the applicants, the applicants would have been provided with funds from EU 
sources in the amount of more than 5.6 million euros.  

On 26 September 2025, the Ministry of Education received a notification from the European 
Public  Prosecutor's  Office  on  the  initiation  of  criminal  prosecution  in  the  matter  of  the 
concurrent continuing crimes of damage to the financial interests of the EU under the Criminal 
Code, both in the preparation stage. Subsequently, the case was transferred to the Police Force 
Presidium of the Slovak Republic, Banská Bystrica unit, for the purpose of further investigation, 
which  is  currently  ongoing.  The  employees  of  the  provider,  as  well  as  the  statutory 
representatives of the organizations, have already been questioned. 

Case study 6. The case of inflated costs of beekeeping equipment, 
reported by Romania 

Reporting country: 

Romania   

Irregularity type: 

False documentation  

Amount affected: 

More than 240,000 EUR (1,224,832 RON) 

Industry/Product: 

EAGF fund, Apiculture (beekeeping)  

Suspicion:  

Overstated values for equipment presented on fraudulent 
invoices.   

This  case  concerns  an  acquisition  of  non-self-propelled  beekeeping  transport  equipment 
(beekeeping  trailer/beekeeping  pavilion)  and  non-self-propelled  equipment  for  loading  and 
unloading  hives  in  transhumant  beekeeping.  Prosecutors  from  the  National Anti-Corruption 
Directorate – Bacău Regional Service indicted 12 defendants, without placing them in custody, 
in connection with the unlawful receipt of RON 1 224 832 in European funds, as follows: 

•  10 private individuals, all of them beekeepers or on behalf of various companies, each 
charged  with  the  offence  of  using  or  presenting,  in  bad  faith,  false,  inaccurate  or 
incomplete documents or statements, resulting in the wrongful receipt of EU funds; 

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•  a company and its administrator, U.M.C., each charged with incitement to the use or 
presentation, in bad faith, of false, inaccurate or incomplete documents or statements, 
resulting in the wrongful receipt of EU funds, as a continued offence consisting of 10 
acts,  and with  forgery of private documents,  as a continued offence consisting of 18 
acts. 

The 10 private individuals, acting as beekeepers or on behalf of various companies, applied for 
financial support under the 2022 National Apiculture Programme (funded from European and 
national sources), under the component ‘Acquisition of non-self-propelled beekeeping transport 
equipment  (beekeeping  trailer  /  beekeeping  pavilion)  and  non-self-propelled  equipment  for 
loading and unloading hives used in transhumant beekeeping’. 

They were allegedly induced by U.M.C., by means of promises of material benefits, to submit 
applications  between  27 April  and  2 May  2022  for  financial  support  under  this  component, 
reporting overstated values for the equipment to be acquired. For that purpose, U.M.C. provided 
them  with  pro  forma  invoices  issued  by  the  company  containing  incomplete  data.  Those 
documents accompanied each beneficiary’s letter of intent. Subsequently, U.M.C. prepared and 
issued, on behalf of the same company, a total of 18 fiscal invoices containing false information 
as  to  the  purchase  value  of  the  equipment.  Between  28 July  and  1 August  2022,  the  10 
defendants  submitted  these  documents  to  the  Agency  for  Payments  and  Intervention  for 
Agriculture, knowing them to be false. 

For example, evidence relating to the company’s sale of equipment described as ‘utility trailers’ 
showed  that  the  10  trailers  were  purchased  by  the  company  at  prices  of  RON 19 499.99 
(including  VAT)  and  RON 23 099.99  (including  VAT),  whereas  the  price  charged  by  the 
company in its commercial dealings with the 10 beekeepers was RON 118 950 (including VAT). 

To secure recovery of the damage identified in the case, the prosecutors imposed precautionary 
measures on certain immovable property belonging to the defendants. The prosecutors sent the 
indictment  to  the  Neamț  Tribunal  (Tribunalul  Neamț),  along  with  the  proposal  that  the 
precautionary measures be maintained. 

Case study 7. The case of conflict of interest (family connections), 
reported by Hungary 

Reporting country: 

Hungary  

Irregularity type: 

Conflict of interest   

Amount affected: 

N/A, no subsequent financial damage found    

Industry/Product: 

N/A 

Suspicion:  

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Undeclared close relationship between a supplier and a 
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financial interests 

A person was found to have a conflict of interest, as the investigation identified several projects 
in which that person carried out substantive procedural steps, while their spouse was a supplier 
in the projects concerned. In all cases, the person under examination made an ad-hoc declaration 
of  absence  of  conflict  of  interest. According  to  the  information  provided  by  the  Managing 
Authority, no factors affecting the projects  were  identified  during the checks. The  employer 
took action in relation to the person concerned. 

Case study 8. The case of conflict of interest (professional ties with 
both the beneficiary and the contractor), reported by Bulgaria 

Reporting country: 

Bulgaria  

Irregularity type: 

Conflict of interest, false declaration 

Amount affected: 

N/A 

Industry/Product: 

Trainings  

Suspicion:  

Conflict of interest was falsely undisclosed in a single tender 
procedure, resulting in a selection of a contractor who failed 
to fulfil conditions of participation.  

The General Directorate ‘National Police’ received a report alleging that unlawful actions had 
been committed by a beneficiary of a cross-border cooperation project. During the check of the 
selection of a contractor with a single tender in accordance with the Practical Guide on contract 
procedures  for  European  Union  external  action  (PRAG  version  2020.0),  concerning  the 
participation of Bulgarian stakeholders in a training course, it was found that, when selecting a 
contractor,  the  contracting  authority  had  not  fulfilled  the  conditions  for  participation  in  the 
selection procedure and had allowed a conflict of interest. 

The beneficiary association had concluded a contract with a person for the preparation of tender 
documents for the project and for the contract at issue. According to the information available 
in the curriculum vitae submitted on the conclusion of the above-mentioned contract, it was 
established that the person was a member of the company’s staff. According to the curriculum 

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vitae, the person is responsible for the ‘Development of project proposals, preparation of project 
applications,  organisation,  monitoring  and  coordination  of  the  implementation  of  approved 
projects’ in the company applying for the contract.  

A  declaration  was  submitted  by  the  company  representing  the  contractor  stating  that  the 
tenderer ‘had not participated in the preparation of the tender procedure, where this might entail 
a breach of the principle of equal treatment, including distortion of competition, that cannot be 
remedied otherwise’. This constitutes a conflict of interest between the person involved in the 
preparation of the tender documents and the contractor selected. 

The contracting authority, the association, submitted to the MA false information contained in 
a  false  declaration  completed  by  the  contractor,  signed  personally  by  the  contractor’s 
representative and submitted to a representative of the contracting authority, and the beneficiary, 
the  association,  failed  to  inform  the  MA  (Directorate  for  Technical  Services  –  Ministry  of 
Regional Development and Public Works) of the circumstances that had come to its attention 
during the procedure, namely that the selected contractor had a conflict of interest in breach of 
the rules of the Practical Guide (point 2.6.10.1.2 Rejection from a given procedure (c)). 

Upon completion of the inspection, the materials were reported to the competent prosecutor’s 
office and pre-trial proceedings were initiated for criminal offences under Article 248a (3)(1) 
in conjunction with (2)(1) of the Criminal Code. 

Case study 9. The case of targeted operation against food fraud, 
reported by Greece  

Reporting country: 

Greece  

Irregularity type: 

Counterfeit food and beverage products 

Amount affected: 

Approx. 95 million EUR 

Industry/Product: 

Food and beverages  

Suspicion:  

N/A, targeted operation  

Participation of the Sub-Directorate for Financial Crimes (YDOE) in Operation OPSON XIV 
(from  December  2024  to  May  2025)  to  combat  food  fraud  in  general  and  the  trafficking  of 
counterfeit/counterfeit  and  low-quality  food  and  beverages  in  particular.  The  operation 
involved law enforcement authorities from EU Member States and non-EU countries, with the 
support  of  the  European  Antifraud  Office  (OLAF),  the  European  Commission  Directorate-
General  for  Health  and  Food  Safety  (DG  SANTE),  the  European  Commission  Directorate-
General  for  Agriculture  and  Rural  Development  (DG  AGRI)  and  the  European  Union 
Intellectual Property Office (EUIPO).  

This  operation  resulted  in  the  dismantling  of  13  criminal  organizations,  the  arrest  of  101 
persons, the prosecution of 631 persons, the seizure of illicit goods with a total estimated value 

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of EUR 95 million and the total checks carried out amounting to 31 165 (ref. EUROPOL press 
release dated 06/10/2025). 

The sub-objectives of Operation OPSON XIV, in accordance with EUROPOL’s Operational 
Plan, shall consist of: 

• 

the protection of animals, plants and public health 

•  preventing the trafficking of counterfeit/counterfeit food and beverages 

• 

focusing attention on international crimes requiring the support of EUROPOL 

•  strengthening  cooperation  between  national  law  enforcement  agencies,  food  control 
agencies, the private sector of the food and beverage industry, EUROPOL and other 
organizations involved in the operation 

•  strengthening inter-agency cooperation 

•  strengthening 

the  capacity  of 

the  field  of 
counterfeit/counterfeit  food  by  raising  awareness  of  the  threats  and  regulations 
associated with these products 

law  enforcement  authorities 

in 

•  accurately record and send results related to seizures of illegal food and beverages 

• 

• 

identifying new threats 

increasing  consumer  and  law  enforcement  awareness  of  food  crime  and  its 
consequences 

•  strengthening cooperation with the Prosecution Service at local and national level 

• 

improving  the  exchange  of  information  between  EUROPOL,  INTERPOL  and 
participating countries 

•  strengthening cooperation between the private and public sectors. 

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