COMMISSION STAFF WORKING DOCUMENT Follow-up by Member States to the Recommendations of the PIF Report 2024 Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT 37th Annual Report on the protection of the European Union's financial interests and the fight against fraud - 2025
Date: 2026-07-28
Institutions: European Anti-Fraud Office, European Commission
Subjects: EU Member State, EU budget, EU strategy, activity report, corruption, digitisation, fight against crime, financial control, fraud, fraud against the EU

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 28.7.2026  SWD(2026) 248 final  COMMISSION STAFF WORKING DOCUMENT Follow-up by Member States to the Recommendations of the PIF Report 2024  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) 249 final} - {SWD(2026) 250 final} - {SWD(2026) 251 final}  
 
 
Table of Contents 

1. 
1.1. 

1.2.1. 
1.2.2. 

Overview of Member States’ replies to the questionnaire ..............................................................5 
Introduction..........................................................................................................................................5 
Overarching Themes and Guiding Principle .......................................................................5 
1.1.1. 
1.2.  Recommendation 1 ..............................................................................................................................6 
Reporting maturity and strategic focus ...............................................................................6 
Best Practices ......................................................................................................................9 
1.3.  Recommendation 2 ............................................................................................................................ 10 
Information flow ............................................................................................................... 10 
Cooperation between administrative and investigative/judicial bodies ............................ 11 
Best Practices .................................................................................................................... 13 
1.4.  Recommendation 4: ........................................................................................................................... 14 
Digitalisation and AI ......................................................................................................... 14 
Digitalisation barriers ........................................................................................................ 15 
State of Play of Arachne ................................................................................................... 16 
Best Practices .................................................................................................................... 18 

1.4.1. 
1.4.2. 
1.4.3. 
1.4.4. 

1.3.1. 
1.3.2. 
1.3.3. 

Responses from the Member States ............................................................................................... 19 

2. 
Q.1.1 How would you evaluate your level of maturity of your current reporting process for reporting 

irregularities and, in particular, fraud? ............................................................................................... 19 
Following Q1.1, please specify "Other". ....................................................................................................... 19 
Q.1.2 Which part of the Anti-Fraud Cycle do your Anti-Fraud Efforts target most? .................................... 20 
Q.1.3 Please explain your reasons for this focus. .......................................................................................... 20 
Q.1.4 Which part of the Anti-Fraud Cycle do your Anti-Fraud Efforts target most? .................................... 28 
Q.1.5 Please explain your reasons for this choice ......................................................................................... 28 
Q.1.6 How do you measure the effectiveness of your Anti-Fraud system? ................................................... 34 
Q.1.7 (IMS users) How do you ensure adequate knowledge of existing staff? ............................................. 41 
Following Q1.7, please specify "Other". ....................................................................................................... 42 
Q.1.8 (IMS users) How is new staff trained on existing reporting and coordination procedures related to 

IMS? .................................................................................................................................................. 43 
Following Q.1.8, please specify "Other". ...................................................................................................... 44 
Q.2.1 (AFCOS) What systems/practices do you have in place to ensure uninhibited information flow 

between judicial and reporting authorities? ....................................................................................... 46 

Q.2.2 (AFCOS) Which communication methods are used for coordination of your Anti-Fraud efforts? 

IMS .................................................................................................................................................... 51 

Q.2.2 (AFCOS) Which communication methods are used for coordination of your Anti-Fraud efforts? 

Secure data exchange platforms (Online) .......................................................................................... 52 

Q.2.2 (AFCOS) Which communication methods are used for coordination of your Anti-Fraud efforts? 

Shared case management systems ..................................................................................................... 52 

Q.2.2 (AFCOS) Which communication methods are used for coordination of your Anti-Fraud efforts? 

Encrypted email ................................................................................................................................. 53 

Q.2.2 (AFCOS) Which communication methods are used for coordination of your Anti-Fraud efforts? 

Regular meetings ............................................................................................................................... 53 

Q.2.2 (AFCOS) Which communication methods are used for coordination of your Anti-Fraud efforts? 

Other (please specify) ........................................................................................................................ 53 
Following Q.2.2, please specify "Other". ...................................................................................................... 54 
Q.2.3  (All  entities  involved  with  fraudulent  irregularities)  If  your  Member  State  uses  secured  online 
platforms  or  shared  case  management  systems,  roughly,  what  percentage  of  fraudulent 

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irregularity  cases  are  processed  and  followed  up  primarily  through  these  digital  channels  (as 
opposed to paper or conventional correspondence)? ......................................................................... 54 

Q.2.4 (IMS users) Which IMS fields prove the most difficult to receive accurate, complete, and timely 

information for? ................................................................................................................................. 55 

Q.2.5 (All entities involved with fraudulent irregularities) How do you try to balance the confidentiality 

of investigations with the necessity to report? ................................................................................... 58 
Q.2.6 (AFCOS) How does your system enable timely follow-up to cases in IMS? ...................................... 63 
Q.2.7 (AFCOS) In which areas of reporting have you encountered problems when creating or updating 

cases? Cooperation with national administrative bodies.................................................................... 66 

Q.2.7 (AFCOS) In which areas of reporting have you encountered problems when creating or updating 

cases? Cooperation with national investigative bodies ...................................................................... 67 

Q.2.7 (AFCOS) In which areas of reporting have you encountered problems when creating or updating 

cases? Cooperation with international administrative bodies ............................................................ 67 

Q.2.7 (AFCOS) In which areas of reporting have you encountered problems when creating or updating 

cases? Cooperation with international investigative bodies ............................................................... 68 

Q.2.7 (AFCOS) In which areas of reporting have you encountered problems when creating or updating 

cases? Other (please specify) ............................................................................................................. 68 
Following Q2.7, please specify "Other". ....................................................................................................... 68 
Q.2.8 (AFCOS) Please feel free to share any additional thoughts or experiences you have regarding the 
topics discussed in this section or support you require from the Commission/OLAF regarding 
them. .................................................................................................................................................. 69 

Q.4.1 Are there any AI tools that you use as part of your national anti-fraud strategy or AFS to protect 

the financial interests of the Union? .................................................................................................. 72 
Q.4.2 Please specify which AI tools you use as part of your NAFS? ............................................................ 72 
Q.4.3 Please specify which AI tools you use as part of other AFS? Which AFS are they a part of? ............ 73 
Q.4.4 (AI users) What are the main uses of Artificial Intelligence within your systems? ............................. 74 
Please specify "Other" uses. .......................................................................................................................... 74 
Q.4.5. Have you conducted a cyber/AI threat assessment in 2025? .............................................................. 75 
Q.4.6 What were the main findings of the threat assessment?....................................................................... 76 
DISCLAIMER ON ARACHNE .................................................................................................................... 78 
Q.4.7 What is your Arachne integration status? ............................................................................................ 79 
Q.4.8 If you are only partially feeding data into Arachne, what are the reasons? ......................................... 79 
Please specify "Other" reasons. ..................................................................................................................... 79 
Q.4.9 For which funds is Arachne currently implemented? .......................................................................... 80 
Please specify other national or EU-funded programmes. ............................................................................. 81 
Q.4.10 How would you describe the level of implementation across these funds. ........................................ 82 
Q.4.11 Are there any AI tools you use that would benefit from accessing the data available in Arachne 
or  that  could  improve  Arachne’s  performance,  adoption  rate  by  national  authorities  or 
effectiveness? ..................................................................................................................................... 83 
Q.4.12 When using Arachne, what are the main challenges that you face? .................................................. 84 
Please specify "Other" challenges. ................................................................................................................ 85 
Q.4.13 Has Arachne been incorporated into your NAFS or other AFS? ....................................................... 86 
Q.4.14 Are your data analysis tools interacting with Arachne? ..................................................................... 86 
Q.4.15 Please list the data analysis tools which are/are planned to interact with Arachne. ........................... 87 
Q.4.16 How would you rate the interoperability of the systems on average? ................................................ 88 
Q.4.17 Please explain the interaction of the two (or more) systems in your administration. ......................... 88 
Q.4.18 Are you satisfied with the type of support available on Arachne? ..................................................... 89 
Q.4.19 What type of support (training/content/guidebooks) on Arachne would be the most useful to you?

 ........................................................................................................................................................... 89 
Please specify "Other" type of support. ......................................................................................................... 90 

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Q.4.20  How  do  you  plan  to  (further)  incorporate  digitalisation  into  your  (future)  national  anti-fraud 

strategies? .......................................................................................................................................... 90 

Q.4.21 Please  select three barriers to the digitalisation of your anti-fraud efforts, that you believe are 

most crucial to overcome. .................................................................................................................. 93 

Q.4.22 Please feel free to specify any other additional challenges or experiences regarding this section, 

which you would like to share. .......................................................................................................... 93 
Q.5.1 Please list the national services and bodies consulted to reply to this questionnaire. .......................... 94 

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

LIST OF ABBREVIATIONS 

AFA 
AFIS 
AI 
AMIF 

Anti-Fraud Architecture 
Anti-Fraud Information System 
Artificial Intelligence 
Asylum, Migration and Integration Fund 
Authority for Anti-Money Laundering and Countering the Financing of 
Terrorism 
Anti-Fraud Coordination Services 
Commission Anti-Fraud Strategy 
Common Agricultural Policy 

Committee on Budgetary Control 
CAP Strategic Plan 
European Court of Auditors 
Early Detection and Exclusion System 
European Public Prosecutor’s Office 
European Regional and Development Fund 
European Social Fund 
European Union 
Fund for European Aid to the Most Deprived 
Fraud Prevention and Detection Network 
Institutions, Bodies, Offices and Agencies 
Irregularity Management System 
Instrument for Pre-Accession 
Information Technology 
Joint Customs Operation 
Just Transition Fund 
National Anti-Fraud Strategies 
European Anti-Fraud Office 
Protection of financial interests 

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

Recovery and Resilience Facility 
National Recovery and Resilience Plan 
Treaty on the Functioning of the European Union  
Traditional own resources 
Union Anti-Fraud Programme 
Value Added Tax 

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

1.  OVERVIEW OF MEMBER STATES’ REPLIES TO THE QUESTIONNAIRE 

1.1.  Introduction 

In its PIF Report 2024 the Commission made recommendations to Member States, covering: a) closing 
the  reporting  gap  in  relation  to  suspected  fraud  and  irregularities,  b)  establishing  more  effective 
communication channels, c) adoption of a national anti-fraud strategy, and d) digitalisation as a pillar 
of the national anti-fraud strategy. A specific questionnaire has been addressed to the Member States to 
collect  information  about  how  they  have  implemented  these  recommendations.  Their  replies  are 
analysed in this document, which is divided in two parts: the first part provides an overview and analysis 
of their replies, while the second part details, for each question of the survey, the specific replies given. 

The replies to the third recommendation on the adoption of a national anti-fraud strategy are covered in 
the staff-working document on national anti-fraud strategies. 

1.1.1.  Overarching Themes and Guiding Principle 

Similar to the previous year, three central themes emerged from the Member States' responses. First, as 
was  the  case  last  year,  there  is  a  strong  call  for  training  and  guidance  in  the  replies,  as  well  as  an 
appreciation for it. Second, Member States openly share their approaches when tackling issues such as 
the  closing  of  the  reporting  gap.  From  these  contributions,  best  practices  could  be  formed.  Where 
applicable, the analysis compiles best practices that Member States identified in addressing common 
issues to provide an overview of potential solutions. Third, there were findings in this year’s replies that 
complement  or  contrast  findings  from  last  year’s  replies.  Where  applicable  a  comparison  between 
findings from last year and this year is drawn. 

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

1.2.  Recommendation 1 

RECOMMENDATION 1  – CLOSING THE REPORTING GAP  IN RELATION TO SUSPECTED 
FRAUD AND IRREGULARITIES 

Member  States  are  reminded  of  the  need  to  report  all  irregularities  and  suspected  fraud  to  the 
Commission in a timely and complete manner in accordance with the obligations set down in sectoral 
regulations. This will provide for a more complete dataset at EU level facilitating better trend analysis 
and more timely prevention and investigation interventions 

1.2.1.  Reporting maturity and strategic focus 

Following  the  2023  PIF  Report,  11 (1)  Member  States  reported  having  a  well-established  reporting 
system with no identified gaps. Following the 2024 PIF Report, this number rose to 18 (2) Member 
States, representing an increase of more than 60 % compared with the previous year. This may point to 
improvements  in  national  reporting  arrangements,  greater  awareness  of  reporting  obligations,  or 
increased confidence in national systems. At the same time, the findings should be interpreted with 
appropriate caution, as it is based on Member States’ own assessments. 

Prevention continues to be the dominant focus of national anti-fraud efforts, followed by detection. A 
total of 24 (3) Member States identified prevention as the part of the anti-fraud cycle they target most, 
while  a  remaining  3  selected  detection (4).  The  explanations  provided  were  highly  consistent. 
Prevention is generally seen as more cost-effective, less administratively burdensome, and better suited 
to protecting EU funds before financial losses occur. Many authorities described prevention as being 
present  in  fraud  risk  assessments,  staff  training,  declarations  on  conflicts  of  interest,  guidance  for 
beneficiaries, the use of red flags, early controls, and the use of Arachne. 

(1)  Austria, Czechia, Estonia, Finland, France, Germany, Luxembourg, Malta, Poland, Romania, Slovakia 

(2)  Austria, Bulgaria, Czechia, Germany, Estonia, Finland, Croatia, Italy, Lithuania, Luxembourg, Latvia, Malta, 

Netherlands, Poland, Portugal, Sweden, Slovenia, Slovakia 

(3)  Austria, Belgium, Croatia, Cyprus, Czech Republic, Estonia, Finland, France, Germany, Greece, Hungary, 
Ireland, Italy, Latvia, Lithuania, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, 
Sweden 

(4)  Several Member States indicated in their explanations that detection was equally prioritised, or only slightly 

less prioritised, than prevention. 

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

FIGURE 1 – WHICH PART OF THE ANTI-FRAUD CYCLE DO YOUR ANTI-FRAUD EFFORTS TARGET 
MOST/LEAST? 

Targeted Least vs Targeted Most 

Prevention 

Detection 

Investigation 

Recovery 

25 

20 

15 

10 

5 

0 

5 

10 

15 

20 

25 

Targeted Least 

Number of Member States 

Targeted Most 

By contrast, responses were more dispersed when Member States were asked which part of the anti-
fraud cycle is targeted least. Recovery, investigation and detection were all mentioned. However, the 
qualitative replies reveal a clear pattern: investigation is often the least targeted area because it usually 
falls outside the remit of managing and reporting authorities and lies primarily with prosecutors, police, 
the European Public Prosecutor’s Office (EPPO), or other judicial bodies. This was explicitly noted by 
several  Member  States,  including  Luxembourg,  Slovenia,  Czechia,  Greece,  Germany  and  Romania. 
Recovery  was  also  frequently  identified  as  receiving  comparatively  less  attention  in  cases  where 
preventive systems are already well developed and reimbursement mechanisms are firmly established. 

As regards staff knowledge and training on Irregularity Management System (IMS), a clear majority of 
Member  States  rely  on  OLAF  or  Commission  materials  (22  Member  States (5)),  regular  training 
sessions  (20  Member  States (6)),  liaison  officers  or  trainers  in  contact  with  OLAF  (18  Member 
States (7)), and national guidance or manuals (17 Member States (8)). 

For  the  training  of  new  staff,  the  most  commonly  reported  methods  are:  clear  task  allocation  (19 
Member  States (9)),  national-level  coordination  (17  Member  States (10)),  written  documentation  (16 

(5)  Austria, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Germany, Greece, Hungary, Ireland, Italy, 
Latvia, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Finland 

(6)  Austria,  Belgium,  Bulgaria,  Croatia,  Czech  Republic,  Finland,  France,  Germany,  Hungary,  Ireland,  Italy, 

Latvia, Lithuania, Luxembourg, Netherlands, Poland, Romania, Slovenia, Spain, Sweden 

(7)  Austria, Belgium, Bulgaria, Cyprus, Czech Republic,  Finland, France, Germany, Hungary, Ireland, Malta, 

Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Croatia 

(8)  Belgium, Bulgaria, Croatia, Czech Republic, Denmark, France, Germany, Greece, Hungary, Ireland, Italy, 

Latvia, Poland, Romania, Slovakia, Slovenia, Spain 

(9)  Austria,  Bulgaria,  Croatia,  Czech  Republic,  France,  Germany,  Hungary,  Ireland,  Latvia,  Lithuania, 

Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovenia, Spain, Sweden 

(10)  Austria, Bulgaria, Cyprus, Czech Republic, Estonia, Germany, Hungary, Ireland, Italy, Luxembourg, Poland, 

Portugal, Romania, Slovenia, Spain, Sweden, Croatia 

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

Member States (11)), and national IMS guidance (16 Member States (12)). By contrast, regional-level 
coordination,  grace  periods,  and  coordination  with  other  Member  States  are  used  only  to  a  limited 
extent, with no more than 7 Member States reporting the use of any of these methods (13). 

Overall,  the  replies  point  to  a  broad  commitment  among  Member  States  to  anti-fraud  reporting, 
characterised  by  a  prevention-led  approach,  extensive  use  of  training,  growing  reliance  on  risk 
assessment, and increasing coordination through AFCOS and IMS support structures. They also suggest 
that  closing  the  reporting  gap  depends  not  only  on  legal  obligations,  but  equally  on  operational 
consistency, staff capacity, coordination, and systematic quality control of reporting data. 

FIGURE 2 – HOW DO YOU ENSURE ADEQUATE KNOWLEDGE OF EXISTING STAFF? 

OLAF/Commission 
issued materials 

Regular training 
sessions 

Liaison officers/ 
contact with OLAF 
Trainers 

National 
Guidance/Guidebook
s 

Other 

0 

5 

10 

15 

20 

Frequency of Response 

(11)  Bulgaria, Croatia, Czech Republic, Denmark, Finland, Germany, Ireland, Latvia, Luxembourg, Netherlands, 

Portugal, Romania, Slovakia, Slovenia, Spain, Sweden 

(12)  Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Germany, Greece, Hungary, Ireland, Italy, Latvia, 

Luxembourg, Poland, Slovakia, Slovenia, Spain 

(13)  Grace Period: Belgium, Germany, Croatia, Ireland, Luxembourg, Slovenia, Slovakia 

Coordination at Regional level: Austria, Germany, Spain, Ireland, Lithuania, Poland 

Transfer of the case responsibility ownership: Belgium, Denmark, Croatia, Ireland, Luxembourg 

Coordination with other Member States: Austria, Czechia, Croatia, Ireland 

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

1.2.2.  Best Practices 

The  replies  show  broad  Member  States’  commitment  to  anti-fraud  reporting,  with  prevention-led 
systems, strong use of training, growing use of risk assessment and increasing coordination through 
AFCOS/IMS  support  structures.  The  most  transferable  best  practices  mentioned  by  Member  States 
include: 

• 

• 

• 

regular fraud risk self-assessment linked to action, 

strong staff training and onboarding for IMS/reporting, 

clear task allocation and referral pathways, 

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

•  national coordination mechanisms and working groups, 

• 

effectiveness measurement combining audits, risks, cases and recoveries. 

The main common learning is that closing the reporting gap requires not just  a legal obligation, but 
operational consistency, staff capability, coordination and systematic quality control of reporting data. 

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

1.3.  Recommendation 2 

RECOMMENDATION  2  –  ESTABLISHING  MORE  EFFECTIVE  COMMUNICATION 
CHANNELS 

Better coordination between national authorities, OLAF and the EPPO is also necessary to ensure that 
cases investigated by EU bodies are duly reported at the earliest possible moment in compliance with 
the relevant EU sectoral legislation. National authorities must correctly identify and address existing 
loopholes in the information flow in relation to suspected fraud, the moment they are first reported, and 
even more so, when following-up on them both in judicial and administrative proceedings at national 
level. The Commission is committed to further developing and providing the necessary guidelines, IT 
tools and support. The Commission will also facilitate to the maximum extent possible the necessary 
coordination between the bodies involved. 

1.3.1.  Information flow 

The replies show that most Member States have put in place formal or semi-formal arrangements to 
support the flow of information between reporting and judicial authorities. These arrangements include 
central  contact  points  or  single  points  of  contact,  reporting  guidelines  and  manuals,  cooperation 
protocols or memoranda of understanding, regular inter-agency meetings, direct email exchanges, and 
dedicated AFCOS coordination structures. 

Regular  meetings  are  by  far  the  most  widely  used  coordination  method,  reported  by  25  Member 
States (14). IMS is also widely used as a coordination tool, with 22 Member States (15) referring to its 
use in this context. Encrypted email is used by 15 Member States (16). It is also noteworthy that, among 
the 16 Member States (17) using either secure online platforms or shared case-management systems, 
14 (18) rely on these tools for most of their communication

(14)  Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, 
Hungary,  Ireland,  Italy,  Latvia,  Lithuania,  Luxembourg,  Malta,  Netherlands,  Poland,  Portugal,  Romania, 
Slovakia, Slovenia, Spain 

(15)  Austria,  Belgium,  Bulgaria,  Croatia,  Cyprus,  Czech  Republic,  Denmark,  Estonia,  Finland,  Germany, 
Hungary, Italy, Latvia, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden 

(16)  Bulgaria,  Cyprus,  Czech  Republic,  Denmark,  Estonia,  Finland,  France,  Germany,  Greece,  Lithuania, 

Luxembourg, Netherlands, Poland, Portugal, Spain 

(17)  Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Italy, Latvia, Netherlands, 

Poland, Portugal, Romania, Slovakia, Spain 

(18)  Czech Republic, Estonia, Finland, Germany, Greece, Hungary, Italy, Latvia, Netherlands, Poland, Portugal, 

Romania, Slovakia, Spain 

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

FIGURE 3 – WHICH COMMUNICATION METHODS ARE USED FOR COORDINATION OF 
YOUR ANTI-FRAUD EFFORTS? 

Shared case management 

systems 

Secure data exchange 

platforms (Online) 

Regular meetings 

Other 

IMS 

Encrypted email 

Implementation 
stage 

Not Used 

Planned to Use 

Used 

T
A

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
E

S
E

I

F

R
F

R
H

U
H

E

I

T

I

T
L

U
L

V
L

T
M

L
N

L
P

T
P

O
R

E
S

I

S

K
S

Member States 

1.3.2.  Cooperation between administrative and investigative/judicial bodies 

The main operational weakness identified in the replies concerns access to timely information from 
investigative  and  judicial  authorities,  in  particular  as  regards  updates  on  ongoing  criminal 
proceedings  and  final  judicial  outcomes.  Member  States  repeatedly  referred  to  difficulties  in 
obtaining  the  information  needed  to  complete  or  update  IMS  entries,  especially  in  relation  to 
sanctions  fields,  case  updates,  the  classification  of  fraud  or  suspected  fraud,  modus  operandi, 
recovery and amount fields, and judicial status and outcomes. 

These difficulties are particularly pronounced where reporting authorities depend on prosecutors, 
police, the EPPO, or courts for updates, and where criminal proceedings are lengthy or subject to 
confidentiality constraints. Several Member States also referred to structural limitations linked to 
the  EPPO  Regulation,  under  which  AFCOS  does  not  always  receive  operational  information 
directly. This confirms a pattern already identified in the PIF report 2024. 

At the same time, cooperation with national administrative bodies appears to function relatively 
well. A total of 24 Member States (19) reported no issues in this area. Cooperation with investigative 
bodies was assessed less uniformly: 18 Member States (20) reported no issues, 7 reported minor 

(19)  Austria,  Bulgaria,  Croatia,  Czech  Republic,  Denmark,  Estonia,  Finland,  France,  Germany,  Greece, 
Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, 
Slovakia, Slovenia, Sweden 

(20)  Austria,  Belgium,  Bulgaria,  Estonia,  Finland,  France,  Germany,  Ireland,  Italy,  Latvia,  Lithuania, 

Luxembourg, Malta, Netherlands, Portugal, Romania, Slovenia, Sweden 

      -       

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

issues (21), and 2 reported serious issues (22). This suggests that the principal reporting bottleneck 
lies  not  in  administrative  coordination  as  such,  but  in  access  to  follow-up  information  from 
investigative and judicial authorities once a case enters the criminal justice chain. 

Taken together, the replies indicate that the effectiveness of communication channels depends less 
on the creation of new reporting routes than on the existence of structured governance, routine 
coordination,  and  reliable  mechanisms  for  follow-up,  particularly  between  administrative  and 
judicial actors. The key challenge remains ensuring that information continues to flow after a case 
becomes judicial, so that administrative reporting remains timely, complete and accurate. 

FIGURE  4  –  AREAS  OF  REPORTING  WHERE  MEMBER  STATES 
ENCOUNTERED PROBLEMS 

Each dot represents one Member State reporting an issue 

Cooperation with national 
investigative bodies 

Cooperation with international 
investigative bodies 

Cooperation with national 
administrative bodies 

Cooperation with international 
administrative bodies 

Issue Type 

Minor Issues 

Serious Issues 

2 

4 

6 

8 

10 

Number of Member States 

(21)  Czech Republic, Denmark, Greece, Croatia, Hungary, Poland, Slovakia 

(22)  Cyprus, Spain 

      -       

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

1.3.3.  Best Practices 

The Member States’ replies show that effective communication channels depend above all on 
structured governance, routine coordination and reliable follow-up mechanisms, especially 
between  administrative  and  judicial  actors.  The  most  transferable  best  practices  mentioned  by 
Member States include: 

• 

• 

• 

formal cooperation agreements and written referral/update procedures, 

regular multi-authority meetings and AFCOS-led coordination, 

clear case ownership and periodic follow-up reviews, 

•  national case-management systems feeding into IMS, 

• 

strict but workable confidentiality arrangements on a need-to-know basis and staged 
reporting, 

•  named contact points and liaison structures, and 

• 

continuous quality control of IMS data. 

The  main  common  learning  is  that  improving  communication  is  less  about  creating  one  new 
channel and more about ensuring that information continues to flow after a case becomes judicial, 
so that administrative reporting remains timely, complete and accurate. 

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1.4.  Recommendation 4: 

RECOMMENDATION  4  –  DIGITALISATION  AS  A  PILLAR  OF  THE  NATIONAL  ANTI-
FRAUD STRATEGY 

The Commission reiterates its call to national authorities to embed the digitalisation of the fight 
against fraud in their national anti-fraud strategies, with the aim of: a) assessing the level of threat 
posed  to  the  EU  budget  by  the  rise  in  cybercrime  and  the  use  of  AI  and  other  innovative 
technologies, in  particular by  organised  crime; b)  identifying their  knowledge and  skill  gaps in 
relation to the deployment, development and use of innovative technologies to fight fraud more 
effectively; c) identifying the actions needed to address such threats and vulnerabilities 

1.4.1.  Digitalisation and AI 

Digitalisation remains an important component of anti-fraud efforts across the Member States, but 
implementation remains uneven and is often approached cautiously. As regards AI in particular, a 
large majority of Member States (21 (23)) reported that they do not use AI tools as part of their anti-
fraud strategies. By contrast, 3 Member States (24) stated that they use AI as part of a national anti-
fraud  strategy,  while  6 (25)  reported  using  AI  in  the  context  of  other  anti-fraud  strategies  or 
frameworks. 

Where AI is used, it is generally applied to anomaly detection and predictive analytics, reflecting 
the  broader  emphasis  on  prevention  and  detection  within  the  anti-fraud  cycle.  The  examples 
provided by Member States include AI or machine-learning tools for anomaly detection and risk 
analysis  in  agriculture  and  customs, tools  supporting  audits  and the  prediction of  irregularities, 
text-processing  and  transcription  support,  analytical  applications  in  risk  scoring  or  network 
analysis, and automated invoice checks. 

Overall, the replies suggest that the use of AI remains at an exploratory stage and is more often 
sector-specific than fully integrated into national anti-fraud systems. 

The replies also indicate limited progress in the assessment of cyber- and AI-related threats. Only 
3 Member States reported having carried out a comprehensive assessment in 2025, while 8 (26) 
carried out a partial assessment. A further 15 Member States (27) reported having conducted no 
such assessment and having no plans to do so, while 1 Member State (28) indicated that such an 
assessment was planned. This suggests that the recommendation to assess cyber and AI-related 
threats is only beginning to be reflected in national practice. 

As  regards  future  digitalisation  efforts,  Member  States  indicated  that  they  intend  to  focus  in 
particular  on  stronger  interoperability  between  systems,  expanded  use  of  Arachne  and  future 
Arachne+, improved  risk-analysis  tools,  better  data  integration,  possible  use  of AI  for anomaly 

(23)  Austria,  Belgium,  Bulgaria,  Cyprus,  Denmark,  Estonia,  Finland,  Germany,  Greece,  Ireland,  Latvia, 
Lithuania, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia, Slovenia, Sweden, Croatia 

(24)  Czech Republic, Italy, Portugal 

(25)  Belgium, France, Hungary, Italy, Slovenia, Spain 

(26)  Austria, Belgium, Estonia, Ireland, Latvia, Malta, Slovakia, Spain 

(27)  Bulgaria,  Cyprus,  Denmark,  Finland,  France,  Germany,  Greece,  Croatia,  Hungary,  Lithuania, 

Netherlands, Poland, Portugal, Romania, Slovenia 

(28)  Italy 

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detection  or  complaint  analysis,  and  digital  platforms  to  support  transparency  and  case 
management. 

1.4.2.  Digitalisation barriers 

The previous year’s analysis identified interoperability problems, legal barriers, and data protection 
or security concerns as the main obstacles to further digitalisation. This year’s replies confirm the 
same barriers and allow them to be quantified more clearly. The three most significant barriers 
identified  by  Member  States  are  interoperability  challenges  (19  Member  States (29)),  budget 
constraints (16 Member States (30)), and data-protection concerns or other legal issues (12 Member 
States (31)). 

These  findings  suggest  that  the  main  obstacles  to  further  digitalisation  are  structural  and 
organisational, rather than conceptual. The qualitative replies reinforce this conclusion. Member 
States  referred  to  systems  that  do  not  communicate  effectively  with  one  another,  uneven  data 
quality  and  access,  fragmented  institutional  arrangements  that  slow  digital  progress,  legal  and 
privacy frameworks that complicate automated data use, and existing applications that are rigid 
and costly to adapt. 

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

(29)  Cyprus,  Estonia,  Finland,  France,  Germany,  Greece,  Croatia,  Hungary,  Ireland,  Italy,  Latvia, 

Luxembourg, Malta, Netherlands, Portugal, Slovakia, Slovenia, Spain, Sweden 

(30)  Belgium, Bulgaria, Czech Republic, Denmark, Estonia, Finland, Hungary, Ireland, Latvia, Lithuania, 

Luxembourg, Poland, Romania, Slovakia, Spain, Croatia 

(31)  Data protection concerns: Austria, Belgium, France, Germany, Greece, Hungary, Ireland, Luxembourg, 

Malta, Poland, Portugal, Sweden 

Legal issues: Austria, Bulgaria, Cyprus, Czech Republic, Estonia, France, Germany, Lithuania, Poland, 
Romania, Slovakia, Sweden 

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FIGURE 5 – BARRIERS TO THE DIGITALISATION OF ANTI-FRAUD EFFORTS 

Interoperability challenges 

Budget constraints 

Legal issues 

Data protection concerns 

Skill gaps 

Outdated legacy systems 

0 

5 

10 

15 

Frequency of Response 

1.4.3.  State of Play of Arachne 

Last  year’s  analysis  found  that  22  Member  States (32)  used  Arachne  as  part  of  their  anti-fraud 
strategies. This year, that number has risen slightly to 23 (33). At the same time, the survey provides 
a more nuanced picture of how the tool is implemented in practice. Arachne is not simply either 
“used” or “not used”. In many cases, it is only partially integrated: data may cover only certain 
funds, be uploaded manually, or be provided only to a limited extent. The findings therefore point 
not only to broad uptake of the tool, but also to considerable variation in the depth and quality of 
its use. 

The main reasons cited by Member States for partial implementation are technical limitations (8 
Member  States (34)),  strategic  decisions  to  provide  only  the  minimum  dataset  (7  Member 
States (35)), and legal constraints (6 Member States (36)). This suggests that partial integration is 
often a pragmatic compromise rather than a rejection of the tool itself. 

(32)  Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Estonia, France, Greece, Hungary, Ireland, Italy, 

Latvia, Lithuania, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, Slovenia, Spain 

(33)  Austria,  Belgium,  Bulgaria,  Cyprus,  Czech  Republic,  Denmark,  Estonia,  Finland,  France,  Greece, 
Croatia,  Hungary,  Ireland,  Italy,  Latvia,  Luxembourg,  Malta,  Poland,  Portugal,  Romania,  Slovakia, 
Slovenia, Spain 

(34)  Cyprus, Czech Republic, France, Greece, Ireland, Luxembourg, Slovenia, Spain 

(35)  Czech Republic, Finland, France, Latvia, Luxembourg, Slovenia, Spain 

(36)  Austria, Cyprus, France, Poland, Slovenia, Spain 

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FIGURE 6 – ARACHNE INTEGRATION STATUS 

Partially feeding data into the 
system (minimum mandatory 
dataset) 

Feeding all possible data into 
the system 

Planning to adopt 

No plan to adopt 

0 

5 

10 

15 

Frequency of Response 

Problems  already  identified  by  individual  Member  States  in  the  last  year’s  questionnaire  were 
confirmed by the replies to this year’s targeted questions. The most frequently cited obstacles to 
wider use or deeper implementation of Arachne are false alerts (19 Member States (37)), difficulty 
in interpreting indicators (18 Member States (38)), and compatibility issues (14 Member States (39)). 
The  individual  replies  also  reveal  additional  recurring  concerns,  including  the  lack  of  unique 
identifiers for individuals, the absence of automatic access to certain national data, unclear audit 
trails or source data, unclear algorithms, and the time-consuming nature of manual uploads. 

According to Member States, these factors also help explain why interaction between Arachne and 
other national data-analysis tools remains limited. Where such interaction exists, interoperability 
is  generally  assessed  as  medium  to  high,  but the number  of Member  States  concerned  remains 
small. In practice, many systems still rely on XML exports, manual uploads, or extraction from 
national systems into Arachne, rather than on automated or API-based interoperability. 

Views on the support available for Arachne are mixed. Nine Member States reported being satisfied 
with the support provided, and also nine reported dissatisfaction. The most frequently requested 
forms of support are staff training (13 Member States (40)), Arachne Academy tutorials and videos 
(12  Member  States (41)),  and  guidance  on  risk  indicators  and  their  interpretation  (12  Member 

(37)  Austria, Belgium, Cyprus, Czech Republic, Denmark, Estonia, France, Greece, Croatia, Hungary, Italy, 

Latvia, Luxembourg, Malta, Poland, Portugal, Slovakia, Slovenia, Spain 

(38)  Belgium,  Bulgaria,  Czech  Republic,  Denmark,  Estonia,  Finland,  France,  Greece,  Croatia,  Hungary, 

Ireland, Italy, Latvia, Portugal, Romania, Slovakia, Slovenia, Spain 

(39)  Austria,  Belgium,  Czech  Republic,  Finland,  France,  Hungary,  Ireland,  Italy,  Luxembourg,  Poland, 

Portugal, Slovakia, Slovenia, Spain 

(40)  Belgium, Bulgaria, Czech Republic, France, Greece, Croatia, Hungary, Luxembourg, Poland, Romania, 

Slovakia, Slovenia, Spain 

(41)  Belgium,  Bulgaria,  Czech  Republic,  Greece,  Croatia,  Hungary,  Luxembourg,  Poland,  Romania, 

Slovakia, Slovenia, Spain 

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States (42)). This again underlines a broader pattern in the replies: the challenge lies not only in 
access  to  the  tool,  but  also  in  ensuring  that  its  outputs  are  sufficiently  clear,  usable,  and 
operationally relevant. 

1.4.4.  Best Practices 

The replies show that Member States increasingly recognise digitalisation as an essential pillar of 
anti-fraud  policy,  but  implementation  remains  uneven,  fragmented  and  constrained  by 
interoperability,  legal  uncertainty  and  limited  budget.  The  most  transferable  best  practices 
mentioned by Member States are: 

• 

• 

embedding digitalisation in anti-fraud strategies, 

improving interoperability between national systems and EU tools, 

•  deploying AI in targeted, secure and risk-based ways, 

• 

• 

• 

combining digital outputs with human analysis and operational follow-up, 

clarifying legal and data protection frameworks, and 

investing in training and technical support. 

The main common learning is that digitalisation becomes a more effective part of anti-fraud efforts 
when it is backed by usable data, interoperable systems, legal certainty, skilled staff and integration 
into everyday control workflows. 

(42)  Belgium,  Bulgaria,  Czech  Republic,  France,  Greece,  Croatia,  Hungary,  Luxembourg,  Romania, 

Slovakia, Slovenia, Spain 

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2.  RESPONSES FROM THE MEMBER STATES 

RECOMMENDATION  1  –  CLOSING  THE  REPORTING  GAP  IN  RELATION  TO 
SUSPECTED FRAUD AND IRREGULARITIES  

Member  States  are  reminded  of  the  need  to  report  all  irregularities  and  suspect  fraud  to  the 
Commission  in  a  timely  and  complete  manner  in  accordance  with  the  obligations  set  down  in 
sectoral regulations. This will provide for a more complete dataset at EU level facilitating better 
trend analysis and more timely prevention and investigation interventions 

Q.1.1  How  would  you  evaluate  your  level  of  maturity  of  your  current 
reporting process for reporting irregularities and, in particular, fraud? 

Response 

Frequency  Percentage 

Member States 

We  use  a  well-established  reporting  system 
capturing  all  relevant  data  on  suspected  fraud 
cases and irregularities 

18  66.7% 

AT, BG, CZ, DE, 
EE,  FI,  HR,  IT, 
LT, LU, LV, MT, 
NL, PL, PT, SE, 
SI, SK 

We are currently improving our reporting system 
to  better  capture  and  report  suspected  fraud 
cases and irregularities 

We have a strong reporting system but with some 
gaps in capturing all relevant data 

3  11.1% 

BE, EL, FR 

3  11.1% 

CY, DK, HU 

Other (please specify) 

3  11.1% 

ES, IE, RO 

Following Q1.1, please specify "Other". 

Member 
State 

Response 

ES 

IE 

Most of the managing authorities consulted indicated that they are currently improving the 
reporting system, except for two authorities that use a strong or well-established reporting 
system. 

Option 2 is our choice - to add narrative to explain this:      
Each  reporting  authority  in  Ireland  attended  IMS  training  by  OLAF  in  October  2025, 
clarifying obligations in terms of IMS. This has been revisited in interdepartmental meetings 
which they have all attended,    
Much expenditure coming from the funds under shared management funds are incurred 
via the Exchequer vote process before they come from the support of the EU fund. Any 

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Member 
State 

Response 

instances  of  fraud/  suspected  fraud  would  fall  within  the  anti-fraud  policies  of  the 
government department and would therefore be excluded from expenditure declarations. 

RO 

Following  consultation  with  the  bodies  listed  in  the  reply  to  question  5.1,  it  became 
apparent that the  reporting process is at various stages of development. Consequently, 
multiple answers apply - specifically, the first three options. 

Q.1.2  Which part  of  the  Anti-Fraud  Cycle  do your  Anti-Fraud  Efforts 
target most? 

Response 

Frequency  Percentage 

Member States 

Prevention 

24  88.9% 

AT, BE, CY, CZ, 
DE, EE, EL, ES, 
FI, FR, HR, HU, 
IE,  IT,  LT,  LV, 
MT, NL, PL, PT, 
RO, SE, SI, SK 

Detection 

3  11.1% 

BG, DK, LU 

Q.1.3 Please explain your reasons for this focus. 

Member 
State 

Response 

AT 

BE 

BMLUK  [Federal  Ministry  of  Agriculture  and  Forestry,  Climate  and  Environmental 
Protection, Regions and Water Management]:      
To increase awareness in the area of funding; compliance training at BMLUK. The other 
parts  of  the  cycle  are  also  covered,  e.g.  annual  review  by  the  certification  body  of 
recoveries by the paying agency.  
BMASGPK  [Federal  Ministry  of  Labour,  Social  Affairs,  Health,  Care  and  Consumer 
Protection]:   
This focus is established in the anti-fraud strategy for the ESF+/JTF. 

Which part of the Anti-Fraud Cycle do your Anti-Fraud Efforts target most?  

BE AFCOS:  
Prevention is the foundation of a coherent anti-fraud approach. Thanks to our stakeholder 
management we have noticed that a lack of anti-fraud knowledge throughout the network. 
Given  this  reality  we  have  restarted  with  the  basics  to  improve  overall  levels  of 
comprehension of the whole Anti-fraud Cycle.    

PSW (Public Service of Wallonia) ERDF Wallonia:  
The  PSW  emphasises  the  pillars  of  prevention  and  detection  in  that  it  highlights  those 

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Member 
State 

Response 

things that  make it  possible to reduce the overall risk and limit subsequent costs, since 
detection  is  an  indispensable  ally  to  prevention.  The  PSW  emphasises  the  in-depth 
assessment  of  fraud  risks,  the  implementation  of  preventive  measures,  the  raising  of 
awareness and training of staff, the reduction of fraud opportunities before they arise, early 
detection mechanisms, enhanced checks, and tools to alert and report.   

FPS (Federal Public Service) Finance (Customs disputes):  
the 
Disputes Department is to recover duties; it therefore makes sense that their efforts are 
more focused on recovery than on the other strands of the anti-fraud cycle.  

The  mandate  of 

EUROPA WSE (ESF VL):  
As MA we focus on detection because every organisation that receives European funds 
has to report. We perform checks on those reports, which lead to corrections. While there 
is significant focus on prevention (e.g. informing the organisations), the main body of work 
concerning anti-fraud happens at the reporting stage. That is also when we can sanction 
the organisations.   
Investigation and recovery concerning anti-fraud is handled by different services within our 
department/government.   

ERDF and RRF Brussels Capital Region:  
The use of Arachne focuses primarily on preventing and detecting fraud and irregularities. 
In the context of project selection, ex ante analyses are also carried out in relation to double 
sources  of  financing.  The  checking  and  analysis  of  the  permit  from  the  authorities  also 
concerns detection of possible irregularities and potential conflicts of interest in order to 
prevent fraud.   

ESF Agency (ESF Wallonia-Brussels):   
The ESF Agency improves these procedures for detecting irregularities and fraud risks; it 
is  part  of  the  French  Community’s  working  group  on  combating  fraud.  As  part  of  the 
renewal exercise for 2026-2027, an analysis was carried out for both the double subsidy 
risk and the financial risk for all the files. 

Prevention  in  the  fight  against  irregularities  and  fraud  is  of  paramount  importance  for 
protecting the EU's financial interests. Applying preventive measures reduces the risk of 
fraud and other irregularities. These types of measures are a more effective and efficient 
way  of  protecting  financial  interests  than  taking  action  after  a  fraud  has  already  been 
committed 

Prevention  is  the  primary  focus  of  the  anti-fraud  cycle.  Focusing  on  prevention  helps 
ensure compliance with EU regulations, minimise the risk of financial corrections imposed 
by  the  European  Commission,  and  safeguard  EU  and  national  resources.  Strong 
prevention through risk assessments, clear procedures, guidance, and training, limits fraud 
risks in key areas such as public procurement and project implementation, while promoting 
integrity, accountability, and effective use of EU funds in Cyprus. 

Prevention can lead to much greater efficiency in the use of public funds. By raising staff 
awareness and effectively vetting grant applicants during the evaluation phase (i.e., before 
the legal act is issued), many problematic applicants can be excluded at this stage, thereby 
preventing  future  cases  that  would  otherwise  require  additional  audits,  sanctions,  and 
enforcement actions.     

Prevention  plays  an  important  role  in  the  National  Recovery  Plan  (action  plan  for  the 
systematic prevention of conflicts of interest, red-flag warning system).    
We  consider  fraud  prevention  to  be  a  vital  part  of  the  cycle.  If  appropriate  anti-fraud 
measures are taken, the incidence of fraud will be reduced, leading to a reduced need for 
subsequent detection, investigation and enforcement.    

BG 

CY 

CZ 

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Member 
State 

Response 

Prevention is an essential element of the work of the controls and irregularities unit, which 
focuses  primarily  on  systematic  risk  prevention  by  means  of  regular  staff  training, 
specialised workshops and continuously strengthening internal control mechanisms. Other 
preventive measures include rigorous project checks, during which we focus on identifying 
potential  irregularities  and  ensuring  compliance  with  the  rules  on  protecting  the  EU’s 
financial  interests.  The  objectives  are  to  minimise  the  risk  of  fraud,  increase  the 
transparency of processes and ensure that public money is handled responsibly.    
Another  objective  is  to  prevent  irregularities  and  fraud  at  the  stage  of  preparation  and 
administration  of  projects.  Much  of  the  work  consists  of  setting  up  control  procedures, 
internal guidelines and methodological support.  
Please note: There was an equal number of votes by the contributors for "Prevention" and 
"Detection". 

The Rhineland-Palatinate ERDF managing authority:  
Under  administrative  proceedings,  the  focus  is  on  prevention  and  detection,  given  that 
investigation is primarily the task of the law enforcement authorities.  

The North Rhine-Westphalia (NRW) ERDF managing authority:    
Limiting the scope for fraud through simplified cost options and evidence requirements.   

The Saxony-Anhalt ESF managing authority:  
Prevention, detection and recovery are core tasks of the managing/certifying authorities. 
In Germany, the law enforcement authorities are responsible for investigation.   

The Lower Saxony ERDF managing authority:      
When  fraud  and  corruption  are  detected  at  an  early  stage,  the  subsequent  funding 
processes are not affected. Fraud risks are identified at an early stage through analysis 
and monitoring and countered through targeted measures.  

The EU Paying Agency for Lower Saxony, Bremen and Hamburg:  
We  focus  on  detection  and  reporting  cases  to  the  public  prosecutor’s  office  and  OLAF. 
Fraud prevention training is also provided.  

DE 

The ESF Plus Federal Programme, led by the Federal Ministry of Labour and Social Affairs 
(BMAS):   
The  focus  is  on  prevention  and  detection  for  preventive  and  efficiency-related  reasons. 
Consequently, the number of cases of fraud or suspected fraud can be reduced from the 
outset in a pre-emptive manner, meaning there is naturally less need for investigation and 
recovery.  

The Schleswig-Holstein ERDF managing authority:  
In principle, prevention reduces risks, which means that the amount of work in terms of 
detection, investigation and recovery is lower in the first place.   

The Bremen ERDF managing authority:  
Identifying possible intentions of fraud is a prerequisite for an effective anti-fraud strategy. 
In  particular,  this  concerns  the  staff  of  the  bodies  involved  in  the  implementation  of  the 
ERDF  (intermediate  bodies,  managing  authority,  accounting  body).  Appropriate 
awareness-raising is carried out by means of training courses or mandatory instructions, 
which the managing authority makes available to the competent bodies.   

The AMIF managing authority:     
The focus is on preventing, detecting and investigating irregularities and fraud. This serves 
to protect the AMIF managing authority, the entire grant system and EU funds.   

The Federal Office for Agriculture and Food (BLE):  
Infringements  identified  in  relation  to  the  measures  we  implement  are  generally  not 

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Member 
State 

Response 

deliberate  infringements committed with the intention of perpetrating fraud but negligent 
acts  (failing  to  meet  deadlines/submit  notifications,  negligently  providing  incorrect 
information, etc.). In this context it should also be noted that, under German law, intent to 
commit fraud must be proven. Thus, the focus is more on identifying fraud risks, raising 
awareness  and  analysing  management  and  control  systems,  all  of  which  are  grouped 
together as a set of measures.   
The Hessen ERDF managing authority :   
Prevention and detection help stop the EU funds in question from being charged to the 
Commission at all. Management and control systems have a particular impact on these 
two stages.  

The Thuringia ERDF managing authority:  
The ERDF guidance document provides direction for the intermediate bodies on following 
up on suspicious transactions. It includes an annex on indicators of fraudulent or corrupt 
behaviour.  Particularly  in  investigations,  the  managing  authority  helps  to  ensure  the 
availability of all the information needed to determine whether there is an irregularity in the 
case.   

The Baden-Württemberg ERDF managing authority:  
A focus on fraud prevention can often obviate the need for further anti-fraud measures.   

The Brandenburg ERDF managing authority:  
Preventive measures to combat fraud in relation to the EU budget are generally less costly 
than  subsequent  detection  and  sanctioning  of  fraud  cases.  Targeted  prevention  makes 
more efficient use of public funds and avoids the costs of investigations, court proceedings 
and recoveries. Moreover, prevention reinforces trust in the EU, averts financial losses for 
the EU budget and helps stop the misuse of EU funds. Preventive checks, internal audits 
and  risk  management  systems  enable  weaknesses  in  the  system  to  be  identified  at  an 
early stage and can prevent an additional burden for EU institutions. 

Danish Business Authority:  
We  find  it  difficult  to  prevent  fraud  and  don’t  encounter  a  lot  of  fraud  cases,  therefore 
resources are best spent on detection and investigation.  

Danish Agricultural and Fisheries Agency:  
A strong focus in our Anti-fraud system lies in case workers’ identification of “Red Flags”. 

Our anti‑fraud efforts address all stages of the Anti‑Fraud Cycle, as each phase is essential 
for a resilient system.     
However, our implementing authorities primary focus is on prevention  — particularly on 
risk  assessment  and  thorough  application  screening.  Strengthening  these  early‑stage 
controls helps us significantly reduce downstream issues, since detection, investigation, 
and recovery are far more resource‑intensive and place a heavier burden on the system. 
By identifying risks upfront, we aim to minimise the likelihood that cases escalate into later, 
more problematic stages and thereby reduce overall system‑level issues.   
While investigative bodies place the greatest emphasis on successfully pursuing criminal 
cases, implementing authorities prioritise early‑stage prevention to stop issues before they 
develop into cases requiring investigation. 

‘Special Service for Institutional Support and Information Systems (EYTHYPS):     
Addressing  fraud  risks  in  a  timely  manner  through  more  robust  procedures,  audits  and 
transparency mechanisms limits the likelihood of irregularities, reduces the administrative 
and  financial  costs  of  subsequent  corrections,  and  more  effectively  ensures  the  correct 
and lawful use of EU resources.  

Recovery and Resilience Facility Special Coordination Service (EYSTA):  
The  responsibilities  of  the  Service  and  the  other  bodies  involved  in  the  planning  and 

DK 

EE 

EL 

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Member 
State 

Response 

implementation of Recovery and Resilience Fund (RRF) projects and actions are limited 
to the taking of measures to prevent and detect irregularities (including those indicating 
fraud)  in  RRF  projects  and  to  correct/recover  the  relevant  resources  from  the  final 
recipients of the funds. Investigative powers have been conferred to and are exercised by 
other national bodies. 

For management authorities, efforts are mainly focused on prevention, identifying the risks 
associated  with  different  procedures  and  adopting  various  preventive  measures  (risk 
assessment,  development  of  an  anti-fraud  culture,  codes  of  ethics,  staff  training  and 
awareness-raising,  segregation  of  duties,  procedures  to  prevent  conflicts  of  interest)  in 
order to prevent or significantly reduce the occurrence of fraud.  
They also devote considerable effort to the detection phase, with robust detection systems 
that complement a framework focused on preventing fraud from occurring in the first place, 
with detection acting as a second line of defence and prevention as the backbone of the 
model.  

ES 

FI 

FR 

Detection  would  complement  this  approach  through  continuous  controls,  administrative 
and technical checks in the field, early warning mechanisms and reporting channels, which 
make it possible to identify potential irregularities at an early stage and take action as soon 
as possible.  
A managing authority indicates that it has an anti-fraud strategy in place, which includes 
measures  to  combat  fraud  and  any  illegal  activity  affecting  the  financial  interests  of  the 
Union.  These  measures 
for 
investigating  fraud,  and  recovery  and  deterrence  measures  with  proportionate  and 
dissuasive penalties. 

fraud  prevention  and  detection,  conditions 

include 

The  fight  against  fraud  focuses  on  an  effective  and  efficient  management  and  control 
system for preventing fraud. Up-to-date guidance and regular training support the system 
and ensure it functions. These measures ensure that staff are familiar with the necessary 
procedures  and  receive  practical  guidance  on  how  to  apply  the  legislation,  thereby 
strengthening fraud prevention and fostering a culture of responsibility. 

To protect the EU budget, the first step is to increase efforts to prevent fraud, focusing on 
three areas:  

- greater consideration of the risk of fraud by all bodies responsible for the management of 
European funds and in the context of audits;  

-  continuation  of 
professionalisation of staff responsible for combating fraud;  

the  proactive  policy  pursued  by  partners 

in  relation 

to 

the 

- increasing awareness of breaches of probity in risk sectors. 

Contribution  from  the  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  of 
Fisheries:   
We  consider  prevention  important  as  it  contributes  significantly  to  reducing  the  risk  of 
irregularities  and  consequently  reducing  the  number  of  investigations  and  finally  of 
recoveries.  

HR 

Contribution from the Ministry of Labour, Pension System, Family and Social Policy:  
We  target  prevention  and  detection  most  since  this  seems  to  be  the  best  way  to  avoid 
irregularities and frauds in general.  

Contribution from the Ministry of Regional Development and EU funds:  
Anti-fraud  efforts  within  the  management  and  control  system  for  the  use  of  ESI  Funds 
target  all  elements  of  the  Anti-Fraud  Cycle  –  prevention,  detection,  investigation  and 
recovery – as they are equally important for the effective protection of the EU’s financial 

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interests. Managing Authority and other bodies in the management and control system for 
the  use  of  ESI  Funds  are  responsible  for  preventing  and  detecting  irregularities  and 
suspected  fraud  in  a  timely  manner,  ensuring  appropriate  follow-up  and  reporting,  and 
monitoring the implementation of corrective measures, including financial corrections and 
the recovery of unduly spent funds.  

Contribution from the Ministry of Finance, Customs Administration:  
Prevention  -  by  using  the  risk  analysis  system  during  the  import  customs  clearance 
procedure, we use defined risk rules.  
Detection  -  refers  to  the  post  clearance  control.  When  selecting  a  company  for  post 
clearance control, we apply statistical mathematical analysis.  
Recovery (refund) - we take all legal measures for the payment of established duties from 
the  debtor  and  from  the  persons  who  guarantee  such  amounts  (e.g.  customs  agent 
provides a guarantee for the importer).    

Contribution from the Ministry of Agriculture, Forestry and Fisheries (Paying  Agency for 
Agriculture, Fisheries and Rural Development):    
After  establishing  of  irregularities,  Paying  Agency  takes  the  appropriate  measures  to 
remedy  the  deficiencies  of  irregularity  and  where  appropriate,  to  recover  the  amounts 
wrongly paid taking into consideration all case circumstances and influence of irregularity 
on project eligibility.  

Contribution from HR AFCOS unit:  
From our point of view, based on the risk assessment and training needs analysis, it can 
be concluded that the focus is put mainly on prevention. However, this does not diminish 
the efforts of other bodies within the AFCOS System, whose focus is also on other parts 
of the Anti-Fraud Cycle.   

HU 

Our strategic choices were influenced by the ‘prevention is better than cure’ approach. 

IE 

IT 

Authorities in Ireland have expressed that the nature of the Exchequer funding provided 
upfront  to  fund  cofinancing  actions  leads  to  prevention  being  targeted  the  most. 
Departments  have  committed  to  promoting  cultures  that  deter  fraudulent  activity,  to 
facilitate the prevention of fraud and corruption.  

This area being targeted the most does not negate measures in place to target all stages 
of the Anti-Fraud cycle. 

Measures to combat illegal conduct focus on overseeing the entire anti-fraud cycle, in order 
to ensure the timely detection of irregularities and fraud, thereby safeguarding the financial 
integrity of the EU budget. The strengthening of preventive controls, risk analysis and the 
coordination of investigations makes it possible to identify problems at an early stage and 
to take the necessary corrective action quickly. European and national funds are managed 
according  to  a  number  of  largely  binding  procedures  governing  the  various  stages: 
beneficiaries are chosen according to established criteria; the implementation of projects 
by beneficiaries and the certification of expenditure are subject to first-level sample checks 
using an extraction methodology based on prior risk assessment. The checks are, in turn, 
subject  to  quality  review  procedures  and  are  supported  by  a  management  information 
system in which each individual project undergoes continuous automatic checks prior to 
the first-level checks. The MA prepares and provides instructions to beneficiaries for the 
proper  implementation  and  management  of  the  measures;  any  reports  of  suspected 
irregularities  or  fraud  in  the  context  of  the  implementation  of  projects  funded  by  the 
Programme  are  carefully  investigated  by  the  MA,  which  then  takes  all  appropriate 
measures; participation in training courses on the ethics and legality of all office resources 
is encouraged; declarations of the absence of conflicts of interest in regard to the office’s 
internal resources and of all those involved in the implementation of the funded projects 
are  obtained;  the  Arachne  risk  classification  system  is  used  and  periodic  risk  self-

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assessments  are  carried  out  in  accordance  with  the  methodology  indicated  by  the 
European Commission, through the Risk Self-Assessment Group (GAR), measuring the 
probability  and  impact  of  specific  and  commonly  recognised  risks  that  are  particularly 
relevant  to the Programme’s key processes, with corrective action taken where the risk 
exceeds the accepted limit. 

LT 

We have noticed that we need to pay more attention to prevention, so we are talking to the 
Agencies, who provide financial support from European funds to do this more responsibly. 
Therefore, we are paying more attention to working with the Agencies. 

LU 

LV 

MT 

NL 

PL 

Because of the format of the answers, we chose one option, i.e. detection. However, we 
focus on both prevention and detection.  

We cofinance projects in the area of RDI and renewable energy production, as well energy 
efficiency.  The  beneficiaries  have  to  pay  every  expense  in  advance  and  get  then 
reimbursed by the ERDF, based on the checks we perform. We do not intervene in their 
existing accounting procedures as this would be far beyond scope and our responsibility. 
Before agreeing to cofinance a project, we perform checks on the reputation, financial and 
administrative  capacities  of  the  potential  beneficiaries  and  verify  that  their  financial 
statements have been published as well as their fiscal and social obligations are fulfilled. 
That  would  reduce  the  risk  beforehand  and  could  maybe  be  considered  as  prevention 
measure.  
The  focus  on  prevention  is  essential  to  the  ESF+  because  it  protects  the  integrity, 
resources,  and  long‑term  stability  of  EU  funds.  Strong  preventive  measures  reduce 
opportunities  for  misconduct  and  ensure  that  public  funds  are  used  for  their  intended 
purposes. By identifying risks early, we can detect irregularities before they escalate into 
significant financial or reputational damage. 

Prevention  stops  the  fraud  before  it  happens,  which  is  always  more  cost‑effective  than 
repairing damage afterward. 

This question is not applicable since prevention, detection, investigation and recovery are 
all dealt with by the respective national  authorities accordingly. Kindly refer to the reply 
provided in Question 1.6. 

Prevention is better than cure and therefore the focus is on prevention. However, different 
parties  approach  the  fight  against  fraud  from  slightly  different  angles.  Dutch  Customs 
(revenue)  mainly  manage  investigations  and  recovery.  The  managing  authorities 
(expenditure) mainly deal with prevention. 

In cohesion policy, prevention  in the anti-fraud cycle is a key element ensuring that EU 
funds are used correctly, efficiently and in line with the law. In the implementation of EU 
funds,  prevention  is  systemic  and  is  an  integral  part  of  the  management  and  control 
system.  In  accordance  with  Article  74  of  Regulation  (EU)  2021/1060,  institutions  are 
obliged to have effective and proportionate anti-fraud measures and procedures in place. 
This means, among other things, that they are obliged to conduct fraud risk assessment 
and carry out verifications to respond to emerging threats. This allows risks to be identified 
earlier, e.g. before grant agreements are concluded or procurement takes place. Another 
function of prevention in the anti-fraud cycle in cohesion policy is to protect the financial 
interests of the EU. In accordance with the principle of sound financial management, EU 
money should be spent in a way that ensures legality, efficiency and economy. Effective 
prevention  reduces  the  number  of  financial  corrections  and  the  risk  of  payments  being 
suspended and thus has a direct impact on the liquidity of programmes and beneficiaries. 
In addition, effective  preventive  mechanisms significantly reduce the likelihood  of fraud, 
while the cost of prevention is markedly lower than that of reacting to fraud that has already 
happened. Prevention also makes the other stages of the anti-fraud cycle more efficient 
since, through transparent processes, it makes it easier for irregularities to be detected. 
Although detection, investigation and recovery are crucial, it is prevention that determines 

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the effectiveness of the entire system of protection and the fight against irregularities and 
fraud.     

In agricultural policy, the detection stage is of key importance and is facilitated by a series 
of  effective  tools  that  have  been  introduced  and  are  used  to  identify  potential  fraud, 
particularly during the verification of aid applications. These tools include guidelines and 
entries in handbooks of procedures outlining the process of detecting atypical elements 
that can be an indicator of fraud. 

PT 

A number of fraud-prevention measures have been adopted under the National Anti-Fraud 
Strategy (NAFS), such as adopting anti-fraud policies, establishing mechanisms to ensure 
coordination between the various bodies involved  in  handling  and monitoring European 
funds, and setting up integrated IT systems. 

Following  consultation  with  the  bodies  listed  in  the  reply  to  question  5.1,  it  became 
apparent that the answers to this question vary and are specific to the activities of each 
body,  meaning  the  answer  covers  three  parts  of  the  anti-fraud  cycle:  prevention, 
investigation and recovery. Their detailed responses are presented below.  

National Agency for Public Procurement:  
Prevention  and  detection.  In  its  capacity  as  reform  and  investment  coordinator,  the 
National  Agency  for  Public  Procurement  conducts  verification  and  control  activities  for 
projects  funded  under  the  national  recovery  and  resilience  plan  in  accordance  with 
Government  Emergency  Order  No  70/2022,  which  established 
the  applicable 
arrangements in relation to the cycles referred to above.  

Ministry of Energy:  
Investigation. The limited number of staff involved in investigating and resolving suspected 
irregularities makes the prevention and detection stages difficult to implement. To remedy 
these deficiencies, platforms and algorithms could be created to prevent the emergence 
of suspicions of irregularities.     

Ministry of Investments and European Projects:   
Prevention,  detection  and  recovery.  The  Managing  Authority  regularly  implements 
measures to prevent and detect fraud and to recover unduly paid amounts.  

RO 

North-East Regional Development Agency:   
Prevention  is  a  priority  in  our  strategy  in  order  to  mitigate  fraud  risks  and  foster  closer 
cooperation and stronger coordination among all stakeholders. Detection: the occurrence 
of  multiple  situations  that  arose  in  2025  has  highlighted  the  need  for  staff  to  prioritise 
detection and improve detection methods.  

West Regional Development Agency:   
Prevention  and  detection.  This  is  the  first  financial  cycle  where  the  West  Regional 
Development Agency serves as the Managing Authority for the 2021-2027 West Regional 
Programme.  

Managing Authority for the South-West Oltenia Regional Programme:   
Prevention, detection and recovery. The Regional Development Agency’s anti-fraud efforts 
are  focused  on  preventing  and  detecting  irregularities  and  suspected  fraud  at  an  early 
stage, and on recovering affected amounts through financial corrections and administrative 
measures, in line with applicable legislation. These activities are carried out in line with the 
managing  authority’s  role  as  the  administrative  authority  responsible  for  managing  EU 
funds.  

North-West Regional Development Agency:   

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As no cases of suspected fraud were identified in 2024, efforts under the anti-fraud strategy 
are focused on prevention and detection. 

SE 

Prevention is cost-effective. 

Reply for the AKTRP (Agency for Agricultural Markets and Rural Development):  
we would indicate three areas: Prevention, Detection and Recovery (since the link does 
not allow all three to be selected at the same time). These three areas are systematically 
regulated at the Agency. Each of the areas is supported by written procedures. We have 
a system of red flags, checklists and funding recovery procedures in place at the institution.  

Reply  for  the  MKRR  (Ministry  of  Cohesion  and  Regional  Development),  which  has 
indicated two areas:  
Prevention and Detection (since the link does not allow both to be selected at the same 
time). As the managing authority (MA) for ESI funds, the Ministry strives, within the limits 
of its powers, to prevent and detect irregularities and fraud under the management and 
control system (MCS system) in place. 

Anti-fraud  measures  are  designed  to  cover  all  stages  of  the  anti-fraud  cycle.  Anti-fraud 
efforts  are  mainly  focused  on  prevention,  as  we  have  a  legislative  and  methodological 
framework in place, including the implementation of effective control systems, and staff are 
trained to recognise fraudulent behaviour and risk situations. This approach is considered 
the most effective, as strengthening preventive measures directly contributes to reducing 
the incidence of irregularities and fraud. 

SI 

SK 

Q.1.4  Which part  of  the  Anti-Fraud  Cycle  do your  Anti-Fraud  Efforts 
target most? 

Response 

Recovery 

Investigation 

Prevention 

Detection 

Frequency  Percentage 

Member States 

12  44.4% 

11  40.7% 

BE,  BG,  DK, 
ES, FR, HU, IE, 
LV, NL, PL, SE, 
SK 

CY, CZ, DE, EE, 
EL,  FI,  HR,  LU, 
PT, RO, SI 

3  11.1% 

AT, IT, MT 

1  3.7% 

LT 

Q.1.5 Please explain your reasons for this choice 

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AT 

ALL parts are covered. NOTE: It is therefore not possible to specify, in reply to Q.1.4, which 
part is ‘targeted most’. 

Which part of the Anti-Fraud Cycle do your Anti-Fraud Efforts target least?  

BE AFCOS:  
There is an increased focus on the recovery of funds throughout the Belgian network. With 
budgets  under  pressure  amid  all  partners  recovery  is  an  essential  part  of  an  effective 
system. Nonetheless compared to the efforts made in all parts of the anti-fraud cycle we 
noticed  the  efforts  concerning  recovery  are  not  yet  at  the  level  of  the  other  anti-fraud 
stages.  
PSW (Public Service of Wallonia) ERDF Wallonia:  
The PSW has invested heavily in prevention and detection and already has a solid system 
for recovery available to it. Efforts in 2026 will focus on the investigation cycle. The PSW 
aims  to  harmonise  procedures  for  treating  internal  and  external  irregularities  and  to 
contribute to improving relations with judicial authorities. The correction and prosecution 
phases take place ex post but are nonetheless important to the PSW. The application of 
visible sanctions serves as a deterrent.    

FPS Finances (Customs disputes):   
Other departments’ mandates are to carry out prevention, detection and investigations.    

ERDF and RRF Brussels Capital Region:  
The greatest focus is on prevention and detection, meaning that the focus on investigation 
and  recovery  is  lesser  in  comparison.  Nevertheless,  measures  have  been  taken  to 
investigate identified irregularities and potential cases of fraud, and where necessary, to 
address these (for example checking and analysing expenditure, carrying out supervisory 
missions, etc.). 

The overly broad regulatory scope of securities/collateral makes it difficult for the managing 
authorities  to  exercise  their  recovery  rights  when  imposing  financial  corrections.  The 
investigation  of  fraud  falls  within  the  competence  of  the  national  law  enforcement 
authorities. There is a significant delay in the investigation of crimes by law enforcement 
agencies 

The investigation phase is comparatively less directly targeted by the NAFS because the 
Strategy’s  principal  function  is  to  strengthen  the  horizontal  anti-fraud  system,  while 
investigative  and  prosecutorial  powers  remain  with  specialised  competent  authorities 
under their respective legal mandates. The NAFS can add most value before and around 
the  investigation  phase:  by  improving  prevention,  risk  assessment,  detection,  reporting 
channels, referral mechanisms, information exchange and coordination. Once a suspected 
the  applicable 
fraud  case  reaches  the  investigation  stage,  action  depends  on 
administrative, criminal or EU-level procedures and on the mandates of bodies such as 
national  investigative  authorities,  the  Law  Office  of  the  Republic,  EPPO  and  OLAF. 
Accordingly,  the  Strategy  does  not  seek  to  duplicate  or  interfere  with  these  functions. 
Instead,  it  supports  them  indirectly  by  strengthening  investigative  capacity,  clarifying 
referral and communication protocols, improving the quality of information transmitted to 
competent authorities and promoting more consistent inter-agency cooperation. 

Investigations in the legal sense are conducted by the law enforcement authorities rather 
than bodies of the implementation system. In a more general sense, the latter bodies must, 
as  part  of  their  control  activities,  find  out  as  much  information  as  possible  about  the 
irregularity detected and reach their own conclusion so that they can pass the matter to 
other competent authorities.    

Investigations are usually  carried out at the first stage. They  are then  passed  on to  the 
authorities responsible, such as the law enforcement authorities.    

BE 

BG 

CY 

CZ 

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Investigations of suspected fraud cases are carried out by the law enforcement authorities 
and other competent bodies, and not by the Ministry’s control department. 

The Rhineland-Palatinate ERDF managing authority:   
Under  administrative  proceedings,  the  focus  is  on  prevention  and  detection,  given  that 
investigation is primarily the task of the law enforcement authorities.   

The NRW ERDF managing authority:   
Confirmed  fraud  leads  to  automatic  recovery.  There  are  well-established  national 
procedures in this regard.   

The Saxony-Anhalt ESF managing authority:   
In Germany, the law enforcement authorities are responsible for investigation.   

The Lower Saxony ERDF managing authority:   
By  applying  the  reimbursement  procedure  and  carrying  out  thorough  checks,  possible 
attempts at fraud can be detected even before the funds are paid out.   

The ESF Plus Federal Programme, led by the Federal Ministry of Labour and Social Affairs 
(BMAS):   
The  focus  is  on  prevention  and  detection  for  preventive  and  efficiency-related  reasons. 
Consequently, the number of cases of fraud or suspected fraud can be reduced from the 
outset in a pre-emptive manner, meaning there is naturally less need for investigation and 
recovery.   

The Schleswig-Holstein ERDF managing authority: There have been no recent cases of 
ERDF-related fraud in Schleswig-Holstein. Therefore, it has not been necessary to carry 
out any investigations.   

DE 

The Bremen ERDF managing authority:   
Investigating  possible  attempts  at  fraud  falls  within  the  remit  of  the  public  prosecutor’s 
office  or its  delegated  bodies. The task of the core  administration is to identify  possible 
intentions of fraud, to step up the administrative checks in case of suspicion, and, if the 
suspicion is confirmed, to report it to the managing authority and the public prosecutor’s 
office.   

The AMIF managing authority:   
The recovery of EU funds usually takes the form of reductions in grants. These are often 
the result of irregularities being detected and investigated and not the stated aim. The aim 
is to ensure that the grant system operates in a reliable and transparent manner and is as 
free as possible from irregularities, and that irregularities are investigated and corrected. If 
and  insofar as the recovery of funds is warranted, the process is initiated  as quickly as 
possible to prevent losses for the EU budget.   

The Hessen ERDF managing authority:   
statutory division of responsibilities at national level: investigations are carried out (after a 
criminal  complaint  has  been  filed)  by  the  competent  public  prosecutor's  office/the 
European Public Prosecutor's Office.   

The Thuringia ERDF managing authority:   
Prevention is key. Effective prevention allows the intermediate body to better exercise its 
responsibilities. The implementing bodies are also in a position to detect irregularities at 
an early stage and take the necessary measures. The aim is to take an early decision on 
reportable cases so that OLAF can be involved as soon as possible.   

The Baden-Württemberg ERDF managing authority:   

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As  soon  as  there  is  a  suspicion  of  fraud,  the  case  is  referred  to  the  competent  law 
enforcement  authorities,  which  are  responsible  for  investigating  the  suspected  fraud 
further.  Investigations  are  also  carried  out  as  part  of  administrative-law  proceedings  in 
order to protect the financial interests of the EU budget.   

The Brandenburg ERDF managing authority:   
As effective prevention is the first priority, in many cases there is no need for recovery, as 
no payment has been made at all. While the recovery of EU funds following a fraud case 
is an important mechanism, preventive measures should be prioritised in the fight against 
fraud. This not only protects the EU budget from losses in the long term, but also ensures 
that EU funds are used more efficiently and responsibly, in the best interests of citizens 
and the EU as a whole. 

In  general,  we  experience  a  low  degree  of  fraud  or  suspected  fraud.  Combined  with  a 
strong system for detection, recovery is rarely a relevant course of action. When relevant, 
we don’t experience any difficulties in recovering funds. 

While our anti‑fraud efforts span the entire Anti‑Fraud Cycle, the phase in which we are 
least directly involved is the criminal investigation stage.   
This is not because criminal proceedings are any less important—on the contrary, they are 
essential—but  the  EPPO  Regulation  limits  the  active  role  AFCOS  units  can  take  in 
EPPO‑led investigations, and AFCOS does not typically represent cases in that context. 
Cooperation with prosecutors remains smooth, constructive, and highly valued.  
In  administrative  proceedings,  however,  we  are  fully  engaged  in  detection,  clarification, 
and recovery activities. Since the operational focus of the grants implementation system 
is on prevention—particularly through risk assessment and ex‑ante controls—many issues 
are  addressed  before  they  escalate.  When  irregularities  do  occur,  we  handle  them 
comprehensively through administrative detection and recovery mechanisms. 

Special Service for Institutional Support and Information Systems (EYTHYPS):   
Management  and  control  system  (MCS)  procedures  cover 
the  detection  and 
documentation of suspected fraud. Further investigation and the treatment of cases under 
criminal or administrative law do not fall within the jurisdiction of the MCS authorities but 
are carried out  by the competent national  bodies  and judicial authorities of  the  Hellenic 
Republic, in accordance with the current institutional framework.  

Recovery and Resilience Facility Special Coordination Service (EYSTA):   
EYSTA has no powers to investigate irregularities indicating fraud. Investigative powers 
have  been  conferred  to  and  are  exercised  at  the  national  level  by  specific  bodies  and 
services. 

The  implementation  of  robust  controls  and  preventive  measures  and  effective  early 
detection mechanisms significantly reduces the likelihood of fraud materialising or having 
a  significant  financial  impact.  It  is  therefore  the  effectiveness  of  the  prevention  and 
detection phases that would justify devoting less effort to the later phases of the anti-fraud 
cycle.  
For  the  managing  authorities,  investigation  and  recovery  are  reactive  and  subsidiary  in 
nature and only come into play in specific cases, whereas prevention and detection are 
ongoing, cross-cutting activities integrated into all management procedures.  
In the case of investigation, this is normally carried out by specialised entities, while the 
role  of  the  managing  authority  and  intermediate  bodies  focuses  on  communication, 
coordination and the application of any corrective measures that may arise (withdrawal of 
expenditure, refunds).  
In the case of recovery, the lesser efforts devoted to it can be justified because, at national 
level,  in  accordance  with  current  legislation,  reimbursement  procedures  are  fully 
established, systematised and operational, and their application constitutes a direct legal 

DK 

EE 

EL 

ES 

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obligation that does not require further development to ensure their effectiveness in the 
field of European funds. 

The  focus  of  anti-fraud  efforts  is  on  a  well-functioning  and  effective  administrative  and 
control system that prevents fraud. 

We experienced technical difficulties with the introduction of effective tools to achieve this 
objective. 

Note: Considering that the question should be "Which part of the Anti-Fraud Cycle do your 
Anti-Fraud Efforts target least?" these are the answers:  

Contribution from the Ministry of Agriculture, Forestry and Fisheries (Paying  Agency for 
Agriculture, Fisheries and Rural Development):  
In the case when the irregularity contains ascertaining elements related to suspicion(s) of 
fraud against EU financial interests, Paying Agency send the report/document as well as 
relevant documentation to the EPPO in order to analyse what measures should be taken 
in accordance with the legal provisions.  

Contribution from the Ministry of Labour, Pension System, Family and Social Policy:  
This is part of the anti-fraud cycle that is covered by other institutions specialised in frauds 
investigation, such as EPPO and the State Attorney's office.  

Contribution from the Ministry of Regional Development and EU funds:  
Our anti-fraud efforts do not target any part of the Anti-Fraud Cycle least. All four elements 
–  prevention,  detection,  investigation,  and  recovery  –  are  addressed  in  a  balanced  and 
integrated manner, as they are equally important for ensuring effective protection of the 
EU’s financial interests. Bodies within the management and control system for the use of 
ESI  Funds  are  responsible  for  implementing  measures  across  the  entire  cycle,  from 
preventing and detecting irregularities and suspected fraud to ensuring appropriate follow-
up, reporting and recovery of unduly spent funds.  

Contribution from the Ministry of Finance, Customs Administration:  
We do not conduct investigations, that is the responsibility of other bodies. We cooperate 
in certain stages of the procedure if necessary. 

The National Anti-Fraud and Anti-Corruption Strategy (NAFS) for European Union funds 
was adopted as a national institutional strategy in Hungary, in order to avoid redundancy 
with  the  policy-level  National  Anti-Corruption  Strategy  (NACS).  Institutions  set  up  to 
perform tasks related to EU funds have limited means to recover assets in the absence of 
cooperation from the beneficiary or other relevant stakeholders (the tax administration and 
judicial bodies can act in the case of asset recovery). 

The majority of cases that are identified through investigation processes do not transpire 
to be proven cases of fraud, which can be credited to the prevention and detection systems 
currently in place.  
In  addition,  as  expenditure  is  incurred  via  the  Exchequer  Vote  process  initially,  any 
instances  of  fraud/suspected  fraud  fall  within  the  anti-fraud  policies  of  the  government 
department and are excluded from expenditure claims. Therefore, recoveries do not occur 
regularly due to this. 

All stages are taken into consideration as part of anti-fraud efforts. 

We do a lot of analytical work to identify the cause of financial fraud. 

FI 

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HR 

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LU 

LV 

Which part of the Anti-Fraud Cycle do your Anti-Fraud Efforts target least?  
The investigation would be the responsibility of the national jurisdictions and/or EPPO, in 
case we would detect a fraud or suspicion of fraud. 

Fraud  investigation  becomes  the  second  most  important  activity  because  it  ensures 
accountability,  closes  control  gaps,  and  deter  future  fraud,  as  well  as  protects 
organisational integrity and public trust. 

MT 

Same as above. Kindly vide Malta's provided in Questions 1.3 and 1.6. 

NL 

PL 

PT 

Again, different parties approach the fight against fraud from slightly different angles. For 
example,  the  managing  authorities  (expenditure)  focus  least  on  recovery  and  Customs 
(revenue) focus least on prevention. 

Each  stage  of  the  anti-fraud  cycle  is  the  responsibility  of  the  competent  institutions  or 
services  in  the  area  concerned.  Within  their  remit  they  take  appropriate  measures  to 
combat  fraud  in  accordance  with  treaty  obligations,  EU  regulations  and  national  law. 
Where appropriate they cooperate and exchange information with each other. Recovery 
might constitute a relatively weak part of the cycle given how long recovery proceedings 
last, due, for example, to appeals and court proceedings. 

Our answer to the previous question (Q.1.4) concerns a part of the anti-fraud cycle to which 
relatively little attention is currently devoted.    

The  anti-fraud  coordination  service  (AFCOS)  and  the  bodies  involved  in  handling  and 
monitoring  European  funds  have  no  mandate  to  investigate  cases  with  signs  of  fraud. 
However, they do have reporting channels and encourage the Ministério Público (public 
prosecutor) to become involved where potential cases of fraud have been detected. It then 
falls to the bodies in question to conduct the investigations. Protocols have been drawn up 
for  coordination  between  the  bodies  responsible  for  handling  and  monitoring  European 
funds  and  judicial  bodies,  including  a  cooperation  protocol  between  the  inspectorate-
general  of  finances  (IGF)  and  the  Procuradoria-Geral  da  República  (office  of  the 
prosecutor-general),  which  was  adopted  on  7  April  2005  at  the  IGF’s  annual  general 
meeting. 

Following  consultation  with  the  bodies  listed  in  the  reply  to  question  5.1,  it  became 
apparent that the answers to this question vary and are specific to the activities of each 
body and cover all parts of the anti-fraud cycle. Their detailed responses are presented 
below.  

National Agency for Public Procurement:   
Investigating  fraud  falls  within  the  remit  of  criminal  investigation  authorities  and  other 
authorised bodies, rather than the National Public Procurement Agency.  

RO 

Ministry of Energy:   
The limited number of staff involved in investigating and resolving suspected irregularities 
makes  the  prevention  and  detection  stages  difficult  to  implement.  To  remedy  these 
deficiencies,  platforms  and  algorithms  could  be  created  to  prevent  the  emergence  of 
suspicions of irregularities.  

Ministry of Investments and European Projects:   
Fraud investigations do not fall within the Managing Authority’s remit.  

North-East Regional Development Agency:   
Investigations  are  conducted  by  institutions  authorised  by  law.  Any  suspicions  of  fraud 
identified within our organisation are referred for investigation to the Romanian Anti-Fraud 
Directorate, the European Public Prosecutor’s Office and/or the National Anti-Corruption 

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Department.  

West Regional Development Agency (recovery):   
Given the current stage of implementation of the 2021-2027 West Regional Programme, 
the number of suspected irregularities or cases of fraud is low.  

South-West Oltenia Regional Development Agency:   
Criminal investigations fall  within  the remit of other specialised national authorities. The 
Managing Authority’s role is limited to prevention, detection, reporting and administrative 
recovery, in compliance with the division of responsibilities under national and European 
legislation.  

North-West Regional Development Agency:   
There were no suspected cases of fraud in 2024. 

SE 

Recovery is the least resource-intensive area. 

Investigating and proving fraud is a matter for the judicial system.  

SI 

SK 

The MKRR explains:   
For this part, most competences lie with other authorities. To that end, as the MA for ESI 
funds, the  MKRR has stepped  up  its cooperation  over the past year with the  European 
Delegated  Prosecutor’s  office  in  Slovenia  and  the  criminal  police,  with  a  focus  on 
investigations. This measure is also described in the questionnaire on the implementation 
of Article 325 by the Member States (2025 PIF Report). 

Recovery  is  one  of  the  key  activities  of  the  MA/IB,  as  they  are  responsible  for  timely 
reporting  and  updating  irregularities  and  for  taking  all  steps  to  recover  ineligible 
expenditure in a timely manner. Despite the measures in place (legal and methodological 
framework, controls, audits carried out), there are still differences between the amounts 
recommended for recovery and the amounts actually recovered from the entity that caused 
the irregularity. At the same time, the recovery process can be legally and administratively 
complex. 

Q.1.6 How do you measure the effectiveness of your Anti-Fraud system? 

Member 
State 

Response 

BMLUK:   
All cases of suspected fraud reported by the paying agency are studied by the certification 
body. The evolution in cases is monitored. The Finanzprokuratur [Lawyer and legal advisor 
of the Republic of Austria] is called in in cases of doubt.  

BMASGPK: In view of the very small number of ESF fraud cases in Austria, the system 
can be considered effective and efficient. 

Belgian AFCOS:  
By the level by which the secretariat of the Belgian AFCOS has been contacted for advice 
and  input  on  the  matter.  Due  to  its  decentralised  structure  other  effort  to  measure 
effectiveness are taken by the respective partners.  

AT 

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PSW ERDF Wallonia:   

At the PSW, we have put in place a self-assessment tool for fraud risks, which functional 
administrations in charge of European funds are required to fill in and update once a year. 
A  form  for  the  self-assessment  of  cross-cutting  fraud  risks,  to  be  filled  in  by  each 
department,  is  also  in  the  process  of  being  drawn  up.  Recommendations  in  the  audits 
carried  out  by  the  CAIF  (Cellule  Audit  de  l'Inspection  des  Finances)  and  the  European 
Commission are also opportunities to challenge our system and to improve it on a regular 
basis. The PSW has also set up some working groups, ‘Mira Anti-Fraud’ and ‘OLAF’, which 
allow  for  brainstorming  the  various  current  measures  and  improving  them,  or  for 
implementing new ones.    

ERDF and RRF Brussels Capital Region:  
Through the internal collecting of  data and  information relating to detected irregularities 
and (potential) instances of fraud.   

EUROPA WSE (ESF VL):  
We do not currently measure the effectiveness of our Anti-Fraud system. 

BG 

CY 

The system is the National Strategy for the Prevention and Combating of Irregularities and 
Fraud affecting the Financial Interests of the European Union for the Period 2021-2027. A 
large part of the employees involved in the fight against fraud use the Arachne tool. There 
is institutional coordination between the various units involved in the fight against fraud. 
The effectiveness of the anti-fraud system within some of the MA is measured by the fraud 
risk self-assessment. If necessary, additional measures are planned and implemented 

Currently the effectiveness is not formally assessed. The annual assessment of the anti-
fraud efforts is one of the KPIs of the action plan for the NAFS which has been finalised. 

By the number of detected cases of suspected criminal activity and the success rate in 
criminal proceedings.    

By the number of fraud cases detected.    

CZ 

We observe the number and value of fraud cases detected, the number of checks and the 
regular evaluation of fraud risks.    

The effectiveness of the anti-fraud system is assessed not as a whole but based on the 
results  of  controls  and  investigations:  mainly  by  the  number  and  nature  of  irregularities 
identified and their subsequent handover to the bodies concerned for follow-up.    

By the ratio of total projects to identified cases. 

The Rhineland-Palatinate ERDF managing authority:   
On the  basis  of the  level of detail and  quality of the  following: reports submitted by the 
intermediate  bodies,  on-the-spot  verifications,  checks  carried  out  by  the  audit  authority, 
and system checks carried out by the managing authority. Any shortcomings in the fraud 
prevention system can be identified through this.   

DE 

The Saxony-Anhalt ESF managing authority:   
The number of suspicious cases detected by the management and control system and the 
audit authority.    

The ESF Plus Federal Programme, led by the Federal Ministry of Labour and Social Affairs 
(BMAS):   
A regular self-assessment is carried out of the managing authority’s strategic approach to 
preventing and combating fraud and corruption. This self-assessment incorporates all the 

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available  information  on  combating  fraud  and  exchanges  between  the  relevant 
stakeholders, for example on ongoing cases of fraud and suspected fraud involving the 
ESF and the main identified risk areas, so as to enable emerging risks and fraud trends to 
be investigated and addressed in a timely manner.    

The Bremen ERDF managing authority:   
The number of possible fraud attempts reported (no reports thus far); the results of audits 
of operations carried out by the audit authority; verification of the effectiveness of control 
mechanisms using the self-assessment tool.   

The AMIF managing authority:   
The framework is established on the basis of rules in our funding guidelines and funding 
manual,  as  well  as  the  internal  guidelines  on  handling  irregularities.  Alongside  the 
management  and  control  system,  (fraud)  risk  management  and  risk  analysis,  a  control 
framework has been established. Moreover, the quality assurance and reporting channels, 
the  audits  of  operations  carried  out  by  the  audit  authority  and  the  self-declarations 
requested  from  applicants  facilitate  monitoring  and  serve  to  prevent  and  combat  fraud. 
Detected cases of irregularities are  also collected, counted and analysed centrally. The 
reasons for the irregularities, the results of the investigations, and the `follow-up measures 
and their effectiveness are analysed. The control mechanisms are updated on an ad hoc 
or  regular  basis.  The  control  strategy  was  revised  in  2025.  As  a  result,  more  thorough 
checks are carried out on evidence of use of funds. The number of cases and adjustments 
make it possible to measure the effectiveness of the fraud prevention system quantitatively 
and qualitatively.   

The Hessen ERDF managing authority:   
Regular programme-specific fraud risk assessment in line with the presentation of a risk 
assessment tool by the Commission (see guidance document). Depending on any residual 
risks identified, supplementary anti-fraud measures are implemented in the management 
and control system.   

The Thuringia ERDF managing authority:   
Effectiveness  is  not  specifically  measured.  Reports  on  suspicious  cases  and  audits  of 
operations are used to draw conclusions about the fraud prevention system. In the case of 
frequent  reports  or  prominent  cases  involving  operations,  appropriate  adjustments  are 
made to the fraud prevention system.   

The Baden-Württemberg managing authority:   
On  the  basis  of  continuously  updated  fraud  statistics,  which  now  cover  three  funding 
periods and show a very low number of cases.   

The Brandenburg ERDF managing authority:   
Statistics and a list of suspected fraud cases from cross-checks with all operations in the 
funding  period.  Very  low  number  of  confirmed  cases  of  fraud,  given  the  number  of 
applications for which no payment is made once fraud is suspected and also the number 
of  cases  of  suspected  fraud  reported  to  the  competent  investigating  authorities  which 
actually result in a conviction entailing a fine and/or imprisonment. 

Danish Business Authority:   
We  don’t  have  a  formal  system  in  place  to  measure  the  effectiveness  of  our  anti-fraud 
efforts. It is  our experience that we rarely  get  a case  of fraud even though  projects are 
continuously monitored by several different parties. This is in part because of the general 
low  amount  of  fraud  in  our  country  but  also  suggests  that  our  preventive  and  control 
measures are working effectively.  

Danish Agricultural and Fisheries Agency:   
Varies.  Regarding  detection,  operationability  and  usability  of,  e.g.  "Red  flags"  for  case 

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workers is essential.   
Regarding recovery, the success-rate in recovering irregular or wrongful amounts is used 
as measure. 

We  measure  the  effectiveness  of  our  Anti‑Fraud  system  through  a  combination  of 
quantitative  indicators  and  qualitative  assessments  across  all  stages  of  the  Anti‑Fraud 
Cycle. Key elements include:  

Prevention indicators:   
- quality and depth of risk assessments   
- the proportion of applications flagged or adjusted based on preventive controls   
- reduction in the number of cases escalating into detection or investigation phases   
Detection and administrative investigation metrics:   
- number and type of irregularities identified in administrative checks   
- timeliness and accuracy of case clarification   
- patterns or recurring issues that signal system‑level vulnerabilities   

EE 

Recovery performance:   
- amounts recovered through administrative procedures   
- recovery rate relative to identified financial impact   
- time required to complete recovery processes   

System‑level impact:   
-  overall  decrease  in  downstream  cases  requiring  resource‑intensive  investigation  or 
recovery   
- feedback from internal and external audits   
- alignment with regulatory requirements and cooperation frameworks  

Our  overarching  goal  is  to  ensure  that  strong  preventive  controls  reduce  the  need  for 
later‑stage  interventions,  while  maintaining  the  capacity  to  detect,  clarify,  and  recover 
losses effectively when issues do arise. 

Special Service for Institutional Support and Information Systems (EYTHYPS):   
The effectiveness of the anti-fraud system is measured using a combination of quantitative 
and  qualitative  data,  such  as  the  number  of  detected  suspicions  of  fraud,  results  from 
audits and verifications, and the findings of the Financial Audit Committee (EDEL) and EU 
audit bodies.   

Recovery and Resilience Facility Special Coordination Service (EYSTA):    
In  accordance  with  the  Manual  of  MCS  Procedures  for  the  National  Recovery  and 
Resilience  Plan,  EYSTA  carries  out  a  yearly  assessment  of  fraud  risks  and  of  the 
effectiveness of the preventive measures that have been incorporated into the applicable 
MCS. The assessment is based on the results of the planned audits carried out both by 
EYSTA  itself  and  by  other  competent  national  and  European  bodies.  If  new  risks  are 
detected,  EYSTA  takes  initiatives  to  plan  new  measures  and  incorporate  them  into  the 
MCS to mitigate these risks, and then amend the Fraud Risk Assessment Methodology, 
so that the estimate of the overall risk remains at acceptable levels. 

The responses from the various authorities consulted include the following measures or 
mechanisms applied to assess their effectiveness:  

- The effectiveness of the anti-fraud system is measured through a set of qualitative and 
quantitative  indicators  focused  mainly  on  the  prevention  and  detection  phases,  which 
make  it  possible  to  assess  the  system's  ability  to  minimise  the  risk  of  fraud  and  detect 
possible  irregularities  at  an early stage. In particular, the degree of implementation and 
compliance with preventive controls, the results of periodic controls and verifications, and 
the absence or low incidence of significant irregularities are considered essential. Similarly, 

EL 

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it  is  considered  necessary  to  analyse  the  number,  type  and  recurrence  of  alerts  or 
indications  detected,  as  well  as  the  time  taken  to  identify  and  deal  with  them,  and  the 
evolution of the residual risk of fraud, assessed through periodic risk analyses and self-
assessments of the anti-fraud system.  

- The effectiveness  of the  anti-fraud system  is measured primarily through a risk-based 
continuous improvement approach, supported by these key elements:  

- Periodic risk self-assessment exercises (matrices): these are carried out periodically and 
allow  for  a  comparison  of  inherent  risk  vs.  residual  risk,  validating  whether  the  controls 
implemented reduce it to acceptable levels. The results are reviewed, distributed internally 
and, if necessary, lead to action plans and additional controls.  

- Follow-up of corrective actions: supervision of the implementation of measures derived 
from the self-assessment and evaluation of their impact, adjusting controls when new risks 
or inefficiencies are detected.  

- Results of controls and verifications (administrative and on-site), together with the use of 
red flags, which make it possible to check in practice whether the detection mechanisms 
are working and whether the net risk is decreasing.  

- Analysis of irregularities and feedback: the recording and monitoring of detected cases, 
as  well  as  the  withdrawal  of  irregular  expenditure  and  refunds,  serve  to  identify 
weaknesses in the system and strengthen internal procedures.  

-  Collection  of  data  from  the  anti-fraud  system,  such  as  the  number  of  complaints,  the 
number and identification of offending companies, etc., with a system of indicators of the 
effectiveness of the anti-fraud system (ratios of complaints per channel, infringements by 
type  of  project,  infringements  reported  to  the  competent  authorities)  currently  being 
implemented. An indicator has been implemented, number of complaints in relation to the 
number of cases handled each year, which has remained at levels considered minimal, 
both in relation to historical data and in comparison with other similar organisations. 

Anti-fraud procedures are assessed on the basis of fraud risks, the effectiveness of the 
measures in place, the strength of the control system, the level of training and the findings 
of  the  audit  and  certifying  authority.  The  assessment  is  based  on  the  European 
Commission’s detailed guidance, which will be developed continuously and systematically. 

Through  audits  conducted  by  the  CCCOP  (Commission  for  the  Certification  of  the 
Accounts of Paying Agencies) and the AnAFe (National Authority for the Audit of European 
Funds) 

Contribution from the Ministry of Agriculture, Forestry and Fisheries (Paying  Agency for 
Agriculture, Fisheries and Rural Development):  
Undertaking fraud risk assessments.  

Contribution  from  the  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  of 
Fisheries:  
Mostly,  the  measurement  is  based  on  the  number  of  irregularities  and  suspicion  of 
fraud/fraud detected whereas the less cases are detected or more cases are prevented, 
the Anti-Fraud system is more effective.  

Contribution from the Ministry of Regional Development and EU funds:  
Our Anti-Fraud system is considered effective, as it ensures the prevention, detection and 
correction of irregular or fraudulent behaviour throughout the implementation of ESI Funds. 
We measure its effectiveness through the results of preventive, detective and corrective 
measures within the management and control system, including the timely detection and 

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reporting of irregularities, the follow-up of suspected fraud cases, and the application of 
financial corrections and recovery of unduly paid amounts.  
The  system’s  effectiveness  is  further  assessed  through  audit  findings,  management 
verifications,  risk  assessments,  and  continuous  improvement  activities  such  as  training 
and awareness-raising for relevant bodies and beneficiaries. 

The effectiveness of the strategy is monitored  through the implementation status of the 
measures set. 

This  is  measured  by  the  small  number  of  proven  case  and  relatively  small  amounts  of 
funding involved in proven fraud cases following investigation at each year end 

The effectiveness of the anti-fraud system is measured by the ability to detect cases of 
irregularities and/or fraud as soon as possible in order to avoid the disbursement of funds 
and/or to launch the procedures for the recovery of funds already paid in a timely manner. 
Other  elements  taken  into  account  are  the  degree  of  coordination  and  cooperation 
between  the  national  and  European  authorities  involved,  as  well  as  the  effective 
implementation  of  the  preventive  and  corrective  measures  taken.  Specifically,  the 
effectiveness of anti-fraud  measures  are assessed  mainly through: (i) periodic risk self-
assessment,  which  may  be  followed  by  corrective  action;  (ii)  results  of  the  first-level 
management checks; (iii) results of the audit of operations and system audit. 

HU 

IE 

IT 

LT 

We are positive, because the number of reports from Agencies is decreasing. 

LU 

LV 

MT 

NL 

PL 

We regularly conduct a risk analysis that includes not only the  identification of potential 
risks but also a review of recent irregularities. Because this number fluctuates over time, it 
provides us with a clear indication of whether the measures we implement are effective. 
Given that the number of fraud cases within our fund remains consistently very low, we 
can confirm the overall effectiveness of the systems and controls we have in place. 

All  EU  funds  institutions  have  an  internal  control  system  for  combating  fraud,  which  is 
periodically  improved  and  operates  effectively.  Preventive  and  control  measures  have 
been introduced for the timely identification of fraud risks, and fraud cases are assessed. 

Prevention, detection and recovery of irregularities and suspected cases of fraud are dealt 
with by the Managing Authorities (Planning and Priorities Coordination Division and Funds 
and Programmes Division) and Paying Agency (Agriculture and Rural Paying Agency) of 
European  Union  (EU)  funds.  Detection  is  also  managed  by  the  Audit  Authority  and 
Certifying Body of EU funds. Cases of suspected fraud are forwarded and dealt with by 
the Financial Investigations Directorate (FID) within the Internal Audit and Investigations 
Department.  In  addition,  FID,  in  its  role  as  the  Maltese  AFCOS,  also  holds  a  quarterly 
Irregularity  Reporting  Sub-Group  meeting  between  the  above-mentioned  national 
authorities. The meeting is held to ensure correct and complete reporting of irregularities 
and  suspected  cases  of  fraud  by  the  Maltese  AFCOS  in  the  Irregularity  Management 
System (IMS). 

Here  too,  there  are  differences.  For  example,  Customs  (revenue)  uses  sampling.  For 
expenditure,  a  fraud  risk  cycle  is  applied  in  which  the  accuracy  of  the  risk  analyses  is 
checked retrospectively. There is also constant monitoring. 

The indicators considered when measuring the effectiveness of the anti-fraud system in 
cohesion policy include:   

1. The existence of procedures, adopted in each programme, covering areas such as the 
fight against irregularities and fraud.   
2. Regular fraud risk assessments and application of the results of such analysis in the 
preparation of annual control plans.   
3.  The  number  of  views  of  the  educational  materials  on  YouTube  concerning  the  fight 

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against fraud, including conflicts of interest.   
4. The available channels for reporting irregularities and red flags.   
5. The use of data analysis tools.   
6. The assessment results included in reports on audits of the management and control 
system carried out by the Audit Authority.   

The indicators considered when measuring the effectiveness of the anti-fraud system in 
agricultural policy include:   

1. The results of analyses, verifications and comparison of available data.   
2. The results of the quarterly monitoring of cases where fraud is suspected.    
3.  The  results  of  the  quarterly  monitoring  of  cases  referred  to  the  law  enforcement 
authorities.   
4. The results of the quarterly monitoring of cases where fraud has been confirmed. 

PT 

The  NAFS  sets  measurable  indicators  and  targets  enabling  us  to  ascertain  the 
implementation level of each of its measures. 

RO 

National Agency for Public Procurement:   
Through  continuous  monitoring  and  control  activities,  as  set  out  in  the  operational 
procedures.  

Paying and Intervention Agency for Agriculture:   
By correlating prevention with detection and recovery, we have achieved our objectives.  

Ministry of Energy:   
This was achieved by: ensuring the effectiveness of the procedural system through user 
compliance;  consulting  dedicated  platforms  such  as  Arachne,  ONRC,  REGAS  and 
www.dubla-finantare.ro;  and  concluding  partnerships  with  other  public  institutions  to 
prevent double funding. Warning systems should be set up within the platforms used to 
identify  businesses  applying  for  European  funds  that  may  present  potential  eligibility-
related vulnerabilities.  

Ministry of Investments and European Projects:   
The number of fraud notifications confirmed as such.  

North-East Regional Development Agency:   
Following  the  checks  carried  out  during  the  audit  visits,  the  conclusion  on  the  effective 
functioning of the management and control system at the level of key requirement 7 is as 
follows: ‘The system works. Some improvements are needed (category 2)’. In addition, the 
internal fraud risk assessment found that the consistent application of preventive measures 
and internal checks by the Managing Authority has significantly strengthened the anti-fraud 
control  system  and  reduced  the  risk  of  fraud  in  the  use  of  funds.  However,  ongoing 
monitoring  is  necessary  to  ensure  that  anti-fraud  measures  laid  down  in  specific 
operational procedures remain effective and are adapted to emerging threats.  
West Regional Development Agency:   
The management and control system is verified by the Audit Authority within the Romanian 
Court of Auditors. The management and control system of the Managing Authority for the 
West  Regional  Programme  currently  falls  under  category  2:  ‘The  system  works.  Some 
improvements are needed’.  

South-West Oltenia Regional Development Agency:   
We  assess  effectiveness  by  monitoring  the  results  of  management  verifications,  the 
number  and  type  of  irregularities  identified,  the  financial  corrections  applied,  and  the 
amounts recovered; by complying with reporting deadlines; and by constantly improving 
the internal procedures and the risk analysis tools used.  

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North-West Regional Development Agency:   
As a result of the anti-fraud measures adopted by the North-West Regional Development 
Agency and the implementation of activities to prevent and mitigate fraud risks, the system 
adopted is highly effective. 

SE 

SI 

SK 

We monitor the number of OLAF notifications and recoveries. 

Effective. 

Effectiveness is assessed based on closure rates, time to recovery, and implementation 
of corrective actions following reported irregularities. 

Q.1.7  (IMS  users)  How  do  you  ensure  adequate  knowledge  of  existing 
staff? 

Response 

Frequency  Percentage 

Member States 

OLAF/Commission issued materials 

22  81.5% 

Regular training sessions 

20  74.1% 

Liaison officers/ Trainers in contact with OLAF 

18  66.7% 

National IMS Guidance/Guidebooks 

17  63.0% 

Other (please specify) 

11  40.7% 

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

AT, BE, BG, CZ, 
DE,  ES,  FI,  FR, 
HR,  HU,  IE,  IT, 
LT,  LU,  LV,  NL, 
PL, RO, SE, SI 

AT, BE, BG, CY, 
CZ,  DE,  ES,  FI, 
FR, HR, HU, IE, 
MT, PL, PT, RO, 
SI, SK 

BE,  BG,  CZ, 
DE, DK, EL, ES, 
FR, HR, HU, IE, 
IT,  LV,  PL,  RO, 
SI, SK 

AT, BE, CZ, DE, 
EE,  EL,  HU,  IE, 
LV, NL, SK 

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Following Q1.7, please specify "Other". 

Member 
State 

Response 

AT 

BE 

CZ 

DE 

EE 

EL 

HU 

IE 

LV 

NL 

SK 

Training as required. 

ERDF and RRF Brussels Capital Region:   
Internal documents and some training sessions and/or workshops from time to time. 

Communication between reporting entities/sharing of good practice. 

The Federal Office for Agriculture and Food (BLE):   
Internal material.   

The Thuringia ERDF managing authority:   
Relevant training material is provided by the European Commission. Staff use this material 
for  professional  development  and  to  keep  their  knowledge  up  to  date  in  relation  to 
irregularities. 

We  ensure  adequate  knowledge  of  our 
through  a  combination  of 
experience‑based  competence  and  structured  support  mechanisms.  In  Estonia,  the 
number of IMS users is relatively small, as most operational data is maintained in national 
databases  and  only  uploaded  to  IMS  when  required.  As  a  result,  our  IMS  users  are 
long‑standing staff members with substantial practical experience in both the system and 
the underlying administrative processes.  

IMS  users 

Whenever  questions  or  technical  issues  arise,  users  receive  direct  guidance  from  the 
Country Officer, who liaises with OLAF colleagues when necessary. This ensures that our 
users  remain  up  to  date  with  system  requirements,  procedural  changes,  and  best 
practices, even though the user base is limited. The combination of experienced staff and 
reliable  support  channels  allows  us  to  maintain  a  consistently  high  level  of  IMS‑related 
knowledge. 

Through  the  anti-fraud  network  composed  of  staff  from  the  Managing  Authorities  of  the 
Partnership Agreement for Regional Development (ESPA) programmes. 

AFCOS  organises  regular  (quarterly)  irregularity-reporting  working  group  meetings  for 
reporting bodies to discuss current policy issues. 

IMS training took place in Dublin in October 2025, with representatives from each reporting 
authority in attendance in-person and online. The reporting structure has been restructured 
in 2025 and efforts to solidify this will continue in 2026. Country Officers have been put in 
place.  

An AFCOS Network handbook had been in production. This is an initiative led by AFCOS, 
in consultation with all reporting authorities and OLAF. It is due for adoption imminently. 

Additional information posted in IMS system (library) regarding the completion of individual 
fields,  as  well  as  emails 
team,  which  sometimes  provide 
recommendations/instructions  for  entering  information  into  the  system  or  completing 
specific fields. 

from 

IMS 

the 

Instructions are drawn up for staff dealing with registration in IMS. The team has also been 
the same for years. If new staff are assigned this task in the future, they will receive training, 
for which the OLAF manuals will be a good guide. 

Guidance  for  IMS  users  within  the  AFCOS  network  is  also  provided  through  individual 
technical  or 
in  particular  when  dealing  with  specific  cases  and 
consultations 

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Response 

methodological  issues  related  to  the  reporting  of  irregularities,  as  well  as  within  the 
Irregularities Working Group established under the Steering Committee for the Protection 
of the European Union's Financial Interests, where recurring problems, the most common 
errors  in  reporting  and  proposed  measures  to  improve  the  quality  and  completeness  of 
data are discussed. AFCOS network partners have the opportunity to discuss and present 
proposals  and  jointly  resolve  issues  related  to  improving  the  protection  of  financial 
interests. 

Q.1.8  (IMS  users)  How  is  new  staff  trained  on  existing  reporting  and 
coordination procedures related to IMS? 

Response 

Frequency  Percentage 

Member States 

Specification  of  responsibilities  ensuring  clear 
attribution of tasks 

19  70.4% 

Coordination at National level 

17  63.0% 

Extensive  written  documentation  of  necessary 
tasks 

16  59.3% 

National IMS Guidance/Guidebooks 

16  59.3% 

A Grace Period involving the new and old hire 

7  25.9% 

Coordination at Regional level 

6  22.2% 

Transfer of the case responsibility ownership 

5  18.5% 

AT, BG, CZ, DE, 
ES,  FR,  HR, 
HU,  IE,  LT,  LU, 
LV, MT, NL, PL, 
PT, RO, SE, SI 

AT, BG, CY, CZ, 
DE,  EE,  ES, 
HR,  HU,  IE,  IT, 
LU, PL, PT, RO, 
SE, SI 

BG,  CZ,  DE, 
DK, ES, FI, HR, 
IE,  LU,  LV,  NL, 
PT, RO, SE, SI, 
SK 

BE,  BG,  CZ, 
DE, DK, EL, ES, 
HR,  HU,  IE,  IT, 
LU,  LV,  PL,  SI, 
SK 

BE, DE, HR, IE, 
LU, SI, SK 

AT,  DE,  ES,  IE, 
LT, PL 

BE, DK, HR, IE, 
LU 

Coordination with other Member States 

4  14.8% 

AT, CZ, HR, IE 

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Response 

Frequency  Percentage 

Member States 

Other (please specify) 

9  33.3% 

BE,  CZ,  DE,  FI, 
HU, IE, MT, PL, 
SK 

Following Q.1.8, please specify "Other". 

Member 
State 

Response 

BE 

ESF VL EUROPA WSE:  
As we only have one person responsible for IMS, there is no training readily available at 
this moment.  

ERDF & RRF Brussels-Capital Region:  
Internal information transfer and documentation of the persons with specific responsibilities 
and knowledge regarding irregularities and fraud. 

CZ 

Pooling of good practice between colleagues. 

The ESF Plus Federal Programme, led by the Federal Ministry of Labour and Social Affairs 
(BMAS): As part of the induction for new staff, information is provided about the reporting 
procedure.  The  material  issued  by  OLAF  and  the  national  IMS  guidelines/guidance 
documents are made available in a central information database.   

DE 

The AMIF managing authority:   
Comprehensive training, awareness-raising and induction of new staff.   

FI 

HU 

IE 

MT 

PL 

SK 

The AFCOS, the Federal Ministry of Finance:   
Regular workshops for IMS users in order to present current developments and issues in 
relation to recording irregularities in the IMS, provide solutions and improve data quality. 

In-person training, limited number of users. 

The AFCOS senior IMS expert provides practical IMS training for all new IMS users when 
IMS privileges are made available. 

Work in this space is ongoing, ensuring staff and namely country officers are trained up. 
Support from OLAF has been of huge benefit across the Irish system. 

New  staff  is  trained  by  IMS  managers,  OLAF  IMS  training  and  also  through 
OLAF/Commission issued materials. 

- Training courses for new staff;  
- Mentoring during the first few quarters of work;   
- Institutions’ in-house training material on the rules for making reports in IMS, covering 
the use for that purpose of data from institutions’ own information systems. 

Guidance  for  IMS  users  within  the  AFCOS  network  is  also  provided  through  individual 
consultations 
technical  or 
in  particular  when  dealing  with  specific  cases  and 
methodological  issues  related  to  the  reporting  of  irregularities,  as  well  as  within  the 
Irregularities Working Group established under the Steering Committee for the Protection 
of the European Union's Financial Interests, where recurring problems, the most common 
errors  in  reporting  and  proposed  measures  to  improve  the  quality  and  completeness  of 

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data are discussed. AFCOS network partners have the opportunity to discuss and present 
proposals  and  jointly  resolve  issues  related  to  improving  the  protection  of  financial 
interests. 

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RECOMMENDATION 2 – ESTABLISHING MORE EFFECTIVE COMMUNICATION CHANNELS  

Better coordination between national authorities, OLAF and the EPPO is also necessary to ensure 
that  cases  investigated  by  EU  bodies  are  duly  reported  at  the  earliest  possible  moment  in 
compliance  with  the  relevant  EU  sectoral  legislation.  National  authorities  must  correctly  identify 
and address existing loopholes in the information flow in relation to suspected fraud, the moment 
they  are  first  reported,  and  even  more  so,  when  following-up  on  them  both  in  judicial  and 
administrative proceedings at national level. The Commission is committed to further developing 
and providing the necessary guidelines, IT tools and support. The Commission will also 

Q.2.1 (AFCOS) What systems/practices  do you have in place to ensure 
uninhibited information flow between judicial and reporting authorities? 

Member 
State 

Response 

AT 

E-Mails. 

Belgian AFCOS:  
As  previously  stated,  the  decentralised  structure  in  Belgium  has  as  a  result  that 
communication between reporting and judicial authorities does not necessarily run through 
the BE AFCOS Secretariat. However, we are in close contact with the Belgian magistrates 
of  the  EPPO  and  invite  them  during  the  AFCOS  sessions  to  inform  all  partners  of  the 
current situation. The Secretariat is also capable of transferring the necessary information 
to the judicial authorities by writing an investigation report under art 29 Belgian Code of 
Criminal Procedure.   

PSW ERDF Wallonia:  
(PSW) At the Walloon regional level, a workflow already provides for procedures laid down 
in regional legislation to pass on fraud cases to the Public Prosecutor’s Office (Article 20 
of the Decree of 28 February 2019 on the monitoring of laws and regulations on economic 
policy,  employment  and  scientific  research  policy,  and  also  the  introduction  of 
administrative fines for breaches of these laws and regulations). The Public Prosecutor’s 
Office procedure for sending information between the Belgian Public Prosecutor’s Office 
(PPO) and the European PPO allows for a rapid transfer of cases (Circular No 03/2022 of 
the College  of Principal  Public Prosecutors). A procedure for addressing  and correcting 
fraud is being drawn up at PSW level. 

Reporting authorities request regular reports from judicial authorities 

We are in the process of acquiring a whistleblowing platform that will be used as a case 
management tool. 

Established clear instructions for handing over cases and defined guidelines. Regular inter 
agency meetings or working groups to discuss ongoing cases and share information. 

The NRW ERDF managing authority:   
Filing of criminal complaints due to suspected fraud.   

BE 

BG 

CY 

CZ 

DE 

The Lower Saxony ERDF managing authority:   
Encrypted email system on Lower Saxony’s secure federal-state network.   

The ESF Plus Federal Programme, led by the Federal Ministry of Labour and Social Affairs 
(BMAS):   
The  reporting  authorities  usually  file  a  criminal  complaint  and  provide  the  documents 

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necessary for the judicial authorities’ assessment. Moreover, Sections 406d  and 475 of 
the Code of Criminal Procedure (StPO) regulate the relevant right of access to information.   

The Bremen ERDF managing authority:   
When a possible case of fraud is detected by the intermediate bodies, as is generally the 
case, they inform the managing authority and, at the same time, step up the administrative 
checks.  If  the  suspicion  is  not  confirmed,  the  intermediate  bodies  inform  the  managing 
authority accordingly. However, if the suspicion is confirmed, the intermediate bodies refer 
the  case  to  the  public  prosecutor’s  office  and  inform  the  managing  authority.  Once  the 
public prosecutor’s office has come to a conclusion, the intermediate body is informed. In 
turn, the intermediate body informs the managing authority.    

The AMIF managing authority:   
In both our internal guidelines on handling irregularities and audit documentation, we have 
established a system for reporting cases of fraud to the competent Ministry of the Interior, 
our legal service, the public prosecutor’s office and the European Commission (via IMS to 
OLAF). The roles of the bodies involved and the reporting channels are clearly defined.   

The Thuringia ERDF managing authority:   
Please see the ERDF guidance document and the 2025 manual on reporting irregularities 
in shared management. In  accordance with the applicable national  legal provisions, the 
implementing  body  or  the  authorising  body  must  notify  the  public  prosecutor’s  office 
accordingly,  also informing the  managing authority.  A digital-only reporting  process has 
been available since the end of January and is being tested. 

Danish Agricultural and Fisheries Agency:   
Systematic approach to when suspected cases are reported to relevant authorities. The 
Danish Agriculture and Fisheries Agency is always ready to assist the judicial authorities 
with information regarding irregular cases. 

In Estonia, criminal investigations are initiated by the implementing bodies responsible for 
project  management,  and  they  act  as  the  primary  contact  point  for  the  competent 
investigative authority (EPPO or the national prosecution service). AFCOS supports both 
the implementing bodies and the managing authority by facilitating information exchange 
at key stages — including the initiation of a case and the quarterly follow‑up on its progress.   

Due to the EPPO Regulation and the internal information‑sharing arrangements in place, 
AFCOS  does  not  receive  operational  information  directly  from  EPPO.  As  a  result,  the 
implementing  bodies  remain  the  main  channel  for  communication  with  investigative 
authorities.  AFCOS  ensures  an  unhindered  flow  of  administrative  information  by 
maintaining regular contact with the implementing bodies, providing guidance on reporting 
obligations,  and  consolidating  the  information  required  for  OLAF  and  Commission 
reporting. 

Communication with:   
A)  the  office  of  the  European  Delegated  Prosecutors,  e.g.  verbally,  over  email,  via  the 
distribution of printed information,  
B) national prosecution authorities. 

The Spanish AFCOS carries out information and monitoring functions for the classification 
and reporting of suspected fraud, informing the authorities of the existence of ongoing legal 
proceedings, as well as their completion, requesting information from the judicial bodies, 
all  on  the  basis  of  the  criteria  contained  in  the  document  ‘Criteria  for  classification  and 
procedure for action regarding irregularities and suspected fraud in operations and projects 
that are the subject of criminal proceedings’ issued by AFCOS.  

AFCOS  has  recommended  that  all  managing  authorities,  when  referring  a  case  to  the 

DK 

EE 

EL 

ES 

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European Public Prosecutor's Office, as well as when obtaining any updates on the case, 
communicate  this  to  AFCOS  so  that  it  can  monitor  the  correct  communication  in  IMS, 
where appropriate, of suspected fraud. In this way, AFCOS can be aware of cases sent to 
the European Public Prosecutor's Office and request updates on their status. In the various 
training courses given, the importance of keeping the information in IMS and AFCOS up 
to date has been explained and highlighted so that AFCOS can monitor cases that have 
gone to court.  

There  is  a  protocol  signed  with  the  National  Police  for  collaboration  and  exchange  of 
information with AFCOS, and the renewal of the protocol with the Civil Guard is currently 
pending  signature.  Under  these  protocols,  requests  for  information  are  received, 
sometimes  in  the  context  of  European  Public  Prosecutor's  Office  investigations,  which 
allows the AFCOS to contact EPPO in order to obtain the necessary information to, where 
appropriate, proceed with communication in IMS.  
Any information obtained by AFCOS, either through IMS reviews or by other means, which 
involves a modification of communications is forwarded to the authorities responsible for 
it, with AFCOS monitoring the correct communication.  
There is also a protocol between the National Audit Office and AFCOS, both of which are 
part  of  the  General  State  Comptroller  (IGAE),  relating  to  the  exchange  of  information 
between  the  two  units  on  cases  of  suspected  fraud  in  the  area  of  the  Recovery, 
Transformation and Resilience Plan. 

The  authorities  responsible  for  implementing  EU  programmes  exercise  administrative 
powers.  The  legislation  in  each  sector  sets  out  the  powers  and  duties  of  authorities  to 
monitor activities and if necessary, carry out recovery. If an administrative authority has 
reason to suspect fraud, it makes a request to the pre-trial investigation authority, such as 
the  police,  for  an  investigation  into  the  matter.  The  administrative  authorities  are  also 
responsible for IMS reporting. The Police and Customs carry out criminal investigations in 
accordance  with  their  powers,  while  prosecutors  prosecute  and  the  courts  conduct  the 
judicial process.   

Roles and powers are clearly split among the various authorities. The Police, Customs and 
the  public  prosecutors,  i.e.  the  enforcement  authorities  and  judicial  authorities,  operate 
independently  and  have  the  power  to  conduct  criminal  investigations  and  take  coercive 
measures. The administrative authorities do not hold these kinds of powers but provide 
the authority conducting the preliminary investigation with the necessary information in the 
investigation request. 

We are strengthening governance in the fight against fraud with a new architecture steered 
by  the  MICAF  (the  Interministerial  Anti-Fraud  Coordination  Mission).  This  involves  the 
interministerial unit for the anti-fraud monitoring of public funds and a number of national 
anti-fraud operating groups (groupes opérationnels nationaux anti-fraude - GONAF).   
For example: The interministerial unit for the anti-fraud monitoring of public funds, attached 
to the MICAF, will play a key role in dealing with fraud linked to European expenditure. 
With  regard  to  the  Recovery  and  Resilience  Facility  (RRF),  this  unit  will  coordinate 
dedicated  working  groups  (WGs),  particularly  in  the  field  of  energy  renovation  and 
apprenticeships.  The  monitoring  unit  will  also  analyse  the  risks  associated  with 
implementing new European arrangements.   

In this new architecture, operational management relating to revenue fraud will be carried 
out  by  the  GONAFs,  co-facilitated  by  the  MICAF,  the  DGFiP  (Directorate-General  for 
Public Finance) and the DGDDI (Directorate-General for Customs and Indirect Taxation). 
These groups will coordinate efforts to combat revenue fraud, such as fraud linked to VAT, 
e-commerce, tobacco and counterfeiting by drawing on strengthened information-sharing 
and risk-analysis mechanisms.   

We  are  improving  the  effectiveness  of  investigations  led  by  the  EPPO  through  better 

FI 

FR 

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coordination and improved stakeholder awareness;   

We are developing the role of the financial courts in order to make the fight against fraud 
affecting the EU’s financial interests a more integral part of their investigations. 

Contribution from HR AFCOS unit:  
Enhanced  cooperation  between  reporting  and  judicial  bodies  is  ensured  by  adopting 
Decision  on  Establishing  the  AFCOS  Network,  which  obliges  AFCOS  Network  bodies 
(including judicial bodies) to exchange the information with the bodies of the management 
and  control  system  for  the  use  of  funds  of  the  European  Union,  the  bodies  of  the 
management and monitoring system for the implementation of activities under the National 
Recovery  and  Resilience  Plan  2021–2026,  AFCOS  Unit,  and  the  European  Anti-Fraud 
Office (OLAF). The first Decision was adopted in 2008, and the new one was adopted in 
2025. Exchange of information may also take form of AFCOS Network meetings. 

The Internal Audit and Integrity Directorate acts as a single point of contact between the 
(reporting) managing authorities and the investigating authorities. The directorate monitors 
procedures initiated following suspicion of fraud and forwards the information obtained to 
the competent managing authorities and investigating authorities. 

The Irish AFCOS does not have a role in this space. It is for the government department/ 
bodies managing EU funds to do so. They have stressed clear lines of communication with 
An  Garda  Síochána,  or  another  appropriate  civil  authority,  where  an  investigation  of  a 
suspected fraud has taken place. 

The managing authorities (MA) and the judicial authorities primarily exchange information 
through  ordinary  certified  email  channels,  i.e.  by  way  of  the  criminal  investigation  body 
performing the investigations (subject to prior authorisation from the prosecuting judicial 
authority). 

HR 

HU 

IE 

IT 

LT 

Direct communication. 

LU 

LV 

MT 

NL 

PL 

The  information  is  first  transmitted  to  the  competent  Minister.  From  there  on,  after  a 
coordination discussion with the audit authority, a written denunciation letter, signed by the 
competent Minister would be sent to the EPPO and national jurisdictions. 

Reporting of suspicions of fraud to EPPO or national judicial authorities is carried out in 
accordance  with  regulatory  enactments.  In  additions  each  ES  funds  authority  have  a 
contact  person  in  EPPO  with  whom  they  can  exchange  information  and  receive 
consultations. 

The Maltese AFCOS is the reporting authority with respect to irregularities and cases of 
suspected fraud forwarded by the Managing Authorities, Paying Agency, Audit Authority 
and  Certifying  Body  of  EU  funds  (kindly  refer  to  the  reply  provided  in  Question  1.6). 
Information flow with respect to suspected cases of fraud is dealt with by FID with judicial 
authorities, in terms of the Internal Audit and Financial Investigations Act (Cap. 461 of the 
Laws of Malta). 

There are set procedures that staff must follow if they suspect fraud when dealing with a 
project  grant.  As  soon  as  further  investigation  shows  that  the  suspicion  is  justified,  an 
external party is contacted and informed. That party decides whether to pursue the matter 
and contacts the Public Prosecutor’s Office and the EPPO. These procedures are also set 
out in writing. 

One such practice is the regular exchange of information on the basis of the cooperation 
agreement  between  the  National  Public  Prosecutor  and  the  minister  responsible  for 
regional  development,  as  regards  the  transmission  of  information  on  ongoing  and 
concluded proceedings concerning projects cofinanced by EU funds:   

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- Periodic cooperation: receiving from the National Public Prosecutor’s Office information 
on proceedings in cases in which the public prosecutor handling the case has consented 
to the transmission of information to the institution;   
- Ongoing cooperation: exchange of information via a dedicated email address where it is 
necessary to obtain data on specific proceedings;   
-  Direct  referral  of  questions  by  managing  authorities  to  individual  public  prosecutors’ 
offices regarding specific ongoing proceedings.   

The  exchange  of  information  at  the  stage  of  judicial  proceedings  is  a  formal  process 
governed by the relevant legislation. In addition, the competent national institutions have 
access  to  digitised  case  files  and  to  a  judicial  information  portal,  which  facilitates 
communication  and  exchange  of  information  between  the  judicial  authorities  and  these 
institutions. However, the decision on whether or not to grant access to case files (including 
in  digital  form)  is  taken,  in  accordance  with  the  relevant  legislation,  by  the  authority 
handling  the  case.  Furthermore,  an  agreement  is  currently  being  prepared  on  the 
electronic transmission to organisational units of the Police of information collected in the 
CST2021 IT system, which supports programme implementation.   

In agricultural policy, each irregularity found is analysed individually in order to determine 
whether  there  is  substantiated  suspicion  that  the  beneficiary  has  committed  a  crime  or 
minor offence. Decisions on whether to refer a case to the law enforcement authorities and 
draw up a notice of substantiated suspicion that a crime/minor offence has been committed 
are taken by the competent administrative authority without undue delay.   

All  cases  referred  to  the  law  enforcement  authorities  are  recorded  in  the  in-house 
information system, with the stage that ongoing criminal proceedings have reached being 
indicated.  If  there  is  no  information  on  the  current  stage  of  criminal  proceedings  being 
conducted by law enforcement authorities, a request for such information to be transmitted 
is sent to the authority conducting the case and the data is updated in  the system. The 
data in the IMS report is then supplemented on the basis of the information received.   

For ongoing cases that are subject to reporting in IMS, quarterly verification is carried out 
until the criminal proceedings in the case have been completed. 

Information provided by OLAF or the EPPO (or both) is treated confidentially.   

The  protocols  for  coordination  with  the  judicial  bodies  establish  secure  mechanisms  for 
sending  information,  and  procedures  and  channels  for  national  authorities  to  exchange 
information on irregularities. 

Clear rules for reporting suspected fraud cases.  
Designated persons responsible for communicating information.  
Use of specific systems for transmitting information. 

Communication and the dissemination of information take place via email. 

Regular contacts and communication and inter-ministerial group meetings. 

The process of reporting irregularities to OLAF involves several key steps, proceeding from 
the Managing Authority (MA) or Intermediate Body (IB) via the Certifying Authority/Paying 
Authority  (CA/PA)  to  the  AFCOS.  The  MA/IB  is  responsible  for  reporting  the  detected 
irregularity and for recording the information on the irregularity in the national IT monitoring 
system (ITMS). The MA/IB is responsible for resolving the irregularity. For this reason, the 
MA/IB receives information on all initiated and ongoing proceedings from the authorities 

PT 

RO 

SE 

SI 

SK 

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conducting criminal proceedings on the basis of the legislation governing the provision of 
information related to criminal proceedings by the police, the prosecution and the courts. 
These entities are obliged to provide the requested cooperation; it may only be refused if 
this could jeopardise the independent exercise of their statutory tasks. If the audit authority 
(AA)  detects  an  irregularity  on  its  own  initiative  and  does  not  refer  the  matter  to  the 
implementing authority, it is obliged to issue a report on the detected irregularity via the 
ITMS.  If  a  statutory  body,  an  employee  or  a  person  acting  on  behalf  of  the  MA/IB  is 
suspected of having committed a criminal offence in connection with the implementation 
of the programme, a paper report on the detected irregularity is drawn up, approved and 
submitted to the CA/PA and AFCOS.  

The ITMS contains detailed information on the irregularity in question, on the basis of which 
the competent authority/CA/PA forwards their report to AFCOS and subsequently AFCOS 
reports the cases via IMS. There is regular communication and exchange of information 
(e.g. on legal procedures, technical procedures) between all the above-mentioned bodies. 
Where  necessary,  other  bodies  are  also  involved,  such  as  the  AA,  law  enforcement 
authorities, etc.  

In the case of agricultural funds, judicial authoririties contact/inform the Agricultural Paying 
Agency (APA). The exchange of information then takes place as follows: APA via IMS to 
AFCOS.  

The exchange of information regarding fraudulent irregularities is based on a cooperation 
agreement between AFCOS and the General Prosecutor's Office of the Slovak Republic. 
On 18 December 2025, a new Memorandum of Cooperation was concluded between the 
Office of the Government of the Slovak Republic as AFCOS and the Ministry of the Interior 
of  the  Slovak  Republic,  specifically  the  Office  for  the  Fight  against  organised  Crime  - 
UBOK, with the aim of strengthening cooperation in this area.  

AFCOS  independently  receives  information  on  the  initiation  and  final  judgment 
(acquittal/conviction) of criminal prosecution against legal persons for a crime committed 
in  connection  with  assistance  and  support  provided  from  European  Union  funds  in 
accordance with Act No. 91/2016 Coll. on the Criminal Liability of Legal Persons.  

The guidelines  issued by the competent national authorities in the field  of handling and 
reporting  irregularities  (in  particular  AFCOS  and  the  Ministry  of  Finance  of  the  Slovak 
Republic) set out a detailed procedure for processing and using the information provided 
on ongoing criminal prosecutions in order to ensure the continuous, active and effective 
protection of the financial interests of the European Union in the Slovak Republic and to 
improve the correct reporting of irregularities with qualifications IRQ3 and IRQ5. 

(AFCOS)  Which  communication  methods  are  used 

Q.2.2 
coordination of your Anti-Fraud efforts? IMS 

for 

Response 

Frequency  Percentage 

Member States 

Used 

      -       

22  81.5% 

AT, BE, BG, CY, 
CZ, DE, DK, EE, 
ES, FI, HR, HU, 
IT,  LU,  LV,  MT, 

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Response 

Frequency  Percentage 

Member States 

Planned to Use 

Not Used 

PL, PT, RO, SE, 
SI, SK 

2  7.4% 

LT, NL 

3  11.1% 

EL, FR, IE 

Q.2.2 
for 
(AFCOS)  Which  communication  methods  are  used 
coordination of your Anti-Fraud efforts? Secure data exchange platforms 
(Online) 

Response 

Used 

Frequency  Percentage 

Member States 

11  40.7% 

CZ, DE, EE, EL, 
ES,  HU,  IT,  LV, 
NL, PL, RO 

Planned to Use 

2  7.4% 

BE, CY 

Not Used 

14  51.9% 

AT, BG, DK, FI, 
FR,  HR,  IE,  LT, 
LU, MT, PT, SE, 
SI, SK 

Q.2.2 
for 
(AFCOS)  Which  communication  methods  are  used 
coordination  of  your  Anti-Fraud  efforts?  Shared  case  management 
systems 

Response 

Used 

Frequency  Percentage 

Member States 

10  37.0% 

CZ, DK, EE, ES, 
FI,  FR,  NL,  PT, 
RO, SK 

Planned to Use 

3  11.1% 

CY, EL, LU 

Not Used 

14  51.9% 

AT, BE, BG, DE, 
HR,  HU,  IE,  IT, 
LT, LV, MT, PL, 
SE, SI 

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(AFCOS)  Which  communication  methods  are  used 

Q.2.2 
coordination of your Anti-Fraud efforts? Encrypted email 

for 

Response 

Frequency  Percentage 

Member States 

Used 

15  55.6% 

BG,  CY,  CZ, 
DE, DK, EE, EL, 
ES,  FI,  FR,  LT, 
LU, NL, PL, PT 

Planned to Use 

1  3.7% 

BE 

Not Used 

11  40.7% 

AT, HR, HU, IE, 
IT, LV, MT, RO, 
SE, SI, SK 

(AFCOS)  Which  communication  methods  are  used 

Q.2.2 
coordination of your Anti-Fraud efforts? Regular meetings 

for 

Response 

Frequency  Percentage 

Member States 

Used 

25  92.6% 

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

Not Used 

2  7.4% 

HR, SE 

(AFCOS)  Which  communication  methods  are  used 

Q.2.2 
coordination of your Anti-Fraud efforts? Other (please specify) 

for 

Response 

Used 

Not Used 

      -       

Frequency  Percentage 

Member States 

8  29.6% 

19  70.4% 

AT, CZ, DE, ES, 
HR, IE, SI, SK 

BE,  BG,  CY, 
DK,  EE,  EL,  FI, 
FR,  HU,  IT,  LT, 

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Response 

Frequency  Percentage 

Member States 

LU, LV, MT, NL, 
PL, PT, RO, SE 

Following Q.2.2, please specify "Other". 

Member 
State 

Response 

AT 

CZ 

DE 

The AFCOS is only a facilitator and coordinator and assists in OLAF’s on-the-spot checks 
or audit requests from OLAF. In practice, OLAF makes contact by email. 

Ad hoc meetings. 

The AMIF managing authority:   
The German managing authorities of the home affairs funds (AMIF, ISF and BMVI) use a 
common IT system (the ITSI); however, there is no web-based fraud detection software as 
part of a common case management system. 

ES 

Protocols of cooperation between authorities 

- AFCOS Network meetings (meetings between MCS AFCOS Network bodies and AFCOS 
Unit)  and  meetings  between  AFCOS  Unit  and  management  and  control  system  bodies 
which are organised when necessary   
- Irregularity Management Guidelines issued by AFCOS Unit and intended for MCS bodies  
- Written communication on specific issues 

AFCOS  liaise  with  the  country  officers  and  reporting  authorities  on  a  regular  basis. 
Quarterly meetings are held throughout the year, in addition to bilateral conversations as 
required. AFCOS plays the role of the URT-liaison officer for all reporting authorities and 
will update the user list on a quarterly basis. 

Conferences, annual meetings. 

Paper form  in case the person acting on behalf  of the implementing authority would  be 
suspected of committing a criminal offense. 

HR 

IE 

SI 

SK 

Q.2.3  (All  entities  involved  with  fraudulent  irregularities)  If  your 
Member State uses secured online platforms or shared case management 
systems,  roughly,  what  percentage  of  fraudulent  irregularity  cases  are 
processed and followed up primarily through these digital channels (as 
opposed to paper or conventional correspondence)? 

Response 

76–100% 

      -       

Frequency  Percentage 

Member States 

13  48.1% 

CZ, DE, EE, EL, 
ES,  FI,  IT,  LV, 

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Response 

Frequency  Percentage 

Member States 

26–50% 

51–75% 

NL, PL, PT, RO, 
SK 

2  7.4% 

DK, FR 

1  3.7% 

HU 

Q.2.4 (IMS  users)  Which IMS fields prove the most  difficult to receive 
accurate, complete, and timely information for? 

Member 
State 

Response 

AT 

n/a 

BE 

BG 

CY 

ESF VL EUROPA WSE:  
The problem is that the fields change over time. Sometimes we have to add information 
for projects that are already closed. 

In rare cases, it is difficult to precisely determine the amount affected by the irregularity 

Categorization/classification of irregularities, persons concerned, relevant EU provisions. 

Field 6.9   

Fields 6.3, 6.4, 6.7, 6.8, 7.2 and 7.3   

CZ 

Field 8.5: Police progress reports on criminal investigations are either late or we do not 
receive them at all, making it difficult to provide information in this field.    

Annexes - for example, judgments with a jurisdiction clause and data from insolvency and 
enforcement proceedings. 

The Lower Saxony ERDF managing authority: All mandatory fields can be completed with 
the available information.   

The EU Paying Agency for Lower Saxony, Bremen and Hamburg: No 2.2.2 ‘Function or 
role’.   

The Schleswig-Holstein ERDF managing authority: It is most difficult to obtain information 
for IMS fields 6.7.1 and 6.7.2 (Irregularity committed from/to).   

DE 

The Bremen ERDF managing authority: No 3.11 ‘Definition of the priority axis’; No 3.12 
‘Definition of the operation’; No 6.8 ‘Determination of the type of irregularity’. For each of 
the above-mentioned fields, the applicable criteria should be selected from the drop-down 
lists  provided.  These  correspond  only  vaguely  to  the  actual  programme  structures  and 
irregularities detected. The best possible choice must be made.   

The  AMIF managing authority: Category  No  6  in the IMS, ‘Type of irregularities’, since, 
often, not enough information is available. Obtaining information is often time-consuming.   

The Federal Office for Agriculture and Food (BLE):   

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State 

Response 

2.1.2  ‘National  identification  number’,  2.1.3,  2.1.4:  as  a  rule,  this  information  is  not 
requested in advance, for example identity cards or the like do not have to be presented 
for aid to be granted, and the holding number is not necessarily requested if the aid is not 
area aid under direct payments. 2.1.7 ‘Parent company’.   

The Baden-Württemberg managing authority:   
3.11  ‘Priority  axis’  and  3.12.  ‘Operation(s)’,  as  this  priority  axis,  which  underlies  the 
programme, is not available. 6.8.1–6.8.3 ‘Detailed information on the irregularity’: here too 
the options do not correspond to reality / it is difficult to classify specific projects. In general, 
the  fact  that  fields  3.11  and  3.12  and  6.8.1  to  6.8.3  are  mutually  dependent  poses  a 
challenge, as, while the selection made in the first field is not necessarily appropriate, it is 
necessary in order to reach the more precise options in the following fields. 

Danish Business Authority:  
-  The  financial  scope  (amounts  involved  and  amounts  recovered)  as  this  information  is 
often  only  available  as  preliminary  assessment  at  the  time  of  the  first  report  and  may 
change as further checks, administrative decisions and possible amounts are recovered.  
-  Classification  of  the  irregularity,  including  the  assessment  of  whether  it  is  a  case  of 
suspected fraud, since the final classification  often only can be determined  after further 
examination and possible investigation.  
- Administrative and legal follow-up since the necessary information to fill in the required 
fields often relies on information from other authorities. 

For us, the most time-consuming item is IMS field 6.1 (the date on which the information 
was  received  that  led  to  the  suspicion  that  an  irregularity  had  been  committed).  This 
information  has  to  be  identified  from  multiple  sources  and  cannot  be  retrieved 
automatically. 

Field 10 on the development of court decisions. More specifically, judicial authorities do 
not inform the reporting authorities of any notified cases of suspected fraud. Consequently, 
the reporting authorities cannot update these cases. 

- Details of the projects and operations affected by the irregularity.  
- Obtaining information on ongoing or open cases, given the confidential nature of such 
proceedings, which would affect IRQ3 communications.  
-  Obtaining  final  judgments  and  the  information  to  be  included  in  IMS  for  IRQ5 
communications.  
- Information for updating fields 9 on actual repayments 

DK 

EE 

EL 

ES 

FI 

Sanctions are the most challenging fields, as judicial processes typically take a long time. 

FR 

The cancellation of an irregularity following a court decision removes all or some of the 
data already entered in IMS, in particular the modus operandi, which makes it  difficult to 
trace operations. 

Contribution from the Ministry of Agriculture, Forestry and Fisheries (Paying  Agency for 
Agriculture, Fisheries and Rural Development):  
Case update field, in the case where refund is requested from the user, the refund process 
sometimes takes a long time, which can make it difficult to update in a timely manner.  

HR 

Contribution  from  the  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  of 
Fisheries:  
Fields  on  classification  of  irregularity  as  "suspected  fraud"  and/or  "fraud",  taking  into 
account that such information should come from judicial authorities.  

Contribution from the Ministry of Labour, Pension System, Family and Social Policy:  
4.3 Total amount of irregularity  
8.2 Amount of irregularity  

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Member 
State 

Response 

8.2.1 whereof not paid  
8.2.2 whereof paid  
9.5 Amount recovered  
9.14 Recovery measures already taken  
10.5 Status of procedure  
10.6 Sanctions  

Contribution from the Ministry of Regional Development and EU funds:  
Section 10 of the IMS (Sanctions) – information on reported fraud to the State Attorney's 
Office of the Republic of Croatia and EPPO and actions taken or proceedings initiated is 
provided only on request and in a very limited scope. The proceedings themselves take a 
very long time, so there are long periods when there is no information to report. The same 
situation applies to criminal/civil court proceedings  – some cases are pending for a very 
long time, and information on the progress of the proceedings is not available.   

For  the  IMS  users  the  most  difficult  task  is  obtaining  accurate,  complete,  and  timely 
information for the following system points:   
2.2. NUTS levels   
The system does not allow a single User to select multiple NUTS regions.  

3.11. Priority and 3.12. Theme   
The options  offered  in the  IMS are not consistent with the Decision  on Irregularity form 
4.1.4. Expense  amount and 4.1.5.  Irregularity  amount  – difficulties occur when entering 
data  due  to  dependency  on  data  given  by  other  employees,  which  can  sometimes  be 
contradictory and inadequate.  

6.9. Modus operandi   
A  large  portion  of  the  data  that  would  cover  Modus  operandi  as  in  the  Decision  on 
Irregularity is also entered in point 11. Comment: it should be clarified in more detail what 
is entered where.  

8 and 9  
Everything regarding the amount and refund, as it depends on data employees provide, 
as well as 4.1.4 and 4.1.5. 

The programmes’ national monitoring system provides accurate and timely information for 
completing  the  IMS.  In  cases  of  suspected  fraud,  due  to  the  time  needed  to  conduct 
criminal proceedings, the final information is available only after a lengthy period, which 
has an impact on the completion of the Type of irregularity, Modus operandi, Classification 
of the irregularity and Sanctions fields. 

6.8.1 Category  

6.8.2 Type  

6.8.3 Type of irregularity  

6.9 Modus operandi 

There have not been any issues in any of the areas. 

To date, the financial crime investigation service does not yet have access to this system 
but will soon. 

N/A 

HU 

IE 

IT 

LT 

LU 

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Member 
State 

Response 

LV 

MT 

NL 

PL 

PT 

RO 

SE 

SI 

SK 

Problematic  receipt  of  timely  information  in  cases  where  information  is  received  from 
investigative authorities (e.g., IMS fields 6.1., 6.7., 7.1.) 

No  difficulties  are  encountered  due  to  continuous  communication  with  the  Managing 
Authorities, Paying Agency, Audit Authority and Certifying Body of EU funds. 

For  the  PA,  the  system  provides  the  possibility  to  update  the  fields,  and  additional 
information can therefore always be added until a case is closed. Constantly keeping track 
of this information is time-consuming, which makes it particularly difficult. 

In some cases, in which criminal proceedings are still ongoing, it is difficult to obtain up-to-
date  data  from  law  enforcement  authorities  due  to  the  confidentiality  of  proceedings.  In 
particular, this concerns cases where the reporting institution was not the party that sent 
the notice of a possible criminal offence.   

Due to the specific nature of criminal cases and the nomenclature used in court judgments, 
it is sometimes difficult for the reporting institution to establish all those personal data of a 
convicted natural person that must be included in the IMS reporting form. This is because 
in  their  judgments,  courts  do  not  always  include  information  such  as  the  personal 
identification  (PESEL)  number  or  the  registered  residence  address  of  the  person 
concerned. Particularly long criminal cases, i.e. those whose duration significantly exceeds 
the financial perspective concerned, constitute a separate category of case.   

Another problematic issue is how to properly reflect the type of criminal penalties imposed 
by courts using the list of options available in IMS (tab 10). 

6.7 Irregularity committed on / between; 6.8 Type of irregularity e 6.9 Modus operandi. 

Procedures/sanctions 

We do not see any difficulties in this regard. 

The date when a suspicion of fraud was detected. 

Fields in Chapter 10 – Sanctions. For CAP - fields related to other proceedings (judicial, 
criminal  proceedings)  and  fields  related  to  the  nomenclature  of  individual  payment 
requests. 

Q.2.5 (All entities involved with fraudulent irregularities) How do you try 
to  balance  the  confidentiality  of  investigations  with  the  necessity  to 
report? 

Member 
State 

Response 

AT 

Austria has clear legal rules on data protection and confidentiality and the need to report. 

BE 

      -       

PSW ERDF Wallonia:    
(PSW)  Access  to  information  is  restricted  and  only  OLAF  representatives  or  people  in 
charge of collecting reports know the contents of the file in order to prevent any data leak. 
At  the  level  of  investigations  within  the  administration,  only  the  people  in  charge  of 

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Member 
State 

Response 

investigations are informed of the contents of the file. Reports are made by means of a 
platform for reporting irregularities, via the integrity officer, or via the OLAF Working Group. 
At the level of the judicial authorities, only the people who submit the files and the judges 
in charge of the investigation know the contents of the file. They are communicated to the 
judicial authorities by official report.   

ERDF and RRF Brussels Capital Region:    
It  is  a  question  of  weighing  up  the  principle  of  confidentiality  against  the  duty  to  report, 
complying  with  the  rules  and  guidelines  on  reporting  and  applying  the  principle  of  data 
minimisation (whereby an objective is to be achieved using as little confidential or sensitive 
information as possible).  

EUROPA WSE (ESF VL):  
Investigations are performed by different colleagues than the personnel of ESF Flanders 
(VSI  instead  of  Europa  WSE).  As  such  confidentiality  is  mostly  contained  within  their 
investigations, while we only receive the results. 

In  accordance  with  national  legislation  and  methodological  guidelines  issued  by  the 
AFCOS Directorate, the reporting organisations shall promptly report the information that 
has become known to them through the investigations initiated 

Only  dedicated  staff  is  involved  in  reporting;  information  is  saved  in  locked  folders 
accessible  only  to  dedicated  staff.  The  reporting  duty  is  only  assigned  to  the  dedicated 
team. 

Official investigations are usually conducted under legislation such as the Control Code 
and  the  Tax  Code,  which  include  confidentiality  obligations  for  investigators.  The  same 
confidentiality  arrangements  apply  to  law  enforcement  authorities.  The  confidentiality  of 
investigations is thus guaranteed by confidentiality obligations.   

Communication without undue risk of exposure to persons without authority or jurisdiction.   

By limiting the number of interested parties, and by passing on information according to 
the rules (Code of Ethics).   

BG 

CY 

Notifications are issued only by selected staff. Documents and information relating to an 
investigation are never stored on a shared disk; they are cloud-based (SharePoint) and 
accessible only to the staff involved in the investigation. This means that information flows 
in a timely and secure manner.   

CZ 

We achieve an appropriate balance between ensuring the confidentiality of investigations 
and reporting obligations through strict compliance with the rules and robust protection of 
sensitive data. Upon request, the managing authority (MA) provides the law enforcement 
authorities with all the necessary documentation. Once the case has been transferred the 
MA fully respects the confidentiality of the criminal proceedings and is prohibited from any 
form  of  involvement  therein.  Communication  may  take  place  provided  it  does  not 
undermine the investigation or the rights of those concerned.   

As such it is possible to comply with  the  legal  obligation to report serious suspicions of 
fraudulent conduct without  prejudice  to the  integrity  of ongoing  investigations,  for which 
the law enforcement authorities have sole responsibility. 

The Lower Saxony ERDF managing authority:   
All the necessary information is already requested as part of the ongoing funding process. 
Where there are reasonable grounds to suspect fraud, the investigation is referred to the 
competent public prosecutor’s office.   

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The EU Paying Agency for Lower Saxony, Bremen and Hamburg: Secure data exchange 
through data exchange platforms.   

The ESF Plus Federal Programme, led by the Federal Ministry of Labour and Social Affairs 
(BMAS):   
Access to OLAF is restricted to a selected group of people.   

The  Schleswig-Holstein  ERDF  managing  authority:  Confidentiality  between  the  bodies 
involved is guaranteed by having separate systems.   

The Bremen ERDF managing authority:   
Beneficiaries  submit  a  list  of  all  supporting  documents  to  the  intermediate  bodies  when 
making  payment  claims.  A  sample  is  taken  from  this  list.  Accordingly,  the  individual 
supporting documents are requested and made available electronically to the intermediate 
bodies. If suspicions of possible fraud arise in the context of the administrative check, the 
sample is enlarged and additional supporting documents are requested. If the suspicions 
are confirmed, a report is  made to the public prosecutor’s  office.  At the same  time, the 
managing authority is informed.   

The AMIF managing authority:   
As  regards  reporting  to  national  bodies  (ministries,  supervisory  authorities,  public 
prosecutor’s offices), confidentiality is ensured by various national rules in laws, guidelines 
and  control  systems.  Moreover,  the  number  of  people  who  are  privy  to  the  information 
should  be  as  low  as  possible  and  limited  to  what  is  necessary.  Hence  the  respective 
responsibilities of the employees are clearly defined and restricted. Staff are instructed not 
to  disclose  information  to  unauthorised  persons.  In  the  ITSI  IT  system  for  home  affairs 
funds, it is ensured that beneficiaries can only view information on the projects that they 
have made an application for and are to carry out.   

The Thuringia ERDF managing authority:   
Investigations  are  carried  out  as  part  of  the  examination  of  documents  or,  where 
applicable,  consultation  procedures  or  preliminary  checks  with  short  or  medium  time 
frames. It is also possible to report suspicions anonymously.   

The Brandenburg ERDF managing authority:   
Confidentiality obligation, sensitive handling of data, reporting and activities undertaken by 
competent persons only (very small group). 

Danish Business Authority:   
Balance  is  ensured  by  reporting  in  IMS  at  an  overall  and  factual  level  without  sharing 
information  that  could  negatively  impact  ongoing  investigations.  Reporting  is  based  on 
available information and updated when it is possible to share new information, taking into 
account confidentiality.  

Danish Agricultural and Fisheries Agency:   
To remain vigilant in providing necessary information to relevant authorities and protecting 
information in accordance with GDPR. 

We  balance  the  confidentiality  of  investigations  with  reporting  obligations  by  strictly 
following  the  legal  framework  governing  access  to  investigative  information.  Criminal 
investigations  are  handled  by  the  competent  investigative  prosecutor,  who  determines 
what information can be shared with other authorities. As a result, Estonian authorities do 
not receive operational details that could compromise confidentiality. Reporting is therefore 
based solely on information that can be disclosed without affecting the investigation, and 
we rely on the implementing bodies to provide the elements that may be shared.   
This  approach  ensures  that  sensitive  investigative  information  remains  protected,  while 

DK 

EE 

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Response 

Estonia can still meet its reporting obligations to OLAF and the Commission using verified, 
non‑confidential data. 

EL 

In such circumstances, it is stated that the case is under investigation, so any information 
is limited to details that are strictly necessary and do not affect the audit of the case. 

Through a thorough analysis of each case and the identification of those allegedly affected. 
This  process  makes  it  possible  to  determine  what  information  is  essential  for  the 
intermediary bodies, while protecting the integrity of the investigation and the privacy of 
the  individuals  involved,  seeking  a  middle  ground  where  transparency  does  not 
compromise  the  effectiveness  of  the  investigation  or  cause  unnecessary  harm  to  third 
parties.  
Likewise, by eliminating irrelevant personal data, referring to the obligation to comply with 
personal  data  protection  regulations  and  using  passwords  to  open  files,  as  well  as  by 
transmitting communications through internal systems, such as the Civil Guard's Internal 
Investigation Management System.  

ES 

FI 

FR 

HR 

In  the  case  of  the  AFCOS  Infofraude  reporting  channel,  which  is  intended  to  receive 
information  on  fraud,  irregularities  or  any  other  illegal  activity  affecting  the  financial 
interests of the EU, as well as the internal information channels of some authorities, reports 
may  be  submitted  anonymously.  For  those  whistleblowers  who  decide  to  report  non-
anonymously, the application of Law 2/2023 of 20 February, regulating the protection of 
persons  who  report  regulatory  infringements  and  the  fight  against  corruption,  is 
guaranteed. 
the 
whistleblower's identity is guaranteed, so that it will not be disclosed to anyone. To this 
end, in all communications, verification actions or requests for documentation carried out 
by AFCOS, data relating to the identity of the person who submitted the information, as 
well as any other data that could lead to their total or partial identification, will be omitted. 
Confidentiality clauses are also included in all written requests for information that are sent.  

the  case  of  non-anonymous  reports, 

the  confidentiality  of 

In 

In the case of irregularities detected and reported in the first instance by the authorities 
responsible  for  fund  management,  which  have  been  referred  to  the  European  Public 
Prosecutor's Office by them, there would in principle be no confidentiality issues because 
most of the data is known to those authorities for communication purposes.  
In  cases  other  than  these,  when  AFCOS  becomes  aware  of  an  investigation  by  the 
European  Public  Prosecutor's  Office  and  requests  information  for  communication 
purposes via IMS, it is the European Public Prosecutor's Office that decides what data it 
can or cannot provide. 

Reporting  focuses  only  on  the  necessary  data;  data  protection  and  data  security  are 
ensured. 

If an irregularity with an intentional element is found during an investigation, Article 40 of 
the Code of Criminal Procedure requires that this irregularity be reported to the competent 
public prosecutor’s office. 

Contribution from the Ministry of Agriculture, Forestry and Fisheries (Paying  Agency for 
Agriculture, Fisheries and Rural Development):  
Data is updated respecting data entry by authorised IMS users.  

Contribution  from  the  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  of 
Fisheries:  
We  include  as  much  as  possible  information  on  irregularity,  which  is  detected  by 
administrative  authorities,  excluding  only  confidential  information  as  instructed  by 
authorities that are conducting investigation.  

Contribution from the Ministry of Regional Development and EU funds:  
In most cases, this is not a problem, since we only receive specific information after the 

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Member 
State 

Response 

confidential actions are completed, so limited reporting through IMS does not represent a 
violation  of  confidentiality.  Certain  information  that  we  find  out  while  the  action  is  in 
progress is usually not relevant for reporting.   
In exceptional cases, we would try to report confidential information through a general note 
without violating confidentiality, and in the case that this exact information it is extremely 
important for reporting - the request should be sent directly to the competent authority for 
approval of reporting. 

When  the  judicial  body  informs  the  reporting  authority  about  proceedings  relating  to  a 
fraudulent case, it is then possible to record it in the IMS. 

This varies on a case-by-case basis. Generally, stakeholders are only informed on a need-
to-know basis. 

The  balance  between  the  confidentiality  of  investigations  and  the  need  for  reporting  is 
ensured (subject to formal authorisation by the prosecuting judicial authority) through the 
transmission of essential information in a proportionate and timely manner, in compliance 
with confidentiality constraints, the duty of investigative confidentiality and data protection 
legislation. Reports are updated periodically, providing additional information as soon as it 
is  compatible  with  the  progress  of  the  investigation,  in  close  coordination  with  the 
competent authorities. In the event of pending criminal proceedings, the judicial authorities 
are  continually  informed  of  the  need  to  provide  updated  data,  in  part  because  the 
characterisation of the irregularity could be changed. 

We  trust  our  partners,  so  we  always  report  violations  when  we  see  them  without 
compromising our investigation (in case of an ongoing investigation). 

As  soon  as  a  suspicion  of  fraud  rises  it  will  be  reported  to  the  judicial  authorities.  The 
confidentiality would not play a role. 

Reporting is carried out in accordance with the EPPO guidelines and in compliance with 
the  requirements  set  out  in  regulatory  enactments.  Regarding  internal  investigations,  a 
clear  separation  between  internal  investigations  and  mandatory  reporting  has  been 
assessed and established, through initial fact-finding and assessment. 

As explained in Question 1.6, a quarterly Irregularity Reporting Sub-Group meeting is held 
to ensure correct and complete reporting of irregularities and suspected cases of fraud in 
line with standing reporting obligations. 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

We anonymise the information. 

PL 

PT 

Reporting institutions have guaranteed access to the minimum information necessary to 
carry  out  their  duties,  with  the  confidentiality  of  proceedings  being  maintained.  A  key 
aspect is to maintain balance, i.e. for the authorities to send only the information necessary 
to complete the tasks without disclosing evidentiary details or sensitive data. 

Cases of irregularity with signs of fraud are reported, provided there is no confidentiality 
clause (on the key elements of cases) that may block such reporting.   

All  detected  cases  of  irregularity  with  signs  of  fraud  are  covered  by  the  confidentiality 
clauses laid  down  in the particular administrative  act  to which the  handling  of a  case is 
subject.  If,  during  the  correction  process,  the  judicial  body  imposes  another  level  of 
confidentiality, that new level becomes applicable immediately. 

RO 

Compliance with regulations on the confidentiality of criminal investigations.  
Requesting authorisation to report on a case-by-case basis 

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Member 
State 

Response 

SE 

SI 

SK 

Ongoing  registered  cases  are  kept  confidential  in  the  registration  system.  The  parties 
involved in the proceedings are informed. 

Recovery  and  Resilience  Office:  We  proceed  in  line  with  the  guidelines  of  the  law 
enforcement bodies. Irregularity reports include only information that does not jeopardise 
investigations. The MKRR explains: Basic information on the suspicion of fraud detected 
is  always  provided/reported.  Other  information  that  has  come  to  light  by  the  time  the 
irregularity is closed is provided at that stage. 

We receive only the amount of information required to meet the reporting rules of the IMS. 
This information does not include any sensitive information or operational details related 
to investigation. 

Q.2.6 (AFCOS) How does your system enable timely follow-up to cases in 
IMS? 

Member 
State 

Response 

In  Austria,  the  AFCOS  is  set  up  purely  as  a  coordination  body.  It  does  not  have  any 
investigative  powers  of  its  own  in  the  area  of  funding.  However,  each  responsible 
department has an audit authority and a paying body. Each department is obliged to report 
irregularities for each fund. It is therefore not possible for Austria’s AFCOS to track cases 
in IMS.   

AT 

Data entered in IMS is available / retrievable at any time 

Belgian AFCOS:  
Recently  the  role  of  country  officers  within  the  IMS  system  has  been  taken  up  by  the 
Secretariat  of  the  BE  AFCOS.  It  is  still  up  to  the  partner  authorities  to  report  their 
irregularities  directly  into  the  system.  If  there  are  data  quality  issues,  we  contact  our 
respective liaison officers ensuring an update of the data surrounding these irregularities.  

BE 

PSW ERDF Wallonia ERDF, JTF and RRF at the PSW level:   
The OLAF working group meets quarterly. It is charged by the Walloon government with 
reporting  irregularity  cases  to  OLAF  where  this  is  required  or  reporting  an  absence  of 
irregularity cases, pursuant to EU rules and with reference to the European Development 
Fund  (ERDF),  the  Just  Transition  Fund  (JTF)  and  Wallonia’s  parts  of  the  National 
Recovery  and  Resilience  Plan  (NRRP)  and  the  Brexit  Adjustment  Reserve  (BAR).  The 
working  group  is  made  up  of  members  representing  the  various  administrations 
responsible.  Minutes  are  taken  of  all  OLAF  working  group  meetings.  These  set  out  the 
proposals put to the working group members for examination, and, for in-person meetings, 
the decisions taken by the working group, as well as all the related documents sent to all 
members 
to  OLAF 
electronically.  If,  for  the  period  concerned,  there  are  no  irregularities  that  need  to  be 
reported, the secretariat also reports this fact to OLAF electronically. Suspicions of fraud 
involving criminal offences are passed on to the Belgian judicial authorities.   
The processes for reporting internal and external irregularities were put in place in 2023. 
The  procedures  for  processing  and  rectifying  irregularities  or  the  integrity  officer’s 
procedure for internal fraud management as part of the internal reports are being drawn 
up.    

the  meeting.  The  secretariat  reports 

irregularities 

following 

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Member 
State 

Response 

The  ESF  Agency  takes  part  in  the  OLAF  Working  Group  chaired  by  the  PSW  and 
contributes to its work for the ESF and AMIF programmes. 

The  national  legislation  and  the  methodological  guidelines  issued  by  the  AFCOS 
Directorate precisely describe the grounds for creating a follow-up notification for tracking 
cases in IMS. Employees from the reporting organisations are periodically trained on these 
rules and an opportunity is created to discuss emerging issues and cases 

Irregularities deducted nationally are first withdrawn from EU funding and then reported to 
IMS so therefore no follow-up is required. 

By  continuously  assessing  the  data  in  the  IMS,  identifying  any  deviations  and  critical 
states, observing trends and evolution; possibility of rapidly updating data.    

Procedures are in place for certain activities such as the continuous updating of cases and 
their enforcement. Prevention also works insofar as individual errors are analysed in terms 
of their potential impact on other funds, other related projects, etc. In such cases, an on-
site  public  administrative  check  may  take  place  and,  if  necessary,  the  project  may  be 
suspended, and the grant may even be withdrawn.    

Monitoring in IMS, regular reporting; those responsible monitor the status of open cases.    

Compliance with established internal procedures in accordance with the timelines set in 
internal guidelines and legislation. 

The Lower Saxony ERDF managing authority:   
Reporting deadlines have been set for relevant cases.   

The Bremen ERDF managing authority:   
The managing authority records reportable irregularities in the IMS within two months of 
their  detection.  If  an  attempt  at  fraud  is  confirmed  by  the  public  prosecutor’s  office,  the 
original alert is adjusted accordingly.   

The AMIF managing authority:   
The  complete  recording  of  cases  in  the  IMS  always  takes  place  in  a  timely  manner,  in 
accordance with the requirements set out in the manual on handling irregularities and the 
IMS guidance document, our management and control system and our internal guidelines. 
This recording is monitored by our supervisory authority, the Federal Ministry of the Interior 
(BMI).  Comments  and  amendments  by  the  BMI  are  always  taken  into  account  and 
incorporated.   

The Thuringia ERDF managing authority:   
Reconciliation of irregularities on a monthly basis and where necessary. 

Danish Business Authority:   
We manually follow up on cases both internally and with relevant authorities to ensure that 
new information is registered as soon as possible.  

Danish Agricultural and Fisheries Agency:   
Effective  communication  with  other  relevant  administrative  authorities  in  the  reporting 
process. 

Estonia  ensures  timely  follow‑up  to  cases  in  IMS  through  national  case‑management 
systems, where all irregularities are processed in accordance with established procedures. 
Each case is monitored throughout its lifecycle, and implementing bodies are responsible 
for ensuring that all necessary steps are taken without delay. Once national procedures 
progress, the relevant information is uploaded to IMS. IMS is updated on a quarterly basis, 
in line with the Commission’s reporting requirements.   

BG 

CY 

CZ 

DE 

DK 

EE 

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Member 
State 

Response 

Because the primary case handling takes place in secure national databases, follow‑up 
actions  are  carried  out  promptly,  and  IMS  is  updated  systematically  based  on  the 
developments recorded in the national systems. 

The Greek AFCOS does not monitor cases in the IMS. This falls within the remit of EDEL 
and the Ministry of Rural Development and Food. 

A quarterly check is carried out by cross-referencing all data relating to IRQ3 and IRQ5 
reported  in  IMS  and  requests  for  relevant,  discrepant  or  necessary  information.  Any 
changes  detected  in  relation  to  the  previous  quarter  are  consulted  with  the  relevant 
authority to verify their origin, requesting correction if necessary, and following up on this.  
Any update to information known to AFCOS through any channel, which involves a change 
in  IMS,  is  communicated  to  the  authority  responsible  for  such  communication  and  is 
followed up until the update is confirmed in IMS. 

All the essential information relating to suspected fraud and irregularities and their current 
status is stored in the system. 

EL 

ES 

FI 

FR 

The AFCOS is not responsible for such follow-up in France. 

Contribution by the Croatian AFCOS unit:  
The  AFCOS  unit  has  developed  guidelines  on  the  management  of  irregularities  for  the 
authorities of the management and control system for the use of EU funds. The guidelines 
set the time limit for complying with the obligation to submit initial and follow-up reports to 
the AFCOS unit, which then checks the quality of the reports submitted. If corrections need 
to  be  made,  the  AFCOS  unit  sends  the  reports  back  to  the  reporting  authority,  giving 
appropriate instructions.   
The  guidelines  also  state  that,  on  a  quarterly  basis,  the  person  responsible  for  the 
irregularity case must check whether new circumstances have arisen in relation to the case 
reported and, if so, draw up a follow-up report in the IMS system. 

Reporting  authorities  typically  fulfil  their  follow-up  obligation  by  regularly  checking  the 
information in their own records. It is also worth noting in relation to IRQ3 cases that there 
is a single-channel exchange of information between the development policy institutional 
system and the investigating authority, which also helps ensure that IMS data are up to 
date. 

AFCOS  have quarterly  network meetings where the  need for  all reporting  authorities to 
follow-up on cases is stressed. 

The alert management system allows for timely follow-up of cases through a detailed and 
exhaustive preliminary assessment and investigation phase, as well as a continuous focus 
on  the  progress  of  the  procedures  launched.  If  this  analysis  reveals  critical  issues, 
information  anomalies  or  significant  risk  elements,  the  necessary  investigations  and 
information flows to the competent authorities and bodies are promptly activated, ensuring 
the  traceability  of  the  activities  carried  out  and  the  timely  adoption  of  the  resulting 
measures. 

To date, the financial crime investigation service does not yet have access to this system 
but will soon. 

The audit authority handles the IMS. 

AFCOS is not involved in reporting / following-up cases in IMS. Each EU funds authority 
performs these functions independently. 

HR 

HU 

IE 

IT 

LT 

LU 

LV 

MT 

Through coordination with the Managing Authorities and Paying Agency of EU funds. 

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Member 
State 

Response 

NL 

Further developments in irregularities or suspicions of fraud are always recorded promptly 
in IMS. AFCOS: IMS is not yet being used. We are currently taking the administrative steps 
to organise this. 

The  process  of  reporting  irregularities  to  the  Commission  in  IMS  is  coordinated  and 
organised  by  the  national  AFCOS,  which  is  responsible,  among  other  things,  for 
developing the national procedure, i.e. a set of compulsory rules for the individual reporting 
institutions, including as regards the updating of cases. The AFCOS regularly monitors the 
status of cases reported to the Commission in terms of whether they can be updated or 
closed. In cooperation with individual reporting institutions, it also takes specific measures 
to ensure that the information from Poland concerning individual reports is as up to date 
as possible.    

The approaches adopted by the competent institutions allow the timely notification of the 
follow-up  actions  in  the  cases  reported  in  IMS,  thanks  mainly  to  inter-institutional 
cooperation  that  allows  up  to  date  information  to  be  obtained  as  necessary.  Such 
cooperation takes place, for example, on the basis of the cooperation agreement between 
the  National  Public  Prosecutor  and  the  minister  responsible  for  regional  development 
governing  the  transmission  of  information  on  ongoing  and  concluded  proceedings 
concerning  projects  cofinanced  by  European  funds.  In  addition,  institutions  carry  out 
periodic  reviews  of  cases,  monitoring  on  an  ongoing  basis  the  follow-up  actions  in  the 
proceedings being conducted. 

Procedures and mechanisms are in place for sending the information needed to follow up 
cases reported to OLAF. 

Periodic 
communication 

follow-up 

/  clear  procedures 

for  monitoring  cases 

/ 

interinstitutional 

OLAF reports are registered and are available on the authority’s common file space. 

Regular, timely reporting in place. 

Our  system  enables  timely  follow-up  to  cases  in  the  IMS  through  regular  notifications, 
defined  case  processing  deadlines,  clearly  assigned  responsibilities,  and  regular 
monitoring of case status. Cases are continuously updated, tracked with status indicators, 
and escalated to the appropriate management level in case of delays. Deployment of the 
“Reports  to  OLAF”  module  enables  the  AFCOS  to  export  reported  irregularities  from 
ITMS2014+ and ITMS21+ to the IMS system export irregularities to OLAF’s IMS platform.  

AFCOS  regularly  obtains  information  about  initiated,  ongoing  and  completed  criminal 
proceedings  based  on  the  Cooperation  Agreement  concluded  with  the  General 
Prosecutor's  Office  of  the  Slovak  Republic,  the  Ministry  of  the  Interior  of  the  Slovak 
Republic and on the basis of the Act No. 91/2016 Coll. on the Corporate Criminal Liability.  
MA/IB/AA/CA/PA regularly informs AFCOS in accordance with the procedures and rules 
of the process for reporting irregularities, including their updates, set out in the Manual for 
Reporting Irregularities issued by AFCOS. 

PL 

PT 

RO 

SE 

SI 

SK 

Q.2.7  (AFCOS)  In  which  areas  of  reporting  have  you  encountered 
problems  when  creating  or  updating  cases?  Cooperation  with  national 
administrative bodies 

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Response 

Minor issues 

Frequency  Percentage 

Member States 

3  11.1% 

BE, CY, ES 

No issues 

24  88.9% 

AT, BG, CZ, DE, 
DK,  EE,  EL,  FI, 
FR, HR, HU, IE, 
IT,  LT,  LU,  LV, 
MT, NL, PL, PT, 
RO, SE, SI, SK 

Q.2.7  (AFCOS)  In  which  areas  of  reporting  have  you  encountered 
problems  when  creating  or  updating  cases?  Cooperation  with  national 
investigative bodies 

Response 

Minor issues 

Serious issues 

Frequency  Percentage 

Member States 

7  25.9% 

CZ, DK, EL, HR, 
HU, PL, SK 

2  7.4% 

CY, ES 

No issues 

18  66.7% 

AT, BE, BG, DE, 
EE,  FI,  FR,  IE, 
IT,  LT,  LU,  LV, 
MT,  NL,  PT, 
RO, SE, SI 

Q.2.7  (AFCOS)  In  which  areas  of  reporting  have  you  encountered 
problems  when  creating  or  updating  cases?  Cooperation  with 
international administrative bodies 

Response 

Minor issues 

Serious issues 

Frequency  Percentage 

Member States 

1  3.7% 

1  3.7% 

PL 

ES 

No issues 

25  92.6% 

      -       

AT, BE, BG, CY, 
CZ, DE, DK, EE, 
EL,  FI,  FR,  HR, 
HU,  IE,  IT,  LT, 
LU, LV, MT, NL, 

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Response 

Frequency  Percentage 

Member States 

PT, RO, SE, SI, 
SK 

Q.2.7  (AFCOS)  In  which  areas  of  reporting  have  you  encountered 
problems  when  creating  or  updating  cases?  Cooperation  with 
international investigative bodies 

Response 

Minor issues 

Serious issues 

Frequency  Percentage 

Member States 

3  11.1% 

EL, PL, SK 

2  7.4% 

CY, ES 

No issues 

22  81.5% 

AT, BE, BG, CZ, 
DE, DK, EE, FI, 
FR, HR, HU, IE, 
IT,  LT,  LU,  LV, 
MT,  NL,  PT, 
RO, SE, SI 

Q.2.7  (AFCOS)  In  which  areas  of  reporting  have  you  encountered 
problems when creating or updating cases? Other (please specify) 

Response 

Minor issues 

Serious issues 

Frequency  Percentage 

Member States 

1  3.7% 

IE 

2  7.4% 

EE, ES 

No issues 

24  88.9% 

AT, BE, BG, CY, 
CZ, DE, DK, EL, 
FI, FR, HR, HU, 
IT,  LT,  LU,  LV, 
MT, NL, PL, PT, 
RO, SE, SI, SK 

Following Q2.7, please specify "Other". 

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Member 
State 

Response 

EE 

The main reporting difficulties arise in relation to cases under EPPO investigation.   
Due  to  the  EPPO  Regulation,  AFCOS  does  not  receive  operational  information  on 
EPPO‑led  investigations.  This  means  that  Estonia  cannot  access  the  details  needed  to 
create or update IMS cases beyond the limited information that implementing bodies are 
allowed  to  share.  As  a  result,  reporting  on  EPPO  cases  is  constrained  by  the  strict 
confidentiality rules that prevent the transmission of investigative information to AFCOS. 

ES 

Cooperation and exchange of information with judicial authorities 

Saying 'minor issues' solely to add narrative here.  

IE 

AFCOS have consulted with each reporting authority, and the feedback received stressed 
good cooperation with all of the above-mentioned stakeholders. The cooperation involves 
the reporting authorities. AFCOS has a limited role. 

Q.2.8  (AFCOS)  Please  feel  free  to  share  any  additional  thoughts  or 
experiences  you  have  regarding  the  topics  discussed  in  this  section  or 
support you require from the Commission/OLAF regarding them. 

Member 
State 

Response 

AT 

BE 

DE 

EE 

      -       

Each  department  (in  Austria,  seven  departments  are  involved)  is  obliged  to  report 
irregularities and provide reports for the respective fund. 

Belgian AFCOS:  
Currently  a  lot  of  information  concerning  IMS  is  posted  in  the  ALIB  library.  This  library 
contains a high number of guidelines, instructions, ...that in reality partners get lost in the 
sea of documentation. We  would like to  obtain  one  pager’s summarizing  the necessary 
steps to ensure compliance with the set-up created by OLAF. This will help to boost quality 
levels of cases throughout the network. 

The Lower Saxony ERDF managing authority:   
The future systems (e.g. Arachne+) should be mandatory in the light of extensive testing 
phases and information. Up-to-date information on new developments in the IMS reporting 
process.   

The ESF Plus Federal Programme, led by the Federal Ministry of Labour and Social Affairs 
(BMAS):   
Unfortunately, the OLAF IMS is not self-explanatory. Mandatory fields are not adequately 
described.  Dependencies  are  inadequate,  so  there  is  a  regular  need  for  revision.  The 
search function is limited.   

The Thuringia ERDF managing authority:   
OLAF’s feedback is rather lengthy. The reporting channels from OLAF to other units of the 
European Commission are not very transparent. 

Estonia would welcome further support from the Commission and OLAF in areas where 
regarding  EPPO‑led 
national  authorities 
investigations.   

limitations,  particularly 

face  structural 

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Member 
State 

Response 

While the current guidance is clear and workable, we see a need to further harmonise IMS 
pick‑lists and their practical use across Member States. More consistent definitions and 
clearer  distinctions  between  categories  would  improve  comparability  and  enhance  the 
value of OLAF’s analyses. In addition, pick‑lists should be aligned with those used by other 
Commission  services  (for  example,  EC  auditors)  to  ensure  coherence  across  different 
reporting and control systems and to avoid parallel or inconsistent classifications   
We  would  also  welcome  the  creation  of  a  dedicated  working  group  or  network  for  IMS 
Country Officers.   
Such a platform would support regular exchanges, promote consistent reporting practices, 
and strengthen cooperation between Member States and OLAF, especially in areas where 
national approaches differ or where reporting is affected by external constraints. 

EL 

The new revision of Regulation (EU, Euratom) No 883/2013 should stipulate that national 
anti-fraud strategies in the Member States will be drawn up exclusively by the AFCOSs. 

There are a number of irregularities that are sometimes not reported or are reported late, 
and which AFCOS is unable to follow up properly, such as:  

- Irregularities reflected in OLAF reports. The reports are not received by AFCOS, which 
means that it cannot follow up either the IMS communication or the adoption of corrective 
measures. One possible improvement would be to inform AFCOS when the Commission 
sends the Member State the OLAF recommendations and report, so that it can follow up 
on the corresponding communication.  

ES 

- Cases referred by OLAF to the European Public Prosecutor's Office. No information is 
obtained  on  these  cases.  In  order  to  improve  communication,  it  would  be  advisable  for 
OLAF to notify AFCOS of cases that it has referred to the European Public Prosecutor's 
Office, so that these can be followed up and communicated appropriately. If, for reasons 
of confidentiality, this cannot be done at the initial stage, it could be done at a later stage 
of the proceedings, such as at the start of the trial phase.  

Furthermore, a common point of contact could be created between AFCOS, OLAF and the 
European Public Prosecutor's Office to facilitate the exchange of information, also for the 
purposes  of  communication  in  IMS,  given  that  on  occasions  the  same  information  is 
received by the three institutions without there being proper coordination.  
It  would  be  desirable  for  the  Commission  to  standardise  protocols  and  issue  clear 
guidelines  for  the  purposes  of  communication  and  information.  One  way  of  achieving 
complete and accurate communications within the deadline would be to establish some 
form  of  penalty  for  non-compliance,  including  financial  penalties,  depending  on  the 
seriousness of the breach and in accordance with the principle of proportionality. 

Contribution by the Croatian AFCOS unit:  
The  authorities  of  the  management  and  control  system  for  the  use  of  EU  funds  have 
difficulties  in  obtaining  timely  information  on  cases  in  which  criminal  proceedings  have 
been initiated, because Croatian legislation imposes restrictions on the disclosure of such 
information.  
Additionally, the prolonged duration of most criminal proceedings further complicates the 
follow-up and closure of cases. 

In order to promote uniform reporting at EU level, we recommend organising professional 
events focusing on the interpretation and practical application of EU legislation and OLAF 
guidelines. 

Data sharing/GDPR compliance is a significant issue that requires clarity and the need for 
a unique national identifier is a significant obstacle to coordinating anti-fraud measure This 
can limit the effectiveness of the use of Arachne. 

HR 

HU 

IE 

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Member 
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Response 

IT 

It  would  be  useful  if  the  European  judicial  authority  were  to  inform  the  administrative 
authorities responsible for managing the relevant European funds as soon as possible in 
cases of suspected fraud under investigation, within the limits permitted by the applicable 
legal framework and in accordance with the requirements of confidentiality and due regard 
for  the  confidentiality  of  investigations.  Moreover,  this  information  would  be  particularly 
helpful at the conclusion of ongoing investigations in cases where the managing authority 
could not otherwise have detected the case of suspected fraud. In such circumstances, 
notification  from  the  judicial  authority  may  be  the  only  means  by  which  the  managing 
authority was in a position to carry out the activities within its remit, including alerts in the 
IMS-OLAF system. The timely transmission of this information would also allow the case 
to  be  handled  properly,  efficiently  and  quickly,  including  from  an  administrative  point  of 
view,  in  line  with  the  responsibilities  assigned  to  managing  authorities  under  the 
programmes financed by the European Union. 

NL 

No further comments. 

PL 

PT 

SK 

Questions 1.2 and 1.4 are identical. It has been assumed that question 1.4 concerns the 
part of the anti-fraud cycle in which the institutions’ actions have had the least effect, and 
this is how the answer was approached. 

The national administrative bodies have been very cooperative, providing a great deal of 
information for the investigations conducted by OLAF and the national judicial bodies. 

AFCOS welcomes the continued support from the Commission and OLAF in improving the 
quality  and  timeliness  of  case  reporting  in  the  IMS.  In  particular,  we  consider  the  new 
version  of  the  Handbook  on  “Reporting  of  irregularities  in  shared  management”  to  be 
especially beneficial. We also positively assess initiatives aimed at the exchange of best 
practices  among  Member  States  and  the  workshops  organised  by  OLAF,  which 
significantly contribute to enhancing the professional capacities of the authorities involved. 

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

RECOMMENDATION  4  –  DIGITALISATION  AS  A  PILLAR  OF  THE  NATIONAL  ANTI-FRAUD 
STRATEGY  

The  Commission  reiterates  its  call  to  national  authorities  to  embed  the  digitalisation  of  the  fight 
against fraud in their national anti-fraud strategies, with the aim of: a) assessing the level of threat 
posed  to  the  EU  budget  by  the  rise  in  cybercrime  and  the  use  of  AI  and  other  innovative 
technologies,  in  particular  by  organised  crime;  b)  identifying  their  knowledge  and  skill  gaps  in 
relation to the deployment, development and  use  of  innovative technologies to  fight fraud  more 
effectively; c) identifying the actions needed to address such threats and vulnerabilities 

Q.4.1 Are there any AI tools that you use as part of your national anti-
fraud strategy or AFS to protect the financial interests of the Union? 

Response 

Frequency  Percentage 

Member States 

No 

21  77.8% 

Yes, as part of other AFS 

6  22.2% 

AT, BE, BG, CY, 
DE, DK, EE, EL, 
FI,  HR,  IE,  LT, 
LU, LV, MT, NL, 
PL, RO, SE, SI, 
SK 

BE, ES, FR, HU, 
IT, SI 

Yes, as part of the NAFS 

3  11.1% 

CZ, IT, PT 

Q.4.2 Please specify which AI tools you use as part of your NAFS? 

Member 
State 

Response 

CZ 

IT 

Automatic transcription and translation of wiretaps using AI: the main advantage of this is 
that  speakers  can  be  detected  and  identified  and  that  natural  language  queries  can  be 
asked  over  the  processed  texts  of  wiretaps.  We  are  also  able  to  create  automatically 
generated summaries of the text of wiretaps. The application is under development, with 
the focus on removing unwanted sounds in a recording, recognising foreign languages for 
better translation and extracting vital identities (of interest). 

The use of advanced technologies, including solutions based on artificial intelligence and 
machine  learning,  is  part  of  the  broader  process  of  strengthening  fraud  prevention  and 
detection  systems  promoted  in  particular  by  AGEA  (Agricultural  Payments  Agency).  In 
terms of planning and operations, AGEA has launched initiatives to modernise anti-fraud 
checks geared towards advanced data analysis and the detection of anomalous patterns, 
in line with developments in national and European anti-fraud strategies and the integrated 
use of risk analysis tools such as Arachne. 

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Member 
State 

Response 

PT 

With  a  view  to  increasing  the  effectiveness,  efficiency  and  proportionality  of  audits,  the 
AI4Audit project (funded by the Technical Support Instrument) has developed AI-derived 
models  to  detect  and  predict  irregularities  in  EU  funds.  This  makes  audits  less  work-
intensive and more accurate. 

Q.4.3 Please specify which AI tools you use as part of other AFS? Which AFS 
are they a part of? 

Member 
State 

Response 

BE 

ES 

FR 

HU 

IT 

SI 

FPS Finances (Customs disputes):   
SAS Enterprise Guide and Python – part of the risk management and selection strategy 

The  Strategic  Plan  of  the  Tax  Agency  uses  artificial  intelligence  tools  to  identify  risky 
operations in the field of e-commerce, both at the time of clearance and for subsequent 
controls.  The  specific  tools  used  are  algorithms  designed  in-house  by  the  Spanish  Tax 
Agency. 

Given  the  ever-increasing  level  of  sophistication  and  intensity  of  fraud  involving  public 
finances and the EU budget committed in cyberspace, it was deemed useful to organise 
effective  cooperation  between  the  State  services  responsible  for  combating  fraud  in 
cyberspace more specifically. The MICAF therefore intends to share maps of online fraud 
together with the most appropriate detection solutions (e.g. a benchmark for arrangements 
to analyse crypto-currency transactions). This flagship action is part of the new roadmap 
of the national anti-fraud strategy for the EU budget. 

In  2025  we  carried  out  AI  analyses  using  AI  models  and  solutions  developed  by  us.  In 
order  to  protect  tax  secrecy  and  personal  data,  our  solutions  operated  in  a  closed  IT 
environment and, where necessary, on anonymised datasets. Preparatory work has been 
carried out on the applicability of a large commercial AI platform (LLM). We carried out AI 
developments  for  fraud  detection  under  a  National  Tax  and  Customs  Administration 
strategy (tax strategy, IT sub-strategy). 

Verification mechanisms using artificial intelligence  have already been introduced in the 
fund management information system, SIF2127. Many processes are currently undergoing 
digital reprocessing, with artificial intelligence solutions also expected to be applied. 

Financial Administration of the Republic Slovenia:   
We use QlikSense (QS) portal as an IT analytic tool and self-developed applications for 
different  areas  of  our  responsibilities  within  QS  for  analytical  work,  risk  analyses,  risk 
management, and consequently for planning activities. AI, machine learning (ML), Insight 
Advisor and natural language processing (NLP) are integrated within QS.  Within QS, the 
Insight  Advisor  leverages  ML  and  NLP  to  understand  users’  questions,  automatically 
analyse data, and generate visual insights that explain what is happening and why. Qlik 
Intelligence features further use NLP and generative AI to translate insights and predictions 
into clear, natural-language explanations, enabling users to easily understand results and 
make data-driven decisions directly within QS. These features are currently used in our 
analytical work to a limited extent. 

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Q.4.4 (AI users) What are the main uses of Artificial Intelligence within 
your systems? 

Response 

Frequency  Percentage 

Member States 

Anomaly detection 

Predictive analytics 

Automated classification 

Natural language processing 

8  29.6% 

8  29.6% 

5  18.5% 

5  18.5% 

BE, CZ, ES, FR, 
HU, IT, PT, SI 

BE, CZ, ES, HU, 
IT, PL, PT, SI 

BE, CZ, ES, HU, 
IT 

BE, CZ, HU, LV, 
SI 

Pattern recognition 

4  14.8% 

BE, CZ, HU, SI 

Other (please specify) 

5  18.5% 

None 

17  63.0% 

BE,  EE,  ES,  IT, 
SK 

AT, BG, CY, CZ, 
DE,  DK,  EL,  FI, 
HR,  IE,  LT,  LU, 
LV, MT, NL, RO, 
SE 

Please specify "Other" uses. 

Member 
State 

Response 

BE 

EE 

SPF Finances (Customs litigation):  
Network analysis 

We  are  currently  in  an  exploratory  phase  with  AI,  but  our  organisations  have  already 
carried out a Copilot‑related risk assessment and are able to use the tool in practice.   
This early stage allows us to test different use cases, evaluate benefits and limitations, and 
gradually integrate AI solutions in a controlled and responsible manner. 

ES 

An intermediate body uses AI to assist in the programming of computer applications. 

Law No 132 of 23 September 2025 – the first comprehensive national measure following 
the AI Act – laid down principles and delegating powers for the use of artificial intelligence 
that  respect  privacy,  dignity,  equality,  security  and  transparency,  harmonising  national 
legislation with Regulation (EU) 2024/1689 and introducing monitoring mechanisms. With 
a view to combating fraud, the new offence of deepfakes (Article 612-quater of the Criminal 
Code)  stands  out.  It  punishes,  with  a  term  of  imprisonment  of  one  to  five  years,  the 
dissemination  of  content  that  has  been  falsified  or  altered  through  the  use  of  artificial 
intelligence  systems  that  is  likely  to  mislead.  Other  points  of  note  include  the  generic 

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IT 

      -       

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

Member 
State 

Response 

aggravating circumstance for offences committed by means of AI (Article 61(11-decies) of 
the  Criminal  Code),  and  the  increase  in  penalties  for  financial  offences,  with  special 
aggravating  factors  for  circumventing  and  manipulating  the  market  when  carried  out  by 
means of AI systems. These safeguards are particularly relevant for preventing fraudulent 
conduct through the use of false identities, voice phishing, digital document manipulation 
and disinformation campaigns used for economic and financial offences. The Customs and 
Monopolies  Agency  is  heavily  involved  in  a  programme  to  renew  equipment  aimed  at 
adopting state-of-the-art non-intrusive verification technologies, including through the EU 
co-financing  programme  (CCEI)  for  customs  controls  and  chemical  laboratories.  These 
innovative tools are designed to support the automatic detection of non-tax offences in the 
context of customs checks at certain airport customs offices located in the main postal and 
delivery  service  hubs  which  manage  commercial  traffic  flows  linked  to  e-commerce  or 
those dedicated to checking the baggage of international passengers. Operations using 
AI/ML-based models for the identification of cigarettes, drugs, weapons, explosives, and 
undeclared currency are currently being developed. As regards the protection of the ‘Made 
in Italy’ brand  and  the fight against counterfeiting, the ‘AUTENTICA’ mobile application, 
currently at the initial trial operational phase, uses artificial intelligence and computer vision 
to assists officials during anti-fraud checks. The Ministry of Justice has continued to follow 
the plan outlined in the NRRP aimed at expanding the digitisation of files to cover those 
under  the  responsibility  of  both  the  civil  (justices  of  the  peace,  juvenile  courts,  first  and 
second instance proceedings on merits) and criminal (criminal sections of courts, courts of 
appeal  and  public  prosecutor’s  offices)  sectors.  In  parallel,  the  digital  infrastructures  for 
wiretapping  were  upgraded  through  the  Digital  Interception  Database  (Archivio  Digitale 
delle Intercettazioni – ADI). In February 2025, the migration and synchronisation of content 
from the Public Prosecutor’s Offices’ local systems to the centralised inter-district systems 
was completed, with new interceptions delivered via that system in ISO format. Thus, the 
traceability  of  processes  and  the  overall  control  of  risk  points  have  been  strengthened, 
increasing transparency and accountability over the course of the entire lifecycle of judicial 
data.  Another  aspect  is  ‘Datalake  Giustizia’,  a  NRRP  project  aimed  at  centralising  the 
functions  of  extracting,  querying  and  storing  data  on  proceedings,  with  an  interactive 
dashboard linked to criminal records (REGEWEB) and information fed into it by the court's 
Case Management System (SICP) and the Electronic Crime Reporting Portal (NdR). The 
tool,  which  will  gradually  be  rolled  out  into  more  areas,  enables  constant  monitoring  of 
proceedings and key indicators (types of crime, population profiles, territorial distribution), 
which makes it possible to analyse phenomena in a timely manner, gauge the timing of 
urgent and precautionary measures, assess the impact of related civil proceedings and, 
above  all,  pre-emptively  implement  measures  in  vulnerable  areas  to  prevent  risk 
escalation. The integration of these elements (digitisation of files, inter-district interception 
systems, anti-fraud strategy with AI/ML safeguards and data lake analysis) has produced 
a  single  platform  that  combines  interoperability,  data  quality  and  predictive  capacity, 
providing  administrations and judicial  authorities with  operational  levers and information 
that adheres to European standards for the protection of the EU’s financial interests. 

SK 

Automated checks of invoices 

Q.4.5. Have you conducted a cyber/AI threat assessment in 2025? 

Response 

Frequency  Percentage 

Member States 

No assessment was conducted or planned 

15  55.6% 

      -       

BG,  CY,  DE, 
DK,  EL,  FI,  FR, 

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Response 

Frequency  Percentage 

Member States 

Yes, a partial assessment was conducted 

8  29.6% 

HR, HU, LT, NL, 
PL, PT, RO, SI 

AT, BE, EE, ES, 
IE, LV, MT, SK 

Yes,  a 
conducted 

comprehensive  assessment  was 

3  11.1% 

CZ, LU, SE 

No,  however  we  are  planning/have  planned  an 
assessment 

1  3.7% 

IT 

Q.4.6 What were the main findings of the threat assessment? 

Member 
State 

Response 

BMLUK (Federal Ministry for Agriculture):   
In 2025, cyber threats were systematically considered as part of the existing information 
security management system (ISMS) (risk analysis includes cyber threat scenarios). Dark 
web  analyses  are  also  performed  to  identify  potential  dangers  at  an  early  stage  and 
continually improve information security. Technological developments, particularly in the 
area of artificial intelligence, are taken into account.   

In addition, there is a risk assessment by the paying agency Agrarmarkt Austria (AMA) on 
the topic of security and AI for that institution. 

Europa WSE (ESF Flanders):   
Europa  WSE  (ESF  Flanders)  is  part  of  the  Department  WEWIS.  The  department  has 
performed  different  Cyber/AI  assessments  in  2025,  related  to  the  security  framework 
ISO27001, the NIS2 legislation, the CyFun framework of the CCB, the European AI Act, 
…   

Last year’s threat assessment concluded that there were no new major threats impacting 
our  environment  and  no  significant  security  incidents  occurred.  In  addition,  penetration 
tests  identified  zero  critical  or  high  vulnerabilities,  confirming  the  overall  strength  of  our 
security posture. There are some lower risk threats that are not mitigated on our roadmap. 
New critical software vulnerabilities are solved within the first weeks. 

In the ongoing risk analysis, the most significant vulnerability discovered was an obsolete 
version of the Apache Tomcat application server.    

The results are not yet available. However, we note that the improvement of measures is 
fully dependent on the allocation of sufficient funds. 

Our  public‑sector  employees  are  required  to  complete  annual  self‑study  training  on 
cybersecurity and to pass a test at the required level.   
Regular  training  ensures  that  employees’  knowledge  and  skills  meet  current  security 
requirements and that they are able to prevent and identify potential threats.   
The  training  and  testing  are  carried  out  within  the  designated  training  system,  which 
ensures consistent content, monitoring, and compliance. 

AT 

BE 

CZ 

EE 

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

Member 
State 

Response 

The responses from the various entities consulted cover the four possible answers. Among 
the positive responses are the following:  
The  Spanish  Tax  Agency  (AEAT)  as  a  whole,  through  its  Tax  Information  Technology 
Department, continuously analyses cyber threats, as does the General State Comptroller's 
Office  (IGAE)  through  its  Budget  Information  Technology  Office,  in  order  to  establish 
security measures for the systems.  
One  intermediary  body  indicates  the  following  cyber  threats  detected  in  its  information 
security policy: accidental or deliberate damage that may affect the availability, integrity or 
confidentiality  of  the  information  processed  or  the  services  provided;  rapidly  evolving 
threats with the potential to impact the confidentiality, integrity, availability, intended use 
and value of information and services.  
Other agencies indicate that they include  a specific risk related to computer damage in 
their risk assessment matrix, with the result of the assessment being an acceptable risk, 
while  another  indicates  that  they  identified  new  potential  risks  that  they  attempted  to 
mitigate with the resulting action plan. 

The Department of Agriculture conducts this annually to achieve their ISO status. There 
were no major findings in 2025. 

The national IT (CTIE) performs these assessments on a regular basis. 

Internal  regulation  is  needed  for  the  use  of  AI  in  an  institution.  Determining  the 
responsibility of the data regulation for the use of AI in an institution. 

The  Ministry  for  European  Funds  and  the  Implementation  of  the  Electoral  Programme 
(MFI)  remains  a  core  participant  in  a  centralised  cyber  threat  assessment  framework 
managed  by  the  Malta  Information  Technology  Agency  (MITA).  While  the  technical 
execution  and  primary  data  analysis  are  conducted  at  MITA  level  to  ensure  a  unified 
'Whole-of-Government'  security  posture,  these  assessments  directly  encompass  all 
Ministry-specific  systems  such  as  emails.  Consequently,  the  Ministry  is  continuously 
assessed  against  emerging  threats,  with  security  updates  and  mitigation  strategies 
implemented as a direct result of MITA's ongoing findings. Access to the findings of these 
threat assessments is held within MITA. 

ES 

IE 

LU 

LV 

MT 

SE 

The authority noted the importance of supply chain security and has begun strengthening 
it. 

SK 

In  the  Slovak  Republic,  the  obligation  to  assess  cybersecurity  risks  for  public  sector 
entities,  including  cyber  threats  and  threats  related  to  artificial  intelligence,  is  set  out  in 
national legislation (Act No. 69/2018 Coll. on Cybersecurity). The Government Office of 
the  Slovak  Republic  (AFCOS)  and  Ministry  of  Investments,  Regional  Development  and 
Informatization  of  the  Slovak  Republic  conducted  a  risk  assessment  in  2025,  which 
confirmed  the  need  for  continuous  monitoring  of  cyber  threats  and  threats  related  to 
artificial  intelligence,  implementation  of  appropriate  preventive  and  organisational 
measures, as well as regular review and update of security controls in response to evolving 
risks. Given the sensitive nature of information related to cyber threats and threats related 
to artificial intelligence, detailed findings, namely vulnerabilities, tools used, and mitigation 
measures taken, are subject to limited access and cannot be shared beyond the scope 
required by applicable law. 

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

DISCLAIMER ON ARACHNE 

The Financial Regulation creates a legal basis for a modernised data-mining and risk-scoring tool, 
what we refer to as “Arachne+”, for the purposes of budget implementation. Overall, the objective 
of Arachne+ is to improve even further the efficiency of the tool and at the same time to reduce the 
administrative burden and provide a user-friendly tool to prevent, detect, correct, and follow-up on 
irregularities such as fraud, corruption, conflicts of interest, double funding. 

As set by the Financial Regulation, Arachne+ will be applicable to all management modes, and the 
Member States will have an obligation to input data as from the post-2027 MFF (i.e. from 1 January 
2028). 

In terms of its use by the Member States, it will remain voluntary, however, in a joint statement on 
the  occasion  of  the  adoption  of  Regulation  2024/2509,  there  was  a  commitment  by  the  Council, 
Commission, and Parliament to reassessing mandatory use of the tool for the post-2027 MFF, based 
on a Commission assessment of the tool's readiness by 2027. 

The  Expert  Group  was  established  by  Commission  Decision  C(2024)7889  to  formalise  the 
cooperation between the Commission and the Member States towards the further development of the 
system and its generalised use by the Member States, and the development of the tool in consultation 
with its potential users. The work of the Expert Group will provide the Member States’ input in the 
design of the tool and will be included in the assessment of readiness for the mandatory use of the 
tool by the Member States. 

The Member States were invited to nominate their national representatives to the Expert Group at 
the end of 2024. 

There are 4 main criteria to be targeted by the assessment of readiness, leading to potentially re-open 
discussions on mandatory use. These are aligned with the key objectives of the development of the 
future tool: 

Risk indicators - shall be sufficiently uniform, objective, proportionate, necessary for risk assessment 
and  based  on  reliable  sources  of  information;  Interoperability  -  interoperability  with  relevant  IT 
systems and databases, including those of Member States, allowing for an automatic transfer of the 
relevant information in real time where feasible, and avoiding duplication of reporting; Artificial 
intelligence - for analysing and interpreting data; and in addition, Data protection – that the system 
shall comply with general data protection principles. 

If you have any queries on the development of Arachne+ or would like to have further information 
on the Expert Group, you can contact BUDG-DATA-MINING-TOOL@ec.europa.eu. 

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Commission Staff Working Document – Follow-up by Member States to Recommendations of the 
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Q.4.7 What is your Arachne integration status? 

Response 

Frequency  Percentage 

Member States 

Partially  feeding  data  into  the  system  (minimum 
mandatory dataset) 

15  55.6% 

Feeding all possible data into the system 

8  29.6% 

AT, CY, CZ, DK, 
EL,  ES,  FI,  FR, 
HU,  IE,  LU,  LV, 
MT, PL, SI 

BE,  BG,  EE, 
HR, IT, PT, RO, 
SK 

No plan to adopt 

Planning to adopt 

2  7.4% 

2  7.4% 

DE, LT 

NL, SE 

Q.4.8 If you are only partially feeding data into Arachne, what are the 
reasons? 

Response 

Frequency  Percentage 

Member States 

Technical limitations 

8  29.6% 

Strategic choice (only minimum dataset needed) 

7  25.9% 

Legal constraints 

6  22.2% 

Data not available in national systems 

5  18.5% 

Limited staff capacity 

Other (please specify) 

5  18.5% 

8  29.6% 

CY, CZ, EL, ES, 
FR, IE, LU, SI 

CZ,  ES,  FI,  FR, 
LU, LV, SI 

AT, CY, ES, FR, 
PL, SI 

CY,  CZ,  EL,  FI, 
FR 

CZ,  ES,  FI,  FR, 
LU 

CZ,  DK,  ES,  FI, 
HU, IE, MT, PL 

Please specify "Other" reasons. 

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

Member 
State 

Response 

CZ 

DK 

ES 

FI 

HU 

IE 

MT 

PL 

The scope of the data and the frequency of updates was established at national level by 
the Ministry for Regional Development.    

The scope is set in the National Recovery Plan methodological environment. 

Arachne is not widely used in Denmark, so article 22 data from RRF is uploaded every 3rd 
month to Arachne. 

Responses regarding the  Arachne integration status vary depending on the programme 
management  authorities  and  even  at  the  level  of  intermediate  bodies  within  the  same 
programme, covering the five possible answers to question Q.4.7. 

Implementation of the RRF will end at the end of 2026. 

Beyond the minimum dataset, we feed in the data laid down in Hungarian legislation in line 
with the commitment under the conditionality procedure. 

Bodies who are using Arachne are utilising it and feeding all possible data into the system. 
Some  bodies  are  in  the  process  of  implementing  it.  This  context  led  to  the  answer  of 
partially feeding data. 

All minimum mandatory data is being transmitted to Arachne, together with any additional 
optional data that is currently available. 

Arachne is currently used as part of the National Recovery and Resilience Plan, including 
for  the  cyclical  transmission  of  the  input  data.  The  institution  sends  this  data,  which  is 
obligatory. In addition, it is necessary to streamline the process for inputting data in order 
to reduce administrative burdens. Legal barriers have also been identified, particularly as 
regards compliance with national data protection rules. 

Q.4.9 For which funds is Arachne currently implemented? 

Response 

Frequency  Percentage 

Member States 

ERDF 

17  63.0% 

ESF / ESF+ 

17  63.0% 

RRF 

      -       

17  63.0% 

BE,  BG,  CY, 
CZ, ES, FR, HR, 
HU,  IE,  IT,  LU, 
LV, MT, PT, RO, 
SI, SK 

AT, BE, BG, CY, 
CZ,  FR,  HR, 
HU,  IE,  IT,  LU, 
LV, MT, PT, RO, 
SI, SK 

BE,  BG,  CY, 
CZ,  DK,  EL,  FI, 
HU,  IE,  IT,  LV, 

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Response 

Frequency  Percentage 

Member States 

CAP – Pillar II (Rural Development) 

12  44.4% 

EMFAF 

12  44.4% 

Cohesion Fund 

11  40.7% 

AMIF / ISF / BMVI 

CAP – Pillar I 

Other national or EU-funded programmes (please 
specify) 

7  25.9% 

6  22.2% 

7  25.9% 

MT, PL, PT, RO, 
SI, SK 

CY, EE, EL, ES, 
HR, HU, IT, LV, 
PT, RO, SI, SK 

BE,  BG,  CY, 
CZ, EE, ES, HR, 
HU, LV, PT, RO, 
SK 

BE,  BG,  CY, 
CZ, HR, HU, LV, 
MT, PT, RO, SK 

BE,  BG,  CZ, 
HU, PT, RO, SK 

CY,  EE,  ES,  IT, 
LV, PT 

AT,  BE,  HR, 
HU, IE, RO, SK 

Please specify other national or EU-funded programmes. 

Member 
State 

Response 

AT 

BE 

HR 

JTF 

PSW ERDF Wallonia:    
BAR 

Contribution  from  the  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  of 
Fisheries:  
Under the EMFAF, the Intermediate Body of the Managing authority has been delegated 
part  of  the  selection  of  operations  function.  Namely,  the  IB  performs  checks  on 
procurement  procedures  for  beneficiaries  who  are  not  subject  to  public  procurement 
obligations. In these procedures, the IB uses  Arachne. The EMFAF Managing  authority 
does not use Arachne.   

Contribution from the Ministry of Regional Development and EU funds:  
Fund for European Aid to the Most Deprived (FEAD) and Youth Employment Initiative (YEI) 

HU 

Brexit 

IE 

The Department of Agriculture are currently planning to adopt in respect of the CAP and 
EMFAF funds.  

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Member 
State 

Response 

The  Special  EU  Programming  Body  use  Arachne  for  PEACEPLUS  approved  and 
contracted projects.  

Arachne  is  built  into  the  EPPM  that  the  Department  of  Justice  uses  for  the  AMIF  fund. 
Work is continuing on this to ensure effective utilisation.  

BMVI and Cohesion Fund are not applicable to Ireland 

RO 

Just Transition Fund 

In  addition  to  the  listed  funds,  Arachne  is  implemented  for  the  following  additional 
programs:  

- CFP (Common Fisheries Policy): Arachne supports projects related to the management 
and funding of fisheries resources.  
-  EU  Solidarity  Fund:  Arachne  assists  in  managing  financial  resources  allocated  for 
disaster relief and recovery.  

SK 

-  Horizon  Europe:  While  primarily  a  research  and  innovation  fund,  elements  related  to 
project management and compliance monitoring can benefit from Arachne's functionalities.  

- Just Transition Fund  

- Interreg VI-A Slovakia – Czech Republic 2021 – 2027 

Q.4.10 How would you describe the level of implementation across these 
funds. 

Response 

Frequency  Percentage 

Member States 

Pilot phase for some funds 

3  11.1% 

ES, FI, SI 

Implemented only for a limited number of funds 

7  25.9% 

Implemented for most funds 

8  29.6% 

Fully implemented for all funds 

5  18.5% 

DK,  EE,  EL,  IE, 
LU, LV, PL 

BE,  BG,  CY, 
FR,  HR,  MT, 
RO, SK 

AT,  CZ,  HU,  IT, 
PT 

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Q.4.11 Are there any AI tools you use that would benefit from accessing 
the  data  available  in  Arachne  or  that  could  improve  Arachne’s 
performance, adoption rate by national authorities or effectiveness? 

Member 
State 

Response 

AT 

No. 

PSW ERDF Wallonia:  
At the level of the Walloon Region, not for the moment  

ERDF and RRF Brussels Capital Region:  
No use made of AI tools by the ERDF and RRF Brussels Capital Region  

Europa WSE (ESF Flanders):    
We  do not know of any  AI tools as such. It would benefit us if  Arachne  would  be more 
accessible/easier to interpret (with regards to action/follow-up). We do not currently use 
any AI tools.  
Communauté germanophone:   
No AI tools used 

Not yet 

N/A 

None. 

We don’t currently use AI-tools. 

We  are  not  yet  using  AI  tools  that  directly  integrate  with  Arachne,  but  several  types  of 
solutions could benefit from access to its data. AI‑based text analysis, pattern recognition 
and  predictive  models  could  improve  anomaly  detection  and  risk  scoring.  In  the  future, 
such tools could also support Arachne’s performance and help increase its adoption once 
national implementation progresses and data access is ensured. 

No. AI tools are not used at this stage. 

No 

Not currently. 

The  authorities  managing  cohesion  policy  funds  which  employ  Arachne  for  their 
management and control system do not use tools with AI-based functionalities. 

Contribution from the Ministry of Labour, Pension System, Family and Social Policy:  
No.  
Contribution from the Ministry of Regional Development and EU funds:  
AI tools are not currently in use. 

No,  there  are  no  such  tools  at  present.  We  recommend  allowing  such  data  to  be 
transmitted to the Member States’ monitoring and information systems in order to facilitate 
access to information and reduce the administrative burden. 

n/a 

Advanced data  analytics and decision support tools, including those based on  machine 
learning  techniques,  could  significantly  benefit  from  access  to  the  data  available  in 

BE 

BG 

CY 

CZ 

DK 

EE 

EL 

ES 

FI 

FR 

HR 

HU 

IE 

IT 

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Member 
State 

Response 

Arachne.  Further  integration  would  improve  the  quality  of  risk  analyses,  improve  the 
detection of anomalous patterns and reduce false positives, helping to increase the overall 
effectiveness  of  Arachne  and  facilitate  its  wider  uptake  by  the  competent  national 
authorities. 

LU 

LV 

MT 

PL 

PT 

RO 

SI 

SK 

N/A 

No 

Currently the full use of AI is still being examined. 

There are tools at national level that would benefit from accessing the data available in 
Arachne  because  of  the  data  it  contains  from  other  Member  States  sent  by  foreign 
institutions. 

No 

n/a 

NO 

At this time, some authorities use only a limited number of AI tools. These tools are mainly 
simple  AI-based  assistants  built  on  large  language  models  and  are  used  for  general 
support  purposes  only.  They  are  not  integrated  with  ARACHNE  and  do  not  currently 
require  access  to  Arachne  data,  nor  are  they  designed  to  improve  ARACHNE’s 
performance, adoption rate, or effectiveness. 

Q.4.12 When using Arachne, what are the main challenges that you face? 

Response 

Frequency  Percentage 

Member States 

False alerts 

19  70.4% 

Difficulty interpreting indicators 

18  66.7% 

Incompatibility  issues  (Filetype  concerns,  data 
quality, size limits) 

14  51.9% 

AT, BE, CY, CZ, 
DK, EE, EL, ES, 
FR, HR, HU, IT, 
LU, LV, MT, PL, 
PT, SI, SK 

BE,  BG,  CZ, 
DK, EE, EL, ES, 
FI, FR, HR, HU, 
IE,  IT,  LV,  PT, 
RO, SI, SK 

AT, BE, CZ, ES, 
FI,  FR,  HU,  IE, 
IT,  LU,  PL,  PT, 
SI, SK 

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Response 

Frequency  Percentage 

Member States 

Legal concerns (e.g., Data Privacy) 

11  40.7% 

Other (please specify) 

8  29.6% 

AT, BG, CZ, ES, 
FR,  HU,  IE,  PL, 
RO, SI, SK 

CZ, EE, ES, FR, 
HR, MT, PL, RO 

Please specify "Other" challenges. 

Member 
State 

Response 

The difficulty of ex-ante controls; missing time periods and data sources; impossibility of 
sanction monitoring; unclear audit trail of Arachne data; lack of information from national 
records of beneficial ownership.    

Data insufficiently updated.    

Arachne does not yet include data from the Comenius operational programme and other 
operational  programmes  from  the  2021-2027  programming  period,  so  it  has  not  been 
possible to make full use of Arachne. According to information from the working party for 
the 2021-2027 monitoring system there is a problem validating uploaded batches, which 
must be at least 95% validated to be uploaded to the production environment. 

Our PRIA has an internally developed risk system, so we have challenges to merge our 
system with Arachne. 

Legal validity of the results 

In order to calculate all the risk indicators in Arachne, data must be incorporated for which 
no provision for recording and collection is made in the sectoral regulations on funds. In 
the implementation of cohesion policy in France, users import into Arachne only data which 
are recorded and stored in the programme’s data recording system. Some data recording 
systems are themselves connected with other databases which have APIs, such as those 
of INSEE (establishment data) and the INPI (beneficial owners). Feeding data into Arachne 
when it does not work in an interoperable or automated way with other databases becomes 
a technical and time-consuming exercise requiring operational support. 

Contribution from the Ministry of Labour, Pension System, Family and Social Policy:  
When  checking  potential  conflict  of  interest  for  private  persons  there  is  no  unique 
identification information (such as VAT number) that would help determine the identity of 
a person – in this way these checks seem useless. 

CZ 

EE 

ES 

FR 

HR 

MT 

Identity Card or Passport Numbers cannot be inserted in the system. 

Some flaws in the functionalities of the tool and difficulties in using it have been identified, 
including but not limited to the presence of false positive results, legal barriers, in particular 
as  regards  compliance  with  national  data  protection  rules,  additional  administrative 
burdens  related  to  the  collection  of  data  for,  unclear  algorithms  for  the  calculation  of 
individual risk indicators and no service desk tool to deal with errors. Problems have also 
been  identified  with  downloading  large  data  packages  in  a  single  session  and  slow 
response times when processing larger amounts of data. 

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Member 
State 

Response 

There is no possibility for automated data extraction and integration into the Arachne file. 
The  Ministry  of  Energy  compiles  an  Excel  file  manually,  using  data  from  the 
proiecte.pnrr.gov  platform  and  the  Contract  Monitoring  unit,  without  any  degree  of 
automation. For such automation to be feasible, the Ministry of Energy would need access 
to the Arachne platform and trained staff capable of exporting data from Excel files to the 
Arachne platform.  

RO 

Ministry of Investments and European Projects:   
SMIS  

Audit Authority:   
Difficulties  in exporting data from the  national management systems (e.g.  SMIS 2021+, 
eMS) to Arachne. 

Q.4.13 Has Arachne been incorporated into your NAFS or other AFS? 

Response 

Frequency  Percentage 

Member States 

Yes, as part of the NAFS 

10  37.0% 

Yes, as part of other AFS 

9  33.3% 

BG,  CY,  CZ, 
DK, HU, IT, MT, 
PT, RO, SK 

AT, BE, CY, EE, 
EL,  IE,  IT,  LU, 
SI 

No, but implementation is being considered 

4  14.8% 

ES, FI, FR, PL 

No 

3  11.1% 

ES, HR, LV 

Q.4.14 Are your data analysis tools interacting with Arachne? 

Response 

No 

Frequency  Percentage 

Member States 

10  37.0% 

Yes (please specify which) 

6  22.2% 

Not yet, but planned (please specify which) 

5  18.5% 

      -       

BE, CY, DK, EL, 
ES, FI, FR, HR, 
LV, PL 

AT,  CZ,  IT,  MT, 
RO, SK 

BG, EE, LU, PT, 
SI 

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Response 

Not applicable 

Frequency  Percentage 

Member States 

2  7.4% 

HU, IE 

Q.4.15 Please list the data analysis tools which are/are planned to interact 
with Arachne. 

Member 
State 

Response 

AT 

BG 

CZ 

EE 

IT 

LU 

MT 

PT 

RO 

SI 

SK 

Databank: IDEA. 

It is planned to adapt and synchronised analysis tools with ARACHNE 

Arachne is used as the basis for risk analyses for planning on-the-spot checks. 

Internal risk scoring system 

‘Among the data analytics tools planned to interact with Arachne is the “SAS (Statistical 
Analysis System) platform”, which is used for advanced data analytics and to support fraud 
detection and prevention activities. The inclusion of SAS is consistent with AGEA Circular 
No 34322 of 28 April 2025 and is part of the broader strengthening of the risk analysis and 
decision-making support systems available to the relevant authorities.   
The Inspectorate-General for Financial Relations with the European Union (IGRUE) of the 
Ministry  of  Economic  Affairs  and  Finance  (MEF)  has  continued  to  participate  in  the 
Arachne  expert group set  up by European Commission Decision  of 20  November 2024 
(C(2024) 7889 final), aimed at designing a corporate data mining and risk scoring tool to 
prevent, detect, correct and monitor irregularities, including fraud, corruption, conflicts of 
interest and double funding. IGRUE appointed one of the members representing Italy and 
has begun discussions with the national working group with a view to sharing the Italian 
position to be put before European experts on the diverse issues discussed at the various 
planned meetings’. 

Our  own  data  exchange  platform  cannot  interact  with  Arachne  (no  upload  currently 
possible). It is foreseen to have this for 2028-2034. 

The data analysis tool interacting with Arachne is the Management and Control Information 
System (MCIS), formerly the Structural Funds Database (SFD). MCIS is Malta’s central 
system  for  the  management,  monitoring,  and  payment  processing  of  EU-funded 
operations.  When  Arachne  identifies  risk  indicators  or  red  flags,  the  outputs  are  further 
analysed within MCIS using detailed project, financial, and beneficiary data to support any 
follow-up checks. 

The  plan  is  to  ensure  that  Arachne  will  be  interoperable  with  the  IT  systems  of  the 
European Funds. 

Ministry of Energy:   
Operational procedures for the management of irregularities, anti-fraud and anti-corruption 
policy, checklists and questionnaires on the identification of serious irregularities and fraud 
indicators. 

- 

Information and monitoring system ITMS2014+ a ITMS21+. Regarding plans it´s currently 
difficult to confirm the tool as there were few discussions mentioning different information 

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Member 
State 

Response 

system  for  next  programming  period.  Some  authorities  use  basic  AI-assisted  or 
spreadsheet-based  tools  for  internal  data  handling,  but  these  tools  do  not  interact  with 
Arachne. In the future, integration  of additional data analytics tools may  be considered, 
depending on legal requirements, data protection, and technical feasibility. 

Q.4.16 How would you rate the interoperability of the systems on average? 

Response 

Frequency  Percentage 

Member States 

3 Medium Interoperability 

3  11.1% 

MT, RO, SK 

4 High Interoperability 

2  7.4% 

AT, IT 

1 Very Low Interoperability 

1  3.7% 

CZ 

Q.4.17 Please explain the interaction of the two (or more) systems in your 
administration. 

Member 
State 

Response 

AT 

The data from the IDEA database is fed into Arachne via manual data upload. 

Information should be downloaded automatically from the MS2014+ system to Arachne.    

Data for the programming period 2021 onwards are not yet available in Arachne.    

CZ 

IT 

Our publicly available data analysis tools are not directly linked to the Arachne system. As 
for screening the risks and inspections of entities, we use supplementary systems such as 
ESM,  EU  Sanctions  and  other  available  databases  that  enable  us  to  carry  out  more 
comprehensive  verifications  than  would  be  possible  using  only  the  Arachne  system. 
Accordingly, Arachne is one of the supporting sources of information rather than being the 
main (interconnected) analytical tool. 

The  SAS  platform  developed  by  AGEA  processes  EU  and  national  data  collected  in 
Arachne  to  produce  more  detailed  and  refined  outputs,  which  are  used  to  steer  fraud 
prevention and detection activities, as well as for on-going risk monitoring. This interaction 
between Arachne and SAS, although not yet fully operational at all stages, is a key element 
of  the  anti-fraud  data  analysis  ecosystem  and  a  step  towards  broader  interoperability 
between anti-fraud information management systems. 

MT 

Data is extracted from MCIS and uploaded in Arachne. 

Ministry of Energy:   
Automated data transfers from the NRRP platform to Arachne are not possible.  

Ministry of Investments and European Projects:   
Data retrievals from SMIS for insertion into Arachne.  

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Member 
State 

Response 

Regional Development Agency:   
Arachne interacts with the SMIS 2021 management IT system. 

SK 

Slovakia  currently  provide  data  only  via  XML  export  from  national  systems/import  to 
Arachne.  Discussions  with  the  Arachne  support  team  regarding  automation  of  data 
exchange (API integration) are ongoing. 

Q.4.18 Are you satisfied with the type of support available on Arachne? 

Response 

Frequency  Percentage 

Member States 

Yes 

No 

Not  applicable/  We  were  not  aware  of  such 
support 

9  33.3% 

9  33.3% 

5  18.5% 

AT,  CY,  EE,  FI, 
IE,  IT,  LV,  MT, 
PT 

BE, BG, CZ, FR, 
HR, HU, RO, SI, 
SK 

DK, EL, ES, LU, 
PL 

Q.4.19 What type of support (training/content/guidebooks) on  Arachne 
would be the most useful to you? 

Response 

Frequency  Percentage 

Member States 

Training for staff (from induction training to expert 
training) 

13  48.1% 

Arachne Academy tutorials/videos 

12  44.4% 

Guidance  on 
interpretation 

risk 

indicators  and 

their 

12  44.4% 

      -       

BE, BG, CZ, EL, 
ES,  FR,  HR, 
HU, LU, PL, RO, 
SI, SK 

BE, BG, CZ, EL, 
ES,  HR,  HU, 
LU,  PL,  RO,  SI, 
SK 

BE, BG, CZ, EL, 
ES,  FR,  HR, 
HU, LU, RO, SI, 
SK 

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Response 

Frequency  Percentage 

Member States 

Technical assistance 

10  37.0% 

Arachne forum (peer exchange) 

8  29.6% 

BE, CZ, EL, ES, 
HR, HU, LU, PL, 
RO, SI 

BE, CZ, EL, ES, 
HR, HU, RO, SI 

Financial support 

Other (please specify) 

4  14.8% 

CZ, ES, HR, HU 

2  7.4% 

DK, FR 

Please specify "Other" type of support. 

Member 
State 

Response 

DK 

. 

FR 

For  assistance  with  cohesion  policy,  users  currently  rely  on  the  expertise  of  their 
correspondent in the European Commission in order to import data in the expected format. 
The Commission also offers some training sessions for users. However, it would probably 
also be necessary to develop tailored assistance to improve the programme information 
systems  so  that  they  are  fully  compatible  with  Arachne.  Furthermore,  users  often  also 
request assistance to interpret the risks identified by Arachne. 

Q.4.20 How do you plan to (further) incorporate digitalisation into your 
(future) national anti-fraud strategies? 

Member 
State 

Response 

AT 

Not yet decided. 

Belgian AFCOS:  
The ambition is to fully integrate digitalisation in our anti-fraud strategies.  

BE 

Europa WSE (ESF Flanders):   
At Europa WSE, we are currently in the process of implementing CATE, an AI program 
that will help our checks during the reporting. 

BG 

Not applicable yet 

CY 

We plan to implement the NAFS digitalisation actions: establish a working group to map 
data sources and tools (including AI applications), conduct a systems/databases mapping 
exercise,  develop  a  concept  for  a  data  integration  tool  in  consultation  with  relevant 

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Member 
State 

Response 

CZ 

DE 

DK 

EE 

stakeholders, explore funding options, and ensure fuller utilisation of  Arachne, including 
systematic upload of programme and transaction data. 

With  the  development  and  introduction  of  relevant  tools  and  processes  in  the  state 
administration, further updates of the NAFS will comprise their use for the anti-fraud area. 

Further integration will be considered after checking compatibility with existing IT systems 
and the legal situation. 

Danish Business Authority:   
In the new programming period we plan to use Arachne+.  

Danish Agricultural and Fisheries Agency:   
At the moment, adoption of Arachne is the primary focus of future digitalization of our anti-
fraud efforts. 

We  plan  to  further  integrate  digitalisation  into  our  national  anti‑fraud  strategies  by 
expanding  the  use  of  data‑driven  tools,  improving  access  to  interoperable  information 
systems, and strengthening analytical capabilities. This includes continuing to experiment 
with  the  use  of  artificial  intelligence—such  as  text  analysis  and  pattern  recognition—in 
areas  where  it  can  increase  the  effectiveness  of  controls.  We  also  intend  to  assess 
opportunities to safely implement and use AI‑based tools in risk analysis and to identify 
patterns through enhanced data analytics.   

To mitigate fraud risks, different digital elements, including AI‑based solutions, should be 
embedded  at  every  stage  of  application  processing  to  ensure  timely  prevention  or 
detection  of  irregularities.  As  national  discussions  progress  and  as  tools  like  Arachne+ 
become  more  fully  implemented,  our  approach  will  be  further  refined.  We  also  closely 
monitor developments and best practices in other countries, which inform and guide our 
digitalisation decisions. 

EL 

Article 50(1) of Law 4914/2022 provides for the digitalisation of the handling (receipt and 
examination) of complaints concerning programmes/projects co-financed under the ESPA. 
This should be implemented in the Integrated Information System within the year. 

Improvement of tools for risk analysis, the widespread use of databases for prevention and 
detection purposes, and the analysis of the interoperability of databases.  

According to a management authority consulted, incorporating data from its management 
application files into Arachne, in compliance with European regulations.  

Establishment  of  digital  platforms  for  transparency  and  oversight,  big  data  analysis 
systems, and the use of AI to identify anomalies and predict corruption risks.  

In updates or new general or specific management risk prevention plans.  

Use of AI to facilitate preliminary analysis of complaints received. 

Making use of Arachne and other officially recorded data. 

Under consideration 

Not applicable. 

We  are  working  continuously  on  the  digitalisation  of  fraud  prevention  and  detection 
processes and tools. 

ES 

FI 

FR 

HR 

HU 

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Member 
State 

Response 

IE 

IT 

LT 

LU 

LV 

MT 

NL 

PL 

PT 

RO 

The authorities in Ireland have stressed the importance of digitalisation and digital tools in 
anti-fraud efforts. 

Digitisation  will  be  further  incorporated  through  enhanced  interoperability  between 
information systems, the use of advanced data analytics and decision support tools, as 
well as the  progressive use of technological solutions geared towards risk analysis and 
fraud prevention. Particular attention will be paid to integration between databases, data 
quality and training of the staff involved. 

- 

N/A 

Possibilities of further digitalization will be analysed during elaboration of the next NAFS. 

The incorporation of digitalization will be considered at the time the NAFCS is updated. 

We  will  ensure  that  the  systems  operate  firstly  in  accordance  with  privacy  laws,  then 
preferably in a coordinated manner with good instructions and regular refresher training. 

Poland has not adopted a national anti-fraud strategy (NAFS). There are no plans to draw 
up  such  a  document  at  national  level.  IT  tools  are  used  in  the  anti-fraud  process,  for 
example  during  checks  and  verifications,  when  tracing  networks  of  connections  and 
checking conflicts of interest, and so on. 

The  NAFS  has  measures  in  place  covering  digitalisation  and  the  interoperability  of  IT 
systems. 

Through continuous and specialised training and investment in AI tools at the Ministry of 
Energy. 

SE 

There is no national strategy. 

SI 

Re  Q4.7  The  AKTRP  has  selected  two  means:  Partially  feeding  data  into  the  system...  
and Testing adaptability... 

Digitalisation  will  be  introduced  gradually,  in  line  with  the  strategic  objectives  of  the 
National Strategy for the Protection of the EU's Financial Interests in the Slovak Republic, 
with a focus on the systematic use of existing digital tools, such as the ARACHNE system, 
improving the quality and availability of data and increasing the awareness and capacities 
of national authorities.   

SK 

The  current  National  Strategy  for  the  Protection  of  the  EU's  Financial  Interests  in  the 
Slovak  Republic  already  defines  a  permanent  task  to  ensure  the  implementation  of 
sophisticated  analytical  software  tools,  including  the  ARACHNE  system,  in  project 
evaluation  and  risk  identification.  The  upcoming  update  of  the  National  Strategy 
emphasises  that  digitalisation  should  be  one  of  the  key  pillars  of  the  protection  of  the 
European Union's financial interests in the Slovak Republic, across the entire anti-fraud 
cycle. 

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Q.4.21 Please select three barriers to the digitalisation of your anti-fraud 
efforts, that you believe are most crucial to overcome. 

Response 

Frequency  Percentage 

Member States 

Interoperability challenges 

19  70.4% 

Budget constraints 

16  59.3% 

Data protection concerns 

12  44.4% 

Legal issues 

Skill gaps 

12  44.4% 

10  37.0% 

Outdated legacy systems 

9  33.3% 

CY, DE, EE, EL, 
ES, FI, FR, HR, 
HU,  IE,  IT,  LU, 
LV, MT, NL, PT, 
SE, SI, SK 

BE,  BG,  CZ, 
DK,  EE,  ES,  FI, 
HR, HU, IE, LT, 
LU, LV, PL, RO, 
SK 

AT, BE, DE, EL, 
FR, HU, IE, LU, 
MT, PL, PT, SE 

AT, BG, CY, CZ, 
DE, EE, FR, LT, 
PL, RO, SE, SK 

BE,  DK,  EL,  FI, 
HR, IT, MT, PT, 
RO, SI 

BG,  CY,  CZ, 
DK,  ES,  IT,  LT, 
LV, NL 

Q.4.22  Please  feel  free  to  specify  any  other  additional  challenges  or 
experiences regarding this section, which you would like to share. 

Member 
State 

Response 

The AMIF managing authority:   
The strict data protection requirements, the fact that there are different IT systems for each 
fund  type  and  the  lack  of  staff  with  adequate  Arachne+  and  IT  skills  also  make  using 
ARACHNE+ challenging.   

Additional answers to Q. 4.7 from individual managing authorities (multiple answers not 
possible):   

– Testing adaptability with national systems:   
The AMIF managing authority; The Lower Saxony ERDF managing authority   

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Member 
State 

Response 

– Planning to adopt: The Brandenburg ERDF managing authority 

One of the key challenges we continue to face in the digitalisation of our anti‑fraud efforts 
is ensuring consistent access to high‑quality, interoperable data across institutions. Limited 
data availability or fragmented systems can slow down the effective use of digital tools, 
including risk‑analysis platforms and AI‑based solutions.   
Another important aspect is the human factor. Even when digital tools are available, the 
data is ultimately used and interpreted by people, and human errors can lead to incorrect 
assessments  or  create  additional  risks.  Ensuring  that  staff  have  the  necessary  skills, 
training, and support to use these tools effectively is therefore essential.   

We also recognise the need to implement new technologies safely and responsibly. While 
digital  tools  offer  significant  potential,  their  integration  requires  careful  consideration  of 
data protection, security, and governance. Digitalisation efforts also progress at different 
speeds across organisations, which can create uneven capabilities and require additional 
coordination.   
We continue to monitor developments and best practices in other Member States, which 
help inform our decisions and guide our digitalisation efforts 

EE 

EL 

- 

Very rigid management applications, which make any change costly and time-consuming.  
Shortage of specialised human resources for the implementation of tools, processes, and 
procedures for the development of solutions for  the digitization  of the  anti-fraud  system 
and cooperation with external authorities. 

Contribution  of  the  Ministry  of  Agriculture,  Forestry  and  Fisheries  (Paying  Agency  for 
Agriculture, Fisheries and Rural Development):  
Our future goal will be better use of IT, in particular data integration from different central 
base in order to lower administrative burden and to ensure the most efficient and effective 
use of EU fund. 

In  respect  of  question  4.18.  Satisfaction  with  support  exists  but  increased  supports 
welcome, i.e. EU or national level. Shared management members of AFCOS network will 
be discussing Arachne usage as a rolling agenda item going forward in order to facilitate 
conversations on best practice, key challenges and peer exchange etc. 

No further comments. 

in addition, regarding Q4.16:  2 Low interoperability 

ES 

HR 

IE 

NL 

SI 

Q.5.1 Please list the national services and bodies consulted to reply to this 
questionnaire. 

Member 
State 

Response 

Federal  Ministry  of  Agriculture  and  Forestry,  Climate  and  Environmental  Protection, 
Regions and Water  
Management.  Federal  Ministry  of  Labour,  Social  Affairs,  Health,  Care  and  Consumer 
Protection. Federal Ministry of Finance. 

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AT 

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Member 
State 

Response 

FPS  Economy  -  CICF  (Interdepartmental  Committee  for  Coordinating  the  Fight  against 
Economic Fraud) - AFCOS BE   

FPS FINANCES    

FPS BOSA (Policy and Support)   

FPS JUSTICE    

COMMUNITIES (German-speaking, Flemish and French)   

REGIONS (Brussels Capital, Flemish and Walloon)    

ERDF, RRF & ESF BRUSSELS-CAPITAL REGION    

ERDF, RRF & ESF WALLONIA    

ERDF, RRF & ESF FLANDERS    

WALLOON PAYING AGENCY (ORGANISME PAYEUR WALLON (OPW))    

FLEMISH  AGENCY  FOR  AGRICULTURE  AND  FISHERIES 
LANDBOUW & ZEEVISSERIJ)   

(AGENTSCHAP 

FEDERAL POLICE 

The  Prosecution  of  the  Republic  of  Bulgaria,  Managing  authorities,  the  National  Fund 
Directorate  within  the  Ministry  of  Finance  (Certifying  Authority/Accounting  Body/ 
Coordination Body at national level regarding the Recovery and Resilience Facility), the 
Central  Coordination  Unit  within  the  Council  of  Ministers  (central  coordinator  of  the 
European Commission’s SFC 2007 and SFC 2014 fund management systems at national 
level and of the Arachne), the AFCOS Directorate 

AFCOS  Secretariat,  Managing  Authorities,  Audit  Office  of  the  Republic,  COPA,  Cyprus 
Police, Management Authority, Tax Authorities and Customs Department. 

National Coordination Authority, Managing authorities, Component owners, Police of the   
Czech Republic - National organised Crime Agency, Prosecutor General’s Office, General 
Customs Directorate. 

AFCOS  Germany,  the  Federal  Ministry  of  Finance,  The  Federal  Foreign  Office,  The 
Federal Ministry of Labour  and  Social  Affairs, The Federal  Ministry of Agriculture, Food 
and Regional Identity, The Federal Ministry of Economic Affairs and Energy, The Federal 
Ministry  of  the  Interior,  The  managing  authorities  of  the  federal  states,  Investitionsbank 
Schleswig-Holstein 

Audit Authority of the Danish Ministry of Finance  
Danish Ministry of Justice  
Danish Director of Public Prosecutions  
Danish National Special Crime Unit  
Danish Ministry of Taxation  
Danish Tax Agency  
Danish Customs Agency  
Danish Business Authority  
Danish Agency for Green Transition and Aquatic Environment  
Danish Agricultural and Fisheries Agency 

BE 

BG 

CY 

CZ 

DE 

DK 

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PIF Report 2024 

Member 
State 

Response 

EE 

The questionnaire was sent to 11 national bodies, and we received substantive input from 
eight of them. 

EL 

ES 

Εθνική Αρχή Διαφάνειας (ΕΑΔ) (National Transparency Authority)  
Επιτροπή Δημοσιονομικού Ελέγχου (ΕΔΕΛ) (Financial Audit Committee)  
Ειδική  Υπηρεσία  Θεσμικής  Υποστήριξης  &  Πληροφοριακών  Συστημάτων  (ΕΥΘΥΠΣ) 
(Special Service for Institutional Support & Information Systems)  
Ειδική  Υπηρεσία  Συντονισμού  Ταμείου  Ανάκαμψης  (ΕΥΣΤΑ)  (Recovery  and  Resilience 
Facility Special Coordination Service)  
Υπουργείο Αγροτικής Ανάπτυξης και Τροφίμων (ΥΠΑΑΤ) (Ministry of Rural Development 
and Food) 

European Social Fund Administration Unit (UAFSE)  
Sub-Directorate  General  Economic  Management  and  European  Funds  (managing 
authority for AMIF)  
Sub-Directorate General Economic Sustainability and Social Affairs ( managing authority 
for European  
Maritime, Fisheries and Aquaculture Fund)  
Sub-Directorate General Inspection and Control (Directorate-General for European Funds)  
Sub-Directorate  General  European  Territorial  Cooperation  (managing  authority  for  ETC 
programmes)  
Sub-Directorate General Agricultural Funds- FEGA (Spanish Agricultural Guarantee Fund 
- coordinating  
body of the paying agencies)  
FEGA Internal Audit Division  
Sub-Directorate General ERDF (managing authority for ERDF)  
Sub-Directorate General Planning and Management of Infrastructures and Resources for 
Security  
(managing authority for ISF))  
Sub-Directorate Genera for the Management of the National Recovery Plan ( Directorate 
General for the  
Recovery and Resilience Plan and Mechanism, General Secretariat for European Funds)  
State Agency for Tax Administration (AEAT)- Customs and Excise Department  
State Agency for Tax Administration (AEAT)- Department of Financial and Tax Inspection.  
Undersecretariat of the Ministry of Agriculture, Fisheries and Food -Anti-fraud and Internal 
Control Unit  
Civil Guard  
National Police 

FI 

Ministry of Finance, Ministry of Economic Affairs and Employment, Ministry of Agriculture 
and Forestry, Ministry of the Interior, State Treasury, Finnish Food Authority 

FR 

ANCT, MICAF, ANAFE, DGTrésor 

1.  Ministry  of  Agriculture,  Forestry  and  Fisheries  and  Paying  Agency  for  Agriculture, 
Fisheries and Rural Development   

2. Ministry of Justice, Public Administration and Digital Transformation   

HR 

3. Ministry of Labour, Pension System, Family and Social Policy (Managing Authority for 
the  Operational  Programme  Efficient  Human  Resources  2014-2020  and  Programme 
Efficient  Human  Resources  2021-2027)  and  Intermediate  body  level  2  -  Croatian 
Employment Office, Office for Financing and Contracting of EU Projects   

4. Ministry of Regional Development and EU funds (Managing Authority for the Operational 
Programme Competitiveness and Cohesion 2014-2020 and Programme Competitiveness 
and Cohesion 2021-2027 and Integrated Territorial Programme) and Intermediate Bodies 

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Member 
State 

Response 

level 2 - Central Finance and Contracting Agency for European Union Programmes and 
projects  (CFCA),  Croatian  Agency  for  SMEs,  Innovation  and  Investments  (HAMAG-
BICRO), Croatian Waters   

5. Ministry of Finance, Customs Administration   

6. Ministry of Finance, Tax Administration   

7.  Ministry  of  Agriculture,  Forestry  and  Fisheries,  Directorate  of  Fisheries  -  the  EMFAF 
Managing Authority  

8. Croatian AFCOS Unit at the Ministry of Finance 

HU 

The National Development Centre’s Internal Audit and Integrity Directorate and Common 
Services Directorate, and the members of the Artificial Intelligence Working Group and the 
Irregularity Reporting Working Group. 

An Garda Siochana  

Department of Agriculture, Food and the Marine.  

Department of Education  

Department of Finance (AFCOS)  

Department of Further and Higher Education  

Department of Justice  

Department of Public Expenditure  

IE 

Department of Housing  

Department of Transport  

Garda National Economic Crime Bureau  

Special EU Programming Body  

Northern and Western Regional Assembly  

Southern Regional Assembly  

Eastern and Midland Regional Assembly  

Revenue Commissioners 

involvement  of  all  of 

follow-up  was  prepared  with 

This 
following 
the 
institutions/administrations  that  make  up  the  Italian  AFCOS  pursuant  to  Article  3  of 
Presidential Decree No 91/2007 and Article 3 of Decree-Law No 19/2024:   
Department for European Affairs at the Prime Minister’s Office;   
Department for Cohesion Policy and Southern Italy at the Prime Minister’s Office;   
Department of Public Administration at the Prime Minister’s Office;   
Department for Regional Affairs and Autonomies at the Prime Minister’s Office;   
NRRP Unit at the Prime Minister’s Office;   
Special Economic Zones (SEZ) Unit at the Prime Minister’s Office;   
Italian Court of Auditors;   

the 

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IT 

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

Member 
State 

Response 

Infrastructure  and 

for  High-Level  Oversight  of  Priority 

Network  of  NRRP  Anti-Fraud  Contact  Persons  at  the  State  General  Accounting 
Department;   
Coordination  Committee 
Construction Projects (CCASIIP);    
Carabinieri;   
the Guardia di Finanza (financial police);   
National Anti-Corruption Authority (ANAC);   
Financial Intelligence Unit (FIU) at the Bank of Italy;   
National Anti-Mafia and Anti-Terrorism Directorate;   
Central Criminal Police Directorate;   
Anti-Mafia Investigation Directorate;   
Ministry of the Interior;   
Ministry of Justice;   
Ministry of Economic Affairs and Finance;   
Ministry of Enterprises and Made in Italy;   
Ministry of Agriculture, Food Sovereignty and Forestry;   
Ministry of Infrastructure and Transport;   
Ministry of Labour and Social Policy;   
Ministry of Education and Merit;   
Customs and Monopolies Agency;   
Revenue Agency;   
Agricultural Payments Agency (AGEA);   
Joint Conference. 

LT 

Ministry of Finance, Ministry of the interior. 

LU 

LV 

MT 

NL 

PL 

Ministry of Housing and Spatial Planning - Ministry of the Economy - Ministry of Labour - 
Ministry  of  Agriculture,  Food  and  Viticulture  -  Ministry  of  Finance  and  Ministry  of  Home 
Affairs  

All authorities from the AFCOS network. 

Ministry for European Funds and the Implementation of the Electoral Programme (MFI) 

Ministry  of  Justice,  Ministry  of  Social  Affairs,  Ministry  of  Economic  Affairs,  Ministry  of 
Agriculture  (management  authorities  /  policy  implementation),  paying  agencies  and 
AFCOS. 

Ministry  of  Funds  and  Regional  Policy  (partnership  agreement  coordinating  authority), 
Agency for Restructuring and Development of Agriculture (paying agency) and Ministry of 
Finance (AFCOS). 

Inspeção-Geral de Finanças (inspectorate-general of finances) (AFCOS)   

Agência para o Desenvolvimento & Coesão (agency for development and cohesion)   

PT 

Instituto de Financiamento da Agricultura e Pescas (Institute for the funding of farming and 
fisheries)   

Estrutura de Missão Recuperar Portugal (‘Portugal recovery’ task force)   

Autoridade Tributária e Aduaneira (tax and customs authority) 

English translation  

Romanian 
National Agency for Public Procurement  
Agenția Națională pentru Achiziții Publice 
Agenția Națională de Administrare a Bunurilor Indisponibilizate  National  Agency  for  the 
Administration of Seized Assets  

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RO 

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PIF Report 2024 

Member 
State 

Response 

of 

of 

for 

Agency 

Labour, 

Ministry 

Ministry of Energy  

Ministry of Culture  

for  Payments  and 

Ministry of Development, 

National Integrity Agency  

Certifying and Paying Authority  

National Agency of Civil Servants  

Ministry of Education and Research  

Ministry  of  Agriculture  and  Rural 

National Agency for Fiscal Administration  
the  Financing  of  Rural 

Agenția Națională de Administrare Fiscală 
Agenția pentru Finanțarea Investițiilor Rurale  Agency 
Investments  
Agenția Națională a Funcționarilor Publici 
Agenția Națională de Integritate 
Agenția de Plăți și Intervenție pentru Agricultură 
Intervention for Agriculture  
Autoritatea de Certificare și Plată 
Consiliul Concurenței  Competition Council  
Ministerul Afacerilor Interne  Ministry of Internal Affairs  
Ministerul Agriculturii și Dezvoltării Rurale 
Development  
Ministerul Economiei, Digitalizării, Antreprenorialului și Turismului 
Economy, Digitalisation, Entrepreneurship and Tourism  
Ministerul Culturii 
Ministerul Dezvoltării, Lucrărilor Publice și Administrației 
Public Works and Administration  
Ministerul Educației și Cercetării 
Ministerul Energiei 
Ministerul Muncii, Familiei, Tineretului și Solidarității Sociale  Ministry 
Family, Youth and Social Solidarity  
Ministerul Finanțelor  Ministry of Finance  
Ministerul Investițiilor și Proiectelor Europene  Ministry  of  Investments  and  European 
Projects  
Ministerul Mediului, Apelor și Pădurilor  Ministry of Environment, Waters and Forests  
Ministerul Sănătății  Ministry of Health  
Ministerul Transporturilor și Infrastructurii 
Oficiul Național de Prevenire și Combatere a Spălării Banilor  National  Office  for  the 
Prevention and Control of Money Laundering  
Secretariatul General al Guvernului 
Autoritatea Națională pentru Administrare și Reglementare în Comunicații 
Authority for Management and Regulation in Communications  
Agenția pentru Dezvoltare Regională Nord-Est  North-East 
Agency  
Agenția pentru Dezvoltare Regională Sud-Est  South-East 
Agency  
Agenția pentru Dezvoltare Regională Sud Muntenia 
Development Agency  
Agenția pentru Dezvoltare Regională Vest – ADR Vest  West  Regional  Development 
Agency (ADR Vest)  
Agenția pentru Dezvoltare Regională Sud-Vest Oltenia  South-West  Oltenia  Regional 
Development Agency  
Agenția pentru Dezvoltare Regională București-Ilfov 
Development Agency  
Agenția pentru Dezvoltare Regională Nord-Vest 
Development Agency  
Agenția pentru Dezvoltare Regională Centru – ADR Centru 
Development Agency (ADR Centre)  
Parchetul de pe lângă Înalta Curte de Casație și Justiție Public 
attached to the High Court of Cassation and Justice  
Autoritatea de Audit  Audit Authority  
Autoritatea Vamală Română  Romanian Customs Authority  
Ministerul Justiției 

Secretariat-General of the Government  

Ministry of Transport and Infrastructure  

Ministry of Justice 

South-Muntenia 

Bucharest-Ilfov 

Development 

Development 

Prosecutor’s 

North-West 

Regional 

Regional 

Regional 

Regional 

Regional 

Regional 

National 

Centre 

Office 

SE 

The Swedish Agency for Economic and Regional Growth, the Swedish ESF Council and 
the Swedish Economic Crime Authority. 

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PIF Report 2024 

Member 
State 

Response 

SI 

URSOO, AKTRP, FURS, UPPD, MNZ, MKRR. 

SK 

the  Slovak  Republic,  Ministry  of 

Investments,  Regional  Development  and 

Bratislava Self-Governing Region - Interact, Ministry of Transport of the Slovak Republic, 
Ministry of Finance  
of 
Informatization of the Slovak  
Republic,  Ministry  of  Agriculture  and  Rural  Development  of  the  Slovak  Republic, 
Agricultural Paying Agency,  
Ministry  of  Health  of  the  Slovak  Republic,  Ministry  of  the  Environment  of  the  Slovak 
Republic, Supreme Audit  
Office  of  the  Slovak  Republic,  Antimonopoly  Office  of  the  Slovak  Republic,  Public 
Procurement Office,  
Government  Office  of  the  Slovak  Republic,  Ministry  of  Justice  of  the  Slovak  Republic, 
Ministry of Labour, Social  
Affairs and Family of the Slovak Republic, Ministry of  Economy of the  Slovak Republic, 
Ministry of the Interior of  
the Slovak Republic, Ministry of Culture of the Slovak Republic, Financial Directorate of 
the Slovak Republic,  
General  Prosecutor's  Office  of  the  Slovak  Republic,  Ministry  of  Education,  Research, 
Development and Youth  
of  the  Slovak  Republic,  National  Implementation  and  Coordination  Authority  (NICA)– 
Office of the Deputy Prime Minister of the Slovak Republic for the Recovery and Resilience 
Plan and Knowledge Economy. 

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