EN EN

EUROPEAN COMMISSION

Brussels, 18.9.2026 COM(2026) 491 final

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND

THE COUNCIL

on the implementation and impact of Regulation (EU) 2017/1939 on the European

Public Prosecutor’s Office

{SWD(2026) 278 final}

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1. Introduction

In 2017, the Council adopted Regulation (EU) 2017/1939 of 12 October 2017 implementing

enhanced cooperation on the establishment of the European Public Prosecutor’s Office (the

EPPO) (‘the EPPO Regulation’)1, which entered into force on 20 November 2017. During the

evaluation period, three EU Member States did not participate in the EPPO (Denmark, Hungary

and Ireland). However, on 29 May 2026, Hungary notified the Commission of its intention to

join the EPPO. The Commission adopted its Decision confirming Hungary’s participation in

the EPPO on 10 July 2026, which entered into force on 2 August 20262.

The EPPO is the public prosecution office of the EU, responsible for investigating, prosecuting

and bringing to judgement perpetrators of crimes affecting the EU’s financial interests provided

for in Directive (EU) 2017/1371 (‘the PIF Directive’)3 and determined by the EPPO Regulation

(‘PIF crimes’). The PIF Directive lays down a definition of – and penalties for – the following

criminal offences, to the extent that they damage or are likely to damage the EU’s financial

interests: (i) fraud, including cross-border VAT fraud involving a total damage of at least EUR

10 million; (ii) corruption4; (iii) misappropriation; and (iv) money laundering. It also includes

provisions on ancillary offences. Additionally, the EPPO is responsible for investigating and

prosecuting: (i) offences involving participation in a criminal organisation, if the focus of the

criminal organisation is to commit PIF crimes; and (ii) offences inextricably linked to PIF

crimes5.

The EPPO, which is independent and acts in the interest of the EU as a whole, began operations

on 1 June 2021. The EPPO is a key component of the EU’s anti-fraud architecture (AFA), which

has evolved over time with a set of policies, bodies and mechanisms. These policies, bodies and

mechanisms that make up the AFA include: (i) the European Anti-Fraud Office (OLAF); (ii)

the European Union Agency for Criminal Justice Cooperation (Eurojust); (iii) the European

Union Agency for Law Enforcement Cooperation (Europol); (iv) the Authority for Anti-Money

Laundering and Countering the Financing of Terrorism; and (v) new and upcoming actors, such

as the European Union Customs Authority. With its White Paper of July 2025, the Commission

launched a reflection on how the EU’s AFA can be strengthened and modernised to provide

better protection for the EU’s financial interests6.

The creation of the EPPO aimed to improve the protection of the EU budget as well as address

long-standing shortcomings in the AFA, especially in investigations and prosecutions of PIF

crimes. Prior to the creation of the EPPO, national authorities were the only ones responsible

for investigating and prosecuting PIF crimes, and they faced significant limitations, especially

in cross-border cases. This fragmentation created substantial challenges in addressing complex

1 OJ L 283, 31.10.2017, pp. 1-71, ELI: http://data.europa.eu/eli/reg/2017/1939/oj. 2 Commission Decision (EU) 2026/1701, OJ L, 2026/1701, 13.7.2026, ELI:

http://data.europa.eu/eli/dec/2026/1701/oj. With the entry into force of this Decision, the EPPO Regulation has

ceased to be an act adopted within the framework of enhanced cooperation and has become automatically an

ordinary act of Union law, to be regarded as part of the acquis which has to be accepted by candidate States for

accession to the EU. 3 OJ L 198, 28.7.2017, pp. 29-41, ELI: http://data.europa.eu/eli/dir/2017/1371/oj. PIF stands for ‘protection des

intérêts financiers’ (protection of the financial interests). 4 With the entry into force of Directive (EU) 2026/1021 on combating corruption (OJ L, 2026/1021, 11.5.2026,

ELI: http://data.europa.eu/eli/dir/2026/1021/oj), references to ‘corruption’ in the PIF Directive have been replaced

with ‘bribery’. 5 The EPPO can exercise its competence over criminal offences inextricably linked to PIF crimes only when the

conditions set out in Article 25(3) of the Regulation are met (see below, fn 16). Unless otherwise specified, the

Articles and Chapters mentioned in this report refer to Articles and Chapters of the EPPO Regulation. 6 White Paper for the Anti-fraud Architecture Review, COM(2025) 546 final, 16.7.2025. The results of the AFA

review will be presented in a Commission Communication planned for the end of 2026.

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fraud cases, including large-scale cross-border VAT fraud. National authorities often lacked the

necessary tools, resources and/or expertise to act swiftly and effectively across jurisdictions,

leading to gaps in enforcement and accountability.

At the same time, due to limitations in their mandates, the existing EU bodies and agencies had

limited means to ensure the effective protection to the EU’s financial interests. Eurojust and

Europol were limited to giving support to – and coordinating the work of – national judicial and

law enforcement authorities. Similarly, OLAF, as a body tasked with carrying out

administrative investigations, relied and continues to rely on the national authorities for any

judicial follow-up. The insufficient recovery of proceeds of PIF crimes and the insufficient

return of these proceeds to the EU budget were additional problems, as they are still today. The

impact assessment accompanying the Commission proposal for an EPPO Regulation estimated

that less than 10% of the total amount of fraud was ever recovered7. The level of deterrence

was also low.

The EPPO was therefore expected to address the need to: (i) better prevent PIF crimes; (ii)

ensure the common investigation and enforcement for such offences; and (iii) put in place a

common European prosecution policy for these crimes. To address these needs, the EPPO

Regulation set the general objective of contributing to the strengthening of the protection of

the EU’s financial interests through the following four specific objectives:

• to investigate, prosecute, and bring to judgment perpetrators of, and accomplices to, PIF

crimes in national cases;

• to enable more effective investigations and prosecutions of cross-border PIF crimes by

establishing a common EU investigation and prosecution zone and allowing for more

effective investigations and prosecutions in cross-border cases;

• to ensure consistency and fairness across Member States by establishing common rules

and procedures for the investigation and prosecution of PIF crimes;

• to ensure the independence and accountability of prosecutions for PIF crimes and

gain/foster public trust in such prosecutions.

2. Purpose and scope of the evaluation

The purpose and scope of the present evaluation are regulated by Article 119(1) of the EPPO

Regulation. The evaluation serves four main objectives. Firstly, it examines whether the EPPO

Regulation has been completely and correctly implemented. Secondly, it assesses the EPPO’s

governance and use of resources, including significant obstacles to its activities and possible

areas for simplification and reduction of administrative burden. Thirdly, it assesses the EPPO’s

performance and its working practices in relation to its objectives and tasks (as well as the

overall impact of the EPPO on the problems it was meant to address) against the Better

Regulation criteria of effectiveness, efficiency, relevance, coherence and EU added value.

Fourthly, it identifies lessons learnt and points to areas for improvement.

The evaluation covers the period from the EPPO Regulation’s entry into force on 20 November

2017 until the end of June 2025, while taking account, where relevant, of developments until

13 July 2026. It covers the 24 EU Member States participating in the enhanced cooperation on

the establishment of the EPPO (‘Member States’) during the evaluation period and, where

relevant, the non-participating Member States. The evaluation also considers the EPPO’s

7 SWD(2013) 274 final (the ‘impact assessment’), 17.7.2013, p. 24. The impact assessment is available here:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=swd:SWD_2013_0274.

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cooperation with relevant EU institutions, bodies, offices and agencies (IBOAs) as well as

international organisations and non-EU countries, including enlargement partners.

This is the first evaluation of the EPPO Regulation. Its baseline is therefore the situation before

the EPPO was created, where national authorities were responsible for investigating and

prosecuting PIF crimes. The data presented in the 2013 impact assessment refer to the situation

in 2011, approximately one decade before the EPPO started its operations, and are overall quite

limited. The impact assessment provided some data on the extent to which Member States

followed up on cases transferred to national judicial authorities by OLAF. It reported that, by

the end of 2011, national judicial authorities had decided on 471 out of a total of 1 030 actions

transferred to them by OLAF in the period between 2006 and 2011. Out of these 471 decisions,

199 had resulted in a conviction by a criminal court8.

The total annual financial impact of irregularities identified as ‘suspected fraud’ by OLAF in

2011 was estimated at EUR 404 million (EUR 295 million for expenditure and EUR 109 million

for revenues)9. However, the 2013 impact assessment noted that this amount is seriously

underestimated, as it is dependent on Member States’ willingness and capability to detect and

record crime and also to report it to the competent EU bodies10.

3. Key findings

3.1. Effectiveness

The evaluation finds that the EPPO Regulation has been effective in establishing and

operationalising a new, well-functioning EU-level investigative and prosecutorial

framework for PIF offences, and in generating early operational results consistent with its

objectives. Since becoming operational in 2021, the EPPO has steadily increased its activities.

This is reflected in part by the significant increase in: (i) investigations opened (576 in 2021

and 2 030 in 2025); (ii) freezing orders granted by national authorities upon its request (EUR

147.3 million in 2021 and EUR 1.13 billion in 2025); (iii) indictments issued (5 in 2021 and

275 in 2025); and (iv) convictions obtained (1 in 2021 and 159 in 2025)11.

Although the lack of structured pre-EPPO data makes comparison difficult, the available

evidence supports the conclusion that the EPPO has addressed the fragmentation of national

enforcement and strengthened the handling of cases, including in particular cross-border cases.

The EPPO Regulation and the EPPO itself have made a substantial contribution to the intended

objectives by creating an operational framework that enables independent investigations and

prosecutions to be pursued under a common EU mandate, while mainly relying on decentralised

delivery through national systems. The evidence indicates the EPPO’s increasing operational

activity and capacity to handle complex cases, and in particular cross-border cases where the

EPPO’s effectiveness and EU added value are even higher. The EPPO has indeed moved

beyond traditional judicial cooperation mechanisms by putting in place an integrated EU-

wide investigation and prosecution framework for PIF offences. Under the previous system,

cross-border evidence gathering relied heavily on mutual legal assistance procedures, which

were often time-consuming. Under the EPPO framework, European Delegated Prosecutors

(EDPs) may directly assign investigative measures to EDPs in other participating Member

States, substantially streamlining cross-border investigations. In 2025 alone, EDPs issued 1 524

such requests.

8 Ibid. p. 15. 9 Ibid. pp. 75-76. 10 Ibid. p. 91. 11 Data for 2021 refer to seven months of activity only (1 June-31 December).

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A further key achievement lies in the successful implementation of the EPPO’s hybrid

institutional model, combining a central office with EDPs embedded and operating in

national systems. This structure has allowed the EPPO to have better visibility, compared to

national authorities, over complex cases and coordination across jurisdictions, enabling a more

consistent approach to investigations and prosecutions. The EPPO’s centralised overview of

investigations, coupled with EDPs on the ground, is a significant operational advantage. It

enables the EPPO to identify links between cases that might otherwise remain undetected by

national authorities, as shown in flagship EPPO cases such as Admiral, Calypso and Midas. For

example, in 2024, the EPPO organised 41 multi-site action days. Action days have proven to

be an effective operational tool as they involve simultaneous searches, arrests and asset seizures

across several jurisdictions. Governance arrangements, including the role of the EPPO’s

Permanent Chambers and the EPPO College, have contributed to strategic direction and

oversight, although the evidence base on the internal functioning of the EPPO remains limited12.

Furthermore, the EPPO’s cooperation with national authorities, EU institutions, and external

partners has also developed positively, allowing access to information and operational support.

However, challenges remain, as explained in more detail in Section 3.3 below.

The evaluation finds that the EPPO Regulation’s specific objective of ensuring consistency

and fairness across Member States by establishing common rules and procedures for the

investigation and prosecution of PIF crimes is yet to be fully achieved. The EPPO College has

adopted internal rules and guidelines to ensure a uniform operational framework, and the

Permanent Chambers ensure consistency in EPPO cases. However, consistency depends to a

large extent on the implementation of the Regulation by Member States. The evaluation notes

some areas where uneven implementation has prevented the EPPO from fully exercising its

investigative powers.

Qualitative evidence shows that the establishment of the EPPO has led to greater public trust,

with several stakeholders emphasising the importance of a truly independent, EU-level public

prosecutor’s office in charge of combating PIF crimes.

In short, and despite some limitations linked to the uneven implementation of the EPPO

Regulation, the EPPO’s activities have effectively addressed key weaknesses identified at the

time of the baseline assessment, in particular: (i) the fragmentation of enforcement; (ii) uneven

prioritisation of PIF offences; and (iii) practical barriers to pursuing complex cross-border cases

through purely national mechanisms.

As regards the broader impact of the EPPO’s activities, including final judicial outcomes,

financial recovery achieved through final decisions, and longer-term impacts such as

deterrence, decisive evidence that would allow to measure it is only partly available. This is

due to several factors. Firstly, the data collected by the EPPO concern investigative and

prosecutorial activities rather than the broader impacts of these activities. Secondly, criminal

proceedings can only be regarded as finalised once all available remedies have been exhausted,

a process that often takes several years. Thirdly, Member States are under no obligation to

report to the EPPO information such as the number of convictions, acquittals or amounts

recovered. Finally, even where such data are available, they reflect only the EPPO’s direct

impact on the cases it has handled and do not measure broader effects, such as increased

deterrence or improved protection of the EU’s financial interests.

12 The study team that conducted the external support study faced challenges in obtaining the required level of

breadth and balance of primary evidence, as it was not granted direct access to the EDPs.

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3.2. Efficiency

The evaluation finds that the EPPO has generally used its allocated resources efficiently to

attain its objectives, in a context where the extent of its operational activity far exceeded

expectations. The revised Legislative Financial Statement (LFS)13 anticipated that the EPPO

would handle around 970 active cases annually from 2023 onwards. In practice, the EPPO

already handled 515 active cases during its first seven months of operations in 2021, increasing

to 3 602 active cases by the end of 2025. The EPPO’s budget and staff also increased

considerably during the evaluation period to cater for the increased workload, includingin light

of the EPPO’s mandatory prosecution obligations14 and the growing number of crime reports

Over the evaluation period, the EPPO demonstrated strong organisational and financial

management capacity, including high budget execution rates and prioritisation of operational

work, delivering considerable operational efficiency compared with the pre-EPPO situation.

The evaluation finds that the EPPO’s structure and operational model has generated substantial

efficiencies, especially in complex cross-border investigations. The EPPO has improved

coordination across jurisdictions, accelerated investigations and prosecutions, and strengthened

the EU’s ability to detect and investigate cross-border fraud, especially VAT fraud schemes.

The evaluation finds that the overall benefits of the EPPO could significantly outweigh the costs

related to its establishment and functioning. This is especiallytruewhen bearingin mind the

‘knock on’ effects following from the EPPO’s operations, such as improvements to deterrence

and greater protection of the EU budget. The EPPO has delivered significant operational

efficiencies compared with the pre-EPPO situation, particularly in complex cross-border cases.

The creation of the EPPO has allowed to better detect fraud and enabled significant levels of

cross-border cooperation that are reportedly much quicker than the pre-EPPO situation.

Furthermore, the operational structure put in place by the Regulation works well, making it

easier to: (i) mobilise resources and expertise; (ii) coordinate investigations; and (iii) streamline

prosecutions across multiple jurisdictions. This all helps to make investigations more efficient.

At the same time, the evaluation identifies some areas where further efficiency gains are

possible, such as in the work of the EPPO’s Permanent Chambers, which are a useful forum for

supervision and direction of EPPO cases, in particular in complex cross-border cases. The

evaluation also identifies shortcomings in the EPPO’s digital infrastructure, particularly its

Case Management System (CMS).

Further efficiency gains also depend on the Member States. For instance, the EPPO’s

investigations rely on law enforcement resources at the national level. The evaluation finds that

the support given to the EPPO is uneven across Member States, with the levels of staffing of

national law enforcement bodies supporting the EPPO varying from one Member State to the

other. In some instances, Member States set up dedicated police forces to support the EPPO,

which the EPPO welcomed. In other Member States, the EPPO liaises with different authorities,

according to the specific circumstances of each case.

Other challenges in the EPPO’s work that impact its efficiency derive from the inadequate

implementation of the EPPO Regulation in the Member States. The assessment of the

conformity of national legislation with the EPPO Regulation identified a set of recurring issues

13 The LFS accompanying the 2013 Commission proposal was revised in June 2017. Further references are thus

made to the ‘revised LFS’, which is available here: https://www.eppo.europa.eu/sites/default/files/2025-

08/Commission_Revised_LFS_EPPO_2017.pdf. 14 Whenever there are reasonable grounds to believe that a PIF offence is being – or has been – committed, the

EPPO ‘shall’ initiate an investigation (Article 26(1)), with only a few exceptions (see Article 25(2)).

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in the implementation of the Regulation across Member States15, such as national legislation

not allowing direct reporting from national competent authorities to the EPPO. This may reduce

the number of relevant reports sent to the EPPO in a timely manner and potentially delay the

opening of cases.

3.3. Coherence

The evaluation concludes that the EPPO Regulation and its implementation have proven to

be coherent overall, both internally and externally, despite some gaps, inconsistencies and/or

ambiguities.

The internal assessment shows that, although the Regulation is consistent in its overarching

design and objectives, some specific issues have been identified, in particular in the following

three areas: (i) the difficulty in calculating, especially at the early stages of an investigation, the

threshold of EUR 10 million of total damage resulting from cross-border VAT fraud, which

needs to be met for the EPPO to exercise its competence; (ii) the notion of the ‘focus’ of activity

of criminal organisations, as the EPPO can investigate and prosecute organised crime cases

only if the focus of an organised crime group is to commit PIF crimes; and (iii) the complex

rules governing the EPPO’s exercise of competence over inextricably linked offences16.

Stakeholders also identified structural tensions in the EPPO’s data protection regime under

Chapter VIII of the Regulation, which does not always clearly delineate the scope of its data

protection provisions vis-à-vis national law. This means that it is not always clear where the

Regulation ends and where national law begins, nor how the two should interact in practice.

On external coherence, the evaluation finds that the EPPO Regulation is broadly consistent with

the relevant EU, national, and international interventions. This is despite some limitations in

cooperation with non-EU countries, which do not always recognise the EPPO as a competent

authority for the purpose of judicial cooperation. One of the areas examined by the external

coherence assessment is the EPPO Regulation’s coherence with the EU Charter of Fundamental

Rights, the European Convention on Human Rights, the procedural rights Directives, and the

case law of the Court of Justice of the EU and European Court of Human Rights. No major

structural non-compliance issues were identified. However, the evaluation notes that

differences in national procedural safeguards and shortcomings in the transposition of the

procedural rights Directives affect the uniformity of defence rights in EPPO proceedings,

particularly on legal aid, access to case files, translation practices, and standards of pre-trial

detention.

Furthermore, the evaluation notes that the EPPO’s mandate is generally consistent with the

mandates of OLAF, Europol, Eurojust and other relevant EU bodies. Overall, cooperation

frameworks broadly function well, although challenges remain, particularly concerning

information sharing, hit/no-hit systems and the risk of parallel investigations, which are issues

under reflection for the upcoming AFA review17.

15 For the detailed assessment of the conformity of national legislation with the EPPO Regulation, see Annexes 6

and 7 to the study supporting the evaluation, ISBN 978-92-68-42141-3, available here:

https://commission.europa.eu/law/cross-border-cases/judicial-cooperation/networks-and-bodies-supporting-

judicial-cooperation/european-public-prosecutors-office-eppo_en. 16 When PIF crimes are inextricably linked to non-PIF crimes (e.g. forgery of documents), the EPPO, pursuant to

Article 25(3), cannot exercise its competence if: (a) the maximum sanction provided for by national law for the

PIF offence is equal to or less severe than the maximum sanction for the inextricably linked offence, unless the

latter offence has been instrumental to commit the PIF offence; or (b) there is a reason to assume that the damage

(likely to be) caused to the EU’s financial interests by the PIF offence does not exceed the damage (likely to be)

caused to another victim. 17 White Paper for the Anti-fraud Architecture Review, pp. 8-12.

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Cooperation with Eurojust

Eurojust supports and works with national prosecutorial and judicial authorities to combat a

wide range of serious and complex cross-border crimes, including PIF crimes. The EPPO and

Eurojust signed a Working Arrangement in February 202118 and allowed each other indirect

access to information in their respective CMSs based on a hit/no-hit system. However, the

evaluation highlights that the system is not automated and that exchange of data could be

optimised19.

Cooperation between the EPPO and Eurojust mostly takes place via meetings between the

European Chief Prosecutor and the Eurojust President and between the respective liaison teams,

where possibilities to strengthen institutional cooperation and coordination are discussed. The

EPPO is also supported by national desks at Eurojust.

This evaluation, as well as the recent evaluation of Eurojust20, suggests that both: (i) overall

operational cooperation between the EPPO and Eurojust is strong and consistent (although the

two bodies have so far cooperated in only a limited number of cases21); and (ii) there is room

for further improvement, for instance with regard to the hit/no-hit mechanism.

Cooperation with OLAF

Both the EPPO and OLAF have been tasked with protecting the EU’s financial interests by

investigating conduct affecting these interests. OLAF’s core mission is to carry out

administrative investigations for the purpose of fighting fraud, corruption and any other illegal

activity affecting the EU’s interests as well as into serious misconduct by EU staff and members

of the EU institutions, while the EPPO is responsible for investigating, prosecuting and bringing

to judgment PIF crimes.

In accordance with Article 101 of the EPPO Regulation, the relationship between the EPPO

and OLAF should aim in particular to ensure that all available means are used to protect the

EU’s financial interests through complementarity and support by OLAF to the EPPO, based on

the principle of non-duplication save in specific circumstances determined in the relevant legal

instruments in which both bodies can investigate the same facts. When OLAF conducts

complementary investigations, the EPPO and OLAF can investigate the same facts

simultaneously from two different viewpoints, based on the principle of non-duplication22, with

the aim for OLAF to collect information relevant for either: (i) the adoption of precautionary

measures; or (ii) the conduct of financial, disciplinary or administrative action. . Furthermore,

in some cases the EPPO has requested support from OLAF during its own investigations. As

OLAF stakeholders have reported, such support from OLAF is particularly valuable in complex

financial or structural projects, where OLAF’s administrative expertise is essential. Between

2021 and 2024, OLAF conducted complementary administrative investigations in 84 cases, and

18 This and all other Working Arrangements and Agreements mentioned in this report are available on the EPPO’s

website (https://www.eppo.europa.eu/documents_en). 19 The EPPO submitted eight names for cross-checking to Eurojust in 2024, while Eurojust has not sent any request

to the EPPO in the same timeframe. 20 Evaluation of the European Union Agency for Criminal Justice Cooperation, SWD(2025) 182 final. 21 In 2022, Eurojust supported 14 cases involving the EPPO, 26 cases in 2023, and 25 cases in 2024. The two

bodies have implemented agreements on the workflow of the EPPO cases to be handled by Eurojust and the

EPPO’s participation in joint investigation teams supported by Eurojust. 22 OJ L 248, 18.9.2013, pp. 1-22, ELI: http://data.europa.eu/eli/reg/2013/883/oj, as amended by Regulation (EU,

Euratom) 2016/2030 OJ L 317, 23.11.2016, pp. 1-3, ELI: http://data.europa.eu/eli/reg/2016/2030/oj and

Regulation (EU, Euratom) 2020/2223, OJ L 437, 28.12.2020, pp. 49-73, ELI:

http://data.europa.eu/eli/reg/2020/2223/oj.

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carried out support activities in 22 cases. This represents a small proportion of the total number

of investigations opened by both the EPPO and OLAF23.

Cooperation between the EPPO and OLAF, which is also regulated in the Working

Arrangement signed in July 2021, requires the two bodies to exchange information, including

through the hit/no-hit system, which is currently suboptimal as it is not automated.

Although the mandates of the EPPO and OLAF are distinct24, this evaluation finds that the

overall legal framework for cooperation between the two offices remains complex. National

authorities are obliged to report to the EPPO any criminal conduct in respect of which the EPPO

can exercise its competence. EU IBOAs are obliged to report to both the EPPO and OLAF.

National authorities may also voluntarily report to OLAF, and private parties may report to the

EPPO and/or OLAF. This can create an administrative burden for the EPPO and OLAF because,

in many cases, both offices have to assess the input received, which may result in duplications

of reporting and investigations.

Where OLAF identifies suspicions of criminal offences, it is required to submit an EPPO Crime

Report (ECR) to the EPPO. OLAF is the largest source of case referrals to the EPPO among

the EU IBOAs, and its role is therefore central to ensuring effective reporting to the EPPO,

whether by sending ECRs or by assessing and referring reports emanating from other IBOAs

to the EPPO25. However, as the EPPO receives more reports from other sources, such as

national authorities and private sectors, the EPPO considers the number of ECRs sent by OLAF

(as well as other IBOAs) not sufficient.

In accordance with Article 101(4) of the EPPO Regulation, the EPPO ‘may’ provide

information to OLAF if it decides not to conduct an investigation or has dismissed a case. The

European Court of Auditors’ Special Report 26/2025 found that such reporting from the EPPO

to OLAF is limited and this may reduce the potential for administrative follow-up26.

Cooperation with Europol

Europol supports law enforcement authorities in preventing and combating serious crime,

including PIF crimes, and terrorism. In January 2021, the EPPO and Europol concluded a

Working Arrangement, which was followed by an arrangement on the exchange and protection

of classified information, and a Memorandum of Understanding on secure communication

(both signed in November 2021).

Overall, the evaluation concludes that the cooperation between Europol and the EPPO is good

and clearly defined, with the mandates of both bodies being respected and the provisions of the

Working Arrangement well implemented27.

The EPPO and Europol have set up the EPPO-Europol Steering Committee, which meets once

or twice a year and decides on strategic priorities. The EPPO has indirect access to Europol data

23 For example, in 2024, the EPPO opened 1 504 investigations, compared with 5 support activities and 21

complementary investigations performed by OLAF in the same year. 24 The European Court of Auditors (ECA) reached the same conclusion in its special report 26/2025, ‘EU bodies

fighting fraud – Clear mandates but exchange of information and Commission oversight remain insufficient’ (‘the

ECA Special Report 26/2025’). The report is available here: https://www.eca.europa.eu/en/publications?ref=SR-

2025-26. 25 Recital 51 of the EPPO Regulation provides that, to comply with the obligation to inform the EPPO where a

suspicion of a PIF offence is identified, EU IBOAs should have in place efficient mechanisms for a preliminary

evaluation of allegations reported to them and may make use of OLAF to that end. 26 The ECA Special Report 26/2025, pp. 27-28. 27 Between 2022 and 2024, the number of requests for which Europol provided support to the EPPO grew from 28

to 83 (158 in total in the whole period). On the other hand, Europol submitted a total of 12 ECRs over the same

period.

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in relation to offences within its mandate through a hit/no-hit system, which the evaluation finds

neither up to date nor efficient. As a follow-up to searches and hits found, Europol shares data

via its Secure Information Exchange Network Application (SIENA), which the EPPO joined in

2022. SIENA is designed to enable the exchange of operational and strategic crime-related

information and intelligence between Member States, Europol and its partners.

Stakeholders noted that the ownership of Europol data rests with the Member States. This can

result in delayed access for the EPPO, as Europol must seek Member States’ consent before

sharing these data. Europol stakeholders stressed the fact that any data the EPPO receives and

that are not relevant to it, but could be useful to Europol, should be shared with Europol.

Cooperation with the European Commission

In 2021, the EPPO and the Commission signed a Cooperation Agreement, which was revised

in 2024. The main purpose of the revision was to improve the EPPO’s notifications to the

Commission, so as to enable the Commission to take precautionary and corrective measures.

As part of the amendments, the EPPO was also granted direct access to several databases, and

new notification templates were introduced, as well as the ‘EPPO box’, which is a dedicated

and secure tool to exchange case-related information.

Stakeholders’ feedback on those amendments is generally positive, as they allow for more direct

exchanges of information between the relevant Commission services and the EPPO, instead of

communicating via OLAF. In 2025, the EPPO notified indictments and simplified prosecution

procedures to the Commission amounting to: (i) EUR 171.3 million of estimated damage related

to expenditure fraud; and (ii) EUR 1.19 billion of estimated damage related to revenue fraud.

However, it was not possible to establish the precise number of notifications received by the

Commission. There is an ongoing process to both refine the notification procedures and

improve the effectiveness of the EPPO’s notifications for the purpose of the Commission’s

follow-up.

Overall, the Directorates-General (DGs) of the Commission responsible for the management of

EU funds have referred to the EPPO as a ‘game changer’ for its ability to connect cross-border

fraud patterns that were difficult to address using purely national approaches. Some DGs noted

the EPPO’s reluctance to share information with the Commission due to confidentiality issues

related to ongoing criminal investigations, although they also reported that steps had been taken

over the evaluation period to improve information exchange.

Cooperation with non-participating Member States and non-EU countries

The evaluation reports that the EPPO is committed to ensuring strong cooperation with non-

participating Member States and non-EU countries, which is crucial for investigating and

prosecuting cross-border cases and recovering assets.

The number of non-participating Member States has reduced over the evaluation period as

Poland and Sweden joined the EPPO in 2024. Hungary joined the EPPO in 2026. The EPPO

signed a Working Arrangement with the Office of the Prosecutor General of Hungary in 2021

and the Danish Ministry of Justice in 2023. In 2023, cooperation formally started with Ireland,

although no Working Arrangement has been signed so far. In 2025, Denmark was involved in

14 EPPO cases, Ireland in 18, and Hungary in 175. Overall, the evaluation concludes that

cooperation with the competent authorities of the non-participating Member States works well,

although stakeholders indicated some gaps in communication and the exchange of information

channels.

Cooperation with the competent authorities of non-EU countries also improved during the

evaluation period. By the end of 2025, the EPPO had signed Working Arrangements with public

10

prosecutors’ offices in 17 non-EU countries (of which seven are EU candidate countries) and

with anti-corruption structures in four non-EU countries, as well as three Memoranda of

Understanding. The number of active EPPO cases linked to non-EU countries has significantly

increased since the EPPO’s establishment in 2021. By the end of 2022, non-EU countries were

involved in 61 EPPO cases; by the end of 2025, this number rose to 193.

The evaluation finds that, in some instances, the EPPO faced challenges in being recognised by

non-EU countries as a competent authority for the purpose of judicial cooperation in criminal

matters. In the absence of EU-level agreements on cooperation between the EPPO and the

authorities of non-EU countries, the EPPO relies on the existing international agreements on

mutual legal assistance to which the EU and/or the Member States are parties. However, such

agreements regulate cooperation among the competent authorities of states, and do not cover

cooperation with an EU body such as the EPPO. Some non-EU countries were thus not always

able to recognise the EPPO as a competent authority in the same way they would have

recognised a national prosecutor’s office.

3.4. Added value

The evaluation concludes that the EPPO provides significant EU added value compared to

what Member States could have achieved acting alone, while acknowledging that the absence

of precise data on the extent to which PIF crimes were investigated and prosecuted before the

EPPO means it is not possible to exactly quantify benefits and outcomes. However, the EPPO’s

effectiveness in strengthening the protection of the EU budget already demonstrates its added

value. The EPPO’s hybrid structure, combining a central office with EDPs in the Member

States, enables operational action across borders while preserving national legal expertise.

Before the EPPO, national authorities and existing EU bodies faced structural limitations in

investigating and prosecuting complex cross-border fraud, particularly large-scale VAT fraud

and organised criminal activity. Stakeholders emphasised the ‘helicopter view’ available to the

EPPO that enables it to identify the broader criminal networks behind such offences. The

EPPO’s integrated structure now makes it possible for connections between cases, people and

companies to be identified across jurisdictions in a manner that was previously not possible.

The EPPO has significantly improved the speed and effectiveness of cross-border

investigations. The system whereby EDPs directly assign investigative measures to one

another has proven substantially faster and more efficient than the traditional mutual legal

assistance or mutual recognition mechanisms. The evaluation notes that operational tools such

as coordinated action days created major added value: (i) enabling simultaneous searches,

arrests and the freezing of assets across several Member States; and (ii) reducing the risks of

evidence destruction, dissipation of assets or suspects fleeing. Therefore, the EPPO now enables

a more effective investigation and prosecution of complex cases involving the financial interests

of the Union compared to what Member States could previously achieve on their own.

Furthermore, the evaluation finds that national judicial authorities have also benefited from the

EPPO’s establishment and dedicated training initiatives, such as the EPPO Academy.

3.5. Relevance

The evaluation shows that the EPPO has largely adapted to evolving needs, thus remaining

relevant in a changing environment, although some shortcomings remain. As expected, over

time the EPPO has established an effective EU-level investigative and prosecutorial system

capable of handling complex cross-border cases, particularly large-scale VAT fraud cases,

while addressing long-standing problems of fragmented national enforcement, weak ownership

of cases, and jurisdictional conflicts. The need for a centralised EU prosecutorial structure has

become even more pronounced due to the growing scale, sophistication and digitalisation of

11

organised financial crime. EPPO caseloads, investigations and trials have increased

substantially since the EPPO’s foundation, demonstrating both the demand for and the

operational relevance of the Office. Complex cross-border fraud schemes (such as carousel

VAT fraud, e-commerce fraud and the use of shell companies) and the involvement of cross-

border organised crime groups increasingly require coordinated EU-level investigations,

specialised expertise and central steering mechanisms that national authorities alone cannot

provide.

However, the EPPO’s effectiveness and added value depend heavily on consistent support from

Member States. It also depends on the correct implementation of the Regulation by Member

States and, as appropriate, all IBOAs, as well as cooperation with other IBOAs, non-

participating Member States and non-EU countries. In other words, the evaluation finds that the

EPPO is not able to respond to some system-wide shortcomings on its own.

The evaluation further highlights that crime trends are evolving rapidly through digitalisation,

encrypted communications, AI and crypto-assets, requiring the EPPO to continue developing

advanced technological and analytical capabilities. The EPPO must therefore adjust its

investigations to the current trends in organised, cross-border, and digital crime. In that respect,

a recurring theme in the open-ended responses to the survey carried out in the framework of

this evaluation concerned a possible need to explore extending the EPPO’s mandate to areas

such as direct taxation offences, sanctions violations, excise fraud, cybercrime and broader

customs offences.

The evaluation also finds that the EPPO’s international cooperation framework may become

insufficient over time. Existing Working Arrangements and Memoranda of Understanding with

non-EU countries are useful but non-binding, and stakeholders increasingly see a need for more

formal and legally binding agreements, as cross-border criminal activity expands globally.

Finally, the EPPO is particularly relevant in the broader context of increasing EU spending

under the next Multiannual Financial Framework and the need to continue ensuring the strong

and effective protection of the EU budget.

4. Conclusion

The EPPO has successfully put in place a well-functioning EU criminal investigative and

prosecutorial system, significantly improving the previously fragmented national landscape. Its

strongest achievements lie in the institutional capacity it has built, the coordinated cross-border

investigations it has enabled, and the development of operational capabilities that did not

previously exist. Its EU added value is therefore evident, in all cases but particularly in cross-

border coordination and enforcement. Its relevance remains high, and its overall design is

broadly coherent.

At the same time, the EPPO is still a relatively young body, operating in a field where criminal

proceedings are complex and often lengthy. The full impact of the EPPO is therefore not yet

measurable in a precise and quantifiable manner. Although institutional and operational

performance is well evidenced, more time and more mature data will be needed to effectively

assess outcome-level results – such as final convictions, confirmed financial recoveries, and

deterrence effects. Furthermore, the EPPO has evolved under operational pressures that

diverged significantly from the assumptions underlying the original legislative design,

particularly in relation to caseload and resource demands. The system also operates under

constraints, including legal ambiguities and variability in national legal and procedural

frameworks, which may affect consistency and the efficiency of the EPPO’s activities.

The evaluation also identifies areas for improvement. These include: (i) strengthening the

evidence base on outcomes, judicial results and recoveries; (ii) reducing divergences in national

12

implementation; (iii) improving procedural safeguards for suspects and accused persons; (iv)

streamlining the EPPO’s data protection rules; and (v) enhancing cooperation and information

exchange with relevant actors and the authorities of non-EU countries. Continued attention to

operational tools, resources, and legal frameworks will be important to keep pace with

increasingly complex and digital forms of fraud.

These findings will feed into the broader reflection in the context of the ongoing review of the

EU Anti-Fraud Architecture.

EN EN

EUROPEAN COMMISSION

Brussels, 18.9.2026 SWD(2026) 278 final

COMMISSION STAFF WORKING DOCUMENT

EVALUATION

Accompanying the document

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND

THE COUNCIL

on the implementation and impact of Regulation (EU) 2017/1939 on the European

Public Prosecutor's Office

{COM(2026) 491 final}

Table of contents

1. INTRODUCTION ....................................................................................................... 1

2. WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ............. 2

2.1 Description of the intervention and its objectives ............................................... 2

2.2. Points of comparison ........................................................................................... 9

3. HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION

PERIOD? ..................................................................................................................... 9

3.1. Establishment, operationalisation and resources of the EPPO ............................ 9

3.2. Implementation of the EPPO Regulation at national level ................................ 10

3.3. External context shaping the EPPO’s activities ................................................. 11

3.4. Observed outputs, results and impacts ............................................................... 13

4. EVALUATION FINDINGS ..................................................................................... 14

4.1. To what extent was the intervention successful and why? ........................................ 15

4.2. How did the EU intervention make a difference and to whom? ............................... 44

4.3. Is the intervention still relevant? ............................................................................... 47

5. WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ....................... 52

5.1. Conclusions ............................................................................................................... 52

5.2. Lessons learned ......................................................................................................... 53

ANNEX I: PROCEDURAL INFORMATION ............................................................... 55

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ....................... 57

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS

ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) ........ 67

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS .............................................. 118

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............... 122

Glossary

Term or acronym Meaning or definition

AFA Anti-fraud Architecture

AMLA Authority for Anti-Money Laundering and Countering the

Financing of Terrorism

AWP Annual Work Programme

CAAR Consolidated Annual Activity Report

CCBE Council of Bars and Law Societies of Europe

CJEU Court of Justice of the European Union

CMS Case Management System

CoE Council of Europe

DG AGRI Directorate-General for Agriculture and Rural Development

DG BUDG Directorate-General for Budget

DG DIGIT Directorate-General for Digital Services

DG EMPL Directorate-General for Employment, Social Affairs and

Inclusion

DG ENEST Directorate-General for Enlargement and Eastern

Neighbourhood

DG HOME Directorate-General for Migration and Home Affairs

DG HR Directorate-General for Human Resources and Security

DG JUST Directorate-General for Justice and Consumers

DG REGIO Directorate-General for Regional and Urban Policy

DG TAXUD Directorate-General for Taxation and Customs

DGT Directorate-General for Translation

DPO Data Protection Office

EAW European Arrest Warrant

ECA European Court of Auditors

ECHR European Convention on Human Rights

ECtHR European Court of Human Rights

ECP European Chief Prosecutor

EDP European Delegated Prosecutor

EDPS European Data Protection Supervisor

EEAS European External Action Service

EJN European Judicial Network

EIO European Investigation Order

EP European Prosecutor

EPPO European Public Prosecutor’s Office

EU European Union

EUDPR European Union Data Protection Regulation (Regulation(EU)

2018/1725)

Eurojust European Union Agency for Criminal Justice Cooperation in

Criminal Matters

Europol European Union Agency for Law Enforcement Cooperation

EQ Evaluation question

FATF Financial Action Task Force

FTE Full-time equivalents

GDPR General Data Protection Regulation (Regulation (EU) 2016/679)

IBOAs EU institutions, bodies, offices and agencies

ISG Interservice Steering Group

JHA Justice and Home Affairs

KPI Key performance indicator

LED Law Enforcement Directive (Directive (EU) 2016/680)

LFS Legislative Financial Statement

MFF Multiannual Financial Framework

MLA Mutual legal assistance

MLAT Mutual Legal Assistance Treaty

MTIC fraud Missing trader intra-Community fraud

MoU Memorandum of Understanding

NEDPA National Assistant to the European Delegated Prosecutor

OECD Organisation for Economic Co-operation and Development

OLAF European Anti-Fraud Office

PIF Protection des intérêts financiers (protection of the financial

interests).

PIF Convention 1995 Convention on the protection of the European

Communities’ financial interests

PIF crimes Crimes affecting the financial interests of the European Union

PIF Directive Directive (EU) 2017/1371 on the fight against fraud to the

Union’s financial interests by means of criminal law

Revised LFS Revised Legislative Financial Statement (the LFS accompanying

the Commission proposal was revised in June 2017 on the basis

of the draft Regulation resulting from the negotiations in the

Council)

SIENA Secure Information Exchange Network Application

SNE Seconded National Expert

SPD Single Programming Document

STEPPO Jean Monnet Module entitled ‘EPPO and EU Law: A Step

Forward in Integration’

SWD Staff Working Document

TEU Treaty on European Union

TFEU Treaty on the Functioning of the European Union

UNODC United Nations Office on Drugs and Crime

VAT Value added tax

1

1. INTRODUCTION

The purpose and scope of the present evaluation report are regulated by Article 119(1) of

Regulation (EU) 2017/1939 of 12 October 2017 implementing enhanced cooperation on

the establishment of the European Public Prosecutor’s Office (the EPPO) (‘the EPPO

Regulation’)1. Article 119(1) of the EPPO Regulation requires the European Commission

to ‘submit an evaluation report on the implementation and impact of [the EPPO]

Regulation, as well as on the effectiveness and efficiency of the EPPO and its working

practices’ no later than five years after the date on which the EPPO assumed the

investigative and prosecutorial tasks conferred on it by the EPPO Regulation (this date

was 1 June 2021)2 and every five years thereafter. The present report fulfils that

requirement and:

•examines whether the EPPO Regulation has been completely and correctly

implemented in the Member States and, where relevant, by the EPPO;

•analyses the EPPO’s governance and use of existing resources, identifying:

(i) any significant obstacles to the activities of the EPPO and progress towards its

mission and the causes of those obstacles; and (ii) areas for simplification and

reduction of administrative burden;

•assesses the EPPO’s performance and its working practices in relation to its

objectives and tasks, as well as its overall impact on the problems it was meant to

address. In line with the Commission’s Better Regulation Guidelines/Toolbox,

the assessment covers the criteria of effectiveness, efficiency, relevance,

coherence and EU added value;

•draws conclusions and identifies lessons learned and areas for improvement

(ensuring clear links between the evidence collected, sources used and analysis

produced), including in view of a possible revision of the EPPO Regulation.

This evaluation covers the period from 20 November 2017 (the date of entry into force of

the EPPO Regulation) until the end of June 2025. Whenever possible, however, the

evaluation has taken into account subsequent relevant developments until 13 July 2026.

As far as the material scope is concerned, the evaluation covers the EPPO’s

establishment and all its activities within this period, including its operations since

1 June 2021. The evaluation covers the 24 Member States participating in the enhanced

cooperation on the establishment of the EPPO (‘the Member States’) during the

evaluation period and, where relevant, the non-participating Member States (Denmark,

Hungary and Ireland). On 29 May 2026, Hungary notified the Commission of its

intention to join the EPPO. The Commission adopted its Decision confirming Hungary’s

participation in the EPPO on 10 July 2026, which entered into force on 2 August 20263.

The evaluation also considers the EPPO’s cooperation with relevant EU institutions,

1 OJ L 283, 31.10.2017, pp. 1-71, ELI: http://data.europa.eu/eli/reg/2017/1939/oj. 2 Commission Implementing Decision (EU) 2021/856 of 25 May 2021, OJ L 188, 28.5.2021, pp. 100-102,

ELI: http://data.europa.eu/eli/dec_impl/2021/856/2021-05-28. 3 Commission Decision (EU) 2026/1701, OJ L, 2026/1701, 13.7.2026, ELI:

http://data.europa.eu/eli/dec/2026/1701/oj. With the entry into force of this Decision, the EPPO Regulation

has ceased to be an act adopted within the framework of enhanced cooperation and has become

automatically an ordinary act of Union law, to be regarded as part of the acquis which has to be accepted

by candidate States for accession to the EU.

2

bodies, offices and agencies (IBOAs) as well as international organisations and non-EU

countries, including enlargement partners.

The evaluation draws on an external support study (the study) that was carried out by an

independent consultant (the consultant’s final report is published online)4. It also draws

on other sources, including the Commission’s exchanges with the EPPO and

consultations in the context of the ongoing review of the EU’s anti-fraud architecture

(AFA).

The evaluation methodology is set out in Annex II. It is subject to three main limitations.

Firstly, the sensitive nature of the EPPO’s work, and the individual nature of confidential

casework restrict the availability of certain data and associated analysis. Secondly, the

Commission’s proposal for the EPPO regulation was accompanied by an impact

assessment, but the baseline data were never set out in detail, making the ex post

assessment more difficult. Thirdly, the study team faced challenges in obtaining the

required level of breadth and balance of primary evidence because the consultant was not

granted direct access to the European Delegated Prosecutors (EDPs). The consultant

mitigated these limitations by (i) conducting a site visit to the EPPO’s central office and

holding structured group discussions with senior EPPO staff; (ii) extending its

consultations with other stakeholders (notably national authorities and practitioners);

(iii) analysing the Member States’ replies to a questionnaire circulated via the Council

General Secretariat; and (iv) examining the EPPO’s written responses to general

questions as well as dedicated questions on the implementation of the EPPO Regulation

in 11 Member States. The EPPO also provided written responses to targeted questions

concerning 11 Member States where specific implementation issues had been identified.

2. WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION?

2.1 Description of the intervention and its objectives

The EPPO was established in 2017 with a mandate to investigate, prosecute and bring to

judgement perpetrators of, and accomplices in, crimes against the financial interests of

the EU ( ‘PIF crimes’)5. These are provided for in Directive (EU) 2017/1371 (‘the PIF

Directive’)6. The PIF Directive defines and sets penalties for the criminal offences of

fraud (including cross-border VAT fraud involving a total damage of EUR 10 million),

corruption7, misappropriation and money laundering – to the extent that those offences

damage or are likely to damage the EU’s financial interests. It includes provisions on

4 ‘Study Supporting the Evaluation of the implementation and impact of Regulation (EU) 2017/1939 of

12 October 2017 on the European Public Prosecutor’s Office (EPPO), and of the effectiveness and

efficiency of the EPPO and its working practices’, ISBN 978-92-68-42063-8, and its Annexes, ISBN 978-

92-68-42141-3, available here: https://commission.europa.eu/law/cross-border-cases/judicial-

cooperation/networks-and-bodies-supporting-judicial-cooperation/european-public-prosecutors-office-

eppo_en.

This study builds on a study previously commissioned by the Commission as well as its extension (the

Extension of the Compliance Assessment). These are both available here:

https://www.europarl.europa.eu/committees/en/study-presentation-compatibility-of-nati/product-

details/20240118EOT08142. 5 Articles 4 and 22(1) of the EPPO Regulation. PIF stands for ‘protection des intérêts financiers’

(protection of the financial interests). 6 OJ L 198, 28.7.2017, pp. 29-41, ELI: http://data.europa.eu/eli/dir/2017/1371/oj. The PIF Directive was

recently amended by Directive (EU) 2026/1021 of 29 April 2026on combating corruption, OJ L,

2026/1021, 11.5.2026, ELI:http://data.europa.eu/eli/dir/2026/1021/oj. 7 Directive (EU) 2026/1021 has now replaced references to ‘corruption’ in the PIF Directive with

references to ‘bribery’, but the term ‘corruption’ will be used in this report.

3

ancillary offences as well. The EPPO is also competent for offences relating to

participation in a criminal organisation – if the focus of such a criminal organisation is on

committing PIF crimes8 – as well as for offences that are inextricably linked to PIF

crimes9.

The need for the EPPO arose from a pressing requirement to combat fraud and other

crimes affecting the integrity of the EU’s financial interests. According to the impact

assessment accompanying the Commission Proposal for the EPPO Regulation (‘impact

assessment’), the EU’s financial interests were not sufficiently protected before the

EPPO’s establishment10. The responsibility for investigating and prosecuting PIF crimes

rested solely with national authorities before the EPPO was established. However, these

authorities faced significant limitations because their powers were either confined to

national territories or, in cross-border cases, had to rely on existing cooperation

instruments. This fragmentation created made it very hard to address complex cases of

fraud, including large-scale cross-border VAT fraud. National competent authorities

often lacked the necessary tools, resources and/or expertise to act swiftly and effectively

across jurisdictions, leading to gaps in enforcement and accountability.

The existing EU bodies and agencies, due to limitations in their mandate, had limited

means to effectively protect the EU’s financial interests. The European Union Agency for

Criminal Justice Cooperation (Eurojust) and the European Union Agency for Law

Enforcement Cooperation (Europol)11 were limited to supporting and coordinating the

work of national judicial authorities and national law enforcement authorities

respectively. Eurojust could ask for investigations to be launched but could not ensure

that they were followed up at the Member State level and could not conduct

investigations or prosecutions itself. Similarly, Europol could not ensure that its analyses

in the Member States were followed up and could not conduct investigations itself.

Likewise, the European Anti-Fraud Office (OLAF), as a body tasked with carrying out

administrative investigations, relied on the national judicial authorities for any judicial

follow up.

The 1995 Convention on the protection of the European Communities’ financial interests

and its protocols (the PIF Convention)12 provided for only limited harmonisation across

the EU in the definition of, and penalties for, criminal offences affecting the EU’s

financial interests.

An additional problem was the insufficient recovery of proceeds of criminal offences

affecting the EU’s financial interests, as it is still today. The impact assessment estimated

8 Article 22(2) of the EPPO Regulation. 9 Article 22(3) of the EPPO Regulation. The EPPO can only exercise its competence over offences that are

inextricably linked to PIF crimes when the conditions set out in Article 25(3) of the EPPO Regulation are

met. 10 Commission Staff Working Document, Impact assessment accompanying the proposal for a Council

regulation on the establishment of the European Public Prosecutor’s Office, SWD(2013) 274 final of

17 July 2013, pp. 11ff. The impact assessment is available here: https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=swd:SWD_2013_0274. 11 When the proposal for the EPPO Regulation was adopted, Eurojust was formally a ‘unit’ and Europol

was the ‘European Police Office’. 12 The PIF Convention was drawn up on the basis of Article K.3 of the Treaty on European Union,

OJ C 316, 27.11.1995, p. 49; Council Act of 27 September 1996, OJ C 313, 23.10.1996, p. 1; Council Act

of 29 November 1996, OJ C 151, 20.5.1997, p. 1; and Council Act of 19 June 1997, OJ C 221, 19.7.1997,

p. 1. See the two Commission reports on the implementation of the PIF Convention and its protocols,

COM(2004) 709 final, 25.10.2004 and COM(2008) 77 final, 14.2.2008.

4

that only a very small part of the total amount of fraud was ever recovered. Expert

opinions and available data showed that recovery rates were below 10%13.

The level of deterrence was consequently low, particularly for Member States’ actions to

investigate and prosecute offences affecting the EU’s financial interests.

The EU suffered significant financial losses as a result of these problems. Between 2008

and 2017, the total estimated annual financial impact of suspected expenditure fraud

increased from EUR 77.2 million to EUR 380.9 million, while the suspected annual

financial impact of fraud relating to own resources remained relatively constant at

EUR 75-76 million (with a maximum of EUR 176.2 million in 2014 and a minimum of

EUR 61 million in 2013)14. In the annual reports on the protection of the EU’s financial

interests (the PIF reports) that were issued following the adoption of the EPPO

Regulation but before the EPPO started its operations, the estimated impact of suspected

fraud against the EU’s financial interests remained in the same range (EUR 365.3 million

in 2019 and EUR 253.6 million in 2020)15.

The EPPO Regulation and the EPPO as a body were therefore expected to address the

following needs:

• the need to improve the prevention of criminal offences against the EU’s financial

interests;

• the need for common investigation and enforcement for offences affecting the

EU’s financial interests; and

• the need for a common European prosecution policy for certain types of crimes.

The following problem drivers could be identified behind these needs.

• Limits of the existing measures: there was no EU prosecution policy to tackle

crimes affecting the EU’s financial interests. The existing legal framework was

implemented in a fragmented way. The rules and sanctions set out in the PIF

Convention could only be effective if they were complemented by measures to

ensure that those rules and sanctions were actually applied in practice. The impact

assessment also identified issues in coordination of, and continuity between,

investigation, prosecution and enforcement16.

• Low levels of national investigations and prosecutions of offences against the

EU’s financial interests (including inconsistent follow-up of OLAF

investigations): this was in part due to the low motivation of national authorities

to prosecute crimes affecting the EU’s financial interests because of a ‘lack of

ownership’ and the perceived difficulties of such cases. They were often left ‘at

the bottom of the pile’ as a result17.

• Low level of deterrence: this is often considered the ultimate objective of criminal

justice legislation. In light of the weaknesses described above, the deterrent effect

13 See the impact assessment, p. 24. 14 Annual reports on the protection of the EU’s financial interests from 2008 to 2017, which are available

here: https://anti-fraud.ec.europa.eu/about-us/reports/annual-reports-protection-eus-financial-interests-pif-

report_en. The EU’s annual budget amounted to EUR 130.9 billion in 2008, EUR 132.8 billion in 2013,

EUR 135.5 billion in 2014 and EUR 134.5 billion in 2017. 15 The EU’s annual budget amounted to EUR 148.2 billion in 2019 and EUR 153.6 billion in 2020. 16 See the impact assessment, p. 12. 17 Ibid. p. 19.

5

of the enforcement regime existing at the time was insufficient. This was

particularly the case for Member States’ investigation and prosecution of offences

against the EU’s financial interests.

The EPPO Regulation set the following objectives for addressing these needs and

problem drivers. The general objective is to contribute to the strengthening of the

protection of the EU’s financial interests. This general objective would be achieved

through the following specific objectives.

• To investigate, prosecute and bring to judgment perpetrators of, and accomplices

to, criminal offences affecting the EU’s financial interests (in national cases).

This includes exercising prosecutorial functions in the competent courts of the

Member States until cases are finally resolved.

• To enable more effective investigations and prosecutions of cross-border offences

against the EU’s financial interests by establishing a common EU investigation

and prosecution zone and allowing for more effective joint investigations and

prosecutions in cross-border cases. This cooperation is crucial for addressing the

limitations faced by national authorities, which often lacked the jurisdictional

reach necessary to tackle such crimes effectively.

• To ensure consistency and fairness across Member States by establishing

common rules and procedures for the investigation and prosecution of crimes

affecting the EU’s financial interests. This includes rules on the admissibility of

evidence and judicial review of procedural measures.

• To ensure the independence and accountability of prosecutions for crimes

affecting the EU’s financial interests and gain/foster public trust in such

prosecutions.

These objectives are closely linked to the tasks assigned to the EPPO, the activities that

the EPPO was expected to undertake and the structure with which it was created.

Article 8(1) of the EPPO Regulation18 states that the EPPO is a an ‘indivisible Union

body operating as one single Office’. The EPPO is composed of a central office in

Luxembourg and a decentralised level in each of the participating Member States. The

complexity of the EPPO Regulation is reflected in the fact that its activities can be

grouped in five distinct clusters. It is important to note that the EPPO Regulation also

sets out tasks to be undertaken by actors other than the EPPO (particularly EU IBOAs

and Member States). The clusters are:

1. Organisation of the EPPO, including establishing the internal set-up and managing

the Office, at both the operational and non-operational levels.

At the non-operational level, this includes the following.

o The College is responsible for the general oversight of the EPPO’s activities,

ensuring coherence, efficiency and consistency in its prosecution policy. The

College is composed of all European Prosecutors and the European Chief

Prosecutor. It does not take operational decisions in individual cases (Article 9).

o The European Chief Prosecutor (ECP) is the head of the EPPO and is supported

by two Deputy European Chief Prosecutors (Articles 11, 14 and 15).

18 Unless otherwise specified, the Articles and Chapters mentioned in the present section refer to Articles

and Chapters of the EPPO Regulation.

6

o The Administrative Director manages the EPPO for administrative and budgetary

purposes (Articles 18 and 19).

Other activities under the non-operational level include:

o the EPPO’s role in ensuring proper financial management (Articles 90-95);

o the need to abide by relevant staff provisions (Articles 96-98);

o the adoption of, and the need to follow, rules of procedures, College decisions and

guidelines; programming and reporting (multiannual Single Programming

Documents (SPDs), Annual Work Programmes (AWPs), Consolidated Annual

Activity Reports (CAARs) and Annual Reports) (Article 114).

At the operational level, the EPPO’s organisation includes the following.

o The Permanent Chambers monitor and direct investigations and prosecutions

(Article 10). They are composed of three members (one Chair, who can be the

ECP, a Deputy ECP or a European Prosecutor; and two European Prosecutors).

The EPPO College decided to establish 15 Permanent Chambers19.

o The European Prosecutors (EPs). There is one EP per Member State participating

in the EPPO. They supervise investigations and prosecutions (Articles 12 and 16).

European Delegated Prosecutors (EDPs), at the decentralised level, act on behalf

of the EPPO in the Member States and are responsible for the investigations and

prosecutions on the ground (Articles 13 and 17). There should be at least two

EDPs in each Member State20.

2. Functioning of the EPPO in its operational work (i.e. investigations and

prosecutions, which are its core business):

o Investigation of PIF crimes: the EPPO’s competence to investigate PIF offences

is defined in Article 22 (material competence), Article 23 (territorial and personal

competence) and Article 120 (temporal competence). The EPPO decides to

exercise its competence either by initiating an investigation or by taking over

(evoking) an investigation from national authorities. This includes rules on:

- investigations, including the initiation and allocation of competences within

the EPPO (Article 26), the right of evocation (Article 27), the conduction of

the investigations (Article 28) and the lifting of privileges or immunities

(Article 29); and

- investigation measures and other measures (Articles 30-33), covering cross-

border investigations, the enforcement of assigned measures and pre-trial

arrests and cross-border surrenders.

o Prosecution of PIF crimes, including:

- rules on prosecution, including referrals and transfer of proceedings to national

authorities (Article 34), termination of investigations (Article 35), prosecutions

19 Article 2(1) of Decision 015/2020 of the College of the EPPO on the Permanent Chambers:

https://www.eppo.europa.eu/sites/default/files/2021-

01/2020.015%20Decision%20on%20the%20Permanent%20Chambers%20-%20final.pdf.

Decision 085/2021 of the College of the EPPO further amended College Decision 015/2020 but did not

change the number of Permanent Chambers. 20 The number of EDPs in each Member State is agreed by the ECP and the competent authorities of the

Member States.

7

before national courts (Article 36), admissibility of evidence gathered by the

EPPO (Article 37) and disposition of confiscated assets (Article 38);

- rules on alternatives to prosecution (Article 39); and

- rules on simplified prosecution procedures (Article 40).

In addition, the rules on the EPPO’s operational work also cover procedural

safeguards for suspects and accused persons, including the scope of their rights

(Article 41) and the rules on the judicial review of EPPO acts and decisions

(Article 42).

3. Cooperation with partners (Articles 99-105), including Eurojust, OLAF, Europol,

other EU IBOAs (including the Commission), non-EU countries and international

organisations and non-participating Member States.

4. Obligations on Member States, which are central to the adequate implementation

of the EPPO Regulation, including providing the EDPs with the resources and

equipment necessary to exercise their functions (Article 96(6)) and nominating

candidates for the positions of EDPs and EPs (Articles 16 and 17).

5. Processing of information (Chapters VII: processing of information –

Articles 43-46; and Chapter VIII: Data protection – Articles 47-89). These include

rules on access to information by the EPPO (Articles 43), establishing the Case

Management System (CMS) (Article 44), case files (Article 45) and access to the

CMS within the EPPO (Article 46).

The rules of the EPPO Regulation on data protection (including rules on information

to be made available or given to data subjects and on their rights) aim to ensure that

data processing by the EPPO complies with the existing EU data protection rules and

that it is sufficiently operationally robust to ensure the protection of operational

personal data and the admissibility of evidence in court.

Against this background, the expected outcomes of the EPPO Regulation can be

summarised as follows.

• Outputs are the first and most quantifiable level of outcomes. They are generally

measured through key performance indicators (KPIs) collected by the EPPO and

reported in the Annual Reports/CAARs. Specifically, they include indicators that

measure the number and speed of investigations, prosecutions and rulings, and

the amounts recovered.

• Results are linked to the needs set out above and include the strengthening of the

EU’s AFA, higher levels of investigation and prosecutions, as well as higher

levels of deterrence.

• Impacts are linked to the identified problems, which the EPPO was meant to

address. They include better protection of the EU’s financial interests, higher

recovery rates and lower levels of PIF offences.

The EPPO’s expected outcomes are dynamic. If the EPPO’s objective of increasing

deterrence is achieved, the number of cases the EPPO has to deal with may well fall over

time. However, this is unlikely to be observed in this early phase of the EPPO’s

existence.

Figure 1 below presents a visual overview of how the intervention related to the EPPO

Regulation was expected to function.

8

Figure 1: Intervention logic

9

2.2. Points of comparison

This is the first evaluation of the EPPO Regulation. Its baseline is therefore the situation

before the EPPO was created, when national authorities were competent to investigate

and prosecute PIF crimes.

The limited data presented in the 2013 impact assessment relate to the situation in 2011,

approximately one decade before the EPPO started its operations. The impact assessment

provided some data on the extent to which Member States followed up on cases that

OLAF had transferred to national judicial authorities. It reported that, by the end of 2011,

national judicial authorities had decided on 471 out of a total of 1 030 actions transferred

to them by OLAF in the period between 2006 and 2011. 199 out of these 471 decisions

resulted in a conviction by a criminal court21.

The total annual financial impact of irregularities identified as ‘suspected fraud’ by

OLAF in 2011 was estimated at EUR 404 million (EUR 295 million for expenditure and

EUR 109 million for revenues)22. However, the impact assessment notes that this is a

serious underestimate because it relies on Member States’ willingness and capability to

detect and record crime and to report it to the competent EU bodies23.

In terms of caseload, the impact assessment estimated that the EPPO would be

responsible for 2 500 investigations per year, leading to 1 667 prosecutions and 1 200

convictions24. However, the revised Legislative Financial Statement accompanying the

draft Regulation estimated a lower number of cases (970 annually from 2023 onwards)25.

In light of the above, the points of comparison identified here should be treated with all

due caution. Their use in the present evaluation is limited accordingly.

3. HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD?

This section provides a factual overview of the state of play in the implementation of the

EPPO Regulation during the period covered by the evaluation.

3.1. Establishment, operationalisation and resources of the EPPO

The EPPO was established by the EPPO Regulation, which entered into force in

November 2017. The first years were devoted to the setting-up of the EPPO, which

started operating on 1 June 2021. The EPPO has subsequently further developed its

institutional, administrative and procedural arrangements (including governance and

internal procedures, the central and decentralised set-up, and operational workflows).

In its setting-up phase, the EPPO relied on shared services and working arrangements at

the EU level. This included information technology (IT) procurement and digital

21 Impact assessment, p. 15. 22 Ibid. pp. 75-76. 23 Ibid. p. 91. 24 Based on options 4c and 4d (centralised and decentralised options) (ibid. pp. 100ff.). 25 The LFS accompanying an initiative estimates the initiative’s impact on the EU budget over time. The

LFS accompanying the Commission proposal was revised in June 2017 on the basis of the draft Regulation

resulting from the negotiations in the Council. Further references are therefore made to the ‘revised LFS’,

which is available here: https://www.eppo.europa.eu/sites/default/files/2025-

08/Commission_Revised_LFS_EPPO_2017.pdf. For the purpose of this report, ‘case’ and ‘investigation’

are synonyms.

10

workspace services; human resources (HR) and security functions; and payments and

interpretation services. In parallel, the EPPO developed its own organisational structures

and progressed towards IT autonomy26, which was eventually achieved in 2025.

The EPPO scaled up from its pre-operational phase in 2020 to full operations. The

committed budget rose from EUR 34.54 million in 2021 to EUR 85.98 million in 2025.

The authorised statutory staff at the central office (temporary and contract agents)

increased from 122 in 2021 to 275 in 2025. The number of active EDPs increased from

95 to 182. Recruitment and retention challenges led the EPPO to complement its staffing

approach through a seconded national experts (SNEs) scheme. There were 43 authorised

SNEs at the end of 2025.

Table 1: The EPPO’s resources (budget and staffing), 2020-202527

3.2. Implementation of the EPPO Regulation at national level

The EPPO Regulation required amendments to national laws to ensure the proper

functioning of the EPPO and its seamless inclusion in national justice systems. The

assessment of the conformity of national legislation with the EPPO Regulation identified

a set of recurring issues in the implementation of the EPPO Regulation across the

Member States, particularly in relation to the implementation of the following articles28.

• Articles 4, 6(1) and 28(1) on the EPPO’s tasks, independence and investigations:

in some Member States, national authorities (e.g. investigative judges, inquiring

magistrates and customs authorities) exercise powers in the context of EPPO

cases that can: (i) hinder the EPPO Regulation’s allocation of tasks and

26 In the context of the EPPO, IT autonomy refers to the transition from reliance on the Commission’s

shared digital infrastructure to the establishment of internally managed and proprietary digital services. 27 Study, p. 33. 28 For the assessment of the conformity of national legislation with the EPPO Regulation, see Annexes 6

and 7 to the study. Unless otherwise specified, the articles mentioned in the present and following sections

are articles of the EPPO Regulation.

Year Phase/

milestone

Committe

d budget

(EUR

thousands)

Staff at the

central

office

(filled)

EDPs

(FTE)

Key developments

2020 Pre-operational

set-up n/a 63 n/a

Ramp-up year before start of

operations

2021 Operational start

(from 1 June) 34 544 122 95

Adapted budget linked to delays

in EDP appointments and staff

limitations

2022 Scaling of

operations 50 234 221 114

Resource increase linked to

infrastructure, ICT costs and

CMS developments

2023 Continued

scaling-up 65 719 235 140

Further consolidation of core

capacity and EDP deployment

2024 Further

expansion 75 200 275 166

Budget adjusted to prioritise

increasing EDP numbers and

continuing CMS development

2025 Consolidation and

further expansion 85 913 299 182

Start of operations in Poland and

Sweden; contribution agreement

related to the Ukraine Facility

Regulation

11

responsibilities to the EPPO; (ii) compromise the EPPO’s independence; and/or

(iii) either prevent the EDPs and EPs from carrying out some investigative

measures in PIF cases or result in instructions to other national authorities to

undertake them. Furthermore, in at least eight Member States, the EPPO is

prevented from investigating or prosecuting some categories of persons

(e.g. members of government).

• Article 24(1)-(3): the legislation of some Member States provides that the

national authorities should report criminal conduct in respect of which the EPPO

could exercise its competence to a specific national authority, which should then

report such conduct to the EPPO – rather than reporting immediately and directly

to the EPPO.

• Articles 25(6) and 42(2)(c): a significant number of Member States have not

designated a judicial authority as the authority competent to decide on the

attribution of competences in the case of a disagreement between the national

prosecution authorities and the EPPO. They have also not provided for a judicial

review of such decisions by the designated authorities. The Court of Justice of the

European Union (CJEU) is consequently not in a position to give preliminary

rulings on the interpretation of Articles 22 and 25 in relation to any conflict of

competence between the EPPO and the competent national authorities.

• Article 39: in a few Member States, the national authorities retain the power to

take the final decision on dismissing a case – even though the EPPO Regulation

stipulates that this prerogative lies exclusively with the Permanent Chamber.

This evaluation also covered compliance of national law with the articles on data

protection. The assessment did not specify the level of such compliance but rather

examined the Member State approach in regulating the interplay between the data

protection framework established by the EPPO Regulation and national law. Many

Member States rely on the direct applicability of the EPPO Regulation and have not

adopted any national measure. Some Member States have adopted dedicated legislation

to implement the relevant provisions of the EPPO Regulation, but others depend on

general data protection frameworks applicable to national authorities (e.g. rules

transposing Directive (EU) 2016/680 – ‘the Law Enforcement Directive’ or LED)29.

3.3. External context shaping the EPPO’s activities

3.3.1. EU legal and policy landscape

The EU legal and policy landscape shaping the EPPO is defined first by the relationship

between the EPPO Regulation and the PIF Directive, which had to be transposed into

national law by 6 July 2019. Both instruments depend on national implementation, so the

EPPO’s framework builds on partly diverging definitions, sanctions and limitation

periods across the Member States. This was a deliberate outcome of the negotiations but

ended up creating the risk of legal and practical frictions when it comes to the EPPO’s

exercise of competence30.

29 Directive (EU) 2016/680, OJ L 119, 4.5.2016, pp. 89-131, ELI: http://data.europa.eu/eli/dir/2016/680/oj. 30 When PIF crimes are inextricably linked to non-PIF crimes (e.g. forgery of documents), the EPPO,

pursuant to Article 25(3), cannot exercise its competence if either (i) the maximum sanction provided for

by national law for the PIF offence is equal to or less severe than the maximum sanction for the

inextricably linked offence, unless the latter offence has been instrumental to commit the PIF offence; or

12

The EPPO operates within the wider EU’s AFA, which has evolved over time with a set

of policies, bodies and mechanisms in place. These include the EPPO, OLAF, Eurojust,

Europol and the Authority for Anti-Money Laundering and Countering the Financing of

Terrorism (AMLA) as well as new and upcoming actors, such as the European Union

Customs Authority (EUCA). The EU’s AFA is being reviewed by the Commission,

which launched a White Paper on 16 July 2025 to reflect on how the EU’s AFA can be

strengthened and modernised to better protect the EU’s financial interests31. The AFA’s

review seeks to enhance effectiveness, avoid overlaps and make better use of financial

and human resources while also addressing new challenges, such as the increased

involvement of cross-border and organised crime groups targeting EU funds or the use of

advanced technologies (including AI tools).

The policy context includes the debate about extending the EPPO’s material competence

beyond PIF offences32 as well as the implications of non-participation by some Member

States in the EPPO for the effectiveness of cross-border investigations.

3.3.2. Economic and social developments

The implementation of the EPPO Regulation and the EPPO’s early operations took place

within a shifting economic and social context (most notably the COVID-19 pandemic,

which affected activity levels in 2020 and 2021). This makes early comparisons difficult

to interpret. As the EPPO moved from start-up into steady operations, the reported

increases in workload indicators in 2021-25 need to be read in the context of this post-

launch ramp-up and the broader environment in which EU funds were being

implemented and managed (including the increase in EU expenditures in the aftermath of

the adoption of the NextGenerationEU).

3.3.3. Technological advances and crime trends

Over the period under assessment, the EPPO’s operational context has been shaped both

by evolving fraud and financial crime affecting the EU’s financial interests (particularly

of a cross-border nature) and by growing reliance on digital tools for cross-border case

handling. Recent studies have found that financial crime is the most pervasive criminal

market in the EU33. The EPPO has itself, in its 2025 Annual Report, acknowledged that

‘conventional criminal activities focusing on illegal goods … or on criminal exploitation

of vulnerable people … are increasingly combined with, or even replaced by, criminal

activities related to the trading of legal goods, carried out using criminal modalities that

cause massive damage to the financial interests of both the EU and its Member States.’34

The development of the CMS and progress towards IT autonomy require secure handling

of sensitive data and, where relevant, effective interoperability with partner systems.

These trends sit within a broader move towards more digital criminal justice processes,

including initiatives that enable electronic transmission of information and more

structured cooperation across jurisdictions.

(ii) there is a reason to assume that the damage (likely to be) caused to the EU’s financial interests by the

PIF offence does not exceed the damage (likely to be) caused to another victim. 31 White Paper for the Anti-fraud Architecture Review, COM(2025) 546 final, 16.7.2025. The results of the

AFA review will be presented in a Commission Communication planned for the end of 2026. 32 See Section 4.3.2 below. 33 ‘Global Organized Crime Index 2025, Europe’, p. 2, available here: Global-Organized-Crime-

Index_Continental-Overview_Europe.pdf. 34 EPPO 2025 Annual Report, p. 72.

13

3.4. Observed outputs, results and impacts

In line with the monitoring arrangements in place (e.g. Annual Reports and SPDs), this

section reports on some indicators describing the EPPO’s activity and reported outcomes.

Box 1: How to read the indicators

The process usually starts when the EPPO receives a report – be it from private parties,

national authorities or EU IBOAs. Some reports lead to the EPPO opening an

investigation, but others do not (for example, because the conduct reported does not

amount to a PIF crime). For the purpose of this report, ‘case’ and ‘investigation’ are

synonyms.

If national authorities have not yet started an investigation into the conduct reported, the

EPPO is in principle obliged to open an investigation (under the principle of legality or

mandatory prosecution35). If national authorities have already started an investigation, the

EPPO can decide whether or not to evoke it (i.e. take it over).

Once the EPPO has finalised the investigation, the EPPO can do one of the following

four actions: (i) dismiss the case36 and possibly refer it to OLAF or to the national

authorities responsible for recovery or other administrative follow-up; (ii) bring it to

judgement before a national court (i.e. indict or prosecute); (iii) refer it back to national

authorities (if the investigation revealed that the facts do not constitute a criminal offence

for which the EPPO is competent or that the specific conditions for the exercise of the

EPPO’s competence are no longer met); or iv) dispose of it by means of a simplified

prosecution procedure. Cases brought to judgment may result in a conviction or an

acquittal by national courts at the end of national trials.

35 Whenever there are reasonable grounds to believe that a PIF offence is being or has been committed, the

EDPs ‘shall initiate an investigation’ (Article 26(1); emphasis added). See also Recitals 61 and 81, which

mention the principle of legality. There are only a few exceptions to this principle, such as when a PIF

crime causes (or is likely to cause) damage of less than EUR 10 000 (see Article 25(2)). 36 A case should be dismissed if prosecution has become impossible for any of the reasons provided for by

Article 39(1), including the lack of relevant evidence.

Figure 2: Different steps in an EPPO case

14

3.4.1. Operational achievements

The evaluation covers the years in which the EPPO became fully operational and

developed as an organisation. It is therefore not surprising that all activity indicators

increased over the period. The number of the EPPO’s active investigations grew from

515 at the end of 2021 to 3 602 at the end of 2025. However, the number of reports

received from the EU IBOAs has remained relatively stable since the first full year of the

EPPO’s operations (2022).

Table 2: Selected activity indicators reported by the EPPO (2021-2025)37

Indicator 2021* 2022 2023 2024 2025

Reports received 2 832 3 318 4 187 6 547 6 966

from private parties 1 282 1 924 2 494 4 623 4 629

from IBOAs 190 103 108 113 143

from national authorities 1 351 1 258 1 562 1 760 2 107

ex officio 9 33 23 51 87

Investigations opened 576 865 1 371 1 504 2 030

Active investigations at year end 515 1 117 1 927 2 666 3 602

of which ongoing in trial phase (before

national courts)

5 73 155 309 517

Dismissed cases (by the EPPO) 3 59 166 197 292

Indictments/prosecutions (by the EPPO) 5 87 139 205 275

Convictions (by national courts) 1 20 48 102 159

Acquittals (by national courts) 0 0 5 4 8 * Data concerning 2021 refer to only seven months of activity (1 June-31 December)

3.4.2. Strategic impacts and systemic role

The EPPO reports the outcomes of its activities using indicators (e.g. the numbers of

indictments and convictions) and data on freezing orders and asset-recovery-related

measures. Table 2 above shows that there has been a continuous increase in indictments

and convictions since operations began. It also shows a similar trend for freezing orders

(including the value of freezing orders granted and the amounts of assets effectively

frozen38). Table 2 also indicates a steady rise in the number of indictments by the EPPO

as well as convictions and acquittals by national courts between 2021 and 2025. This

suggests that, as the EPPO has matured operationally, a growing number of

investigations have progressed to the prosecution and adjudication stages. However,

these figures represent annual outcomes reported by the EPPO rather than a single cohort

of cases, so they should not be read as showing the final status of all persons indicted

during the period.

4. EVALUATION FINDINGS

This section presents an assessment of (i) the implementation and impact of the EPPO

Regulation; and (ii) the effectiveness and efficiency of the EPPO and its working

practices. It draws on the five Better Regulation criteria (effectiveness, efficiency,

relevance, coherence and EU added value). The presented findings are based on the

results of the study. These build on (i) evidence gathered through desk research;

(ii) semi-structured interviews; (iii) an online survey of national authorities and

37 Study, p. 36. 38 See Section 4.1.1.7, Table 3.

15

practitioners (including a survey of the Member States circulated through the Council);

(iv) a dedicated analysis of the status of implementation in each Member State; and

(v) four dedicated case studies.

4.1.To what extent was the intervention successful and why?

This section examines the extent to which the EPPO Regulation and its implementation

were successful and why by reference to the intervention’s effectiveness (Section 4.1.1),

efficiency (Section 4.1.2) and coherence (Section 4.1.3).

4.1.1. Effectiveness

Effectiveness in this context is the extent to which the EPPO Regulation has progressed

towards achieving its intended objectives and has delivered results in line with the

intervention logic. It is assessed through a set of interrelated thematic areas, which are

examined in the following subsections and reflect the structure of the evaluation

questions (see Annex III for the full list of evaluation questions).

Main findings on effectiveness

Overall, the EPPO Regulation has been effective in: (i) establishing and operationalising

a new, well-functioning EU-level investigative and prosecutorial framework for offences

affecting the EU’s financial interests; and (ii) generating early operational results that are

consistent with its objectives and intervention logic. The EPPO Regulation and the EPPO

have made a substantial contribution to achieving the intended objectives by creating an

operational framework that enables investigations and prosecutions to be pursued under a

common EU mandate, while mainly relying on decentralised delivery through national

systems. The evidence indicates increasing operational activity and an emerging capacity

to handle complex cases, especially those with cross-border elements. The handling of

cross-border complex cases is a core area where effectiveness is most visible, because it

directly reflects the EPPO Regulation’s intended mechanism of change. The EPPO’s

activities address key weaknesses that have been identified at the baseline (notably

fragmentation of enforcement; uneven prioritisation of PIF offences; and practical

barriers to pursuing complex cross-border cases through purely national mechanisms).

As regards the broader impact of the EPPO’s activities (including final judicial outcomes,

financial recovery and longer-term impacts such as deterrence), decisive evidence that

would allow to measure it is only partly available. These limitations reflect: (i) the time

needed for cases (especially complex cases) to mature through national judicial systems;

and (ii) structural constraints on the availability and comparability of outcome data

across participating Member States.

4.1.1.1. Progress towards the objectives and the EPPO Regulation’s

overall contribution to achieving the objectives

It is difficult to assess the EPPO’s effectiveness from a quantitative perspective. The

EPPO Regulation’s overall objective is to contribute to the strengthening of the

protection of the EU’s financial interests. The assessment of this ‘contribution’ can be

based on figures, but they will only provide one part of the overall picture. This is due to

five reasons. Firstly, the data collected by the EPPO are linked to investigations and

prosecutions, rather than their impact. Secondly, criminal cases can only be considered as

finalised once all redress mechanisms have been exhausted (this usually takes years).

Thirdly, the Member States are not obliged to provide the EPPO with some types of data

(e.g. conviction numbers, amounts recovered and acquittals). Fourthly, even if these data

were available, they would only provide evidence of the EPPO’s direct impact on cases it

16

has investigated and prosecuted, but not on its indirect impact (e.g. deterrence or better

protection of the EU budget). Finally, a purely quantitative approach may not capture the

specificity of criminal justice. For instance, a reduction in the number of convictions does

not necessarily signify that investigations and prosecutions are inefficient because cases

may be dismissed for reasons that do not depend on the investigating and prosecuting

authorities (e.g. expiry of limitation periods and the death of accused persons) or because

those authorities may themselves ask for the acquittal of accused persons if they realise

that there is insufficient evidence to convict them. Furthermore, if the objective of

increasing deterrence is achieved, one would in the longer term expect a reduction in the

number of cases that the criminal justice authorities have to deal with.

Specific objective 1 – Investigate, prosecute and bring to judgement perpetrators of, and

accomplices to PIF offences (in national cases)

Table 2 above shows an increase in the number of cases that the EPPO has opened (from

576 in 2021 to 2 030 in 2025) and that were ongoing at the end of each year (from 515 to

3 602 over the same period) since the EPPO’s creation. These figures provide an

indication of the extent of the EPPO’s casework and its outputs, but it is difficult to

assess the actual impact of these activities. The EPPO’s work had immediate outcomes.

Five indictments were issued in 2021, covering crimes like corruption and fraud in the

first seven months of operation (rising to 275 indictments by the end of 2025). The

number of convictions resulting from the EPPO’s investigations and prosecutions also

increased, more than doubling annually between 2022 and 2024 before increasing by

50% in 2025 (see Table 2, Section 3.4.1 above).

These trends reflect the fact that, while the EPPO started operations in June 2021, the rate

of increase in the number of cases and indictments increase has not yet plateaued. The

EPPO itself estimates that the EPPO has not yet reached ‘cruising speed’ – contrary to

expectations when it was being set up. Given the demand-driven nature of the EPPO and

the principle of mandatory prosecution, it is difficult to assess the number of cases the

EPPO would have to deal with when it reaches ‘cruising speed’. The annual increase in

the number of cases might well reach 10% or more.

It is similarly difficult to assess the EPPO’s impact on the recovery of the proceeds of

PIF crimes. Its Annual Reports provide information on the freezing orders granted by

national authorities and the assets that have been effectively frozen (see Table 3,

Section 4.1.1.7 below). Data on the actual amount recovered are incomplete, if not

entirely lacking, because the EPPO has only been able to allocate resources to collect and

record information generated by national judicial authorities for 2024 (covering

investigations and prosecutions undertaken in 2022-2024). In 2024, the total value of

final judicial recovery orders issued by the national courts in relation to prosecutions

brought by the EPPO stood at EUR 231.7 million. However, the true amount is very

likely to be higher than the actual amounts concretely recovered, because court orders do

not directly translate into actual amounts recovered. The Commission started putting an

EPPO Overview Mechanism in place in 2024 in order to gather better data on the actual

amounts recovered.

Despite the above-mentioned difficulties in providing quantitative data, national

authorities and practitioners that were surveyed considered that the EPPO contributed to

the objective of investigating, prosecuting and bringing to judgement perpetrators of, and

accomplices in, PIF offences to a great or moderate extent.

17

Figure 3: To what extent does the EPPO contribute to investigating, prosecuting and

bringing to judgement perpetrators of, and accomplices in, PIF crimes (in national

cases)? (n=86)39

Specific objective 2 – Enable more effective investigations and prosecutions of cross-

border PIF offences by establishing a common EU investigation and prosecution zone (in

cross-border cases)

National authorities and practitioners who responded to the survey largely agreed that the

EPPO enables more effective investigations and prosecutions of cross-border PIF crimes.

Over 54% (47 out of 86) agreed with the statement to a great or moderate extent. Only

10% (9 out of 86) agreed with it to a limited extent or not at all. About a third were not in

a position to express a view.

Figure 4: To what extent does the EPPO contribute to enabling more effective

investigations and prosecutions of cross-border PIF offences? (n=86)40

The EPPO has likened its operational work to ‘uncovering a continent of crime’41. This

refers to crimes that were not previously investigated and prosecuted by national

authorities – either because the national authorities were not aware of them or because

the national authorities did not investigate them adequately (either because of insufficient

resources and expertise or because they were not properly prioritised). Operation

Admiral is a notable example of the EPPO’s impact on detecting and countering PIF

crimes.

Box 2: Operation Admiral – Overview

Operation Admiral is a landmark EPPO investigation. The case originated in a report

submitted by an employee of the tax authorities in Coimbra, Portugal. The official noted

a suspicious discrepancy regarding a small company selling mobile small electronic

devices. The company employed only two individuals but reported an annual turnover

exceeding EUR 200 million. Following an administrative enquiry, the matter was not

pursued further because, from the point of view of the tax authorities, the company’s tax

and VAT filings were in order. A Portuguese EDP nonetheless opened an investigation.

39 Study, p. 41. The figure draws on the results of the survey of national authorities and practitioners. 40 Study, p. 42. The figure draws on the results of the survey of national authorities and practitioners. 41 EPPO Annual Report 2024, introductory forward by the European Chief Prosecutor, p. 5.

32,6% 27,9%

14,0%

24,4%

1,2%

To a great

extent

To a moderate

extent

To a limited

extent

Not at all I can’t say

30,2% 24,4%

8,1% 2,3%

34,9%

To a great

extent

To a moderate

extent

To a limited

extent

Not at all I can’t say

18

The case evolved into what is thought to be the largest VAT fraud case ever investigated

in the EU. Within 18 months of the initial report, the EPPO had uncovered a criminal

network that extended across more than 30 countries, including 26 EU Member States.

The main features of the criminal enterprise were:

• organisational complexity: the network involved approximately 9 000 companies and

600 individuals;

• criminal syndicates: the EPPO identified at least five distinct criminal organisations

operating as a vertically integrated ‘criminal industry’;

• estimated damages: the total estimated damage (i.e. to the national and EU budgets)

resulting from the crimes covered by Operation Admiral was EUR 2.9 billion.

Beyond the impact at the EU level, Operation Admiral also uncovered damages of

EUR 80 million in Portugal alone. One stakeholder involved in the case reported that the

investigation would never have been opened before the EPPO was set up.

Most of the national authorities interviewed agreed that the EPPO has been effective in

addressing PIF crimes that would have not been addressed otherwise. This chimes with

the views of the Member States participating in the EPPO that responded to the Council

questionnaire. More than half of them (13 out of 21) consider that the EPPO contributed

to the strengthening protection of the EU’s financial interests to a great extent and 6 out

of 21 to a moderate extent.

Specific objective 3 – Ensure consistency and fairness across Member States by

establishing common rules and procedures for the investigation and prosecution of

crimes affecting the EU’s financial interests

Compared with the other specific objectives, national authorities and practitioners who

responded to the survey were less certain of the extent to which the EPPO managed to

establish common rules and procedures. 43% (37 out of 86) felt unable to provide an

opinion. Nevertheless, most of those that did provide an answer found that the EPPO did

so to a moderate (27.9%, 24 out of 86) or great extent (16.3%, 14 out of 86).

Figure 5: To what extent does the EPPO contribute to ensuring consistency and fairness

across the Member States? (n=86)42

At the central level, the College has adopted internal rules of procedure and operational

guidelines setting out the EPPO’s prosecutorial policy in order to ensure a uniform

framework for operations and methodologies for investigations. Furthermore, the role of

the Permanent Chambers is also to act as the operational engine in order to ensure

consistency and particularly to avoid similar criminal conducts receiving different

handling according to the jurisdiction in which they occur.

However, consistency depends to a large extent on the implementation of the Regulation

by Member States. The evaluation notes some areas where uneven implementation has

prevented the EPPO from fully exercising its investigative powers, such as those

42 Study, p. 44. The figure draws on the results of the survey of national authorities and practitioners.

16,3% 27,9%

9,3% 3,5%

43,0%

To a great

extent

To a moderate

extent

To a limited

extent

Not at all I can’t say

19

mentioned in Section 3.2 above (i.e. investigative judges and other authorities unduly

interfering with the powers of the EDPs/EPs; conflicts of competence between the EPPO

and national prosecutors being solved by authorities that do not qualify as a ‘court’ or

‘tribunal’ and whose decisions cannot be subject to judicial review; inability to

investigate or prosecute specific categories of persons protected by privileges or

immunities if national authorities refuse to lift their immunity).

Specific objective 4 – Ensure the independence and accountability of, and gain/foster

public trust in, prosecutions against crimes affecting the EU’s financial interests.

There is little tangible information on the way in which the implementation of the EPPO

Regulation and the EPPO’s work have affected public trust in prosecutions against

crimes affecting the EU’s financial interests. However, most of the practitioners,

representatives of IBOAs and national authorities that were interviewed during the

evaluation consider that setting up the EPPO had increased trust.

Success stories have raised awareness of the EPPO’s existence and role. For example,

some interviewees reported that turnovers in the small electronic goods sector (known

among prosecutors and investigators as a sector often chosen by organised criminal

groups to commit missing trader intra-Community (MTIC) fraud) had fallen drastically

after the Admiral case.

Interviews with the EPPO central office identified specific cases where lack of

cooperation from national authorities had affected the independence of the EPPO’s

actions. The assessment of the implementation of the EPPO Regulation has identified

two Member States whose legislation is not compliant with Article 6(1) on the EPPO’s

independence. In one Member State, national law requires all prosecutors – including

EDPs – to comply with the Prosecutor General’s instructions, commands and orders. In

the other Member State, national law requires its Board of Prosecutors General to check

the decisions by the EPPO to use certain investigative techniques43.

General objective – Contribute to strengthening the protection of the EU’s financial

interests.

The EPPO only started operations in 2021, so it is still too early to observe any impact on

crime trends or the EPPO’s long-lasting contribution to the protection of the EU’s

financial interests. The PIF reports published annually by the Commission show a rise in

the number of irregularities detected and reported as fraudulent on the EU’s expenditure

side (from 466 in 2021 to 746 in 2024) and on its revenue side (482 in 2021 to 537 in

2024). However, the total value of these fraudulent irregularities has decreased. On the

expenditure side, the value of fraudulent irregularities fell from EUR 1.654 billion in

2021 to EUR 399.7 million in 2024. The fall is less pronounced on the revenue side, with

the value of fraudulent irregularities decreasing from EUR 157 million in 2021 to

EUR 84.2 million in 2024. It is difficult to assess the extent to which these figures reflect

a trend and the extent to which the EPPO has contributed to them.

Despite its successes, the impact of the EPPO is continuously being shaped by the

adaptive responses of criminal organisations. Interviewed practitioners stated that

criminal networks appear to have reacted to the EPPO’s establishment by ‘forum

shopping’ (i.e. strategically moving their operations to Member States where they

perceive investigative units to be less skilled or where detection risks are lower). Some

national practitioners that were interviewed, as well as interviewees from the EPPO’s

43 See Annex 9 to the study, section on ‘Implementation at national level’.

20

central level, noted that criminal groups seek workarounds by re-focusing their activities

on areas that do not fall within the EPPO’s competence or by ensuring that their activities

remain below the EUR 10 million threshold for VAT fraud. Criminal groups’ apparent

awareness of the EPPO and of its mandate and activities indicates that the EPPO is a

success in the current context.

4.1.1.2. Material competence and legal framework

The notion of ‘material competence’ refers collectively to the offences that the EPPO

may investigate and prosecute. The EPPO shares competence with national authorities,

although its competence has priority over that of national authorities. The effectiveness

of the legal framework therefore depends not only on the Regulation’s rules on

competence but also on the Member States implementing them. Before the EPPO became

operational, national authorities investigated and prosecuted PIF offences, with uneven

follow-up and limited continuity in cross-border enforcement. In the absence of formal

indicators to measure the effectiveness of the rules on material competence, this

evaluation relies on operational proxies to show how such rules operate in practice as an

insight into the EPPO’s action.

• The effective exercise of the EPPO’s material competence is reflected in the

massive growth of investigations into core PIF offences (see Table 2 above).

• The sheer scale of the EPPO’s investigations with a cross-border dimension

demonstrate its capacity to tackle transnational criminality. In line with its

mission to overcome fragmented national law enforcement, the EPPO operates

effectively in multijurisdictional cases. Cross-border investigations rose rapidly

from 142 in 2021 to 316 in 2022, 545 in 2023 and 767 in 2024. The 2025 Annual

Report confirmed that this transnational focus remained robust, with a cross-

border dimension present in 987 (27%) of the EPPO’s 3 602 active cases. The

financial impact of these operations has been massive. By the end of 2025,

revenue fraud (VAT and customs) – which is predominantly transnational and

linked to organised crime – accounted for EUR 45.01 billion (representing more

than 67% of the total estimated damage under investigation).

• The practical importance of the EPPO’s competence over inextricably linked

offences is reflected in the growing number of active cases in which such

offences are investigated alongside PIF crimes. By the end of 2025, 615 active

EPPO cases (around 17% of all active cases) included an inextricably linked

offence. The 2025 Annual Report indicated that such offences were increasingly

part of the modus operandi in sophisticated fraud schemes. Forgery of documents

was identified as the most common type of inextricably linked offence.

Stakeholder evidence collected for the first case study annexed to the study supporting

this evaluation highlights practical difficulties in applying the rules that extend the

EPPO’s competence beyond core PIF offences – particularly those on inextricably linked

offences, which stakeholders consider insufficiently clear and which can complicate and

delay decisions on whether the EPPO should exercise its competence 44.

44 See Case Study 1, Annex 8, to the study. See also, for instance, the position paper that the Union of

Italian Criminal Chambers submitted in response to the call for evidence by the Commission. The call for

evidence and the feedback received are available here: https://ec.europa.eu/info/law/better-regulation/have-

your-say/initiatives/14308-European-Public-Prosecutors-Office-EPPO-evaluation_en .

21

Complementing the operational and qualitative evidence, the survey of national

authorities and practitioners (80 responses) suggests moderately positive perceptions of

the adequacy of the EPPO’s material competence: 53.8% considered it adequate ‘to a

great extent’ or ‘to a moderate extent’. However, the large share of respondents selecting

‘cannot say’ (36.3%) points to limited visibility or uneven familiarity with the issue and

suggests that these results should be interpreted with caution.

Figure 6: Perceptions of adequacy of the EPPO’s material competence (n=80)45

Overall, the material competence framework has enabled the EPPO to effectively pursue

the main forms of criminality within its mandate, including core PIF offences, cross-

border fraud and mixed fraud patterns. However, the framework remains only partially

effective. In particular, divergent interpretation of the ‘focus’ criterion in Article 22(2);

the exclusion of national direct taxes and offences inextricably linked to them under

Article 22(4); and the limiting conditions in Article 25(3) continue to generate

fragmentation and delays and can lead to similar facts being treated differently in

different jurisdictions. These factors are partly outside the EPPO Regulation’s direct

scope, but they do affect how consistently the EPPO’s mandate can be exercised in

practice.

4.1.1.3. Consistency and coordination across Member States

The mapped evidence shows that meaningful progress has been made in putting

cooperation mechanisms in place and using them in day-to-day operations. This indicates

that cooperation and information-exchange both function well in practice.

Evidence on the EPPO’s intake and reporting system also points to improvements in

overall coordination through standardisation and centralised triage. The EPPO has

established a uniform reporting template. A dedicated ‘Report a Crime’ web form is

accessible via the EPPO website in all the EU’s official languages. The template supports

automated import into the EPPO’s CMS and is paired with guidance and over 100

awareness sessions to key stakeholders. At the central level, the EPPO’s CMS underpins

cooperation and information exchange by enabling secure sharing and procedural

oversight across the central office and EDPs throughout the case lifecycle.

Box 3: Illustration of the ‘single office’ information advantage

In the case of Operation Admiral, a national authority detected a red flag (a company

with minimal staffing and very high turnover) and channelled the information to the

EPPO. The EPPO then used the CMS to connect the case to a significantly wider cross-

border network of entities and persons during the investigation. This confirms that the

EPPO’s information architecture can convert local detection into coordinated cross-

border follow-up that would be more difficult to achieve through fragmented bilateral

exchanges alone.

Evidence from the survey of national authorities and practitioners broadly supports these

findings, while also highlighting uneven familiarity with some cooperation channels. A

45 Study, p. 51. The figure draws on the results of the survey of national authorities and practitioners.

31,3% 22,5%

7,5% 2,5%

36,3%

To a great extent To a moderate extent To a limited extent Not at all I can’t say

22

majority of the national authorities and practitioners who expressed a view considered

that cooperation and information exchange between the EPPO and national competent

authorities function to a moderate or great extent (45 out of 71 respondents, around

63%). A smaller share considered it effective only to a limited extent or not at all (13 out

of 71, around 18%). However, a significant proportion of respondents indicated that they

‘cannot say’ (13 out of 71, 18%) – suggesting that not all practitioners have direct

operational exposure to these exchanges.

The evidence gathered shows that, within the framework of the EPPO Regulation, the

EPPO has put in place several procedures, internal guidelines and working methods that

are intended to support more consistent cross-border investigation and prosecution of PIF

crimes in participating Member States. However, the available evidence does not allow a

robust conclusion on whether ‘similar cases’ have been treated consistently across

Member States in practice. Nor does it make it possible to identify concrete instances

where comparable investigations resulted in prosecution in one Member State but not in

another. Across a number of Member States, respondents describe coordination and

competence-handling as generally smooth and note that it is often resolved through

consultation and direct dialogue (including in situations where parallel investigations

arise).

Overall, the evaluation finds that the EPPO has in practice largely managed to direct

investigations and prosecutions across Member States and to coordinate cross-border

investigations effectively. However, the quality, speed and consistency of its activities

remain partly dependent on national police capacity, national procedural frameworks and

timely cooperation from national authorities.

4.1.1.4. Governance and internal functioning

The EPPO’s governance model and its functioning are designed to combine strategic

steering at the central level in Luxembourg with investigations and prosecutions being

carried out on the ground by the EDPs, who are embedded in national systems

(decentralised level). The ECP leads the EPPO, directs its activities and represents it

externally. The College provides general oversight, determines priorities and prosecution

policies, and adopts internal rules. The Permanent Chambers monitor and direct

investigations and prosecutions with the support of the supervising EPs.

Regarding relations between the College and the ECP, interview evidence indicates that

achieving a balance between collegial governance and strong central leadership can be

sensitive at times. This was particularly the case during the early period of institutional

set-up. One former EP suggested that Member States with particularly high caseloads

may exert a disproportionate informal influence in College discussions because the

volume of their cases can shape shared assumptions about what is ‘typical’ or

operationally important.

Evidence from the interviews suggests that opinions are mixed regarding the

proportionality and practicality of the structure based on Permanent Chambers. One

former EP argued that the Permanent Chambers’ members may not be sufficiently close

to the applicable national procedural context. The Regulation envisages a clear decision

chain (Permanent Chambers – EPs – EDPs), but national procedural arrangements

complicate its application in some cases. In particular, if investigative judges and/or other

national authorities retain powers over key prosecutorial decisions, this constrains the

extent to which the Permanent Chambers can supervise and direct cases in the way the

Regulation intends. The Permanent Chambers provide a central oversight and quality

assurance layer by approving key prosecutorial decisions and, where necessary,

23

instructing further investigative steps to align the EDPs’ proposals with the EPPO’s

policy. In parallel, the College has adopted guidelines to standardise decisions in a

number of areas, including evocation and referral, simplified prosecution procedures and

cross-border investigations.

The CMS is a core component of the EPPO’s single-office model. It is designed to

support secure access to case information, information-sharing and central oversight

across the EPPO. Feedback from a former EP and national authorities suggests that

usability and document handling can be burdensome – particularly in complex and

document-heavy financial crime investigations. This impacts the effectiveness of the

EPPO’s governance because the Permanent Chambers and other central oversight

mechanisms depend on timely and reliable access to the materials of the EPPO’s cases.

However, some national actors described the CMS as an important tool for linking

information across jurisdictions and identifying cross-border connections between cases.

Overall and despite the above-mentioned limitations to the evidence base, the EPPO’s

governance structure and working practices appear broadly effective in enabling the

achievement of the EPPO’s mission. The single-office model; the division of roles

between the ECP, the College and the Permanent Chambers; and the supporting case-

management infrastructure provide an effective framework for central steering, cross-

border visibility of cases and consistent decision-making. However, effectiveness is not

without its own problems. As caseloads increase, the Permanent Chambers face growing

proportionality and workload pressures. National procedural diversity can slow down or

complicate the decision chain.

4.1.1.5. Cooperation with EU IBOAs and international partners

The EPPO regularly engages and cooperates with several partners, including EU IBOAs

and authorities of non-participating Member States and non-EU countries. The EPPO can

enter into working arrangements with its partners to govern these relationships.

Cooperation with Eurojust

Eurojust supports and works with national authorities to combat a wide range of serious

and complex cross-border crimes, including PIF crimes. In line with Article 100 of the

EPPO Regulation and Article 50 of the Eurojust Regulation46, the EPPO and Eurojust

signed a Working Arrangement in February 2021 that sets out rules on their cooperation.

The EPPO and Eurojust have implemented indirect access to information in their

respective CMSs based on a hit/no-hit system. Their cooperation takes place in a number

of ways, including meetings between the respective liaison teams. The EPPO’s cases are

supported by national desks at Eurojust. Eurojust supported 14 cases involving the EPPO

in 2022, 26 cases in 202347 and 25 cases in 202448. The two bodies have also

implemented agreements on the workflow of the EPPO cases to be handled by Eurojust

and the EPPO’s participation in joint initiatives hosted by Eurojust.

46 Regulation (EU) 2018/1727, OJ L 295, 21.11.2018, pp. 138-183ELI:

http://data.europa.eu/eli/reg/2018/1727/oj. This has been amended by: Regulation (EU) 2022/838, OJ L

148, 31.5.2022, pp. 1-5, ELI: http://data.europa.eu/eli/reg/2022/838/oj; Regulation (EU) 2023/2131, OJ L,

2023/2131, 11.10.2023, ELI: http://data.europa.eu/eli/reg/2023/2131/oj; Regulation (EU) 2025/2082, OJ L,

2025/2082, 15.10.2025, ELI: http://data.europa.eu/eli/reg/2025/2082/oj. 47 Evaluation of Eurojust, SWD(2025) 182 final, p. 29. 48 EPPO Annual Report 2024, p. 107. No relevant data were provided in the 2025 EPPO Annual Report.

24

The hit/no-hit exchanges between the EPPO and Eurojust are not automated but instead

have to be conducted through ‘regular communication’49 rather than an automated

workflow. Feedback from interviews indicates that, in practice, there are not many

requests for exchange of data under the hit/no-hit system. The EPPO submitted eight

names for cross-checking to Eurojust in 2024. Eurojust did not send any request to the

EPPO in that year. The low level of information exchange suggests that the expected

exchange of data is not taking place under the hit/no-hit system.

The EPPO and Eurojust liaison teams meet on a regular basis (at least once a year since

2022) to discuss possible ways of strengthening institutional cooperation and

coordination. In addition, there are high-level meetings between the Eurojust President

and the European Chief Prosecutor. Feedback from interviews as well as the recent

evaluation of Eurojust suggests that there is still room for further improvement and that,

overall, cooperation between the EPPO and Eurojust is strong and consistent but limited.

Cooperation with OLAF

Both the EPPO and OLAF have been tasked with protecting the EU’s financial interests

by investigating conduct that affects those interests. In accordance with Article 101 of the

EPPO Regulation, the relationship between the EPPO and OLAF should aim in particular

to ensure that all available means are used to protect the EU’s financial interests, through

complementarity and support by OLAF to the EPPO. OLAF’s core mission is to carry

out administrative investigations for the purpose of fighting fraud, corruption and any

other illegal activity affecting the EU’s financial interests as well as into serious

misconduct by EU staff and members of the EU institutions. The EPPO is responsible for

investigating, prosecuting and bringing to judgement PIF crimes. The cooperation

between the EPPO and OLAF focuses on mutual reporting in accordance with the

existing legal framework, complementing each other’s mandate for the protection of the

EU budget and exchanging necessary information (including through the hit/no-hit

system). Non-duplication is the key principle regulating EPPO-OLAF relations. Pursuant

to Article 101(2), if the EPPO conducts a criminal investigation, OLAF should not open

any parallel administrative investigation into the same case – except in the circumstances

expressly provided for by the EPPO Regulation or Regulation (EU, Euratom) 883/2013

(‘the OLAF Regulation’)50.

The OLAF Regulation was amended in 2020 to take into account the entry into force of

the EPPO Regulation. Some elements set out in the OLAF Regulation are not mirrored in

the EPPO Regulation. This creates practical and legal uncertainties in some cases.

49 Extension of the Compliance Assessment, p. 48. 50 Regulation (EU, Euratom) No 883/2013, OJ L 248, 18.9.2013, pp. 1-22,

ELI: http://data.europa.eu/eli/reg/2013/883/oj.

This has been amended by Regulation (EU, Euratom) 2016/2030, OJ L 317, 23.11.2016, pp. 1-3,

ELI: http://data.europa.eu/eli/reg/2016/2030/oj and by Regulation (EU, Euratom) 2020/2223, OJ L 437,

28.12.2020, pp. 49-73, ELI: http://data.europa.eu/eli/reg/2020/2223/oj.

Article 12d of the OLAF Regulation also enshrines the principle of non-duplication of investigations.

Article 101(3)(c) of the EPPO Regulation allows the EPPO to request OLAF to support or complement the

EPPO’s activity, in particular by conducting administrative investigations. Article 12f of the OLAF

Regulation provides that OLAF should inform the EPPO if the EPPO is conducting an investigation and

the Director-General of OLAF considers that an investigation by OLAF should also be opened. The EPPO

may object to OLAF opening an investigation or performing certain acts.

25

The mandates of the EPPO and OLAF are distinct51, but this evaluation finds that the

overall legal framework remains complex because it requires coordination between

national, EU administrative and EU criminal procedures. As a result, the system in place

does not always prevent duplication of investigations and reporting. For instance,

national authorities are obliged to report to the EPPO any criminal conduct in respect of

which the EPPO can exercise its competence52. EU IBOAs are obliged to report to both

the EPPO and OLAF53. National authorities may also voluntarily report to OLAF. Private

parties may report to the EPPO and/or OLAF54. This situation could help ensure that no

conduct affecting the EU’s financial interests goes undetected (especially in cases where

the elements for opening a criminal investigation are not prima facie sufficient).

However, it can also create an administrative burden for the EPPO and OLAF because

both Offices often have to assess the input received and this may result in duplication of

investigations and reporting55.

The EPPO and OLAF signed a Working Arrangement in July 2021. The Arrangement is

generally being implemented correctly. The monthly clearing house meetings are a useful

occasion for discussing matters of common interests and resolving outstanding issues,

including in the allocation of competence56. The EPPO and OLAF cooperate in various

ways. The main procedures in the cooperation between the EPPO and OLAF include

mutual reporting, the hit/no-hit mechanism, complementary investigations and support

activities.

Cooperation and information sharing between the EPPO and OLAF have both been

increasing over the years. If OLAF suspects the existence of a criminal offence, it is

required to submit an EPPO Crime Report (ECR) to the EPPO57. OLAF is the largest

source of case referrals to the EPPO among the EU IBOAs. Its role is therefore central to

ensuring effective reporting to the EPPO, whether by sending ECRs itself or by assessing

and referring reports emanating from other IBOAs to the EPPO58. However, the EPPO

receives more reports from other sources (such as national authorities and private sectors

– see Table 2 above) and therefore considers the number of ECRs sent by OLAF (as well

as other IBOAs) to be insufficient59.

The EPPO is exempt from the requirement in Article 8(1) of the OLAF Regulation that is

applicable to all other IBOAs to transmit relevant information to OLAF60 – provided that

the EPPO is competent to investigate a given case. Likewise, Article 101(4) of the EPPO

51 The European Court of Auditors (ECA) reached the same conclusion in its Special Report 26/2025, ‘EU

bodies fighting fraud – Clear mandates but exchange of information and Commission oversight remain

insufficient’ ( ‘ECA Special Report 26/2025’). The report is available here:

https://www.eca.europa.eu/en/publications?ref=SR-2025-26. 52 Article 24(1) of the EPPO Regulation. 53 Article 24(1) of the EPPO Regulation; Articles 1, 5, 7, and 12 of the OLAF Regulation. 54 Recital 49 of the EPPO Regulation; Article 5(1) of the OLAF Regulation. 55 ECA Special Report 26/2025, p. 19. 56 Interviews of the consultant with representatives of the Commission. 57 Article 24(1) of the EPPO Regulation; Article 12c of the OLAF Regulation. 58 Recital 51 of the EPPO Regulation notes that, in order to comply with the obligation to inform the EPPO

where a suspicion of a PIF offence is identified, EU IBOAs should have efficient mechanisms in place for

a preliminary evaluation of allegations reported to them and that they may use OLAF to that end. 59 EPPO Annual Report 2024, p. 5: ‘Over 70% [of the reports to the EPPO] came from private parties,

close to 27% from national authorities, and less than 1% from OLAF. … institutions, bodies, offices and

agencies … need to step up the detection and reporting of suspicions of fraud to the EPPO.’ 60 Article 8(1) of the OLAF Regulation’ refers to ‘information relating to possible cases of fraud,

corruption or any other illegal activity affecting the financial interests of the Union’.

26

Regulation states that the EPPO ‘may’ provide information to OLAF if it decides not to

conduct an investigation or has dismissed a case. Under the Working Arrangement, the

EPPO will report to OLAF only when it cannot exercise its competence61. Both the

OLAF stakeholders that were consulted and data included in the European Court of

Auditors’ (ECA) Special Report 26/2025 confirmed that such reporting from the EPPO

to OLAF is limited62. In addition, the number of dismissed allegations that the EPPO

referred to OLAF since October 2023 is low and this may limit the potential for

administrative follow-up. The ECA noted that OLAF does not have the opportunity to

consider whether it would be cost-effective to open an administrative investigation in

95% of the cases initiated but dismissed by the EPPO or which the EPPO has decided not

to investigate63. The EPPO’s position is that the limited level of reporting is due to the

need to protect confidentiality and the suspects’ rights64.

OLAF stakeholders reported that the EPPO and OLAF do not have direct access to each

other’s CMSs because they are not interconnected. They also reported that the hit/no-hit

system is outdated because it is a manual process. The ECA Report also noted this and

highlighted the risk that this can delay the opening of investigations65. OLAF carries out a

hit/no-hit check before starting an investigation, with a view to verifying whether the

EPPO is already conducting an ongoing investigation into the same facts. The EPPO then

manually cross-checks the information and shares the results with OLAF. If the facts are

the same or if criminal suspicion is substantiated, then either the EPPO conducts the

investigation exclusively or OLAF carries out a complementary investigation or support

activity66. Between 2022 and 2024, 162 of the 3 317 allegations assessed by OLAF were

transferred to the EPPO67. There were 133 hit/no-hit requests in 2022, 32 in 2023 and 235

in 202468. The ECA considers that the current hit/no-hit system cannot sufficiently

guarantee that parallel investigations into the same facts will be avoided. The ECA points

out that OLAF opened investigations into 236 allegations between 2022 and 2024

without performing a hit/no-hit check. For these allegations, OLAF had either assessed

them as falling outside the EPPO’s competence or knew from other sources that the

EPPO had decided not to exercise its competence 69. The ECA therefore notes that the

current system cannot ensure that the EPPO will assess all allegations of fraud for

potential crimes. This is particularly the case when OLAF considers that an allegation

does not provide sufficient evidence for OLAF to open an investigation 70.

Unlike OLAF, the EPPO is not obliged to perform a hit/no-hit check. This leaves room

for mistakes and can lead to duplications if, for instance, the EPPO opens an

investigation without checking, after OLAF has already completed its check. OLAF

stakeholders reported that there had been at least one case where parallel investigations

took place without the EPPO and OLAF being aware, and that this was only discovered

61 Interview of the consultant with a representative of the Commission. 62 ECA Special Report 26/2025, pp. 27-28. 63 Ibid. pp. 28-29. 64 EPPO’s replies to the ECA Report 26/2025, p. 7 (https://www.eca.europa.eu/Lists/ECAReplies/EPPO-

Replies-SR-2025-26/EPPO-Replies-SR-2025-26_EN.pdf). 65 ECA Special Report 26/2025, p. 25. 66 Article 101 of the EPPO Regulation; Article 12 of the OLAF Regulation. Interview of the consultant

with a representative of the Commission. 67 ECA Special Report 26/2025, p. 24. 68 EPPO Annual Reports for 2022-2024. No relevant data were provided in the 2025 EPPO Annual Report. 69 ECA Special Report 26/2025, p. 26; Case Study 2: EPPO’s working relationship with OLAF (Annex 8 to

the study). The 2025 EPPO Annual Report did not contain any relevant data. 70 ECA Special Report 26/2025, p. 25.

27

through an on-the-spot check by OLAF. This case demonstrates that there is therefore

some room for improvement because it shows that both Offices should regularly perform

hit/no-hit checks and that an automated system could alleviate administrative burden.

Duplication might also arise in later stages of the investigation (for instance, if OLAF

identifies a suspect who is already under investigation by the EPPO). This situation

demonstrates the need for continuous cross-checking. According to the ECA Special

Report, OLAF performed 250 hit/no-hit checks in 2022-2024 in relation to allegations

for which an administrative investigation was opened. Only four of these checks were

carried out after the initiation of investigations71.

Article 101(3) of the EPPO Regulation, Articles 12f-12g of the OLAF Regulation and the

Working Arrangement cover the complementary activities of the EPPO and OLAF. In

accordance with the Working Arrangement, OLAF can conduct complementary

investigations with a view to facilitating the collection of relevant information for the

adoption of precautionary measures or the conduct of financial, disciplinary or

administrative actions. When OLAF conducts complementary investigations, the EPPO

and OLAF can investigate the same facts simultaneously from two different viewpoints.

However, the investigations have different aims. OLAF’s administrative investigations

focus on recovering money and recommending administrative, disciplinary or

precautionary measures. The EPPO’s criminal investigations focus on the criminal

accountability of the suspects. OLAF can propose complementary investigations and the

EPPO can request them. In practice, OLAF proposes more investigations than the EPPO

requests. Overall, there are few complementary investigations and support activities

compared with the total number of investigations opened by the EPPO and OLAF. For

example, the EPPO opened 1 504 investigations in 2024, while OLAF carried out 4

support activities and 17 complementary investigations in the same year72.

Interviews with OLAF staff indicate that the EPPO is not sufficiently relying on OLAF’s

capacities to make financial or disciplinary recommendations, particularly through

complementary investigations. The EPPO considered that OLAF’s involvement is not

strictly necessary to adopt administrative measures. In that respect, the ECA Report notes

that ‘Complementary investigations by OLAF can be an effective way to reinforce the

protection of the EU budget by recommending the adoption of administrative measures,

such as exclusion from EU financing (blacklisting) and early detection, as early as

possible in the process, subject to EPPO deciding when the right moment is to provide

OLAF with the information it needs to decide whether opening a complementary

investigation would be cost-effective.’73 However, as the ECA Report also notes, the

EPPO does have the power to propose to the Commission to put suspects on the Early

Detection and Exclusion System (EDES)74. In the EPPO’s replies to the ECA, the EPPO

noted that the revised cooperation framework between the EPPO and the Commission,

which was established in December 2024, will allow the responsible Commission

services to adopt administrative measures, on the basis of information from the EPPO,

‘equally fast if not quicker’ than OLAF recommendations originating from

complementary investigations75.

71 Ibid. p. 26. 72 See also Table 48 of the State of Play analysis (Annex 9 to the study). 73 ECA Special Report 26/2025, p. 29. 74 Article 144(2) of Regulation (EU, Euratom) 2024/2509, OJ L, 2024/2509, 26.9.2024,

ELI: http://data.europa.eu/eli/reg/2024/2509/oj. 75 EPPO’s replies to the ECA Special Report 26/2025, p. 6.

28

The EPPO can request support activities from OLAF during its investigations. OLAF

stakeholders reported that support activities are particularly valuable in complex financial

or structural projects, where OLAF’s administrative expertise is essential. In cases where

OLAF performs supporting measures requested by the EPPO, the two Offices should – in

order to protect the admissibility of evidence in criminal proceedings as well as

fundamental rights and procedural guarantees – ensure that the procedural safeguards

provided for in the EPPO Regulation are observed (Article 12(e)(3) of the OLAF

Regulation).

OLAF’s support activities to the EPPO have remained relatively limited in recent years

because the national authorities are the EPPO’s primary source of support76. In 2022, the

EPPO made 20 requests for support to OLAF and OLAF provided support in 13 of those

cases. OLAF provided support in 4 cases in 2023 and in 5 cases in 202477. Furthermore,

support can sometimes be complex and lead to delays because of OLAF’s need to

comply with multiple legal frameworks at the EU and national level78, which creates a

risk that OLAF may end up not providing sufficient support or sufficient protection for

procedural guarantees. OLAF therefore considers that complementary investigations

could better protect the EU’s budget. The EPPO believes instead that support measures

should increase79.

Cooperation with Europol

Europol helps protect the EU’s financial interests by supporting law enforcement

authorities in preventing and combating serious crime, including PIF crimes, and

terrorism. Article 102(2) of the EPPO Regulation states that the EPPO should be able to

obtain, at its request, any relevant information held by Europol concerning any offence

within the EPPO’s competence. It further states that the EPPO may also ask Europol to

provide analytical support to a specific investigation conducted by the EPPO. In turn, the

EPPO-Europol cooperation is regulated by Article 20a of the Europol Regulation80.

In January 2021, the EPPO and Europol concluded a Working Arrangement, which sets

out the modes of cooperation between the two bodies. This Working Arrangement

remains fit for purpose. It was followed by an arrangement on the exchange and

protection of classified information and by a Memorandum of Understanding on secure

communication (both instruments were signed in November 2021).

Stakeholders from Europol were positive about cooperation with the EPPO. They

confirmed that the mandates of both bodies are respected and the provisions of the

working arrangement are being well implemented. Between 2022 and 2024, the number

of requests for which Europol provided support to the EPPO (in the form of information

exchange, analytical support, expertise, etc.) rose from 28 to 83 (158 in total in the whole

period). Europol for its part submitted a total of 12 ECRs over the same period. No

comparable data were included in the 2025 EPPO Annual Report.

76 Interviews of the consultant with representatives of the Commission; ECA Special Report 26/2025, p. 8. 77 EPPO Annual Reports for 2022-2024; OLAF Annual Reports for 2022-2023; no relevant data were

provided in the 2025 EPPO Annual Report. 78 Interviews of the consultant with representatives of the Commission. 79 Case Study 2: EPPO’s working relationship with OLAF. 80 Regulation (EU) 2016/794, OJ L 135, 24.5.2016, pp. 53-114; ELI:

http://data.europa.eu/eli/reg/2016/794/oj. This has been amended by: Regulation (EU) 2021/1133, OJ L

248, 13.7.2021, pp. 1-10, ELI: http://data.europa.eu/eli/reg/2021/1133/oj; Regulation (EU) 2022/991 OJ L

169, 27.6.2022, pp. 1-42, ELI: http://data.europa.eu/eli/reg/2022/991/oj; and Regulation (EU) 2025/2611,

OJ L, 2025/2611, 22.12.2025, ELI: http://data.europa.eu/eli/reg/2025/2611/oj.

29

The EPPO and Europol have set up the EPPO-Europol Steering Committee81, which

meets once or twice a year and decides on strategic priorities. The EPPO is closely

cooperating with Europol’s European Financial and Economic Crime Centre (EFECC)

and is an associated party of several of Europol’s analysis projects (APs). In October

2024, the EPPO became a member of the EU Innovation Hub for internal security, which

is hosted at Europol. The EPPO also participates in the European Multidisciplinary

Platform Against Criminal Threats (EMPACT) Operational Action Plans (OAPs), which

are relevant to its mandate. In 2024, the EPPO became the leader of an Operational

Action under the EMPACT OAP targeting MTIC fraud.

The EPPO has indirect access to Europol data in relation to PIF offences through the

hit/no-hit system. However, Europol stakeholders noted that the tool is not up to date

because it was created in a context where less data were available (Europol and the EPPO

now collect vastly more data). They also noted that it is not very efficient because, for

instance, it is difficult to connect data without knowing the context behind it. As a

follow-up to searches and hits that are found, Europol shares data via its Secure

Information Exchange Network Application (SIENA). which the EPPO joined in 2022.

SIENA is designed to enable the exchange of operational and strategic crime-related

information and intelligence between the Member States, Europol and its cooperation

partners.

On data exchange, stakeholders noted that the ownership of Europol data rests with the

Member States and that this can delay the EPPO’s access. The Member States need to

give their consent before Europol can exchange information with the EPPO82. Europol

stakeholders also stressed the point that all data that the EPPO receives and that are not

relevant to it but could be interesting to Europol should be shared with Europol.

Overall, cooperation between Europol and the EPPO is considered strongly effective and

clearly defined83.

Cooperation with the Commission’s spending Directorates-General (DGs)84

The Commission’s spending DGs play an important role in reporting cases to the EPPO

due to their role in disbursing and monitoring EU funds. However, some challenges have

been reported regarding cooperation between the spending DGs and the EPPO. These

challenges have resulted in a low number of EPPO reports stemming from the

Commission as a whole.

The cultural difference between the spending DGs’ administrative role and the criminal

justice area in which the EPPO operates poses three particular challenges. First, there are

some difficulties in translating the administrative realities of ‘irregularity’ and ‘financial

corrections’ into the legal definitions of ‘damage’ or ‘loss’ required for criminal

prosecution. Second, spending DGs do not hold the operational data for shared

management funds because these data are held by national or regional authorities. Third,

while the need to keep the secrecy of investigations was well understood, spending DGs

noted that it would be useful for them to receive information from the EPPO on systemic

81 EPPO, Relations of the EPPO with its partners, p. 107, available at:

https://www.eppo.europa.eu/assets/annual-report-2024/pdfs/relations-eppo-with-partners.pdf 82 Interview of the consultant with a representative of an EU Agency (study, p. 122). 83 Ibid. 84 Spending DGs are DGs that are in charge of spending or monitoring the highest amount of EU funds.

Examples are DG AGRI (Agriculture and Rural Development), DG EMPL (Employment, Social Affairs

and Inclusion) and DG REGIO (Regional and Urban Policy).

30

deficiencies or crime patterns when investigations are ongoing because this would allow

them to monitor the system or look for fraudulent irregularities in a more targeted way.

A further, fourth, challenge reported by spending DGs relates to the fact that official

institutional notifications by the EPPO about significant developments in investigations

often reach them only after the EPPO has issued a press release. Advance notice would

make it easier to handle the relevant information and would avoid internal escalations

and unnecessary coordination work. Furthermore, some notifications did not mention the

relevant national Paying Agencies as injured parties, even though judges need this in

order to be able to recognise these parties in recovery procedures.

In 2021, the EPPO and the Commission signed a Cooperation Agreement establishing

the modalities of their cooperation. This was revised in 2024 with the particular aim of

improving the EPPO’s notifications to the Commission so that the Commission can take

precautionary and corrective measures85. The amendments aimed to provide for more

direct communication between the EPPO and the Commission DGs; to give the EPPO

direct access to some databases; to introduce new notification templates; and to introduce

the EPPO box, which is a dedicated and secure tool for exchanging case-related

information86. The stakeholders have provided generally positive feedback on the

amendments because they consider that they allow more direct exchanges of information

between the relevant Commission services and the EPPO (instead of indirect

communication via OLAF). As a result of the review, the DGs are now more directly

involved and have clearer roles87.

In 2025, the EPPO notified indictments and simplified prosecution procedures to the

Commission. These related to a total of EUR 171.3 million of estimated damage related

to expenditure fraud and EUR 1.19 billion of estimated damage related to revenue

fraud88. The new framework for communication between the EPPO and the Commission

DGs is currently being implemented89.

Overall (and despite the above-mentioned difficulties, which were addressed with the

2024 amendments to the Cooperation Agreement), the spending DGs consider the EPPO

a ‘game changer’ because it can connect cross-border fraud patterns that had been

difficult to identify and address when handling was purely national. They consider that

the EPPO provides a unique opportunity to ensure criminal accountability that

complements administrative tools – even if the length of criminal proceedings means that

it is not yet possible to demonstrate the final benefits.

Non-participating Member States

The number of Member States not participating in the EPPO fell over the evaluation

period. Denmark, Hungary, Ireland, Poland and Sweden were not part of the EPPO when

the EPPO started its operations on 1 June 2021, but Poland and Sweden joined it in 2024.

On 29 May 2026, Hungary notified the Commission of its intention to join the EPPO.

The Commission adopted its Decision confirming Hungary’s participation in the EPPO

on 10 July 202690, which enters into force 20 days after its publication on the Official

Journal.

85 EPPO Annual Report 2024, p. 106. 86 Interview of the consultant with a representative of the Commission. 87 Ibid. 88 EPPO Annual Report 2025, p. 73. 89 Interviews of the consultant with representatives of the Commission. 90 Commission Decision (EU) 2026/1701.

31

The EPPO’s strategy has been to ensure that cooperation with non-participating Member

States is strong, because such cooperation is crucial for investigating and prosecuting

cross-border cases and for recovering assets. The EPPO signed a Working Arrangement

with the Office of the Prosecutor General of Hungary in 2021 and the Danish Ministry of

Justice in 2023. Cooperation formally started with Ireland in 2023, but a working

arrangement has not been signed yet.

As highlighted in Table 50 in Annex 9 to the study supporting this evaluation and in the

2025 EPPO’s report on its international activities91, there were only a few EPPO cases

involving Denmark and Ireland between 2021 and 2023. However, the number of EPPO

cases involving Hungary increased from 17 in 2021 to 175 in 2025 (there were 18 cases

involving Ireland and 14 cases involving Denmark at the end of 2025).

Overall, cooperation with the non-participating Member States is reported to be working

well. National prosecutors of non-participating Member States are aware that they have

to execute EIOs from the EPPO. However, stakeholders indicated some gaps in

communication channels, because communication currently takes place by email and

post. The EPPO does not use the e-evidence system to transfer mutual legal assistance

requests and EIOs (eEDES). Introducing a safe system to share relevant data would make

cooperation more secure and effective.

Non-EU countries, including enlargement partners

The EPPO can establish and maintain cooperative relations with non-EU countries and

international organisations. Article 104 of the Regulation outlines several mechanisms

for cooperation with third countries. These include concluding Working Arrangements

with third countries’ authorities; strategic information exchanges; mutual legal assistance

in accordance with different legal bases; and the secondment of liaison officers to the

EPPO. Article 104(1) provides that Working Arrangements ‘may in particular, concern

the exchange of strategic information and the secondment of liaison officers to the

EPPO.’ The EPPO can also designate a contact point in third countries. However, the

Working Arrangements cannot form the basis for the exchange of personal data and do

not bind either the EU or its Member States. By the end of 2025, the EPPO had signed

Working Arrangements with public prosecutors’ offices in 17 non-EU countries

(including 7 EU candidate countries) and with anti-corruption structures in four non-EU

countries. It had also signed 3 Memoranda of Understanding (MoUs)92.

In practice, the EPPO can face challenges in being recognised by non-EU countries as a

competent authority for the purpose of judicial cooperation in criminal matters. The

EPPO is a body of the EU, not a national authority. In the absence of EU-level

agreements binding on the EPPO, the EPPO relies on the existing international

agreements on mutual legal assistance to which the EU and/or the Member States are

Parties. However, such agreements regulate the cooperation between the competent

authorities of states. Non-EU countries may therefore be unable to recognise an EU body

such as the EPPO as a competent authority in the same way that they would recognise a

national prosecutor’s office.

The number of active EPPO cases linked to non-EU countries has significantly increased

since the EPPO was established in 202193. By the end of 2022, non-EU countries had

91 EPPO Annual Report 2025 – International activity (https://www.eppo.europa.eu/sites/default/files/2026-

06/AR_2025_International_activity_final_short.pdf), p. 4. 92 The full list of these Arrangements/MoUs is available on the EPPO’s website. 93 See Table 49 in Annex 9 to the study.

32

been involved in 61 EPPO cases. By the end of 2025, this number had risen to 19394.

Third-country public prosecutors that were interviewed assessed the cooperation with the

EPPO positively overall (particularly in cross-border investigations and gathering

evidence). Stakeholders often referred to timely communication, mutual understanding of

procedural standards and effective exchange of documentation. The EPPO’s structure as

a single point of contact simplifies the legal cooperation process and can avoid

unnecessary procedural duplication. However, the number of cases in which the public

prosecutors who were interviewed had dealt with the EPPO was low overall.

4.1.1.6. Operational achievements: reports, investigations, prosecutions

The number of ECRs has gradually increased since the EPPO started operations in 2021

(as shown in Table 2 above). The reporting to the EPPO is crucial for the EPPO to

become aware of possible PIF crimes. The EPPO mostly exercises its competence on the

basis of the reports that it receives. National Financial Intelligence Units (FIUs) play an

important role in this respect. This point is recognised by the EPPO, which established

cooperation with FIUs and participated in outreach events to inform FIUs of the EPPO’s

role95. 13 of the 17 consulted FIUs reported a high or mature level of cooperation with the

EPPO but also highlighted uneven levels of cooperation: some FIUs cooperate with the

EPPO on the basis of MoUs, while others rely on general anti-money laundering

framework.

IBOAs report to the EPPO much less than private parties and national authorities report

to the EPPO. Some stakeholders (including stakeholders from other IBOAs) pointed to a

lack of ‘legal literacy’ regarding the EPPO’s mandate and competence. Furthermore,

interviewees from the Commission and OLAF point to the fact that there may be

uncertainty as to whether to report cases to OLAF or to the EPPO, with OLAF often

being chosen over the latter. This is because OLAF has existed for longer and because of

the ‘cultural proximity’96 between the staff of the spending DGs and OLAF, which is

formally part of the Commission.

The establishment of the EPPO has led to an increase in the identification, investigation,

and prosecution of PIF crimes. The EPPO’s work has had a particular impact in

addressing large-scale cross-border offences, such as MTIC and customs fraud.

Examples of large-scale cross-country EPPO cases include Operation Admiral (and the

follow-ups) and Operation Moby Dick97; Operation Moby Dick, in which over 195

individuals and 400 companies were investigated, highlighted the sophistication with

which organised criminal groups defrauded Member States of, allegedly, over

EUR 520 million through VAT carousel fraud. Interviewees at both the national and the

central EPPO levels stated that this and other operations only happened because of the

EPPO’s existence.

The establishment of the EPPO has led to a qualitative leap forward in the effectiveness

of investigations relating to crimes affecting the EU’s financial interests. Interviewees

reported the following improvements.

94 EPPO Annual Report 2022, p. 97; EPPO Annual Report 2025 – International activity, p. 4. 95 See 2025 Egmont Plenary, Luxembourg – Co-Chairs’ Statement, available at:

https://egmontgroup.org/news/2025-egmont-plenary-luxembourg-co-chairs-statement/. 96 Study, p. 80. 97 See EPPO press release (2025) https://www.eppo.europa.eu/en/media/news/moby-dick-suspected-

ringleader-eu520-million-vat-fraud-investigation-turns-himself.

33

• The EPPO goes beyond the traditional cooperation mechanisms and has

established an integrated ‘EU investigation and prosecution zone’. Cross-

border evidence-gathering used to rely on mutual legal assistance (MLA)

procedures, which were often slow. Under the EPPO framework, an EDP can

directly assign investigative measures to EDPs in other Member States. This

substantially streamlines the investigations in cross-border cases. In 2025, EDPs

issued 1 524 requests to EDPs in other Member States, achieving a speed and

information gain that – as many stakeholders stated, albeit without quantifiable

indicators – traditional mechanisms simply could not match. One interviewee

reported that, during a joint action day, evidence of the location of one suspect

was found in one Member States and led to that suspect’s arrest in another

Member State within hours, something that would have taken much longer

without the EPPO.

• The EPPO’s helicopter view makes it much more effective. It enables the

EPPO to identify connections between cases that national authorities may not be

able to spot. In 2024, the EPPO organised 41 multisite action days98. Action days

are not expressly mentioned in the EPPO Regulation, but they have turned out to

be an effective instrument that allows simultaneous searches, arrests and asset

seizures in multiple locations and jurisdictions.

Furthermore, in some casesorganised criminal groups are reportedly considering

establishing their operations in jurisdictions where the investigative and prosecutorial

capacities are perceived to be less of a risk to their activities. One prosecutor who was

interviewed mentioned a wiretapping case where the members of an organised criminal

group were overheard discussing the option of relocating to a Member State that does not

participate in the EPPO.

The EPPO’s operational model has also resulted in a significant increase in the number

of indictments. These rose from 5 in 2021 to 275 in 2025. By the end of 2025, 517 cases

were in the trial phase and 159 convictions had been secured after the EPPO’s

prosecutions. Unfortunately, there is no comparable data for the number of indictments,

trials and convictions in the situation before the establishment of the EPPO.

4.1.1.7. Financial impact: seizures, confiscations, recoveries

Table 3 presents some indicators of the EPPO’s financial impact since June 2021.

Table 3: Financial impact: freezing orders granted, assets effectively frozen and

estimated damages to the EU budget99

Outcomes (EUR) 2021 2022 2023 2024 2025

Freezing orders

granted

147.3

million

359.1

million

1.5 billion 2.42 billion 1.13 billion

Assets effectively

frozen

n/a100 n/a n/a101 849 million 288.93

million

98 EPPO CAAR 2024, p. 14. 99 Study, p. 82. ‘Freezing’ is the temporary prohibition of the transfer, disposal or movement of property.

‘Confiscation’ is the final deprivation of such property. National courts grant freezing and confiscation

orders, usually at the request of national prosecutors or the EPPO. 100 The 2021 Annual Report states that the total value of confiscated assets amounted to EUR 22 000

(p. 13).

34

Estimated damage to

EU budget

5.4 billion 14.1 billion 19.27 billion 24.8 billion 67.27 billion

A distinction should be drawn between the value of freezing orders granted and the value

of assets effectively frozen. Freezing orders are granted by competent courts or judges

upon the EPPO’s request, but the simple ‘granting’ of such orders does not ensure that

the whole amount of the assets concerned is automatically frozen. For instance

EUR 2.42 billion in freezing orders were granted in 2024, but only EUR 849 million of

assets was physically frozen by national authorities further to the EPPO’s requests.

‘Estimated damage’ is the damage (likely to be) caused as a result of all PIF offences

under investigation at the end of each year (including those PIF offences for which

investigations were opened in previous years), based on the EPPO’s calculations. The

EPPO, OLAF and spending DGs have different ways of estimating estimated damage102.

Data on the final recovery of assets are difficult to collect. Assets can only be recovered

after judicial proceedings have been concluded – these can last for several years – and

once all remedies have been exhausted. Furthermore, the Member States retain amounts

relating to VAT fraud that are recovered as a result of judicial decisions. The ECA

estimates the total value of final recovery orders issued by national courts in 2024 at

EUR 231.7 million103. Once again, the actual amounts recovered are not provided. No

additional information on the final amounts recovered could be collected through the

questionnaire circulated via the Council. This information ‘blind spot’ is symptomatic of

structural difficulties in collecting data.

The present evaluation can only conclude that the EPPO Regulation and the EPPO

appear to be on track to eventually increase higher recoveries, but it cannot provide a

definitive, system-wide assessment of the extent of achieved recoveries attributable to the

EPPO’s action.

4.1.2. Efficiency

The efficiency assessment examines the relationship between the resources allocated to

and used by the EPPO and the changes it generated (i.e. the activities conducted and the

outcomes achieved).

Main findings on efficiency

The EPPO has generally used its resources efficiently to attain its objectives, although,

according to the EPPO, it has operated in a state of continuous underfunding, since its

workload far exceeded the initial expectations. The EPPO has demonstrated high

organisational efficiency by achieving a high budget execution rate through mature

financial management and significantly more operational efficiency than was the case

before it was established. The qualitative assessment carried out in the context of this

evaluation indicates that the benefits of the EPPO could significantly outweigh the

costs related to its establishment and functioning, especially bearing in mind the ‘knock

on’ effects following from the EPPO’s operations, such as improvements to deterrence

101 The 2023 Annual Report states that final confiscations of more than EUR 60 million were ordered by

courts in definitively resolved cases (p. 70). 102 For instance, if a fraudulent irregularity on a project worth EUR 1 million is identified early (for

example, after the disbursement of the first EUR 100 000), the spending DGs would estimate the damage at

EUR 100 000, while the EPPO would use the total figure of EUR 1 million. 103 ECA Special Report 26/2025, p. 36. The ECA clarifies here that this figure ‘[i]ncludes only the final

court orders issued in 2024 concerning the investigations opened in 2022-2024.’

35

and enhanced protection of the Union budget. However, the evidence also indicates some

areas where efficiency gains are still possible, with many of them not depending on the

EPPO alone, but rather on the Member States.

4.1.2.1. Overview of the EPPO’s use of resources

The EPPO is financed through the general budget of the EU. Its annual subsidy is

authorised under the MFF. The EPPO’s financial needs have grown substantially over

the years, driven by the increasing number and complexity of investigations as well as

the increasing number of Member States participating in the EPPO. This has necessitated

a similar increase in the EPPO’s human resources and has far exceeded the expectations

outlined in the Legislative Financial Statement (LFS) that accompanied the proposal for

the EPPO Regulation. The revised LFS anticipated a gradual budgetary increase between

2018 and 2023, at which point it expected that the EPPO would have a stable structure

and budget.

Table 4: Revised LFS – Estimated Budget 2018-2023 (EUR thousands)104

Budget Title 2018 2019 2020 2021 2022 2023 Total

Staff0 2 254 3 294 7 658 9 252 11 328 33 786

Infrastructure and

operating0 690 986 1 479 1 676 1 972 6 803

Operational0 1 967 1 967 4 063 4 649 5 377 18 022

Total 0 4 911 6 247 13 200 15 577 18 677 58 611

The revised LFS also provided human resource estimates. As Table 5 below shows, it

was anticipated that the EPPO would require 115 full-time equivalents (FTE) by 2023.

These would comprise 80 FTE establishment plan posts (including staff transferred from

the Commission, OLAF and Eurojust) and 35 FTE external contracted personnel.

Table 5: Revised LFS – Human Resource Estimates 2018-2023105

Human resources 2018 2019 2020 2021 2022 2023 Total

New establishment plan posts (FTE) 0 32 5 23 8 12 80

Of which AD 0 26 3 14 4 4 51

Of which AST 0 6 2 9 4 8 29

New external personnel (FTE) – contracted 0 0 5 17 7 6 35

Total new staff (per year) 0 32 10 40 15 18 115

Total staff (cumulative) 0 32 42 82 97 115

As Table 1 above shows, the evolution of the EPPO’s budget and human resources has

been significantly different. For example, the EPPO’s 2023 budget was EUR 66 million

(the revised LFS had estimated it at EUR 18.7 million). Its 2025 authorised budget was

EUR 85.9 million. The numbers of both statutory staff and EDPs have similarly

increased and far exceed the revised LFS’s estimates.

A significant proportion of the EPPO’s resources was allocated to operationally-focused

job types and activities during the evaluation period. The study compares similar data for

Eurojust and Europol and concludes that – despite significant differences between the

EPPO and those two agencies as well as the fact that the EPPO was in a capacity-build-

up phase throughout the evaluation – the EPPO prioritised its operational work in its

initial years while relying on lighter administrative support. The EPPO’s administration

104 Study, p. 88. 105 Ibid.

36

was therefore underdeveloped because the EPPO was trying to establish and increase its

operational functions. However, the EPPO has made progress over the evaluation period

towards a more balanced human resource structure. 90% of EPPO positions (including

EDPs) were operational in 2021. This decreased to 85.5% in 2024106.

4.1.2.2. Efficiency of the EPPO’s use of resources

The available evidence and feedback from stakeholders indicate that the EPPO has

generally used its allocated resources efficiently to attain its objectives. The significant

differences between the budgetary expectations outlined in the revised LFS and the

operational reality (and resulting demands placed on the EPPO’s resources) underpin all

the considerations on the EPPO’s efficiency. The EPPO had to deal with a much greater

level of work, including work related to cross-border cases, than was initially anticipated.

Looking at casework, the revised LFS estimated that the EPPO would deal with 970

active cases per year from 2023 onwards. In practice, the EPPO had 515 active cases at

the end of 2021 (after its first seven months of operations) and this rose to 3 602 by the

end of 2025. The EPPO attributes this increase to two key factors: (i) the increasing

number of ECRs being submitted; and (ii) the difficulty of clearing cases from its roster

of active cases, given the complexity of cases and the length of time it takes to progress

such cases through the investigation and prosecution process.

The ratio of active cases to the number of staff / EDPs has also increased significantly –

despite the increasing number of staff/EDPs. At the end of 2021, the EPPO was handling

two active cases per staff member (including EDPs), 5.4 active cases per EDP, 70 active

cases per EP and 102.7 active cases per Permanent Chamber. At the end of 2024, these

figures had increased to 5.9 active cases per staff member, 16.1 active cases per EDP,

111.1 active cases per EP and 177.7 active cases per Permanent Chamber107. This

suggests an increase in workload but could also indicate increased organisational

efficiency as the EPPO’s operational maturity has developed. However, this EDP-case

ratio does vary significantly between Member States108.

Many factors influence the appropriateness of such ratios (e.g. the complexity or status of

cases), but the increasing organisational efficiency over the evaluation period was

supported by stakeholder feedback. The EPPO viewed the resourcing situation over the

evaluation period as insufficient, referring to ‘severe underfunding’ (particularly by

comparison with casework demands). Representatives of the Commission stated that they

would typically expect a new EU body to be operating with stable resources and to have

reached ‘cruising speed’ by the end of the evaluation period. However, while the

Commission services define ‘cruising speed’ by reference to the stability of structures

and resources, the EPPO refers to the continuing growth in the number of cases as

evidence that the EPPO has not yet reached ‘cruising speed’ and needs to continue

growing (particularly given the principle of mandatory prosecution under which it

operates; the fact that new Member States have joined or will join the EPPO; and the

increasing numbers of ECRs).

The EPPO states that the perceived underfunding caused a number of challenges during

the evaluation period. These include:

• Low predictability of operational expenditure, particularly in the first years.

106 For further details, see Table 9 and Figure 9 in the study, p. 91. 107 These calculations are based on end-of-year figures reported in the EPPO’s CAARs. 108 Study, p. 93.

37

• Structural understaffing and recruitment challenges: the EPPO reports that core

central office teams were still understaffed in November 2025; although it is

challenging to assess the appropriate number of staff in the different areas of the

EPPO’s work, benchmarking against EU agencies operating in similar fields

(despite the differences in their mandates) further supports this point109.

• Inability to invest sufficiently in digital tools: the EPPO’s leadership and senior

management noted that the CMS’s ability to support information-sharing (for

example, with other EU IBOAs) and analysis is limited. Core HR processes that

should be automated are reportedly still carried out manually.

• Burdensome programming and reporting processes: the EPPO’s leadership and

senior management have highlighted this point and also reported challenges in

ensuring that prosecutors understand the technicalities of the EU budget process.

Overall, the combination of the EPPO being in its build-up phase, the lack of insight into

the operational reality and scale of the EU’s needs before June 2021, and the related

restrictions on financial and human resources have created a challenging implementation

environment for the EPPO’s budget and HR management. The EPPO’s efficiency in this

regard is nevertheless assessed as generally positive.

4.1.2.3. Efficiency of the EPPO’s working practices

Some challenges have been identified, but the EPPO’s working practices have generally

been implemented efficiently. Assessing the cost-effectiveness of the EPPO requires a

detailed understanding of the different types of costs related to the EPPO’s activities and

the resulting benefits, quantified and monetised as much as possible. However, while the

costs at the EU level are clear, only limited data are available on the national-level costs

associated with implementing the EPPO Regulation and supporting the EPPO’s

activities. In addition, the challenges regarding the quantification of certain impacts

(e.g. damage in a case, freezing and confiscation of assets, recoveries for the EU budget)

prevent a fully quantitative and monetised assessment of the benefits. In this context, the

outcome of this exercise is a qualitative assessment of the balance of costs against

benefits, supplemented by targeted calculations based on a range of assumptions that try

to illustrate the potential financial impact of the EPPO.

Box 4: Assessment of the EPPO’s cost-effectiveness

Costs: the costs to the EU budget in 2019-2025 totalled around EUR 341 million110. The

Member States also incurred costs when setting up their national systems to support the

EPPO. These national costs relate to: (i) EDPs’ employment rights (e.g. social security

and pension rights); (ii) the national assistants to the EDPs (NEDPAs)

(e.g. remuneration); (iii) adaptation and maintenance/updating of IT systems; (iv)

training, capacity-building and awareness-raising; and (v) building/infrastructure

provided to the EDPs. The national-level stakeholders that were consulted were usually

unable to isolate the costs specifically related to the EPPO because they are often

109 Study, p. 95. 110 This is the sum of the EPPO budget appropriations for each year (n) as reported in Section III of the EU

annual budget for the year n+1: 2019: EUR 4.9 million; 2020: EUR 11.7 million; 2021: EUR 45.0 million;

2022: EUR 55.6 million; 2023: EUR 65.1 million; 2024: EUR 74.8 million; and 2025: EUR 84.0 million.

These amounts do not reflect the final budget figures consumed by the EPPO, but they do reflect a

consistent set of data that also includes costs for 2019 and 2020. See Box 5 of the study (‘Assessment of

the EPPO’s cost-effectiveness’), pp. 97ff., for more details and for the various assumptions and limitations

of the estimations used in this section.

38

integrated within broader budget lines. Only one Member State has so far been able to

provide a clear breakdown of costs – declaring annual costs of EUR 444 000

(EUR 424 000 relating to the employment rights of the EDPs111 and EUR 20 000 relating

to operational measures).

The study estimated on the basis of this information that the total cost for Member States

in 2021-2025 was around EUR 37.7 million. Combined with the costs for the EU budget,

the total costs of the EPPO Regulation amounted to around EUR 370.9 million.

Benefits: the EPPO has significantly boosted the protection of the EU’s financial

interests in the Member States by: improving enforcement; prioritising investigations and

prosecutions of PIF offences; and removing practical barriers to the investigation and

prosecution of complex cross-border cases (thus significantly improving the speed,

effectiveness and efficiency of investigations, particularly as regards VAT fraud).

It is nevertheless difficult to assess many of these benefits in monetary or other

quantitative terms. The analysis conducted for the purpose of this evaluation has

therefore focused on trying to estimate the share of the benefits that relates to freezing,

confiscation and recovery. The EPPO handles cases that cause significant estimated

damage to the EU budget and its activities can be complemented (including through

financial penalties and deterrence and compliance measures). For instance, the Hellenic

Independent Authority for Public Revenue noted greater compliance with import rules in

the aftermath of the EPPO’s investigation in the Calypso case (revenue from duties and

VAT on imported goods in the port of Piraeus increased from EUR 139.9 million in July

2024 to EUR 143 million in July 2025112). This illustrates how EPPO’s activities boost

compliance with import rules, but the available evidence does not demonstrate whether

or not this impact was due to the EPPO alone.

Estimating potential for confiscation and recovery in 2021-2025: the study estimated

an upper and lower percentage for recovery in EPPO cases on the basis of: (i) a small

number of already existing estimates of the proportion of provisionally seized/frozen

assets that are ultimately confiscated; (ii) the percentage of criminal proceeds that are

confiscated at the end of criminal proceedings; and (iii) data on freezing orders obtained

by the EPPO and assets that are effectively frozen. The study applied these rough

estimates to the volume of assets effectively frozen in 2024 and 2025 and tentatively

predicted that the amount potentially confiscated/recovered could range between

EUR 237.7 million and 424.5 million for 2024 and between EUR 80.9 million and

144.5 million for 2025. As these figures show, annual recovery figures change depending

on the nature and value of the cases being brought. Furthermore, it is unclear what will

be returned to the EU centrally. These estimates nevertheless indicate that the potential

benefits of the EPPO could besignificant. A range of national-level stakeholders

supported this assessment.

In this context, the EPPO has (as already pointed out) delivered significant operational

efficiencies compared with the pre-EPPO situation, particularly in complex cross-border

cases. First, the creation of the EPPO has allowed to better detect fraud and enabled

significant cross-border cooperation that is reportedly much quicker than before. Second,

the operational structure established by the EPPO Regulation and implemented by the

111 The cost of EDPs’ remuneration is borne by the EPPO. The Member States bear the cost of their rights

relating to social security, pension and insurance coverage. 112 EPPO press release, 2025, https://www.eppo.europa.eu/en/media/news/investigation-calypso-more-2-

400-shipping-containers-seized-port-piraeus.

39

EPPO is working well and making it more possible to mobilise resources and expertise,

coordinate investigations and streamline prosecutions across multiple jurisdictions –

thereby increasing the efficiency of investigations. The assessment did nevertheless

reveal some challenges in the EPPO’s work that can have an impact on efficiency,

notably:

• The Permanent Chambers’ role: a small number of stakeholders (notably former

EPs) noted that the Permanent Chambers are a useful forum for supervision. They

nevertheless argued that the Permanent Chambers should not take important case

decisions (for example, whether or not to bring a case to judgement). They further

stated that, while the Permanent Chambers can play a valuable role in complex

cases, their involvement can be excessive for simpler files.

• Reporting forms and information sharing: the EPPO uses different templates for

reporting and exchange of information. The feedback from the stakeholders who

were consulted was mixed. Some representatives of national authorities noted that

the process of submitting ECRs takes a long time and could be simplified, while

others stated that the burden is limited (particularly when compared with

expectations during the negotiation of the Regulation). Others acknowledged the

burden but also recognised that the EPPO had taken steps to improve the

efficiency of the reporting channels, particularly from the perspective of FIUs.

One EU IBOA representative stated that the EPPO box system for sharing

information with the EPPO was cumbersome and that the evidence and

documentation provided are not always accessible to the relevant EPs and EDPs.

• Operational challenges, including access to national resources: the EPPO relies

heavily on the provision of resources, including investigative resources, at the

national level. Many national-level stakeholders highlighted the challenges that

this raises, including: (i) significant differences in the level of support provided

not only between but also within Member States (the EPPO may have to

cooperate with different national authorities according to the circumstances of

each case); (ii) staffing level of national law enforcement; and (iii) high case

levels. The EPPO welcomed the fact that some Member States ensure that the

EPPO has dedicated investigative teams, but there are times when the complexity

and large scope of cases continue to outweigh the capacity of dedicated staff113.

There is also significant variation in both the absolute and relative number of

NEDPAs allocated to the EDPs, as well as part-time NEDPAs. In absolute terms,

the number of NEDPAs (in FTE terms) in December 2025 ranged from 0.2 (i.e. 1

day per week) in one Member State (a ratio of 0.1 NEDPA per EDP) to 54 in

another Member State (a ratio of 2.6 NEDPAs per EDP) 114.

• Challenges resulting from a set of recurring issues that the evaluation found in the

implementation of the EPPO Regulationacross Member States: as mentioned,

there are cases where national law does not allow directly reporting to the EPPO

and this may reduce the number of ECRs timely transmitted to the EPPO and

potentially delay the opening of cases.

• Challenges resulting from the EPPO’s multilingual environment: such challenges

are inherent in an EU body that operates in 24 Member States. However, the

113 In 2025, only seven participating Member States had dedicated investigative teams supporting the

EPPO, with a total of 114 dedicated investigators. 114 Study, p. 103.

40

EPPO Regulation does not expressly regulate how to deal with them. In practice,

resource constraints make the EPPO heavily reliant on machine translation.

However, Member States’ rules on translation vary greatly. Some Member States

are flexible and open to accepting of translations from different sources. Other

Member States are very formalistic and impose specific requirements (e.g. only

translations by sworn translators are accepted).

4.1.2.4. Cooperation with EU IBOAs

The findings on the efficiency of the EPPO’s cooperation with EU IBOAs (including

how it has been streamlined over time) are mixed. Overall, the EPPO has established

good relations with relevant EU IBOAs and has consistently sought to improve the

procedures for cooperation. Challenges nevertheless remain, particularly as regards

exchange of information. This is discussed in detail in Section 4.1.1.5 above.

Concerning the EPPO’s cooperation with OLAF, there is an ongoing need for an

automated hit/no-hit system, better mutual understanding of each Office’s competence to

avoid unnecessary referrals, and improved quality and substantiation of case referrals.

For cooperation with Europol and Eurojust, the main efficiency challenges in both cases

related to information/data exchange via the hit/no-hit system.

As far as the EPPO’s cooperation with the Commission is concerned, some spending

DGs noted that the EPPO is reluctant to share information with the Commission due to

confidentiality issues related to ongoing criminal investigations. The EPPO confirmed

this, stating that, if such information-sharing and possible ensuring actions by the

Commission take place too early, they could impact EPPO cases (for instance by

inadvertently disclosing the existence and/or details of ongoing investigations to potential

suspects). However, the spending DGs did also confirm that steps had been taken during

the evaluation period to improve the efficiency of information exchange.

An additional challenge as regards cooperation with EU partners concerns the Eurofisc

network 115. The EPPO is currently required to access data held by the Eurofisc network

indirectly via specific Member States. This is less efficient than having direct access to

the relevant databases and tools. However, this challenge should be removed once the

Council approves the amendment to the Eurofisc Regulation116 that the Commission

proposed in November 2025117.

More generally, the efficiency of the EPPO’s cooperation with EU IBOAs also relies on

the lifting of privileges and immunities from persons under investigation and on staff

members being authorised to testify as witnesses. A refusal by an IBOA to lift privileges

and immunities stemming from the Protocol or even the duty of confidentiality set in the

Staff Regulations may make it impossible to investigate or prosecute specific offences118.

4.1.2.5. Potential for simplification and costs savings

Stakeholders provided limited feedback on activities and operations that had turned out

to be too expensive or cost-ineffective. As noted above, the efficiency of the EPPO’s

work has been hindered by specific challenges rather than particularly costly or

115 The Eurofisc network was launched in 2010 to combat cross-border VAT fraud. It comprises liaison

officials from the 27 Member States and Norway. 116 Council Regulation (EU) No 904/2010, OJ L 268, 12.10.2010, pp. 1-18, as subsequently amended. 117 COM(2025) 685 final, 14.11.2025. 118 See Case T-99/25, 10 June 2026, EPPO v Court of Auditors, ECLI:EU:T:2026:380.

41

inefficient approaches. However, for most of those challenges, steps have been or are

being taken to improve the situation and others may follow.

The evidence gathered indicates that there appears to be limited awareness and use of

Article 91(6) of the EPPO Regulation. This enables the EDPs to request financial support

from the EPPO for exceptionally costly investigation measures. In 2022, only one formal

request was received. Spending on this budget line remained limited in 2023

(EUR 78 208) and 2024 (EUR 47 371)119.

The use of digital tools and in particular the CMS is one area where efficiency (and

effectiveness) benefits can still be realised. As noted above, the CMS is not considered to

be user-friendly and is reported to be burdensome. Furthermore, access rules do not allow

NEDPAs to input data into it and EDPs therefore have to input case data themselves, thus

reducing the time they can devote to their core tasks. The EPPO reports that it has not

had the resources to properly invest in improving IT systems (e.g. integrating AI tools for

data analysis in the CMS or introducing digital HR tools).

4.1.3. Coherence

The coherence assessment examines the extent to which the EPPO Regulation is a

consistent and unified framework, both internally (i.e. whether the different elements of

the Regulation work together as intended) and in its interaction with other relevant EU,

national and international interventions. Coherence is particularly important for the

EPPO because its hybrid design combines centralised EU-level functions with

decentralised implementation through national judicial systems.

Main findings on coherence

The EPPO Regulation and its implementation have proven, despite some gaps,

inconsistencies and/or ambiguities, to be coherent overall, both internally and

externally. The internal assessment shows that, while the Regulation is consistent in its

overarching design and objectives, its coherence remains uneven in practice. The

Regulation establishes the EPPO as a single and indivisible EU body. However, the

interaction between its provisions and their reliance on national laws creates structural

tensions that undermine its consistent application across the Member States. Likewise,

the external assessment shows that the EPPO Regulation is broadly consistent with

relevant EU, national and international interventions, but also that some challenges

remain (for example, as regards cooperationwith OLAF and specific issues related to

cooperation with EU third countries and the protection of procedural safeguards in the

context of EPPO proceedings).

4.1.3.1. Internal coherence

The EPPO Regulation was the outcome of complex and long negotiations, which resulted

in the creation of a hybrid investigative and prosecutorial body that combines centralised

and decentralised elements. Bearing this in mind, stakeholders identified some

shortcomings in the EPPO’s internal coherence, primarily relating to provisions that

would benefit from further clarification. In particular, some provisions are not

sufficiently clear in the light of the EPPO’s hybrid structure and the Regulation’s

extensive reliance on national law. The interaction between certain Articles consequently

creates ambiguities and potentially divergent interpretations and implementation

practices across Member States.

119 EPPO, Reports on Budgetary and Financial Management, financial years 2021-2024.

42

Most of the issues at stake in this respect have already been addressed in the previous

sections. They concern, among others, the difficulties in calculating the threshold of

EUR 10 million-damage for cross-border VAT fraud; the unclear notion of the ‘focus’ of

the activity of a criminal organisation; the complex rules on the exercise of the EPPO’s

competence in cases of inextricably linked offences; and the ambiguity created by the

misalignment between Articles 25(6) and 42(2)(c) on conflicts of competence.

Another issue relates to the wording of Article 31 of the Regulation. This does not clearly

set out the rules to be followed when, in the context of an EPPO cross-border case, the

national legislation of more than one Member State would require the EDPs involved to

obtain a judicial authorisation to perform specific investigative measures. This issue was

subject to the interpretation of the Court of Justice of the European Union in its ruling in

Case C-281/22120. The Court ruled in this case that it is the courts of the Member State of

the EDP responsible for the investigation that are competent to verify the adoption and

justification of investigation measures; and that judicial review of such measures in other

Member States may only relate to matters concerning the enforcement of those measures.

possible issues of internal coherence connected with Chapter VIII of the EPPO

Regulation, which sets out a stand-alone regime of data protection for the EPPO.

Stakeholders highlighted the point that Chapter VIII’s legislative design reflects the

EPPO’s hybrid structure, containing references to national data protection legislation

(including national laws transposing the Law Enforcement Directive (LED) as well as, in

certain cases, national criminal procedural rules). Some Member States have enacted

EPPO-specific implementing legislation to clarify the application of the EPPO

Regulation’s data protection provisions. Most of the other Member States instead rely

primarily on the fact that the Regulation is directly applicable and supplement it with

general national data protection rules that are applicable to law enforcement authorities.

One stakeholder noted that, in line with recital 93, the EPPO’s legal framework is

consistent with the national laws transposing the LED, thus avoiding inconsistencies and

situations where the EPPO has less operational capacity than national prosecution

services121. However, the Regulation does not always clearly delineate the scope of its

data protection provisions vis-à-vis national law. Stakeholders noted that it is not always

clear where the Regulation ends and where national law begins and that it is also unclear

how the two should interact in practice122. Stakeholders generally agreed that these issues

have so far resulted in only limited practical difficulties in daily operations. They

nonetheless highlighted structural tensions within the Regulation and questioned whether

such an approach ensures effective, consistent and legally certain application of the

Regulation’s rules on data protection in the Member States.

4.1.3.2. External coherence

48% of the respondents (36 out of 75) to the study’s survey agreed that the EPPO’s work

is consistent with the mandate and activities of other EU IBOAs (including Europol,

Eurojust and AMLA). Only 2.7% (2 out of 75) disagreed. Similarly, 50.7% (38 out of 75)

agreed that the EPPO’s work is consistent with OLAF’s work and only 2.7% (2 out of

75) disagreed.

120 Case C-281/22, 21 December 2023, G. K. and Others (Parquet européen), ECLI:EU:C:2023:1018. 121 Study, p. 115. 122 Workshop organised by the consultant to validate the findings of the implementation check in the

Member States with senior legal academics and representatives of the Commission.

43

As mentioned above, the EPPO’s mandate appears to be generally consistent with those

of the Justice and Home Affairs (JHA) and AFA agencies and bodies. OLAF, the EPPO,

Europol and Eurojust have clearly defined but complementary roles. However, some

gaps persist, particularly in information-sharing. The evaluation revealed challenges in

the EPPO’s relations with these three bodies and especially with OLAF. The system

currently in place may occasionally fail to prevent parallel investigations from taking

place. Further improvements to the hit/no-hit system, more automated checks and

increased reporting would improve coherence.

The EPPO’s cooperation with the Commission is well-structured overall, but limited

information-sharing and indirect access to databases continue to cause difficulties. The

implementation of the recently amended Cooperation Agreement is expected to lead to

improvements.

The Regulation also appears to facilitate cooperation with the Member States. The EPPO

has concluded Working Arrangements and MoUs with several national authorities to

improve coordination. Some issues nevertheless remain regarding the direct reporting by

national authorities to the EPPO (Article 24). In this respect, the legislation of some

Member States is deemed not to be fully compliant with the EPPO Regulation.

Cooperation with the non-participating Member States is effective overall, but some

frictions and inefficiencies persist – prompting stakeholders to indicate that full

participation in the EPPO would more effectively ensure operational coherence.

Similarly, the legal framework for cooperation with non-EU countries is complex. The

notification of the EPPO as a competent authority by the EU or the Member States is not

always recognised by non-EU countries because the EPPO is a non-state authority.

Stakeholders indicated that legally binding EU‑level frameworks with key non-EU

countries would be more effective.

Regarding the coherence of the data protection framework, the evaluation shows a high

level of uncertainty among stakeholders about the implementation of Chapter VIII of the

Regulation. The interaction between the EPPO Regulation and the European Union Data

Protection Regulation (EUDPR) is relatively clear, but concerns have been raised about

the interaction between the EPPO Regulation and national LED-based regimes. The

EPPO’s stand-alone data protection regime and the LED must be aligned because most

operational data are processed in the national systems. However, the uneven transposition

of the LED in the Member States risks leading to an inconsistent application of the

EPPO’s data protection regime.

Regarding transfers of data to third countries, limitations were encountered due to the

divergences between the EU and national frameworks, transparency gaps and the need to

rely on the EDPs’ powers as national prosecutors in some cases (this means that national

safeguards apply instead of the EPPO safeguards). There appears to be effective

cooperation with the European Data Protection Supervisor, with no reported formal

complaints, enforcement actions or sanctions.

Fundamental rights are an important aspect of the external coherence. One particular

concern is whether the Regulation is consistent with the fundamental rights framework

established under the European Convention on Human Rights (ECHR), the EU Charter

of Fundamental Rights (CFR), relevant EU Directives on procedural safeguards and the

case law of the European Court of Human Rights (ECtHR) and the CJEU.

Article 41 of the EPPO Regulation lays down obligations to uphold fundamental rights in

EPPO proceedings (including the right to a fair trial). Article 42(1) provide that

‘procedural acts of the EPPO that are intended to produce legal effects vis-à-vis third

44

parties shall be subject to review by the competent national courts in accordance with the

requirements and procedures laid down by national law’. The check on the

implementation of the EPPO Regulation in the Member States did not detect any major

instances of non-compliance with the fundamental rights framework. The interviews with

Member States’ authorities confirmed that they do not consider this framework to be a

major structural issue in the implementation of the EPPO Regulation. However,

Article 41 refers to the rights of suspects and accused persons as provided for in EU law,

including the relevant EU Directives on procedural safeguards. The correct

implementation of those rights should therefore be properly assessed in the context of the

compliance checks concerning the transposition of those Directives. These checks have

detected several shortcomings in Member States’ transposition measures123.

Desk research and stakeholder feedback indicate that differences in national procedural

rights (i.e. differences resulting from minimum harmonisation at EU level and the so far

incomplete transposition of the Directives on procedural safeguards) are compromising

the uniformity of defence standards in EPPO cases. Some respondents to the

Commission’s call for evidence reported shortcomings in the protection of procedural

rights for suspects and accused persons at national level. They further stated that these

shortcomings were resulting in different standards of defence in EPPO proceedings, thus

potentially undermining the right to a fair trial124. In particular, defence lawyers

highlighted practices of prolonged pre-trial detention without indictment (sometimes for

more than a year) as well as indictments that are often amended or fragmented (resulting

in defendants facing multiple and successive indictments125. Other stakeholders reported

other issues (e.g. variations in translation practices; limited or unclear national provisions

on access to legal aid; and discrepancies in national rules on access to prosecutorial case

files) that prevent timely access to relevant case materials126.

4.2. How did the EU intervention make a difference and to whom?

The assessment of EU added value examines the extent to which the EPPO and its

founding Regulation have delivered results that could not have been achieved (or not to

the same extent) by Member States acting alone.

Main findings on EU added value

Thanks to its centralisation of resources and prosecutorial authority at the EU level,

coupled with decentralisation of its offices, the EPPO has delivered substantial EU

added value by enabling more effective investigation and prosecution of complex cases

involving the financial interests of the Union compared to what Member States could

previously achieve on their own. There are no precise data on the extent to which PIF

crimes were investigated and prosecuted before the EPPO. It is therefore impossible to

quantify the benefits and compare them with the cost of transferring human and

operational resources from the Member States to the EPPO. The evaluation nevertheless

finds, on the basis of the evidence that has been collected (particularly under

effectiveness), that the Member States could not have achieved the objectives of the

Regulation if they had been acting alone.

123 These shortcomings are currently being addressed through enforcement. 124 Council of Bars and Law Societies of Europe (CCBE), Response to the call for evidence. 125 Interview of the consultant with the CCBE. 126 German Bar Association, Response to the call for evidence; interview of the consultant with a national

authority and the CCBE. See also the European Criminal Bar Association’s proposal to the EPPO College

on guidelines in respect of access to the file (https://ecba.org/extdocserv/projects/eppo/2024-01-05-

12_October2023_Guidelineaccesscasefile75.pdf).

45

National judicial authorities have also benefited from the EPPO’s operational model and

dedicated training initiatives. The EPPO has – by providing specialised tools, expertise

and opportunities for professional development – enhanced cooperation and expertise

within national prosecution authorities in the field of the fight against PIF crimes. The

EPPO is a critical building block of the EU’s AFA. The EPPO has significantly

strengthened the overall protection of the EU’s financial interests by adding a criminal

justice component to the already existing administrative component.

4.2.1. Whether the Member States could have achieved the same objectives

acting alone

The general objective of the EPPO Regulation is to contribute to the strengthening of the

protection of the EU budget. As reported above, the mere fact that the EPPO is effective

in achieving this objective shows that the EPPO provides more value than the Member

States could have achieved acting alone. The EPPO’s hybrid structure (with a central and

a decentralised level) enables the effective coordination of investigations and

prosecutions. It also ensures that the EPPO benefits from the legal knowledge of the

EDPs working in the Member States. The structure places the EDPs within the national

systems and at the same time under an EU hierarchy.

As explained above, there were gaps in the protection of EU funds before the EPPO

became operational. Evidence from interviews conducted for this evaluation suggests that

Member States acting alone lacked the ‘helicopter view’ necessary to identify the vast

range of criminal activity involving organised criminal groups engaged in PIF crimes –

particularly in the area of MTIC fraud. These crimes would often not have been

investigated before the EPPO was established – or at least not to the same extent –

because only a few Member States have the necessary capacity or expertise. The above-

mentioned Operation Admiral is a clear example of how such a helicopter view is central

to the effective investigation and prosecution of PIF crimes.

One interviewee familiar with the prosecution of PIF crimes estimated that, before the

EPPO was established, only a small fraction of an organised criminal network would

have been affected by an investigation or a prosecution and that the bulk of it would have

been able to continue operating elsewhere with relative impunity. Such an outcome is

now nearly or even entirely impossible because we now have an EU-level prosecuting

authority that acts across 24 Member States and can cooperate with the three other

Member States as well as international partners.

The speed with which evidence can be collected and shared to build complex cases is

also relevant. The system of EDPs assigning measures to other EDPs in line with the

nature of the EPPO as a single office has turned out to be much quicker than traditional

cross-border evidence-gathering instruments (including EU instruments such as the EIO).

One prosecutor who was interviewed noted that investigative efforts for PIF crimes

would often ‘stop at the borders’ before the EPPO was established127. By contrast, the

EPPO now allows EDPs and EPs to work in a single structure with the support of a

central office (including analysts and CMS128) and to connect data across files.

Connections between persons, companies and cases can now be made in a way that

would have not been possible before.

127 Study, p. 146. 128 Despite the above-mentioned shortcomings, the CMS allows the automatic extraction of data from

uniform ECRs and enables analysts to spot trends and connections across seemingly disparate national

files. This was described as ‘difficult or impossible’ before the EPPO was established.

46

The above-mentioned action days are an example of the EPPO’s added value. They allow

the EPPO to take simultaneous measures in different Member States and play a critical

role in preventing dissipation of assets, destruction of evidence or the flight of suspects

once an investigation is revealed. Practitioners who were interviewed referred to this

practice as ‘efficient and swift’ 129 and particularly mentioned the coordination of

investigations across the EU without the need to require judicial authorisation in multiple

Member States. Practitioners also noted that the EPPO adds value through effective

cooperation with third countries. Cross-border cases involving such third countries might

well not have been a top priority for national authorities but are now unlikely to be

deprioritised.

Responses to the survey’s open questions indicate that the EPPO has addressed systemic

vulnerabilities in the prosecution of cross-border crimes. Some practitioners broadly

characterised the EPPO as a ‘game changer’ and a ‘major step forward’ that has

transformed the EU’s fight against PIF offences from a system of fragmented national

efforts to a cohesive, independent system based on an EU-level investigative and

prosecutorial body. In this respect, respondents to the survey particularly mentioned the

following reasons why the EPPO provides EU added value.

• Centralisation: the EPPO is a unified and independent body that can manage

serious cross-border cases that exceed the capacity of national-level institutions.

• Specialised focus: the EPPO has enhanced the fight against high-value offences

involving EU funds. It has done so thanks to its dedicated prosecutorial capacity,

specialised knowledge, know-how and high level of expertise.

• Independence and neutrality: the EPPO safeguards investigations from

domestic political pressures and national administrative constraints.

• Procedural coherence: the EPPO tries to ensure the uniform protection of EU’s

financial interests by applying a standardised approach to the investigation and

prosecution of PIF crimes – while also respecting the specificity of each case,

• Low thresholds above which the EPPO can exercise its competence (except

for VAT fraud): the EPPO is in principle competent for all crimes that do more

than EUR 10 000 in damage to the EU budget. The practitioners greatly

appreciate this because it allows the identification and prosecution of cases that

may have been neglected under the pre-EPPO regime (see Section 2.1).

• Strengthening and supporting the national investigative and prosecutorial

capacities: the EPPO Academy is one example of this. It was launched in 2023

and provides a structured environment for specialised training. Its curriculum is

targeted at the most prevalent and damaging forms of financial criminality,

including MTIC fraud. One interviewee stated that the Academy is helping to

‘raise the bar’ in terms of prosecution authorities’ ability to identify, prosecute

and ultimately dismantle complex criminal organisations.

4.2.2. Contribution to the AFA policy framework

The EPPO’s contribution to the AFA has been to introduce a criminal justice logic to

complement OLAF’s administrative investigations and the Commission’s administrative

measures. OLAF focuses on administrative investigations, financial recovery and

disciplinary follow-up. The EPPO aims to establish criminal accountability and

129 Study, p. 146.

47

dismantle the criminal organisations behind large-scale fraud. The two Offices’ bilateral

cooperation ensures that both avenues are available to protect the budget – even if

optimal coordination between them remains a work in progress. This approach has been

welcomed by the interviewees who discussed the AFA and the EPPO’s role in it and

highlighted the gap that existed before the EPPO was established130.

The EPPO has become a key player in the AFA also with regard to deterrence and

security since it contributes to general prevention by ‘following the money’ and securing

convictions, thus protecting not only the budget but also the EU’s internal security.

4.3. Is the intervention still relevant?

The relevance assessment examines whether the EPPO’s objectives remain appropriate to

the problems, needs and priorities that the EPPO Regulation was intended to address; and

whether they continue to do so in a meaningful way.

Main findings on relevance

Overall, the evidence shows that the EPPO has taken steps to meet the needs identified

before its establishment; and that it has largely adapted to evolving needs, thus

remaining relevant in a changing environment (even though some shortcomings remain).

As expected, the EPPO has over time established an increasingly effective judicial

pipeline for PIF crimes. The EPPO is nevertheless unable to resolve some system-wide

shortcomings on its own (e.g. information exchange with other bodies). In addition,

evidential constraints make definitive findings more difficult. The needs and scope that

originally justified the EPPO are evolving and increasing. The EPPO must therefore

strive to remain as relevant as possible by preparing to respond to the current trends in

organised, cross-border and digital crime. Relations with third countries could similarly

be improved with further formalisation.

4.3.1. Responsiveness to the original needs, evolutions in those needs and

emerging trends

The EPPO has taken concrete measures that are consistent with the needs that it was

established to meet. It has put in place an effective EU-level investigative and

prosecutorial system for countering PIF crimes. It deals effectively with complex cross-

border fraud (including VAT-related cases). It uses competence management tools

(including evocation and central steering) to address long-standing issues of fragmented

handling, weak ownership and jurisdictional friction. However, the extent to which these

early developments translate into more effective protection of the EU budget is

influenced by factors beyond the EPPO’s mandate. These factors include support from

the Member States, which remains uneven, and their implementation of the Regulation.

In line with the intervention logic, the EPPO’s design seeks to translate the identified

needs into outputs. This evaluation concludes that the needs that prompted the EPPO’s

establishment are evolving significantly. This is due to multiple factors, including the

changing financial landscape; the increasing complexity of cross-border criminal activity;

structural changes in the AFA; and widespread digitalisation.

With regard to the need for a common prosecution approach and a central EU-level

investigative and prosecutorial structure for PIF crimes, the evidence gathered is

consistent with the EPPO’s functioning as a central body responsible for handling PIF

cases. Reports addressed to the EPPO, investigations opened by it, its active cases as well

130 Study, p. 150.

48

as cases in the trial phase have all increased substantially over the evaluation period. The

EPPO is therefore absorbing case inflow, opening and carrying out investigations, and

moving a growing number of cases towards trial. This is consistent with responding to

the original problems of uneven judicial follow-up and weak incentives to prosecute –

particularly where cross-border complexity had previously reduced prioritisation of PIF

cases and contributed to the fragmentation of their handling. However, the

implementation of the Regulation in 24 systems does still lead to some discrepancies.

Consequently, the Regulation’s specific objective of ensuring ‘consistency and fairness

across Member States by establishing common rules and procedures for the investigation

and prosecution’ of PIF crimes is still not fully achieved and remains relevant.

As far as the need for common investigation and enforcement capacity for complex

cross-border fraud is concerned, the available evidence shows alignment between the

EPPO’s operational focus and serious VAT fraud. The EPPO’s 2024 Annual Report

states that over half (53%) of the overall estimated damage to the EU budget that the

EPPO identified was due to cross-border VAT fraud. At the end of 2025, 67% of overall

estimate damage was caused by revenue fraud (VAT and customs).

As discussed in the study131, the Admiral and Midas cases are examples of actual delivery

on the type of coordination challenge the EPPO was intended to address. Admiral

spanned 22 Member States, non-participating Member States and non-EU countries and

involved an estimated EUR 2.9 billion in damage as well as complex networks across

thousands of entities. Midas involved coordinated operational activity across 17

countries, including large numbers of searches and requests based on Article 31 of the

Regulation. These examples show how the EPPO has improved oversight, coordination

and handling of cross-border investigations into complex fraud patterns. In addition,

stakeholder perception also illustrates the EPPO’s positive impact on investigations and

enforcement. Most respondents stated that they had experienced either a strong positive

impact or a moderate positive impact on investigations and prosecutions of PIF crimes.

Figure 7: The perceived relevance of the EPPO’s establishment to national authorities 132

The need for common investigation and enforcement is evolving in the light of a variety

of factors: the complex nature of cross-border crime; the increasing use of technology by

fraudsters; and the increasing role of organised crime. The EPPO’s Annual Reports

highlight the point that the number of investigations involving PIF-crime-focused

criminal organisations has grown significantly – from 30 in 2021 to 529 in 2025. The

complexity of cross-border and organised crime requires specialised skills and experts

131 Annex 8 to the study, Case Study 3 on VAT fraud. 132 Study, p. 154.

49

(an ‘elite corps of highly specialised financial fraud investigators’ in the wording of the

ECP133). VAT fraud is an example of a crime type becoming more complex because there

has been a shift from the well-known carousel fraud to more sophisticated schemes, such

as e-commerce scams and complicated chains of shell companies.

The supporting study (Annex 9) shows that organised crime networks are using advanced

tools (ranging from encrypted communications to AI) for their cross-border operations.

Digitalisation is a key trend that is increasing the need to combat fraud at the EU level

and therefore requiring the EPPO to adapt to new forms of crime. For instance, one

OLAF stakeholder noted in an interview that fraud patterns and control strategies are

evolving in the e-commerce sector. This is typical of several forms of criminality that

quickly adapt to the developments in society and investigation techniques. On the one

hand, this requires the constant development of in-house digital capabilities and

sufficient analytical support (including by Europol). On the other hand, fraudsters are

also increasingly using digital tools. A stakeholder from an EU agency called this

phenomenon the ‘democratisation of crime’ because the online world has lowered the

barrier to entry to committing a crime and because AI provides an opportunity to commit

further crimes. However, AI may also allow more effective investigations.

To maintain its relevance, the EPPO will have to seize the opportunity to use technology

intensively in its operations. The specific objective of investigating, prosecuting and

bringing to judgement perpetrators of, and accomplices to, PIF crimes must therefore be

adapted to changes in technology-driven crime.

As regards the need for competence management and central steering, the evidence

on the EPPO’s exercise of its right of evocation is relevant because it relates directly to

some gaps that were identified in the impact assessment (including jurisdictional conflict

and lack of ownership). Pursuant to Article 27 of the Regulation, whenever national

authorities inform the EPPO that they have started an investigation into PIF crimes, the

EPPO must decide as soon as possible and within five days whether to exercise its right

of evocation (i.e. whether to take over the case). The Annual Reports up to 2024 note that

Permanent Chambers issued instructions to evoke every year, with the number of such

instructions rising to 22 in 2024134. This is consistent with central steering being used in

practice and confirms the EPPO’s responsiveness because it shows that the EPPO’s

competence management tools were used to bring cases into a coherent framework rather

than leaving them dispersed and potentially deprioritised.

With regard to the need for prevention and deterrence, the evaluation finds that early

signals are available. However, there is limited evidence to permit precise quantification.

The need for prevention was one of the reasons why the EPPO was established. The

impact assessment explicitly linked weak enforcement to a sense of impunity, implying

that a stronger enforcement response should contribute to deterrence. The observed

scaling-up of the investigative and prosecutorial response to PIF crimes, the significant

share of estimated damage associated with cross-border VAT fraud and the systematic

use of competence management tools collectively provide a plausible early signal that

enforcement capacity has been strengthened. One tax authority stakeholder stated that

criminal groups have reacted to the EPPO’s establishment by shifting their focus to taxes

and duties that fall outside the EPPO’s competence. This demonstrates the level of

deterrence connected to the EPPO’s creation, although the EPPO’s establishment may

133 EPPO Annual Report 2022, p. 4. 134 There are no data on the number of evocations in the 2025 Annual Report.

50

also have had the unintended consequence of pushing fraudsters into other forms of fraud

or other locations.

The complexity and volume of funding in the EU changed during the evaluation period,

notably in response to the COVID-19 pandemic. This changing context intensifies the

need to prevent these crimes. The 2025 Annual Report 2025 highlights the point that,

while NextGenerationEU will conclude by the end of 2026, only 50% of funds had been

disbursed by the end of 2025135. The large number of disbursements that are therefore

expected in the remaining year constitute an increased risk of fraud. The EPPO

Regulation’s general objective of contributing to the strengthening of the protection of

the EU’s financial interests therefore remains both relevant and necessary. In addition, in

the light of the changing budgetary context (due not only to NextGenerationEU but also

to the forthcoming MFF), the EPPO’s specific objective of ensuring the independence

and accountability of prosecutions against PIF crimes and gaining/fostering public trust

in them is crucial in order to maintain confidence in the EU. Several stakeholders also

noted the importance of having an independent body investigate PIF crimes, thus setting

a ‘European standard’ for investigations and prosecutions of such crimes.

The available evidence is not sufficient for a full quantification of prevention effects.

However, in a response to the Council questionnaire, one stakeholder noted that the

EPPO’s ‘positive preventive effect’ exceeds expectations 136. In addition, one national

authority stated that the EPPO has also contributed to prevention by signalling the EU’s

intention of countering serious and organised crime. There are also further evidential

limitations that make it difficult to draw conclusions about relevance at this stage. One

key limitation is the lack of complete and comparable baseline data on national criminal

proceedings for PIF offences. As a result, the evaluation can credibly describe

operational scale and the direction of travel (including the rising caseload and increasing

number of cases reaching trial), but it cannot quantify the extent to which any change in

enforcement outcomes is attributable to the EPPO.

The extent to which the EPPO can respond to the original needs depends also on how

well the wider EU AFA supports fully-fledged protection of the EU budget. The recent

ECA Special Report makes five points in this regard. First, it confirms that the EPPO’s

criminal mandate is clearly defined and complementary to OLAF’s administrative one.

Second, it identifies some systemic challenges in reporting and information exchange

that could weaken coordination and follow-up work. In particular, it highlights the

administrative burden created by dual reporting of allegations to both the EPPO and

OLAF. Dual reporting does nevertheless help ensure that both OLAF and the EPPO are

aware of instances where their intervention might be needed. Third, the ECA Special

Report highlights the point that the two offices’ CMS are not interconnected. Fourth, it

highlights an information gap regarding discontinued investigations, observing that the

EPPO informed OLAF of only 5% of its discontinued investigations. Reporting more of

them would probably allow OLAF to apply complementary administrative measures

when criminal proceedings are discontinued, including protective actions and recovery-

oriented steps. Fifth, it notes gaps in monitoring the implementation of recoveries

ordered by national courts following EPPO prosecutions.

135 EUR 241.53 billion out of EUR 357 billion has already been disbursed in grants and EUR 157.57 billion

out of EUR 291 billion has already disbursed in loans (data available here:

https://ec.europa.eu/economy_finance/recovery-and-resilience-scoreboard/disbursements.html). 136 Study, p. 155.

51

These findings do not call into question the EPPO’s responsiveness in line with its

criminal mandate. However, they do illustrate the extent to which the original

enforcement gap can be closed in practice. They also show that measures taken to

address the needs identified at the time of the EPPO’s establishment could be more

effective if the limitations identified by the ECA were resolved at the wider AFA level.

4.3.2. Alignment of the EPPO’s material competence with evolving needs

These is evidence that the EPPO’s material competence and its exercise could be further

clarified in some cases. As noted above, the main issues at stake are the unclear notion of

the ‘focus’ of the activity of a criminal organisation; the EPPO lacking competence over

crimes that affect national direct taxes; and diverging interpretations of the conditions in

which the EPPO can exercise its competence in the case of inextricably linked offences.

The unclarity of the notion of ‘focus’ of the activity of a criminal organisation is

particularly relevant and potentially problematic at a time when cross-border crimes are

becoming more widespread and sophisticated.

Another issue concerns the uncertainties resulting from the threshold of EUR 10 million

above which the EPPO can exercise its competence in cross-border VAT fraud cases.

The EPPO states that some Member States only report VAT fraud cases to it once the

information available to them confirms that the threshold has been met – while other

Member States already report them when they consider that the threshold could

potentially be met. In light of the increasing complexity of these cases (including their

connection to sophisticated criminal networks) the approach to calculation and reporting

should be clarified to avoid situations where Member States do not report cases that

exceed the threshold if the EPPO had the opportunity to connect the dots. Some

stakeholders consulted through the questionnaire circulated by the Council also called for

the threshold to be lowered, but other stakeholders argued that the current threshold

allows the EPPO to focus on the most serious crimes.

A recurring theme in the open-ended responses to the survey concerned extension of the

EPPO’s mandate, especially in five distinct areas: (i) violations of EU restrictive

measures (‘sanctions’); (ii) excise duties; (iii) all customs offences – not just those

currently covered; (iv) high-level corruption; and (v) cybercrime 137. Another response to

the Member State questionnaire disseminated through the Council highlighted the point

that the PIF Directive does not currently address some ‘evolving threats’ (e.g. ‘cyber-

enabled’ crimes and other new crime trends).

4.3.3. Adequacy of the international cooperation framework

The working arrangements with the competent authorities of non-EU countries have been

helpful, but they are not legally binding and may not be adequate in the future,

considering the growing complexity of cross-border crime. Information exchange and the

appointment of liaison officers to the EPPO facilitate cooperation and are usually

regulated in Working Arrangements, but these Arrangements may not adequately keep

pace with ongoing crime trends.

137 The European Parliament has called for the EPPO’s competence to be extended to include cross-border

environmental crime (see, for example, European Parliament resolution of 20 May 2021

(2020/2027(INI))). However, this area was not mentioned in the survey’s replies or in the replies to the

questionnaire circulated via the Council.

52

All the interviewed stakeholders from non-EU countries138 could see a benefit in

cooperating with the EPPO (for example, in speeding up communication and information

exchange). However, they also noted that their interactions with the EPPO have been

limited to date, and were therefore uncertain about how they could improve their

cooperation with the EPPO. One recurring theme was the potential need to formalise

relations. Stakeholders noted that legally binding agreements would be preferable,

particularly for countries receiving EU funds, because the current Working Arrangements

and MoUs are only an ‘expression of goodwill’ (as one third-country liaison prosecutor

phrased it). Another third-country prosecutor who was interviewed warned that, while

they had not yet experienced any difficulties in cooperating with the EPPO, they did

nevertheless expect that challenges might arise in the future due to the non-binding

nature of the Working Arrangements regulating their partnership. In addition to legal

restrictions and uncertainties, there may also be practical limits to the EPPO’s operations.

One EU IBOA stakeholder interviewed doubted the EPPO’s ability to investigate

complex cases in other regions of the world ‘within workable timeframes’ and explained

that they continue to report to OLAF for cases involving non-EU countries.

5. WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED?

5.1. Conclusions

The evaluation finds that the EPPO Regulation has been effective to a very meaningful

extent in establishing and operationalising an EU-level investigative and prosecutorial

framework for PIF crimes. The early operational results are broadly consistent with the

intervention logic. Effectiveness is most apparent in the institutional set-up, operational

activities and strengthened handling of cases, especially cross-border cases. However,

decisive evidence that would allow to measure the broader impact of the EPPO’s

activities, including final judicial outcomes, financial recovery and longer-term impacts

such as deterrence, is only partly available.

On efficiency, there is evidence that the EPPO has generally used its allocated

resources efficiently, despite demand being much greater than originally anticipated.

Compared with the pre-EPPO situation, it has delivered clear efficiency gains in the

handling of PIF crimes (particularly in complex cross-border cases) by centralising intake

of cases, linking information across jurisdictions and coordinating investigations within a

single prosecutorial framework. This positive assessment should be read in the light of

the substantial gap between the assumptions underpinning the 2017 revised LFS and the

operational reality that emerged in practice. The evaluation finds that the EPPO’s

benefits could significantly outweigh its costs and that broader benefits should also be

seen as coming from ‘knock on’ effects such as improvements to deterrence and

enhanced protection of the EU budget.

On coherence, the Regulation is largely coherent in its overall design and intent,

including the establishment of a ‘single office’ model operating through a decentralised

structure. However, coherence remains uneven in practice, largely due to the extensive

reliance of the EPPO and the Regulation on national systems. The identified issues are

linked to divergent national procedural arrangements, including when investigative

judges or other national authorities retain roles that can limit the EPPO’s ability to

exercise its mandate uniformly. These dynamics do not necessarily reflect deficiencies in

the Regulation alone, but they can affect the level of consistency with which the EPPO’s

138 The supporting study team conducted four interviews with stakeholders from third countries.

53

competence is exercised across jurisdictions. The analysis also points to specific legal

and operational issues that shape coherence and effectiveness in practice, such as those

connected with the protection of procedural safeguards for suspects and accused persons,

conflicts of competence and reporting to the EPPO under Article 24(1).

EU added value is substantial, particularly where the EPPO provides capabilities that

would be difficult to replicate through purely national action. Notable examples include

coordinated handling of complex cross-border cases and creating a clearer accountability

chain for prosecution under a common EU mandate. EU added value is most visible in

operational and coordination functions. Longer-term added value linked to outcomes and

impacts requires further time and evidence to be assessed with confidence.

Relevance remains high. The needs and objectives that led to the EPPO’s establishment

remain relevant. Evolving crime patterns (including greater complexity, digitalisation and

a growing international dimension) make it more important to maintain an effective

framework. The evidence also suggests a need for continued adaptation of working

practices and cooperation arrangements in order to remain responsive to these trends.

5.2. Lessons learned

The EPPO has made progress in achieving the objectives for which it was established.

However, a number of areas have been identified where further attention could help

consolidate performance and support more consistent results, without prejudging future

policy choices. The following lessons learned from this retrospective exercise reveal

areas for possible improvement.

• Strengthening the evidence base on outcomes and impacts. A recurring

limitation of this evaluation has been the limited and non-uniform data on

outcome indicators (including final judicial outcomes and confirmed recoveries).

Further work to improve the consistency of outcome reporting and the

comparability of indicators across Member States would strengthen future

assessments and support clearer performance management. The 2025 figures

reported in Tables 1 and 3 above are now a baseline for future evaluations.

• Reducing variability linked to national implementation and procedural

environments. The decentralised model necessarily operates through diverse

national legal and procedural frameworks. The available evidence indicates that

this continues to affect the consistency of implementation across the Member

States and the protection afforded to affected persons. This points to a need not

only for the Member States to continue their operational support to the EPPO but

also for consideration to be given to how to improve competence assessment,

reporting obligations, the protection of procedural safeguards for suspects and

accused persons, as well as more standardised cooperation arrangements and

secure channels for information exchange.

• Addressing recurrent legal clarity and compliance issues. Several issues

identified in the analysis may merit further clarification or practical mitigation in

the longer term. These include uneven compliance with the direct reporting

obligation under Article 24(1). This can create delays, introduce intermediaries,

and potentially affect the EPPO’s ability to exercise its right of evocation

consistently. In addition, the resolution of conflicts of competence between the

EPPO and national prosecuting authorities under Article 25(6) remains regulated

differently across the Member States, with implications for the functioning of the

judicial review framework under Article 267 TFEU and Article 42(2)(c) of the

54

Regulation. Stakeholders also indicate that further clarification of certain aspects

of the EPPO’s material competence under Article 22 and the exercise of this

competence under Article 25 (including concepts such as the ‘focus’ of criminal

activity and ‘inextricably linked offences’) may improve the consistency of

competence determinations and reporting practice.

• Improving efficiency and coherence in cooperation and information

exchange. The EPPO’s cooperation with EU partners is generally well structured

and functioning well. Information exchange between OLAF and the EPPO could

nevertheless be improved. Improvements may also be needed with regard to fraud

reporting obligations, which vary and may result in the duplication of reporting to

– and investigations of – the EPPO and OLAF, and with regard to the manual

nature of the hit/no-hit mechanism. The evaluation suggests that automation and

more reciprocal checks could reduce administrative burden and reduce the risk of

parallel investigations. Cooperation with Eurojust and Europol could also be

enhanced, especially with regard to the hit/no-hit mechanism.

• Raising awareness of the EPPO’s role and strengthening its visibility in non-

EU countries, while also progressively consolidating international

cooperation arrangements as the external dimension of the EPPO’s activities

grows. Stakeholder consultation responses show that Working Arrangements

with third countries have been useful, but their non-binding nature (coupled with

the complexity of the avenues for cooperation under Article 104) may become a

problem as the number of cases linked to non-EU countries increases. A limited

set of interviews with stakeholders indicates that there could be value in making

cooperation frameworks with key partners more formalised and legally secure.

• Streamlining the EPPO’s data protection rules. The expected amendments to

the EUDPR could provide an opportunity to simplify the EPPO’s data protection

rules by removing the stand-alone regime in Chapter VIII of the EPPO

Regulation. This would reduce fragmentation, avoid legal ambiguity (EPPO

Regulation vs national law) and enable better data-sharing between the EPPO and

the relevant national and EU actors, while also preserving the flexibility needed to

accommodate the EPPO’s unique nature.

• Targeted digital improvements, stronger administrative support and more

consistent national operational backing. The EPPO’s CMS remains

cumbersome and insufficiently adapted to operational needs. Administrative

support remains limited relative to workload. Efficiency remains heavily

dependent on uneven national support arrangements (including access to

dedicated investigators, support staff and data systems).

Overall, these areas for improvement should be understood primarily as opportunities to

consolidate an operationally functioning system; strengthen consistency across Member

States; and improve the evidence base for assessing outcomes and impacts over time –

rather than as definitive judgements on long-term performance.

55

ANNEX I: PROCEDURAL INFORMATION

− Directorate-General for Justice and Consumers

− Organisation and timing of the evaluation study on which the Staff Working

Document was mainly based

Tasks Time

First Inter-service Group (ISG) meeting –

discussion of the Call for Evidence

17 July 2024

Second ISG meeting– discussion of the

Terms of Reference for the launch of the

tender

2 October 2024

Signature of the contract 3 June 2025

Kick-off meeting 17 June 2025

Draft Inception Report 8 July 2025

Third ISG meeting 15 July 2025

Final Inception Report 2 September 2025

Submission of the Correlation Tables 23 September 2025

Submission of the Summary National

reports

21 October 2025

Draft interim report 4 November 2025

Fourth ISG meeting 18 November 2025

Final interim report 13 January 2026

Draft Final report 2 February 2026

Fourth ISG meeting 9 February 2026

Final Report, correlation tables, summary

national reports

18 March 2026

Draft SWD 24 April 2026

Sixth ISG 30 April 2026

− Inter-service Group members: Secretariat-General, Legal Service, DG BUDG, DGT,

OLAF, DG HR, DG HOME, DG ENEST, EEAS, DIGIT, DG TAXUD, DG JUST.

Evidence, sources and quality

− The results of this SWD are mainly informed by an evaluation study conducted by an

independent consultant. This evaluation study took place from 3 June 2025 to March

2026 under the guidance of an interservice steering group established by different

services of the European Commission and under the framework contract JUST EC-

JUST/2024/OP/0001 for Evaluation, Impact Assessment and Related Policy Support

Services in the Justice and Consumers Policy Areas.

− The analytical assessment covers the period from the adoption of the EPPO

Regulation, with operational analysis focusing on the period from the start of EPPO

operations on 1 June 2021 to the end of June 2025. Where relevant, the evaluation

considers later developments to better contextualise the study’s findings.

− The evaluation examines developments across the 24 participating Member States

and, where relevant, the three non-participating Member States, as well as

cooperation with EU institutions, bodies, offices and agencies, third countries and

56

relevant international partners. The evaluation covers all EPPO activities in this

timeframe, including establishment, internal workings and external operations.

− The evidence base of this evaluation study consisted of two main components:

analysing available documentation and consulting stakeholders.

− The methodology on gathering of data is described in the annexes below, which also

detail the methodological limitations and its impacts in the evidence collection.

57

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED

This annex sets out the methodology, analytical framework and core analytical tools used

in the evaluation of the implementation and impact of Regulation (EU) 2017/1939, and

of the effectiveness and efficiency of the EPPO and its working practices. It explains

how evidence was gathered, analysed and triangulated, how the evaluation criteria were

operationalised, what limitations affected the evidence base, how uncertainty was

handled, and what steps were taken to assure the quality and robustness of the analytical

results.

Overall methodological approach

The study that supported the evaluation applied a mixed-methods design. This combined

legal and documentary analysis, national legal mapping, qualitative consultation, survey

evidence, quantitative analysis of administrative, financial and operational data, in depth

case-studies, and structured comparative assessment. The evaluation consisted in a

mixed-methods exercise structured around two analytical tools: the intervention logic and

the evaluation matrix.

The mixed-methods design was chosen because the subject of the evaluation is

institutionally complex, legally dense, and operationally heterogeneous across Member

States. No single method or source could provide a sufficiently robust basis for

answering all evaluation questions. Some questions required close legal and institutional

analysis, others required examination of performance data, and others depended on

qualitative insight into the functioning of the EPPO in practice. The overall approach

therefore relied on triangulation across different forms of evidence and on criterion-

specific judgement rather than on a single unified quantitative model.

The methodology was also shaped by the nature of the intervention under evaluation. The

EPPO is a recent and still maturing body operating within a multi-level legal and

institutional environment. Its effects are mediated by national legal frameworks, national

capacities, cross-border cooperation arrangements and the wider EU anti-fraud

architecture.

Analytical framework and analytical models used

Intervention logic

The intervention logic was used to reconstruct the rationale of the EPPO Regulation and

the expected chain of results linking the intervention to the needs it was intended to

address. It described:

•the core problems and needs which led to the creation of the EPPO;

•the legal and institutional mechanisms introduced by the Regulation;

•the expected outputs, results and longer-term effects;

•the assumptions underpinning the chain of change; and

•the external factors likely to influence implementation and outcomes.

The intervention logic supported the evaluation in three ways. First, it provided the

conceptual basis for assessing whether the legal and institutional design of the EPPO was

fit for purpose. Second, it helped distinguish between immediate operational outputs,

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intermediate results and longer-term impacts. Third, it made it possible to assess whether

observed developments were consistent with the original rationale and expected

pathways of change.

Evaluation matrix

The evaluation matrix translated the evaluation questions into a structured framework of

judgement criteria, indicators, data sources and methods. It ensured that each question

under the five evaluation criteria was linked to:

•a clear analytical focus;

•one or more judgement criteria;

•measurable or assessable indicators;

•identified sources of evidence; and

•appropriate analytical techniques.

The matrix was used to guide evidence collection, structure the analysis and ensure

consistency between the evaluation questions, the evidence gathered and the final

findings. It also helped maintain traceability from source material to evaluative

judgement.

Criterion-based analytical assessment

The five standard Better Regulation evaluation criteria: effectiveness, efficiency,

relevance, coherence and EU added value were followed. Each criterion was assessed

using a combination of evidence types and analytical lenses appropriate to the underlying

questions. For example:

• effectiveness relied strongly on implementation evidence, legal mapping,

operational data, consultation evidence and case studies;

• efficiency relied on resource data, workload and activity information, cost-benefit

tables, survey and interview evidence, and comparative assessment of resource

use and outputs;

• relevance relied on analysis of the original problem definition, changing needs,

emerging fraud patterns and current institutional and legal challenges;

• coherence relied on legal and institutional mapping and consultation evidence on

operational interaction with other bodies; and

• EU added value relied on comparative reasoning, state-of-play analysis,

counterfactual reflection and consultation evidence.

The assessment used structured evaluative judgement, grounded in the evaluation matrix

and supported by triangulated evidence.

Triangulation model

Triangulation was a central analytical principle throughout the study that supported the

evaluation. The analysis focused on structured triangulation across sources, considering

the consistency of findings and explanatory factors for variation. In practical terms,

triangulation meant comparing and combining legal and policy documents,

administrative, operational and financial data, national legal mapping outputs, case

studies, written input and consultation evidence, survey evidence, external assessments

and institutional reporting.

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No single source was treated as conclusive on its own where corroborating evidence was

available. Findings were treated as more robust where several sources pointed in the

same direction. They were treated as more tentative where evidence diverged, where a

point rested mainly on one type of source, or where evidence remained narrow or

incomplete. This approach was particularly important in areas where access to internal

EPPO perspectives was constrained.

Evidence collection methods

Desk research and document reviews

Desk research formed a core methodological strand. This included EPPO planning and

reporting documents, relevant EU and national legal and policy materials, internal

documents of the Commission and confidential documents shared by the EPPO for the

attention of the study team, academic literature and other sources required to address the

evaluation questions.

The documentary review was used to:

• establish the legal and institutional baseline;

•identify the intended objectives, functions and architecture of the EPPO;

•reconstruct the wider anti-fraud context;

•support the intervention logic and criterion-specific analysis; and

•identify implementation developments, reported bottlenecks and evolving needs.

The documentary review covered both public and non-public material. Where non-public

documents were used, the report indicates that these were marked as confidential in the

footnotes.

National legal mapping and assessment of implementing measures

National legal mapping was a major methodological component of the study and should

be understood as one of its core analytical building blocks. The national legal mapping

and conformity assessment was done using correlation tables and country reporting, with

detailed material presented in Annexes 6 and 7 of the study supporting the evaluation.

The correlation tables were shared separately. This work was done by the contractor in

collaboration with national legal experts.

This strand of work assessed the completeness and consistency of national transposition

and implementation of the EPPO Regulation, and identified notable divergences,

ambiguities or implementation issues. It was particularly relevant to Objective 1 of the

study, namely examination of whether the EPPO Regulation had been completely and

correctly implemented in the Member States and, where relevant, by the EPPO.

The legal mapping served several analytical functions:

•establishing the state of implementation in each participating Member State;

•identifying differences in legal and institutional arrangements relevant to

operational practice;

•informing the assessment of effectiveness, coherence and relevance; and

•providing a structured basis for later comparative analysis and implementation

checks.

Targeted stakeholder consultations

60

Targeted consultations included 67 semi-structured interviews with stakeholders such

as EPPO leadership and senior management, national authorities and practitioners,

former European Prosecutors, EU institutions and bodies, international organisations,

third countries, and academic and legal experts. It also included written responses from

the EPPO central level, a site visit to the central office in Luxembourg to conduct

discussions with senior EPPO staff, written responses from 17 FIUs facilitated by the

Egmont Group, Council-channel input from 22 Member States, and a survey of

national authorities and practitioners, which received 105 responses. The targeted

consultation served several functions:

•gathering evidence on practical implementation and operational experience;

•identifying perceived strengths, bottlenecks and unintended effects;

•testing the plausibility of explanations derived from documentary and quantitative

evidence; and

•testing the balance and proportionality of emerging findings.

The consultation strategy reached a broad range of stakeholder categories, but not all

intended groups were covered to the same extent (see limitations). This affects the

balance of evidence and is discussed further below.

Survey of national authorities and practitioners

Surveys formed one part of the primary evidence base. The survey of national authorities

and practitioners was disseminated to 198 targeted contacts, with broader dissemination

through the European Judicial Network in criminal matters, Eurofisc and the

Commission’s EU Network against Corruption, and with support from the Jean Monnet

Module entitled ‘EPPO and EU Law: A Step Forward in Integration’ (STEPPO), co-

funded by the European Commission and the University of Milan-Bicocca. The survey

generated 105 responses.

Survey data were used to complement interview evidence, widen the evidence base

geographically and institutionally, and provide a more structured overview of stakeholder

views on selected issues. The survey results were interpreted cautiously. They were not

treated as statistically representative of all relevant stakeholder populations, but as a

structured source of targeted stakeholder evidence.

The original methodology also envisaged surveys of EPPO central and decentralised

staff. As discussed below, these could not be implemented as intended.

Member State questionnaire disseminated through the Council

A structured questionnaire was disseminated through the Council in order to gather

targeted input from participating and non-participating Member States on the

implementation and functioning of the EPPO framework in practice. This instrument was

intended to complement the legal mapping, interviews and survey evidence by capturing

Member State perspectives in a more formalised and comparable format. In total, replies

were received from 24 Member States, comprising 21 participating Member States and

three non-participating Member States. The questionnaire provided useful evidence on

national experiences of cooperation with the EPPO, perceived implementation issues,

and views on operational and institutional strengths and challenges. As with other

consultation tools, the responses were interpreted as targeted stakeholder evidence rather

than as a complete or statistically representative account of Member State views.

Validation workshops

61

Validation workshops were used as a quality-assurance and robustness-checking tool

rather than as a primary means of generating new evidence. Their purpose was to test the

soundness, balance and proportionality of the emerging findings, and to identify whether

any important elements had been omitted, overstated or understated. One workshop was

held to validate the findings of the implementation checks in the 24 participating

Member States, with the participation of the study’s Senior Legal Experts and

Commission representatives from the fields of criminal law and data protection. The

discussions focused in particular on data protection measures, findings relating to

provisions newly covered under this study, and updates since the 2022 compliance

assessment. A separate working session was also scheduled on Poland.

A further workshop was organised with legal and academic experts and practitioners to

test the overall findings of the study supporting the evaluation. The discussion was

organised around four themes that appear across the evaluation criteria analysis, namely:

•material competence;

•operational adequacy of cooperation arrangements;

•systemic design of cooperation; and

•mandate, demand and system constraints.

Call for Evidence

The Call for Evidence submissions were used, where relevant, as contextual inputs

complementing the core evidence base. In total, 10 submissions were received from five

countries, from both private citizens and organisations. These submissions were not

treated as a primary evidence source. Rather, they were used as contextual material,

particularly where they raised issues relevant to the evaluation questions or broader

policy environment.

Case studies

The study supporting the evaluation included four dedicated case studies on material

competence, the EPPO’s working relationship with OLAF, VAT fraud, and cross-

border investigations, presented in Annex 8 of the study supporting the evaluation.

These case studies were developed to test and illustrate findings on specific topics

supporting the broader analysis.

The case studies were not used to generate stand-alone conclusions detached from the

rest of the evidence base. They were interpreted in conjunction with wider documentary,

legal, quantitative and consultation evidence.

Quantitative and comparative analysis

Quantitative analysis formed a distinct methodological strand, even though the study

supporting the evaluation did not rely on a formal econometric or causal model. The

report contains extensive use of budgetary, staffing, activity and outcome data, including

tables on the EPPO’s resources, selected activity indicators, outcomes of the EPPO’s

activities, legislative financial statement estimates, budget evolution, staffing allocation

and benchmarking.

The quantitative analysis drew on:

•EPPO reporting and planning documents;

•annual reports and published activity data;

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•budget and staffing information;

•survey data;

•Member State implementation and operational comparisons; and

•information from external sources where relevant.

This strand of analysis was used to identify and interpret:

•operational trends;

•workload developments;

•resource use;

•selected outputs and early outcomes;

•cross-country differences; and

•relationships between legal design, institutional arrangements and observed

practice.

Comparative analysis was also used. Comparison points included, where possible:

•the original expectations and assumptions reflected in preparatory material and

the impact assessment;

•the pre-operational and early operational state of play;

•differences across participating Member States; and

•where relevant, the position of the EPPO in the wider EU anti-fraud architecture.

The quantitative analysis was primarily descriptive and evaluative rather than predictive.

It supported criterion-based judgements but was not used to infer precise causal effects.

Assessment of costs and benefits under the efficiency criterion

The study that supported the evaluation included a structured assessment of costs and

benefits under the efficiency criterion. The SWD contains a dedicated Annex IV (Cost-

benefit table) and the main body includes an efficiency chapter, with a standalone cost-

effectiveness assessment and budgetary and staffing tables.

It was not possible to provide a full monetised ex-post cost-benefit assessment. Rather,

the assessment involved a structured comparison of identifiable costs and observed or

expected benefits, based on available evidence. The assessment drew on:

•EPPO budget and staffing data;

•legislative financial statement estimates;

•workload and activity data;

•survey and interview evidence on resource adequacy and operational pressure;

•evidence on outputs, selected outcomes and areas of simplification or burden; and

•comparisons with expectations and assumptions in the original impact

assessment, where relevant.

The original impact assessment is relevant in this context because it included cost-benefit

analysis of alternative EPPO models and explicitly discussed the uncertainty associated

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with causal assumptions linking prosecutions, recovery and deterrence. It also presented

cost and benefit estimates for different institutional options.

In the present evaluation, however, the analysis of costs and benefits remained

proportionate to the available evidence and to the limitations of a recent and still

evolving body. The efficiency assessment, therefore, focused on reasoned judgement

regarding resource use, operational pressures, administrative burden, simplification

potential, and the relationship between available resources and observed outputs or

constraints.

State of play and baseline reconstruction

The study supporting the evaluation also included a state-of-play and baseline

reconstruction exercise, presented in Annex 9 to the study supporting the evaluation. The

State of Play Annex covers implementation of the EPPO Regulation, activities and

outcomes, and the external context shaping the EPPO. This analytical step was important

because the evaluation required comparison between:

•the problems and expectations underlying the creation of the EPPO;

•the legal and institutional arrangements established by the Regulation;

•the actual developments observed during the evaluation period; and

•the changing external context, including evolving fraud patterns and changes in

the wider anti-fraud architecture.

The state-of-play exercise helped anchor the analysis of relevance, effectiveness and EU

added value. It also informed counterfactual reflection, especially in relation to questions

about whether Member States could have achieved similar results alone and how the

situation had changed relative to the pre-EPPO context.

Methodological limitations and deviations from the original plan

Access limitations affecting consultation with EPPO staff

The largest methodological challenge concerned limited access to EPPO staff,

particularly at the decentralised level. The original methodology proposed online surveys

targeted to decentralised EPPO staff, including EDPs and National EDP Assistants, and

to central EPPO staff, including the European Chief Prosecutor, the European

Prosecutors and administrative staff. The access to these stakeholder groups for the

purpose of administering the surveys was not provided by the EPPO, except for

interviews and written input from central staff, and the surveys, therefore, could not be

launched as intended.

This affected the breadth and balance of the primary evidence base and reduced the

possibility of triangulating internal EPPO perspectives across a wider range of central

and decentralised staff.

Reduced volume and balance of interviews

The total number of interviews completed was lower than originally planned, largely

because a substantial share of intended interviews with EPPO staff did not take place,

including consultations with at least 48 decentralised staff and at least 26 central staff.

Evidence on internal functioning, therefore, came mainly from central EPPO leadership

and senior management. This has direct implications for findings concerning internal

governance, internal procedures, internal efficiency, and the operational experience of

European Delegated Prosecutors and their assistants.

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Limited access to former EPPO actors

Attempts were made to consult former European Prosecutors and former EDPs, but

beyond two interviews with former European Prosecutors no further interviews were

secured. This further narrowed the range of reflective and retrospective perspectives

available on institutional design, governance and early implementation.

Incomplete implementation of planned focus groups and additional follow-up

The original design included at least two focus groups, but access constraints required

adjustment of the envisaged approach. Focus group discussions were indeed originally

envisaged as a complementary consultation method to gather operational insight that

could not readily be captured through interviews, surveys or documentary review,

particularly in light of the limited access to EPPO staff at central and decentralised

levels. The initial design foresaw a small number of online focus groups involving

practitioners from selected national contexts, in order to explore the practical experience

of the EPPO’s added value, its impact on national case handling, and the interaction

between EPPO operations and national investigative and prosecutorial structures.

However, despite outreach to potential participants, no positive responses for

engagement were received, and the focus groups did not take place. This gap was partly

mitigated through interviews, survey responses, Member State questionnaire replies and

case-study analysis.

Data and timing limitations

The evaluation also faced more general limitations linked to the relatively short

operational life of the EPPO, differences across national contexts, and the maturity of

outcome data. Some outcomes of interest, particularly court outcomes, recovery and

longer-term deterrence effects, are inherently lagged. This limited the possibility of

drawing firm conclusions on some longer-term effects.

In addition, not all relevant data were equally comparable across sources or across

Member States. Administrative and reported data were nevertheless used wherever

appropriate, in line with Better Regulation guidance encouraging the reuse of available

administrative data and efforts to draw on both qualitative and quantitative sources.

Mitigation measures

In response to these limitations, mitigation measures were applied. Contingency actions

were integrated into the methodological approach and used where possible to strengthen

the evidence base and support triangulation. Consultations were expanded with other

stakeholders, particularly EU institutions, bodies, offices and agencies, and national

authorities and practitioners, and that more than 20 interviews were conducted with EU

IBOAs and 53 inputs were received from national authorities and practitioners through

interviews, written input and Council-channel responses. More broadly, mitigation relied

on:

•widening consultation with external and national stakeholder;

•making fuller use of documentary and legal evidence;

•using national legal mapping and case studies as additional analytical support;

•relying on structured triangulation rather than single-source findings; and

•qualifying findings more carefully where the evidence base was narrower.

65

Where planned methods could not be implemented, the analysis was adapted rather than

forcing unsupported conclusions.

Uncertainty and robustness of analytical results

Uncertainty in the analytical results arose primarily from five sources:

•the relatively short operational period of the EPPO;

•limited access to decentralised EPPO perspectives;

•uneven stakeholder coverage across categories;

•varying national legal and institutional contexts; and

•incomplete or only partially mature data on longer-term outcomes.

These uncertainties affected some parts of the evaluation more than others. They were

particularly relevant to questions concerning internal governance, internal procedures,

operational pressures at the decentralised level, and the medium-term and long-term

effects of EPPO action.

Uncertainty was addressed in four ways. First, the study supporting the evaluation used

structured triangulation to compare evidence from legal, documentary, quantitative and

consultation sources. Second, it differentiated between stronger and weaker findings

depending on the breadth and consistency of the supporting evidence. Third, it avoided

over-precise claims or strong causal assertions where evidence did not support them.

Fourth, it distinguished clearly between established observations, stakeholder perceptions

and evaluative interpretation.

The study supporting the evaluation did not use a formal causal or econometric model to

attribute observed developments exclusively to the EPPO Regulation. Such an approach

would not have been proportionated or robust in light of the available evidence, the short

observation window, and the interaction of the EPPO with wider institutional and

national factors. Instead, the study supporting the evaluation relied on reasoned

evaluative judgement supported by triangulated evidence and structured

comparison.

Overall, the study supporting the evaluation rests on a broad and mixed evidence base

combining legal analysis, documentary review, national implementation mapping,

consultation evidence, surveys, case studies, quantitative analysis and comparative

assessment.

The evidence base is strongest in relation to:

•legal and institutional design;

•implementation mapping across Member States;

•broad operational developments;

•interaction with the wider anti-fraud architecture; and

•selected aspects of relevance, coherence and the EU added value.

It is weaker, and conclusions should therefore be interpreted with greater caution, in

relation to:

•internal functioning at the decentralised EPPO level;

•operational experience of EDPs and their assistants;

66

•some aspects of internal efficiency and governance; and

•longer-term outcomes such as deterrence and full recovery effects.

This differentiated assessment of reliability is important. Although there is a sufficiently

robust basis for evaluative judgement across all five criteria, not all findings carry the

same degree of certainty. Where the evidence base was narrower or more mixed, this has

been reflected in more cautious and qualified conclusions.

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ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION)

Evaluation matrix

This Annex presents the evaluation matrix that has guided the assessment of each evaluation question within the study. The matrix details:

•the overarching evaluation questions (highlighted in grey) and related sub-questions;

•the criteria against which evidence-based judgements will be made on each question/sub-question (i.e. what information do we need to know to make

a judgement on the evaluation question);

•examples of qualitative and quantitative indicators that will inform the responses to the evaluation questions; and

•the data sources and research methods proposed to capture the data necessary to fill the indicators and provide information for the judgement criteria.

It covers the evaluation criteria of effectiveness, efficiency, relevance, coherence and EU added value.

Effectiveness

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

EQ1: To what extent has progress

been made towards achieving the

objectives of the EPPO considering

the expectations and the working

arrangements included on the

Regulation?

• Progress has been made towards

achieving the general objective of the

EPPO Regulation, the resulting

activities/working practices and the

expected effects / causal mechanisms.

• Progress has been made towards

achieving the specific and activity-

based objectives outlined in the EPPO

Multi-annual work programmes and

the Single Programming Documents,

the resulting activities/working

practices and the expected effects /

causal mechanisms.

• Number and type of programming

documents produced

• All output and result KPI listed in

the EPPO’s SPD, by objective and

action area

• Number of investigations conducted,

amounts of money temporarily

seized pending trial, and the

effectiveness of the cooperation

among members of the EPPO

working in different Member States

• Number of prosecutions/convictions

for offences affecting the Union’s

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

studies on the functioning of the

EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, such as EU

Commission, OLAF and JHA

Agencies, national competent

authorities and national

prosecutors)

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Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

• The objectives of the EPPO Regulation

have been achieved– i.e. positive

effects (outputs, results, impacts) – and

related explanatory factors (i.e. why

and how, causal mechanisms,

attribution139).

• The challenges / negative effects of the

EPPO Regulation and related

explanatory factors.

financial interest handed down by

national courts, disaggregated by

year

• Amount of EU budget recovered,

disaggregated by year and by

management type (direct, indirect or

shared management)

• Stakeholder perceptions on issues

such as: quality of investigations

conducted; the nature and impact of

internal and external factors

influencing the achievement of

effects; level of expertise within the

EPPO

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Case studies

• Implementation check

EQ1.1: To what extent have the

EPPO’s activities and operations

contributed to achieving the overall

EU’s policy objective and priority

of fighting crime against the Union’s

financial interests?

• The EPPO’s activities have contributed

to achieving the overall EU’s policy

objective and priority of fighting crime

against the Union’s financial interests

• The EPPO’s activities that aim to have

an effect on fighting crime against the

Union’s financial interests have the

expected effects

• Assessment of the wider context of

interventions that aim to affect overall

EU policy objectives and priorities

(e.g. work of JHA agencies)

• The achievements of the EPPO’s

activities – i.e. positive effects

(outputs, results, impacts) – with

regard to overall EU policy objectives

• As above, indicators from the Multi-

annual work programmes, SPD

related to the achievement of overall

EU policy objectives and priorities,

e.g. number of investigations

conducted, amounts of money

temporarily seized pending trial, and

the effectiveness of the cooperation

among members of the EPPO

working in different Member States,

• Number of prosecutions /

convictions for offences affecting

the Union’s financial interest handed

down by national courts,

disaggregated by year

• Impact indicators related to the scale

and magnitude of offences affecting

• Document review (e.g. the EPPO’s

programming documents, and other

outputs, EU policy documents and

reporting etc.

• Targeted consultations

- with external stakeholders (EU

IBOAs, such as EU

Commission, OLAF and JHA

Agencies, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

139 It will be necessary to assess how and why the provisions of the EPPO Regulation and EPPO activities were expected to cause and caused in practice the identified and observed effects (outputs, results, impacts). These are known as the ‘causal mechanisms’ or ‘causal logic’. In

this context, it will also be necessary to assess to what extent the effects can be attributed to the EPPO Regulation and EPPO activities (attribution).

69

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

and priorities and related explanatory

factors (i.e. why and how, causal

mechanisms, attributions)

• The challenges / negative effects of the

EPPO’s activities with regard to the

overall EU policy objectives and

priorities, and related explanatory

factors

• Effects and challenges in the years

prior to the Regulation, where relevant.

• Comparison of the balance of

achievements / challenges against the

overall EU policy objectives / priorities

and effects baseline

the Union’s financial interests

• Stakeholder perceptions on the level

of the EPPO’s contribution to the

high-level objectives; and on other

contributing factors

• Case studies

• Implementation check

EQ1.2: To what extent do the rules on

the material competence of the

EPPO allow or prevent the Office

from fulfilling its mission?

• The rules on the material competence

are in line with the Office’s mission

• The Offices’ material competence

allows the EPPO to fulfil its mission

• There are no issues relating to the

EPPO material competence

• Limitations to the material competence

of the EPPO (i.e. the way to which the

EPPO may exercise its competence) do

not prevent it from fulfilling its

mission

• The EPPO’s KPIs related to its

material competence

• Stakeholder perceptions on the

extent to which the rules on the

material competence of the EPPO

allow it or prevent it from fulfilling

its mission

• Document review (e.g. the EPPO’s

programming documents, and other

outputs, EU policy documents and

reporting etc.

• Targeted consultations

- with external stakeholders (EU

IBOAs, such as EU Commission,

OLAF and JHA Agencies,

national competent authorities and

national prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Case studies

• Implementation check

EQ1.3: How effective is the

cooperation and information

exchange between the EPPO and

• The cooperation and information

exchange between the EPPO and the

national competent authorities is

• The EPPO’s KPIs related to

cooperation and information

exchange between the EPPO and

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

70

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

the national competent authorities

and to what extent has the cooperation

and information exchange required by

the establishment of the EPPO led to

improvements in overall

coordination?

effective

• The cooperation and information

exchange required by the establishment

of the EPPO are in place

• The cooperation and information

exchange is effective

national competent authorities

• Evidence that cooperation and

information exchange required by

the establishment of the EPPO are in

place

• Evidence that the cooperation and

information exchange has led to

improvements in overall

coordination

• Evidence that the cooperation and

information exchange has increased

the overall response to financial

crime affecting the Union budget

• Stakeholder perceptions on the

extent to which the cooperation and

information exchange between the

EPPO and national competent

authorities has been effective

• Stakeholder perceptions on the

extent to which the cooperation and

information exchange required by

the establishment of the EPPO led to

improvements in overall

coordination

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Case studies

• Implementation check

EQ1.4: Were adequate procedures

put in place – and if so, to what extent

– to ensure consistent investigation

and prosecution of PIF crimes

across the participating EU Member

States, thus ensuring that similar

cases in different Member States

are duly investigated by the EPPO?

Were there cases where similar

investigations led to prosecutions in

• Procedures are in place to ensure

consistent investigation and

prosecution of PIF crimes

• Differences in procedures do not result

in similar cases in different Member

States being investigated by the EPPO

or not

• Regardless of the procedures, similar

investigations in different Member

States are investigated by the EPPO

• Number / type of procedures in place

to ensure consistent investigation

and prosecution of PIF crimes across

the participating EU Member States

• Stakeholder perception whether the

procedures in place ensure consistent

investigation and prosecution of PIF

crimes across the participating EU

Member States

• Number / type of cases where

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

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Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

one Member State but not in another,

even where the evidence-base was

adequate in both situations?

• These cases led to prosecutions, in all

Member States where they took place

similar investigations led to

prosecutions in one Member State

but not in another, even where the

evidence-base was adequate in both

situations

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

•

EQ1.5: To what extent has the EPPO

managed, in practice, to direct

investigations and prosecutions in

the Member States, and ensure

effective coordination of its cross-

border investigations and

prosecutions?

• The EPPO managed to direct

investigations and prosecutions in the

participating Member States

• The EPPO managed to ensure effective

coordination of its cross-border

investigations

• The EPPO managed to ensure effective

coordination of its cross-border

prosecutions

• Number of investigations and

prosecutions in the participating

Member States directed by the EPPO

• Number of cases of conflict of

jurisdiction

• Stakeholder perceptions on the

extent to which the EPPO has

managed to direct investigations and

prosecutions in the Member States

• Stakeholder perceptions on the

extent to which the EPPO has

ensured effective coordination of its

cross-border investigations

• Stakeholder perceptions on the

extent to which the EPPO has

ensured effective coordination of its

cross-border prosecutions

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

EQ1.6: To what extent have the

differences in the national

implementation of the PIF Directive

had an impact on the EPPO’s ability

to prevent fraud to the Union’s

financial interest?

• There are no differences in the national

implementation of the PIF Directive

• If differences exist, they have no

impact on the EPPO’s ability to

prevent fraud to the Union’s financial

interest

• Number / type of differences in the

national implementation of the PIF

Directive across Member States

• Stakeholder perception on the extent

to which existing differences have an

impact on the EPPO’s ability to

prevent fraud to the Union’s

financial interest

• Document review (e.g. the PIF

Directive Implementation Reports, the

EPPO’s programming documents,

legal documents and other outputs,

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

72

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Case studies

• Implementation check

EQ1.7: To what extent can the

system of shared competence

between the EPPO and the national

authorities in combating crimes

affecting the Union’s financial

interests, based e.g. on the right of

evocation of the EPPO, be considered

to be adequate?

• The system of shared competence

between the EPPO and the national

authorities is clearly defined

• The system of shared competence is

working as intended

• The system of shared competence

between the EPPO and the national

authorities is effective.

• Definition of shared competence

between the EPPO and national

authorities

• The EPPO’s activities that aim to

contribute to the shared competence

with the national authorities

• Degree if alignment between the

EPPO’s activities related to shared

competence, as per the EPPO

Regulation and in practice (including

any changes over the

implementation period)

• Output and result PKPIs listed in the

EPPO’s SPW/AWP and Activity

Reports

• Challenges / negative effects related

to the shared competence between

the EPPO and national authorities

• Stakeholder perceptions on the

extent to which the system of shared

competence between the EPPO and

the national authorities in combating

crimes affecting the Union’s

financial interests a) is clearly

defined; b) is working as intended;

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Case studies

• Implementation check

73

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

c) is effective.

EQ1.8: How effective have the

EPPO’s governance structure (in

particular the division of tasks

between the European Chief

Prosecutor, the College, and the

Permanent Chambers) and working

practices been in enabling the EPPO

to fulfil its mission?

• The structure, tasks and functions of

the different components of the EPPO

(in particular the division of tasks

between the European Chief

Prosecutor, the College, and the

Permanent Chambers) as set out in the

EPPO Regulation are having the

expected effects.

• Assessment of the practical

implementation of the governance

structure and working practices, and

changes over the implementation

period.

• Comparison of the regulatory and

practical situations.

• Comparison of working practices

against other EU JHA bodies.

• The contribution of the EPPO’s

governance structure and working

practices to the implementation of its

activities and, ultimately, their effects

(including attribution and causal

mechanisms).

• Assessment of explanatory factors and

wider context affecting the

implementation of the EPPO’s

activities and the related effects.

• Comparison of the effects achieved

against the expected effects (baseline).

• Degree of alignment between the

EPPO Regulation and the

implemented governance structure

and working practices

• Stakeholder perceptions on the

effectiveness of the governance

structure and working practices in

enabling the EPPO to fulfil its

mission

• Output and result KPIs listed in

EPPO’s SPD, by objective

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Implementation check

EQ1.9: How effective is the

cooperation between the EPPO and

the EU institutions, bodies, offices

and agencies in the investigation of

• The EPPO’s work has been

implemented in a way that ensures

close cooperation between the EPPO

and the EU institutions, bodies, offices

• Type / number of cooperation and

information exchanges with Eurojust

(Article 100)

• Type / number of cooperation and

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

74

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

PIF offences, the recovery of funds

and application of administrative

measures?

and agencies in the investigation of PIF

offences

• The EPPO’s work has been

implemented in a way that ensures

close cooperation between the EPPO

and the EU institutions, bodies, offices

and agencies in the recovery of funds

• The EPPO’s work has been

implemented in a way that ensures

close cooperation between the EPPO

and the EU institutions, bodies, offices

and agencies in the application of

administrative measures

information exchanges with OLAF

(Article 101)

• Type / number of cooperation and

information exchanges with Europol

(Article 102)

• Type / number of cooperation and

information exchanges with other

EU institutions, bodies, offices and

agencies (Article 103)

• Number of working arrangements

between the EPPO and EU

institutions, bodies, offices and

agencies, as per Article 99 EPPO

Regulation

• Stakeholder perceptions on the

effectiveness of the cooperation

between the EPPO and the EU

institutions, bodies, offices and

agencies in (i) the investigation of

PIF offences; (ii) the recovery of

funds; and (iii) application of

administrative measures

• Stakeholder perceptions on how the

cooperation could be improved in

the future

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Case studies

• Implementation check

EQ1.10: How effective is the

cooperation with the competent

authorities of non-participating

Member States, enlargement

countries and other third countries,

as well as with international

organisations? Do the rules on the

representation of the EPPO in the

international fora enable the EPPO to

• The cooperation with the competent

authorities of non-participating

Member States is effective

• The cooperation with the competent

authorities of enlargement countries is

effective

• The cooperation with the competent

authorities of other third countries is

effective

• Type / number of working

arrangements between the EPPO and

authorities of non-participating

Member States, enlargement

countries and other third countries

and international organisations, as

per Articles 99(3), 104(1) and 105(1)

EPPO Regulation

• Number of secondments of liaison

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

75

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

effectively fulfil its statutory mission? • The cooperation with the competent

authorities of international

organisations is effective

• The rules on the representation of the

EPPO in the international fora enable it

to effectively fulfil its statutory mission

officer to the EPPO

• Number of EPPO contact points in

non-participating Member States,

enlargement countries and other

third countries

• Number of international agreements

concluded by the Union in areas that

fall under the EPPO’s competence

• Evidence of cooperation in cases

where an international agreement is

not in place

• Number of cases where the EPPO

requested legal assistance in criminal

matters from authorities of

enlargement countries and other

third countries (as per Article 104(5)

EPPO Regulation)

• Number of information transfers

from the EPPO to the competent

authorities of enlargement countries

and other third countries or

international organisations (as per

Article 104(6) EPPO Regulation)

• Number of extraditions of a person

requested by the EDP to the

competent authority of his/her MS in

accordance with applicable treaties

and/or national law (Art. 104(7)

EPPO Regulation)

• Number of instances that

participating MS notified the EPPO

as a competent authority in the

absence of a legal instrument

relating to cooperation in criminal

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

• Case studies

76

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

matters and surrender between the

EPPO and the competent authorities

of the non-participating Member

States (Art. 105(3) EPPO

Regulation)

EQ1.11: To what extent have the

EPPO’s activities and operations

led to a higher number of reports,

investigations, and prosecutions of

PIF crimes, including large scale

cross-border offences such as VAT

carousel fraud?

• Reports, investigations, and

prosecutions of VAT carousel fraud

have increased

• Reports, investigations, and

prosecutions of corruption have

increased

• Reports, investigations, and

prosecutions of money laundering have

increased

• Reports, investigations, and

prosecutions of misappropriation have

increased

• The increase in these can be attributed

to the EPPO’s activities and

operations.

• Number of reports, investigations

and prosecutions of PIF crimes

(including large scale cross-border

offences) that can be attributed to the

EPPO’s activities and operations

• Stakeholder perceptions on the

extent to which EPPO’s activities

have led to a higher number of

reports, investigations, and

prosecutions of PIF crimes

• Document review (e.g. the EPPO’s

programming documents, legal

documents and other outputs,

academic commentary and other

studies on the functioning and impact

of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

EQ1.12: To what extent have the

prosecutions carried out by the

EPPO led to a higher number of

indictments and convictions for PIF

offences in participating Member

States compared to the number of

prior national indictments and

convictions?

• Indictments and convictions for PIF

offences stemming from investigations

and prosecutions carried out by the

EPPO have increased in participating

Member States

• The increase in indictments and

convictions for PIF offences are

correlated to EPPO cases.

• Number of indictments and

convictions for PIF offences in

participating Member States carried

out by the EPPO

• Number of prior national

indictments and convictions

• Stakeholder perceptions on the

extent to which the prosecutions

carried out by the EPPO led to a

higher number of indictments and

convictions for PIF offences in

participating Member States

compared to the number of prior

• Document review (e.g. the EPPO’s

programming documents, AWP and

Annual Reports, legal documents and

other outputs, academic commentary

and other studies on the functioning

and impact of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

77

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

national indictments and convictions Administrative Director)

• Online surveys

EQ1.13: To what extent have the

amounts seized, confiscated, and

recovered increased both in the

participating Member States and the

Union?

• The amounts seized, confiscated, and

recovered have increased (per

participating Member State)

• The amounts seized, confiscated, and

recovered have increased (overall)

• The amounts seized, confiscated, and

recovered have increased

(disaggregated by management type

(direct, indirect, shared))

• Amounts seized, confiscated and

recovered per participating Member

States, in the Union overall, and

disaggregated by management type

(direct, indirect, shared)

• Stakeholder perceptions on the

amounts seized, confiscated and

recovered

• Document review (e.g. the EPPO’s

programming documents, AWP and

Annual Reports, legal documents and

other outputs, academic commentary

and other studies on the functioning

and impact of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

EQ1.14: To what extent have the

EPPO’s investigations and

prosecutions and their judicial

outcome contributed to a better

protection of the Union’s financial

interest and had any impact on

relevant crime trends?

• The EPPO’s investigations,

prosecutions and judicial outcomes

have contributed to a better protection

of the Union’s financial interest

• The EPPO’s investigations,

prosecutions and judicial outcomes

have had a (positive) impact on

relevant crime trends

• Objectives, activities and expected

effects (and causal mechanisms) of

the EPPO to contribute to a better

protection of the Union’s financial

interest

• Achievements and challenges of the

EPPO’s investigations and

prosecutions and their judicial

outcome

• Type of implications on relevant

crime trends

• Stakeholder perceptions on the

extent to which the EPPO’s

investigations and prosecutions and

their judicial outcome contributed to

a better protection of the Union’s

financial interest

• Document review (e.g. the EPPO’s

programming documents, AWP and

Annual Reports, legal documents and

other outputs, academic commentary

and other studies on the functioning

and impact of the EPPO, etc.)

• Targeted consultations

- with external stakeholders (EU

IBOAs, national competent

authorities and national

prosecutors)

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director)

• Online surveys

78

Evaluation questions Judgement criteria Examples of indicators Data sources / research methods

• Stakeholder perceptions on the

extent to which they had any impact

on relevant crime trends

Efficiency

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

EQ2: To what extent has the EPPO

fulfilled its objectives at the lowest

costs?

• Cost-effectiveness of the EPPO’s

activities and operations in relation

to its objectives.

• Caseloads are processed timely and

efficiently.

• Assessment of efficiency in

financial and human resource

allocation, considering workload,

staffing levels, and resource

prioritisation.

• Identification of areas, activities

and operations where additional

financial investment and/or human

resource enhancement are needed.

Identification of associated

challenges (e.g. low ability to detect

PIF crime; insufficient know-how

of national investigators, lack of

specialised police investigators and

financial data analysts).

• Assessment of the EPPO’s

governance structures,

organisational set-up and work

processes, including an analysis

their efficiency and administrative

burden.

• Identification of areas for potential

• Overall budget execution rate (% of

committed and spent budget vs.

allocated budget).

• Amount of EU budget recovered as a

result of EPPO prosecution.

• Cost-effectiveness ratios (e.g. cost per

investigation, prosecution and/or value

of assets frozen in the EPPO’s

investigations, amount recovered per

investigation, amount recovered per

number of investigations opened, etc.).

• Time taken for case allocation,

procedural delays due to potential

governance complexity.

• Efficiency of resource use

(caseload/number of ongoing and

closed investigations and number of

indictments per staff member,

proportion of budget spent on

operational activities).

• Number of reallocations of financial

resources between budget lines and

associated justifications (e.g.

reallocations from administrative to

operational expenditures).

• Savings achieved through

digitalisation, procedural

• Meta-analysis of the efficiency sub-

questions as well as findings of the

effectiveness assessment and relevant

indicators/descriptors.

• Review of relevant documents

concerning the EPPO.

• Consultations with EPPO internal and

external stakeholders.

• Case studies (e.g. examining EPPO’s

cooperation with OLAF, and with

national authorities, or examining

specific cost-intensive activities, such as

ICT infrastructure projects, incl. the

EPPO’s Case Management System

(CMS) and the IT Autonomy

Programme).

• Implementation check – resource

analysis.

79

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

cost reduction, simplification and

administrative burden reduction,

without compromising operational

effectiveness.

simplification, and inter-agency

cooperation.

• Staff efficiency metrics (staff vacancy

rates, workload per staff member,

impact of understaffing on

investigations).

• Audit findings on inefficiencies and

challenges with financial management.

• Stakeholder perceptions of

inefficiencies and areas for

improvement in the EPPO’s work

processes.

• Additional output, result and impact

indicators as listed below.

EQ2.1: To what extent has the EPPO

used the resources allocated to it by

the budgetary authority efficiently to

attain its objectives?

• Objectives of the EPPO,

implemented through its activities

and operations, have been achieved

using the available inputs.

• There is positive cost-effectiveness

compared to planned targets and

KPIs.

• Findings of the implementation

check, resources assessment, and

effectiveness assessment indicate

that the EPPO has used its

resources effectively (e.g. regarding

to what extent have the EPPO’s

investigations and prosecutions and

their judicial outcome contributed

to a better protection of the Union’s

financial interest).

• Resource have been allocated

efficiently, through identification of

priority activities/budget lines

• Output, result and impact indicators as

listed above (EQ1 and EQ2).

• Total budget of the EPPO, by year and

by budget line title (Title 1: Staff

expenditure, Title 2: Infrastructure and

operating expenditure, and Title 3:

Operational expenditure), as per MFF

programming (Working Documents III

accompanying the Commission’s draft

annual EU budgets), including

amended and actual expenditure.

• Rate of budget execution (as reported

in the Annual Reports and

Consolidated Annual Reports and the

EPPO’s Reports on the budgetary and

financial management).

• Proportion of budget implementation,

compared to SPD target.

• Rate of outturn, compared to SPD

target.

• Document review:

- EU legislation and policy

documentation (e.g. Regulation (EU)

2017/1939, Directive (EU)

2017/1371, and Commission and

Council Decisions);

- EPPO administrative / operational

documentation (e.g. annual reports,

CAARs, SPDs, financial reports;

ECA audit reports, Rules of

Procedure, relevant College

Decisions, Annual assessments of

the EPPOs internal control system,

EPPO-wide Staff Survey results);

- EPPO Regulation Impact

Assessment;

- European Parliament’s Discharge

Reports on the EPPO’s budget

implementation; Working

Documents III accompanying the

80

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

• Challenges were identified related

to the resourcing and resource

allocation, including capacity of

spending available resources

(careful inspection of human and

financial requests made by the

EPPO to the Budgetary Authority

along with the Commission’s

assessment of these requests, which

are available in Working

Documents III accompanying the

Commission’s draft annual EU

budgets).

• Staff vacancy rate, by year, compared

to the SPD target.

• Number and proportion of statutory

and non-statutory staff, by type (e.g.

temporary, contract, SNE, Central

Office statutory staff, European

Delegated Prosecutors).

• New investigations, and

active/ongoing cases and investigations

opened in the past, by crime type, by

year. Share of VAT fraud

investigations and investigations with a

cross-border dimension.

• Caseload to staff ratio, by year.

• Number of closed cases, to staff ratio,

by year.

• Number of indictments filed by the

EPPO, by crime type, by year.

• Asset frozen and/or confiscated during

investigations, by year.

• Impacts of internal and external

factors.

• Investments made in the core ICT

infrastructure).

• Audit findings related to reliability of

annual accounts (results of audits

conducted by the Internal Audit

Service (IAS), the Internal Audit

Capability (IAC), and the European

Court of Auditors (ECA)).

• Stakeholder perceptions on the

efficiency of budget allocation

between areas and activities

Commission’s draft annual EU

budgets;

- Quantitative data from the EPPO’s

CMS.

- National level legal research:

identifying relevant national

laws/practices under Article 38.

• Targeted consultations:

- Interviews with internal (e.g. College

members, Administrative Director,

Operations Unit, IT, Security and

Corporate Services unit, Human

Resources unit, national support

staff, Senior Coordinator on Fight

against Organised Crime) and

external stakeholders (EU

institutions including EU

Commission, in particular DG JUST,

DG BUDG, DG DIGIT and DG HR,

and JHA Agencies, national

competent authorities and national

prosecutors as well as relevant legal

practitioners);

- Online surveys.

• Case studies (e.g. examining specific

cost-intensive activities, such as ICT

infrastructure projects incl. the EPPO’s

Case Management System (CMS), IT

Autonomy Programme).

• Implementation check – resource

analysis.

EQ2.2: Which areas, if any, can be • There are examples of cost- • Instances of reengineering of • Document review:

81

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

identified where the EPPO’s activities

and operations turned out to be too

expensive or deliver too few benefits

compared to the costs incurred?

intensive activities/budget lines (for

instance ICT infrastructure

projects) that may not provide

proportional benefits in terms of the

EPPO’s core objectives.

• There are areas where final

expenditure exceeded initial

estimates or where expenditure was

inefficient due to delays and other

challenges caused by internal and

external factors.

• There was the necessity to make

budgetary adjustments or

reallocations to face budgetary

challenges.

• The findings from audit reports and

internal control assessment

indicates that some activities and

operations were too expensive or

delivered too few benefits

compared to the costs.

procedures to reduce administrative

burden (as reported in CAARs).

• Number (and size) of budgetary

adjustments per year (and trend over

the years),

• Cost-benefit ratios for core EPPO

activities and operations (if possible).

• Expenditure growth in areas where

costs were expected to stabilise.

• Cancellation rates of payment

appropriations (these may be as a

result of overestimation or

inefficiencies in spending).

• Budget reallocations between budget

lines.

• Results of audit reports and internal

control assessments.

• Comparison of planned vs. actual

commitment appropriations by budget

line (by analysing information in

Working Documents III accompanying

the Commission’s proposals for the

draft annual EU budgets, which report

on draft budget as well as executed

budget in the past).

- EPPO administrative / operational

documentation (e.g. annual reports,

CAARs, SPDs, Reports on

Budgetary and Financial

management; ECA audit reports,

audit reports from the Internal Audit

Service (IAS) and Internal Audit

Capability (IAC), relevant College

Decisions, Annual assessments of

the EPPO’s internal control system,

EPPO-wide Staff Survey results);

European Parliament’s Discharge

Reports on the EPPO’s budget

implementation; Working

Documents III accompanying the

Commission’s proposals for the draft

annual EU budgets.

• Targeted consultations:

- Interviews with internal (e.g. College

members, Administrative Director,

Operations Unit, IT, Security and

Corporate Services unit, Human

Resources unit, national support

staff, Senior Coordinator on Fight

against Organised Crime) and

external stakeholders (EU

institutions including EU

Commission, in particular DG JUST,

DG BUDG, DG DIGIT and DG HR,

and JHA Agencies, national

competent authorities and national

prosecutors);

- Online surveys.

• Case studies (e.g. examining specific

82

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

cost-intensive activities, such as ICT

infrastructure projects, incl. the EPPO’s

Case Management System (CMS), IT

Autonomy Programme).

• Implementation check – resource

analysis.

EQ2.3: Which are the areas (processes,

governance, cooperation arrangements,

IT services, etc), if any, where there is

potential for simplification and costs

savings, and why?

• There is potential for burden

reduction, cost reduction or

simplification with the EPPO

activities, processes and systems

without compromising the quality

of outputs (e.g. building on those

identified in the Extension Study of

the Compliance assessment of

measures adopted by the Member

States to adapt their systems to

Council Regulation (EU)

2017/1939 of 12 October 2017

implementing enhanced

cooperation on the establishment of

the EPPO).

• National legal/procedural

mechanisms for charging costs to

offenders are identified and

assessed.

• There are challenges related to

simplification and burden reduction

within the EPPO.

• There are costs and other negative

effects associated with the

inefficiencies identified that hamper

the efficiency and effectiveness of

the EPPO.

• IT automation and digital

• Indicators on efficient resource use, as

detailed above.

• Output and result KPIs listed in the

EPPO’s SPDs, as detailed above.

• Administrative burden reduction

measures (as reported in CAARs).

• Number of MS where procedural costs

are charged to offenders.

• Description of identified mechanisms

for charging procedural costs to

offenders (e.g., legal basis, types of

costs).

• Assessment of applicability and

practical implications of such

mechanisms for EPPO cases/cost

• Number and progress with

implementation of digitalisation

initiatives and IT automation projects

aimed at improving efficiency (e.g. the

EPPO’s Case Management System

(CMS), IT Autonomy Programme).

• Number of inefficiencies or

opportunities for simplification, cost or

burden reduction identified, by type of

area or activity.

• Stakeholder perceptions on the nature

and scale of inefficiencies identified,

as well as the nature and scale of any

• Document review:

- EPPO administrative / operational

documentation (e.g. annual reports,

CAARs, SPDs, Reports on

Budgetary and Financial

management; ECA audit reports,

relevant College Decisions, Annual

assessments of the EPPOs internal

control system, EPPO-wide Staff

Survey results);

- Extension Study of the Compliance

assessment of measures adopted by

the Member States to adapt their

systems to Council Regulation (EU)

2017/1939 of 12 October 2017

implementing enhanced cooperation

on the establishment of the EPPO;

- European Parliament’s Discharge

Reports on the EPPO’s budget

implementation; Working

Documents III accompanying the

Commission’s proposals for the draft

annual EU budgets.

• Targeted consultations:

- Interviews with internal EPPO

stakeholders (e.g. College members,

Administrative Director, Operations

Unit, IT, Security and Corporate

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

transformation initiatives aimed at

reducing costs and improving

efficiency have been successful.

• Inter-institutional cooperation and

procurement have an impact on

costs reduction.

potential simplification measures.

• Stakeholder perceptions (EDPs,

national authorities, defence lawyers)

on the potential impact of such

mechanisms on EPPO's

budget/operations.

Services unit, Human Resources

unit, national support staff, Senior

Coordinator on Fight against

Organised Crime);

- Online surveys.

• Case studies.

• Implementation check – resource

analysis.

EQ2.4: How efficient are the EPPO’s

working practices both from the

operational point of view and from the

organisational set-up?

• The EPPO’s operational and

administrative activities are

conducted in a timely manner and

to a high degree of quality,

compared to what is expected.

• Efficiency challenges and actions

taken to address them exist (e.g. use

of ICT tools; use of inter-

institutional procurement

procedures or Service Level

Agreements with EU IBOAs; or

introduction of a process-based

control framework).

• Review of human resource

allocation and progress in

establishing mid-term human

resources strategic planning, aimed

at improving the fulfilment of the

establishment plan.

• Assessment of whether the

Permanent Chambers are provided

with effective administrative, legal

and policy support.

• Review of resources provided for

the decentralised level of the EPPO.

• Specific actions taken to enhance

• Qualitative perceptions of the EPPO’s

staff and operational partners on the

quality and timeliness of the delivery

of EPPO operational activities.

• Qualitative perceptions of the EPPO’s

staff on the quality and timeliness of

EPPO administrative activities.

• Number and type of efficiency

challenges identified (including those

reported in the EPPO’s risk register +

assessment of the adequacy of risk

registers vs real occurrences). Actions

taken to improve the efficiency of

working practices, by type, by year –

e.g. ICT projects initiated.

• Progress with the implementation of:

The IT Autonomy Programme, aimed

at offering a full catalogue of

administrative IT services internally,

and the CMS Programme, to support

digitalisation in core business

operations.

• Number of staff recruited and

redeployed according to needs.

• Number and proportion of staff that

report being ‘engaged’ or ‘satisfied’

• Document review:

- EU legislation and policy

documentation (e.g. Regulation (EU)

2017/1939, Directive (EU)

2017/1371, and Commission and

Council Decisions);

- EPPO administrative / operational

documentation (e.g. annual reports,

CAARs, SPDs, financial reports;

ECA audit reports, Rules of

Procedure, relevant College

Decisions, Annual assessments of

the EPPO’s internal control system,

EPPO-wide Staff Survey results;

Data and information recorded in the

EPPO’s risk register); EPPO

Regulation Impact Assessment;

European Parliament’s Discharge

Reports on the EPPO’s budget

implementation; Working

Documents III accompanying the

Commission’s draft annual EU

budgets.

• Targeted consultations:

- Interviews with internal (e.g. College

members, Administrative Director,

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

cross-border cooperation between

the Central Office and the

decentralised offices.

• Assessment of the practical

implementation of the functions of

centralised and decentralised level

of the EPPO, and changes over the

implementation period.

• Comparison of the regulatory and

practical situation.

• Assessment of the use IT and

communication capabilities to

support the EPPO’s operational and

strategic goals (e.g. progress with

the implementation of the EPPO’s

two ongoing programmes: 1) the IT

Autonomy Programme, to offer a

complete catalogue of

administrative IT services fully

managed internally, and 2) the Case

Management System (CMS)

Programme, to further develop the

digitalisation of the organisation in

its core business area).

with the EPPO’s working practices and

internal communication.

Operations Unit, IT, Security and

Corporate Services unit, Human

Resources unit, national support

staff, Senior Coordinator on Fight

against Organised Crime) and

external stakeholders (EU

institutions including EU

Commission, in particular DG JUST,

DG BUDG, DG DIGIT and DG HR,

OLAF and JHA Agencies, national

competent authorities and national

prosecutors);

- Online surveys.

• Case studies.

• Focus groups (EDPs/EPs, national

practitioners).

• Implementation check – resource

analysis.

EQ2.5: To what extent has the

expected cooperation and

sharing/allocation of resources

between the EPPO and the Member

States contributed to efficient

investigations by the EPPO?

• The findings of the effectiveness

assessment (e.g. regarding

cooperation and information

exchange between the EPPO and

the national competent authorities).

• Resource-sharing and allocation

arrangements between the EPPO

and the MSs (both participating and

non-participating in the

establishment of the EPPO) have an

• Challenges reported in cooperation

mechanisms.

• Number of joint-training initiatives,

courses, and instances academic

cooperation (including a traineeship

schemes). Resources allocated to these

initiatives (both financial and human).

• Data on crime reports received from

national authorities.

• Data on cross-border investigations,

• Document review:

- EPPO administrative / operational

documentation (e.g. annual reports,

CAARs, SPDs, financial reports;

ECA audit reports, Rules of

Procedure, relevant EPPO College

Decisions, EPPO-wide Staff Survey

results);

- EPPO Regulation Impact

Assessment.

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

impact on case resolution times,

effectiveness, and prosecution rates.

• Cooperation and (including

cooperation and on security

matters) shared resources have

facilitated EPPO investigations.

rate of prosecutions and data on the

number of persons indicted.

• Resource allocation efficiency in terms

of caseload per European Delegated

Prosecutor.

• Value of assets frozen and seized in the

EPPO’s cross-border investigations.

• Value of EU budget recovered in

EPPO’s cross-border investigations

• Stakeholder perceptions of cooperation

effectiveness.

• Targeted consultations:

- Interviews with internal (e.g. College

members, Administrative Director,

Operations Unit, IT, Security and

Corporate Services unit, Human

Resources unit, Senior Coordinator

on Fight against Organised Crime)

and external stakeholders (national

competent authorities and national

prosecutors);

- Online surveys.

• Case studies (e.g. examining the

potential benefits of the EPPO for

participating Member States and the

EPPO’s cooperation with national

authorities in complex cross-border

investigations).

• Focus groups (EDPs/EPs, national

practitioners).

• Implementation check – resource

analysis.

EQ2.6: To what extent has the EPPO

managed to streamline procedures in

its cooperation with the Commission

and other EU institutions, bodies

offices and agencies, in particular

OLAF, Eurojust and Europol, thereby

enhancing the protection of the

Union’s financial interests and

strengthening the Union’s anti-fraud

architecture?

• Agreed actions stemming from

working arrangement concluded

with EPPO partners have been

timely implemented.

• The findings of the effectiveness

and coherence assessments in the

area of cooperation and policy

work.

• Cooperation with EPPO partners

favoured the elimination of

procedural redundancies and

avoidance of parallel investigations.

• Inter-agency cooperation led to

• Data on key meetings/decisions

involving the Commission and other

EU institutions, bodies, offices and

agencies, in particular Europol, OLAF

and Eurojust.

• Number of information exchanges with

OLAF (e.g. replies to hit/no-hit

requests in order to avoid parallel

investigations into the same facts).

• Number of requests upon which

OLAF, Eurojust, Europol etc. provided

support.

• Number of inter-institutional

• Document review:

- EPPO administrative / operational

documentation (e.g. annual reports,

CAARs, SPDs, financial reports,

Rules of Procedure, relevant EPPO

College Decisions, EPPO-wide Staff

Survey results);

- EPPO Regulation Impact

Assessment.

• Targeted consultations:

- Interviews with internal (e.g. College

members, Administrative Director,

Operations Unit, IT, Security and

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

better protection of the EU’s

financial interests (e.g. through

recovery of EU budget).

procurement procedures or Service

Level Agreements with EU IBOAs.

• Value of EU budget recovered thanks

to EPPO actions in cooperation with

other EU agencies.

• Actions agreed in working

arrangements with other agencies

implemented, by type. Data on actions

implemented within agreed timelines.

• Stakeholder perceptions of the EPPO’s

cooperation with the Commission and

other EU institutions, bodies offices

and agencies.

Corporate Services unit, Senior

Coordinator on Fight against

Organised Crime) and external

stakeholders (EU institutions

including EU Commission, European

Financial and Economic Crime

Centre (EFECC), OLAF, Eurojust,

Europol, members of EPPO-Europol

Steering Committee);

- Online surveys.

• Case studies (e.g. examining the EPPO’s

cooperation with OLAF in large-scale

VAT or customs fraud cases).

Relevance

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

EQ3: How well do the objectives of

the EPPO Regulation correspond to

the evolving needs within the EU and

among the stakeholders? Is any

adaptation necessary in the light of

evolving needs?

• The objectives of the EPPO

Regulation were aligned to the

needs and problems identified

within the EU and among relevant

stakeholders at the time of

adoption.

• The objectives of the EPPO

Regulation were aligned to

Article 86 TFEU and the general

objectives of the EU area of

freedom, security and justice.

• The objectives of the EPPO

Regulation still correspond to the

needs and problems within the EU

and among relevant stakeholders

today.

• Identification of problems / needs

when the Regulation was adopted /

today that were not (fully or partially)

considered by the EPPO, its legislative

and operational framework.

• Stakeholder perception on the extent to

which the objectives of the EPPO

Regulation correspond to the needs /

problems within the EU and among

stakeholders (at the time of adoption /

today).

• Meta-analysis of the sub-questions and

relevant indicators/descriptors.

• Review of relevant documents at the

EU level.

• Review of relevant documents

concerning the EPPO.

• Targeted consultations with the EPPO

internal stakeholders.

• Targeted consultations with EPPO

external stakeholders.

• Targeted consultations with the

Commission, EU IBOAs.

• Case studies (e.g. examining the EPPO’s

material competence and adequacy of the

provisions included in the Regulation).

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

EQ3.1: How well has the EPPO been

able to respond to the needs for which

it was established?

• Needs assessments were undertaken

with the EPPO stakeholders before

the adoption of the Regulation.

• The EPPO’s objectives were and

still are aligned to (internal and

external) stakeholders’ needs.

• The EPPO’s activities and tasks

were designed and implemented to

meet the needs of its stakeholders.

• Presence of areas of activity or tasks

where the relevance of the EPPO is

limited according to stakeholders’

perception.

• Reference in EPPO documents (in

particular programming documents) to

priorities identified at the EU level.

• Changes in the priorities identified in

the EPPO Programming documents

since 2021.

• Stakeholder perception on the extent to

which the EPPO through its activities

and tasks has been able to respond to

their needs since its establishment.

• Presence of different views among

EPPO stakeholders regarding its

relevance to their needs.

• Review of relevant documents

concerning the EPPO (including the IA

of the EPPO Regulation, single

programming documents, annual reports,

College decisions, rules of procedures,

etc.).

• Consultations with the EPPO internal

stakeholders (College members,

Administrative Director, Operations Unit,

national support staff).

• Consultations with EPPO external

stakeholders (EU institutions including

EU Commission, OLAF and JHA

Agencies, national competent authorities

and national prosecutors).

EQ3.2: To what extent are these needs

evolving or likely to evolve in future,

taking also into account the evolution

of cross-border criminality in the EU,

the EU’s overall anti-fraud architecture

as well as broader trends such as

digitalisation; if they are not evolving

or likely to evolve, why?

• Needs assessments are updated

whenever there are relevant

contextual changes.

• The EPPO’s strategic objectives set

out in its multiannual work

programmes were aligned with

emerging needs of the EU, the

organisation and its stakeholders as

they evolved during the years.

• Changes in the EPPO’s activities

and tasks were made to respond to

the changing/emerging needs of the

organisation and its stakeholders.

• The EPPO developed strategies and

actions to address horizontal trends

such as digitalisation.

• The type/complexity and crime

• Type of changes occurred in the EU

context since the entry into force of the

Regulation.

• Type of changes occurred in the EPPO

objectives, priorities and tasks since

the entry into force of the Regulation.

• Percentage of internal and external

stakeholders reporting a change in their

needs/priorities since the establishment

of the EPPO.

• Level of correspondence between the

changes identified and the EPPO

objectives, priorities and tasks.

• Number and type of actions

(e.g. guidelines, cooperation efforts,

projects, networks, activities, tools,

etc.) implemented or participated by

• Review of relevant EU documents

(including policy and legislative

documents, strategies, studies and reports

in the area of justice and related to PIF

crimes).

• Review of relevant documents

concerning the EPPO (including single

programming documents, annual reports,

College decisions, rules of procedures,

etc.).

• Consultations with the EPPO internal

stakeholders (College members,

Administrative Director, Operations Unit,

national support staff)

• Consultations with EPPO external

stakeholders (EU institutions including

EU Commission, OLAF and JHA

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

areas of the cases dealt with by the

EPPO has changed since its

establishment.

the EPPO to align its objectives and/or

tasks to emerging needs and changing

context.

• Type of new, emerging needs and

priorities in the EU context we are

likely to affect the work and

responsibilities of the EPPO.

• Trend in the number of cases dealt

with by the EPPO per crime area.

• Reference in EPPO documents to new

priorities identified at the EU level.

• Stakeholder perception on the type of

actions needed by the EPPO to address

emerging trends and evolving needs.

Agencies, national competent authorities

and national prosecutors)

EQ3.3: In particular, to what extent is

the existing material competence

scope of the EPPO aligned with the

evolving needs within the EU

especially with regard to addressing

complex cross-border crimes?

• EPPO’s competence scope is still

adequate and aligned to the needs

within the EU.

• The objectives, competences and

functions outlined in the EPPO

Regulation are still relevant.

• There are changes in the nature,

type and complexity of cross-

border crimes that require a change

in the material competence scope of

the EPPO.

• Type of new, emerging needs and

priorities in the EU context we are

likely to affect the work and

responsibilities of the EPPO.

• Number of instances where an

interference or conflict with others’

competence was identified.

• Number and type of priority areas

identified in the fight against cross-

border crimes at the EU level currently

outside the competence scope of the

EPPO.

• Stakeholder perception regarding

necessary changes in the material

competence of the EPPO to better deal

with cross-border crimes and the

protection of the EU financial interests.

• Stakeholder perception on difficulties

related to the division of competences

between the EPPO and the other

• Review of relevant EU documents

(including policy and legislative

documents, strategies, studies and reports

in the area of justice and related to PIF

crimes).

• Consultations with the EPPO internal

stakeholders (College members,

Administrative Director, Operations Unit,

national support staff).

• Consultations with EPPO external

stakeholders (EU institutions including

EU Commission, OLAF and JHA

Agencies, national competent authorities

and national prosecutors).

• Case studies (e.g. examining the EPPO’s

material competence and adequacy of the

provisions included in the Regulation).

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

relevant components of the EU anti-

fraud architecture.

EQ3.4: How well does the system

envisaged in the EPPO Regulation

for cooperation on the international

level correspond to the actual needs of

the EPPO, especially with regard to

the cooperation with third States and

international organisations?

• The definition of the cooperation

provisions in the Regulation does

not raise any issues of interpretation

or clarity and it is aligned with the

needs of the EPPO.

• The possibilities foreseen by the

Regulation in terms of cross-border

cooperation (especially with third

countries and international

organisations) are adequate to meet

the needs of the EPPO.

• The objectives and requirements in

terms of cooperation are feasible to

implement vis-à-vis the EPPO’s

resources, capacities and legal

framework.

• Number and type of problems raised

by the EPPO in implementing cross-

border cooperation actions.

• Number and type of actions

implemented or participated by the

EPPO to enhance/improve cooperation

with partners, in particular third States

and international organisations.

• Number of working arrangements

concluded with Third Countries’

authorities.

• Number of organisations and networks

where the EPPO is a member/observer.

• Stakeholder perception on the level of

adequacy of the provisions of the

Regulation on EPPO cooperation with

Third Countries and international

organisations.

• Stakeholder perception on the level of

adequacy of the actions implemented

by the EPPO to cooperate on the

international level.

• Review of relevant EU documents

(including policy and legislative

documents, strategies, studies and reports

in the area of justice and related to PIF

crimes).

• Consultations with the EPPO internal

stakeholders (College members,

Administrative Director, Operations Unit,

national support staff).

• Consultations with EPPO external

stakeholders (EU institutions including

EU Commission, national authorities in

third countries, representatives from

international institutions with

international agreements or where the

EPPO is a member/observer).

Coherence

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

EQ4: Internal Coherence: How well

do the different provisions of the

EPPO Regulation operate together

to achieve its objectives?

• The EPPO’s tasks and

responsibilities are clearly defined.

• The internal governance structure

(European Chief Prosecutor,

College, Permanent Chambers,

• Stakeholder perceptions (e.g. EPPO

prosecutors, legal experts) on whether

the mandate is sufficiently clear.

• Evidence of discrepancies,

ambiguities or conflicts in the

• Targeted consultation (European Chief

Prosecutor, Deputy European Chief

Prosecutors, Senior Coordinator in the

Fight against Organised Crime,

European Prosecutors, European

90

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

European Delegated Prosecutors)

functions with clear roles and

responsibilities.

• The EPPO has a coherent process

for handling investigations and

prosecutions.

• The EPPO’s powers are effectively

aligned with national legal

frameworks.

wording of the Regulation.

• Number and nature of internal

conflicts or inefficiencies reported in

cooperation.

• Stakeholder feedback on whether

coordination works smoothly, as well

as instances of procedural

inefficiencies.

• Evidence of legal or procedural

barriers in specific Member States.

Delegated Prosecutors, Legal Service,

Operations and College Support Unit,

Case Analysts, Financial Investigators,

DG JUST).

• Desk research (the EPPO Regulation,

internal rules of procedure, annual

reports, working arrangements and

academic literature).

• Implementation assessment.

• Case studies (e.g.examining how

different EPPO levels coordinate

investigations across multiple Member

States).

EQ5: External Coherence: In how

far are EPPO’s tasks clearly

defined? What overlaps e.g. with

other actors, or gaps or

inconsistencies can be identified?

How well does the existing legal

framework, including existing

instruments such as working

arrangements, clarify the

cooperation among the different

actors? To what extent does the

EPPO Regulation facilitate the

cooperation between the EPPO and

other actors?

• The EPPO’s mandate is clearly

defined and distinct from other EU

and international bodies to avoid

unnecessary overlaps or gaps.

• The EPPO has structured

mechanisms for seamless

cooperation with OLAF, Eurojust,

Europol, and other JHA actors.

• The foreseen cooperation between

the EPPO and AMLA is clearly

defined.

• The EPPO can cooperate with non-

participating Member States

through alternative legal channels.

• The EPPO has functional legal and

operational mechanisms to

cooperate with third countries and

international bodies.

• The EPPO’s role in financial crime

investigations is complementary to

that of the European Court of

Auditors (ECA) and other

• Existence of clear legal provisions

defining EPPO’s scope, powers, and

responsibilities.

• Comparison of EPPO’s mandate with

OLAF, Eurojust, Europol, and

national authorities to identify

overlaps or gaps.

• Stakeholder perceptions on the

EPPO’s mandate.

• Number of cases where legal conflicts

between EPPO and national

authorities led to delays or

complications.

• Evidence of legal barriers at the

national level.

• Targeted consultation (European Chief

Prosecutor, European Deputy Chief

Prosecutors, Legal Service, Senior

Coordinator in the Fight against

Organised Crime, European Prosecutors,

European Delegated Prosecutors,

Strategy and Executive Unit, Operations

and College Support Unit, OLAF,

Eurojust, Europol, AMLA, DG JUST,

DG HOME, DG BUDG, European

Parliament, ECA, National Authorities,

National Authorities in Non-

Participating Member States, National

Authorities in Third Countries).

• Desk research (the EPPO Regulation,

internal rules of procedure, annual

reports, working arrangements, the

Regulations on Eurojust, Europol and

OLAF, European Parliament studies, and

other relevant EU agencies and ECA

Reports).

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

financial oversight bodies. • Implementation assessment.

EQ5.1: To what extent is the EPPO’s

mandate coherent with that of the

Justice and Home Affairs and anti-

fraud agencies and bodies and the

anti-fraud architecture of the EU, in

particular OLAF?

• The EPPO’s mandate aligns with

the objectives and functions of

Justice and Home Affairs (JHA)

agencies and EU anti-fraud

institutions, particularly OLAF,

ensuring clear complementarities

in their roles.

• There are structured mechanisms

to facilitate effective operational

coordination and information

exchange between the EPPO and

relevant bodies.

• The investigation and prosecution

procedures of the EPPO are

coherent with those of OLAF,

Europol, and Eurojust, ensuring

jurisdictional clarity and

procedural consistency.

• The foreseen cooperation between

EPPO and AMLA is clearly

outlined.

• The EPPO’s role is clearly

distinguished from that of other

agencies, preventing unnecessary

duplication of efforts and ensuring

an efficient division of tasks.

• The Hit/No-Hit system’s ability to

prevent parallel or redundant

investigations.

• Degree of overlap or complementarity

in mandates, roles, and legal

frameworks.

• References to the EPPO in the

strategy documents of OLAF,

Europol, Eurojust, and other relevant

JHA agencies and bodies.

• Feedback from stakeholders on the

relationship between the EPPO and

JHA agencies and bodies.

• Awareness of stakeholders of how to

approach a situation involving a

potentially conflicting mandate.

• Feedback from stakeholders on the

information-sharing mechanisms

between the EPPO and other agencies.

• Number of reports of gaps and

conflicts in mandates between the

EPPO and the other JHA agencies and

bodies.

• Number of joint investigations and

operations involving the EPPO and

other agencies.

• Number of reports of criminal

conduct issued by OLAF to the

EPPO.

• Number of cases where the EPPO

requested OLAF’s support in

investigations.

• Number of matches on the Hit/No-Hit

system.

• Number of duplicated or overlapping

investigations conducted by the EPPO

• Targeted consultation (Deputy

European Chief Prosecutors, Senior

Coordinator in the Fight against

Organised Crime, European Prosecutors,

Legal Service, Operations and Support

Unit, IT, Security and Corporate

Services Unit, OLAF, Eurojust, Europol,

AMLA, DG JUST, Independent

Experts).

• Desk research (the EPPO Regulation,

Regulations on Europol, Eurojust, and

OLAF, working arrangements, internal

rules of procedure, annual reports,

Commission reports, ECA reports).

• Case studies (e.g.examining EPPO’s

cooperation with OLAF in large-scale

VAT or customs fraud cases).

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

and other JHA agencies and bodies.

EQ5.2: To what extent does the EPPO

Regulation facilitate appropriate

cooperation with the EU Institutions

with which it has working

arrangements, specifically the

Commission?

• The EPPO Regulation provides a

clear legal framework that

facilitates appropriate cooperation

between the EPPO and EU

institutions with which it has

working agreements.

• The existing working

arrangements between the EPPO

and relevant EU Institutions

effectively support operational and

strategic cooperation.

• The information-sharing and

communication mechanisms

between the EPPO and EU

Institutions function without

problems.

• The EPPO’s collaboration with EU

Institutions leads to concrete

actions, such as improved fraud

detection, case referrals, and

policy developments.

• Clarity and specificity of the

provisions on cooperation in the

EPPO Regulation and working

arrangements.

• Stakeholder perceptions of whether

the legal framework and working

arrangements sufficiently support

cooperation.

• Stakeholder perceptions of

effectiveness in communication and

data exchange.

• Number of fraud cases referred to

EPPO by EU Institutions.

• Targeted consultation (Deputy

European Chief Prosecutor, Senior

Coordinator in the Fight against

Organised Crime, Legal Service,

Operations and Support Unit, DG JUST,

DG HOME, DG BUDG, OLAF).

• Desk research (the EPPO Regulation,

working arrangements, annual reports

and anti-fraud strategy reports).

EQ5.3: To what extent does the EPPO

Regulation facilitate appropriate

cooperation between the EPPO and

national authorities? Are there any

legal barriers that hinder cooperation?

Does Article 25(6) provide an adequate

mechanism for resolving conflicts of

competence?

• The EPPO Regulation establishes

clear and effective provisions for

cooperation between the EPPO

and national authorities, ensuring

smooth collaboration in

investigations and prosecutions.

• The legal framework enables

timely and efficient information

exchange, joint investigations, and

operational support between the

EPPO and national authorities

without unnecessary

• Presence of clear legal provisions in

the EPPO Regulation defining

cooperation with national authorities

(e.g. Article 24 of the Regulation).

• Clear division of roles and

responsibilities in working

arrangements between the EPPO and

national authorities.

• Extent of the delays with national

authorities responding to requests.

• Feedback from stakeholders showing

a clear division of roles and

• Targeted consultation (Deputy

European Chief Prosecutors, European

Prosecutors, European Delegated

Prosecutors, Senior Coordinator in the

Fight against Organised Crime,

Operations and College Support Unit,

Legal Service, Case Analysts, Financial

Investigators, National Authorities,

Eurojust).

• Desk research (the EPPO Regulation,

working arrangements and annual

reports).

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Evaluation question Judgement criteria Examples of indicators Data sources / research methods

administrative burdens.

• The national authorities have a

clear understanding of their roles

and responsibilities in relation to

the EPPO.

• There are no significant legal

barriers exist that obstruct

cooperation between the EPPO

and national authorities, and any

challenges identified are addressed

through legal clarifications or

procedural adjustments.

• Article 25(6) of the EPPO

Regulation provides an adequate

and effective mechanism for

resolving conflicts of competence

between the EPPO and national

authorities.

responsibilities.

• Number of cases in each Member

State – investigation, prosecution, and

convictions.

• Number of conflicts of competences

between the EPPO and national

authorities, including the number

successfully / not successfully

resolved.

• Implementation assessment.

• Case studies (e.g. examining the

EPPO’s cooperation with national

authorities in complex cross-border

cases).

EQ5.4: To what extent do the

Member States not participating in

the EPPO (i.e. Denmark, Hungary,

Ireland) create potential gaps in

investigations and prosecutions?

• The quality of the cooperation on

cross-border investigations and

prosecutions of crimes affecting

the EU’s financial interests.

• The impact on the cooperation and

information exchange between the

EPPO and national authorities in

those countries.

• The successful use of existing

cooperation mechanisms

(e.g. OLAF, Eurojust, mutual legal

assistance) to mitigate the impact

of non-participation.

• There are no delays and/or

complications due to jurisdictional

limitations in non-participating

• Gaps in cross-border investigations

and prosecutions of crimes affecting

the EU’s financial interests.

• Number of cases where the EPPO’s

jurisdictional limitations led to

difficulties in investigations.

• Number of requests for information or

assistance from the EPPO to non-

participating Member States and their

response rates.

• Stakeholder perceptions of the impact

of non-participation.

• Average time taken for non-

participating states to respond to

EPPO-related requests.

• Number of cases where OLAF,

• Targeted consultation (Deputy

European Chief Prosecutors, European

Prosecutors, European Delegated

Prosecutors, Senior Coordinator in the

Fight against Organised Crime,

Operations and College Support Unit,

Legal Service, Case Analysts, Financial

Investigators, National Authorities in

Non-Participating Member States,

OLAF, Eurojust, DG JUST).

• Desk research (the EPPO Regulation,

working arrangements and press

releases).

94

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

Member States.

• The national authorities in non-

participating Member States

cooperate with the EPPO, despite

not being part of its jurisdiction.

Eurojust, or mutual legal assistance

effectively facilitated cooperation.

• Opinions of stakeholders on whether

existing cooperation mechanisms

effectively facilitate cooperation with

non-participating Member States.

• Existence of working arrangements

between the EPPO and non-

participating Member States.

EQ5.5: How does the EPPO’s

cooperation with the European

Court of Auditors (ECA), and other

financial oversight bodies contribute to

a coherent anti-fraud strategy?

• The cooperation between the

EPPO and the European Court of

Auditors (ECA) and other

financial oversight bodies

contributes effectively to the EU’s

anti-fraud strategy.

• The information exchange and

coordination between the EPPO,

ECA, and other financial oversight

bodies enhance the detection and

investigation of fraud affecting the

EU’s financial interests.

• The existing legal and operational

framework facilitates smooth

collaboration between the EPPO

and financial oversight bodies,

with clear procedures and

responsibilities.

• The cooperation mechanisms

between the EPPO and financial

oversight bodies prevent

duplication of efforts and ensure a

complementary approach to fraud

detection and enforcement.

• Presence of working arrangements

between the EPPO and financial

oversight bodies.

• Clear division of roles and

responsibilities for cooperation in the

working arrangements between the

EPPO and financial oversight bodies.

• Cases where financial oversight

bodies’ audits led to EPPO

investigations.

• Existence of clear guidelines for

interaction.

• Stakeholder assessments of whether

cooperation is positive and helpful.

• Number of fraud cases referred by

ECA and financial oversight bodies to

EPPO.

• Targeted consultation (Deputy

European Chief Prosecutors, Senior

Coordinator in the Fight against

Organised Crime, Legal Service,

Operations and College Support Unit,

ECA, DG JUST, DG BUDG).

• Desk research (the EPPO Regulation,

working arrangements and ECA

reports).

EQ5.6: To what extent is the EPPO’s • The EPPO’s legal framework • Presence of legal obstacles preventing • Targeted consultations (European

95

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

cooperation with third countries and

international organisations legally

and operationally coherent? How well

do existing mutual legal assistance

treaties (MLATs) and cooperation

arrangements facilitate EPPO’s work

in non-EU jurisdictions?

allows for cooperation with third

countries.

• The operational cooperation

between the EPPO and other third-

country authorities results in the

timely and efficient exchanges of

information, evidence, and legal

assistance.

• The existing MLATs and

cooperation agreements provide

adequate legal mechanisms for

EPPO to request and receive

assistance from third countries

without unnecessary delays or

obstacles.

• The EPPO’s interactions with

international organisations

(e.g. UNODC, OECD, FATF) and

third-country law enforcement

agencies align with international

legal standards.

• The absence of direct cooperation

agreements with certain third

countries does not create

significant legal or operational

gaps in the EPPO’s ability to

investigate and prosecute

transnational financial crimes.

direct cooperation with certain

jurisdictions.

• Alignment of EPPO’s cooperation

mechanisms with EU and

international legal frameworks.

• Number of cases where EPPO

successfully obtained evidence or

cooperation from enlargement

countries and other third countries.

• Stakeholder perceptions of the

cooperation in practice.

• Number of requests for legal

assistance processed successfully vs

rejected/delayed.

• Number of formal collaborations,

joint initiatives, or information

exchanges between EPPO and

international bodies.

• EPPO’s alignment with international

anti-corruption and anti-money

laundering frameworks.

• Number of cases where lack of a

cooperation agreement with a third

country hindered investigations.

Deputy Chief Prosecutor, European

Prosecutors, European Delegated

Prosecutors, Senior Coordinator in the

Fight against Organised Crime, Legal

Service, Operations and Support Unit,

Enlargement countries and other Third-

Country National Authorities, OECD,

FATF).

• Desk research (the EPPO Regulation,

working arrangements, annual reports,

MLATs, the UNODC and FATF

Conventions and OECD reports).

EQ6: External Coherence: To what

extent is the EPPO’s data protection

regime aligned with Regulation (EU)

2018/1725 (EUDPR) and other

relevant instruments of the EU data

• The EPPO’s data protection

framework is aligned with

Regulation (EU) 2018/1725

(EUDPR) and other relevant EU

data protection instruments.

• The EPPO has clear internal

• Degree of alignment between the

EPPO’s data protection rules and

EUDPR requirements.

• Official reports or legal assessments

on the EPPO’s adherence to EU data

protection law.

• Targeted consultation (Deputy

European Chief Prosecutors, Legal

Service, DPO, Operations and College

Support Unit, National Daya Protection

Authorities, EDPS, DG JUST, individual

Experts).

96

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

protection acquis? procedures and mechanisms to

ensure compliance with EU data

protection rules in handling,

storing, and sharing personal data.

• The cooperation between the

EPPO and external actors

(e.g. OLAF, Europol, Eurojust,

national authorities) ensures that

data sharing respects EU data

protection standards.

• The EPPO’s data protection

regime effectively integrates

oversight mechanisms, including

the role of the European Data

Protection Supervisor (EDPS) and

internal Data Protection Officers

(DPOs).

• The EPPO’s operational practices,

including data retention, security

measures, and access controls, are

aligned with EU data protection

requirements.

• The wording of agreements on data

sharing between the EPPO and other

EU/International actors.

• Stakeholder feedback on the balance

between data protection and

operational efficiency.

• Stakeholders’ perception on the

alignment of the EPPO’s data

protection regime with EUDPR and

other EU data protection instruments.

• Frequency and outcomes of EDPS

reviews, inspections, or

recommendations concerning the

EPPO.

• Stakeholder confidence in EPPO’s

cybersecurity and data protection

safeguards.

• Number of complaints, legal

challenges, or concerns raised by

individuals or institutions regarding

EPPO’s data handling.

• Examples of data protection-related

issues.

• Desk research (EPPO Regulation,

Internal Guidance Documents, EUDPR,

GDPR, Law Enforcement Directive,

Charter of Fundamental Rights of the

European Union, EDPS Decisions and

Reports).

EQ6.1: How do the data protection

rules of the EPPO Regulation and

national legislation interact? Is it clear

whether the national or EU data

protection regime applies? More

specifically, is it clear which EU data

protection instrument applies?

• The legal framework defines the

interaction between the EPPO

Regulation’s data protection

provisions and national data

protection laws.

• There is guidance on whether EU

or national data protection laws

apply in specific situations, such as

investigations, data sharing, and

cross-border cooperation.

• It is established which EU data

protection instrument applies to

• Legal provisions detailing the

relationship between the EPPO’s data

protection rules and national laws.

• Agreements or guidelines clarifying

legal interaction.

• Consistency between EPPO’s internal

policies and the correct EU legal

framework.

• Extent of stakeholder awareness and

understanding of data protection

responsibilities.

• Number of cases where data

• Targeted consultation (DPO, Legal

Service, Case Analysts, National

Authorities, EDPS).

• Desk research (EPPO Regulation,

Internal Guidance Documents, EUDPR,

GDPR, Law Enforcement Directive,

Charter of Fundamental Rights of the

European Union, EDPS Decisions and

Reports).

97

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

different aspects of EPPO’s

operations.

• The EPPO staff and national

authorities have a shared

understanding of data protection

responsibilities and applicable

legal frameworks in joint

investigations.

protection uncertainties led to

investigation delays or complications.

• Compliance of national law with the

data protection provisions of the

EPPO Regulation.

EQ6.2: Does the transfer of data to

third countries adhere to EU data

protection standards? Do the

mechanisms employed by the EPPO

when transferring data to these

countries, particularly those without

adequacy decisions, comply with EU

data protection rules?

• The EPPO’s data transfers to third

countries comply with the

requirements of Regulation (EU)

2018/1725, the GDPR, and other

relevant EU data protection

instruments.

• The mechanisms used for data

transfers align with EU legal

requirements and ensure adequate

protection of personal data.

• For transfers to third countries

without an adequacy decision, the

EPPO implements appropriate

safeguards.

• The EPPO has clear internal

guidelines, procedures, and

oversight mechanisms to ensure

compliance with EU data

protection rules in international

data transfers.

• Existence of legal provisions ensuring

compliance with EU data protection

rules in the EPPO’s data transfers.

• Number of reported issues related to

EPPO’s international data transfers.

• Legal and operational consistency

between EPPO’s transfer mechanisms

and EU data protection standards.

• Compliance with Schrems

requirements, ensuring supplementary

measures for transfers.

• Availability of additional safeguards

in data transfers.

• Reports or feedback from the EDPS

on the EPPO’s compliance with

international data transfer rules.

• Targeted consultation (DPO, Legal

Service, Case Analysts, EDPS, National

Authorities, Third-Country Authorities).

• Desk research (EPPO Regulation,

Internal Guidance Documents, EUDPR,

GDPR, Law Enforcement Directive,

Charter of Fundamental Rights of the

European Union, EDPS Decisions and

Reports, CJEU case law, MLATs).

EQ6.3: To what extent do the

European Data Protection

Supervisor (EDPS) and the EPPO

cooperate to ensure compliance with

EU data protection rules? How well

does this cooperation support the

• The EPPO has a structured and

formalised cooperation framework

with the EDPS.

• The EDPS provides timely and

effective guidance, supervision,

and recommendations to the EPPO

• Existence of a clear definition of roles

and responsibilities in the legal

framework and/or other agreements.

• Frequency of consultations between

the EPPO and the EDPS regarding

data transfers.

• Desk research (EPPO Regulation,

Internal Guidance Documents, EUDPR,

GDPR, Law Enforcement Directive,

Charter of Fundamental Rights of the

European Union, EDPS Decisions and

Reports, CJEU case law).

98

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

EPPO in aligning its operations with

EU data protection standards, and are

there any gaps or challenges in this

collaboration?

to ensure compliance with EU data

protection rules.

• The EPPO implements EDPS

recommendations.

• Regular and structured

communication channels exist

between the EPPO and the EDPS.

• Implementation of EDPS

recommendations in EPPO’s data

transfer policies.

• Any unresolved or recurring

compliance issues identified by the

EDPS.

• Feedback from EDPS on EPPO’s

internal data protection policies.

• Targeted consultation (DPO, Legal

Service, Strategy and Executive Office

Unit, IT, Security and Corporate

Services Unit, EDPS, EDPB).

EQ7: External Coherence: To what

extent is the EPPO Regulation

coherent with the fundamental

rights framework established under

the European Convention on Human

Rights (ECHR), the EU Charter of

Fundamental Rights (CFR), relevant

EU directives on procedural

safeguards, and the case law of the

ECtHR and the CJEU?

• The EPPO ensures compliance

with the right to fair trial and

defence rights, in line with

Article 6 ECHR and Articles 47-48

CFR.

• The EPPO provides access to

effective remedies and judicial

review, in line with Article 13

ECHR and Article 47 CFR.

• The EPPO respects the principle of

ne bis in idem, in line with

Article 50 CFR and Protocol No. 7

ECHR.

The EPPO guarantees victims’

rights to information, participation,

and access to remedies, in line

with Directive (EU) 2012/29 and

Article 47 CFR.

• Stakeholder feedback from defence

lawyers on their ability to effectively

challenge EPPO decisions, EPPO

compliance with procedural rights and

avenues for redress.

• Stakeholder feedback from national

judges on the quality of EPPO

requests for coercive measures.

• Stakeholder feedback from defence

lawyers on the risk of double

prosecution in cross-border cases.

• Stakeholder interviews with victim

support organisations on the

accessibility of EPPO procedures.

• Number of victim complaints filed

against the EPPO for lack of access to

justice.

• Desk research (the EPPO Regulation,

ECHR, CFR, Directive (EU) 2016/343,

Directive (EU) 2013/48, Directive (EU)

2012/13, Directive 2010/64, Directive

2016/1919, Directive 2016/800,

Directive (EU) 2012/29, CJEU case law,

ECtHR case law, annual reports and

reports from CSOs).

• Targeted consultation (Legal Service,

EDPs, Defence Lawyers, Fair Trials,

National Prosecutors and Judges, Victim

Support Organisations, Academics

whose expertise focuses on procedural

rights).

EU added value

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

EQ8: To what extent could the

identified changes / results have been

• Similar changes / results could

have been achieved at MS/EU or

• Number of cross-border investigations

before and after the establishment of

• Desk research (EPPO Regulation, IA

and explanatory memorandum,

99

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

achieved without the EPPO / the

EPPO Regulation?

international level.

• Similar changes/results could have

been achieved without the 2017

EPPO Regulation.

• The subsidiarity analysis in the IA

/ explanatory memorandum was

valid, and the EPPO Regulation

remains fit for purpose.

the EPPO.

• Amounts recovered before and after

the establishment of the EPPO.

• Stakeholder perception of the type of

changes brought about by the EPPO

Regulation.

• Stakeholder perception whether the

subsidiarity analysis was valid.

• Types of changes/results that

stakeholders consider would not have

been achieved at MS/EU or

international level without the EPPO.

• Types of changes/results that

stakeholders consider would not have

been possible without the 2017 EPPO

Regulation.

• Stakeholder perception whether

stopping the EPPO’s activities would

have negative / positive consequences.

• Subsidiarity justification raised in the

IA / explanatory memorandum that

have been achieved by the EPPO.

changes/results of EPPO as outlined in

Annual Activity Reports, etc.).

• Targeted consultation

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director, Unit and

Sector representatives);

- with external stakeholders (EU

IBOAs, national authorities and

practitioners).

• Online surveys.

EQ8.1: Which, if any, objectives of

the EPPO Regulation and the EPPO

could have been achieved, to a similar

level or more, by the Member States

acting alone (and if so, how)?

• Achieving the objectives of the

EPPO Regulation goes beyond

what could have been achieved, to

a similar level or ore, by the

Member States acting alone.

• Additional target groups have been

addressed that would not have been

addressed by the Member States

acting alone (evidence of scope

effects).

• A higher volume of services has

been offered, which could not have

• Stakeholders’ perceptions of the

objectives of the EPPO and the EPPO

Regulation that could not have been

achieved by Member States acting

alone.

• Stakeholder perceptions which

objectives of the EPPO and the EPPO

Regulation might have been achieved

sufficiently by the Member States

acting alone.

• Stakeholder perceptions on whether

possible scope and scale effects have

• Desk research (e.g. performance data

related to the tasks of the EPPO).

• Targeted consultation

- with external stakeholders (EU

IBOAs, such as EU Commission,

OLAF and JHA Agencies,

national competent authorities and

national prosecutors);

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director).

100

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

been achieved by Member States

acting alone (evidence of scale

effects).

• A higher volume of end users have

been addressed, which could not

have been achieved by Member

States acting alone (evidence of

scale effects).

been achieved.

• Number of prosecutions / convictions

for offences affecting the EU’s

financial interests handed down by

national courts, disaggregated by year.

• Online surveys

EQ8.2: To what extent can the

resulting benefits be measured when

compared with the relocation of

human and operational resources

from the participating Member States to

the EPPO?

• The benefits outweigh any losses

made by participating Member

States through the relocation of

human and financial resources to

the EPPO.

• Evidence of benefits in participating

Member States to the EPPO vs

activities at Member State level.

• Stakeholder perception on the extent

to which the resulting benefits

outweigh the costs of relocation of

human resources and operational

resources from the participating

Member States to the EPPO.

• Desk research (e.g. evidence of

benefits / losses in participating

Member States).

• Targeted consultation

- with external stakeholders (EU

IBOAs, such as EU Commission

and JHA Agencies, national

competent authorities and national

prosecutors);

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director).

• Online surveys

• Case studies (e.g.examining the

potential benefits of the EPPO for

participating Member States).

EQ8.3: To what extent have the

EPPO’s activities and cooperation

with the JHA and anti-fraud policy

areas helped to improve the ability of

Member States compared to what they

could do at national level?

• The EPPO’s activities and

cooperation with the JHA policy

area helped to improve the ability

of Member States, compared to

what they could do at national

level.

• Member States acting at national /

regional levels could not have

achieved similar activities /

• Types of activities / cooperation with

the JHA policy area that stakeholders

consider could have been achieved by

Member States acting at national /

regional levels.

• Number of prosecutions / convictions

for offences affecting the EU’s

financial interests handed down by

national courts, disaggregated by year.

• Targeted consultation

- with external stakeholders (EU

IBOAs, such as EU Commission

and JHA Agencies, national

competent authorities and national

prosecutors);

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

101

Evaluation question Judgement criteria Examples of indicators Data sources / research methods

cooperation with the JHA policy

area.

Administrative Director).

• Online surveys.

• Focus groups (EDPs/EPs, national

practitioners).

EQ8.4: What was the contribution of

the EPPO to the JHA and anti-fraud

policy areas, for example, in terms of

cooperation with other JHA and anti-

fraud agencies and bodies?

• The EPPO has contributed to the

JHA policy area, for example

through cooperation with other

JHA agencies and bodies.

• Examples / types of EPPO

contributions to the JHA policy area.

• Stakeholder perception of the number

/ types / quality of the EPPO’s

contribution to the JHA policy area.

• Targeted consultation

- with external stakeholders (EU

IBOAs, such as EU Commission,

OLAF and JHA Agencies,

national competent authorities and

national prosecutors);

- with internal stakeholders

(European Chief Prosecutor,

College, Permanent Chambers,

Administrative Director).

• Online surveys.

Evaluation questions: summary responses

The below table presents a summary of the key findings for each research and evaluation question.

Effectiveness

Research questions Key findings

EQ1: To what

extent has progress

been made towards

achieving the

objectives of the

EPPO considering

the expectations and

the working

arrangements

included on the

Positive impact across all four specific objectives and the general objective of the EPPO. Further detail provided in the answers to the more

specific questions below.

102

Research questions Key findings

Regulation?

EQ1.1: To what

extent have the

EPPO’s activities

and operations

contributed to

achieving the

overall EU’s policy

objective and

priority of fighting

crime against the

EU’s financial

interests?

Substantial Increase in the number of cases: Since becoming operational, the EPPO has overseen a dramatic rise in caseload, with active

investigations growing from 576 in 2021 to a projected 12,030 by 2025, and indictments increasing from 5 to 275 over the same period.

Uncovering a "Continent of Crime": The EPPO has successfully identified and prosecuted large-scale transnational crimes, such as Missing Trader

Intra-Community (MTIC) fraud, which were previously undetected or deprioritized by national authorities. A landmark example is Operation

Admiral, which uncovered a criminal network of 9 000 companies and an estimated EUR 2.9 billion in damages.

A majority of surveyed national practitioners and authorities agree that the EPPO has effectively addressed crimes that would otherwise have

remained ignored. Specifically, 90% of responding Member States believe the EPPO has strengthened the protection of the Union’s financial

interests to a great or moderate extent.

EQ1.2: To what

extent do the rules

on the material

competence of the

EPPO allow or

prevent the Office

from fulfilling its

mission?

To a large extent, the material competence rules allow the EPPO to fulfil its mission in relation to core PIF criminality, but they constrain

effectiveness at the margins.

The framework clearly enables the EPPO to act on the main forms of criminality within its mandate, including core PIF offences, cross-border

fraud and mixed fact patterns, which is reflected in the scale and profile of operational activity.

By end-2025, the EPPO had 3 602 active cases, including 981 revenue fraud cases and 615 cases containing an inextricably linked offence,

indicating that the competence framework is operationally significant rather than marginal. This is consistent with the Regulation, which anchors

EPPO competence in offences affecting the Union’s financial interests and, under defined conditions, offences that are inextricably linked to them.

At the same time, the evidence indicates recurring frictions in borderline cases, especially around the Article 22(2) “focus” criterion for criminal

organisations, Article 22(4) exclusion of national direct taxes, and Article 25(3) conditions for linked offences. These issues appear to generate

delays, fragmentation, uneven treatment across Member States and, in some cases, missed investigative opportunities.

The overall judgement is therefore that the framework is broadly enabling but only partially effective at the margins.

EQ1.3: How

effective is the

cooperation and

information

exchange between

the EPPO and the

national competent

authorities and to

what extent has the

Cooperation and information exchange between the EPPO and national competent authorities appear to be largely effective and have led to

tangible improvements in overall coordination, although the evidence is stronger on operational establishment and increasing use than on fully

verified performance against all planned targets.

The evidence indicates that the EPPO has put in place and operationalised standardised reporting and exchange mechanisms, centralised intake and

triage, secure channels and structured cooperation with national and EU partners.

Operational use has also increased markedly: in 2025 the EPPO processed 6 966 reports and opened 2 030 investigations, which the EPPO itself

links partly to improved cooperation with relevant national authorities. The underlying legal architecture is also geared towards close cooperation

103

Research questions Key findings

cooperation and

information

exchange required

by the establishment

of the EPPO led to

improvements in

overall

coordination?

and mutual information exchange with OLAF, Europol, Eurojust and national authorities.

At the same time, some important caveats remain. The evidence does not allow full verification of certain SPD-style performance targets,

especially timeliness targets, and the ECA audit points to continuing weaknesses in downstream information flows, including incomplete

communication of discontinued cases and the fact that the impact of the revised November 2024 reporting template could not yet be assessed.

The overall judgement is therefore broadly positive but qualified, with clear coordination gains in practice, though not all dimensions of

performance can yet be verified robustly.

EQ1.4: Were

adequate procedures

put in place - and if

so, to what extent -

to ensure consistent

investigation and

prosecution of PIF

crimes across the

participating EU

Member States, thus

ensuring that similar

cases in different

Member States are

duly investigated by

the EPPO? Were

there cases where

similar

investigations led to

prosecutions in one

Member State but

not in another, even

where the evidence

base was adequate

in both situations?

The EPPO has put in place a number of procedures, internal guidelines and organisational arrangements that are capable of supporting greater

consistency in cross-border investigation and prosecution, but the available evidence does not allow a robust conclusion on whether similar cases

have in practice been treated consistently across Member States.

The Regulation itself is designed around a single office model with central monitoring, direction and supervision, and with Permanent Chambers

tasked with ensuring coherence in investigations and prosecutions. The evidence also points to concrete procedural instruments intended to

harmonise practice, notably the Article 31 Guidelines and structured arrangements for cross-border assignments and evidence gathering. However,

the study evidence remains much stronger on the existence and adequacy of procedures in design terms than on demonstrable outcome consistency

across jurisdictions.

In particular, the data available does not permit identification of specific comparable cases where the evidence base was adequate in both situations

but prosecution occurred in one Member State and not another. It is therefore more defensible to conclude that procedures for consistency have

been put in place to a meaningful extent, but evidence of their results in ensuring equivalent treatment of similar cases remains limited.

EQ1.5: To what

extent has the EPPO

managed, in

practice, to direct

To a large extent, the EPPO has managed in practice to direct investigations and prosecutions across the participating Member States and to

coordinate cross-border investigations effectively, but the quality and speed of that direction remain partly dependent on national capacities and

procedures.

The evidence indicates that the EPPO is functioning not merely as a coordination platform, but as an operational prosecutor’s office acting through

104

Research questions Key findings

investigations and

prosecutions in the

Member States, and

ensure effective

coordination of its

cross-border

investigations and

prosecutions

its decentralised structure. The Regulation provides for this through a single-office model, central monitoring and direction, Permanent Chamber

decision-making, and the power to instruct European Delegated Prosecutors.

In operational terms, the 2025 Annual Report shows a substantial and expanding caseload, with 6 966 reports processed, 2 030 investigations

opened and 27% of active investigations having a cross-border dimension. It also records decisions assigning measures to assisting EDPs in other

participating Member States, which is a direct proxy for active cross-border operational coordination. This supports a broadly positive assessment.

However, the evidence also points to constraints linked to national implementation conditions, including police support, database access,

procedural bottlenecks and other national operational dependencies. The ECA likewise notes that national authorities remain the EPPO’s primary

source of support, while EU-body support is additional and comparatively limited.

The overall finding is therefore that the EPPO has largely succeeded in directing and coordinating investigations in practice, but not yet under

uniformly favourable operational conditions across all jurisdictions.

EQ1.6: To what

extent have the

differences in the

national

implementation of

the PIF Directive

had an impact on

the EPPO’s ability

to prevent fraud to

the Union’s

financial interest?

Differences in national implementation of the PIF Directive have had a meaningful but uneven negative impact on the EPPO’s preventive

capacity. Under the Regulation, EPPO competence is anchored in PIF offences as implemented in national law, so divergences in national

transposition and interpretation can affect what is treated in practice as PIF-relevant, how quickly cases are reported and verified, and whether

mixed schemes can be pursued coherently.

The evidence suggests four main prevention-relevant pathways: first, narrower national offence definitions or reporting frameworks may filter out

relevant conduct before it reaches the EPPO; second, temporal gaps in criminalisation can create periods in which the EPPO cannot act; third,

divergent national sanction structures can interact with Article 25(3)(a) to limit EPPO handling of mixed schemes; and fourth, divergent

interpretation of key PIF elements, notably around serious cross-border VAT fraud and procurement fraud, can delay or narrow competence

verification and case opening.

The impact does not appear to prevent EPPO action generally, but it does appear to reduce the timeliness, coherence and consistency of preventive

criminal follow-up in specific high-leverage areas. Given the Better Regulation requirement to avoid over-claiming causality where indicators are

limited, this should be framed as a contribution-based judgement rather than causal attribution.

EQ1.7: To what

extent can the

system of shared

competence

between the EPPO

and the national

authorities in

combating crimes

affecting the

Union’s financial

The shared competence model can be considered broadly adequate in legal design and institutional logic, but only conditionally adequate in

practice. The Regulation expressly establishes a system of shared competence based on the EPPO’s right of evocation, supported by duties of

reporting and sincere cooperation. In design terms, the model gives the EPPO priority to act while allowing it to operate through national criminal

justice systems, which is also consistent with the original intervention logic of overcoming fragmented national prosecution of offences affecting

the Union’s financial interests. In practice, however, adequacy depends heavily on how national systems operationalise the model.

The evidence points to frictions in delayed or filtered reporting, competence disputes, and uneven national operational support, including database

access and investigative support. The recent ECA report is consistent with these concerns, noting that the current reporting and information-

sharing system does not ensure that all relevant allegations are assessed efficiently by the EPPO and that information exchange weaknesses limit

protective action.

105

Research questions Key findings

interests, based e.g.

on the right of

evocation of the

EPPO, be

considered to be

adequate?

The overall judgement is therefore that the system is workable and generally fit for purpose, but not uniformly effective across Member States.

EQ1.8: How

effective have the

EPPO’s governance

structure (in

particular the

division of tasks

between the

European Chief

Prosecutor, the

College, and the

Permanent

Chambers) and

working practices

been in enabling the

EPPO to fulfil its

mission?

The EPPO’s governance structure and working practices appear broadly effective in enabling mission delivery, but with important constraints

affecting proportionality, scalability and the smooth operation of the decision chain across diverse national systems.

The legal design provides a coherent central governance framework: the European Chief Prosecutor heads and directs the Office, the College sets

strategic priorities and general rules, and the Permanent Chambers monitor investigations and prosecutions and take key operational decisions,

including prosecution, dismissal, referral and simplified procedures.

The Regulation also includes mechanisms intended to support continuity, consistency and proportionality, including written procedures, delegation

of certain Permanent Chamber decisions in less serious or less complex cases, and reporting lines designed to ensure coherence across the Office.

The available evidence base is also limited, as it relies mainly on documentary review, senior EPPO input, external stakeholders and a small

number of former EP perspectives rather than broader direct feedback from EPs and EDPs.

Overall, the governance model is broadly fit for purpose and has supported mission delivery, but not without friction, and its effectiveness at scale

remains partly conditional on national procedural environments and operational support tools.

EQ1.9: How

effective is the

cooperation

between the EPPO

and the EU

institutions, bodies,

offices and agencies

in the investigation

of PIF offences, the

recovery of funds

and application of

administrative

measures?

The EPPO has supported cooperation with EU IBOAs to an extent that positively contributed to operational delivery and information exchange.

However, some stakeholders described the cooperation as request-driven and sometimes slowed by mismatches in assumptions about who holds

operational documentation (e.g. misunderstanding of concepts such as shared management of EU funds).

Cooperation between the EPPO and OLAF is increasing but still lacks effectiveness in practice. For example, information sharing remains limited,

the hit/no hit process is manual and considered outdated, and there is a continued risk of duplication or delays, including limited EPPO reporting to

OLAF (as noted by the ECA).

Cooperation between the EPPO and Europol is effective and, in many respects, fit for purpose. Constraints remain, including Member State

ownership of certain data and the absence of liaison officer arrangements, despite being foreseen.

Changes to the VAT administrative cooperation framework would significantly improve EPPO access to tax data and reduce inefficiencies.

106

Research questions Key findings

EQ1.10: How

effective is the

cooperation with the

competent

authorities of non-

participating

Member States,

enlargement

countries and other

third countries, as

well as with

international

organisations? Do

the rules on the

representation of the

EPPO in the

international fora

enable the EPPO to

fulfil its statutory

mission effectively?

Cooperation with Third Countries is expanding, but some challenges persist: the EPPO increased cooperation via WAs and MoUs, yet third

countries do not always recognise the EPPO as a competent judicial partner, creating risks of delays and uncertainty over evidence and data

transfer.

The EPPO has also formalised cooperation with a number of organisations and networks, and is providing training activities, workshops and other

support activities as part of his cooperation.

The number of NPMS to the EPPO has reduced over the evaluation period. The EPPO’s strategy has been to ensure that ties and cooperation with

NPMS are strong, as it is crucial for investigating and prosecuting cross-border cases and for the recovery of assets. The EPPO Signed WA with

the Office of the Prosecutor General of Hungary in 2021 and the Danish Ministry of Justice in 2023. In 2023, cooperation formally started with

Ireland. However, some experiences of parallel proceedings were identified where both the EPPO and Hungarian authorities were conducting

investigations over the same crime.

EQ1.11: To what

extent have the

EPPO’s activities

and operations led

to a higher number

of reports,

investigations, and

prosecutions of PIF

crimes, including

large scale cross-

border offences

such as VAT

carousel fraud?

The EPPO has contributed to uncovering previously undetected criminality: The EPPO has successfully identified a "continent of PIF crime,"

specifically targeting complex transnational schemes like Missing Trader Intra-Community (MTIC) fraud that were frequently overlooked or

deprioritized by national authorities. A prime example is Operation Admiral, which uncovered a EUR 2.9 billion network that a stakeholder noted

would likely never have been investigated under previous national frameworks.

During the EPPO’s preparatory phase, over half of the Member States reported having no relevant statistics or cases related to the crimes within

the office's jurisdiction, indicating that these offences were significantly under-prosecuted at the national level.

EQ1.12: To what

extent have the

prosecutions carried

The volume of indictments issued by the EPPO has escalated from only five in 2021 to a projected 275 in 2025. Furthermore, the number of

convictions resulting from these prosecutions more than doubled annually between 2022 and 2024