The Commission has launched a reflection process for the review of the EU Anti-Fraud Architecture, inviting anti-fraud actors and all stakeholders to contribute. The review complements the preparatory work on the next Multiannual Financial Framework.
The European Commission launched a review of the EU’s anti-fraud framework on 17 July. The exercise aims to modernise safeguards for the bloc’s budget amid rising threats such as transnational fraud and AI-driven crime. It will align with preparations for the next Multiannual Financial Framework (MFF) to ensure efficient protection of EU funds.
Clarify, harmonise
Criminal networks increasingly exploit legal gaps and advanced technologies like cryptocurrencies. The review will address inefficiencies across the anti-fraud cycle, from prevention to recovery of misused funds. „Effective deterrence and response will be at the heart of the exercise,“ reads the Commission press release on the anti-fraud architecture. It prioritises better data-sharing, investigative tools and coordination between EU and national bodies.
The process will focus on improving information collection, deploying AI for fraud detection and clarifying roles for agencies. It will also explore ways to harmonise administrative and criminal probes. The Commission urges anti-fraud actors and stakeholders to contribute ideas by 2025. Final proposals, including potential laws, will emerge in 2026.
Effective deterrence and response will be at the heart of the exercise. – The European Commission
The EU’s anti-fraud architecture comprises a number of bodies: the European Court of Auditors (ECA), the European Union Agency for Criminal Justice Cooperation (Eurojust), the European Union Agency for Law Enforcement Cooperation (Europol), the European Public Prosecutor’s Office (EPPO), the European Anti-Fraud Office (OLAF), the EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA), as well as the member states‘ relevant authorities, or AFCOSes.
Uneven criteria
The 2013 PIF Directive standardises penalties for budget fraud. But challenges persist. National Anti-Fraud Coordination Services (AFCOS) have vague mandates and uneven resources. Older member states designed their AFCOS under flexible EU rules, while the latest arrivals (Romania, Croatia, Bulgaria) faced stricter criteria during accession talks.
This has created disparities. Newer members operate robust AFCOS systems with heavier workloads, while older ones use looser frameworks. The review must reconcile these differences without undermining national sovereignty. Clarity on AFCOS roles is critical, as their current ambiguity weakens cooperation with bodies like the European Public Prosecutor’s Office (EPPO).
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“The Union legislative framework is quite general and insufficiently clear in respect of the member states’ obligation to protect the financial interests of the EU and the tasks of an AFCOS, which can be interpreted in different ways in each member state,“ says an analysis published in European Criminal Law Review, a journal focusing on EU criminal law. “This has led to significantly different AFCOS models and thus to major differences in the national legal frameworks that regulate both the protection of the financial interests of the EU as well as the structure, role, and mandate of an AFCOS.“
A shared duty
The OLAF regulation obliges states to designate AFCOS units but lets them choose their structure. Some embed them in finance ministries; others treat them as standalone agencies. Outputs vary widely. The review will assess whether to impose standardised models – a move likely to face resistance.
A Commission white paper guiding the process stresses “efficiency through synergy”. It highlights gaps in asset recovery: between 2019 and 2022, only a fraction of defrauded sums were reclaimed. The review will propose fixes, possibly updating the PIF Directive and OLAF’s mandate.
The Union legislative framework is quite general and insufficiently clear in respect of the member states’ obligation to protect the financial interests of the EU. – European Criminal Law Review
The Commission’s mission letter links the exercise to Europol and EPPO’s work. These agencies pool cross-border resources, but their scope is narrower than the anti-fraud architecture’s remit. The review will weigh how to replicate their collaboration models.
Protecting the EU budget remains a shared duty. The Commission sets legal frameworks, but member states enforce them. With fraud risks growing, the bloc cannot afford fragmented defences. The 2026 reforms will test Brussels’ ability to balance ambition with respect for national autonomy – a challenge as old as the EU itself.
Sovereignty issues ahead
Critics argue the review dodges tough questions. AFCOS reforms risk inflaming sovereignty debates, while tech upgrades demand costly investments. But the alternative – leaving gaps for criminals to exploit – is worse. The Commission’s success hinges on convincing capitals that shared threats require shared solutions.
The stakes are high. EU citizens already question how Brussels manages their taxes. A 2023 Eurobarometer survey found 56 per cent doubt the bloc’s ability to curb fraud. Modernising the anti-fraud architecture is not just about money – it’s about proving the EU can protect its core policies. Failure risks eroding trust in cohesion funds, farm subsidies and pandemic recovery schemes. Success could set a global benchmark for tackling financial crime in the digital age.
By 2026, the Commission must balance ambition with realism. While tighter tech controls and shared databases may offer quick wins, harmonising AFCOS roles will prove trickier. But as fraudsters innovate, the EU’s defences cannot stand still.
