What changed between the draft committee report and the plenary report

3. MOTION FOR A EUROPEAN PARLIAMENT RESOLUTION

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with observations forming an integral part of the decision on discharge in respect of the implementation of the budget of the European Public Prosecutor’s Office for the financial year 2024

(2025/2155(DEC))

The European Parliament,

– having regard to its decision on discharge in respect of the implementation of the budget of the European Public Prosecutor’s Office for the financial year 2024,

– having regard to Rule 102 of and Annex V to its Rules of Procedure,

– having regard to the opinion of the Committee on Civil Liberties, Justice and Home Affairs,

Changed:– having regard to the report of the Committee on Budgetary Control (A100000/2026),(A10-0050/2026),

A. whereas the European Public Prosecutor's Office (EPPO) is the independent public prosecution office of the Union, responsible for investigating and prosecuting crimes against the financial interests of the Union and bringing to judgment the perpetrators of, and accomplices to, criminal offences as provided for by Directive (EU) 2017/1371 of the European Parliament and of the Council (PIF-related crime) and as indicated by Council Regulation (EU) 2017/1939;

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Changed:B. whereas the competence of the EPPO encompasses several types of fraud, andincluding includescross-border VAT fraud with damages above EUR 10 million, money laundering, corruption and other offences for which the EPPO exercises the functions of prosecutor in the competent courts of the participating Member States, until the end of the proceedings;

C. whereas the EPPO is one of the components of the Union’s anti-fraud architecture and, as such, its actions are coordinated with and complementary to those of the other components of the architecture, to achieve streamlined, efficient coordination that enhances the overall effectiveness of the architecture;

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Changed:D. whereas the EPPO intervenesis whereembedded in the prerogativesnational judicial systems of the nationalparticipating authoritiesMember States and has a priority competence for investigating and prosecuting the crimes concerned stop ataffecting the bordersfinancial interests of theirthe country,Union, andwhile other organisations, such as Eurojust,European OLAFUnion Agency for Criminal Justice Cooperation (Eurojust), European Anti-Fraud Office (OLAF) and Europol,European Union Agency for Law Enforcement Cooperation (Europol), do not have the necessary powers to carry out the relevant criminal investigations and prosecutions;

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Changed:E. whereas the procedural acts of the EPPO are subject to judicial review by the national courts in line with national laws and the Court of Justice of the European Union (the ‘Court of Justice’) - by means of preliminary ruling or judicial reviews– has residual powers to ensure-ensures a consistent application of Union law;law, in particular the uniform interpretation of Regulation (EU) 2017/1939 and Directive (EU) 2017/1371;

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Changed:F. whereas the EPPO is composed of a central level, with its headquarters in Luxembourg, consisting of the European Chief Prosecutor, 24 European Prosecutors (one per participating Member State following the participation of Poland and Sweden in the EPPO, sincewhich took place on 20 March and 19 July 2024, respectively), the Administrative Director, as well as a decentralised, national level consisting of the European delegated prosecutors (EDPs) in the 24 participating Member States;

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Changed:G. whereas at the central level the European Chief Prosecutor and the 24 European Prosecutors form the College of the EPPO (the ‘College’) and are allocated to 15 Permanent Chambers with the task of supervising the investigations and prosecutions carried out by the EDPs at the national level, who operate with complete independence from their national authorities;

H. whereas, under Article 93 of Regulation (EU) 2017/1939 the EPPO Administrative Director, acting as the authorising officer of the EPPO, shall implement its budget under its own responsibility and within the limits authorised in the budget and shall send each year to the Union’s budgetary authority all information relevant to the findings of any evaluation procedures;

I. whereas, in accordance with Article 50(2) of the EPPO’s Financial Rules, the Accounting Officer of the Commission also acts as the Accounting Officer of the EPPO and is responsible for the preparation of the annual accounts, which are consolidated with those of the Union;

J. whereas, under the current framework, the final annual accounts are scrutinised by the Court of Auditors (the ‘Court’) and the Council recommends and Parliament decides whether to grant discharge to the EPPO’s Administrative Director in respect of the implementation of the budget for a given financial year;

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Changed:K. whereas scrutiny over the management of the EPPO resources and related expenditure cannot ignore the examination of operational activities, including the methods of their execution, their consequences and impact and is expected to take into account the peculiarities of prosecution and investigative actions by a continuous evaluation to ensuring that resources remain sufficient and are efficiently spent to ensure operational effectiveness;success;

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L. whereas the EPPO has been operating autonomously in the implementation of its budget only since 24 June 2021 and it has started its operational activities on 1 June 2021, which is also the dies a quo for the five-year term indicated in Article 119 of Regulation (EU) 2017/1939 upon reaching which the Commission will have to submit to Parliament and to the Council and to national parliaments an evaluation report on the implementation and impact of such Regulation, and on the effectiveness and efficiency of the EPPO and its working practices, together with its conclusions;

M. whereas Article 119(2) of Regulation (EU) 2017/1939 provides that the Commission is to submit legislative proposals to Parliament and the Council if it concludes that it is necessary to have additional or more detailed rules on the setting up of the EPPO, its functions or the procedure applicable to its activities, including its cross-border investigations;

N. whereas any Commission’s proposal for a revision of the EPPO regulatory framework can be submitted only after giving due consideration to Parliament resolutions adopted since the date of the start of the EPPO operational activities and taking into account the role of the EPPO within the Union’s anti-fraud architecture, the revision of which was launched by the Commission in September 2025, following Parliament’s calls to do so;

1. Welcomes the positive opinion of the Court on the reliability of the EPPO’s accounts for the year ended 31 December 2024 and on the legality and regularity of the underlying revenue and payments;

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Changed:2. Acknowledges the importance of the EPPO with regard to the protection of the financial interests of the Union and, in particular, the Union’s budget; recalls Parliament’s strong support for the establishment of the EPPO and expresses appreciation for the work that the EPPO does in investigating and prosecuting crimes such as fraud, corruption and serious cross-border VAT fraud; reiterates the central role of the EPPO in safeguarding the Union’s financial interests and underlines that it constitutes a cornerstone of the Union’s anti-fraud framework and of the broader system of governance based on integrity, accountability, transparency and sound financial management;

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Removed:3. Stresses the EPPO’s unique role with regard to Union law enforcement as a prosecution service and points out that because of its nature the EPPO is obliged to investigate all matters within its competence, when brought to its attention; highlights therefore the need to promptly dedicate the necessary resources to fulfil its duties and to ensure progress and the timely conclusion of investigations;

Added:3. Stresses the unique role of the EPPO with regard to Union law enforcement as a prosecution service and points out that because of its nature the EPPO is obliged to investigate all matters within its competence, when brought to its attention; recalls that according to the EPPO Annual Report, by the end of 2024 the EPPO handled 6 547 crime reports (56 % more than in 2023) and 2 666 active investigations (around 38 % more than in 2023) with estimated damages of EUR 24,8 billion (EUR 19,27 billion in 2023 and EUR 14,1 billion in 2022) and that judges granted freezing orders worth EUR 2,42 billion (compared to EUR 1,5 billion in 2023); stresses that the constantly increasing figures confirm that the resources should be aligned to the operational needs to strengthen the independence of the EPPO; calls on the Commission to promptly allocate the necessary resources to enable the EPPO to fulfil its duties and to ensure progress and the timely conclusion of investigations, including the one into the acquisition of the COVID-19 vaccine in the Union, which was commenced in 2022 and remains ongoing under confidentiality rules without public disclosure of details to protect the integrity of the proceedings; recalls that transparency must be balanced with the presumption of innocence and respect for ongoing judicial proceedings; encourages the EPPO to maintain clear public communication where legally permissible; stresses that human and financial resources allocated to the EPPO for high-complexity cases of major budgetary and reputational impact must ensure the diligent progression of the investigation and provide responsible communication of their status and conclusion, in full respect of legal constraints;

Budgetary and financial management

4. Notes that the overall final budget allocated to the EPPO for 2024 was EUR 76 382 368, which was a substantial increase from the EUR 65,9 million allocated in 2023 and the EUR 51,2 million allocated in 2022;

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Changed:5. Points out that the initial 2024 budget (amounting to EUR 71 888 321) approved by the Union’s budgetary authority was 24 % less than that requested by the EPPO in its estimates of revenue and expenditure for 2024 even if higher by 9 % when compared with the previous year; observes that two amending budgets were adopted in 2024 and that upon the EPPO’s request in February 2024, the budget was increased in June 2024 by EUR 3 600 000,000 in June 2024, with financial and human resources to cover the increased costs related to the participation in the EPPO of Poland and Sweden;Sweden in the EPPO; underlines the fact that the increase had to cover the salaries of the additional EDPs to be appointed in Poland and Sweden and of the staff to be hired and the related operational expenditure, but that part of these additional funds were allocated to Central Office staff to prepare for the IT autonomy project imposed by the discontinuation of the Commission’s services in the IT area; notes that the second amending budget increased the level of appropriations by EUR 894 047 in November 2024, upon a proposal offrom the Union’s budgetary authority to address the high level of salary indexation in 2024 and that because the EPPO had already allocated part of its first amending budget to anticipate the higher-than-expected salary indexation, the second additionally granted resources were redeployed to security-related expenditure; considers that this recurrent reliance on amending budgets highlights the need for a more realistic ex-ante budgeting approach and for earlier and more structured engagement with the EPPO during the annual budgetary procedure;

Changed:6. Notes that, in 2024, three budget transfers were adopted in accordance with Article 26 of the EPPO Financial Rules allowing the European Chief Prosecutor, on a proposal drawn up by the Administrative Director, to transfer appropriations from one title to another up to a maximum of 10 % of the appropriations for the financial year and from one chapter to another or within each chapter without limit; observes that the total net value of those transfers was EUR 3,2 million, compared to EUR 1,2 million in 2023, and that such transfers were needed for the developments of the IT autonomy programme, the requested regularisation of the close protection services under the service level agreement (SLA) with the Commission’s Directorate General for Human Resources and Security and the changes in the remuneration update, to accommodate the higher than anticipated salary indexation that reached 7,2 % compared to the initial budgetary hypothesis of 3,4 %%;

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Changed:7. Acknowledges that the estimate of any budgetary needneeds related to the EPPO’s activities remainremains very difficult because of the peculiarity of EPPOthe EPPO’s activities, linked to the unpredictable level of fraud detection and to the wide variety of its cases; is aware that the EPPO has no discretion with regard to pursuing prosecutions and, in the meantime,and has no leverage onwith regard to resources and procedural constraints of national systems on which it depends for the investigative activities; observes that the lack of a fixed correlation between the number and the costs of investigations also preventsimpedes expenditure forecast, but recalls that the Union’s resources to be protected are increasing and the complexity of the regulatory framework governing their deployment makes it more difficult thefor investigations, not only for what concerns the recovery and resilience facility (RRF) and its unprecedented implementation mode but also for the high volume of resources allocated;expenditure; believes that this context suggests the need for additional allocation of resources to finance EPPOthe EPPO’s activities and reiterates the need for the EPPO to be provided with sufficient resources to adequately fulfil its mandate; considers that such unpredictability could justify the establishment of a dedicated budgetary contingency mechanism without prejudice to the need for a realistic ex-ante budget reflecting workload trends, to allow the EPPO to respond effectively to sudden increases in workload;

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Changed:8. Understands that 2024 was a difficult year for the EPPO, because it had to deal with an increase ofin its workload in the 22 participating Member States, to manage the enlargement to include Poland and Sweden and, simultaneously, to achieve IT autonomy from the Commission; notes that in 2024 the EPPO requested 45 establishment plan posts for IT autonomy, and later 37 posts in an amending budget, but both requests were denied; observes that in particular the lack of additional resources allocated to achieve IT autonomy resulted in the need to divert towards the IT sector members of staff initially meant to support the operations and resorting to intra muros contractors; considers that it remains essential to award financing to ensure the EPPO’s full IT autonomy and strong cybersecurity prevent operational disruptions; stresses that the continued reliance on external contractors and the diversion of operational staff to IT tasks, resulting from the lack of establishment-plan posts for IT autonomy, risks undermining the EPPO’s investigative capacity and long-term institutional resilience; calls on the budgetary authority to provide dedicated, sustainable staffing for EPPO digital autonomy in order to protect investigative effectiveness and cybersecurity;

9. Points out that the budgetary implementation rate for the financial year 2024 was 98,5 %, over the expected performance indicator of 95 % and in line with the previous years (99,6 % in 2023 and 98,1 % in 2022); appreciates that for a second year in a row the EPPO has not returned any funds to the Union’s budgetary authority, demonstrating a solid absorption capacity of the granted budget; points out that, in 2024, the overall execution rate for payments reached 86,4 % of the EPPO’s final budget, with an average payment time of 16,7 days, thanks to enhanced use of e-invoicing, improving from previous years (in 2023 the execution rate was 85,3 %, with an average payment time of 17 days, and in 2022 the execution rate was 76,6 % with an average payment time of 23,8 days); observes that the percentage of late payments remained stable and very low (0,85 % out of the total number of payments in 2024, compared to 0,86 % in 2023; or 1,09% out of the total amount of payments in 2024, compared to 1,08 % in 2023);

10. Observes that, in line with previous years and with the strategy prioritising the operational expenditure related to investigation, prosecution and security measures, in 2024, the EPPO allocated 44,6 % of its budget to operational activities (compared to 43 % in 2023 and 41 % in 2022) where the main cost drivers were the remuneration of the EDPs followed by operational ICT activities (19 %), such as the maintenance and development of the EPPO’s case management system (CMS) and the linguistic services (10 %); notes that the EPPO budget was mainly absorbed by expenditure related to temporary agents (33,6 %, EUR 25 671 160, compared to 32,2 % in 2023) and the EDPs’ remuneration (23,9 %, EUR 18 252 391, compared to 22,1 % in 2023) followed by costs for linguistic services (4,6 %, EUR 3 491 000, compared to 6,2 % in 2023) and operational ICT hardware and software (4,5 %, EUR 3 426 711, compared to 5,5 % in 2023);

11. Notes that in 2024 the participation of Poland and Sweden was announced and that the 2024 budget was only partially concerned, due to the gradual intake of two European Prosecutors and of a number of EDPs; observes that the 2024 increase approved by the Union’s budgetary authority granted additional 20 central office posts and additional EDPs in anticipation of Poland’s and Sweden’s participation in the EPPO;

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Changed:12. Observes that costs for operational missions slightly increased further in 2024, reaching EUR 1 292 000 (compared to EUR 1 175 000 in 2023 and EUR 980 000 in 2022) and absorbed approximately 3,7 % of the overall operational appropriations (EUR 34,1 million) but overall in line with the increasing level of intensity of investigations and stable in terms of value; understands that there has been a reduction in the overall travel expenditure, that the use of videoconferences facilities as a cost-effective and secure alternative to staff mission is being promoted by the EPPO and that participation in online meetings is the standard practice for internal coordination and exchanges with Member States authorities and Union partners, but missions remain relevant practicenecessary in operational context;and judicial contexts, for ensuring a consistent approach across the EPPO, for training or raising awareness to stakeholders;

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13. Recalls that, under Article 107 of Regulation (EU) 2017/1939, the translation services required for the administrative functioning of the EPPO at the central level shall be provided by the Translation Centre of the bodies of the European Union, but that urgent matters and investigative purpose allow the EDPs to decide on the modalities of translation, in accordance with applicable national law; observes that, in 2024, the costs occurred for translation and interpretation services decreased to EUR 3 491 000 corresponding to 10 % of the operational appropriations (compared to EUR 4 086 500, corresponding to 14 %, in 2023); notes that 88,8 % of CMS documents were machine translated (8,8 % above the performance indicator) and appreciates the EPPO’s efforts to enhance the cost-effectiveness of its translation services;

14. Observes that, in 2024, EPPO launched 15 calls for tenders and awarded 9 contracts (4 procedures were cancelled) and that 2 were open procedures while 12 were negotiated procedures; notes the intensive use of the EPPO framework contracts that resulted, in 2024, with the EPPO signing 288 specific contracts under existing framework contracts (compared to 234 in 2023), for a total of more than EUR 13 million (compared to EUR 11 million in 2023), while no contract was concluded by negotiated procedure without prior publication of a contract notice; remarks that in 2024, about 65 % of the contracts awarded directly by the EPPO were to SMEs, out of which all but 3 were from the same Member State; understands that the EPPO has developed its own purchasing capacity, has managed its own specific contracts in the implementation of existing framework contracts and has continued, in parallel, to operate through SLAs with other Union institutions, bodies, offices, and agencies and by joining inter-institutional contracts with varied market operators; appreciates that, in 2024, all of the EPPO’s procurement procedures and contract management activities were performed using digital IT tools, which is in line with the performance indicator target; reminds that the use of inter-institutional framework contracts allows maximising economies of scale, ensuring sound financial management on one side and compensating for the lack of available human resources on the other;

15. Appreciates the positive trend in the carry-over of appropriations from the previous exercise (2023), amounting to EUR 9 392 990 or 14,2 % (compared to EUR 10 969 680 or 24,4 % in 2022) out of which 96,9 % were consumed (compared to 84,8 % in 2023 and 90,8 % in 2022) and only 3,1 % were cancelled (compared to 15,2 % in 2023 and 9,2 % in 2022); notes that the carry-over of payment appropriations from 2024 to 2025 amounted to EUR 9 200 802, relatively stable compared to the above amount from 2023 to 2024; observes that the carry-overs were mainly due to appropriations committed towards the end of year for operational digital investments, and outstanding amounts on external service providers’ contracts;

16. Reiterates that the 2017 legislative financial statement (LFS) is no longer fit-for-purpose; stresses that the current LFS prevents the EPPO from running a mid-term budgetary review obliging to wait until the very end of the budgetary adoption process to have clarity on the resource level it can implement in the subsequent year; underlines that this limits the EPPO’s capacity to anticipate budget implementation preparatory activities and, in particular, affects the early launch of recruitment, delaying the progress towards full occupancy and the overall absorption capacity of the EPPO, as a matter of fact preventing to elaborate a comprehensive staffing strategy which is not the result of yearly budgetary negotiations ; points out that to achieve maximum flexibility in the development of an innovative organisation model as the EPPO is crucial; believes that the revision of the LFS is to be made irrespective of the changing of EPPO mandate, at the latest in the framework of the revision of Regulation (EU) 2017/1939 for which an evaluation has been launched by the Commission;

17. Appreciates the continuous strengthening of the EPPO’s administrative capacity, which is progressively addressing initial weaknesses resulting from the EPPO’s approach to limit the non-operational expenditure to essential level support services; maintains that the budgetary and human resources allocated to the EPPO are expected to be adequate to allow the efficient and successful carrying out of its mandate and the normal handling of the related administrative procedures; reminds that additional funding and strengthening of EPPO staffing is crucial to enable the EPPO to effectively combat VAT crime, protect the Union’s financial interests, and uphold the rule of law, which are key Union priorities; reiterates its call on the Commission to review the EPPO budgetary framework in close cooperation with the EPPO to find adequate ways to support it in its work; recalls that in the Amending Letter 1/2022, the Commission undertook to deliver to Parliament a staffing assessment by the end of 2023 and that this was emphasised in paragraph 5 of European Parliament resolution of 25 April 2024 on the Council position on Draft amending budget No 3 to the general budget 2024 reinforcing the European Public Prosecutor's Office following the accession of Poland and the expected participation of Sweden; regrets that the Commission has neither delivered such an assessment, nor consulted or communicated with the EPPO in respect of the staffing assessment, and yet that the Commission did not endorse the EPPO requests and did not engage in a dialogue for an updated assessment of the real needs; calls on the Commission to allocate additional resources, justified by the growing number of complex cases, and emphasises that these should not be dependent on the revision of Regulation (EU) 2017/1939 or of the EPPO mandate, but rather on the importance of the fight against organised crime and the protection of the Union’s financial interests in the next multiannual financial framework (MFF);

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Removed:18. Stresses that the modus operandi of criminal organisations is increasingly transnational, structured on the recurrent involvement of complex corporate structures used as a front and opaque legal vehicles deployed across multiple jurisdictions having unequal levels of enforcement of Union law; highlights the fact that the strategy of organised crime aims to fraudulently divert Union funds and conceal the proceeds of crime through money-laundering operations which affect the legal economy and also emerge as large-scale cross-border VAT fraud; points out that these criminal schemes systematically exploit regulatory fragmentation and procedural asymmetries between Member States, as well as the limitations inherent in the national focus of law enforcement and judicial authority; emphasises, in this specific regard, the added value of EPPO’s actions, which allow to fill the gap left by not coordinated national initiatives and that represent the most effective instrument to disrupt trans-national criminal activities and intervene in protection of the Union’s financial interests and the internal market;

Added:18. Reiterates that the budgetary and human resources allocated to the EPPO remain structurally insufficient in view of its rapidly increasing workload, in particular as regards RRF-related cases and the cross-border VAT fraud, which harms the internal market and fair competition; urges the Commission to engage in a dialogue with the EPPO to deliver the staffing assessment announced in Amending Letter 1/2022 on resources needs aligned with operational requirements; stresses that revising the outdated 2017 Legislative Financial Statement is necessary to reflect real workload indicators and cannot be made conditional on a change of mandate, given the expansion of the Union’s financial interests at stake; calls on the Commission to present, without delay, an updated staffing and funding assessment, prepared in close consultation with the EPPO and based on measurable workload indicators and cases; calls on the Commission to ensure that future budget proposals are based on updated workload indicators rather than outdated assumptions;

Removed:19. Notes the conclusions and recommendations made by the Court in its Review 02/2025 ‘Performance-orientation, accountability and transparency – lessons to be learned from the weaknesses of the RRF’; calls for a dedicated increase in funding within the next MFF to ensure the EPPO can continue to meet its objectives and obligations in face of the increased complexity of the financing instruments;

Added:19. Stresses that the modus operandi of criminal organisations is increasingly transnational, structured on the recurrent involvement of complex corporate structures used as a front and opaque legal vehicles deployed across multiple jurisdictions having unequal levels of enforcement of Union law; highlights the fact that the strategy of organised crime aims to fraudulently divert Union funds and conceal the proceeds of crime through money-laundering operations which affect the legal economy and also emerge as large-scale cross-border VAT fraud; points out that these criminal schemes systematically exploit regulatory fragmentation and procedural asymmetries between Member States, as well as the limitations inherent in the national focus of law enforcement and judicial authority; emphasises, in this specific regard, the added value of EPPO’s actions, which allow to fill the gap left by not coordinated national initiatives and that represent the most effective instrument to disrupt trans-national criminal activities and intervene in protection of the Union’s financial interests and the internal market; calls for concrete measures to strengthen the operational effectiveness of EPPO investigations, in particular by addressing structural obstacles that continue to hinder cross-border inquiries; stresses the need for a minimum level of procedural harmonisation among participating Member States in areas that directly affect the work of EDPs, including access to evidence, timelines for judicial authorisations, and rules governing investigative measures; urges Member States to grant the EPPO direct and secure access to key national database such as customs systems, tax registers, and beneficial ownership registries, while ensuring full compliance with data-protection requirement;

Removed:20. Notes that in 2024 the costs related to the provisions of Article 91(6) of Regulation (EU) 2017/1939 (exceptionally costly measures carried out by the national authorities and covered by the EPPO) remained marginal (0,1 % of the operational budget, compared to 0,4 % in 2023); understands that, in 2023, a first financing agreement was signed in the framework of a pilot for the reimbursement of claims made under Article 91(6) of Regulation (EU) 2017/1939, to cover the cost of the measures carried out at national level on behalf of the EPPO and that the Court has audited the item in 2023 and had deemed it legal and regular; believes that this provision offers EPPO the opportunity to intervene effectively in trans-national investigative scenarios where a Member state might hesitate to deploy its resources, in consideration of an unbalanced result of the cost-benefit analysis; calls on the Commission to explore how the resort to this option by Member states and EPPO could become more strategically effective;

Added:20. Notes the conclusions and recommendations made by the Court in its Review 02/2025 ‘Performance-orientation, accountability and transparency – lessons to be learned from the weaknesses of the RRF’; calls for a dedicated increase in funding within the next MFF to ensure the EPPO can continue to meet its objectives and obligations in face of the increased complexity of the financing instruments, which may expose Union funds to a higher risk of fraud and mismanagement;

Added:21. Notes that in 2024 the costs related to the provisions of Article 91(6) of Regulation (EU) 2017/1939 (exceptionally costly measures carried out by the national authorities and covered by the EPPO) remained marginal (0,1 % of the operational budget, compared to 0,4 % in 2023); understands that, in 2023, a first financing agreement was signed in the framework of a pilot for the reimbursement of claims made under Article 91(6) of Regulation (EU) 2017/1939, to cover the cost of the measures carried out at national level on behalf of the EPPO and that the Court has audited the item in 2023 and had deemed it legal and regular; believes that this provision offers EPPO the opportunity to intervene effectively in trans-national investigative scenarios where a Member state might hesitate to deploy its resources, in consideration of an unbalanced result of the cost-benefit analysis; calls on the Commission to explore how the resort to this option by Member states and EPPO could become more strategically effective, and to provide the EPPO with the necessary resources to this end;

Internal management and internal control - performance

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Changed:21.22. Is aware that the College is responsible for the general oversight of the EPPO’s activities and for taking decisions on strategic matters and that in 2024 it met 20 times adopting 70 decisions; believes that College’s decisions ensure coherence, efficiency and consistency in the prosecution policy of the EPPO throughout the participating Member States; welcomes the College’s decisions adopted in 2024 on the working arrangements establishing the methods of cooperation with Parliament, the European External Action Service (EEAS) and the revised annexes of the agreement with the Commission; observes that the College also amended rules on other Staff put at the disposal of the European Public Prosecutor’s Office but not employed by it (National European Delegated Prosecutors’ Assistants (NEDPAs)) and established a housing allowance for certain categories of staff housed in Luxembourg; notes that, as appointing authority, the College appointed EDPs in Austria, Belgium, Bulgaria, France, Germany, Greece, Italy, Netherlands, Poland and Sweden, selected members of the Ethics Committee and members of the Disciplinary Board for EDPs as well as the Administrative Director ad interim; notes the College’s decisions in 2024 on budget-related matters, such as the adoption of the EPPO’s Single Programming Document 2024-2026, the final accounts for the financial year 2023, EPPO’s 2023 Consolidated Annual Activity Report, the Single Programming Document for the period 2025-2027, the budget 2025 and the corresponding financing decision for the year 2025 and amendments to the budget and the Single Programming Document; the College also adopted Security Rules applicable to the Digital Communication and Information Systems of the EPPO, and the Security Strategy 2024-2028.2024-2028;

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23. Notes that in 2024 the Permanent Chambers held 491 meetings, to monitor and direct the investigations and prosecutions conducted by the EDPs, allocated randomly immediately after registration, and to ensure the coordination of investigations and prosecutions in cross-border cases, the coherence, efficiency, and consistency in the EPPO’s prosecution policy throughout the participating Member States by implementing the decisions adopted by the College;

24. Considers that, overall, the internal control systems in force are effective; notes that key performance indicators (KPIs) have been established to monitor on a quarterly basis the implementation of the annual and multi-annual work programmes; observes that the 2024 assessment of the internal control framework (ICF) confirmed measurable progress in the deployment of internal controls and that the Risk Assessment exercise for year 2025 was carried out with dedicated workshops at operational and administrative levels, followed by an updated risk management policy approved by the College on 26 February 2025;

25. Maintains that the Internal Audit Service of the Commission (IAS) and the Internal Audit Capability of the EPPO (IAC) should coordinate their actions with a view to advising and assisting the EPPO in the establishment of its main core processes and the achievement of its objectives; observes that there were no joined advisory initiatives between the IAS and the IAC in 2024; welcomes that, after the appointment in September 2024 of the new Head of the IAC, efforts have been focused on follow-up to the previous audit recommendations, on drafting the IAC standard operating procedures (SOP), and on preparing and submitting for approval of the Strategic Audit Plan 2025-2027 to the College;

26. Recalls that in 2023, the IAS initiated a limited review of the EPPO’s building blocks of assurance, which was finalized in 2024; notes that all recommendations were addressed, resulting in further enhancements to the assurance framework and governance processes, including the formalisation of procedures, improved documentation and digitalization of planning and programming processes, refinements to the ICF, and a strengthened approach to risk management; observes that, from November 2024 until the end of January 2025, the IAS conducted an advisory engagement on IT in view of the IT autonomy in the EPPO and that the advisory final report was issued at the end of the year 2024; notes that in 2024 external and internal audit recommendations and discharge requirements continued to be regularly monitored;

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Changed:26.27. Notes that the EPPO continued its efforts to set in place a system to monitor efficiency gains and cost savings, and notes that in 2024 it launched a review of the strategic and operational planning and monitoring processes (to increase the ability to contribute to EPPO activities’ strategic focus and to achieve sustained high implementation or absorption rate of available resources) and established a mid-term human resources strategic planning, to allow for the increased fulfilment of the establishment plan and addressing staffing gaps through hiring or professional growth; observes that, in this regard, the EPPO also established careerstarted pathsworking andon more specific job description frameworks to align staff with strategy and contribute to maintaining high staff engagement;

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28. Notes that the benchmarking exercise carried out by the IAC with the EPPO human resources mapped the EPPO staff adopting the same principles as in other organizations; observes that by comparing the deployed human resources of the EPPO with a set of other Union entities and national prosecution offices against a standardised set of pillars, it allowed the identification of gaps in staff allocation in comparison to other Union institutions; understands that this model has been used as a reference for EPPO budget requests, but only in respect of administrative and support functions, because the unique nature of the EPPO core activities prevents its use as a specific reference for the operational area of the EPPO;

29. Appreciates the EPPO’s efforts to improve the internal control environment; remarks that in 2024 a set of standards of conduct, processes, and structures have been established; calls on the EPPO to address as soon as possible the still outstanding issues, concerning the conflict of interests policy, learning and development policy, internal mobility policy, vulnerability and patch management policy, succession planning and exit procedures;

30. Notes that the 2024 internal controls’ self-assessment was based on the assessment of the internal control indicators and of the deployment of the EPPO’s Anti-fraud Strategy 2023-2025, on the results of the EPPO’s risk management policy and of the ex-post controls; appreciates that, for what concerns the assessment of the internal control components, out of 71 compliance criteria, 55 (77 %) have been fully implemented, while 15 (22 %) are partially implemented and require further development and one criterion only (1 %) has not yet seen significant implementation; observes that among the 11 open findings, 10 are follow-up items from previous assessments, while 1 represents a newly identified issue in 2024, while four deficiencies highlighted in the 2023 assessment have been fully remediated;

31. Endorses the EPPO’s continued efforts to improve risk controls and proactively address both existing and emerging risks; believes that the EPPO control activities provide adequate level of assurance on risks mitigation and notes that, in 2024, the internal control officer led a series of workshops with the relevant managers to assess risks, including emerging and fraud-related risks, resulting in the identification of new emerging risks, mainly in digital services, security and operations, that reflect the evolving risk landscape;

Change 18

Changed:31.32. Notes that the EPPO’s anti-fraud strategy 2023-2025, updated in 2023 as per the requirements set by Regulation (EU) 2017/1939 and the EPPO’s Financial Rules, is linked to an action plan that is part of the EPPO internal control environment, is monitored annually and has been reviewed in 2024; observes that in 2024, implementation focused on awareness-raising with 17 training sessions organised on the EPPO’s ethical framework, the anti-fraud strategy and the code of good administrative behaviour, ensuring broad staff participation; welcomes the adoption of the whistleblowing process, occurred in early 2025; remarks that, pending the adoption of a comprehensive conflicts of interest policy, obligations and declaration procedures remain in place for senior management and staff involved in financial circuits, procurement and recruitment; calls for the swift adoption of a comprehensive conflicts of interest policy in order to ensure public trust in the EPPO’s integrity framework;