What changed between the draft committee report and the plenary report

Removed:H. whereas Eurofisc, a multilateral network of Member State tax liaison officials, has proven effective as a decentralised early-warning mechanism; whereas its transaction network analysis (TNA) tool generates actionable intelligence on suspicious cross-border VAT chains; whereas under the Commission proposal to amend Council Regulation (EU) No 904/2010, the EPPO and OLAF would be granted direct, centralised access to the VAT Information Exchange System (VIES) and Eurofisc, within their respective mandates and subject to data protection safeguards as noted by the European Data Protection Supervisor;

Added:J. whereas the detection of complex cross-border VAT fraud also relies on whistleblowers and investigative journalists, as reflected by the fact that the large majority of crime reports processed by the EPPO originate from private parties rather than institutions; whereas the effective protection of reporting persons under Directive (EU) 2019/19377 is therefore an integral part of the EU’s AFA;

Added:K. whereas Eurofisc, a multilateral network of Member State tax liaison officials, has proven effective as a decentralised early-warning mechanism; whereas its transaction network analysis (TNA) tool generates actionable intelligence on suspicious cross-border VAT chains; whereas under the general agreement to amend Council Regulation (EU) No 904/2010 reached in May 2026, the EPPO and OLAF would be granted direct, centralised access to the VAT Information Exchange System (VIES), within their respective mandates and subject to data protection safeguards as noted by the European Data Protection Supervisor;

Removed:J. whereas the ViDA package requires e-invoicing and real-time digital reporting to be introduced for intra-Community business-to-business transactions by 2030;

Added:M. whereas disparities in the levels of administrative sanctions applied by Member States in respect of VAT fraud on imports, create conditions that enable operators to exploit the jurisdiction with the lowest penalties;

Removed:K. whereas the AFCOS established in each Member State in line with Article 12(a) of the OLAF Regulation3 currently serve as the primary national interface for cooperation with OLAF and the EU’s anti-fraud architecture (AFA) internal layer; whereas the effectiveness of AFCOS varies significantly across Member States; whereas the revision of their role is expected to be tackled as part of the revision of the OLAF Regulation;

Added:N. whereas the ViDA package requires e-invoicing and real-time digital reporting to be introduced for intra-Community business-to-business transactions from July 2030;

Changed:6.9. Stresses that granting the EPPO and OLAFOLAF, direct,in automatedthe andexercise centralisedof their mandates, access to VIES, EurofiscVIES and the Central Electronic System of Payment Information is– essentialas indicated in the Opinion of Parliament’s Committee on Budgetary Control on the proposal for ensuringa Council regulation amending Regulation (EU) No 904/20108 – ensures the effective countering of cross-border carousel fraud; calls on the Commission to issue clear procedural guidelines to the relevant bodies to ensure legal certainty and to prevent any obstacle to an effective, and where appropriate, simultaneous deployment of the administrative and criminal investigation tools; insistswelcomes thatthe general agreement reached in May 2026 on the amended Regulation (EU) No 904/2010, ifand adopted,insists that it must be implemented with full respect for the distinct legal frameworks applicable to OLAF’s administrative mandate and the EPPO’s criminal enforcement mandate, in line with the European Data Protection Supervisor’s Opinion 1/2026 of 7 January 2026;

Removed:7. Emphasises that cross-border cooperation on VAT fraud requires not only data exchange at EU level, but also robust bilateral and multilateral cooperation mechanisms among the Member States’ tax administrations;

Added:10. Calls on the Commission, in the context of the post-2027 MFF, to ensure adequate funding and staffing for OLAF and the EPPO in order to strengthen data analysis capacities, operational coordination, investigations and recovery actions relating to VAT fraud, and for Eurofisc, through the Single Market and Customs Programme;

Removed:8. Calls on the Commission to support actions aiming to reinforce the operational effectiveness of Eurofisc; insists that Eurofisc’s TNA tool should be further developed with AI-assisted pattern recognition capabilities, enabling real-time cross-border detection of suspicious VAT transaction chains; invites the Member States to strengthen their mutual cooperation within Eurofisc and ensure the timely and complete provision of transactional data;

Added:11. Emphasises that cross-border cooperation on VAT fraud requires not only data exchange at EU level, but also robust bilateral and multilateral cooperation mechanisms among the Member States’ tax administrations, including through direct exchange of information;

Removed:10. Acknowledges that the Reverse Charge Mechanism, as provided for under Articles 199a and 199b of the VAT Directive4, has demonstrated clear effectiveness as a targeted anti-fraud instrument by removing the structural opportunity for missing traders to collect VAT and disappear before remitting it; stresses that the mechanism should be retained and, where appropriate, extended; calls on the Commission to bring forward in good time a proposal to extend and, where the evidence warrants, to broaden the scope of Articles 199a and 199b beyond 2026;

Added:17. Notes that EPPO investigations have shown that professional enablers – such as accountants, lawyers and brokers – have a role in the setting-up of shell company chains that make carousel fraud scalable; calls on the Commission to enforce full transposition of the beneficial ownership provisions of the sixth Anti-Money Laundering Directive9, including on the role of professional enablers;

Removed:11. Notes with concern that crypto-asset transactions are increasingly used by organised criminal networks as a layering mechanism for the proceeds of VAT carousel fraud, exploiting the pseudonymity and cross-border transferability of crypto assets to rapidly move and conceal fraudulent gains before detection; welcomes the entry into force of Council Directive (EU) 2023/22265 (DAC8), which requires crypto-asset service providers to report crypto-asset transaction data to national tax authorities from 2026 onwards; calls on the Commission to ensure, as part of the AFA review, that DAC8 reporting data is accessible to Eurofisc, OLAF and EPPO under their respective mandates for the purposes of VAT fraud investigation; calls on the Commission to assess the extent to which data reported by crypto-asset service providers has helped to identify VAT fraud proceeds and to report its findings to Parliament and the Council by 2028;

Added:18. Acknowledges that the Reverse Charge Mechanism, as provided for under Articles 199a and 199b of the VAT Directive10, has demonstrated clear effectiveness as a targeted anti-fraud instrument by removing the structural opportunity for missing traders to collect VAT and disappear before remitting it; stresses that the mechanism should be retained and, where appropriate, extended; calls on the Commission to bring forward in good time a proposal to extend and, where the evidence warrants, to broaden the scope of Articles 199a and 199b beyond 2026;

Changed:14.24. Welcomes the Commission’s AFA review as a timely and comprehensive initiative to map the existing architecture, identify loopholes and promote coherence across the entire anti-fraud cycle; underlines that this review is an opportunity to establish a genuinely integrated EU anti-fraud framework in time for the post-2027 MFF; considers that, in view of the considerable financial impact of cross-border fraud on revenue, in particular VAT and customs duties, the protection of the EU’s revenue should be one of the strategic priorities within the context of the review;

Removed:15. Calls on the Commission to ensure that the 2026 communication resulting from the AFA review is accompanied by a concrete legislative package covering the justifiably expected revisions of the OLAF Regulation and of the EPPO Regulation6 and, where appropriate, consistent further amending of the Europol Regulation7, the Eurojust Regulation8, Eurofisc’s governance framework, and the PIF Directive; stresses that Parliament expects the AFA review to result in agreed-upon binding legislative change, not merely coordination guidelines;

Added:25. Stresses that the AFA revision should suggest measures to prevent a lack of judicial independence, ineffective prosecution services and insufficient anti-corruption safeguards, in such a way to prevent, detect and recover VAT fraud; points out that where structural vulnerabilities create heightened risk for VAT fraud losses, targeted recommendations are required and recalls that the Conditionality Regulation12 allows measures to be taken where deficiencies in tackling tax fraud, tax evasion, corruption and other breaches affect the collection of EU revenues;

Added:26. Recognises the particular difficulty of recovering VAT revenue lost to fraudulent activity; underlines, therefore, the importance of preventive and precautionary measures and urges the Commission, in the context of the AFA review, to explore targeted and risk-based approaches, such as sampling and statistical extrapolation of the results of a limited number of controls to the overall population of affected transactions, and the preventive blocking of VAT numbers suspected to be used for fraudulent purposes;

Added:27. Calls on the Commission to ensure that the 2026 communication resulting from the AFA review is accompanied by a concrete legislative package covering the justifiably expected revisions of the OLAF Regulation and of the EPPO Regulation and, where appropriate, consistent further amending of the Europol Regulation, the Eurojust Regulation, Eurofisc’s governance framework, and the PIF Directive; stresses that Parliament expects the AFA review to result in agreed-upon binding legislative change, not merely coordination mechanisms or guidelines;

Changed:17.30. Urges the Commission to use the AFA review to address the governance deficit identified by ECA Special Report 26/2025, the lack of accountability and the missing wider overview of the strategies and priorities of the individual components; calls for the establishment of structured, regular reportingreporting, which should include performance indicators, on follow-up actions taken in response to OLAF recommendations and judgments in EPPO cases; stresses that well targeted indicators are essential to support evidence-based policymaking, improve accountability and enable meaningful parliamentary scrutiny of the EU’s AFA; recalls the importance of exchanging best practice between the Member States;

Added:31. Calls on the Commission to ensure that the AFA review establishes structured operational cooperation between the EU anti-fraud bodies and AMLA, reflecting the close link between VAT fraud and money laundering; takes the view that beneficial ownership transparency, underpinned by AMLA’s access to central registers under Directive (EU) 2024/1640, could be a valuable early-warning tool for the early identification of shell entities used in missing trader networks;

Added:33. Reiterates Parliament’s long-standing call for a single, integrated and interoperable information and monitoring system for EU spending, which should include data mining and risk-scoring tools; insists that the use of such a system must be a precondition for accessing EU funds under the next MFF; demands that all Commission and national databases used for the management and monitoring of EU funds be directly accessible to the ECA, without prior aggregation or modification, in order to safeguard the independence and effectiveness of audits;

Added:34. Calls for the systematic and strengthened use of the Early Detection and Exclusion System (EDES) under the next MFF; stresses that economic operators involved in fraud, corruption, serious irregularities, including VAT-related irregularities, or serious breaches of contractual obligations, must be effectively excluded from EU funding across all programmes and delivery models, including performance-based instruments; regrets the fragmented use of exclusion mechanisms and the lack of interoperability between EDES and national systems; stresses that effective exclusion mechanisms are essential to prevent the repeated misuse of EU funds and to ensure a credible EU anti-fraud framework;

Added:37. Urges the EPPO and OLAF to devote adequate attention to, and allocate sufficient resources for, serious VAT cases that would recover larger amounts of lost revenue for the EU budget;

Added:38. Emphasises the importance of the cooperation between Europol and OLAF in forensic analysis operations, and calls for clearer rules governing such cooperation to enable synergies in the area of forensics in order to optimise coordination; calls, furthermore, for strengthened analytical cooperation between OLAF and Eurofisc in combining and analysing customs and VAT data for the detection of cases of customs and VAT fraud; underlines the importance of OLAF being granted full access to the EU Customs Data Hub in order to improve its detection and prevention work;

Removed:23. Reiterates its long-standing call for the Commission to assess whether the EUR 10 million threshold under Article 2 of the PIF Directive should be lowered, because it may fail to capture MTIC schemes structured across multiple Member States, and, if appropriate, to propose an amendment addressing this issue;

Added:41. Stresses the EPPO’s crucial role in the protection of the EU’s financial interests and as an essential component of the EU’s AFA competent for investigating, prosecuting and ensuring justice for crimes affecting the EU budget, such as fraud, corruption and cross-border VAT fraud;

Removed:24. Is aware of the important role the EPPO plays in protecting the EU’s financial interests; believes that the ongoing revision of the EPPO Regulation should confirm the EPPO’s mandate, allowing for the necessary focus on the criminal misconduct that affects the EU’s budget, and calls for steps to ensure that the EPPO, within its operational capacity, is able to handle complex, multi-jurisdictional VAT carousel investigations;

Added:42. Stresses that the cross-border nature of carousel fraud means that any Member State not participating in the EPPO leaves an exploitable gap in the EU’s prosecutorial coverage; takes note of the Commission decision13 confirming Hungary’s participation in the EPPO, and of Ireland’s stated intention to bring forward all necessary legislation to join the EPPO;

Removed:27. Notes that the recovered amounts that are routed to the EU’s budget following their seizure by the EPPO and confiscation by national courts is limited; underlines that the final recovery of lost funds technically falls outside the EPPO’s operational mandate, and that the EPPO’s remit ends once a conviction and confiscation order are secured; believes that a specific provision should be added to clarify roles and responsibilities, taking into account the need to involve EU authorities in the recovery process, without prejudice to the legitimate rights and expectations of the parties involved and who suffered damage; maintains that the budgetary and discharge authority needs to fully understand the financial impact of the confiscations and their execution;

Added:47. Calls on the Commission, in cooperation with the EPPO and the Member States, to establish a clear and binding framework ensuring that assets and proceeds confiscated following EPPO investigations are effectively returned to the EU budget, in full or in part, and duly recorded as EU revenue; underlines that such a mechanism would strengthen deterrence, reinforce the credibility of EU anti-fraud efforts, contribute to the protection of the EU’s financial interests and ensure that recovered funds can be redeployed to finance EU priorities; stresses that transparency and reporting obligations on the amounts confiscated, returned and reallocated must be guaranteed, with full information provided to Parliament as budgetary and discharge authority;

Added:48. Notes that the recovered amounts that are routed to the EU’s budget following their seizure by the EPPO and confiscation by national courts is limited; underlines that the final recovery of lost funds technically falls outside the EPPO’s operational mandate, and that the EPPO’s remit ends once a conviction and confiscation order are secured; believes that a specific provision should be added to clarify roles and responsibilities and enhance coordination between EU and national authorities in supporting the recovery process, while fully respecting the competences of the Member States and without prejudice to the legitimate rights and expectations of the parties involved and the parties who suffered damage; maintains that the budgetary and discharge authority needs to fully understand the financial impact of the confiscations and their execution;

Added:50. Calls for Europol’s operational capacity to be strengthened through increased staffing and technical resources in order to enable it to be able to handle the large number of VAT fraud cases;

Added:52. Calls for Europol, in the revision of the Europol Regulation, to be given direct access to Eurofisc’s TNA tool, network maps of suspected fraud chains and list of high-risk traders, as well as other data collected by Eurofisc; notes that Europol does not currently have direct access to Eurofisc systems, that it cannot even query Eurofisc databases independently and that it does not receive Eurofisc data automatically and instead only receives information on a case-based arrangement; notes that this hampers investigations and causes time delays; calls for this to be reflected in the revised AFA;

Changed:33. Calls56. onWelcomes the CommissionCommission’s toannouncement createtasking OLAF with creating a structured monitoring mechanism on the follow-up actions taken in response to EPPO convictionsnotifications under Article 103(2) of the EPPO Regulation and OLAF administrative recommendations in VAT-related cases, specifying the amounts actually recovered versus the amounts recommended for recovery,recovery; calls for adequate resources to be allocated to OLAF for this task, and asks that it report annually to Parliament and the Council on this matter;

Added:57. Calls on the Commission to propose a clear legislative act ensuring that amounts recovered from fraudsters following EPPO investigations and related to damages to the EU’s financial interests, are appropriately returned to the EU budget;

Changed:34.58. Notes with concern the findings of ECA Special Report 08/2025 on VAT fraud on imports, which identified systemic failures in the enforcement of VAT obligations upon importation; stresses that fraudulent under-declaration of customs value, the misuse of VAT exemptions upon importation, and the infiltration of e-commerce flows from non-EU countriescountries, including through platforms systematically undervaluing shipments in order to heavily misuse low-value exemptions, constitute a growing vector of revenue loss that is closely interconnected with intra-Community VAT fraud; underlines the need to improve the cross-border exchange of information between customs and VAT authorities;

Changed:35.59. Calls on the Commission to address, in the AFA legislative package,address the vulnerabilities identified in Customs Procedures 42 and the Import One-Stop Shop; insists that the technical architecture governing the EU customs data hub must be designed, from the outset, to ensure full real-time interoperability with Eurofisc’s TNA tool and with the investigative systems of OLAF and the EPPO under their respectivenational mandates;systems; calls on the Commission to ensure the automated cross-referencing of customs declaration data against VAT registration records in VIES and against Eurofisc risk indicators;

Added:The protection of the European Union's financial interests is a shared responsibility that requires a coordinated, modern and effective anti-fraud framework. VAT fraud, particularly cross-border carousel fraud, continues to deprive both the Union and its Member States public revenues, while distorting competition within the Single Market and increasingly serving as a source of financing for organised criminal networks. The evolution of these criminal schemes demonstrates that fraudsters exploit legal, operational and technological gaps that no single national authority can effectively address alone.

Added:This report therefore calls for a strengthened and more coherent EU Anti-Fraud Architecture in the context of the post-2027 Multiannual Financial Framework. It recognises the complementary roles of OLAF, the European Public Prosecutor's Office, Europol, Eurojust and Eurofisc, while highlighting that closer cooperation, timely information exchange and interoperable digital systems are indispensable for detecting, investigating and prosecuting complex VAT fraud. Particular emphasis is placed on enhancing cooperation between customs and tax authorities, and on making better use of advanced digital technologies, including real-time data analysis.

Added:The report also stresses that effective fraud prevention requires not only stronger investigative capacities but also a governance framework that ensures accountability, clear allocation of responsibilities and measurable performance. The forthcoming review of the EU Anti-Fraud Architecture should therefore be accompanied by concrete legislative proposals addressing identified weaknesses and reinforcing cooperation among all anti-fraud actors.

Added:The report also underlines the importance of preserving and, where justified, extending the Reverse Charge Mechanism as one of the most effective targeted instruments for combating carousel VAT fraud. At the same time, the report stresses that the Union must draw lessons from previous large-scale VAT fraud schemes affecting the EU Emissions Trading System (ETS1), which resulted in billions of euros in revenue losses. In light of the forthcoming implementation of ETS2, it is essential that the Commission identifies potential vulnerabilities at an early stage and incorporates effective anti-fraud safeguards into the new system before it becomes fully operational.