Changes from report parliamentary committee draft to plenary report

Change 19

Changed32.33. Notes that, in respect of its investigative and prosecutorial functions, the EPPO redesigned the internal processes in place to support its investigations,investigations amongby, othersinter byalia, developing tools to improve the efficiency of its processing of information and connectivity with multiple partners, developing dedicated software, improving the quality of translation services and reducing the human translation needs and associated cost,costs, exploring ways in which AI can be used to better manage the vast volumes of information it is processing, assessing them both from a technicaltechnical, legal and legal/ethicalethical perspective; appreciates, in this regard, the EPPO’s efforts in the setting up KPIs linked to its peculiarparticular business model; maintainswelcomes itsinitiatives remarkto improve reporting on results and underlines the needimportance of timely, accurate and transparent reporting to Parliament to demonstrate the impact of the EPPO’s actions with regard to the protection of the Union’s financial interests; maintains that there is still a need to report on the amounts seized, confiscated and eventually recovered to the Union’s budget, whose safeguard is ultimately the raison d'être of the Union’s anti-fraud architecture of which the EPPO is an important component;

Change 20

Changed33.34. Understands that monitoring and follow-up actions, including reporting on the recovery results, are not in the EPPO’s remit and require resources and specific prerogatives that are not part of the EPPO’s mission;prerogatives; reiterates its requestcall toon the Commission to support the EPPO in identifying indicators linked to the achievement of that essential task, and to set out in the framework of the revision of the anti-fraud architecture the most appropriate features to ensure a continuous flow on data and information to allow proper analysis; stresses that an enhanced monitoring system and more data of good granularitydetailed anddata, aggregatedset inout clusteraccording perto typologytype of misconduct, sector of interest or geographical area, are necessary to identify patterns of fraud and would make more tangible the impact of the EPPO’s investigations;

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35. Notes that the EPPO has adopted its business continuity plan; encourages the EPPO to adopt also its digital strategy and the vulnerability and patch management policy (both currently under development); observes that the EPPO is still progressing on KPI development, which are not yet established for a specific area, and on a structured evaluation of risk tolerance levels;

36. Stresses the sharp and continuous increase in crime reports submitted to the EPPO, that reached 6 547 by 31 December 2024 (56 % more than in 2023 when they were 4 187), resulting in the opening of 1 504 investigations (almost 10 % more than in 2023, when EPPO opened 1 371 investigations representing the 58 % more than in 2022); observes that this increase has been driven mainly by reports from private parties (4 623, which is 85 % more than in 2023 and significantly above the performance indicator range), as well as from national authorities (1 760, which is 12 % more than in 2023); regrets that among Union institutions, bodies, offices and agencies, the EPPO received in 2024 only 113 crime reports (108 in 2023), the largest amount of them (59) from OLAF (72 in 2023); maintains that, when compared to the increasing trend of irregularities and frauds, the detection level is still suboptimal, suggesting that no significant improvement in terms of detection and reporting has been achieved;

37. Underlines that on 31 December 2024, the EPPO had 2 666 active investigations, (around 38 % more than in 2023 when they were 1 927) and that the percentage of cross-border cases, concerning several countries, was stable (29 % in 2024 and 28 % in 2023);

38. Stresses the increasing estimation of damage, that the EPPO indicates at the end of 2024 to be EUR 24,8 billion (EUR 19,27 billion in 2023 compared to EUR 14,1 billion in 2022 and EUR 5,4 billion in 2021) out of which the 53 % would concern VAT fraud (EUR 13,15 billion);

Change 21

Changed38.39. Emphasises the growing performance level of the EPPO as confirmed by the increasing number of indictments (205 in 2024 compared to 139 in 2023, 87 in 2022 and 5 in 2021) and of freezing orders obtained (in 2024 for EUR 2,42 billion compared to EUR 1,5 billion in 2023, EUR 359,1 million in 2022 and EUR 147 million in 2021); regrets that the absence of a clear and enforceable framework for the monitoring and reporting of confiscated and recovered amounts continues to prevent a full assessment of the budgetary impact of EPPO investigations; reiterates its call for legislative and budgetary solutions to ensure that amounts recovered following EPPO-led investigations are effectively traced, reported and returned to the Union budget; observes that 102 criminal cases were concluded in 2024 with a court conviction (48 cases in 2023 compared to 20 cases in 2022); regrets that the lack of clear regulatory framework has prevented EPPO from providing updated and reliable data on confiscation for the year 2024 (reminding that in 2023 EUR 60 million were confiscated compared to EUR 2 million in 2022);

Change 22

Changed39.40. Expresses its concern about the number of investigations opened onregarding the implementation of the RRF; underlines that by the end of 2024, the EPPO was handling 311 active cases related to the NextGenerationEU, out of which 307 stemmed from the RRF (233 at the end of 2023), corresponding to approximately 17 % of all active expenditure fraud investigations and for thean estimated damageamount of EUR 2,8 billion in damages to the Union’s financial interests of EUR 2,8 billion, (corresponding to 30 % of the overall estimated damage for expenditure fraud, compared to 25 % in 2023); observes that the EPPO’s investigations into fraud affecting the RRF reveal significant disparities across Member States, reflecting variations in the allocation of funds, crime detection capabilities, and the diverse nature of fraud schemes perpetrated; regretsis worried by the lack of an obligation on Member States to report RRF cases to the Commission through the irregularity management system (IMS), preventing de facto the structured monitoring and structuredrisk analysis of the RRF cases; stresses the importance of cooperation among national authorities, the EPPO and the Commission to improve structured reporting; is worried that reporting of cases from Union institutions, including the Commission, accounts for not even 3 %, raising further concerns onregarding the Commission’s oversight ability towith oversightregard to the RRF; calls on the Commission to address these deficiencies as a matter of urgency and, in cooperation with the EPPO, to improve interoperability of reporting systems and clarify roles to ensure robust monitoring of RRF-related irregularities;

41. Reiterates that EPPO's workload, which was initially underestimated, has significantly increased and is expected to continue growing particularly on RRF-related cases; understands that the EPPO communicates the criminal patterns detected in its investigations to Member States, the Commission and the Recovery and Resilience Task Force, with the objective of enhancing prevention and detection and mitigate the risk of fraud; notes that while the cases under investigation span in diverse sectors and RRF-specific initiatives there is the common trait of organised crime involvement every time the fraudulent scheme is set up on a large-scale and ensures high-value illicit profit;

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Changed41.42. Observes that around 6 % of the offences investigated by the EPPO by the end of 2024 concerned participation in a criminal organisation, which focused its criminal activity on the commission of criminal activity provided for in Directive (EU) 2017/1371 (PIF-related crime); reiterates that only the enhanced cooperation amongst the components of the anti-fraud architecture can effectively counter such fraudulent conduct and safeguard the achievements of the RRF’s objectives and of the Union’s policies at large; believes that only the joint coordinated deployment of judicial and administrative measures can protect the financial interests of the Union and reiterates its call on the Commission to provide adequate support to the EPPO on how to foster the adoption of the remedial measures which follow the EPPO’s independent investigation and prosecution of crimes affecting the RRF; calls for a reinforced coordination framework involving the EPPO, the Commission and the Member States, aimed at strengthening RRF fraud investigation and prevention, ensuring systematic follow-up of EPPO investigations and improving the exchange of relevant information; urges the Commission to keep the Union’s budgetary authority informed regarding the outcome of its action;

Human resources, staff well-being and equality

Change 24

Changed42.43. Notes that in 2024 the upward trend in the number of staff has been maintained reaching a total of 258 at the end of 2024 (from 58 in 2020, to 122 in 2021, 217 in 2022 and 238 by the end of 2023) with an increase a little higher than 9,5 %; praises the high occupation rate, around to 96 % (it was around 93 % end 2023) for all categories excluding seconded national experts, where it is at 83 %; observes that in 2024 the number of external service providers (32) and intra-muros (10) remained almost unchanged (compared to 34 and 9, respectively, in 2023).2023);

44. Appreciates that, in 2024, the EPPO administrative capacities in the recruitment area improved and that 50 selection procedures were supervised (in 2023 there were 24 selection), along the onboarding of 47 new members of staff (compared to 45 in 2023), 6 seconded national experts, and 6 trainees; acknowledges the challenging recruitment conditions in Luxembourg, linked to the high cost of living, in particular for the hiring of lower grades, for which the EPPO underlines the small number of applicants, a high rejection rate of the offers submitted to the successful candidates and a chronic very limited talent pool with small offer of specialised skills; underlines that the more limited teleworking opportunities, in comparison to what offered by other employers, could also result in making the positions less attractive; reiterates its call on the EPPO and the Commission to identify further measures that could enhance the EPPO's attractiveness for highly skilled professionals with international experience;

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Changed44.45. Is aware that the EPPO requested 419 posts in its establishment plan by the end of 2024 and that 289 posts were instead granted; stresses that the posts requested were 513 in 2025 and that, again, only 307 were granted, increasing the gap between the resources needed and those allocated; agrees with the EPPO that without the requested increase of staff the EPPO’s ability to fulfil its mandate efficiently, in line with the Union citizens’ expectations, is considerably reduced, the backlog of cases will continue to increase, the administration of justice in cases of fraud affecting the Union’s financial interests will be delayed, and the fight against organised crime groups, stealing from public finances and damaging European economies, will be far less efficient; notes the EPPO’s remarks about the increasing tendency of working time-credit being accumulated by staff as a consequence of the limited resources and of the increased individual workload, which potentially generates individual resilience risks as well as potential increased turnover; underlines, therefore, the necessity for the EPPO to be equipped with adequate staffing and budgetary resources in line with the tasks entrusted to it;

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Changed45.46. Appreciates the fact that the allocation of staff across the EPPO is oriented towards maximising performance and notes that by end 2024, out of 412 posts, 319 were dedicated to the operational activities, that is over 77 % (compared to 80 % in 2023), against 18 % dedicated to administrative tasks (compared to 14 % in 2023) in line with the EPPO’s approach to prioritise the operational activities; observes, however, that the percentage of staff divertedallocated towardsto bureaucratic-administrativeadministrative and support tasks has increased; understands that this mainly is a consequence of some recent change in the Commission policy, such as the discontinuation of the IT services, that has resulted in obliging the EPPO to handle the most crucial tasks with its own staff, which was therefore assigned to non-operational positions;

Change 27

Changed46.47. Maintains that the EPPO’s workload perspectives will require further resources; points out that the constantly increasing number of RRF-related cases and VAT fraud, and the complexity of the investigations involving organised crime cross-border operations, will also bring increasing workload on the administrative and central support functions which are inextricably linked to EPPO’s operations; is concerned by the risk of underestimating the needs of the EPPO and overestimating its capacities to react effectively to increasing demands;

48. Remarks that by December 2024, the percentage of staff voluntarily leaving the EPPO (since the start of the year) amounted to 2,8 %, marking a limited turnover of 6 staff in 2024 (compared to 11 in 2023, or 4,62 %) mainly related to the choice of the interested staff to move to other Union entities, locally or abroad, offering better conditions of engagement; observes that adequate attention to staff well-being is also confirmed by the many initiatives planned in 2024 (and then in large part executed in 2025) related to the housing allowance implementation, to training and professional-development which allows the EPPO to offer a more competitive package in line with those of the other institutions in Luxembourg; notes that the number of long-term sick leave is also very limited;

49. Notes that in 2024 a well-being policy started to be developed to further enhance staff’s satisfaction at work and promote protective health factors; welcomes, in this perspective, the agreement with the psychosocial service of the Commission to facilitate free psychosocial consultations with specialists of diverse nature for all EPPO staff; appreciates the further EPPO initiatives to promote staff well-being, such as the internal and external selection procedures that enabled, in 2024, 10 members of staff to benefit from internal career moves, and the revision of the conditions of engagement, that were eventually amended at the end of 2024 to allow EPPO staff to benefit from a career under indefinite terms of engagement earlier than before;

50. Points out that, in late 2023, new guidelines on the notion of place of telework had been updated at the EPPO, bringing in 2024 increased autonomy to the staff; observes that a dialogue with staff has kept going on ever since, but resulting in no further adjustment in 2024; recalls that the EPPO operates a flexitime scheme and a work-from-home standard scheme, which provides for one day of telework per week as a basis and a maximum of three days per week, plus extensions accepted in light of serious health or family constraints; notes that current framework also includes 10 days’ work from outside the place of employment in a given year, to be used without link to other days of leave; maintains that the EPPO’s current working conditions allow staff to take advantage of digital solutions by integrating a good level of autonomy in the management of working patterns, facilitating the conciliation of private and work life and promoting team morale and spirit whose impact assessment was carried out via constant interaction with the staff and Staff Committee (encompassing the monitoring and revisions in general);

Change 28

Changed50.51. Notes with satisfaction that adequate gender balance in management positions was reached in 2024 and 2025 (4 women, 5 men) by appointments in middle and senior management of the under-represented gender; observes, on the point of geographical balance, that all the 26 Member StatesEU thatnationalities are partyrepresented, to the EPPO arevarious representeddegrees, onin its staff, with some nationalities more represented than others; calls on the EPPO to finalise its strategy on diversity and inclusion, the implementation of which was decided in 2023;

52. Acknowledges that the front line of the EPPO is composed by the EDPs working at the decentralised level in 24 different Member States; notes that, since 31 December 2024, the offices of the EDPs were located in 44 cities in 22 Member States; observes that, by end 2024, the EPPO had 166 appointed EDPs, taking into account that ten EDPs from Sweden (2) and Poland (8) were appointed in December 2024 but only started operational activities in January 2025; recalls the importance of ensuring EDPs’ full independence, on the basis of a merit-based and objective appointment procedure in accordance with Article 17 of Regulation (EU) 2017/1939 and of the principle of national procedural autonomy;

Change 29

Changed52.53. Underlines that the EPPO had indicated a total of 172 EDPs as the target to be appointed by the end of 2024, without considering any additional need resulting from the enlargement to Poland and Sweden; points out that the Union’s budgetary authority agreed to increase the number of EDPs from 140 to 166 only with the allocation of 24 EDPs to Poland and 2 to Sweden; stresses that Union’s budgetary authority continued to grant resources for covering EDPs remunerations corresponding to the payment of 80 % of the AD9 salary, instead of 100 % of the AD9 salary, as decided by the EPPO to make the position more attractive for senior prosecutor having adequate long-lasting professional experience to handle the complex EPPO cases; understands that, because of the financial constraint resulting from this gap in the resources allocated, by the end of 2024 the EPPO was able to deploy, besides the 2 EDPs in Sweden, only 8 EDPs in Poland (instead of the 24 EDPs needed) and 156 EDPs in the other remaining Member States; notes that the slowing down of the intake of additional EDPs negatively affects EPPO’s capacity to direct an increasing number of investigations and prosecutions; further notes that due to the funding gap, the EPPO also had to reduce or postpone investments in the Case Management System, thus preventing the EPPO from improving its ability to direct cross-border investigations; calls on the Commission to assess the situation, in consideration of the increasing workload and of the sensitiveness of the cases handled, and to report to Parliament the results and the possible solutions to cover the financial gap;

Change 30

Changed53.54. Maintains that the appointment of EDPs is the shared responsibility of the EPPO and the Member States, because while European Prosecutors are nominated by the Member States and then appointed by the Council, EDPs are nominated by the Member States and appointed by the College; encourages Member States to contribute to the full independence of EDPs and the EPPO; notes that the EPPO has strived to improve the working status of the EDPs in order to make the position more appealing, such as to align the remuneration of EDPs with that of Union officials of equivalent level of responsibility,responsibility (AD9), rather than 80 % of the salary of Union officials, as originally provideddecided for,by the Commission, taking into account that the career progression of EDPs in their national systems remains unclear and, in several cases, the national salary of the most experienced national prosecutors was higher than the salary offered for the EDP position, obliging the EPPO to intervene for the implementation of Article 16(1) of the Conditions of Employment of the EDPs, which provides that, in the case of total net remuneration lower than the national salary, a top-up amount is provided to ensure that the remuneration matches the previous level; reiterates its call for foreseeing a clear career progression path for the EDPs and more favourable administrative discipline on social security and health insurance coverage; insists on the creation of a specific EDPs status, consistently with the nature of their judicial function and calls on the Commission to accordingly propose amendments to Regulation (EU) 2017/1939, in the circumstance of its incoming revision, which will also cover the issue of the social security and health insurance coverage gap of the EDPs that has not yet been resolved by all the Member States through legislative or administrative arrangements, even if their adoption is mandatory under Regulation 2017/1939;

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55. Understands that in 2024 the EPPO preferred running internal staff satisfaction survey rather than resorting to an external costly provider under the existing framework contract, but regrets the lack of involvement of the Staff Committee, which would have been more appropriate; notes that recurring issued were raised repeatedly by staff in the survey, mainly focused on work-life balance and the interpretation of the accessibility of teleworking from abroad for family or personal reasons; notes that the EPPO indicates its rigid teleworking discipline to be one of the possible disincentives to recruitment and encourages the EPPO to further explore alternatives that -without bringing prejudice to the effectiveness of its working methods and questioning the corporate culture could offer an increased level of autonomy which, in turn, might bring an higher level of satisfaction among the staff;

56. Notes that, during 2024, the EPPO recorded 1 504 expressions of interest for training programmes, with 851 successfully completed, accounting for a total of 13 984 training hours, equivalent to 1 865 days of training for both internal and external courses; observes that for specialised external training in legal and administrative matters, the EPPO recorded 42 expressions of interest for training programs, with 22 in progress and 17 successfully completed, which accounted for 992 training hours, equivalent to 132 days of training;

57. Notes that also in 2024 EPPO training strategies were in line with, and relevant to, the EPPO’s mission, as they targeted the operational (operational workshops and other training) and administrative (trainings under SLAs, within the domain of digital services, in the field of security, and many other of varied nature) areas, according to the needs of the organization; understands that in 2024 training was focused on areas such as safety, security (information security and ICT general security awareness), ethics, sustainability (green public procurement and climate risk) and for enhancement of digital skill (also relevant in the context of preparation for the IT autonomy project of the EPPO eventually finally achieved in 2025); welcomes the EPPO’s approach to tailor the contents of the training offer strictly on the role, responsibilities, grades of the target population, with small info sessions provided to specific teams following ad-hoc requests with a focus on defined points (e.g. the role of the confidential counsellors);

58. Observes that staff was duly informed on the training opportunities through the EPPO’s intranet, providing as well contents for new joiners and other user-friendly resources; appreciates that the training offer in 2024 was well received and that, for example, by the end of 2024, 86,2 % of EPPO staff (statutory staff, seconded national experts and intra-muros contractors) had attended the anti-fraud policy training while for the anti-harassment and whistleblowing actions, in 2024 two general sessions on associated contents targeted general staff (34 and 16 participants accordingly) and one was held for managers (9 participants) and members of the College (6 participants);

59. Welcomes that in 2024 no case of burnout has been reported; notes that the EPPO has encouraged measures seeking to offset the continuously increasing workload to reduce risk of burnout; observes, however, that in 2024, no assessment on workload distribution across different teams and members of staff was conducted;

60. Notes that in 2024 EPPO organised info-sessions on anti-harassment for staff, managers and the College, and that such sessions were organised for specific teams and specific Units on request, on an ad hoc basis, with contents tailored to the needs of each population; appreciates that the confidential counsellors expression of interest procedure was launched in 2024, leading to the election (in hand with the Staff Committee) of the Counsellors in Q1 2025; remarks the first case of harassment reported within the EPPO in 2024;

Change 31

Changed60.61. Observes that, following the positive conclusions of the pilot carried out in 2023, a traineeship policy was drafted and has been approved in 2024, followed by a first cycle of effective trainees the same year; notes that 8 trainees were hosted at the EPPO during 2024, working -as defined in the traineeships policy-, at a time regime pegged to that one of the EPPO’s statutory staff, in this case, under the provisions of Commission Decision C(2022)1788 of 24.3.2022 on working time and hybrid working; appreciates that all EPPO trainees receive a monthly income figure (as a grant); stresses that the high cost of living in Luxembourg poses a considerable obstacle for potential trainees;

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Ethical framework and transparency

62. Is aware that, overall, the EPPO’s ethical framework is being gradually built up; understands that the limited human resources didn't allow for its completion in 2024; urges that the preparatory work be completed to adopt a comprehensive conflicts of interest policy needed to consolidate and improve existing rules and better cover all relevant instances in a single coherent document;

63. Appreciates that, following Parliament requests, the dedicated training programme on the EPPO ethics framework has become mandatory to all EPPO post holders, including European Prosecutors and EDPs and has achieved in 2024 the expectedly high participation rate;

64. Notes that, in 2024, a total of 17 raise-awareness sessions were organised on the EPPO’s ethical framework, the anti-fraud strategy and the code of good administrative behaviour, ensuring broad staff participation, in the framework of the implementation of the anti-fraud strategy 2023–2025, adopted on 1 March 2023, aiming to counter fraud at all levels of the organisation, even internally, with objectives linked to a dedicated action plan and to KPIs as components of the EPPO’s internal control environment monitored on an annual basis by the internal control officer; remarks that conflict of interest rules and declaration procedures are in place for senior management and staff involved in financial circuits, procurement and recruitment; observes that a dedicated fraud risk assessment is carried out on an annual basis, to identify and address potential risks, including conflict of interests; appreciates the fact that the Guidelines for the EPPO Staff on Outside Activities and Assignments apply to all staff’s activities unrelated to hobbies or leisure but however relevant and outside the remit of the EPPO;

65. Reiterates its calls for the introduction of a more robust revolving door policy which should include an extended cooling-off period of at least two years for senior EPPO officials before they can engage in private-sector employment, in particular where related to EPPO areas of investigation; insists that the EPPO conduct an annual review of compliance with these post-employment restrictions; reminds that prevention of revolving doors is to be included in the overall EPPO ethics framework;

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Changed65.66. Welcomes the EPPO’s follow-up with regard to the most recent Parliament resolution on discharge that asked for the adoption of a dedicated whistleblowing and anti-retaliation procedure to integrate the implementing rules to the Staff Regulations adopted by the College (College Decision 077/2021 laying down guidelines on whistleblowing applicable within the EPPO) and to accompany Article 45.12 of the EPPO’s Financial Rules (establishing the actions to be undertaken in the circumstances) in order to ensure a safe and protected workplace; understands that a specific whistleblowing and anti-retaliation procedure has been prepared during 2024 and approved in early 2025; encourages the EPPO to keep intensive internal dialogue on whistleblowing with the confidential counsellors and to involve the NEDPAs on the inherent matters; stresses that the effective implementation of whistleblowing and anti-retaliation procedures is essential for safeguarding the EPPO’s internal integrity and credibility; invites the EPPO to report to the discharge authority on the practical functioning of these safeguards, including staff awareness and trust in the system;

67. Maintains that the EPPO internal integrity framework is crucial to the external perception of the EPPO’s independence and autonomy; believes that by mandating public disclosure of all financial interests and external activities of senior officials, including members of the College, the risk of undue influence will result mitigated and that a periodic review of these declarations will allow identifying in advance any potential undetected risk; appreciates the EPPO’s will to explore effective ways to achieve this objective, duly taking into account the sensitivity and specificity of the prosecutorial function;

Change 33

Changed67.68. Notes that transparency is crucial in the EPPO’s interactions with external actors; appreciates EPPOthe availabilityopenness of the EPPO to look into ways on how to further increase transparency of its interactions with external actors, with due consideration of the sensitivity and specificity of the prosecutorial functionfunction, including the supervision by courts and the imperative to protect the EPPO's independence; maintains the view that the establishment of a mandatory public register of all meetings between the EPPO’s officials and representatives of third parties, including lobbyistslobbyists, even when engaged in advocacy activities related to policy priorities, and national government representatives,representatives would greatly contribute into reinforcing public trust in the EPPO’s independence and its capacity to launch immediate investigations on any case of misuse of public funds, in such a way to prevent any perception of undue influence;

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Digitalisation, cybersecurity and data protection

69. Regrets that Parliament’s calls on the Commission to reconsider the decision of the Commission’s Directorate-General for Digital Services (‘DG Digital Services’, formerly DIGIT) to discontinue the provision of digital workplace services to the EPPO have not been followed-up; appreciates the Commission’s decision to temporarily extend the provision of IT services until June 2025, to facilitate the transition, but deplores that the final result is a situation whose financial viability is questionable at best, and which is performance-wise suboptimal; reiterates its considerations on the security and confidentiality-related arguments, and on the purely financial aspects, because the outsourcing would appear much more costly than the in-house solution where adding up the resources needed to solve the complex administrative aspects and to adapt to the de-centralised configuration of the EPPO with EDPs and NEDPAs in several locations across the Union;

70. Underlines that, while the EPPO achieved adequate IT autonomy only in 2025, the preparatory work in 2024 made it tangible the most significant digitalisation investments in the history of the EPPO and that, to accomplish IT autonomy and to prevent adverse impact on the operational activities, the EPPO had to launch many actions; reminds that even if the Commission had provided technical support to the EPPO during the transition to the IT autonomy, from a budgetary perspective, the EPPO had to move resources from operational activity to IT in any event, and the Commission did not agree to compensate them; recalls, in this regard, that at the end of February 2024 the EPPO’s request for an amending budget 2024 (for about EUR 3 million and 37 established plan posts) was rejected and that this refusal follows previous Commission’s rejection to grant 45 establishment plan additional posts to fill the gap stemming from the discontinuation of DG Digital Services, submitted in January 2023;

71. Points out that in 2024, the EPPO’s operational ICT budget amounted to EUR 6,61 million, representing 19 % of the overall operational budget (compared to EUR 4,7 million in 2023 and EUR 5,6 million in 2022); observes that the increase in absolute terms reflects the significant preparatory work undertaken for IT autonomy, including the reinforcement of in-house capacities in cybersecurity, IT service management, and infrastructure monitoring, as well as the technical transition of services previously provided by DG Digital Services; notes that such investments were strategically targeted to ensure continuity, independence, and security of the EPPO’s digital environment and laying the necessary foundation for the successful achievement of IT autonomy in June 2025; underlines that while the share of IT expenditure within the operational budget remained stable, 2024 was characterised by a decisive concentration of effort and resources to prepare the EPPO’s transition to full digital independence;

72. Understands that even after having achieved it, in 2025, the EPPO emphasises that supporting the IT autonomy requires additional human and financial resources, which so far have not been granted because of the limitation imposed by the overall available budgetary resources in the concerned lines; calls on the Commission to reconsider its decision and to allocate additional resources to ensure that the effectiveness and legal soundness of the EPPO operations are not at a stake;

73. Notes that in 2024, in the IT area, the EPPO has continuously acted on the two major projects of the IT autonomy programme and of the CMS programme, the former to provide a complete catalogue of administrative IT services fully managed internally, the latter to progress in the development of digitalisation in the core business area of investigations and prosecutions; believes that the solution of recruiting intra-muros contractors for handling these projects offers immediate operational continuity but should not be conceived as a definitive solution for the EPPO, taking into account the extremely sensitive nature of its activities and the need to ensure continuity and reliability of its digital services, as well as the highest level of security of its IT infrastructure, systems and equipment; reiterates its concerns on the risk of lack of perception by the Commission of the sensitiveness of the issue, demonstrated by a superficial assessment of the problem which could adversely impact the EPPO’s operational activities and represents a potential reputational risk for the Union in the case it results in weakening the EPPO’s operational capacity;

74. Recalls that the complexity of the EPPO IT infrastructure stems from the EPPO’s decentralised structure, that obliges each EDP to use both national and EPPO’s CMS, which are different data bases governed by different access rights; points out that the processing and exchange of information between the central services of the EDPs and the EPPO requires the digitalisation of the casefile by the EDPs, obliged to use national digital tools in compliance with national law, but also obliged to consider the need of having such digital documents in formats compatible with the EPPO central system and with the systems used by other EDPs who are partners in the investigative cases;

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Changed74.75. Maintains that integration of the EPPO’s CMS and national case-management systems is necessary to increase the effectiveness of the investigations and it is to be pursued in the circumstance of the revision of Regulation (EU) 2017/1939; anticipates that such integration would require a common consistent digitalisation level across the participating Member States to set a digital working environment that is secured to the same standard as the EPPO’s central officeoffice, andwhile fully respecting national legal frameworks; recalls that the inherent shared costs, on the Member States and the Union, should be taken into account in the budgetary estimation and forecast; appreciates the role and contributions of the NEDPAs in the effective use and feeding of the systems and suggests considering the attribution to them of a specific status in the occasion of the revision of Regulation (EU) 2017/1939; stresses that any future integration should be based on a balanced sharing of responsibilities between the Union and the Member States;

Change 35

Changed75.76. Considers it crucial to mitigate the risks on the EPPO’s IT structural integrity stemming from the aggressive practices of the associations of organised criminals investigated and prosecuted by the EPPO that are prone to react aggressively to EPPO’s interventions to disrupt their criminal activities; appreciates that the overall improved security strategy and global information security policy framework that was proposed in 2023 has been formally approved and adopted in 2024; underlines that physical and digital security and their governance are essential enablers of EPPO’s operational independence and effectiveness and require resources, such as those deployed in the creation of a dedicated unit to address cyber and physical security;

77. Stresses that the EPPO is requested to deal with an increasing number of cases involving high-tech components and digital criminal methodologies, hence it needs up-to-date equipment and IT systems in order to be able to integrate into the investigative processes and analyses the advanced technologies that are often used by highly skilled criminal networks;

Change 36

Changed77.78. Notes that in operational areas the EPPO applies great caution in the use of artificial intelligence and agrees that while AI can assist with data processing, the evaluation of evidence and prosecutorial decision-making remain strictly within full human responsibility; welcomes this approach as essential to safeguarding fundamental rights, legal certainty and accountability; underlines that the EPPO does not perceive AI as able to reduce staff needs, but rather as a supporting tool in coping with the increasing workload; encourages targeted investment in AI tools - provided that their use remains proportionate and training,subordinated to human oversight - and training whose budgetary implications should be offset by efficiency gains in translation and other support processes; calls on the EPPO to provide guidelines to staff on how to use those instruments, specifically targeting the typical processes inherent to EPPO peculiar mandate;

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79. Is aware that EPPO cases and related case files and evidence are referred to the EPPO and registered in any Union language and that each case may have hundreds to thousands of documents, received in bulk, that needs to be translated in working languages for case analysis and investigation, while the EPPO reports and decisions, issued in English, have to be translated back to the language of the reporting Member State for referral to national courts; understands that this process is carried out by machine translation services delivered by the CDT - Centre De Traduction; observes that the cost of eTranslation services in 2024 was EUR 1 051 000 for the machine translation tools, and EUR 2 308 452 for human translation; asks the EPPO to explore possible better use of these machine translation services which is so far not AI-assisted but based on vocabulary data sets, delivered from DG Digital Services’ eTranslation service, and updated on an annual basis;

80. Reiterates its support to the EPPO’s requests for resources to protect its cybersecurity and calls for the swift implementation of a robust cybersecurity strategy to safeguard the EPPO’s operations and data integrity;

81. Observes that the EPPO digital strategy and vulnerability and patch management policy are currently under development and that the existing services are ensuring vulnerability assessment and automated scanning tool and notification for the crucial CMS environment; calls on the EPPO to prioritise those measures that are material to guarantee a safe working environment, the continuity of the activities and the protection of the relevant information;

82. Welcomes the continuous dialogue between the EPPO’s data protection officer and the European Data Protection Supervisor’s contact point for the EPPO and their regular bilateral meetings; encourages the College, whose decisions complement the actual legal framework, to engage with the European Data Protection Supervisor in a periodic revision of the existing practices and procedures in view of the need to ensure usability of personal data for investigation and prosecution and in the meantime to safeguard their protection;

Buildings and security

83. Observes that the lease agreement by which Luxembourg authorities provide rent-free the building currently hosting the EPPO’s headquarters was not amended in 2024 and that the EPPO paid the same annual service charge fee of EUR 716 724 in 2024 as in 2023, without additional costs;

84. Notes that the EPPO currently occupies ten floors in the tower and four floors in the annex of Tower B (TOB) building; is aware that seven additional floors are under refurbishment by the host state from early 2025 and will be gradually delivered to the EPPO during Q4 2025; understands that the new floors will help overcome the current shortage of space and will offer the opportunity to unify and efficiently redistribute EPPO services within the premises; recalls the nature of EPPO activities and their inherent confidentiality, hence welcomes the assignment of individual workspace to each staff member in single, double or triple office; appreciates the already existing measures to ensure accessibility of the offices to persons with reduced mobility or other disability;

Environment and sustainability

85. Is aware that the EPPO occupies part of a building provided rent-free by the host state and that the environmental parameters are managed by the national authorities, in compliance with local environmental requirements; welcomes the actions launched by the Luxembourg authorities to support the EPPO in promoting environmental management resulting in the installation of 20 charging stations for electric vehicles in underground car park and the replacement of energy-saving interior lighting and facade blinds in the entire premises of the EPPO’s central office to enhance the building energy efficiency; notes that water filtering machines have been installed on all floors and this decreases the use of plastic bottles; observes that the EPPO’s central office is integrated in Luxembourg network of free public transport making it easily reachable through low environmental impact means at no cost for staff and visitors and the underground car park provides a dedicated zone for bicycle parking;

86. Notes that the EPPO follows the Commission Decision C(2025) 2495 – Guide on Missions and Authorized Travel, considering not only green travel solutions for staff carrying out mission but also systematically assessing the need for missions against the feasibility of online meetings;

Interinstitutional cooperation