Summary of findings for sampled FRAs

AuthorMélissa Campagno - Goya Razavi - Brian Kessler - Léna Bonnemains - Olga Mala
Study on the implementation of Article 125(4)(c) of the CPR in the Member States
5. Summary of findings for sampled
This section examines the co ntent of the sample of FRAs gathered as part of this st udy to analyse
how Authorities assess the different categories of fraud and corruption risks, what measures they
have in place, and analyses the extent to which the measures are proportional to the risk identified.
Where relevant, it also refers to external indicators of frau d risk to challenge the self-assessme nt of
risks, or to provide context to the findings.
The analysis of the fraud risks was performed for s ix risk categories, defined from the EC FRA
template by grouping of recommended measures into logical groups. In this study we assess and
compare the level of risks across the six categories of risks, as well as analyse what measures were
used by authorities to mitigate those risks. The study also assesses the proportionality of measures
put in place to the level of risks as assessed by authorities.
The current section analyses the overarching findings across all risk categories and measures
applied for their mitigation.
The risks of fraud are high for the majority of the sampled OPs, according to the
authorities. Authorities assess fraud risks to be high or medium fo r 64% of the sampled OPs.32
Authorities across the sample of OPs analysed the severity of risk of conflict of interest as the
highest across six categories of risk. 83% of the authorities consider this r isk to be high or
medium.33 The next two highest rated r isks were avoidance or man ipulation of procurement
procedure and manipulation of project cost and quality (see figure belo w).
Figure 6: Level of fraud risks across risk categories
Source: PwC
At the other end of the spectrum, Authorities assessed risks related to lack of skills and collusive
bidding to be the lowest across risk categories, with 56% and 55% of Authorities assessing these
risks to be high or medium, respectively.
External corr uption indicators should be taken into accou nt wh en compar ing fr aud
risks across MS. The widespread use of the EC FRA template means that many authorities are
using the same structure and approach in assessing their fraud risks. However, the way authorities
32 27 out of 42 OPs where data was collected. For eight OPs authorities did not assess risks or did not do so in a template sufficiently
close to the EC one so that their assessment can be compared with the rest of the sample.
33 In 33 out of 40 OPs. For 10 OPs authorities did not assess risks related to conflict of interest or did not do so in a template sufficiently
close to the EC one so that their assessment can be compared with the rest of the sample.
18%, 7 OPs
23%, 9 OPs
24%, 10 OPs
39%, 15 OPs
44%, 17 OPs
45%, 15 OPs
45%, 18 OPs
41%, 16 OPs
41%, 17 OPs
34%, 13 OPs
38%, 15 OPs
27%, 9 OPs
38%, 15 OPs
36%, 14 OPs
34%, 14 OPs
26%, 10 OPs
18%, 7 OPs
27%, 9 OPs
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Conflict of interest
Manipulation of project costs
Manipulation of public procurement
Double funding
Lack of skills
Collussive bidding
Low risk Medium risk High risk

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