WORKING WITH DG ECHO AS AN NGO PARTNER | 2021 - 2027
FRAUD AND AID DIVERSION
The conditions for significant cases are not cumulative. Meeting any of the criteria is sufficient to classify a case as significant.
Senior staff refers to individuals with significant authority or responsibility within the organisation, covering both HQ level and country level positions. Base managers and individuals overseeing critical operational aspects or controlling the organisations’ financial and/or material resources are considered senior staff since they hold key managerial responsibilities (even if they may not hold officially a managerial position/title).
In case of doubt in individual cases, you can reach out to ECHO-REPORTFRAUD@ec.europa.eu.
If the alleged fraudulent activity itself is large (>10k€), but, proportionally, the specific ECHO contribution is below 10k€, it will not qualify as significant based solely on the financial impact criterion from ECHO’s perspective. However, it could be if other criteria are met (e.g. be part of a larger fraud scheme or systemic fraud or reputational impact).
Whether or not significant, partners must still notify DG ECHO after having concluded their investigation if the allegation is substantiated or partially substantiated with an impact on DG ECHO funds, regardless of the amount
A case is defined as significantly affecting operations when the incident alters or compromises the ability to deliver one or more results set out in the action (as per the single form).
If an organisation initially classifies a case as "less significant" but later uncovers information indicating that it meets any of the criteria for a "significant case" the partner is obliged to inform DG ECHO immediately. The 3 or 4 cases – whose total amount would accumulate to EUR 10,000 - should be linked (e.g. same or similar offender, similar fraud scheme, etc.) and fall under the timeline of one action.
Not significant (assuming other criteria are not met).
But whether or not significant, partners must still notify DG ECHO after having concluded their investigation if the allegation is substantiated or partially substantiated with an impact on DG ECHO funds, regardless of the amount.
Not significant (assuming other criteria are not met).
But whether or not significant, partners must still notify DG ECHO after having concluded their investigation if the allegation is substantiated or partially substantiated with an impact on DG ECHO funds, regardless of the amount.
NGO are invited to report significant cases to DG ECHO, which then decides whether to involve OLAF based on the severity and specifics of the incident.
International Organisation (Ios) must report cases of established and suspected fraud affecting the financial interests of the Union and their follow-up to OLAF.
In addition, they must inform DG ECHO of the following:
- Established fraud with a financial impact on DG ECHO funds.
- Suspected fraud which may have significant impact on the operations funded by DG ECHO.
- Suspected fraud which is likely to have a reputational impact.
Not all significant cases are automatically transmitted to OLAF. DG ECHO evaluates each case and decides whether OLAF's involvement is necessary, based on agreed criteria.
IO must report cases of established and suspected fraud affecting the financial interests of the Union and their follow-up to OLAF.
OLAF is internal to the EU Commission, and all commission services are obliged to share requested data.
Case specific details are not shared externally unless a legal right exists. However, general reporting on our anti-fraud and aid diversion work is available also to external stakeholders (e.g. in the Annual Activity Report).
Yes. Final reports should be sent with anonymised personal data and provide sufficient information for understanding the investigation's outcomes.
NGOs as Implementation Partners (IP) should report incidents to the IO, which then follows the reporting process outlined under HACA requirements, ensuring the chain of accountability.
Yes, the updated rules reflect ECHO’s commitment to shared risk management and aim to reduce administrative burdens while maintaining accountability and enhancing reporting efficiency.
IO must report cases of established and suspected fraud affecting the financial interests of the Union and their follow-up to OLAF. In addition, they must inform DG ECHO of the following:
- Established fraud with a financial impact on DG ECHO funds.
- Suspected fraud which may have significant impact on the operations funded by DG ECHO.
- Suspected fraud which is likely to have a reputational impact.
The reports to DG ECHO for these incidents should focus on the impact on operations rather than the specifics of the fraud, which will be disclosed to OLAF.
The guidelines for reporting significant fraud or aid diversion are alike, but not identical. Apart from the issue of the potential amount involved, other factors would determine whether it is deemed significant.
If you have any queries, you can reach out to ECHO-REPORTFRAUD@ec.europa.eu.
There is no new annual reporting.
For non-significant cases reported before January 2026, partners are still required to inform DG ECHO on the outcome of the investigation in 2026 ,as per the previous reporting requirements, to close the loop.
For cases of aid diversion with less significant impact (whether alleged or proven), your organization needs to inform DG ECHO (either the Desk Officer or the field office or both) as part of the regular operational exchanges taking place during the implementation (e.g. in operational meetings or during field monitoring visits).
