GRECO ¦ Outcome of the 99th Plenary Meeting

99th GRECO Plenary Meeting – Strengthening anti‑corruption oversight and renewing focus on sub‑national integrity

GRECO’s 99th Plenary Meeting, held in Strasbourg on 17–19 March 2025, reaffirmed the Group of States against Corruption’s central role in monitoring and driving anti‑corruption reforms across Europe and partner countries. The plenary produced a series of decisions and follow‑up measures that signal continuing pressure on member states to implement GRECO’s recommendations, a reinvigorated focus on sub‑national integrity through the launch of the Sixth Evaluation Round, and closer cooperation with other rule‑of‑law bodies and civil society.

Renewed priorities – sub‑national integrity and evaluator training

At the top of the agenda was the announcement that GRECO’s Sixth Evaluation Round for 2025 will examine Preventing corruption and promoting integrity at the sub‑national level. This is a strategically important shift. Corruption risks and integrity gaps frequently play out at regional and local tiers of government where day‑to‑day public services are delivered and procurement decisions are made. By bringing sub‑national authorities directly into its evaluation framework, GRECO aims to surface practical vulnerabilities, elevate good practice, and push for reforms where citizens most commonly encounter public institutions.

To support this expansion, GRECO organised a training session for evaluators on 20–21 March 2025 and issued updated Guidelines for Evaluation Teams (GrecoEval6(2025)2) together with a time schedule for evaluation visits (GrecoEval6(2025)1). The meeting also appointed a Gender Equality Rapporteur for the Sixth Round, underlining GRECO’s intention to mainstream gender considerations in assessments of corruption risk and integrity frameworks.

Bastian Schwind-Wagner _Follow

"GRECO’s decisions at the 99th Plenary Meeting reinforce the organisation’s role in driving anti‑corruption reform by focusing on sub‑national integrity, strengthening evaluator training, and maintaining pressure on member states through targeted follow‑up. Enhanced cooperation with international bodies and deeper engagement with civil society will improve the evidence base for practical reforms and increase public accountability.

Practitioners in financial crime and compliance should monitor GRECO’s upcoming country reports and follow‑up deadlines closely, as these will signal changes in legal frameworks and enforcement priorities. Proactive adaptation of risk assessments and compliance measures to address identified local vulnerabilities will be essential to reduce corruption risks and support effective enforcement."

Sustaining multi‑institutional cooperation

The plenary highlighted continuing partnerships with other international rule‑of‑law and anti‑corruption actors. GRECO’s president reported exchanges with the Venice Commission on the updated Rule of Law Checklist and participation in events with the OECD , UNODC and other bodies. The Secretariat convened counterparts from GRECO, OECD, OAS and UNODC to discuss civil society engagement, demonstrating a recognition that more coherent cross‑institutional approaches are needed to tackle corruption and strengthen prevention.

High‑level missions and targeted country follow‑up

GRECO confirmed a programme of targeted high‑level missions and evaluation visits for 2025, including missions to Denmark, Türkiye and Poland, and evaluation visits to Estonia, the Slovak Republic, Luxembourg and Slovenia. These missions serve both as a diagnostic tool and as a mechanism to maintain political engagement at senior levels. They also underscore GRECO’s practice of pairing country‑level scrutiny with direct outreach to national authorities to accelerate implementation of recommendations.

Compliance monitoring – pressure, closure, and escalation

The plenary adopted multiple compliance reports across the Third, Fourth and Fifth Rounds. Notably, GRECO adopted the Third Round evaluation report on Kazakhstan and set a 30 September 2026 deadline for a situation report on implementation. In the Fourth Round, GRECO concluded that Portugal’s compliance remained globally unsatisfactory and required a progress report by 31 March 2026, while asking its Statutory Committee to press Portugal diplomatically to achieve tangible results.

The Fifth Round decisions showcased both closures and escalations. Compliance procedures were closed for Albania, Norway, North Macedonia, Sweden, and the United Kingdom, indicating satisfactory reform trajectories in those jurisdictions for the evaluated themes – central government and law enforcement integrity. By contrast, Germany, the Netherlands and Poland were found not in sufficient compliance and were required to report back by 31 March 2026. Azerbaijan and Portugal received compliance reports under Rule 31 revised bis with additional progress requested within 18 months. GRECO’s practice of escalating to letters addressed to Ministers of Foreign Affairs or Permanent Representatives illustrates a willingness to raise shortcomings to politically senior levels when technical follow‑up proves insufficient.

Civil society engagement and public outreach

GRECO has moved to strengthen civil society engagement, adopting revised proposals to improve interactions with non‑governmental organisations and national associations of local and regional authorities. The inclusion of civil society actors in the training programme for Sixth Round evaluators and plans for an outreach event alongside the 100th Plenary Meeting are practical steps to widen stakeholder input. GRECO will also present a thematic study on findings from the Fifth Evaluation Round at that outreach event, providing a platform to translate technical evaluation outcomes into public debate and policy advocacy.

Transparency, publication and procedural discipline

The plenary reiterated the importance of prompt publication of GRECO reports and set out practical steps to be followed by member states when consent for publication is given. GRECO urged certain delegations, including Azerbaijan, Spain and Türkiye, to authorise the publication of previously adopted reports without delay so that progress is reflected in annual statistics and public records. At the same time, the President reminded delegations of the confidential nature of plenary procedures and cautioned against public statements that could compromise deliberations.

Implications for practitioners in financial crime, compliance and enforcement

For investigators, compliance officers and policy makers working on financial crime, several practical takeaways emerge from the 99th Plenary Meeting:

1. GRECO’s shift to examine sub‑national integrity will generate new evidence and recommendations relevant to local procurement, licensing, and public‑private interactions that are often exploited in asset‑related corruption and money laundering schemes. Practitioners should anticipate country reports that identify vulnerabilities in local controls, conflict‑of‑interest regimes, and oversight mechanisms, and use those findings to inform risk assessments and targeted compliance measures.
2. The sustained use of high‑level missions and diplomatic channels to press for reform means that anti‑corruption priorities may receive renewed political backing in states under scrutiny. This can translate into legislative and institutional changes that affect investigative powers, whistleblower protections, and asset recovery processes. Financial crime practitioners should monitor GRECO follow‑up timelines and country responses to anticipate shifts in enforcement capacity and legal frameworks.
3. Enhanced civil society engagement and the public release of GRECO reports increase transparency and can catalyse domestic demand for reform. NGOs, journalists and civic actors often leverage GRECO findings to push for oversight and enforcement. Private‑sector compliance functions should be attentive to this dynamic, since public scrutiny can lead to stricter regulatory expectations and compliance obligations.

Conclusion – sustained scrutiny and broader engagement

The 99th GRECO Plenary Meeting consolidated momentum on several fronts: a strategic expansion to sub‑national anti‑corruption evaluation, reinforced cooperation with other rule‑of‑law bodies, targeted missions to maintain political pressure, and improved engagement with civil society. For the anti‑corruption and financial crime community, GRECO’s decisions point to an evolving monitoring landscape that will produce more granular assessments of integrity vulnerabilities and create fresh opportunities and imperatives for prevention, enforcement and compliance. Keeping pace with GRECO’s outputs and the national responses they provoke will be essential for those aiming to reduce corruption risks and strengthen the integrity of public institutions across all levels of government.

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