GRECO ¦ Outcome of the 101st Plenary Meeting

GRECO ¦ Outcome of the 101st Plenary Meeting

GRECO’s 101st Plenary: Strengthening oversight, speeding up compliance and pushing transparency

At its 101st Plenary Meeting (Strasbourg, 18, 19 and 21 November 2025), chaired by President David Meyer, the Group of States against Corruption (GRECO) focused its attention on three interlinked priorities: improving the speed and visibility of member states’ compliance with anti‑corruption recommendations, reinforcing mechanisms for integrity at sub‑national levels and in law enforcement, and increasing transparency around GRECO’s own outputs. The adopted Programme of Activities for 2026 formalises these priorities while allowing flexibility to respond to unforeseen scheduling needs.

President’s priorities and outreach

President Meyer used the session to recognise the practical contributions of national delegations to GRECO’s monitoring work, emphasising that permanent appointment of delegation members is fundamental to effective communication and follow‑up. He reiterated the importance of timely notification of delegation changes to keep contact lists accurate and ensure smooth coordination. The President also reported active outreach and high‑level engagement throughout 2025: a high‑level mission to Türkiye, meetings with EU and Council of Europe counterparts, and participation in thematic events on transparency, privacy and anti‑corruption. These contacts reflect GRECO’s intent to align monitoring work with broader European and international anti‑corruption efforts.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"GRECO’s 101st Plenary reinforced the need for timely national action and greater transparency to ensure anti‑corruption recommendations lead to measurable reforms. Member states are urged to prioritise publication of GRECO reports and to meet reporting deadlines so that monitoring results remain credible and actionable.

The plenary also highlighted practical integrity measures at sub‑national level and within law enforcement, including whistleblower protections and ethics tools for police. Countries with outstanding recommendations should use the next twelve months to demonstrate concrete progress and respond to GRECO’s follow‑up requests."

Monitoring and evaluation workstream

GRECO confirmed the composition of teams for the Sixth Round, which focuses on preventing corruption and promoting integrity at sub‑national level, and reminded members of the importance of meeting advance deadlines so appropriate local authorities can be included in evaluations. The 2025 schedule of Sixth Round visits shows an active year, with evaluation missions completed in several jurisdictions and remaining missions planned, including a final visit scheduled for Slovenia and a high‑level mission to Poland.

Compliance procedures and concrete outcomes

The plenary reiterated that strict adherence to submission deadlines for implementation reports is essential for the integrity of the compliance process. GRECO adopted a number of compliance decisions across the Fourth and Fifth Evaluation Rounds. It closed compliance procedures for several members whose follow‑up had reached the required standard, including Belgium (Fourth Round) and Iceland, Finland and Slovenia (Fifth Round), by adopting addenda to their relevant compliance reports. At the same time, GRECO concluded that Belgium, Croatia and France are not yet in sufficient compliance with Fifth Round recommendations and requested progress reports by 30 November 2026. For those three states, the Secretariat will also ask the Secretary General of the Council of Europe to write to the respective Ministers of Foreign Affairs to stress the need for tangible action.

The meeting also addressed compliance concerns for Romania under the Fourth Round, requesting additional information by 30 November 2026, and public interest steps such as calling on member states to authorise timely publication of adopted reports. The President singled out a number of delegations that should urgently allow publication of outstanding reports, including Azerbaijan and Türkiye (reports from 2023) and Czechia, Hungary and Türkiye (reports from 2024).

Sub‑national integrity and policing ethics on the agenda

Reflecting GRECO’s growing focus on local governance, the plenary welcomed a jointly organised side event with the Congress of Local and Regional Authorities on consolidating integrity at sub‑national level. The Sixth Round’s orientation towards local authorities is a clear institutional pivot: GRECO stressed that national authorities must provide available and timely information so sub‑national entities can be meaningfully assessed.

A substantive exchange of views introduced Norway’s Dilemma Archive as a practical tool to strengthen police ethics and conduct, a welcome example of operational resources that can help law enforcement agencies translate integrity standards into everyday decision making. GRECO also took note of a thematic paper prepared by the Secretariat on whistleblower protection in law enforcement, a topic of growing relevance as whistleblowing mechanisms continue to be recognised as essential to detect and deter corruption within security services.

Transparency of GRECO outputs

The plenary discussed transparency in depth and invited further work on a proposal that would increase the automatic publication of GRECO’s reports. The Secretariat’s standing guidance on publishing adopted reports was reiterated: member states are asked to coordinate same‑day publication with GRECO, clearly mark adoption and publication dates, ensure national language versions are easily accessible on domestic websites, and provide links to GRECO’s official language versions. GRECO also urged delegations to notify the Secretariat promptly of publication URLs and set a cut‑off (5 December 2025 for reports to be counted in the 2025 General Activity Report) so annual statistics on compliance are accurate.

Partnerships and external engagement

The plenary took note of information shared by observer organisations and Council of Europe bodies, including the European Union and OSCE /ODIHR , underscoring the importance of continued cooperation across international mechanisms. The Secretariat reported active engagement in UNODC , OECD and other fora, and preparations for COSP‑11 and a joint special event on collective accountability with several peer‑review secretariats. This sustained external engagement positions GRECO as a key interlocutor in global anti‑corruption monitoring and peer review.

Next steps and implementation deadlines

GRECO adopted its Programme of Activities for 2026, which sets out core monitoring priorities and institutional roles while acknowledging the need for scheduling flexibility. The plenary stressed that where examinations of compliance reports must be postponed, the Secretariat will negotiate new, feasible deadlines with affected members. Specific compliance reporting deadlines were set for countries found lacking in sufficient implementation; Heads of delegation were asked to report by 30 November 2026 on progress for outstanding recommendations.

Conclusions and implications for practitioners

The 101st Plenary underlined GRECO’s dual approach: advancing technical monitoring – particularly at sub‑national and law enforcement levels – while pressing for political commitment and public transparency to make monitoring outcomes meaningful.

For practitioners in anti‑corruption and compliance functions, the meeting sends three clear signals:

  1. National authorities must prioritise timely responses and authorise report publication to ensure accountability is visible.
  2. Law enforcement integrity and whistleblower protections remain priority areas requiring practical tools and institutional buy‑in.
  3. GRECO will increasingly link monitoring outcomes to public transparency and to high‑level diplomatic follow‑up where compliance is insufficient.

The decisions adopted at this plenary and the Programme of Activities for 2026 point to a year in which GRECO expects stronger implementation and greater public availability of its findings, while maintaining the procedural flexibility needed to manage a busy monitoring calendar. Countries facing outstanding recommendations should treat the next twelve months as a decisive window to convert commitments into verifiable reforms.

The information in this article is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified lawyer.
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Bastian Schwind-Wagner
Bastian Schwind-Wagner Bastian is a recognized expert in anti-money laundering (AML), countering the financing of terrorism (CFT), compliance, data protection, risk management, and whistleblowing. He has worked for fund management companies for more than 24 years, where he has held senior positions in these areas.