EPPO ¦ Annual Report 2025

EPPO 2025: How cross‑border fraud and organised networks are reshaping financial crime in the EU

The European Public Prosecutor’s Office (EPPO) closed 2025 with 3 602 active investigations and an estimated total damage to public finances exceeding €67.27 billion. Those headline figures are a clear indicator that fraud affecting the EU’s financial interests has reached an industrial scale. Revenue fraud – VAT and customs – alone accounts for roughly €45.01 billion of the damage under investigation, while non‑procurement expenditure fraud remains the single largest category of active cases by number. Equally striking is the EPPO’s workload growth: the Office opened 2 030 investigations in 2025, almost 35% more than in 2024, driven largely by improved cooperation with national authorities and a deliberate focus on organised criminal groups that treat EU funding as a source of mass profits.

What the numbers mean in practice

The figures in the EPPO’s annual report are not abstract. They reflect a landscape where criminal networks have professionalised and turned mainstream EU markets into laundering channels. Investigations expose sophisticated multi‑jurisdictional structures: conduit companies, buffers, brokers, missing traders and “paper mills” that generate artificial invoices and tax credits. Prosecutors increasingly encounter hybrid schemes that combine VAT or customs fraud with money‑laundering, procurement manipulation and corruption. The result is a criminal ecosystem that blends legal trade with illegal conduct and makes detection and attribution more difficult for single countries acting alone.

Revenue fraud evolves, not disappears

Traditional carousel VAT fraud has not vanished, but organised groups have supplemented and sometimes replaced it with fragmented linear schemes. These schemes often lend VAT directly from paying customers, exploit one‑stop shop regimes and leverage e‑commerce platforms. The range of goods used as fraud vehicles has expanded: electronics, used cars, high‑value consumer goods, fuel and excisable products, pharmaceuticals and even digital licences. Customs fraud has multiplied too, from undervaluation and misclassification to large‑scale evasion through abuse of simplified procedures and illicit transhipment routes. The EPPO’s “Calypso” investigation, coordinated across many Member States, revealed criminal networks importing goods from China into the EU while evading duties and VAT, prompting one of the largest container seizures ever recorded.

Bastian Schwind-Wagner _Follow

"The EPPO’s 2025 findings demonstrate that fraud targeting EU funds has become systemic and transnational, requiring coordinated investigative responses and stronger preventive controls across procurement, customs and subsidy systems. Persistent involvement of organised networks and professional enablers shows that prosecutions must be paired with measures that increase corporate transparency and disrupt illicit financial infrastructures.

To protect public finances and the integrity of EU programs, policymakers should prioritise cross‑border data sharing, tighter scrutiny of procurement and import routes, and robust asset recovery mechanisms. Strengthening cooperation between the EPPO, national authorities, customs and financial intelligence units will be essential to deter large‑scale fraud and reclaim illicitly obtained resources."

The role of organised crime and professional enablers

Investigations show that organised crime groups do far more than execute schemes: they build and control the infrastructure that makes fraud scalable. These groups set up cross‑border corporate chains, dominate segments of logistics and port clearances, operate underground banking and hawala networks, and use professional facilitators – accountants, brokers, lawyers – to shelter transactions. Notably, criminal networks with links to Chinese supply chains have emerged as major players in extra‑EU import fraud. The EPPO finds that, for many of these groups, fraud is a business model: high profits, relatively low detection risk and numerous reinvestment opportunities in legitimate or semi‑legitimate markets.

Expenditure fraud and the NextGenerationEU spotlight

The Recovery and Resilience Facility (RRF) has been a major target: 518 active EPPO cases relate to NextGenerationEU funds, with an estimated damage to EU finances of €5.08 billion. Fraud patterns here include misrepresentation in subsidy applications, forged invoices, inflated project costs, and manipulation of tender specifications. Large green and digital transformation projects are at particular risk, with procurement fraud taking forms such as restrictive technical specifications or conflicts of interest that effectively favour a preselected company. The EPPO’s findings underline that speed and scale of public spending – even when needed for recovery and transformation – increase vulnerability when oversight, procurement design and local detection capacities vary across Member States.

Corruption, misappropriation and money laundering: the follow‑on effects

Corruption remains present in a subset of high‑value procurement and subsidy cases. The EPPO’s investigations reveal both active and passive corruption of officials involved in awards and execution of contracts, and misappropriation by authorized officials who divert funds or certify ineligible work. Money laundering is the natural follow‑on: organised groups convert proceeds into real estate, vehicles and cash, route funds through international structures, use unregulated transfer systems and increasingly rely on crypto assets to obfuscate origin. The scale is material: freezing orders granted in 2025 reached €1.13 billion and assets frozen during the year amounted to nearly €289 million.

Operational implications for investigators and policymakers

1. Cross‑border coordination is essential. Nearly a third of active investigations have a cross‑border dimension. The EPPO’s increase in investigations and in indictments (275 in 2025, up 34% from 2024) shows the tangible benefits of a transnational prosecutorial office. National authorities remain the primary source of reports, but the EPPO’s activity also reveals gaps in detection and reporting from EU institutions and bodies.

2. Criminal methodologies adapt quickly to enforcement successes. As prosecutions and seizures close traditional carousel routes, networks shift to import‑driven schemes or trade‑based laundering. This agility demands equally nimble investigative responses: follow money flows across jurisdictions, combine customs and tax expertise with criminal intelligence, and deploy asset recovery measures swiftly before proceeds disappear.

3. Professional enablers and complex corporate structures are force multipliers for fraud. Investigators need forensic accounting, corporate transparency tools, beneficial‑ownership data and close engagement with financial intelligence units and private sector intermediaries, including payment providers and marketplaces.

4. Procurement design and oversight must be hardened. Public contracting for major transitions – green, digital, health – should incorporate stronger conflict‑of‑interest checks, improved technical evaluation safeguards to avoid restrictive specifications, and enhanced ex‑post verification mechanisms, including digital forensics and independent audits tied to milestone payments.

Two illustrative cases and what they teach

The Greek agricultural funding case: an organised criminal group is alleged to have used forged declarations and fictitious farms to claim CAP subsidies, causing damage estimated in the tens of millions of euros. The operation exposed how criminal networks recruit straw beneficiaries and use bogus land records to siphon rural subsidies. The take‑away: agricultural schemes remain vulnerable to document forgery and identity manipulation; satellite and on‑site verification, combined with cross‑checking of land registers, are powerful deterrents.

The Italian fuel VAT scheme: the seizure of assets tied to a €260 million VAT fraud in the fuel sector highlights how commodity trading, tax warehouses and transnational missing‑trader networks facilitate massive evasion. The investigation shows the importance of combining customs, tax and criminal investigations, and of seizing both proceeds and the operational means – such as warehouses – to disrupt recidivist networks.

Policy and enforcement priorities going forward

Strengthen cross‑border investigative capacity and data sharing. Criminal patterns exploit jurisdictional gaps; detecting and prosecuting them requires harmonised financial data, faster mutual legal assistance, and collaborative use of FIU and customs intelligence.

Tackle professional facilitation. Targeting the service providers and corporate structures that enable fraud adds leverage: sanctions, regulatory scrutiny and criminal liability for enablers can disrupt entire fraud ecosystems.

Enhance transparency in procurement and beneficial ownership. Clearer ownership data and traceable tender histories reduce opportunities for shell‑company abuse and tender rigging.

Boost controls on import and customs procedures. Improving customs risk profiling, supply‑chain traceability and audits of simplified procedures can counter the growing share of import‑centred fraud.

Integrate asset recovery into prosecution from day one. Freezing orders and value‑based confiscation are essential to transform convictions into deterrents and to return resources to the EU budget.

Conclusion

The EPPO’s 2025 report shows that the fight against fraud affecting the EU budget is now a large‑scale, strategic endeavour. Criminal groups have professionalised their operations and adapted rapidly: fraud now sits at the intersection of trade, finance and corporate complexity. Countering this threat requires not only prosecutions but also preventive design in public spending, stronger cross‑border investigative tools, and measures aimed at the commercial and professional infrastructures that enable large‑scale fraud. The EPPO’s rising caseload and growing number of convictions demonstrate that a transnational prosecutorial approach is a necessary element of an effective European response.

Dive deeper

• EPPO ¦ Annual Report 2025 ¦ Link