GRECO ¦ Outcome of the 102nd Plenary Meeting

GRECO ¦ Outcome of the 102nd Plenary Meeting

GRECO’s 102nd Plenary: Strengthening transparency, stepping up evaluations and pressing for compliance

At its 102nd plenary in Strasbourg (23–27 March 2026) GRECO underlined continuity in governance and a clear focus on institutional effectiveness. President David Meyer opened the meeting by thanking delegations for their active engagement in the mutual evaluation process and emphasised that this session was the first plenary to examine evaluation reports from the 6th Evaluation Round – a milestone for the monitoring cycle. The President reiterated procedural expectations: delegations are appointed on a permanent basis, only designated representatives should attend plenaries, and any change to a delegation must be promptly notified to the Secretariat to keep lists and mailing arrangements accurate.

The Secretariat reported sustained outreach and visibility. Contributions ranged from participation in international events – including the UN Conference of the State Parties to the UNCAC and regional anti‑corruption conferences – to support for parliamentary and judicial stakeholders. Eleven GRECO reports and a thematic paper on whistleblower protection in law enforcement were published since the prior plenary. The Secretariat also welcomed new staff and acknowledged a recent secondment, reflecting the continuing need for capacity to support an expanding workload.

Progress on evaluation and compliance rounds

Evaluation activity advanced across multiple rounds. GRECO confirmed team compositions for 6th Round evaluations of Denmark, Malta and Spain and noted a busy 2026 schedule of nine on-site visits, including to the United Kingdom, Poland, Latvia, the Netherlands and Sweden. A core message for member States was the importance of meeting deadlines for identifying sub‑national authorities to be evaluated and for supplying full questionnaire responses, given the complexity of sub‑national integrity frameworks.

GRECO adopted the 6th Round evaluation reports for Estonia and the Slovak Republic and set 30 September 2027 as the deadline for situation reports on implementation of recommendations. GRECO also encouraged both countries to disseminate identified good practices among their sub‑national authorities, and Estonia authorised publication of its report while the Slovak Republic was invited to do so as soon as possible.

On compliance procedures, GRECO stressed adherence to reporting timelines. A high‑level mission to Poland in November 2025 was noted and gratefully acknowledged by participating authorities. Under the Joint 1st and 2nd Rounds GRECO adopted a compliance report on Kazakhstan and concluded the country remained not in sufficient compliance with earlier recommendations; GRECO requested a progress report by 31 March 2027 and decided to alert Kazakhstan’s Consul General to the need for determined action.

Fourth Round developments focused on prevention of corruption among members of parliament, judges and prosecutors. GRECO adopted addenda and interim compliance reports for several members. Notably, an addendum for Ukraine closed the Fourth Round compliance procedure in respect of that member. For Türkiye GRECO judged the level of compliance had improved to the point that the designation “globally unsatisfactory” no longer applied and ceased further application of the automatic Rule 32 procedure, while requesting targeted follow‑up on outstanding measures. By contrast, Denmark’s compliance procedure was closed without achieving an adequate level of implementation, with GRECO expressing deep regret at the protracted non‑compliance, particularly concerning recommendations addressed to members of parliament. Heads of delegation from Czechia, Denmark, Hungary, Ukraine and Türkiye were asked to report on further progress by 31 March 2027.

Fifth Round follow‑up addressed prevention of corruption in central governments and law enforcement agencies. GRECO adopted compliance reports for the Republic of Moldova and Türkiye and noted that both required further progress to reach adequate compliance, setting a 30 September 2027 deadline for situation reports. Greece was found not to be in sufficient compliance under the Fifth Round and was asked to report by 31 March 2027; the Statutory Committee President was also invited to send a letter to Greece’s Permanent Representative urging determined action. Lithuania’s compliance procedure was closed after adoption of a Second Compliance Report.

Bastian Schwind-Wagner
Bastian Schwind-Wagner

"GRECO’s 102nd Plenary reinforced the organisation’s dual focus on transparency and rigorous follow‑up, pressing member States to publish reports and implement recommendations within clear deadlines. This approach aims to strengthen domestic integrity frameworks and ensure that evaluation findings translate into tangible reforms.

For practitioners tackling financial crime, the plenary’s outcomes offer sharper benchmarking tools and increased public visibility of shortcomings, which can be used to advocate and prioritise reforms. Sustained monitoring and targeted Rule 32 measures should help maintain pressure on governments to address systemic vulnerabilities."

Transparency and publication policy

GRECO adopted a standardized approach to increased transparency, deciding that a public summary of each evaluation or compliance report should be published on GRECO’s website within six months of adoption unless the member State authorises publication of the full report earlier. For reports already covered by the arrangement, summaries were scheduled to be published on 1 June 2026. The plenary reiterated that publication of full reports remains the objective and that summaries do not substitute for full reports. GRECO called on States to authorise publication of previously adopted reports without delay and reminded members of practical requirements when publishing adopted reports: agree a same‑day publication date with the Secretariat, clearly mark both the adoption and publication dates, make the national language version available on a domestic website, notify the Secretariat with a link, and include a link on the domestic site to the official language versions on GRECO’s website.

Topical developments and thematic work

Delegations provided updates on domestic anti‑corruption developments with presentations from Bulgaria, Georgia, Romania and the United States, and supplementary information from Albania, Azerbaijan, Cyprus, Malta, the Netherlands, Portugal and Slovenia. Issues flagged included institutional reorganisations of anti‑corruption bodies, allocation of oversight responsibilities, pressures on prosecutorial and judicial independence, allegations raised by whistleblower magistrates, and integrity challenges in federal administrations. The Secretariat presented a thematic paper on Codes of Conduct which GRECO welcomed as a contribution to member States’ policy and legislative work.

Deliverables, deadlines and next steps

GRECO adopted its General Activity Report 2025 and instructed the Secretariat to forward it to the Statutory Committee and the Committee of Ministers, with presentation to the Ministers’ Deputies planned. Where compliance remained incomplete, GRECO set reporting deadlines – typically 31 March 2027 for targeted progress reports and 30 September 2027 for broader situation updates – and invoked Rule 32 measures where necessary, including letters from the Statutory Committee to national authorities to press for tangible progress.

The plenary also adopted a schedule of upcoming meetings, including the 103rd Plenary in Strasbourg (8–12 June 2026) and the 104th Plenary (16–20 November 2026), both convened in person.

Implications for financial crime and anti‑corruption practitioners

The 102nd Plenary reinforced two interlinked lines of action: enhancing transparency of GRECO’s monitoring outputs and intensifying follow‑up where member States lag on implementation. For practitioners working at the intersection of financial crime and public integrity, the decisions carry practical significance. Standardised public summaries will broaden access to evaluation findings and facilitate comparative analysis of weaknesses in prevention frameworks, codes of conduct and integrity safeguards. The reinforced timetable for follow‑up reporting and the use of Rule 32 mechanisms will keep pressure on governments to convert recommendations into concrete legislative, institutional and operational changes – steps that can materially affect anti‑money laundering controls, asset recovery processes and the independence of criminal justice actors.

What to watch next

Key items to monitor after this plenary include whether member States authorise publication of full reports currently pending release; the substance of situation reports due in March and September 2027 from several members with outstanding recommendations; and how GRECO’s increased transparency measures influence domestic debate and reform momentum. For investigators, compliance officials and policy makers, GRECO’s outputs and follow‑up will continue to be a valuable source of benchmarked assessments of national anti‑corruption systems and a lever for advocating reform that reduces vulnerabilities to financial crime.

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.