This chapter highlights the importance of adopting a strategic approach and well-defined monitoring and evaluation frameworks to counter fraud. It outlines the core components of robust M&E systems, including embedding monitoring and evaluation within the strategy cycle, strengthening data use, designing and selecting appropriate indicators, and recognising key measurement and analytical limitations.
Evaluating, Updating and Monitoring Anti‑Fraud Strategies
A Methodology
Abstract
Integrity is one of the pillars of political, economic and social, structures, and a cornerstone of good governance (OECD, 2017[1]). Yet, no country is immune to breaches of integrity – fraud and corruption are widespread across all societies and, if not addressed, can undermine trust in public institutions, jeopardise the functioning of democracies, and harm social and economic well-being (OECD, 2024[2]). Globally, a clear trend is emerging: the scale and impact of fraud are increasing, exacerbated by developments in technology and growing risks of serious and organised crime to commit widespread, systematic fraud. According to the Association of Certified Fraud Examiners’ (ACFE) Global Fraud Survey, organisations are estimated to lose 5% of funds globally to occupational fraud each year (amounting to over USD 5 trillion in losses). Furthermore, the 2025 annual report of the European Public Prosecutor’s Office (EPPO) stated that the damage resulting from fraud and other crimes against the EU budget was estimated to be approximately EUR 25 billion, marking a significant increase of 22.5% compared to the previous year. More than half of this damage was linked to cross-border VAT fraud, which included the systematic involvement of criminal organisations (ACFE, 2024[3]; European Public Prosecutor’s Office, 2025[4]).
Within the EU, the obligation to protect the EU budget by countering fraud and any other illegal activities affecting the EU’s financial interests is a shared responsibility between the EU and its Member States.1 The European Commission, the European Parliament and the European Court of Auditors strongly encourage the adoption of national anti-fraud strategies (NAFS) in EU Member States to effectively and efficiently protect the EU’s financial interests (European Commission, 2023[5]). A NAFS not only improves the prevention, detection, and response to irregularities and fraud nationally, but also strengthens institutional co-operation and accountability, transparency for the public on anti-fraud efforts, and cross-organisational collaboration and co-ordination to address common issues jointly, such as with the European Anti-Fraud Office (OLAF), EU institutions, and other EU Member States.
Importantly, adopting a NAFS can enable countries to move towards proactive detection and prevention of fraud by bringing together resources and expertise across different areas and levels of government to address fraud in a holistic and systematic manner (OECD, 2026[6]). Against this background, there is a growing recognition that addressing modern-day fraud requires governments to move away from fragmented, agency-specific interventions to adopting a whole-of-government approach. As part of the preparatory work for the next Multiannual Financial Framework (MFF), the European Commission has launched an Anti-Fraud Architecture Review with a view to better addressing the challenges and bridging existing gaps in the protection of the EU’s financial interests. The White Paper for the review notes that a key measure to strengthen prevention at the national level is through the adoption of NAFS with related action plans (European Commission, 2025[7]). The key elements of a NAFS are highlighted in the box below and further elaborated in the sub-chapter on “Cross-cutting principles for effective M&E systems.”
The OECD Public Integrity Indicators (PIIs) consist of specific criteria derived from best standards and practices set out in the OECD Recommendation on Public Integrity and other international legal instruments. The PIIs support countries with an objective assessment of the strengths and weaknesses of their anti-corruption and integrity systems, including the quality of strategic frameworks (e.g. National Anti-Corruption and Anti-Fraud Strategies). The European Commission’s Guidelines for the elaboration of NAFS follow a similar approach to the development of a strategic approach to counter fraud. Whether a strategic framework has been adopted as a single national strategy or in another form, a strategic approach for public integrity, including countering fraud, should include the following elements:
Problem analysis: risk identification, analysis and mitigation: the problem analysis provides the foundation of the anti-fraud strategy and involves conducting a fraud risk assessment to assess the nature, extent and impact of fraud in the country, including relevant fraud risks. This preparatory stage should also include an assessment of the opportunities and challenges that may facilitate or hinder the implementation of an effective anti-fraud strategy (such as existing legislation, organisation, procedures, means and resources, and co-operation between relevant anti-fraud institutions), to select the most effective risk mitigation measures upon the development of the strategy and action plan.
Strategy design: prioritising the objectives, policy consultation and co-ordination: following the completion of a comprehensive problem analysis and fraud risk assessment, the next step is to develop an anti-fraud strategy which should mitigate the identified risks and challenges, ensuring that there is coherence across the involved entities, policies and objectives. This involves identifying and prioritising the anti-fraud objectives, covering the stages of the anti-fraud cycle, and consulting and co-ordinating among the relevant anti-fraud stakeholders.
Developing indicators with baselines, milestones and targets: performance indicators are key elements that demonstrate the progress made (or the results reached) towards the anti-fraud strategy’s objectives. Indicators can be based on quantitative or qualitative data, allowing for benchmarking to assess the effectiveness of different interventions in the anti-fraud strategy.
Drafting the action plan, distributing responsibilities and costing activities: the action plan is the primary instrument for implementing the anti-fraud strategy. The action plan should include the proposed objectives, measures, responsible institutions, indicators and respective data sources, estimates of the capital and operational expenditures and any additional costs, and be publicly available.
Implementing, monitoring, evaluating and communicating the results: finally, the anti-fraud strategy should include a robust monitoring and evaluation framework to assess progress to achieving strategic objectives and inform updates or revisions to the anti-fraud strategy and action plan. The benefit of monitoring and evaluation for management, policy design, and organisational learning also depends significantly on how the progress and results of the strategy are communicated. As such, communication is an integral part of the anti-fraud strategy and its monitoring and evaluation framework.
Source: Adapted from (OECD, 2024[8]; OECD, 2020[9]; European Commission, 2016[10]; OECD, 2017[1]).
The 2026 OECD Anti-Corruption and Integrity Outlook shows that countries are increasingly adopting dedicated frameworks to fight fraud, with approaches varying from integrating anti-fraud objectives in existing anti-corruption and integrity frameworks to adopting stand-alone national, sectoral and organisational anti-fraud strategies to safeguard public funds (see Figure 1.1). Out of 63 OECD Member and partner countries, including 25 EU Member States and 5 EU candidate countries, 7 countries (11%) have national, comprehensive anti-fraud strategies in force, and 19 countries (30%) have strategies adopted at the level of an individual ministry or agency (“organisational-level strategies”). Furthermore, 10 countries (16%) have anti-fraud strategies for a specific sector of the economy, an area of public spending, or a dedicated funding scheme (OECD, 2026[6]).
Note: Underlined countries in “EU Members and EU candidate countries” are candidates for membership to the European Union.
The OECD Secretariat conducted research on 63 Member and partner countries to identify publicly available, up-to-date anti-fraud strategies. Standalone anti-fraud strategies are adopted by the central government and are not dedicated to a single activity or programme. Sectoral strategies tackle fraud in a specific sector of the economy, programme, or funding scheme. Organisational-level strategies contain anti-fraud objectives related to the activities of a ministry or public agency. The categories of anti-fraud strategies are not mutually exclusive, and countries can have several types of strategies at once. However, for visualisation purposes, only one type of strategy is displayed per country, giving preference to national-level strategies. For example, a country that has a standalone national anti-fraud strategy and anti-fraud objective(s) found within the anti-corruption strategic framework is only displayed once, for the former category.
Source: (OECD, 2026[6])
Although more countries are adopting strategic frameworks to counter fraud, many still lack well-defined monitoring and evaluation (M&E) frameworks to assess the contribution of counter fraud efforts and inform whether existing measures are effective. The 2026 Anti-Corruption and Integrity Outlook highlights this as a broader trend: among the 46 OECD Member and partner countries that have relevant strategic objectives on anti-corruption and integrity in place, less than half of countries make use of outcome-level indicators and evaluation to demonstrate the concrete advantages of integrity improvements, and only 37% of the countries had an end of term evaluation planned as a formal activity (OECD, 2026[6]).
M&E frameworks are fundamental concepts to understand how anti-fraud strategies are implemented, whether the strategy is achieving the desired results, and ultimately whether fraud is reduced. To keep pace with evolving fraud risks, anti-fraud strategies should be accompanied by a robust M&E framework to ensure that strategies remain living, evidence-based documents that are equipped to address current threats but also emerging fraud risks. Additionally, ensuring that the results and progress under anti-fraud strategies are communicated with both internal and external stakeholders is a key transparency measure, enabling accountability and increasing the credibility of integrity efforts to stimulate future action.
Although interconnected concepts, M&E are distinct activities that serve different but complementary purposes:
Monitoring corresponds to a routine process of evidence gathering and reporting to ensure that resources are adequately spent, outputs are successfully delivered, and milestones and goals are met during the life cycle of the project. For monitoring, it is necessary to systematically collect information on specified indicators to provide the main stakeholders of an ongoing initiative with insights about progress and challenges in its implementation.
Evaluation, in turn, is a structured and objective assessment of an ongoing or completed initiative, its design, implementation and results. The goal of evaluation is to determine the relevance and fulfilment of objectives, its coherence, efficiency, effectiveness, impact and sustainability, as well as the worth or significance of a policy intervention. Above all, evaluations should trigger learning and enable continuity and coherence over time (OECD, 2020[11]).
Against this background, the report sets out an integrated methodology for monitoring, evaluating and updating anti-fraud strategies. The objective of the report is to strengthen efforts for comprehensive oversight and continuous improvement of anti-fraud measures, by providing a structured, dynamic approach to managing anti-fraud strategies that not only respond to current threats but adapts to future challenges. The methodology is primarily intended for entities co-ordinating the implementation, monitoring and evaluation of anti-fraud strategies (such as the Anti-Fraud Coordination Service, AFCOS, within EU Member States) but may also be useful for implementing entities of an anti-fraud strategy. The methodology is applicable to all types of anti-fraud strategies, regardless of whether a national, sectoral, regional or organisational-level approach has been chosen. The report is complemented by an Annex including Practical Tools for M&E, intended to equip countries with the necessary resources to establish a robust M&E framework:
Tool 1: Sample Questionnaire for Evaluation – Evaluation tool
Tool 2: Catalogue of Outcome and Impact Indicators – Evaluation tool
Tool 3: Checklist for Updating Anti-Fraud Strategies and Action Plans – Evaluation and Update tool
There is not a single, universally accepted legal definition of “fraud” that applies globally (OECD, 2026[6]). For the purposes of this report, the definition of fraud to the EU’s financial interests set out in Directive (EU) 2017/1371 of the European Parliament and of the Council of 5 July 2017 on the fight against fraud to the Union’s financial interests by means of criminal law (the PIF Directive) will be used to ensure that there is a clear understanding of the various components of fraud affecting the EU’s financial interests (Box 1.2).
(a) in respect of non-procurement-related expenditure, any act or omission relating to:
(i) the use or presentation of false, incorrect or incomplete statements or documents, which has as its effect the misappropriation or wrongful retention of funds or assets from the Union budget or budgets managed by the Union, or on its behalf;
(ii) non-disclosure of information in violation of a specific obligation, with the same effect; or
(iii) the misapplication of such funds or assets for purposes other than those for which they were originally granted;
(b) in respect of procurement-related expenditure, at least when committed in order to make an unlawful gain for the perpetrator or another by causing a loss to the Union's financial interests, any act or omission relating to:
(i) the use or presentation of false, incorrect or incomplete statements or documents, which has as its effect the misappropriation or wrongful retention of funds or assets from the Union budget or budgets managed by the Union, or on its behalf;
(ii) non-disclosure of information in violation of a specific obligation, with the same effect; or
(iii) the misapplication of such funds or assets for purposes other than those for which they were originally granted, which damages the Union's financial interests;
(c) in respect of revenue other than revenue arising from VAT own resources referred to in point (d), any act or omission relating to:
(i) the use or presentation of false, incorrect or incomplete statements or documents, which has as its effect the illegal diminution of the resources of the Union budget or budgets managed by the Union, or on its behalf;
(ii) non-disclosure of information in violation of a specific obligation, with the same effect; or
(iii) misapplication of a legally obtained benefit, with the same effect;
(d) in respect of revenue arising from VAT own resources, any act or omission committed in cross-border fraudulent schemes in relation to:
(i) the use or presentation of false, incorrect or incomplete VAT-related statements or documents, which has as an effect the diminution of the resources of the Union budget;
(ii) non-disclosure of VAT-related information in violation of a specific obligation, with the same effect; or
(iii) the presentation of correct VAT-related statements for the purposes of fraudulently disguising the non-payment or wrongful creation of rights to VAT refunds.
While M&E are distinct functions, their effectiveness depends on a set of shared preconditions. These conditions ensure that M&E are not a stand-alone or retrospective exercise, but an integral part of the strategy cycle. In addition, both functions rely on common principles related to data use, indicator selection and design, and the recognition of measurement and analytical limitations, which are outlined in this sub-section.
1.2.1. Embedding M&E in the strategy cycle: objectives, implementation planning, and intervention logic
Monitoring and evaluation are most effective when they are embedded in the design phase of an anti-fraud strategy, rather than introduced at implementation or closure stages. Early integration enables the establishment of baseline conditions against which progress and results can later be assessed (Johnsøn and Søreide, 2013[13]). It also ensures that data needs, indicators, and reporting mechanisms are designed in parallel with strategic interventions. A clear intervention logic is therefore required, setting out how the strategy is expected to produce change. This begins with well-defined strategic objectives, which serve as the foundation for implementation planning, indicator development, and subsequent evaluation (OECD, 2017[1]; OECD, 2020[9]).
Strategic objectives should be directly informed by fraud risk assessments and a robust problem analysis, ensuring that the anti-fraud strategy responds to the most significant vulnerabilities. The objectives may be further broken down into sub-objectives, measures, activities, indicators, milestones, and targets. The European Commission’s Guidelines on National Anti-Fraud Strategies emphasise that objectives should cover all stages of the anti-fraud cycle and reflect both expenditure and revenue-related risks, where relevant. They should also be aligned, where applicable, with broader national anti-fraud and anti-corruption strategies. Importantly, objectives should remain limited in number to ensure prioritisation, feasibility, and effective follow-up, and should be formulated according to the SMART criteria (specific, measurable, achievable, relevant, and time-bound), taking into account available resources (European Commission, 2016[10]).
Source: OECD Secretariat.
Once strategic objectives are defined, implementation planning should translate them into concrete and operational activities. Action plans should clearly specify responsibilities, timelines, and expected outputs, allowing both implementers and external stakeholders to understand what will be done, by whom, and when (Hoppe, 2013[14]). They should also identify how progress and results will be measured, thereby linking operational delivery to the M&E framework. This intervention logic should be expressed in a results chain that articulates the causal pathway from inputs and activities to outputs, outcomes, and intended impacts. Result chains can plot out the relationship between the different goals of the strategy and clarify which activities will be carried out, along with the intended inputs, outputs and outcomes for each of them. This is specifically what will be monitored and evaluated to determine the success of a strategy.
Alternatively, a Theory of Change (ToC) approach may be used to provide a more flexible conceptual mapping of how and why change is expected to occur, including assumptions and contextual factors influencing implementation. As such, a ToC involves outlining the activities and their inputs, outputs and outcomes, as well as the underlying assumptions about how each activity will bring about changes towards achieving the strategic goals of an anti-fraud strategy. This is essential to reduce the risk that activities are ineffective, irrelevant, or have unwanted side-effects (Pyman and Heywood, 2024[15]). While the ToC is based on causal logic, it also requires an explanation for the causal pathway (if X happens, then Y will follow, because predetermined conditions have been fulfilled) (Johnsøn, 2012[16]).
Overall, effective monitoring and evaluation rely on a set of interconnected foundations, including early integration into strategy design, a coherent intervention logic, and clear links between objectives, activities, and results. These elements ensure that M&E systems are grounded in a structured and measurable framework, enabling both performance assessment and learning. The following sections build on these foundations by examining in greater detail the development of indicators, the use of data, and key considerations in measurement and analysis.
1.2.2. Developing and selecting indicators with baselines, milestones and targets
Once policymakers have a clear picture of the specific issues to be addressed and the outcomes they expect from the strategy, appropriate indicators need to be identified to represent each objective. Indicators provide measures that operationalise objectives to assess whether an objective is fulfilled. They can be based on quantitative or qualitative data and should reflect changes connected to the anti-fraud strategy (Georgieva-Andonovska, 2016[17]). Monitoring implementation using indicators also allows for identifying risks as well as upcoming challenges and opportunities during the implementation process and can therefore serve as a valuable management tool to inform operational decision making. This allows for benchmarking that can assess the effectiveness of different interventions in the strategy and in other parts of the public integrity system. There are four types of indicators that are relevant for the objectives in the anti-fraud strategy and its corresponding action plan:
Input indicators are the resources spent, or activities carried out to fulfil a specific purpose (e.g. staff, funds, time, equipment).
Output indicators refer to actions that have been completed, such as establishing new practices or procedures, training staff or adopting a conflict-of-interest policy. Output indicators show that proposed actions are taking place along the planned timeline and allow for adjustments to the timeline if unforeseen logistical challenges arise.
Outcome indicators measure the extent to which actions under an anti-fraud strategy are having the desired short- and medium-term effects, such as improved inter-institutional co-operation or increased use of whistleblowing channels. Outcome indicators should not be defined for each action (or measure) but rather for operational (second level) objectives.
Impact indicators capture the broader, long-term effects of anti-fraud strategies, such as achieving a strong anti-fraud culture, an increased trust in anti-fraud institutions or strengthened capacities to prevent and detect fraud. These indicators are typically defined at the level of strategic objectives (first level), or at the level of the strategy as a whole. Outcome and impact indicators are therefore traditionally more relevant for the anti-fraud strategy itself, whereas the action plan typically focuses on activities, deliverables, and output indicators (OECD, 2025[18]).
Importantly, indicators should be linked to the different parameters of the Theory of Change (ToC) or results chain to provide information on whether the anti-fraud strategy is achieving its intended objectives at the output, outcome or impact level (Johnsøn, 2011[19]). For example, an overarching objective of an anti-fraud strategy may be to improve collaboration amongst the various anti-fraud stakeholders. To achieve this, a secondary strategic (or operational) objective may be to enhance the anti-fraud strategy lead (i.e. AFCOS or other) co-ordination mandate and capacities. Output level indicators in this case could be the number of strategy lead co-ordination meetings with cross-institutional participation and the percentage of managing authorities that rate the co-ordination as beneficial towards supporting their respective anti-fraud activities. The expectation is then clear that once these (and potentially other) indicators are fulfilled, the objective will be met, which, in turn, will then contribute to the fight against fraud. An example of linking indicators to the different parameters of a results chain is provided in Figure 1.3 below.
Source: Elaborated by OECD Secretariat, adapted from (Johnsøn, 2011[19]).
The indicators and monitoring mechanisms should be agreed upon during the design phase of the anti-fraud strategy to outline how the strategy lead may assess the effectiveness of given actions, objectives and the overall strategy. With that noted, monitoring is an ongoing effort; as fraud risks and organisational needs evolve, indicators should be reviewed and adjusted accordingly over time to ensure that efforts to fight fraud are effective. Strategy leads should therefore revisit the indicators once the implementation and monitoring begin to assess whether the selected indicators are still relevant and whether data collection is possible at the defined intervals to inform the decision process on the updating and revision of the action plan. In this regard, strategy leads may consider establishing formal mechanisms to review and adjust indicators, baselines, and targets when there are significant changes to fraud risks, the institutional context, or in the conditions for implementing the strategy. This would support the continued relevance of monitoring and evaluation systems and ensure that they continue to provide useful information for decision making.
Unlike monitoring exercises which typically consider output indicators, evaluations should place more emphasis on outcome and impact indicators. Nevertheless, it should be noted that while outcome and impact indicators are valuable tools to assess the effectiveness and impact of a strategy, they do not serve as definitive evidence as to whether a strategy is effective; all outcome indicators are influenced by external factors that are indirectly related to a strategy, which is why multiple indicators should be used to measure the effectiveness of an objective. For instance, using perception-based indexes as the sole outcome-level indicators for an anti-fraud strategy is discouraged, as variations cannot be exclusively attributed to the strategy and do not always correspond to changes in actual levels of fraud or corruption. Indeed, a series of high-profile fraud scandals could worsen perceptions of fraud in a society, even though these revelations might be due to strengthened investigations, enhanced transparency, or decreased impunity, whereas a low perception of fraud could indicate that a large portion of fraud remains undetected or underreported (Pyman, 2017[20]). Triangulating macro-level indexes such as perception-based indicators with “objective” outcome or impact-level indicators based on undisputed facts (e.g. fraud losses measured in monetary terms or volume of fraud reports) is therefore advisable where resources permit (Johnsøn, 2011[19]).
Identifying relevant indicators for a national anti-fraud strategy depends on the strategic goals and objectives of each organisation, with consideration given to the availability, frequency and ease of data collection, resources, and existing information flows and ownership of data. With this said, Box 1.3 below includes a few key considerations that should be considered when formulating indicators.
Use clear and practical indicators: Focus on feasible indicators to monitor policy implementation and impact, avoiding overly ambitious attempts to measure nearly immeasurable concepts without adequate resources. Emphasise concrete results over abstract notions like "reduction of fraud". Indicators should not try to measure several aspects at once but focus on one element of the objective. The indicators should be developed according to the SMART criteria, meaning they need to be specific, measurable, achievable, realistic, and time bound.
Define where the data are produced and who is responsible for providing them: For each indicator, clarify which area, unit or function is responsible for collecting the necessary information to inform the indicator, how the data are collected and how often or at what frequency data are collected. Defining an elaborate indicator that relies on a broad survey of the public might be an interesting perception proxy, however, without adequate financial and human resources, it could be difficult to produce at a mature level.
Keep resources in mind: Acknowledge that measuring success requires resources. While strategies may propose ambitious methods for measuring progress, implementation may falter without adequate resources. Where possible, use information that is already collected or can be easily accessed, for example, the number of disciplinary investigations. Where this is not possible, allow for additional costs (financial and personnel) of collecting data.
Anticipate difficulties and risks: Reflect on possible difficulties and risks of collecting and analysing data and draw up potential solutions to avoid these.
Establish baselines: Provide a starting point for measurement by determining baseline data for each indicator. Historical data or initial assessments can contribute to establishing these baselines.
Set targets, including target dates: Establish targets for each indicator, defining what the expected performance is for a set date.
Consider limitations of quantitative indicators: Acknowledge that impact may not always be fully captured through numbers alone. Identify what each indicator can and cannot show and avoid drawing conclusions beyond its scope. Complement quantitative data with qualitative evidence (such as case reviews, stakeholder feedback, or process evaluations) to understand how outcomes are achieved. For instance, the number of detected conflict-of-interest cases does not reveal how these cases are handled, so it should be paired with qualitative insights on decision making and follow-up.
Check validity of the measurement defined: The defined indicators need to measure what they are set out to do or put differently, by fulfilling all indicators set for an objective, can it be assumed that the objective has been reached? To do so, backward mapping can be helpful. This means that, assuming all indicators are fulfilled, is there still the possibility that the objective is not achieved? If not, how can this gap be filled? In some cases, there may not be enough direct indicators available and proxy indicators might need to be used.
Avoid adverse incentives: Some indicators can unintentionally encourage undesirable behaviour. For example, an indicator such as "reduction in the number of reported fraud cases" may incentivise underreporting or discouraging complaints in order to show progress, which can obscure the true scale of fraud rather than reduce it. Mitigate this risk by:
Communicating that an increase in detected or reported fraud can reflect stronger detection systems and improved trust in reporting mechanisms.
Pairing this indicator with others (e.g. detection rates, investigation outcomes, recovery of funds) to ensure a balanced interpretation of performance.
Setting realistic expectations that improved systems may initially lead to higher reported fraud, reflecting better oversight rather than worsening performance.
Avoid the use of output measures for outcome indicators: A common mistake in designing indicators is using output measures as outcome indicators. When selecting appropriate indicators for an anti-fraud strategy and action plan, it is key to remember what each indicator is intended to measure: outcome indicators should measure outcomes (are the actions under the strategy having the desired short- and medium-term effects?), whereas output indicators measure whether actions are taking place along the planned timeline.
Avoid presenting measures as targets or outcomes: Where measures are presented as targets (e.g. ‘train 100 civil servants on new public procurement rules’) or outcomes (e.g. ‘improve conflict of interest detection by training civil servants on new public procurement rules’), it becomes difficult to define meaningful indicators with clear baselines and targets, and to monitor progress or adjust over time.
Source: Adapted from (Council of Europe, 2013[21]; Schumann, 2016[22]).
Examples of data sources can include public opinion surveys, public sector diagnostics, cross-country surveys or combined surveys. Table 1.1 presents examples of potential data sources for indicators measuring anti-fraud strategies.
Source: Adapted from (OECD, 2023[23]) based on information adapted from (United Nations, 2011[24]) (Parsons, 2013[25]) (Kaptein, 2007[26])
A catalogue of sample outcome and impact-level indicators based on common anti-fraud strategic and operational objectives, including potential data sources, is included in Annex B ‘Catalogue of outcome and impact-level indicators.’
1.2.3. Acknowledging and mitigating measurement and analysis limitations in M&E
Monitoring and evaluation of anti-fraud strategies rely on data that is often partial, context-dependent, and subject to interpretation. As a result, both monitoring and evaluation exercises are vulnerable to methodological and cognitive biases, as well as limitations in data quality, availability, and comparability. If these constraints are not explicitly recognised and addressed, they can lead to misleading conclusions about performance, effectiveness, or impact. This section therefore outlines key approaches to identifying, acknowledging, and mitigating measurement and analysis limitations in order to strengthen the robustness, credibility, and usability of M&E findings for anti-fraud strategies:
Increase awareness of potential biases. Openly acknowledging biases helps raise awareness, fosters critical discussion of their likely effects, and supports the adoption of additional measures or processes to address them.
Proactively identify unintended consequences. Unintended consequences can be difficult to anticipate. Reflecting on those that have already occurred in similar contexts can provide insight into outcomes that are likely to arise in the future.
Triangulate data. Use multiple sources of information to validate and cross-check findings when assessing outcomes or impacts. For example, the OECD Public Integrity Indicator (PII) 3.2 on the grounding of evidence in anti-corruption strategies asks whether the problem analysis draws on at least four different sources from a list of eight. This list includes indicators from international organisations or research institutions; employee, household, business, or other surveys; data from public registries (e.g. law enforcement, audit institutions, national statistics offices); published research from national or international organisations or academic institutions; and commissioned studies. (OECD, 2025[27])
Use ‘critical friends.’ Involving individuals external to the evaluation process can help challenge groupthink, raise counterarguments, and offer alternative interpretations. This approach is partially reflected in OECD PII Indicator 3.4 on the inclusiveness and transparency of intergovernmental and public consultations. (OECD, 2025[28])
Ensuring there is a methodology plan. Establishing clear data and analysis protocols prior to data collection can help reduce the likelihood of monitoring actors seeking out information that confirms their own beliefs.
Prioritise the safety and comfort of participants. This is to encourage participation and help to inspire honest responses. For stakeholders, for example, this could include tailoring surveys in ways that are appropriately worded.
Being methodologically transparent. Providing full methodological accounts surrounding measurement and analysis enables it to be replicated. For example, this could be demonstrated by requiring that monitoring reports are published for all action plans, at least once a year, and available (publicly or to relevant stakeholders) no later than 4 months after the defined reporting schedule. (Pasanen, 2025[29]; Schütte, 2017[30]; OECD, 2024[8])
Taken together, these approaches highlight that credible monitoring and evaluation depend not only on the availability of data and indicators, but also on a conscious and structured effort to recognise and manage their inherent limitations. Embedding safeguards against bias, strengthening transparency, and diversifying sources of evidence are therefore essential elements of robust M&E systems. Within the broader set of cross-cutting principles presented in this chapter, these considerations reinforce the need for methodological rigour and critical reflection throughout the design, implementation, and interpretation of M&E activities in anti-fraud strategies.
References
[3] ACFE (2024), Occupational Fraud 2024: A Report to the Nations, Association of Certified Fraud Examiners, https://www.acfe.com/-/media/files/acfe/pdfs/rttn/2024/2024-report-to-the-nations.pdf (accessed on 13 October 2025).
[21] Council of Europe (2013), Designing and Implementing Anti-Corruption Policies: Handbook.
[7] European Commission (2025), White Paper for the Anti-Fraud Architecture Review, European Commission, Brussels, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0546 (accessed on 13 December 2025).
[5] European Commission (2023), Commission Anti-Fraud Strategy Action Plan - 2023 revision, https://anti-fraud.ec.europa.eu/document/download/7cff3f2b-192a-44a0-be7d-ee58c08ba8fc_en?filename=cafs-action-plan-2023-rev_en_0.pdf (accessed on 5 November 2024).
[10] European Commission, E. (2016), Guidelines on National Anti-Fraud Strategies, European Commission, https://sfc.ec.europa.eu/sites/default/files/EN-ORI-General%20Guidelines%20on%20National%20Anti-Fraud%20Strategies%20ARES(2016)6943965.pdf (accessed on 15 November 2024).
[4] European Public Prosecutor’s Office (2025), EPPO Annual Report 2024, https://www.eppo.europa.eu/sites/default/files/2025-03/EPPO%20Annual%20Report%202024_2.pdf (accessed on 13 October 2025).
[17] Georgieva-Andonovska, E. (2016), Monitoring and Evaluation of Anticorruption Action Plans, World Bank, https://documents1.worldbank.org/curated/en/129401593200074880/pdf/Monitoring-and-Evaluation-M-E-of-Anti-Corruption-Action-Plans.pdf (accessed on 22 March 2026).
[14] Hoppe, T. (2013), Strengthening Anti-Corruption Policies and Practices in Turkey (TYSAP), https://rm.coe.int/16806dd1b6.
[16] Johnsøn, J. (2012), “Theories of change in anti-corruption work: A tool for programme design and evaluation”, U4 Anti-Corruption Resource Centre, Chr. Michelsen Institute.
[19] Johnsøn, J. (2011), “How to Monitor and Evaluate Anti-Corruption Agencies: Guidelines for Agencies, Donors, and Evaluators”, U4 Anti-corruption Resource Centre 8, https://www.u4.no/publications/how-to-monitor-and-evaluate-anti-corruption-agencies-guidelines-for-agencies-donors-and-evaluators-2.pdf (accessed on 22 March 2026).
[13] Johnsøn, J. and T. Søreide (2013), Methods for learning what works and why in anti-corruption: An introduction to evaluation methods for practitioners, https://www.u4.no/publications/methods-for-learning-what-works-and-why-in-anti-corruption-an-introduction-to-evaluation-methods-for-practitioners.pdf.
[26] Kaptein, M. (2007), Developing and Testing a Measure for the Ethical Culture of Organizations: The Corporate Ethical Virtues Model, ERIM Report series Research in Management, No. ERS-2007-084-ORG, Erasmus Research Institute of Management (ERIM), http://hdl.handle.net/1765/10770.
[6] OECD (2026), Anti-Corruption and Integrity Outlook 2026: Harnessing the Integrity Advantage, OECD Publishing, Paris, https://doi.org/10.1787/16708b78-en.
[27] OECD (2025), Evidence-based problem analysis and use of diagnostic tools, OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/indicators/1000053/subindicators/1000340 (accessed on 21 April 2026).
[28] OECD (2025), Inclusiveness and transparency of inter-institutional and public consultations, OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/indicators/1000053/subindicators/1000342 (accessed on 21 April 2026).
[18] OECD (2025), Integrity reporting template and guidelines for federal public organisations in Belgium: Strengthening the strategic approach to public integrity, OECD Publishing, Paris, https://doi.org/10.1787/f2363170-en.
[2] OECD (2024), Anti-Corruption and Integrity Outlook 2024, OECD Publishing, Paris, https://doi.org/10.1787/968587cd-en.
[8] OECD (2024), OECD Public Integrity Indicators, https://www.oecd.org/en/topics/public-integrity.html (accessed on 3 April 2025).
[23] OECD (2023), A Strategic Approach to Public Integrity in Hungary: The 2023-25 National Anti-Corruption Strategy and Action Plan, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/a5461405-en.
[11] OECD (2020), Improving Governance with Policy Evaluation: Lessons From Country Experiences, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/89b1577d-en.
[9] OECD (2020), OECD Public Integrity Handbook, OECD Publishing, Paris, https://doi.org/10.1787/ac8ed8e8-en.
[1] OECD (2017), “Recommendation of the Council on Public Integrity”, OECD Legal Instruments, OECD/LEGAL/0435, OECD, Paris, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435 (accessed on 7 April 2025).
[12] Official Journal of the European Union (2017), “DIRECTIVE (EU) 2017/1371 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 5 July 2017 on the fight against fraud to the Union’s financial interests by means of criminal law”, Official Journal of the European Union, Vol. L 198/29.
[25] Parsons, J. (2013), Indicators of Inputs, Activities, Outputs, Outcomes and Impacts in Security and Justice Programming, Department for International Development (DFID).
[29] Pasanen, T. (2025), How cognitive biases affect monitoring, evaluation and learning – and what can be done about it, https://odi.org/en/insights/how-cognitive-biases-affect-monitoring-evaluation-and-learning-and-what-can-be-done-about-it/.
[20] Pyman, M. (2017), Research comparing 41 national anti-corruption strategies, Insights and guidance for leaders, https://curbingcorruption.com/wp-content/uploads/2018/07/Pyman-et-al-2017-Research-comparing-41-national-anti-corruption-strategies.pdf (accessed on 12 March 2026).
[15] Pyman, M. and P. Heywood (2024), Sector-Based Action Against Corruption, Springer Nature Switzerland, Cham, https://doi.org/10.1007/978-3-031-59336-9.
[22] Schumann, A. (2016), “Using Outcome Indicators to Improve Policies: Methods, Design Strategies and Implementation”, OECD Regional Development Working Papers, No. 2016/2, OECD Publishing, Paris, https://doi.org/10.1787/5jm5cgr8j532-en.
[30] Schütte, S. (2017), Bespoke monitoring and evaluation of anti-corruption agencies, https://www.u4.no/publications/bespoke-monitoring-and-evaluation-of-anti-corruption-agencies.pdf.
[24] United Nations (2011), The United Nations Rule of Law Indicators - Implementation Guide and Project Tools, Department of Peacekeeping Operations and Office of the High Commissioner for Human Rights, New York.
← 1. Article 325(1) of the Treaty on the Functioning of the European Union, TFEU