This chapter provides guidance on developing a robust monitoring system to support anti-fraud strategies. It provides anti-fraud strategy stakeholders with guidance on when and how to monitor, outlines key questions to consider when using and communicating the results of monitoring to update anti-fraud action plans, highlights good practices for addressing common monitoring challenges, and defines governance and institutional responsibilities for monitoring activities.
Evaluating, Updating and Monitoring Anti‑Fraud Strategies
A Methodology
Abstract
Monitoring is essential to ensure that an anti-fraud strategy achieves its objectives and facilitates continuous improvement (European Institute of Innovation and Technology, 2025[1]). When conducted appropriately, monitoring allows strategy leads to measure what is working and address what is not working (including unintended implications). Furthermore, it generates information to communicate the progress and results of an anti-fraud strategy to relevant stakeholders, thus bolstering the credibility of the strategy, establishing the basis for transparency, and ensuring that stakeholders are accountable for achieving results and using resources efficiently. As a result, monitoring may provide leverage for the promotion of an anti-fraud strategy.
Generally, monitoring and evaluation are often bundled and treated as a single component of strategy design. They each have their specific challenges and ways of addressing them. This chapter focuses on monitoring activities (while Chapter 2 above offers guidance for the evaluation stage of an anti-fraud strategy). Monitoring is the systematic, continuous collection and analysis of information about the progress of a strategy. It assesses whether implementation is progressing as planned, enables corrective action to be taken as needed, and provides stakeholders with an indication of the extent of the progress being made (ILO, 2011[2]). It is important to acknowledge that establishing and implementing a robust monitoring system for a strategy requires a stable source of continuous resources to produce and analyse supporting data, in addition to significant stakeholder co-operation and co-ordination (Goergens and Kusek, 2009[3]).
This chapter acknowledges the challenges associated with monitoring exercises, sets out good practices to address them and provides a framework for developing monitoring systems underpinning anti-fraud strategies. It consists of three substantive parts. The first section addresses the questions of , when and how to monitor, and presents different methodological questions for consideration. The second section focuses on the governance of monitoring systems, reviewing different models in place regarding institutional arrangements for who is responsible for monitoring. The third section focuses on how to utilise and communicate the results from monitoring effectively, including strengthening the credibility and accountability of an anti-fraud strategy.
Monitoring is most likely to be useful and effective when it is prioritised early and embedded in a strategy cycle from the beginning (Johnsøn and Søreide, 2013[4]). Early planning supports the development of effective baselines (before implementation) assessments, which are useful to draw on when assessing the impacts of strategy implementation. To insert monitoring activities early, a clear understanding of how a strategy will initiate desired change is required.
The monitoring process should not become a bureaucratic burden. The European Commission’s Guidelines on National Anti-Fraud Strategies state that monitoring activities are continuous. Using indicators, monitoring should cover the level of implementation of measures under the strategy’s action plan. The strategy lead could develop a tool or standard reporting form which will allow the entities responsible for the implementation to report progress in a simple way. To provide the tool with the necessary data and information regarding the implementation progress, implementing agencies should designate a focal point for the anti-fraud strategy to be responsible for channelling the information. Based on this information, the strategy lead co-ordinator could prepare an overview of progress made every 6 months that will be presented and discussed regularly by senior leadership. In addition, the strategy lead could prepare a brief report of the status quo of the implementation and propose adjustments on an annual basis, if necessary, to be reflected in the next annual action plan. Figure 4.1 provides a basic example of how monitoring activities can be input into a tool, which is then synthesised for review by senior leadership. While there may be additional country specific steps and procedures needed in a structure, the elements in the figure should be present.
Source: Developed by OECD Secretariat
Integrating monitoring into the strategy cycle involves taking into consideration the various resources available (i.e. human, financial and time). In the Norton Rose Fulbright comparative analysis of 41 NIACs (mentioned above in Section 3), it was found that ‘less than a third of strategies note clear timelines or deadlines for each reform measure. […] Furthermore, most strategies either do not assess or only note as assumptions key aspects to a strategy’s success, like funding or full-time resources.’ (Pyman, 2017[5])
4.2.1. When to monitor
There are two aspects to consider when determining the appropriate time to monitor a NAFS:
The availability of data for key indicators will influence decisions relating to the appropriate time to conduct monitoring. The availability of data will vary depending on the indicator; surveys from relevant stakeholders may only be available annually, while administrative or budgetary data may be available monthly. The monitoring of these indicators should occur periodically (i.e. when new data becomes available). For other indicators, data availability may be proactively planned and flexible (e.g. data from interviews with key stakeholders).
Having an understanding of how long it takes for an activity to have an impact should inform the timing of monitoring. For example, a policy featuring integrity values in school education is unlikely to show its effects in a general population survey within the following one or two years. Long-term objectives call for a long-term time frame for monitoring (OECD, 2017[6]). Consideration must also be given to current and future strategy cycles.
4.2.2. Selecting monitoring methods
There are three sets of factors which should be considered when selecting how monitoring should be executed (Johnsøn and Søreide, 2013[4]):
Nature of the strategy: range of a strategy’s goals and objectives, and the types of activities planned.
Aims of monitoring: creating an understanding to answer questions about the strategy through monitoring to determine whether implementation is going to plan.
Data and resources available: considering what is needed for monitoring. To support the capability of monitoring, the importance of the quality, interoperability and traceability of the data that will be used should be considered given their impact on the reliability of results, including the consistent interoperability of systems and use of digital technologies. Furthermore, integrating the use of digital technologies to analyse monitoring data can ensure that activities are conducted accurately, fairly, and transparently. In this regard, mechanisms that ensure the consistency and verifiability of data should be considered to strengthen the usefulness of monitoring exercises (Hlacs and Wells, 2025[7]).
An anti-fraud strategy will typically involve multiple activities and objectives. Taking that into consideration, a combination of methodological approaches, which relies on both quantitative and qualitative methods, should be the most appropriate. For example, if resources were spent as planned, quantitative budgetary data may need to be analysed. Any combination of methodologies used should be appropriate as long as it takes into consideration the selected indicators and intentions of monitoring. As stated above, Table 2.2 in Chapter 2 provides potential data sources for indicators measuring anti-fraud strategies.
Member States with an anti-fraud strategy have developed monitoring and reporting mechanisms to enable the adequate implementation of the measures included in their action plans, together with additional mechanisms for evaluating their strategy (see Box 4.1 below).
Bulgaria
Bulgaria’s NAFS for the period 2021-2027 envisages an action plan with operational objectives, activities, responsible institutions, time periods as well as the performance indicators relevant to the achievement of the strategic goals and operational objectives. As of 2024, the action plans also include a dedicated section for reporting on the necessary financial resources to implement specific measures.
The AFCOS Bulgaria and the Council of Ministers are the entities responsible for monitoring and reporting on the implementation of the strategy. The AFCOS Directorate, in its capacity as the central monitoring body, can ensure that relevant information about the overall status of the implementation of actions is collected and analysed from the implementing entities. While the implementation period of the action plan is one year, its monitoring interval is every 6 months. In its previous strategy for the period 2014-2020, Bulgaria relied on quarterly reporting; however, following a recommendation, quarterly reporting was replaced by semi-annual monitoring to lower the related administrative burden. In July 2022, the Council of Ministers approved the Report on the implementation of the tasks set out in the 2021 action plan, implementing the NAFS for the period 2021-2027, and monitoring the implementation of partially completed and outstanding tasks from previous periods.
Croatia
Croatia’s NAFS for the period 2010-2012 includes an action plan with operational objectives, activities, responsible institutions, and time periods. The Independent Department for Combating Irregularities and Fraud (AFCOS Croatia) is the entity responsible for monitoring and reporting the strategy and action plan. The implementation period of the action plan is one year. The reporting mechanism of the action plan is twofold: it includes two-monthly reports from the bodies responsible for the implementation of operational objectives to the AFCOS Croatia, and biannual monitoring reports from the AFCOS Croatia on the current situation of the fulfilment of operational objectives and measures from the Strategy or the Action Plan including problems which occurred in the implementation. These biannual reports are submitted to the National Authorising Officer (NAO). In case the commitments outlined in the NAFS and the action plan are not fulfilled, the AFCOS Croatia will organise a meeting with a representative of the body in which problems appeared during the implementation, to reach an agreement on remedial actions thereof. Subsequently, the AFCOS Croatia will submit to the NAO a conclusion on corrective measures to be undertaken to implement the measures and operational objectives of the NAFS and its action plan.
To enhance the credibility and transparency of a NAFS, the methodology and indicators used to monitor its implementation should be clearly communicated. As a good country example, the portal of the Ukrainian National Agency on Corruption Prevention (NACP) (NAZK, 2023[10]) includes a methodological page listing the different types of indicators they use and the monitoring procedure for the respective activities of their anti-corruption programme (included Figure 4.2 in the following section). The latter consists of an internal institutional control by the implementing agency, followed by a data verification stage at the NACP. Each activity listed includes its level of implementation, which is publicly available on its website. This methodology is also similar to the one used to develop the OECD Public Integrity Indicators (OECD, 2023[11]), which are based on data submitted by participating countries (prior to being validated by the OECD).
Following the decision on the type of data that will be required, it will be important to formalise and establish the governance or institutional responsibilities around monitoring. Decisions regarding who will conduct monitoring exercises must consider who is best placed to process and collect data, taking into consideration where the data needs to be produced and recorded.
4.3.1. Diversity and participation in monitoring
Citizen participation
International best practice suggests that monitoring may also benefit from being participatory and inclusive (Wathne, 2022[13]; Chêne, 2012[14]). While in practice, many monitoring systems do not necessarily involve civil society (OECD, 2023[11]; Chêne, 2008[15]), those that do greatly benefit from including diverse perspectives. Including citizens and civil society groups (e.g. NGOs, academic institutions, research institutes, media and think tanks) increases a broader sense of ownership and can help to produce support for the strategy, which can provide governmental leverage for the promotion of integrity, more broadly (Markiewicz and Patrick, 2015[16]). Participatory monitoring can also alleviate some of the obstacles associated with the monitoring of NAFS. For example, members of civil society could be best placed to identify appropriate indicators and measures. This is because including the perspectives from marginalised groups can help to ensure that monitoring is sensitive to their different experiences (OECD, 2023[17]).
Additionally, civil society can play an important role in gathering data and monitoring. For instance, a community score card, often conducted by civil society groups, is a community-based monitoring tool used to assess services, projects, and government performance by analysing qualitative data obtained with focus group discussions with community members (Georgieva-Andonovska, 2016[18]). Box 4.2 provides an example from Colombia, which encourages citizens to participate in identifying potential flags.
The World Bank report “Enhancing Government Effectiveness and Transparency” provides examples of how the use of a digital application can facilitate citizen participation, including a case study on Colombia. In particular, the authors describe a smartphone application that was introduced in 2013 to fight corruption and wrongdoing in procurement processes. The application allows citizens to flag over-priced, neglected or incomplete public works in municipalities to the government’s transparency secretariat.
This real-time information supports the government in continuous monitoring and identifying priority areas to review components of the process, launch corruption investigations and subsequently complete unfinished projects. It also highlights the way in which the Colombian Society of Engineers (SCI) started publicly collecting and analysing procurement data following suspicions of rigged bidding processes. As a result, this prompted the government to make compulsory the use of standardised open tender documents for public transport works beginning in early 2019, among other reforms.
Source: (Bajpai and Myers, 2020[19]).
As such, the results obtained from participatory tools can be a useful supplement to government sourced data and generate new ideas and approaches, leading to the continual improvement of strategy over time (UNODC, 2015[20]). To be truly participatory, monitoring systems should include and foster active participation of beneficiaries or those affected by the anti-fraud strategy, and other primary stakeholders in designing and implementing monitoring systems. Special consideration should be given to encouraging the genuine participation of marginalised people or groups which may be disproportionately or differently impacted by strategy activity and face specific challenges to being able to participate in such processes (OECD, 2023[17]). Participatory monitoring should start early and involve jointly establishing expected results, how to track progress, collect data, and undertake analysis. It also involves collaboration on the development of action plans to address any identified weaknesses of a strategy (Georgieva-Andonovska, 2016[18]).
4.3.2. Capacity, skills, and institutional mandates
Consideration should be given to the resources, skills and capacity needed to monitor, as monitoring expertise and specialisation are necessary to produce reliable data and analysis. As mentioned, creating a monitoring team comprised of individuals with a range of professional experience, including individuals with expertise in the management of a monitoring system, performance indicators and systems, statistical analysis, public sector management reform, and performance budgeting (Georgieva-Andonovska, 2016[18]). In practice, it is often observed that limited institutional capacity and insufficient resources can undermine the efficacy of monitoring systems (Chêne, 2008[15]; 2012[14]). Ensuring that there is predictable and dependable funding for the monitoring function is key, as monitoring is a continuous process. Furthermore, being cognisant of the organisational risks associated with monitoring exercises is essential to allow for early mitigation for such exercises to be effective.
The individual entities involved in a strategy may overestimate their performance when assessing the implementation components of an anti-fraud strategy. As a result, the monitoring framework of strategies may be insufficient if they rely on the implementing entities to self-assess and monitor their own progress. Therefore, when possible, an entity responsible for central monitoring of the implementation of the strategy should aim to ensure there is an independent validation of progress and related activities. This evaluation could be completed by the co-ordinating entity, another government department or an external monitor such as a civil society group or external service provider. This exercise may also bring value to support the implementing entities to better understand how they can assess their own performance. (OECD, 2020[21])
Against this background, the country may consider empowering a central body (e.g. the AFCOS in EU Member States) with the overarching responsibility to co-ordinate and supervise the monitoring process. While the actual monitoring of day-to-day implementation of measures towards the achievement of the operational objectives and strategic goals will be conducted by the implementing authorities, a central body could ensure that the relevant information on the overall status of the implementation of the strategy is bundled and analysed jointly. This will support a complete and coherent picture that facilitates decision making, communication and provides incentives for improvement through benchmarking.
Monitoring and evaluation are only effective if used as intended. An appropriately functioning system will provide a continuous stream of information, which is essential for the credibility of a NAFS and to ensure that stakeholders are accountable for achieving results and using resources effectively. The results of monitoring enable the identification of problems and strategy weaknesses to inform modifications and adjust the direction whilst in the implementation stage. As an example, the criteria used within the OECD Public Integrity Indicators to assess an effective monitoring system provide a starting point for ensuring that monitoring practices can lead to improvements in implementation (Table 4.2).
Source: OECD (2023[11]), OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/.
When completed well, monitoring will provide vital information to inspire more effective strategy design and implementation. Communicating the results of monitoring effectively to all stakeholders is necessary for inviting feedback and suggestions for improvement, but also for enabling accountability and increasing the credibility of a NAFS strategy (Georgieva-Andonovska, 2016[18]).
Communication with stakeholders on the progress and results under the strategy enables accountability, increases the credibility of integrity efforts and stimulates future action. The benefit of M&E for management, policy design, and organisational learning depends significantly on how progress and results are communicated and incorporated into future versions of the anti-fraud strategy and its corresponding action plan. As such, communication is considered an integral part of an anti-fraud strategy and its M&E framework (OECD, 2017[22]). As mentioned in the previous section, monitoring reports will inform the update the strategy. Some considerations are outlined in Table 4.3 below and a more comprehensive list is included in Annex C in the form of a checklist for updating the action plan to support the NAFS co-ordinator’s assessment of whether action plan is fit for purpose.
Source: OECD authors’ elaboration based on Annex C.
Monitoring reports should highlight successes, challenges, and areas needed for improvement. Transparency around the monitoring processes and their results is key with all stakeholders, as they should have a clear sense of the status of the strategy’s implementation and the progress made. When communicating the results of monitoring reports, it is important to try to provide a comprehensive overview about what the results say and mean, as well as about how the results were produced. This can be achieved by:
1. Being clear on the scope of monitoring. Transparency on what was measured and when will help to avoid misunderstandings. What was monitored? Are results reflecting outputs (e.g. number of staff that received integrity training) or outcomes (e.g. degree of integrity in a unit)? How were the criteria evaluated?
2. Distinguishing between facts and interpretation. Stay objective in communication by making clear what was measured apart from the conclusions that have been drawn. This will bolster the credibility of monitoring and give stakeholders the chance to engage with the analysis.
3. Being clear and transparent on gaps. Stakeholders who understand the shortcomings of a measurement or a methodology of monitoring will be more likely to use and engage with the results sensibly.
4. Communicating important contextual influences. Contextual information should be communicated alongside monitoring results when it may help stakeholders to make sense of findings and/or make reasonable judgements. (OECD, 2017[6])
The example of Ukraine and Mexico, Box 4.3 and set of Figure 4.2 provide possible methods for how monitoring results may be publicly disseminated.
Ukraine
In Ukraine, reports on the implementation progress of the 2023-2025 State Anti-corruption Policy (SCAP) are available through a user-friendly website, maintained by the National Agency on Corruption Prevention.
From the homepage, there is a graph allows the user to view how many measures have been implemented (partially or in full), are still in progress, have not yet been initiated or have not been implemented. It also indicates which government agency is responsible for each measure and gives a ranking of the top implementers, specifying the proportion of their programme measures carried out. The availability of the information demonstrates a high level of transparency, which facilitates accountability and creates a benchmark for other agencies.
The SCAP’s activities are organised under three general themes:
1. Increasing the effectiveness of the anticorruption system;
2. Prevention of corruption in priority sectors; and
3. Ensuring the unavoidability of liability for corruption.
These themes comprise a series of topics which have the following available information:
Description of the problems identified. For navigation purposes, the topic’s page only shows a list of problems. If a user clicks a particular one, a new page emerges with information on all the programme measures addressing that issue, and the state of their implementation. There are also links to detailed documents that comprehensively explain the nature of the problem, how it was identified and by whom, citing key sources and assessments by international monitoring mechanisms and organisations.
Comprehensive overview of monitoring methodologies and results. There is also a view that shows all the measures associated with a particular topic, problem or expected strategic result. By clicking on each of these measures, the user receives a breakdown of how the activity is expected to achieve the desired outcome (i.e. the theory of change’s underlying assumption), its timeline and implementation status, the indicators used to measure it, and the data collection methodology.
The link to a form for relevant actors to give feedback on the implementation of each activity.
The below Figure 4.2 illustrates a possible navigation pathway through the website.
Mexico
In Mexico, the National Council for the Evaluation of Social Development Policy (CONEVAL) is a decentralised public agency that co-ordinates the evaluation of the National Social Development Policy and other related policies, programmes, or interventions.
This is applied to their national instruments, including the National anti-corruption policy. CONVEAL has a monitoring sheet which includes various sections such as the programme’s description, results, coverage and industry analysis. Specifically, the results section of the monitoring sheet includes the impact evaluations, relevant findings directly related to the objectives of the programme (stemming from other types of external evaluations and the progress of the indicators for results), as well as the way in which their measurement is carried out.
Taking into consideration the comments from the respective programme, the CONEVAL will finalise the report is issued. The evaluation unit will publish the monitoring and evaluation report. They will also send it to the corresponding bodies included in the report.
Note: This set of images is intended to illustrate how a user can navigate the monitoring data on the website of the National Agency on Corruption Prevention, starting from a general overview of the strategy’s broad axes and clicking to the implementation assessment of one activity linked with a specific topic, problem and objective.
References
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