To effectively address current and emerging fraud risks, anti-fraud strategies should be treated as living documents that evolve through the incorporation of evaluation findings into regular strategy updates. This chapter outlines key questions for anti-fraud strategy leads to consider when determining the nature and scope of strategy updates, highlights good practices for using evaluation results to inform revisions, and emphasises the importance of communicating progress and results to both internal and external stakeholders to foster policy coherence and continuous learning over time.
Evaluating, Updating and Monitoring Anti‑Fraud Strategies
A Methodology
Abstract
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. Evaluations of anti-fraud strategies should serve as a building block to adjust the strategy and action plan to achieve the desired change (baseline and mid-term evaluations), generate lessons for future strategies (end-term evaluations), and cultivate citizen trust in the policy process and support for anti-fraud efforts. The European Commission’s Guidelines on National Anti-Fraud Strategies take a similar approach to M&E. According to the Guidelines, the operational objectives of the NAFS should be updated or revised based on the results of M&E, introducing new measures or adjusting the existing measures, and updating indicators and deadlines. In addition, they emphasise the need to inform the general public about the measures taken under the anti-fraud strategy, including publishing information about the strategy and its operational objectives, and developing awareness-raising campaigns targeting whole-of-society, including specific sectors. (European Commission, European Anti-Fraud Office (OLAF), 2016[1])
Yet, OECD data shows that most OECD Member and partner countries that have relevant strategic objectives in place do not make use of outcome-level indicators and evaluation to demonstrate the concrete advantages of integrity improvements, and less than half of countries have an end of term evaluation planned as a formal activity (OECD, 2026[2]). This not only impacts countries’ ability to showcase the return on investment for implementing measures under an anti-fraud strategy, but also in defending resource allocation towards anti-fraud measures and making the case for further investments in such efforts.
Furthermore, while the adoption of anti-fraud and anti-corruption strategies is an increasing practice globally, gaps between strategic cycles are common, where strategies have sometimes expired for years before a new or updated strategy is developed (OECD, 2026[2]). This impacts countries’ ability to ensure that anti-fraud reforms are embedded and deliver sustained results, as strategy continuity and learning across strategic cycles is essential for anti-fraud strategies to be effective and serve as useful tools for reform – particularly given the rapidly evolving nature of fraud.
Against this background, ensuring strategic continuity and learning by incorporating the results of system-wide evaluations into every update of an anti-fraud strategy is a crucial step to ensure that efforts to fight fraud are effective. This includes ensuring that strategy updates are informed by high and cross-cutting fraud risks identified in Fraud Risk Assessments conducted by implementing entities of the anti-fraud strategy, which should be collected and consolidated by the central body responsible for strategy co-ordination. Consolidating data from Fraud Risk Assessments also equips strategy leads with information about high fraud risks in specific sectors (e.g. agriculture, energy, transport), which could inform sector-specific strategic objectives addressing emerging risks and building on lessons learned from past crises. (OECD, 2026[2])
Table 3.1 includes key criteria on evaluation practices to measure to what degree evaluations have informed decision making in the development of anti-fraud strategies and ensure transparent and effective evaluation practices, outlined by the OECD PII on evaluation practices (OECD, 2024[3]).
Note: The list of criteria in this table respond to the OECD Public Integrity Indicators, Principle 3, indicator 8.
Source: (OECD, 2023[4]) and OECD Public Integrity Indicators.
3.1.1. When is an update required?
Once an evaluation has been conducted (e.g. mid-term or end-term), there are a range of questions that the co-ordinating body of the anti-fraud strategy should consider to determine whether the anti-fraud strategy should be updated as well as the nature and extent of the update. An update of an anti-fraud strategy could entail updating or revising the primary and secondary objectives, adjusting the management resources, and/or adjusting the impact and outcome indicators. The nature and extent of the update will depend on the specific findings from monitoring and evaluation reports, as well as external factors such as structural, organisational or political changes. These considerations are outlined in Table 3.2 below and a more comprehensive list is included in Annex C in the form of a checklist for updating anti-fraud strategies and action plans to support the NAFS co-ordinator’s assessment of whether the current strategy or action plan is fit for purpose.
Note: By answering the following questions, the NAFS co-ordinating authority can assess whether an update of the NAFS is needed and, if so, determine the nature and extent of the revision required. A full description of the checklist and its intended purpose, user, interlinkages with other tools and guidance on application and limitations is provided in Annex C. The questions should be tailored to the relevant national context prior to be used for updating a NAFS.
Source: OECD Secretariat.
3.1.2. Communicating the results of evaluations
Communicating with both internal and external stakeholders about the progress and results under the anti-fraud strategy enables accountability, increases the credibility of integrity efforts and stimulates future action. In addition, the proactive publication of information and the availability of relevant data related to the anti-fraud strategy can serve as additional sources of evidence for monitoring and evaluation, while strengthening social oversight, the traceability of public management and analytical capacity regarding fraud risks and patterns. In this regard, the body responsible for co-ordinating the implementation, monitoring and evaluation of the anti-fraud strategy (often the AFCOS in EU Member States) should ensure that the results of monitoring and evaluation are appropriately communicated, and that the action plan is made publicly available, for instance by publishing monitoring and evaluation reports on a dedicated webpage managed by the central body, such as the AFCOS webpage. Table 3.3 provides an overview of some elements that the body responsible for co-ordinating the implementation, monitoring and evaluation of the anti-fraud strategy may consider when drafting both monitoring and evaluation reports.
Source: OECD Secretariat, based on, among others, (European Commission, European Anti-Fraud Office (OLAF), 2016[1]); (European Commission, 2022[5]).
Ensuring independence, objectivity, and clearly defined responsibilities is essential for guaranteeing the reliability of evaluation results. These factors are crucial when planning and designing future anti-fraud strategies that aim to address the limitations or weaknesses identified in previous iterations. Box 3.1 highlights successful examples from countries that have used evaluations to foster policy coherence and continuous learning over time.
Mid-term evaluation of Bulgaria’s National Strategy for Preventing and Combating Irregularities and Fraud 2021-2027
The Bulgarian AFCOS Directorate, with the support of the OECD under this TSI project, recently conducted a mid-term evaluation of its National Strategy for Preventing and Combating Irregularities and Fraud 2021-2027 (Bulgarian NAFS). The mid-term evaluation involved the collection of quantitative and qualitative data, benchmarking against the OECD Public Integrity framework, as well as surveys and structured interviews with several anti-fraud authorities involved in the implementation of the Bulgarian NAFS, such as managing authorities, national revenue and customs agencies, audit bodies, the public procurement agency, the public prosecutor’s office, and law enforcement bodies.
The mid-term evaluation followed the DAC evaluation criteria and set out a series of recommendations to improve the overall governance and implementation framework of the Bulgarian NAFS, as well as to cover key priority areas in the form of updated strategic and operational objectives to effectively address current and emerging fraud risks affecting the EU’s financial interests in Bulgaria.
Following the mid-term evaluation, the AFCOS Council will develop a new strategic document for the next programming period (2028-2034) that takes into consideration the recommendations provided. Importantly, the new Bulgarian NAFS will include measurable outcome indicators at the level of strategic and operational objectives to equip the AFCOS Directorate with the necessary information to effectively assess the level of achievement of objectives under the Bulgarian NAFS. The results of the mid-term review, including the new Bulgarian NAFS, will be published on the website of the AFCOS Directorate.
Mid-term evaluation of Greece’s sectoral Anti-Fraud Strategy 2021-2027
Greece adopted its first anti-fraud strategy in 2014, which was developed by the General Secretariat for Public Investments and the National Strategic Reference Framework (NSRF) through the Special Service for Institutional Support and Information Systems (EYTHYPS) under the National Coordination Authority. The Greek Anti-Fraud Strategy, which was updated in March 2017, covers operations supported by the European Regional Development Fund (ERDF), the Cohesion Fund (CF), the European Social Fund Plus (ESF+), the Just Transition Fund (JTF), and the European Maritime, Fisheries and Aquaculture Fund (EMFAF). As such, Greece has a sectoral national anti-fraud strategy rather than a national anti-fraud strategy covering all expenditure sectors.
The Special Service of Institutional Support and Information Systems (SISS) within the National Coordination Authority (NCA), is responsible for planning and monitoring the implementation of the Anti-Fraud Strategy in the framework of the Management and Control System. The SISS recently conducted a mid-term evaluation of its Anti-Fraud Strategy with the support of the OECD as part of this TSI project.
Following the mid-term evaluation, the SISS is in the process of updating its Anti-Fraud Strategy based on the recommendations made as a result of the mid-term evaluation. By delineating the responsibilities of the relevant entities in the anti-fraud architecture, defining strategic objectives and measures for their implementation, and designing indicators to monitor and evaluate progress, the mid-term evaluation supports Greece’s commitment towards a comprehensive approach to fighting fraud. The SISS recently conducted a meeting with the members of its Anti-Fraud Network (45 participants) to discuss the proposals for updating the Anti-Fraud Strategy and define next steps, building ownership for future strategy implementation among relevant stakeholders.
Source: Elaborated by the OECD Secretariat based on OECD Analytical Reports regarding the Review and Recommendations for Updated National Anti-Fraud Strategies in Bulgaria and Greece (unpublished).
To summarise, there are three core elements that should be included in evaluation systems of anti-fraud strategies to ensure that the results of evaluations inspire new action:
Effective communication. The results of evaluations should be communicated clearly to both internal and external stakeholders. For example, the OECD PII 3.5 on the adequacy of implementation structures and reporting requires public and civil society groups to be consulted on monitoring reports. Likewise, OECD PII criterion 3.8.2 assesses whether national authorities publish evaluation reports online. Communicating evaluation results to various groups is crucial for encouraging participation in decision making on future actions. A participatory approach at this stage, measured by criterion 3.8.3, helps bring diverse perspectives on what actions to take. If an objective remains unmet in a specific sector, stakeholders from that sector, or sector-service users, may offer valuable insights into the factors undermining efficacy and provide guidance on how to address those challenges in the future.
Feedback mechanisms to foster participation. To support a participatory approach, evaluation processes should include mechanisms for processing and responding to stakeholder feedback (Johnsøn, 2011[6]). These mechanisms promote accountability in how results are used. Formal feedback channels can include review processes, peer reviews, seminars, and workshops (Schütte, 2017[7]). For these mechanisms to be effective, they require adequate staff, financial resources, and the backing of senior management (OECD, 2010[8]). Therefore, feedback mechanisms should be incorporated into the evaluation process and budgeted accordingly. Unfortunately, these mechanisms are often overlooked in action plans. In a comparative analysis of 41 National Integrity Action Plans (NIACs), it was found that only a few countries had public feedback or participatory monitoring and evaluation mechanisms (Pyman, 2017[9]).
Having a plan for responding to feedback. The credibility of the evaluation system and the broader anti-fraud strategy is strengthened when feedback is systematically recorded, and transparency is maintained about whether (and how) strategy design or implementation is adjusted in response. Chile’s National Public Integrity Strategy, passed in December 2023, serves as an example. It was developed through a participatory approach, incorporating insights from public consultations. The strategy document details how these insights were integrated, providing transparency by listing academics and NGOs involved in the process, as well as the percentage of responses to each survey question conducted between October and November 2022 (Government of Chile, 2023[10]).
A proactive policy to respond to poor results will also help bolster credibility and accountability. In Colombia, for example, those tasked with achieving targets are required to provide detailed explanations when targets are not met, which is made publicly available on a government website (Mackay, 2007[11]). To ensure accountability for the implementation of recommendations, agreed follow-up actions should be tracked, and subsequent evaluations should assess whether recommendations were implemented and if they had the desired effects, as well as a review of the feedback and response mechanisms in place (Johnsøn, 2011[6]).
3.1.3. Being cognisant of potential spill-over effects from communication
Anti-fraud messaging plays a critical role at various stages of the strategy development cycle. Sensitising citizens and public servants about fraud and integrity issues can help build demand for the strategy and encourage diverse stakeholder participation in its development, monitoring, and evaluation through consultation and feedback processes. Raising awareness about specific fraud schemes or integrity related concerns, such as double funding or misrepresenting eligibility requirements to receive grant schemes, can also drive the behavioural changes the strategy seeks to achieve.
Furthermore, as Chapter 4 sets out below, communicating monitoring results is vital for ensuring that implementing agencies can identify which aspects of the anti-fraud strategy are working and where adjustments are necessary. Equally, publicising evaluations can enhance trust in the policy process. By making evaluation results accessible, citizens and watchdog organisations can see not only the positive impacts of reforms but also how policymakers acknowledge limitations and commit to addressing them in future iterations.
Anti-fraud strategies should include plans to communicate the results of both monitoring and evaluation in a way that is transparent, effective, and tailored to different audiences. A key distinction between monitoring and evaluation reports lies in their periodicity: monitoring data should be updated regularly, whereas evaluations are conducted at specific points in time. Consequently, while monitoring reports are routinely consulted by stakeholders involved in implementing the anti-fraud strategy, other actors (e.g. institutional donors or the general public) are more likely to engage with evaluations, which are infrequent and often covered by traditional media. This makes it all the more important to consider potential spill-over effects when communicating evaluation results. These effects can be beneficial, as demonstrating positive outcomes may strengthen public or political support for integrity efforts (Georgieva-Andonovska, 2016[12]). For example, showcasing audit exercises or investigations into breaches of regulations may deter future violations.
Nevertheless, research shows that not all messaging is effective and can backfire or produce negative, unforeseen side effects if not managed properly. For instance, some argue that telling individuals who are already aware of or have strong views on the issue that corruption is widespread risks signalling that many people engage in it, making it seem more socially acceptable. This can also suggest that the problem is too large to address, potentially discouraging public administration staff and citizens from taking action. If they perceive that everyone else is participating in fraudulent practices, they may feel that the rational choice is to follow suit. Additionally, factors such as the medium used and the credibility of the messenger are crucial determinants of whether a campaign is well received and can effectively promote the desired change (Peiffer and Cheeseman, 2023[13]).
Against this background, it is important to frame evaluation results in a way that fosters citizen’s trust in the reform process. Additionally, building awareness of accountability feedback loops, where citizens can meaningfully engage in reform efforts, can help prevent or counter citizen apathy. A delicate balance must also be struck when communicating negative results to internal stakeholders. Poor results should be viewed as a call to action, but care must be taken to avoid shaming, which could incentivise the manipulation of evaluation processes in the future. Focusing on overarching goals, rather than specific objectives or indicators, in management communication may reduce the risk of “gaming” the system. Many of these risks can be mitigated through continuous dialogue with stakeholders and by avoiding the communication of abstract information without sufficient context (OECD, 2017[14]).
In their “How-to Guide to Anti-Corruption Messaging”, Peiffer and Cheeseman outline several key principles for designing effective anti-corruption campaigns, which are equally applicable to communication campaigns for anti-fraud strategies:
Ensure messaging is clear, concise, and consistent
Avoid ’negative’ messaging about the extent of the problem
Refrain from blaming or shaming the audience
Use credible positive messaging where possible
However, the two researchers highlight that there are no universal solutions and stress the importance of tailoring, targeting and testing communications (“the three Ts”) to minimise the risks of ineffective or counterproductive messaging. Their findings and recommendations are summarised in the following communications work plan, along with the key questions to consider for each of its five stages:
1. How does awareness-raising feature in your theory of change? Will changing public attitudes lead to your desired outcomes? Is changing public perceptions feasible? Can messages be combined with policy changes or other expressions of commitment to anti-fraud to make them credible?
2. Identify key aims and how messages can be embedded within an anti-fraud strategy to maximise impact. Identify your target audience and learn about what they already believe and how they feel about the aims of your messaging campaign, so you can identify themes and issues that resonate and align with their values. Avoid negative descriptive messages and consider using positive, credible messaging, e.g. based on public disapproval of fraud.
3. Decide the best placed people and institutions to “author” and deliver the message, based on their credibility to your intended audience. Think through how your intended audience can be best reached, and which kinds of media are the most effective and accurate.
4. Focus groups can help to check that the meaning of a message is as intended. Use experimental techniques to test what impact messaging is most likely to have on your intended audience. Select only those messages shown to have a positive effect.
5. Design a monitoring and evaluation plan to assess impact. Communicate messages in conjunction with other interventions. Learn from what went wrong or right to inform future messaging campaigns.
Note: “Anti-corruption” has been replaced with “anti-fraud” by the OECD Secretariat to enhance the clarity of the message, given that the key principles are applicable to anti-fraud campaigns.
Source: Adapted from (Peiffer and Cheeseman, 2024[15]).
References
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[15] Peiffer, C. and N. Cheeseman (2024), A How-to Guide to Anti-Corruption Messaging, Center for International Private Enterprise (CIPE), https://www.cipe.org/resources/a-how-to-guide-to-anti-corruption-messaging/ (accessed on 22 March 2026).
[13] Peiffer, C. and N. Cheeseman (2023), “Message misunderstood: Why raising awareness of corruption can backfire”, U4 Brief, U4 Anti-Corruption Resource Centre, Chr. Michelsen Institute.
[9] 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).
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