Fighting Bid Rigging in Public Procurement in Austria, Bulgaria, Croatia, Cyprus, Greece and Romania

3. Institutionalising co‑operation to fight bid rigging

Abstract

This chapter discusses the role of co-operation in fighting bid rigging. Competition authorities cannot act alone: procurement bodies, audit institutions, the financial police, anti-corruption agencies and prosecutors may observe suspicious behaviour and support enforcement. The chapter explores the benefits, requirements and challenges of co-operation, drawing on the experience of the six countries. It reviews formal and informal co-operation mechanisms and presents common challenges and proposed solutions. Several common issues emerged across the countries: the importance of clear legal frameworks for information exchange, the value of formal agreements to ensure continuity, the reliance on informal channels and trust, and the need for training to recognise red flags and report them.

3.1. The role and objectives of institutionalised co-operation in fighting bid rigging

Co‑operation is indispensable for the detection and deterrence of bid rigging. Competition authorities cannot act alone: procurement bodies, audit institutions, the financial police, anti-corruption agencies and prosecutors may observe suspicious behaviour and support enforcement. Establishing formal and informal channels for co‑operation and information exchange can help ensure timely reporting of concerns and promote co‑ordinated responses to collusion risks. This chapter explores the benefits, requirements and challenges of co‑operation, drawing on the experience of the six participating countries.

Chapter 2 underscored that procurement officials and non-competition enforcers are key audiences for outreach. They are also the main counterparts for competition authorities, given their proximity to procurement processes, their oversight role and their potential to detect suspicious conduct. Unlike the private sector (which is the target of enforcement), these public authorities can be the partners of competition authorities, transmitting information and triggering enforcement. Where appropriate, such information or evidence may be shared in parallel with both the national competition authority and the European Commission (DG COMP), in line with the applicable legal framework. The following sections therefore focus primarily on co‑operation with these actors.

The analysis builds on discussions held during the project’s workshops and fact-finding meetings with national stakeholders (mentioned in Table A.A.2). These exchanges enabled the OECD team to assess the state of co‑operation, identify barriers and highlight good practices and potential improvements.

3.2. Formal and informal co‑operation mechanisms

Competition authorities often enter into co-operation agreements or Memoranda of Understanding (MoUs) with other public bodies, such as public procurement agencies, audit bodies or anti-corruption offices. MoUs typically include commitments to share information, consult on cases of mutual interest, provide training and participate in joint initiatives. Because the information involved can be confidential (for example, if it concerns ongoing investigations, tender documents or company data), MoUs usually contain specific clauses on the protection (and, in most cases, the non-sharing) of business-sensitive or confidential case information. MoUs are usually not legally binding. Still, they provide an institutional framework and signal a mutual intention to co‑operate.

Most project countries have MoUs to support inter-institutional co‑ordination, with varying degrees of formality and practical implementation.

• In Bulgaria, the Commission on the Protection of Competition (CPC) has MoUs with the National Audit Office (NAO), the Public Financial Inspection Agency, the Public Procurement Agency and the Chief Prosecutor’s Office. These agreements include provisions on mutual training, but implementation has been limited.

• In Croatia, the Croation Competition Agency (CCA) has a co‑operation agreement with the Ministry of Economy, which provides the CCA with access to the Electronic Registry of Public Procurement. The CCA also has an agreement with the State Attorney’s Office1 to strengthen co‑operation on the detection and prosecution of bid rigging. This includes mutual technical assistance, joint trainings and co‑ordination in public procurement cases.

• In Cyprus, the Commission for the Protection of Competition (CPC) has a co‑operation agreement with the Treasury of the Republic to provide for mutual advisory support, timely information exchange on matters of shared competence, notification of relevant decisions and case law concerning distortions to public procurement, and for the joint development of educational and informational initiatives aimed at preventing anti-competitive practices in public tenders.2

• In Greece, the Hellenic Competition Commission (HCC) signed a protocol of co‑operation in 2019 with the Hellenic Single Public Procurement Authority.3

• In Romania, a bid-rigging module was established in 2010 as a multi-agency platform4 to support co‑operation. It holds regular meetings (including four in 2023) to facilitate experience-sharing and co‑ordinate detection efforts across institutions.

The existence of an agreement does not always guarantee co‑operation. Some MoUs remain underused due to rigid provisions, insufficient institutional buy-in or lack of implementation measures. Formal co‑operation needs to be supplemented by practical operational arrangements (such as designated focal points or templates for information sharing) that translate commitments into interaction.

Therefore, alongside formal instruments, informal co‑operation can be an important co‑operation path. Some competition authorities have informal co‑operation channels with procurers and other bodies. Informal co‑operation can be more agile and responsive, as it relies on working-level relationships between officials and tends to develop organically through prior collaboration, personal contacts or participation in task forces and working groups. Informal mechanisms may include ad hoc exchanges of information, case referrals or expert consultations. While such co‑operation may lack the structure and visibility of MoUs, it can be effective in contexts where institutional trust is strong, and confidentiality requirements are respected. Stakeholders interviewed for this project’s fact-finding stressed that informal channels and interpersonal trust were particularly valuable.

Both forms of co‑operation (formal and informal) have advantages and limitations. Formal agreements offer predictability and institutional accountability, while informal exchanges allow for flexibility and responsiveness. Ideally, competition authorities should foster a dual approach: securing formal agreements to set the basis for co‑operation, while promoting a culture of routine and informal interaction at operational level. This combination can help ensure that channels of co‑operation are not only established but actively used.

3.3. Lessons from fact-finding meetings on co-operation

The OECD team conducted fact-finding meetings with competition and procurement authorities, oversight bodies and prosecutors in the six countries. These exchanges gave insights into how co‑operation functions in practice. The discussions helped identify institutional strengths and successes, barriers to information sharing and opportunities to make co‑operation more systematic and sustainable.

The following country-by-country review summarises the main insights from these fact-finding interviews. Each subsection highlights the specific mechanisms in place, the challenges reported and the potential avenues for strengthening co‑operation.

3.3.1. Austria

Fact-finding interviews with the Federal Procurement Agency (BBG) highlighted potential paths for co‑operation. BBG staff explained that suspicions of collusion are referred first to the Chief Compliance Officer and then to the BBG’s legal department, which assesses whether the matter should be reported to the Federal Competition Authority for Austria (AFCA). In practice, much of the detection work relies on scrutiny of bids in sensitive markets, where few large players dominate.

The BBG maintains internal channels for escalating suspicions and uses its own whistleblowing system. However, only the legal department is authorised to transmit information; operational departments cannot. The BBG underlined that under current law, tenders can only be suspended or bidders excluded on the basis of a final conviction, not on the basis of suspicion.

The BBG expressed interest in further training from the AFCA on recognising bid-rigging patterns across tenders and clarifying under which conditions exclusion or self-cleaning may apply. It also pointed to the potential use of digital tools and databases to strengthen detection, and noted the lack of a centralised procurement database as a major obstacle.

Discussions with the Public Prosecutor’s Office of Economic Affairs and Corruption of Austria (WKStA) confirmed that co-operation with the AFCA is working well in practice. This is especially true of joint investigations such as in the road construction cartel, mentioned in Section 1.4. The two institutions have conducted joint searches, divided investigative tasks and shared evidence. However, challenges remain around the treatment of leniency applicants and key witnesses. Under Austrian criminal law, WKStA cannot access the identity or statements of leniency applicants co‑operating with the AFCA, which they may need for their cases. WKStA noted that ECJ case (C-2/23)5 may clarify the balance between EU confidentiality rules and national criminal prosecution.

WKStA also pointed to the lack of a clear legal basis for co‑operation. While informal channels exist, there is no regulation requiring WKStA and the AFCA to inform each other of cartel cases. Officials stressed the need for formal agreements or MoUs that would ensure continuity of co‑operation. They suggested simple frameworks covering information sharing, mutual training and designated points of contact.

Other than these specific challenges, the overall relationship is constructive. Joint training activities are already planned, and both sides expressed openness to formal co‑operation.

3.3.2. Bulgaria

Fact-finding meetings in Bulgaria involved the Public Financial Inspection Agency (PFIA), the Public Procurement Agency (PPA) and the NAO. Each institution plays a distinct role in the procurement cycle.

In Bulgaria, the CPC has a dual mandate: it enforces both competition law, and public procurement and concessions law. The CPC is the review body for appeals against the legality of procurement and concession decisions under the Public Procurement Act and the Law on Concessions.

Fact-finding meetings stressed that formal co‑operation frameworks are underused. Detection of bid rigging is not yet embedded in day-to-day control functions; additional training, contact and clearer co‑operation protocols for use in the field with the CPC would be useful.

The PFIA conducts ex post financial inspections of procurement procedures, often one to two years after award. Inspectors focus on administrative compliance by contracting authorities. Where breaches are within the PFIA’s remit, they can impose sanctions; when issues fall outside their competence, they refer matters to the relevant body (including the CPC or the public prosecutor). In practice, referrals to the CPC occur only after the PFIA finalises its own inspection (draft report, objections period and final report). The PFIA does not alert the CPC at earlier stages. There have been no recent referrals specifically on bid rigging, and cartel indicators are rarely visible in the documents reviewed ex post.

A 2017 multi-party MoU covering information exchange exists, and a 2011 tripartite agreement (PFIA-NAO-CPC) addressed bid-rigging co‑operation more directly. However, both instruments have seen limited operational use. The PFIA cited the ex post nature of its work, the evidentiary threshold it applies before referring cases and closer day-to-day links with the prosecutor. The PFIA highlighted practical needs: (1) more CPC-led training on bid-rigging red flags and evidentiary expectations; and (2) simple referral templates and focal points.

The PPA is positioned upstream in the procurement cycle. Co‑operation with the CPC is grounded in the Public Procurement Act and complemented by an MoU under review. The PPA supplies the CPC with market-monitoring information (e.g. statistics on complaints in procurement review cases). It works to provide the CPC with tailored access to the national e‑procurement platform, including data fields requested by the CPC. The e‑procurement platform centralises tender information and is publicly accessible (basic fields). While the public sees limited data (e.g. number of bidders, award price), the CPC can obtain full tender datasets (including bidder identities, bid prices and metadata) upon request. Technical solutions are being finalised to streamline this access.

Since mid-2024, all procedures above BGN 5 million are subject to PPA ex ante control focussed on tender design, documentation and evaluation methodology, aimed at removing barriers to participation. The PPA also runs random ex post control and mandatory checks (e.g. single-bid tenders are systematically flagged). Under the National Recovery and Resilience Plan, the PPA is tackling single bidding, including outreach to firms to understand non-participation (reported reasons include legal instability, complex documentation, low estimated values and insufficient market research).

The PPA sees scope to deepen practical co‑operation with the CPC through (1) regular case discussions; (2) training for contracting authorities and businesses on competition risks on bid-rigging patterns and red flags; and (3) routine contact points. Staff exchanges are not feasible at present due to capacity constraints and vacancies. The PPA supports more frequent meetings among all procurement-oversight bodies to align terminology, approaches and expectations.

The NAO participates in two co-operation frameworks with the CPC: the 2017 multi-party MoU (on broader topics) and the 2011 tripartite agreement (CPC-NAO-PFIA) focussed on bid rigging. The latter is considered still substantively adequate, but largely “dormant” in practice due to workload pressures and the absence of regular triggers for engagement. BNAO audits concentrate on the acts of contracting authorities, not on bidder behaviour. As a result, bid-rigging indicators are infrequently encountered during audits, although auditors have full access to tender documents when needed. One case involved identical formatting and errors across two bids, which raised suspicion.

The BNAO suggested renewing co-operation through: (1) CPC presentations of closed bid-rigging cases to auditors and PFIA experts; (2) small expert workshops (beyond classroom training) to discuss real cases; (3) designated liaison officers in each institution to sustain continuity in co‑operation; and (4) exploring digital screening tools as e‑procurement matures. They also noted that contracting authorities sometimes refrain from alerting the CPC to avoid perceived disruption of contract execution, and that no statutory deadline to report suspicions exists.

Across PFIA, PPA and BNAO, interviewees converged on three priorities: (1) operationalising existing MoUs with simple, ready-to-use procedures (referral templates, contacts); (2) regular, CPC-led capacity building tailored to each institution’s role (ex ante design checks, ex post audits, financial inspections); and (3) streamlined data access for the CPC from the e‑procurement platform, with clear protocols on confidentiality and use.

3.3.3. Croatia

Fact-finding included the State Commission for the Control of Public Procurement Procedures (DKOM) and the Ministry of Economy’s Directorate for the Public Procurement System (DPPS). Overall, co‑operation is described as good (formalised by agreement on co-operation and complemented by regular informal contacts). Meanwhile, operational improvements are sought in access to data, joint training and mainstreaming collusion content into the certification of procurers.

DKOM is the first instance review body for procurement remedies, and its decisions are fully public. Co‑operation with the CCA has strengthened over the past four to five years and is both formal and informal (exchanges, advice requests and joint workshops). DKOM has full access to the e‑procurement platform, based on national public procurement law, enabling it to download complete tender files. Although DKOM’s proceedings are based on written evidence and focused on legal review of procurement acts, commissioners occasionally detect red flags (e.g. recurring subcontractor patterns, unexplained documentation omissions, computational errors). In such cases, DKOM alerts the CCA and transmits the file.

DKOM underlined three priorities: (1) joint training on common bid-rigging schemes identifiable at the evaluation stage; (2) involving the State Attorney and auditors in joint events; and (3) sustaining close informal contact with the CCA alongside the formal agreement. Staff exchanges are not envisaged in the short term due to capacity constraints, while knowledge exchange is preferred.

The DPPS leads procurement policy, legislation, strategy and supervision and oversees the e‑procurement platform. Co‑operation with the CCA is underpinned by an agreement that provides the CCA access to tender data, with a legal obligation to meet at least annually. In practice, contact is both formal and on-demand, including responses to CCA data requests.

DPPS manages the certification system for public procurement officials (initial 50 hours plus renewal every three years, with additional training). While competition features as a principle in the Public Procurement Law, collusion is not yet a mandatory module. Officials considered it feasible to add collusion content to initial or renewal curricula via by-law amendment (after public consultation), noting that uptake depends on perceived relevance among certified officials.

The DPPS favours pragmatic co-operation: (1) keeping agreements light and flexible while ensuring data access for the CCA; (2) co-hosting events (e.g. on the new e-procurement platform) with CCA participation; and (3) exploring case-based training focused on Croatian examples, which stakeholders find most compelling. As in other institutions, staffing constraints (retirements, vacancies) limit options for staff secondments.

Key takeaways for strengthening co‑operation include: (1) regular case discussions among DPPS, CCA, DKOM (and, where relevant, the State Attorney and auditors); (2) embedding collusion modules in the procurer certification/recertification; and (3) ensuring CCA’s analytical access to the e‑procurement database, including standardised extracts to support screening.

3.3.4. Cyprus

Fact-finding meetings in Cyprus included the Public Procurement Directorate of the Treasury of the Republic, the Audit Office of the Republic and the Tenders Review Authority (TRA). Co‑operation with the CPC is based on a recent MoU and ad hoc operational contacts. Overall, stakeholders reported constructive engagement and a shared interest in strengthening data access and training, while noting capacity constraints and a challenge.

The Public Procurement Directorate leads on procurement policy, EU-law transposition, issuing guidance and standard tender documents; professionalisation of the procurement workforce; and operation of the e‑procurement system. An MoU with the CPC (in 2022) sets an intention to co‑operate. It was described as useful in signalling commitment to mutual initiatives, but insufficiently concrete. The directorate is not seeking formalised or standardised co-operation frameworks, but pragmatic arrangements that include training and data sharing. In 2024, it held several technical meetings with the CPC to discuss among others the new e- procurement system. While CPC requested the inclusion of several variables relevant for collusion screening, only some could be incorporated due to the system’s original design objectives and cost constraints. CPC has also requested direct access to the system, with a response from the Directorate still pending. As a result, there remains uncertainty as to whether the system will effectively support the detection of bid rigging in public tenders.

The directorate can invite the CPC to its trainings to show red flags. It would be important to clarify to contracting authorities that reporting suspicions to the CPC does not automatically stop tender procedures. A strong policy priority is transparency (e.g. publishing bid prices) to bolster public trust, which requires balancing with collusion-risk considerations. Looking ahead, the directorate sees value in two-way information flows: CPC access to raw procurement data, and CPC feedback on market risks to help shape tender design.

The Audit Office is an independent body conducting real-time and ex post audits on public tenders. It may review tender documents for legality and value for money, and provide non-binding recommendations to contracting authorities. Complainants sometimes approach the Audit Office because its process is free, unlike TRA appeals. Co‑operation with the CPC is case based. The Office has sent findings to the CPC in specific matters (e.g. where one firm repeatedly won) and has participated in CPC unannounced inspections. Officials noted that, when support is needed, they contact the CPC directly. Therefore, they did not see an immediate need for a formal MoU. At the same time, they expressed openness to deepening engagement through training and awareness activities (e.g. on bidder exclusion and bid-rigging indicators).

The TRA is a quasi-judicial review body with five members who assess the legality of procurement decisions. It receives around 47‑50 appeals per year. However, since appeals concern procedural legality, bid rigging is not something they might encounter. The TRA expressed interest in informal meetings with the CPC to discuss general market concerns.

3.3.5. Greece

Fact-finding in Greece included the Hellenic Court of Audit (HCA) and the Hellenic Single Public Procurement Authority (HSPPA). Stakeholders stressed the importance of structured, confidential co‑operation. They also highlighted that the Greek procurement system has strong ex ante legality controls and a mature e‑procurement/transparency infrastructure.

The HCA6 has constitutional and statutory competences over public contracts. While its primary focus is compliance with procurement law, bid-rigging indicators can occasionally surface (e.g. recurring winners by sector/region). However, the one-month window for pre-award control and confidentiality constraints make detection and referral to the HCC challenging.

The HCA indicated that any co‑operation instrument should respect the Court’s judicial nature and strict confidentiality rules. Therefore, a general, light MoU (or equivalent protocol) between the HCA and the HCC would be best to (1) set high-level principles for confidential communication; (2) provide for joint seminars and working groups; and (3) designate liaison officers. Staff-level exchanges or joint technical groups could be feasible.

The HSPPA issues opinions and guidance, monitors compliance, supports contracting authorities and reviews preliminary appeals. An MoU on bid rigging was signed with the HCC, but stakeholders underlined that co‑operation to date is on an informal, case-by-case basis. HSPPA officials come across potential competition distortions in their review and audit functions. When this happens, they advise contracting authorities to contact the HCC directly and, where appropriate, guide them on how to proceed. At least ten such referrals were made in 2024.

Co‑operation is considered essential because many bid-rigging investigation leads originate from contracting authorities or from the HSPPA’s oversight work. The HSPPA also assesses and advises contracting authorities on self-cleaning.

Priorities identified jointly by the HSPPA and the HCC include:

• Data access and usability: pursue joint meetings with the Ministries of Digital Governance and Infrastructure to secure access for the HCC and the HSPPA to the national procurement platforms ESIDIS and KIMDIS. Current access is ad hoc. Permanent data access would likely require legislative adjustments but would allow the HCC and the HSPPA to obtain the historical and statistical data needed for screening collusion risks (e.g. bidder identities, links, timestamps, pricing metadata) without having to request permission from contracting authorities. The HSPPA is interested in statistical monitoring and the HCC in detailed competition-relevant data. The ongoing platform upgrade provides an opportunity to provide for such access.

• Capacity building: joint trainings for contracting authorities on tender issues (e.g. how to proceed when suspicions arise, evidence preservation, exclusion/self-cleaning).

• Information exchange infrastructure: support creation of databases on past infringements and ensure that contracting authorities have access to competition authority decisions on bid rigging. This would allow public buyers to verify information beyond self-declarations and to identify operators previously sanctioned. Practical steps could include a contact point for transmitting decisions or sector-level information on ongoing investigations; while decisions are public, they are difficult for contracting authorities to track systematically.

• Revision of the MoU: consider negotiating a new protocol between the HCC and the HSPPA, keeping clauses that have proven useful and introducing new provisions. Possible elements include: (1) enabling HSPPA, at its discretion, to pass on alerts received from contracting authorities to the HCC, balancing the need to protect their relationship with the value of timely competition alerts; (2) clarifying that the transmission of such information should depend on the case and the quality of the information, to avoid overloading the HCC with unsubstantiated signals; and (3) adding co‑operative elements such as joint advocacy for procurement data access and more frequent joint seminars for contracting authorities.

3.3.6. Romania

Fact-finding in Romania involved the Court of Accounts (Directorate for Public Procurement Control) and the National Agency for Public Procurement (ANAP). Stakeholders reported functioning co‑operation frameworks and referrals, alongside a strong push to improve data access to make co‑operation more systematic.

The Court of Accounts is Romania’s supreme audit institution, conducting ex post audits of contracting authorities (including procurement) at central and county level. The Directorate for Public Procurement Control applies two complementary methodologies to select procedures for review using financial and procurement data, media reports and prior audit results: a risk-based financial audit approach and a conformity audit. Teams examine the way tender procedures were designed and conducted, identifying irregularities and fraud risks.

Co‑operation with the Romanian Competition Council (RCC) is grounded in a protocol first concluded in 2021 and updated in 2023. When audits reveal suspicions of fraud or collusion, the Court notifies the competent authority. A past notification helped trigger an RCC investigation that led to an infringement decision. Officials highlighted that co‑operation was effective but could be improved, particularly around digital data-sharing and timeliness.

Access to procurement data is obtained via the e‑procurement portal through ad hoc data requests to the digital agency in charge of the e‑procurement platform. Relationships are good and response times quick, but stakeholders highlighted data-quality concerns. The Court is investing in data-driven auditing and plans a risk-analytics platform that would integrate procurement with vertical datasets (e.g. sectoral data). Officials emphasised that without robust and interoperable digital tools, co‑operation gains will be limited.

Priority actions identified by the Court include: (1) mutual training (budget permitting), including closed-case presentations and targeted red-flag sessions; and (2) exploring legal simplification of the procurement framework to reduce ambiguity.

The ANAP leads procurement policy, oversight and ex ante control. Its selective ex ante checks occur at two stages: (1) before tender notice publication, reviewing documentation (division into lots, estimated value, barriers to entry); and (2) during evaluation, reviewing selection and award criteria and their application. Where there are bid-rigging red flags, the ANAP advises contracting authorities to report to the RCC.

Co‑operation with the RCC is long-standing, including their joint opinion clarifying how exclusion and self-cleaning should be applied to bidders sanctioned for collusion (mentioned in Section 2.4.5). More broadly, co‑operation is supported by a formal protocol that was renewed in September 2025. Discussions on the renewal focussed on strengthening the exchange of data and information and standardising referrals. The ANAP was also interested in collusion patterns and RCC enforcement trends to support guidance and training for contracting authorities.

3.4.  Conclusions on fighting bid rigging through institutional co‑operation

Effective co‑operation can become the bridge between awareness, prevention and enforcement. The advocacy efforts outlined in Chapter 2 equip public officials with the skills to prevent, spot and report bid-rigging risks, and co‑operation can turn this knowledge into action. Across all six countries, Chapter 3 highlighted that several bid-rigging investigations were initiated based on alerts or informal tips from procurement bodies, auditors and anti-corruption entities.

Overall, fact-finding confirmed that formal co‑operation frameworks, such as MoUs, can enable inter-institutional collaboration. Still, interviewed stakeholders often pointed out that legal frameworks alone are insufficient to ensure co‑operation. Even where reporting channels exist, there can be a lack of clarity on information sharing. Several stakeholders mentioned they did not feel comfortable reporting “just suspicions of collusion”. Informal relationships and trust matter.

Interviewees stressed that co‑operation improves when procurement officials are trained to recognise red flags and understand what and how to report. Procurement officials mentioned the need for continuous training and clear, user-friendly guidance on the requirements of competition law. Project participants often repeated that competition officials also need to understand procurement law and practice.

The project confirmed that co‑operation requires institutional commitment at the top, repeated engagement and an understanding of different institutional constraints and incentives.

Across the six countries, a few practical lessons recur:

• Balance formal and informal channels: light, flexible MoUs (or protocols) that set principles, confidentiality safeguards and roles work best when paired with regular working-level exchanges.

• Reduce barriers to co‑operation: single points of contact in each body and simple referral templates can make co‑operation easier.

• Secure lawful data access: comprehensive access to e‑procurement systems (including historical and machine-readable procurement data) is essential for screening and detection. Where needed, public bodies should get access for all lawful purposes and apply appropriate information confidentiality safeguards, including by seeking law reforms to this end.

• Invest in joint capacity building.

Notes

← 1.  For further detail, see: https://www.aztn.hr/en/potpisan-sporazum-o-suradnji-agencije-za-zastitu-trzisnog-natjecanja-i-drzavnog-odvjetnistva-republike-hrvatske/.

← 2.  For further detail, see: http://www.competition.gov.cy/competition/competition.nsf/All/C46E21F798A7804EC2258A460024DAD6?OpenDocument&highlight=%CE%BD%CF%8C%CE%B8%CE%B5%CF%85%CF%83%CE%B7.

← 3.  For further detail, see: https://www.epant.gr/enimerosi/deltia-typou/item/10-deltio-typou-mnimonio-synergasias-epitropis-antagonismoy-eaadisy.html.

← 4.  The participating agencies include the Romanian Competition Council, the National Public Procurement Authority, the National Council for the Resolution of Complaints, the Prime Minister’s Control Corps, the Romanian Court of Accounts, the Public Prosecutor’s Office in the High Court of Cassation and Justice, the Anti-Fraud Department, the Romanian Digital Agenda Agency and the National Anti-Corruption Directorate.

← 5.  The Judgement was rendered on 30 October 2025. For further detail see: https://eur-lex.europa.eu/eli/C/2025/6587/oj/eng

← 6.  The Hellenic Court of Audit is a supreme judicial and audit body of Greece, established by the Constitution, which safeguards transparency and legality in the management of public finances. Among its judicial functions, it supervises and audits the accounts of the State and performs ex ante and legality checks on major public contracts.