Examples of public procurement risks throughout the procurement cycle: Managing Public Procurement Risks in Greece

Pre-tendering phase
Needs analysis (assess budgetary constraints, ensure alignment with organizational objectives, …)
Risk	Root cause	Risk category	Mitigation measures
Needs are determined based on approved budget and not on real needs based on needs analysis	Lack of supporting tools to conduct needs analysis	Operational	Development of needs analysis checklist, including elements to establish the requirements in terms of timing, quality, and quantities
	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
	Approval of the budget before the registration of their needs	Fiscal	Capacity-building activities on needs analysis Put in place processes at the contracting authority-level for needs analysis prior to budget approval
Influence of external actors on the definition of needs	Lack of integrity trainings for procurement staff	Operational	Capacity-building activities on integrity in public procurement
	No safeguards in place to prevent integrity breaches	Fraud and corruption Operational	Validation of the procurement plan by the head of the public entity Validation of any changes to the procurement plan by the head of the public entity Adoption of anti-corruption strategy/ policy/ action plan Adoption of two person rule (at least two officials in each department) Rotation of officials Conduct regular audits
	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
	Lack of guidelines on integrity in public procurement	Operational	Development of a code of conduct
	Corruption or conflict of interest	Fraud and corruption	Validation of any changes to the procurement plan by the head of the public entity Promote whistle-blowing mechanisms Carry out regular audits Rotation of procurement officials
Needs analysis are based on wrong information on the market (such as artificial shortage of goods and services)	Collusion among economic operators	Fiscal	Build the capacity of procurement officials on the identification of collusive practices
	Lack of capacity to conduct proper market analysis	Operational	Capacity-building activities on needs analysis
Inadequate needs analysis (e.g. lack of understanding of the real needs)	Lack of assignment of clear responsibilities related to gathering needs and lack of involvement of appropriate employees	Operational	Preparation and publication of an annual procurement plan that includes information such as budget, expected timeline and a brief description of the needs Involve employees that can contribute to the definition of needs
	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis Creation of professional networks or communities of practice for public procurement officials to facilitate networking and the exchange of experience
	Lack of knowledge of the legal requirements of the public procurement law	Operational	Provide comprehensive training programmes for procurement staff on relevant legal requirements and regulations
	Lack of supporting tools to adequality perform needs analysis	Operational	Development of needs analysis checklist, including elements to establish the requirements in terms of timing, quality, and quantities
	Involvement of third party actor not aware of the real needs of the entity	Operational Fraud and corruption	Capacity-building activities on integrity in public procurement Capacity-building activities on needs analysis
	Needs analysis focusing on a chosen item (product) instead of the real need	Operational	Capacity-building activities on needs analysis Involving end users in the definition and validation of needs (through surveys, meetings, questionnaires, etc.)
Lack of needs analysis	Lack of clarity and details regarding the statement on the definition of the needs made by the public entity	Legal/regulatory/compliance	Preparation and publication of an annual procurement plan that includes information such as budget, expected timeline and a brief description of the needs
	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
	Lack of knowledge of the legal requirements	Operational	Provide comprehensive training programmes for procurement staff on relevant legal requirements and regulations
	Lack of supporting tools to conduct needs analysis	Operational	Development of needs analysis checklist, including elements to establish the requirements in terms of timing, quality, and quantities
Estimation of needs not recorded	Lack of capacity to adequately record needs	Operational	Capacity-building activities on needs analysis and organisational procedures Use of an information system for recording needs
	Lack of knowledge of legal requirements for estimation of needs	Operational	Provide comprehensive training programmes for procurement staff on relevant legal requirements and regulations
	Lack of internal recording systems for procurement documents including needs analysis	Operational	Implement a knowledge management system and guidelines to ensure procurement documents are adequately archived
Unjustified needs	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
	Lack of knowledge of legal requirements of the public procurement law	Operational	Provide comprehensive training programmes for procurement staff on relevant legal requirements and regulations
	Needs not clearly defined	Legal/regulatory/compliance Fraud and corruption	Capacity-building activities on needs analysis and relevant legal requirements
Corruption (actors influencing the definition of needs) and/or conflict of interest	Lack of guidelines on integrity in public procurement	Fraud and corruption Operational	Capacity-building activities on integrity in public procurement Development of a code of conduct
	No suitable control and review systems in place	Fraud and corruption Operational	Validation of the procurement plan by the head of the public entity Validation of any changes to the procurement plan by the head of the public entity Regular internal audits on the procedures Rotation of procurement officials Robust vetting and selection of officials
Needs analysis does not take into account functional or operational prerequisites (e.g. personnel, facilities or infrastructure) to allow the use of the supplies needed	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
	Lack of knowledge regarding existing functional prerequisites	Operational	Capacity-building activities on needs analysis
Not taking into account the specific needs of some end users (such as women, people with disabilities, etc.)	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
	Lack of communication with users	Operational	Involving end users in the definition and validation of needs (through surveys, meetings, questionnaires, etc.)
Political interference in needs analysis and planning	Lack of safeguards to avoid political interference	Fraud and corruption Operational	Develop and publish evidence-based business case for the procurement (linking it to the entity's operational and business planning process) Promote whistle-blowing mechanisms
Tight timeframes limiting the time to carry out proper needs analysis	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
Change in scope of needs	Lack of consultation with potential users	Fraud and corruption Operational	Involving end users in the definition and validation of needs (through surveys, meetings, questionnaires, etc.)
Change in scope of needs	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis
Insufficient capacity to conduct a complete needs assessment	Lack of training and supporting tools to conduct needs analysis	Operational	Capacity-building activities on needs analysis
	Lack of a digital system with up-to-date inventory data	IT	Use a digital inventory management system that tracks and updates data for needs assessment
	Lack of capacity to conduct needs analysis	Operational	Capacity-building activities on needs analysis

Pre-tendering
Market engagement (identify and reach out to potential suppliers, conduct meetings, site visits, engage in collaborative discussions with suppliers, ..)
Risk	Root cause	Risk category	Mitigation measures
Lack of engagement and consultation with the market	Lack of knowledge of the legal requirements	Operational	Provide comprehensive training programmes for procurement staff on relevant legal requirements and regulations
	Lack of capacity on how to engage with the market	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices
	Lack of guidelines on how to engage with the market	Operational	Develop market engagement guidelines
	Conduct below the limit procedure to avoid using ESIDIS platform for market engagement	Fraud and corruption	Monitor the progress of market engagement activities regularly and conduct reviews to identify any deviations from the planned approach
	No mandatory use of the consultation platform provided through ESIDIS	Operational	Monitor the progress of market engagement activities regularly and conduct reviews to identify any deviations from the planned approach Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices
	No mandatory legal requirement to conduct market consultation	Legal/regulatory/compliance	Consider introducing mandatory market consultation for certain procedures
Poor understanding of the needs of the entity by economic operators	Market engagement communications are not well-organized, lack clarity, or are ambiguous, leading to misunderstandings	Operational	Use standardised templates for market engagement Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices Communicate with the market in a clear, detailed, and unambiguous way
Corruption risks when engaging with market actors	Close interaction between officials and economic operators	Fraud and corruption	Share relevant information with all economic operators and keep records of meetings with economic operators Widely disseminate information about upcoming tenders and opportunities to participate in market consultations Maintain thorough documentation of all market engagement activities, including supplier interactions, communications, and decisions made Rotation of procurement officials
	Lack of safeguards and internal control system	Operational Fraud and corruption	Maintain thorough documentation of all market engagement activities, including supplier interactions, communications, and decisions made Strengthen internal controls by implementing robust systems for monitoring, reporting, and auditing public procurement procedures Carry out regular audits Rotation of procurement officials Robust vetting and selection of officials
	Lack of guidelines on integrity in public procurement	Operational Fraud and corruption	Development of a code of conduct Develop market engagement guidelines which address integrity issues
	Lack of capacity on how to engage with the market	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices
Collusion between economic operators during the market engagement phase	Lack of safeguards and internal control system to avoid communication between potential bidders	Fraud and corruption	Build the capacity of procurement officials on the identification of collusive practices Include clauses in the consultation process that outline the consequences of providing false information, such as disqualification from future tenders or legal action Avoid unnecessary meetings and other opportunities which may allow potential bidders to communicate
	Lack of enforcement of specific provisions in the PPL (article 73.4) regarding the market engagement procedure, ensuring transparency and integrity	Legal/regulatory/compliance	Include clauses in the consultation process that outline the consequences of collusive practices, such as disqualification from future tenders or legal action.
Unequal treatment of economic operators when engaging with them (e.g. providing more information to some economic operators)	Conflict of interest / corruption	Fraud and corruption	Ensure that relevant information is shared with all economic operators and keep records of meetings with economic operators Widely disseminate information about upcoming tenders and opportunities to participate in market consultations Development of a code of conduct Rotation of procurement officials Robust vetting and selection of officials
	Lack of capacity on how to engage with the market	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices
	Lack of guidelines on how to engage with the market	Operational	Develop market engagement guidelines
	Lack of enforcement of specific provisions in the PPL regarding the market engagement procedure, ensuring transparency and integrity	Legal/regulatory/compliance	Offer regular training sessions for procurement staff focused on legal requirements regarding market engagement strategies, techniques, and best practices
	Lack of knowledge needed to secure the equal treatment of economic operators	Operational	Conduct regular training sessions for procurement staff on the principles of fair competition and equal treatment of economic operators Share relevant information with all economic operators and keep records of meetings with potential bidders Widely disseminate information about upcoming tenders and opportunities to participate in market consultations
Lack of capacity within contracting authorities to engage with the main market players	Lack of guidelines on how to engage with the market	Operational	Develop market engagement guidelines, including how to identify the main market players
	Lack of staff	Operational	Assess current staff roles and responsibilities to ensure optimal allocation of tasks Conduct targeted recruitment campaigns to attract qualified procurement professionals Outsourcing market engagement
Economic operators do not respond to the call for consultation	Lack of capacity on how to engage with the market	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices
	Lack of attractiveness of the opportunity	Operational	Provide clear incentives such as public recognition, detailed feedback, and opportunities for future engagement to encourage economic operators to participate actively in consultations Collaborate with industry associations to encourage their members to participate in the consultation Validate that needs are communicated to the market in a detailed and accurate way
	Bad reputation of the contracting authority	Operational	Make the consultation process as straightforward as possible, reducing barriers to participation by providing clear instructions and support throughout the process Increase transparency in procurement processes by clearly communicating procedures, criteria, and decisions Regularly monitor potential reputational risks and address them proactively
Engagement with the wrong (e.g. not relevant) economic operators	Lack of capacity on how to engage with the market	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices
	Failure to identify the main market players	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices Maintain records of economic operators' contacted during market engagement (e.g. in an information management system) Participate in private sector events to actively engage with the market and stay informed about emerging trends and opportunities
	Lack of guidelines on how to engage with the market	Operational	Develop market engagement guidelines Monitoring by contracting authorities of the register for excluded economic operators

Pre-tendering phase
Market analysis (identify potential suppliers, analyse market trends, assess the competitive landscape by understanding competitors' offers.)
Risk	Root cause	Risk category	Mitigation measures
No market analysis is performed	Lack of capacity on how to conduct market analysis	Operational	Capacity-building activities on market analysis Use of standardised process and templates for market analysis such as the OECD market analysis checklist
	Lack of market engagement	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices Conducting interviews (in the pre-consultation process) with market stakeholders or people with expertise in a field Review existing market research reports to gain a comprehensive understanding of the current market landscape and supplier capabilities Participate in private sector events to actively engage with the market and stay informed about emerging trends and opportunities
	Lack of market analysis to favour a specific economic operator	Fraud of corruption	Use of standardised process and templates for market analysis such as the OECD market analysis checklist Validation of the market analysis report by the head of the procurement department/ head of contracting authority
Inadequate market analysis (e.g. lack of economic analysis of the market, insufficient market research)	Lack of capacity (e.g. lack of guidelines) on how to conduct market analysis	Operational	Capacity-building activities on market analysis Use of standardised process and templates for market analysis such as the OECD market analysis checklist Develop guidelines on market analysis
	Lack of market engagement	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices Conducting interviews (in the pre-consultation process) with market stakeholders or people with expertise in a field Review existing market research reports to gain a comprehensive understanding of the current market landscape and supplier capabilities Participate in private sector events to actively engage with the market and stay informed about emerging trends and opportunities
	Budget not aligned with market reality	Fiscal	Carry out more accurate financial planning (including contingencies) though the market research and analysis for budget approval Engage with potential suppliers to discuss cost structures, pricing trends, and financial risks, helping to form a more accurate financial outlook
	Failure to identify the main players in the market and/or solutions available	Operational	Conducting interviews (in the pre-consultation process) with market stakeholders or people with expertise in a field Implement a category management approach to build sector-specific expertise or establish cross-departmental procurement teams to provide sector and subject-matter expertise Participate in private sector events to actively engage with the market and stay informed about emerging trends and opportunities
	Market analysis not informed by a thorough understanding of the market	Operational	Capacity-building activities on market analysis Use of standardised process and templates for market analysis such as the OECD market analysis checklist Implement a category management approach to build sector-specific expertise or establish cross-departmental procurement teams to provide sector and subject-matter expertise
	Use of limited or obsolete sources for market analysis	Operational	Capacity-building activities on market analysis Use of standardised process and templates for market analysis such as the OECD need analysis checklist
Market analysis is not documented	Lack of capacity on how to conduct market analysis	Operational	Capacity-building activities on market analysis Use of standardized process and templates for market analysis such as the OECD market analysis checklist
Market analysis is not documented	Lack of internal recording systems for procurement documents including market analysis	Legal/regulatory/compliance	Store procurement documents, including market analysis reports, centrally in a secure, easily accessible digital repository Prepare market analysis documentation in accordance with standard procedures, clearly outlining the required steps, data sources, and evaluation criteria to guarantee a thorough and consistent study Define access rights and permissions to ensure only authorized personnel can view, edit, or approve procurement documents Provide training sessions and resources for procurement staff on document management protocols and the importance of accurate recording of market analysis findings
False market analysis	Decision-making based on assumptions rather than informed by a thorough understanding of the market	Operational	Capacity-building activities on market analysis Use of standardised process and templates for market analysis such as the OECD market analysis checklist
False market analysis	Collusion between economic operators	Fiscal	Capacity building activities for contracting authorities on the detection of collusive practices and application of corrective measures Validation of the market analysis report by the head of the procurement department/ head of contracting authority Raise awareness of whistleblowers channels
Lack of time to conduct a proper market analysis	Poor forecasting and procurement planning	Operational	Establish collaborative forecasting processes involving key stakeholders such as user departments, finance, and procurement teams Provide training programmes for procurement staff on forecasting techniques, procurement planning methodologies, and use of forecasting tools
Lack of time to conduct a proper market analysis	Limited availability of skilled personnel or resources dedicated to market analysis	Operational	Offer regular training sessions for procurement staff focused on market analysis strategies, techniques, and best practices Use of standardised process and templates for market analysis such as the OECD market analysis checklist Outsourcing the market analysis
Underestimation of the financial aspect during the market analysis phase	Lack of capacity on how to conduct market analysis	Operational	Capacity-building activities on market analysis Use of standardised process and templates for market analysis such as the OECD market analysis checklist
	Lack of market engagement	Operational	Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices Engage with potential suppliers to discuss cost structures, pricing trends, and financial risks, helping to form a more accurate financial outlook Participate in private sector events to actively engage with the market and stay informed about emerging trends and opportunities
	Use of limited or obsolete sources for market analysis	Operational	Capacity-building activities on market analysis Use of standardised process and templates for market analysis such as the OECD need analysis checklist

Pre-tendering phase
Procurement planning (establish procurement timeline, ensure compliance, document the procurement plan, develop a procurement strategy, …)
Risk	Root cause	Risk category	Mitigation measures
Artificial division of needs in the planning phase to use non-competitive procedures	Corruption or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Implement controls and oversight to prevent artificial splitting of contracts Conduct periodic audits and reviews of procurement plans to detect irregularities Rotation of procurement officials
	Lack of controls over planning	Operational Fraud and corruption	Implement controls and oversight to prevent artificial splitting of contracts Conduct periodic audits and reviews of procurement plans to detect irregularities Implement a red-flag function within systems like KIMDIS to automatically detect and signal any potential artificial contract splits during the planning phase, ensuring better oversight and compliance with competitive procurement procedures
	Lack of guidelines on integrity in public procurement	Legal/regulatory/compliance Fraud and corruption	Provide training on legal requirements and ethical considerations in procurement planning Develop and apply a code of conduct
	Local market preference	Legal/regulatory/compliance Fraud and corruption	Educate stakeholders on the benefits of fair and open competition in procurement Build internal capacity to conduct objective assessments and evaluations of supplier capabilities Develop and apply a code of conduct Rotation of procurement officials
	Lack of knowledge regarding artificial division of the needs	Legal/regulatory/compliance	Provide training on legal requirements and ethical considerations in procurement planning
Lack of proper record keeping of procurement plans	Lack of internal public procurement processes	Operational	Implement electronic procurement planning systems with document management features Make the use of standard templates mandatory Conduct periodic audits to verify completeness and accuracy of records
Lack of proper record keeping of procurement plans	Lack of internal recording systems for procurement documents including procurement planning	Operational	Implement electronic procurement planning systems with document management features Make the use of standard templates mandatory Conduct periodic audits to verify completeness and accuracy of records
Inadequate procurement planning or deviations from good practices (e.g. unrealistic time planning of the award procedures, unrealistic budgeting or unavailable funds)	Lack of communication and coordination between the different units within the contracting authority	Operational	Implement regular meetings, workshops, or communication platforms to facilitate dialogue between units Foster collaboration and information sharing across units to avoid duplication of efforts Provide training sessions on procurement policies, procedures, and best practices across units Assign the role of coordinator to an employee of the contracting authority
	Lack of information critical to planning (e.g. period of consumption of available stocks, expiration date of existing contracts and any options, average length of award process on a case-by-case basis, completed expropriations in case of the construction of a new road, time to issue the necessary permits to start a project, etc.)	Operational Fraud and corruption	Implement an automated inventory management system to track stocks of goods in real-time Set up alerts and notifications for low stock levels or expiring items to prevent stockouts Collaborate with end-users and departments to forecast procurement needs and adjust stock levels accordingly Provide training for staff involved in stock management on best practices and procedures
	Lack of capacity on how to effectively plan procurement activities leading to significant delays	Operational	Implement standardized procurement planning templates and guidelines Conduct regular reviews and approvals to ensure compliance with established procedures Provide training to procurement staff on proper planning methodologies and adherence to policies Introduce the use of an electronic procurement monitoring system with alert functions for key deadlines and milestones
	Lack of consideration of key elements such as potential risks and potential litigation	Operational Fraud and corruption	Implement standardised procurement planning templates and guidelines taking into account key elements in procurement planning Provide training to procurement staff on proper planning methodologies and adherence to policies
	Procurement planning not taking into account time needed for approvals by various public bodies	Operational	Foster a culture of collaboration between procurement and administrative departments Implement guidelines for the procedure with steps and time frames for each step, including the time required for approvals to ensure better procurement planning
Delays in preparing procurement plans	Lack of public procurement internal processes	Operational	Implement standardised timelines and milestones for procurement planning Foster collaboration between procurement, legal, and finance teams to streamline processes
Delays in preparing procurement plans	Lack of capacity on how to effectively plan procurement activities leading to significant delays	Operational	Capacity building activities focusing on procurement planning
Misuse of exception procedures due to a misunderstanding of legal exceptions (e.g. extreme urgency, protection of national security interest, unjustified continuation of existing contracts)	Lack of proper training on legal exceptions and their appropriate application	Operational	Provide regular and mandatory training for procurement officials on legal exceptions and proper procedures Develop and disseminate detailed guidelines on the application of exception procedures, including clear criteria and examples
	No consideration of the total value of the required goods, services or public works from all units in a specific contracting authority	Legal/regulatory/compliance Fraud and corruption	Develop robust guidelines and criteria for invoking exception procedures Implement oversight mechanisms to review and approve exception requests Provide training on ethical considerations and legal compliance related to exceptions Implement standard procedures, including the mandatory notification of all units of the procurement under consideration
	Corruption and/or conflict of interest	Operational Fraud and corruption	Implement oversight mechanisms to review and approve exception requests Implement standard procedures, including the mandatory notification of all units of the procurement under consideration
Lack of capacity within contracting authorities to properly plan procurement activities	Lack of guidelines on how to properly plan procurement activities	Operational	Implement standardized procurement planning templates and guidelines to properly plan procurement Provide training to procurement staff on proper planning methodologies and adherence to policies Conduct regular reviews and approvals to ensure compliance with established procedures
	Lack of internal coordination among the different units of the contracting authority	Operational	Implement regular meetings, workshops, or communication platforms to facilitate dialogue between units Foster collaboration and information sharing across units to avoid duplication of efforts Provide training sessions on procurement policies, procedures, and best practices across units Assign the role of coordinator to an employee of the contracting authority
Influence of external players on planning	Corruption or conflict of interest	Fraud and corruption	Conduct periodic audits and reviews of procurement plans to detect irregularities Development of a code of conduct Promote whistle-blowing mechanisms Rotation of procurement officials Robust vetting and selection of officials
Contracting authorities plan to conduct procurement independently, despite being legally required to use a central procurement process	Corruption or conflict of interest	Fraud and corruption	Conduct periodic audits and reviews of procurement plans to detect irregularities Development of a code of conduct Promote whistle-blowing mechanisms
	Poor public procurement planning	Operational	Implement standardised procurement planning templates and guidelines with specific reference to purchases made by the Central Procurement Body Conduct regular reviews and approvals to ensure compliance with established procedures Provide training to procurement staff on proper planning methodologies and adherence to policies
	Lack of communication between the contracting authority and the central purchasing body	Operational	Implement regular meetings, workshops, or communication platforms to facilitate dialogue between contracting authorities and central purchasing bodies
Cost estimates are inconsistent with market prices	Lack of market engagement	Operational	Engage with potential suppliers to discuss cost structures, pricing trends, and financial risks, helping to form a more accurate financial outlook Review existing market research reports to gain a comprehensive understanding of the current market landscape and supplier capabilities
Cost estimates are inconsistent with market prices	Lack of market analysis	Fiscal	Conduct market research and price analysis to validate cost estimates Use benchmarking data and industry standards to ensure accuracy
Cost manipulation in order to include a bribe to public officials	Corruption and/or conflict of interest	Fraud and corruption	Conduct periodic audits and reviews of procurement plans to detect irregularities Provide training on ethical standards and consequences of malpractice Development of a code of conduct Adopt the two person rule Rotation of procurement officials Robust vetting and selection of officials
Mischaracterising a project as supply, service, or work	Lack of capacity to determine and qualify the needs	Operational	Use of standardized processes and templates for market analysis such as the OECD needs analysis checklist Invest in capacity building activities on needs analysis (i.e. defining the type of contract: work, services or supply)
Mischaracterising a project as supply, service, or work	Corruption and/or conflict of interest	Fraud and corruption	Conduct periodic audits and reviews of procurement plans to detect irregularities Provide training on ethical standards and consequences of malpractice Development of a code of conduct Promote whistle-blowing mechanisms
Distortion of competition (e.g. size of the contract limits competition)	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Rotation of procurement officials Robust vetting and selection of officials
	Lack of capacity on the how to prepare tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
	Lack of guidelines on how to promote participation of SMEs	Strategic	Establish guidelines specifically outlining strategies and mechanisms to promote the participation of Small and Medium Enterprises (SMEs), including eligibility criteria, set-asides for SMEs, simplified procurement procedures, and strategies to enhance SME access to information and opportunities
	Lack of competency on the division of the contract into lots	Operational	Include a mandatory division into lots in internal processes when appropriate Provide guidance on the division of contracts into lots
Not taking into account the life cycle of the procured products, leading to false cost estimations	Lack of capacity on how to estimate the life cycle cost	Operational	Provide training on life cycle costs Disseminate existing life cycle costing tools
Lack of budget approval	Delays in budget allocation	Fiscal	Improved coordination between procurement and financial functions

Pre-tendering phase
Preparation of tender documents (develop detailed technical specification, establish evaluation criteria, ensure compliance with relevant laws and regulation, …)
Risk	Root cause	Risk category	Mitigation measures
Subject of the contract
The subject matter of the contract lacks clarity	No use of HSPPA template when preparing tender documents	Operational	Disseminate and mandate the use of HSSPA templates
The subject matter of the contract lacks clarity	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
Choice of the procedure
Inappropriate choice of procedure (e.g. between works, services and goods, misuse of exceptions)	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Lack of knowledge and understanding of the public procurement framework and processes	Legal/regulatory/compliance	Increase capacity on the use of different procurement procedures, including guidance on the use of non-competitive procedures Use HSPPA template and guidelines for preparing tender documents that outline the required content, format, and structure
	Lack of capacity for comprehensive needs analysis and effective procurement planning	Operational	Provide targeted training programmes and workshops for procurement staff involved in needs analysis and procurement planning Conduct a thorough needs assessment to accurately define project scope, specifications, and deliverables before initiating the tender document preparation
Abuse of non-competitive procedure or use of non-competitive procedures without justification	Lack of knowledge on the preparation of tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples Use HSPPA template and provide guidelines for preparing tender documents that outline the required content, format, and structure
	Lack of use of existing guidelines on the use of non-competitive procedures	Operational Fraud and corruption	Increase capacity on the use of different procurement procedures, including guidance on the use of non-competitive procedures Disseminate and promote the use of existing guidance on the use of non-competitive procedures Establish a procedure for checking the existence of the required conditions for applying emergency procedure
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Disclose all potential conflict of interests through formal declarations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Inadequate procurement planning	Operational	Implement standardized timelines and milestones for procurement planning Foster collaboration between procurement, legal, and finance teams to streamline processes
Incorrect contract value estimate (e.g. over estimation of price)	Lack of knowledge on the preparation of tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations
	Inadequate needs analysis	Operational Fraud and corruption	Capacity building on needs analysis, develop a standard template of needs analysis, making its use mandatory
	Lack of market analysis	Operational Fraud and corruption	Strengthen capacity to engage with the market, including using the market analysis guidelines developed with the OECD Use benchmarking data and industry standards to ensure accuracy Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations
Artificial splitting of contracts	Lack of training on integrity in public procurement	Operational Fraud and corruption	Develop and implement training programmes focused on integrity in public procurement Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement Development of a code of conduct
	Lack of safeguards and internal control system	Operational Fraud and corruption	Establish a process for the validation and review of tender documents, including the division of contracts into lots Disclose all potential conflict of interests through formal declarations Implement regular monitoring and compliance checks to assess adherence to integrity standards in procurement activities, including the division of contracts into lots Statutory Tenure Limit (rotation of procurement personnel) Robust Personnel Selection and Integrity Vetting
	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents, including the division of contracts into lots Disclose all potential conflict of interests through formal declarations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct Rotation of procurement officials
	Lack of knowledge of the public procurement framework and process	Legal/regulatory/compliance	Increase capacity on the use of procurement procedures, including the division of contracts into lots
Choice of award and selection criteria
Unclear award and selection criteria	Lack of capacity on the choice of award and qualification criteria	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents, including award criteria Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Robust vetting and selection of officials
	Lack of knowledge regarding the definition of selection and award criteria in tender documents	Operational	Increase capacity through knowledge sharing initiatives, training, and guidance notes with concrete examples Establish a process for the validation and review of tender documents, including ensuring selection and award criteria are disclosed
Lack of or inadequate method of verification of the selection and award criteria	Lack of application of existing guidelines on choosing the award and qualification criteria	Operational Fraud and corruption	Use HSPPA template and guidelines for preparing tender documents that outline the required content, format, and structure
	Lack of use of HSPPA template	Operational Fraud and corruption	Disseminate and mandate the use of HSPPA templates
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents, including selection and award criteria Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Robust vetting and selection of officials
Selection and award criteria not disclosed in advance or not sufficiently defined in the tender documents	Corruption and/or conflict of interest	Fraud and corruption	Maintain accurate records of all meetings and consultations with potential bidders Establish a process for the validation and review of tender documents, including ensuring selection and award criteria are disclosed
Restrictive qualification criteria	Lack of capacity on the choice of qualification criteria	Operational	Increase capacity through knowledge sharing initiatives, training, and guidance notes with concrete examples Establish a process for the validation and review of tender documents
	Lack of guidelines on integrity in public procurement	Operational Fraud and corruption	Develop and implement training programmes focused on integrity in public procurement Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement Implement regular monitoring and compliance checks to assess adherence to integrity standards in procurement activities. Rotation of procurement officials
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Robust vetting and selection of officials
	Lack of knowledge or misinterpretation of the public procurement legal framework	Legal/regulatory/compliance	Increase capacity through knowledge sharing initiatives, training, and guidance notes with concrete examples Establish a process for the validation and review of tender documents
Lack of sustainability consideration in the award and selection criteria	Lack of capacity on the choice of sustainable award and qualification criteria	Strategic	Strengthen strategic procurement capacity Establish coordination and consultation with technical experts Outsourcing drafting award and qualification criteria ( when there is a lack of expertise internally)
	Lack of market engagement regarding sustainability aspects of the tender	Strategic	Consultation with relevant stakeholders internal and external to government
	Lack of strategic orientations from the top management	Strategic	Develop a public procurement strategy including sustainability consideration Disseminate National Strategy on Green Public Procurement and provide trainings on its application
	Lack of guidelines on how to use public procurement to promote strategic objectives	Strategic	Develop capacity building tools on sustainable public procurement Support from senior leadership for the use of public procurement to promote strategic objectives
Selection and award criteria to favour specific suppliers	Lack of guidelines on integrity in public procurement	Operational Fraud and corruption	Develop and implement training programmes focused on integrity in public procurement. Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement Implement regular monitoring and compliance checks to assess adherence to integrity standards in procurement activities
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Development of a code of conduct Rotation of procurement officials Robust vetting and selection of officials
Preparation of tender documents
No options to make contract modifications during the post-tendering phase	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through knowledge sharing initiatives, training, and guidance notes with concrete examples Include adjustment clauses in the tender documents that allow for flexibility in pricing or scope under predefined circumstances. Specify clear conditions under which adjustments can be requested or triggered, such as changes in material costs, labor rates, or unforeseen delays.
Lack of time to prepare tender documents	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through knowledge sharing initiatives, training, and guidance notes with concrete examples. Focus on enhancing skills in market research, requirements gathering, risk assessment, and procurement strategy development.
Lack of time to prepare tender documents	Inadequate procurement planning	Operational	Conduct a thorough needs assessment to accurately define project scope, specifications, and deliverables before initiating the tender document preparation. Maintain transparency throughout the planning phase by documenting decisions, requirements, and stakeholder inputs. Make all documentation accessible for review and audit purposes.
Unclear tender documents (e.g. vague language, inaccurate CPV code)	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
	Inadequate or erroneous adjustment of HSPPA's templates to a particular tendering process	Operational	Disseminate and mandate the use of HSSPA templates Training on how to properly use HSPPA templates
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Disclose all potential conflict of interests through formal declarations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Robust vetting and selection of officials
	Tender documents include contradictory requirements	Operational	Establish a process for the validation and review of tender documents Disseminate and mandate the use of HSSPA templates Training on how to properly use HSPPA templates
Unlawful tender documents (e.g. tender documents favouring a specific EO, use of the wrong legal framework, discriminatory elements)	Lack of knowledge of the public procurement framework and process	Legal/regulatory/compliance	Increase capacity on the use of procurement procedures Introduce guidance on the use of non-competitive procedures
	No use of HSPPA template when preparing tender documents	Operational	Disseminate and mandate the use of HSSPA templates
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Incorporate an agreement preventing individuals with potential conflict of interest from participating in the bidding process Rotation of procurement officials Robust vetting and selection of officials
	Lack of or limited public consultation or market engagement	Legal/regulatory/compliance	Strengthen market analysis and market engagement capacity, including through the use market engagement guidelines and templates
	Use of wrong templates and inappropriate terms as a result of misidentifying the contract as a supply of goods/services or work	Operational	Use HSPPA templates Establish a process for the validation and review of tender documents
Lack of innovative solutions	Lack of capacity on how to prepare innovation tender documents	Operational	Strengthen strategic procurement capacity Establish coordination and consultation with technical experts Outsourcing drafting technical specifications (when there is a lack of expertise internally)
	Lack of market analysis on existing innovative solutions	Operational	Consultation with relevant stakeholders Strengthen market analysis capacity, including through market analysis guidelines and templates
	Failure to incorporate information provided by economic operators during the market engagement	Operational Fraud and corruption	Following consultation include all EO's comment into the market analysis and justify when not incorporated into the procurement documents Strengthen market analysis capacity, including developing guidelines and templates for market engagement and providing training on their application Maintain accurate records of all meetings and consultations with potential bidders
	Lack of guidelines on how to use public procurement to promote strategic objectives	Strategic	Develop capacity building and tools on innovation in public procurement Incorporate information provided by economic operators during the market engagement or justify lack of incorporation
	Lack of strategic orientations from the top management	Strategic	Develop a public procurement strategy promoting the use of innovative solutions Support from senior leadership for the use of public procurement to promote strategic objectives
	Lack of definition and clear understanding of the notion of ''innovation''	Capacity	Develop capacity building and tools on innovation in public procurement
Penalty clauses missing from contract	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
	No use of HSPPA template when preparing tender documents	Operational	Disseminate and mandate the use of HSSPA templates
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the validation and review of tender documents Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations
Outdated tender requirements	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples Focus on capabilities and functions rather than requirements in tender document specifications Strengthen market analysis capacity
Outdated tender requirements	No use of HSPPA template when preparing tender documents	Operational	Disseminate and mandate the use of HSSPA templates
Providing confidential information to specific economic operators related to tender documents	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Develop a code of conduct
	Lack of safeguards and internal control system	Operational Fraud and corruption	Maintain accurate records of all meetings and consultations with potential bidders Disclose all potential conflict of interests through formal declarations Implement regular monitoring and compliance checks to assess adherence to integrity standards in procurement activities Rotation of procurement officials Robust vetting and selection of officials
	Lack of guidelines on integrity in public procurement	Operational Fraud and corruption	Develop and implement training programmes focused on integrity in public procurement Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement Develop a code of conduct
Unbalanced contract terms (between contracting authority and economic operators)	Lack of capacity on how to prepare tender documents	Operational Fraud and corruption	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples Strengthen market analysis capacity
	No use of HSPPA template when preparing tender documents	Operational	Disseminate and encourage the use of HSSPA templates and provide guidelines on how they should be used
Submission timeline not conducive to competition	Lack of capacity on how to prepare tender documents	Operational Fraud and corruption	Increase capacity through sharing knowledge initiatives, training, and guidance notes with concrete examples
	Lack of capacity on how to plan public procurement activities	Operational	Implement standardized timelines for submissions Provide targeted training programmes and workshops for procurement staff involved in procurement planning
	Failure to incorporate information provided by economic operators during the market engagement relevant to submission timeline	Operational Fraud and corruption	Following consultation include all EO's comment into the market analysis and justify when not incorporated into the procurement documents Strengthen market analysis capacity, including developing guidelines and templates for market engagement and providing training on their application Maintain accurate records of all meetings and consultations with potential bidders
	Lack of communication with the market	Operational	Strengthen market analysis and market engagement capacity, including through market engagement guidelines and templates
Cyber-attacks to manipulate tender documents	Lack of security and capacity of current IT systems	IT	Invest in IT solutions and infrastructure upgrades to support the evolving needs of public procurement Implement real-time alerts and response mechanisms to mitigate cyber threats and unauthorized access attempts in public procurement
Tender documents do not address negative impacts on safety and health	Lack of capacity on how to prepare tender documents	Operational	Increase capacity through knowledge sharing initiatives, training, and guidance notes with concrete examples
	Lack training on health and security risks	Health and safety	Establish comprehensive training programmes focused on health and security risks specific to public procurement activities Partner with accredited training providers, health and safety consultants, or government agencies specializing in occupational health and safety to deliver high-quality training sessions.
Use of inappropriate HSPPA templates (e.g. not corresponding to the nature of the subject of the contract)	Lack of knowledge of the existing public procurement tools and guidelines	Operational	Increase capacity on the use of procurement procedures, including disseminating guidance on the use of templates
	Corruption and/or conflict of interest	Fraud and corruption	Establish a process for the review of tender documentation

Pre-tendering phase
Preparation of technical specifications (gathering requirements, defining specifications, research and benchmarking, consultation and review..)
Risk	Root cause	Risk category	Mitigation measures
Outdated technical specifications	Lack of capacity regarding the preparation of tender specifications	Operational	Establish coordination and consultation between procurement team and technical experts, e.g. review and sign off on tender specifications Provide training for procurement officials on identifying and updating outdated technical specifications
	Lack of market analysis	Operational	Strengthen market analysis capacity Develop market analysis templates
	Lack of communication between contracting authority's units	Operational	Foster collaboration between technical, legal, and procurement teams to align technical specifications with legal and regulatory requirements. Conduct interdisciplinary workshops and meetings to promote understanding and consensus on technical needs
	Lack of engagement with the market	Operational	Strengthen market consultations and adequate market research through capacity-building activities
Inadequate or unclear technical specifications	Lack of capacity (e.g. lack of technical knowledge) regarding the preparation of tender specifications	Operational	Establish coordination and consultation between procurement team and technical experts, e.g. review and sign off on tender specifications Provide training programmes for procurement officials on developing technical specifications Develop guidelines on preparing tender specifications for public procurement officials. Seek input from technical experts, suppliers and other stakeholders to ensure guidelines are practical, fair, and promote competition.
	Lack of market analysis	Operational	Strengthen market analysis capacity Develop market analysis templates
	Technical specification not drafted as required outputs (lack of functional approach)	Operational Fraud and corruption	Develop standardised templates and guidelines for preparing technical specifications
	Lack of communication between contracting authority's units	Operational	Foster collaboration between technical, legal, and procurement teams to align technical specifications with legal and regulatory requirements Conduct interdisciplinary workshops and meetings to promote understanding and consensus on technical needs Assign the role of coordinator to an employee of the contracting authority
	Failure to take into account the capabilities of contractors, producers, service providers	Operational	Establish a process to verify and incorporate feedback from stakeholders to ensure relevance
	Lack of involvement of the appropriate personnel	Fraud and corruption Operational	Clearly outline the roles and responsibilities of personnel involved in the preparation of technical specifications Schedule regular meetings to discuss and review technical specifications, ensuring all appropriate personnel are engaged Assign the role of coordinator to an employee of the contracting authority
No consideration of specifications that could increase the quality of the deliverables (e.g. environmental and social considerations)	Lack of public procurement strategy	Strategic	Establish a clear and comprehensive public procurement strategy aligned with organizational goals and legal frameworks Define objectives, priorities, and key performance indicators (KPIs) to guide procurement activities
	Lack of capacity to integrate environmental and social considerations into the technical specifications	Operational	Provide training and capacity building for procurement officers on integrating environmental and social considerations into tender specifications Establish cross-departmental procurement teams to provide sector and subject-matter expertise Outsourcing of drafting technical specifications (when there is a lack of expertise internally)
	Lack of guidelines on how to include environmental and social considerations in tender specifications	Operational	Provide training and capacity building for procurement officers on integrating environmental and social considerations into tender specifications Enhance awareness of green procurement practices, lifecycle assessments, and eco-labels
	Fear of the unknown	Operational	Provide training and capacity building for procurement officers on integrating environmental considerations into tender specifications Enhance awareness of green procurement practices, lifecycle assessments, and eco-labels Establish cross-departmental procurement teams to provide sector and subject-matter expertise Outsourcing of drafting technical specifications (when there is a lack of expertise internally)
	Focus on cost-saving measures rather than quality improvements, resulting in minimal specifications	Operational	Strengthen the capacity of procurement professionals on strategic procurement Enhance awareness of green procurement practices, lifecycle assessments, and eco-labels Establish cross-departmental procurement teams to provide sector and subject-matter expertise
Lack of or outdated technical studies	Lack of time to conduct technical studies	Operational	Collaborate with external consultants or technical specialists to conduct detailed studies where internal capacity is limited Carry out regular studies to ensure information is up-to-date, relevant, and reflects current market conditions Account for the time required to conduct technical studies as part of procurement planning
	Poor quality of technical studies	Operational	Collaborate with external consultants or technical specialists to conduct detailed studies where internal capacity is limited Ensure studies are up-to-date, relevant, and reflect current market conditions Establish cross-departmental procurement teams to provide sector and subject-matter expertise Establish a mechanism for ongoing monitoring of technical studies to identify emerging trends or changes that may impact specifications Establish a standard procedure for carrying out technical studies
	Lack of capacity regarding the preparation of tender specifications	Operational	Establish coordination and consultation between procurement team and technical experts, e.g. review and sign off on tender specifications Establish cross-departmental procurement teams to provide sector and subject-matter expertise Collaborate with external consultants or technical specialists to conduct detailed studies where internal capacity is limited
Illegal technical specification (e.g. tailored to specific economic operators)	Lack of internal control system to check the legality of tender specifications	Fraud and corruption Legal/regularoty/compliance	Establish a process for the validation and review of tender documents
	Lack of trainings on integrity in public procurement	Fraud and corruption Operational	Provide training programmes for procurement officials on integrity in public procurement to raise awareness of the risks
	Lack of capacity regarding the preparation of tender specification	Operational	Establish coordination and consultation between procurement team and technical experts, e.g. review and sign off on tender specifications Provide training programmes for procurement officials on developing and drafting technical specifications
	Corruption and/or conflict of interest	Fraud and corruption	Keep records of meetings with potential bidders Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct Rotation of procurement officials Robust vetting and selection of officials
	Broad discretion granted to contracting authorities in defining technical specifications	Fraud and corruption Operational	Establish a process for the validation and review of technical specifications when appropriate (e.g. particularly sensitive or complex procurements) Identify affiliations or relationships between service providers and affiliated entities Publish information on the involvement of affiliated entities in the preparation of technical specifications
	Lack of judicial review of the technical specifications chosen by the contracting authority	Legal/regulatory/compliance Fraud and corruption	Establish a process for the validation and review of technical specifications when appropriate (e.g. particularly sensitive or complex procurements) Maintain detailed records of reviews, consultations, and approvals to demonstrate transparency and accountability
	Lack of market analysis	Fraud and corruption Operational	Strengthen market analysis capacity Develop market analysis templates
Technical specification limiting competition (e.g. restrictive technical specification preventing foreign participation)	No control mechanism to review technical specification before release	Fraud and corruption Operational	Establish an internal or external process for the validation and review of technical specifications (e.g. oversight mechanism or committee to review and approve) when appropriate Conduct periodic audits and reviews to detect irregularities
	Lack of knowledge of the market	Operational	Strengthen market consultations and adequate market research through capacity-building activities
	Corruption and/or conflict of interest	Fraud and corruption	Share relevant information with all economic operators and keep records of meetings with potential bidders Disclose all potential conflict of interests through formal declarations Rotation of procurement officials Robust vetting and selection of officials
	Use of restrictive technical specifications	Fraud and corruption Operational	Develop guidelines to limit unnecessary restrictions in technical specifications that could artificially reduce competition Establish a process for the validation and review of technical specifications (e.g. oversight mechanism or committee) when appropriate (e.g. particularly sensitive or complex procurements)
	Lack of capacity regarding the preparation of tender specifications	Operational	Establish coordination and consultation between procurement team and technical experts, e.g. review and sign off on tender specifications Provide training programmes for procurement officials on developing and drafting technical specifications Consult with contracting authorities in Greece and in other Member States (if relevant) who have conducted similar procurements
Conflict of interest (e.g. between procurement officials and economic operators)	Lack of safeguards and internal control system to prevent collusion	Fiscal Fraud and corruption	Implement internal control systems to monitor the preparation of technical specifications and detect potential collusion or unfair advantages Conduct regular audits or reviews of procurement processes to control compliance with guidelines and policies
	Lack of training on integrity in public procurement	Operational Fraud and corruption	Consult with legal function to ensure that guidelines on preparing tender specifications comply with legal requirements and regulations Provide training programmes for procurement officials on integrity in public procurement.
	Lack of training on conflicts of interest	Fraud and corruption Operational	Raising awareness on the potential risks of such practice Share relevant information with all economic operators and keep records of meetings with potential bidders Disclose all potential conflict of interests through formal declarations
Repeatedly engaging the services of the same consulting firms without proper justification	Corruption and/or conflict of interest	Fraud and corruption Operational	Select consulting firms through transparent and competitive bidding processes, with clear evaluation criteria Implement systems to track and monitor spending and contracts with specific consulting firms, identifying any irregularities or over-concentration of work Develop reporting mechanisms to regularly review and report on the distribution of contracts among consulting firms, ensuring a fair and competitive environment Rotation of procurement officials Robust vetting and selection of officials
	Lack of capacity regarding the preparation of tender specification	Operational	Establish coordination and consultation between procurement team and technical experts, e.g. review and sign off on tender specifications Provide training programmes for procurement officials on developing and drafting technical specifications
	Lack of internal control system	Fraud and corruption Operational	Establish a process for the validation and review of technical specifications (e.g. oversight mechanism or committee) when appropriate (e.g. particularly sensitive or complex procurements) Disclose all potential conflict of interests through formal declarations

Tendering phase
Publication of the call for tender (draft tender notice, select publication channels, publish the notice, manage clarifications, …)
Risk	Root cause	Risk category	Mitigation measures
Incomplete contract notice	Lack of capacity on how to publish the call for tender	Operational	Provide comprehensive training sessions and workshops for procurement officers on how to effectively publish tender notices, including guidance on legal requirements, platforms such as TED (Tenders Electronic Daily), KIMDIS, ESIDIS, etc. and best practices for timely and accurate publication Develop standardised guidelines and manuals detailing the procedures and responsibilities involved in publishing tender notices. Make these resources easily accessible and regularly update them to reflect any changes in regulations or platforms.
	Lack of interoperability between e-procurement systems and KIMDIS registry	IT	Establish protocols for data synchronisation and compatibility checks to minimize errors in tender publication
	No availability of a digital tool for eSender	IT	Establish processes to reduce the risk of discrepancies in published notices and increase consistency in information dissemination
Late publication of call for tender (e.g. publication in KIMDIS or ESIDIS)	Lack of capacity on how to publish the call for tender	Operational	Provide comprehensive training sessions and workshops for procurement officers on how to effectively publish tender notices, including guidance on legal requirements, platforms such as TED (Tenders Electronic Daily), and best practices fortimely and accurate publication Develop standardised guidelines and manuals detailing the procedures and responsibilities involved in publishing tender notices and make these resources are easily accessible and regularly updated to reflect any changes in regulations or platforms
	Lack of capacity to effectively plan public procurement activities	Operational	Develop and disseminate standardized templates and guidelines for procurement planning Implement comprehensive training programmes tailored to procurement officers and relevant staff to enhance their planning capabilities
	Lack of knowledge of the legal requirements	Legal/regulatory/compliance	Provide training and continuous education for procurement staff on the importance of consistency in tender notice publication and the consequences of non-compliance with legal and procedural guidelines
	No availability of a digital tool for eSender	IT	Establish processes to reduce the risk of discrepancies in published notices and increase consistency in information dissemination
	Lack of interoperability of e-procurement systems and KIMDIS registry	IT	Establish protocols for data synchronization and compatibility checks to minimize errors in tender publication
Inappropriate bid submission timeline (e.g. insufficient time to prepare the bid)	Lack of communication with the market	Operational	Assess submission timelines as part of market engagement Provide training on market engagement
	No extension of the submission timeline despite modification of the contract terms	Operational	Provide training and continuous education for procurement staff on the importance of consistency in tender notice publication and the consequences of non-compliance with legal and procedural guidelines Implement comprehensive training programmes tailored to procurement officers and relevant staff to enhance their planning capabilities
Incorrect publication of the call for tender (e.g. CPVs in tender notice are different from the tender documents, notices published in different places are not the same i.e. TED and national press)	Inadequate control and verification systems	Legal/regulatory/compliance Fraud and corruption	Deploy automated verification systems or tools that cross-check tender notices published across different platforms. Use algorithms to detect discrepancies in content, deadlines, and contact information, triggering alerts for corrective action. Conduct regular audits and spot-checks to monitor compliance with publication standards and identify areas for improvement in the consistency and accuracy of tender notices.
	Lack of capacity on how to publish the call for tender	Operational	Provide comprehensive training sessions and workshops for procurement officers on how to effectively publish tender notices. Include guidance on legal requirements, platforms such as TED (Tenders Electronic Daily), and best practices for ensuring timely and accurate publication. Develop standardised guidelines and manuals detailing the procedures and responsibilities involved in publishing tender notices. Make these resources easily accessible and regularly update them to reflect any changes in regulations or platforms.
	No availability of a digital tool for e-sender	IT	Establish processes to reduce the risk of discrepancies in published notices and increase consistency in information dissemination
	Lack of interoperability of e-procurement system and KIMDIS registry	IT	Establish protocols for data synchronisation and compatibility checks to minimise errors in tender publication
Lack of effective control over publication	Lack of safeguards and internal control system on the publication of the call for tender	Operational Fraud and corruption	Establish rigorous review and approval processes for tender notices Establish regular monitoring and auditing mechanisms to assess the effectiveness of internal controls over the publication of tender notices Maintain and regularly review records of access to e-procurement system
Lack of effective control over publication	Modifications to the tender invitation not recorded/published	Legal/Regulatory/Compliance Fraud and corruption	Develop procedures for internal notification within the organization whenever there is a modification to a tender invitation Use the existing mandatory standardized procedure to publicly announced all the modifications to tender invitation Conduct awareness campaigns to educate stakeholders, including suppliers and contractors, about the process for handling and documenting changes to tender invitations
Illegal or unjustified lack of publication of the call for tender	Lack of capacity on how to publish the call for tender	Operational	Provide comprehensive training sessions and workshops for procurement officers on how to effectively publish tender notices. Include guidance on legal requirements, platforms such as TED (Tenders Electronic Daily), KIMDIS and ESIDIS and best practices for timely and accurate publication Develop standardized guidelines and manuals detailing the procedures and responsibilities involved in publishing tender notices. Make these resources easily accessible and regularly update them to reflect any changes in regulations or platforms.
	Selection of non-appropriate tender procedure	Legal/regulatory/compliance Fraud and corruption	Provide training programmes for procurement officers and stakeholders on different tender procedures available under procurement regulations Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
Lack of use or incorrect use of ESIDIS despite legal requirement (mandatory use of ESIDIS in case of contract of more than EUR 30 000)	Lack of process control in case of non-use of the electronic platform (ESIDIS)	Operational Fraud and corruption	Regularly review procurement activities for compliance with the requirement for mandatory use of ESIDIS and establish a corrective action plan for any deviations identified Provide training sessions for procurement staff to increase familiarity with the platform
	Corruption and/or conflict of interest	Fraud and corruption	Conduct regular audits of compliance Develop and implement training programmes focused on integrity in public procurement Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement Develop a code of conduct
	Lack of capacity regarding the use of ESIDIS	Operational	Provide training sessions for procurement staff to increase familiarity with the platform
	Lack of supervision	Operational Fraud and corruption	Establish regular monitoring and auditing mechanisms

Tendering phase
Preparation and submission of bids (complete all required forms and documentation, ensure the bid package is correctly assembled, submit the bid on time, maintain records of the submission for audit and verification purposes)
Risk	Root cause	Risk category	Mitigation measures
Lack of competition	Lack of market engagement	Operational	Increase outreach and market engagement efforts to attract more bidders Offer regular training sessions for procurement staff focused on market engagement strategies, techniques, and best practices Develop market engagement guidelines
	No proper publication of call for tender	Legal/regulatory/compliance Fraud and corruption	Use the mandatory standardized procedures for the publication of calls for tender on the electronic platforms (KIMDIS, ESIDIS) Maintain transparent communication channels for stakeholders to verify the publication of tenders Train procurement officials on the importance of proper tender publication and the procedures to follow
	Short deadline for submission of offers	Operational Fraud and corruption	Establish guidelines for setting timelines for tender submissions, considering the complexity and scope of the procurement Set deadlines which provide ample time for economic operators to prepare comprehensive and competitive bids Provide advance notice of upcoming tenders to allow economic operators to prepare in advance Consult with industry stakeholders when setting deadlines to ensure they are realistic and achievable
	Poor quality of tender documents	Operational	Use HSPPA templates for tender documents to ensure consistency and completeness Provide training for personnel involved in the preparation of tender documents. Ensure they understand the importance of quality documentation and are skilled in drafting clear and precise tenders
	Low number of suppliers	Fiscal	Simplify the bidding process and reduce barriers to entry for new and smaller suppliers Carry out extensive market consultation process
	Restrictive technical specifications limiting the number of bidders	Operational Fraud and corruption	Develop guidelines to limit unnecessary restrictions in technical specifications that could artificially reduce competition Establish a process for the validation and review of technical specifications (e.g. oversight mechanism or committee to review and approve)
Issue with the electronic platform for the submission of bids (e.g. failure to upload a bid)	Old and non-functional e-procurement system	IT	Maintain and support the e-procurement system
Collusive practices, including: Bid rigging Information exchange between bidders Market allocation Bid rotation Quantity limitation Cover bidding Bid suppression	Inadequate legal provisions and enforcement mechanisms making it easier for economic operators to engage in collusive practices	Fiscal Fraud and corruption	Implement regular audits and monitoring of procurement processes to detect and prevent collusive practices Create clear and accessible channels for reporting suspected collusion. Ensure that all stakeholders are aware of these channels and understand the reporting process. Ensure that penalties for collusion are substantial enough to deter potential violators (including exclusion from future tenders)
	Corruption and/or conflict of interest	Fraud and corruption	Implement and enforce strict codes of conduct for all individuals involved in the procurement process Create robust whistleblower protection programmes to encourage the reporting of corrupt activities without fear of retaliation Increase transparency in procurement processes by publishing all relevant documents and decisions Rotation of procurement officials Robust vetting and selection of officials
	Lack of competency from the contracting authority to detect collusive practices	Operational	Build the capacity of procurement officials on the identification of bid rigging patterns
	Distortion of competition in the market	Fiscal Fraud and corruption	Procurement processes should be open, transparent, and accessible to all qualified suppliers Conduct regular market analyses to identify and address any barriers to competition Implement measures to ensure equal opportunities for all suppliers, including SMEs Use clear and objective evaluation criteria in tender processes. Ensure that these criteria are publicly available and applied consistently to all bidders
	Lack of transparency of the procurement process to detect collusive practices	Operational Fraud and corruption	Promote transparency in the procurement process by publicly disclosing all tender-related information, including evaluation of bids
Errors by economic operators when submitting an offer	Lack of capacity of economic operators on preparing and submitting bids	Operational	Use and promote the use of existing technical support and helpdesk services to assist economic operators Provide detailed instructions and training on the submission process

Tendering phase
Clarification of tender documents (receive and log request, review and analyse the question, prepare clear and detailed responses, communicate all clarifications, record all clarifications issues,…)
Risk	Root cause	Risk category	Mitigation measures
Clarifications are not uploaded to the electronic platform (e.g. dissemination of clarifications only to certain bidders)	Contracting authorities do not use the existing standard procedure for providing clarifications	Legal/regulatory/compliance Fraud and corruption	Apply the standardised process for clarifications that ensures that all bidders are notified when new clarifications are added Implement regular audits and monitoring of procurement processes to detect and prevent non-compliant practices
	Lack of capacity and knowledge to clarify tender documents	Operational	Provide training for procurement officials on how to provide effective and adequate clarifications, including understanding the technical aspects of the tender and the needs of the bidders Put in place processes for coordination and consultation with technical experts Implement capacity-building programmes to enhance the skills and knowledge of procurement staff with focus on areas like understanding tender documents, clarifying queries, and managing the clarification process Pair less experienced staff with seasoned procurement professionals for mentoring and support
	Corruption and/or conflict of interest	Fraud and corruption	Establish and enforce strict ethical guidelines and codes of conduct for all personnel involved in the procurement process Conduct regular audits and inspections by independent bodies to detect and deter corrupt practices Provide regular training sessions on anti-corruption measures and conflict of interest policies for all procurement staff
	Lack of knowledge of the legal requirements	Legal/regulatory/compliance	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff with focus on areas like understanding tender documents, clarifying queries, and managing the clarification process Pair less experienced staff with seasoned procurement professionals for mentoring and support
	No publication of the tender modifications on ESIDIS	Legal/regulatory/compliance Fraud and corruption	Regularly monitor and conduct compliance checks that all modifications are published on KIMDIS Provide training for procurement staff on the use of the ESIDIS platform, focusing on how to publish tender modifications and the importance of doing so
Lack of clarification	Contracting authorities do not use the existing standard procedure for providing clarifications	Legal/regulatory/compliance Fraud and corruption	Apply the standardised process for clarifications that ensures that all bidders are notified when new clarifications are added Set and communicate a clear timeframe within which all clarification requests will be addressed Implement regular audits and monitoring of procurement processes to detect and prevent non-compliant practices
	Insufficient capacity and knowledge regarding the clarification of tender documents	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff with a focus on areas like understanding tender documents, clarifying queries, and managing the clarification process Pair less experienced staff with seasoned procurement professionals for mentoring and support Provide procurement functions with sufficient resources and authority to provide clear and accurate responses Ensure coordination and consultation with technical experts
	Corruption and/or conflict of interest	Fraud and corruption	Establish and enforce strict ethical guidelines and codes of conduct for all personnel involved in the procurement process Conduct regular audits and inspections by independent bodies to detect and deter corrupt practices Provide regular training sessions on anti-corruption measures and conflict of interest policies for all procurement staff Robust vetting and selection of officials
No extension of the submission period in case of modifications of significant terms	Lack of knowledge regarding clarification of tender documents	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff. Focus on areas like understanding tender documents, clarifying queries, and managing the clarification process. Pair less experienced staff with seasoned procurement professionals for mentoring and support
Risk of appeals following numerous clarification requests	Poor quality of clarifications provided	Operational	Develop tender documents that are clear and comprehensive from the outset to minimise the need for extensive clarifications Provide clear and concise clarifications Ensure adequate training on the preparation of clarifications
Inadequate clarifications or clarification modifying extensively the contract terms	Contracting authorities do not use the existing standard procedure for providing clarifications	Legal/regulatory/compliance Fraud and corruption	Apply the standardised process for clarifications that ensures that all bidders are notified when new clarifications are added Implement a quality control process for all clarifications to ensure they are accurate, clear, and comprehensive Have clarifications reviewed by a senior procurement official before release
	Lack of capacity to clarify tender documents	Operational	Provide training for procurement officials on how to provide effective and adequate clarifications. This includes understanding the technical aspects of the tender and the needs of the bidders
	Poor quality (e.g. unclear) tender documents	Operational Fraud and corruption	Develop tender documents that are clear and comprehensive from the outset to minimise the need for extensive clarifications Use HSPPA templates and checklists to prepare tender documents Have tender documents reviewed by multiple stakeholders, including legal, technical, and procurement experts
	Corruption and/or conflict of interest	Legal/regulatory/compliance Fraud and corruption	Use a formal amendment process for significant changes to contract terms Communicate these amendments clearly and provide ample time for bidders to adjust their proposals Robust vetting and selection of officials
Numerous clarification requests leading to the cancellation of the tender	Inadequate market analysis	Operational Fraud and corruption	Strengthen market analysis and engagement with the private sector Use tools such as the OECD guidelines for market analysis
	Poor quality of tender document	Operational	Develop tender documents that are clear and comprehensive from the outset to minimise the need for extensive clarifications Use HSPPA templates and checklists to prepare tender documents Have tender documents reviewed by multiple stakeholders, including legal, technical, and procurement experts

Tendering phase
Tender opening (open the tender publicly, records the names of the bidders and their details, ensure all submissions are properly documented, securely store all tender documents, ..)
Risk	Root cause	Risk category	Mitigation measures
Absence of clear, open, and fair processes for receiving and reviewing bids	Lack of safeguards and internal security process	Legal/regulatory/compliance Fraud and corruption	Develop and enforce standardised procedures and guidelines for receiving and reviewing bids Conduct regular audits of compliance
	Lack of capacity regarding tender opening	Operational	Conduct regular training for procurement officials on tender opening
	Lack of training on integrity in public procurement	Operational Fraud and corruption	Develop and implement training programmes focused on integrity in public procurement Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement
Disclosing confidential information during tender opening	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Develop and enforce standardised procedures and guidelines for receiving and reviewing bids Conduct regular audits to ensure compliance Develop and implement training programmes focused on integrity in public procurement Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement Development of a code of conduct
	Lack of safeguards and internal security process	Operational Fraud and corruption	Develop and enforce standardised procedures and guidelines for receiving and reviewing bids Conduct regular audits of compliance Use of ESIDIS in case of contract above EUR 30 000 Robust vetting and selection of officials
	Lack of knowledge of the legal requirements and obligation on tender opening	Operational	Conduct regular training for procurement officials on tender opening
	Lack of training on integrity in public procurement	Operational Fraud and corruption	Provide training on confidentiality requirements
ESIDIS platform experiencing technical issues (e.g. failure to download the bid)	Technical failure of ESIDIS	IT	Have contingency plans in place, such as manual processes, to be used in case of technical failures
Tender opening before the appointment of the evaluation committee	Corruption and/or conflict of interest	Fraud and corruption	Establish a clear timeline and protocol that ensures the evaluation committee is appointed before any tender opening Conduct regular audits of compliance
	Lack of safeguards and internal security process	Operational Fraud and corruption	Establish a clear timeline and protocol that ensures the evaluation committee is appointed before any tender opening
	Lack of knowledge and competency regarding tender opening	Legal/regulatory/compliance	Provide training on public procurement procedures
Low number of bids received	Lack of attractiveness (e.g. low budget, existence of prerequisites for the project implementation...)	Fiscal	Increase market engagement activities such as information sessions, pre-tender briefings, and outreach programmes Simplify bid requirements where possible and ensure wide publication of tender opportunities to attract more participants Build the capacity of procurement officials on promoting competition for a specific contract (procedures, award and selection criteria, minimum requirements, etc.)
	Poor quality (e.g. unclear) procurement documents	Legal/regulatory/compliance	Use HSPPA templates and checklists to prepare tender documents Have tender documents reviewed by multiple stakeholders, including legal, technical, and procurement experts Build the capacity of procurement officials on ensuring competition for a specific contract (procedures, award and selection criteria, minimum requirements, etc.)
	Small number of suppliers (e.g. due to the choice of award and selection criteria, minimum requirements, technical and economic capacity)	Fiscal	Widely disseminate information about upcoming tenders (e.g. through Prior Information Notices, entity's website) Preparation and publication of an annual procurement plan that includes information such as budget, expected timeline and a brief description of the need

Tendering phase
Evaluation of tender (assemble the evaluation committee, review all received tenders for compliance with submission requirements, evaluate tenders, score each tender, document the evaluation process,..)
Risk	Root cause	Risk category	Mitigation measures
Subjective evaluation of tender (e.g. lack of justification for the selection of the winning offer, award criteria applied during evaluation differ from those included in the tender documents)	Corruption and/or conflict of interest	Fraud and corruption	Develop clear, measurable award criteria as much as possible and establish procedures providing for detailed justification of the evaluation and scoring of criteria Develop and implement training programmes focused on integrity in public procurement Create comprehensive guidelines or manuals specifically addressing integrity issues in procurement Disclose all potential conflict of interests through formal declarations and consider disqualifying members from participation to avoid any possible biases Conduct regular controls to ensure compliance
	Poor quality of tender documents	Operational	Use HSPPA templates and checklists to prepare tender documents Have tender documents reviewed by multiple stakeholders, including legal, technical, and procurement experts
	Lack of capacity on bid evaluation	Operational	Provide comprehensive training to evaluation committee members on how to apply the criteria objectively and consistently
	Lack of safeguards and internal control system	Operational Fraud and corruption	Implement standardised scoring matrices to ensure uniform assessment and minimize subjectivity Rotation of procurement officials Robust vetting and selection of officials Conduct regular controls to ensure compliance
Lack of public procurement technical knowledge of the members of the tender evaluation committee (e.g. non-identification of non-compliant bids)	Lack of capacity of the members of the evaluation committee	Operational	Provide comprehensive training to evaluation committee members on how to apply the criteria objectively and consistently Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices Include technical experts and procurement specialists on the evaluation committee to provide guidance and knowledge
	Lack of guidelines on how to evaluate an offer	Operational	Provide detailed guidelines and checklists for evaluating tenders to support thorough and consistent assessments
Economic operators challenging the evaluation process/the award decision	Corruption and/or conflict of interest	Fraud and corruption	Develop clear, measurable award criteria as much as possible Document all stages of the evaluation process Promote whistle-blowing mechanisms
	Poor quality of tender documents	Operational	Use HSPPA templates and checklists to prepare tender documents Have tender documents reviewed by multiple stakeholders, including legal, technical, and procurement experts
	Subjective evaluation of tenders	Fraud and corruption Legal/regulatory/compliance	Develop clear, measurable award criteria as much as possible Document all stages of the evaluation process Provide detailed guidelines and checklists for evaluating tenders to support thorough and consistent assessments
	Lack of capacity of the member of the evaluation committee	Operational Fraud and corruption	Provide comprehensive training to evaluation committee members on how to apply the criteria objectively and consistently and how to duly justify their evaluation
	Lack of assurance on the absence of conflict of interest of the member of the evaluation committee	Operational Fraud and corruption	Disclose all potential conflict of interests through formal declarations and consider disqualifying members from participation to avoid any possible biases
Delays in evaluating bids	Lack of capacity on bid evaluation	Operational	Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices Provide comprehensive training to evaluation committee members on how to apply the criteria objectively and consistently Include technical experts and procurement specialists on the evaluation committee to provide guidance and knowledge
	Lack of effective planning of public procurement activities	Operational	Preparation and publication of an annual procurement plan that includes information such as budget, expected timeline and a brief description of the need Include contingencies in the procurement timeline (e.g. for potential challenges)
	Administrative burdens and lack of capacity	Operational	Adequately staff and resource evaluation committees to handle the workload Include contingencies in the procurement timeline (e.g. for potential challenges)
	Submission of appeals	Operational	Implement firm deadlines for the submission of appeals and for addressing them to prevent prolonged delays Equip evaluation committee members with comprehensive training on appeal scenarios, ensuring faster, informed responses that minimise delays
Tender cancellation at the evaluation phase	Lack of capacity on bid evaluation	Operational	Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices
	No eligible bids submitted	Operational Fraud and corruption	Increase market engagement activities such as information sessions, pre-tender briefings, and outreach programmes Simplify bid requirements where possible and ensure wide publication of tender opportunities to attract more participants Build the capacity of procurement officials on promoting competition for a specific contract (procedures, award and selection criteria, minimum requirements, etc.)
	Low number of bids received	Fiscal Fraud and corruption	Widely disseminate information about upcoming tenders (e.g. through Prior Information Notices, entity's website) Preparation and publication of an annual procurement plan that includes information such as budget, expected timeline and a brief description of the need
	Administrative burdens and lack of capacity	Operational	Build the capacity of procurement officials on ensuring the maximal possible competition for a specific contract (procedures, award and selection criteria, minimum requirements, etc.)
	Cancellation of the tender after the approval of an appeal	Legal/regulatory/compliance	Define a clear and structured process for handling appeals, including timelines and responsibilities Enhance communication with bidders to clarify any doubts or concerns before the tender is finalized Develop an action plan to address the issues raised in the appeal and prevent similar problems in the future
Inadequate evaluation of tenders (e.g. failure to verify documents and certificates submitted by the bidders)	Supporting documentation not verified by contracting authority	Fraud and corruption Legal/regulatory/compliance	Provide check lists to be filled in by the evaluation committee for every bid evaluation Conduct regular audits of evaluation procedures
	Lack of capacity of the member of the evaluation committee	Operational Fraud and corruption	Provide comprehensive training to evaluation committee members on how to apply the criteria objectively and consistently
	Lack of capacity from the contracting authority to identify potential errors	Operational Fraud and corruption	Provide check lists to be filled in by the evaluation committee for every bid evaluation Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices Selection of evaluation committee members in accordance with the regulation
	Lack of knowledge of the legal requirements	Operational	Provide comprehensive training to evaluation committee members on the legal requirements on bids evaluation Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices
	Corruption and/or conflict of interest	Fraud and corruption	Conduct regular audits Publish summary reports of the evaluation process and outcomes to increase transparency Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct Robust vetting and selection of officials
	Bid scoring inconsistent with tender documents	Fraud and corruption Operational	Develop clear, measurable award criteria as much as possible and establish procedures providing for detailed justification of the evaluation and scoring of criteria Provide comprehensive training to evaluation committee members on how to apply the criteria objectively and consistently Provide the evaluation committee with checklists, guiding their evaluation Publish summary reports of the evaluation process and outcomes to increase transparency
Lack of transparency in the evaluation process of non-competitive procedures	Lack of safeguards and internal control system	Operational Fraud and corruption	Thoroughly document and steps of the process and make them available for review Publish summary reports of outcomes for public scrutiny Carry out regular audits Robust vetting and selection of officials
	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Develop clear, measurable award criteria as much as possible and establish procedures providing for detailed justification of the evaluation and scoring of criteria Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Lack of training on integrity in public procurement	Operational Fraud and corruption	Build the capacity of procurement officials on the identification of integrity breaches Provide training on ethical standards and consequences of malpractice
Lack of negotiations with the awarded contractor for negotiated procedures	Corruption and/or conflict of interest	Fraud and corruption	Build the capacity of procurement officials on the identification of integrity breaches Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Lack of capacity on bid negotiation	Operational	Conduct regular training programmes on public procurement regulations, negotiation techniques, and best practices Develop standardised negotiation frameworks and templates and consider making their use mandatory
Lack of information on beneficial ownership	Lack of capacity on bid evaluation	Operational	Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices Implement compliance checks on adherence to regulations regarding beneficial ownership
Manipulation of bid evaluation to the advantage of a specific economic operator	Corruption and/or conflict of interest	Fraud and corruption	Disclose all potential conflict of interests through formal declarations and consider disqualifying members from participation to avoid any possible biases Conduct regular internal and external audits to detect and prevent corrupt practices Promote whistle-blowing mechanisms Development of a code of conduct Robust vetting and selection of officials Rotation of procurement officials
	Lack of training on integrity in public procurement	Operational Fraud and corruption	Build the capacity of procurement officials on the identification of integrity breaches Provide training on ethical standards and consequences of malpractice
Failure to maintain adequate records (e.g. minutes of the evaluation process, documents necessary to lodge a preliminary appeal)	Lack of legal sanctions in case the required documents are not provided	Fraud and corruption Legal/regulatory/compliance	Consider introducing sanctions for officials who do not provide to economic operators all the documents required by the law Provide clear guidance and training on maintaining records
	Lack of internal record keeping system for procurement documents, including bid evaluation	Operational Fraud and corruption	Establish an internal record keeping system for procurement documents Provide clear guidance and training on maintaining records
	Minutes of the evaluation committee not uploaded on ESIDIS	Fraud and corruption Operational	Consider making it clear in the law that all minutes of the evaluation committees have to be uploaded on ESIDIS and provide for sanctions for officials who do not upload evaluations on ESIDIS Provide clear guidance and training on maintaining records, including uploading minutes of the evaluation committee on ESIDIS
	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Implement audit trails to track all actions and decisions taken during the evaluation process Provide clear guidance and training on maintaining records Promote whistle-blowing mechanisms
Financial offer is no longer viable due to legal changes (labor legislation, safety and health legislation, etc.)	Force majeure	Fiscal	Consider inserting contract price adjustment clauses in case of changes in the legal framework, at least for the changes that can be foreseen (e.g. changes in the minimum wage)
	Delays in the public procurement procedure	Operational	Include clauses in the contract that allow for adjustments in case of significant legal changes
Failure to verify ESPD content	Lack of capacity on bid evaluation	Operational	Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices
Failure to verify ESPD content	Incorrect completion of ESPD	Legal/regulatory/compliance Fraud and corruption	Conduct regular training programmes on public procurement regulations, evaluation techniques, and best practices Where possible, use automated tools to verify the European Single Procurement Document (ESPD) content
Risk of not enforcing exclusion criteria effectively	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Implement monitoring mechanisms to ensure exclusion criteria are consistently applied Establish and follow up on corrective action plans for bidders who do not initially meet criteria Conduct regular internal and external audits to detect and prevent corrupt practices Promote whistle-blowing mechanisms Development of a code of conduct
	Lack of capacity of the members of the evaluation committee	Operational	Provide comprehensive training to evaluation committee members on how to apply the criteria objectively and consistently
	Lack of a digital registry to record the economic operators who meet common grounds for exclusion	Operational Fraud and corruption	Consider introducing an electronic registry to track economic operators who do not meet common grounds for exclusion
False documentation and information submitted by bidders	Corruption and/or conflict of interest	Fraud and corruption	Implement a rigorous verification process for all submitted documents and information Impose strict penalties for submitting false information Maintain a registry of economic operators
	Lack of safeguards and internal control system	Fraud and corruption Operational	Conduct risk-based controls and background checks on bidders

Tendering phase
Issuance and signing of contract (prepare the final contract document, obtain necessary internal approvals, send the final contact, ensure both parties signed the contract, retain copies for official records..)
Risk	Root cause	Risk category	Mitigation measures
Lack of justification from the contracting authority to deviate from the recommendation of the evaluation committee	Corruption and/or conflict of interest	Legal/regulatory/compliance Fraud and corruption	Document all stages of the procurement process by requiring detailed documentation and justification whenever the contracting authority deviates from the evaluation committee’s recommendation
	Lack of knowledge of the legal requirements	Operational Fraud and corruption	Provide guidelines and information on the public procurement law for members of the decision making body of the contracting authority
Contract terms different from what was foreseen in the tender	Corruption and/or conflict of interest	Legal/regulatory/compliance Fraud and corruption	Conduct a thorough review of the contract terms by legal and procurement specialists before signing to ensure they match the tender specifications Conduct regular audits to ensure compliance Develop and implement training programmes focused on integrity in public procurement
	Lack of capacity on drafting the contract terms	Operational	Use standardized contract templates that align closely with the terms outlined in the tender documents Implement capacity-building programmes to enhance the skills and knowledge of procurement staff
Delays in signing the contract	Lack of capacity to effectively plan public procurement activities	Operational	Raise awareness of the economic operators on the importance of signing the contract as soon as possible Include a maximum timeline for the preparation of contracts in internal processes Include contingencies in the procurement timeline
	Corruption and/or conflict of interest	Fraud and corruption	Document all stages of the procurement process Conduct regular controls to ensure compliance Develop and implement training programmes focused on integrity in public procurement
	Lack of financial resources	Fiscal	Maintain regular communication with the technical and finance departments of the contracting authority to ensure sufficient financial resources remain available
	Numerous appeals from economic operators	Legal/regulatory/compliance	Include contingencies in the procurement timeline
	Poor quality of tender documents	Operational	Use HSPPA templates and checklists to prepare tender documents Have tender documents reviewed by multiple stakeholders, including legal, technical, and procurement experts Provide training for officials on tender preparation
	Delay in the submission of supporting documents by the winning bidder	Legal/regulatory/compliance	Adherence to a strict and clear timetable and regular communication with the contractor
Lack of signature of the contract by the economic operator	Culture of not applying legal sanctions due to the economic operator's failure to sign the contract	Legal/regulatory/compliance Fraud and corruption	Establish guidelines and processes for the application of legal sanctions
	Lack of capacity to effectively plan public procurement activities	Legal/regulatory/compliance Operational	Include contingencies in the procurement timeline
	Change of mind of the economic operator	Fiscal	Maintain regular communication with the economic operator throughout the process to address any concerns or issues that might prevent them from signing Have contingency plans in place to quickly move to the next qualified bidder if the selected economic operator fails to sign Raise awareness among the economic operators on the importance of signing the contract as soon as possible
Not applying the legal sanctions in case the contract is not signed by the economic operator	Corruption and/or conflict of interest	Legal/regulatory/compliance Fraud and corruption	Document all stages of the procurement process Implement automated systems that trigger penalties or other sanctions when contract signing deadlines are missed
	Lack of knowledge and competency from the CA regarding the signature of the contract	Operational	Provide legal support so that sanctions are applied correctly and consistently
Breaches of personal data protections	Lack of safeguards and internal control system	Legal/regulatory/compliance Fraud and corruption	Carry out regular controls, outsource legal expertise on data protection requirements if needed
Breaches of personal data protections	Lack of knowledge of the data protection legislation	Legal/regulatory/compliance	Provide training to all employees involved in the procurement process on data protection best practices
Cancellation of the tender procedure	Changes in goals or strategic objectives or choices of the entity	Strategic	Provide adequate notice and justification to bidders and handle the cancellation process transparently Establish clear criteria and communication protocols for the cancellation of tender procedures and better procurement planning
Cancellation of the tender procedure	Corruption and/or conflict of interest	Fraud and corruption	Provide adequate notice and justification to bidders and handle the cancellation process transparently Establish clear criteria and communication protocols for the cancellation of tender procedures and better procurement planning

Post-tendering
Monitoring contract performance (ensure contract milestones and deadlines are met, maintain detailed records of all monitoring activities, review progress reports and performance metrics, conduct site visits and inspections..)
Risk	Root cause	Risk category	Mitigation measures
Delays in contract performance	Lack of contracting authority capacity and knowledge to monitor contract performance	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Provide resources such that staffing is proportional to the workload Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Lack of capacity to effectively plan public procurement activities	Operational	Develop a comprehensive training program on procurement planning Engage external experts to support the planning of complex procurement activities
	Bidder selected without the necessary resources and technical experience to perform the contract	Operational Fraud and corruption	Enhance the prequalification and evaluation criteria to ensure bidders have the required resources and technical expertise Perform thorough background checks and due diligence on suppliers Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Adoption of procedures providing for detailed justification of the evaluation and scoring of criteria Robust vetting and selection of officials
	Corruption and/or conflict of interest	Fraud and corruption	Regular inspections and progress reporting by experienced individuals in contract project management Provide training on ethical standards and consequences of malpractice Development of a code of conduct Enforce strict anti-corruption policies and code of conduct
Products, works and services delivered differ from the what is foreseen in the contract	Lack of due diligence before accepting products, works and services	Legal/regulatory/compliance Fraud and corruption	Implement strict verification and quality control procedures to ensure products, works and services match contract specifications Ensure contracting authority staff responsible for receiving goods, services and works have appropriate training and qualifications Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Bidder selected without the necessary resources and technical experience to perform the contract	Operational Fraud and corruption	Enhance the prequalification and evaluation criteria to ensure bidders have the required resources and technical expertise Perform thorough background checks and due diligence Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Lack of capacity on monitoring contract performance	Operational	Ensure that the number of the staff is proportional to the workload Invest in capacity-building programmes for staff involved in monitoring. This includes training on monitoring techniques, data analysis, and reporting Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Lack of communication with the contractor	Operational	Regular communication with suppliers to ensure common understanding of requirements and contract terms
	Lack of capacity of the members of the receiving committee	Operational	Train receiving committee members on quality standards and verification processes
Lack of proper and regular monitoring of contract performance	Lack of KPIs for contract performance	Legal/regulatory/compliance	Define key performance indicators (KPIs) for monitoring contract performance
	Lack of capacity to monitor contract performance	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Provide resources such that staffing is proportional to the workload, including assigning dedicated staff to monitor performance and the authority and resources to enforce compliance Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Lack of digital monitoring system	Operational	Invest in digital tools and systems to support the monitoring of contract performance
	Corruption and/or conflict of interest	Fraud and corruption	Implement a clear separation of roles and responsibilities among those involved in evaluation and reception Conduct regular training sessions on ethical practices and integrity in procurement for all staff involved in the procurement process Implement stringent conflict-of-interest policies and ensure transparency in subcontractor selection. Conduct regular audits to detect and address any conflicts
Failure to perform the contract in line with contract clauses	Bidder selected without the necessary resources and technical experience to perform the contract	Operational Fraud and corruption	Enhance the prequalification and evaluation criteria to ensure bidders have the required resources and technical expertise Perform thorough background checks and due diligence Include experts with relevant technical and industry knowledge in the evaluation committee to provide insights and ensure thorough assessments
	Lack of capacity to monitor contract performance	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Provide resources such that staffing is proportional to the workload, including assigning dedicated staff to monitor performance and the authority and resources to enforce compliance Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Insufficient supplier management	Operational Fraud and corruption	Organize a kick-off meeting to ensure mutual understanding on contract conditions and responsibilities Seek to establish good working relationships by setting regular meetings to communicate expectations and issues Provide feedback on progress reports and organize meetings to inform suppliers of requirements and timeframes for deliverables Implement capacity-building programmes to enhance the skills and knowledge of procurement staff
	Lack of knowledge of health and safety issues on the part of the contracting authority	Health and safety risks	Implement regular training sessions focused on public procurement processes, contract management, and relevant legal frameworks to ensure that contracting authority staff are well-informed and up-to-date
	Subcontractors do not comply with contract clauses, such as on health and safety	Health and safety risks Fraud and corruption	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Ensure that the number of the staff is proportional to the workload, including assigning dedicated staff to monitor performance and have the authority and resources to enforce compliance Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise Include requirements that subcontractors comply with clauses in areas such as health and safety and require the main contractor to report on compliance
	Corruption and/or conflict of interest (e.g. collusion between contractors and contracting authority staff)	Fraud and corruption	Conduct regular checks of compliance with contract terms Conduct regular training sessions on ethical practices and integrity in procurement for all staff involved in the procurement process Promote whistle-blowing mechanisms Robust vetting and selection of officials
Lack of transparency in the monitoring process	Lack of KPIs for contract performance	Operational	Define key performance indicators (KPIs) for monitoring contract performance
Lack of transparency in the monitoring process	Lack of safeguards and internal control system	Operational Fraud and corruption	Conduct regular training sessions on ethical practices and integrity in procurement for all staff involved in the procurement process Conduct regular audits
Delays in the reception of goods, services and works	Lack of capacity in the contracting authority due to workload, lack of internal procedures, etc.	Operational	Ensure contracting authority staff responsible for receiving goods, services and works have appropriate training and qualifications Train receiving committee members on quality standards and verification processes Definition of a strict timetable and more detailed internal procedures for monitoring and acceptance of the contract deliverables

Post-tendering phase
Modification of contract (identify the need for a contract modification, draft the proposed changes, amend the contract formally, communicate the changes, ..)
Risk	Root cause	Risk category	Mitigation measures
Unlawful modifications of the contract (e.g. illegal increases of contract value (in terms of quantities and scope, illegal contract extension)	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Implement an approval process for modifications, requiring sign-off from legal and compliance departments Conduct regular audits to verify that modifications adhere to legal requirements and are properly documented Promote whistle-blowing mechanisms Robust vetting and selection of officials
	Lack of capacity to modify the contract in line with legal and regulatory requirements	Operational	Invest in capacity building initiatives to enhance the skills and knowledge of procurement staff in modifying contracts according to legal and regulatory requirements Develop and implement standard procedures for contract modifications that align with legal standards
	Lack of digital system with monitoring and red-flagging capabilities	Operational	Invest in and implement digital procurement systems that include monitoring and red-flagging capabilities to identify and address issues promptly Regularly update digital systems to incorporate the latest regulatory requirements and technological advancements
	Lack of safeguards and control mechanisms over contract modifications	Operational Fraud and corruption	Establish a process and requirement for detailed justification of the need to modify the contract
Modification of the object of the contract	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Implement an approval process for modifications, requiring sign-off from legal and compliance departments Conduct regular audits to verify that modifications adhere to legal requirements and are properly documented Promote whistle-blowing mechanisms Robust vetting and selection of officials
	Lack of capacity to modify the contract in line with legal and regulatory requirements	Operational	Define the scope of the contract clearly and include clauses that restrict changes to the core objectives and deliverables Invest in capacity building initiatives to enhance the skills and knowledge of procurement staff in modifying contracts according to legal and regulatory requirements
	Lack of digital system with monitoring and red-flagging capabilities	Operational	Invest in and implement digital procurement systems that include monitoring and red-flagging capabilities to identify and address issues promptly Regularly update digital systems to incorporate the latest regulatory requirements and technological advancements
	Lack of safeguards and control mechanism over the contract modifications	Operational Fraud and corruption	Establish a process and requirement for detailed justification of the need to modify the contract
Change of contractors not meeting the required standards during contract implementation	Corruption and/or conflict of interest	Legal/regulatory/compliance Fraud and corruption	Conduct thorough due diligence on any new contractors to ensure they meet the required standards before approving changes Require high-level approval for any changes in contractors, ensuring that the decision is scrutinized from multiple perspectives
	Lack of capacity to modify the contract in line with legal and regulatory requirements	Operational	Invest in capacity building initiatives to enhance the skills and knowledge of procurement staff in modifying contracts according to legal and regulatory requirements Develop and implement standard procedures for contract modifications that align with legal standards
	Lack of safeguards and control mechanism over the contract modifications	Operational Fraud and corruption	Establish a process and requirement for detailed justification of the need to modify the contract Establish a clear legal supervision and approval hierarchy for contract modification Regular audits to ensure compliance with procedures in place Establish robust internal control systems
Numerous amendments to the contract	Force majeure	Legal/regulatory/compliance	Include comprehensive force majeure clauses in contracts to define the scope, obligations, and procedures in case of unforeseen events Develop contingency plans to manage and mitigate the impacts of force majeure events on contract performance
	Poor quality of tender documents	Operational Fraud and corruption	Use HSPPA templates for tender documents to ensure consistency and completeness Implement an internal process for reviewing tender documents to identify and rectify any deficiencies before publication Provide training on preparation of tender documents
	Inadequate needs analysis	Operational Fraud and corruption	Use tools such as the OECD needs analysis guidance Engage relevant stakeholders in the needs analysis process to capture diverse perspectives and needs
	Lack of safeguards and control mechanisms over contract modifications	Operational Fraud and corruption	Establish a process and requirement for detailed justification of the need to modify the contract
	Corruption and/or conflict of interest	Fraud and corruption	Make the contract modification process transparent and communicate changes to all stakeholders Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct Robust vetting and selection of officials
Unforeseen circumstances leading to contractual changes	Lack of clarity of circumstances requiring contractual changes	Legal/regulatory/compliance	Clarify the application of force majeure Include clauses in the contract that outline the conditions under which contract adjustments are permissible Require independent verification of the circumstances necessitating contract modifications
Unforeseen circumstances leading to contractual changes	Changes in regulation	Legal/regulatory/compliance	Include clauses in the contract that outline the conditions under which contract adjustments are permissible
Major amendments to the contract undermining the equitable treatment of bidders at the selection phase	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Make the contract modification process transparent and communicate changes to all stakeholders Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct Robust vetting and selection of officials
	Lack of proper monitoring	Operational	Provide training on project and contract monitoring
	Lack of safeguards and control mechanism over the contract modifications	Operational Fraud and corruption	Establish a process and requirement for detailed justification of the need to modify the contract Implement an approval process for modifications, requiring sign-off from legal and compliance departments Conduct regular audits to verify that modifications adhere to legal requirements and are properly documented Promote whistle-blowing mechanisms
	Lack of capacity to modify the contract in line with legal and regulatory requirements	Operational	Invest in capacity building initiatives to enhance the skills and knowledge of procurement staff in modifying contracts according to legal and regulatory requirements Develop and implement standard procedures for contract modifications that align with legal standards
Failure to exercise extension clauses before the end of the contract	Inadequate monitoring	Operational	Establish dedicated contract monitoring teams with clear roles and responsibilities Invest in monitoring tools and systems to track contract performance and compliance effectively
	Lack of communication with the supplier	Operational	Develop a communication plan outlining the methods, frequency, and channels for communication with suppliers throughout the contract lifecycle Schedule regular meetings with suppliers to discuss contract performance, address issues, and build a collaborative relationship
No contract amendment despite changes in the execution of the contract (e.g. increase in contractual value, changes in prices)	Corruption and/or conflict of interest	legal/regulatory/compliance Fraud and corruption	Regularly update contracts to reflect changes in execution to maintain alignment with the current state of the project Conduct regular audits to ensure amendments are made in a timely way Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct Robust vetting and selection of officials
	Lack of contract monitoring	Operational Fraud and corruption	Continuously monitor legal and regulatory changes that may impact contract terms and ensure timely amendments Maintain open lines of communication with all stakeholders to ensure that necessary amendments are identified and implemented Develop detailed procurement plans that outline timelines and responsibilities for all procurement activities, including making contract modifications
Failure to publish contract modifications	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Conduct regular audits Consider introducing sanctions for not publishing contract modifications Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Lack of knowledge of the legal requirements	Legal/regulatory/compliance	Provide specialized legal training for procurement staff to ensure they understand the legal requirements and implications of contract modifications Ensure access to legal advisors who can provide guidance on contract modification issues
	Lack of capacity to modify the contract in line with legal and regulatory requirements	Operational	Invest in capacity building initiatives to enhance the skills and knowledge of procurement staff in modifying contracts according to legal and regulatory requirements Develop and implement standard procedures for contract modifications that align with legal standards
	Lack of safeguards and internal control system	Operational Fraud and corruption	Conduct regular audits Consider introducing sanctions for not publishing contract modifications
Poor or non-application of the price revision formula	Lack of capacity on invoicing and payment	Operational	Ensure contracts include clear and detailed price revision formulas Train staff on how to apply these formulas correctly Provide comprehensive training programmes for staff involved in invoicing and payment Develop and implement detailed guidelines and procedures for invoicing and payment processes Regularly review and update training materials to reflect current best practices and regulatory changes
	Lack of contract monitoring	Operational Fraud and corruption	Regularly review price revisions to ensure accuracy
	Lack of knowledge of the legal requirements of the price revision formula	Operational	Train staff on how to apply these formulas correctly Provide comprehensive training programmes for staff involved in invoicing and payment

Post-tendering
Ordering (issuing purchase orders, managing the receipt of goods and services, verifying that they meet contract specifications and processing payments)
Risk	Root cause	Risk category	Mitigation measures
Not ordering from the current contract (i.e. continuing to order from a previous contract)	Lack of supervision and control mechanisms	Operational Fraud and corruption	Establish clear roles and responsibilities for contract management and supervision. Implement regular audits and inspections to ensure compliance Develop a comprehensive internal control system to monitor procurement activities
	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Implement strict internal controls and audits to monitor orders Implement strict anti-corruption policies and conflict of interest declarations Conduct regular training on ethics and compliance for procurement staff
	Non-activation of the termination clause of the previous contract	Legal/regulatory/compliance Fraud and corruption	Ensure clear understanding and enforcement of all contract clauses Monitor contract performance closely and act promptly on breaches Provide training for procurement staff on contract management and enforcement
	Lack of capacity regarding the ordering of the goods and services foreseen in the contract	Operational	Make procurement staff aware of the latest contracts Conduct regular training and capacity-building programmes for procurement staff Develop and implement standard operating procedures for ordering goods and services
	Lack of digital monitoring systems	IT	Use procurement software that flags outdated contracts and highlights the current ones
The goods and services foreseen in the contract were never ordered	Poor procurement planning	Operational	Develop comprehensive procurement plans based on needs assessments and market analysis Involve all relevant stakeholders in the planning process Review and update procurement plans regularly to adapt to changes
	Inadequate needs analysis	Operational	Conduct thorough needs assessments before initiating the procurement process Engage with end-users to gather detailed requirements Use tools such as the OECD needs analysis guidelines Provide training for procurement staff on contract management and enforcement
	Lack of capacity regarding the ordering of the goods and services foreseen in the contract	Operational	Make procurement staff aware of the current contracts Conduct regular training and capacity-building programmes for procurement staff Develop and implement standard operating procedures for ordering goods and services
	Inaccurate delivery schedule in tendering documents	Operational	Ensure accuracy and transparency in all tender documents Verify and validate delivery schedules with suppliers Conduct thorough reviews of all tender documents before issuance
Delays in the ordering process of a central framework agreement	Lack of a record keeping system in the contracting authority participating in the framework agreement	Operational	Implement a comprehensive record-keeping system for all procurement activities Maintain complete, accurate, and up-to-date documentation Regularly review and audit records to ensure compliance
	Lack of capacity to effectively plan public procurement activities	Operational	Develop comprehensive procurement plans based on needs assessments and market analysis Involve all relevant stakeholders in the planning process Review and update procurement plans regularly to adapt to changes
	Lack of capacity in the contracting authority regarding the ordering of the goods and services foreseen in the contract	Operational Fraud and corruption	Streamline the ordering process by setting clear timelines and responsibilities Make procurement staff aware of the latest contracts Conduct regular training and capacity-building programmes for procurement staff Develop and implement standard operating procedures for ordering goods and services
	Lack of communication between the supplier, the contracting authority and the central purchasing authority	Operational	Regular communication such as meetings and updates to ensure alignment
No records of the order of the goods and services available	Lack of internal system to record the order of the goods and services	Operational Fraud and corruption	Put in place robust documentation and record-keeping practices Conduct regular audits to verify that records are complete and accurate Promote whistle-blowing mechanisms Conduct regular training on ethics and compliance for competent staff
	Lack of digital system	Operational	Maintain a digital procurement system that logs all transactions and orders
Legal disputes and litigation	Bidder selected does not have the resources to deliver the goods and services	Fiscal Fraud and corruption	Seek to establish good working relationships with contractors by setting regular meetings Prepare and sign minutes of meetings to record discussed and agreed points in written manner
Legal disputes and litigation	Corruption and/or conflict of interest	Fraud and corruption Legal/regulatory/compliance	Specify in the contract documents how to resolve any disputes which might arise during the contract execution Provide feedback on progress reports and update meetings to inform them of requirements and timeframes for deliverables Monitor and update reports and continuously seek to manage and mitigate issues throughout the process Conduct regular training on ethics and compliance for procurement staff
Ordering goods or services not covered by the contract	Corruption and/or conflict of interest	Fraud and corruption	Conduct periodic audits to identify discrepancies between contracted items and orders Implement strict anti-corruption policies and conflict of interest declarations Conduct regular training on ethics and compliance for procurement staff

Post-tendering
Monitoring contract performance (ensure contract milestones and deadlines are met, maintain detailed records of all monitoring activities, review progress reports and performance metrics, conduct site visits and inspections..)
Risk	Root cause	Risk category	Mitigation measures
Delays in contract performance	Lack of contracting authority capacity and knowledge to monitor contract performance	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Provide resources such that staffing is proportional to the workload Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Lack of capacity to effectively plan public procurement activities	Operational	Develop a comprehensive training program on procurement planning Engage external experts to support the planning of complex procurement activities
	Bidder selected without the necessary resources and technical experience to perform the contract	Operational Fraud and corruption	Enhance the prequalification and evaluation criteria to ensure bidders have the required resources and technical expertise Perform thorough background checks and due diligence on suppliers Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Adoption of procedures providing for detailed justification of the evaluation and scoring of criteria Robust vetting and selection of officials
	Corruption and/or conflict of interest	Fraud and corruption	Regular inspections and progress reporting by experienced individuals in contract project management Provide training on ethical standards and consequences of malpractice Development of a code of conduct Enforce strict anti-corruption policies and code of conduct
Products, works and services delivered differ from what is foreseen in the contract	Lack of due diligence before accepting products, works and services	Legal/regulatory/compliance Fraud and corruption	Implement strict verification and quality control procedures to ensure products, works and services match contract specifications Ensure contracting authority staff responsible for receiving goods, services and works have appropriate training and qualifications Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Bidder selected without the necessary resources and technical experience to perform the contract	Operational Fraud and corruption	Enhance the prequalification and evaluation criteria to ensure bidders have the required resources and technical expertise Perform thorough background checks and due diligence Promote whistle-blowing mechanisms Provide training on ethical standards and consequences of malpractice Development of a code of conduct
	Lack of capacity on monitoring contract performance	Operational	Ensure that the number of the staff is proportional to the workload Invest in capacity-building programmes for staff involved in monitoring. This includes training on monitoring techniques, data analysis, and reporting Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Lack of communication with the contractor	Operational	Regular communication with suppliers to ensure common understanding of requirements and contract terms
	Lack of capacity of the members of the receiving committee	Operational	Train receiving committee members on quality standards and verification processes
Lack of proper and regular monitoring of contract performance	Lack of KPIs for contract performance	Legal/regulatory/compliance	Define key performance indicators (KPIs) for monitoring contract performance
	Lack of capacity to monitor contract performance	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Provide resources such that staffing is proportional to the workload, including assigning dedicated staff to monitor performance and the authority and resources to enforce compliance Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Lack of digital monitoring system	Operational	Invest in digital tools and systems to support the monitoring of contract performance
	Corruption and/or conflict of interest	Fraud and corruption	Implement a clear separation of roles and responsibilities among those involved in evaluation and reception Conduct regular training sessions on ethical practices and integrity in procurement for all staff involved in the procurement process Implement stringent conflict-of-interest policies and ensure transparency in subcontractor selection. Conduct regular audits to detect and address any conflicts
Failure to perform the contract in line with contract clauses	Bidder selected without the necessary resources and technical experience to perform the contract	Operational Fraud and corruption	Enhance the prequalification and evaluation criteria to ensure bidders have the required resources and technical expertise Perform thorough background checks and due diligence Include experts with relevant technical and industry knowledge in the evaluation committee to provide insights and ensure thorough assessments
	Lack of capacity to monitor contract performance	Operational	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Provide resources such that staffing is proportional to the workload, including assigning dedicated staff to monitor performance and the authority and resources to enforce compliance Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise
	Insufficient supplier management	Operational Fraud and corruption	Organize a kick-off meeting to ensure mutual understanding on contract conditions and responsibilities Seek to establish good working relationships by setting regular meetings to communicate expectations and issues Provide feedback on progress reports and organize meetings to inform suppliers of requirements and timeframes for deliverables Implement capacity-building programmes to enhance the skills and knowledge of procurement staff
	Lack of knowledge of health and safety issues on the part of the contracting authority	Health and safety risks	Implement regular training sessions focused on public procurement processes, contract management, and relevant legal frameworks to ensure that contracting authority staff are well-informed and up-to-date
	Subcontractors do not comply with contract clauses, such as on health and safety	Health and safety risks Fraud and corruption	Implement capacity-building programmes to enhance the skills and knowledge of procurement staff Ensure that the number of the staff is proportional to the workload, including assigning dedicated staff to monitor performance and have the authority and resources to enforce compliance Develop and disseminate comprehensive guidelines for contract performance monitoring, including early intervention when issues arise Include requirements that subcontractors comply with clauses in areas such as health and safety and require the main contractor to report on compliance
	Corruption and/or conflict of interest (e.g. collusion between contractors and contracting authority staff)	Fraud and corruption	Conduct regular checks of compliance with contract terms Conduct regular training sessions on ethical practices and integrity in procurement for all staff involved in the procurement process Promote whistle-blowing mechanisms Robust vetting and selection of officials
Lack of transparency in the monitoring process	Lack of KPIs for contract performance	Operational	Define key performance indicators (KPIs) for monitoring contract performance
Lack of transparency in the monitoring process	Lack of safeguards and internal control system	Operational Fraud and corruption	Conduct regular training sessions on ethical practices and integrity in procurement for all staff involved in the procurement process Conduct regular audits
Delays in the reception of goods, services and works	Lack of capacity in the contracting authority due to workload, lack of internal procedures, etc.	Operational	Ensure contracting authority staff responsible for receiving goods, services and works have appropriate training and qualifications Train receiving committee members on quality standards and verification processes Definition of a strict timetable and more detailed internal procedures for monitoring and acceptance of the contract deliverables

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