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Call key data
Operational Strengthening of Montenegro’s AFCOS System for the protection of the EU Financial Interests
Funding Program
Instrument for Pre-accession Assistance
Call number
EuropeAid/186515/DD/ACT/ME
deadlines
Opening
23.04.2026
Deadline
19.06.2026 16:30
Funding rate
100%
Call budget
€ 250,000.00
Estimated EU contribution per project
€ 250,000.00
Link to the call
Call content
short description
The objective of this twinning light is to strengthen the operational and preventive anti-fraud capacity of the AFCOS system by developing practical tools for managing irregularities and fraud, enhancing institutional coordination and cooperation with OLAF, reinforcing reporting and procedural frameworks, and increasing the awareness and capacity of stakeholders involved in protecting the EU’s financial interests.
Call objectives
Overall Objective
Reinforcing Operational and Preventive Anti-Fraud Mechanisms within Montenegro’s AFCOS System.
Specific Objective
Strengthened operational and preventive anti-fraud capacity of the AFCOS system through the development of practical irregularity and fraud management tools, enhanced institutional coordination and cooperation with OLAF, strengthened reporting and procedural frameworks, and increased awareness and capacities of relevant stakeholders involved in the protection of EU financial interests.
The elements targeted in strategic documents i.e. National Development Plan/Cooperation Agreement/Association Agreement/Sector reform strategy and related Action Plans
Relations between Montenegro and the European Union are governed by the Stabilisation and Association Agreement (SAA), which entered into force on 1 May 2010 and provides the legal framework for political dialogue, regional cooperation, economic relations and the use of EU financial assistance. The SAA establishes Montenegro’s obligation to align its legal and institutional framework with EU standards, including in the area of protection of the EU financial interests.
The activities envisaged under this Twinning Light project are directly linked to Chapter 32 – Financial Control, which was provisionally closed in January 2026. Chapter 32 encompasses public internal financial control, external audit, protection of the EU’s financial interests and protection of the euro from counterfeiting.
The project is also aligned with Chapter 22 – Regional Policy and Coordination of Structural Instruments, as effective protection of EU financial interests is a precondition for sound management of IPA III funds and future Structural and Cohesion Funds.
Furthermore, the project is consistent with the Framework Financial and Partnership Agreement (FFPA) signed between Montenegro and the European Commission, which obliges Montenegro to ensure effective systems for prevention, detection and reporting of irregularities and fraud, including reporting through the Irregularity Management System (IMS).
Furthermore, the project is consistent with the Reform and Growth Facility Agreement, signed between Montenegro and the European Commission, which obliges Montenegro to ensure effective systems for prevention, detection and reporting of irregularities and fraud, including reporting through the Irregularity Management System (IMS).
The Action Document under IPA III identifies the need for strengthening operational tools, enhancing IMS reporting procedures (including for the Reform and Growth Facility), and raising awareness among stakeholders and the general public regarding protection of EU financial interests.
At national level, the project contributes to the implementation of the National Anti-Fraud Strategy for the Protection of the European Union’s Financial Interests (NAFS) 2025–2028, adopted by the Government of Montenegro together with its Action Plan 2025–2026. This strategic document defines key policy objectives aimed at strengthening the institutional, operational and preventive capacities of the AFCOS system and improving coordination among institutions responsible for protecting EU financial interests.
The action also builds on the results of the Strategy for Combating Fraud and Management of Irregularities for the Protection of EU Financial Interests for the period 2019–2022, whose evaluation provided recommendations for strengthening the AFCOS system, improving irregularity management procedures and enhancing administrative capacities.
In addition, the project is consistent with the Public Finance Management Reform Programme 2022–2026, which includes measures aimed at strengthening internal control systems, improving risk management and reinforcing mechanisms for prevention and detection of irregularities and fraud in the management of EU funds.
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Expected effects and impacts
Expected activities
COMPONENT I – Strengthening operational and strategic framework for effective protection of EU financial interests
Result 1: Strengthened operational anti-fraud framework within the AFCOS system
- Sub-Result 1.1: National Anti-Fraud Strategy’s Action Plan 2027–2028 developed
- A.1.1.1. An in-depth analysis of the implementation of the current National Anti-Fraud Strategy will be conducted, including assessment of achieved indicators, identified gaps, and recommendations emerging from previous evaluations. The analysis will include structured consultations with representatives of the AFCOS, AFCOS Network members and IPA structure;
- A.1.1.2. Based on the analysis, a comprehensive draft Action Plan (2027–2028) will be prepared. The Action Plan will define clearly measurable activities, institutional responsibilities, deadlines and output and outcome indicators in line with Government guidelines for strategic documents. The Action Plan will also be based on the results of the “Fraud risk analysis with statistical analysis of irregularity cases, in the context of implementing projects financed from IPA funds” (to be developed by AFCOS in 2026), ensuring full coverage of the remaining period of the NAFS and alignment with OLAF recommendations.
- Sub-Result 1.2: Fraud Prevention and Detection Checklist for EU-Funded Projects with Practical Guidance Manual developed
- A.1.2.1. A comparative analysis of EU Member State practices in fraud prevention and detection throughout the project lifecycle will be conducted, with a view to identifying best practices and applicable red flag indicators;
- A.1.2.2. Based on the analysis, a comprehensive Fraud Prevention and Detection Checklist for EU-funded projects will be developed, incorporating red flag indicators and structured control points applicable to procurement procedures, grant award processes, contract implementation, and verification of payment claims;
- A.1.2.3. A Practical Guidance Manual will be prepared as an integral part of the tool, defining verification steps, documentation requirements, risk indicators and control measures to be assessed prior to validating each checklist item;
- A.1.2.4. The Checklist and the Practical Guidance Manual will be tested through a dedicated practical workshop involving representatives of IPA structure.
- Sub-Result 1.3: Developed Methodology for handling irregularity and suspected fraud cases and reporting via IMS, in the context of the Reform and Growth Facility.
- A.1.3.1. Mapping of existing procedures for detection, preliminary assessment and reporting of irregularities and suspected fraud cases will be conducted, including identification of procedural gaps, bottlenecks and overlaps;
- A.1.3.2. A detailed Methodology for handling irregularity and suspected fraud cases will be developed, which includes specific provisions on reporting obligations to the European Commission and OLAF in line with the Reform and Growth Facility Agreement and clearly defines roles and responsibilities of the AFCOS, Irregularity Officers, IBFM/IBPMs and other relevant institutions;
- A.1.3.3. Specific guidance will be included on the structured use of the Irregularity Management System (IMS), documentation standards, timelines, communication channels with EU institutions, and follow-up of reported cases in the context of the Reform and Growth Facility.
- Sub-Result 1.4 Awareness-raising public event organised
- A.1.4.1 One national public event organised with participation of AFCOS system institutions, civil society organisations and media. The event will focus on the importance of protecting EU financial interests and promoting zero fraud tolerance.
COMPONENT II – Capacity building of AFCOS system stakeholders through practical anti-fraud training
Result 2: Increased operational capacity of AFCOS system stakeholders, including local self-government, in the prevention, detection and reporting of irregularities and fraud and in cooperation with OLAF.
- Sub-Result 2.1: Enhanced practical skills of AFCOS system staff and IPA structure in detecting, classifying and reporting irregularities and fraud.
- A.2.1.1. A practical training will be delivered focusing on detection, classification and reporting of irregularities and fraud in EU-funded projects. The training will be based on real case scenarios and simulation exercises, covering identification of red flags, classification of irregularities, documentation requirements and reporting through the Irregularity Management System (IMS). It will also include elements of financial forensics tailored for non-financial staff, enabling participants to identify anomalies in financial data, detect suspicious transactions and better understand financial evidence in the context of fraud cases.;
- A.2.1.2. Study visit for 6/7 officials to EU Member State in order to acquire hands on experience of the modus operandi regarding on-the spot controls and anti-fraud measures. The study visit will focus on the practical application of tools and methodologies developed during the Twinning project, such as the Fraud Prevention and Detection Checklist and related guidance, enabling participants to gain hands-on insight into their implementation in an EU Member State context.
- Sub-Result 2.2: Strengthened capacities of public officials at central and local self-government level in applying EU anti-fraud requirements and tools in the management of EU-funded projects
- A.2.2.1. A targeted training will be delivered for public officials involved in the implementation and management of EU-funded projects, with particular focus on local self-government units acting as beneficiaries, contracting authorities or implementing bodies under programmes such as IPA III, cross-border cooperation and IPARD. The training will cover EU anti-fraud requirements, practical identification of irregularities, prevention measures and reporting obligations. Particular attention will be given to risks specific to project implementation level, including procurement, contract management and conflict of interest situations.
- Sub-Result 2.3: Improved knowledge and practical application of fraud risk assessment and prevention mechanisms
- A.2.3.1. A specialised training will be delivered on fraud risk assessment and prevention in EU-funded programmes, focusing on practical methodologies for identifying, analysing and mitigating risks;
- A.2.3.2. The training will cover the use of risk indicators (“red flags”), with specific attention given to prevention and detection of conflict of interest situations, particularly in procurement and project implementation.
- Sub-Result 2.4: Enhanced capacity of judges and prosecutors in the protection of the EU financial interests and cooperation with EPPO
- A.2.4.1. A specialised training session will be delivered for judges and prosecutors on the legal framework for the protection of the EU financial interests, including relevant EU legislation, national criminal provisions and obligations arising from the Reform and Growth Facility Agreement;
- A.2.4.2. The training will address practical aspects of cooperation with the European Public Prosecutor’s Office (EPPO), including referral mechanisms, exchange of information, interaction between administrative findings and criminal proceedings, and handling of cases involving EU-funded projects.
- A.2.4.3. A practical case-based session will be incorporated into the training, focusing on scenarios involving suspected fraud, corruption and conflict of interest affecting EU funds.
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Expected results
Components and results per component
COMPONENT I – Strengthening operational and strategic framework for effective protection of EU financial interests
Result 1: Strengthened operational anti-fraud framework within the AFCOS system
The following indicative sub-results will be achieved:
- Sub-Result 1.1: National Anti-Fraud Strategy’s Action Plan 2027–2028 developed in line with Government Guidelines for strategic documents and OLAF recommendations;
- Sub-Result 1.2: Fraud Prevention and Detection Checklist for EU-Funded Projects with Practical Guidance Manual developed;
- Sub-Result 1.3: Developed Methodology for handling irregularity and suspected fraud cases and reporting via IMS, in the context of the Reform and Growth Facility;
- Sub-Result 1.4: Awareness-raising public event organised
COMPONENT II – Capacity building of AFCOS system stakeholders through practical anti-fraud training
Result 2: Increased operational capacity of AFCOS system stakeholders, including local self-government, in the prevention, detection and reporting of irregularities and fraud, as well as in cooperation with OLAF
The following indicative sub-results will be achieved:
- Sub-Result 2.1: Enhanced practical skills of AFCOS system staff and IPA structure in detecting, classifying and reporting irregularities and fraud
- Sub-Result 2.2: Strengthened capacities of public officials at central and local self-government level in applying EU anti-fraud requirements and tools in the management of EU-funded projects
- Sub-Result 2.3: Improved knowledge and practical application of fraud risk assessment and prevention mechanisms within the AFCOS system;
- Sub-Result 2.4: Enhanced capacity of judges and prosecutors in the protection of the EU financial interests and cooperation with EPPO
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Eligibility Criteria
Regions / countries for funding
Montenegro (Црна Гора)
eligible entities
Public Body (national, regional and local; incl. EGTCs)
Mandatory partnership
No
Project Partnership
Only Public Administrations and Mandated bodies as per Twinning Manual of European Union Member States may apply through European Union Member States’ National Contact Points.
One of the experts may act as the Project Leader (PL) responsible for general coordination.
Qualifications and skills of PL:
- University level education or equivalent professional experience of 8 years in public administration;
- Computer literacy;
- Working level of English language (oral and written);
- Presentation, communication and organizational skills.
Specific requirements:
- Proven experience in strategic project management and coordination of EU-funded or institution-building projects;
- Demonstrated capacity to lead multidisciplinary expert teams;
- Experience in cooperation with OLAF regarding irregularities and fraud;
- Minimum 3 years of experience in institution building in the field of combating irregularities and fraud;
- Experience in working within the public administration/s in the EU Member States, or candidate countries in the areas relevant to this TWL project;
- Knowledge of legislation related to the protection of EU financial interests;
Tasks of the Project Leader:
- Overall management and coordination of the project, in cooperation with Beneficiary Country Project Leader;
- Cooperation with main beneficiary and representatives of bodies in AFCOS system in undertaking all activities;
- Coordinating and ensuring sound implementation of envisaged activities;
- Providing professional advice to main beneficiary and representatives of bodies in AFCOS system during the project implementation period;
- Ensuring backstopping and financial management of the project in Member State Project reporting.
other eligibility criteria
Beneficiaries of the project are institutions involved in the Montenegrin AFCOS system. The system consists of three interrelated levels: the AFCOS within the Ministry of Finance, the IPA structure (IBFM/IBPMs and bodies managing EU funds), and institutions responsible for combating fraud, corruption and other forms of irregularities (AFCOS Network).
The main beneficiary of this Twinning Light project is the Ministry of Finance – Department for Protection of EU's Financial Interests/AFCOS, which acts as the coordinating body of the AFCOS system and the official contact point for OLAF.
Other beneficiaries include bodies managing EU funds under IPA III and the Reform and Growth Facility, as well as members of the AFCOS Network, including the Ministry of Justice, Ministry of European Affairs, Ministry of Interior, Police Administration, Revenue Administration and Customs Administration, Audit Authority, Agency for Prevention of Corruption, State Prosecutor’s Office, Ministry of Agriculture, Forestry and Water Management, Directorate for Payments, Ministry of Public Works, Employment Office, Ministry of Labour, Employment and Social Dialogue and the Ministry of Tourism, Ecology, Sustainable Development and Development of the North.
In accordance with Title IV of the Reform and Growth Facility Agreement, all institutions involved in the management and control of EU funds are required to ensure effective internal control systems, timely reporting of irregularities and suspected fraud, and structured cooperation with the European Commission, OLAF, EPPO and the European Court of Auditors. The Twinning Light project will support operational clarification and coordination mechanisms within the AFCOS system to ensure full compliance with these obligations.
The AFCOS currently operates with a limited number of staff and performs a coordinating role across the system. Effective cooperation between the AFCOS and other institutions is essential for ensuring sound financial management and protection of EU financial interests.
A Project Steering Committee will be established at the beginning of the project to ensure strategic guidance and monitoring of implementation. It will be composed of representatives of the AFCOS, selected members of the AFCOS Network and the EU Delegation. In line with the provisions applicable to Twinning Light projects under direct management, the EUD - acting as Contracting Authority, will ensure contractual oversight of the action. The Steering Committee will meet at least 2 times during the project implementation period to review progress and validate key deliverables. Ad hoc meetings can be organised if needed.
Day-to-day coordination of activities will be ensured by the AFCOS in close cooperation with the Member State Project Leader.
Additional information
Topics
Relevance for EU Macro-Region
EUSAIR - EU Strategy for the Adriatic and Ionian Region, EUSDR - EU Strategy for the Danube Region
project duration
8 months + 3 months reporting period
Additional Information
Twinning proposals must be submitted by the Member State Administration to the EU Member States National Contact Points for Twinning following the instructions of the Twinning Manual which must be strictly observed (including the use of the template).
Only one Twinning proposal for Member State can be submitted by the Member State National Contact Points for Twinning to the Contracting Authority within the deadline for applications.
The MS application should be submitted to the Contracting Authority via the email address of Member State National Contact Points for Twinning.
Deadline for submission of Twinning proposals by the MS National Contact Points to the Contracting Authority: 19 June 2026, 16:30 Central European Time (UTC+01:00).
The deadline for submission of Twinning proposals by the EU Member State Public Administrations to the corresponding National Contact Point is decided by the latter.
Any application received by the Contracting Authority after this deadline will not be considered.

