Consultation on the EU’s anti-corruption strategy
Together with our partners in the CHANCE network, Repubblika is participating in this consultation on the EU’s anti-corruption strategy.
CHANCE – the Civil Hub Against Organised Crime in Europe – has submitted an open letter to the European Commission as part of the public consultation on the future EU Anti-Corruption Strategy.
While welcoming the Commission’s initiative, the network calls for a comprehensive European framework that treats prevention, enforcement, transparency and accountability as equally important elements of the fight against corruption. The letter highlights the close links between corruption, organised crime and threats to democracy, stressing the need for stronger coordination across Member States.
Drawing on the experience of its member organisations, CHANCE puts forward several recommendations, including stronger protection for civil society organisations, investigative journalists and whistleblowers; the creation of multi-stakeholder cooperation platforms at national and EU level; a long-term strategy supported by dedicated resources and clear implementation timelines; and robust monitoring mechanisms to assess progress and ensure accountability.
The network also underlines the importance of safeguarding civic space and involving civil society as a permanent partner in anti-corruption efforts.
Through this contribution, CHANCE reaffirms its commitment to promoting transparency, integrity and democratic participation across Europe, and to supporting a more effective and ambitious EU response to corruption.
To: The European Commission
Attn: Directorate-General for Justice and Consumers
Subject: Civil Hub Against Organised Crime in Europe Submission to the Open Public Consultation on the EU Anti-Corruption Strategy
July 2026
To the Attention of the European Commission – DG JUST,
The Civil Hub Against Organised Crime in Europe welcomes the European Commission’s initiative to adopt a comprehensive EU anti-corruption strategy. As a pan-European network officially launched in 2019 at the European Parliament to promote cooperation among civil society organi-sations confronting mafias, organised crime, and corruption, our network advocates for equity, solidarity, and the protection of the common good through civic monitoring and promoting whis-tleblowing. Our network acknowledges that corruption represents the primary structural enabler for transnational organised crime, systemic financial evasion, and hostile foreign interference. In an era characterised by increasingly sophisticated, cross-border threats, the prevailing fragmenta-tion of anti-corruption frameworks across Member States has to transition towards a more synchro-nised European architecture.
In contributing to this institutional dialogue, our network shares the vision within the Commission’s consultation framework, recognizing the proposed measures as the fundamental, non-negotiable pillars of a credible European anti-corruption framework. We posit that these areas cannot be structured as hierarchical priorities, but must instead be addressed as equally relevant components of a unified public integrity architecture requiring simultaneous, maximum-priority implementation. Any attempt to rank these pillars or neglect specific segments would risk compromising the struc-tural foundation of the others, as defensive prevention mechanisms remain ineffective without cred-ible prosecutorial deterrence, which in turn depends on strong domestic and international data-sharing networks. Within the domain of preventing corruption and supporting integrity, a systemic approach must address both the public and private spheres symmetrically. This requires combining macroeconomic safeguards (such as institutionalised risk assessments and the mitigation of vulner-abilities within high-risk sectors, and institutional anti-corruption compliance programmes and plans and anti-corruption audits across all public sector – institutions and public enterprises of all kind) with extensive societal measures, including the enhancement of civic monitoring, public awareness, integrity education, and independent academic research to build a genuine culture of transparency. This preventive shield must be seamlessly mirrored within the private sector by aug-menting corporate accountability through internal compliance programmes, integrity health checks, dedicated anti-corruption audits, and guidelines designed to insulate the internal market from corrupt manipulation and criminal infiltration. Concurrently, the pillar of detection, investiga-tion, and prosecution of corruption must be treated not as a reactive alternative to prevention, but as its primary enforcement mechanism. Achieving a credible deterrent requires ensuring opera-tional independence impartiality, and capacity for specialized national anti-corruption authorities, alongside facilitating the reporting of misconduct by institutionalising the effective protection of whistleblowers. Operationally, this may require modernization of the EU’s anti-corruption approach through the introduction of advanced technological standards, interoperable data collection mod-els, and dedicated artificial intelligence systems capable of uncovering the complex infiltration of organised crime and hybrid threats into institutions and public policy design. Additionally, because corruption networks operate transnationally, these internal standards cannot be separated from the European Union’s engagement with international partners. The Strategy must maintain symmetrical rigor across its external actions, treating the strengthening of anti-corruption frameworks and rule-of-law standards in candidate and potential candidate countries as an uncompromisable benchmark of the EU accession process. Synchronising these internal enforcement mechanisms with a proac-tive, reinforced presence in multilateral fora and international bodies is the path towards a coher-ent, zero-tolerance integrity system capable of protecting both the EU’s single market and its geo-political borders.
While the Civil Hub Against Organised Crime in Europe endorses the overarching goals and thematic priorities delineated by the Commission, the ultimate efficacy of the EU Anti-Corruption Strategy will depend on by several factors such as the EU’s capacity to engage its stakeholders and encourage their sense of ownership in this process, while simultaneously the strategic vision is backed by distinct budgetary allocations, binding implementation timelines, and mandatory, trans-parent channels for civil society oversight to ensure long-term accountability. To bridge this gap between strategic alignment and operational execution, and drawing upon our networks’ ground-level experience in anti-corruption monitoring across Europe, we would like to highlight the fol-lowing key areas where the strategy needs to go further.
First, the EU Anti-Corruption Strategy should explicitly recognize civil society organizations as sus-tainable, long-term partners, sending a clear and unified message to all Member States regarding their role in public integrity. To make this partnership real, the strategic framework must protect an enabling environment by reversing the ongoing erosion of protections for those who expose wrongdoing, such as civil society organizations, journalists, activists, and whistleblowers. To achieve this, the Strategy should push for uniform measures across all Member States to guarantee transparency and open communication, ensuring that these principles are no longer sidelined under the guise of emergency, data protection or security concerns. Moreover, the Strategy must establish EU-wide measures to protect civil society and the investigating journalists from being stigmatized or targeted by the very institutions they monitor. When public authorities abuse their mandate to label civil society organisations as “hybrid threats” or coordinated smear campaigns for legitimate criticism, it undermines the core pillars of anti-corruption efforts and democracy itself. To prevent this dangerous chilling effect, the EU needs to outline clear boundaries that stop state bodies from using disproportionate institutional reactions to silence public debate on corrup-tion or insulate themselves from accountability. Instead of allowing institutions to act as self-serving interest groups, the final framework should serve as a clear directive across all Member States, ensuring that state power is never weaponized to force civil society into self-censorship.
Second, the Strategy should foster the institutionalization of sector-specific, multi-stakeholder co-operation platforms to drive both the implementation and the dynamic monitoring of anti-corruption framework both nationally and at the EU level. At the EU level, structuring regular working groups, and expanding the scope of the existing networks (such as the EU Network against Corruption) that bring together national and European public bodies, the business sector, and civil society provides space to bridge policy and impact. At national level, supporting the development of multi-stake-holder anti-corruption coalitions can strengthen solidarity between citizens and civil society organ-isations. These platforms may be an opportunity to address systemic regulatory gaps where rules across Member States remain highly fragmented, such as conflicts of interest, lobbying, political party and campaign financing. Furthermore, these regular collaborative networks can serve as an ideal resource for coordinating the monitoring of anti-corruption frameworks in each member state, as well as at the EU level. By gathering input from multiple angles, these groups can report holisti-cally on actual progress, identify ground-level implementation bottlenecks, and directly address specific national and European compliance challenges. These networks, platforms and working groups should be granted the right to request and co-organise EU-level hearings on significant national anti-corruption developments that are relevant to the Union, including national initiatives that may restrict civil society space or weaken anti-corruption standards. They should also be en-couraged and supported to submit specific opinions, concerns and recommendations to Member States, EU institutions and the Commission. The recipients of such submissions should be required to provide a reasoned response.
Third, the future EU Anti-Corruption Strategy must move beyond fragmented approaches by em-bracing a long-term vision that ensures institutional predictability and continuity. To guarantee sus-tainability, it is essential for this strategic framework to target an extended temporal horizon that aligns with or even exceeds a single multiannual financial framework, backed by distinct budgetary allocations and clear timelines. Within this overarching strategic framework, annual or biannual anti-corruption action plans could be deployed to detail specific priorities, adapt to emerging trends, and operationalize immediate objectives. Furthermore, to maximize public impact and policy effectiveness, the strategy must build a synchronized integrity architecture. This requires setting ambitious, symmetrical objectives addressed to both the European Union institutions, which must lead by example in transparency and accountability, and the Member States, thereby ensuring total convergence between EU-level policy design and national and regional reforms.
Finally, to effectively bridge the gap between strategic alignment and actual implementation, the strategy must establish monitoring and evaluation mechanisms to track progress. In this regard, clear targets and data sources must be defined, leveraging established instruments such as the annual Rule of Law Report, Eurobarometer data, statistics from CJEU and national courts, as well as the European Public Prosecutor’s Office (EPPO) reports. Building on these tools, standardized performance indicators must be established, requiring both Member States and EU institutions to report on a regular basis. This framework must generate the comparative data necessary to assess core criteria such as administrative compliance, institutional performance, and the tangible impact of anti-corruption measures. Additionally, the framework should introduce joint peer-review dele-gations among Member States to constructively „audit” the implementation performance of the EU strategy at the national level. Before transitioning into a binding mechanism, this exercise should initially serve as a valuable opportunity to exchange practical experiences and best practices, fos-tering mutual learning and reinforcing a shared European culture of integrity. To maintain account-ability throughout this cycle, the definitive results of monitoring and evaluation activities must be made fully public and accessible; while certain sensitive internal investigative or administrative processes may require confidential handling, all key stakeholders must be kept systematically up-dated on strategic outcomes and progress.
We remain at your disposal for further consultations and are available to provide additional data from our network’s actions against corruption at both European and national levels. We trust that these recommendations will support the Commission in ensuring a more effective framework across the Union.
Sincerely,
On behalf of CHANCE – Civil Hub Against orgaNised Crime in Europe
Radu Nicolae, Asociația pentru Cooperare și Dezvoltare Durabilă (Romania)
Libera. Associazioni, Nomi e Numeri contro le mafie (Italy)
Repubblika (Malta)
BASTA! (Belgium)
Mafianeindanke (Germany)
HOLA (Spain)
Eine Welt (Germany)
ENGIM (Albania)
Entretodos (Portugal)
DeMains Libres (France)
Open Space Foundation (Bulgaria)
Bregal (Spain)