Bogdan-Ionut Dintoi Your ref. 24.10.2025 No 3368/2025
DLAF (Fight against Fraud Department Our ref. 14.11.2025 No 11-4.1/4769-2
[email protected]
Reporting of suspected fraud in the
IMS system
Dear AFCOS Romania colleagues,
Thank you for your letter and for your initiative to enhance cooperation and share best
practices among AFCOS services. We appreciate the opportunity to contribute to the joint
effort of safeguarding the financial interests of the European Union.
Please note that the following responses reflect the practices applied in both
the agriculture (AGRI) and Cohesion Policy (CP) sectors in our country:
1. Definition of PACA in National Legislation
While our national legislation does not explicitly define PACA, its application is guided by
Government Regulation No. 55 of 12 May 2022. This regulation requires the implementing
body to notify the managing authority within 10 working days of circumstances that may lead
to a financial correction or indicate suspected fraud. The managing authority then reports these
cases to OLAF via the IMS system.
We follow the definition provided in OLAF’s handbook “Reporting of irregularities in shared
management” and the national guidance document “Guidance on reporting
irregularities”. PACA refers to a first written assessment by a competent authority—
administrative or judicial—based on specific facts, concluding that an irregularity has
occurred. This may later be revised depending on the outcome of further procedures.
In IMS, PACA corresponds to field 7.1 “Date of discovery,” typically the date of an
administrative decision (e.g., to reject or recover funds). Cases are reported within two months
after the end of the quarter in which the decision was made.
2. Timing of Reporting Suspicion of Fraud (IRQ3) in IMS
Suspicions of fraud are reported in line with OLAF’s handbook, which requires Member
States to submit the first report no later than two months after the end of the quarter in which
the PACA was made.
A case is classified as IRQ3 (or IRQ4 under the updated terminology) when it has
been determined through administrative procedures that the irregularity was committed
Suur-Ameerika 1 / 10122 Tallinn / Estonia / +372 611 3558 /
[email protected]
www.rahandusministeerium.ee / Reg. code: 70000272
intentionally. If the case involves other Member States, it is reported to the
Commission immediately, with relevant details.
3. Documents or Actions Triggering IRQ3 Registration
IRQ3 classification may be triggered by various circumstances, such as the initiation of
criminal proceedings, reports to law enforcement, falsified documents, tip-offs, complaints,
or findings from on-the-spot checks.
Registration in IMS follows an administrative decision confirming intentional misconduct,
typically supported by documentation gathered during the procedure. In many cases, this also
results in the exclusion of the beneficiary from future Union funding.
We remain at your disposal for any further clarifications and look forward to continued
cooperation.
Yours sincerely,
(signed digitally)
Anu Alber
Head of Financial Control Department
(acting as AFCOS Estonia and as the Auditing Authority for Cohesion Policy etc.)
Ministry of Finance
Copy to:
DLAF Camelia Iorgoiu
DLAF Mircea Papuc
Virve Teppart +372 5885 1494
[email protected]
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