Operational Strengthening of Montenegro’s AFCOS System for the protection of the EU Financial Interests

Twinning Light grant (EuropeAid, ME 25 IPA FI 01 26 TWL) under IPA III to strengthen Montenegro's Anti-Fraud Coordination Service (AFCOS) for protection of EU financial interests with a total budget of €250,000. Only public administrations and mandated bodies from EU Member States may apply through their National Contact Points, with one Twinning proposal allowed per Member State. The action covers an eight month implementation period plus three months reporting and will deliver practical tools, strengthened reporting procedures, targeted trainings, a study visit and awareness activities, including enhanced cooperation with OLAF and EPPO. Proposals must be submitted by Member State National Contact Points by 19 June 2026, 16:30 CET to DELEGATION-MONTENEGRO-PROCEDURES@eeas.europa.eu and enest-twinning@ec.europa.eu.

What it funds

Overview

Twinning Light action to strengthen Montenegro's Anti-Fraud Coordination Service (AFCOS) operational and preventive capacity: development of practical irregularity and fraud management tools and procedures, enhanced coordination with OLAF and EPPO, IMS reporting improvements, targeted trainings, one study visit and a national awareness event.

Budget and duration:Maximum EU contribution €250,000. Maximum implementation period 8 months plus 3 months reporting.

1. 1Who can apply: Only public administrations and mandated bodies from EU Member States, submitting through their National Contact Points for Twinning.
2. 2Submission route and deadline: Member State National Contact Points must send proposals to delegation-montenegro-twinning@eeas.europa.eu and enest-twinning@ec.europa.eu by 19 June 2026, 16:30 CET.
3. 3Expected start and decision timing: Published 23 April 2026; provisional award notification September 2026; evaluation committee meetings envisaged from 22 June 2026.

Basic facts and administrative information

Publication reference:EUROPEAID/186515/DD/ACT/ME. Programme: IPA III Action Programme for 2025-2027 Montenegro – Direct management (IPA 2025). Twinning Reference: ME 25 IPA FI 01 26 TWL. Instrument type: Twinning Light call for proposals under Action Grants. Beneficiary country: Montenegro. Maximum EU budget available for the action: €250,000. Project maximum duration: 8 months implementation period plus 3 months reporting. Publication date: 23 April 2026. Deadline for submission: 19 June 2026, 16:30 Central European Time (Brussels time). Provisional notification of results: September 2026. Contracting authority / implementing agency: Delegation of the European Union to Montenegro, Cooperations Section (delegation-montenegro-coops@eeas.europa.eu). Proposals to be sent via Member State National Contact Points for Twinning to: DELEGATION MONTENEGRO TWINNING DELEGATION-MONTENEGRO-PROCEDURES@eeas.europa.eu and Twinning coordination team enest-twinning@ec.europa.eu.

Purpose, objectives and scope

Overall objective:Reinforcing operational and preventive anti-fraud mechanisms within Montenegro’s AFCOS system to ensure effective protection of the EU financial interests. Specific objective: Strengthen operational and preventive anti-fraud capacity of the AFCOS system through development of practical irregularity and fraud management tools, enhancement of institutional coordination and cooperation with OLAF, reinforcement of reporting and procedural frameworks (including structured use of the Irregularity Management System IMS and obligations under the Reform and Growth Facility), and increase awareness and capacities of stakeholders involved in protecting EU financial interests.

Key components, results and planned activities

The action is structured around two components delivering concrete outputs and capacity building for AFCOS and the AFCOS Network.

1. 1Component I: Strengthening operational and strategic framework for effective protection of EU financial interests. Results and sub-results include: 1.1 National Anti-Fraud Strategy Action Plan 2027–2028 prepared; 1.2 Fraud Prevention and Detection Checklist for EU-funded projects and Practical Guidance Manual developed and tested; 1.3 Methodology for handling irregularities and suspected fraud cases and reporting via IMS developed in the context of the Reform and Growth Facility; 1.4 One national awareness-raising public event organised.
2. 2Component II: Capacity building of AFCOS system stakeholders through practical anti-fraud training. Results and sub-results include: 2.1 Practical training on detection, classification and reporting of irregularities and fraud for AFCOS staff and IPA structure; 2.2 Targeted training for central and local public officials managing EU-funded projects; 2.3 Specialised training on fraud risk assessment and prevention mechanisms; 2.4 Specialised training for judges and prosecutors on protection of EU financial interests and cooperation with EPPO; plus a study visit for 6–7 officials to an EU Member State.

Eligibility and who may apply

Only Public Administrations and Mandated bodies from European Union Member States may apply. Applications must be submitted through the EU Member State National Contact Points for Twinning following the Twinning Manual and using the prescribed Twinning Light template. Only one Twinning proposal per Member State may be submitted to the Contracting Authority for this call. Proposals must be transmitted by the Member State National Contact Points by the deadline to the Contracting Authority email addresses indicated in the invitation letter.

Eligible Applicant Types:Only public administrations and mandated public bodies of EU Member States (national administrations acting via their National Contact Points for Twinning). This excludes private entities, NGOs, universities acting alone, or non-public bodies; partners must be Member State administrations as per the Twinning Manual.

Funding Type:EU action grant under the Twinning Light modality (Action Grants) financed from IPA III pre-accession funds; the financial instrument is a grant covering the Twinning Light project budget up to €250,000.

Consortium Requirement:A single Member State public administration submits the Twinning Light proposal via its National Contact Point. The Member State can propose a Member State Project Leader and short-term experts; the action does not require a multi-country consortium but expects an implementing Member State administration to lead and provide experts.

Beneficiary Scope (Geographic Eligibility):Implementing applicants: EU Member States (public administrations). Beneficiaries: Montenegro (the Twinning Light action is targeted at Montenegrin institutions: Ministry of Finance – Department for Protection of EU's Financial Interests/AFCOS, IPA management bodies, AFCOS Network members).

Target Sector:Finance / public administration / rule of law: anti-fraud, irregularity management, public financial management, judicial cooperation (EPPO), and administration capacity building. Thematic sectors include public financial control, financial integrity, anti-fraud and governance.

Mentioned Countries:Montenegro is the beneficiary country explicitly mentioned. EU Member States are the eligible applicants (no specific Member States mandated – any EU Member State public administration may apply through its National Contact Point).

Project Stage:Maturity expected: implementation and operationalisation of recently adopted strategic and legislative reforms. The project targets development and rollout of operational tools, training and practical implementation (research and design completed at policy level; project aims at development, validation, demonstration/operationalisation and capacity building).

Funding Amount:Total maximum EU contribution for the Twinning Light project: €250,000.

Application Type:Open call to EU Member State public administrations via the Twinning National Contact Points. Proposals must be submitted by Member State National Contact Points by email to the Contracting Authority; use of the Twinning Light template and Twinning Manual mandatory.

Nature of Support:Monetary grant funding to finance the Twinning Light action and provision of expert inputs from the Member State administration (in-kind expert time delivered by Member State experts). Beneficiaries will receive grant money (project budget) and non-monetary technical assistance delivered by Member State experts (project leader, component leaders, short-term experts).

Application Stages:Single-stage submission of Twinning Light proposal by Member State National Contact Point to the Contracting Authority. Evaluation includes administrative/eligibility checks and qualitative evaluation based on selection and award criteria; provisional timetable foresees evaluation committee meetings starting 22 June 2026 and notification in September 2026. Operational selection includes assessment of selection criteria (Yes/No) and scoring of award criteria (scored 1 to 5).

Success Rates:Not published. As a single-award Twinning Light action with a fixed budget of €250,000, the chance of success depends on the number and quality of Member State proposals received. No explicit success rate is provided in the fiche.

Co-funding Requirement:No specific co-funding requirement for the beneficiary is indicated in the Twinning Light fiche. The action is financed up to the maximum EU contribution of €250,000. Member State applicants must provide experts (in-kind) and are responsible for backstopping and financial reporting; administrative and in-kind contributions from Member State administration and the beneficiary (e.g., facilities, staff time) are envisaged but not quantified as a cash co-financing obligation.

Eligibility, selection and award criteria details

Eligibility:Only EU Member State public administrations and mandated bodies may apply through their National Contact Points for Twinning. The Twinning Manual and specific Twinning Light templates must be strictly observed and used. Selection criteria: operational capacity of the Member State Project Leader and proposed short-term experts; selection criteria assessed on a Yes/No basis where a single negative disqualifies the proposal. Award criteria: scored qualitatively 1 to 5 and include proposed methodology, experience of the Project Leader, institutional setting and capacity, relevance and quality of the Member State presentation and proposed experts. See Annexes C6bis and C8 of the Twinning Manual for administrative compliance and selection fact sheet procedures.

Profiles and human resources required

The action requires a Member State Project Leader (one expert may act as PL) and Component Leaders plus short-term experts. Profiles and responsibilities are specified:

1. 1Project Leader profile and tasks: university level education or equivalent professional experience of 8 years in public administration; minimum 3 years of institution building experience in anti-fraud areas; computer literacy; English working level; proven strategic project management and capacity to lead multidisciplinary teams. Tasks: overall coordination, cooperation with beneficiary PL, backstopping and financial management, quality assurance of project delivery.
2. 2Component Leaders profile and tasks: university degree or equivalent and at least 8 years public administration experience; minimum 3 years relevant experience in protection of EU financial interests, irregularity management, anti-fraud policies or training; tasks include planning and implementing component activities, supervising short-term experts, ensuring quality of deliverables and facilitating beneficiary cooperation.
3. 3Short-term experts profile and tasks: university level education or equivalent, at least 3 years experience implementing EU anti-fraud legislation and irregularity management, computer literacy, English working level, experience in training delivery; tasks include designing and delivering specialised trainings, drafting methodologies and tools, cooperating with beneficiary institutions, and contributing to public awareness materials.

Deliverables, indicators and targets

Deliverables and targets are clearly defined with timelines (most deliverables targeted by IQ–IIQ 2027). Key tangible deliverables include: Action Plan for National Anti-Fraud Strategy 2027–2028; Fraud Prevention and Detection Checklist and Practical Guidance Manual; Methodology for handling irregularities and reporting via IMS in the context of the Reform and Growth Facility; validated training materials and training sessions delivered; study visit delivered; one national awareness-raising event; e-brochure and e-flyer for sustained visibility and awareness.

Implementation arrangements, institutional framework and sustainability

Contracting Authority:EU Delegation to Montenegro performing tendering, contracting and accounting. Beneficiary institutions: Ministry of Finance – Department for Protection of EU's Financial Interests/AFCOS (main beneficiary and counterpart), IPA management bodies, AFCOS Network members (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, among others). A Project Steering Committee will be established composed of AFCOS representatives, selected AFCOS Network members and the EU Delegation; it will meet at least twice during implementation. Day-to-day coordination by AFCOS in close cooperation with Member State Project Leader. Facilities: the beneficiary will provide office space and meeting rooms; rental of venues allowed only where justified.

Sustainability measures:formal institutionalisation of developed tools and procedures within AFCOS system and their integration into regulatory frameworks; formal adoption of Action Plan by competent national authorities; targeted capacity building to mitigate staff turnover risk; electronic visibility materials for continued dissemination.

Application and submission guidance

Member State public administrations must prepare a Twinning Light proposal following the Twinning Manual, using the mandatory Twinning Light template. Only one proposal per Member State may be submitted to the Contracting Authority. Proposals must be sent by the Member State National Contact Point for Twinning to the Contracting Authority email addresses before the stated deadline. The subject line of submission messages should indicate: Member State name - proposal for ME 25 IPA FI 01 26 TWL. Late applications will not be considered.

1. 1Documents referenced and mandatory to consult: Twinning Manual (including Annex C6bis, Annex C8), Twinning Light fiche and annexes, Practical Guide to Contract Procedures for EU external actions (PRAG).
2. 2Submission emails: DELEGATION-MONTENEGRO-PROCEDURES@eeas.europa.eu and enest-twinning@ec.europa.eu.
3. 3Registration/administration instruction: indicate Member State name in subject line as specified in invitation letter.

Templates and application form structure

The Twinning Manual prescribes mandatory templates and structure for Twinning Light proposals. Required elements typically include administrative forms, a technical description (methodology, work plan, detailed description of activities and deliverables), staffing and expert profiles (Project Leader, component leaders, short-term experts), timetable, cost estimate and justification, and declaration of eligibility by the Member State National Contact Point. Proposals must comply with the Twinning Light Administrative Compliance and Eligibility grid (Annex C6bis) and the Selection Fact Sheet (Annex C8).

1. 1Proposal cover and administrative identification (Member State, contact details, Twinning reference).
2. 2Executive summary and relevance to NAFS 2025–2028 and IPA III priorities.
3. 3Technical proposal: methodology, detailed activities per component, milestones and deliverables, quality assurance measures, and sustainability measures.
4. 4Staffing plan: CVs of proposed Project Leader, Component Leaders and short-term experts, demonstrating compliance with profile requirements.
5. 5Logistics: study visit plan, workshops, events and facilities arrangements.
6. 6Budget: cost breakdown in line with PRAG and Twinning Light rules; justification for any rental of premises if necessary.
7. 7Annexes: supporting legal declarations, letters of commitment from proposed experts or Member State administration as required by the Twinning Manual.

Risks, assumptions and monitoring

Identified risks include loss of critical competencies or key people, lower-than-expected participant numbers for trainings, delays in institutional cooperation, or resource constraints. Assumptions required for success include availability and willingness of beneficiary institutions to cooperate, timely provision of data and access to staff, and timely adoption of project outputs by competent national authorities. Monitoring will be performed against clearly defined indicators linked to each component; targets include numbers trained, tools developed, and validation workshops executed.

Contact and submission details

Submission email addresses for Member State National Contact Points for Twinning:DELEGATION-MONTENEGRO-PROCEDURES@eeas.europa.eu and enest-twinning@ec.europa.eu. For general contracting authority queries: delegation-montenegro-coops@eeas.europa.eu. Submission deadline to Contracting Authority: 19 June 2026, 16:30 CET. For registration and administration, include in the subject: Member State name - proposal for ME 25 IPA FI 01 26 TWL.

Relevant legal and policy framework

The action aligns with a broad set of EU acquis and policies relevant to protection of the EU financial interests including, inter alia, Regulation (EU, Euratom) No 883/2013 (OLAF investigations), Directive (EU) 2017/1371 (PIF Directive), EPPO-related instruments, financial rules for the general budget of the Union, the IPA III Regulation and implementing rules, PRAG and other guidance documents. The project is consistent with Montenegro’s SAA obligations, Chapter 32 – Financial Control (provisionally closed January 2026), public finance management reform programmes and the National Anti-Fraud Strategy 2025–2028.

Detailed project fiche and annexes including the Twinning Light fiche and Annex C9 are available from the Contracting Authority and through Member State National Contact Points for Twinning. The Twinning Light fiche contains the full logical framework, detailed activity descriptions, deliverables, indicators and annexed legislative references. Twinning fiche and annexes Invitation letter Publication notice (Annex C9bis) ¹

Concise summary: what this opportunity is about

This Twinning Light call finances a short, targeted institutional capacity-building action (maximum €250,000; 8 months implementation) to strengthen Montenegro’s AFCOS system for protection of EU financial interests. It seeks an EU Member State public administration to lead the action and provide a Project Leader, component leaders and short-term experts. The project will develop practical operational tools (Action Plan 2027–2028, Fraud Prevention and Detection Checklist, Practical Guidance Manual, IMS reporting methodology), deliver practical trainings and a study visit, and organise awareness-raising activities. The aim is to operationalise recent reforms, improve irregularity and fraud detection and reporting (including in the context of the Reform and Growth Facility), enhance cooperation with OLAF and EPPO, and institutionalise sustainable procedures and communication materials for long-term impact. Member State administrations must apply via their Twinning National Contact Points using the mandatory templates by 19 June 2026, 16:30 CET, and proposals are evaluated against strict eligibility, selection and award criteria as set out in the Twinning Manual.

Footnotes

1. 1The Twinning Manual and its annexes set out required templates, administrative compliance grids and selection fact sheets referenced in this call. Applicants must use the Twinning Light template and follow the Twinning Manual procedures available via Member State National Contact Points for Twinning and the European Commission Twinning coordination team.

Funding Opportunity Overview

This is a Twinning Light grant opportunity funded by the European Commission under the Instrument for Pre-Accession Assistance (IPA III) Action Programme for 2025-2027. The project aims to strengthen the operational and preventive anti-fraud capacity of Montenegro's Anti-Fraud Coordination Service (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 awareness and capacity of stakeholders involved in protecting EU financial interests.

Reference Number:EuropeAid (ME 25 IPA FI 01 26 TWL)

Total Budget:€250,000

Application Deadline:19 June 2026, 16:30 Central European Time (UTC+01:00)

Project Duration:8 months implementation period plus 3 months reporting period

Status:Open for submission

Who Can Apply

Only Public Administrations and Mandated bodies from European Union Member States may apply through their respective National Contact Points for Twinning. Applications must be submitted by the Member State National Contact Points to the Contracting Authority (EU Delegation to Montenegro). Only one Twinning proposal per Member State can be submitted within the deadline.

Project Objectives and Components

Overall Objective

Reinforcing operational and preventive anti-fraud mechanisms within Montenegro's AFCOS system to enhance the AFCOS system's operational adjustment for effective protection of EU financial interests in line with evolving competences and responsibilities.

Specific Objective

Strengthened operational and preventive anti-fraud capacity of the AFCOS system through 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 protection of EU financial interests.

Component I: Strengthening Operational and Strategic Framework

This component focuses on developing practical tools and strategic documents for effective protection of EU financial interests. Key deliverables include:

• National Anti-Fraud Strategy Action Plan for 2027-2028 developed in line with Government guidelines and OLAF recommendations
• Fraud Prevention and Detection Checklist for EU-funded projects with practical guidance manual incorporating red flag indicators and structured control points
• Methodology for handling irregularity and suspected fraud cases with specific provisions on reporting obligations to the European Commission and OLAF in the context of the Reform and Growth Facility Agreement
• One national awareness-raising public event with participation of AFCOS system institutions, civil society organisations and media (minimum 30 participants)

Component II: Capacity Building of AFCOS System Stakeholders

This component aims to increase operational capacity of AFCOS system stakeholders through practical anti-fraud training. Key activities include:

• Practical training for AFCOS and IPA structure staff on detection, classification and reporting of irregularities and fraud based on real case scenarios and simulation exercises, including financial forensics elements (minimum 25 officials trained)
• Study visit for 6-7 officials to an EU Member State to acquire hands-on experience of on-the-spot controls and anti-fraud measures
• Targeted training for public officials at central and local self-government level on EU anti-fraud requirements and tools in management of EU-funded projects (minimum 20 officials trained)
• Specialised training on fraud risk assessment and prevention methodologies with focus on red flags and conflict of interest situations (minimum 20 officials trained)
• Specialised training for judges and prosecutors on legal framework for protection of EU financial interests and cooperation with the European Public Prosecutor's Office (EPPO) (minimum 10 participants trained)

Beneficiary Administration

The main beneficiary 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 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, and other relevant ministries.

Main Contact Person:Ms. Nataša Kovačević, Head of Department for Protection of EU's Financial Interests/AFCOS, Ministry of Finance, Stanka Dragojevića 2, 81000 Podgorica, Montenegro

Expert Requirements

Project Leader

The Project Leader from the EU Member State must have university-level education or equivalent professional experience of 8 years in public administration, with proven experience in strategic project management and coordination of EU-funded or institution-building projects. Specific requirements include demonstrated capacity to lead multidisciplinary expert teams, minimum 3 years experience in institution building in combating irregularities and fraud, experience in cooperation with OLAF, working-level English language proficiency, and knowledge of legislation related to protection of EU financial interests. The Project Leader is responsible for overall management and coordination of the project, cooperation with the Beneficiary Country Project Leader, and ensuring sound implementation of activities.

Component Leaders

Component Leaders must hold a university degree or equivalent professional experience of at least 8 years in public administration, law, economics, finance or related fields. They must have minimum 3 years of relevant experience in at least one of the following areas: protection of EU financial interests, irregularity and fraud management, development of anti-fraud policies or operational tools, or implementation of training programmes related to anti-fraud or risk management. Working-level English language proficiency and strong analytical, organisational and communication skills are required. Practical experience in cooperation with EU institutions (OLAF and/or EPPO) and experience in development of operational guidelines or manuals are considered assets.

Short-term Experts

Short-term experts must have university-level education or equivalent professional experience of 8 years in public administration, with at least 3 years of experience implementing EU legislation on combating irregularities and fraud for protection of EU financial interests. Required knowledge includes legislation related to protection of EU financial interests (including PIF Directive EU 2017/1371), irregularity and fraud management, cooperation with OLAF and/or EPPO, and monitoring and evaluation of public policies related to protection of EU financial interests. Working-level English language proficiency, computer literacy, presentation and communication skills are essential. Experience in development and delivery of trainings is an asset.

Implementation Arrangements

Implementing Agency:Delegation of the European Union to Montenegro, Cooperations Section, delegation-montenegro-coops@eeas.europa.eu, Vuka Karadžica 12, 81000 Podgorica, Tel.: +382 (0) 20 444 600

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 AFCOS, selected members of the AFCOS Network and the EU Delegation. The Steering Committee will meet at least 2 times during the project implementation period to review progress and validate key deliverables. Day-to-day coordination of activities will be ensured by AFCOS in close cooperation with the Member State Project Leader.

The Beneficiary will provide necessary working premises for project implementation, including appropriate office space, meeting rooms and logistical support within the premises of the Ministry of Finance. Where justified by the nature of specific activities such as larger training sessions, workshops, conferences or public events, the project budget may foresee rental of appropriate premises in line with Twinning Manual provisions and principles of sound financial management.

Selection and Award Criteria

Selection criteria consider the operational capacity of the Member State Project Leader and short-term experts mentioned in the proposal, assessed on a Yes/No basis. A single negative evaluation of one criterion disqualifies the proposal. Award criteria consider the merit of main qualifying aspects of the proposal and are evaluated using a scoring system (1 to 5). Selection and award of the Member State will be based on evaluation of qualitative aspects including the proposed methodology, experience of the proposed Project Leader, institutional setting and capacity of the administration, and Member State presentation. Evaluation will follow Annex C6bis of the Twinning Manual (Administrative Compliance and Eligibility Grid) and Annex C8 (Twinning Light Selection Fact Sheet).

Provisional Notification Date:September 2026

Application Submission

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, including strict use of the template. Proposals should be sent to DELEGATION MONTENEGRO TWINNING at DELEGATION-MONTENEGRO-PROCEDURES@eeas.europa.eu and to the Twinning coordination team at enest-twinning@ec.europa.eu before the deadline of 19 June 2026, 16:30 (Brussels time). For registration and administration purposes, applicants are requested to indicate in the subject line: Member State name - proposal for ME 25 IPA FI 01 26 TWL.

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 the deadline will not be considered. The tentative date for starting evaluation committee meetings is 22 June 2026.

Strategic Context and Alignment

This project is aligned with Montenegro's EU accession process and specifically supports Chapter 32 – Financial Control, which was provisionally closed in January 2026. 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. The project contributes to implementation of the National Anti-Fraud Strategy for Protection of EU Financial Interests (NAFS) 2025-2028 and its Action Plan 2025-2026, adopted by the Government of Montenegro. It also supports the Public Finance Management Reform Programme 2022-2026 and is consistent with the Framework Financial and Partnership Agreement and Reform and Growth Facility Agreement signed between Montenegro and the European Commission ¹.

The project builds on results of previous Twinning Light projects supporting AFCOS, including Capacities Development for AFCOS (2018-2019, €200,000), Improving Capacities of AFCOS System Bodies in Irregularities Management (2023, €100,000), and Further Enhancing the Functioning of Montenegrin AFCOS System (2024-2025, €250,000). The current project will focus on plugging remaining gaps in the system and further developing the AFCOS structure.

Performance Indicators and Targets

The project includes clearly defined indicators linked to each component and result. For Component I, targets include preparation of the National Anti-Fraud Strategy Action Plan 2027-2028, development of Fraud Prevention and Detection Checklist and Practical Guidance Manual, development of methodology for handling irregularities and suspected fraud cases, and organisation of at least one validation workshop with minimum 20 officials from AFCOS, IPA structure and AFCOS Network. For Component II, targets include minimum one training session for AFCOS and IPA structure representatives with at least 25 officials trained, training of at least 20 officials from central and local self-government institutions, training of at least 20 officials on fraud risk assessment, organisation of one study visit for 6-7 officials to an EU Member State, and minimum one specialised training for judges and prosecutors with at least 10 participants. At least 70 percent of participants must demonstrate improved knowledge and practical skills through post-training evaluation and case-based exercises ².

Sustainability and Crosscutting Issues

Sustainability of project results will be ensured through formal institutionalisation of developed tools and procedures within the AFCOS system and their integration into existing regulatory and operational frameworks. The National Anti-Fraud Strategy Action Plan for 2027-2028 will be formally adopted by competent national authorities, ensuring political ownership and continuity beyond project duration. Capacity-building activities target both AFCOS staff and representatives of IPA structure and AFCOS Network institutions, mitigating risks related to staff turnover and ensuring institutional memory. Awareness-raising activities will foster a culture of transparency, prevention and zero tolerance for fraud. The project will develop targeted communication and visibility materials in digital format, including an e-brochure and e-flyer, designed for broad and continuous use beyond project duration.

The project integrates principles of equal opportunities, non-discrimination and balanced participation of women and men in all activities. It contributes to strengthening good governance, transparency and rule of law by reinforcing mechanisms for prevention, detection and reporting of irregularities and fraud in management of EU funds. Environmental considerations will be respected, with printed materials limited to what is strictly necessary and electronic dissemination prioritised. Events will be organised to minimise environmental impact. The project contributes to Sustainable Development Goal 16 – Peace, Justice and Strong Institutions.

Key Documents and References

Detailed information on this call for proposals is contained in the Twinning Manual and in the specific project Twinning Fiche, available at the European Union Member States National Contact Points for Twinning. Key reference documents include the Invitation Letter (23 April 2026), Annex C9 (23 April 2026), and Twinning Fiche (23 April 2026). The project is based on applicable Union acquis including Regulation (EU, Euratom) No 883/2013 concerning OLAF investigations, Directive (EU) 2017/1371 on fighting fraud to EU financial interests by criminal law, Regulation (EU) 2021/1529 establishing IPA III, and the Facility Agreement between the European Union and Montenegro on Reform and Growth Facility arrangements.

Footnotes

1. 1The project is directly linked to Montenegro's obligations under the Stabilisation and Association Agreement (SAA), which entered into force on 1 May 2010 and establishes Montenegro's obligation to align its legal and institutional framework with EU standards, including in the area of protection of EU financial interests. The project also supports implementation of obligations arising from the Reform and Growth Facility Agreement, particularly Articles 9, 10 and 11 regarding reporting obligations, structured cooperation with OLAF and EPPO, protection of whistleblowers, prevention and management of conflicts of interest, and systematic follow-up of primary administrative or judicial findings.
2. 2Additional performance indicators include improved cooperation between AFCOS, IPA structure institutions and other bodies involved in protection of EU financial interests, improved knowledge and exchange of EU Member States' good practices regarding anti-fraud measures, and knowledge improvement of participants regarding protection of EU financial interests, cooperation with OLAF and EPPO and reporting of irregularities, with at least 20 percent increase in correct responses in post-training evaluation questionnaires compared to pre-training assessment.