Corruption prevention (ES0124)

3.5.1. Approval of the National Anti-Fraud Strategy (ENA)

Brief description

The ENA is a tool for developing the national anti-fraud system, primarily in the area of protecting the EU's financial interests, and involves multiple actors in the fight against fraud. This strategy defines the strategic goals, the operational objectives into which they are broken down, and the measures that prioritise activities for the strategy's implementation period, which will b e carried out through annual National Action Plans (NAP).

Objectives

• Improvement of the existing anti-fraud framework through the establishment of an anti-fraud strategy and action plan based on risk assessment.
• Improve the monitoring and evaluation framework for institutions involved in the fight against fraud.
• Improve commitment, awareness and capacity building in the fight against fraud.

3.5.2. Organic Law on Public Integrity (APLO)

Brief description

The draft bill incorporates measures derived from the Anti-Corruption Plan. It contains various measures such as the creation of the Independent Public Integrity Agency, conceived as an independent administrative authority with its own legal personality and functional autonomy, called upon to play a central role in risk assessment and supervision of areas most susceptible to corrupt behaviour, the development of integrity risk maps, the roll-out of compulsory training programmes on ethics a n d good governance for public employees, and the regular conduct of campaigns and surveys to measure public perception of corruption a n d thus gauge the effectiveness of public policies. At the same time, the Act strengthens the regulatory framework for procurement and amends criminal law to increase penalties for corruption offences and extend the statute of limitations.

Objectives

• Ensure the full implementation of the State Plan against Corruption.
• Strengthen the prevention of corruption in all administrations.
• To improve public perception of the integrity of the public sector."

3.5.3. Creation of an Independent Public Integrity Agency as the central body for the prevention, supervision and prosecution of corruption

Brief description

The creation of the Agency would first involve mapping agencies and functions to streamline the anti-corruption ecosystem, followed by the analysis and definition of coordination strategies at both the national and regional levels. The Agency will have the power to initiate investigations, oversee compliance with key regulations (procurement, lobbying, conflicts of interest, accountability) and protect whistleblowers. Its implementation requires far-reaching legislative reform to amend Law 3/2015 on Senior Officials, Law 9/2013 on Transparency, Law 9/2017 on Contracts, Law 2/2023 on the protection of whistleblowers a n d the future Draft Law on transparency a n d integrity in activities of interest. It will be an independent administrative authority, as regulated by the Law on the Legal Regime of the Public Sector, so that it has the greatest autonomy, which reinforces public confidence. Its independence is key to issuing recommendations, coordinating plans and analysing risks rigorously.

Objectives
• Strengthen the independence and effectiveness of public integrity oversight.
• Ensure consistency and unity in corruption prevention policies.
• Build greater public confidence in institutions."

3.5.4. Comprehensive system for the protection of whistleblowers

Brief description

Development and implementation of a Comprehensive National System for the Protection of Whistleblowers, coordinated by the AIPI, to consolidate a robust, multi-channel model for protecting individuals who report acts of corruption and other serious offences. This system must include mechanisms for the secure receipt of complaints, legal and psychological support, effective protection measures against retaliation, and guarantees of anonymity. The system will be integrated into the institutional architecture of public integrity and will be aligned with OECD principles and the obligations arising from Directive (EU) 2019/1937. At the request of the Hay Derecho Foundation at the plenary meeting of the Forum on 6 October 2025 approving the Plan, the allocation of material and human resources for the AIPI is specified. It is considered appropriate to start with a budget of €7.5 million and 64 staff, almost half of whom would be dedicated to investigating the information. For 2025, a budget of €5,223,090 and 41 staff members, 8 of whom would be assigned to investigating the information.

Objectives

• Promote public confidence in institutional mechanisms for public integrity through effective guarantees of confidentiality and protection.
• Establish secure reporting channels accessible from multiple platforms, including digital, physical, and telephone format
• Widely disseminate the right to report, the associated guarantees and the existing resources for support, especially in the civil service."

3.5.5. Transforming the Public Sector Procurement Platform with Big Data and Artificial Intelligence to prevent corruption

Brief description

The Public Sector Procurement Platform will be transformed into a new-generation tool. Its dual objective will be to strengthen transparency and prevent corruption through Artificial Intelligence, RPA and advanced data analytics. This initiative will enable large-scale audits of open data to detect irregular patterns and move towards a structural and automated supervision model. Citizen audit mechanisms will also be incorporated so that individuals and social organisations can monitor the most sensitive procurement processes. Their implementation will require regulatory reforms to the Public Sector Contracts Act, the Transparency Act and the Common Administrative Procedure Act.

Objectives

• Enable large-scale audits through statistical analysis of open data.
• Facilitate the detection of irregular patterns indicative of possible fraud.
• Incorporate mechanisms that will allow individuals and social organisations to access, analyse and monitor procurement processes with a high risk of corruption.
• Build public confidence in the use of public funds."

3.5.6. Strategic coordination for the systematic development and implementation of Integrity Pacts and Green Integrity Pacts in Spain: towards a State Network of Integrity Pacts

Brief description

This commitment implements the measures included in Component 3.1 of the State Plan to Combat Corruption. Its objective is to lay the groundwork for the proper regulatory, technical, financial, institutional, and progressive development of a national model for Integrity Pacts within the framework of the Fifth Open Government Plan, in its two forms—general and green— as an instrument for preventing the risks of fraud, corruption and other irregularities in public procurement, and strengthening integrity and transparency through the intervention of an independent and neutral third-party monitor. The implementation of the commitment is envisaged through pilot experiences, the definition of action protocols, a technical application guide, the establishment of a public register of agreements signed, monitoring mechanisms and specific working groups and, finally, the creation of a State Network of Integrity Pacts, coordinated between administrations, authorities and civil society organisations specialising in public integrity, transparency and sustainability. In the particular case of the Green Integrity Pact, in addition to incorporating the component of strengthening integrity, it will seek to: i) ensure transparency, accountability and establish measures to prevent fraud and corruption throughout the public procurement process to ensure that funds are used for their legitimate purpose; and ii) prevent possible environmental damage that could put one or more ecosystems at risk, as well as possible harm to potentially at-risk populations.

Objectives

The commitment pursues a number of strategic objectives aimed at intensifying efforts to strengthen institutional integrity, prevent risks of fraud, corruption and collusive practices in public procurement, and ensure environmental sustainability, structured along the following lines of action:

1. Institutionalise Integrity Pacts as a mechanism for integrity in public procurement. • Incorporate the Integrity Pact and the Green Integrity Pact (GIP) into Spain’s 5th OGP Plan as preventive mechanisms against the risks of corruption, collusion or fraud in public procurement in Spain, in accordance with the State Plan to Combat Corruption. • Promote their systematic, progressive and multi-level incorporation into national, regional and local strategies and regulatory frameworks on public integrity and sustainable procurement.
2. Strengthen the regulatory and control framework to ensure access to information, transparency and accountability (as pillars of Open Government). • Promote access to public information, compliance with the law and traceability of public procurement procedures through the intervention and monitoring of independent expert monitors. • Introduce good governance practices, foster an institutional culture based on integrity, and strengthen the operational capacity of contracting entities. • Coordinate cooperation frameworks between authorities, control bodies and civil society organisations, particularly with the Independent Office for Regulation and Supervision of Procurement, as a technical assistance body in the implementation of these mechanisms. • Promote effective compliance with environmental impact studies and public consultations with affected communities, especially in projects with climate financing or significant ecological impact.
3. Structured citizen participation and an inclusive approach to contract monitoring • Facilitate the involvement of civil society and academic entities with technical expertise in monitoring contracts at high risk of fraud, corruption or other irregularities. In the case of GIPs, this objective requires involving environmental experts in the public procurement process through the pre-monitoring a n d monitoring group a n d training the monitoring group on specific environmental issues related to the project to ensure effective monitoring a n d completion. • Incorporate sustainability experts and potentially affected groups into contract monitoring. • Promote specialised training for monitoring groups on environmental issues related to the subject matter of the contract, to ensure effective and informed support.
4. Mitigation of environmental risks in public procurement • Apply preventive measures in procedures with medium, medium-high and high environmental risk or with funding linked to environmental protection, in order to avoid serious, extensive, persistent or irreversible damage to the ecosystem or the affected territory. • Ensure independent and transparent technical environmental supervision of projects with a high ecological impact."

3.5.7. Observatory against Fraud and Corruption in Healthcare

Brief description

The Observatory's Standing Committee has presented a strategic plan with the following lines of action: • Axis 1. Prevention. The functions in the area of prevention will include proposing to the competent bodies in the Ministry the actions in the area of procurement that it considers appropriate; promoting best practices in the area of transparency; ensuring that department staff are informed of the communications that must be made in relation to the anti-corruption strategy; and promoting the inclusion of specific courses on the subject in the Department's Training Plan.
• Axis 2. Alert System. With regard to the alert system, improvements in data quality will be proposed to the competent bodies within the Ministry; the necessary tools for risk mapping will be promoted; the systematisation of the monitoring of Ministry contracts will be proposed; study possible conflicts of interest and propose legislative changes to avoid them; promote awareness among Department staff of the Ministry's information and reporting mailboxes; promote the creation of systems for recognising best anti-fraud practices in the field of health; coordinate relations with the relevant state, European and international bodies and units in the field of anti-fraud policies and propose actions to the Department's Inspection Service.
• Axis 3. Collaboration. Collaboration will be promoted with public or private entities or bodies that have monitoring, supervisory or control functions in matters of public procurement or corruption prevention. The aim is to develop an intensive programme of collaboration with all bodies and organisations that have functions of oversight and monitoring of public procurement within our legal system, as well as independent entities or organisations working in the field of transparency, in our country or internationally, such as: the National Commission for Markets and Competition (CNMC); the Independent Office for the Regulation and Supervision of Procurement (OIReScon); the National Anti-Fraud Coordination Service SNCA (under the IGAE); the Independent Whistleblower Protection Authority (AIPI); the State Network of Anti-Fraud Offices and Agencies; and independent authorities at the regional and local levels, such as the AntiFraud Office of Catalonia. Contacts will also be established at European and international level, such as the Commission itself, the European Anti-Fraud Office (OLAF), the European Medicines Agency (EMA), NEIWA (European Network of Integrity Authorities a n d Whistleblowers) a n d the European Healthcare Fraud a n d Corruption Network ( EHFCN), and the European Observatory on Health Systems and Policies. Likewise, collaboration with organised civil society will be sought and the possibility of enabling direct citizen participation will be studied.

Objectives

General objective:
• Promote a policy of integrity in the Ministry of Health, and in the field of health in general, that permeates all public institutions with competence in health management in order to provide citizens with effective and efficient public health care, with their active participation.

Specific objectives:
• Improve integrity policies in recruitment at the Ministry of Health and in the health sector in general.
• Achieve transparent and ethical institutions that promote integrated information management for the prevention of corruption in the healthcare sector.
• Promote advances in data management in the healthcare sector, especially in the area of procurement.
• Provide the various public administrations with the necessary tools to improve integrity systems in the healthcare sector.
• Provide entities that manage public health services with anti-corruption alert systems.
• Promote and establish a culture of integrity and public ethics among healthcare professionals and citizens. • Consolidate instruments for managing conflicts of interest in the health sector.
• Strengthen systems for reporting illegal activities.
• Generate synergies for collaboration with the main national and international entities and associations dedicated to anticorruption policies.
• Reward and highlight those organisations that implement best practices in integrity and transparency."

3.5.8. Collaboration in the fight against doping

Brief description

An online system through which athletes, support staff and any member of the public can anonymously report to CELAD any information relating to the use, administration or trafficking of substances or methods prohibited in sport.

Objectives

This initiative consists of providing anyone who wishes to collaborate in the fight against doping with the necessary means to send this information to CELAD, allowing them to do so anonymously and confidentially."