What changed

E. whereas the 2025 VAT Gap Report estimates an EU-wide VAT compliance gap of EUR 128 billion; whereas carousel fraud is estimated to cost the EU between EUR 12.512,5 billion and EUR 32.832,8 billion annually;

I. whereas it insists that compliance with anti-fraud rules, access for the EU’s anti-fraud architecture (AFA) components to relevant information for investigative and prosecutorial reasons, strong anti-fraud coordination service (AFCOS) obligations and coordinated national anti-fraud strategies, and strong recovery mechanisms must all be embedded as horizontal requirements in the MFF sectoral regulations, the Financial Regulation6,Regulation, and the specific instruments governing the EU’s AFA;

J. whereas the detection of complex cross-border VAT fraud also relies on whistleblowers and investigative journalists, as reflected by the fact that the large majority of crime reports processed by the EPPO originate from private parties rather than institutions; whereas the effective protection of reporting persons under Directive (EU) 2019/193772019/1937 is therefore an integral part of the EU’s AFA;

9. Stresses that granting the EPPO and OLAF, in the exercise of their mandates, access to VIES and the Central Electronic System of Payment Information – as indicated in the Opinion of Parliament’s Committee on Budgetary Control on the proposal for a Council regulation amending Regulation (EU) No 904/20108904/2010 – ensures the effective countering of cross-border carousel fraud; calls on the Commission to issue clear procedural guidelines to the relevant bodies to ensure legal certainty and to prevent any obstacle to an effective, and where appropriate, simultaneous deployment of the administrative and criminal investigation tools; welcomes the general agreement reached in May 2026 on the amended Regulation (EU) No 904/2010, and insists that it must be implemented with full respect for the distinct legal frameworks applicable to OLAF’s administrative mandate and the EPPO’s criminal enforcement mandate, in line with the European Data Protection Supervisor’s Opinion 1/2026 of 7 January 2026;

17. Notes that EPPO investigations have shown that professional enablers – such as accountants, lawyers and brokers – have a role in the setting-up of shell company chains that make carousel fraud scalable; calls on the Commission to enforce full transposition of the beneficial ownership provisions of the sixth Anti-Money Laundering Directive9,Directive, including on the role of professional enablers;

18. Acknowledges that the Reverse Charge Mechanism, as provided for under Articles 199a and 199b of the VAT Directive10,Directive, has demonstrated clear effectiveness as a targeted anti-fraud instrument by removing the structural opportunity for missing traders to collect VAT and disappear before remitting it; stresses that the mechanism should be retained and, where appropriate, extended; calls on the Commission to bring forward in good time a proposal to extend and, where the evidence warrants, to broaden the scope of Articles 199a and 199b beyond 2026;

19. Notes with concern that crypto-asset transactions are increasingly used by organised criminal networks as a layering mechanism for the proceeds of VAT carousel fraud, exploiting the pseudonymity and cross-border transferability of crypto assets to rapidly move and conceal fraudulent gains before detection; welcomes the entry into force of Council Directive (EU) 2023/2226112023/2226 (DAC8), which requires crypto-asset service providers to report crypto-asset transaction data to national tax authorities from 2026 onwards; calls on the Commission to ensure, as part of the AFA review, that DAC8 reporting data is accessible to Eurofisc, OLAF and the EPPO under their respective mandates for the purposes of VAT fraud investigation; calls on the Commission to assess the extent to which data reported by crypto-asset service providers has helped to identify VAT fraud proceeds and to report its findings to Parliament and the Council by 2028;

25. Stresses that the AFA revision should suggest measures to prevent a lack of judicial independence, ineffective prosecution services and insufficient anti-corruption safeguards, in such a way to prevent, detect and recover VAT fraud; points out that where structural vulnerabilities create heightened risk for VAT fraud losses, targeted recommendations are required and recalls that the Conditionality Regulation12Regulation allows measures to be taken where deficiencies in tackling tax fraud, tax evasion, corruption and other breaches affect the collection of EU revenues;

42. Stresses that the cross-border nature of carousel fraud means that any Member State not participating in the EPPO leaves an exploitable gap in the EU’s prosecutorial coverage; takes note of the Commission decision13decision confirming Hungary’s participation in the EPPO, and of Ireland’s stated intention to bring forward all necessary legislation to join the EPPO;