Fraud involving EU funds: rules, controls and criminal risks for beneficiaries and consultants

EU funds are one of the most important sources of financing for public and private investments in Romania: infrastructure, digitalisation, agriculture, innovation, regional development, training and much more. However, they come with a complex set of rules on the eligibility of expenditure, project selection, procurement, reporting and control. Any serious deviation from these rules can trigger not only financial corrections but also criminal liability for beneficiaries, legal representatives, directors, consultants or other persons involved in implementation.

In recent years, European institutions such as the European Anti-Fraud Office (OLAF) and the European Public Prosecutor’s Office (EPPO) have intensified checks on how EU funds are used, and Romania constantly appears among the Member States with a high number of investigations concerning suspected fraud and irregularities. At the same time, at national level, offences related to EU funds are regulated both in Law no. 78/2000 on preventing, discovering and sanctioning acts of corruption and in the Criminal Code, supplemented by special legislation on irregularities and financial corrections, such as Government Emergency Ordinance (GEO) no. 66/2011.

This article aims to explain, in accessible language, how fraud involving EU funds is defined, what essential rules beneficiaries and consultants must know, what “irregularity” versus “fraud” means, how the system of controls and reporting works, and, above all, what criminal risks exist for persons involved in managing these funds.

1. Legal framework: between EU law and Romanian law

The protection of the financial interests of the European Union is governed, at European level, by a “package” of legal acts which lay down both the general financial rules and the obligation for Member States to criminalise fraud involving EU funds in their national criminal law.

1.1. EU level: PIF Directive, Financial Regulation and EPPO

At EU level, the key instruments are:

• Directive (EU) 2017/1371 on the fight against fraud to the Union’s financial interests by means of criminal law (the so-called “PIF Directive”), which requires Member States to criminalise fraud involving EU funds, corruption affecting EU funds, money laundering related to such acts and certain serious VAT offences, and sets minimum rules on definitions, penalties and limitation periods. The text can be consulted in English and other languages on EUR-Lex.
• Regulation (EU, Euratom) 2018/1046 on the financial rules applicable to the general budget of the Union (the “Financial Regulation”), which lays down principles of sound financial management, including obligations relating to control, prevention of conflicts of interest, reporting of irregularities and recovery of unduly paid amounts. An official summary can be found on EUR-Lex – Financial Regulation 2018/1046.
• Regulation (EU) 2017/1939 implementing enhanced cooperation on the establishment of the European Public Prosecutor’s Office (EPPO), which creates a supranational prosecution office responsible for investigating and prosecuting offences affecting the financial interests of the Union (“PIF offences”), including fraud involving EU funds above certain thresholds (generally above EUR 10,000) or with particular impact. The regulation is available on EUR-Lex, and an overview is published on the EUR-Lex summaries page.
• Specialised EU bodies: OLAF – European Anti-Fraud Office, which conducts administrative investigations into fraud and other irregularities affecting EU funds, and EPPO, which carries out criminal investigations in participating Member States, including Romania.

According to the annual OLAF reports, available on the page “Annual OLAF reports”, the amounts recommended for recovery of EU funds exceed hundreds of millions of euro each year, and Romania is among the countries with a significant number of cases investigated. In parallel, EPPO issues annual reports on its ongoing investigations and indictments concerning crimes affecting the Union’s financial interests.

1.2. National level: Law 78/2000, Criminal Code and GEO 66/2011

In Romania, the main legal instruments relevant to fraud involving EU funds are:

• Law no. 78/2000, in particular Articles 18¹–18³, which criminalise the use or presentation of false, inaccurate or incomplete documents or statements, as well as the unlawful change of the destination of funds or assets from the EU budget, when the act results in the unlawful obtaining or retention of funds or the unlawful reduction of EU resources. The consolidated version can be consulted on the official Legislative Portal.
• The Criminal Code, which in Article 306 – “Unlawful obtaining of funds” criminalises the use or presentation of false, inaccurate or incomplete documents or data to obtain public funding unduly, and in Article 244 – “Fraud” punishes misleading a person by presenting a false fact as true or a true fact as false in order to obtain an unjust material gain.
• GEO no. 66/2011 on the prevention, detection and sanctioning of irregularities in obtaining and using European funds and/or related national public funds, which defines “irregularity” and “fraud”, as well as the procedure for establishing budgetary claims and applying financial corrections. The updated text is available on the Legislative Portal.
• Implementing legislation for the EPPO Regulation, in particular Law no. 6/2021, which lays down measures for the application of the EPPO Regulation in Romania.
• Guidelines and practical manuals on irregularities and fraud, for example:
  • Guide on fraud and irregularities management in ESIF-funded projects;
  • Guide on prevention of irregularities and fraud – Regional Programme North-West;
  • Guide with examples of irregularities/frauds – ADR South-West Oltenia;
  • Practical guide for beneficiaries of EU-funded projects.

In addition, there are numerous decisions of the High Court of Cassation and Justice and of the courts of appeal which shape the case-law on fraud involving EU funds. For example, Decision no. 4/2016 delivered in an appeal in the interest of the law clarified the relationship between Article 18¹ of Law 78/2000 and the offences of fraud and unlawful obtaining of funds where both EU funds and national funds are involved.

2. Eligibility and obligations of beneficiaries and consultants

In practice, many situations which end up being classified as “fraud involving EU funds” originate in the way the eligibility rules and contractual obligations are understood (or ignored). Beneficiaries and consultants need to be aware from the application stage that EU funds are not “free money” but funding strictly conditional on compliance with a series of criteria and procedures.

2.1. Eligibility of projects and expenditure

For each funding programme (transport and infrastructure, ROP, PNRR, agricultural programmes etc.), the calls and guidance documents set out eligibility criteria for:

• type of beneficiary (SME, public authority, NGO, large enterprise);
• type of project (investment, R&D, vocational training, digitalisation);
• eligible expenditure (works, equipment, services, staff, indirect costs) and ineligible expenditure;
• project duration, geographical area and other specific conditions (for example, compliance with the “Do No Significant Harm – DNSH” principle).

Presenting false or misleading information in the application about eligibility (for example, simulating the fulfilment of financial ratios, inflating the number of jobs to be created, presenting as “needed” equipment already owned by the beneficiary etc.) can, depending on the context, lead to the reclassification of the facts as unlawful obtaining of funds or use of false or inaccurate documents, if the intention to mislead the managing authority is proven.

2.2. Implementation obligations: from procurement to reporting

Once the financing contract or decision is signed, the beneficiary is required to implement the project in accordance with the approved documents, the applicable legislation and the contractual provisions. Key obligations include:

• carrying out procurement in a transparent and competitive manner, in accordance with national public procurement law where applicable, or with the specific rules for private beneficiaries;
• keeping supporting documents and clear accounting records that allow verification of the reality and eligibility of expenditure;
• submitting progress and financial reports on time through statements of expenditure, reimbursement requests or payment claims;
• notifying the managing authority or intermediate body of any significant change to the project (change of location, equipment, budget structure etc.);
• implementing measures to prevent conflicts of interest and fraud, in line with the requirements of the 2018 Financial Regulation and the national guidance.

Consultants (especially those who draft applications, budgets, feasibility studies or provide project management services) normally have contractual obligations towards the beneficiary, but they also face potential criminal exposure if they participate in designing or implementing fraudulent schemes (for example by deliberately drafting false or inaccurate documents to help the beneficiary obtain or keep funds unduly).

2.3. The role of consultants: where legitimate “optimisation” ends and criminal risk begins

In practice, beneficiaries often rely on consultancy firms to maximise their chances of receiving funding. From a criminal law perspective, it is essential to distinguish between:

• legitimate optimisation – presenting the real data in the most favourable way, making full use of the eligibility criteria, structuring the project so as to obtain a high score, without distorting reality;
• distortion of reality – intentionally adjusting data, inventing indicators or resources, inflating costs, simulating activities or contractual relationships, with the aim of obtaining an undue financial advantage.

A consultant who agrees to “fix” documents, propose “front” suppliers or prepare fictitious justifications assumes a criminal risk comparable to that of the beneficiary and may be classified as an instigator or accomplice to offences such as unlawful obtaining of funds or intellectual forgery, depending on the circumstances.

3. Irregularity versus fraud: why the distinction matters

Not every mistake in an EU-funded project is “fraud”. The legal framework and national guidelines clearly distinguish between an “irregularity” and “fraud”, and this distinction has immediate consequences: in the first case, financial corrections (administrative measures) are typically applied, while in the second case criminal prosecution authorities intervene.

3.1. Definition of “irregularity” and “fraud” in GEO 66/2011

According to GEO no. 66/2011, an “irregularity” is any infringement of EU or national law, or of the provisions of the financing contracts, which has or may have a detrimental effect on the EU budget or related national public funds by charging an unjustified amount. “Fraud” is defined in the same act as a criminal offence committed in connection with obtaining or using EU funds, as incriminated by the Criminal Code or other special laws.

Consequently, any deviation from the rules can be an irregularity, but only intentional acts that fit within a criminal offence become “fraud”. In practice, the same factual situation may first be classified as an irregularity (by financial control structures) and later, following a notification, become the subject of a criminal investigation.

3.2. Examples of irregularities that do not necessarily amount to criminal offences

In many projects, irregularities stem from lack of knowledge, negligence or misinterpretation of the rules, for example:

• an expenditure is incorrectly classified as eligible, although the programme guide excludes it (for example, purchase of second-hand assets under a call which only finances new assets);
• missing the deadline for submitting reimbursement requests or failing to submit certain supporting documents in time;
• clerical errors in the electronic systems, subsequently corrected, without any fraudulent intent;
• use of a procurement procedure slightly different from the recommended one (for example, a formal mistake in publishing a call for tenders), without any indication that a particular bidder was favoured.

These situations may lead to financial corrections – i.e. a reduction or cancellation of funding for the part affected – but do not necessarily result in criminal files in the absence of indications of fraudulent intent. This is why proper documentation of decisions, careful reading of the guidance and seeking clarifications from the managing authority are essential to demonstrate good faith.

3.3. When an irregularity becomes criminal fraud

An irregularity turns into “fraud” when there are indications that the breach of the rules was committed with the intention to obtain or keep EU funds unduly or to unlawfully reduce budgetary resources. Typical examples include:

• falsifying or “cosmetising” supporting documents (invoices, contracts, delivery and acceptance certificates, timesheets, participants’ lists) in order to simulate expenditure or activities;
• fixing tenders and procurement procedures through sham offers or cartels of companies, so that a predetermined supplier wins;
• unlawfully changing the destination of funds or purchased equipment, while falsely reporting the achievement of indicators;
• fictitious reporting of indicators (for example, number of persons trained, participants in courses or jobs created) to avoid repayment of funds.

In such cases, in addition to financial corrections, the control authorities may notify the prosecution bodies (National Anticorruption Directorate – DNA, local prosecutors’ offices or EPPO, depending on jurisdiction), and not only the beneficiary entity but also the individuals involved – directors, legal representatives, project managers, consultants, accountants, technical experts etc. – may be targeted.

4. Common typologies of fraud involving EU funds

An analysis of OLAF reports and national case-law reveals recurring patterns of fraud involving EU funds. Knowing these typologies is important for both prevention and understanding high-risk areas.

4.1. “Paper projects” and fictitious activities

One category of fraud involves projects in which the reported activities are in fact non-existent or only partially implemented. Typical examples are:

• training projects where courses, participants and training hours are reported although they did not actually take place or were only formally organised;
• consultancy, study or strategy projects where deliverables are copy-pasted from other projects, recycled or without any real utility, but are claimed as if they were original results;
• investment projects in which equipment is present only formally at the project location but is in fact used in another business of the beneficiary or has been resold.

In such cases, prosecutors analyse in detail correspondence, documents, witness statements and material traces (for example the physical presence of equipment) to determine whether the false reporting of activities was deliberate.

4.2. Overpricing and rigged procurement procedures

Another frequent typology concerns manipulation of procurement procedures to favour certain companies, usually in exchange for illicit benefits (commissions, disguised subcontracting, personal advantages). Common examples include:

• procedures where the technical specifications are tailored “to order” for a single supplier, artificially excluding competitors;
• bidders that are formally distinct but controlled by the same shareholders or affiliates, so that “competition” is only on paper and prices are inflated;
• chains of subcontracting through which services or works are actually performed by companies linked to decision-makers, at prices disproportionate to market value.

In such scenarios, in addition to corruption offences (bribery, trading in influence), fraud involving EU funds may be retained if it is shown that the procedure was used to extract EU resources in a fraudulent manner.

4.3. Changing the destination of funds and using assets for other purposes

Law 78/2000 specifically criminalises the unlawful change of the destination of funds or assets obtained from the EU budget when this is done in breach of legal provisions and results in damage to the Union’s financial interests. In practice, situations include:

• use of equipment purchased through the project in other projects or in non-eligible activities, without informing the managing authority;
• moving the investment to another location or to another beneficiary without approval, while formally reporting that indicators have been met;
• using pre-financing funds for expenditures unrelated to the project (for example, covering other debts of the beneficiary).

Even if the beneficiary views such decisions as “temporary” or “economically justified”, from a legal perspective they can fall under the offences concerning change of destination of funds, especially if concealed from the managing authority.

4.4. Examples of concrete cases in court practice

Doctrinal articles and case-law analyses published on platforms such as Universul Juridic, Revista Pro Lege or BizLawyer describe cases where courts have held that:

• false documents were used to obtain financing for non-existent farms or agricultural investments;
• compliance with eligibility conditions for agricultural subsidies was fictitiously reported, with the involvement of consultants and officials;
• funding was obtained for vocational training programmes in which the real beneficiaries did not participate in courses or did not receive the promised certificates.

These cases are useful for understanding how courts interpret the constituent elements of offences related to EU funds and the relationship between Law 78/2000 and the Criminal Code.

5. Reporting irregularities and suspicions of fraud

The system for protecting the EU’s financial interests is based on the idea that irregularities and suspicions of fraud should be detected and reported as early as possible, in order to limit losses and enable authorities to react promptly. Beneficiaries, consultants and persons involved in project implementation have clear reporting obligations.

5.1. Obligation to report irregularities under GEO 66/2011

GEO 66/2011 provides that beneficiaries of EU funds must report irregularities identified in their own projects to the managing authority or intermediate body. Some specific instructions issued by various authorities (for example, the Fund for Internal Security – Ministry of Internal Affairs) set concrete deadlines (usually five working days from identification) and describe the format of reports.

At public administration level, there are also dedicated IT systems for reporting irregularities, such as the Irregularity Management System (IMS), described in documents like “Reporting irregularities and frauds to the EC and OLAF”.

5.2. Reporting to OLAF and EPPO

Any person – not only authorities – can report to OLAF a suspicion of fraud affecting EU funds, including anonymously, through the online form available on the page “Report fraud”. OLAF may open administrative investigations and transmit recommendations to national authorities or to EPPO.

In Member States participating in EPPO, including Romania, offences affecting the EU’s financial interests can also be reported directly to the European Public Prosecutor’s Office via the channels indicated on the page “Reporting a crime to the EPPO”. EPPO cooperates with European Delegated Prosecutors in each Member State and has priority jurisdiction for a range of PIF offences (fraud, corruption, money laundering, serious VAT fraud) above certain value thresholds.

5.3. Internal reporting and whistleblowing channels

Within beneficiary entities, especially in the public sector and large organisations, it is advisable to set up internal reporting channels so that employees can report suspicions of fraud or irregularities without fear of retaliation. Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law, transposed into national law, strengthens this framework, including for the area of EU funds.

6. Criminal risks for beneficiaries and consultants

Beyond financial corrections (reductions of financing, obligation to repay amounts received, interest and penalties), fraud involving EU funds can lead to serious criminal penalties for both individuals and legal entities. This section summarises the main relevant offences in Romanian law.

6.1. Unlawful obtaining of funds (Article 306 Criminal Code)

Article 306 of the Criminal Code punishes the use or presentation of false, inaccurate or incomplete documents or data to obtain approvals or guarantees required to access funding obtained or guaranteed from public funds, where this results in the unlawful obtaining of those funds. The penalty is imprisonment from 2 to 7 years, and the attempt is also punishable.

Legal scholars have pointed out that this offence largely “transposes” into the Criminal Code the model initially set out in Article 18¹ of Law 78/2000, originally applicable only to EU funds and later extended to all public funds. Detailed analyses of Article 306 can be found, for example, in commentaries published on BizLawyer or on specialised portals such as Codul penal adnotat – Article 306.

6.2. Special offences relating to EU funds in Law 78/2000

Law 78/2000, in its updated form, contains a dedicated chapter on the protection of the EU’s financial interests. For example:

• Article 18¹ punishes the use or presentation of false, inaccurate or incomplete documents or statements where the act results in the unlawful obtaining or retention of funds or assets from the EU budget or from budgets managed by or on behalf of the EU.
• Article 18² criminalises the change, without complying with legal provisions, of the destination of funds or assets obtained or retained from the EU budget or from budgets managed by or on behalf of the EU.
• Article 18³ concerns actions or omissions resulting in the unlawful reduction of resources of the general EU budget or budgets managed by or on behalf of the EU, including through the use or presentation of false documents.

These provisions can be consulted in full on the Legislative Portal – Law 78/2000. Relevant case-law, including decisions delivered in appeals in the interest of the law, is analysed in detail in doctrinal articles such as the one published on Universul Juridic.

6.3. Other relevant offences: fraud, forgery, corruption, money laundering

Fraud involving EU funds rarely appears “alone” in criminal files. It is usually associated with other offences, such as:

• Fraud (Article 244 Criminal Code), where the deception of the managing authority goes beyond the mere use of false documents and involves a wider scheme of fraudulent conduct;
• Intellectual forgery and use of forged documents, where supporting documents are drawn up with false data or are used despite the author’s knowledge that they do not reflect reality;
• Corruption offences – bribery, trading in influence – where the selection of suppliers, subcontractors or evaluation decisions is “bought” or influenced in exchange for money or other advantages;
• Money laundering, where sums fraudulently obtained from EU funds are passed through several transactions to conceal their origin.

Under the PIF Directive and the EPPO Regulation, such acts fall under the category of “PIF offences” or related offences, and EPPO has jurisdiction where the value thresholds and connection criteria laid down in EU law are met.

6.4. Liability of consultants and other participants

Consultants, auditors, technical experts or other persons involved in a project are not “immune” simply because they are not the direct beneficiaries of funds. Under the Criminal Code, they may be held liable as:

• perpetrators – when they directly commit the act (for example, they draft and submit false documents in the name of the beneficiary, acting under a mandate);
• co-perpetrators – when they act together with the beneficiary’s representatives in designing and executing the fraudulent scheme;
• instigators – when they persuade or encourage the beneficiary to commit the offence (for example, they explicitly propose “cosmetising” documents to meet eligibility conditions);
• accomplices – when they knowingly facilitate the commission of the offence (for example, by providing “friendly” companies for rigged tenders or templates for forged documents).

In addition, legal persons (including consultancy firms) may be criminally liable under the Criminal Code provisions on corporate criminal liability if offences are committed in their interest or on their behalf, by their governing bodies or representatives.

7. How beneficiaries and consultants can reduce risks

Fraud involving EU funds is not inevitable. Most projects are implemented correctly, and problems often arise from lack of information or attempts at shortcuts to save time or money in the short term. From a prevention perspective, a few simple principles can significantly reduce risks:

7.1. Keep rigorous documentation and archives

Any important decision concerning the project (selection of suppliers, budget changes, reorganisation of activities) should be documented: explanatory notes, minutes, correspondence, internal reports. A clear and complete archive helps both in administrative controls and, in case of suspicion, in proving good faith.

7.2. Comply with procurement procedures and avoid conflicts of interest

Even if the beneficiary is not a contracting authority in the classical sense under public procurement law, the guidelines generally impose transparency and competition requirements. It is important to:

• request offers from several suppliers, based on clear specifications;
• avoid offers from companies that are affiliated or controlled by the same persons, unless there is an objective and transparent justification;
• record the reasons for choosing a particular supplier, including in terms of price and quality.

The Financial Regulation and national guidelines emphasise the prevention of conflicts of interest, and authorities increasingly scrutinise links between beneficiaries, suppliers and consultants.

7.3. Invest in training and a culture of compliance

Employees involved in the project (project managers, financial/accounting staff, technical experts) should be trained on eligibility rules, procurement, reporting and fraud prevention. Guides published by organisations such as the Institute for Public Policy (IPP), the Regional Development Agencies or the National Agency of Civil Servants (ANFP) are useful resources in this respect.

7.4. Ask for clarifications and interpret “grey areas” restrictively

Instead of pushing the limits of eligibility, it is preferable to request written clarifications from the managing authority or intermediate body. A “creative” interpretation of the rules may seem, at first sight, a clever solution, but it may later generate irregularities and suspicions of fraud. A cautious, restrictive interpretation is often the best protection.

7.5. React promptly to internal suspicions

If you discover internal indications that certain activities are fictitiously reported, that a supplier is linked to decision-makers or that documents have been “adjusted”, do not ignore these warning signs. A quick internal review, possibly with the support of an independent lawyer or compliance consultant, can prevent the escalation of the situation into a criminal case.

8. Conclusions

Fraud involving EU funds is not just about “European money”; it is a problem that affects the credibility of the state, the business environment and genuine development opportunities. The regulatory framework – from the PIF Directive and the EPPO Regulation to Law 78/2000, the Criminal Code and GEO 66/2011 – is increasingly strict, and the capacity of control bodies, both at national and EU level, is steadily growing.

For beneficiaries and consultants, the core message is simple:

• EU funds are not a “bonus” or an “opportunity” to “take money out of the system” but public resources subject to strict rules;
• any “optimisation” that involves distorting reality, hiding information or manipulating procedures can quickly become the subject of a criminal investigation;
• investing in compliance, transparency and fraud prevention is, in the long run, far cheaper than the cost of financial corrections, criminal proceedings and loss of reputation.

Without an individual analysis of each case, this article cannot replace personalised legal advice, but it can serve as a starting point for beneficiaries and consultants who want to better understand the risks and build internal mechanisms to prevent them.

Frequently Asked Questions (FAQ)

What does “fraud involving EU funds” actually mean?

Fraud involving EU funds essentially means the use of deceptive means (false documents, inaccurate statements, concealment of relevant information, manipulation of procedures) in order to obtain or keep funding from the EU budget unduly, or to unlawfully reduce budgetary resources. At EU level, Directive (EU) 2017/1371 requires Member States to criminalise such acts; in Romania, they are regulated in Law 78/2000 and in the Criminal Code.

What is the difference between an “irregularity” and “fraud” in EU-funded projects?

An “irregularity” is any breach of the applicable rules (legal, contractual or procedural) which has or may have a detrimental effect on the EU budget by charging an unjustified amount. “Fraud” is a criminal offence, i.e. an intentional breach that falls under provisions of the Criminal Code or special laws (such as Law 78/2000). In short, not every irregularity is fraud, but every fraud involves a serious, intentional irregularity.

What criminal risks does a beneficiary face when using inaccurate documents in the application?

If the use or presentation of false, inaccurate or incomplete documents or data results in the unlawful obtaining of public funds, the act may be classified under Article 306 Criminal Code (“Unlawful obtaining of funds”) or Article 18¹ of Law 78/2000, depending on the nature of the funds, with penalties of up to 7 years’ imprisonment. In addition, offences of forgery or fraud may be engaged, depending on the circumstances.

Can consultants or consultancy firms be held criminally liable?

Yes. Consultants may be criminally liable as perpetrators, co-perpetrators, instigators or accomplices if they intentionally participate in designing or executing a fraud (for example by proposing overpricing schemes, “fixing” documents or facilitating rigged tenders). Consultancy firms can also be held criminally liable as legal persons if the offences were committed in their interest or on their behalf.

What should I do if I discover an irregularity in my own project?

First, document the situation (what happened, when, who is involved, what amounts are affected). Then notify the managing authority or intermediate body, observing the deadlines under GEO 66/2011 and the programme’s instructions. In parallel, assess, with legal support, whether there are indications of fraudulent intent. Prompt reporting and cooperation with the authorities can limit financial consequences and may also be relevant from a criminal law perspective.

When is a case handled by EPPO rather than by DNA or national prosecutors?

EPPO has jurisdiction over offences affecting the EU’s financial interests (“PIF offences”), such as fraud involving EU funds, corruption or money laundering linked to such acts, above certain value thresholds (generally at least EUR 10,000) and under the conditions laid down in Regulation (EU) 2017/1939. In these cases, European Delegated Prosecutors in Romania conduct the investigations on behalf of EPPO, in cooperation with national authorities.

What are the simplest measures to prevent fraud involving EU funds?

The main measures are: rigorous documentation of all decisions and expenditures; strict compliance with procurement procedures; avoidance of conflicts of interest; training of staff involved in the project; establishment of internal channels for reporting suspicions; requesting written clarifications from authorities in case of doubt; and choosing consultants who prioritise compliance and integrity over “tricks” to obtain points.