AID systems are among the most important multipurpose tools used worldwide to prevent and combat corruption in the public sector. Their core purpose is to build a culture of integrity, foster public officials’ accountability, and promote public trust by collecting information on officials’ assets, incomes, revenue streams, expenditures, and activities to inform on actual or potential conflicts of interest.

qAID – an EU-funded initiative – aims to be the first comprehensive EU project to enhance the effectiveness of national AID systems in EU Member and Candidate States. In its recent study, the team analysed survey responses from EU Member and Candidate States (with missing data complemented through desk research and secondary sources) to deliver a detailed picture of current arrangements, identify best practices and key trends, and develop recommendations to improve effectiveness.

As the authors note, although most EU Member States have rules in place requiring asset and interest disclosure, there remain significant differences regarding the scope of declarations, the transparency and accessibility of information, and the effectiveness of verification and enforcement measures – including approaches to risk analysis.

1. Completion and lodging of declarations

An analysis of existing arrangements shows that, for the collection of declarations, most EU Member States task an independent central (and/or national) authority with this function. Some countries, however, employ different models: Germany implements internal collection within the institutions; Greece combines collection by an independent decentralised authority with collection by an independent central authority; Poland combines an independent decentralised authority with internal collection. In Candidate States, the dominant model likewise assigns collection to an independent central authority, with the notable exception of Bosnia and Herzegovina, which uses independent decentralised authorities; Montenegro and Ukraine apply mixed approaches – central + decentralised and central + internal, respectively.

The method of filing can be paper-based, electronic (e-filing), or mixed, and most jurisdictions use a mixed approach. In some cases (e.g., Albania and Ukraine), national law requires filers to submit declarations both in paper and electronic form. In Ireland, officials may file on paper or by emailing a scanned copy to the competent authority. In Latvia, the method depends on the declarant: most civil servants must file electronically, while certain categories – those subject to official-secret protections – submit on paper.

The report notes a clear trend toward digitalisation: many countries are introducing electronic submission systems that can streamline filing, facilitate verification (including automated cross-checks), and improve public access. At the same time, the implementation of e-filing requires substantial technical, economic, and human resources.

The categories of persons subject to the disclosure obligation also differ across jurisdictions. In general, the obligation is typically imposed on public officials; however, the precise list of persons falling within this category varies.

In EU Member States, both public officials and politically exposed persons (PEPs) are generally required to file declarations (with the exceptions of Croatia and Germany). In a number of countries, the obligation also extends to other persons who, under national law, are classified neither as public officials nor as PEPs – for example, individuals participating in public procurement procedures who are not civil servants (Slovenia); presidents of professional associations (e.g., lawyers, certified public accountants, architects, solicitors, etc.) under special legislation (Portugal); and persons holding certain elective offices (Italy).

In Candidate States, the picture is similar: most countries require declarations from public officials and, except for North Macedonia and Ukraine, from political office-holders. In most Candidate States, all public officials must file asset and interest declarations; however, there are exceptions where the obligation applies only to specific categories – for example, those included in special registers (Georgia), those holding managerial positions in institutions (Bosnia and Herzegovina), or those defined by national laws and by-laws (Serbia). In many cases the obligation also extends to other categories of persons, such as managers of companies in which the state holds at least 50% of shares and which employ more than 50 persons (Albania); persons performing managerial functions in subdivisions of state-budget institutions; as well as persons performing managerial functions in subdivisions and persons with control/oversight functions in state and municipal enterprises, and in commercial organisations with a wholly state-owned or controlling state stake (Moldova).

Many countries broaden the scope by extending the obligation to related persons – such as spouses, cohabitants, or children – to prevent the concealment of illicit assets. This approach is followed in all Candidate States; among EU Member States, Germany, Greece, Portugal, and Slovenia limit the requirement to the office-holder only, while in the others the obligation extends at least to declarants’ spouses and their minor children. At the same time, as the authors note, any such extension should, first, be balanced against the privacy rights of persons who do not hold public office, and, second, take into account the actual capacity and resources of the authorities responsible for collection and/or verification to process this additional data.

The content of declarations also varies. In all or almost all countries, declarations include such core categories of information as income, movable and immovable property, financial liabilities, securities, participation in commercial entities, as well as other remunerated or unremunerated work. However, Candidate Countries to the EU often require disclosure of a broader set of information. For example, in Moldova the declaration includes information on expenditures for services (accommodation, travel, construction, renovation, medical services) and on gifts (kept in a separate register by the employer); in Serbia filers indicate whether assets are held domestically and abroad; in Ukraine declarations cover objects of unfinished construction that have not been commissioned or for which title has not been registered, as well as transactions carried out during the reporting period (for example, the acquisition or termination of ownership).

As regards filing frequency, in most EU Member States declarations are filed upon assuming office and/or shortly after assuming office, and/or annually during the period of service, and/or upon leaving office. With the exceptions of Slovenia and Poland, respectively, filers are generally not required to disclose before taking office and/or after leaving service. As a rule, during tenure declarations are filed more than once. Some EU Member States (Bulgaria, Germany, Italy and Portugal) also require disclosure when a potential conflict of interest arises. Almost all Candidate Countries require a declaration at least once a year (except North Macedonia) and upon leaving office (except Bulgaria); only Montenegro requires more than one filing per year. Certain jurisdictions also prescribe more specific filing moments, for example upon reinstatement after parental leave (Moldova), during nomination for various posts in the judiciary (Albania), or upon dismissal [where the departure did not occur at the employee’s initiative] (Ukraine). At the same time, none of the Candidate Countries requires officials to file a declaration when a potential conflict of interest arises.

Under certain conditions, countries may provide for exemptions from the obligation to file a declaration. Such conditions may include thresholds (level of income, value of assets), geographic location (for example, assets and interests located abroad), or the time of acquisition (for example, before entering public service, during service, or after leaving). Such exemptions are typically found in EU Member States, whereas in Candidate Countries they are less common and confined to specific circumstances.

2. Verification and analysis of declarations

Once submitted to the competent authority, declarations must undergo verification. Depending on the country, checks may focus on timeliness of filing, correctness of completion, accuracy and reliability of the data, consistency and completeness of the information, the presence of potential discrepancies (for example, expenditures not supported by declared income), and compliance with anti-corruption legislation.

Although the authors note that designating a separate body for verification is preferable, in all EU Member States and Candidate Countries the authority responsible for collecting declarations also carries out verification, with one exception: in Italy, each institution collects declarations, while the National Anti-Corruption Authority (ANAC) conducts the verification.

Most countries employ a mixed verification model that combines automated and manual checks. For example, in Moldova not all national databases are interoperable with the e-Integrity IT system, so operators must consult several existing databases manually. In Latvia, verification consists of two stages: the first is fully automated and performed by the Payment Administration Information System (MAIS), which automatically approves and publishes a declaration if no inconsistencies are detected; the second stage involves manual checks by State Revenue Service staff where the system declines to approve a submission automatically. Fully automated checks are provided only in Georgia and Greece, while exclusively manual checks are used in Germany, Slovenia, Poland, Albania, Bosnia and Herzegovina, and Serbia.

A number of countries, including those that rely on manual checks, verify all or almost all submitted declarations (Albania, Georgia, Germany, Latvia, Portugal and Serbia – over 70% of declarations; Bulgaria and Croatia – 91–100%). In other countries that use a mixed approach to verification (Italy, Moldova, North Macedonia and Romania), less than 10% of declarations are reviewed. As the authors note, low verification shares may indicate either the effective operation of risk-analytics systems that select declarations for review, or an inability to process a larger volume of verifications, since this requires substantial financial and human resources and can be time-consuming, especially where checks are manual.

The study identifies the following triggers for launching verification:

• the initiative of the responsible authority, which decides how to review declarations using specific inputs (e.g., results of criminal investigations or media monitoring);
• whistleblower reports – the public availability of declarations enables citizens, journalists and civil society organisations to detect and report possible violations;
• information about possible violations received from another public authority;
• the results of risk analysis – in countries that apply such a mechanism, verification focuses on (or at least prioritises) declarations of officials from “risk groups”;
• random selection.

In all Candidate Countries and in almost all EU Member States (except Greece), declarations are selected for verification either at the initiative of the verifying authority or on the basis of whistleblower reports or information from other bodies. Reviews triggered by risk analysis are rare (Georgia, in particular, reported examining best practices for such checks).

Verification of the content of declarations – above all the accuracy and completeness of the information provided – is carried out by comparing it against external sources (cross-checking). Cross-checking is critical for detecting violations and, in turn, for enforcing national legislation: without it, it is impossible to verify the substance of a declaration, identify potential discrepancies and, consequently, uncover cases of corruption. Nearly all of the countries analysed (with the exception of Ireland) recognise the importance of cross-checking and conduct it.

Sources used for cross-checking include:

• public registers and government databases – used universally;
• media and open sources (OSINT) – used rarely in EU Member States (Italy, Latvia, Poland, Portugal) and more frequently in Candidate Countries;
• private registers and databases – used selectively in certain countries (among Member States: Greece, Italy, Latvia, Romania; among Candidates they may be used more often);
• foreign databases – used only to a very limited extent: in the EU, by Italy and Latvia; among Candidate Countries, by Serbia (open data only) and Ukraine (a broad range of external sources, including those with restricted access).

In most countries, cross-checking of declaration content is conducted in a mixed format (automated and manual). For example, in Ukraine the method depends on the risk level (low – automated exchanges between registers; high – manual requests). In Portugal, cross-checks are conducted only manually (while overall verification is mixed); in Slovenia, basic verification is manual, and cross-checking can be either manual or automated upon request.

With regard to the depth of verification, the study notes that in all EU Member States it covers at least the accuracy of the data, the detection of potential inconsistencies across form fields and – except in Croatia – the completeness of the information. In Portugal, checks also extend to the possible existence of a conflict of interest or other incompatibilities affecting the declarant’s eligibility for office (i.e., breaches of anti-corruption standards). In Candidate Countries, verification covers a broader set of elements, such as checks for undeclared assets and private interests (Albania), possible restrictions on the exercise of public functions (Montenegro), illicit enrichment (North Macedonia), conflicts of interest and unjustified income (Ukraine), as well as timeliness of filing (Moldova). At the same time, the authors point out that because information on senior officials is published annually after the filing deadline, some such filers often submit after that date to avoid media attention.

Where violations are identified, many countries allow the declarant time either to correct the content of the declaration and resubmit (except Greece, Italy, Poland, Albania, Moldova, Montenegro and Serbia) or to provide the verifying authority with explanations regarding the alleged violations (except Poland).

Sanctions applied in the event of violations include:

• fines and/or the initiation of administrative proceedings against the declarant – the most common sanctions; according to the study, fines are not provided for only in Ireland (except at the local level) and Poland, and administrative proceedings are not provided for in North Macedonia;
• disciplinary measures – applied in roughly half of the countries;
• criminal liability – applied in certain EU Member States and in almost all Candidate Countries (except Moldova and Montenegro);
• “soft” measures – public censure – sometimes used both in the EU (Bulgaria, Germany, Latvia, Slovenia) and in Candidate Countries (Bosnia and Herzegovina, Montenegro, Serbia, Ukraine).

Typically, the specific sanction depends on the type of violation. For example, in Moldova incomplete information initially prompts a request to resubmit (without a sanction); a material discrepancy between income and expenditures triggers administrative proceedings; and failure to file or late filing may result in a fine.

Attention in the study is also devoted to mechanisms for analysing declarations from a corruption-risk perspective. Although risk analysis and verification are conceptually distinct, in practice they often overlap: risk analysis typically precedes – and triggers – verification, estimating the likelihood of irregularities, whereas verification ensures accuracy and enables enforcement.

Suspicious and “at-risk” declarations are identified on the basis of risk indicators (so-called red flags), which determine the declaration’s risk level. Risk analysis is used to prioritise checks and conserve resources, but does not in itself prove violations. More than half of the surveyed countries provide for some form of risk analysis – it is not implemented in Albania, Bosnia and Herzegovina, Croatia, Ireland, North Macedonia, Poland, Portugal, and Slovenia.

Methods can be manual, automated, or mixed. The choice of method is not always linked to how declarations are filed: for example, Greece and Georgia have e-filing yet use a mixed approach; Germany, Italy and Moldova conduct risk analysis manually. In Bulgaria, inspectors cross-check declarations against state registers; Serbia combines automated elements with random selection; Ukraine applies logical and arithmetic control (LAC) to flag inconsistencies and rank declarations by a calculated risk rating for subsequent verification.

Common risk indicators include data inconsistencies, missing information, late submission, and discrepancies between an official’s lifestyle and the contents of the declaration. Notably, only Ukraine and Latvia maintain formalised, regularly updated red-flag lists – other countries rely on more limited, standardised indicators; Ukraine’s system uses a weighted scoring model to trigger verification above a risk threshold.

3. Recommendations for strengthening AID systems

The authors also propose general recommendations for improving Asset and Interest Disclosure (AID) systems:

• define the overall architecture and allocation of roles (central vs decentralised levels), with clear mandates, lines of responsibility and interaction procedures;
• ensure comprehensive scope and clear definitions, so that regulations cover all material asset and income types as well as the main categories of conflicts of interest;
• expand the personal scope (spouse, minor children and other dependants) where justified and with appropriate data-protection safeguards;
• implement e-filing with pre-filled fields, automated completeness and logic checks, and the ability to publish promptly;
• ensure machine-readable data to enable automated cross-checks and analytics;
• introduce risk analytics with red flags, weighted indicators and prioritisation of reviews (a mixed model – automation and expert judgement);
• establish appropriate follow-up procedures even for probable violations and designate the competent authorities for investigating potential breaches;
• integrate cross-checks with state registers (tax, property, vehicles, corporate ownership) and, where feasible, with private databases and foreign registers;
• develop interoperability and secure data exchange between agencies, including cross-border exchange where there is a legal basis;
• design a proportionate sanctioning regime (fines, administrative and criminal measures);
• balance transparency and privacy: publish information sufficient for accountability while restricting access to sensitive data;
• conduct regular effectiveness reviews (metrics, KPIs, impact assessment) and publish aggregated statistics on checks and violations;
• ensure phased implementation (pilots, feedback loops, algorithm tuning), internal controls and documentation of IT processes (including access-rights management);
• provide adequate human and financial resources to verifying authorities, with training and capacity-building;
• develop guidance materials and advisory channels for officials on disclosure and the management of conflicts of interest.