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| dossier | COM(2024)249 - . |
|---|---|
| document | COM(2024)249 |
| datum | 19 juni 2024 |
4. Conclusions based on the audit work performed in 2023
1. Conclusions on performance audits
Contributing to the Commission’s performance-based culture and greater focus on value for money, the Internal Audit Service carried out performance audits and comprehensive audits (13) in 2023 as part of its strategic audit plan. For half of these engagements, the Internal Audit Service did not identify high residual risks in the areas or processes audited and did not issue any critical or very important recommendations. Various strengths and good practices were noted, including strong and continuous staff commitment, despite the high workload and challenging environment in which various auditees operated (for more details see section 1 of the Annex).
The resulting audit conclusions concerned: (1) performance management; (2) EU policy implementation; (3) internal control systems in relation to legality and regularity; (4) preparedness for and early implementation of the EU budget; (5) cooperation with third parties that implement policies and programmes; (6) information technology; and (7) other processes.
In line with its methodology and best practices, the Internal Audit Service approaches performance in an indirect way. It assesses the performance of the Commission’s departments and services in implementing policies, programmes and actions by reference to the risks associated with them. With this approach, it aims to ensure that Directorates-General and services have developed appropriate performance frameworks, performance measurement tools, and comprehensive monitoring systems.
The following sections set out the Internal Audit Service’s conclusions on the various performance aspects it focused on in its 2023 audits.
1. Performance management
A robust performance management system is essential for ensuring that (i) objectives and performance indicators are effectively set and in line with the Commission priorities; (ii) they are regularly monitored and reported on; and (iii) the activities of the Commission deliver the maximum performance and added value. Stakeholders and citizens increasingly require clear evidence of the Commission’s delivery on political and operational objectives.
The Commission is therefore committed to applying a strong performance framework. The Communication on the EU budget performance framework under the 2021-2027 multiannual financial framework comprises the necessary tools and procedures to set objectives, and measure and monitor progress towards them.
It is within the performance framework that the Internal Audit Service conducted three audits in the area of performance management and issued a number of very important recommendations (14):
1. The Commission uses evaluations as an important tool for the effective and efficient management of interventions (15). In this context, the Internal Audit Service conducted an audit on intervention-level evaluations in the Directorates-General for International Partnerships, and for Neighbourhood and Enlargement Negotiations and the Service for Foreign Policy Instruments. The objective of the audit was to assess whether the process to evaluate interventions is adequately designed, and effectively and efficiently implemented so that the main evaluation objectives (i.e. assessing the performance of an intervention, identifying opportunities to improve current and future interventions, and reporting on the outcome to stakeholders and the wider public) are achieved. The Internal Audit Service concluded that the audited Directorates-General and the Service for Foreign Policy Instruments have put in place an evaluation framework encompassing guidance, templates, an information technology tool, and outsourced support services. However, the process put in place to evaluate interventions would require further improvements for the efficient and effective achievement of the main evaluation objectives, relating to (i) shortcomings in the evaluation guidance, templates, and the information technology tool; (ii) implementation of the evaluation process; and (iii) monitoring, overview, and reporting at headquarters.
2. A second audit was conducted on Horizon Europe. The audit considered the state of play of implementation of the Horizon Europe programme and assessed specific aspects of its performance. The Internal Audit Service found that although the governance arrangements and the processes to prepare the work programmes and the budget planning are, adequately designed and effectively implemented in general, further improvement would be needed on the specific governance arrangements for EU missions.
3. A third audit aimed to assess the processes put in place for measuring and reporting on the performance of technical support projects in the Directorate-General for Structural Reform Support. The Directorate-General designed and put in place processes and controls for performance measurement and reporting on project outcomes and results in general. However, there would be a need for further improvement in their effectiveness relating to the performance measurement methodology.
2. EU policy implementation
In 2019, the President of the Commission defined the political priorities for a five-year period. A key responsibility of the Commission is to translate these priorities into concrete actions. The different Directorates-General and services play an active role in designing and implementing EU policies. They do so by, among others, proposing EU legislation, assisting Member States in its implementation, ensuring that EU law is complied with, and ensuring the EU’s external representation for matters other than foreign affairs and security policy. Two audits conducted by the Internal Audit Service assessed:
1. Eurostat’s role in the European Statistical System;
4. The European Anti-Fraud Office’s effectiveness in fraud prevention activities.
Both audits concluded that there are adequate controls in place to effectively implement the respective audited processes
3. Internal control systems in relation to legality and regularity
Providing reassurance to the College, as well as to the Directorates-General and services, on the efficient and effective implementation of internal controls on financial management remains one of the priorities of the Internal Audit Service. Following a comprehensive risk assessment and the resulting strategic audit plan for 2021-2023, the Internal Audit Service conducted eleven audit engagements in this area in 2023. These audits revealed a need for significant improvements and led to the issuance of a number of very important recommendations (16).
1. The Internal Audit Service conducted a thematic review of the Commission’s risk at payment in the Directorate-General for Budget and a sample of Directorates-General and services such as Directorate-General for Agriculture and Rural Development Directorate-General for Employment, Social Affairs and Inclusion; Directorate-General for International Partnerships; Directorate-General for Neighbourhood and Enlargement Negotiations; Directorate-General for Regional and Urban Policy; Directorate-General for Research and Innovation; European Innovation Council & SMEs Executive Agency; European Research Council Executive Agency; and European Research Executive Agency. This engagement aimed to provide (re)assurance on the calculation of the Commission’s risk at payment and, ultimately, to contribute to a consistent and convincing narrative (mainly in the discharge procedure) concerning: (i) differences with the European Court of Auditors errors; and (ii) together with the Internal Audit Service’s previous review of the Commission’s corrective capacity, the Commission’s capacity to protect the EU budget, considering its multi-annual control systems. The Internal Audit Service recognised that the Commission had made efforts to improve the quality and clarity of the reporting on the risk at payment both at the Directorate-General/service level (in the annual activity reports) and at corporate level (in the annual management and performance report). The audit concluded that the corporate instructions for the reporting on the risk at payment and risk categorisation were overall well designed and effectively implemented by the Directorates-General and services sampled. However, further improvement is required in the Commission’s analysis and reporting on the root causes of errors in relation with the European Court of Auditor’s findings.
5. The audit on the preparedness for closing the 2014-2020 programming period of the European Structural and Investment Funds was conducted in the Directorates-General for Regional and Urban Policy, for Employment, Social Affairs and Inclusion, and for Maritime Affairs and Fisheries. The audits focused on the operational programme’s life cycle during which the Commission made conclusive checks on the legality and regularity of the expenditure. The audit found that the Directorates-General had already implemented several key measures to support effectively and efficiently the preparation of the closure process. However, further improvement in the internal planning of the closure exercise and the arrangements for the financial settlement at closure are needed.
6. Following the merger of the former audit functions of the Directorates-General for Regional and Urban Policy and for Employment, Social Affairs and Inclusion in 2021, which created the Joint Audit Directorate for Cohesion, the Internal Audit Service assessed the adequacy of the management and control systems put in place by the Joint Audit Directorate for Cohesion to ensure the efficient and effective implementation of its mandate. The audit concluded that although the Joint Audit Directorate for Cohesion had put in place adequately designed management and control systems to implement its mandate effectively, there remains a need for further improvement in the efficiency of its internal activities. Its complex organisational structure had led to a loss of efficiency in internal administrative support processes (including human resources management, budget and financial management, reporting). In addition, it had not made a documented comprehensive assessment of the efficiency gains achieved from its establishment. Furthermore, it continued to use different information technology systems and tools of the two Directorates-General to support its processes, which were not fully integrated, and impacted the efficiency of operations.
7. The Internal Audit Service carried out an audit on the implementation of the Innovation Fund, up to the signature of the grant agreements, in the Directorate-General for Climate Action and the European Climate, Infrastructure and Environment Executive Agency. It concluded that overall adequate controls and processes for the implementation of the Innovation Fund had been designed and put in place. However, there is a need for further improvement in the efficiency and effectiveness of the process for evaluating proposals.
8. The Recovery and Resilience Facility entered into force in 2021 as the key element of the NextGenerationEU temporary recovery instrument. The Internal Audit Service conducted an audit on ex ante controls of the Recovery and Resilience Facility payment requests (prior to the authorisation of the payments to a Member State) in the Directorate General for Economic and Financial Affairs and in the Recovery and Resilience Task Force. It concluded that while acknowledging the steps already taken, the design and implementation of the ex ante controls for the assessment of the Member States’ payment requests under the Recovery and Resilience Facility needed to be further enhanced to strengthen their effectiveness. In particular, further improvement is required in the assessment of the audit and control milestones and in the protection of sensitive non-classified information.
9. An audit was conducted in the Directorates-General for Environment, for Energy, for Climate Action, and in the European Climate, Infrastructure and Environment Executive Agency. It focused on the execution of the Programme for the Environment and Climate Action (LIFE programme) for the period 2021-2027 (design and implementation up to the signature of the grant agreements). It concluded that, while the governance, controls and processes put in place by the audited Directorates-General and the executive agency for the implementation of the LIFE programme 2021-2027 were overall adequately designed. However, further improvement is needed in the management of conflicts of interest in the evaluation process.
10. Five engagements were carried out by the Internal Audit Service for which no critical or very important weaknesses in the internal control systems of the audited entities were identified: two audits were conducted in the Directorate-General for European Civil Protection and the Humanitarian Aid Operations with an audit on annual financial clearance of accounts in the Directorate-General for Agriculture and Rural Development. While they concentrated on financial matters, they also included performance issues, namely an audit on the financial management of humanitarian aid under indirect management. Another audit in the Directorate-General for Migration and Home Affairs focused on the preparedness for closing actions and programmes funded under the 2014-2020 Internal Security Fund and the Asylum, Migration and Integration Fund. The Internal Audit Service also conducted a limited review on data protection in the Directorates-General for International Partnerships, for Neighbourhood and Enlargement Negotiations, for European Civil Protection and Humanitarian Aid Operations, for Trade, for Taxation and Customs Union and the Service for Foreign Policy Instruments. It focused on the state of compliance of the audited Directorates-General and services with the key provisions of the EU Data Protection Regulation (Regulation (EU) 2018/1725) and the associated implementing rules, with particular consideration to the transfer of data to non-EU countries. Lastly, the Internal Audit Service conducted a limited review on the assessment process performed by the Health Emergency Preparedness and Response Authority of its internal control framework and reported in the annual activity report for 2022.
1. Preparedness for and early implementation of the EU budget
1. The management of a significant budget and the realisation of its goals under the multiannual financial framework for 2021-2027, together with NextGenerationEU, including the Recovery and Resilience Facility, aimed to mitigate the socio-economic effects of the COVID-19 pandemic and facilitate Europe’s progression towards a modern, greener and more sustainable future, which carries substantial inherent risks. In this context the Internal Audit Service included in its 2023 audit plan seven audits covering the initial steps in planning and implementing the EU budget. For the majority of these audits the results were overall positive, except for two audits where the Internal Audit Service issued two recommendations rated as very important.
11. The Internal Audit Service carried out an audit in the Directorate-General for Defence Industry and Space on the preparedness of its management and control systems for implementation of the 2021-2027 Space Programme. It concluded that although the management and control systems were overall adequately designed for implementation of the 2021-2027 Space Programme, there is a need for further improvement in relation to the security management plans.
12. The Internal Audit Service conducted an audit on the Digital Europe Programme in the Directorate-General for Communications Networks, Content and Technology and the European Health and Digital Executive Agency. It focused on the early phases of implementation of the 2021-2027 Digital Europe Programme supporting and fostering the digital transition in the European economy in the years to come. The audit concluded that the controls and processes put in place by the audited entities for the early phases of implementation of the Digital Europe Programme were overall adequately designed and effective. However, improvement is needed in the design of the controls for the management of conflicts of interest and ethics.
13. A further five engagements did not identify any critical or very important weaknesses in the internal control systems of the audited entities: two of these engagements covered the first implementation phase (from the publication of the calls for proposal until the signature of the grant agreements) of grant management under the Horizon Europe programme, one in the Research Executive Agency, and another one in the European Research Council Executive Agency and the European Health and Digital Executive Agency. Three audits focused on the early stages of implementation of the 2021-2027 multiannual financial framework, mainly on the preparedness of the management and control systems: (1) for the implementation of the Citizens, Equality, Rights and Values and Justice programmes in the Directorate-General for Justice and Consumers and the European Education and Culture Executive Agency; (2) for the implementation by the European Education and Culture Executive Agency of the Erasmus+, Creative Europe and European Solidarity Corps programmes and their supervision by the Directorate-General for Education, Youth, Sport and Culture; and (3) for early implementation of grants in the EU4Health Programme in the Directorate-General for Health and Food Safety, the European Health Emergency, Preparedness and Response Authority and the European Health and Digital Executive Agency.
5. Cooperation with third parties implementing policies and programmes
Budget implementation tasks can be entrusted to EU bodies referred to in Articles 70 and 71 of the Financial Regulation. Currently, the landscape of EU decentralised agencies is diverse in terms of their governance structures, mandates and tasks. Considering the risks identified by the Internal Audit Service related to the Commission’s responsibility in cooperating with, monitoring and supervising these bodies.
1. The Internal Audit Service carried out two engagements in 2023, which involved a Commission partner, Directorates-General and various decentralised agencies or other autonomous bodies. They covered the coordination between the Directorate-General for Migration and Home Affairs and the EU decentralised agencies (17) together with a limited review on the cooperation and coordination mechanisms to prevent, detect and respond to serious cross-border threats to health in the Directorate-General for Health and Food Safety, European Health Emergency Preparedness and Response Authority, the European Centre for Disease Prevention and Control and the European Medicines Agency. The Internal Audit Service did not identify any critical or very important weaknesses.
6. Information security and technology
In view of generally heightened security concerns, legal obligations, Member States’ expectations, new user requirements, and a corporate approach to information management, the Commission established in 2019 a corporate information security strategy. This strategy complements the Commission’s Data, Information and Knowledge Management strategy, the Digital strategy, and the information technology security strategy. Furthermore, the Commission adopted, in 2022, a proposal for a Regulation of the European Parliament and of the Council on common information security rules for all Union institutions, bodies, offices and agencies, and a proposal for a Regulation of the European Parliament and of the Council laying down measures for a high common level of cybersecurity at the institutions, bodies, offices and agencies of the Union which, following the interinstitutional negotiations, was adopted by the co-legislators in December 2023, and entered into force in January 2024.
The Internal Audit Service conducted four audits on information security and technology in 2023. These audits identified a number of areas requiring further improvement (10 out of a total of 52 very important recommendations issued in 2023).
1. The Commission is exposed to high inherent information security risks, including the risk to confidentiality of information. New information security risks have been emerging in recent years as more information is handled electronically. To address these risks, effective controls should be in place to ensure that, the information is categorised in line with its sensitivity and is handled according to its categorisation level to protect confidentiality. The audit on protection of confidentiality of information covered the three key actors at corporate level responsible for information security - the Directorate-General for Human Resources and Security, the Directorate-General for Digital Services and the Secretariat-General. It concluded that the Commission has progressed in putting in place an adequate corporate framework and effective corporate controls, including effective risk management to protect the confidentiality of information. The audit identified additional actions required at corporate level to support more effectively the Commission services in their responsibility to protect the confidentiality of information concerning external service providers, information technology controls, and the process for managing information security incidents.
2. The Internal Audit Service conducted an audit in the Directorate-General for Competition on Case Management Rationalisation (CASE@EC). This is the flagship of the Commission’s information systems rationalisation exercise project under this DG’s lead. The audit concluded that although the Directorate General for Competition has made progress in designing and implementing governance and internal control processes for the CASE@EC project, there is a need for further improvement in the way in which certain information technology security controls have been designed, applied or documented. In this context, the Internal Audit Service identified two very important issues.
3. The EU’s emissions trading system (EU ETS) is a cornerstone of the EU’s policy to combat climate change and its key tool for reducing greenhouse gas emissions in a cost-effective manner. It is the world’s first major carbon market and remains the biggest one, managed by the Directorate-General for Climate Action and a third party. The Directorate-General for Digital Services is one of several system suppliers, and provides standardised information technology services, including some security services. The Internal Audit Service conducted a limited review of the security plan and associated security measures of the EU ETS information system managed by the Directorate-General for Climate Action. While the security processes of the EU ETS information system had gradually become more mature, further improvement is required in their design and effectiveness. The audit identified two very important issues in the design of the 2022 information technology security plan for the EU ETS information system and the governance framework for its implementation. Since 2010, the Directorate-General for Climate Action has issued a reservation every year in its annual activity reports on reputational, legal, and financial grounds related to security risks identified in relation to the Union Registry under EU ETS.
14. Another audit was conducted on the management of information technology security in the Directorate-General for Education, Youth, Sport and Culture concerning the control system to manage the security of the information technology systems. The audit concluded that there is a need for further improvement in its effective implementation. It identified inconsistencies in data classification between the information technology security plan for the indirect grant management platform and its business impact assessment conclusion.
7. Other processes
Three audits assessed performance aspects within other processes on:
1. corporate communication in the Directorate-General for Communication;
2. human resources management in the Directorate-General for Competition;
The two audits did not reveal critical or very important weaknesses in the control systems.
3. large-scale building projects involving works in the Office for Infrastructure and Logistics in Brussels and the Office for Infrastructure and Logistics in Luxembourg.
The Internal Audit Service acknowledged the challenges faced by the two offices, mainly that they need to manage a wide client base with different needs and the fact that they are operating in a dynamic and competitive real-estate market as well as in a complex and changing legal frameworks. The audit concluded that although the offices had, overall, designed and effectively implemented an adequate framework for the management of large-scale building projects, there remained a need for further improvement in its efficiency, including the extent to which the procurement procedures are sufficiently documented, transparent and competitive.
2. Internal Audit Service limited conclusions
The Internal Audit Service issued limited conclusions on the state of internal control to all Commission’s Directorates-General and services (18) in February 2024. These limited conclusions contributed to the 2023 annual activity reports of the Directorates-General and services concerned. Drawing on the audit work carried out in the last five years, they cover all open recommendations issued. The Internal Audit Service’s conclusion on the state of internal control is limited to the management and control systems that were audited. It does not cover systems not audited by the Internal Audit Service in the past five years.
3. Overall opinion on the Commission’s financial management
As required by its mission charter, the Internal Audit Service issues an annual overall opinion on the Commission’s financial management. This is based on the audit work in the area of financial management in the Commission carried out by the Internal Audit Service during the past three years (2021 to 2023). It also takes into account information from other sources, namely the reports of the European Court of Auditors. The overall opinion is issued at the same time as this report and covers the same year.
Based on this audit information, the internal auditor considered that, in 2023, the Commission had put in place governance, risk management and internal control procedures which, taken as a whole, are adequate to give reasonable assurance over the achievement of its financial objectives. However, the overall opinion is qualified with regard to the reservations the authorising officers by delegation made in their declarations of assurance issued in their respective annual activity reports.
In arriving at the overall opinion, the Internal Audit Service also considered the combined impact of all amounts estimated to be at risk at payment as these go beyond the amounts put under reservation. The overall amounts at risk at payment are the best estimation of the authorising officers by delegation of the amount of the expenditure authorised not in conformity with the applicable contractual and regulatory provisions at the time of the payment in 2023. In their annual activity reports, Directorates-General and services estimate amounts at risk at payment to total between EUR 2 742.5 million and EUR 3 291.5 million approximately. This corresponds to between 1.6% and 1.9% of total relevant expenditure (19) from the Commission budget, European Development Fund and EU Trust Funds in 2023 and therefore below the materiality of 2% as defined in the instructions for the preparation of the 2023 annual activity reports.
These amounts at risk at payment in 2023 do not yet take into account any financial corrections and recoveries related to deficiencies and errors which the Directorates-General and services will detect and correct in the future due to the multi-annual corrective mechanisms built into the Commission’s internal control systems.
Given these elements, the Internal Audit Service considers that the EU budget is therefore adequately protected in total and over time.
Without further qualifying the overall opinion, the Internal Audit Service drew the attention of the Commission to the need to build on the lessons from managing its financial resources in a challenging context.
The response to challenges over the past few years has underlined the strengths and flexibility of the EU budget and NextGenerationEU to react to crises. However, new high risks that may affect assurance and performance have arisen due to the fast-paced and volatile environment, where responding to crises is becoming the norm, coupled with the unprecedented amounts mobilised, the creation of innovative and complex instruments and new approaches to existing programmes.
To ensure that the budget is duly protected over time, it is important to keep the focus on measures to mitigate these risks. In addition to collaboration with Member States and with third parties, areas that will continue to require particular attention include performance-based programmes and financial instruments. This is against a backdrop of extraordinary pressure on human resources, already identified within the Commission as a crosscutting risk, which makes the achievement of policy and financial management objectives even more challenging.
Furthermore, the Commission needs to ensure that adequate governance, risk management and internal control arrangements are designed for the programmes and instruments conceived for the next Multiannual Financial Framework.
The Internal Audit Service will continue to monitor the impact of the risks on the soundness of the Commission’s financial management.
5. Consultation with the Commission’s financial irregularities panel
No systemic problems were reported in 2023 by the panel set up pursuant to Article 143 of the Financial Regulation (20), where it gives the opinion referred to in Article 93 of the Financial Regulation.
1
()The report does not cover the European Peace Facility, decentralised European agencies, the European External Action Service or other autonomous bodies audited by the Internal Audit Service, which receive separate reports.
2
()Regulation (EU, Euratom) 2018/1046 of the European Parliament and of the Council of 18 July 2018 on the financial rules applicable to the general budget of the Union, amending Regulations (EU) No 1296/2013, (EU) No 1301/2013, (EU) No 1303/2013, (EU) No 1304/2013, (EU) No 1309/2013, (EU) No 1316/2013, (EU) No 223/2014, (EU) No 283/2014, and Decision No 541/2014/EU and repealing Regulation (EU, Euratom) No 966/2012OJ L 193, 30.7.2018, Amending Regulation 2022/2434 (EU, Euratom).
3
()The audit reports finalised from 1 February 2023 to 31 January 2024 are included in this report.
4
()Communication to the Commission, Mission Charter of the Internal Audit Service of the European Commission, C(2022)8450 final of 28 November 2022.
5
()For details, see Communication to the Commission, Charter of the Audit Progress Committee of the European Commission, C(2020) 1165 final of 27 February 2020.
6
()The Internal Audit Service’s audit universe covers 50 organisational entities in total. For some of these entities, more than one final audit, review or consulting report was issued in 2023. See the staff working document accompanying this report for a detailed overview of entities for which final audit and review reports were issued.
7
()0ne engagement was carried over from the 2023 audit plan to the 2024 audit plan – Audit on anti-fraud strategy in the Directorates-General for International Partnerships, Neighbourhood and Enlargement Negotiations, European Civil Protection and Humanitarian Aid Operations, the Service for Foreign Policy Instruments, and the European External Action Service.
8
()Some audit engagements were followed-up more than once and some follow-up notes covered more than one audit engagement.
9
()The list of audits closed after a follow-up is included in section 2.2 of the Annex.
10
()This refers to audits that span multiple Commission Directorates-General and/or services (multi-DG audits) or audits conducted in Commission Directorates-General/services and in the decentralised agencies or other autonomous bodies (multi-entity audits).
11
()Out of 795 recommendations issued in 2019-2023, 789 recommendations were fully accepted, two were partially accepted and four were rejected.
12
()The chart shows the rating of the recommendations at the cut-off date. This may differ from the rating in the original audit report because, in the context of a follow-up audit, the Internal Audit Service may assess that the actions taken by the auditee partly mitigated the risks initially identified and the rating of the recommendation was therefore downgraded.
13
()In total, the Internal Audit Service carried out 32 performance and comprehensive audit engagements and engagements with some performance aspects (limited reviews and financial/compliance audits). For more details see the Annex.
14
() 10 out of a total of 52 very important recommendations issued in 2023 (19%).
15
()In the external action domain, ‘interventions’ are all activities implemented or funded to achieve policy objectives, such as an individual project or a budget support operation.
16
()28 out of a total of 52 very important recommendations issued in 2023 (54%).
17
()European Monitoring Centre for Drugs and Drug Addiction; European Union Agency for Asylum; European Union Agency for Law Enforcement Cooperation; European Union Agency for Law Enforcement Training; and European Union Agency for the Operational Management of Large-Scale IT Systems in the Area of Freedom, Security and Justice.
18
()No audits were carried out in the advisory service Inspire, Debate, Engage and Accelerate Action during the 2019-2023 period, as no high risks were identified, and therefore no limited conclusion was provided.
19
()Relevant expenditure means the total amount of payments made in 2023 minus the total amount of new pre-financing paid in 2023 plus the total amount of old pre-financing cleared in 2023 as reported by the Commission services in their 2023 annual activity reports.
20
()Since the entry into force of the 2018 Financial Regulation the functions of all institutions’ financial irregularities panel have been transferred to the Early Detection and Exclusion System Panel referred to in Article 143 of the Financial Regulation.
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