Over time, the several applications of the integrity pact across different EU countries increasingly attracted the interest of the European Commission for its potential use in mitigating corruption risks when implementing EU-funded projects. Compared to the traditional “control and audit” approach, integrity pacts (IPs), with their preventive and collaborative approach, offer a viable alternative, contribute to a better return on investments, and a greater likelihood that EU-funded projects are completed successfully and achieve the sought-for regional development impacts.

In 2014, the European Commission, through the Directorate General for Regional and Urban Policy (DG REGIO), and Transparency International partnered up on a project to pilot the use of integrity pacts to monitor EU-funded projects for the programming period 2014-2020. The programme targeted eleven Member States with relevant risks of corruption and fraud in the spending of EU Funds: Bulgaria, Czechia, Greece, Hungary, Italy, Latvia, Lithuania, Poland, Portugal, Romania, and Slovenia.

The programme was divided into two phases. The preparatory phase ran through 2015 and involved knowledge sharing on the tool among stakeholders in different countries and an application and selection process for procurement projects to be monitored. In May 2015, DG REGIO published two calls for expression of interest - one for managing authorities (national authorities managing EU funds) willing to pilot the tool in upcoming projects, and the other for civil society organisations (CSOs) interested in serving as monitors.

Received expressions of interest by managing authorities and CSOs were assessed and shortlisted by an evaluation committee against the criteria set in the calls. In the end, 15 CSOs (10 of them Transparency International chapters) were selected to participate in the project.

The second phase started in January 2016 and involved IP implementation on 19 contracting projects worth over €920 million across a wide range of policy areas and sectors.

IP implementation took place through different stages. In the preparatory stage, MAs, CSOs, and contracting authorities (CAs) destined to receive EU funding worked together to define and agree on the terms of the IP and adapt its provisions to the national context. In the second stage, the parties designed the IP monitoring activities and signed the Memoranda of Understanding. In the third stage, CSOs monitored all the stages of the different procurement procedures associated with a specific contracting project, from pre-tendering up to the contract execution phase.

The objectives of IP implementation were not limited to fostering the transparency and accountability of the contracting projects – they also aimed to improve the value for money of the contracts, foster business integrity and fair competition among bidders and contractors, and engage affected communities through sustained dissemination, promotion, outreach, and advocacy activities at the national, regional, and international level. The monitoring costs and supporting activities to achieve these goals were entirely covered by DG REGIO.

Monitoring on the project was concluded at the end of 2021. By then, CSOs had monitored a total of 52 public contracting procedures, 35 of them resulting in the award of a contract, provided 768 recommendations, and produced around 90 monitoring reports.

Overall, the application of the integrity pacts has had multiple benefits on public contracting projects. In most cases, the monitoring activities improved the procurement process's governance, as seen in better contracting strategies, higher-quality tender documentation, increased transparency, and mitigation of risks in the execution phase. In some cases, they also contributed to identifying irregularities and their resolution through a constructive approach.

In terms of stakeholder engagement, some IPs were found to have contributed to increased affected communities’ involvement in the procurement process and better outreach to the general public by the CAs, as well as increased dedication to business integrity and fair competition by bidders and contractors. At a more general level, implementers gathered insights on problems affecting public procurement systems in the concerned countries, in some cases leading to reform of laws and regulations.

At the same time, CSOs faced some challenges. Several projects were affected by delays, often due to governance problems within the CAs, and this meant that some partners could not monitor the procurement procedures until the end. In some cases, monitoring activities were hindered by legal provisions that did not allow monitors to fully access the decision-making process. In other instances, partners observed a lack of commitment by some of the CAs in upholding the provisions of the IPs.

Other challenges stemmed from the specific characteristics of the projects selected for the pilots. Some of them, especially those related to administrative capacity, turned out to be too technical or not visible or tangible enough to raise sufficient interest and engagement from affected communities. In other cases, such as Latvia, the projects faced public opposition due to unclear benefits. This not only complicated the monitor's work but also caused misunderstanding about their role by the public and the media.

Towards the end of the project, the COVID-19 pandemic also disrupted the monitoring activities, causing significant delays in the implementation of the project and cancellation or online rescheduling of several citizen engagement activities, including on-site visits, training, and public events.

Despite such challenges, the pilot project largely achieved its core objectives of fostering integrity, transparency, and accountability in the monitored projects and extracting important learnings for more strategic and systematic future use of the IP tool in EU-funded projects. There is now greater awareness of the integrity pact among and beyond the countries that have taken part in the pilot, and the project contributed to the generation of substantial knowledge and learning on IPs, as well as to the creation of a network of experienced experts on integrity in public procurement.