Introduction

Member of GRECO since 2007, Italy has undergone four full evaluation rounds (in 2007, 2009, 2012 and 2016; see in particular, Yearbook 2014, p.182; Yearbook 2015, pp. 168-169; Yearbook 2019, pp. 169), each focusing on a different aspect of the Council of Europe’s anti-corruption framework. The Fifth Evaluation Round, which is now in its compliance phase, aims to assess the effectiveness of the measures adopted by member States to prevent corruption and promote integrity in central Governments (top executive functions) and law enforcement agencies.

As evidence of the need for international scrutiny over anti-corruption measures, Italy ranks  52nd out of 182 monitored countries in the global ranking compiled by Transparency International in its latest report on the perception of corruption worldwide. The picture becomes even more concerning when contextualised within a negative trend that saw Italy drop in 3 years from 41st place to its current 52nd place in terms of corruption perception, following an overall positive decade regarding corruption prevention. This trend has not gone unnoticed by the National Anti-corruption Authority (ANAC), which intervened during the presentation of the Report to highlight critical issues requiring immediate action.

As already seen in the analysis of the 2024 Evaluation Report, following the outline of the situation and the measures in place, GRECO had formulated 19 recommendations to improve the legislative and institutional framework related to the focus of this round. However, for the publication of the First Compliance Report of the Fifth Round on 6 July 2026, GRECO drew a critical assessment on the implementation of these recommendations: out of the 19 addressed to Italy, only one recommendation has been implemented, 13 have been partly implemented and five have not been implemented.  

The fact that emerges immediately is the significant gap, within the executive, between the progress recorded for the personnel and members of the offices of direct collaboration and the almost total lack of implementation of the recommendations concerning the holders of Government posts. A similar picture can also be observed regarding the recommendations addressed to law enforcement agencies where, aside from the substantial improvement regarding the balanced representation of genders, a clear divide emerges between the commitment of the Guardia di Finanza and carabinieri (military corps) and the persistent inaction of the state Police. This picture is fundamental to understanding the actual extent of the actions undertaken by the Italian authorities, especially regarding the 13 partly implemented recommendations. 

Personnel in managerial positions

Starting with the analysis of the recommendations addressed to the executive, a clear gap emerges in the framework related to preventive integrity checks and the systemic analysis of corruption and integrity-related risks. Regarding the verification of the absence of grounds for non-eligibility and incompatibility, the Italian authorities report the formalisation of a three-phase declaratory model for managerial positions within the new Integrated Plan of Activities and Organisation (PIAO) 2026-28 of the Presidency of the Council of Ministers, providing for random checks on 10% of declarants with the aim of overcoming a merely procedural system. Concerning risk analysis, the PIAO has structured a two-tier monitoring system through dedicated digital tools. On a broader scale, ANAC’s National Anti-corruption Plan (PNA) 2025 introduces a comprehensive three-year strategy in line with GRECO’s recommendations, featuring  measurable objectives and indicators. However, the Group criticises the PNA due to a lack of clarity on the applicability of these measures also to members of the offices of direct collaboration of ministers and to holders of Government posts (ministers, undersecretaries, special commissioners). Consequently, in GRECO’s view, recommendations i and i are not implemented to date. 

At the core of the regulatory framework requested by GRECO for the executive, recommendation III envisages the adoption of codes of conduct for persons with top executive functions. In other words, a regulatory framework within which, through the addition of specific guidelines, conflicts of interest, the acceptance of gifts, contacts with third parties, outside activities, and post-employment restrictions are comprehensively regulated. 

In observance of this recommendation, the Italian authorities adopted, by Decree of the President of the Council of Ministers (DPCM) of 13 December 2024, the new Code of Conduct for the Presidency of the Council of Ministers. Whilst GRECO welcomes this publication in light of its extension to personnel serving in offices of direct collaboration, political officeholders remain excluded. This limitation generates a state of consistent partial implementation, which is also reflected in subsequent recommendations.

Indeed, ministers and other political officeholders remain without direct guidance on the management of conflict of interest, an obligation that applies instead to members of the offices of direct collaboration.  This category remains, as already highlighted in the evaluation report, bound only to the less stringent rules on protocol gifts, while in other contexts an effective publication practice is still lacking (recommendation IX). 

The same asymmetry is evident in the rules on "pantouflage" (recommendation X). The prohibition of this practice is now explicitly binding upon members of the offices of direct collaboration and is monitored through a new IT database. Nevertheless, the post-employment regime has not been strengthened for all persons with top executive functions (PTEFs), thus disregarding GRECO’s indications, which reiterates that the 12-month cooling-off period applicable to ministers is too short. This urgent need for legislative intervention was also flagged by ANAC to the Government and Parliament, as noted in the Report. 

The situation differs regarding the rules on accessory activities (recommendation VIII), which GRECO specifically addresses to the personnel of the offices of direct collaboration. In this area, although there is no asymmetry of the type shown thus far,  implementation remains partial. While Article 7(2) of the Code extends the applicability of the authorisation regime for accessory activities to such personnel, the lack of guarantees regarding the publication of the relevant authorisations weakens the final assessment. 

Alongside this internal framework, the Report examines the scope of external interactions and awareness-raising. Regarding transparency, GRECO acknowledges the progress made, assessing recommendation Vas partly implemented concerning the guarantee of general public consultation on Government draft legislation via the “ParteciPa” platform. the Group likewise welcomes the progress in implementing recommendation VI, following the approval in first reading by the Chamber of deputies of the parliamentary bill on the “regulation of institutional relations activity for the representation of interests” (A.C. 2336), noting that this text includes among public decision-makers: members of Parliament, members of the Government, presidents and members of independent authorities, senior officials of public entities and heads of offices of direct collaboration. The potential introduction, upon definitive approval, of rigorous rules on the disclosure of contacts, coupled with a one-year cooling-off period precluding registration as lobbyists, along with an adequate supervision mechanism, would constitute a significant advancement. On the other hand, ANAC President Giuseppe Busia, speaking at the aforementioned presentation of the Transparency International index, highlighted the intrinsic limitations of the bill. While acknowledging the progress, he stressed that greater transparency could be ensured by fully exploiting the new digital tools available.

The divide emerges once again in the area of training. On the one hand, the Anti-Corruption and Transparency Prevention Officer (RPCT) has prepared operational vademecums and training sessions for the personnel of the offices of direct collaboration differentiated by risk profile; on the other hand, there is a persistent lack of similar initiatives for ministers and other political officeholders  (recommendation IV). In any case, the possibility of obtaining, upon request, confidential counselling regarding specific situations remains absent for all PTEFs.

Regarding the extension to all PTEFs of the obligation to declare all their financial interests, potentially including those of family members (recommendation XI), the Italian authorities have reported exclusively operational improvements without, however, responding to GRECO’s indications. The recommendation is therefore considered wholly not implemented, as is the one concerning the imposition of substantive verifications on declarations (recommendation XII). In this case, GRECO, while recognising the potential of measures adopted for verification purposes, recalls that the point raised in the recommendations concerned gaps identified in the activity of the Competition Authority (AGCM), which have not been adequately addressed. 

Concluding the section on the executive, with regard to the sanctions framework (recommendation XIII), there has been no change to the current regulatory framework concerning the existing while insufficient sanctions in the event of breaches of obligations by members of Government. Although the Code of Conduct now extends to members of the offices of direct collaboration the same disciplinary rules applicable to the rest of the personnel of the Presidency of the Council of Ministers, the recommendation is considered only partly implemented. 

Law enforcement agencies

In contrast to what has been stated so far, a cross-cutting success is found within the group of recommendations directed at law enforcement agencies: the reduction of the gender gap regarding representation in recruitment and internal career moves (recommendation XIV). This result must be read by highlighting a relevant methodological aspect: GRECO evaluates the compliance of the results achieved by the three forces based on the effectiveness of the pre-existing framework, rather than on new regulatory provisions.  

In fact, the Italian authorities report across the three police forces substantial improvements in numerical terms of recruitment and career progression in line with the natural maturation of the measures making up the current framework, without having applied any modifications to it. This does not mean that the gap has been filled, but that the measures in place are moving in the right direction.

Asymmetries emerge from the report’s analysis devoted to the implementation of the recommendation relating to the ethical and preventive infrastructure(recommendations XV, xvi, xvii). The report highlights a clear divide between the proactivity of military forces (the Carabinieri and the Guardia di Finanza) and the passive stance of the civilian law enforcement agency (the Polizia di Stato). In this regard, the measures adopted by the Guardia di Finanza comply with the recommendation, having adopted a new Code of Ethics in 2025, supported by a database containing practical examples related to their duties. This includes a direct intranet channel through which personnel can submit questions regarding ethical issues. Subsequently, GRECO positively evaluates the actions of the Carabinieri regarding ethical counselling mechanisms and the creation of a new FAQ section on the intranet, while suspending judgment on the work towards a new code of ethics pending its concrete implementation. Conversely, the absence of a similar code and independent counselling services within the structure of the State Police makes the assessment inevitably negative.

The same picture applies to personnel management and integrity checks related to promotions and transfers (recommendation XVIII). On the one hand, GRECO considers the level of integrity checks in the military forces to be satisfactory and appreciates the policies and obligations linked to the prohibition of territorial entrenchment during the first year of service, even though new instruments such as the obligation to periodically declare potential incompatibilities have not been introduced. On the other hand, the Group judges the measures currently in force for the state police to be entirely insufficient. 

Finally, with respect to the whistleblower protection, a further divide is noted in the field of training. The provision of specific modules delivered in direct collaboration with ANAC at the academies and inspector schools of the Carabinieri and Guardia di Finanza was evaluated positively, a result that clashes with the lack of implementation of the e-learning activities planned by the State Police, which are still pending delivery.

Conclusion

The picture that emerges from the First Compliance Report of the Fifth Evaluation Round is that of a country moving at two different speeds when it comes to implementing anti-corruption measures. 

As regards the central government, against the backdrop of generally encouraging interventions that have particularly involved the offices of direct collaboration, there is an insufficiency and in some cases a complete absence measures the recommendations addressed to holders of Government posts. 

The same division emerged among law enforcement agencies, where the actions undertaken by the military forces are countered by the immobility of the State Police in almost all of the recommendations.

In light of this, GRECO is calling on Italy to make substantial progress over the next 18 months in order to successfully conclude the Fifth Evaluation Round.