The case, explained

PNRR Corruption Investigation: New Developments and Corporate Liability

5 min read · Updated June 2026 · Editorial oversight: Avv. Federico Papa

The extensive European Public Prosecutor's Office (EPPO) operation concerning alleged PNRR fund fraud reached a turning point with recent investigative developments, clarifying charges of criminal conspiracy aimed at aggravated fraud and money laundering. According to press reports, the investigation launched in 2024 revealed a complex system designed to illicitly obtain over 600 million euros using advanced technology and transnational corporate networks. In this article, we will analyze the legal profiles of this complex case, focusing on the impact of administrative liability for entities. By constructing a didactic "twin case," we will explore the procedural dynamics awaiting those involved, offering an operational guide for professionals called to manage such serious allegations.

In brief

This article examines the 2024 PNRR fraud investigation, updated with recent developments. It explores crimes such as influence peddling and aggravated fraud for public funding, with a focus on Decree 231/2001 (corporate liability). Through a hypothetical "twin case," the analysis illustrates defense strategies, the role of compliance models, and potential trial outcomes within the context of protecting European Union financial interests.

  1. The Fact

    The investigation, known as E-GAP and coordinated by the EPPO, uncovered an alleged fraudulent system aimed at seizing PNRR funds dedicated to business internationalization. According to reports from La Stampa, Open, and Milano Finanza, the core of the accusation lies in creating fictitious tax credits and using shell companies to obtain Simest-managed funding.

    The mechanism, per the prosecution's hypothesis, involved using AI to forge financial statements and the complicity of professionals to facilitate applications via illicit influence. Currently, the case is at the stage of closing preliminary investigations, following 2024 arrests and seizures totaling approximately 600 million euros. The suspects face charges including criminal conspiracy, aggravated fraud, and transnational money laundering, also involving corporate liability for lack of oversight.

  2. Rules at Play

    The legal pillars of this case are:

    1. Art. 346-bis of the Criminal Code (Influence Peddling), punishing those who exploit relationships with public officials for undue economic advantage; this rule was recently narrowed by the Nordio Reform.
    2. Art. 640-bis of the Criminal Code (Aggravated Fraud for Obtaining Public Funds), providing severe penalties for obtaining state or EU grants through deception.
    3. Legislative Decree 231/2001, introducing administrative liability for companies when crimes are committed in their interest or benefit.

  3. Case Law Perspective

    The Court of Cassation has clarified that for corporate liability under Decree 231, the commission of a crime by a senior manager is not sufficient; the prosecution must prove organizational fault, meaning the absence or inadequacy of compliance models designed to prevent fraudulent conduct. Regarding influence peddling, the Joint Sections ruled that mediation is unlawful when aimed at unduly interfering with public administration decision-making.

    Finally, case law confirms that PNRR funds enjoy enhanced protection, as they are equated to the financial interests of the European Union, justifying the broad jurisdictional reach of the EPPO.

  5. Analysis drafted and verified with edit.legal

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  8. Lessons for Professionals

    1. Adopting a 231 Compliance Model is not a mere bureaucratic burden but an essential legal shield.
    2. Due diligence on external consultants is vital: vague contracts with high success fees are clear red flags for investigative authorities.
    3. In EPPO investigations, the defense strategy must focus promptly on remedial actions to prevent preventive seizures and the freezing of business operations.

References: Art. 346-bis c.p.Art. 640-bis c.p.D.Lgs. 231/2001Regolamento UE 2021/241Legge 114/2024 (Riforma Nordio)

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Avv. Federico Papa
Editorial oversight: Avv. Federico Papa·ICAM

Frequently asked questions

What are the penalties for PNRR fund fraud?

For the crime of aggravated fraud to obtain public funding (Art. 640-bis of the Criminal Code), the penalty is imprisonment from two to seven years, in addition to sanctions for the involved entity.

Can a company be acquitted if it lacks a 231 Model?

It is very difficult. Without a suitable organizational model, the entity struggles to prove the absence of so-called organizational fault. Acquittal is only possible if it is proven that the crime was not committed in the interest or for the benefit of the company.

How does the Nordio Reform affect influence peddling?

The reform narrowed the scope of the offense by punishing only the exploitation of existing relationships (no longer merely claimed ones) and requiring that the promised or given benefit be exclusively economic in nature, thus restricting the scope of punishable conduct.

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