Combating fraud and counterfeiting of non-cash means of payment

08-12-2017

The IA presents the problem of non-cash payment fraud in a coherent and clear manner. The link between the problem (sub-) drivers, specific and general objectives of the proposal is rather straightforward. The objectives could be more specific and time-bound, however, to bring them in line with the SMART criteria. The IA sets out the content of all options in a clear manner. However, the quality of data, analysis and stakeholder consultation leaves an overall poor impression, partly because the combined IA and evaluation study, which is the external expertise informing the assessment, is not available online and therefore impossible to verify. For instance, according to the IA, the qualitative scores were validated with the focus group participants and external reviewers; however, the results of the validations are not reported in the IA report and only seven stakeholders attended the focus group. Such low attendance is rather surprising, considering that the qualitative assessment was given particular weight when deciding on the preferred option. The IA provides a rather inconsistent synopsis of the three consultation processes and the stakeholders’ contributions are not available online. The IA does not make clear what the stakeholders’ views were on the retained or discarded measures and options. Making the study accessible online could perhaps provide the information needed to understand the logic behind the assessment, the stakeholder consultation and the choice of the preferred option.

The IA presents the problem of non-cash payment fraud in a coherent and clear manner. The link between the problem (sub-) drivers, specific and general objectives of the proposal is rather straightforward. The objectives could be more specific and time-bound, however, to bring them in line with the SMART criteria. The IA sets out the content of all options in a clear manner. However, the quality of data, analysis and stakeholder consultation leaves an overall poor impression, partly because the combined IA and evaluation study, which is the external expertise informing the assessment, is not available online and therefore impossible to verify. For instance, according to the IA, the qualitative scores were validated with the focus group participants and external reviewers; however, the results of the validations are not reported in the IA report and only seven stakeholders attended the focus group. Such low attendance is rather surprising, considering that the qualitative assessment was given particular weight when deciding on the preferred option. The IA provides a rather inconsistent synopsis of the three consultation processes and the stakeholders’ contributions are not available online. The IA does not make clear what the stakeholders’ views were on the retained or discarded measures and options. Making the study accessible online could perhaps provide the information needed to understand the logic behind the assessment, the stakeholder consultation and the choice of the preferred option.