Pursuing Recoveries and Preventing Reoccurrence - Final Report of the Covid Counter Fraud Commissioner

9th December 2025

The report is written by the Covid Counter Fraud Commissioner, appointed in December 2024 to lead a government-wide review of fraud and error in spending related to COVID-19 pandemic.

Its purpose is to assess how much government has recovered so far, identify where further recoveries are possible, examine flawed contracts and payments, and draw out lessons and reforms to prevent similar fraud in future crises.

The focus is on fraud and error, i.e. dishonest claims or mistakes leading to incorrect payments or contracts, rather than on broad political issues such as corruption or "cronyism" (which are explicitly excluded from scope unless linked to underlying fraud).

Key findings

The pandemic response involved extraordinary and urgent decisions, including rapid procurement (e.g. of PPE), grant and loan schemes (for businesses, furlough, etc.), many administered via new or scaled-up delivery systems — but often with poor or absent safeguards against fraud or error.

The urgency and scale of spending meant many public bodies were unprepared for fraud risk; existing controls proved inadequate in some cases.

That said — significant recovery work has already been done:

For example, one department cancelled £0.7 billion of PPE orders after recognising over-ordering.

Efforts such as loan-scheme oversight, repayment schemes, and enforcement have led to some repayments — but only a fraction of the total estimated losses have been recovered to date.

The report estimates that out of roughly £10.9 billion lost to COVID-19 fraud and error, only £1.8 billion has been formally recovered.

There remains substantial scope to recover further sums, and many areas (departments, contract categories) where recovery work is incomplete or inconsistent.
GOV.UK

Lessons learnt

The report draws several systemic lessons from how fraud and error manifested during the pandemic — key ones include:

Fraud prevention was not sufficiently embedded in emergency planning — crisis decision-making often overlooked fraud risk.

Large, ambitious programmes delivered rapidly are intrinsically risky and need built-in challenge and controls, including risk assessments and "clean-up cost" allowances.

Crisis responses tend to assume goodwill and common purpose — but that may mask varying standards or incentives across departments. To avoid this, the government should incentivise proactive fraud prevention and reward recoveries.

Good data collection, transparency, and cross-departmental collaboration are essential — especially when working with unknown or new suppliers/recipients.

Main recommendations

The report sets out a number of general and department-specific proposals to strengthen fraud prevention and recovery for future crises:

Embed fraud-control as a core element of crisis preparedness and digital/data-sharing infrastructure — including better transparency over grants, contracts, beneficial ownership, and public-fund flows.

Update processes so that risk assessments — including potential fraud/abuse — are mandatory before emergency programmes are approved; incorporate "challenge champions" and fixed allowances for mitigation/recovery costs.

Give departments a share of recovered funds (or similar incentive) to encourage proactive recovery effort.

Strengthen legislation: the report notes support for the Public Authorities (Fraud, Error and Recovery) Bill (PAFER), which — once law — will extend the period during which action against COVID-19 fraud can be taken; and recommends a permanent, cross-government counter-fraud agency and enforcement function for future crises.

Establish a formal, ongoing oversight panel (chaired by a senior minister, with external members) to monitor implementation of recommendations, review progress, and maintain accountability for at least two years.
GOV.UK

Context & Scope — What the report doesn't do

The report does not attempt to assess whether COVID-19 support measures in general were justified, effective, or proportionate. Its remit is restricted to fraud and error in related spending.

It does not investigate alleged corruption or "cronyism" in procurement, unless there is clear evidence of fraud.

Cases that have already been referred for criminal investigation or civil litigation are excluded to avoid interference; the report instead summarises counts and status.

Headline Figures
stimated total cost to public finances from COVID-related fraud and error ~ £10.9 billion

Amount formally recovered so far
£1.8 billion

Proportion of losses recovered
16-17% (1.8 / 10.9)

Remaining estimated unrecovered losses
£9.1 billion (i.e. after recovery)

Number of major schemes or contract-sets vulnerable to fraud identified
Many — including rapid-procurement of PPE, grants, loans, furlough, business-support and other emergency schemes.

Time allowed for government action under new proposed legislation
Up to 12 years to bring action on COVID-era frauds under the Public Authorities (Fraud, Error and Recovery) Act 2025.

Read the full report HERE