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On May 31, 2026, the European Union (EU) Directive 2026/1021, “On combatting corruption,” (the “Directive”) entered into force, becoming the first-ever EU-wide criminal law framework on corruption. The Directive harmonizes and replaces previous EU anti-corruption laws, such as the 1997 Convention “On the fight against corruption involving EU and Member States officials” and the 2003 Council Framework Decision “On combating corruption in the private sector,” and amends the 2017 Directive “On the fight against fraud to the Union’s financial interests by means of criminal law.”
The Directive had a long road to passage. The European Commission put forward a Joint Communication in May 2023 laying out its intention to modernize corruption rules across the bloc. Following two years of negotiation, the European Council and European Parliament reached political agreement on the final text in December 2025. Parliament formally adopted the Directive in March 2026, and the Council gave final approval the following month. Member states now have until June 1, 2028 to transpose most provisions into national law, with an exception until 2029 for certain provisions related to the prevention of corruption.
According to the European Council, the Directive has three main functions:
- Introducing common definitions for corruption offenses, including bribery in the public and private sectors, misappropriation, trading in influence, obstruction of justice, enrichment from corruption offences, concealment and certain serious violations of unlawful exercise of public functions;
- Establishing common minimum penalties for corruption for both individuals and companies; and
- Aligning EU law with international standards, such as the United Nations Convention Against Corruption (UNCAC), into EU law.
Impact on Companies
In terms of penalties, the Directive specifies that companies involved in corruption offences may face fines ranging from three to five percent of their total worldwide turnover, or from €24 to €40 million, depending on the offence. Legal entities can be held liable where a failure of supervision or control by leadership enabled an offense. Notably, an effective compliance program is treated as a mitigating factor at sentencing, though not a full defense.
While there is significant overlap with the Directive, companies currently operating under Sapin II, the UK Bribery Act, or the FCPA should carefully study the Directive before the 2028 deadline. Organizations should benchmark their existing compliance programs, due diligence approaches and operations across all jurisdictions. Not all of the defined offenses have exact equivalents in the current laws of every EU member state. Turnover-based penalties and expanded jurisdictional reach mean even non-EU headquartered companies with business in the EU could fall into scope. Compliance officers should track national implementing legislation closely, as member states retain discretion to go further than the floor the Directive sets, so some rules may still vary by jurisdiction even after harmonization.
The Directive also reflects the EU’s broader focus on strengthening anti-corruption enforcement and corporate accountability, reinforcing the importance of maintaining robust, globally consistent compliance programs.
To help compliance leaders prepare, Ethixbase360 will be hosting a webinar this fall examining the Directive, key implementation considerations and the practical steps organizations can take ahead of the 2028 deadline.