What do organisations need to prepare for ahead of the EU Anti-Corruption Directive's 2028 transposition deadline?

The EU Anti-Corruption Directive (Directive 2026/1021) entered into force on 31 May 2026 and establishes the first EU-wide criminal law framework on corruption. Member states have until 2028 to transpose most of its provisions into national law, but the compliance preparation window is now. The Directive introduces common definitions for corruption offences, minimum penalties (including fines of 3-5% of worldwide turnover or €24-40 million), and -- critically -- makes the adequacy of a company's compliance programme a mitigating factor in sentencing. Organisations should benchmark their current compliance programmes against the Directive's defined offence categories, review third-party due diligence processes, and assess their exposure to turnover-based penalties ahead of transposition.

What does France's first Sapin II financial penalty signal about expectations for corporate anti-corruption programmes?

In July 2026, France's Sanctions Committee issued its first-ever financial penalty under Sapin II -- €350,000 against an unnamed company and €60,000 personally against its legal representative, following an AFA audit that found deficiencies in risk mapping, third-party due diligence, training, and controls. The landmark decision signals that France's enforcement of corporate anti-corruption programme obligations has moved from potential to actual. Three points are critical: first, Sapin II requires no underlying act of bribery -- a company can be sanctioned for an inadequate prevention programme alone; second, the relevant date for compliance assessment is the date of the final AFA control report, not later proceedings; third, remediation after the audit is taken into account only when determining sanction amount, not whether a sanction is issued. Companies currently under or anticipating an AFA audit should treat the control period itself as the window to act.

What do the latest enforcement and legislative developments mean for UK anti-corruption compliance?

The UK's Economic Crime and Corporate Transparency Act (ECCTA) introduced the Failure to Prevent Fraud offence (in force 1 September 2025) and broadened corporate attribution to a senior manager test, expanding the range of individuals whose conduct can be attributed to the company. The SFO has signalled its intention to make active use of the new offence. As with the UK Bribery Act's adequate procedures defence, the reasonable procedures requirement places the compliance programme at the centre of any legal analysis. UK organisations should assess whether their anti-fraud and anti-corruption controls satisfy the reasonable procedures standard under the scrutiny of the new senior manager attribution test.

What does the growing regulatory focus on compliance programme adequacy and effectiveness mean in practice?

Regulators across Europe are moving from asking whether a compliance programme exists to asking whether it works. The EU Directive makes compliance programme adequacy a sentencing factor. France's first Sapin II penalty was specifically triggered by deficiencies in risk mapping, due diligence, training, and controls -- not by a bribery incident. The UK's ECCTA places reasonable procedures as the primary defence. Germany's proposed OWiG reforms would formally codify compliance programme quality as a factor in corporate sanction decisions for the first time. This convergence means that a compliance programme that describes policies without demonstrating how they operate, how they are tested, and how they are refreshed is increasingly insufficient across multiple European jurisdictions simultaneously.

What are the implications for third-party due diligence, risk assessment, controls and corporate governance?

Third-party due diligence is the most frequently cited deficiency in European anti-corruption enforcement actions. France's first Sapin II penalty specifically identified third-party due diligence deficiencies. The EU Directive's compliance programme mitigating factor requires that due diligence be genuinely risk-based and documented -- not a one-time onboarding check. For corporate governance, the Directive's liability framework and the ECCTA senior manager test together increase the personal exposure of board members and senior executives who oversee compliance functions. Governance structures should ensure that compliance programme oversight reaches board level and that third-party risk is reported at a senior enough level for genuine accountability.

What practical steps can organisations take now to strengthen their anti-corruption compliance programmes across European jurisdictions?

Key practical steps for multinational organisations ahead of the EU Directive's 2028 transposition deadline: benchmark your existing compliance programme against the Directive's defined offence categories to identify gaps before national transposition determines the enforcement standard; review third-party due diligence processes against the specific deficiencies that triggered France's first Sapin II financial penalty (risk mapping, due diligence, training, controls); assess your exposure to turnover-based penalties under the Directive; examine whether governance arrangements provide the board-level oversight that regulators now expect; and monitor national transposition developments in your key EU jurisdictions, since member states retain discretion to go beyond the Directive's minimum floor. In the UK, review whether anti-fraud and anti-corruption controls satisfy the ECCTA reasonable procedures standard under the new senior manager attribution test.

Home » Resources » The Future of Anti-Corruption Compliance in Europe: Preparing for the EU Directive and Beyond

The Future of Anti-Corruption Compliance in Europe: Preparing for the EU Directive and Beyond

Ethixbase360
September 30, 2026

Europe’s anti-corruption landscape is entering a new phase. The EU Anti-Corruption Directive establishes the first EU-wide criminal law framework on corruption, introducing common definitions and minimum penalties and creating potentially significant implications for corporate liability. Member states have until 2028 to transpose most of its provisions, but developments across Europe already point to a broader shift toward greater corporate accountability and increased scrutiny of the effectiveness of compliance programmes.

At the national level, enforcement is also evolving. France has issued its first financial penalty under Sapin II for deficiencies in a corporate anti-corruption programme, Germany is considering reforms that would significantly increase potential corporate fines, and the UK continues to strengthen its corporate crime framework, including through the Failure to Prevent Fraud offence.

The webinar will bring together senior compliance and legal practitioners to examine how these developments are changing expectations for multinational organisations and what they mean in practice for compliance leaders preparing for the next phase of anti-corruption enforcement.

Topics will include:

The EU Anti-Corruption Directive and what organisations should be preparing for ahead of the 2028 transposition deadline
Recent enforcement and legislative developments across key European jurisdictions, with a particular focus on France and the UK
Recent developments under Sapin II and what they signal about expectations for corporate anti-corruption programmes in France
The growing focus on the adequacy and effectiveness of corporate compliance programmes
Implications for third-party due diligence, risk assessment, controls and corporate governance
Practical steps organisations can take now to strengthen their compliance programmes across jurisdictions

Join us to hear from leading legal and compliance practitioners on what Europe’s evolving anti-corruption landscape means in practice and the steps organisations can take now to prepare for what comes next. Register today to reserve your place.

Speakers:

Anna Romberg, Executive Vice President, Sustainability, Legal & Compliance, Getinge
Daphné Latour, Avocate associée, DL Avocats
Nicholas Querée, Partner, Addleshaw Goddard LLP
Virna Di Palma, Head of Global Content & Brand, Ethixbase360 – Moderator

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