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July 2026 – Directive (EU) 2026/1021 (the “Directive”) represents the most significant modernization of the European Union's anti-corruption framework in more than two decades. It substantially expands corporate exposure by harmonizing corruption offences, strengthening corporate criminal liability, increasing sanctions, and encouraging more robust compliance programs throughout the European Union.
The Directive provides a clear indication of the European Commission's enforcement priorities and establishes the direction of future anti-corruption enforcement throughout the EU.
Companies operating in Europe should therefore use the transposition period to assess corruption risks, strengthen governance arrangements, and ensure that compliance programs can withstand regulatory scrutiny before the new rules take effect.
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