On 29 April 2026, the new Directive No. 2026/1021on combating corruption was adopted. Member States must transpose it into national law by 1 June 2028.
The Directive introduces a common minimum framework for defining corruption offences across the EU. It covers, in particular, bribery in both the public and private sectors, misappropriation, trading in influence, obstruction of justice, enrichment from corruption offences and concealment of proceeds of corruption.
For companies, the tightening of liability of legal persons is particularly important. Liability will not be based solely on the conduct of members of management or persons authorised to act on behalf of the company. The Directive also covers situations where the commission of a corruption offence was made possible by a lack of supervision or control by persons in leading positions.
Sanctions may be significant. For the most serious offences, Member States must make it possible to impose a fine of up to 5% of the worldwide turnover of the legal person or EUR 40 million.
At the same time, the Directive expressly provides that effective internal controls, ethical rules and compliance programmes may be taken into account as a mitigating circumstance when sanctioning legal persons. The same applies to the prompt voluntary reporting of the offence to the competent authorities and the adoption of remedial measures.
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