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ARTICLE · 20 JULY 2026

The EU Anti-Corruption Directive: A New Framework For Businesses Operating In The EU

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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With a transposition deadline of 1 June 2028, companies should map exposure against the new offence categories, update anti-bribery policies and strengthen internal investigation capabilities...

GermanyCriminal Law

On 29 April 2026, the European Parliament and the Council of the EU adopted Directive (EU) 2026/1021 on combatting corruption (the Directive), which entered into force on 31 May 2026. The Directive establishes minimum rules on the definition of corruption offences and penalties, and introduces a range of preventive and enforcement measures aimed at creating a more consistent EU-wide approach to tackling corruption. Thus, it replaces two existing instruments: the 2003 Framework Decision on corruption in the private sector and the 1997 EU Convention on the fight against corruption involving officials.

The Directive forms part of a broader shift in EU criminal law towards harmonised sanctions and strengthened enforcement. For Germany in particular, it aligns closely with the proposed reform of corporate sanctions under section 30 of the Administrative Offences Act (Ordnungswidrigkeitengesetz, OWiG), which we covered in our previous insight. 

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