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EU Anti-Corruption Directive country transposition tracker
Criminal law has traditionally been one of the last bastions of national sovereignty, with EU intervention largely confined to particular sectors and cross-border enforcement. The result has been a fragmented anti-corruption framework: procedural cooperation has steadily developed, including through the establishment of the European Public Prosecutor’s Office for offences affecting the Union’s financial interests, while the substantive criminal law of corruption has continued to differ considerably among Member States.
Directive (EU) 2026/1021 on combatting corruption now seeks to establish a more coherent European baseline. It introduces minimum rules on the definition of corruption offences in both the public and private sectors, the maximum terms of imprisonment available for those offences, sanctions for legal persons, limitation periods and investigative tools. Among its most consequential features for businesses are fines linked to worldwide turnover and the express recognition of effective compliance programmes, voluntary self-reporting and remediation as potential mitigating circumstances. The Directive therefore promises more than cosmetic harmonisation: in several jurisdictions, it will require a substantial recalibration of both criminal liability and corporate exposure.
The Directive entered into force on 31 May 2026 and must, for the most part, be transposed into national law by 1 June 2028. A longer deadline of 1 June 2029 applies to certain obligations concerning national anti-corruption strategies and sectoral risk assessments. The transposition process remains at an early stage in many Member States. This Tracker follows its progress across our EU jurisdictions and highlights the principal features of the existing national regimes, the legislative changes likely to be required and the practical implications for companies.
AUSTRIA
Austria has not yet begun formal transposition of the EU Anti-Corruption Directive, but existing anti-corruption institutions and much of the substantive criminal law framework are already broadly aligned with the Directive. The most significant changes are likely to concern substantially higher corporate fines, potential amendments to corporate criminal liability rules and adjustments to limitation periods, making effective compliance programmes, internal controls and whistleblowing systems increasingly important for businesses.
Austria must implement the Directive’s substantive requirements by 1 June 2028, with prevention, risk assessment and anti-corruption strategy obligations due by 1 June 2029. While extensive institutional reform appears unnecessary, the transposition process may prompt a broader review of Austria’s corporate criminal liability regime, particularly in light of the Directive’s significantly higher sanctions for legal entities.
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BULGARIA
As of September 2026, Bulgaria has not formally commenced transposition of the EU Anti-Corruption Directive and no dedicated implementing legislation has been publicly identified. However, the country has already undertaken significant anti-corruption reform through the 2026 Act on Counteracting Corruption among Persons Holding Public Office, meaning that parts of the Directive’s institutional and preventive requirements are already broadly reflected in the existing framework.
The most significant changes are likely to concern corporate liability and sanctions, as Bulgaria will need to align its regime with the Directive’s substantially higher turnover-based fines and recognise effective compliance programmes, self-disclosure and remediation as mitigating factors. Businesses operating in sectors with significant public-sector interaction, such as construction, healthcare, energy, defence and IT, should closely monitor developments ahead of the 1 June 2028 transposition deadline.
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CROATIA
As of August 2026, Croatia has not yet published any dedicated legislation to transpose the EU Anti-Corruption Directive. However, the country already has a well-established anti-corruption framework, including corporate criminal liability, specialised anti-corruption institutions and limitation periods that appear broadly aligned with many of the Directive’s requirements.
The main areas requiring further assessment are the alignment of corporate sanctions, the treatment of compliance programmes and remediation as mitigating factors and certain definitional and aggravating-circumstance provisions. Businesses operating in public procurement, infrastructure, healthcare and publicly funded projects should monitor developments closely ahead of the 1 June 2028 transposition deadline.
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CZECH REPUBLIC
As of September 2026, the Czech Republic has not yet formally commenced transposition of the EU Anti-Corruption Directive and there is currently no indication that draft implementing legislation is being prepared. While the Czech legal framework already contains established rules on corporate criminal liability and broadly aligns with several of the Directive’s concepts, significant changes are expected in relation to turnover-based corporate fines and the express recognition of compliance programmes, internal controls, whistleblowing systems and remediation measures as mitigating factors.
Further amendments may also be required to limitation periods, although existing interruption mechanisms could reduce the need for legislative change. Businesses active in public procurement, subsidies and concession-based sectors should closely monitor developments ahead of the 1 June 2028 transposition deadline.
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HUNGARY
As of August 2026, Hungary has not yet formally begun transposing the EU Anti-Corruption Directive, and no draft legislation or dedicated government initiative has been announced. Nevertheless, the new government’s stated zero-tolerance approach to corruption, together with the establishment of the National Asset Recovery and Asset Protection Office (NVVH), suggests that the Directive is likely to receive significant attention during the upcoming legislative process.
Hungary’s core anti-corruption framework is already broadly aligned with many of the Directive’s substantive requirements. The principal areas requiring legislative action are likely to include clarification of turnover-based fines for legal entities, the introduction of a standalone offence of enrichment from corruption, expansion of the definitions of “official” and “high-level official”, formal recognition of compliance programmes as mitigating factors and the adoption of additional institutional measures, including a national anti-corruption strategy and sector-specific corruption risk assessments.
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POLAND
As of September 2026, Poland has not yet published any draft legislation to transpose the EU Anti-Corruption Directive. While the existing legal framework for corporate liability and anti-corruption enforcement already addresses many of the Directive’s core concepts, significant amendments will be required, particularly in relation to turnover-based fines for legal entities and the introduction of mitigation mechanisms linked to voluntary disclosure, remedial measures and effective compliance programmes.
The most significant practical impact for businesses is likely to be the prospect of substantially higher financial penalties and increased scrutiny of compliance frameworks, especially in sectors reliant on public procurement, concessions and public funding. By contrast, Poland’s existing limitation periods and institutional anti-corruption framework already appear broadly aligned with the Directive’s requirements.
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ROMANIA
Romania has not yet published dedicated transposition measures, but the Directive is expected to trigger a broad review of the country’s anti-corruption framework, including corporate sanctions, liability of legal entities, whistleblowing arrangements, limitation periods, immunity procedures and prevention mechanisms. Romania already recognises corporate criminal liability and has established anti-corruption institutions, meaning that parts of the existing framework provide a foundation for implementation.
The most significant changes for businesses are likely to be the introduction or adjustment of turnover-based corporate fines, the expansion of ancillary sanctions and the stronger recognition of compliance programmes, self-disclosure and remediation as mitigating factors. Companies operating in sectors involving public procurement, concessions, subsidies and public-service functions should closely monitor developments as Romania assesses the alignment of its current framework with the Directive’s requirements.
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SERBIA
As Serbia is not an EU Member State, it is not required to transpose the EU Anti-Corruption Directive. However, given Serbia’s EU accession objectives and the Directive’s potential extraterritorial implications for businesses operating in the EU market, its requirements are likely to remain relevant for Serbian companies, particularly those that are part of international groups or participate in EU-related business activities.
Serbia’s existing anti-corruption and corporate criminal liability framework already reflects many of the concepts contained in the Directive, including corporate liability, mitigation through voluntary reporting and remediation and specialised anti-corruption institutions. The most significant area of divergence is the sanctions regime, as the Directive’s turnover-based fines substantially exceed current Serbian corporate penalties and would require major legislative changes should Serbia choose to align its framework more closely with EU standards.
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SLOVAK REPUBLIC
As of 31 August 2026, Slovakia has not yet initiated a formal transposition process for the EU Anti-Corruption Directive and no legislative proposal has been made public. However, Slovakia already has an established framework for corporate criminal liability and specialised anti-corruption institutions, meaning that many core elements of the Directive are already reflected in national law.
The most significant changes are likely to concern substantially higher corporate fines – which currently cap at EUR 4 million – and the express recognition of voluntary reporting, remediation measures and effective compliance programmes as mitigating factors. While amendments to limitation periods and institutional arrangements may also be considered, their necessity will need to be assessed during the transposition process ahead of the 1 June 2028 deadline.
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