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EU Anti-Corruption Directive Tracker
A new baseline for Anti-Bribery and Corruption (ABAC) compliance
Summary of EU Anti-Corruption Directive
- Harmonised EU baseline: The new directive establishes minimum anti-corruption standards across Member States. Swiss companies with EU operations must track how each country implements it into national law.
- Tougher penalties: Sanctions for corruption are now aligned with EU competition law and GDPR levels, requiring organisations to reassess their compliance frameworks.
- Six key changes: Corporate liability, "leading position" definitions, trading in influence, penalties, jurisdictional reach, and standards are all being reformed.
- Action needed now: Swiss businesses should map EU touchpoints, prioritise high-risk sectors, review intermediaries, and align ABAC policies with emerging EU standards.
A new EU anti-corruption baseline is emerging
We have developed an overview of the implementation status across EU Member States to help Swiss businesses understand where legislative developments are taking place and assess the potential implications for their European operations.
The EU is moving towards a more harmonised anti-corruption framework. The new directive is intended to establish minimum standards across Member States, while allowing individual countries to adopt or retain more stringent national rules.
For businesses, this means the compliance challenge will not be limited to understanding the directive itself. The more practical challenge will be tracking how each Member State implements the requirements into national law, where local regimes go further, and how quickly enforcement expectations evolve. One of the key changes is leveling up the sanctions resulting from corruption infringements to the EU level of the competition law and GDPR. As a consequence, organisations will have to revisit their risk assessments and take measures thereof.
This matters for any organisation with an EU connection. That may include businesses operating in the EU, selling into EU markets, working with EU-based counterparties, supporting EU activity through digital infrastructure, or participating in high-risk and government-adjacent sectors such as defence, infrastructure, energy, healthcare and regulated supply chains.
What is changing under the directive?
The directive is expected to raise the minimum anti-corruption baseline across the EU. Businesses should focus first on the areas where existing ABAC frameworks may need to change.
Key actions for Swiss-based businesses now
Swiss-headquartered businesses should use the EU transposition period to assess where EU anti-corruption reforms may affect their group operations, commercial relationships and compliance framework. The key question is not only whether the Swiss parent is directly in scope, but whether the group has EU-linked activity that could create legal, regulatory or commercial exposure.
What Swiss-based businesses should do now
How ready is your organisation?
- Do you know which EU Member States are most relevant to your business?
- Have you identified employees who may fall within the expanded “leading position” concept?
- Have you reviewed lobbyist, consultant and intermediary arrangements?
- Can you evidence that your ABAC programme operates effectively in practice?
- Have you assessed whether EU-linked digital infrastructure creates additional exposure?
- Are your M&A due diligence procedures calibrated to longer lookback periods?
