This article by Dr Jacopo Costa is one of two Basel Institute commentaries on the EU’s new Anti-Corruption Directive.

While the companion piece examines the directive’s legal and institutional implications, this article takes a political economy perspective. It considers what the directive reveals about changing understandings of corruption, how corruption risks are evolving in an increasingly interconnected and technology-driven environment, and where future EU anti-corruption efforts may need to focus.

The key message is that the directive represents an important advance in legal harmonisation, but that effective anti-corruption policy will also require stronger strategic thinking, greater use of data and technology, and closer attention to emerging corruption risks linked to procurement, border security and financial infrastructure.

In April 2026, the European Union formally adopted Directive 2026/1021 on combatting corruption. Following years of negotiations, political disagreements and institutional bargaining, the EU now has a comprehensive anti-corruption framework establishing common definitions, offences, sanctions and preventive measures across its member states.

This is a landmark achievement. But it would be a mistake to view the directive as the culmination of the European anti-corruption journey.

In fact, its adoption marks the beginning of a much larger challenge: turning a legal framework into an effective EU Anti-Corruption Strategy that can address the evolving forms of corruption emerging in an increasingly complex geopolitical and technological landscape.

Why the directive matters

For years, the EU lacked a coherent anti-corruption framework. Although member states had their own legislation, there were significant differences in how corruption offences were defined, investigated and punished.

These discrepancies created loopholes that could be exploited by corrupt individuals and hindered cross-border cooperation between national authorities.

The new directive aims to address these issues by introducing common minimum standards across the EU. In particular, it:

• harmonises the definitions of bribery in the public and private sectors, trading in influence, misappropriation, obstruction of justice, illicit enrichment and the concealment of criminal proceeds;
• introduces common standards for criminal sanctions, corporate liability, statutes of limitation, whistleblower protection, anti-corruption strategies and specialised anti-corruption bodies; and
• broadens the definition of public officials to encompass not only national officeholders, but also senior EU officials and individuals performing public duties on behalf of public institutions. This reflects the reality of contemporary governance, where public services are increasingly delivered through hybrid public–private arrangements.

It is the most ambitious attempt yet to establish a shared European anti-corruption framework.

A more modern understanding of corruption

One of the directive’s most significant strengths is its recognition that corruption is not confined to the traditional notion of an envelope stuffed with cash being exchanged.

We welcome this change in perspective greatly, because our research demonstrates clearly that contemporary corruption is increasingly networked, sophisticated and relational. It often relies on intermediaries, influence brokers, hidden financial channels, luxury gifts, preferential treatment, future career opportunities and informal exchanges of favours.

Including offences such as trading in influence, illicit enrichment, concealing criminal proceeds and aiding or abetting corruption schemes shows an understanding of how corruption operates in modern societies.

This evolution is important because anti-corruption frameworks often struggle to keep up with the evolving nature of corruption. The directive is a valuable attempt to address this issue and close the resulting gap.

The price of political compromise

Legislation is never produced in isolation from politics. Significant disagreements emerged among EU institutions and member states during the adoption process. Several governments expressed concerns about subsidiarity and the potential consequences of criminalising particular behaviours.

So, the final directive is less ambitious than the original proposal.

One example concerns the offence previously known as “abuse of office”. Following intense political resistance, particularly from countries such as Germany and Italy, the final text replaced it with the more cautious formulation of “unlawful exercise of public functions”. The compromise facilitated agreement, but introduced ambiguity that could hinder enforcement.

Similarly, criminal sanctions and limitation periods were reduced during negotiations. Maximum prison sentences were reduced, and statutes of limitation were scaled back considerably compared to earlier drafts.

These compromises highlight a recurring dilemma in policymaking not only in Europe but everywhere: achieving consensus often necessitates compromising on ambition. The result is a directive that establishes a common baseline, yet leaves considerable room for interpretation among member states.

The missing security lens

Perhaps the most significant limitation of the directive is its relatively little guidance on what anti-corruption efforts should look like in today’s rapidly changing security environment.

Because corruption is increasingly also a geopolitical and security issue. Foreign influence operations, sanctions evasion schemes, strategic corruption, illicit financial networks, organised crime infiltration and the manipulation of critical supply chains all represent corruption-related risks affecting European security and resilience.

Yet these challenges remain largely outside the directive’s core focus. There is a risk that anti-corruption efforts will continue to focus on traditional forms of misconduct while underestimating emerging threats linked to geopolitical competition and hybrid forms of influence.

The technology gap

Considering the hype around artificial intelligence in society generally, the most striking omission in the directive is the limited attention devoted to technological innovation. Over the past decade, governments, international organisations and researchers have been exploring how artificial intelligence, big data analytics, risk indicators, predictive modelling and open-source intelligence can bolster anti-corruption initiatives.

Technology is now essential for identifying suspicious procurement patterns, pinpointing conflicts of interest, tracing illicit financial flows and exposing corruption networks. Yet the directive contains almost no strategic vision regarding the role of technology in anti-corruption governance, which is surprising.

Research conducted under the EU-funded FALCON project – of which the Basel Institute is a consortium member – demonstrates that effective anti-corruption systems are increasingly dependent on digital infrastructures capable of collecting, integrating, analysing and cross-referencing large volumes of information. Without these capabilities, many corruption risks remain invisible until significant damage has already occurred.

It’s important to stress that adopting new technologies – purchasing software, etc. – is the easy part. EU states also need to create the institutional and data infrastructures that allow these technologies to function effectively. Digitisation, interoperability, standardised datasets, machine-readable information and cross-border information sharing are all prerequisites for the next generation of anti-corruption systems.

Three areas that deserve greater attention

From our research in the following areas, we can say for sure that they deserve particular attention in the EU’s Anti-Corruption Strategy and future initiatives:

1. Public procurement

Public procurement remains one of the sectors most vulnerable to corruption. This issue is exacerbated by Europe’s increased investment in defence, critical infrastructure, energy security, technological innovation and strategic industrial policies.

Central priorities should include strengthening transparency, reducing direct awards, improving oversight of sub-threshold contracts, and introducing AI-based risk assessment tools.

2. Border governance

Managing borders and customs procedures is another critical challenge, as research at the Port of Rotterdam and the Kapitan Andreevo crossing demonstrates. Corruption at the border facilitates a wide range of criminal activities, including smuggling, trafficking, evasion of sanctions, tax fraud and the movement of illicit goods.

Greater automation, data integration and harmonisation of border management systems across member states could significantly reduce opportunities for corruption and strengthen the EU’s capacity to detect emerging threats.

3. Financial infrastructures

Modern corruption relies heavily on financial infrastructure. Complex financial networks, shell companies, professional intermediaries, offshore structures and, increasingly, cryptoassets can facilitate the movement and concealment of illicit funds.

The future of anti-corruption policy hinges on strengthening the links between anti-corruption and anti-money laundering frameworks, and on developing new approaches that can address digital financial ecosystems.

Will the EU’s Anti-Corruption Strategy help put the directive into action?

The adoption of Directive 2026/1021 sends an important message that corruption remains a priority issue for the European Union. The directive establishes a much-needed common foundation and introduces valuable innovations to improve both prevention and enforcement. It provides a stronger legal framework than the fragmented system that existed previously.

But legal harmonisation alone will not be enough. The directive’s effectiveness will ultimately depend on how member states implement its provisions, and on whether the European Union can develop a broader strategic vision capable of addressing emerging corruption risks.

This is where the forthcoming EU Anti-Corruption Strategy could play a decisive role. To be effective and not just a paper exercise, it must be adaptive, technology-driven and security-conscious. This strategy must respond to current corruption and anticipate its potential evolution.

And it needs to be based on a participative process that considers the valuable research and perspectives of civil society organisations, academics and others outside of government.

If the directive provides the legal architecture, the strategy can provide the direction. Together, they could form the basis of a more adaptive and forward-looking European anti-corruption framework – one that is able to keep pace with a rapidly changing world.