The comparative report on the assessment and explanation of enforcement capabilities and performance of contrast of domestic and cross-border corruption in the EU is a first, design-oriented version of Deliverable which as the purpose to build the conceptual, methodological and data foundations for analysing how European criminal justice systems prevent, investigate, prosecute and sanction corruption, both domestic and cross-border. The full empirical results or final policy recommendations are due at a later stage, and currently this report is built around the core idea of “criminal accountability” as the capacity and willingness of criminal justice institutions to investigate, prosecute, adjudicate and sanction corruption in a legally sound, effective and even-handed way avoiding avoids two major distortions: impunity, meaning systematic under-enforcement or shielding of powerful actors, and weaponisation, meaning selective or politicised use of criminal law.
The current comparative report determines that anti-corruption research has paid far more attention to governance, transparency, political competition and public administration than to the criminal-law side of corruption control.
The main gaps identified are strong: criminal justice institutions are often treated as a black box, that enforcement is too often proxied through simple conviction or prosecution figures, and that there is still no systematic mapping of institutional and policy change in enforcement across Europe. The report observes that despite repeated reforms and continued monitoring, there partial evidence on whether these reforms actually changed enforcement capability, prosecution patterns or the distribution of accountability across political and economic actors.
One key definition concerns criminal accountability: the capacity and willingness of criminal justice institutions to investigate, prosecute, adjudicate and sanction corruption in a legally sound, effective and even-handed way across different categories of actors. It treats accountability as a sequential process: detection, investigation, charging, adjudication, appeal and sanctioning. Criminal accountability is not the same as criminalisation. A country may have bribery offences in its penal code and still lack credible accountability. Second, it is not captured by aggregate outputs taken in isolation, because those outputs may reflect underlying corruption, political incentives or reporting practices rather than genuine even-handed enforcement.
The gaps identified are conceptual as much as empirical: criminal accountability has remained under-theorised within integrity-system approaches, often discussed only indirectly through impunity or immunities.
The initial observations show that “criminal accountability” requires better enforcement, not necessarily more enforcement, ensuring focus on legality, sequencing, even-handedness and the institutional conditions under which cases move or collapse, considering that more enforcement is not automatically better, because enforcement itself can be distorted and politically instrumentalised.
Methodologically, the report proposes to measure Criminal Accountability and Enforcement using a combined and multi-source measurement framework, which draws on EUCAL and judicial-transparency indicators as well as on official statistics, elite-level domestic enforcement data, and foreign-bribery case information. It focuses on three dimensions: system integrity, actual enforcement outcomes, and the patterns of impunity and weaponisation that emerge. The main gaps concern data and comparability. But the report does not yet offer a final measurement system: criminal accountability requires a layered design, a composite architecture that joins law, institutions, organisations, cases and outcomes in one comparative panel.
Considering evaluation, the report argues that enforcement should be assessed as the product of institutions, organisations and political settings, not as an autonomous legal output, also combining the measurement of domestic enforcement and cross-border enforcement. Practically, the methodological combination includes cross-national quantitative work, mixed methods and legal-comparative approaches. Much evidence is informative but thin on institutional content. Studies often isolate outcomes from institutions instead of integrating them. Evaluation has to become unified and cumulative, which is achieved by linking enforcement outcomes to institutional and organisational conditions across levels and arenas, combining cross-national analysis with targeted case studies to counter the fragmentation.
Concerning comparative Case-Study Evidence on Criminal Accountability for Corruption across Levels and Arenas the report covers France, Italy and Spain as a comparison of elite accountability trajectories; Romania as a national and sub-national study of uneven enforcement; Italy, France and the United Kingdom as a comparison of corporate criminal liability; and EPPO plus judicial cooperation as a study of transnational enforcement. The preliminary conclusions are still partial, but several lines are already visible: criminal enforcement must be integrated with broader public-administration and integrity reforms; In the corporate liability case the Italian, French and UK models offer converging but distinct balances between compliance and enforcement, which can inform future EU harmonisation. In the EPPO case, the report suggests that the EU anti-corruption system has improved compared with the previous fragmented order but still suffers from structural weaknesses.
The report has completed its role as a first-version roadmap, clarified the core questions, defined the key concepts, mapped the main institutional configurations, and sketched how these will later become indicators of criminalisation, enforceability and sanctioning: it keeps the debate open but the terms on which the next phase will proceed.
At this stage the gaps are by now very clear: statistical reporting is fragmented and heterogeneous. EU-level data are still weak on high-level political corruption and cross-border cases. Institutional design remains under-mapped in relation to outcomes. And domestic responses are still insufficiently integrated with EU and international mechanisms in complex cross-border cases.
In these early stages, the preliminary conclusions point towards three directions: more systematic and comparable EU-level data; closer attention to prosecutorial and judicial governance, including specialisation, resources and safeguards for independence; and better integration between domestic systems and mechanisms such as OLAF and EPPO. The report argues that the real gap in European anti-corruption policy is not only in law, but in the translation from law into credible, even-handed enforcement. The future work in this area is to identify when that translation works, when it stalls, and what kind of institutional design makes it more credible without sliding into politicisation or selective justice.
Here you can find the full deliverable for a more extensive insight: https://corruptiondata.eu/wp-content/uploads/2026/02/BridgeGap_D8.3_Comparative-Report_V1.0.pdf