Anti-Corruption 2026

DENMARK Law and Practice Contributed by: Christian Monberg, Simon Evers Hjelmborg, Ann Sophie Juul Hird and Linn Dyrgaard Stinus, Accura Advokatpartnerselskab

9. Assessment 9.1 Assessment of the Applicable Enforced Legislation The OECD published an evaluation of Denmark in 2023 (the so-called Anti-Bribery Convention Phase 4 report). The Report contains several recommenda - tions pertaining to the legislation and awareness of foreign bribery and a comment on the fact that Den - mark has very few cases revolving around corruption and bribery. The Phase 4 report points to several weaknesses of the Danish anti-corruption and anti-bribery legislation and enforcement, including the following. • Investigation and legislation regarding bribery from foreign countries is not sufficient. • There is no clarification on the legal basis for small facilitation payments The Phase 4 report also points to several strengths of the Danish anti-corruption and anti-bribery legislation and enforcement, including the following. • The steps taken against anti-money laundering and the greater protection of whistle-blowers. • Danish companies usually have well-established anti-corruption programmes and are aware of the risk of bribery from foreign counties. Based on this, the OECD sets out the following rec - ommendations for Denmark. • Develop a comprehensive national policy or strat - egy to fight foreign bribery. • Proactively detect, investigate and prosecute for - eign bribery. • Clarify the legal basis for the small facilitation pay - ments. • Adopt a clear and transparent framework for non- trial resolutions. • Increase sanctions for false accounting and foreign bribery-related money laundering offences.

• Further raise awareness of foreign bribery. • Take proactive steps to extend the OECD Conven - tion to Greenland and the Faroe Islands. Furthermore, Denmark is ranked number one as the least corrupt country in the world in the Corruption Perceptions Index 2024. However, Denmark has faced criticism for its limited implementation of external recommendations aimed at enhancing anti-corruption measures (see Adden - dum to the second compliance report for Denmark, adopted by the Group of States against Corruption). For further information, see the Denmark Trends and Developments article for Chambers Anti-Corruption 2026. Although there is plenty of public debate on, eg, the regulation of lobbying activities and the revolving door phenomenon (see 2.2 Influence-Peddling and 2.6 Lobbyists and the Denmark Trends and Devel - opments article for Chambers Anti-Corruption 2026) , there are no scheduled changes to the current legisla - tion and enforcement body. 9.2 Likely Changes to the Applicable Legislation of the Enforcement Body However, the authors note that amendments to the Access to Public Administration Files Act may be expected in the near future. Accordingly, an expert committee has been established to propose changes to the provisions of the Access to Public Adminis - tration Files Act that regulate access to documents in political decision-making processes. This initiative follows criticism that the current rules fail to ensure a sufficient degree of transparency and public access to the workings of the public administration. The con - cerns have primarily related to the provisions govern - ing access to documents in political decision-making processes, including Section 24 (the ministerial advice rule) and Section 27 (2) (the parliamentary communi - cation rule).

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