From 29 June 2026, organisations can be held liable in the UK where a senior manager commits an offence while acting within the actual or apparent scope of their authority. This represents a significant expansion of corporate criminal liability in the UK, building on the regime introduced by the Economic Crime and Corporate Transparency Act 2023, which was limited to certain economic crime offences.
This is the second article in our series on the Crime and Policing Act 2026 for businesses. In our previous article, we focused on four practical implications of the new law, including the increased risk of corporate liability, the need for effective compliance programmes and training, and the greater scrutiny that businesses can expect from stakeholders.
In this article, we examine three of the key concepts underpinning the new regime under the Crime and Policing Act 2026:
- The expanded scope of offences: The new statutory attribution model is no longer limited to specified economic crimes and can apply to any criminal offence committed by a senior manager acting within the scope of their authority.
- Who qualifies as a “senior manager”: The definition is broad and focuses on the role an individual plays in managing or organising all or a substantial part of an organisation’s activities, rather than on job title alone.
- Extraterritorial implications: Businesses with international operations should carefully consider how the new attribution rules may apply in a cross-border context.
For a fuller discussion of these issues, including practical considerations for businesses, see the full article here.
Please contact any of the authors listed above if you would like to discuss how these changes may affect your business.