Sweeping new crime law set to reshape corporate accountability from late June

One of the most consequential pieces of criminal-justice legislation in years is about to take effect, with the Crime and Policing Act 2026 due to come into force from 29 June. Lawyers say the Act marks one of the most significant developments in UK corporate criminal law in decades, fundamentally changing when and how organisations can be held responsible for the actions of their senior people.

Under the central reform, if a senior manager of an organisation, acting within the actual or apparent scope of their authority, commits a criminal offence under UK law, the organisation will be treated as having committed the offence too. Crucially, in those circumstances there is no defence available to the organisation, a sharp departure from the previous position in which prosecutors often struggled to pin liability on companies at all.

The change dramatically widens corporate exposure, reaching far beyond the narrow categories of offence to which corporate liability was once effectively confined. Legal advisers have been urging businesses to review their governance, training and compliance arrangements before the new regime begins, warning that the bar for prosecuting organisations is about to fall significantly.

What the law changes

For decades, prosecutors found it notoriously difficult to convict large companies of criminal offences, because the law generally required proof that a 'directing mind' at the very top of the organisation was personally culpable. In diffuse, modern corporate structures, that test was hard to meet, allowing some organisations to escape liability even where serious wrongdoing had occurred within their ranks.

The new Act recasts that test around the conduct of senior managers, a broader category than the traditional directing mind. Where such a manager commits an offence within the scope of their authority, the organisation is fixed with criminal liability automatically. By removing the defence in those situations, the legislation shifts the emphasis firmly towards prevention, since once the trigger is met there is little room to argue the point in court.

Alongside the corporate-liability reforms, the Act bundles together a range of new policing powers and offences, part of a wider effort to update the toolkit available to forces dealing with everything from organised crime to public order. The corporate provisions, however, are the elements that have most alarmed boardrooms and most occupied the legal profession in the run-up to commencement.

“From the end of June, the question for boards is no longer whether they have a defence, but whether they have done enough to stop offences happening in the first place.”

— Corporate crime solicitor advising businesses on the new Act

What businesses are being told to do

With commencement looming, advisers have been pressing organisations to act quickly. The emphasis is on demonstrable prevention: clear policies, robust training, effective reporting channels and a culture in which wrongdoing is identified and stopped before it escalates. For many firms, particularly smaller ones without large in-house legal teams, the new regime represents a substantial compliance challenge.

The reforms also sharpen the focus on who counts as a senior manager, a question that will turn on the reality of a person's role rather than their job title. Organisations are being advised to map out where real decision-making authority sits, since it is the conduct of those individuals that could now expose the whole organisation to criminal liability.

• The Crime and Policing Act 2026 comes into force from 29 June 2026
• Organisations can be liable where a senior manager commits an offence within their authority
• In those circumstances there is no defence available to the organisation
• The reform widens liability well beyond previously narrow categories
• The Act also introduces a range of new policing powers and offences

Background

Calls to make it easier to prosecute companies have grown louder over many years, fuelled by high-profile cases in which serious corporate wrongdoing went unpunished because the law could not bridge the gap between individual misconduct and organisational responsibility. Reformers argued that the old directing-mind test was outdated in an era of complex, decentralised businesses.

The new Act is the culmination of that long campaign, drawing on earlier moves to introduce 'failure to prevent' offences in areas such as bribery, tax evasion and, more recently, fraud. By extending automatic corporate liability to a far wider range of offences, it represents a significant tightening of the legal framework around how organisations behave.

What happens next will play out in the months after commencement, as prosecutors test the new powers and businesses scramble to show they have taken prevention seriously. For boardrooms across the country, the message from their lawyers is unambiguous: the cost of inaction has just risen sharply, and the time to prepare is now.