On 29 June 2026, one of the biggest changes to UK corporate criminal law in years took effect. Under section 250 of the Crime and Policing Act 2026, a company or partnership can now be found guilty of a crime committed by one of its senior managers. The rule applies to businesses of every size, including small limited companies and ordinary partnerships.
This guide explains, in plain English, what the new law does, who counts as a senior manager, how it differs from the failure to prevent fraud offence, and the practical steps a UK director or owner-manager should take now. Every date and figure here is taken from the Act itself or from GOV.UK, with the sources listed at the end.
What is the Crime and Policing Act 2026?
The Crime and Policing Act 2026 is a UK law that received Royal Assent on 29 April 2026. Its section 250 widens corporate criminal liability so that a company or partnership is guilty of an offence whenever one of its senior managers, acting within their authority, commits that offence. The measure took effect on 29 June 2026.
Before this change, prosecutors usually had to prove that a company's "directing mind and will", in practice its board or most senior leaders, was behind a crime. That old "identification doctrine" was hard to apply to large, layered businesses, so corporate prosecutions often failed. The new rule lowers the bar by attributing a senior manager's conduct to the organisation itself. If you are unclear on who is legally responsible for running a company, start with our guide to director responsibilities in the UK.
What changed on 29 June 2026?
From 29 June 2026, section 250 made companies and partnerships criminally liable for any offence committed by a senior manager acting within the actual or apparent scope of their authority. It repealed sections 196 to 198 of the Economic Crime and Corporate Transparency Act 2023, which had attached liability for economic crimes only. One rule now covers the full range of criminal offences.
| Question | Before 29 June 2026 | From 29 June 2026 |
|---|---|---|
| Which offences attach to the company? | Economic crimes only (ECCTA 2023) | All criminal offences |
| Whose conduct counts? | The "directing mind" at board level, plus senior managers for economic crime | Any senior manager acting within their authority |
| Which businesses? | All in theory, but narrow in practice | All sizes, including small companies and partnerships |
| Legal basis | Common law plus ECCTA 2023 ss.196 to 198 | Crime and Policing Act 2026, s.250 |
The start date was set by the Crime and Policing Act 2026 (Commencement No. 1 and Saving Provision) Regulations 2026. There is no transition period and no grandfathering for existing managers, so the rule applies to senior-manager conduct from 29 June 2026 onwards.
Who counts as a senior manager?
A senior manager is anyone who plays a significant role in making decisions about how the whole, or a substantial part, of the organisation's activities are managed, or in the actual managing of those activities. It is a test of real influence, not of job title, so a department or regional head can qualify even without the word "director" in their name.
This is the same definition Parliament used for corporate manslaughter and reused in the 2023 economic-crime rules. Depending on how much of the business they really run, it can reach an operations manager, a finance lead, a site manager or a head of sales. Because it turns on substance rather than your company register, it is worth mapping who actually holds decision-making power. Our explainer on the difference between shareholders and directors helps clarify who sits where.
What does actual or apparent authority mean?
Actual or apparent authority means the senior manager was doing something of a type they were allowed to do, or that a person in their position would ordinarily do. Crucially, they do not need to have been authorised to commit the crime itself. The company is liable if the wrongdoing happened while they were carrying out their normal role.
In other words, you cannot escape liability by pointing out that nobody signed off the offence. If a manager with authority over, say, supplier contracts or health and safety commits an offence while exercising that authority, the act is treated as the company's own. That is why prevention, culture and clear controls now matter more than ever, a theme we return to below.
How is this different from the failure to prevent fraud offence?
The failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023 came into force on 1 September 2025, applies only to large organisations, and gives a defence where the business had reasonable fraud-prevention procedures. Section 250 is far broader: it covers all offences, all company sizes, and offers no "reasonable procedures" defence at all.
| Feature | Failure to prevent fraud (ECCTA 2023) | Identification doctrine (CPA 2026, s.250) |
|---|---|---|
| In force from | 1 September 2025 | 29 June 2026 |
| Which offences | Specified fraud offences only | Any criminal offence |
| Which businesses | Large organisations only | All sizes, plus partnerships |
| Whose conduct | An "associated person" (employee, agent, subsidiary) | A senior manager acting within authority |
| Defence available? | Yes, reasonable prevention procedures | No statutory defence |
"Large organisation" for the fraud offence means meeting two of three tests: more than 250 employees, more than £36 million turnover, or more than £18 million in total assets. The new identification rule has no such threshold, so a two-person limited company is exposed in the same way as a multinational group.
Does it apply to small companies and partnerships?
Yes. Section 250 applies to companies of all sizes and to partnerships, with no turnover or headcount threshold. A small limited company can be prosecuted for an offence committed by a senior manager just as a large one can. For partnerships, any proceedings are brought in the partnership's own name rather than against individual partners.
This matters most for owner-managed businesses, where the founder is often the only "senior manager" and wears every hat. It sits alongside other 2026 changes tightening the rules around UK companies, such as Companies House identity verification. Keeping clean records is part of staying on the right side of all of them, and our guide on how long to keep business records sets out the basics.
What should directors and owners do now? A worked example
Directors should map who counts as a senior manager, tighten their internal controls and training, and document their compliance culture. Because there is no "reasonable procedures" defence, the aim is to stop offences happening in the first place. A clear governance trail also helps if HMRC or another authority ever investigates.
Take a worked example. Priya owns a small ecommerce limited company with eight staff. Her operations manager, Tom, has day-to-day authority over couriers, packaging and supplier deals. If Tom commits a regulatory offence while running that side of the business, for instance breaching product-safety or environmental rules, section 250 can make the company itself guilty, even though Priya never knew. Before 29 June 2026 that link was far harder to prove. Now it is the default position. The practical lesson is that Priya should not simply trust Tom, she should give him written procedures, training and oversight.
Use this checklist to reduce your exposure:
- Map your senior managers. List everyone who genuinely controls a substantial part of the business, not just the statutory directors.
- Write down the rules. Give those people clear, role-specific procedures covering the laws they could realistically breach.
- Train and refresh. Make compliance training routine, and keep dated records that it happened.
- Build a speak-up culture. People should be able to flag risks early without fear of blame.
- Keep your paperwork. Good records evidence your controls. See how long to keep business records.
- Get advice on grey areas. If a role carries real legal risk, take professional advice. Our tax advisory service can help you build a compliant, well-documented structure.
If you are worried about how an investigation might begin, our guide on what triggers an HMRC investigation shows the warning signs to manage.
Frequently asked questions
When did the Crime and Policing Act 2026 come into force?
Section 250, the part that widens corporate criminal liability, came into force on 29 June 2026. The Act itself received Royal Assent on 29 April 2026. The start date was set by the Crime and Policing Act 2026 (Commencement No. 1 and Saving Provision) Regulations 2026.
Does the new corporate criminal liability rule apply to small companies?
Yes. Section 250 applies to companies and partnerships of all sizes, with no turnover or employee threshold. A small limited company can be prosecuted for an offence committed by a senior manager in exactly the same way as a large business.
Who is a senior manager under the Crime and Policing Act 2026?
A senior manager is someone who plays a significant role in deciding how the whole, or a substantial part, of the organisation is managed, or in actually running it. It depends on real influence rather than job title, so it can include managers who are not statutory directors.
Is there a defence if my company had good compliance procedures?
No. Unlike the failure to prevent fraud offence, section 250 has no statutory "reasonable procedures" defence. Strong controls and training still reduce the risk of an offence occurring, and help in any investigation, but they are not a complete legal shield.
What should you do next?
The new identification doctrine raises the stakes for every UK business, not just the big ones. The smart response is not panic but good housekeeping: know who your senior managers are, give them clear rules, train them, and keep the evidence. That is the same disciplined approach that keeps your tax and accounts in order too.
If you would like help building a compliant, well-documented business, book a free call with Zmartly and our qualified accountants will help you get your governance and records investigation-ready.
