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ARTICLE · 07 JULY 2025

Very Large Organisations Sentencing Guidelines: Evolution, Not Revolution

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The Sentencing Council's latest amendments to Very Large Organisations (VLOs) sentencing under the sentencing guidelines for Health and Safety, Food Safety, Food Hygiene...

United KingdomCompliance
Andrew Litchfield
Andrew Litchfield
Natalie Barton-Howes
Natalie Barton-Howes
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The Sentencing Council's latest amendments to Very Large Organisations (VLOs) sentencing under the sentencing guidelines for Health and Safety, Food Safety, Food Hygiene, and Corporate Manslaughter offences, taking effect from 1 June 2025, demonstrate the incremental nature of regulatory change. For organisations with significant turnover, these changes signal higher financial exposure and the need for enhanced compliance strategies.

While the changes appear significant on paper, a closer examination suggests a more nuanced picture of these amendments, which codify existing judicial practice rather than introduce any significant transformation.

How are VLOs sentenced?

The current sentencing framework operates through a structured step-by-step process that begins with categorising organisations by turnover: micro (up to £2 million), small (£2 million-£10 million), medium (£10 million-£50 million), and large (over £50 million). However, there's a fifth, and more

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