Rewriting The Rules On Corporate Criminal Liability

The extension of corporate criminal liability to offences committed by senior managers marks a significant widening of an organisation's liability net. Organisations should treat the commencement date in June as an important milestone for ensuring their governance and compliance arrangements adequately address the expanded scope of exposure. In this article, we provide an overview of the reform and the practical implications for companies and LLPs, including professional services firms.

What's changing?

The Crime and Policing Act 2026 (CPA 2026), which received Royal Assent on 29 April 2026, will significantly extend corporate criminal liability from 29 June 2026 for all bodies corporate (including limited liability partnerships (LLPs)) and partnerships. The long-established principle that companies can only be criminally liable for offences committed by those representing the 'directing mind and will' of the organisation, a high bar to satisfy, will, in effect, be entirely