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The Crime and Policing Act 2026, which received Royal Assent on 29 April 2026, extends the application of the reformed corporate identification doctrine to all criminal offences (rather than just economic crimes).
With effect from 26 December 2023, the Economic Crime and Corporate Transparency Act 2023 (ECCTA) had already reshaped the corporate criminal landscape (you can read more on the ECCTA on our blog here). Alongside its significant reforms to Companies House, the ECCTA amended the long‑standing corporate 'identification doctrine'. Previously, a company could only be held criminally liable where an individual representing its 'directing mind and will' committed an offence. The ECCTA relaxed this test for economic crimes, triggering corporate liability where a senior manager committed an offence within their actual or apparent authority (rather than just economic crimes).
Among its wide-ranging provisions, the Crime and Policing Act goes further and extends this reformed attribution test to all criminal offences. Companies can therefore be criminally liable for any offence committed by a senior manager acting within their actual or apparent authority, regardless of the type of offence (see section 254 of the Act). The extension exposes companies to greater risk of criminal liability for a broader range of offences, including in respect of health and safety, environmental regulation, modern slavery or workplace misconduct.
The change will take effect on 29 June 2026.
For more detail and analysis on senior manager attribution, please see our corporate crime team's previous blog on the Crime and Policing Bill.
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