The Crime & Policing Act 2026, which gained Royal Assent just last week, is said to ‘quietly but fundamentally’ rewrite the government’s approach to corporate criminal liability, introducing new ways in which companies may be held criminally responsible for crimes committed by ‘senior managers’.

Chapter Two, Section 130 of the Act, is titled ‘criminal liability of bodies corporate and partnerships where senior manager commits offence’.

This is described as: ‘Where a senior manager of a body corporate or partnership… acting within the actual or apparent scope of their authority commits an offence’.

Importantly, ‘senior manager’ means an individual who ‘plays a significant role in the making of decisions about how the whole or a substantial part of the activities of the body corporate or partnership are to be managed or organised, or the managing or organising of the whole or a substantial part of those activities’.

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