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The Crime and Policing Act 2026 received Royal Assent on 29 April 2026 and is now being commenced in stages. The headlines were about knives, protests and shop theft. The change that matters most to the businesses and senior people we represent is quieter and far more consequential: a fundamental expansion of corporate criminal liability that makes it far easier to hold an organisation criminally responsible for what the company's senior managers do. This is a defence reading of what the Act actually changes, with that reform at its centre, and why it makes early, pre-charge engagement matter more, not less.
The Crime and Policing Act 2026 is one of the broadest pieces of criminal justice legislation in years, running to roughly 78 measures. The Bill completed its passage and received Royal Assent on 29 April 2026, so it is now law, although it is being switched on in stages. Some provisions were live on or shortly after assent; others are commenced later by regulations; and a few of the most significant, including the corporate liability reform, have their own dates of commencement.
The act introduces criminal liability for criminal activity for antisocial behaviour, knife crime, retail crime, child protection and serious crime, among others. The reporting concentrated on the most visible of these. The directors, senior managers and regulated professionals we act for are far more likely to feel the Act through its corporate liability and investigation provisions, and that is where this article concentrates.
One point of clarification first, because it shapes how people read the Act. It does not reform pre-charge bail or release under investigation. Those rules still come from the Police, Crime, Sentencing and Courts Act 2022. If you are released under investigation today, this Act does not change that. What it changes is the landscape surrounding the investigation.
The single most consequential provision in this Act is the expansion of corporate criminal liability under section 250, in force from 29 June 2026.
For decades, convicting a company of a serious offence ran into the identification doctrine. Prosecutors had to prove that a “directing mind and will” of the organisation, (in practice a board-level individual) was personally culpable/blameworthy. In any large business, that burden of proof was extremely hard to establish, and serious prosecutions would fail on that basis. The identification doctrine protected exactly the organisations whose scale made oversight hardest.
Reform of that doctrine had already begun in the field of economic crime. The Economic Crime and Corporate Transparency Act started dismantling it, first by widening the identification doctrine for economic crime offences, and then through the new offence of failure to prevent fraud. That sat alongside two earlier failure to prevent models: the failure to prevent bribery offence under the Bribery Act, and the failure to prevent the facilitation of tax evasion under the criminal finances legislation. Each of those was a targeted response to a single category of economic crime.
Section 250 is not targeted in that way. It applies corporate liability across criminal offences generally. Where a senior manager, acting within the actual or apparent scope of their authority, commits a criminal offence, the organisation itself can be criminally liable for that offence.
Three features make this a major shift.
First, the category of senior manager is broad. It is not limited to the 'directing mind' of the old identification doctrine. Senior managers are those who play a significant role in the management of the whole or a substantial part of the organisation’s activities, which can reach well below the board. The conduct of more people can now be attributed to the organisation.
Second, it is no longer simply confined to fraud act offences. Where the failure to prevent offences each covered one area, false accounting here, bribery there, section 250 reaches criminal offences generally. A senior manager committing a criminal offence within the apparent authority their role carries can expose the organisation to liability for that offence, whatever its subject.
Third, and this is the point most often missed, there is, no reasonable procedures defence available. The failure to prevent offences give an organisation a statutory defence if it had reasonable procedures in place to prevent the conduct. Section 250 is a different mechanism. It attributes the senior manager’s offence to the organisation directly, so there is no equivalent statutory defence to invoke a level of protection. A strong compliance programme remains valuable in reducing the risk of the underlying conduct, but it is not a shield written into this section.
For directors, senior managers and the organisations they run, this is a structural change in criminal exposure. A single senior manager, acting within the apparent authority their role carries, can now expose the whole organisation to criminal liability across a far wider range of offences than before, and without the compliance defence that the failure to prevent regime provides.
It also sharpens the position of the individuals. An investigation that engages section 250 is, by definition, an investigation into what a senior manager did within their actual or apparent authority. The organisation and that individual can find their interests aligned in some respects and sharply divided in others, and the potential criminal exposure runs in both directions at once.
This is where our work begins. When an investigation can attach to both an organisation and its senior people, the worst thing that can happen is for everyone to respond separately, in different directions, before anyone has taken stock. Getting ahead of the investigation rather than reacting to it, is the entire point of pre-charge representation, and under section 250, proactive representation matters now more than it ever did before.
The Act also expands what the police can do during an investigation. Three changes are highlighted below:
The Act substantially reforms the confiscation regime under the Proceeds of Crime Act 2002, with the stated aim of making a defendant’s benefit from criminal conduct easier to calculate and resulting orders easier to enforce. For anyone with assets, confiscation is often the part of a case with the longest shadow, reaching across property, business interests and family finances. In some instances, confiscation orders under POCA far outlast the original sentence imposed, and unless payment of any calculated benefit is paid within strict time limits, a further sentence in default can be given by the judge. Reforms that make benefit easier to calculate tend to widen the reach of these orders, which makes the financial side of a case something to handle from the outset, not at the end. The prosecution ordinarily instruct a financial investigator early doors. From a defence angle, proactivity is key when dealing with potential proceeds of crime.
Beyond those provisions, the Act creates and reshapes a long list of offences and powers. In brief, it tackles antisocial behaviour through new Respect Orders, an extension of closure notices and higher fixed penalty notices; it strengthens knife crime measures, including a new offence of possessing a bladed article with intent to cause harm; it creates a bespoke offence of assaulting a retail worker; it introduces new child criminal exploitation and “cuckooing” offences, alongside measures targeting AI-generated child sexual abuse material (generated indecent images of children). It also adds further intimate image abuse offences, including new “nudification” and non-consensual image offences and an extended three-year time limit to bring a prosecution, building on the recent reforms we have covered in how the new deepfake offence works. The wider point for anyone reading this is simple: the Act adds to the surface area of the criminal law, and several of its new offences turn on intent and surrounding circumstances, which is precisely where a defence is built or lost.
Read together, the changes point one way. The Act widens who can be prosecuted, widens what the police can do while investigating, and widens what the Crown can recover at the end of a successful prosecution. None of that changes the principle that the strongest position in any criminal case is the one taken earliest. Having prosecuted these cases as well as defended them, we read a new Act for one thing: where it shifts the balance, and where a defence can still get ahead of it. The investigation stage now carries more weight than ever. An organisation exposed through a senior manager, a device that opens connected accounts, an asset position that confiscation can reach: each is best addressed before a charging decision is made, not after.
We act for individuals, directors and businesses across England and Wales who are under investigation or anticipate that they may be, and our focus is the pre-charge stage. In practice that means coordinating the response where both an organisation and its senior managers are exposed under section 250; testing the lawfulness of every power the police rely on, from entry and search to the extraction of digital material; addressing the asset and confiscation dimension early; and engaging with the investigating authority to shape the decision before it hardens into a charge. For many people the first formal contact is still an invitation to a voluntary interview under caution, and how that interview is approached can shape everything that follows.
We offer confidential consultations, in person at our London offices or remotely by secure call. Initial enquiries are handled discreetly and quickly.
If you are affected by an investigation under the new Act, you do not have to navigate it alone. Speak to us today.
It is a wide-ranging criminal justice statute of roughly 78 measures, covering antisocial behaviour, knife crime, retail crime, child protection and serious crime among others. It is now law and is being commenced in stages. For businesses and senior managers, its most significant provision is the expansion of corporate criminal liability under section 250.
Yes. The Bill received Royal Assent on 29 April 2026 and is now the Crime and Policing Act 2026. Assent does not bring every provision into force at once; the Act is commenced in stages, and some measures, including section 250, have their own commencement dates.
Section 250 expands corporate criminal liability. In force from 29 June 2026, it allows an organisation to be held criminally liable where a senior manager, acting within the actual or apparent scope of their authority, commits a criminal offence. It applies to criminal offences generally rather than only fraud, and it replaces the older identification doctrine for those offences.
Under section 250, an organisation can be criminally liable where a senior manager, not any employee, commits an offence within the actual or apparent scope of their authority. A senior manager is someone playing a significant role in managing the whole or a substantial part of the organisation. Unlike the failure to prevent offences under the Bribery Act and the Economic Crime and Corporate Transparency Act, there is no statutory reasonable procedures defence to section 250.
Three elements must be present. First, a senior manager of the organisation. Second, that person acting within the actual or apparent scope of their authority. Third, the commission of a criminal offence. Where all three are met, the offence is attributed to the organisation, which can be prosecuted for it. There is no separate reasonable procedures defence to invoke.
It is the earlier Economic Crime statute that began dismantling the identification doctrine, first by widening it for certain economic crime offences and then by creating the failure to prevent fraud offence. Section 250 of the Crime and Policing Act 2026 goes further, extending corporate liability beyond fraud to criminal offences generally.
No. The Act does not reform pre-charge bail or release under investigation, which continue to come from the Police, Crime, Sentencing and Courts Act 2022. It does, however, change the powers available to the police while an investigation is ongoing.
Take advice before you take any other step, and before you speak to investigators. The strongest position in a criminal case is almost always the one established earliest, at the pre-charge stage, where the evidence and the procedure can be tested before a charging decision is made. You can contact our team directly for a confidential discussion.
Lex Vindico Group is regulated by the Solicitors Regulation Authority. We represent individuals and businesses nationally across England and Wales in criminal, regulatory, and parallel-proceedings defence at every stage, and most decisively, at the pre-charge stage.
This article is written by Akram Mula, LLM, Solicitor Advocate and CPS-approved Prosecutor, founder of Lex Vindico Group. It is general legal information about the Crime and Policing Act 2026, not legal advice on any specific case. The Act is being commenced in stages and statutory references in this article, including section numbers and commencement dates, are flagged for editorial verification before publication. For advice on your individual circumstances, contact our team directly.
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