Corporate criminal liability may arise in a number of ways, including through senior manager attribution, failure to prevent offences and other statutory regimes.
The UK corporate criminal liability framework has evolved significantly in recent years, including through the introduction of new failure to prevent offences and reforms to senior manager attribution rules.
These developments have been further expanded by section 250 of the Crime and Policing Act 2026 (CPA 2026), which extends the range of individuals whose conduct can be attributed to the organisation and provides a statutory route where a senior manager commits an offence while acting within the actual or apparent scope of authority.
As a result, organisations must have a clear understanding of how authority is exercised in practice and ensure that governance arrangements, compliance controls and reporting mechanisms remain effective and appropriately aligned to the risks they face.
Under CPA 2026, s 250, a ‘senior manager’ is defined as an individual who plays a significant role in the making of decisions about how the whole or a substantial part of an organisation’s activities
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