Chris Roberts comments on a recent expansion to the UK’s corporate criminal liability regime, in CDR News and Commercial Risk
30 Jun, 2026 - CHRIS ROBERTSPartner Chris Roberts has provided comment in CDR News and Commercial Risk on Section 250 of the Crime and Policing Act 2026, which significantly expands the UK’s corporate criminal liability regime. Effective from 29 June 2026, all UK companies can now be held criminally liable for offences committed by a “senior manager” when “acting within the actual or apparent scope of their authority”.
Commenting on the significance of Section 250, Chris said: “Today’s legislative development is significant because it enables prosecutors to hold companies criminally liable for the actions of their ‘senior managers’, a term which is deliberately broadly drafted. It does not create a new offence, but it does mean businesses can now find themselves facing prosecution for conduct they may not even have known about.”
Highlighting the implications for senior managers, Chris commented: “Senior managers will face greater scrutiny from both prosecutors and their own organisations.
“Unlike failure to prevent bribery, there is no defence based on having adequate or reasonable procedures in place. This is simply a mechanism for attributing a senior manager’s criminal conduct to the company.”
Chris added: “The reform has arrived with little fanfare and remains under the radar for many businesses. But prosecutors will be keen to deploy it as part of a broader effort to make full use of everything in their “toolbox”.”
Chris’ comments were published in CDR News and Commercial Risk, 30 June 2026.