The new regime, introduced under the Crime and Policing Act 2026, extends liability beyond economic crime and broadens the definition of ‘senior manager’ to include those playing a ‘significant role’ in management or compliance. Writing in NLJ this week, Simon Parsons of Bath Spa University warns that companies can now be liable for criminal acts committed by senior staff acting within either their actual or ‘apparent authority’.
The reforms move beyond the old ‘identification doctrine’ tied to directors and controlling minds, meaning HR leaders, compliance managers and other executives may now fall within scope.
Parsons says organisations should urgently review governance structures, train senior staff to identify legal risks and strengthen compliance systems before ‘minor problems’ escalate into full-blown corporate criminal liability.
