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Civil Fraud Case Update: Q1 2026
Mary Young
On 29 April, the Crime and Policing Bill received Royal Assent, and the Crime and Policing Act 2026 is now on the statute books.* It introduces a further, transformative expansion of corporate criminal liability in the UK so that companies may be held criminally liable where a “senior manager” commits an offence while acting in their actual or apparent authority, for all crimes. This marks a fundamental departure from the current senior manager framework under the Economic Crime Corporate Transparency Act 2023 (ECCTA) where, currently, corporate liability is restricted to economic crimes.
Throughout 2025, health and safety prosecutions have affected every major sector, with courts issuing substantial fines and, in some cases, custodial sentences for directors or individuals. These prosecutions highlight persistent failings in work-at-height controls, vehicle and machinery safety, risk assessment, maintenance and the protection of both workers and the public.
Private prosecutions can offer a more efficient and effective way of accessing justice for victims and deterring further criminality.
The FCA has recently released its newsletter ‘Enforcement Watch 1’ (‘EW1’) – a new online publication providing legal practitioners and others involved in the financial services industry an invaluable insight into the regulatory body’s enforcement priorities, aims and policies.
This online safety update provides a summary of the significant changes to Ofcom’s implementation of the Online Safety Act 2023 and the regulator’s enforcement strategy over the last year, and their potential impact on tech companies.
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