Crime and Policing Act 2026: what does this mean for charities?

The scope of corporate criminal liability has been widened, impacting charities and their senior managers. On 29 June 2026, section 250 of the Crime and Policing Act 2026 (CPA) came into force, marking a significant extension of corporate criminal liability in the UK. Previously, under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), a charitable company could be held liable only for specified economic crimes committed by a “senior manager”. The CPA has reformed the law and extends a company’s liability to all criminal offences.

What are the implications for charities?

The extension of a body corporate’s liability to all criminal offences is a significant development for the charities sector. In a nutshell, where a senior manager of a charity commits any criminal offence when acting within their actual or apparent authority, the charity’s liability is no longer limited to financial or economic crime and may arise across the charity’s full range of activities. Further, the previous “adequate procedures” defence is no longer available. An emphasis on compliance will be the charity’s best defence to this new legislation. Good compliance throughout the organisation will help reduce the risk of wrongdoing in the first place and may also be taken into account by prosecutors when deciding whether it is in the public interest to prosecute the charity.

Who is a “senior manager”?

A “senior manager” is defined as someone who plays a significant role in (i) the making of decisions about how the whole or a substantial part of the organisation’s activities are to be managed or organised; or (ii) the actual managing or organising of the whole or a substantial part of those activities.

In a charity, this may include:

chief executives and executive directors;
senior leadership team members;
heads of functions (for example finance, fundraising or services); and
programme or regional leads with operational autonomy.

The focus is on actual decision-making authority, not job title.

Examples of criminal offences covered under CPA

Examples of the wider range of offences committed by senior managers that could now be more easily attributed to corporates include:

Data privacy and protection offences
Computer misuse offences
Modern slavery and human trafficking offences
Obstruction of justice and failure to disclose offences
Health and safety at work offences
Environmental offences
Offences against the person
Trade and sanction offences
Economic offences that were not covered by section 196 ECCTA

Practical steps

Charities should now:

Identify senior managers in practice by assessing where key decision-making sits
Reassess risk of liability beyond fraud to all areas of potential criminal liability
Review existing governance frameworks and internal controls to ensure sufficient oversight
Raise awareness internally to ensure senior staff understand the implications

Conclusion

The CPA is a decisive move towards increased liability for corporates and is a clear statement that strong internal governance should be a priority for all. As such, ensuring that internal governance procedures are robust and fit for purpose should remain high on the agenda for all charities.

If you need legal advice on governance and compliance, see how our charities lawyers can assist you.