On 29 April 2026, the Act received Royal Assent, extending the senior manager attribution provisions under s.196 of the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”). Where ECCTA previously held companies liable for economic crimes committed by senior managers, the Act now holds companies accountable for all criminal offences committed by a senior manager acting within their actual or apparent authority.
The extension exposes companies to greater risk of criminal liability for a broader range of offences, including in respect of health and safety, environmental regulation, modern slavery or workplace misconduct.
The expansion of senior manager attribution will come into force on 29 June 2026.
For more detail and analysis on senior manager attribution, please see our previous blogpost on the Crime and Policing Bill.
Key contacts
Susannah Cogman
Partner, London
Robert Hunt
Partner, London
Kate Meakin
Partner, London
Elizabeth Head
Of Counsel, London
Ali Grodzki
Senior Associate, London
Stefan Fong
Trainee Solicitor, London
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