UK Crime and Policing Act 2026: Corporate Criminal Liability Expands to All Offences — Including Modern Slavery

Effective June 29, 2026, Section 250 of the UK's Crime and Policing Act 2026 (CPA) replaced the Economic Crime and Corporate Transparency Act 2023's senior manager provisions with a far broader regime: companies incorporated anywhere in the world are now criminally liable for any UK criminal offence committed by a "senior manager" acting within the actual or apparent scope of their authority. Critically, there is no "reasonable procedures" defence available — unlike the Failure to Prevent Fraud offence — meaning a compliance program mitigates prosecution risk but does not provide a statutory shield. The regime explicitly captures Modern Slavery Act violations (slavery, servitude, forced labour, human trafficking) and environmental protection offences, making it a direct supply chain liability mechanism. The "senior manager" definition is deliberately broad and extends beyond C-suite to include individuals in operations, legal, HR, and compliance who play a significant role in managing a substantial part of the business. For international companies with UK operations or senior managers conducting business subject to UK law, this is a material upgrade in criminal exposure: lawyers advising multinational clients should immediately map senior manager populations, conduct a gap analysis against Modern Slavery Act and Environmental Protection Act obligations, and implement role-specific training and escalation controls.