The panel highlighted how the UK’s approach to tackling economic crime is undergoing a significant shift, driven by Companies House reform and the introduction of the new Failure to Prevent Fraud offence. Speakers emphasised that Companies House is moving away from its traditional role as a passive repository of corporate information and becoming a far more assertive, intelligenceled regulator. Key to this transformation is the introduction of mandatory identity verification for directors, people with significant control, and third parties who file information on behalf of companies. This enhanced scrutiny is intended to improve the accuracy of the register, disrupt the misuse of corporate structures, and make it harder for criminals to use UK companies as vehicles for fraud.
The discussion also explored the expanded investigative powers granted to Companies House, including the ability to query, reject, or remove information where it appears suspicious or inaccurate. This represents a clear departure from the previous “file and forget” model. Panel members noted that these changes will place greater responsibility on companies to ensure filings are complete and defensible, while also enabling more effective collaboration between Companies House, law enforcement bodies, and other regulators. The reforms are supported by increased filing fees and investment in new technology, signalling a longterm commitment to elevating the quality of corporate data and strengthening the UK’s reputation as a safe and transparent place to do business.
Alongside these reforms, the introduction of the Failure to Prevent Fraud offence under the Economic Crime and Corporate Transparency Act was a central theme of the session. The panel outlined how the offence will apply to large organisations and create criminal liability where an employee or agent commits fraud for the organisation’s benefit. The only defence will be demonstrating that ‘reasonable procedures’ were in place to prevent such conduct. The only formal guidance has been produced by the Home Office, but sector-specific, non-official guidance has been produced by organisations, including the ICAEW. The speakers underscored that companies should expect to undertake structured fraud risk assessments, enhance staff training, improve reporting channels, and strengthen controls across highrisk areas. The offence aligns with previous corporate criminal frameworks for bribery and tax evasion, reinforcing a broader shift toward preventative governance and accountability at senior levels.
