Corporate Criminal Offence (CCO): As enforcement activity ramps up, is your business ready?

Earlier this year, we looked at why corporate criminal offence (CCO) compliance matters and how businesses can protect themselves from criminal charges. These charges can arise if someone working for them helps others to evade tax. Now, HMRC’s latest update confirms what many in the industry have anticipated. Enforcement activity is increasing and scrutiny is intensifying.

HMRC’s latest corporate criminal offence statistics

As of 30 June 2025, HMRC has made its first charging decision under the corporate criminal offences act. In addition, there are a further:

• 11 live corporate criminal offence investigations underway
• 27 additional cases under active review
• 121 opportunities reviewed and rejected to date

HMRC hasn’t shared details about the rejected cases where no charges were made. However, they did still investigate other tax and regulatory issues.

What does this mean for businesses?

The corporate criminal offence legislation was never just about prosecutions. HMRC wants businesses to change how they work by putting strong procedures in place to stop tax evasion. However, the first charging decision signals a clear warning that companies need to take this risk seriously. If they don’t act, they could face investigation for failing to prevent tax evasion.

A timely reminder: Reasonable procedures are your defence

If your organisation hasn’t yet conducted a thorough risk assessment or implemented proportionate procedures, such as training, now is the time. HMRC’s enforcement strategy is sector-wide and risk-based, meaning no business is immune.

At PKF Francis Clark, we continue to support clients by:

• Identifying vulnerabilities through tailored risk assessments
• Designing and embedding procedures that meet HMRC’s expectations
• Delivering training to ensure staff understand their responsibilities

Additional offences: Fraud prevention legislation

The Economic Crime and Corporate Transparency Act 2023, effective from 1 September 2025, introduced a new offence for failure to prevent fraud. This will apply to large organisations and further expands the scope of corporate liability. Businesses must act now to ensure they are not only corporate criminal offence-compliant but also prepared for this next wave of regulation which requires reasonable prevention procedures to be in place for fraud not just tax evasion.

Final thoughts on corporate criminal offence

HMRC’s latest update is a clear warning. Corporate criminal offence compliance is no longer just a theory – it’s a real and growing area of enforcement. Whether you’re a small business or a multinational, the expectation is the same. Take steps to stop tax evasion or face the consequences.

If you’re unsure where to start or want to review your current procedures, our team is here to help.