What the ‚Crime and Policing Bill‘ Means for Your Compliance Obligations as a Leader

1. The Liability Situation Has Fundamentally Changed

Anyone in a position of responsibility today is under heightened scrutiny. Not only from regulatory authorities but also from legislators. With the „Crime and Policing Bill 2025“, the UK is taking a drastic step: companies can now be held liable for almost all offenses committed by their employees. And this without definite proof of individual culpability at the leadership level.

The Supreme Court in Spain has also recently made it clear: corporate criminal responsibility can only be excluded if a functional compliance system is demonstrably established. The message is clear: organizational failure will be criminally prosecuted.

What is already a reality in other countries is becoming increasingly likely in Germany. Political and regulatory pressure is rising. And with it the personal liability for managers, board members, and supervisory board members.

If you are in a responsible position, a formal rulebook is no longer sufficient. The requirements for corporate governance and compliance have tightened. You are required to take active responsibility.

Because one thing is clear: in a serious case, investigative authorities check not only whether rules exist but also whether they are being followed. Whether violations were known. Whether training took place. Whether hints were pursued. And whether you as a leader fulfilled your supervisory duties.

A functional compliance management system (CMS) is no longer a „nice to have“. It is your strategic risk buffer. Your shield against personal liability. And your proof that you are fulfilling your responsibilities.

3. What Needs to Be Done Now: Your Strategic Roadmap

An effective CMS is characterized by three things: effectiveness, traceability, and practical application. The following steps are now crucial:

a) Update risk analysis
What risks have changed? What new legal requirements are there? Review your risk inventory at least annually and document the results traceably.

b) Clarify roles and responsibilities
Compliance is team effort – but it doesn’t work without clear responsibilities. Define who is responsible for what. From the whistleblower system to internal investigations to escalation to management.

c) Make training mandatory
Compliance thrives on understanding. Conduct regular, target group-specific training – also for top management. Only this way can you ensure that all relevant risks are understood.

d) Understand documentation as proof
In case of doubt, you must be able to prove that your CMS works. Keep records, decisions, and measures in a structured way. Digital, audit-proof, and accessible at all times.

e) Use external audit
An independent view of your system provides security. An external compliance audit or a maturity model like IDW PS 980 provides valuable insights and strengthens your argument in case of liability.

4. Why This Means Leadership Now

Compliance was long the domain of lawyers. Today it is a top management issue. And a sign of modern, responsible leadership.

Because: In an increasingly complex world, stakeholders expect more than just compliance. They expect attitude. Integrity. And the willingness to take responsibility. Those who lead well today, ensure good rules – and live by them.

This is not a contradiction to economic efficiency. On the contrary: Companies with a strong compliance profile are more resilient, more attractive to partners, and invest more sustainably in their reputation.

5. Your Next Step: Update Your Compliance Understanding

If you truly want to embed compliance as a leader, you need up-to-date knowledge – practical, strategic, and with a view to your responsibility.

A good start: S+P seminars on compliance leadership.
Find out more now

There you get an update on new liability issues, best practices from corporate practice, and concrete impulses for the further development of your CMS.

Conclusion:

Compliance is more than rules. It is a leadership tool. A protection mechanism. And your statement for responsible corporate governance. Use current developments to future-proof yourself and your company.

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