Failure to Prevent Fraud – Reasonable Procedures Policy

Fraud prevention procedures built on the six Home Office principles for the ECCTA 2023 offence, for large organisations and smaller firms adopting them voluntarily.

Editable Word document
14
10pages
Guidance notes included
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Health, safety & compliance

Failure to Prevent Fraud – Reasonable Procedures Policy

About this document

What it’s for

A fraud prevention policy and framework built around the six principles in the Home Office guidance on the failure to prevent fraud offence in section 199 of the Economic Crime and Corporate Transparency Act 2023 (in force since 1 September 2025). It also covers how you deal with fraud committed against your business.

When to use it

  • Large organisations: the offence applies if you (or your group) meet two of three size tests
  • Smaller firms: as good practice, when supplying large organisations that expect you to have procedures, or when tendering
  • Alongside your anti-bribery and tax evasion policies

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  1. Policy statement
  2. Scope
  3. Definitions
  4. The law in summary
  5. Roles and responsibilities
  6. Risk assessment
  7. Proportionate prevention procedures
  8. Due diligence
  9. Fraud against the Organisation
  10. Raising concerns
  11. Investigation and response
  12. Training and communication
  13. Monitoring and review

Also included

  • Approval
  • Risk rating key
  • Incident log

How to complete it

  • Check whether you are in scope using section 4 and the threshold table
  • Complete the fraud risk assessment (Appendix A) with input from each part of the business
  • Tailor the procedures in section 7 to your risks and name the Fraud Prevention Lead
  • Train staff, issue the acknowledgement (Appendix D) and review annually

Key points to check

  • Confirm the thresholds and guidance on gov.uk before relying on them
  • A small firm’s senior managers can still make the company liable for fraud under separate rules

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

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Health, safety & compliance

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Guidance notes in every document

Written for UK businesses

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