The number of live cases being reviewed under the Corporate Criminal Offences (CCO) legislation has increased slightly in the last six months, while no further charging decisions have been secured.
As of 31 December 2025, HMRC reported 11 live Corporate Criminal Offences (CCO) investigations with a further 32 'live opportunities' under review.
- Cases span various business sectors, including software providers, waste services, accountancy, transport, and legal services.
- On 30 June 2025, HMRC reported 11 live cases with a further 27 opportunities under review.
- This means there are five more cases live than in the previous six months.
As at 31 December 2025:
- HMRC had reviewed and rejected 126 opportunities.
- In those cases that have been rejected, investigations have resulted in HMRC being satisfied with explanations provided and did not establish deliberate facilitation.
- HMRC had secured one charging decision. It is understood that an accountancy firm appeared at Manchester Crown Court on 7 August 2025, along with six individuals, in respect of alleged Research and Development (R&D) tax credit repayment fraud. The trial is scheduled for September 2027.
There are two offences under the CCO rules, introduced by the Criminal Finances Act 2017:
- The facilitation of UK tax evasion.
- The facilitation of foreign tax evasion.
Organisations found guilty of the offences face potentially unlimited fines.
- A business may commit an offence when it does not have procedures to prevent a person or company that is providing services on its behalf from criminally facilitating tax evasion.
HMRC say that investigations are not the sole measure of success. The legislation was introduced to drive behavioural change and pressure organisations to put procedures in place that reduce the opportunity for facilitation to occur.
HMRC have said that they will update this information biannually.
Useful guides on this topic
Corporate Criminal Offence: failure to prevent tax evasion
A corporate offence of failure to prevent the criminal facilitation of tax evasion applies from 30 September 2017.
Corporate Criminal Offence: failure to prevent tax evasion toolkit
This is an interactive tool to determine 'At a glance' whether there has been an offence committed under the Criminal Finances Act (2017) in respect of a corporate failure to prevent the criminal facilitation of tax evasion.
Corporate Anti-Tax Evasion Policy Template
S.44 - s.52 of the Criminal Finances Act 2017 lays out the corporate criminal offences of facilitating tax evasion. As part of the qualifying defence to such a charge, HMRC expects all corporate entities to have an Anti-Tax Evasion policy in place.
External link
HMRC FOI release: Number of live Corporate Criminal Offences investigations