DROPLETS
In-house counsel for companies operating in the UK must act because a new statutory change eliminates the prior compliance shield for corporate criminal liability, holding organizations accountable for offences committed by senior managers acting within the scope of their authority.
The UK’s Crime and Policing Act 2026 introduces a second major expansion of corporate criminal liability in three years, scrapping the prior ‘identification principle’ that limited corporate liability to acts of senior individuals deemed the organization’s ‘directing mind’. Under the new rule, prosecutors may attribute any offence committed by a senior manager acting within the scope of their authority directly to the company, covering a broad range of existing offences including fraud, bribery, and economic crime. Even well-resourced compliance frameworks no longer provide automatic protection from liability. In-house counsel should review governance structures, reporting lines, and senior manager oversight protocols to mitigate emerging risk.
In-house counsel for companies subject to the EU Corporate Sustainability Reporting Directive must act because the revised standards will alter mandatory sustainability disclosure requirements for upcoming reporting cycles.
The European Commission has formally adopted revised European Sustainability Reporting Standards (ESRS), updating the initial 2023 framework governing mandatory sustainability disclosures for companies subject to the EU Corporate Sustainability Reporting Directive (CSRD). The revisions narrow general disclosure requirements to reduce reporting burdens, clarify pending sector-specific standards, and align ESRS requirements with parallel EU sustainability rules including the Corporate Sustainability Due Diligence Directive. The updated standards apply to reporting periods starting on or after January 1, 2024, with first disclosures due in 2025 for large public interest entities and 2026 for other large covered undertakings. In-house counsel should review the updated standards against their company’s upcoming CSRD reporting timelines, adjust internal disclosure processes, and confirm cross-alignment with due diligence obligations to avoid noncompliance penalties.
In-house counsel for asset managers, fund operators, and financial institutions active in the DIFC must monitor these proposed reforms, as they would materially alter compliance, structuring, and operational requirements for funds operating in the jurisdiction.
On July 7, 2026, the Dubai Financial Services Authority (DFSA) published Consultation Paper No. 173, proposing a comprehensive overhaul of the regulatory framework governing funds operating in the Dubai International Financial Centre (DIFC). The proposed changes include updates to fund classification rules, licensing requirements, disclosure obligations, and operational standards for both public and private DIFC funds. In-house counsel for relevant firms should review the consultation paper, submit feedback during the open comment period if aligned with their business priorities, and begin preliminary assessments of required compliance and operational adjustments to prepare for final rule implementation.
In-house counsel for companies operating in the UK must act because a new statutory change eliminates the prior compliance shield for corporate criminal liability, holding organizations accountable for offences committed by senior managers acting within the scope of their authority.
The UK’s Crime and Policing Act 2026 introduces a second major expansion of corporate criminal liability in three years, scrapping the prior ‘identification principle’ that limited corporate liability to acts of senior individuals deemed the organization’s ‘directing mind’. Under the new rule, prosecutors may attribute any offence committed by a senior manager acting within the scope of their authority directly to the company, covering a broad range of existing offences including fraud, bribery, and economic crime. Even well-resourced compliance frameworks no longer provide automatic protection from liability. In-house counsel should review governance structures, reporting lines, and senior manager oversight protocols to mitigate emerging risk.
In-house counsel for companies subject to the EU Corporate Sustainability Reporting Directive must act because the revised standards will alter mandatory sustainability disclosure requirements for upcoming reporting cycles.
The European Commission has formally adopted revised European Sustainability Reporting Standards (ESRS), updating the initial 2023 framework governing mandatory sustainability disclosures for companies subject to the EU Corporate Sustainability Reporting Directive (CSRD). The revisions narrow general disclosure requirements to reduce reporting burdens, clarify pending sector-specific standards, and align ESRS requirements with parallel EU sustainability rules including the Corporate Sustainability Due Diligence Directive. The updated standards apply to reporting periods starting on or after January 1, 2024, with first disclosures due in 2025 for large public interest entities and 2026 for other large covered undertakings. In-house counsel should review the updated standards against their company’s upcoming CSRD reporting timelines, adjust internal disclosure processes, and confirm cross-alignment with due diligence obligations to avoid noncompliance penalties.
In-house counsel for asset managers, fund operators, and financial institutions active in the DIFC must monitor these proposed reforms, as they would materially alter compliance, structuring, and operational requirements for funds operating in the jurisdiction.
On July 7, 2026, the Dubai Financial Services Authority (DFSA) published Consultation Paper No. 173, proposing a comprehensive overhaul of the regulatory framework governing funds operating in the Dubai International Financial Centre (DIFC). The proposed changes include updates to fund classification rules, licensing requirements, disclosure obligations, and operational standards for both public and private DIFC funds. In-house counsel for relevant firms should review the consultation paper, submit feedback during the open comment period if aligned with their business priorities, and begin preliminary assessments of required compliance and operational adjustments to prepare for final rule implementation.
In-house counsel for companies operating in the UK must act because a new statutory change eliminates the prior compliance shield for corporate criminal liability, holding organizations accountable for offences committed by senior managers acting within the scope of their authority.
The UK’s Crime and Policing Act 2026 introduces a second major expansion of corporate criminal liability in three years, scrapping the prior ‘identification principle’ that limited corporate liability to acts of senior individuals deemed the organization’s ‘directing mind’. Under the new rule, prosecutors may attribute any offence committed by a senior manager acting within the scope of their authority directly to the company, covering a broad range of existing offences including fraud, bribery, and economic crime. Even well-resourced compliance frameworks no longer provide automatic protection from liability. In-house counsel should review governance structures, reporting lines, and senior manager oversight protocols to mitigate emerging risk.