Who is an associated person under the failure to prevent fraud offence?
An associated person is a person who performs services for or on behalf of the relevant body — which can include employees, agents, subsidiaries, and other service providers. The category is wider than payroll and is assessed on all the circumstances.
Not sure this applies to you? The offence targets large organisations that meet the size test — check whether you are in scope.
In short
- Can include employees, agents, subsidiaries, and other service providers
- Wider than payroll — supply chain and subsidiaries can count
- Classification is fact-specific and reserved for qualified review
Because the test looks at services performed for the organisation, supply-chain and subsidiary activity can matter. The classification of any given relationship is a legal judgement reserved for qualified reviewers.
DefenceFile helps you organise evidence by relationship and service context — building an associated-person register, capturing attestations, and keeping the record discoverable — so reviewers can assess each relationship on its facts.
The sample board pack — a one-page view of where evidence is complete and what is missing — opens in your browser, no email, no form.
Official sources
- Economic Crime and Corporate Transparency Act 2023
Royal Assent 2023-10-26; accessed 2026-06-15.
- Home Office failure-to-prevent-fraud guidance v1.5
Updated 2025-10-10; accessed 2026-06-15.
Keep reading
DefenceFile organises evidence for legal and compliance review. It does not provide legal advice, create privilege, certify scope, certify reasonable procedures, or guarantee that a statutory defence will succeed.