ECCTA anti-fraud policy template
A plain-text policy template covering commitment, associated-person identification, prevention procedures, training, reporting, review, and attestation. Structured around the Home Office six-principle model. Free to download — no email required.
What this template covers
The template provides a ten-section policy structure: purpose and scope, commitment statement, associated-person identification, fraud risk assessment, prevention procedures, training and awareness, reporting and escalation, monitoring and review, an attestation record, and the legal boundary. Each section prompts for your organisation's facts.
How to use it
Download the plain-text file, complete the blanks with your organisation's facts, and have a qualified reviewer (legal counsel, compliance officer, or adviser) review the completed document before treating it as evidence. The attestation record section documents who reviewed and accepted the policy.
What it does not do
This template organises the policy-drafting process. It is not legal advice, does not perform scope analysis, does not assess whether procedures are reasonable, and does not guarantee that a statutory defence under s.199 ECCTA 2023 will succeed. Reasonableness is a legal determination requiring qualified human review.
Source basis
Structured around the Home Office failure-to-prevent-fraud guidance v1.5 (Updated 2025-10-10), which describes the six fraud-prevention principles. Accessed 2026-06-15.
Legal boundary
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. The completed template is a working document; its legal weight depends on the quality of the facts entered and the qualified review applied.
Related resources
Use this in DefenceFile
Once adopted, your anti-fraud policy can be attached as a dated evidence document in DefenceFile — pinned to Principle 1 (top-level commitment) in your board pack. The first working session covers this attachment. See how the first session works.