ECCTA guidance tracker for failure-to-prevent-fraud evidence teams.

Primary legislation containing sections 199 to 206 and Schedule 13 for the failure-to-prevent-fraud offence.

Safe wording: Use for statutory structure and section references; do not say software supplies the statutory defence.

Commencement regulations bringing sections 199 to 206 and Schedule 13 into force on 1 September 2025.

Safe wording: Use for in-force timing; do not treat commencement as a risk score or evidence of any particular enforcement action.

Home Office guidance v1.5 covering scope, associated persons, reasonable fraud-prevention procedures, UK nexus, and examples.

Safe wording: Use for prevention-procedure principles and factual thresholds; do not say following the guidance guarantees the defence.

Joint CPS-SFO prosecution guidance for corporate charging decisions, public-interest factors, and corporate liability routes.

Safe wording: Use for prosecutor posture and charging context; avoid predictions about whether a buyer will be prosecuted.

SFO guidance on evaluating compliance programmes, including reasonable-procedures evidence for s.199 ECCTA and whether controls operate in practice.

Safe wording: Use to explain why evidence-in-operation matters; do not claim a policy set or workflow certifies reasonable procedures.