New rules on fraud, ID checks, employment rights and immigration are reshaping what good governance looks like. At S&B Activate 2025, in-house lawyers and business leaders discussed how to prepare for these changes. This article shows how to close the accountability gap and build stronger systems and culture for the future. 

A wave of new rules has arrived. Companies House ID verification checks, the failure to prevent fraud offence, Employment Rights Bill and tighter immigration rules all point to greater accountability in 2026.

At S&B Activate 2025, many in-house teams said they know what’s coming but don’t feel fully prepared. Most attendees reported being partway through ID verification and fraud prevention work, but many are unsure about right-to-work compliance.

The conversation centred on closing the accountability gap and using these new rules to build stronger systems, culture and trust.

Strengthen governance through clearer accountability

New Companies House rules make identity checks a practical test of governance. Directors and Persons of Significant Control (PSCs) must verify their identity on strict timelines, and PSCs who aren't directors are easy to overlook.

Lucy Barnes, Legal CoSec Head at Stevens & Bolton, warned: “The practical challenge often lies in the detail. It is quite easy to miss PSCs who are not directors, or to assume the confirmation statement deadline is the only date that matters.”

With wider enforcement powers behind these changes, including fines and potential director disqualification, strong systems matter more than ever.

Key takeaways:

• Map who needs to verify and by when. Identify all directors and PSCs, including those who are not on the board, and diarise the relevant deadlines.
• Decide how ID checks will be done in practice. Confirm whether individuals will use One Login or ACSP-supported routes, and brief them early.
• Align verification with board processes. Join up company secretarial, legal and in-house teams so filings and governance stay in step.

Embed stronger fraud controls across the business

Greater accountability means showing that fraud risks are managed in practice.

The new failure to prevent fraud offence applies to large organisations and carries unlimited fines and significant reputational exposure. It could be triggered when an employee, subsidiary, agent, or someone else providing service for or on your behalf commits a fraud offence for the organisation’s or one of its client’s benefit. The good news is that there is a defence of proving you had “reasonable” prevention procedures in place.

As James Evison, Partner in Commercial Litigation at Stevens & Bolton, put it: “putting in place prevention measures isn’t necessarily about doing everything. It is about doing what is reasonable in all the circumstances, and being able to demonstrate it clearly.”

Government guidance mirrors familiar Bribery Act principles, focusing on top level commitment, risk assessment, proportionate prevention measures, due diligence, communication and ongoing review.

Key takeaways:

• Carry out a focussed fraud-risk assessment. Pinpoint where fraud could realistically arise—for instance sales, procurement, through intermediaries and in financial systems.
  Review existing policies. Review, update or create new anti-fraud, anti-bribery, financial crime and whistleblowing measures to ensure they are comprehensive and fit for purpose.
• Evidence “reasonable procedures”. Communicate with your people, keep training logs, risk assessments, board minutes and decision trails so you can show what you did.

Improve workforce systems through new employment duties

The Employment Rights Bill marks a major shift in workplace accountability. Some of the key changes set out in the latest version of the Bill include the right for employees to be able to bring an unfair dismissal claim after six months’ service (rather than the current requirement for two years’ service), easier union recognition and tougher duties to prevent sexual harassment, including by some third parties. The government is also now seeking to remove the cap on compensation for unfair dismissal claims. 

For employers, the impact will be significant and they will need to start planning for the changes well in advance. Probation and dismissal processes will need tightening. Industrial relations strategies will need refreshing. Zero and low-hours arrangements, and tactics like “fire and rehire”, will come under far greater scrutiny.

The Bill also raises the bar on culture. Employers will need to show they have taken all steps to prevent harassment and consider how they will manage risks that sit outside their direct control, including the impact of behaviour of third parties, such as clients, customers and contractors.

89% of the audience at S&B Activate were already reviewing policies for the Employment Rights Bill, but far fewer have taken practical steps needed for compliance, such as auditing zero-hours use or assessing the wider harassment risk.

Hannah Ford, Partner in Employment at Stevens & Bold, confirmed: “Accountability is shifting. These reforms don’t just change the rules—they demand stronger systems, clearer processes and a culture that can stand up to scrutiny.”

Key takeaways:

• Update hiring and probation processes. Train managers on the changes to the unfair dismissal framework and record performance concerns carefully from the outset as employers will need to act more quickly if employees are able to bring a claim for unfair dismissal with just six months’ service.
• Refresh industrial relations strategy. Plan for quicker routes to union recognition and stronger union rights of access, and upskill HR and managers on constructive engagement.
• Strengthen anti-harassment measures. Review policies, training, reporting channels and contracts with key clients and suppliers to address third party risk.

Raise compliance standards across hiring and workforce checks

Tightening immigration and right-to-work rules are raising expectations on how businesses must comply with their obligations in relation to sponsoring overseas nationals and complying with their obligations to prevent illegal working.. Higher salary and skills thresholds, increasingly complex sponsorship duties and an increase in Home Office audits of sponsors and greater enforcement in relation to illegal working means systems now need to be watertight.

Many in-house teams are still unsure of their footing. Only 39% of attendees felt confident they were fully compliant with right-to-work and sponsorship duties, and most don’t know whether they are compliant.

Kerry Garcia, Partner in Employment and Immigration at Stevens & Bolton, described the sponsorship regime as “one of the most expensive and complex in the world” and also waned in relation to right to works and the prevention of illegal working that “ninety-five per cent compliance will not be enough” To be able to establish a statutory excuse against a civil penalty if it turns out that an employee is working illegally. Civil penalties can reach £60,000 per illegal worker, and many issues stem from inconsistent processes or gaps in manager understanding on the right to work check processes. The risk here will increase further when new legislation comes into effect extending the right to work and civil penalty regime to beyond just employees of the business, and to workers and contractors and potentially even to individuals with whom the business has no contractual relationship. 

Key takeaways:

• Audit right-to-work checks and sponsorship files. Ensure processes match the latest guidance and are applied consistently across the business and ensure that the business is adhering to its sponsor obligations.
• Train HR and line managers on right to work checks. Clarify acceptable documents, the rules on repeat checks and how records must be captured.
• Ensure Key Personnel on the sponsor licence are up to date on the lates sponsor guidance and Immigration Rules as there are frequent changes
• Factor immigration into deals and restructurings. Assess sponsor licence implications early in acquisitions, mergers and TUPE transfers.

Accountability builds confidence

Collectively, these changes shift how regulators, investors and employees assess organisations. Policies alone no longer carry weight. What matters is whether systems function in practice and whether the organisation can demonstrate how it meets its responsibilities.

For in-house lawyers, this creates pressure but also opportunity. Closing the accountability gap now helps avoid last minute scrambles, strengthens culture and builds long-term confidence across the business.

Legal advice you can act on

For tailored guidance on preparing for regulatory change and new obligations please get in touch with your S&B contact or a member of our Corporate, Employment or Immigration teams.