The Ministry of Justice has published a new five-year strategy for tackling fraud, bribery and corruption, with greater emphasis on systematic risk assessment, data analytics, artificial intelligence and fraud prevention by design.
Published on 4 September 2026 and applying to England and Wales, the MoJ Counter Fraud Strategy 2026 to 2030 is an internal departmental strategy rather than a new regulatory regime for private businesses. It does not create new criminal offences or additional statutory duties for company directors.
It does, however, provide a useful indication of how a major government department intends to identify and investigate fraud over the next five years. For businesses dealing with public bodies or operating in environments where financial conduct is closely scrutinised, the direction of travel is worth understanding.
What does the MoJ Counter Fraud Strategy 2026 to 2030 actually do?
A counter-fraud strategy is a structured framework for identifying fraud risks, putting preventative controls in place, detecting suspicious activity and responding where concerns arise.
The Ministry of Justice says its new strategy has been informed by continuing fraud risk assessments and horizon scanning. Its Enterprise Fraud Risk Assessment identified four particularly significant areas of risk: insider threats, commercial risk, digital and technology risk, and threats from third parties.
The strategy is organised around four core pillars:
- Governance and Assurance,
- Risk Identification,
- Control Implementation; and
- Response.
These are supported by Culture and Capability and Data Analytics
The scale of the issue identified in the document is substantial. The strategy cites Public Sector Fraud Authority estimates that between £39.8 billion and £58.5 billion of public money is subject to fraud and error each year. It also refers to National Audit Office estimates that individual departments may lose between 0.5% and 5% of their operating budgets to fraud and error. These are figures cited by the Ministry of Justice from existing public-sector sources rather than new estimates produced specifically for this strategy.
The strategy therefore places prevention alongside investigation. The stated objective is increasingly to identify risk before loss occurs rather than relying solely on action after suspected fraud has already taken place.
Why is greater use of data and AI important for fraud investigations?
One of the clearest themes in the strategy is the move towards more systematic use of data.
The Ministry of Justice says it wants to move away from more fragmented and ad hoc analysis towards fraud prevention and detection embedded within its services and controls. It intends to run structured pilots and scale approaches that prove effective.
Specific planned actions include testing and piloting analytics and AI detection tools, improving data sharing, creating performance dashboards and working with AI, digital and data specialists to understand emerging risks. The strategy also proposes horizon scanning specifically for emerging cyber and AI fraud methods.
This is significant because data-led investigation can change how concerns first arise.
Traditional fraud enquiries may begin with a complaint, whistleblower report or obvious accounting discrepancy. Increasing use of analytics creates the possibility that unusual patterns across transactions, records or datasets may themselves prompt further investigation.
That does not mean an unusual transaction establishes fraud. There can be entirely legitimate explanations for financial activity that initially appears inconsistent or unexpected.
For businesses, however, it reinforces the value of maintaining records which explain significant transactions and the commercial reasoning behind them. If a transaction is questioned months or years later, contemporaneous documents can be more persuasive than an explanation reconstructed from memory.
Where concerns have already developed into allegations of dishonest conduct, our fraud claims and investigations solicitors can advise on the legal and evidential issues that arise.
What does fraud prevention by design mean for organisations?
The Ministry of Justice says it intends to embed fraud detection and prevention into new services and controls by design. Planned measures include fraud prevention checklists, a control library, detailed fraud risk assessments for major projects and programmes, and clearer responsibility for identified risks.
The strategy applies to the Ministry of Justice and should not be treated as imposing those specific requirements on private companies.
There is nevertheless a broader governance lesson.
Fraud controls are generally more effective when considered before a problem occurs. An organisation which waits until money has disappeared before asking who could authorise payments, how transactions were checked or whether conflicts were identified may find it much harder to reconstruct events.
For businesses, proportionate preventative steps can include making responsibilities clear, maintaining reliable accounting records, establishing appropriate approval processes and documenting exceptions to normal procedures.
The appropriate controls will depend on the size and nature of the business. A small owner-managed company will not require the same infrastructure as a government department.
The central principle is that fraud risk should form part of ordinary commercial governance rather than being considered only once an allegation has arisen.
Will greater information sharing lead to more scrutiny of businesses?
The strategy indicates that greater information gathering and data sharing will form an important part of the Ministry of Justice’s counter-fraud response.
It proposes increased sharing of data and intelligence across the MoJ, its executive agencies and public bodies, alongside greater cross-government collaboration and access to appropriate investigative capabilities.
It would go too far to say that this strategy itself gives investigators new legal powers. It does not.
The practical implication is instead that government counter-fraud activity is becoming increasingly coordinated and evidence-led. Businesses dealing with government departments may therefore find that information is assessed across a wider context rather than solely within an individual transaction or contract.
This makes consistency particularly important.
Financial records, contractual documents, explanations provided to public authorities and internal records should accurately reflect the underlying position. Inconsistencies do not necessarily prove wrongdoing, but they can generate questions that require explanation.
Where an investigation subsequently develops into a commercial dispute or recovery claim, the documentary record may become central to establishing what happened. FWJ’s commercial litigation team advises businesses on both bringing and defending complex claims where fraud allegations or disputed financial transactions form part of the proceedings.
What should directors and businesses take from the strategy?
The MoJ Counter Fraud Strategy does not change the statutory duties owed by directors of companies in England and Wales. Nor does it create a new compliance code that private businesses are required to adopt.
Its significance lies in what it says about the development of fraud prevention and investigation within government.
The strategy points towards more structured risk assessment, increased use of data, greater cross-organisational information sharing, prevention built into processes and continued investment in investigative capability. It also expressly recognises that fraud methods themselves are changing as technology develops.
For businesses, the sensible response is not to try to replicate a government counter-fraud framework. It is to consider whether their own systems and records are proportionate to the risks they actually face.
Directors should know how significant payments are approved, whether unusual transactions can be explained, where responsibility for financial controls sits and whether concerns raised internally are properly recorded and considered.
Where suspected fraud has already occurred, preserving documents and electronic records can become particularly important. Early decisions about evidence, internal investigations and communications with third parties can affect later civil recovery or defence proceedings.
The Ministry of Justice strategy is therefore relevant not because it introduces new duties for businesses, but because it demonstrates an increasingly data-led and preventative approach to fraud risk. Organisations which can explain their transactions through clear records, appropriate controls and documented decision-making will generally be better placed to respond if their conduct is later scrutinised.
