Fraud remains the most prevalent crime in England and Wales, affecting millions of individuals and businesses each year and costing the UK economy billions. Against this backdrop, the Government launched its Fraud Strategy 2026–2029 in March 2026, committing £250 million over three years to strengthen the national response to fraud.
The strategy is structured around three pillars – Disrupt, Safeguard and Respond – with the aim of preventing fraud at source, protecting individuals and businesses, and improving outcomes for victims. While the strategy contains several welcome developments, many of its measures build on existing initiatives rather than representing wholly new interventions. For insurers and other sectors that bear the cost of fraud, the key question is whether the proposals go far enough to meaningfully reduce the scale of the problem.
The first pillar focuses on disrupting criminal activity before fraud occurs. Central to this is the creation of a £30 million Online Crime Centre, designed to identify and block criminal websites, phone numbers and other digital infrastructure used by fraudsters. The Government also intends to expand intelligence-led policing to identify fraud hotspots and coordinate responses more effectively.
These proposals reflect an increased recognition that fraud is largely an online crime, with scams often originating on digital platforms or through telecommunications networks. Enhancing the capability to identify and dismantle the infrastructure used by organised criminal groups is therefore a logical and necessary step.
The strategy also emphasises the use of artificial intelligence to analyse data and detect fraud patterns. For an industry where data is fundamental, this development will resonate with insurers, many of whom are already investing heavily in AI-driven fraud detection tools. The potential to combine data from multiple sources to identify organised criminal groups could significantly strengthen the UK’s ability to disrupt fraud networks.
Encouragingly, there are signs of increasing collaboration between government and industry in this area. Since our fraud roundtable with Lord Hanson in October 2024, we have been engaging with the Public Sector Fraud Authority (PSFA), which has demonstrated a strong willingness to work with industry to improve fraud detection. In particular, the PSFA has been developing an Organised Crime Group Detection Model, designed to identify patterns of fraud activity across datasets. Our upcoming meeting with the PSFA to review this model reflects a broader shift towards collaboration and shared intelligence.
However, the success of these initiatives will ultimately depend on the extent to which data can be shared across sectors. Evidence consistently shows that individuals involved in fraud rarely confine their activity to a single industry. A fraudster targeting insurers may also be committing fraud against banks, retailers or government services. Cross-industry data sharing is therefore critical to identifying repeat offenders and organised networks. While the strategy recognises the importance of intelligence sharing, it is not yet clear that it goes far enough in facilitating systematic data sharing across sectors, which remains a significant barrier to effective prevention.
The second pillar focuses on protecting individuals and businesses from fraud. Key measures include:
These measures largely build on existing initiatives and public awareness campaigns. While important, they are unlikely to be transformative in isolation.
A more significant issue lies in the role of online platforms and technology companies. A large proportion of fraud now originates through social media advertising, messaging services and other digital platforms. Yet the strategy does not introduce new obligations for technology companies, instead relying on existing frameworks such as the Online Fraud Charter, the Online Safety Act, and regulatory oversight by Ofcom.
This has attracted criticism from consumer groups. Rocio Concha, Head of Policy and Advocacy at Which?, noted that the strategy risks being overly reactive if technology platforms are not required to prevent scams appearing on their services in the first place.
This concern is widely shared across the insurance industry. At our 2024 fraud roundtable, insurers provided numerous examples of fraudulent advertising and impersonation scams originating on online platforms, causing significant financial harm and distress to victims. The tools to tackle this already exist within the Online Safety Act, particularly in relation to fraudulent advertising. What is now required is rapid and robust implementation, alongside meaningful enforcement by Ofcom.
In this respect, the strategy’s reliance on existing regulatory frameworks may represent a missed opportunity. Given the speed at which technology-enabled fraud evolves, there is a strong argument that online platforms should face clearer and more immediate accountability for preventing fraud on their services.
The third pillar focuses on improving the response to victims of fraud.
The Government plans to introduce a new Report Fraud service to replace Action Fraud, aiming to streamline reporting and improve intelligence gathering. In addition, a Fraud Victims’ Charter, due to be introduced in 2027, will establish clear standards for victim care, response times and reimbursement.
Improving the reporting process is long overdue. The existing Action Fraud system has been widely criticised for failing to provide timely support or effective follow-up for victims. If the new reporting framework successfully improves intelligence gathering and victim engagement, it could represent a meaningful improvement.
For insurers, clearer standards around victim care and reimbursement may also help strengthen public trust in how fraud cases are handled.
Alongside these operational measures, the strategy outlines several structural and legal reforms.
Responsibility for fraud, economic crime and cybercrime will be consolidated within the National Police Service and the National Crime Agency, with the aim of improving coordination and specialist capability.
The strategy also explores the potential use of civil penalties as an alternative to criminal prosecution, which could allow enforcement action to be taken more quickly in certain cases.
Separately, the ‘failure to prevent fraud’ offence, which came into force on 1 September 2025, introduces criminal liability for large organisations that fail to prevent employees from committing fraud. This measure is likely to drive stronger internal fraud prevention systems within large corporates.
The Home Office has indicated that further calls for evidence will follow the publication of the strategy. These will focus on:
These consultations present an important opportunity for industry stakeholders to help shape the next phase of policy development.
A central question remains whether the £250 million investment over three years is sufficient given the scale of the problem. Fraud costs the UK economy many billions annually, and the societal harm caused to victims is significant.
Fraud is a complex, rapidly evolving crime that thrives on fragmentation between sectors and jurisdictions. Breaking down those barriers – through greater intelligence sharing, stronger accountability for online platforms, and closer cooperation between government and industry – will be critical.
Sarah Hill - Counter-Fraud Partner
Natalie Larnder - Partner and Head of Market Affairs


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