Is corporate hospitality legal? What the Bribery Act guidance says
Sources checked 3 October 2026 · 3 min read
Yes — in the government’s own words, reasonable and proportionate hospitality isn’t what the Bribery Act 2010 is aimed at. Here is what the Ministry of Justice’s published guidance actually says, quoted word for word, with a short checklist at the end. It’s general information, not legal advice.
The short answer from the Ministry of Justice
The quick start guide that accompanies the Act lists this among its key points:
“Hospitality is not prohibited by the Act”
And it answers the question “Can I provide hospitality, promotional or other business expenditure under the Act?” directly:
“Yes. The Government does not intend that genuine hospitality or similar business expenditure that is reasonable and proportionate be caught by the Act, so you can continue to provide bona fide hospitality, promotional or other business expenditure.”
The then Secretary of State for Justice put it more plainly in his foreword to the full guidance:
“Rest assured – no one wants to stop firms getting to know their clients by taking them to events like Wimbledon or the Grand Prix.”
What the full guidance says (paragraph 26)
“Bona fide hospitality and promotional, or other business expenditure which seeks to improve the image of a commercial organisation, better to present products and services, or establish cordial relations, is recognised as an established and important part of doing business and it is not the intention of the Act to criminalise such behaviour. The Government does not intend for the Act to prohibit reasonable and proportionate hospitality and promotional or other similar business expenditure intended for these purposes. It is, however, clear that hospitality and promotional or other similar business expenditure can be employed as bribes.”
What makes hospitality a problem
The guidance is clear that it’s the intention and the scale that matter, not the fact of hospitality. On how the authorities would judge it, the quick start guide says:
“In any case where it was thought the hospitality was really a cover for bribing someone, the authorities would look at such things as the level of hospitality offered, the way in which it was provided and the level of influence the person receiving it had on the business decision in question.”
Paragraphs 26 to 32 of the full guidance sit in its section on bribing foreign public officials (section 6 of the Act), but they are its fullest statement of how hospitality is judged. Paragraph 30 gives tickets as an example of a routine courtesy:
“But in the absence of any further evidence demonstrating the required connection, it is unlikely, for example, that incidental provision of a routine business courtesy will raise the inference that it was intended to have a direct impact on decision making, particularly where such hospitality is commensurate with the reasonable and proportionate norms for the particular industry; e.g. the provision of airport to hotel transfer services to facilitate an on-site visit, or dining and tickets to an event.”
And the quick start guide closes the point:
“So you can continue to provide tickets to sporting events, take clients to dinner, offer gifts to clients as a reflection of your good relations, or pay for reasonable travel expenses in order to demonstrate your goods or services to clients if that is reasonable and proportionate for your business.”
Source: GOV.UK — Bribery Act 2010 guidance (Ministry of Justice) (opens in a new tab)
Your own policy sets the standard
The guidance leaves the detail to each organisation:
“It is, however, for individual organisations, or business representative bodies, to establish and disseminate appropriate standards for hospitality and promotional or other similar expenditure.”
So before inviting a client, check your own gifts and hospitality policy — and, as a courtesy, theirs. Public-sector guests usually work to stricter rules.
A practical checklist
- Keep it proportionate to the relationship and to what’s normal in your sector.
- Avoid timing it around a live tender or contract decision.
- Invite the organisation, not just one decision-maker, and say who else is coming.
- Record it: who, what, when, and the cost per guest.
- Check whether your guest’s employer needs to approve it first.
Our written quote gives a per-guest cost including VAT and lists every inclusion, which is usually what a hospitality register asks for.
The tax side
Whether hospitality is allowed and how it’s taxed are separate questions. On tax, HMRC defines the term broadly:
“Business entertainment means the provision of free or subsidised hospitality or entertainment.”
Our VAT and tax guide summarises what HMRC says about reclaiming VAT and deducting the cost.
Sources
- GOV.UK — Bribery Act 2010 guidance (Ministry of Justice) (opens in a new tab)
- Ministry of Justice — The Bribery Act 2010: Guidance (PDF) (opens in a new tab)
- Ministry of Justice — The Bribery Act 2010: Quick start guide (PDF) (opens in a new tab)
- HMRC Business Income Manual BIM45010 (opens in a new tab)
Checked 3 October 2026. Venue rules, dates and guidance change; the version in force applies. General information from the Ministry of Justice’s published guidance, not legal advice. Your legal or compliance team can confirm how it applies to you. We’re not affiliated with the venues, organisers or bodies quoted. We source hospitality through venues, promoters and their appointed hospitality partners.