Executive Summary
- What’s new: On 12 October 2026, the UK government announced a consultation on the current whistleblowing framework. This includes the potential introduction of a financial rewards scheme for whistleblowers reporting economic crime information that results in successful enforcement by the SFO. On 13 October 2026, the SFO also updated its Corporate Cooperation Guidance by introducing a new route for companies to communicate directly with the SFO’s director of legal services before formally self-reporting.
- Why it matters: The economic crime enforcement landscape is evolving in the UK, with focus on using US-style financial incentives for whistleblowing and the creation of more informal cooperation channels in an effort to achieve improved detection and prosecution of such offences. This may lead individuals to prioritise reporting information to authorities directly, rather than doing so internally within the organisation, and companies to engage with authorities at earlier stages of an investigation. The SFO clearly seeks to expand the avenues through which it receives information in the hopes of securing improved enforcement outcomes against businesses with a UK nexus.
- What to do next: Companies should continue to monitor the potential UK whistleblower reforms and may wish to consider whether existing whistleblowing policies and procedures are sufficient in encouraging internal reports to be made.
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On 12 October 2026, the UK government announced a consultation on the potential reform of the current whistleblowing framework. The proposals include the creation of a Serious Fraud Office (SFO) incentivisation scheme to provide financial rewards to individuals who report information about economic wrongdoing that leads to successful enforcement action. The scheme aims to encourage individuals to come forward with information to UK authorities to improve detection, investigation and prosecution of serious economic crime.
Although whistleblower incentivisation schemes operate successfully in other jurisdictions, in particular in the US and Canada, the UK has historically opposed the idea of law enforcement agencies paying informants and previously rejected the idea of such reform. (Certain limited incentivisation schemes did exist — through HM Revenue and Customs (HMRC), for example — which have now been expanded.) The debate was revived in February 2024 by the then-incoming SFO director, Nick Ephgrave, who stated during his inaugural speech that he was in favour of financial incentives for whistleblowers. Ephgrave pointed out that the SFO was disadvantaged vis-à-vis other authorities that offered such incentives because UK insiders would choose to report knowledge of wrongdoing in jurisdictions where they could secure payouts. For instance, as the government notes in the consultation, UK nationals are the second-largest overseas user group of the US Securities and Exchange Commission (SEC) rewards scheme. The consultation suggests that Ephgrave’s departure from the SFO will not impact the introduction of the reform.
In July 2026, the Independent Review of Disclosure and Fraud Offences, chaired by Jonathan Fisher KC, recommended that the UK government legislate to allow the SFO to implement an incentivisation scheme for economic crime whistleblowers. Additionally, the UK tax authority, HMRC, recently launched its own rewards scheme for individuals reporting serious tax avoidance or evasion whose information leads to the collection of at least £1.5 million in tax.1,2
The current consultation was launched on the back of these developments in the UK enforcement landscape and is expected to close on Friday, 8 January 2027.
Notably, on 13 October 2026, the SFO also updated its Corporate Cooperation Guidance by introducing a new route for companies to discuss a potential self-report directly with the SFO’s director of legal services ahead of making a formal report. According to the official communication, the SFO considers that this new, informal contact channel will create a clearer and swifter path for companies to enter into Deferred Prosecution Agreement (DPA) negotiations. The Corporate Cooperation Guidance currently provides that businesses that report promptly and cooperate fully will, barring exceptional circumstances, be invited to enter DPA negotiations. However, in the past five years the SFO has successfully secured only one DPA.
Overview of the Proposed Whistleblower Incentivisation Scheme
Rewards and Funding
Only whistleblowers who provide information which is “significant and original” and leads to a successful enforcement outcome would qualify for a reward under the proposed scheme.
Any potential reward would be calculated as a percentage of the total financial penalty or fine imposed on a company by the SFO. Most existing overseas incentivisation schemes specify a percentage range for a reward (such as, in case of the SEC scheme, between 10% and 30%) and do not impose a cap on the value of rewards (although, as the government notes in the consultation, the Ontario Securities Commission does cap the potential reward at 5 million Canadian dollars).
In line with the US practice, under the updated HMRC scheme, the reporting individual may receive a reward of between 15% and 30% of the tax collected, excluding penalties and interest, and there is no cap on the size of the reward. The UK’s principal antitrust regulator, the Competition and Markets Authority (CMA), operates a nonstatutory discretionary incentivisation scheme, offering a reward of up to £250,000 to individuals reporting unlawful cartel activity.
The consultation proposes that the rewards would be funded from financial penalties and fines imposed on companies and, therefore, would only be paid once the case has successfully concluded.
Eligibility
Under the current proposal, the eligibility requirements for the new scheme would be entirely separate from the criteria for making a protected whistleblowing disclosure under the UK employment law framework. Some of the factors that the government is currently considering include whether an individual has a legal duty to report the information, partook in the misconduct to which their disclosure relates or has obtained the information through dishonest means. The fact that the two programs would be independent of each other means also that eligible individuals would not be limited to workers and employees within the company but could include others that potentially have information about misconduct, such as nonexecutive directors or external consultants and contractors.
The scheme may also be made available to overseas whistleblowers (i.e., persons who reported relevant information that led to successful enforcement by the SFO to overseas authorities) due to the international character of economic crime.
New Offences
In order to prevent abuse of the scheme, the government is considering the introduction of two new criminal offences: (i) for knowingly making false reports under the scheme; and (ii) for harassing or intimidating whistleblowers who report information pursuant to the scheme. These proposals recognise the balance between the risks associated with whistleblower rewards and whistleblower protections. The proposal related to a new offence for harassment and intimidation of whistleblowers is broadly consistent with changes in other jurisdictions designed to enhance whistleblower protections, including the EU Whistleblowing Directive.3
Future Considerations for Businesses
These recent developments show the SFO’s appetite to increase the volume and quality of the information in its pipeline to improve investigative and enforcement outcomes. Potential changes to whistleblower rewards in the UK could significantly expand the information available to the SFO to commence investigations and disincentivise internal reporting of potential wrongdoing.
Companies should continue to monitor the potential UK whistleblower reforms and may wish to consider whether existing whistleblowing policies and procedures are sufficient in encouraging internal reports to be made. Effective whistleblower procedures that encourage internal reports (both from employees and external stakeholders) assist in the early detection of potential wrongdoing. Those procedures should effectively register, triage and escalate whistleblowing concerns to qualified individuals within the organisation for investigation. Ensuring sufficient protections for whistleblowers are in place to avoid retaliation is also critical to fostering a speak-up environment that encourages internal reports.
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1 Skadden, “UK To Create Whistleblower Incentives To Boost Tax Collection” (4 December 2025).
2 HM Revenue and Customs, “Reporting serious tax avoidance or evasion” (26 November 2025).
3 Article 21 of the Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law [2019] OJ L 305/17.
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