Whistleblowing reform: what the government’s consultation means for your business

On 12 October 2026, the government launched a consultation on reforming the UK whistleblowing framework, which runs until 8 January 2027.

Ministers call it “the most comprehensive assessment of whistleblowing by the government since the introduction of PIDA”. The consultation also seeks views on a Serious Fraud Office (SFO) scheme to pay financial rewards to people who report economic crime. Businesses of every size should pay attention.

Background: the current framework and why reform is on the table

The Public Interest Disclosure Act 1998 (PIDA) added whistleblowing protections to the Employment Rights Act 1996 (ERA). Under those protections, workers who report wrongdoing are protected from detriment and, if they are employees, from dismissal. A worker is protected only if they reasonably believe two things: that their disclosure is in the public interest and that it shows a listed type of wrongdoing, such as a criminal offence, a breach of a legal obligation or danger to health and safety. Claims are brought in the Employment Tribunal and the protections apply from the first day of employment.

The government says three developments have led to calls for a fundamental review: the EU Whistleblowing Directive of 2019, the success of financial incentive schemes in the US and a series of major scandals in the UK. The SFO proposal follows recommendations from Jonathan Fisher KC in Part 2 of his Independent Review of Disclosure and Fraud Offences, published in July 2026.

Key proposals

Financial rewards for economic crime whistleblowers

The government supports an SFO scheme that would reward people whose information leads to a corporate conviction or a Deferred Prosecution Agreement. The consultation points to the success of overseas schemes, “especially the US Securities Exchange Commission (SEC) whistleblowing scheme”. It notes that UK nationals are the second largest overseas user group of the SEC scheme.

Under the proposal, rewards would be paid out of the company’s fine or penalty and calculated as a percentage of it. The government is asking whether rewards should be uncapped, as they are under most comparable schemes. Comparable schemes typically pay between 10% and 30% of the recovered amount, and HMRC’s Strengthened Reward Scheme pays up to 30%.

Eligibility would not depend on making a protected disclosure, so a person wouldn’t need to be a worker to qualify and rewards could be available whatever country the whistleblower is in. The consultation also proposes new criminal offences of knowingly making a false report under the scheme and of harassing or intimidating whistleblowers who use it.

Who is protected and what they can report

The government is asking whether protection should extend to further groups. It suggests self-employed individuals may have a stronger case than volunteers. The public interest test will stay.

The consultation also asks whether the list of wrongdoing adequately covers risks from AI and wrongdoing linked to corruption. It further asks whether two changes are needed to the routes for making disclosures: removing the requirement that a disclosure to a regulator is believed to be ‘substantially true’ and creating a new protected route for disclosures to trade unions.

Enforcement and oversight

The most significant proposal for employers is a possible statutory duty to have whistleblowing procedures and a policy in place and to follow up on disclosures. The duty could be modelled on Irish law or on the FCA’s SYSC 18 rules. It could be enforced through civil penalties, possibly by a designated government body.

It would apply to private-sector employers with 50 or more employees and to all public-sector employers. The government’s initial view is against creating an ‘Office of the Whistleblower’ and it prefers an AI-assisted tool to help workers find the right regulator to report to.

Other proposals

The consultation also asks whether the seven-day deadline for applying for interim relief should be extended to 14 days.

Implications for businesses

• Policies and procedures: employers should check their policies and procedures against the Irish model, which requires secure and confidential reporting channels, written acknowledgement within seven days, a designated person to handle disclosures and feedback to the whistleblower within three months. In a 2024 survey cited in the consultation, 36% of workers said confidentiality risk was their main reason for not blowing the whistle
• Volume and nature of disclosures: the consultation cites evidence that reward schemes increase both the quantity and the quality of reports of corporate misconduct. It also notes that they may give companies a stronger incentive to identify and self-report wrongdoing early. Businesses should expect some individuals to report directly to the SFO, so it’s important to respond credibly to concerns raised internally
• Board-level governance: boards should decide who is accountable for the whistleblowing framework, what management information they receive and how fast they can escalate and self-report. Delay could reduce a company’s credit for cooperating if information instead reaches the SFO through a rewarded whistleblower
• Sector-specific issues: FCA-regulated firms that are already subject to equivalent rules may be exempt from any new statutory duty. However, they would still be exposed to the SFO reward scheme.

Next steps

Responses must be submitted by 11.59pm on Friday 8 January 2027 and a formal government response is expected in 2027. We encourage businesses to consider responding, particularly on the scope of any statutory duty, phased implementation and the design of the reward scheme.