Oct 16 2026
The UK Government has published a consultation on proposals for the Serious Fraud Office (SFO) to introduce a scheme to reward whistleblowers. The framework is part of a wider package of proposed reforms of whistleblowing protections for workers under the Employment Rights Act 1996 (see our blog on those reforms here). In this blog, we look at the main proposals for the scheme, some insights from home and abroad, its practical application and next steps.
The proposals
The proposals build on the recommendations of Jonathan Fisher KC in Part Two of his Independent Review of Disclosure and Fraud Offences, published in July 2026. The consultation forms part of the Government’s response and includes a strong statement of support by the Government for incentivising whistleblowers.
The Government’s proposals (on which they are seeking views) are as follows:
to reward whistleblowers who provide information that is 'significant and original' and that leads to a successful enforcement outcome against a company, such as a conviction or a Deferred Prosecution Agreement (DPA);
eligibility for a reward to depend on several factors linked to the scheme’s objectives, including whether the individual: (i) had a legal duty to report; (ii) was culpable in the offending; (iii) has a serious criminal conviction; and (iv) is an authorised Covert Human Intelligence Source and/or obtained the information through dishonest or illegal means;
rewards to be paid from the company's...
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