SFO publishes updated annual report on whistleblowing disclosures for 2024–25

Key takeaways:

• Greater transparency: The SFO’s latest whistleblowing report goes beyond headline numbers, detailing how disclosures were handled.
• Drop in reports: Whistleblowing disclosures fell by around 10% year-on-year.
• Possible reforms ahead: Incentivisation for whistleblowers is under consideration, and guidance may need to adapt if legislative changes are introduced.

Key statistics

Between 1 April 2024 and 31 March 2025, the SFO Intelligence Division handled 167 whistleblowing disclosures, down from 182 in the previous reporting period – a decrease of around 10%. The SFO’s Annual Report 2024-25 adds further context, noting that the Intelligence Division received approximately 1,450 referrals during the year, all of which were triaged and assessed.

The scope of “qualifying” disclosures included in the whistleblowing report is relatively narrow, reflecting a two-stage test. Firstly, the individual must meet the statutory definition of “worker” under section 230(3) of the Employment Rights Act 1996 – namely, someone working under a contract of employment or any other contract to personally perform work or services for another party who is not their client or customer – and the disclosure must concern their employer. Secondly, the worker must reasonably believe that the disclosure is made in the public interest, and the SFO must agree.

Overall, the SFO states that it “took action” in 153 cases, which represents roughly 92% of disclosures received. In 14 cases, no further action was possible due to missing contact details. However, the report gives limited insight into what “action” means beyond initial administrative steps (for example, acknowledging receipt, requesting additional information, and/or engaging with partner agencies).

Framed that broadly, the metric risks becoming self validating. A simple “thank you” response – or a decision to close the matter after a cursory review – could still be logged as “action”. On that approach, the SFO can deliver a near 100% “action rate” for any disclosure where it has contact details to respond. That figure would say little about whether disclosures were taken forward in practice, informed casework or led to meaningful outcomes.

If the SFO’s aim is greater transparency, future reporting would be more meaningful if it explained how disclosures were triaged and progressed. In particular, it would help to know how many translated into intelligence packages, casework or new investigations. For context, in 2024-25 the SFO reported opening just eight new investigations in total. Without additional granularity, a 100% “action rate” on 153 non-anonymous reports should be treated with a pinch of salt.

Looking ahead

The SFO’s 2024–29 Strategy and 2025–26 Business Plan confirm that whistleblowing remains a strategic priority and is part of a broader ambition to strengthen intelligence-led enforcement and prevention. The SFO has committed to exploring incentivisation options for whistleblowers, alongside measures to improve casework efficiency and deepen collaboration with domestic and international partners. These themes also sit alongside the government’s Anti-Corruption Strategy 2025, which includes a commitment to review routes for reporting corruption and consider financial incentives for reporting economic crime.

Nick Ephgrave, Director of the SFO, has consistently been a vocal advocate for reform in this space. In his first speech as Director in February 2024, he highlighted that around 700 UK whistleblowers have reportedly gone to US authorities since 2012, attracted by more generous rewards. He warned that UK agencies risk losing “smoking gun” evidence as a result. Ephgrave argues that the benefits of paying whistleblowers far outweigh the downsides and has consistently called for modernisation of legislation, which he views as outdated and ill-suited to today’s data-heavy investigations.

Speaking recently on a Financial Times podcast, Ephgrave proposed a codified reward system, modelled on the U.S. approach, to strengthen the UK’s ability to uncover corporate wrongdoing. His confidence in reform has been reinforced by HMRC’s newly announced whistleblower programme in the Budget 2025, which offers rewards of between 15-30% of recovered tax where information leads to the collection of at least £1.5 million in unpaid tax. However, any UK incentive model would need careful tailoring to the UK’s criminal procedure and disclosure framework, including how authorities handle disclosures from potentially implicated insiders and the practical limits of preserving anonymity.

These developments highlight the SFO’s recognition that timely, high-quality intelligence is essential in tackling serious fraud, bribery, and corruption. But absent clearer reporting on how disclosures translate into investigative activity, a shift towards incentivisation risks becoming another headline-friendly initiative with limited evidential value for companies trying to assess real enforcement exposure.

What this means for businesses

Whistleblowing frameworks will remain under close scrutiny. Companies should ensure internal reporting channels are robust, responsive, and aligned with best practice.

In its recent Guidance on Evaluating a Corporate Compliance Programme, the SFO referred to the six principles outlined in the Home Office’s Failure to Prevent Fraud guidance. One key principle is that organisations should regularly monitor and review their fraud detection and prevention procedures and make improvements where necessary. This includes learning from investigations and whistleblowing cases, as well as considering sector-specific insights.

As potential reforms progress – such as incentivisation for whistleblowers – organisations may need to adapt policies and training to reflect a changing legal and enforcement landscape. These developments sit alongside wider trends we have highlighted in recent commentary, including the SFO’s focus on intelligence-driven investigations, its evolving approach to corporate compliance evaluation, and its ambition to become a proactive, authoritative player in the global justice system.

Authored by Reuben Vandercruyssen and Alex Cumming.

AI tools have been used to support editing of this publication. All content has been reviewed and approved by Hogan Lovells lawyers.