UK Law and Practice Contributed by: Neil Swift, Jasvinder Nakhwal, Charlotte Tregunna and Rachel Cook, Peters & Peters
reporting. Prompt disclosure within days of discovery and meaningful co-operation thereafter are now cen - tral determinants of DPA eligibility. For individuals, DPAs are not available, but early co- operation may yield a sentence reduction. Individuals may also seek immunity or undertakings under Sec - tions 71–72 of the Serious Organised Crime and Police Act 2005 or a sentence reduction or review under Sec - tions 74 and 388 of the Sentencing Act 2020. 6.3 Self-Disclosure Procedures Self-reporting may be made directly to the relevant prosecuting or regulatory authority, typically the SFO, CPS or FCA, either by the organisation or through external legal counsel acting as intermediary. The SFO’s 2025 guidance specifies indicative time - frames: the agency aims to contact the reporting party within 48 business hours, decide on whether to open a formal investigation within six months and, where appropriate, conclude DPA discussions within a fur - ther six months. A credible self-disclosure should include: • a clear factual summary of suspected misconduct; • preservation of relevant digital and hard-copy evidence; • disclosure of non-privileged materials; and • transparent dialogue on the scope of internal investigations and potential privilege issues. Individuals making disclosures that concern wrongdo - ing in their workplace and that are in the public inter - est may qualify as statutory whistle-blowers under the Public Interest Disclosure Act 1998. 6.4 Protections Afforded to Whistle-Blowers Statutory whistle-blowers are protected under the Public Interest Disclosure Act 1998 from dismissal or any detriment arising from making a qualifying disclo - sure in the public interest. These protections extend to most workers in the public, private and voluntary sectors and continue after employment ends. Reforms under consideration in 2025 would further strengthen these safeguards. The proposed Office of
the Whistleblower Bill would create an independent oversight body to manage disclosures and enforce standards, while the forthcoming Employment Rights Bill would expand the definition of protected disclo - sures. In addition, since 1 October 2025, under Section 17 of the Victims and Prisoners Act 2024, any non-disclo - sure agreement that seeks to prevent a person from reporting suspected criminal conduct to specified authorities is void to that extent. 6.5 Incentives Provided to Whistle-Blowers As at late 2025, there is no statutory financial reward scheme for whistle-blowers in England and Wales, in contrast to the US Securities and Exchange Com - mission and Department of Justice models, although there are limited incentives for disclosure of cartels and tax evasion. However, momentum towards introducing more wide - spread financial incentives is building. The SFO Direc - tor, Nick Ephgrave, has publicly endorsed the creation of a reward-based programme as part of the agency’s 2025–26 strategy, and proposals for such a scheme are under review alongside the Office of the Whistle - blower Bill. Until legislation is enacted, whistle-blowers’ incen - tives remain non-financial, principally the statutory protections against detriment, and potential credit for co-operation where their evidence contributes to an investigation or enforcement outcome.
7. Enforcement Trends 7.1 Enforcement
Bribery and corruption offences in England and Wales are subject to criminal enforcement, with potential for civil recovery and administrative sanctions in related regulatory contexts. Criminal prosecutions are primarily brought under the BA 2010, the Fraud Act 2006 and, since September 2025, the “failure to prevent fraud” offence under the ECCTA 2023.
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