The UK government is weighing the European Union’s protection-focused whistleblowing model against the United States’ cash-for-tips approach.

By Clare Nida, Nathan Seltzer, Erin Brown Jones, Stefan Bartz, Annie Birch, and Matthew Unsworth

Should the UK do more to protect whistleblowers, or start paying them generous rewards for their information?

On 12 October 2026, the UK government opened a consultation on updating the UK whistleblowing framework (the Consultation). The Consultation acknowledges upfront that the UK’s current whistleblowing framework under the Public Interest Disclosure Act 1998 (PIDA) “may no longer work as intended” in light of a series of major UK scandals.

The government is therefore inviting views on a wide range of options for reform. Some of these options would see the UK emulate the EU Whistleblowing Directive (EUWD), which offers an enhanced level of statutory protection against retaliation for those who speak up. More radical would be the adoption of a US-style whistleblower rewards programme, administered by the Serious Fraud Office (SFO). The government may ultimately choose a combination of the EU and US approaches.

The Consultation could bring a sea change in the UK’s approach to whistleblowing, which has typically relied on conscience (rather than cash) to incentivise reporting. This article provides key takeaways from the Consultation and an in-depth comparison of whistleblowing schemes in major jurisdictions.

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