Introduction
In July 2025, the Department for Business and Trade in Great Britain published a research report (hereinafter “Report”) by Grant Thornton UK LLP (hereinafter referred to as the “reviewers”) on the effectiveness of the whistleblowing Framework within the UK.1 The Report focused on the legal, practical, and social elements of whistleblowing in the UK (hereinafter referred to as the “Framework” and cited as “WBF”). It analyzed literature and interviewed parties to determine the perceptions towards and research surrounding the Framework. Additionally, the reviewers then published a series of recommendations for improving the Framework based on its research findings (hereinafter cited as “WBF Appendices”).2 In summary, the Report found that the Framework for whistleblowers in the UK marks an important start to creating an effective cultural and legal environment for whistleblowers, but requires significant improvement, evidenced in part by the extent of the recommendations by the reviewers.
Legal Background
The Framework, as explored in the Report, consists of four pieces of legislation and a series of legal and extralegal processes. Of principal importance is the 1998 Public Interest Disclosure Act (PIDA), which outlines legal protections for whistleblowers who make qualified disclosures regarding wrongdoing.3 PIDA itself amended a 1996 law, the Employment Rights Act, and was amended in 2013 by the Enterprise and Regulatory Reform Act, building upon PIDA.4 Finally, the Small Business, Enterprise and Employment Act in 2015 created an annual reporting requirement for “prescribed persons,” or entities that are designated to receive whistleblower reports for a given sector.5 Whistleblowing in the UK is considered under the umbrella of employment law, and thus, the legal processes for protecting whistleblowers involve an employment tribunal, a government body “which makes decisions in legal disputes around employment law,” effectively functioning as a court in all but name.6
The Framework also entails numerous firm and sector-specific whistleblowing systems not outlined in legislation. These include internal whistleblowing systems within businesses and regulatory reporting requirements as dictated by sector regulators.7 While the reviewers did not analyze the merits of these systems in the Report, they were nonetheless included in discussions surrounding the efficacy of the Framework and factored into the larger consideration of the Framework’s alignment with the original intention of PIDA.
Finally, the analysis of the Framework included a discussion of the cultural aspects of whistleblowing in the UK. One of the intentions of PIDA, as outlined by the Report, was to support greater cultural recognition of the importance of whistleblowers and encourage the cultural acceptance of whistleblowing.8 Although cultural changes happen for a wide variety of reasons, many independent of legislation, PIDA still regards cultural attitudes as one of its objectives, and therefore, whistleblowing in culture was analyzed by the reviewers as well.
The Report analyzed the three original intentions of PIDA seeking the Framework to:
- Provide whistleblowers with channels to disclose wrongdoing;
- Protect whistleblowers from retaliation, and provide opportunities to seek rectification of injustices suffered for making a disclosure;
- Encourage cultural changes that are more supportive of whistleblowers and whistleblowing.9
Notably, there is no defined intention of seeking resolution of the issues raised by whistleblowers, which this paper discusses in further detail in a later section. Instead, the primary focus of the Framework is on aiding, assisting, and safeguarding whistleblowers themselves, allowing regulators to determine unilaterally and idiosyncratically their own intentions and responses to the material concerns raised by whistleblowers.
Culture
The most positive finding of the Report concerns the cultural attitudes towards whistleblowing. While there are still some cultural stigmas associated with whistleblowing, the reviewers note improvements since the passage of PIDA in 1998.10 Stereotypes surrounding whistleblowers, for example, have become less prevalent in their usage, suggesting broader cultural understanding and hints of the normalization of whistleblowing in UK workplace culture.11 Additionally, there have been an increasing number of reports from whistleblowers, and many organizations have their own whistleblowing systems (as will be explored further), also suggesting a positive cultural shift.12 However, the reviewers hesitate to attribute this cultural shift to PIDA itself, explaining that such changes could be due to a variety of factors, of which PIDA (and the Framework as a whole) is only one potential cause.13
Furthermore, employers appeared to desire a culture of integrity and recognized whistleblowers as both an important part of that workplace culture and a business advantage, as internal issues could be discovered and resolved with greater ease and rapidity with the assistance of internal whistleblower channels.14 Many employers created and used internal whistleblowing systems, the reviewers found, despite no legal requirement in the Framework to implement these systems.15
While the Report noted that there were some shortcomings in the culture for whistleblowing, such as specific instances of organizations’ cultures being hostile to whistleblowers, the general cultural trend in whistleblowing in the UK appears positive. Whether this is a direct result of PIDA, regulations, or a general societal shift, UK whistleblowing culture has improved; some of the workplace systems noted by the Report reflect this improvement.
An area left undiscussed by the Report is the cultural perception of whistleblower rewards in the UK. A report by Eliza Lockhart, a Research Fellow at the Royal United Services Institute found that whistleblower rewards are effective and would be effective in the UK.16 The HMRC has introduced a reward program for whistleblowers who provide information that leads to tax recovery in the UK.17 Nick Ephgrave, Director of the Serious Fraud Office (SFO) has also announced plans to introduce a whistleblower rewards program.18
Disclosure Channels, Employers, and Prescribed Persons
While the cultural shift described in the Report is commendable, routes for whistleblowers to raise concerns—another important aspect of whistleblowing—have been of mixed effectiveness.
As explored above, many employers have internal channels for whistleblowers to raise complaints, and are interested in hearing at least some whistleblowers’ concerns. However, as noted by the Report, the desire to do so generally does not come from an altruistic interest, but is instead “driven by regulatory requirements” or solving issues that hinder performance.19 As will be explored later, differing motives in a whistleblowing framework are cause for concern.
Another channel for disclosure can be found with Prescribed Persons (“PPs”). In essence, PPs are industry-specific government bodies, often regulators, who have been assigned as a valid recipient of whistleblowing concerns. Examples cited in the Report include HMRC, the Care Quality Commission, and the Pensions Regulator in the public administration, health, and financial services sectors, respectively.20 Notably, these three sectors—and their three PPs—have received 96% of whistleblowing disclosures.21 Further, PPs are the bodies themselves—there is no dedicated “Office of the Whistleblower,” although a bill is currently being considered which would establish an independent Office of the Whistleblower.22
Further, PPs treat whistleblower complaints as “intelligence” rather than as individual concerns.23 In other words, PPs tend to consider concerns in the context of other concerns raised. They therefore exercised broad discretion in choosing what concerns to investigate and how. The Report states that PPs “rely on the intelligence that whistleblowers provide to ensure compliance with the laws and rules in Great Britain according to their remit,” indicating the PPs were primarily factoring in whistleblowing into their general regulatory tasks, as opposed to providing an explicit investigatory body to manage whistleblower complaints.24 According to the Report, whistleblowers “Inform the strategy…for overseeing or regulating the relevant organisation,” which at times conflicted with whistleblowers’ expectations, as will be explored in a later section regarding the “expectation gap.”25
Additionally, there is variance in PPs across sectors. The Report found that PPs generally know how to handle whistleblower disclosures, but vary greatly in their methods for doing so.26
Some sectors have multiple PPs, while others have none—of note are the retail, construction, technology, and manufacturing sectors, all of which lack a PP.27 Finally, cross-sector whistleblowing complaints—disclosures that would require multiple PPs to work together—are far more difficult.28 In part, this difficulty is owed to the competing interests, motivations, and practices of each PP.29 Furthermore, the Report notes that PPs essentially have “non-existent mechanisms for coordination and collaboration.”30 Overall, this lack of coordination between PPs creates the possibility that some domestic whistleblowing complaints will be “beyond the scope of the GB framework legislation.” In other words, some corruption schemes may be too large and expansive to be properly combatted by UK whistleblowers under the current Framework. A dedicated Office of the Whistleblower would likely help align the interest of whistleblowers across sectors. With dedicated coordination procedures, this office could allow for an expanded scope of whistleblower effectiveness without revisions to the core of the Framework legislation.
Employment Tribunals
In the UK, as mentioned above, whistleblowing is considered a part of employment law. Therefore, rectifications of violations against whistleblowers are sought with the employment tribunals (ETs).31 As the name would suggest, the employment tribunals are a government body for overall employment-related grievances, to which whistleblowing was added.
ETs are akin to a legal process in resolving disputes. Seeking redress via ET was described to the reviewers as “litigious and adversarial.” The process can be expensive.32 The Report notes that “Workers often lack the necessary resources to pursue their claims in the Employment Tribunal.” Multiple whistleblowers described the ET process as financially burdensome.33 Given this burdensome nature, the Report notes that ETs can also be used tactically by the accused party—often with greater financial and legal resources than the whistleblower—to make the ET process excessively difficult or overwhelming.
Whistleblowers do not generally have any other avenues under the Framework to seek compensation for violations of their protections. The ETs, in theory, allow whistleblowers to challenge “detriment” suffered as a result of their disclosure and receive compensation. At the same time, their employer, who violated their protections, is punished.34 While the Report determined that ETs are favorable to whistleblowers in their complaints at roughly the same rate as all other fields of employment law before the ETs (38% whistleblowers; 42% average all others), other literature cited in the Report ranged from 3% to 21% whistleblower success rates in being awarded compensation.35 Therefore, the true success rate of whistleblowers in the ETs is difficult to determine.
The Report also recognized that, regardless of the compensation awarded to whistleblowers, the second purpose of the ETs (to punish employers’ wrongdoing against whistleblowers) is mostly ineffective.36 The Report notes that the size of some organizations allows them to be unaffected by ET fines or punishments. There is a general lack of enforcement and monitoring by the ET following a decision favorable to a whistleblower.37 Therefore, while the ETs can provide compensation for whistleblowers whose protections were violated, and some whistleblowers were satisfied with the process, according to the Report; they generally do not provide effective incentives for organizations to refrain from the violations in the future or address whistleblower concerns.
The substance of the whistleblower concerns is entirely outside the scope of the ETs. The concerns of the whistleblower are generally not addressed in the ET process, as the ETs serve to protect whistleblowers from retaliation, not to ensure their concerns are addressed.38 In essence, this means that a whistleblower who is repeatedly rebuffed by their employer for valid or legitimate concerns, but is not subjected to “detriment” as a result of their disclosure, will likely not have a case before the ET, and cannot request that the ET compel their employer to properly address their concerns.
Finally, given the financial and psychological costs associated with the ET, a whistleblower may be tempted to settle with their employer rather than pursue a claim. These settlements often come with a nondisclosure provision, further hampering the ability of the whistleblower to seek rectification of their initial concern.39 In essence, the expense and difficulty of the ET process, paired with the comparative ease of settling with an employer via a private agreement, result in whistleblowers’ suffering being minimized if they cease pursuing their claims.
Whistleblower Confusion and the Expectation Gap
Throughout the Report, whistleblowers expressed a general sentiment of confusion mixed with some disillusionment with regard to the Framework. The Framework, in the eyes of many whistleblowers, could at multiple points become divorced from the expectations or desires of the whistleblowers, leading to what the Report deemed an “expectation gap.”40 The expectation gap results from various elements of the Framework, as diverging definitions, methods, and motivations exist in the current Framework at different steps.
Of primary importance are definitions. Whistleblowers, employers, PPs, and the legislation all perceived the definition of a “qualifying disclosure” differently, with the legislation having the narrowest definition.41 The Report notes that both PPs and employers tended to accept broader disclosures than simply “qualifying disclosure.”42 The expectation gap is dangerous, as it can lead some whistleblowers to believe that the disclosure they would be making would be considered a qualified—and therefore protected—disclosure, and later discover that they lacked protections. This disconnect between whistleblower and legislative definitions, especially given PPs’ willingness to accept and consider non-qualifying disclosures, constituted a major cause for the expectation gap, overall contributing to whistleblowers’ hesitancy, concern, and disapproval.
Another frequent issue whistleblowers raised in the Report was a lack of consistency among PPs. As explored previously, PPs were pre-existing government bodies with their own procedures, intentions, and motivations. Therefore, there is a general lack of standardization in how different PPs from different sectors approach whistleblower complaints. This lack of consistency then translates to a lack of ability for whistleblowers to have a general expectation of all PPs, as one PP may meet expectations where another PP does not. These inconsistencies further exacerbate the expectation gap.43
Additionally, employers are inconsistent in their responses to whistleblowers’ concerns. The Report notes that employers tend to accept an even broader range of concerns, as there is a business motive to cast a wide net in order to discover as many issues hindering business performance as possible.44 This means that, similar to the expectation gap with PPs described above, whistleblowers sometimes Report concerns that they believe are qualified disclosures to employers, but are indeed not legally qualified disclosures if the dispute finds itself in the ET process.
The expectation gap creates two concerns highlighted by the Report. First, whistleblowers may be disillusioned and feel hurt or betrayed by the Framework.45 Second, and more importantly, whistleblowers may be subjected to significant professional, financial, and mental harm as a result of making disclosures that they expected to be qualified and protected, only for those disclosures not to be qualified or protected, or for those they hoped would protect them (i.e., PPs) not to do so.46
The Concern of Diverging Motives
In the United States, whistleblower award laws, such as the Dodd-Frank Act’s award provisions, allow whistleblowers to receive financial rewards of 10-30% of collected sanctions if they voluntarily provide original information that leads to a successful enforcement action.47 In essence, these laws give whistleblowers not only compensation for the anguish they may suffer but an incentive to fully cooperate with regulators and the investigation, as they do not receive payment if the prosecution fails. Similarly, regulators’ and the public’s interests are aligned, as they are benefited by sanctions against wrongdoing. Finally, whistleblowers’ attorneys who work on contingency also have an interest in successful prosecution, as a successful prosecution means sanctions are paid, meaning whistleblowers are paid, meaning their attorneys are paid. In other words, whistleblower award laws are one solution that aligns the motives of the public, regulators, whistleblowers, and their attorneys.
The UK Framework lacks such laws, and in its current form, risks dividing the motives of the parties involved. The parties to the Framework—the whistleblowers, the employers, the PPs, and the ETs—do not have an aligned motive when it comes to whistleblowing.
A whistleblower’s motive in blowing the whistle tends to be to have a concern or issue investigated and ultimately addressed. Numerous whistleblowers interviewed in the Report expressed this desire. Whistleblowers’ expectations consistently were to see the concerns they raised rectified—for example, one of the major criticisms of the Framework by whistleblowers was that, while the Framework helped them speak up, it did not make their employers listen to their concerns, much less rectify them.
An employer’s motives may sometimes align with those of the whistleblower insofar as they help solve business issues that brought down efficiency. However, the Report cites a range of literature, noting that there tends to be a lack of response by employers “if the concern implicates senior managers or executives.”48 Therefore, an employer’s motivation is only to solve whistleblower concerns if they improve the organization’s profitability or solve potential regulatory noncompliance issues.
While a diverging motive between whistleblowers and employers is a difficult and expected issue, the motivations between whistleblowers and regulators should be roughly aligned. After all, both are seeking the rectification of issues that cause harm to an organization or industry. However, whistleblowers and PPs in the current Framework diverge in how concerns are treated. Treating whistleblower concerns as pieces of broader “intelligence” best serves the regulators’ abilities to police their sectors and generally “ensure compliance with the law and rules in Great Britain,” but ultimately does not align with whistleblower interests, as their concerns may go uninvestigated.49 Especially with the absence of a mechanism that would encourage further cooperation between a whistleblower and a regulator, e.g., rewards, the expectation gap evidences a disconnect between the whistleblowers’ and PPs’ desires.
ETs are entirely concerned with protecting whistleblowers from retaliation, rather than getting the substantive issues of the concerns resolved. In fact, as explored above, the original concerns raised by the whistleblower are irrelevant to the ET, and it is not within their jurisdiction to act upon them. The purpose of the ETs reflects the general aim of the Framework—to protect whistleblowers from retaliation. The Framework and its legislation are designed to allow whistleblowers to Report wrongdoing by aiming to provide reactive protection against harm they may face (the reactive nature of which is another point of criticism by whistleblowers), rather than incentivize whistleblowers to come forward by requiring the qualified disclosures they make to be taken seriously and effectuate change. In other words, the motivation of the government is primarily to protect whistleblowers from retaliation while the motivation of the whistleblower is primarily to see the issues they raise solved. This divergence represents a major disconnect that, while not mentioned explicitly by the Report, likely is another significant factor in the expectation gap.
While the Report focuses on the current Framework, a stronger solution to this expectation gap would be the implementation of a whistleblower rewards program. Whistleblower reward programs, such as those described by Lockhart, better align the interests of whistleblowers with the interests of regulators who receive whistleblower tips, as both have a focus on remedying the violations and illegal activity taking place.
Reviewer Recommendations
In addition to the Report itself, the reviewers also made a series of recommendations in the appendices to revise the shortcomings they discovered with the Framework. Many of these recommendations demonstrate an effective understanding of the evolving landscape of whistleblowing in the UK, such as the recommendation to “Remove whistleblowing from an employment law context.”50 Although this recommendation is limited in the appendices, it would serve to rectify a significant number of issues raised by whistleblowers in the Report. For example, the ET process confused and angered many whistleblowers, and if whistleblowing were not considered as an employment matter, it would not be within the jurisdiction of the ETs to decide.
The reviewers also appeared keenly aware of the confusion caused by the current PP system. They recommended clarifying the PPs for sectors that had multiple and creating PPs for sectors that had none.51 Additionally, the reviewers recommended a more radical solution—“Create a central prescribed body” to act as a focal point for whistleblower complaints and PPs that receive whistleblower complaints.52 Furthermore, a “central prescribed body” would similarly rectify the theoretical concern of being unable to effectively address an issue that spans multiple sectors, as it would consolidate the currently-divided methods and motives of various PPs in terms of whistleblowing. Although not outright stated, a central body of this type would also help narrow the whistleblower-PP expectation gap, as there would be total consistency, given that all whistleblowing complaints would be heard by the same office. While such recommendations on their own indicate a legitimate commitment to the promotion and protection of whistleblowers, this recommendation appears to have been incorporated into a bill currently progressing through the House of Commons.53 If passed, the “Office of the Whistleblower Bill” would create an independent and central Office of the Whistleblower, similar to the recommendation by the reviewers. The next stage of the bill, its second reading, is currently scheduled for May 2026.
The reviewers further sought to close the expectation gap between whistleblowers and PPs by suggesting that PPs should be “compel[led]…to provide protection to whistleblowers,” as whistleblowers had claimed in the Report that they had generally expected PPs to provide such protection.54 Whistleblowers then were disappointed when not all PPs did so, which contributed to the expectation gap.55 The reviewers also make a series of additional recommendations regarding the expectation gap, including with the ETs. Of note is the recommendation to “Reverse the burden of proof within the proceedings,” which would “introduce a presumption of causation in Employment Tribunal claims where a protected disclosure was deemed to have been made,” which overall would ease the burden upon the whistleblower.56 Whistleblowers had complained about the burden that an ET claim places upon them, and the perceived lack of fairness contributed to the expectation gap.57
The most significant recommendations by the reviewers seek to address the diverging motives issue. The reviewers suggested that there be “Consideration of disincentives and incentives, for example implementation of a United States style reward system.”58 The reviewers cite various literature and claim that “The literature continued that other countries have not seen an increase in the frivolous and malicious reports that are cited as the primary argument against incentives.”59 In essence, the reviewers portray financial rewards and the US-style rewards system in a positive light, even referring to them as a feature that the Framework lacks, which is “considered good practice globally.”60 Despite this positive recognition of financial incentives, the reviewers stop short of recommending adoption, merely requesting that “consideration” be made.
However, like the Report, the recommendations are primarily focused on protecting whistleblowers from retaliation, rather than promoting the resolution of whistleblowers’ concerns. As such, no direct recommendation is made to shift the focus of the Framework from retaliation prevention to whistleblower promotion, as the reviewers evaluating the Framework in relation to the objectives of PIDA, not those articulated by whistleblowers.
Regarding the original intentions of PIDA, a Framework bolstered by the recommendations of the reviewers would likely create a strong and more effective whistleblower protection and anti-retaliation system. However, the Framework’s current lack of focus on ensuring that whistleblowers’ concerns are rectified, combined with the reviewers’ recommendations omitting measures that would refocus the Framework this way, indicates the continued need for improvement in the UK’s whistleblowing landscape.
Conclusion
Ultimately, while whistleblowers appeared primarily critical and skeptical, as described by the Report, the Framework does deserve some commendation. For example, the fact that many employers have adopted internal whistleblowing channels despite no requirement to do so represents an organically shifting workplace culture more supportive of whistleblowing. However, the expectation gap, the current PP system, and the ET process represent significant shortcomings that could have major implications for whistleblowing in the UK.
Primarily, the Framework’s focus on protecting whistleblowers from retaliation rather than ensuring the concerns they raise are properly resolved is cause for concern. This focus has resulted in a split between the whistleblowers, regulators, and public, which both contributes to the expectation gap and undermines the purpose of blowing the whistle overall. A possible way solution would be to focus instead on whistleblower rewards, which better align the interests of whistleblowers and regulators.
- Thornton, Grant. 2025. Understanding the Effectiveness of the Whistleblowing Framework in Great Britain. July 14. https://assets.publishing.service.gov.uk/media/6874e1a7b1b4ebc2c2e4654d/understanding-the-effectiveness-of-the-whistleblowing-framework-in-great-britain.pdf.
- Thornton, Grant. 2025. Understanding the Effectiveness of the Whistleblowing Framework in Great Britain Appendices A-K. July 14. https://assets.publishing.service.gov.uk/media/6874dde292691289bdb7d36a/appendices-a-to-k-understanding-the-effectiveness-of-the-whistleblowing-framework-in-great-britain.pdf.
- WBF at 5.
- WBF at 5.
- WBF at 5.
- HM Courts & Tribunals Service. n.d. “Employment Tribunal.” GOV.UK. Accessed August 19, 2025. https://www.gov.uk/courts-tribunals/employment-tribunal.
- WBF at 6.
- WBF at 5.
- WBF at 5.
- WBF at 116.
- WBF at 14.
- WBF at 13.
- WBF at 14.
- WBF at 111.
- WBF at 39.
- Lockhart, E. (2024). The Inside Track: The Role of Financial Rewards for Whistleblowers in the Fight Against Economic Crime. SOC ACE Research Paper No. 31. Birmingham, UK: University of Birmingham.
- HMRC Set to Launch US-Style ‘Reward Scheme’ for Whistleblowers, Cooley (May 28, 2025), https://www.cooley.com/news/insight/2025/2025-05-28-hmrc-set-to-launch-us-style-reward-scheme-for-whistleblowers.
- The UK’s New Whistleblower Reward Scheme: A Turning Point for Tax Accountability, NAVEX (April 14, 2025), https://www.navex.com/en-us/blog/article/the-uk-s-new-whistleblower-reward-scheme-a-turning-point-for-tax-accountability/.
- WBF at 111.
- WBF at 8.
- WBF at 8.
- UK Parliament. 2025. “Office of the Whistleblower Bill.” Parliamentary Bills. https://bills.parliament.uk/bills/3914.
- WBF at 57.
- WBF at 112.
- WBF at 57.
- WBF at 9.
- WBF at 8.
- WBF at 9.
- WBF at 9.
- WBF at 9.
- WBF at 87.
- WBF at 94.
- WBF at 91.
- WBF at 88.
- WBF at 89.
- WBF at 96.
- WBF at 96.
- WBF at 97.
- WBF at 99.
- WBF at 9.
- WBF at 9.
- WBF at 9.
- WBF at 68.
- WBF at 111.
- WBF at 79-80.
- WBF at 79-80.
- 15 USC § 78u-6.
- WBF at 59.
- WBF at 112.
- WBF Appendices at 6.
- WBF Appendices at 10.
- WBF Appendices at 10.
- UK Parliament. 2025. “Office of the Whistleblower Bill.” Parliamentary Bills. https://bills.parliament.uk/bills/3914.
- WBF Appendices at 19.
- WBF at 79-80.
- WBF Appendices at 23.
- WBF at 93.
- WBF at 121.
- WBF at 49.
- WBF Appendices at 30.
